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Today, Treasury released Final Regulations and Proposed Regulations under Section 59A (‘the base erosion and anti-avoidance tax' or ‘BEAT’). BEAT, which requires certain US corporations to pay a minimum tax associated with deductible payments to non-US related parties, was enacted by the 2017 tax reform act. Treasury previously released proposed regulations under Section 59A on December 13, 2018 (published December 21, 2018 in the Federal Register).

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