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).
External Link