The US Treasury and the IRS on September 1 released final regulations (Final Regulations) under Section 59A (the base erosion and anti-abuse tax or BEAT). These regulations finalize proposed regulations published in the Federal Register on December 6, 2019. The final regulations retain the basic approach and structure of the proposed regulations. Important for the insurance industry is the treatment of reinsurance premiums paid as deductions for purposes of the waiver election.
The Final Regulations are effective 60 days after the date of publication in the Federal Register, but they contain rules for retroactive application.