![]() This new base erosion and anti-abuse tax, colloquially known as “BEAT,” involves complex modified tax computations however, what may be even more difficult for many taxpayers is ascertaining whether they are subject to the BEAT. In an effort to reduce interpretive latitude on the part of taxpayers and resolve several unanswered questions, the IRS released a 193-page proposed regulation set on December 13, 2018. ![]() income tax liabilities by making tax-deductible payments to a foreign parent or foreign related parties, Congress enacted Internal Revenue Code (IRC) Section 59A-tax on base erosion payments of taxpayers with substantial gross receipts-in connection with the Tax Cuts and Jobs Act. Inspired in part by congressional concern that foreign-owned U.S.
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