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Final BEAT Regulations Contain Promise and Pitfalls for Taxpayers

By Kat Gregor, Isabelle Farrar & Stefan Herlitz on November 13, 2020
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On September 3, the Department of the Treasury issued final regulations regarding the base erosion and anti-abuse tax (“BEAT”) imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties.[1] The final regulations provide guidance on a number of areas, an important section of the regulations pertains to the election to waive deductions for purposes of the BEAT.

In this article, we will outline the reasons for, and the mechanics of, this election, as well as how this election, while a taxpayer-friendly inclusion in the regulations, can come at a significant cost for taxpayers. Additionally, the final regulations contained a relaxed anti-abuse provision that makes the effects of the anti-abuse provision less dramatic.

Please click here to read the full article.

Photo of Kat Gregor Kat Gregor
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Photo of Isabelle Farrar Isabelle Farrar
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Photo of Stefan Herlitz Stefan Herlitz
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  • Posted in:
    Financial, Tax
  • Blog:
    Disputing Tax
  • Organization:
    Ropes & Gray
  • Article: View Original Source

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