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IRC 59A Base Erosion Anti-Abuse Tax Overview BEAT applies to base erosion payments (“BEPs”) paid or accrued in taxable years beginning after December 31, 2017 BEAT is a corporate minimum tax imposed on applicable taxpayers that make certain base erosion payments to foreign related parties (“FRPs”)
BEAT considerations for foreign corporations with US branches If a payment is imputed between the US PE and FC’s home office, and that payment would be a base erosion payment if it was a payment between two corporations, then a BEAT liability may arise even in cases where no actual payment was made
How to Calculate BEAT Tax Sometimes referred to as a new alternative minimum tax, when it applies, BEAT increases tax liability for U S corporations and U S branches of non-U S corporations
BEAT Explained: Who’s Affected and What’s Next? To be subject to BEAT, all three requirements previously stated must apply The final requirement for the applicable taxpayer is the beginning position to calculate BEAT
How Does BEAT Apply to Inbound Companies? - KPMG The new base erosion and anti-abuse tax (“BEAT”) may be imposed on U S subsidiaries and branches of foreign companies This article considers how related companies will be aggregated to determine whether the BEAT applies and cautions about new related reporting requirements
Redefining BEAT: What multinationals should know Passed in mid-May by the U S House of Representatives, the bill proposes to transform the base erosion and anti-abuse tax (BEAT) into “Super BEAT,” via proposed section 899—vastly expanding its reach to include many U S and foreign corporations, regardless of size or prior exemptions
What is the TCJA base erosion and anti-abuse tax and how does it work? The BEAT targets large US corporations (including US affiliates of foreign multinational corporations) that make deductible payments, such as interest, royalties, and certain service payments, to related foreign parties
“BEAT” Again- The New BEAT Tax Regime Considerations and Compliance . . . In other words, BEAT applies to corporations (other than RICs, REITs, or S corporations) with gross receipts of at least $500 million over a three-year testing period and a “base erosion percentage” ( as defined in Section 59A (c) (4) (A)) for the taxable year of at least 3 percent
Base Erosion and Anti Abuse Tax: BEAT: BEAT the System: Strategies for . . . If these payments significantly reduce the corporation's U S Taxable income, BEAT may apply, resulting in a minimum tax liability that could negate the tax benefits of the cross-border payment structure BEAT is a complex tax provision with far-reaching implications for multinational corporations