On December 2, 2019, the US Internal Revenue Service (the “IRS”) issued final regulations implementing the base erosion and anti-abuse tax (“BEAT”) rules. These rules impose a minimum tax on taxpayers with over $500 million of gross receipts and that make more than a de minimis amount of deductible payments to foreign affiliates. The final regulations address a significant number of comments provided to the IRS with respect to BEAT regulations originally proposed in December 2018. In addition, newly proposed regulations allow taxpayers to waive deductions to keep the amount of deductible payments that they make to foreign affiliates below the de minimis threshold and thereby avoid the imposition of the BEAT. The attached Legal Update, prepared by Mark Leeds and Lucas Giardelli, explores the final regulations and the proposed rules for deduction waivers.
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