The U.S. Treasury Department and IRS earlier today, December 2, 2019, released for publication in the Federal Register final regulations (T.D. 9885) and additional proposed regulations (REG-112607-19) under section 59A—the Code provision referred to as “BEAT” (the base erosion and anti-abuse tax) as enacted as part of the 2017 U.S. tax law (Pub. L. No. 115-97, enacted December 22, 2017, and often referred to as the “Tax Cuts and Jobs Act”).
This report provides early impressions and observations about these regulations and does not cover in detail provisions relating to partnerships, insurance, qualified derivative payments (QDPs), or consolidated returns. A more detailed report on these regulations will be provided in a future edition of TaxNewsFlash.
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CFC = controlled foreign corporation
PFIC = passive foreign investment company
GILTI = global intangible low-taxed income
ECI = effectively connected income
TLAC = total loss-absorbing capacity
AMT = alternative minimum tax
MTI = modified taxable income
BEMTA = base erosion minimum tax amount
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