Final regulations pending OIRA review: “BEAT” provisions under section 59A

“BEAT” provisions under section 59A

OMB’s Office of Information and Regulatory Affairs (OIRA) reported that it has received for review from the U.S. Treasury Department final regulations under section 59A—the “base erosion and anti-abuse tax” or “BEAT” provisions that were enacted as part of the 2017 tax law (Pub. L. No. 115-97), the law that is often referred to as the “Tax Cuts and Jobs Act” (TCJA).


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Treasury regulations that are identified as “major” regulations are subject to review by OMB’s OIRA before being issued, pursuant to Executive Order 13771.

OIRA reported that it received the following final regulations for review on August 3, 2020:

  • RIN: 1545-BP36: Base erosion and anti-abuse tax proposed regulations [TCJA]

OIRA has further described the regulations, as follows:

These regulations provide guidance under section 59A regarding the base erosion and anti-abuse tax.

Final and additional proposed regulations under section 59A were released in December 2019. Read KPMG’s report about these regulations under the BEAT provisions: KPMG report: Analysis of final regulations and additional proposed regulations under section 59A (“BEAT”) [PDF 798 KB] (39 pages)

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