Final regulations released to Federal Register: BEAT provisions under section 59A

BEAT provisions under section 59A

The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations (T.D. 9910) as guidance 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.

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The final regulations [PDF 384 KB] (24 pages as published in the Federal Register on October 9, 2020) concern measures enacted by the 2017 U.S. tax law (Pub. L. No. 115-97) or the law that is often referred to as the “Tax Cuts and Jobs Act” (TCJA), and provide guidance under sections 59A, 1502, and 6031 regarding certain aspects of the BEAT.

Read a KPMG report—based on the version of the final regulations posted September 1, 2020, on the IRS website—providing initial impressions and observations about the 2020 final regulations. Read TaxNewsFlash [PDF 235 KB]

Comparison against advance version of final regulations

The IRS on September 1, 2020, posted a version of these final regulations on its website. That version of the final regulations includes the following statement:

This document has been submitted to the Office of the Federal Register (OFR) for publication and will be pending placement on public display at the OFR and publication in the Federal Register. The version of the final regulations released today may vary slightly from the published document if minor editorial changes are made during the OFR review process. The document published in the Federal Register will be the official document.

Read a computer-generated document [PDF 1 MB] that provides a comparison of the version of the final regulations submitted today to the Federal Register against the version posted by the IRS on September 1, 2020. This unofficial document was produced by KPMG for the purpose of showing what changes, if any, were made to the regulations prior to being released to the Federal Register for publication. It has not been reviewed for accuracy.

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