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Proposed regulations on “BEAT” released to Federal Register

Proposed regulations on “BEAT” released

The U.S. Treasury Department and IRS this afternoon released for publication in the Federal Register proposed regulations (REG-104259-18) relating to section 59A—the “base erosion and anti-abuse tax” (BEAT)—as enacted by the new U.S. tax law (Pub. L. No. 115-97).


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Read the proposed regulations [PDF 860 KB] (183 pages) concerning the BEAT as released in advance of publication in the Federal Register. The proposed regulations as published in the Federal Register on December 21, 2018, are 42 pages; read that version of the proposed regulations [PDF 397 KB]. Accordingly, comments and requests for a public hearing must be received by a date that is 60 days after December 21, 2018.

Read a KPMG report providing analysis and observations about the BEAT proposed regulations: TaxNewsFlash [PDF 325 KB]

Advance version of proposed regulations

The IRS on December 13, 2018, released a version of these proposed regulations, and with that release, noted that the proposed regulations had been submitted to the Federal Register for publication; that such publication was pending; and that the version of the proposed regulations released on December 13 “… may vary slightly from the published document if minor editorial changes are made during the [Federal Register] review process. The document published in the Federal Register will be the official document.”

Read a computer-generated document [PDF 4.1 MB] (an unofficial document produced by KPMG) that compares the 193-page version of the proposed regulations that was submitted to the Federal Register for publication (released on December 13, 2018), with the 183-page version of the proposed regulations released for publication in the Federal Register (released on December 17, 2018).

This document is intended to show what changes, if any, have been made to the proposed regulations prior to publication in the Federal Register. It has not been reviewed for accuracy.  


Legend: Omitted text is shown as stricken, new text is indicated by the blue highlight, and replaced text is highlighted in orange.

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