BEAT Regulations submitted to OMB
The IRS has submitted its proposed base erosion and anti-abuse tax (BEAT) regulations to the U.S. Office of Management and Budget for review. Under section 59A of the Tax Cuts and Jobs Act (TCJA), the BEAT is an alternative minimum tax on income with deductions for payments between U.S. corporations and their foreign affiliates added back, which is designed to limit shifting of corporate income overseas through intangible property transfers. The regulations are expected to provide guidance on certain exclusions applicable to BEAT calculations, including the cost of goods sold exception and services cost method exception. The review is expected to be completed within 45 days, although certain regulations implementing the TCJA may be designated for a 10-business day expedited evaluation.
Read More: Proposed BEAT Regs Sent to OIRA (paywall)