Legal Alert: BEAT, FATCA and Insurance—proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under FATCA
On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations under section 59A of the Internal Revenue Code of 1986, as amended (Code), commonly referred to as the base-erosion anti-abuse tax (BEAT). The other set of proposed regulations amended the Foreign Account Tax Compliance Act (FATCA) regulations that apply to sections 1441-1446 of the Code.