Today, Treasury released Final Regulations and Proposed Regulations under Section 59A (‘the base erosion and anti-avoidance tax or ‘BEAT’). BEAT, which requires certain US corporations to pay a minimum tax associated with deductible payments to non-US related parties, was enacted by the 2017 tax reform act. Treasury previously released proposed regulations under Section 59A on December 13, 2018 (published December 21, 2018 in the Federal Register).
The final regulations contain 217 pages of preamble language and 125 pages of regulatory text, including 35 examples. The final regulations are effective on December 6, 2019. The proposed regulations contain 43 pages of preamble language and 16 pages of regulatory text, including 4 examples. Public comments are due by February 4, 2019 for the proposed regulations.
PwC will publish a detailed analysis of the final and proposed regulations within the coming days. In addition, we will discuss the latest BEAT guidance in a Tax Readiness Series webcast (registration coming soon).
PwC Tax Insight: Treasury issues proposed BEAT rules
PwC Tax Insight: Preliminary highlights of the proposed BEAT regulations