April 21, 2020
Revisiting Base Erosion and Anti-Abuse tax (“BEAT”, Section 59A) Post-Pandemic: Final and Proposed Regulations are Worth a Second Look
Considering recent economic developments and the CARES Act, it is worth revisiting BEAT, specifically the regulations issued in 2019. Back on December 2, 2019, the IRS issued long-awaited final and proposed BEAT regulations, following on proposed BEAT regulations published on December 21, 2018. The final and proposed regulations maintain the basic approach of the proposed regulations with a few, generally taxpayer-friendly, changes. In this post, GTM’s Brian Abbey discusses some of the key highlights.