To limit profit-shifting, the Tax Cuts and Jobs Act (TCJA) added a new tax, the BEAT. The BEAT focuses on large U.S. corporations that make deductible payments to related foreign parties.
The final regulations provide detailed guidance regarding how to compute certain BEAT calculations for groups of related taxpayers.
The final regulations also contain rules permitting taxpayers to waive deductions for purposes of the BEAT, and additional guidance regarding partnerships and anti-abuse rules.
Updates on the implementation of the TCJA can be found on the Tax Reform page of IRS.gov.
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