Analysis

Lack Of Noncash Exceptions In BEAT Rules Has Wide Scope

Law360 (December 18, 2018, 8:32 PM EST) -- Proposed base erosion and anti-abuse tax regulations provide U.S. multinationals with much-needed answers to calculation questions, but the inclusion of noncash transactions without any exceptions — including when there aren’t recognized gains or losses — could take companies by surprise.

The U.S. Treasury has floated rules to clarify that noncash transactions, such as a transfer of property, may fall under the base erosion and anti-abuse tax. (AP) Enacted as part of the Tax Cuts and Jobs Act in December 2017, the base erosion and anti-abuse tax, or BEAT, limits deductions on payments by a U.S. corporate entity to related parties abroad...

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