On September 1, 2020, the US Internal Revenue Service issued final regulations providing additional guidance on the base erosion and anti-abuse tax (BEAT).
To limit profit-shifting, the Tax Cuts and Jobs Act added a new tax, the BEAT. The BEAT focuses on large US 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.
See Final Regulations