Strategizing International Tax Best Practices – by Keith Brockman

BEAT Regs: One-way street

The IRS and Treasury have released Final Regulations (T.D. 9910) on base erosion and anti-abuse tax (BEAT), with a controversial provision of not allowing the ability to decrease previously waived deductions on an amended return or during an exam.

The Regulations, however, do provide the benefit to waive deductions to avoid BEAT.

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