The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Corporations that elect to file a single consolidated tax return must take into consideration the effect of the Tax Cuts and Jobs Act’s base erosion and antiabuse tax. Under section 59A, the BEAT is imposed on corporations having substantial gross receipts that make base erosion payments, or payments to foreign related parties. New proposed regulations (REG-104259-18) address how the BEAT applies to these consolidated groups.
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