On December 2, 2019, the Internal Revenue Service and the Treasury Department issued final regulations and proposed regulations on the base erosion and anti-abuse tax. As discussed below, the final regulations adopt the general framework and many of the provisions set forth in proposed regulations that were published on December 21, 2018 in the Federal Register, with certain modifications. The new proposed regulations propose a few additional modifications including, most significantly, an election to waive deductions for all tax purposes to avoid the threshold for BEAT application.