IRS Issues Proposed Regulations on BEAT: The Proposed BEAT Regulations Provide New Guidance on Significant Aspects of BEAT That Were Not Addressed in the Statute, but Leave Some Questions Unanswered

Sullivan & Cromwell LLP - December 21, 2018

On December 13, 2018, the Internal Revenue Service and the Treasury Department issued proposed regulations (the “Proposed Regulations”) on the base erosion and anti-abuse tax (“BEAT”).  As discussed in this memorandum, the Proposed Regulations would clarify some of the key aspects of the BEAT regime, but also include a number of surprises and do not provide specific rules on other issues that could have a critical impact on a taxpayer’s ultimate BEAT liability.