Department of the Treasury December 6, 2019 – Federal Register Recent Federal Regulation Documents

Additional Rules Regarding Base Erosion and Anti-Abuse Tax
Document Number: 2019-25745
Type: Proposed Rule
Date: 2019-12-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations that provide guidance regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The proposed regulations would affect corporations with substantial gross receipts that make payments to foreign related parties.
Base Erosion and Anti-Abuse Tax
Document Number: 2019-25744
Type: Rule
Date: 2019-12-06
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations implementing the base erosion and anti-abuse tax, designed to prevent the reduction of tax liability by certain large corporate taxpayers through certain payments made to foreign related parties and certain tax credits. These final regulations also provide reporting requirements related to this tax. This tax was added to the Internal Revenue Code (the ``Code'') as part of the Tax Cuts and Jobs Act. This document finalizes the proposed regulations published on December 21, 2018. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties. The final regulations also affect any reporting corporations required to furnish information relating to certain related-party transactions and information relating to a trade or business conducted within the United States by a foreign corporation.
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