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In brief

In December 2019, the Treasury and the Internal Revenue Service (IRS) published final and proposed regulations implementing the base erosion and anti-abuse tax (BEAT) (“2019 Final Regulations” and “2019 Proposed Regulations,” respectively). On 8 October 2020, the Treasury and the IRS published final regulations (“2020 Final Regulations“) that address the following aspects of the BEAT: determining the taxpayer’s aggregate group; electing to waive deductions for BEAT purposes; applying the BEAT to partnerships; and applying the anti-abuse rule to basis step-up transactions.


The 2020 Final Regulations retain the approach of the 2019 Proposed Regulations with a few key changes and they modify certain portions of the 2019 Final Regulations.

Read the full alert in the North America Tax News and Development Newsletter.