Αποτελέσματα Αναζήτησης
There is hereby imposed on each applicable taxpayer for any taxable year a tax equal to the base erosion minimum tax amount for the taxable year. Such tax shall be in addition to any other tax imposed by this subtitle.
IRC 59A was added to the Internal Revenue Code by section 14401 of P.L. 115- 97 (the Tax Cuts and Jobs Act (“TCJA”)) on December 22, 2017, and imposes a new tax often referred to as the Base Erosion Anti -Abuse Tax (“BEAT”).
The Tax Cuts and Jobs Act of 2017 (P.L. 115-97) added new section 59A (Tax on Base Erosion Payments of Taxpayers with Substantial Gross Receipts), which applies to large corporations that have the ability to reduce U.S. tax liabilities by making deductible payments to foreign related parties.
1 Μαΐ 2018 · New Sec. 59A, enacted by the law known as the Tax Cuts and Jobs Act, P.L. 115 - 97, imposes a base - erosion and anti - avoidance tax (BEAT) on certain corporations making payments to related foreign persons.
Sec. 59A. Tax On Base Erosion Payments Of Taxpayers With Substantial Gross Receipts. Bloomberg Tax offers full-text of the current Internal Revenue Code free of charge.
3 Σεπ 2020 · Treasury and the IRS, on September 1, released final regulations (the Final Regulations) under Section 59A (‘the base erosion and anti-avoidance tax’ or ‘BEAT’). BEAT, which requires certain US corporations to pay a minimum tax associated with, broadly speaking, deductible payments to non-US related parties, was enacted by the 2017 tax reform act.
In the case of a taxpayer which is a foreign person, the preceding sentence shall not apply to the gross receipts of any United States person which are aggregated with the taxpayer’s gross receipts by reason of paragraph (3).
