IRS Issues a Package of Proposed, Final Tax Regulations

In a move long awaited by taxpaying firms with international operations, the Internal Revenue Service and the Treasury Department late Monday issued a series of proposed and final regulations related to the base erosion and anti-abuse tax, or BEAT, and the operation of the foreign tax credit as required by the 2017 tax reform law.

The more than 1,000 pages of proposed and final regulations address—among other things—calculation mechanics, related party transactions, definitions of base erosion payments, total loss absorbing capacity definitions, allocations of research and development expenses, and foreign tax credit allocations and calculations. The American Bankers Association is in the process of reviewing the regulations and invites members to submit feedback to inform a possible comment letter.

View the proposed BEAT regulations.
View the final BEAT regulations.
View the proposed foreign tax credit regulations.
View the final foreign tax credit regulations.