Description
Gain valuable insight into the Base Erosion and AntiAbuse Tax regulations.This topic will provide an overview of the key aspects of the base erosion and antiabuse tax (the BEAT) contained in section 59A of the Internal Revenue Code of 1986, as amended, along with strategies for mitigating the impacts of the BEAT. Following the information, you will be able to identify potential BEAT issues in your organization and how to begin the process of developing response strategies.
Date: 2019-12-18 Start Time: End Time:
Learning Objectives
Overview of the Base Erosion and Anti-Abuse Tax (the BEAT)
• Applicable Taxpayer
• Related Party
• Base Erosion Payments
• Base Erosion Percentage
• Base Erosion Minimum Tax Amount
• Modified Taxable Income
• Application to Partnerships
• Expatriate Entities (Inversions)
• Anti-Abuse Rules
Update on Final BEAT Regulations (If Released)
Strategies for Managing the BEAT
• Intercompany Debt Structures
• Intercompany Services Structures
• Intercompany Royalty Structures
• Intercompany Reinsurance Structures
• M&A Considerations
Robert C. Stevenson-Skadden, Arps, Slate, Meagher & Flom LLP
