What US Internal Revenue Code Section 59A - Base Erosion and Anti-Abuse Tax (BEAT): Base Erosion Percentage Test, Applicable Taxpayers (>$500M Revenue) and Modified Taxable Income Calculation requires
Under IRC § 59A, U.S. corporations and foreign corporations with U.S. branches that are part of a group with average annual gross receipts of at least $500 million must pay a minimum tax if their 'base erosion percentage' is 3% or higher (2% for certain banks/securities dealers), targeting deductible payments made to foreign related parties.
Pillar: Banking & Global Finance · Authority: United States Internal Revenue Service (IRS) · Version: 1.0.0 · Last updated:
Primary source: https://www.irs.gov/forms-pubs/about-form-8991
SHA-256 integrity: 3304c79bc4fb9db2caf1a339edc1fadf197739fe3e273f4c97bfd30a082f4421
Primary Citations — 7 traced to source
- 26 U.S. Code § 59A(a) - Imposition of tax
- 26 U.S. Code § 59A(b) - Base erosion minimum tax amount
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