TEI Files Supplemental Comments on Proposed BEAT Regulations

On August 12, 2019, TEI filed comments with the United States Department of the Treasury and Internal Revenue Service regarding proposed regulations issued under section 59A. New section 59A, added to the Internal Revenue Code by the Tax Cuts & Jobs Act (TCJA), imposes a new tax on taxpayers with excess “base eroding” payments (the BEAT). The Institute’s comments support an alternative method for calculating a taxpayer’s BEAT liability – the “proxy-method” – which would permit taxpayers to maintain the full benefit of any pre-TCJA net operating losses.

TEI’s comments were prepared under the aegis of the Institute’s Tax Reform Task Force and U.S. International Tax Committee. Benjamin Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s submission.

Download the letter.