Page 16 - Large Business IRS Training Guides

General
Overview (cont’d)

• BEAT is a minimum tax amount imposed on

applicable taxpayers that make certain base

erosion payments (“BEPs”) to foreign

related parties (“FRPs”)

tax separate from regular income tax
• Additional

• Different from the old alternative minimum tax

(“AMT”); for instance, it is computed differently

than AMT and any base erosion minimum tax
amount (“BEMTA”) paid is not credited against

future taxes

• Generally targets deductions
arising from
transactions with foreign related parties

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