Page 17 - Large Business IRS Training Guides

Applicable Taxpayer

means a taxpayer, with respect
• Applicable Taxpayer

taxable year,
to any

than a RIC, REIT, or S-
1) that is a corporation (other
corporation),

2) that has average annual gross receipts for the 3­

taxable-year period ending with the preceding taxable

year of at least $500 million, and

base erosion percentage (“BE%”) of 3%
3) that has

(2% for
bank or registered securities dealer)
for the taxable year
(discussed further below) or higher

• Gross
receipts and base erosion percentage are
tested at the aggregate group level
(discussed below)

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