Page 216 - Large Business IRS Training Guides

International Considerations

• Interaction of IRC § 163(j) with the

Base Erosion Anti-Abuse Tax (BEAT)

under IRC § 59A

• Application of IRC § 163(j) to foreign

persons with effectively connected

income (ECI)

• Application of IRC § 163(j) to controlled

foreign corporations (CFCs) and

United States shareholders

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