Page 25 - Large Business IRS Training Guides
P. 25

BEP / ETB (cont’d)







                                   BEP                                                              BETB



                premium or other consideration
                                                                                  reduction in the gross amount of
        Any                                                               Any
                                                                                           or other consideration or any
                                                       any
        paid or accrued to a FRP for                                      premiums
        reinsurance payments                                              deduction from
                                             taken into
                                                                                                   the amount of gross
        account under section 803(a)(1)(B)                       or       premium

                                                                                         related to the BEP
        832(b)(4)(A)


                                                                                                         receipts for the
        Reductions                                                        Reduction to gross
                           in gross receipts from
                                                                                               with respect to the BEP
                                   accrued to –
        amounts paid or                                                   taxable year
        •  a corporation that
                                          is a surrogate
                                                       after
             foreign corporation (SFC)
             11/9/2017; or

        •  a foreign corporation that
                                                      is a
                               the same extended
             member of
             affiliated group as
                                          an SFC


                    •  See discussions
                                                   below for additional rules, including exceptions

                                                                                                                                     23
   20   21   22   23   24   25   26   27   28   29   30