Page 26 - Large Business IRS Training Guides

BEP – Operating Rules

• Amount paid or accrued includes
any form of
including cash, property, stock or
consideration,

assumption of liability

• Amount of BEP is determined on a gross basis; i.e., no

netting allowed, except as otherwise permitted by the

Code or regulations and an MTM rule (discussed further

below)

• Contractual
or legal rights to make or receive payments on
a net basis not relevant

will
• Payments to certain domestic passthrough entities
be treated as made to foreign related parties
that are

beneficiaries or
shareholders of the entities

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