Page 29 - Large Business IRS Training Guides

BEP – Exceptions

Exceptions
to BEPs –

• Amounts paid or accrued in taxable years beginning

aggregate
before January 1, 2018 (subject to special
group rules)

• Certain payments
for services (services cost method or
SCM exception, discussed further below)

(QDP exception, discussed
• Qualified derivative payments

further below)

paid or accrued to a FRP that are subject to tax
• Amounts

as income that is
ECI and for which a withholding
certificate claiming ECI withholding exemption under

section 1441 or
1442 (or, if a treaty applies, amounts
taken into account in determining the FRP’s net taxable

income) has
been obtained from the FRP

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