Page 30 - Large Business IRS Training Guides
P. 30
BEP – Exceptions (cont’d)
to BEPs –
Exceptions
• Amounts
paid or accrued to a foreign insurance
company
electing to be treated as a domestic
corporation under section 953(d)
• Exchange loss on a section 988 transaction
• Amounts
paid or accrued with respect to total loss
securities (discussed
absorbing capacity (“TLAC”)
further below)
• Section 163(j)(2)
disallowed business interest carried
forward from taxable years beginning before January 1,
2018
28
