Page 34 - Large Business IRS Training Guides
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BEP – QDP
                                                                 Exception (cont’d) 1










               QDP Exception  is  not available to –




                      •	  Taxpayer
                                              that fails to satisfy reporting

                           requirements

                                               that would be treated as a BEP if it
                      •	  Payments

                           were not made pursuant to a derivative,

                           including any interest, royalty, or service

                           payment, or


                      •	  In the case of a contract that has derivative and


                           non-derivative components, that portion of the

                                                              allocable to the non-derivative
                           payment properly
                           component







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