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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