Page 203 - International Taxation IRS Training Guides

BEAT Payments

 Base erosion payments
are:

amount paid by the taxpayer to a foreign related person for which a
• Any
deduction is allowable

• Any
amount paid by the taxpayer to a foreign related person for the

acquisition of depreciable or amortizable property
• Reinsurance payments made to a foreign related person

sold paid to certain inverted corporations or to a member of the
• Cost of goods
same expanded affiliated group as an inverted corporation

any base erosion payment, a base erosion tax benefit
• For
is:

• A deduction that is
allowed in the taxable year, including for depreciation or
amortization

• A reinsurance payment that either reduces premiums arising out of indemnity

insurance or reduces premiums paid on reinsurance

• A reduction to gross receipts for cost of goods sold to a inverted corporation

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