Page 204 - International Taxation IRS Training Guides

BEAT Payments
Exceptions to

 Exceptions
to payments subject to BEAT generally
include:

of the service (not including any markup) for service
• Cost
that qualify for the services cost method
payments

• Certain qualified derivative payments

• Payments
to a US branch of a related foreign person to the
extent
treated as effectively connected income

• Exchange loss
with respect to foreign currency

59