The U.S. IRS has published a practice unit, IRC 59A Base Erosion Anti-Abuse Tax Overview. The general overview of the practice unit includes the following:
IRC 59A was added to the Internal Revenue Code by section 14401 of P.L. 115-97 (the Tax Cuts and Jobs Act ("TCJA")) on December 22, 2017, and imposes a new tax often referred to as the Base Erosion Anti-Abuse Tax ("BEAT"). Proposed regulations ("Prop. Treas. Regs.") were published in the Federal Register on December 21, 2018 (26 CFR Part…