📈New IRS Regulations on Base Erosion Tax and Derivative Payments
Base Erosion and Anti-Abuse Tax Rules for Qualified Derivative Payments on Securities Lending Transactions
Summary
This document contains proposed regulations regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The proposed regulations relate to how qualified derivative payments with respect to securities lending transactions are determined and reported. The proposed regulations would affect corporations with substantial gross receipts that make payments to foreign related parties.
Agencies
- Treasury Department
- Internal Revenue Service
Business Impact
$$ - Med
This regulatory text outlines new proposed regulations concerning the Base Erosion and Anti-Abuse Tax (BEAT), specifically focusing on Qualified Derivative Payments related to securities lending. Corporations with substantial gross receipts engaging with foreign related parties must comply with revised reporting requirements by 2027. Non-compliance could lead to increased tax liabilities.