The Resource Can't find the BEAT : the interaction of the new base erosion rules with a foreign bank's branch interest deduction

Can't find the BEAT : the interaction of the new base erosion rules with a foreign bank's branch interest deduction

Label
Can't find the BEAT : the interaction of the new base erosion rules with a foreign bank's branch interest deduction
Title
Can't find the BEAT : the interaction of the new base erosion rules with a foreign bank's branch interest deduction
Creator
Subject
Language
  • eng
  • eng
Summary
The 2017 Tax Cuts and Jobs Act (TCJA) (P.L. 115-97, 22 December 2017) added the base erosion anti-abuse tax (BEAT). The BEAT applies to a foreign bank's interest expense deduction to the extent that such interest is treated as paid or accrued to a foreign related party. The author of this article expresses uncertainty about to what extent interest expense allocated to the foreign bank's U.S. trade or business under Treasury Regulations or an applicable treaty should be treated as paid or accrued to a foreign related party for purposes of the BEAT
Citation source
In: Journal of international taxation. - New York. - Vol. 29 (2018), no. 3 ; p. 30-39
http://library.link/vocab/creatorName
  • Villano, G
  • Leeds, M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • interest deduction
  • foreign bank
  • base erosion
  • anti-avoidance
  • BEAT
  • AOA
Label
Can't find the BEAT : the interaction of the new base erosion rules with a foreign bank's branch interest deduction
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2018/J/JOUROFINT/3_30-39.pdf
Publication
Note
20180404

Library Locations

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