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U.S. IRS Publishes Draft Instructions for Forms on Base Erosion Minimum Tax and GILTI and FDII Deduction

22 October 2018

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Approved Changes

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United States

The U.S. IRS has published the draft version of the Instructions for Form 8991, Tax on Base Erosion Payments of Taxpayers with Substantial Gross Receipts. Form 8991 is used to determine an applicable taxpayer’s tax on its base erosion minimum tax (BEAT) amount for the year under section 59A as introduced by the Tax Cuts and Jobs Act (TCJA). Applicable taxpayers are those that meet the following three criteria: The taxpayer is a corporation other than a regulated investment company, a real estate investment trust, or an S corporation; The taxpayer has average annual gross receipts for the 3-tax-year period...