In a letter to Treasury Secretary Steven Mnuchin dated 4 April 2019, U.S Senator Thom Tillis (R-NC) has requested that an exception be included in the final Base Erosion and Anti-Abuse Tax (BEAT) regulations for payments made by U.S. manufacturers to foreign affiliates for services. In particular, the exception is requested in cases where such affiliates are providing services in connection with the manufacturers' obligations under customer service agreements. According to Senator Tillis, when the Tax Cuts and Jobs Act was passed, it was not the intent of Congress that U.S. manufacturers providing services to unrelated customers outside the U.S....