Executive summaryOn 2 September 2020, the United States (US) Treasury Department and the Internal Revenue Service (IRS) released final regulations (T.D. 9910) on the base erosion anti-abuse tax (BEAT) under Internal Revenue Code1 Section 59A (2020 final BEAT regulations). The regulations finalize proposed BEAT regulations that were issued on 2 December 2019 (2019 proposed BEAT regulations), and revise certain final BEAT regulations issued on the same date (2019 final BEAT regulations).2 More specifically, the 2020 final BEAT regulations generally adopt the aggregate group rules, the election to waive deductions and the partnership rules of the 2019 proposed BEAT regulations. The 2020 final...