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Section 59A Base Erosion and Anti-Abuse Tax

Gain valuable insight into the Base Erosion and Anti-Abuse Tax regulations.

This topic will provide an overview of the key aspects of the base erosion and anti-abuse tax (the BEAT) contained in section 59A of the Internal Revenue Code of 1986, as amended, along with strategies for mitigating the impacts of the BEAT. Following the information, you will be able to identify potential BEAT issues in your organization and how to begin the process of developing response strategies.

Runtime: 107 minutes
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Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of the Base Erosion and Anti-Abuse Tax (the BEAT)

  • Applicable Taxpayer
  • Related Party
  • Base Erosion Payments
  • Base Erosion Percentage
  • Base Erosion Minimum Tax Amount
  • Modified Taxable Income
  • Application to Partnerships
  • Expatriate Entities (Inversions)
  • Anti-Abuse Rules

Update on Final BEAT Regulations (If Released)

Strategies for Managing the BEAT

  • Intercompany Debt Structures
  • Intercompany Services Structures
  • Intercompany Royalty Structures
  • Intercompany Reinsurance Structures
  • M&A Considerations
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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

This course was last revised on December 18, 2019.

Call 1-866-352-9540 for further credit information.

  • Enrolled Agents 2.0
     
  • This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.75
     
  • NJ CLE 2.0
     
  • NV CLE 1.5
     
  • NY CLE 2.0 including Areas of Professional Practice 2
     
  • VT CLE 1.5
     
  • WA CLE 1.75
     
  • WV MCLE 2.0
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 33 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Robert C. Stevenson

Robert C. Stevenson

Skadden, Arps, Slate, Meagher & Flom LLP

  • Senior associate in the Washington, DC office of Skadden, Arps, Slate, Meagher & Flom LLP
  • Adjunct professor teaching on corporate taxation at Howard University School of Law
  • Advises both U.S. and international clients on a broad range of tax transactional, planning and controversy matters, which frequently include an international tax component, such as cross-border acquisitions and joint ventures, post-acquisition integration and restructuring transactions, public and private company mergers and acquisitions, capital market offerings, spin-offs and “Morris Trust” transactions, and subpart F and tax reform planning
  • Also frequently advises clients in the financial services sector on insurance-related corporate transactions, including insurance company mergers and acquisitions, reinsurance transactions, restructurings and related matters
  • Recent publications on international taxation include Moshe Spinowitz and Robert C. Stevenson, To Check or Not to Check? The TCJA’s Impact on Entity Classification Decisions, INT’L TAX J. March-April 2019; Hal Hicks, Moshe Spinowitz, and Robert C Stevenson, Chapter 37 United States, The Inward Investment And International Taxation Review 9th ed. (Tim Sanders, Editor, 2019); Paul E. Schockett and Robert C. Stevenson, International Corporate Tax Reform and Partnership Taxation: Fitting a Triangular Peg into a Rectangular Hole, INT’L TAX J. July-August 2018; Robert C. Stevenson, A Decade of Shooting Itself in the Foot: The IRS’s Battle Against the Killer B, INT’L TAX J. May-June 2017
  • Admitted to practice in New York, New Jersey, and Washington, DC.
  • J.D. and LL.M. degree in taxation, Georgetown University Law Center, Washington, DC; B.S. degree in chemical engineering, Columbia University School of Engineering and Applied Science, New York, NY
  • Can be contact at 202-371-7056 or [email protected]
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Product ID: 406720
Published 2019
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