United States | New IRC Section 899 would increase tax rates and expand BEAT for certain inbound taxpayers
|Tax Alerts, Information Reporting, Asset ...|United States
New IRC Section 899 would increase applicable tax rates and expand base erosion and anti-abuse tax (BEAT) rules on foreign persons tax resident in, or controlled by tax residents of, "discriminatory foreign countries."
The Bill would have broad reach and apply to certain individuals, foreign governments, foreign corporations, private foundations, certain trusts, and certain foreign partnerships of a discriminatory foreign country.
If enacted, the provision would put enormous pressure on foreign co…
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