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New IRS Base Erosion and Anti-Abuse Tax (BEAT) Final Regulations

Sec. 6038A Reporting Issues, Application to Partnerships, Gross Receipts and Base-Erosion Percentage Tests, Recharacterization Rules

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Wednesday, April 1, 2020

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide tax professionals and advisers with a practical guide to the recently issued IRS final regulations on the base erosion and anti-abuse tax (BEAT). The panel will discuss critical provisions of the new IRS final regulations, application to pass-through entities, determining aggregate groups, and Section 6038A reporting requirements. The webinar will also address gross receipts and base-erosion percentage tests, anti-abuse and recharacterization rules, and other crucial considerations.


On Dec. 2, 2019, the IRS issued detailed guidance on the Sec. 59A BEAT. The final regulations provide details on determining which taxpayers are subject to the BEAT rules and base-erosion payments, and minimum amount. They also address reporting and recordkeeping requirements.

The final regulations have a significant impact on corporations with substantial gross receipts that make payments to foreign related parties and corporations required to report under Secs. 6038A and 6038C. The regulations provide critical guidance and clarification on determining the application of BEAT to taxpayers, rules for the gross receipts test and base-erosion percentage test, computation of modified taxable income and the base-erosion minimum tax amount, and anti-abuse and recharacterization rules.

The final regulations also provide relief for nonrecognition transactions, a mechanism for waiving allowable deductions, rules regarding aggregate and consolidated groups, and other crucial items that tax counsel and advisers must consider. Furthermore, the IRS issued proposed regulations on the application of BEAT to partnerships in response to concerns expressed by practitioners.

Listen as our panel of experts discusses provisions of the new IRS final regulations, its application to pass-through entities, reporting requirements, and special rules and tests. The panel will offer planning techniques for taxpayers.



  1. Overview of final and additional proposed regulations
  2. Critical rules and tests
    1. Gross receipts and base-erosion percentage tests
    2. Anti-abuse and recharacterization rules
    3. Aggregate and consolidated group
  3. Application to pass-through entities
  4. Section 6038A reporting requirements and pitfalls to avoid
  5. Best practices and tax planning opportunities for taxpayers


The panel will review these and other key issues:

  • Key provisions of the IRS final regulations on the BEAT for taxpayers
  • New rules on the application of BEAT to partnerships
  • Determining gross receipts and the base-erosion percentage test
  • New rules for anti-abuse and recharacterization
  • Rules for deciding aggregate and consolidated groups
  • Critical Section 6038A reporting challenges and methods to overcome them
  • Proposed waiver election


Krueger, Anke
Anke Krueger

Managing Director

Ms. Krueger has been a member of the International Tax consulting group for more than 10 years. She consults on both...  |  Read More

Odintz, Joshua
Joshua D. Odintz

Baker McKenzie

Mr. Odintz is the managing partner of the firm's Washington Tax Department. He held high-level government positions...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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