The recently enacted 2017 tax reform act imposes a new “base erosion and anti-abuse tax” (BEAT) on large corporations. The BEAT operates as a limited-scope alternative minimum tax, applied by adding back to taxable income certain deductible payments made to related foreign persons. Although positioned as an anti-abuse rule, the BEAT presents challenges for a wide range of common business structures employed by both non-US-based and US-based multinationals.
The New Base Erosion Minimum Tax
Posted In Tax Reform, Uncategorized
David G. NorenDavid G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of "outbound" and "inbound" issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules. Read David G. Noren's full bio.
Jonathan D. LockhartJonathan Lockhart focuses his practice primarily on international tax planning and controversies. Jonathan helps clients structure international acquisitions and reorganizations in a tax-efficient manner, as well as with foreign earnings repatriation, foreign tax credit planning and intellectual property migration. Read Jonathan Lockhart's full bio.
Lowell D. YoderLowell D. Yoder focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, e-commerce, financial, consumer and industrial companies. He advises on tax-efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax-beneficial planning for intangible holding companies, global supply chains and multi-jurisdictional service arrangements. Lowell also represents clients before the Internal Revenue Service (IRS), handling audits and obtaining tax rulings. He works with an extensive network of lawyers worldwide, developing tax-favorable transactional and operational cross-border structures. Lowell is the global head of McDermott's Tax Practice. Read Lowell Yoder's full bio.
EDITOR IN CHIEF
STAY CONNECTED
TOPICS
ARCHIVES
RECENT POSTS
- IRS roundup: December 15 – December 22, 2025
- IRS roundup: November 25 – December 10, 2025
- Potential refund opportunity of buyback excise tax based on § 4501 final regulations
- Major update: Potential refund opportunity for interest and penalty amounts accrued during COVID-19 federally declared disaster
- IRS roundup: November 7 – November 24, 2025
