Final regulations and additional proposed regulations on the Section 59A base erosion and anti-abuse tax (BEAT) were released by the U.S. Treasury Department and IRS on December 2, 2019. In this timely and informative webcast, Duff & Phelps’ Michelle Johnson, Patrick McColgan and Justin Radziewicz discuss the impacts that the final BEAT regulations have on transfer pricing policy considerations.
This webcast explores need-to-know highlights of the final BEAT regulations, fact patterns causing companies to think about change and specific planning considerations for intercompany services, intangibles and related party financing and debt.
Duration: 1 hour
Discussion Topics Include
- Changes in the Final BEAT regulations that matter most for transfer pricing considerations
- Netting and BEAT
- The “Middleman” concept
- Re-examining policies for outbound royalties
- Opportunities to change intercompany debt and financing transactions
- Qualifying for the services cost method (SCM) exception
- SCM documentation requirements and support
Presenters
- Michelle Johnson, Managing Director, Transfer Pricing Services, Duff & Phelps
- Patrick McColgan, Managing Director, Transfer Pricing Services, Duff & Phelps
- Justin Radziewicz, Director, Transfer Pricing Services, Duff & Phelps
