Clark Armitage and Elizabeth Stevens Moderate Panel on Base Erosion and Anti-Abuse Tax at AICPA & CIMA U.S. Tax Update Conference

9:25 AM - 9:50 AM

This session will address practical considerations with respect to the application of the section 59A Base Erosion Anti-Abuse Tax, focusing particularly on issues addressed in the proposed and possibly final regulations.  The discussion will include practical considerations, including multiple-party contracting approaches, the implications of general U.S. federal income tax principles on the determination of whether payments are “base erosion payments,” the application of anti-abuse rules, and practical considerations to address the potential application of the section 59A anti-abuse tax to U.S. taxpayers.

Related Practices/Industries

Jump to Page

We use cookies to make your experience of our website better. By continuing to browse this site you consent to the use of cookies. Please visit our Privacy Policy for more information.