Subpart F and the BEAT - McDermott Will & Emery

Subpart F and the BEAT

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Overview


Lowell D. Yoder authored this bylined article on the interaction between the BEAT and Subpart F. The two sets of rules generally operate independently which can result in double inclusion of the same amount in calculating the BEAT. In addition, harsh results follow when Subpart F inclusions are subject to foreign income tax because no foreign tax credit is allowed when calculating the BEAT.