Failing BEAT’s Services Cost Method Exception Could Cost Big


David Noren, at a District of Columbia Bar Community of Taxation event, addressed whether a markup for services would require the entirepaymentto be included under the new tax bill’s base erosion and anti-abuse tax (BEAT) provision, noting that legislative history could support including just the markup as a base erosion payment. “You do appear to be stuck with a subcontractor service fee being conceptually within the scope of the BEAT,” Mr. Noren said.