Overview
Bloomberg Government quoted George Callas in an article titled “Tax Overhaul Guidance Watch: A Primer.” The article, published September 12, discusses how Treasury and the IRS are chipping away at their list of guidance for last year’s tax overhaul. According to the article, the base erosion and anti-abuse tax (BEAT) is a new part of the tax code, and practitioners have an abundance of questions and concerns.
Callas, a former senior tax counsel to House Speaker Paul Ryan, says that there are some situations in which the BEAT can lead to double taxation. For example, “if the payment is from the US affiliate of a foreign company to a US branch of that foreign company, the US branch is often subject to US tax, and so if you deny the deduction” to the US affiliate making the payment but then tax the US branch receiving the payment, “you are potentially double taxing the income,” he says. “It’s not clear that that’s what was intended.”
The full article can be read at Bloomberg Government (subscription required).