GILTI, Subpart F & BEATAnswered

BEAT $500M gross receipts test — am I really exempt as a small foreign-owned LLC?

D2
dmitri_2bffnew member
May 8, 2026 0 views 1 answer
beatsection 59a$500m thresholdsmall llcgross receipts testapplicable taxpayer

I've been reading scary articles about the Base Erosion and Anti-Abuse Tax (BEAT) under §59A and worrying whether my foreign-owned U.S. LLC is exposed when it pays my foreign parent for services. The LLC has roughly $1.2M of annual revenue. Multiple sources mention a $500M threshold but I want to confirm what that test actually measures and whether I'm in the clear.

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