What types of payments count as base erosion payments under BEAT?
We're trying to figure out exactly which payments our U.S. company makes to related foreign entities count as 'base erosion payments' for BEAT purposes. We pay our foreign parent for inventory (COGS), IP royalties, management services, interest on intercompany loans, and reinsurance premiums. Do all of these count? I heard there are important exceptions.
Related Questions
What is the Base Erosion and Anti-Abuse Tax (BEAT) and who does it affect?
Our company is a U.S. subsidiary of a large foreign multinational. Our CFO mentioned we might be subject to something called BEAT — the Base Erosion Anti-Abuse Tax. I looked it up and it seems very co...
Does BEAT apply to my foreign-owned U.S. corporation that pays royalties to its parent?
I'm the tax director of a U.S. corporation wholly owned by a Japanese parent company. We pay substantial royalties and management fees to our parent — about $80 million per year. Our total deductions ...
How exactly is the BEAT calculated? Walk me through the minimum tax computation.
I understand BEAT conceptually but I'm struggling with the actual math. My U.S. corporation has $150 million in taxable income, $40 million in base erosion payments that are deductible, and $5 million...
What specific categories of income are considered Subpart F income?
My CFC earns a mix of income — some from selling products, some from licensing IP, some from investing excess cash, and some from providing consulting services to related companies. I need to figure o...
What happens to my 401(k) and deferred compensation when I expatriate?
I have about $800,000 in my 401(k), $200,000 in a traditional IRA, and I'm owed about $300,000 in deferred compensation from my former employer. I'm surrendering my green card next year. My tax attorn...
I live in Turkey and do consulting. Should I actually care about U.S. day counts under the treaty tables?
I am a Turkish consultant using a U.S. LLC for software and analytics projects. Most work is done from Istanbul, but I may spend a few weeks in the U.S. this year with one client. I found the IRS trea...
I accidentally spent too many days in the U.S. and may have become a tax resident — what now?
I'm a German citizen who owns a U.S. LLC and I travel to the U.S. frequently for conferences and client meetings. I just realized that between 2024, 2025, and 2026, my weighted day count under the Sub...
What are the anti-inversion rules under IRC 7874 and how do they affect foreign-owned structures?
I've been reading about corporate inversions — companies moving their tax domicile overseas to reduce U.S. taxes. We are a foreign company considering acquiring a U.S. target, and our advisors warned ...
Does the branch profits tax apply to a foreign-owned U.S. LLC treated as a disregarded entity?
I'm a non-U.S. individual operating a consulting business through a U.S. single-member LLC. I understand the LLC is a disregarded entity for tax purposes. Does the branch profits tax apply to me? I th...
What is the FDII deduction and can my U.S. corporation benefit from it?
I own a U.S. C-corporation that sells software licenses to customers all over the world. About 60% of our revenue comes from foreign customers. Someone mentioned that there's a deduction called FDII t...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.


