New Section 59A: Base Erosion and Anti-Abuse Tax (the "BEAT")

Thursday, March 7, 2019  -  Earn 1.5 CE Credits 
Live Webinar United States Time Zones:
1:00 PM – 2:30 PM EDT /  12:00 PM – 1:30 PM CDT  / 10:00 AM – 11:30 AM PDT

The BEAT presents challenges for common business structures used by both non-U.S. based and U.S.-based multinationals. Non-U.S. corporations with income effectively connected to a U.S. trade or business and related party payments may be subject to the BEAT, requiring a careful analysis of the new tax rules.

The impact of new §59A on non-U.S. Based and U.S.-based multinationals

  • Analyzing the reporting requirements and exemptions of the BEAT

  • Identifying transactions that may be subject to the BEAT

  • Determining modified taxable income subject to §59A

  • Tax rate application and methods of calculating the BEAT

  • Tax planning tips limiting exposure and reducing taxable income subject to the anti-abuse tax

The BEAT targets U.S. tax-base erosion by imposing an additional tax liability on certain corporations that make payments to related foreign persons by adding back to taxable income certain deductible payments made to such foreign persons. The BEAT amounts to an alternative minimum tax on a taxpayer’s taxable income regardless of the tax benefits arising from the payments to foreign persons. This modified taxable income is subject to a tax rate of 5% starting from the 2018 tax year and increasing to 12.5% beginning in 2025. Key topics include:

  • Determine the applicability of §59A to U.S. based corporations and non-U.S. affiliates

  • Methods in calculating modified taxable income and applicable tax rates

  • Identifying transactions or operations subject to the BEAT

  • The impact of net operating losses in determining modified taxable income

  • Recognizing the interaction of BEAT with other new tax law provisions

  • Tax planning methods in reducing or limiting BEAT exposure

Level: Intermediate
Delivery Method: Group-Internet Based Live
Recommended CPE/CLE Credit: 1.5 Credit
Field of Study: Taxes
Prerequisites:  An introductory course on international taxes and a working knowledge of international transactions
Advance Preparations: None
Who Should Attend: This webinar is for CPAs, tax executives, accountants, tax attorneys and financial executives.

Presented By:

William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments.  He is also a member of the firm’s Tax Litigation and Controversy Group.  He is a Certified Specialist in Taxation Law.  In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriation's of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court.  Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law.  He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch.  He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute.  In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation. For more information: