Yen did not address the BEAT rules. Foreign income earned by U. However, under the Subpart F rules, U. This system created incentives for multinational companies to shift income away from the U. The TCJA generally establishes a hybrid territorial system by providing for a participation exemption i. Even with this incentive, corporations with foreign operations may continue to use deductible payments to erode the U. The tax is structured as an alternative minimum tax that applies when a multinational company reduces its regular U.
The tax applies to deductible payments to foreign affiliates from domestic corporations, as well as on foreign corporations engaged in a U.
In the case of a foreign corporation engaged in a U. Section 59A e 2 A. Everything you need to educate clients and prepare for the future.
L'ordonnance sur la péréquation financière et la compensation des charges, qui précise la péréquation des ressources, fait également partie de la réforme.
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