BEAT

Wiki says "Note however that if the insurer has elected to be taxed as a U.S. taxpayer then they are not are not subject to BEAT." (Emphasis added; repetition of "are not" retained from original but not the point of this post.)

Odomirok says "It is noted, however, that payments to a foreign company that has elected to be taxed as a U.S. taxpayer under Section 953(d) are not subject to the BEAT." (Emphasis added.)

Odomirok's version seems clearer to me--if the company you're paying isn't foreign (for tax purposes, at least) then you're not really eroding the US tax base.

Is that a fair summary of the exclusion?

Comments

  • Yes, that's correct. I have clarified the wiki. I also did some more research on BEAT and have edited the original exposition and added a pop quiz. I think something on BEAT would make a pretty good exam question. I will tweet about this to draw people's attention to it and make sure everyone sees the changes. Thx.

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