A brief look at what’s been going on in North America…

The US Treasury and the Internal Revenue Service (IRS) has issued final and proposed regulations for the base erosion and anti-abuse tax (BEAT). The BEAT was introduced as part of the Tax Cuts and Jobs Act of 2017 (TCJA”) to prevent US corporations from unduly reducing their US taxable income through payments to related foreign parties.

While generally retaining most features of the proposed regulations issued in December 2018, the final regulations contain a number of amendments. Among these are: an election to waive deductions; the lack of a...