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Daily Tax Report: International

Base Erosion Rules Could Make It Harder For Companies to Move IP

Dec. 26, 2018, 4:58 PM

The 2017 tax overhaul was supposed to encourage multinational companies to move their valuable intellectual property back to the U.S., but recent proposed rules on one of the tax law’s provisions could have the opposite effect.

The Dec. 13 proposed rules on the base erosion anti-abuse tax (BEAT) take away some of the benefits companies could otherwise get when they move intangible assets like patents in a tax-free reorganization, such as when one corporation acquires another through a transfer of stock.

The rules would affect not just companies that rely heavily on intellectual property, like technology or pharmaceutical companies, but...

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