Anti-Abuse Tax to Apply Retroactively Even If Rules Come Late

Almost all multinational companies could face the base erosion and anti-abuse tax, even if the Treasury Department finalizes the rules after its June 22 deadline for other measures created in the tax overhaul.

Treasury allowed for the rules to apply retroactively to the date they were issued even if the final rules weren’t finalized by June 22, according to 2018 proposed rules (REG-132197-17), Kevin Nichols, senior counsel at the Office of International Tax Counsel at Treasury, said at a Feb. 21 conference hosted by the International Fiscal Association in Washington.

• Almost every company ...