IRS Official Warns Against Repricing Transactions to Avoid BEAT

Companies should be careful when adjusting the price of an arm’s-length transaction to reduce their base erosion and anti-abuse tax, known as the BEAT, an IRS official said.

If the facts of a transaction haven’t changed, but a company tries to change the price, it should “take a really close look and make sure that both the before and after price were an arm’s-length price,” Christopher Bello, branch chief for Branch 6 at the IRS Office of Associate Chief Counsel (International), said in response to a question at the American Bar Association meeting in Boca Raton, Fla., on Friday. ...