IRS Prop. Reg.: U.S. Chamber of Commerce Comments Submitted on Aggregate Group Rules Under Base Erosion Anti-Abuse Tax (IRC §59A)

U.S. Chamber of Commerce comments released January 31 on REG-112607-19 that would provide guidance regarding the base erosion and anti-abuse tax imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties. The proposed regulations relate to how a taxpayer determines its aggregate group for purposes of determining gross receipts and the base erosion percentage, provide an election to waive deductions, and address the application of the BEAT to partnerships. [Comments from U.S. Chamber of Commerce]

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