The BEAT Goes On: I.R.C. Section 59A Practice Tips

Summary

This practice note discusses I.R.C. Section 59A, originally enacted by the Tax Cuts and Jobs Act of 2017 (Pub. L. No. 115-97) and amended by the One Big Beautiful Bill Act (OBBBA), Pub. L. No. 119-21, § 70323 (2025). It provides a review of the key features of the base erosion and anti-abuse tax (BEAT), including who is subject to the tax, how the BEAT is computed, and recent changes affecting applicable rates, deductions, and coordination with the foreign tax credit.