ETAX Multijurisdictional Matters R18-12B

When to apply the base erosion anti-abuse tax.

  • Applies when large C corporations, shift taxable income to low taxed countries.
  • Tax applies to entities with gross receipts ≥ $500 million for 3 prior years.
  • Applies to entities with excessive royalties, and management fees to non-U.S. persons.