http://www.ilgfan.com/ One effective way to reduce the amount of base erosion tax payments is to consider whether outbound royalty payments should be embedded in costs of goods sold (COGS). For example, a U.S. subsidiary may act as a distributer for its foreign parent-manufacturer and pay both a royalty to the foreign parent to … See more Looking forward, taxpayers should also consider whether they may be able to eliminate certain outbound payments to related parties. For example, a multinational group may provide services to a customer on a … See more Another option to reduce the amount of base erosion payments is to convert foreign subsidiaries from CFCs to foreign branches via check … See more If a taxpayer still finds itself exceeding the 3% base erosion percentage threshold, the taxpayer should then consider waiving deductions under the 2024 BEAT proposed … See more
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