Kirsten Burmester Comments on BEAT in Tax Notes
Caplin & Drysdale

Kirsten Burmester Comments on BEAT in Tax Notes

Date: 12/9/2019

Treasury is defending its decision not to carve out from the base erosion and antiabuse tax an exception for the global intangible low-taxed income provision or subpart F amidst widespread calls from practitioners.

. . .

Speaking at a December 5 event sponsored by the District of Columbia Bar Taxation Community in Washington, Kimberly Majure of KPMG and Kirsten Burmester of Caplin & Drysdale offered their own explanation for the lack of exception — one not found in the regs’ preamble: that it would lead to many U.S. multinationals not being subject to BEAT.

“It basically would have gutted the statute itself,” Burmester said.

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