{"abstract":"This document contains final regulations implementing the base erosion and anti-abuse tax, designed to prevent the reduction of tax liability by certain large corporate taxpayers through certain payments made to foreign related parties and certain tax credits. These final regulations also provide reporting requirements related to this tax. This tax was added to the Internal Revenue Code (the \"Code\") as part of the Tax Cuts and Jobs Act. This document finalizes the proposed regulations published on December 21, 2018. The final regulations affect corporations with substantial gross receipts that make payments to foreign related parties. The final regulations also affect any reporting corporations required to furnish information relating to certain related-party transactions and information relating to a trade or business conducted within the United States by a foreign corporation.","action":"Final regulations.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2019/12/06/2019-25744.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26}],"citation":"84 FR 66968","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Effective date: The final regulations are effective on December 6, 2019. Applicability dates: For dates of applicability, see Sec. Sec. 1.59A-10, 1.1502-2(d), 1.1502-59A(h), and 1.6038A-2(g).","disposition_notes":null,"docket_ids":["TD 9885"],"dockets":[],"document_number":"2019-25744","effective_on":"2019-12-06","end_page":67045,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2019/12/06/2019-25744.xml","html_url":"https://www.federalregister.gov/documents/2019/12/06/2019-25744/base-erosion-and-anti-abuse-tax","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2019-25744?publication_date=2019-12-06","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2019-12-06/2019-25744/mods.xml","not_received_for_publication":null,"page_length":78,"page_views":{"count":19531,"last_updated":"2026-08-24 04:15:06 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2019-12-06/pdf/2019-25744.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2019-25744.pdf?1575321318","publication_date":"2019-12-06","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2019/12/06/2019-25744.txt","regulation_id_number_info":{"1545-BO56":{"issue":"201910","html_url":"https://www.federalregister.gov/regulations/1545-BO56/section-59a-proposed-regulations","title":"Section 59A Proposed Regulations","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201910&RIN=1545-BO56&operation=OPERATION_EXPORT_XML","priority_category":"Economically Significant"}},"regulation_id_numbers":["1545-BO56"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BO56/section-59a-proposed-regulations","title":"Section 59A Proposed Regulations"},"comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2019-0002","supporting_documents_count":0,"docket_id":"IRS-2019-0002","regulation_id_number":"1545-BO56","title":"Base Erosion and Anti-Abuse Tax (REG-104259-18)","checked_regulationsdotgov_at":"2019-12-09T11:00:12Z"},"regulations_dot_gov_url":null,"significant":true,"signing_date":null,"start_page":66968,"subtype":null,"title":"Base Erosion and Anti-Abuse Tax","toc_doc":"Base Erosion and Anti-Abuse Tax","toc_subject":null,"topics":["Income taxes","Reporting and recordkeeping requirements"],"type":"Rule","volume":84}