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Base Erosion and Anti-Abuse Tax; Correcting Amendment

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Internal Revenue Service (IRS), Treasury.


Correcting amendments.


This document contains corrections to final regulations (TD 9885) that were published in the Federal Register on Friday, December 6, 2019. The 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.


Effective date: The final regulations are effective on August 14, 2020.

Applicability date: December 6, 2019.

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Sarah Hoyt at (202) 317-6848 or Julie Wang at (202) 317-6975 (not a toll-free number).

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The final regulations (TD 9885) that are the subject of this correction are issued under § 1.1.502-59A of the Internal Revenue Code.

Need for Correction

As published, December 6, 2019 (84 FR 66968) the final regulations (TD 9885; FR DOC. 2019-25744) contains an error that needs to be corrected.

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List of Subjects in 26 CFR Part 1

  • Income taxes
  • Reporting and recordkeeping requirements
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Correction of Publication

Accordingly, 26 CFR part 1 is corrected by making the following correcting amendments:

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Paragraph 1. The authority citation for part 1 continues to read in part as follows:

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Authority: 26 U.S.C. 7805 * * *

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Par. 2. Section 1.1502-59A is amended by transferring the section underneath the undesignated heading “Special Taxes and Taxpayers” and following § 1.1502-55.

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Martin V. Franks,

Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration).

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[FR Doc. 2020-16383 Filed 8-13-20; 8:45 am]