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Clark Armitage and Elizabeth Stevens Moderate Panel on Base Erosion and Anti-Abuse Tax at AICPA & CIMA U.S. Tax Update Conference

September 23, 2019, 9:25 AM - 9:50 AM
Moderators:J. Clark Armitage, Elizabeth J. Stevens
Program:Structuring to Address the Base Erosion and Anti-Abuse Tax
Event Sponsor:AICPA & CIMA U.S. Tax Update Conference
Where:

Leonardo Royal Hotel London City

8-14 Cooper's Row

 London EC3N 2BQ, UK

Registration:Click Here To Register

This session will address practical considerations with respect to the application of the section 59A Base Erosion Anti-Abuse Tax, focusing particularly on issues addressed in the proposed and possibly final regulations.  The discussion will include practical considerations, including multiple-party contracting approaches, the implications of general U.S. federal income tax principles on the determination of whether payments are “base erosion payments,” the application of anti-abuse rules, and practical considerations to address the potential application of the section 59A anti-abuse tax to U.S. taxpayers.

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