Assertion: reform's benefit | /r/HasProperty | eliminated for taxable years
Facets:
Source sentences:
text: The benefit for certain credits that reduce BEAT liability is eventually eliminated for taxable years beginning after December 31, 2025 (e.g., the renewable electricity production credit determined under Section 45(a) and the investment credit determined under Section 46, but only to the extent properly allocable to the energy credit determined under Section 48).Costs of goods sold (COGS) are generally excluded from the definition of base erosion payments (except in cases of payments made to certain expatriated or inverted groups), and so, for example, a taxpayer that imports product for manufacturing and/or resale where the cost is treated as part of COGS is likely to be less affected (assuming no other base erosion payments) versus a company that pays a foreign related party for services (subject to a limited exception under the services cost method under Section 482 (with certain modifications) where such amount constitutes the total services cost with no markup—