Another change to the U.S. international tax system under Tax Cuts and Jobs Act 2017 is the Base Erosion and Anti-Abuse Tax (BEAT). Under the new section 59A, there will be a tax equal to the base erosion minimum tax amount for certain taxpayers from the beginning of 2018. One of the parties this provision mainly affect are corporate taxpayers with gross receipts averaging more than $500 million over a three-year period who make deductible payments to foreign related parties.

The proposed regulations issued by the IRS, provide details on which taxpayers can be subjected the section 59A, definition of base erosion payment, calculation method of base erosion minimum tax, and the inclusion of base erosion and anti-abuse tax.