Yes, we believe that Treasury will have authority to issue regulations dealing with potential issues with the ordering of the calculation of the credit under section 53 and the tax under section 59A. Regulations such as these would be in line with our intent in drafting the BEAT interaction provisions in the corporate alternative minimum tax.
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More from Ron Wyden
This interpretation is wildly inconsistent with the longstanding treatment of other provisions that use identical or near-identical language.
This is another desperate attempt by a failed president to escape Americans’ revulsion with his failed agenda, amounting to one tank of Trump-inflated gas.
The White House should make MITRE’s findings public as soon as possible.
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