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Change to the Instructions for Form 8991, Schedule A, line 9b

With the issuance of Notice 2021-36, it is necessary to update the second paragraph of the 
Schedule A, line 9b, instructions for Form 8991. The second paragraph is revised as 
follows.

A taxpayer meets the reporting requirement of Regulations sections 1.59A-6(b)(2) and 
1.6038A-2(b)(7)(ix) by entering the amount on line 9b. For tax years beginning in or after 
2023, a taxpayer will also need to provide a representation that all payments satisfy the 
requirements of Regulations section 1.59A-6(b)(2) and meet the reporting requirements of 
Regulations section 1.59A-6(b)(2) and 1.6038A-2(b)(7)(ix).

                               Tax on Base Erosion Payments of Taxpayers With  
Form 8991
                                                  Substantial Gross Receipts
(Rev. December 2020)                                                                                                    OMB No. 1545-0123
                           For tax year beginning              , 20   , and ending                        , 20
Department of the Treasury       ▶ Go to www.irs.gov/Form8991 for instructions and the latest information.
Internal Revenue Service                                  ▶ See instructions.
Name                                                                                         Employer identification number

Part I Applicable Taxpayer Determination
Check box if this form is being filed by a taxpayer with which another taxpayer has been aggregated under Regs. section 1.59A-2(c) ▶
If  the  above  box  is  checked,  attach  a  statement  listing  the  names  and  EINs  of  all  separate  taxpayers  taken  into  account  in  the 
determination of “1 person” under Regs. section 1.59A-2(c).
                                                                                               (a)              (b)          (c)
                                                                                               First          Second         Third 
                                                                                             Preceding        Preceding    Preceding 
                                                                                             Tax Year         Tax Year       Tax Year
 1a  Gross receipts of the taxpayer. See instructions  .   .   . .  . . .    . . .
b    Gross receipts from partnerships .    .      . . . .  .   . .  . . .    . . .
c    Gross  receipts  of  all  other  persons  treated  as  1  person  pursuant  to  Regs. 
     section 1.59A-2(c) .      . .  . .  . .      . . . .  .   . .  . . .    . . .
d    Gross receipts. Combine lines 1a through 1c .      .  .   . .  . . .    . . .
e    Gross receipts of first, second, and third preceding tax years. Combine columns (a), (b), and (c) of line
     1d . .  .           . . . . .  . .  . .      . . . . .    . .  . . .    . . .         . . . .    . . .   .      1e
f    3-year average annual gross receipts. See instructions .    .  . . .    . . .         . . . .    . . .   .      1f
g    Is line 1f $500 million or more?
       Yes. Continue to line 2.
       No. STOP here and attach this form to your tax return.
2a   Base erosion tax benefit (from Schedule A, line 15, column (a-2)). .    . . .         . . . .    . . .   .      2a
b    Amount of deductions allowed under Chapter 1 of the Internal Revenue Code .             . . .    . . .   .      2b
c    Base  erosion  tax  benefits  resulting  from  reductions  in  insurance  premiums
     reported on Schedule A, line 8, column (a-2)     . .  .   . .  . . .    . . .         .   2c
d    Base erosion tax benefits resulting from reductions in gross receipts reported on
     Schedule A, line 10, column (a-2) .   .      . . . .  .   . .  . . .    . . .         .   2d
e    Add lines 2c and 2d  .      .  . .  . .      . . . .  .   . .  . . .    . . .         . . . .    . . .   .      2e
f    Total deductions for amounts paid or accrued for services to which the exception
     under Regs. section 1.59A-3(b)(3)(i) applies (from Schedule A, line 5b) . . .         .   2f
g    Qualified derivative payments excepted by Regs. section 1.59A-6(b)      . . .         .   2g
h    Total deductions allowed under sections 172, 245A, and 250 for the tax year.          .   2h
i    Does  the  taxpayer  elect  to  waive  deductions  in  accordance  with  Regulations
     section 1.59A-3(c)(6)(i)? .    . .  . .      . . . .  .   . .  . . .    . . .         .   2i
       Yes. Complete Schedule B. Enter the amount from line 15 of Schedule B.
       No. Enter -0-.
j    Deductions  for  exchange  losses  from  section  988  transactions  described  in
     Regulations section 1.59A-2(e)(3)(ii)(D)     . . . .  .   . .  . . .    . . .         .   2j
k    Deductions  for  TLAC  securities  and  foreign  TLAC  securities  described  in
     Regulations section 1.59A-2(e)(3)(ii)(E)     . . . .  .   . .  . . .    . . .         .   2k
l    Reinsurance  losses  incurred  and  claims  payments  described  in  Regulations
     section 1.59A-2(e)(3)(ii)(F) . . .  . .      . . . .  .   . .  . . .    . . .         .   2l
m    Combine lines 2f through 2l .    .  . .      . . . .  .   . .  . . .    . . .         . . . .    . . .   .      2m
n    Total Deductions. Subtract line 2m from the sum of line 2b and line 2e    . .         . . . .    . . .   .      2n
o Base Erosion Percentage. Divide line 2a by line 2n .         . .  . . .    . . .         . . . .    . . .   .      2o                  %
p    Is the taxpayer’s base erosion percentage on line 2o 3% or higher (2% or higher for a bank or securities 
     dealer)?
       Yes. Continue to Part II.
       No. STOP after completing Part I and Schedule A (and, if necessary, Schedule B) and attach this 
       form to your tax return.
For Paperwork Reduction Act Notice, see separate instructions.                 Cat. No. 37815N                      Form 8991 (Rev. 12-2020)

Form 8991 (Rev. 12-2020)                                                                                                Page 2
Part II  Modified Taxable Income (MTI)
3a Taxable income after net operating loss. See instructions . . . . . . . .         . . . . .  . .            3a
b  Base erosion tax benefits for the tax year from Schedule A, line 15, column (b-2) . . . . .  . .            3b
c  Base erosion percentage of the net operating loss deduction allowed under section 172 for the tax year. 
   See instructions .      . . . . . . . .  . .    . . .    .  . . . . . . .         . . . . .  . .            3c
d Modified Taxable Income. See instructions   .    . . .    .  . . . . . . .         . . . . .  . .            3d
Part III Regular Tax Liability Adjusted for Purposes of Computing Base Erosion Minimum Tax Amount
4a Regular tax liability .   . . . . . . .  . .    . . .    .  . . . . . . .         . . . . .  . .            4a
b  Allowed credits, as adjusted (from Schedule C, line 7) . .  . . . . . . .         . . . . .  . .            4b
c  Regular tax liability adjusted for purposes of computing Base Erosion Minimum Tax Amount. Subtract 
   line 4b from line 4a .    . . . . . . .  . .    . . .    .  . . . . . . .         . . . . .  . .            4c
Part IV  Computation of Base Erosion Minimum Tax Amount
5a Modified Taxable Income (from line 3d) . . .    . . .    .  . . . . . . .         . . . . .  . .            5a
b  BEAT Tax rate applicable for current tax year . . . .    .  . . . . . . .         . . . . .  . .            5b       %
c  Base Erosion Minimum Tax. Multiply line 5a by line 5b .  .  . . . . . . .         . . . . .  . .            5c
d  Regular  tax  liability  adjusted  for  purposes  of  computing  Base  Erosion  Minimum  Tax  Amount  (from 
   line 4c) . . .        . . . . . . . . .  . .    . . .    .  . . . . . . .         . . . . .  . .            5d
e  Base Erosion Minimum Tax Amount. Subtract line 5d from line 5c. If zero or less, enter -0- . . .            5e
                                                                                                               Form 8991 (Rev. 12-2020)

Form 8991 (Rev. 12-2020)                                                                                                                                                  Page 3
Schedule A    Base Erosion Payments and Base Erosion Tax Benefits (see instructions)
Does the taxpayer elect to use financial statements per Regs. section 1.59A-3(b)(4)(i)(D) for purposes of calculating interest expense     (Check all applicable boxes in                   
allocable to a foreign corporation’s effectively connected income?   Yes No                                                            columns (c), (d), and (e) below)
                                                                         (a-1)         (a-2)        (b-1)            (b-2)             (c)          (d)                (e)
                                                                       Aggregate       Aggregate    Taxpayer’s Base  Taxpayer’s Base   Any 25%      Person Related   Any Person 
                                                                       Group’s Base    Group’s Base Erosion Payments Erosion Tax       Owner of     Under Sections  Related Within 
                                                                      Erosion Payments Erosion Tax                   Benefits          the Taxpayer 267(b) or         the Meaning of 
                                                                                       Benefits                                                     707(b)(1) to the Section 482     
                  Type of Base Erosion Payments                                                                                                     Taxpayer or Any  to the Taxpayer
                                                                                                                                                    25% Owner of 
                                                                                                                                                    the Taxpayer

1  Reserved for future use .   . .  .   . . . .  . . . .     .     .
2  Reserved for future use .   . .  .   . . . .  . . . .     .     .
3  Purchase or creations of property rights for intangibles (patents, 
   trademarks, etc.) .     . . . .  .   . . . .  . . . .     .     .
4  Rents, royalties, and license fees . . . . .  . . . .     .     .
5a Compensation/consideration paid for services NOT excepted by 
   Regs. section 1.59A-3(b)(3)(i) . .   . . . .  . . . .     .     .
 b Compensation/consideration paid for services excepted by Regs. 
   section 1.59A-3(b)(3)(i)  . . .  .   . . .   $
6  Interest expense .      . . . .  .   . . . .  . . . .     .     .
7  Payments for the purchase of tangible personal property . .     .   
8  Premiums  and/or  other  considerations  paid  or  accrued  for 
   insurance and reinsurance as covered by Regs. section 1.59A-3(b)
   (1)(iii) . . . .      . . . . .  .   . . . .  . . . .     .     .
                                                                                                                                                    Form 8991 (Rev. 12-2020)

Form 8991 (Rev. 12-2020)                                                                                                                                                      Page 4
Schedule A Base Erosion Payments and Base Erosion Tax Benefits (see instructions) (continued from page 3)                                                                           
                                                                                                                                               (Check all applicable boxes in                   
                                                                                                                                           columns (c), (d), and (e) below)
                                                                            (a-1)            (a-2)        (b-1)            (b-2)           (c)          (d)                (e)
                                                                            Aggregate        Aggregate    Taxpayer’s Base  Taxpayer’s Base Any 25%      Person Related   Any Person 
                                                                            Group’s Base     Group’s Base Erosion Payments Erosion Tax     Owner of     Under Sections  Related Within 
                                                                            Erosion Payments Erosion Tax                   Benefits        the Taxpayer 267(b) or         the Meaning of 
                                                                                             Benefits                                                   707(b)(1) to the Section 482     
                  Type of Base Erosion Payments                                                                                                         Taxpayer or Any  to the Taxpayer
                                                                                                                                                        25% Owner of 
                                                                                                                                                        the Taxpayer

 9a Nonqualified derivative payments . . . .   .  . . . . .         .
  b Qualified  derivative  payments  excepted  by  Regs.  section  
    1.59A-6(b) .  .      . . . . . .   . . .     $
10  Payments  reducing  gross  receipts  made  to  surrogate  foreign 
    corporation . .      . . . . . .   . . .   .  . . . . .         .
11  Other payments—specify .     . .   . . .   .  . . . . .         .
12  Combine lines 3 through 11   . .   . . .   .  . . . . .         .
13  Base erosion tax benefits related to payments reported on lines 3 
    through 11, on which tax is imposed by section 871 or 881, with 
    respect  to  which  tax  has  been  withheld  under  section  1441  or 
    1442 at 30% statutory withholding tax rate .  . . . . .         .
14  Portion of base erosion tax benefits reported on lines 3 through 
    11, on which tax is imposed by section 871 or 881, with respect 
    to which tax has been withheld under section 1441 or 1442 at 
    reduced withholding rate pursuant to income tax treaty. Multiply 
    ratio  of  percentage  withheld  divided  by  30%  times  tax  benefit. 
    See instructions     . . . . . .   . . .   .  . . . . .         .
15  Total base erosion tax benefits. Subtract the sum of line 13 and 
    line 14 from line 12. Enter the amount from column (a-2) in Part I, 
    line 2a. Enter the amount from column (b-2) in Part II, line 3b .
                                                                                                                                                        Form 8991 (Rev. 12-2020)

Form 8991 (Rev. 12-2020)                                                                                                                                                                                                        Page 5
Schedule B Waiver of Deductions (see instructions)                                                                                   
                                                                             (b)                   (c)                  (d)                 (e)                   (f)                   (g)                   (h)               (i)                
                                                                         Date on which, or  Provision of Code       Line number on        Name of foreign       Taxpayer              Country of          Amount of             Amount of 
                                                                         period in which,      and regulations,     the controlled        related party that  Identification        organization of    deduction claimed  deduction being 
                         (a)                                               the waived          as applicable, that  group member tax  is or will be the       Number of foreign       the foreign         for the tax year      waived for the tax 
   Description of item or property to which the                            deduction was         allows the         return where the      recipient of the    related party           related party       with respect to the  year with respect 
           deduction relates                                             paid or accrued       deduction for          deduction is        payment that                                                    item or property      to the item or 
                                                                                                 which this           reported            generates the                                                                         property
                                                                                               election relates                           deduction
1
2
3
4
5
6
7
8
9
10
11
12
13
14 Totals from attachment, if necessary .       .                        . . . . .        .    . . . .        .     . . . .    .     .    . . . .          .  . . . .    .          . . . . .
15 Total deductions waived per Regulations section 1.59A-3(c)(6)(i). Add the amounts in column (i). Enter the result here and on Part I, line 2i   .                                                      . . . .
                                                                                                                                                                                                              Form 8991 (Rev. 12-2020)

Form 8991 (Rev. 12-2020)                                                                                                        Page 6
Schedule C Credits Reducing Regular Tax Liability in Computing Base Erosion Minimum Tax Amount (BEMTA)
Part I   Credits Allowed Against Regular Tax (see instructions)
1  Total credits allowed in current year. See instructions  .  . .       . . . . . .     .     . . . . . .             1
2  Credits for increasing research activities from line 1c of all Parts III of Form 3800       2
3  Total  allowed  credit  for  increasing  research  activities  for  current  year.  Enter  the  amount  of  research
   credit reported in Form 3800, Part II, line 38. See instructions .    . . . . . .     .     . . . . . .             3
4  Enter smaller of Schedule C, Part II, line 11, or Part III, line 16 . . . . . . .     .     . . . . . .             4
5  Limitation of applicable section 38 credits. Multiply line 4 by 80% (0.80) .  . .     .     . . . . . .             5
6  Adjustments to allowed credits. Add lines 3 and 5     . .   . .       . . . . . .     .     . . . . . .             6
7  Credits allowed against regular tax in computing BEMTA. Subtract line 6 from line 1. Enter here and 
   on Form 8991, line 4b . . . . . . .          .    . . . .   . .       . . . . . .     .     . . . . . .             7
Part II  Applicable Section 38 Credits 
         (Only complete Parts II and III if you have allowed applicable section 38 credits.)
8  Low-income housing credit from lines 1d and 4d of all Parts III of Form 3800.   .           8
9  Renewable  electricity  production  credit  but  only  to  extent  of  the  renewable 
   electricity under section 45(a) from lines 1f and 4e of all Parts III of Form 3800 .        9
10 Investment  credit  but  only  to  extent  of  energy  credit  property  under  section  48 
   from line 4a of all Parts III of Form 3800 . .    . . . .   . .       . . . . . .           10
11 Total  allowed  applicable  section  38  credits  for  current  year.  Enter  the  amount  of  applicable  credits 
   reported in Form 3800, Part II, line 38. See instructions . . .       . . . . . .     .     . . . . . .             11
Part III BEMTA Determined Without Adjustment for Applicable Section 38 Credits
12 Base erosion minimum tax (Form 8991, line 5c)       . . .   . .       . . . . . .     .     . . . . . .             12
13 Regular tax liability (Form 8991, line 4a) . .    . . . .   . .       . . . . . .     .     . . . . . .             13
14 Subtract Schedule C, Part I, line 3, from line 1 .  . . .   . .       . . . . . .     .     . . . . . .             14
15 Regular tax adjusted for credits that offset BEMTA. Subtract line 14 from line 13     .     . . . . . .             15
16 Base erosion minimum tax determined without adjustment for applicable section 38 credits. Subtract 
   line 15 from line 12; if zero or less, enter -0-. . . . .   . .       . . . . . .     .     . . . . . .             16
                                                                                                                       Form 8991 (Rev. 12-2020)