Value-priced Form 8991 — BEAT

Form 8991 — who files it, when it is due, what late filing costs, and what we charge to prepare it. United States (IRS). Value-priced Form 8991 with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE

Secure a fixed quote

Send what you have. We price the engagement from your own documents, in writing, before any work starts.

24-hour helpline: +1 (416) 619-0068
  • Offices in India, the USA, Canada and the UAE
  • 24-hour helpline: +1 (416) 619-0068
  • Fixed fee agreed before work starts
In 60 words

Form 8991 is an information return: Computes the base-erosion minimum tax on deductible payments made by a large US corporation to related foreign parties. US corporations above the applicable receipts threshold with material deductible payments to foreign affiliates.

Does this bind you?

US corporations above the applicable receipts threshold with material deductible payments to foreign affiliates.

The rule underneath it looks like this. It attacks the deduction, not the profit: intercompany service fees, royalties and interest that are perfectly priced can still trigger a minimum tax, which changes how a group funds and charges its US entity.

Two of the firm’s advisers and the team in the open-plan office

Form 8991 beat — priced before we start

The BEAT computation is priced by how many related foreign parties the US company pays and how clean the ledger is. Where intercompany charges are few and already coded by type, the classification is quick; where service fees, royalties, interest and cost recharges are mixed in one intercompany account, each stream has to be separated and tested before the computation runs. Fee fixed in writing first.

Master file & CbCR — fixed-fee price

From $2,500

fixed, quoted before work starts

The group-level documentation and the country-by-country report, prepared so they agree with each other and with every local file in the footprint.
See the full fee page

Transfer pricing — local file — fixed-fee price

From $2,500

fixed, quoted before work starts

The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.
See the full fee page

Transfer pricing documentation

From $2,500

fixed, quoted before work starts

Intercompany pricing documented before it is questioned — the functional analysis, the benchmarking and the files that support it.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Corporate compliance for a group that trades or holds assets in more than one country, prepared on both sides together.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

The information returns that carry the heaviest penalties — foreign accounts, foreign property, foreign affiliates — prepared from one asset list.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

A personal filing built from your own documents — employment, investment and rental income across borders, with the treaty position set out.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Payroll set up for a workforce split across countries, including the relief that stops the same salary being withheld on twice.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

The filings that follow a move: the departure year, the arrival year, and the income that keeps arriving from the country behind you.
See the fee schedule

All published fees on one page — the whole fee schedule in one place, with no from-to bands to decode.

What the reporting test actually looks at

What decides whether Form 8991 applies
What the test looks atWhere the figure comes from
The obligationComputes the base-erosion minimum tax on deductible payments made by a large US corporation to related foreign parties.
Who it bindsUS corporations above the applicable receipts threshold with material deductible payments to foreign affiliates.
Jurisdiction and authorityUnited States — IRS
Category of filingInformation return

When it is due

Information returns are generally due with — or on the same timetable as — the return they accompany, so the deadline is the filing deadline of the underlying return unless the rules set a separate date. Where an extension covers the return, confirm whether it also covers this form; several information returns keep their own date. The date is confirmed for your year at the start of the engagement, not assumed from last year's.

What late or missed filing costs

The penalty on an information return is charged per form and per year, and it does not depend on tax being owed. That is the whole risk profile: a filer with no tax to pay can still accumulate a substantial liability across unfiled years, and the exposure compounds with each additional entity or account that should have been reported. Where years are already missed, the route chosen for the earliest year affects the relief available for the rest — so the sequence is decided before anything is filed.

The arithmetic, worked through

The same point, with figures rather than adjectives.

Why three small accounts are reportable

Three ordinary foreign accounts, none of which looks like a reporting problem on its own. The account report is tested on the aggregate of all foreign financial accounts at their highest point in the calendar year.

Why three small accounts are reportable
ItemAmount
Current account, highest balanceUS$8,000
Savings account, highest balanceUS$6,000
Account held with a relative, signature authority onlyUS$6,000
Aggregate tested against the thresholdUS$20,000
Reporting threshold (verified, FinCEN)US$10,000

The aggregate of US$20,000 exceeds the US$10,000 threshold, so all three accounts are reported — including the one that is not the filer's money, because signature authority counts. Change any one of those inputs and the answer moves, which is why we run it on your own figures rather than on an illustration.

Treat these numbers as a worked example rather than advice — they exist to make the mechanics visible, and the rates and thresholds are assumed for the illustration. For a real filing, we verify each figure with the authority that publishes it, for your year.

How we prepare and file it, and what it costs

We quote Form 8991 before we start, as part of the return set it belongs to rather than as a line item you discover afterwards. If the work turns out to be smaller than the quote, the quote is what you pay; if it turns out to be larger, we re-quote before continuing. See the Canada–India DTAA explained for comparable engagements.

The four steps

  1. 1Establish whether the reporting test is met, on the correct measure
  2. 2Assemble the holdings, accounts or entities that fall inside it
  3. 3Prepare the return and reconcile it to the tax return it travels with
  4. 4File, and set the calendar entry so next year is not a catch-up
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.
  • A named reviewer signs off every statutory filing.
  • Documents move through an access-controlled portal rather than email.

If you already have an adviser, we will tell you what they should be asking rather than replacing them.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

Foreign account reporting — what this page covers

If you came here for foreign account reporting, this is where it is dealt with. The subject is Form 8991, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

It attacks the deduction, not the profit: intercompany service fees, royalties and interest that are perfectly priced can still trigger a minimum tax, which changes how a group funds and charges its US entity.

From first contact to filed return

  1. Upload the file as it stands

    A secure link arrives after the first call. Incomplete is fine; that is what the review is for.

  2. The number is settled up front

    Priced from your own documents and confirmed in writing before any preparation begins.

  3. Both returns on one desk

    One engagement covers every country the file touches, reconciled line against line.

  4. Your approval, then the filing

    The return is yours to check first. We file once you say so.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

The vocabulary this page leans on

Tax protection
A policy under which the employee is reimbursed only if the assignment leaves them worse off, keeping any windfall.
Staking reward
Consideration received for participating in a network, generally an income event valued at receipt and becoming the cost base for a later disposal.
Green card test
The rule that makes a lawful permanent resident a US tax resident for as long as the status is valid, whether or not they live in the United States.
Resale price method
A method testing the gross margin earned by a reseller, sensitive to consistent classification between cost of sales and operating expense.
form 8991 beat: Our analysis

It attacks the deduction, not the profit: intercompany service fees, royalties and interest that are perfectly priced can still trigger a minimum tax, which changes how a group funds and charges its US entity.

The engagement terms hold no matter what the analysis finds — fee and scope agreed in writing up front, a named reviewer on the output, your approval before the finished work is filed.

Form 8991 beat — what the published fees look like

A first-year file often costs more than the ones that follow, because the entry question, whether the company is within BEAT at all, is answered once and then carried forward. Where the answer is yes, groups usually want the funding and charging arrangements looked at as well, and that is quoted as its own piece of work.

T1134 foreign affiliate reporting

$999fixed, before work starts

Covers: The foreign affiliate return with a full set of schedules per affiliate, restated onto the basis the return requires rather than the basis the local accounts use.

What makes it bigger: The number of affiliates and the tiers between them. Work scales with entity count, not with revenue, and lower-tier affiliates each need their own reporting.

See this fee page

Transfer pricing — local file

$2,500fixed, before work starts

Covers: The local file for one entity: functional analysis, method selection with the alternatives explained, comparables with the search documented, and the results tested against the range.

What makes it bigger: The number of transaction types. Goods, services, royalties and financing are four analyses rather than one, and each needs its own method and its own comparables.

See this fee page

What working with us on form 8991 beat looks like

The order of filing is planned, not improvised

Which return goes first decides whether relief can be claimed at all. That sequence is worked out before anything is submitted.

We say early if it is not our work

If a file needs something this practice does not do, you hear that at the start rather than after a bill.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

The firm’s founder at his desk in the Delhi office

How the engagement runs, phase by phase

Step 1

The opening call

A first call to map the obligations across every country involved

Step 2

Scope in writing

A single fixed fee covering the whole set, agreed before we begin

Step 3

Prepared and checked

Preparation in the order that makes the relief usable, with a reviewer's sign-off

Step 4

Filed, then supported

You approve the finished work, and we file it

The team at work in the open-plan office

How the work runs — quote first, then the work

  • Step 1: Documents first, questions second – We read the file before asking anything, so the questions we do ask are the ones that matter.
  • Step 2: A quote you can hold us to – Fixed in writing against a defined scope. No hourly meter, and no revision after the fact.
  • Step 3: The order of filing decided deliberately – Which return goes first can decide whether relief is available at all. That is planned, not discovered.
  • Step 4: Nothing filed without your sign-off – You see the completed work, ask what you need to, and approve it before submission.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

The rest of this practice

Every link below is a full page of its own — the same depth as this one, for its own subject.

Services these clients use most

Form 5471 — controlled foreign corporation, US international tax Everything on international tax form 5471, at the same depth as this page.
Form 8288 — FIRPTA withholding return Form 8288 FIRPTA withholding — the guide, the FAQ and the fixed fee.
Credit method vs exemption method under Indian DTAAs The full guide to credit method vs exemption method under Indian dtaas, with the fee fixed before any work starts.
Indian GST registration for foreign suppliers Its own page: Indian GST registration for foreign suppliers — mechanism, deadlines and published fees.
Form ITR-2 — NRIs with capital gains (India) Everything on ITR-2 India, at the same depth as this page.
Economic nexus thresholds by state Economic nexus thresholds by state — the guide, the FAQ and the fixed fee.
Form T2062C — section 116 notification The full guide to t2062c section 116 notification, with the fee fixed before any work starts.
Second opinion on an existing structure Its own page: second opinion on an existing structure — mechanism, deadlines and published fees.
Indian company setting up in Canada Everything on Indian company setting up in Canada, at the same depth as this page.

Clients who arrive with this exact page

Tax for freelance designers & writers Everything on freelance designers & writers tax, at the same depth as this page.
Tax for individual athletes — tennis, golf Individual athletes — tennis, golf tax — the guide, the FAQ and the fixed fee.
Seafarers & mariners — what you owe in each country The full guide to seafarers & mariners what you owe in each country, with the fee fixed before any work starts.
Investment funds cross-border tax Its own page: investment funds cross border tax — mechanism, deadlines and published fees.
Tax for corporate & charter pilots Everything on corporate & charter pilots tax, at the same depth as this page.
App & game studios cross-border tax App & game studios cross border tax — the guide, the FAQ and the fixed fee.
E-commerce & marketplaces cross-border tax The full guide to e-commerce & marketplaces cross border tax, with the fee fixed before any work starts.
Hospitality & franchise groups cross-border tax Its own page: hospitality & franchise groups cross border tax — mechanism, deadlines and published fees.
Tax for translators & interpreters Everything on translators & interpreters tax, at the same depth as this page.

Countries and corridors this work reaches

US–Mexico tax corridor Everything on US Mexico tax, at the same depth as this page.
Nigeria tax for expats — country guide Nigeria tax for expats — the guide, the FAQ and the fixed fee.
Cyprus tax for expats — country guide The full guide to Cyprus tax for expats, with the fee fixed before any work starts.
Sweden tax for expats — country guide Its own page: Sweden tax for expats — mechanism, deadlines and published fees.
India–Singapore tax corridor Everything on India Singapore tax, at the same depth as this page.
US–UAE tax corridor US UAE tax — the guide, the FAQ and the fixed fee.
Lithuania tax for expats — country guide The full guide to lithuania tax for expats, with the fee fixed before any work starts.
South Korea tax for expats — country guide Its own page: South Korea tax for expats — mechanism, deadlines and published fees.
Canada–Australia tax corridor Everything on Canada Australia tax, at the same depth as this page.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

Files that look like this one

Case study 1

Fifteen Per Cent Held Back From a Fee for Services in Canada

A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.

Read how this one runs
Case study 2

Wintering in the US Long Enough to Become a US Filer

Days in the United States accumulate across three years, and enough of them make you a US resident for tax regardless of immigration status. The file counts the days properly and files the statement that keeps the position closer connection rather than residence.

Read how this one runs
Case study 3

Accounts Reported Late When the Income Already Was

Where the income was on the return and only the account report was missed, a narrow route allows late filing with a reason attached. It is open only while no income is unreported and no examination has begun, which is why it is checked first.

Read how this one runs
Case study 4

Treaty Relief Claimed on a Cross-Border Estate

The estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.

Read how this one runs
Case study 5

A Penalty Argued on the Facts Rather Than the Form

Reasonable cause is a documented story with dates, not an assertion of good intent. The engagement assembles what the client actually knew and when, and puts the sequence in writing alongside the filings it explains.

Read how this one runs
Case study 6

Green Card Kept, Moved to Canada — Both Returns Still Due

Holding a green card does not end the US filing obligation, and living in Canada starts a Canadian one. The engagement fixes residence under the treaty tie-breaker, then decides which return the relief is claimed on so the two do not contradict each other.

Read how this one runs
Case study 7

Coming Back to Canada After Years Abroad

Returning restarts Canadian residence and re-values what you own on the day you arrive. Foreign pensions, employer plans and accounts opened abroad each land differently, and the reporting thresholds are tested against the whole portfolio rather than each account.

Read how this one runs
Case study 8

Three Countries in One File and Two Treaties That Disagree

Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.

Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

Form 8991 — questions we are asked

Do I file Form 8991 even if no tax is owed?

Information return obligations of this kind are generally required on the facts rather than on the tax result, so a nil position does not remove one. US corporations above the applicable receipts threshold with material deductible payments to foreign affiliates.

What happens if I have missed Form 8991 for several years?

Missed years are dealt with as a package rather than one at a time, because the route chosen for the first year affects the relief available for the rest. We map the years and the obligations before anything is filed.

Is Form 8991 the same as the other reports I already file?

No. Computes the base-erosion minimum tax on deductible payments made by a large US corporation to related foreign parties. Satisfying a different obligation, even one covering the same accounts or entity, does nothing for this one.

Do I need to report a foreign business I own?

Almost certainly, and on more than one form. Canada requires reporting of foreign affiliates on the T1134; the United States has a family of returns keyed to the entity type and your level of control, and several carry penalties that apply whether or not any tax is owed. These are information returns, so the obligation follows the ownership rather than the profit. See T1134.

What is double taxation in a corporation?

That is the economic form: the company pays tax on its profit, then the shareholder pays tax again on the dividend distributed out of that same after-tax profit. Domestic systems soften it with dividend credits or reduced rates on distributions; across borders it is compounded by withholding tax in the paying country. Which relief applies turns on the entity type and the treaty article covering dividends. See repatriating profits.

What is OECD Pillar Two?

A global minimum effective tax for large multinational groups, delivered through top-up taxes rather than a single global rate. Where a group's effective rate in a jurisdiction falls below the agreed minimum, the shortfall is collected — by the parent jurisdiction under the income inclusion rule, by the source jurisdiction under a domestic top-up, or as a backstop by other jurisdictions. Canada has enacted implementing legislation. The compliance burden is data, long before it is tax. See BEPS and Pillar Two.

Meet us in person at any of our offices

Let us take Form 8991 off your desk

One call to the 24-hour helpline is enough to tell you what has to be filed, what it costs, and whether you need us at all.

  • Offices in India, the USA, Canada and the UAE
  • A named reviewer signs off every filing
  • Fixed fees agreed before work starts

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068