Companies facing the base erosion and anti-abuse tax can buy transferable credits up to a point. This calculator finds that point using your own numbers.
BEAT applies a 10.5% floor to modified taxable income, and most transferable credits do not bring that floor down.
This calculator shows how much transferable credit a company facing BEAT can buy before the floor starts taking value back. It runs on the section 59A add-back mechanics, including the 80% treatment of applicable section 38 credits that the One Big Beautiful Bill Act made permanent for tax years beginning after December 31, 2025.
The calculator shows:
The credit volume that holds BEAT at zero, and the volume beyond which the purchase turns net-negative, plotted against net gain and loss.
A line-by-line calculation of preliminary BEAT, the credit add-back, adjusted tax liability, and the net economic result at your purchase price.
How the answer changes between BEAT-friendly credits (sections 45(a) and 48) and everything else (45Y, 48E, 45Q, 45Z).
For illustration only. The calculator covers current-year effect, before carryforwards, timing, risk, transaction costs, and state tax, and it is not tax advice. Full assumptions are listed at the bottom of the tool.
BEAT analysis
BEAT credit purchase calculator
Plug in the company's numbers to see how much of a transferable credit it can buy before BEAT bites, and before the purchase stops adding value. Dollar figures in $M. For illustration only, not tax advice.
Company financials
Tax rates
Tax credits
Transferable purchase
Calculation
APreliminary BEAT, the floor
BRegular tax liability, before credits
E§41 research credit, 100% protected
FApplicable §38 credits, BEAT-friendly
CCredits applied (transferable + §41)
DCredit add-back = E + 80% × min(F, A − (B − C + E))
AAdjusted tax liability (B − C + D)
ABEAT top-up owed, A − (B − C + D)
ARegular tax liability, after credits
Value to the business from the transferable purchase
ACredit value realized this year
APrice paid for the credit
ANet economic result
BEAT Payment Due = A − (B − C + D)
D = E + 80% × min[ F, A − (B − C + E) ]
where BEAT Payment Due, (B − C + D), and (B − C + E) do not go below zero
A
Preliminary BEAT
B
Regular Tax Liability
C
Credits
D
Credit Add-back: 100% of any §41 research credit plus 80% of the lesser of (a) the Applicable §38 Credits or (b) Preliminary BEAT − (Regular Tax Liability − Credits + §41 research credit)
E
§41 research credits
F
Applicable §38 Credits
Assumptions: the company is an applicable taxpayer under section 59A(e); §41 research credits are treated as 100% protected in the BEAT add-back, and the §38 add-back is 80% of the lesser of the applicable §38 credits or the base erosion minimum tax computed without the add-back (section 59A(b)(1)(B)(ii)(II)); credits do not drive regular tax liability below zero and the section 38(c) limit is not binding; the purchase price is nondeductible (section 6418(b)(3)). Current-year effect only, before carryforwards, timing, risk, transaction costs, and state tax.
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