By Heather Ripley ( March 28, 2018, 6:48 PM EDT) -- Perhaps discontented with the repeal of the corporate alternative minimum tax, Congress introduced in the Tax Cuts and Jobs Act a minimum tax with an international flair. New Internal Revenue Code Section 59A's base-erosion anti-abuse tax, or BEAT, aims to prevent large corporate taxpayers from using deductible payments to offshore affiliates (especially those in low- or no-tax jurisdictions) to reduce their U.S. taxable income below 10 percent. Born of the worldwide frustration that animated the Organization for Economic Cooperation and Development initiative against base-erosion and profit-shifting (BEPS) and other countries' unilateral measures such as the United Kingdom's diverted profits tax, the TCJA's new BEAT is more than a little off....