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TaxNewsFlash-United States — KPMG's reports of tax developments in the United States

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TaxNewsFlash-United States

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Recent Articles

February 2020

Feb 21 - Proposed regulations: Deductibility of business meal expenses (text of regulations)

Feb 21 - IRS releases updated instructions for Form 1065 (2019)

Feb 21 - Notice 2020-13: Housing expense limit adjustments, foreign locations for 2020

Feb 21 - Rev. Proc. 2020-13: Guidance for farmers on uniform capitalization rules

Feb 20 - Proposed regulations pending OIRA review: Like-kind exchanges

Feb 20 - Proposed regulations pending OIRA review: Net operating loss (NOL) deduction

Feb 19 - IRS reminder: Revised Form W-4, new filing addresses for Form 941

Feb 19 - Notice 2020-12 and Rev. Proc. 2020-12: Carbon oxide sequestration credit under section 45Q

Feb 18 - KPMG report: Contractor’s “substantial rights” for research tax credit (U.S. Tax Court)

Feb 17 - KPMG reports: Michigan (bank’s claim for sales tax refunds); Ohio (public utility excise tax) Washington State (B&O tax, state school)

Feb 14 - Corrections to final regulations, transfers to partnerships with related foreign partners

Feb 13 - KPMG report: Insights on OECD’s revised “Unified Approach” to tax challenges of digitalisation

Feb 13 - KPMG report: OECD transfer pricing (final) guidance on financial transactions: Initial impressions

Feb 13 - IRS updates and corrects FAQs for QI / WP / WT

Feb 12 - Washington State: Legislation revises B&O tax surcharge

Feb 11 - Proposed regulations: Federal income tax withholding from employee wages

Feb 11 - IRS updates FAQs for QI / WP / WT

Feb 10 - Proposed regulations pending OIRA review: Business interest deduction limitation

Feb 10 - Rev. Rul. 2020-05: Adjustments to basis for life insurance contracts

Feb 10 - IRS practice unit: Interest capitalization for self-constructed assets

Feb 10 - Trump Administration budget proposals for FY 2021

Feb 10 - KPMG report: Nexus, taxation of remote sales, marketplace facilitators (GA, NE, NC, WV)

Feb 10 - KPMG reports: Arizona (mining); Colorado (vehicle-sharing service); Louisiana (passthrough entities); Massachusetts (software)

Feb 7 - PLR: Reimbursement payments, qualifying income for REIT’s 95% income test only

Feb 7 - Puerto Rico: Transition to “SURI” (Internal Revenue Integrated System), updates

Feb 7 - U.S. Treasury quarterly list, countries cooperating with international boycott (no changes)

Feb 5 - Regulations on business interest limitation under section 163(j); OIRA review completed

Feb 4 - Final regulations: Employer-provided vehicles, fleet average and cents-per-mile valuation rules

Feb 4 - Regulations pending OIRA review: Denial of deduction for fines, penalties

Feb 3 - KPMG reports: Kansas (sales tax, telecommunications provider); Utah (tax reform provisions repealed); Washington State (B&O surcharge delayed); multiple states (compact to limit incentives)

January 2020

Jan 31 - IRS update on “micro-captive insurance transactions”

Jan 31 - Louisiana: Online marketplace not a “dealer” required to collect parish sales taxes

Jan 29 - Final regulations: Return due dates, extended due date amendments

Jan 29 - Puerto Rico: Deductible expenses, alternative basic or alternative minimum tax for 2019

Jan 29 - Rev. Rul. 2020-4: Low-income housing credit

Jan 28 - IRS practice unit: Overview of the enhanced oil recovery tax credit

Jan 28 - KPMG report: Highlights of recent tax law changes for the healthcare industry

Jan 27 - IRS reminder: First oil spill liability tax due by January 29, 2020

Jan 27 - U.S. trade court: “Substitution drawbacks” of wine companies

Jan 27 - KPMG report: Expanded scope of $1 million section 162(m) deduction limitation on certain executive compensation, proposed regulations

Jan 27 - KPMG report: Remote sellers and marketplace facilitators update (AR, GA, LA, NC)

Jan 27 - KPMG reports: Arkansas (use tax, trailers); Massachusetts (sales tax remittances); New York (tax on data-related income)

Jan 24 - Notice 2020-6: Relief for reporting required minimum distributions for IRAs for 2020

Jan 23 - IRS offers tax relief for taxpayers affected by Puerto Rico earthquakes

Jan 23 - KPMG report: Year-in-review list of U.S. federal tax developments for 2019 (as reported in TaxNewsFlash)

Jan 23 KPMG report: Analysis and observations about final regulations and future of opportunity zone investments

Jan 22 - IRS posts “training materials” on the 2017 U.S. tax law

Jan 22 - IRS practice unit: FDAP payments – Statistical sampling and projection procedures 

Jan 22 - KPMG report: Global withholding taxes, income and gains from listed securities (2019)

Jan 21 - IRS guidance on Form 8038-CP for bond issuers requesting tax credit payments

Jan 21 - Update on France’s digital services tax

Jan 21 - U.S. Tax Court: IRS written supervisory approval required, trust fund recovery penalty under section 6672

Jan 21 - Washington State: Home improvement retailer entitled to bad debt deduction (court decision)

Jan 20 - KPMG report: Tax planning guide 2020, for individual taxpayers

Jan 20 - KPMG report: Remote sellers and marketplace facilitators update (D.C., Georgia, Iowa, Kansas, Maryland, Nebraska)

Jan 20 - KPMG reports: California (corporate tax rates); New Jersey (pass-through alternative taxation); Virginia (federal tax conformity); Washington State (online research services)

Jan 17 - IRS to consider relief from double taxation related to section 965 repatriation

Jan 17 - Final regulations: Transfers to partnerships with related foreign partners (text of regulations)

Jan 17 - Inflation adjustment factors, Indian coal production credits for 2018 and 2019

Jan 17 - Notice 2020-4: Extension of temporary dyed fuel tax relief, Wisconsin terminals

Jan 16 - IRS to restore sequestered funds (AMT only) to businesses pursuant to OMB determination

Jan 16 - U.S. Tax Court: Written supervisory approval for penalty required before first formal communication to taxpayer 

Jan 15 - Regulations pending OIRA review: Implementing “carried interest” measures

Jan 15 - Proposed regulations on cloud-computing, digital-content transactions; public hearing scheduled

Jan 15 - Notice 2020-8: Biodiesel, renewable fuel credits for 2018-2019

Jan 15 - Alabama and Ohio: Financial institutions-related tax changes effective 2020

Jan 14 - Regulations concerning nuclear decommissioning costs; OIRA review completed

Jan 14 - Tenth Circuit: No redemption rights following sales to enforce federal tax liens

Jan 13 - KPMG report: SEC comments on accounting for income taxes

Jan 13 - KPMG report: Remote sellers and marketplace facilitators update (Alaska, Illinois)

Jan 13 - KPMG reports: Colorado (use tax, licensing agreements); Michigan (holding company); Missouri (telecommunication, license tax)

Jan 10 - Proposed regulations: Revised applicability date for regulations under section 382(h) related to built-in gain, loss

Jan 9 - Puerto Rico: Tax relief for taxpayers affected by January 2020 earthquakes

Jan 8 - U.S. Tax Court: UK entity’s income from work on U.S. outer continental shelf held taxable

Jan 8 - Utah: Corporate tax rate reduction, sales tax changes

Jan 8 - Reminder of energy-related excise tax extenders enacted in late 2019

Jan 8 - IRS National Taxpayer Advocate report for 2019

Jan 6 - U.S. public hearing concerning France’s digital services tax

Jan 6 - U.S. Tax Court: Requirement for IRS supervisory approval before penalty assessments

Jan 6 - TTB reminder, federal excise tax return filing dates for 2020

Jan 6 - KPMG report: Sales tax obligations of marketplace facilitators (Michigan, Missouri, Florida)

Jan 6 - KPMG reports: California (goodwill); Louisiana (sales tax, online sales)

Jan 3 - Oregon: Corporate activity tax, effective January 1, 2020

Jan 3 - Rev. Rul. 2020-2: Covered compensation tables for 2020 plan year

Jan 2 - IRS releases annual revenue procedures for 2020

Jan 2 - KPMG report: State and local tax, technology-related guidance (table, fourth quarter 2019)

2019 Articles

December 2019

Dec 31 - Final regulations for opportunity zones are released to Federal Register

Dec 31 - Notice 2020-5: Standard mileage rates for 2020

Dec 30 - KPMG report: Final regulations on withholding and reporting income to foreign persons (initial impressions)

Dec 30 - Craft beverage excise tax provisions extended through 2020; wine credit transfers

Dec 27 - Changes proposed in 2019 draft instructions for Form 1065 and Schedule K-1

Dec 27 - Final regulations under FATCA; taxpayer burden reduction

Dec 23 - Proposed regulations: Source of income for certain sales of personal property, inventory (text of regulations)

Dec 21 - KPMG report: Tax provisions enacted in December 2019 appropriations legislation

Dec 20 - KPMG report: Initial impressions of final regulations for opportunity zones

Dec 20 - FBAR filings: Deadline again extended for individuals with signature authority

Dec 20 - New Jersey: REITs, RICs, and investment companies excluded from unitary combined group for 2019 and beyond

Dec 20 - Texas: Franchise tax, economic nexus rule is finalized

Dec 20 - KPMG report: Analysis of final and proposed foreign tax credit regulations

Dec 19 - Final regulations: Opportunity zones (text of regulations and FAQs)

Dec 19 - Final regulations: Defining predecessor, successor and limiting recognition of gain under section 355(e) (initial impressions)

Dec 19 - KPMG report: Simplifications to accounting for income taxes

Dec 19 - Proposed regulations: Misdirected direct-deposit refunds

Dec 18 - Regulations pending OIRA review: Business interest limitation under section 163(j)

Dec 18 - KPMG report: State, local tax changes; yearly summary for 2019 (table format)

Dec 18 - Notice 2020-3: Default rate of withholding, periodic payments including retirement and annuity distributions

Dec 17 - KPMG report: Proposed regulations under section 162(m) to address tax law changes (initial impressions)

Dec 17 - Regulations pending OIRA review: Hybrid dividends and payments

Dec 16 - Final regulations: Defining predecessor, successor and limiting recognition of gain under section 355(e) (text of regulations)

Dec 16 - Proposed regulations: Deduction for employee remuneration in excess of $1 million (text of regulations)

Dec 16 - Notice 2020-2: Extended phase-in provisions under section 871(m) regulations

Dec 16 - Rev. Proc. 2020-10: Third six-year remedial amendment cycle, pre-approved defined benefit plans

Dec 16 - KPMG report: Section 409A and equity compensation

Dec 16 - KPMG report: Year-in-review (2019), qualified plan guidance

Dec 16 - KPMG reports: Nebraska (GILTI, FDII); Pennsylvania (sales tax); Texas (gaming machines); Washington State (wooden pallets)

Dec 16 - Regulations relating to foreign tax credits released to Federal Register

Dec 16 - Final regulations: Dividend equivalents from sources within the United States (text of regulations)

Dec 13 - Proposed regulations: Payments made to charities in return for consideration

Dec 12 - Rev. Proc. 2020-9: Extended deadline, plan amendments and hardship distributions

Dec 12 - KPMG report: Analysis of final regulations and additional proposed regulations under section 59A (“BEAT”)

Dec 11 - IRS and TTB agree to whistleblower process regarding federal excise taxes

Dec 10 - Notice 2019-67: Mortality rates, tables for defined benefit pension plans (2021)

Dec 9 - Notice 2019-66: Relief from broad partner tax basis capital account reporting for 2019

Dec 9 - KPMG report: “BEAT” final regulations, provisions applicable to insurance companies

Dec 9 - KPMG reports: California (franchise tax returns); Chicago (tax rate increases); Iowa (federal tax conformity); South Carolina (taxable delivery charges); Washington State (computing activities)

Dec 9 - Final regulations on opportunity zones, pending OIRA review

Dec 6 - Notice 2019-65: Regulations under section 987, additional deferral of effective date

Dec 6 - Rev. Rul. 2019-28: No change to interest rates on tax underpayments, overpayments

Dec 5 - Proposed regulations, payments made to charitable entities; OIRA review completed

Dec 5 - Regulations pending OIRA review: Special rules for nuclear decommissioning costs under section 468A

Dec 4 - OECD responds to U.S. Treasury’s letter on digital services tax

Dec 4 - Treasury opposition to digital services tax initiatives, support for Pillar One

Dec 4 - California: Disregarded limited partnerships no longer subject to filing requirement or annual tax (possible refund opportunities)

Dec 4 - Notice 2019-64: Required amendments list (2019) for qualified retirement plans

Dec 3 - KPMG report: Initial impressions about final and proposed foreign tax credit regulations

Dec 2 - KPMG report: Initial impressions, final regulations and additional proposed regulations under section 59A (“BEAT”)

Dec 2 - U.S. conclusions, trade-related investigation of France’s digital services tax 

Dec 2 - Regulations: Foreign tax credits (text of regulations)

Dec 2 - Regulations implementing BEAT rules (text of regulations)

Dec 2 - Notice 2019-63: Health coverage information-reporting deadline extension

November 2019

Nov 27 - IRS guidance on BBA field exam procedures, partnership returns

Nov 27 - U.S. trade-related report on France’s digital services tax expected next week

Nov 26 - Rev. Proc. 2019-48: Rules for using per diem rates to substantiate expenses incurred away from home

Nov 25 - KPMG reports: California (sales factor); Illinois (sales factor); Massachusetts (tax incentives); Ohio (responsible person)

Nov 22 - Final regulations: Basic exclusion amount, estate and gift taxes (text of regulations)

Nov 22 - Fifth Circuit: No bad debt deduction for payment made to address subsidiary’s undercapitalization

Nov 22 - IRS offers tax relief for taxpayers affected by South Dakota storms

Nov 22 - Tier 2 tax rates for railroads, no changes for 2020

Nov 21 - Ninth Circuit’s decision upholding section 482 stock-based compensation regulations is final

Nov 18 - Final regulations: Ownership-attribution rules for persons related to CFC; rents derived in active conduct of trade or business

Nov 18 - KPMG reports: Arkansas (digital downloads); California (nonresidents); Indiana (software); Tennessee (car subscription service)

Nov 15 - Proposed regulations: Transparency in health plans, insurance coverage

Nov 15 - TTB voluntary disclosure program for unreported changes in control or proprietorship

Nov 15 - KPMG report: 2019-2020 priority guidance plan and REITs

Nov 15 - KPMG report: Private letter rulings concerning REITs in 2019

Nov 14 - Rev. Proc. 2019-46: Business standard mileage rate rules reflecting 2017 tax law changes

Nov 13 - KPMG report: OECD proposal under Pillar Two; addressing tax challenges of digitalisation of the economy

Nov 13 - North Carolina: Market-based sourcing and marketplace-facilitator legislation enacted

Nov 13 - Notice 2019-60: Additional temporary nondiscrimination relief through 2020, closed defined benefit plans

Nov 12 - KPMG report: Comments on “Pillar One” approach to address digital economy tax issues

Nov 12 - Ninth Circuit denies en banc rehearing, section 482 stock-based compensation case

Nov 12 - IRS focus on “syndicated conservation easement” transactions

Nov 12 - IRS releases draft instructions for BBA partnership forms

Nov 11 - BEAT proposed and final regulations; OIRA review completed

Nov 11 - KPMG report: Rules for defined compensation arrangements under section 409A

Nov 11 - KPMG report: Sale of partnership interests resulting in ordinary income

Nov 11 - KPMG reports: Indiana (sales tax, medical records); Nebraska (remote sellers); New Mexico (apportionment, trucking companies); Virginia (interest limitation); Wisconsin (sales tax, CLE seminars)

Nov 8 - Final regulations: Health insurance providers fee, electronic filing requirements

Nov 8 - Rev. Proc. 2019-43: List of automatic changes, accounting methods

Nov 7 - Proposed regulations: Updated life expectancy, distribution period tables for retirement plans

Nov 7 - Second Circuit: Untaxed cigarettes manufactured by and sold on Indian reservation

Nov 6 - Notice 2019-59: Pension plans, cost-of-living adjustments for 2020

Nov 6 - Rev. Proc. 2019-44: Inflation adjustments for 2020, individual taxpayers

Nov 6 - IRS practice unit: Examining taxpayers electing partial disposition of building

Nov 6 - Proposed regulations: Eligible terminated S corporations (initial impressions)

Nov 6 - IRS adds new compliance campaign on cross-border activities (LB&I division)

Nov 4 - Proposed regulations: Eligible terminated S corporations (text of regulations)

Nov 4 - TTB excise tax penalty relief for industry affected by California wildfires

Nov 4 - KPMG reports: Florida (rental real estate); Illinois (advisory services); Maryland (transfer taxes); Massachusetts (patent infringement); Wisconsin (software)

Nov 1 - PLR: Amounts REIT receives from tenants for boat slips, marina storage

Nov 1 - KPMG report: Removal of documentation rules under section 385; future proposed regulations may eliminate per se funding rule

October 2019

Oct 31 - “Documentation regulations” under section 385 are removed; new regulations to be proposed

Oct 31 - Draft of revised Form 8996 for reporting opportunity zone fund data

Oct 31 - Foreign tax credit regulations; OIRA review completed

Oct 30 - Regulations pending OIRA review: Payments to charitable entities in return for consideration

Oct 29 - Final regulations: Information reporting of reportable sales of life insurance contracts, of death benefit payments; initial impressions

Oct 28 - U.S. Tax Court: APAs cancelled; no transfer pricing adjustments and taxpayer not liable for 40% penalty

Oct 28 - U.S. Tax Court: Charitable donation denied, conservation easement not “protected in perpetuity”

Oct 28 - U.S. Tax Court: Notice of deficiency held invalid when two separate, but related, corporations identified

Oct 28 - KPMG report: Guidance on nexus, taxation of remote sales by U.S. states (Arizona, Hawaii, Louisiana, Michigan, North Carolina, South Carolina)

Oct 28 - KPMG reports: Massachusetts (corporate excise tax); Ohio (municipal tax); Wyoming (asset purchase, sales tax)

Oct 25 - Final regulations: Information reporting under section 6050Y; reportable sales of life insurance contracts and death benefit payments

Oct 24 - KPMG report: Proposed regulations address TCJA gross income acceleration requirement

Oct 23 - IRS practice unit: Evaluation of withholding agent’s electronic books and records, reliability of Forms W-8 

Oct 22 - Regulations on interest in corporations as stock or indebtedness (OIRA review completed)

Oct 22 - Regulations to update tables for required minimum distribution rules, section 401(a)(9) (OIRA review completed)

Oct 21 - KPMG reports: Colorado (Boulder’s marketplace guidance); New Jersey (unitary business); Ohio (CAT election); Texas (franchise tax nexus)

Oct 17 - IRS directive, work opportunity tax credit (WOTC)

Oct 14 - KPMG report: Marketplace guidance, sales and use tax (California, Maine, Massachusetts, Texas)

Oct 14 - KPMG reports: Louisiana (GILTI); Washington State (B&O tax)

Oct 11 - Final regulations: Timing of losses related to federally declared disasters

Oct 11 - Notice 2019-58: Treatment of certain interests in corporations as stock or indebtedness, expiration of temporary regulations

Oct 11 - IRS nonacquiescence, transfer of non-capital asset; capital asset sale or exchange treatment

Oct 10 - IRS Chief Counsel Attorney Memorandum advises election under section 952(c) is obsolete (implications for insurance companies)

Oct 9 - Regulations pending OIRA review: Stock or indebtedness, interest in corporations

Oct 9 - Delaware: Additional unclaimed property audit notices and voluntary disclosure program invitations

Oct 9 - IRS priority guidance plan for 2019-2020

Oct 9 - IRS reminder: QI, WP, WT application deadline, November 15, 2019

Oct 9 - Proposed regulations: Contribution limits applicable to ABLE accounts

Oct 9 - Rev. Rul. 2019-24: Tax treatment of transactions involving cryptocurrency

Oct 9 - U.S. Treasury’s quarterly list, countries cooperating with international boycott (no changes)

Oct 8 - Proposed regulations: Transition from interbank offered rates (IBORs) to other reference rates

Oct 8 - Public hearing scheduled; regulations on dividends received deduction limitations from controlled foreign corporations

Oct 8 - Puerto Rico: Electronic filing requirements of Forms W-2 for tax year 2019

Oct 7 - IRS provides tax relief for taxpayers affected by Tropical Storm Imelda

Oct 7 - KPMG report: Marketplace guidance, sales and use tax (Maryland, Wisconsin)

Oct 7 - KPMG reports: Kansas (remote sellers); Maryland (pre-merger NOLs); Massachusetts (interest limitation); Pennsylvania (economic nexus)

Oct 4 - Final regulations for partnerships: Disguised sales; recourse liabilities under section 752 (text of regulations)

Oct 4 - Regulations pending OIRA review: Foreign tax credit guidance

Oct 3 - KPMG report: Initial impressions of proposed regulations addressing repeal of section 958(b)(4); relief provided by Rev. Proc. 2019-40

Oct 3 - KPMG report: Changes proposed in draft versions, Form 1065 and Schedule K-1 for 2019

Oct 1 - IRS guidance limits reach of life insurance reserve election

Oct 1 - KPMG report: Nonresident state income tax withholding, cross-border business travelers

Oct 1 - Proposed regulations, Rev. Proc. 2019-40: Relief provided concerning repeal of section 958(b)(4) (text of regulations)

September 2019

Sep 30 - IRS releases draft versions of Forms 1065, 1120-S for 2019 tax year

Sep 30 - Rev. Proc. 2019-39: Recurring remedial amendment periods for correcting section 403(b) plans

Sep 30 - Notice 2019-54: More time for drought-affected farmers, ranchers to replace livestock

Sep 30 - KPMG reports: New Hampshire (business tax rates); Rhode Island (equipment leasing); Utah (referral business not marketplace facilitator)

Sep 27 - Proposed regulations: Employer shared-responsibility provisions, health reimbursement arrangements

Sep 27 - Rev. Rul. 2019-22: Fringe benefit aircraft valuations, second half 2019

Sep 26 - Federal Circuit: Alternative mixture fuel credit denial upheld

Sep 26 - Regulations on eliminating interbank offered rates (OIRA review completed)

Sep 26 - IRS releases “tax gap” estimates

Sep 25 - Notice 2019-55: Per diem rates, substantiation of employee lodging, meals, incidentals (2019-2020)

Sep 25 - Tax relief for taxpayers affected by storms in Mississippi (February-March 2019)

Sep 25 - KPMG report: State, local tax changes (third quarter 2019, table)

Sep 24 - Rev. Proc. 2019-38: Section 199A “safe harbor” for rental real estate

Sep 23 - KPMG report: Remote seller and marketplace guidance, sales and use tax (Alabama, Florida, Louisiana, Massachusetts)

Sep 23 - KPMG reports: Nebraska (IRC section 965); Vermont (federal tax reform conformity); Virginia (use tax, equipment leased from affiliate)

Sep 20 - Tax treaty update: Protocol to United States-Luxembourg income tax treaty is ratified

Sep 20 - Tax treaty update: Protocol to United States-Switzerland income tax treaty is ratified

Sep 19 - Final regulations: Hardship distributions from section 401(k) plans (text of regulations)

Sep 19 - U.S. agencies propose rule to implement 2% withholding tax on certain foreign payments

Sep 19 - U.S. contractors, exemption from Afghanistan taxes

Sep 17 - Regulations: Additional first-year depreciation deduction (regulations released to Federal Register)

Sep 17 - Regulations under section 59A or “BEAT” provisions (pending OIRA review)

Sep 17 - Notice 2019-52: Low-income housing credit, expanded California wildfire-related disaster relief

Sep 17 - Florida: Reminder of approaching deadline, corporate information reports

Sep 16 - Second Circuit: Jurisdiction of U.S. Court of Federal Claims, claim for overpayment interest

Sep 16 - KPMG reports: Florida (tax rate reduction); New Hampshire (market-based sourcing rules); South Carolina (online marketplace); Texas (retail or wholesale trade)

Sep 13 - KPMG report: Proposed regulations on treatment of built-in items for section 382 (initial impressions)

Sep 13 - Regulations: Additional first-year depreciation deduction (advance release of text of regulations by IRS)

Sep 13 - Final regulations: Additional first-year depreciation (OIRA review completed)

Sep 12 - IRS announces application period for 2020 Compliance Assurance Process (CAP) program

Sep 9 - KPMG reports: Alabama (corporate late-filing relief); Florida (corporate information reports); Georgia (bad debts); Utah (water’s-edge combined group)

Sep 9 - KPMG report: Remote sellers and marketplace nexus guidance (updates from numerous states)

Sep 9 - Proposed regulations: Built-in gains and losses under section 382(h) (text of regulations)

Sep 9 - Regulations: Additional first-year depreciation allowance (OIRA review completed)

Sep 6 - KPMG report: Proposed regulations on changes to income recognition rules; initial impressions

Sep 6 - Rev. Proc. 2019-37: Automatic consent to change method of accounting, section 451 proposed regulations

Sep 6 - Eighth Circuit: South Dakota use tax preempted for certain Indian tribal transactions

Sep 6 - IRS practice unit: French levies eligible for U.S. foreign tax credits

Sep 6 - IRS relief procedures for certain expatriates, U.S. tax law compliance

Sep 5 - Proposed regulations: Timing of income inclusion under section 451 (text of regulations)

Sep 3 - IRS to waive dyed fuel penalty in Florida; hurricane-related relief

Sep 3 - Notice 2019-50: Annual fee imposed on health insurance providers for 2020

August 2019

Aug 30 - Tax treaty update: Protocol to income tax treaty between United States and Japan, entry into force

Aug 30 - Tax treaty update: Protocol to income tax treaty between United States and Spain, entry into force

Aug 29 - Regulations pending OIRA review: Guidance on eliminating interbank offered rates

Aug 29 - Rev. Proc. 2019-36: Foreign insurance companies; effectively connected net investment income (2018)

Aug 28 - Rev. Rul. 2019-21: No change to interest rates for tax overpayments, underpayments (fourth quarter 2019)

Aug 28 - U.S. Tax Court: Taxpayer properly offset interest expenses against real estate income

Aug 28 - Wisconsin: Dividends-received deduction allowed foreign limited partnership under federal check-the-box rules

Aug 27 - Rev. Proc. 2019-23: Updated list of countries, deposit interest paid to nonresident aliens

Aug 27 - Missouri: Extended statute of limitations for sales and use tax refunds (10 years)

Aug 26 - U.S. agreement reportedly reached with France, digital services tax

Aug 26 - KPMG report: Mineral interest income and section 199A deduction

Aug 26 - KPMG report: The “Wyden bill”—a new approach to taxing carried interest

Aug 26 - KPMG reports: California (apportionment); New Jersey (GILTI and FDII); Utah (foreign tax credit)

Aug 23 - Notice 2019-49: Nondiscrimination relief for “closed” defined benefit plans extended through 2020

Aug 22 - Notice 2019-46: Relief for domestic partnerships or S corporations, determining GILTI amounts (initial impressions and observations)

Aug 22 - Proposed regulations: Employer-provided vehicles, fleet average and cents-per-mile valuation rules

Aug 21 - KPMG report: Non-life insurance companies and “BEAT” considerations

Aug 21 - Proposed regulations under section 451(b) and (c); OIRA review completed

Aug 19 - IRS directive on U.S. creditability of two French social taxes; change in IRS position

Aug 19 - U.S. trade-related hearing of France’s digital services tax

Aug 19 - KPMG reports: Florida (GILTI, bonus depreciation); Louisiana (sales tax, medical devices); New York (web-based support services)

Aug 16 - Ninth Circuit affirms Tax Court; intangible assets and valuation in cost-sharing arrangement

Aug 14 - IRS to waive estimated tax penalty automatically for 2018

Aug 14 - Regulations pending OIRA review: Tables for required minimum distribution rules, section 401(a)(9)

Aug 14 - Rev. Rul. 2019-19: Failure to cash retirement plan distribution check does not change gross income

Aug 13 - KPMG report: Initial impressions of cloud-computing, digital-content transactions (proposed regulations)

Aug 13 - IRS releases revised Form 8283 for noncash contributions

Aug 12 - KPMG report: Franchise tax nexus, proposed changes (Texas)

Aug 12 - KPMG reports: California (source of services); Illinois (tax amnesty); Indiana (financial institution tax); Tennessee (IRC section 163(j) limitation)

Aug 9 - Proposed regulations: Classification of cloud-computing transactions, transactions involving digital content (text of regulations)

Aug 9 - KPMG report: Guidance on accounting method change for insurance companies (Rev. Proc. 2019-34)

Aug 6 - Rev. Proc. 2019-34: Simplified procedures for insurance companies to change methods of accounting

Aug 5 - IRS withdraws LB&I directive on cost-sharing arrangements

Aug 5 - KPMG reports: Kansas (remote sellers); Massachusetts (marketplace facilitator); Philadelphia (interest expense limitation)

Aug 1 - KPMG joins amicus brief requesting en banc review by Ninth Circuit (cost-sharing arrangements)

Aug 1 - Reminder: Heavy highway vehicle use tax return (Form 2290) due September 3

Aug 1 - IRS practice unit: Source of income, nonresident alien individuals

July 2019

Jul 31 - Rev. Proc. 2019-33: Relief for bonus depreciation late elections, or revoking prior elections

Jul 29 - KPMG reports: New Jersey (combined reporting); Oregon (corporate activity tax); Oregon (GILTI); Rhode Island (statute of limitations); Tennessee (subpart F income)

Jul 26 - Final regulations for additional first-year depreciation allowance (pending OIRA review)

Jul 26 - IRS notifies virtual currency owners to pay back taxes, file amended returns

Jul 26 - California: Proposals considered, addressing changes to market-based sourcing rules

Jul 25 - Rev. Proc. 2019-32: Extension of time for partnerships filing superseding Forms 1065

Jul 24 - Proposed regulations: Determining built-in gains and losses (OIRA review completed)

Jul 23 - Final regulations: Partnership allocations of foreign income taxes to partners

Jul 23 - IRS adds six new compliance campaigns (LB&I division)

Jul 23 - KPMG report: Section 846 and revised discount factors and guidance on accounting method change (insurance companies)

Jul 22 - G7 finance ministers, agreement on taxation of digital economy

Jul 22 - Rev. Proc. 2019-29: Health insurance premium tax credit, contribution percentage for 2020

Jul 22 - Rev. Proc. 2019-30: Insurance companies, automatic consent for accounting method change

Jul 22 - Rev. Proc. 2019-31: Insurance companies, revised unpaid loss discount factors for 2018 accident year

Jul 22 - KPMG report: States impose tax collection for marketplace facilitators (Ohio, Wisconsin)

Jul 22 - KPMG reports: Kentucky (rental liability fees); Louisiana (BEAT); Maine (unclaimed property); Oregon (corporate activity tax)

Jul 18 - IRS provides tax relief for Texas storm victims

Jul 17 - Final regulations: Partner treated as lessee, when lessor elects to pass through investment tax credits to lessee

Jul 17 - Tax treaty update: U.S. Senate approves Protocols with Switzerland, Luxembourg, Japan

Jul 17 - Notice 2019-45: Expanded list of preventive care for certain chronic conditions (HSA eligibility)

Jul 16 - Tax treaty update: U.S. Senate approves Protocol with Spain

Jul 16 - IRS reminder: Q&As provide guidance about section 965 transition tax

Jul 15 - KPMG report: Certification of professional employer organizations

Jul 15 - KPMG report: States impose tax collection for marketplace facilitators (California, Connecticut, Illinois, Indiana, Pennsylvania, Wisconsin)

Jul 15 - KPMG reports: Missouri (interest expense); Montana (dividends received deduction); San Francisco (gross receipts tax); Texas (franchise tax)

Jul 12 - KPMG report: Proposed passive foreign investment company (PFIC) regulations; initial impressions and observations

Jul 12 - KPMG report: Status of digital services tax legislation, proposals

Jul 12 - Notice 2019-43: Beginning construction “continuity safe harbor” extended for national security concerns (sections 45 and 48)

Jul 11 - IRS relief, taxpayers in Missouri affected by April 2019 storms

Jul 11 - Tax treaty update: Senate expected to consider four Protocols

Jul 11 - Regulations on tax treatment of cloud computing; OIRA review completed

Jul 11 - California: “Loophole closing” legislation adopts certain TCJA changes

Jul 11 - Final regulations: Advance payments for goods, long-term contracts

Jul 11 - Timeline for USTR investigation of France’s digital services tax

Jul 10 - USTR launches Section 301 investigation of France’s proposed digital services tax

Jul 10 - Country-by-country reporting updates from IRS

Jul 10 - Proposed regulations: Passive foreign investment companies (PFICs) and PFIC insurance exception (text of regulations)

Jul 2 - Final regulations: Truncated TINs for wage, tax statements furnished to employees

Jul 2 - Proposed regulations: Multiple employer plans (MEPs)

Jul 1 - IRS updates FAQs on opportunity zones

Jul 1 - Unclaimed property rules for gift cards, gift certificates in Colorado, Washington State

Jul 1 - KPMG report: Sales tax collection requirements for remote sellers, marketplace facilitators (California, Connecticut, Maine, Utah)

Jul 1 - KPMG reports: Louisiana (passthrough entities); Mississippi (apportionment); Oregon (GILTI)

June 2019

Jun 28 - Final regulations: Self-employment tax treatment, partners in partnership that owns disregarded entity (text of regulations)

Jun 28 - Proposed regulations: Section 4968 excise tax, net investment income of colleges, universities (text of regulations)

Jun 28 - IRS provides Q&As concerning section 965 (including transfer and consent agreements)

Jun 28 - Federal Circuit: “Section 1603” cash award, open-loop biomass producing electricity

Jun 27 - Puerto Rico: Sales and use tax holiday, school uniforms and supplies

Jun 26 - New York: Legislation revises GILTI exclusion rules, modifies “Wayfair” threshold

Jun 26 - KPMG report: Excess business loss limitation under section 461(I)

Jun 25 - Tax treaty update: Senate Foreign Relations approves four Protocols

Jun 25 - KPMG report: State, local tax changes (second quarter 2019, table)

Jun 25 - Regulations concerning excise tax on college net investment income (OIRA review completed)

Jun 25 - Notice 2019-42: Opportunity zones designated in Puerto Rico

Jun 25 - KPMG report: Section 199A implications for cooperatives; initial impressions of proposed regulations

Jun 24 - U.S. Senate Finance Committee leaders' letter concerning France’s proposed digital services tax

Jun 24 - KPMG report: IRS position on multiple RAB shares in CSAs

Jun 24 - KPMG report: Opportunity zones and REITs

Jun 24 - KPMG report: States imposing tax collection obligations on remote sellers (Louisiana, Nevada, New Hampshire)

Jun 24 - KPMG reports: Louisiana (NOL ordering rules); San Francisco (proposed tax); Texas (tangible personal property)

Jun 21 - U.S. Supreme Court: In-state beneficiary insufficient for state to tax undistributed trust income

Jun 19 - OIRA review completed: Proposed regulations regarding multiple employer plan (MEP) rules

Jun 19 - KPMG report: Initial impressions of final regulations under section 951A (GILTI) and certain guidance related to foreign tax credits, as well as new proposed regulations under sections 951A and 958 (rules for determining stock ownership)

Jun 19 - KPMG report: Initial impressions of temporary regulations under section 245A; denial of dividends received deduction for certain dividends from current or former CFCs

Jun 18 - KPMG report: Modification of discounting rules for insurance companies (initial impressions about final regulations)

Jun 18 - Notice 2019-27: Guidance for cooperatives and patrons on QBI deduction

Jun 18 - Proposed regulations: Rules under section 199A for cooperatives and patrons (text of regulations)

Jun 18 - Regulations pending OIRA review: Proposed regulations under section 451(b)

Jun 17 - KPMG reports: California (apportionment); New York (royalty payments); Vermont (sales tax sourcing)

Jun 14 - Final regulations: “Global intangible low-taxed income” (GILTI) (text of regulations)

Jun 14 - Regulations: Dividends received deduction limitation when from certain foreign corporations (text of regulations)

Jun 14 - Proposed regulations: Section 958 (determining stock ownership) and section 951A (GILTI) (text of regulations)

Jun 14 - IRS considering new CAP applications; publicly traded corporations must express interest by July 26

Jun 14 - Regulations: Distilled spirits standards, malt beverage labeling rules (OIRA review completed)

Jun 14 - Regulations pending OIRA review: Tax treatment of cloud computing, computer programs, digital content

Jun 13 - Final regulations: Health reimbursement arrangements, account-based group health plans

Jun 13 - Final regulations: Modification of discounting rules for insurance companies

Jun 13 - Final regulations: Nonresident aliens, potential current beneficiaries of electing small business trusts

Jun 13 - KPMG report: Ninth Circuit reverses Tax Court (again), upholds cost-sharing regulations

Jun 13 - IRS practice unit: Allocation of success-based fees in certain acquisitions

Jun 11 - Final regulations: State and local tax credits and charitable contributions (text of regulations)

Jun 11 - D.C. Circuit: Foreign partners and effectively connected income (“Grecian Magnesite” case cited in 2017 tax law)

Jun 11 - OIRA review completed, final regulations on health reimbursement arrangements (HRAs)

Jun 10 - KPMG report: Sales tax obligations of marketplaces, remote sellers (Arizona, Illinois, New York, Tennessee, Vermont)

Jun 10 - KPMG reports: Arizona (federal conformity); Connecticut (sales tax); Illinois (tax rate increases)

Jun 7 - Ninth Circuit reverses Tax Court, validity of cost-sharing arrangement regulations

Jun 6 - Proposed regulations: Exception for U.S. real property interests held by foreign pension funds (initial impressions)

Jun 6 - Proposed regulations: Exception for U.S. real property interests held by foreign pension funds (text of regulations)

Jun 6 - GILTI regulations under sections 951(b) and 951A; OIRA review completed

Jun 6 - JCT overview of GILTI and FDII provisions (sections 250 and 951A)

Jun 5 - Regulations: Dividend received deduction, branch loss recapture (section 245A); OIRA review completed

Jun 5 - Section 45: Renewable electricity, refined coal production inflation factors, reference prices (2019)

Jun 5 - IRS directive, selecting transfer pricing issues involving cost sharing arrangements

Jun 5 - Rev. Rul. 2019-15: Interest rates, tax overpayments and underpayments (third quarter 2019)

Jun 4 - IRS to stop faxing tax transcripts, mailing returns to third parties

Jun 3 - Final regulations: Transfers of property to REITs following corporate distributions

Jun 3 - Regulations concerning SALT credits, charitable contributions; sections 164 and 170(c) guidance (OIRA review completed)

Jun 3 - IRS provides relief for taxpayers affected by Oklahoma storms, flooding

Jun 3 - Minnesota: Corporate conformity legislation, effective retroactively

Jun 3 - KPMG report: Tax collection requirements, remote sellers (Colorado, Maryland, Oklahoma, Tennessee, Texas)

Jun 3 - KPMG reports: Alabama (software sales); Colorado (combined reporting); New Jersey (combined reporting); New York (captive insurance); Ohio (sales tax exemption)

May 2019

May 31 - IRS notices: Oil and gas, marginal well factors, percentage depletion for 2019

May 31 - IRS releases draft Form W-4 for 2020, provides FAQs

May 30 - Proposed regulations: Withholding on distributions, guidance under section 3405

May 30 - Hearing on FDII and GILTI proposed regulations, set for July 10, 2019

May 30 - Regulations pending OIRA review: Proposed regulations under section 245A 

May 29 - Rev. Proc. 2019-25: HSA inflation-adjusted amounts for 2020

May 29 - Alabama: Financial institution excise tax, reform legislation

May 29 - KPMG report: Final regulations, amount determined under section 956 for corporate U.S. shareholders

May 24 - D.C. Circuit: Charitable contribution denied, basis in donated property omitted

May 23 - Final regulations: Certified professional employer organizations (employee leasing companies)

May 23 - Proposed regulations: Passive income exception for foreign insurance companies (OIRA review completed)

May 23 - U.S. Treasury awards $3.5 billion in New Markets Tax Credit (NMTC) allocations

May 22 - Notice 2019-39: Current refundings for certain targeted state, local, Indian tribal government bond programs

May 22 - U.S. Tax Court: Lack of final administrative determination invalidates trust-fund-recovery penalty assessment

May 22 - Delaware: Unclaimed property, voluntary disclosure agreement “invitations” expected soon

May 22 - Final regulations: Amount determined under section 956 for corporate U.S. shareholders (text of regulations)

May 21 - Rev. Proc. 2019-26: Automobile depreciation deduction limits for 2019

May 21 - Kentucky: Deadline to claim deferred tax deduction is July 1, 2019

May 20 - OIRA review: Distilled spirits standards, malt beverage labeling rules (proposed regulations)

May 20 - Proposed regulations: Domestic production activities deduction for agricultural, horticultural cooperatives (OIRA review completed)

May 20 KPMG reports: Florida (GILTI); Hawaii (economic nexus); New Jersey (combined group, minimum tax), Tennessee (GILTI)

May 20 - KPMG report: Remote sellers collecting tax (Louisiana, Virginia)

May 20 - KPMG report: Ownership-attribution rules for CFC related persons; rents from active conduct of trade or business (proposed regulations)

May 17 - Proposed regulations: Ownership-attribution rules for persons related to CFC; rents derived in active conduct of trade or business

May 17 - Oregon: Corporate activity tax bill is signed into law

May 16 - IRS replaces coordinated industry case program with large corporate compliance program

May 16 - Regulations pending OIRA review: Global intangible low-taxed income (GILTI) provisions under sections 951(b) and 951A

May 16 - Regulations pending OIRA review: Excise tax on college net investment income (section 4968)

May 15 - Regulations pending OIRA review: Dividend received deduction (section 245A), branch loss recapture (section 91)

May 15 - Tenth Circuit: S corporation, employees/ESOP beneficiaries held section 267 “related persons”

May 15 - Developments and analysis guide for the 2017 tax law: New KPMG website

May 14 - Proposed regulations: Multiple employer plan (MEP) regulations subject to OIRA review

May 13 - U.S. Supreme Court: States retain sovereign immunity in other state courts (tax audit-related civil action)

May 13 - KPMG reports: Massachusetts (corporate nexus); San Francisco (tax credit, homelessness gross receipts)

May 13 - KPMG report: Sales tax collection obligations of marketplace facilitators (Colorado, Georgia, Indiana, Kansas)

May 13 - KPMG report: Qualified business units (QBUs), foreign currency gain or loss recognition and deferral (report on final regulations)

May 10 - Final regulations: Income, currency gain or loss of “qualified business unit” (section 987)

May 10 - Notice 2019-31: Inflation adjustment factor, carbon oxide sequestration (section 45Q)

May 10 - IRS practice unit: Transaction costs in a corporate separation

May 10 - Colorado: New unclaimed property law; new rules for life insurance companies

May 10 - Texas: Property tax exemption opportunities, pollution control property (Texas Supreme Court decision)

May 9 - Proposed regulations under section 897(I), qualified foreign pension fund requirements (OIRA review completed)

May 9 - Rev. Rul. 2019-13: Cash distributions during the post-termination transition period

May 9 - U.S. Tax Court: Employment tax obligations of charter yacht operator

May 9 - KPMG report: Proposed regulations, withholding obligations incident to transfers of interests by foreign partners, partnerships engaged in U.S. trade or business

May 8 - Notice 2019-34: Maximum FMV of vehicle for 2019 to use special valuation of employee use of employer-provided vehicles; future proposed regulations intended

May 8 - EU comment letter on FDII proposed regulations; alleged “prohibited export subsidy” under WTO obligations

May 8 - Indiana: Sourcing rules for corporate income tax; marketplace facilitators to collect sales tax

May 7 - Proposed regulations: Tax withholding, information reporting concerning partnerships with foreign partners (text of regulations)

May 7 - Notice 2019-33: Future guidance on tax reserves used by public utilities; request for comments

May 7 - Rev. Proc. 2019-22: Private schools' use of website to publicize racially nondiscriminatory policy

May 7 - OIRA review of final regulations, health reimbursement arrangements

May 7 - IRS reminder: May 13 deadline, EIN requirements for responsible parties

May 7 - Third Circuit: Loan guarantees by CFCs includible in taxpayer’s gross income

May 6 - Eleventh Circuit: Taxpayer denied losses from S corporation’s indebtedness

May 6 - KPMG report: Employee or independent contractor; common law test in new tax paradigm

May 6 - KPMG report: Economic nexus legislation, remote sales (Georgia, South Carolina, Tennessee)

May 6 - KPMG reports: Oklahoma (passthrough entity tax); Pennsylvania (deductible interest expense limit)

May 2 - Notice 2019-32: Request for comments, carbon oxide sequestration credit (section 45Q and future regulations)

May 1 - Rev. Proc. 2019-20: Expansion of retirement plan determination letter program

April 2019

Apr 30 - Proposed regulations under section 1400Z-2 for qualified opportunity zones, released to Federal Register

Apr 30 - IRS practice unit: Taxation of shipping and air transport income

Apr 29 - KPMG report: Economic nexus legislative update (California, Colorado)

Apr 29 - KPMG reports: Iowa (business interest deduction limit); Maryland (GILTI); New Jersey (GILTI)

Apr 29 - KPMG report: Twenty questions about possible technical corrections to 2017 Tax Act

Apr 25 - IRS announces Peter Blessing appointed Associate Chief Counsel (International)

Apr 25 - Federal Circuit: State brownfield tax credit amounts held subject to federal income tax

Apr 24 - Notice 2019-30: Recommendations requested for 2019-2020 priority guidance plan

Apr 24 - U.S. Tax Court: Written supervisory approval required before contact with taxpayers, accuracy-related penalty

Apr 23 - Kentucky: Second bill enacted under comprehensive tax legislative package

Apr 22 - IRS reminder for QI / WP / WT periodic-review certification

Apr 22 - KPMG reports: Alabama (no rental tax, tailgating services); Arkansas (federal tax conformity); New Jersey (business interest deduction); New York (GILTI)

Apr 19 - Rev. Proc. 2019-19: Employee plan compliance, self-correction program update

Apr 18 - Opportunity zones: Highlights of the second set of proposed regulations

Apr 18 - Reminder of May 13 deadline: EIN requirements for responsible parties

Apr 18 - KPMG video: OECD’s proposals on taxing the digital economy; comparison to U.S. tax reform

Apr 17 - Proposed regulations: Nonresident aliens, potential current beneficiaries of electing small business trusts

Apr 17 - IRS adds three new compliance campaigns (LB&I division)

Apr 17 - Proposed regulations: Qualified opportunity zone funds under section 1400Z-2 (text of regulations released by IRS)

Apr 17 - OIRA review completed; proposed regulations under qualified opportunity funds (section 1400Z-2)

Apr 16 - Correcting amendments, final regulations under section 199A

Apr 16 - Ninth Circuit: Mailbox rule for refund claims, regulations accorded deference

Apr 16 - Rev. Rul. 2019-10: Fringe benefit aircraft valuations, first half 2019

Apr 15 - Enhanced oil recovery, marginal well production credits; reference price (2018)

Apr 15 - KPMG report: Pricing method, services cost method eligibility under U.S. BEAT provision

Apr 15 - KPMG report: IRS denies tax-favored employer-provided meals in technical advice memo

Apr 15 - KPMG report: Economic nexus, marketplace providers collecting tax (Arkansas, Idaho, Indiana)

Apr 15 - KPMG reports: Arkansas (corporate tax reform); Indiana (remote sales, registration); Massachusetts (multiple points of use)

Apr 12 - OIRA review of proposed regulations: Determining built-in gains and losses

Apr 12 - OIRA review of proposed regulations: Guidance under section 451(c)

Apr 12 - JCT overview of “BEAT” provisions under section 59A

Apr 11 - Tax Court: Captive does not qualify as insurance company, premiums paid not deductible

Apr 11 - Rev. Proc. 2019-18: Safe harbor for professional sports team, valuation of certain player contracts

Apr 11 - New Mexico: Comprehensive tax legislation affecting businesses enacted

Apr 10 - Congressional tax committee leaders express support for OECD efforts, digital services taxes

Apr 9 - Corrections to final regulations under section 965

Apr 8 - IRS provides Form 1065 FAQs, negative capital account reporting

Apr 8 - Final regulations: Tax-exempt bonds, clarifying definition of “investment-type property”

Apr 8 - IRS practice units: Interest capitalization, accounting for developers and subcontractors

Apr 8 - KPMG report: Economic nexus update, marketplace facilitators’ tax collection obligations

Apr 8 - KPMG reports: Georgia (tax treaty implications); Idaho (federal tax reform); New York (federal tax reform); Oregon (Pub. L. No. 86-272)

Apr 8 - Updated FAQ, independence standard, external reviewer of QI / WP / WT

Apr 5 - Proposed regulations pending OIRA review: Passive income exception under section 1297 for foreign insurance companies

Apr 5 - IRS priority guidance plan for 2018-2019 (second quarter update)

Apr 5 - New Jersey: Managerial member of combined group must register; registration portal is open

Apr 3 - Regulations pending OIRA review: Domestic production activities deduction for agricultural, horticultural cooperatives (section 199A(g))

Apr 3 - Rev. Proc. 2019-17: General public use requirements, qualified residential rental projects financed with tax-exempt bonds

Apr 2 - Imports of alcoholic beverages under Craft Beverage Modernization and Tax Reform Act of 2017 (contained in Pub. L. No. 115-97)

Apr 2 - Second Circuit: Tax refund jurisdiction of Tax Court

Apr 1 - KPMG report: New tool for APA submissions

Apr 1 - KPMG report: Other provisions in U.S. tax law—tax accounting, compensation and benefits

Apr 1 - KPMG report: State legislative actions, sales and use tax guidance (CA, KY, NY, ND, VA)

Apr 1 - KPMG reports: Kentucky (economic nexus); Oregon (decoupling from section 199A); Tennessee (business tax classification)

March 2019

Mar 29 - New York: Credits for dual residents, court declines to review cases

Mar 29 - Rev. Rul. 2019-11: Tax treatment of state and local tax refunds

Mar 28 - Notice 2019-24: Housing expense limit adjustments, foreign locations for 2019

Mar 28 - Rev. Proc. 2019-15: List of countries eligible for section 911(d)(1) waiver for 2018

Mar 28 - IRS Appeals guidance on partnership audit procedures under Bipartisan Budget Act (BBA)

Mar 28 - New FAQs under FATCA; compliance items for foreign financial institutions

Mar 28 - Kentucky: Comprehensive tax legislation signed into law

Mar 28 - KPMG report: State, local tax developments (first quarter 2019, table)

Mar 28 - JCT overview of section 163(j), limitation on deduction of business interest

Mar 27 - Notice of withdrawal of proposed regulations under Subchapter C

Mar 27 - Announcement 2019-03: APMA program, APA statistics for 2018

Mar 27 - IRS revises EIN application process

Mar 27 - FASB re-proposes changes to income tax disclosures

Mar 26 - Notice 2019-22: Credit phase-out, qualified plug-in electric vehicles (General Motors, LLC)

Mar 26 - Tax relief for taxpayers affected by storms, flooding in Iowa

Mar 25 - Final regulations: Reportable transactions penalties

Mar 25 - Proposed regulations: Transfers of property to REITs

Mar 25 - OIRA review: SALT credits, charitable contributions; guidance under sections 164 and 170(c)

Mar 25 - JCT report, distributional effects of Public Law 115-97 (U.S. tax law)

Mar 25 - IRS provides FAQ on certifications, periodic reviews for QI / WP / WT

Mar 25 - KPMG report: State sales tax nexus legislation update (Nebraska, North Carolina, North Dakota)

Mar 25 - KPMG reports: Arkansas (unclaimed property); Louisiana (local sales tax); multiple states (corporate nexus)

Mar 22 - IRS relief for storm victims in Nebraska

Mar 22 - Proposed regulations: Corporate partners, transactions involving equity interest of partner

Mar 22 - Proposed regulations: Life insurance contracts, reportable sales and reportable death benefits

Mar 22 - Notice 2019-25: Expanded estimated tax penalty waiver for 2018, individual taxpayers

Mar 22 - Notice 2019-26: Updated mortality improvement rates, tables for defined benefit pension plans (for 2020)

Mar 22 - IRS practice unit: Foreign-initiated adjustments, competent authority guidance

Mar 21 - Final regulations: Verification and certification requirements for certain entities, reporting by FFIs

Mar 20 - JCT report on federal tax system, in effect for 2019

Mar 20 - Washington State: Economic nexus bill enacted; remote retailers and marketplaces affected

Mar 19 - Texas: Personal property renditions due April 1

Mar 19 - U.S. Supreme Court: No fuel tax by Washington State on Native American tribe

Mar 18 - Trump Administration’s FY 2020 budget: “Analytical Perspectives”

Mar 18 - Final regulations: Income test qualification for RICs

Mar 18 - Proposed regulations under “anti-hybrid” provisions; hearing cancelled

Mar 18 - KPMG report: FBAR update for officers, employees

Mar 18 - KPMG report: State legislative actions, sales and use tax for marketplace facilitators

Mar 18 - KPMG reports: New York (broker-dealer); New York (marketplace provider); Utah (corporate nexus)

Mar 15 - Status of Treasury proposed regulations pending OIRA review

Mar 15 - IRS practice unit: Automatic exchange of information

Mar 15 - Agreement between United States and India, exchange of country-by-country reports

Mar 14 - Form 1065 instructions (2018), requirement to provide partnership representative’s taxpayer identification number removed

Mar 14 - IRS reminder about retirement plan correction program, electronic submissions

Mar 13 - Rev. Rul. 2019-06: Covered compensation tables for 2019 plan year

Mar 13 - U.S. Tax Court: S corporation liable for section 6699 penalty; extension application not filed

Mar 12 - Regulations pending OIRA review, qualified opportunity funds (section 1400Z-2)

Mar 12 - Notice 2019-10: Comments requested, fuel excise tax regulations related to power take-off

Mar 12 - Ninth Circuit: Estate tax deficiency sustained, overstated charitable deduction

Mar 11 - Trump Administration budget proposals for FY 2020

Mar 11 - New corporate income tax return filing rules and requirements in China; implications for U.S. multinational corporations

Mar 11 - Final regulations: 296 regulations withdrawn, 79 modified

Mar 11 - Proposed foreign tax credit regulations, hearing cancelled

Mar 11 - U.S. Tax Court: Premium tax credit under Affordable Care Act

Mar 11 - Delaware: Additional unclaimed property audit notices, voluntary disclosure invitations

Mar 11 - KPMG reports: Massachusetts (telecommunication services); Michigan (credit card processing); New Jersey (addbacks); Washington State (apportionment, nexus)

Mar 8 - IRS practice unit: Competent authority, under tax treaty’s MAP article

Mar 8 - KPMG report: Initial impressions, observations on proposed FDII, GILTI regulations under section 250

Mar 7 - Notice 2019-20: Penalty relief, partnership negative tax basis capital account reporting

Mar 7 - Proposed regulations, “anti-hybrid” provisions (hearing scheduled for March 20)

Mar 7 - Proposed regulations, FATCA burden relief (hearing set for April 10)

Mar 7 - IRS relief for certain taxpayers affected by Alabama storms

Mar 6 - Treasury policy statement on tax regulatory process

Mar 6-  Notice 2019-18: Lump-sum payments instead of future annuity payments (defined benefit plans)

Mar 6 - U.S. Tax Court: Indian tribe not liable for employment taxes of corporate division

Mar 5 - Proposed “BEAT” regulations, hearing scheduled for March 25

Mar 5 - Proposed foreign tax credit regulations, corrections

Mar 4 - Proposed regulations under section 250 for FDII deductions (text released) 

Mar 4 - U.S. Supreme Court: Wages paid to injured railroad worker are taxable compensation

Mar 4 - KPMG report: More state actions, economic nexus for remote sales

Mar 4 - KPMG reports: Arizona (rental car “surcharge”); California (transfers to insurers); Kansas (sales tax on ISP equipment)

Mar 1 - Olson to retire as National Taxpayer Advocate

February 2019

Feb 28 - U.S. Tax Court: Determination of and IRS supervisory approval for penalties

Feb 28 - Notice 2019-17: Estimated tax penalty relief for individual farmers, fishermen

Feb 27 - Proposed foreign tax credit regulations, hearing scheduled for March 14

Feb 27 - Final regulations: Utility allowance rules, low-income housing credit (section 42)

Feb 27 - IRS reminders on filing country-by-country reports on Form 8975

Feb 27 - IRS practice unit: Self-employment tax and partners

Feb 27 - Ninth Circuit: IRS third-party contact summons quashed, Publication 1 not reasonable notice

Feb 27 - Senate confirms Desmond as IRS Chief Counsel

Feb 26 - Tenth Circuit: Medical marijuana company’s deductions denied

Feb 25 - U.S. Tax Court: Upper-tier CFC partners’ E&P increased by partnership’s section 951(a) income inclusions

Feb 25 - TTB return is updated, firearms and ammunition excise tax

Feb 25 - KPMG report: Tax rules for parking deductions, increased UBTI

Feb 25 - KPMG report: State actions, economic nexus for remote sales

Feb 25 - KPMG reports: Florida (service receipts); North Carolina (non-taxable dividends); Virginia (municipal fee vs. tax)

Feb 23 - OIRA review completed; proposed regulations under section 250 for FDII deductions

Feb 22 - Final regulations: Low-income housing credit under section 42, compliance monitoring

Feb 21 - Request for information, grandfathered group health plans and insurance coverage

Feb 21 - Final regulations: Centralized partnership audit regime (text of regulations)

Feb 20 - U.S. Supreme Court: State taxation, pensions of former law enforcement employees

Feb 18 - Opportunity zone hearing on proposed regulations: Oral comments highlight need for greater clarity for investments to move forward

Feb 18 - KPMG report: State legislative proposals, economic nexus for retailers

Feb 18 - KPMG reports: Florida (federal tax conformity); Illinois (sales tax exemption); Ohio (location of sales); Virginia (sales apportionment)

Feb 15 - IRS acquiescence: Tax Court decision, hockey team’s pregame meals as de minimis fringe benefit

Feb 13 - Rev. Proc. 2019-13: Safe harbor method of accounting, 100% first-year depreciation for passenger automobiles

Feb 13 - Virginia: Conformity bill pending signature by governor

Feb 12 - IRS National Taxpayer Advocate’s report for 2018

Feb 12 - KPMG report: Year-in-review list of U.S. federal tax developments for 2018 (as reported in TaxNewsFlash)

Feb 11 - KPMG report: Final section 263A regulations and taxpayers with “negative adjustments”

Feb 11 - KPMG report: Payment-acceleration events for section 965 installment payments and transfer agreements

Feb 11 - KPMG report: Section 451(b) and new book-tax conformity rules

Feb 11 - KPMG reports: Iowa (location of services); Mississippi (GILTI); New Jersey (addbacks); Washington State (B&O tax of service providers)

Feb 8 - Senate Finance leadership’s position on proposed EU digital services tax

Feb 5 - U.S. Treasury’s quarterly list, countries cooperating with international boycott (no changes)

Feb 5 - KPMG report: Changes in corrected final regulations under section 199A

Feb 4 - Final regulations under section 199A released to Federal Register

Feb 4 - KPMG reports: Mississippi (coordination with federal tax law); Missouri (sales tax); Texas (resale exemption); Texas (source of receipts); Philadelphia (economic presence)

Feb 4 - Final regulations released to Federal Register, "transition tax” under section 965

Feb 1 - Final regulations under section 199A; new version reflects changes

January 2019

Jan 30 - Final regulations under section 965; new version reflects changes

Jan 30 - IRS operations after shutdown ended

Jan 30 - LB&I focus guide for 2019; IRS strategic goals

Jan 29 - Public hearings scheduled: GILTI and opportunity zone proposed regulations

Jan 29 - IRS practice units: Permanent establishment status and issues

Jan 28 - IRS announces tax filing season opens for individual taxpayers

Jan 28 - IRS practice unit: Energy-efficient commercial buildings, section 179D deduction (expired)

Jan 28 - KPMG report: Legislation proposed in states focuses on “Wayfair” issues (HI, IA, MA, ND, OK, RI, WI) 

Jan 28 - KPMG report: Possible penalty exposure, cost-sharing agreements and stock-based compensation

Jan 28 - KPMG reports: New Jersey (combined reporting); New York City (sale of minority interest in LLC); Utah (sales tax)

Jan 25 - IRS addresses partial government shutdown impact on Tax Court cases

Jan 24 - KPMG report: Analysis and observations of final section 199A regulations

Jan 24 - KPMG report: SEC comments on accounting for income taxes

Jan 23 - IRS final forms, instructions: Implementing U.S. tax law changes

Jan 22 - KPMG report: Regulations addressing treatment under section 199A, dividends paid by REITs

Jan 21 - KPMG report: States follow up with action to “Wayfair” decision (IN, MA, NY, ND, PA, WY)

Jan 21 - KPMG reports: Georgia (resale exemption); Missouri (sales tax); New York (tax proposals for 2020); Oregon (tax proposals)

Jan 18 - Final regulations under section 199A (20% deduction), text released by IRS

Jan 18 - KPMG report: Final regulations relating to “transition tax” under section 965

Jan 17 - OIRA review completed, final regulations under section 199A (20% deduction)

Jan 16 - Notice 2019-11: Estimated tax penalty waiver for 2018, individual taxpayers

Jan 16 - IRS updates contingency plan for IRS operations during government shutdown

Jan 16 - KPMG report: Interim guidance, taxing “excess” executive compensation of exempt organizations

Jan 15 - IRS release, effects of partial government shutdown on IRS operations

Jan 15 - Final regulations under section 965, text is released by IRS

Jan 14 - OIRA review completed, final regulations under section 965 transition tax

Jan 14 - IRS statement on sequestration, refundable AMT credits for corporations

Jan 14 - KPMG report: More states respond to “Wayfair” decision (MO, PA, SC, TX, VA)

Jan 14 - KPMG reports: New Jersey (GILTI and FDII); New Mexico (apportionment); Pennsylvania (hedging transactions)

Jan 14 - KPMG report: Tax policy and the 116th Congress – observations and preliminary analysis

Jan 11 - Notice 2019-08: Values for employee personal use of employer-provided vehicles

Jan 10 - Puerto Rico: Tax law changes affecting corporations, partnerships

Jan 10 - Accounting for AMT credit refunds resulting from tax reform, effects of sequestration

Jan 9 - Coal excise tax, lower tax rates beginning January 2019

Jan 9 - Puerto Rico: New provisions related to individual taxation for 2019

Jan 7 - IRS announces tax filing season for individuals begins January 28

Jan 7 - Public hearing, proposed regulations for opportunity zones

Jan 7 - IRS final forms, instructions for implementing U.S. tax law changes

Jan 7 - New Jersey: New form for reporting dividends, deemed mandatory repatriation dividends

Jan 7 - KPMG report: State, local responses to “Wayfair” decision (DC, GA, IA, NE, UT, WV)

Jan 7 - KPMG reports: Iowa (sales tax, installation services); Louisiana (online retailer); Missouri (sales tax refund claim)

Jan 4 - IRS release, filing season for certain business tax returns

Jan 3 - KPMG report: Preliminary analysis and observations regarding certain exempt organization provisions in JCT Bluebook

Jan 3 - KPMG report: JCT Bluebook clarifies intended application of enhanced charitable contribution deduction

Jan 3 - “Oil spill” excise tax has expired

December 2018

Dec 31 KPMG report: Preliminary analysis and observations, JCT Bluebook description on application of section 163(j) to passthrough entities

Dec 28 - Rev. Proc. 2019-12: Safe harbors, business taxpayer payments to charity for state, local tax credits

Dec 28 - IRS releases annual revenue procedures for 2019

Dec 28 - Final regulations: Tax-exempt private activity bonds, “public approval requirement”

Dec 28 - Proposed regulations: Tax-exempt bonds treated as “retired”

Dec 26 - Proposed regulations under section 864(c)(8) released to Federal Register

Dec 22 - IRS contingency plan during government shutdown

Dec 21 - KPMG report: Initial impressions, proposed regulations implementing “anti-hybrid” provisions of new tax law

Dec 21 - KPMG report: Preliminary analysis and observations regarding certain passthrough provisions in JCT Bluebook

Dec 21 - KPMG report: Preliminary analysis and observations regarding certain international provisions in JCT Bluebook

Dec 21 - Rev. Proc. 2019-08: “Qualified real property” expensing under section 179, alternative depreciation under section 168

Dec 21 - Wisconsin: Elective passthrough entity tax regime enacted

Dec 21 - Third Circuit: Civil penalty assessment for FBAR violation requires “willful conduct”

Dec 21 - Notice 2019-05: Hardship exemptions, individual shared responsibility payment and health insurance

Dec 21 - Notice 2019-06: Future regulations will address centralized partnership audit regime

Dec 21 - Rev. Proc. 2019-09: Adequate disclosures to reduce accuracy-related penalty

Dec 21 - KPMG report: Initial impressions of proposed regulations under section 864(c)(8) 

Dec 20 - Proposed regulations under section 163(j) released to Federal Register

Dec 20 - Proposed regulations on hybrid dividends, payments (text of regulations)

Dec 20 - Proposed regulations under section 864(c)(8) (text of regulations)

Dec 20 - JCT general explanation of new tax law (“Bluebook”)

Dec 19 - KPMG report: “BEAT” proposed regulations, provisions applicable to insurance companies

Dec 19 - Rev. Proc. 2019-06: Unpaid loss discount factors, salvage discount factors for 2018 accident year (insurance)

Dec 19 - Entity classification: Withdrawing change request after regulations render election undesirable

Dec 19 - Notice 2019-04: Extension of temporary dyed fuel tax relief, Wisconsin terminals

Dec 19 - Puerto Rico: Changes to 2018 information returns, declarations

Dec 19 - Puerto Rico: Summary of changes to information reporting, tax withholding

Dec 19 - KPMG report: State, local tax changes (fourth quarter 2018, table)

Dec 18 - KPMG report: Analysis and observations about proposed regulations, FATCA burden relief

Dec 18 - Proposed regulations on hybrid dividends, payments provision; OIRA review completed

Dec 18 - IRS releases draft instructions for Form 965 series

Dec 17 - KPMG report: Analysis and observations about “BEAT” proposed regulations

Dec 17 - Proposed regulations on “BEAT” released to Federal Register

Dec 17 - Regulations pending OIRA review, section 250 deductions for foreign-derived intangible income and GILTI

Dec 17 - KPMG report: Initial impressions of Notice 2019-01 and “PTEP” guidance

Dec 17 - Tax implications, federal district court and constitutionality of Affordable Care Act

Dec 17 - KPMG report: State and local responses to “Wayfair” decision (CA, DC, Philadelphia, WI)

Dec 17 - KPMG reports: Chicago (tax collection by facilitators); Missouri (sales tax exemption for pharmaceutical compounding)

Dec 14 - Notice 2019-01: Future regulations, foreign corporations with previously taxed earnings and profits (text of notice)

Dec 14 - Regulations pending OIRA review, section 199A and 20% deduction for passthrough business income

Dec 14 - KPMG report: Initial impressions about Rev. Proc. 2019-10, computing insurance company reserves

Dec 14 - Notice 2018-93: Credit for carbon oxide sequestration, applicable dollar amounts

Dec 14 - Notice 2018-96: Credit phase-out, qualified plug-in electric vehicles (Tesla, Inc.)

Dec 14 - Notice 2019-02: Standard mileage rates for 2019

Dec 14 - KPMG report: Payroll year-end planning guide, checklist for employment tax

Dec 14 - KPMG report: Initial impressions, proposed regulations under section 59A (“BEAT”)

Dec 13 - Proposed regulations implementing “BEAT” provision under section 59A (text of regulations)

Dec 13 - Rev. Proc. 2019-10: Insurance company, method of accounting change for computing reserves (text of revenue procedure)

Dec 13 - Proposed regulations under FATCA; goal of reducing taxpayer burden

Dec 13 - IRS releases Form 5471 and draft instructions for 2018

Dec 13 - OIRA review completed; proposed regulations implementing “BEAT” provision

Dec 12 - KPMG report: Initial impressions, FAQs on “transition tax” under section 965 for 2018 returns

Dec 12 - IRS provides FAQs, “transition tax” under section 965 for 2018 returns

Dec 12 - IRS provides draft version of Form 965 instructions

Dec 11 - OIRA review completed, proposed regulations under section 864(c)(8), gain or loss from sales of U.S. partnership interests

Dec 11 - Draft instructions, Form 8990: Business interest expense limitation, section 163(j)

Dec 10 - Notice 2018-99: Parking expenses as qualified transportation fringe benefits, nondeductible amount

Dec 10 - FBAR filings: Deadline again extended for certain individuals with signature authority

Dec 10 - Puerto Rico: Registration process outlined for SURI (internal revenue unified system)

Dec 10 - KPMG reports: Colorado (remote sales); Delaware (unclaimed property); Louisiana (credit for taxes paid); Mississippi (limitations period); New York (unclaimed property)

Dec 7 - Notice 2018-97: Initial guidance, new tax benefit for stock options and restricted stock units

Dec 7 - D.C. Circuit: Taxpayer’s refund claim invoking treaty benefits allowed to proceed

Dec 6 - Final regulations pending OIRA review, section 965 transition tax

Dec 6 - Rev. Rul. 2018-32: Increased rates of overpayment, underpayment interest for first quarter, 2019

Dec 5 - KPMG report: Tax planning guide 2019, for individual taxpayers

Dec 5 - Puerto Rico: More guidance, transition to unified digital system (SURI)

Dec 4 - Proposed foreign tax credit regulations released to Federal Register

Dec 4 - Proposed regulations pending OIRA review, gain or loss from sales of U.S. partnership interests

Dec 4 - Notice 2018-95: Transition relief from “once-in-always-in” rule, excluding part-time employees from section 403 plans

Dec 4 - U.S. Tax Court: Summary judgment denied; “deposit method” for customer payment

Dec 3 - KPMG report: Insurance industry implications of proposed regulations under section 163(j)

Dec 3 - KPMG report: States respond to “Wayfair” decision (IA, NJ, UT)

Dec 3 - KPMG reports: Indiana (software); Ohio (resale exemption); San Francisco (economic nexus); Utah (foreign tax credit)

November 2018

Nov 30 - KPMG report: Initial impressions, foreign tax credit proposed regulations

Nov 29 - IRS reminder: “Hardship withdrawal” measures in proposed regulations, relief for hurricane victims

Nov 29 - LB&I directive: Guidance on DPAD claims under now-repealed section 199

Nov 29 - Notice 2018-94: IRS extends health coverage information reporting deadline for employers, providers

Nov 29 - Rev. Proc. 2018-60: Automatic consent procedures, method of accounting changes for timing of revenue recognition

Nov 29 - U.S. Tax Court: Medical-marijuana dispensary operator deficiency challenge denied

Nov 28 - KPMG report: Initial impressions of proposed regulations under section 163(j), business interest limitation

Nov 28 - Proposed regulations: Foreign tax credit provision under new U.S. tax law (text of regulations)

Nov 27 - KPMG report: Like-kind exchange relief, taxpayers affected by California wildfires

Nov 27 - Rev. Proc. 2018-59: Infrastructure safe harbor and section 163(j) business interest limitation

Nov 26 - IRS to release updated Form 3115, "Application for Change in Accounting Method"

Nov 26 - Proposed regulations under section 163(j), business interest limitation (text of regulations)

Nov 26 - Notice 2018-92: Interim guidance, tax withholding, wages and retirement and annuity distributions

Nov 24 - OIRA review completed, proposed regulations on foreign tax credit

Nov 21 - Notice 2018-91: Qualified retirement plans, 2018 “required amendments list”

Nov 21 - Tier 2 tax rates for railroads, no changes for 2019

Nov 21 - OIRA review completed, proposed regulations under section 163(j) and the business interest limitation

Nov 20 - Proposed regulations: Basic exclusion amount, estate and gift taxes (text of regulations)

Nov 20 - Notice 2018-90: Withholding, reporting of IRA payments to state’s unclaimed property funds, relief extended to 2020

Nov 20 - Rev. Proc. 2018-58: Updated list of time-sensitive acts, postponed by IRS

Nov 19 - Final regulations: Simplified methods of accounting, mandatory change for certain manufacturers

Nov 19 - Notice 2018-88: Health reimbursement arrangements, future proposed regulations

Nov 19 - Notice 2018-89: Leave-based donation payments, aid for Hurricane Michael victims

Nov 19 - Hurricane Michael-related tax relief, two more Florida counties

Nov 19 - Hurricane Michael-related tax relief for two additional counties in Georgia

Nov 19 - Hurricane Florence-related tax relief, additional North Carolina county

Nov 19 - Hurricane Florence-related tax relief, more locations in Virginia

Nov 19 - KPMG report: State and local follow-up to “Wayfair” decision (DC, LA, WY)

Nov 19 - KPMG reports: California (mortgage servicer); Kentucky (deductible state taxes, corporations)

Nov 16 - New Jersey: Tax amnesty available through January 15, 2019

Nov 15 - Rev. Proc. 2018-57: Inflation adjustments for 2019, individual taxpayers

Nov 14 - Tax relief for taxpayers affected by California wildfires

Nov 13 - Proposed regulations on hybrid dividends, payments provision pending OIRA review

Nov 12 - KPMG reports: Arkansas (water utility services); Massachusetts (software); South Carolina (sourcing, satellite television)

Nov 9 - IRS priority guidance plan for 2018-2019

Nov 9 - Insurance initiatives in 2018-2019 priority guidance plan

Nov 9 - IRS reminder: November 17 deadline for individuals’ 2017 tax returns filed electronically

Nov 9 - Federal Circuit: “Same taxpayer rule,” no netting of overpayment and underpayment interest

Nov 9 - Proposed regulations: Amendments relating to hardship distributions from section 401(k) plans

Nov 8 - Proposed regulations on foreign tax credit provision, pending OIRA review

Nov 8 - Hurricane Michael-related tax relief for Alabama taxpayers

Nov 8 - Hurricane Michael-related tax relief for two more counties in Georgia

Nov 7 - KPMG report: U.S. congressional elections and tax policy; preliminary observations

Nov 7 - KPMG report: U.S. state and local election results, tax-related ballot measures

Nov 7 - Final regulations: Coverage of preventive services, religious and moral exemptions

Nov 7 - IRS adds FAQs on filing transfer agreements under Code section 965 

Nov 6 - Proposed regulations implementing “BEAT” provision, pending OIRA review

Nov 6 - Proposed regulations: Modification of discounting rules for insurance companies

Nov 5 - Proposed regulations: Discounting rules for insurance companies (text of regulations)

Nov 5 - Notice 2018-85: Self-insured health insurance annual fee

Nov 5 - IRS practice unit: Identifying taxpayers electing partial disposition of building

Nov 5 - KPMG report: More state reactions to “Wayfair” decision (NJ, NC, SC, SD, WY)

Nov 5 - KPMG reports: Ohio (unclaimed property); South Carolina (bank tax); Washington (sales tax, trade-in credits)

Nov 4 - KPMG report: Initial impressions of proposed regulations coordinating sections 956 and 245A

Nov 2 - Hurricane Michael-related tax relief; addition of 31 counties in Georgia

Nov 1 - Proposed regulations under section 956, released to Federal Register

Nov 1 - Notice 2018-83: Pension plans, cost-of-living adjustments for 2019

Nov 1 - FASB changes to lessor accounting for sales and similar taxes, certain lessor costs

Nov 1 - Federal Circuit: Alcohol fuel mixture credit reduces gasoline excise tax

October 2018

Oct 31 - Proposed regulations: Amount determined under section 956 for corporate U.S. shareholders (text of regulations)

Oct 30 - Hearing on proposed “bonus depreciation” regulations scheduled for November 28

Oct 29 - KPMG report: Election 2018—voters to decide key state tax matters

Oct 29 - KPMG report: Update on state actions responding to “Wayfair” decision (CA, CO, LA, UT, VA)

Oct 29 - KPMG reports: Arkansas (sales tax, crowdfunding); Idaho (nexus, single employee); Massachusetts (utility receipts tax)

Oct 29 - IRS adds another South Carolina county for Hurricane Florence relief

Oct 29 - IRS adds more North Carolina counties, Hurricane Florence-related tax relief

Oct 29 - Three more Georgia counties, Hurricane Michael-related tax relief

Oct 26 - Proposed regulations: Removal of regulations on advance payments, goods and long-term contracts

Oct 25 - Proposed regulations pending OIRA review: Section 163(j) business interest limitation

Oct 25 - Proposed regulations for opportunity zones, released in Federal Register

Oct 24 - Two more North Carolina counties added, Hurricane Florence-related tax relief

Oct 23 - Proposed regulations: Health reimbursement arrangements

Oct 22 - KPMG report: U.S. states respond to “Wayfair” decision (CA, OK, TX)

Oct 22 - KPMG reports: California (like-kind exchange); Massachusetts (GILTI); Rhode Island (sales tax nexus); Texas (online education, sales tax)

Oct 22 - KPMG report: Initial impressions of proposed regulations: Opportunity zones and deferral of gains

Oct 19 - IRS adds more areas in Virginia, Hurricane Florence-related relief

Oct 19 - Proposed regulations: Opportunity zones, deferral of gains (text of regulations)

Oct 19 - OIRA review completed, final regulations under section 263A

Oct 18 - Notice 2018-84: Personal exemption at “zero,” health plan implications

Oct 18 - OIRA review completed, opportunity zone regulations

Oct 18 - KPMG report: New section 163(j)—partnership issues

Oct 17 - U.S. Treasury’s list of regulatory projects, implementing new tax law provisions

Oct 17 - IRS adds four more South Carolina counties, Hurricane Florence relief

Oct 17 - IRS reminder: QI / WP / WT application deadline, November 16, 2018

Oct 17 - Rev. Proc. 2018-54: Deemed issuers, diversification requirements for variable contracts (insurance companies)

Oct 16 - IRS temporarily expands low-income housing credit rules, hurricane-related relief

Oct 16 - IRS adds 14 North Carolina counties, Hurricane Florence-related tax relief

Oct 16 - IRS adds six more South Carolina counties, Hurricane Florence relief

Oct 16 - IRS relief, taxpayers in Virginia affected by Hurricane Florence

Oct 16 - U.S. guidance on claiming tax credits, reduced tax rates (imported spirits, beer, wine)

Oct 15 - Initial impressions: Penalty relief “de minimis error” safe harbor; information returns, payee statements and the proposed regulations

Oct 15 - Sixth Circuit: Split-dollar life insurance, economic benefit treated as distribution of property to shareholder

Oct 15 - KPMG report: State actions concerning “Wayfair” decision (AL, CO, DC)

Oct 15 - KPMG reports: Missouri (sales tax exemption); Texas (franchise tax nexus); Utah (arm’s length transactions)

Oct 15 - IRS waives dyed diesel fuel penalty, Hurricane Michael-related shortages

Oct 15 - IRS relief, Georgia counties affected by Hurricane Michael

Oct 15 - IRS relief, taxpayers in 16 Florida counties affected by Hurricane Michael

Oct 15 - KPMG reports: Hurricanes and disaster relief, recovery for affected taxpayers

Oct 12 - Proposed regulations: Removing existing regulations on advance payments for goods, long-term contracts

Oct 12 - Proposed regulations: Penalty relief “de minimis error” safe harbor; information returns and payee statements

Oct 12 - KPMG report: Initial impressions of proposed GILTI regulations

Oct 12 - Proposed regulations under section 965; public hearing on October 22

Oct 12 - Alabama, Illinois, Missouri, New Jersey: Late-filing penalty relief for corporate tax returns due October 15

Oct 12 - Rev. Proc. 2018-50: Increased user fee for U.S. residency certification

Oct 12 - IRS relief, taxpayers in Florida affected by Hurricane Michael

Oct 9 - Notice of additional guidance under section 965

Oct 9 - New Jersey: Corporation business tax law changes enacted

Oct 8 - Puerto Rico: Transition to new unified digital system (SURI)

Oct 8 - IRS allows more time for filing transfer agreement under section 965

Oct 8 - KPMG report: Beginning construction for section 48 investment tax credit

Oct 8 - KPMG report: Cross-border income inclusions (including GILTI) treated as REIT qualifying income

Oct 8 - KPMG report: Notice 2018-68 guidance under section 162(m); narrowly crafted grandfathering provision

Oct 8 - KPMG report: Proposed regulations under section 199A

Oct 8 - KPMG report: Update on state actions responding to “Wayfair” decision (CA, GA, NV, NJ, WV)

Oct 8 - KPMG reports: California (single member LLC); Massachusetts (sales tax collection); South Carolina (federal tax conformity)

Oct 5 - IRS adds two more South Carolina counties, Hurricane Florence relief

Oct 4 - Final regulations under section 263A pending OIRA review

Oct 4 - Guidance on procedures, requirements relating to alcohol excise tax

Oct 4 - IRS reminder: Electing out of 100% bonus depreciation deduction for 2017; October 15 deadline for certain taxpayers

Oct 3 - Proposed regulations under GILTI provisions released in Federal Register

Oct 3 - Rev. Proc. 2018-53: Procedures for private letter rulings, issues relating to divisive reorganizations

Oct 3 - Notice 2018-76: Transitional guidance on deductibility of business meal expenses

Oct 1 - Rettig is new Commissioner of Internal Revenue

Oct 1 - Notice 2018-78: Basis adjustment election under section 965 proposed regulations

Oct 1 - KPMG report: Follow-up state actions, “Wayfair” decision (DC, IL, MD, MA, NE, NJ, NM, SC, SD)

Oct 1 - KPMG reports: California (partnership audits); California (telephone equipment, sales and use tax); New York (promotional materials, sales and use tax)

September 2018

Sep 28 - IRS adds another North Carolina county, Hurricane Florence-related tax relief

Sep 28 - Rev. Proc. 2018-52: Employee plan compliance, corrective programs update

Sep 28 - Rev. Rul. 2018-26: Fringe benefit aircraft valuations, second half 2018

Sep 28 - Notice 2018-79: Extension of replacement period for livestock

Sep 27 - IRS releases draft instructions for Form 1040 for 2018

Sep 27 - IRS updates list of South Carolina counties, Hurricane Florence tax relief

Sep 27 - Notice 2018-80: Future regulations to provide market discount not includible in income under section 451(b)

Sep 27 - KPMG report: State, local tax changes (third quarter 2018, table)

Sep 26 - Second Circuit: Taxable gain from modified variable prepaid forward contracts

Sep 26 - Notice 2018-77: Per diem rates, substantiation of employee lodging, meals, incidentals (2018-2019)

Sep 25 - IRS considering “active trade or business” guidance for ventures with research activities

Sep 25 - IRS adds more North Carolina counties, Hurricane Florence-related tax relief

Sep 24 - Notice 2018-71: Employer credit for paid family and medical leave (Q&As)

Sep 24 - Reminder: Deadline for claiming 2017 biodiesel and alternative fuel incentives is September 29, 2018

Sep 24 - Ninth Circuit: Inconsistency between S corporation’s and shareholder’s returns

Sep 24 - IRS relief, South Carolina taxpayers affected by Hurricane Florence

Sep 24 - KPMG report: New section 163(j)—partnership issues

Sep 24 - KPMG report: New section 163(j)—selected issues

Sep 24 - KPMG reports: Minnesota (sales tax exemption); Texas (online retailer)

Sep 21 - Notice 2018-75: Employer reimbursements made in 2018 for employee moving expenses in 2017

Sep 21 - IRS provides draft instructions for Form 8992 (GILTI)

Sep 21 - Text of proposed regulations: Removal of section 385 “documentation regulations”

Sep 20 - Notice 2018-72: Extensions of phase-in, transition rules under section 871(m) guidance

Sep 19 - Rev. Proc. 2018-49: Changes in method of accounting, rules clarified for “early adopters”

Sep 19 - Notice 2018-74: Modified “safe harbor” explanations for plan administrators to provide for recipients of rollover distributions

Sep 19 - Non-taxation by Luxembourg of U.S. multinational corporation, EC investigation finds no illegal state aid

Sep 18 - IRS waives dyed diesel fuel penalty, Hurricane Florence-related shortages

Sep 18 - IRS reminders relating to Form 8975 “Country-by-Country Report”

Sep 18 - U.S. Tax Court: CFC’s distribution not “qualified dividend income,” but taxable at ordinary rates

Sep 17 - IRS extends deadlines, provides tax relief for taxpayers affected by Hurricane Florence (updated list of counties)

Sep 17 - TTB guidance: “Single taxpayer” rules for excise tax credits, reduced rates on beer, wine, distilled spirits

Sep 17 - KPMG report: Follow-up actions by states on “Wayfair” holding (CA, CO, IL, NV, SD, TX, WI)

Sep 17 - KPMG reports: Alabama (use tax); Massachusetts (federal tax reform)

Sep 14 - IRS guidance for September 2018 deposits of oil spill liability tax

Sep 13 - Proposed regulations under GILTI provisions (text of regulations)

Sep 13 - Rev. Proc. 2018-48: REIT items of income, foreign currency gain under GILTI provisions

Sep 13 - Proposed regulations for opportunity zones, pending OIRA review

Sep 12 - U.S. Senate confirms Rettig to be IRS Commissioner

Sep 10 - KPMG report: Federal excise tax opportunity; drawback for taxed alcohol, manufacture of nonbeverage products

Sep 10 - KPMG report: IRS Compliance Assurance Process (CAP) program for 2019

Sep 10 - KPMG report: State responses to “Wayfair” (IN, MD, NJ, OK, SD)

Sep 10 - KPMG reports: Maine (federal tax conformity); New Jersey (sales tax sourcing); Oregon (pass-through entities)

Sep 10 - GAO report on 2018 tax filing, IRS challenges for 2019

Sep 8 - Update on proposed regulations under GILTI provisions

Sep 7 - IRS practice unit: Determining individual’s residency for treaty purposes

Sep 6 - IRS provides draft version of Form 8991 for “BEAT” reporting

Sep 6 - IRS provides draft versions of schedules for Form 965

Sep 6 - Rev. Proc. 2018-47: Excise tax relief for RICs with section 965 inclusions

Sep 5 - Business taxpayer payments to state, local tax credit programs generally deductible; IRS response to inquiries on proposed regulations

Sep 5 - IRS provides draft versions of Form 965 and Schedule H

Sep 5 - SECA tax audits underway as part of IRS compliance campaigns

Sep 5 - U.S. executive order on expansion of retirement plans

Sep 4 - LB&I directive on selecting timeshare industry issues for examination

Sep 4 - Reminder: IRS offshore voluntary disclosure program closes September 28 (taxpayers with undisclosed foreign financial assets)

Sep 4 - U.S. Tax Court: Statute of limitations if unreported PFIC gains

August 2018

Aug 31 - Rev. Proc. 2018-36: Updated list of countries, deposit interest paid to nonresident aliens

Aug 30 - OIRA review completed on section 385 proposed regulations

Aug 28 - Notice 2018-70: Future regulations on “qualifying relative” and personal exemption amount (new tax law measures) 

Aug 28 - Insurance: IRS LB&I directive, elective treatment for principle-based reserves for variable annuity contracts and life insurance contracts

Aug 27 - Changes to “Compliance Assurance Process” (CAP) program for 2019

Aug 27 - Rev. Proc. 2018-45: Foreign insurance companies; effectively connected net investment income (2017)

Aug 27 - U.S. Tax Court: No charitable contribution deduction for facade easement, long-term lessee

Aug 27 - California: Combined reporting upheld; different treatment of interstate, intrastate businesses

Aug 27 - KPMG report: More states respond or update initial reactions to “Wayfair” decision (AR, CO, NV, SC, SD, TN, TX)

Aug 27 - KPMG reports: California (unclaimed property); Kentucky (GILTI); North Dakota (repatriation); Texas (apportionment); Texas (legal support services)

Aug 24 - Notice 2018-69: Nondiscrimination relief for “closed” defined benefit plans extended through 2019

Aug 24 - KPMG report: State and local tax credits and charitable contributions, proposed regulations

Aug 23 - Proposed regulations: State and local tax credits and charitable contributions (text of regulations)

Aug 23 - Proposed GILTI regulations pending OIRA review; IRS draft forms for GILTI reporting 

Aug 22 - Rev. Proc. 2018-44: Accounting method change, “eligible terminated S corporation” (new tax law)

Aug 21 - Notice 2018-68: Guidance on deduction limitation for remuneration paid to “covered employee” under section 162(m) (new tax law)

Aug 21 - Notice 2018-67: Guidance for new UBTI rules under section 512(a)(6)

Aug 20 - OIRA review completed on SALT credits, charitable contribution regulations

Aug 20 - KPMG report: Two more states respond to “Wayfair” decision (NJ, SC)

Aug 20 - KPMG reports: Colorado (wholesale purchase for resale); Oregon (physical presence); Texas (data processing services); Vermont (federal tax law changes)

Aug 17 - Rev. Rul. 2018-24: Conversion involving mortgage-backed securities not taxable exchange of property

Aug 16 - Eighth Circuit vacates Tax Court’s determination of transfer pricing method

Aug 16 - Senate Finance Committee Republicans identify issues for technical corrections, regulatory guidance for new tax law

Aug 15 - Rev. Proc. 2018-42: New deadline for pre-approved defined contribution plans, opinion letter applications (December 31, 2018)

Aug 15 - U.S. Treasury, CBP interim final rule; alcohol excise tax refunds

Aug 14 - D.C. Circuit: Credit under expired section 45K, for fuel from nonconventional source, landfill gas

Aug 14 - Fifth Circuit: Donation of conservation easement, perpetuity requirement not satisfied

Aug 13 - KPMG report: More states respond or update initial reactions to “Wayfair” decision (AR, CA, LA, ME, MD, MS, NC, SD, WY)

Aug 13 - KPMG reports: Indiana (standing for refund claim); Wyoming (what constitutes a sale)

Aug 13 - Ninth Circuit: Federal excise tax on tobacco products, tribal manufacturer

Aug 13 - Proposed regulations: Centralized partnership audit regime; regulations are re-proposed

Aug 10 - KPMG report: Issues and analysis of section 965 proposed regulations

Aug 10 - Proposed regulations under section 199A released for publication in Federal Register

Aug 10 - Second Circuit: Special 10-year limitations period applies for credit, not deduction, of foreign taxes paid

Aug 9 - KPMG report: Proposed bonus depreciation regulations and 2018 filing season: Opportunities and pitfalls

Aug 8 - Initial impressions: Proposed regulations, IRS guidance for section 199A and 20% deduction for passthrough qualified business income

Aug 8 - Proposed regulations: Section 199A, 20% deduction for passthrough qualified business income (text of regulations)

Aug 8 - U.S. Tax Court: Withholding tax liability under section 1446 held partnership-level item

Aug 7 - Ninth Circuit withdraws decision in cost-sharing arrangements case, new panel to consider appeal

Aug 6 - Final regulations: Centralized partnership audit regime (text of regulations)

Aug 6 - Rev. Proc. 2018-40: Automatic consent, small businesses seeking accounting method change

Aug 6 - Status of Treasury regulations pending OIRA review

Aug 6 - U.S. Tax Court: Repatriation allowed using plan of intercompany debt with return-of-capital distribution

Aug 6 - KPMG report: Update of reaction by states to “Wayfair” decision (KY, MI, NE, SD, WA)

Aug 6 - KPMG reports: Alabama (new federal tax law implications); Vermont (IRC section 965)

Aug 6 - IRS relief, victims of California wildfires and high winds

Aug 3 - Proposed regulations: Additional first year depreciation deduction under section 168 (text of regulations)

Aug 3 - Proposed regulations under section 965 released for publication in Federal Register

Aug 3 - IRS Chief Counsel memo: Overpayments and section 965(h)

Aug 3 - Notice 2018-62: Future regulations on contribution limits for ABLE accounts

Aug 2 - What regulations could be released next? Regulations under sections 199A and 385

Aug 1 - Text of regulations, section 965 “transition tax”

Aug 1 - Final regulations: Information returns, extension of time

Aug 1 - Final regulations: Short-term, limited-duration health insurance

Aug 1 - Update on nominations of IRS Chief Counsel, Treasury deputy secretary

July 2018

Jul 30 - Notice 2018-58: Future regulations to clarify section 529 re-contributions, rollovers, qualified expenses

Jul 30 - KPMG report: Follow-up actions of various states, “Wayfair” decision (IN, MN, NV, NH, RI, UT)

Jul 30 - KPMG reports: Connecticut (GILTI); Michigan (bad debt deduction); Utah (IRC section 965)

Jul 27 - D.C. Circuit: Exclusions from gross income of foreign corporations; regulations (2003) held invalid

Jul 27 - Federal Circuit: Basis of assets for calculating “Section 1603 grants”

Jul 27 - Final regulations: Substantiation, reporting requirements for cash, non-cash charitable contribution deductions

Jul 26 - Insurance: Self-procurement tax imposed on all U.S. premiums paid to captive (New Jersey Tax Court) 

Jul 24 - Ninth Circuit reverses Tax Court, upholds cost-sharing regulations

Jul 24 - Ninth Circuit: Transferee liability, asset sale followed by stock sale

Jul 23 - KPMG report: Compilation of state responses to “Wayfair” 

Jul 23 - KPMG report: More state responses to “Wayfair” decision (MD, MN, NH, UT)

Jul 23 - KPMG report: State and local tax, technology-related guidance (table, second quarter 2018)

Jul 23 - KPMG reports: Texas (manufacturing exemption, software); Wisconsin (taxable laundry services)

Jul 20 - IRS practice unit: Treatment of transaction costs of business transactions

Jul 20 - TTB guidance: Excise tax, transfers of beer between breweries not of same ownership

Jul 19 - Final regulations: Revised 401(k) plan definitions, qualified matching and nonelective contributions

Jul 19 - Finance Committee votes for Rettig to be next IRS Commissioner

Jul 16 - Status of expected regulations; section 965 “transition tax”

Jul 16 - KPMG report: More states indicate responses to “Wayfair" (HI, IN, LA, MT, NH, RI, SC, TX, WY)

Jul 16 - KPMG reports: California (San Francisco rent tax); Missouri (financial institutions taxation); New Jersey (tax amnesty)

Jul 13 - Notice 2018-61: Future regulations to clarify effect of section 67(g) for estates and trusts

Jul 12 - KPMG report: Initial analysis of final regulations addressing “inversions”

Jul 12 - Financial reporting implications of “Wayfair” decision

Jul 11 - IRS provides draft Schedule A, “Itemized Deductions” for 2018

Jul 11 - KPMG report: State and local incentive arrangements from REIT perspective

Jul 11 - Final regulations: Corporate inversions and related transactions (text of regulations)

Jul 9 - KPMG report: States continue to respond to U.S. Supreme Court’s decision in “Wayfair” (AL, IN, NH, OH, UT, WI), federal bill introduced

Jul 9 - New Jersey: Corporation business tax law changes enacted

Jul 9 - KPMG reports: Georgia (IRC section 965); Minnesota (apportionment); Vermont (federal tax conformity)

Jul 5 - KPMG video: Tax reform and U.S. international tax provisions

Jul 2- IRS new “compliance campaigns” include section 965 transition tax (under new tax law)

Jul 2 - IRS releases draft Form 1040 schedules for 2018 tax year

Jul 2 - KPMG reports: Louisiana (sales tax); Massachusetts (apportionment); Pennsylvania (federal bonus depreciation)

Jul 2 - KPMG report: More states respond to U.S. Supreme Court’s decision in “Wayfair” case (HI, ID, IA, MA, ND, RI, TX, VT)

June 2018

Jun 29 - IRS releases draft “streamlined” Form 1040 for 2018 tax year

Jun 28 - CBP guidance: Refunds of excise tax on imported beer, wine, distilled spirits (pursuant to new tax law)

Jun 28 - TTB guidance: Calculating effective tax rates for distilled spirits products (pursuant to new tax law)

Jun 28 - Eleventh Circuit: Refund denied, radioactive waste disposal payments not for nuclear decommissioning

Jun 27 - KPMG report: State, local tax changes (second quarter 2018, table)

Jun 27 - SEC staff comments: Accounting for tax reform, implementing new standards

Jun 27 - New FAQ for QI / WP / WT

Jun 26 - Reminder: June 29 deadline for taxpayers in Puerto Rico, Virgin Islands, American Samoa

Jun 25 - KPMG report: States respond to U.S. Supreme Court’s decision in “Wayfair” case (ND, MN, LA, NJ, MS, MD, WV)

Jun 25 - KPMG reports: Rhode Island (software); Utah (apportionment); Virginia (shopping fees)

Jun 22 - Notice 2018-59: Construction “begin date” for section 48 credit, energy property

Jun 21 - U.S. Supreme Court: Initial impressions of “Wayfair” decision

Jun 21 - U.S. Supreme Court: Employee stock options not taxable “compensation” under RRTA

Jun 21 - Insurance: Tax Court sides with IRS, rejects captive’s insurance company status

Jun 21 - U.S. Supreme Court: Decision issued in “Wayfair” case concerning state tax treatment of remote sellers

Jun 20 - Notice 2018-48: List of population census tracks as designated qualified opportunity zones

Jun 19 - IRS practice unit: Interest capitalization for self-constructed assets

Jun 19 - Rev. Proc. 2018-35: Automatic change, method of accounting for citrus replanting costs

Jun 18 - Proposed regulations: Allocations of partnership liabilities for disguised sale purposes (section 707)

Jun 18 - KPMG reports: Colorado (IRC section 965); New York (manufacturer); North Carolina (federal tax conformity); Rhode Island (IRC section 965); Texas (telecom provider)

Jun 14 - U.S. Treasury’s final update of list of opportunity zones (June 2018)

Jun 13 - Notice 2018-57: Regulations under section 987, one-year deferral of effective date

Jun 12 - Puerto Rico: “Employee retention credit,” as hurricane disaster relief

Jun 11 - Proposed regulations: Tax-exempt bonds, clarifying definition of “investment-type property”

Jun 11 - KPMG reports: Michigan (IRC section 965); Pennsylvania (use tax); multiple states (economic nexus, sales and use tax)

Jun 7 - Final regulations: Partnership transactions involving equity interests of a partner

Jun 7 - IRS updates list of FAQs on opportunity zones

Jun 6 - Missouri: Corporate rate reduction, mandatory single-sales factor apportionment, market-based sourcing enacted

Jun 5 - KPMG report: Mineral interest income, eligible for section 199A deduction?

Jun 5 - KPMG report: Tax reform and publicly traded partnerships

Jun 4 - IRS again updates FAQs, “transition tax” under Code section 965; penalty relief and filing information

Jun 4 - Puerto Rico: Tax holiday for "back to school" purchases

Jun 4 - Third Circuit: No capital gains treatment, taxpayer retained technology rights

Jun 4 - KPMG reports: Missouri (lease add-ons); New Jersey (related-party addbacks); Washington (Seattle employee tax)

May 2018

May 31 - Treasury offers expanded relief for producers claiming wine production credit

May 30 - Proposed regulations: Change to threshold for filing information returns electronically

May 29 - Rev. Rul. 2018-17: Withholding, reporting of IRA payments made to state’s unclaimed property funds

May 25 - IRS notices: Oil and gas, marginal well factors for 2018

May 25 - New FAQs for QI / WP / WT

May 25 - Notice 2018-42: Modifications to standard mileage rates for 2018

May 23 - Notice 2018-54: Future regulations to address state and local tax deductions

May 23 - IRS five-year strategic plan

May 22 - D.C. Circuit: Partnership of single-member LLCs, not eligible for “small partnership” exception

May 22 - Rev. Proc. 2018-34: Premium tax credit, contribution percentage for 2019

May 22 - U.S. Treasury updates list of opportunity zones (May 2018)

May 21 - KPMG reports: Colorado (market-based sourcing); Massachusetts (IRC section 965); Tennessee (federal tax reform); Washington (delivery services, nexus)

May 18 - Iowa: Tax reform legislation includes changes affecting corporate, individual taxpayers

May 17 - Connecticut: New partnership-level tax, in response to federal tax changes

May 17 - Indiana: Federal tax conformity legislation enacted

May 15 - U.S. Treasury’s quarterly list of countries cooperating with international boycott; no changes

May 14 - IRS practice units: R&D, qualified research expenses, nonfunctional currency

May 14 - KPMG reports: Hawaii (economic nexus); Hawaii (federal tax conformity); Ohio (nexus); Washington (unclaimed property)

May 11 - Inflation adjustment factors, carbon dioxide sequestration under section 45Q, Indian coal production credit under section 45

May 10 - Third quarter update to IRS, Treasury priority guidance plan 2017-2018

May 10 - Rev. Proc. 2018-29: Automatic consent, method of accounting change, relating to financial accounting revenue recognition standards

May 10 - Rev. Proc. 2018-30: HSA inflation-adjusted amounts for 2019

May 9 - Rev. Proc. 2018-31: List of automatic changes, accounting methods

May 9 - Federal Circuit: Extraterritorial income transition rule applies for post-2006 earnings

May 8 - Notice 2018-30: Section 382 recognized built-in gains, losses determined without regard to section 168(k) immediate expensing

May 8 - SEC: Text of proposed rules, including “best interest” regulation

May 7 - Tax Court: Government does not bear burden of production for penalties in partnership-level proceedings

May 7 - KPMG reports: Alabama (IRC section 965); Florida (IRC section 965); New York (commonly owned group election); South Carolina (services); Texas (pension trusts)

May 7 - New FAQs for QI / WP / WT certifications, periodic reviews

May 4 - Notice 2018-46: Exception to “United States property” for notional principal contract swaps (section 956)

May 4 - Notice 2018-47: Extension of empowerment zone designation

May 4 - IRS reminder: QI / WP / WT certifications

May 3 - Fifth Circuit: Refund claim denied, overpayment held not “attributable to” foreign taxes paid

May 1 - Notice 2018-44: Housing expense limit adjustments, foreign locations for 2018

April 2018

Apr 30 - KPMG reports: California (sourcing, intangibles); Maryland (apportionment); New York (telecommunications exemption); Pennsylvania (IRC section 965)

Apr 30 - Notice of clarification: Final rule on certain health care-related measures

Apr 27 - Notice 2018-43: Recommendations requested for IRS, Treasury guidance, including guidance to implement new tax law

Apr 27 - Notice 2018-27: Relief for certain employers claiming section 45R credit, health insurance coverage

Apr 27 - Rev. Rul. 2018-11: Inflation adjustment for certain debt instruments

Apr 26 - Rev. Proc. 2018-27: Changes to HSA contribution limitation for 2018, relief measures

Apr 26 - IRS provides FAQs on qualified opportunity zones, under new tax law

Apr 26 - Notice 2018-39: IRS extends temporary relief, taxable fuel removals from certain Wisconsin terminals

Apr 26 - Notice 2018-41: Future regulations, information reporting on reportable policy sales of life insurance contracts (new section 6050Y)

Apr 26 - Rev. Rul. 2018-13: State-assumed interest rates, insurance company post-2016 reserves

Apr 25 - Eleventh Circuit: Rehearing on Alabama’s tax regime for diesel fuel

Apr 24 - First congressional hearing on new U.S. tax law

Apr 24 - Kentucky: Tax reform legislation

Apr 24 - Treasury report on status of regulatory reform actions

Apr 23 - KPMG report: Employer credit, paying employees for family or medical leave

Apr 23 - KPMG report: State and local tax, technology-related guidance (table, first quarter 2018)

Apr 23 - KPMG reports: Nebraska (federal tax conformity); Oregon (IRC section 965); Rhode Island (IRC section 965); Texas (tax amnesty)

Apr 20 - Notice 2018-32: Enhanced oil recovery, marginal well production credits; reference price (2017)

Apr 19 - SEC to propose “best interest” standard, retail customer protection

Apr 19 - U.S. Treasury updates list of opportunity zones, under new tax law

Apr 18 - U.S. Supreme Court: Oral arguments in state tax case to overturn “Quill”

Apr 18 - Section 45: Renewable electricity, refined coal production inflation factors, reference prices (2018)

Apr 17 - Rev. Proc. 2018-25: Automobile depreciation deduction limits for 2018, reflecting new tax law

Apr 16 - Notice 2018-38: Fiscal year U.S. corporations to pay “blended” income tax rate under new tax law

Apr 16 - KPMG reports: Arizona (federal tax conformity); Connecticut (IRC section 965); Indiana (use tax on rentals); New Mexico (consolidated returns)

Apr 14 - IRS updates FAQs, “transition tax” on foreign earnings under Code section 965

Apr 13 - Fringe benefit aircraft valuations for first half 2018

Apr 13 - IRS reminder: Combat zone tax benefits, Armed Forces service in Sinai Peninsula, retroactive to June 2015

Apr 13 - Notice 2018-37: Future regulations to clarify effective date, trust income payment to former spouse

Apr 13 - Rev. Proc. 2018-22: Corrected AMT phaseout threshold amount for estates, trusts

Apr 12 - Notice 2018-35: Transitional guidance, accrual method taxpayers deferring advance payments from income

Apr 12 - Treasury, OMB agreement on review of future tax regulations

Apr 11 - Rev. Proc. 2018-26: Nonqualified uses of proceeds from tax-exempt bonds, new remedial actions

Apr 10 - Updated FAQs on country-by-country reporting, guidance for national security contractors

Apr 9 - IRS Publication 5292: Calculating section 965 amounts, elections available for 2017 returns

Apr 9 - First round of opportunity zones released, under new tax law

Apr 9 - KPMG reports: Alabama (remote sellers); Arizona (sales of intangibles); Georgia (use tax); Tennessee (IRC section 965); Wisconsin (federal tax conformity)

Apr 9 - First Circuit: IRS application of substance-over-form doctrine rejected; DISC contributions to Roth IRAs

Apr 6 - Rev. Proc. 2018-23: No countries eligible for section 911(d)(1) waiver for 2017; Turkey added for 2016

Apr 5 - Notice 2018-24: Determination letter program for individually designed retirement plans; comments requested

Apr 4 - Observations about Notice 2018-31: Country-by-country reporting by “specified national security contractors”

Apr 4 - KPMG report: Casualty loss deduction calculations, individual income tax returns

Apr 3 - New York: State budget includes federal tax reform-related changes

Apr 2 - Initial impressions on Notice 2018-28, computing business interest expense limitation under section 163(j)

Apr 2 - Initial impressions on Notice 2018-26 and guidance under section 965; special elections, reporting and paying the “transition tax”

Apr 2 - Initial impressions on Notice 2018-29, withholding on transfers of non-publicly traded partnership interests

Apr 2 - KPMG reports: Florida, Georgia (federal tax conformity); Indiana (software); Louisiana (online marketplace); Massachusetts (credit recapture); Utah (corporate tax rate)

Apr 2 - Notice 2018-28: Computing business interest expense limitation under section 163(j)

Apr 2 - Notice 2018-26: Special elections under section 965, reporting and paying the “transition tax”

Apr 2 - Notice 2018-29: Transfers of non-publicly traded partnership interests, withholding on transfers

March 2018

Mar 30 - Announcement 2018-08: APMA program, APA statistics for 2017

Mar 30 - Notice 2018-31: IRS guidance on country-by-country reporting by “specified national security contractors”

Mar 27 - Final regulations: Allocation of research credit among controlled group members

Mar 27 - Proposed regulations: Non-government attorneys excluded from receiving records summoned by IRS

Mar 27 - Notice 2018-23: Transitional guidance on expanded nondeductibility of certain fines, penalties and information reporting

Mar 26 - KPMG report: State, local tax changes (first quarter 2018, table)

Mar 26 - KPMG reports: Arkansas (sales tax, amusements); Illinois (federal transition tax); New Jersey (federal transition tax); Utah (federal transition tax)

Mar 23 - Tax technical corrections are enacted, include partnership provisions

Mar 22 - Filing, payment deadlines for taxpayers in Puerto Rico, U.S. Virgin Islands further postponed to June 29, 2018

Mar 19 - KPMG reports: Idaho (federal tax conformity); Indiana (financial institutions tax); Kentucky (fuel tax); Texas (streaming services); Vermont (nexus)

Mar 16 - Rev. Proc. 2018-21: Revisions to opinion and advisory letters for pre-approved master and prototype and volume submitter plans

Mar 14 - Rev. Proc. 2018-19: Reduced user fee for determination letter request for terminating plan (Form 5310)

Mar 14 - U.S. Tax Court: “Short sale” of residence and debt forgiveness held one transaction

Mar 13 - IRS provides FAQs about “transition tax” on foreign earnings (new Code section 965)

Mar 13 - IRS grants businesses more time to file, request six-month extension (winter storms)

Mar 13 - IRS offshore voluntary disclosure program to close, taxpayers with undisclosed foreign assets

Mar 13 - IRS identifies five new LB&I “compliance campaigns”

Mar 12 - KPMG report: FBAR update - No new rules, but enforcement threat looms

Mar 12 - KPMG report: SEC and FASB comments on accounting for income taxes

Mar 12 - KPMG report: Tax reform implications for R&D activities

Mar 12 - KPMG reports: Arkansas (use tax); Georgia (federal tax conformity); Indiana (manufacturing exemption); Ohio (service contracts)

Mar 12 - Proposed regulations: Disclosure of delinquent taxpayer information to State Department passport services contractors

Mar 9 - Announcement 2018-5: Pre-approved defined benefit plans; IRS to issue opinion, advisory letters soon

Mar 7 - Notice 2018-21: Biodiesel, renewable fuel credits for 2017, one-time claim; oil spill liability tax safe harbor

Mar 7 - Rev. Rul. 2018-7: Rates of underpayment, overpayment interest increase for second quarter, 2018

Mar 5 - Notice 2018-20: Australia added to “no TIN list”

Mar 5 - Notice 2018-12: High deductible health plans providing benefits for male sterilization, contraceptives

Mar 5 - Temporary relief for producers claiming the wine production credit under new tax law

Mar 5 - U.S. Tax Court: Excise tax for excess contributions to Roth IRAs from FSC

Mar 5 - KPMG reports: Colorado (official guidance); Colorado (apportionment); New Jersey (partnerships); Virginia (federal conformity)

Mar 2 - Rev. Proc. 2018-18: Inflation adjustments for 2018, revised to reflect new tax law

Mar 1 - Notice 2018-18: Future "carried interest" regulations to clarify partnership interests held by S corporations

Mar 1 - U.S. Tax Court: Income from gravel mined on Indian land, taxable

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