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TaxNewsFlash-Tax Reform

TaxNewsFlash-Tax Reform

Tax reform in the United States

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New tax law in the United States

Recent Articles

2020

Aug 6 - Proposed regulations on “carried interest” (section 1061) released to Federal Register

Aug 5 - Final regulations pending OIRA review: “BEAT” provisions under section 59A

Aug 5 - KPMG reports: Initial analysis of regulations, guidance under section 163(j) (printable version)

Aug 4 - KPMG reports: Initial analysis of regulations, guidance under section 163(j)

Aug 3 - Status of OIRA review of regulations under 2017 tax law

Jul 31 - Proposed regulations under section 1061, “carried interest” rules (text of regulations)

Jul 31 - KPMG report: Analysis of final FDII regulations

Jul 30 - Proposed regulations: Simplified accounting for small businesses, long-term contracts (text of regulations)

Jul 28 - Regulations, IRS guidance: Business interest expense deduction limitations under section 163(j) (text of regulations and guidance)

Jul 21 - KPMG report: Initial impressions about final and proposed regulations, high-tax exception under GILTI and subpart F

Jul 20 - Regulations: GILTI and subpart F high-tax exception (text of final and proposed regulations)

Jul 20 - Proposed regulations on “carried interest” rules under section 1061; OIRA review completed

Jul 17 - Regulations pending OIRA review: Section 954, and coordinating rules under sections 245A and 951A

Jul 14 - Regulations on limiting business interest expense deductions under section 163(j); OIRA review completed

Jul 10 - KPMG report: Initial impressions of final regulations related to deduction for FDII and GILTI under section 250

Jul 9 - Final regulations: Deduction under section 250, FDII and GILTI (text of regulations)

Jul 8 - OIRA review completed: Regulations on high-taxed GILTI exclusion, subpart F income

Jul 7 - KPMG report: Insurance-related measures in consolidated NOL regulations

Jul 6 - Final regulations: Domestic production activities deduction for agricultural, horticultural cooperatives; OIRA review completed

Jul 6 - IRS adds section 965 compliance campaign under TCJA (LB&I division)

Jul 2 - Regulations: Consolidated net operating losses (text of regulations)

Jun 24 - Final regulations: Qualified business income under section 199A; REIT income received by RICs; previously suspended losses; trusts and estates

Jun 23 - KPMG report: Proposed regulations and guidance on qualified transportation fringe benefits

Jun 22 - KPMG report: Qualified opportunity zone rules, as of June 2020

Jun 19 - Proposed regulations: Qualified transportation and commuting expenses under section 274 (text of regulations)

Jun 19 - Proposed regulations, consolidated NOLs: OIRA review completed

Jun 17 - Regulations pending OIRA review: GILTI, high-taxed subpart F income, foreign corporations’ E&P

Jun 16 - Regulations pending OIRA review: Limitation of business interest expense deduction under section 163(j)

Jun 15 - Final regulations under section 250, deduction for FDII and GILTI; OIRA review completed

Jun 11 - Proposed regulations: Limitations on like-kind exchanges

Jun 9 - Proposed regulations pending OIRA review: Consolidated NOLs

Jun 8 - Proposed regulations: “Qualifying relative” and personal exemption amount clarified

Jun 5 - Proposed regulations: Excise tax on excess compensation, parachute payments made by tax-exempt organizations

Jun 4 - Notice 2020-39: Relief for qualified opportunity zones and investors (COVID-19)

Jun 3 - Proposed regulations pending OIRA review: “Carried interest” under section 1061

May 28 - OIRA review and expectations for more regulations, under 2017 tax law

May 27 - Final regulations pending OIRA review: Section 250 deduction for FDII and GILTI

May 26 - Proposed regulations: Income tax withholding, periodic retirement and annuity payments

May 26 - Proposed regulations: Personal exemption at zero, implications for health plan premium tax credit

Mar 24 - KPMG report: Timing considerations for QOF and QOF investors in light of COVID-19

May 21 - Proposed regulations: Rehabilitation credit and rules coordinating with other credits

May 19 - Final regulations: Domestic production activities deduction for agricultural, horticultural cooperatives (pending OIRA review)

May 12 - Proposed regulations: Disallowed deductions and information reporting for fines, penalties

May 7 - Proposed regulations: Deductions allowed estates, non-grantor trusts

May 4 - Proposed regulations, excise tax on tax-exempt organization compensation; OIRA review completed

May 1 - IRS adds new compliance campaign on TCJA (LB&I division)

Apr 24 - KPMG report: Initial impressions of proposed regulations on separately computed UBTI

Apr 23 - IRS provides FAQs on NOL carrybacks for taxpayers with section 965 inclusions

Apr 23 - Proposed regulations: Separately computed UBTI (text of regulations)

Apr 22 - KPMG report: Relief for taxpayers to correct, change QIP depreciation methods (Rev. Proc. 2020-25)

Apr 21 - Proposed regulations concerning like-kind exchanges; OIRA review completed

Apr 20 - Final regulations, section 199A treatment for deductions involving REITs and RICs; OIRA review completed

Apr 20 - KPMG report: Section 1400Z-2 final regulations; observations on correcting amendments (April 2020)

Apr 17 - Proposed regulations, separately computed UBTI; OIRA review completed

Apr 15 - Proposed regulations pending OIRA review: Separately computed UBTI

Apr 9 - KPMG report: Initial impressions of final regulations implementing “anti-hybrid” provisions (sections 245A(e), 267A, and 1503(d))

Apr 7 - Regulations: Hybrid arrangements (text of final and proposed regulations)

Mar 26 - Regulations pending OIRA review: Excise tax on tax-exempt organization compensation

Mar 21 - Proposed regulations, limitation of business interest expense deduction under section 163(j); OIRA review completed

Mar 20 - Proposed regulations, denial of deduction for fines, penalties; OIRA review completed

Mar 13 - OIRA update: Expectations for issuance of regulations, under 2017 tax law (TCJA)

Mar 12 - Proposed regulations, net operating loss (NOL) deduction; OIRA review completed

Mar 6 - Final regulations pending OIRA review: Section 199A treatment for deductions involving REITs and RICs

Mar 3 - Regulations on UBTI, separately computed for each trade or business activity; OIRA review completed

Feb 28 - Regulations implementing “carried interest” measures; OIRA review completed

Feb 27 - Regulations concerning hybrid dividends and payments; OIRA review completed

Feb 24 - Proposed regulations: Deductibility of meal and entertainment expenses

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

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

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

Feb 10 - Rev. Rul. 2020-05: Adjustments to basis for life insurance contracts; clarifications reflecting TCJA changes

Feb 10 - IRS practice unit: Interest capitalization for self-constructed assets; updated for TCJA measures

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 4 - Regulations pending OIRA review: UBTI separately computed for each trade or business activity

Jan 24 - KPMG report: Transactions in the age of tax reform

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

2019 Articles

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

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

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

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

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

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

Dec 19 - Final regulations, opportunity zones; OIRA review completed

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

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 - Proposed regulations: Deduction for employee remuneration in excess of $1 million

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

Dec 16 - Nebraska: State tax treatment of GILTI and FDII

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

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

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

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

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

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 - Regulations: Foreign tax credits (text of regulations)

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

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

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

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

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

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)

Oct 31 - Draft version 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

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

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

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

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

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

Sep 23 - Nebraska: Guidance on state’s treatment of section 965 income

Sep 23 - Vermont: State tax treatment of GILTI and FDII

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

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

Aug 26 - New Jersey: Guidance addressing state tax treatment of FDII and GILTI

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 - Florida: State tax treatment of GILTI, bonus depreciation

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, compliance with U.S. tax law changes

Aug 1 - IRS practice unit: Source of income, nonresident alien individuals (reflecting U.S. tax legislative changes)

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

Jul 29 - Oregon: Legislation revises state’s treatment of global intangible low-taxed income (GILTI)

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

Jul 25 - KPMG report: Proposed regulations concerning university excise tax

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

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

Jul 22 - Louisiana: BEAT not deductible as an income tax

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

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

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

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

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

Jul 1 - IRS updates FAQs on opportunity zones

Jul 1 - Oregon: Proposed state tax treatment of global intangible low-taxed income (GILTI)

Jun 28 - Proposed regulations: Excise tax, net investment income of colleges, universities

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

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 - 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 - KPMG report: Opportunity zones and REITs

Jun 20 - IRS updates FAQs, QBI deduction for cooperatives and patrons

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 16 - House Ways and Means hearing, fringe benefit UBTI

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

Jun 3 - Minnesota: Corporate conformity legislation, effective retroactively

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

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

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

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

May 22 - Senate passes bill to modify 2017 “kiddie tax” changes

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

May 20 - Florida: Pending legislation would adopt GILTI exclusion

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

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

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

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

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

May 6 - Pennsylvania: Deductible interest expense limitation, computation for corporate net income tax purposes

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

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

Apr 29 - KPMG reports:  Interest deduction limitation under section 163(j) (Iowa); GILTI guidance (Maryland, New Jersey)

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

Apr 22 - Federal tax conformity (Arkansas, New Jersey, New York)

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

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

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

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

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

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

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 9 - Corrections to final regulations under section 965

Apr 8 - KPMG video shorts: Implications for businesses, section 199A regulations

Apr 8 - Idaho and New York:  Federal tax reform, conformity measures

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

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

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

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

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

Mar 27 - Ways and Means holds first hearing on 2017 tax law

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

Mar 25 - JCT report, distributional effects of Pub. L. No. 115-97 (U.S. tax law)

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

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

Mar 13 - JCT overview of section 199A deduction, qualified business income

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

Mar 11 - Proposed foreign tax credit regulations, hearing cancelled

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

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

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) 

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

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

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

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

Feb 18 - Florida: Federal tax conformity for corporations

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 11 - Mississippi: Revised guidance on state treatment of GILTI measures from federal tax law

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

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

Feb 4 Mississippi: Guidance on state tax treatment of certain provisions of 2017 federal tax law 

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

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

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

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

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

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

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 -  New Jersey: Guidance on state tax treatment of GILTI and FDII

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

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

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 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 2 - Ways and Means Chairman Brady’s discussion draft for technical corrections legislation

2018 Articles

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

Dec 31 - Notice 2019-09: Interim guidance on excise tax imposed under section 4960, excess remuneration

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

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

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

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 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 - 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 - 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 11 - Notice 2018-100: Waiver of estimated tax penalties attributable to fringe benefit UBTI

Dec 10 - Ways and Means Chairman Brady releases modified version of tax package

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

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

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

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

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

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

Nov 30 - KPMG report: Implications of section 163(j) proposed regulations for exempt organizations

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

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

Nov 26 - Brady releases tax bill with technical corrections, retirement, extenders, other provisions

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

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

Nov 9 - IRS priority guidance plan for 2018-2019

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 7 - IRS adds FAQs on filing transfer agreements relating to Code section 965

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

Nov 6 - Proposed regulations: Form 4720 filing requirement for Chapter 42 excise taxes, abatement

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

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

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

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

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 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 25 - IRS resource, new tax law measures for exempt organizations

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

Oct 22 - Massachusetts: Corporate excise tax treatment of GILTI measures

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

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

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

Oct 18 - OIRA review completed, opportunity zone regulations

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

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

Oct 12 - KPMG report: Initial impressions of proposed GILTI regulations

Oct 12 - Proposed regulations under section 965; public hearing on October 22

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

Oct 9 - New Jersey: Legislation includes rules concerning taxation of GILTI and FDII-determined amounts of income

Oct 9 - Notice of additional guidance under section 965

Oct 8 - IRS allows more time for filing transfer agreement under section 965

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 - South Carolina: Federal tax conformity legislation

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 - Notice 2018-76: Transitional guidance on deductibility of business meal expenses

Oct 1 - Notice 2018-78: Basis adjustment election under section 965 proposed regulations

Sep 28 - House passes third “tax reform 2.0” bill to extend new tax law provisions

Sep 27 - House passes two bills under “tax reform 2.0”

Sep 27 - Notice 2018-80: Future regulations to provide market discount not includible in income under section 451(b)

Sep 27 - IRS releases draft instructions for Form 1040 for 2018

Sep 25 - Notice 2018-71: Employer credit, for paid family and medical leave unavailable to section 501(c)(3) organizations

Sep 24 -  Notice 2018-71: Employer credit for paid family and medical leave (Q&As)

Sep 24 - KPMG report: New section 163(j)—partnership issues

Sep 24 - KPMG report: New section 163(j)—selected issues

Sep 21 - IRS provides draft instructions for Form 8992 (GILTI)

Sep 21 - Notice 2018-75: Employer reimbursements made in 2018 for employee moving expenses in 2017

Sep 19 - Notice 2018-74: Modified “safe harbor” explanations for plan administrators to provide for recipients of rollover distributions

Sep 17 - Massachusetts: Measures concerning state tax implications of Code section 965 and GILTI provisions

Sep 17 - TTB guidance: “Single taxpayer” rules for excise tax credits, reduced rates on beer, wine, distilled spirits

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 13 - Ways and Means approves “tax reform 2.0” bills

Sep 11 - Ways and Means schedules markup of “tax reform 2.0” bills

Sep 10 -  Ways and Means announces introduction of “tax reform 2.0” bills 

Sep 10 - Maine: Federal tax conformity including measures concerning Code section 965 and GILTI provisions

Sep 8 - Update on proposed regulations under GILTI provisions

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

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