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Recent Articles (2021)

Sep 1 - IRS practice unit: Foreign tax credit (business) general principles

Aug 24 - Notice 2021-51: Revised applicability date, withholding and reporting regarding publicly traded partnership interests

Aug 12 - Rev. Proc. 2021-35, Rev. Proc. 2021-34: Safe harbor method accounting, OID on pool of credit card receivables and related automatic consent

Aug 9 - KPMG report: Second set of corrective amendments to qualified opportunity fund regulations

Jun 18 - IRS practice unit: Concepts of GILTI

May 14 - Announcement 2021-10: Qualified opportunity zone boundaries not affected by 2020 census

May 11 - Rev. Proc. 2021-26: CFCs changing methods of accounting to alternative depreciation system

Apr 12 - Proposed regulations: Requirements under section 1400Z-2 for foreign persons, partnerships investing in qualified opportunity funds (text of regulations)

Jan 19 - KPMG report: Final regulations under section 163(j), limitation on deductions for certain business interest expenses

Jan 19 - Final regulations published: Domestic production activities deduction for agricultural, horticultural cooperatives

Jan 15 - KPMG report: Final and proposed regulations, passive foreign investment company (PFIC) rules

Jan 15 - KPMG report: Final regulations on carbon oxide sequestration credit

Jan 15 - KPMG report: Final regulations on “carried interest” under section 1061

Jan 15 - Final regulations released to Federal Register: Excise tax for excess remuneration and excess parachute payment

Jan 14 - Final regulations released to Federal Register: Air transportation excise taxes

Jan 14 - Final regulations released to Federal Register: Denial of deductions for fines, penalties

Jan 14 - Final and proposed regulations: Passive foreign investment company (PFIC) rules (text of regulations)

Jan 14 - Final regulations: Domestic production activities deduction for agricultural, horticultural cooperatives (text of regulations)

Jan 13 - Final regulations released to Federal Register: Limiting business interest expense deductions under section 163(j)

Jan 13 - Final regulations released to Federal Register: “Carried interest” provision under section 1061

Jan 13 - Final regulations released to Federal Register: Credit for carbon oxide sequestration under section 45Q

Jan 13 - KPMG report: Final section 4960 regulations on excise tax for excess remuneration and excess parachute payment for applicable tax-exempt organizations

Jan 12 - Final regulations: Denial of deductions for fines, penalties (text of regulations)

Jan 11 - Final regulations: Air transportation excise taxes (text of regulations)

Jan 11 - Final regulations: Excise tax on excess compensation, parachute payments made by tax-exempt organizations (text of regulations)

Jan 11 - Final regulations on denial of deductions for fines, penalties; OIRA review completed

Jan 8 - Final regulations: Domestic production activities deduction for agricultural, horticultural cooperatives; OIRA review completed

Jan 8 - TTB release: Craft beverage measures effective January 2021

Jan 7 - Final regulations on “carried interest” provision under section 1061 (text of regulations)

Jan 6 - KPMG report: Final regulations on changes to income recognition rules; initial impressions

Jan 6 - Final regulations on “carried interest” provision under section 1061; OIRA review completed

Jan 5 - Final regulations on limiting business interest expense deductions under section 163(j) (text of regulations)

Jan 5 - Final regulations released to Federal Register: Rollover rules for qualified plan loan offset amounts

Jan 5 - Final regulations pending OIRA review: Excise tax on tax-exempt organization compensation

2020 Articles

Dec 31 - Final regulations on limiting business interest expense deductions under section 163(j), OIRA review completed

Dec 31 - Final regulations released to Federal Register: Simplified accounting for small businesses, long-term contracts

Dec 30 - Final regulations released to Federal Register: Revenue recognition and timing of income inclusion under section 451

Dec 29 - Rev. Proc. 2021-9: Residential living facility safe harbor election under section 163(j)

Dec 28 - Final regulations released to Federal Register: Section 162(m) deduction limitation on executive compensation

Dec 28 - Final regulations pending OIRA review: “Carried interest” provision under section 1061 

Dec 23 - Final regulations: Simplified accounting for small businesses, long-term contracts (text of regulations)

Dec 21 - Final regulations: Revenue recognition and timing of income inclusion under section 451 (text of regulations)

Dec 21 - Final regulations pending OIRA review: Domestic production activities deduction for agricultural, horticultural cooperatives

Dec 21 - KPMG report: Final regulations, section 162(m) deduction limitation on executive compensation

Dec 18 - Final regulations: Deduction for employee remuneration in excess of $1 million (text of regulations)

Dec 17 - Final regulations pending OIRA review: Business interest expense deduction limitation under section 163(j)

Dec 15 - Final regulations released to Federal Register: Parking deduction limitations under section 274

Dec 15 - Final regulations pending OIRA review: Denial of deduction for fines, penalties

Dec 14 - Final regulations under section 451(b), OIRA review completed

Dec 10 - Final regulations released to Federal Register: Source of income for certain sales of personal property, inventory

Dec 9 - Final regulations: Qualified transportation and commuting expenses under section 274 (text of regulations)

Dec 7 - Final regulations: Rollover rules for qualified plan loan offset amounts (text of regulations)

Dec 2 - KPMG report: Final regulations under section 1031, like-kind exchanges

Dec 2 - KPMG report: Separately computed UBTI, analysis of final regulations

Nov 30 - Final regulations released to Federal Register: Like-kind exchanges

Nov 30 - Final regulations released to Federal Register: Separately computed UBTI

Nov 27 - Final regulations: Personal exemption at zero, implications for health plan premium tax credit

Nov 27 - Final regulations released to Federal Register: Withholding obligations incident to transfers of interests by foreign partners 

Nov 27 - Final regulations released to Federal Register: Coordinating section 245A and section 951A

Nov 24 - KPMG report: Analysis of final and proposed foreign tax credit regulations

Nov 24 - KPMG report: Final regulations under section 245A and 954(c)(6) and correcting amendments

Nov 23 - Final regulations: Like-kind exchanges (text of regulations)

Nov 23 - Regulations on exception from passive income for foreign insurance companies; OIRA review completed

Nov 20 - Final regulations: Coordinating section 245A “extraordinary disposition rule” with section 951A “disqualified basis rule” (text of regulations)

Nov 19 - Final regulations on like-kind exchanges, OIRA review completed

Nov 19 - Final regulations: Separately computed UBTI (text of regulations)

Nov 18 - Regulations pending OIRA review: Final regulations under section 451(b)

Nov 9 - Notice 2020-75: Future regulations, deductibility of payments by partnerships and S corporations for state and local income taxes

Nov 6 - Rev. Proc. 2020-50: Additional first year depreciation deduction; late elections allowed, or elections may be revoked

Nov 5 - Final regulations released to Federal Register: Additional first year depreciation deduction under section 168(k)

Nov 5 - Regulations released to Federal Register: Section 864(c)(8) treatment, sale of U.S. trade or business partnership interests on look-through basis

Nov 2 - Final and proposed regulations released to Federal Register: Foreign tax credit (text of regulations)

Oct 30 - KPMG report: Correcting amendments to final regulations, FDII and GILTI

Oct 29 - Final regulations pending OIRA review: Like-kind exchanges

Oct 23 - Final regulations released to Federal Register: Consolidated NOLs

Oct 22 - Regulations pending OIRA review: Exception from passive income for foreign insurance companies

Oct 21 - KPMG report: Final regulations on consolidated NOLs, inclusive of insurance company regulations

Oct 19 - Final regulations released to Federal Register: Eligible terminated S corporations

Oct 16 - Final regulations released to Federal Register: Deductions allowed estates, non-grantor trusts

Oct 15 - KPMG report: Initial impressions of final regulations, withholding and reporting obligations on dispositions of certain partnership interests

Oct 13 - Final regulations: Consolidated NOLs (text of regulations released by IRS)

Oct 12 - Final regulations on consolidated NOLs, OIRA review completed

Oct 12 - KPMG report: Treasury responds to insurance comments in proposed and final regulations on foreign tax credit 

Oct 9 - Final regulations released to Federal Register: Computing and reporting life insurance reserves

Oct 9 - Final regulations: “Qualifying relative” and personal exemption amount clarified

Oct 8 - Final regulations released to Federal Register: BEAT provisions under section 59A

Oct 7 - Final regulations: Withholding obligations incident to transfers of interests by foreign partners (text of regulations)

Oct 5 - Final regulations released to Federal Register: Federal income tax withholding from employees’ wages 

Oct 5 - KPMG report: Initial impressions of final and proposed foreign tax credit regulations

Oct 5 - KPMG report: Final regulations on source of income for certain sales of personal property, including inventory

Oct 2 - KPMG report: Final regulations on deductibility of meal and entertainment expenses (initial impressions)

Oct 1 - Final regulations: Guidance concerning ABLE accounts (text of final regulations)

Oct 1 - Final regulations: Federal income tax withholding from employees’ wages

Sep 30 - Final regulations: Deductibility of meal and entertainment expenses (text of regulations)

Sep 29 - Final and proposed regulations: Foreign tax credit (text of regulations)

Sep 29 - Final regulations: Source of income for certain sales of personal property, inventory (text of regulations)

Sep 28 - Final regulations: Income tax withholding, periodic retirement and annuity payments

Sep 23 - Final regulations pending OIRA review: Consolidated NOLs

Sep 23 - KPMG report: Initial impressions of final regulations, excise tax on college net investment income

Sep 22 - KPMG report: Initial impressions of final and proposed regulations, relief concerning repeal of section 958(b)(4)

Sep 22 - Final and proposed regulations on foreign tax credit; OIRA review completed

Sep 21 - Final and temporary regulations: Section 864(c)(8) and tax treatment on sale of U.S. trade or business partnership interests on a look-through basis (text of regulations)

Sep 21 - Final and proposed regulations: Relief provided concerning repeal of section 958(b)(4) (text of regulations)

Sep 21 - Final regulations: Additional first year depreciation deduction under section 168(k) (text of regulations)

Sep 21 - Final regulations: Deductions allowed estates, non-grantor trusts

Sep 18 - Final regulations: Excise tax on college net investment income (text of regulations)

Sep 17 - Final regulations on additional first-year depreciation under section 168(k), OIRA review completed

Sep 16 - Final regulations: Rehabilitation credit and rules coordinating with other credits, released to Federal Register

Sep 15 - Final regulations: Eligible terminated S corporations

Sep 15 - Final regulations: Rehabilitation credit and rules coordinating with other credits (text of regulations)

Sep 15 - KPMG report: Final regulations on computing and reporting life insurance reserves (initial impressions)

Sep 14 - KPMG report: New safe harbor in proposed like-kind exchange regulations

Sep 14 - KPMG report: Proposed regulations define “real property” for like-kind exchanges

Sep 9 - Final regulations, Rev. Rul. 2020-19: Computing and reporting life insurance reserves for insurance companies (text of guidance)

Sep 9 - Final regulations, excise tax on college net investment income; OIRA review completed

Sep 8 - Regulations on business interest expense deduction limitations under section 163(j); effective date and reliance clarifications and changes

Sep 3 - Business interest expense deduction limitations under section 163(j), regulations released to Federal Register

Sep 3 - KPMG report: Highlights of final BEAT regulations under section 59A

Sep 3 - KPMG report: Regulations under sections 245A, 951A, 954 (GILTI); treatment of dividends from foreign corporations

Sep 3 - Regulations pending OIRA review: Section 168(k) final regulations on additional first-year depreciation

Sep 1 - Final regulations: BEAT provisions under section 59A (text of regulations)

Sep 1 - Notice 2020-69: Future regulations to address QBAI for FDII, GILTI purposes and qualified investment property treatment

Sep 1 - Regulations pending OIRA review: Foreign tax credit

Aug 25 - Final regulations pending OIRA review: Excise tax on college net investment income

Aug 24 - Final regulations: “BEAT” provisions under section 59A, OIRA review completed

Aug 21 - Regulations under sections 245A, 951A, 954; treatment of dividends from foreign corporations (text of regulations)

Aug 17 - KPMG report: Proposed regulations on qualified parking deductions

Aug 17 - Proposed regulations: Rollover rules for qualified plan loan offset amounts

Aug 14 - Rev. Proc. 2020-39: Normalization rules for public utilities, 2017 tax law changes (TCJA)

Aug 13 - KPMG report: Analysis of final and proposed regulations, high-tax exception under GILTI and subpart F

Aug 12 - KPMG report: Proposed regulations on carried interest, initial analysis

Aug 8 - Regulations under section 954, coordinating rules under sections 245A and 951A; OIRA review completed

Aug 7 - Final regulations: Payments made to charities in return for consideration (text of regulations)

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 credit 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 credit (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)

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