United States

United States

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

1000
TaxNewsFlash-United States

To subscribe to TaxNewsFlash, fill out the subscription form


New tax law in the United States
Read KPMG's analysis and observations, as well as industry or sector-specific reports about provisions in the new tax law

Recent Articles

July 2019

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 - 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: 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

February 2018

Feb 28 - IRS updates Form W-4, “withholding calculator” to reflect tax law changes

Feb 27 - Notice 2018-19: “Physical presence” test extension; individuals in hurricane-affected U.S. territories

Feb 27 - Qualified opportunity zones, revised census tracts offer new investment options

Feb 26 - KPMG reports: New Mexico (refund claims); Pennsylvania (online marketplaces); Texas (intercompany services); West Virginia (federal tax conformity)

Feb 23 - Rev. Proc. 2018-20: Safe harbor extended, mortality tables of life insurance contracts

Feb 22 - Final regulations: Health insurance provider fee

Feb 20 - Proposed rule: “Short-term, limited-duration insurance” to expand to 12 months

Feb 19 - KPMG report: Qualified opportunity zone investments under new U.S. tax law

Feb 19 - KPMG reports: Arkansas (advertising); Indiana (software); New York (federal tax law changes); Rhode Island and Connecticut (CEO pay ratio)

Feb 15 - Rev. Proc. 2018-17: Effects of prohibited tax year changes for “specified foreign corporations”

Feb 15 - Eleventh Circuit: Deposit forfeited on canceled sale of hotel, not capital gain

Feb 14 - Rev. Proc. 2018-17: Initial impressions, section 965 and “specified foreign corporations” changing tax years

Feb 14 - Reminder: “Oil spill” excise tax now extended through 2018

Feb 13 - Proposed regulations: 298 regulations to be withdrawn, 79 modified

Feb 13 - U.S. Treasury awards $3.5 billion, New Markets Tax Credit allocations

Feb 13 - Rev. Proc. 2018-17: "Specified foreign corporations" changing tax year, application of section 965

Feb 12 - KPMG reports: Connecticut (business tax); Idaho (federal tax conformity); Wisconsin (online legal support)

Feb 9 - Insurance initiatives in IRS priority guidance plan, second quarter update

Feb 9 - IRS practice unit: Foreign personal holding company income, common exceptions

Feb 8 - IRS guidance projects, implementing new tax law provisions

Feb 8 - President to nominate Rettig to be IRS Commissioner

Feb 8 - Rev. Proc. 2018-16: Qualified opportunity zone, guidance to states’ chief executive officers

Feb 8 - Notice 2018-17: Expanded low-income housing credit hurricane-related relief, Puerto Rico

Feb 7 - Changes to EIN application form, instructions for “check-the-box” entities

Feb 7 - New IRS instructions: Form 7004 automatic extension of time to file business income tax, other returns

Feb 7 - Rev. Proc. 2018-14: Extended safe harbor, personal residence repairs of concrete foundations

Feb 6 - IRS release: New tax law, no changes to pension plan cost-of-living adjustments for 2018

Feb 5 - KPMG report: How does U.S. BEAT apply to inbound companies?

Feb 5 - KPMG reports: Missouri (tax proposals); New York (human tissue); Pennsylvania (NOLs); Texas (tax amnesty)

Feb 2 - IRS practice unit: Adjustments to debt basis

Feb 1 - Proposed regulations: Adjusting tax attributes under centralized partnership audit regime

January 2018

Jan 31 - Notice 2018-15: IRS no longer processing new clean renewable energy bonds; section 54C repealed by new tax law

Jan 29 - FAQs recharacterization of Roth IRA contributions under new tax law

Jan 29 - Notice 2018-14: Withholding tax guidance, implementing new income tax law

Jan 29 - U.S. Tax Court: Effects of tax returns filed with Virgin Islands’ tax bureau

Jan 29 - KPMG reports: Louisiana (intangibles addback); Michigan (sourcing); Ohio (“fracking”); Texas (software)

Jan 26 - Rev. Proc. 2018-11: Adequate disclosures to reduce accuracy-related penalty

Jan 25 - Rev. Proc. 2018-13: Unpaid loss discount factors, salvage discount factors for 2017 accident year (insurance)

Jan 24 - Medical device excise tax moratorium once again extended, through 2019

Jan 24 - KPMG report: State and local tax, technology-related guidance (table, fourth quarter 2017)

Jan 23 - Rev. Proc. 2018-12: Safe harbors for “continuity of interest” requirement, value of stock in certain reorganizations

Jan 22 - KPMG reports: New York (federal tax reform); New York (carried interest); Texas (nexus); Multistate (annual use tax reports)

Jan 19 - Notice 2018-13: Additional guidance about “transition tax” on foreign earnings (new Code section 965)

Jan 18 - U.S. Tax Court: Loan guarantees by CFCs includible in taxpayer’s gross income; regulations upheld as valid

Jan 18 - Updated FAQs, information about country-by-country reporting

Jan 17 - Notice 2018-10: Failure-to-deposit penalty relief relating to medical device excise tax

Jan 17 - KPMG report: Accounting for U.S. tax reform under IFRS

Jan 16 - LB&I directives on transfer pricing examinations

Jan 16 - Insurance: IRS concludes some foreign currency agreements are not insurance

Jan 15 - KPMG reports: Arkansas (pollution control); California (surgical instruments); Ohio (tax amnesty); Pennsylvania (penalty assessments)

Jan 12 - U.S. Supreme Court: Certiorari granted in South Dakota case seeking to overturn “Quill”

Jan 12 - Notice 2018-01: Passports revoked, denied for certain tax delinquencies

Jan 11 - IRS releases updated 2018 withholding tables, implementing new tax law changes

Jan 11 - IRS practice unit: Stock basis ordering rules

Jan 10 - IRS practice unit: Self-employment tax in U.S. territories

Jan 9 - Rev. Rul. 2018-04: Revised covered compensation tables for 2018 plan year

Jan 8 - IRS release: New mailing address for Form 8809

Jan 8 - KPMG reports: Indiana (manufacturing exemption); Kansas (use tax); Pennsylvania (bonus depreciation)

Jan 8 - U.S. states start to address federal tax reform

Jan 5 - KPMG report: Tax reform, accounting for income taxes

Jan 5 - U.S. Treasury’s list of countries cooperating with international boycott, no changes

Jan 3 - “Oil spill” excise tax has expired; possible issues for refiners, importers

Jan 2 - U.S. Tax Court: Statute of limitations for certain omissions of gross income

Jan 2 - IRS practice unit: Substantial contribution test for CFC manufacturing exception

Jan 2 - Medical device excise tax resumes, moratorium has expired

2017 Articles

December 2017

Dec 29 - Notice 2018-08: Revised timeline, guidance on implementing new section 1446(f), publicly traded partnerships

Dec 29 - Notice 2018-07: "Transition tax" on foreign earnings (new Code section 965)

Dec 29 - Insurance: Mandatory repatriation considerations under new tax law

Dec 29 - Final regulations: Election out of centralized partnership audit regime

Dec 29 - IRS releases annual revenue procedures for 2018

Dec 27 - IRS release on pre-paying 2018 state and local property taxes

Dec 22 - SEC statement on new tax law in the United States

Dec 22 - FBAR filings: Deadline extended for certain individuals with signature authority  

Dec 22 - Notice 2018-06: IRS extends health coverage form deadline for employers, providers  

Dec 22 - President signs tax bill into law

Dec 21 - Notice 2018-05: Transition rules for withholding agents extended for 2018, 2019

Dec 21 - Rev. Rul. 2018-03: Film packages and domestic production activities deduction under section 199

Dec 21 - KPMG report: State, local tax changes (table summarizing 2017 developments)

Dec 18 - Proposed regulations: CFC’s foreign currency gain, loss; election for mark-to-market accounting for section 988 transactions

Dec 18 - KPMG reports: Arkansas (REMICs); Indiana (databases); Ohio (gift baskets)

Dec 15 - Proposed regulations: Centralized partnership audit regime

Dec 15 - Ninth Circuit: No capital gains treatment of royalties, “all substantial rights” in patents not transferred

Dec 15 - IRS practice unit: Initial stock basis

Dec 14 - Notice 2018-03: Standard mileage rates, increases for 2018

Dec 14 - U.S. Tax Court: Foreign tax credits for “compulsory levies” paid by Mexican branch

Dec 14 - Notice 2017-71: More relief for partnerships, REMICs, others with late-filed Form 1065 and Form 1066 in 2017

Dec 14 - Notice 2018-02: Updated mortality improvement rates, tables for defined benefit pension plans (for 2019)

Dec 14 - Rev. Rul. 2018-02: No alternative fuel mixture credit for butane and gasoline mixture

Dec 13 - Rev. Procs. 2018-08, 2018-09: Safe harbor methods for determining casualty, hurricane-related losses of individuals

Dec 13 - IRS practice unit: Calculation of the section 956 inclusion

Dec 13 - KPMG report: Quarterly summary of accounting, financial reporting developments for companies

Dec 11 - New FAQs for QI / WP / WT

Dec 11 - KPMG report: IFRS accounting for taxes, levies in the United States

Dec 11 - KPMG reports: Colorado (combined reporting); Colorado (nexus); Indiana (sourcing); New Jersey (foreign taxpayer)

Dec 8 - IRS practice units: Tax items of U.S. persons residing abroad

Dec 8 - Notice 2017-75: Future regulations to offer relief from section 409A, payments accelerated to pay income taxes

Dec 6 - Notice 2017-74: Individual taxpayers without available marketplace “bronze-level plan”

Dec 6 - KPMG report: Partnership disguised sale rules may be changing

Dec 5 - Notice 2017-72: Qualified retirement plans, 2017 “required amendments list”

Dec 4 - KPMG reports: New York (information services); Pennsylvania (refund claims); Tennessee (taxpayer conferences); Utah (foreign operating company)

November 2017

Nov 30 - Notice 2017-71: Expanded relief for late-filed partnership, REMIC, and other related Forms 1065 and 1066 filers in 2017

Nov 29 - Proposed regulations: Interplay of centralized partnership audit regime and international tax rules

Nov 29 - Tier 2 tax rates, no changes for 2018

Nov 29 - U.S. Tax Court: Timely filed petition, postage from approved commercial vendor

Nov 27 - Puerto Rico: More guidance providing tax relief following Hurricane Maria

Nov 22 - Rev. Proc. 2017-60: Safe harbor, personal residence repairs of certain concrete foundations

Nov 21 - Extended time, health and pension plans affected by Hurricane Maria

Nov 21 - IRS practice units, common ownership or control under Code section 482

Nov 21 - IRS update to jurisdiction status table, country-by-country reporting

Nov 20 - PLR: F reorganization, from Country A branch of U.S. life insurance company to Country A section 953(d) company

Nov 20 - KPMG reports: Connecticut (combined reporting); Pennsylvania (net loss limits); Tennessee (cloud computing); Vermont (nexus)

Nov 14 - KPMG report: Accounting for income taxes considerations of adopting new revenue recognition guidance

Nov 13 - Rev. Proc. 2017-59: Changes in method of accounting, section 481 adjustment period

Nov 13 - Rev. Rul. 2017-22: Covered compensation tables for 2018 plan year

Nov 13 - KPMG reports: Arkansas (tangible property sales); Colorado (combined returns); Mississippi (economic nexus); Pennsylvania (subscription fees)

Nov 9 - Ninth Circuit: Debt vs. equity implications for foreign tax credits

Nov 9 - Notice 2017-70: Leave-based donation payments, 2017 California wildfires

Nov 7 - IRS audit-related rule changes, financial reporting of partnership tax underpayments

Nov 7 - Pennsylvania: Enacted legislation concerns NOL carryovers, remote sellers, sales tax

Nov 6 - KPMG reports: Indiana (software); Massachusetts (passthroughs); New York (HMO taxation)

Nov 3 - IRS identifies new LB&I “compliance campaigns”

Nov 1 - IRS reminder: ITIN renewals due by end of 2017

October 2017

Oct 31 - Announcement 2017-15: Hardship distributions, loans from retirement plans, hurricane and wildfire relief

Oct 31 - IRS reminder: Electronically filed 2016 tax returns due by November 18; disaster victims and others need to file on paper after November 18

Oct 31 - Notice 2017-67: Qualified small employer health reimbursement arrangements 

Oct 31 - Treasury updates low-income community eligibility data, New Markets Tax Credit

Oct 30 - Notice 2017-68: Expanded hurricane-related relief from “United States property” designation for CFCs

Oct 30 - KPMG report: New employee retention credit, hurricane-related relief

Oct 30 - KPMG reports: Colorado (contract manufacturing); New Jersey (basis adjustment); Ohio (remote sellers); Oregon (bicycle excise tax)

Oct 26 - Kautter appointed IRS “Acting Commissioner” effective November 13

Oct 24 - Insurance initiatives in 2017-2018 priority guidance plan

Oct 23 - KPMG reports: Illinois (manufacturing exemption); Maryland (employee activities); New York (sales tax refunds)

Oct 20 - IRS “business plan” for 2017-2018 includes “burden reducing” projects

Oct 20 - Puerto Rico: Updated guidance on tax deadlines, following Hurricane Maria

Oct 19 - IRS practice unit: Withholding under FIRPTA, sales by individuals

Oct 19 - Rev. Proc. 2017-58: Inflation adjustments for 2018

Oct 19 - Notice 2017-64: Pension plans, cost-of-living adjustments for 2018

Oct 19 - Notice 2017-66: New clean renewable energy bonds, applications for reallocation to public power providers

Oct 19 - Notice 2017-59: Refund claim procedures, undyed diesel fuel removed from Milwaukee terminals

Oct 19 - LB&I directive for mining industry: Units of property, major components

Oct 19 - Second package of proposed regulations withdrawn; definition of “political subdivision” for tax-exempt bonds

Oct 18 - Final regulations: Tax treatment of federal financial assistance provided banks, domestic building and loan associations, and related parties

Oct 18 - Pennsylvania: NOL flat-dollar cap held to violate uniformity clause; taxpayer not allowed an uncapped NOL

Oct 17 - Proposed regulations under section 2704 are withdrawn

Oct 17 - IRS practice units about land development, check-the-box, USRPHC status

Oct 17 - QI / QDD / WP / WT applications for 2017; due November 17

Oct 16 - IRS relief: Taxpayers affected by California wildfires; new counties added

Oct 16 - Do not overlook possible tax implications of NAFTA re-negotiations

Oct 16 - KPMG reports: District of Columbia (digital goods); New Jersey (nexus); Oregon (Portland’s pay-ratio surtax); Multistate (voluntary disclosure)

Oct 16 - KPMG report: Tax reform implications for low-income housing credit

Oct 13 - IRS relief, taxpayers affected by California wildfires

Oct 13 - IRS nonacquiescence: Material participation in real estate activities under section 469

Oct 13 - KPMG report: State and local tax, technology-related guidance (table, third quarter 2017)

Oct 11 - Proposed regulations: Removal of signature requirement from section 754 elections

Oct 10 - IRS practice unit: Failure to file Form 5471, penalties for Category 2 and 3 filers

Oct 10 - Rev. Procs. 2017-56, 2017-57: Changes to defined benefit plan funding method

Oct 10 - U.S. Tax Court: Interest on deficiency when tax-exempt status is revoked

Oct 10 - U.S. Tax Court: No charitable contribution deduction for facade easement, not “in perpetuity”

Oct 9 - KPMG reports: California (water’s-edge election); Colorado (electronic sales); South Dakota (physical presence); Washington State (retail space)

Oct 6 - Notice 2017-61: Self-insured health insurance annual fee

Oct 6 - Notice 2017-62: Employer leave-based donation programs to aid Hurricane Maria victims

Oct 6 - Puerto Rico: Further guidance, relief in response to hurricanes

Oct 6 - Regulations: Exemptions and accommodations for preventive, contraceptive services

Oct 4 - Final report: Treasury regulations, responding to executive order to reduce tax burden

Oct 4 - Notice 2017-56: Disaster relief, “physical presence” test extended, individuals in hurricane-affected U.S. territories

Oct 4 - SEC provides regulatory relief for hurricane victims

Oct 3 - KPMG report: Casualty loss deductions related to hurricanes, claims by individual taxpayers; updated to reflect new law

Oct 3 - Final regulations: Mortality tables for defined benefit pension plans

Oct 3 - Delaware: Companies to be invited, unclaimed property voluntary disclosure program

Oct 2 - Notice 2017-57: Deferred effective date, foreign currency regulations under section 987

Oct 2 - Notice 2017-58: Hurricane-related filing extension; disclosures of “syndicated conservation easement transactions”

Oct 2 - Puerto Rico: Tax authority’s guidance on tax deadlines, following hurricanes

Oct 2 - U.S. Tax Court: Nonresident’s unemployment compensation held taxable income under treaty with Canada

Oct 2 - KPMG report: Accounting for uncertainty in income taxes under IFRS and U.S. GAAP

Oct 2 - KPMG reports: Alabama (business license); Illinois (internet sales); New York (combined reporting); Wisconsin (corporate tax)

September 2017

Sep 29 - President signs aviation tax and hurricane tax-relief legislation

Sep 29 - Rev. Proc. 2017-46: Updated list of countries, deposit interest paid to nonresident aliens

Sep 29 - Rev. Rul. 2017-19: Fringe benefit aircraft valuations for second half 2017

Sep 28 - IRS hurricane-relief, emergency housing for disaster victims

Sep 27 - KPMG report: Unified framework for comprehensive tax reform, initial observations

Sep 27 - Notice 2017-53: One-year extension of time to replace livestock, drought-related sales

Sep 27 - Notice 2017-55: Hurricane-related relief from section 956(c) “United States property” designation for CFCs

Sep 27 - Proposed regulations: Tax-exempt private activity bonds, issued by state and local governments, public approval requirements

Sep 26 - IRS summarizes hurricane-related tax relief 

Sep 25 - IRS extends diesel fuel penalty waiver; Hurricane Irma-related shortages

Sep 25 - Notice 2017-54: Per diem rates, substantiation of employee lodging, meals, incidentals (2017-2018)

Sep 25 - Notice 2017-46: Reporting TINs by FFIs under FATCA Model 1 intergovernmental agreements

Sep 25 - KPMG reports: Alaska (dividends received deduction); Texas (packaging supplies); Wyoming (electricity)

Sep 25 - Final regulations: Withholding from, information reporting on certain gambling winnings

Sep 22 - IRS provides tax relief, victims of Hurricane Maria in Puerto Rico, U.S. Virgin Islands

Sep 22 - LB&I directive: Research credit for increasing research activities under section 41

Sep 22 - KPMG report: State, local tax changes (third quarter 2017, table)

Sep 21 - Rev. Proc. 2017-52: New policy for letter rulings, transactions under section 355

Sep 19 - IRS provides hurricane-related tax relief for taxpayers in Georgia

Sep 19 - IRS offers fuel penalty relief; hurricane-related shortages of ultra low sulfur diesel fuel

Sep 18 - KPMG report: Casualty loss deductions, hurricane-related damage

Sep 18 - LB&I practice units about transfer pricing issues

Sep 18 - Proposed regulations: Truncated TINs for wage and tax statements furnished to employees

Sep 18 - KPMG report: GAO recommendations for low-income housing credit program

Sep 18 - KPMG report: Open-ended guidance, certain stock distributions of RICs (Rev. Proc. 2017-45)

Sep 18 - KPMG reports: Alabama (group losses); Illinois (financing entities); Massachusetts (internet vendors)

Sep 15 - IRS expands tax relief to hurricane victims in Florida

Sep 15 - Proposed regulations: Definitions of “registration-required obligation” and “registered form”

Sep 14 - KPMG report: Tax relief available for businesses affected by Hurricane Irma

Sep 14 - Notice 2017-52: Employer leave-based donation programs to aid Hurricane Irma victims

Sep 14 - IRS practice units: Foreign tax credits, sourcing of income, other topics

Sep 14 - South Dakota: State’s high court upholds “Quill” physical presence standard

Sep 12 - IRS provides tax relief for taxpayers affected by Hurricane Irma

Sep 12 - IRS allows retirement plan loans, hardship distributions relating to Hurricane Irma

Sep 12 - IRS waives dyed diesel fuel penalty; shortages due to Hurricane Irma

Sep 12 - Notice 2017-47: Penalty relief for late-filed partnership returns applies to REMICs

Sep 12 - Notice 2017-51: Marginal well production credit under section 45I; reference price (2016)

Sep 11 - U.S. Tax Court: Estate tax return of predeceased spouse, determining allowable DSUE

Sep 11 - KPMG reports: Indiana (throwbacks); New York (service receipts); Virginia (tax amnesty)

Sep 7 - Rev. Proc. 2017-47: Safe harbor for public utilities, “normalization rules” violations

Sep 6 - Virginia: Related-party addback rule and “subject to tax” exception

Sep 5 - IRS expands dyed diesel fuel penalty relief for Texas

Sep 5 - KPMG report: Disaster relief; tax implications when employers help employees

Sep 1 - Notice 2017-47: Penalty relief for late-filed partnership returns in 2017

Sep 1 - KPMG report: Tax relief available for businesses affected by Hurricane Harvey

August 2017

Aug 31 - Notice 2017-45: Nondiscrimination relief for “closed” defined benefit plans extended through 2018

Aug 30 - U.S. Tax Court: No refund, taxes not paid within lookback period

Aug 30 - IRS announces retirement plan loans, hardship distributions to hurricane victims

Aug 30 - IRS waives dyed diesel fuel penalty because of hurricane-related shortages

Aug 30 - List of countries for country-by-country reporting data exchanges 

Aug 28 - IRS provides tax relief, taxpayers in 18 Texas counties affected by Hurricane Harvey

Aug 28 - KPMG reports: Massachusetts (disaster losses); New Jersey (click-through nexus); North Carolina (interest deduction); Wisconsin (software licensing)

Aug 25 - Rev. Proc. 2017-44: Foreign insurance companies; effectively connected net investment income (2016)

Aug 22 - KPMG report: No deduction for amounts paid captive insurance company (U.S. Tax Court’s opinion)

Aug 22 - U.S. Tax Court: Lifetime gifts, marital deduction asserted in summary judgment motions

Aug 21 - Notice 2017-44: Model amendments adding bifurcated benefit distribution options, defined benefit plans

Aug 21 - U.S. Tax Court: Cement company’s depletion deduction rate for calcium carbonates

Aug 21 - U.S. Tax Court: No deduction for amounts paid to captive insurance company

Aug 21 - Insurance: CCA addresses qualification under section 816(a)

Aug 21 - Colorado: Use tax reporting requirements, proposed rules

Aug 21 - KPMG reports: Arkansas (tax credits); Minnesota (loss limitation); Texas (sales tax exemption); Texas (costs of goods sold)

Aug 14 - KPMG reports: New York (captive insurance); New York (internet access); Texas (apportionment); Washington State (real estate excise tax)

Aug 11 - FAQs: IRS Appeals conferences, attendance by IRS Compliance personnel

Aug 11 - IRS nonacquiescence: Like-kind “reverse exchange” when title held by exchange facilitator

Aug 11 - IRS now accepting country-by-country report (Form 8975)

Aug 10 - IRS reminder about heavy highway vehicle use tax return deadline; Form 2290 due August 31

Aug 9 - Multistate Tax Commission’s special voluntary disclosure program for remote sellers; sales and use tax and state income tax

Aug 8 - IRS letters sent to taxpayers with ITINs expiring in 2017

Aug 8 - Rhode Island: Expanded tax reporting requirements for non-collecting retailers; tax amnesty program

Aug 7 - U.S. Tax Court: Taxpayers limited in charitable contribution deduction, since not “qualified farmers”

Aug 7 - KPMG report: “Convenience of the employer” exclusion for meal deductions

Aug 7 - KPMG report: Implications of “Grecian Magnesite Mining” opinion for private equity funds

Aug 7 - KPMG report: Section 467 can have outsized impact on REITs

Aug 7 - KPMG reports: Colorado (local use tax); Massachusetts (drop-shipments); Minnesota (combined returns); Ohio (forward contracts)

Aug 4 - Notice 2017-42: Additional time to comply with section 871(m) regulations

Aug 3 - Notice 2017-41: Voluntary reporting of catastrophic health insurance coverage

Aug 3 - U.S. Senate confirms Treasury Assistant Secretary for Tax Policy

Aug 1 - Eighth Circuit: No RRTA tax on stock payments, union contract ratification payments

Aug 1 - U.S. Treasury: List of countries cooperating with international boycott

July 2017

Jul 31 - Illinois: Cook County (Chicago) sweetened beverage tax, update

Jul 31 - KPMG reports: Arizona (amusement taxation); New Hampshire (mergers); Nevada (return due date); Texas (franchise tax)

Jul 31 - Puerto Rico: New sales tax prepayments, first due date either August 15 or September 15

Jul 28 - Notice 2017-36: “Documentation regulations” under Reg. section 1.385-2 delayed by one year

Jul 28 - Insurance: PLR allows taxpayer to revoke section 953(d) election

Jul 28 - Puerto Rico: Estimated sales tax rules; room occupancy tax amendments

Jul 28 - Treasury to end myRA program, savings retirement program

Jul 27 - U.S. Tax Court: Intercompany loan balance, guaranty by CFC constitute “United States property”

Jul 27 - Administration and congressional Republican leaders release statement on tax reform

Jul 26 - U.S. Tax Court: Cancellation of APAs held IRS abuse of discretion; deduction allowed for bonus payments as employee compensation

Jul 26 - California: Sales and use tax exemption, manufacturing and R&D equipment

Jul 25 - Illinois: Unclaimed property law is significantly revised

Jul 25 - KPMG report: State and local tax, technology-related guidance (table, second quarter 2017)

Jul 24 - Final regulations: Annual fee imposed on manufacturers, importers of branded prescription drugs

Jul 24 - Final regulations: Health insurance premium tax credit under section 36B

Jul 24 - IRS Appeals to allow “virtual” conferences with taxpayers

Jul 24 - Hearing scheduled on proposed regulations; nuclear power plant decommissioning

Jul 24 - KPMG reports: California (manufacturing exemption); Ohio (nexus); Washington State (internet sourcing)

Jul 21 - Puerto Rico: Package of tax incentives enacted

Jul 18 - Regulations: Return due dates, extended due date amendments

Jul 17 - KPMG report: Foreign partners: U.S. Tax Court rejects IRS’s position in Rev. Rul. 91-32

Jul 17 - KPMG reports: Colorado (use tax); Illinois (soda tax); Indiana (sale of subsidiary); Washington State (B&O tax); Washington State (Seattle residents)

Jul 14 - D.C. Circuit: Taxpayer lawsuit challenging voluntary disclosure program barred 

Jul 13 - U.S. Tax Court: Foreign company’s capital gain not effectively connected income; Rev. Rul. 91-32 is rejected

Jul 13 - Washington State: Sales and use tax, economic nexus legislation enacted

© 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.


For more detail about the structure of the KPMG global organization please visit https://kpmg.com/governance.

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.

Connect with us

Stay up to date with what matters to you

Gain access to personalized content based on your interests by signing up today