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TaxNewsFlash-United States — KPMG's reports of tax developments in the United States
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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: Status of digital services tax legislation, proposals
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 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 reports: Louisiana (passthrough entities); Mississippi (apportionment); Oregon (GILTI)
June 2019
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 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 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 - 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 13 - Final regulations: Health reimbursement arrangements, account-based group health plans
Jun 13 - Final regulations: Modification of discounting rules for insurance companies
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 - OIRA review completed, final regulations on health reimbursement arrangements (HRAs)
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 - 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 - 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 - IRS provides relief for taxpayers affected by Oklahoma storms, flooding
Jun 3 - Minnesota: Corporate conformity legislation, effective retroactively
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 - U.S. Treasury awards $3.5 billion in New Markets Tax Credit (NMTC) allocations
May 22 - Delaware: Unclaimed property, voluntary disclosure agreement “invitations” expected soon
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 - KPMG report: Remote sellers collecting tax (Louisiana, Virginia)
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: Excise tax on college net investment income (section 4968)
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 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 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 8 - Indiana: Sourcing rules for corporate income tax; marketplace facilitators to collect sales tax
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 1 - Rev. Proc. 2019-20: Expansion of retirement plan determination letter program
April 2019
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 23 - Kentucky: Second bill enacted under comprehensive tax legislative package
Apr 22 - IRS reminder for QI / WP / WT periodic-review certification
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 - IRS adds three new compliance campaigns (LB&I division)
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 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 - Updated FAQ, independence standard, external reviewer of QI / WP / WT
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 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)
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 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 - IRS practice unit: Foreign-initiated adjustments, competent authority guidance
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 - 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 - 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 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
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 - 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 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 - KPMG report: State legislative proposals, economic nexus for retailers
Feb 15 - IRS acquiescence: Tax Court decision, hockey team’s pregame meals as de minimis fringe benefit
Feb 13 - Virginia: Conformity bill pending signature by governor
Feb 12 - IRS National Taxpayer Advocate’s report for 2018
Feb 11 - KPMG report: Final section 263A regulations and taxpayers with “negative adjustments”
Feb 11 - KPMG report: Section 451(b) and new book-tax conformity rules
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 - 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 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 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 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 4 - IRS release, filing season for certain business tax returns
2018: TaxNewsFlash Year-in-review
December 2018
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 - 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 - 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 - 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 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 - 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 - 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 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 - 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)
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 - U.S. Tax Court: Medical-marijuana dispensary operator deficiency challenge denied
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 20 - Proposed regulations: Basic exclusion amount, estate and gift taxes (text of regulations)
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 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 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 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 - 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 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 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 - KPMG report: State actions concerning “Wayfair” decision (AL, CO, DC)
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 - KPMG report: Initial impressions of proposed GILTI regulations
Oct 12 - Proposed regulations under section 965; public hearing on October 22
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 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 3 - Proposed regulations under GILTI provisions released in Federal Register
Oct 3 - Notice 2018-76: Transitional guidance on deductibility of business meal expenses
Oct 1 - 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)
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 - 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 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 - 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: IRS Compliance Assurance Process (CAP) program for 2019
Sep 10 - KPMG report: State responses to “Wayfair” (IN, MD, NJ, OK, SD)
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 - 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 - 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 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 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 2018-67: 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 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 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 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 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 - 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 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 - 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 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 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 - 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
June 2018
Jun 29 - IRS releases draft “streamlined” Form 1040 for 2018 tax year
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 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 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 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 7 - Final regulations: Partnership transactions involving equity interests of a partner
Jun 7 - IRS updates list of FAQs on opportunity zones
Jun 5 - KPMG report: Mineral interest income, eligible for section 199A deduction?
Jun 5 - KPMG report: Tax reform and publicly traded partnerships
Jun 4 - Puerto Rico: Tax holiday for "back to school" purchases
Jun 4 - Third Circuit: No capital gains treatment, taxpayer retained technology rights
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 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 10 - Third quarter update to IRS, Treasury priority guidance plan 2017-2018
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 - SEC: Text of proposed rules, including “best interest” regulation
May 7 - New FAQs for QI / WP / WT certifications, periodic reviews
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 - Notice of clarification: Final rule on certain health care-related measures
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 - 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 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 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 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 - 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 - 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 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 - 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 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 26 - KPMG report: State, local tax changes (first quarter 2018, table)
Mar 23 - Tax technical corrections are enacted, include partnership provisions
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 9 - Announcement 2018-5: Pre-approved defined benefit plans; IRS to issue opinion, advisory letters soon
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 - 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 2 - Rev. Proc. 2018-18: Inflation adjustments for 2018, revised to reflect new tax law
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 - Qualified opportunity zones, revised census tracts offer new investment options
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 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 - 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 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 - 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 2 - IRS practice unit: Adjustments to debt basis
Feb 1 - Proposed regulations: Adjusting tax attributes under centralized partnership audit regime
January 2018
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 26 - Rev. Proc. 2018-11: Adequate disclosures to reduce accuracy-related penalty
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 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 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 2018-07: "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 - KPMG reports: Arkansas (REMICs); Indiana (databases); Ohio (gift baskets)
Dec 15 - Proposed regulations: Centralized partnership audit regime
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 - Rev. Rul. 2018-02: No alternative fuel mixture credit for butane and gasoline mixture
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 8 - IRS practice units: Tax items of U.S. persons residing abroad
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”
November 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 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 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)
October 2017
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 26 - Kautter appointed IRS “Acting Commissioner” effective November 13
Oct 24 - Insurance initiatives in 2017-2018 priority guidance plan
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 2017-59: Refund claim procedures, undyed diesel fuel removed from Milwaukee terminals
Oct 19 - LB&I directive for mining industry: Units of property, major components
Oct 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 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 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 - SEC provides regulatory relief for hurricane victims
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 - 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
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 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 - 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 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 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 - 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 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 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 - 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 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 - 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 - 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 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 14 - D.C. Circuit: Taxpayer lawsuit challenging voluntary disclosure program barred
Jul 13 - Washington State: Sales and use tax, economic nexus legislation enacted
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