Tax Reform (TCJA)

Read KPMG's analysis and observations, as well as industry or sector-specific reports about provisions in the TCJA

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Jun 27 - Notice 2022-30: Deferral of provisions under section 59A and 6038A regulations relating to reporting of qualified derivative payments

Jun 14 - KPMG report: Post-TCJA interplay between NOLs and charitable deductions

Jun 7 - Ninth Circuit: Mandatory repatriation tax under section 965 is constitutional

Jan 28 - KPMG report: Regulations addressing tax treatment of U.S. partnerships and S corporations that own stock of CFCs and PFICs

Jan 24 - Final regulations: Rules for determining stock ownership, sections 951A and 958 (text of regulations)

Jan 24 - Proposed regulations: Domestic partnerships and S corporations holding PFICs and CFCs (text of regulations)

Jan 5 - KPMG report: Initial analysis of final regulations concerning foreign tax credit

Jan 4 - KPMG report: Foreign tax credit and certain deductions of life insurance companies (final regulations)

Jan 4 - IRS practice unit: Overview of section 245A dividends received deduction

Dec 28 - Final regulations: Foreign tax credit and clarifying FDII (text of regulations)

Dec 22 - KPMG report: R&E changes from TCJA effective for tax years beginning after December 31, 2021

Dec 13 - Final regulations on foreign tax credit, clarification of FDII; OIRA review completed

Nov 29 - Final regulations pending OIRA review: Foreign tax credit, clarification of FDII

Sep 21 - Final regulations: Rules relating to qualified business asset investment (QBAI) (text of regulations)

Jun 18 - IRS practice unit: Concepts of GILTI

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sep 23 - Final regulations pending OIRA review: Consolidated NOLs

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

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

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

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

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

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

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

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

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

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

Sep 15 - Final regulations: Eligible terminated S corporations

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

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

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

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

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

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

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

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

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

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

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

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

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

Sep 1 - Regulations pending OIRA review: Foreign tax credit

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Jul 31 - KPMG report: Analysis of final FDII regulations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Jun 9 - Proposed regulations pending OIRA review: Consolidated NOLs

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Read archived articles [PDF 337 KB] of TaxNewsFlash-Tax Reform (TCJA)

• December 2017: Conference agreement for H.R. 1, Tax Cuts and Jobs Act—Initial observations [PDF 1 MB]
• December 2017: Senate tax reform bill—Initial observations on Senate-passed bill [PDF 1.45 MB]
• November 2017: House Republican tax reform bill—initial observations on Chairman Brady's mark [PDF 1.7 MB]
• September 2017: Unified framework for comprehensive tax reform—initial observations [PDF 1.0 MB]
• September 2015 (KPMG reports): International tax, patent boxes, and tax reform [PDF 3.62 MB]
• 2014: Tax reform proposals of W&M chairman [PDF 2.92 MB] (2014 "Camp report")

>> Read more on KPMG Institutes: Implementation of 2017 law

>> Return to the TaxNewsFlash U.S. homepage

Read industry or sector-specific reports about provisions in the new tax law: 

• KPMG report: Tax reform: Provisions relevant to compensation, benefits, & qualified plans [PDF 637 KB]
• KPMG report: New tax law: International provisions and observations [PDF 473 KB]
• KPMG report: Tax reform and the potential impacts to the banking industry [PDF 1.4 MB]
• KPMG report: Tax reform: Issues for exempt organizations (Pub. L. 115-97) [PDF 316 KB]
• KPMG report: New tax law: Energy & natural resources - Key provisions [PDF 1.8 MB]
• KPMG report: New tax law: Issues for partnerships, S corporations, and their owners [PDF 589 KB]
• KPMG report: Power and utilities industry measures in new tax law [PDF 944 KB]
• KPMG report: Tax reform, accounting for income taxes [PDF 1.3 MB]
• KPMG report: Accounting for U.S. tax reform under IFRS [PDF 511 KB]