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Tax Update

Brief updates from the previous quarter on legislative, judicial, and administrative developments that may impact U.S. Japanese companies.

In this section, we provide a summary of brief updates from the previous quarter on legislative, judicial, and administrative developments in tax that may impact Japanese companies operating in the United States.

Navigating CAMT

Aug 14

CAMT areas with significant complexity or uncertainty

TaxNewsFlash No. 2023-280  (PDF)

Validating Form W-8BEN and BEN-E treaty claims

Aug 1

A KPMG report that discusses common questions about treaty claims

TaxNewsFlash No. 2023-267  (PDF)

Accounting for income taxes considerations for foreign tax credits following Notice 2023-55

Jul 27

A KPMG report discusses accounting for income taxes considerations of Notice 2023-55 under U.S. generally accepted accounting principles.

Accounting for income taxes considerations for foreign tax credits following Notice 2023-55  (PDF)

Underutilization of alternative dispute resolution programs

Jul 18

IRS alternative dispute resolution and prevention programs and how their underutilization impedes effective tax administration

Underutilization of alternative dispute resolution programs (PDF)

State conformity to federal treatment of section 174 R&E costs

July 13, 2023

Which states likely conform to the amendments to section 174, decouple from those changes, and issues raised by conformity to or decoupling

TaxNewsFlash No. 2023-242  (PDF)

Final regulations: Carryback of consolidated net operating losses

July 10, 2023

Final regulations that affect corporations filing consolidated returns

TaxNewsFlash No. 2023-238  (PDF)

Analysis and observations of direct pay and transferable credit proposed regulations

June 27, 2023

Summary of the operative rules, observations and practical implications

Direct pay and transferable credit proposed regulations  (PDF)

State tax implications of “Inflation Reduction Act”

June 16, 2023

Insights on how states approach conformity to federal tax laws and how states may conform to key provisions of the IRA

State tax implications of “Inflation Reduction Act”

Treasury and IRS release guidance on direct pay and transferable tax credits

June 14, 2023

Guidance documents relating to direct pay and transferable tax credits available under Inflation Reduction Act and CHIPS Act

TaxNewsFlash No. 2023-211  (PDF)

Notice 2023–42: Estimated tax penalty relief for corporations subject to CAMT

June 7, 2023

Relief for corporations that did not pay estimated tax related to the new corporate alternative minimum tax

TaxNewsFlash No. 2023-204  (PDF)

Accounting for tax credits handbook

May 2023

Final regulations that affect corporations filing consolidated returns

Handbook: Tax credits  (PDF)

For more information, please contact:

Tai Kimura | +1 408 367 2204 | tkimura@kpmg.com

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser. This article represents the views of the authors only, and do not necessarily represent the views or professional advice of KPMG.

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