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.