KPMG Tax Publishes
Access our most recent (and archived) KPMG-authored articles published in tax and business journals.
KPMG Tax professionals share their knowledge about and contribute to the discussion of important tax topics by publishing in industry journals. Reprints of their articles are cataloged here.
Recent articles
IRS Notice 2026-53 and DOE Release Reshape §45Z Clean Fuel Credit
October 21, 2026 | In this article, the authors discuss evolving IRS and DOE guidance on the §45Z clean fuel production credit, including expanded fuel pathways and model changes that could significantly affect credit calculations and compliance. | Tax Management Memorandum
Encouraging Domestic Investment in U.S. Infrastructure
October 7, 2026 | In this article, the authors discuss how the U.S. government has used the tax code for decades to signal national economic priorities—for example, through accelerated depreciation for manufacturing, research credits for innovation, and production tax credits for clean energy but it has never promulgated a purpose-driven definitional framework for essential infrastructure as a distinct category of national economic purpose. | Tax Notes Federal
A Comprehensive Guide to Digital Asset Tax Legislation
September 25, 2026 | In this article, the authors provide a detailed description as well as contrasts of the discussion drafts considered at a recent House Ways and Means Committee hearing, as well as prior digital asset proposals and discussion documents against earlier digital asset legislative efforts. | Journal of Taxation of Financial Products
Do Mobile Workers Create Permanent Establishment, TP Challenges?
September 24, 2026 | In this article, the authors explain that, as greater global mobility and connectivity continue to reshape where employees and senior executives are based, KPMG surveyed 22 member firms to examine the transfer pricing challenges arising across jurisdictions.| Tax Management International Journal
The 1% Floor on Charitable Deductions May Erode NOL Carryovers
September 8, 2026 | In this article, the authors discuss that C corporations with NOL carryovers may see those carryovers reduced as a result of OBBBA’s new 1% floor on charitable contribution deductions. | Tax Management Memorandum
Looming Social Security Reform Could Reshape Client Tax Planning
September 3, 2026 | In this article, the authors say that Social Security's trust funds face depletion by 2032 and Congress is weighing a range of tax-focused reforms that could significantly affect financial and tax planning. | Tax Management Memorandum
How Digital Refunds Affect Global Mobility Programs: Lessons From the First Year
July 2, 2026 | In this article, the authors evaluate outcomes from the 2026 filing season and identify emerging patterns. | Tax Notes Federal
Is Your APA Strategy Ready for the IRS’s Acceptance Standards?
June 26, 2026 | In this article, the authors explain why taxpayers contemplating an APA in 2026 face a more rigorous—though clearer—pre-filing landscape with the IRS’s acceptance process for advance pricing agreements, or APAs, now incorporated in the Internal Revenue Manual and thus firmly entrenched in administrative guidance and policy. | Tax Management International Journal
Research Credit Audits: Updates and Considerations
June 22, 2026 | In this article, the authors focus on key developments affecting research credit reporting and enforcement initiatives, including recent revisions to Form 6765, Credit for Increasing Research Activities, and case law updates, as well as examination observations and considerations. | Tax Notes Federal
The Remarkable Resilience of Inbound Private Equity Structures
June 17, 2026 | In this article, the authors examine recent international tax developments that could affect private equity buyers’ decision-making on whether to adopt an inbound or U.S.-parented structure. |Tax Notes Federal
Reported FIFA 2026 World Cup Tax Deal Hasn’t Changed Fundamentals
June 5, 2026 | In this article, the authors discuss the new development surrounding the 2026 FIFA World Cup from the U.S. Treasury and its broader complexities. | Tax Management International
Time’s Up! A Refresher on Tax Statutes of Limitations
May 25, 2026 | In this article, the authors provide an overview of various statutes of limitations for assessment and refunds—including extension requests—with practical insights based on their experiences. | Tax Notes Federal
Archived articles
2026
CAMTyland Adventures, Part VIII: Notice 2026-7’s Rainbow Cards Offer New Moves
May 8, 2026 | In this article, the authors explore the intricate game path created by the most recent corporate alternative minimum tax notice, which offers additional interim guidance for navigating the CAMT regime. This eighth installment of a series focuses on Notice 2026-7.| Tax Notes Federal
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APAs in 2025: Surprising Success, With Challenges for the Future
May 6, 2026 | IN this article, the authors examine the IRS’s 2025 annual report on advance pricing agreements and analyze how, despite operational constraints from the government shutdown and the effects of tariffs, APAs remain a critical tool for managing transfer pricing uncertainty. | Tax Notes International
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Will New OECD Guidance Make Mutual Agreement Procedures More Effective?
April 23, 2026 | In this article, the authors explain that, despite the MEMAP’s nonbinding status, it provides clear and comprehensive end-to-end guidance on MAP and useful template documents, which can help taxpayers and tax administrations, particularly in low-capacity jurisdictions, navigate MAP successfully. | Tax Notes International
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Don’t Let Your IP Transfer Pricing Catch You Off Guard
April 20, 2026 | In this article, the authors warn that as fast-growing companies expand across borders, failing to align intellectual property ownership with where value is created can trigger significant tax and deal risks. | Bloomberg’s Tax Management International Journal
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No Need to Reboot: GenAI Fits the Tax Stack
April 2, 2026 | In this article, the authors explore the taxation of artificial intelligence under existing rules and highlight challenges with two alternative proposals. | Tax Notes Federal
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Academic, Religious Groups Confront Unique Social Security Rules
March 19, 2026 | In this article, the authors say that maintaining cognizance of unique requirements that religious organizations and institutions of higher learning often face not only helps ensure that employers remain compliant, but also protects employees by allowing them to enjoy adequate retirement income. | Tax Management International Journal
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FIFA 2026 World Cup Blows the Whistle on Complex Tax Risks
March 9, 2026 | In this article, the authors say that in the upcoming 2026 FIFA World Cup' s complex web of tax and social security challenges, understanding and addressing the intricate cross-border financial and regulatory issues will help ensure a smooth and compliant tournament for all participants. | Bloomberg’s Tax Management International Journal
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Who Won Gold with the Latest CAMT Guidance from Treasury?
February 27, 2026 | In this article, the authors say that Notice 2026‑7 offers notably broad CAMT relief across repairs, intangibles, domestic R&E, qualified production costs, materials and supplies, distressed companies, and certain international provisions. While among the most taxpayer‑favorable guidance to date, it leaves compliance challenges as final regulations remain pending. | Bloomberg’s Tax Management Memorandum
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Fuel Tax Refund Implementation Encounters Appropriation Hurdles
February 16, 2026 | In this article, the authors provide historical context to how the One Big Beautiful Bill introduced a long-awaited fuel tax refund provision, section 6435, allowing refunds of fuel excise taxes imposed on fuel that is subsequently dyed for a nontaxable use. | Bloomberg’s Tax Management Memorandum
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Can Soaring Tech Salaries Still Qualify for R&D Tax Credits?
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Can the OECD Reshape Cross-Border Work Taxation in a Digital Age?
January 29, 2026 | In this article, the author elaborates on practical solutions for cross-border workforce taxation in response to an OECD consultation on the mobility of individuals—where KPMG was among the stakeholders to contribute detailed insights. | Bloomberg’s Tax Management International Journal
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AI Reshapes Software R&D Tax Credits, Eligibility Landscape
January 28, 2026 | In this article, the authors explore how AI-assisted development fits the four core R&D tests, providing insight into how evolving methodologies may affect eligibility and highlighting the need for updated frameworks as AI and GenAI reshape the software development process and questions arise about the effect on section 41 research and development tax credit eligibility. | Bloomberg’s Tax Management Memorandum
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Expatriates, Cross-Border Workers Must Plan for Social Security
January 22, 2026 | In this article, the author says that international workers and retirees must consider a complex array of factors in planning for future Social Security benefits, including totalization agreements, work impacts, foreign benefits, timing, location, taxation, as well as OBBBA Medicare changes. | Bloomberg Tax Management International Journal
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2025
IRS Keeps Focus on R&D Tax Credit Even as Agency Staff Shrinks
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Legislative Update: The Lummis Crypto Bill and White House Report on Digital Assets
December 23, 2025 | In this article, the authors outline various digital asset legislative proposals, analyze their implications, compare them with the White House report to highlight areas of agreement and divergence on policy, and discuss additional industry issues not addressed by the Lummis bill. | Journal of Taxation of Financial Products
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A Global Survey on the Application of the Control of Risk and DEMPE Frameworks: Switzerland
December 10, 2025 | In this article, the authors summarize findings from a KPMG member firm survey of how tax authorities around the world apply the OECD control of risk framework and the transfer pricing guidelines on development, enhancement, maintenance, protection, and exploitation of intangibles. | Tax Notes International
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How Countries Stack Up in OECD’s 2024 APA Statistics Report
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Dispute Prevention and Resolution Options: Prefiling Update
November 28, 2025 | In this article, the authors revisit the IRS’s options for dispute prevention and provide updates and insights on the prefiling agreement and industry issue resolution programs. | Tax Notes Federal
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How do US-Asia Trade Agreements affect DSTs, FDDEI and VAT
November 7, 2025 | In this article, the authors explain about the US trade agreements announced with Cambodia and Malaysia, as well as the framework agreements announced with Thailand and Vietnam, noting that although the agreements primarily impact bilateral trade between these countries and the US, particularly the rate of customs duties imposed, various provisions and statements focus on other tax issues. | Tax Management International Journal
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Navigating the New 1 Percent Floor on Corporate Charitable Deductions
November 3, 2025 | In this article, the authors explain the new 1 percent floor on corporate charitable deductions and options for corporations that will allow them to avoid suffering permanent disallowances of deductions equal to 1 percent of their taxable income every year. | Tax Notes Federal
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The Good, the Bad, and the Ugly of Distressed QOZ Businesses
October 29, 2025 | In this article, a survival guide for businesses in varying states of financial distress, the authors offer solutions for qualified opportunity zone businesses —categorizing them as the good, the bad, and the ugly to correspond to the magnitude of the hardships a QOZ business may encounter and the relative ease with which it might be able to find a solution. | Tax Notes Federal
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Mexico’s Supreme Court Clarifies Tax Refund Procedures, Deadlines
October 28, 2025 | In this article, the authors explain why requesting a tax refund in Mexico can be a complicated process and provide practical information and tips on what taxpayers should do before, during, and after submitting a tax refund request to keep the process efficient, avoid lengthy legal battles, and ideally get a refund quickly. | Tax Management International Journal
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Customs Enforcement Tightens: Are you Prepared for the Scrutiny?
October 7, 2025 | In this article, the author unpack the latest developments in customs enforcement—including aggressive government audits, the rise of whistleblower actions, and the real possibility of civil and criminal penalties for individuals—while providing practical insights and strategies needed to navigate this new era, protect your organization, and safeguard yourself from costly missteps | Tax Management International Journal
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Sales And Use Tax Strategies For Renewables After OBBBA
September 18, 2025 | In this article, the authors emphasize the importance of managing sales and use tax risks for solar and wind projects in the post-OBBBA federal tax environment. | Law 360
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CAMTyland Adventures, Part VII: Will the OBBBA Crack Snow Flake Lake?
September 22, 2025 | In this article, the author explore the effect of the One Big Beautiful Bill Act on application of the corporate alternative minimum tax in the seventh installment of the “CAMTyland Adventures” series | Tax Notes Federal
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Strict Construction and the Interpretation of Tax Regulations
September 26, 2025 | In this article, the authors revisit the canon of strict construction and provide insights based on recent developments from the U.S. Supreme Court and the Tax Court. | Tax Notes Federal
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Employee Retention Credit Rules Are Still Progressively Evolving
September 11, 2025 | In this article, the author notes the Employee Retention Credit rules evolve post-expiration. Taxpayers should assess options, await IRS actions, or consult advisors for refund claims as Congress amends the law. | Bloomberg's Tax Management Memorandum
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New R&E Expensing Procedures Are Complex With Favorable Options
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CAMTyland Adventures
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IRS APA Statistics Highlight Key Country-Specific Trends
August 8, 2025 | In this article, the authors outline the IRS’s annual report on advance pricing agreements and offer country-specific insights for taxpayers navigating the evolving global tax landscape. | Tax Notes International
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Wyden’s Partnership and Basis-Shifting Acts: A CliffsNotes Version
July 23, 2025 | In this article, the author reviews two bills by Senate Finance Committee that aim to alter partnership tax rules, recognizing that these proposals may not be enacted soon, taxpayers should still study and comment on them since legislative proposals can persist, especially from a taxwriting committee member with a revenue score. | Tax Notes Federal
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IRS Announces Improvements to Its Pre-Filing Agreement Program
July 16, 2025 | In this article, the authors discuss recent changes to the IRS’s Pre-Filing Agreement program. | Tax Notes: Procedurally Taxing
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Two if by Sea: The Role of Tax in the U.S. Shipping Revolution
July 15, 2025 | In this article, the author examines President Trump’s Executive Order 14269, “Restoring America’s Maritime Dominance,” and the tax provisions of the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025. | Tax Notes Federal
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External articles in The Tax Adviser
July 10, 2025 | This collection of articles covers various tax topics, including the Announcement 2024-40 on CHIPS Act-funded construction, clean fuel credits, excise taxes, e-invoicing, partnerships, citizenship-based taxation, retail delivery fees, trade management, foreign tax credits, and taxation of platforms. | The Tax Adviser
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How Intellectual Property Payments Impact US Tariffs on Goods
July 10, 2025 | In this article, the authors say merchandise importers may owe significantly increased duties when the US CBP determines that customs values include not only the value of the goods, but also related royalty and license fees. | Tax Management International Journal
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The Proposed New SALT Regime and Passthroughs: More SALTy Than Sweet?
June 24, 2025 | In this article, the authors examine key provisions of the One Big Beautiful Bill passed by the House concerning the new state and local tax regime and provide critical takeaways affecting passthroughs and partnerships that are paying or accruing taxes subject to the new SALT cap | Tax Notes Federal
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“Materiality” Limits Service Deductions in Mexico: Key Takeaways
June 24, 2025 | In this article, the authors advise that multinationals with Mexican subsidiaries should review recent guidance on documenting the “materiality” of service expenses and consider using advance pricing agreements to avoid uncertainty. | Bloomberg Tax Management International Journal
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Take 2: Evaluating the Revised Retaliatory Measures in the House Bill
June 17, 2025 | In this article, the authors analyze the revised versions of two proposed retaliatory tax measures, consolidated in proposed section 899, now before the Senate as part of the budget reconciliation package, assessing whether the more significant modifications to those now-combined proposals are consistent with Congress’s stated policy goals in responding to “unfair” taxes imposed by foreign countries | Tax Notes Federal
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What Are Common Transfer Pricing Pitfalls in Cash Pooling?
June 12, 2025 | In this article, the authors explore some common pitfalls faced by multinationals in structuring their cash pooling arrangements. Cash pooling arrangements are more intricate than simply setting arm’s length interest rates and book-keeping of deposits and loans. Cash pooling is not observed between unrelated parties, making it challenging to have an optimum yet robust transfer pricing policy. | Bloomberg’s Tax Management International Journal
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New York Ruling on Out-of-State Online Retailers Misses the Mark
June 6, 2025 | In this article, the authors say that an appellate court should give due consideration to legislative intent if they get an opportunity to review a New York trial court’s recent decision that upheld additional income tax obligations on out-of-state online retailers | Bloomberg Tax Insights
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New CAMT Notice: Reasons Taxpayers Are Breathing a Sigh of Relief
June 4, 2025 | In this article, the authors list ten reasons why the new CAMT guidance following last year's release of a complex set of proposed rules is welcome by taxpayers (both in-scope and out-of-scope) appearing in-line with the Trump administration’s deregulatory agenda and desire to decrease administrative burdens placed on taxpayers. | Tax Management Memorandum
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Dreaming of infallibility periodic adjustments under reg section 1482 4
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Limited Benefit From Potential New Domestic Manufacturing Incentives
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Indian Global Capability Centers - what is the cost of delivery
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How Digital Refunds Affect Global Mobility Programs
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Seeking Certainty in an Uncertain Era for Financial Transactions
In this article, the authors examine certain options for companies managing risk and uncertainty regarding significant financial transactions in the current financial climate. | Tax Notes International
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Tax considerations for Cryptocurrency Investors
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Factory Building Expensing as a Domestic Production Incentive Raises Questions
In this article, the authors discuss the potential for Congress to create an incentive entitling taxpayers to expense the cost of buildings placed in service and used in certain manufacturing activities, and offer considerations for policymakers looking to incentivize investment in the United States.
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Any Domestic Manufacturing Incentive Will Need Updated Definitions
In this article, the authors offer reasons why Congress should update the definition of software to align with modern changes in technology, especially if a domestic manufacturing incentive is included in the upcoming tax bill. | Tax Notes Federal
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Dispute Prevention and Resolution Options — Which Is Right for You?
In this article, the authors explore options the IRS provides for dispute prevention and resolution and the agency’s new pilot programs for alternative dispute resolution. | Tax Notes Federal
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Evaluating Possible U.S. Retaliatory Tax Measures
In this article, the authors explore some key issues presented by four retaliatory tax measures now under consideration by President Trump and Congress to respond to discriminatory or extraterritorial taxes imposed by foreign countries.| Tax Notes International
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Deregulatory Actions Hit the Tax World in Real Time
In this article, the authors talk about the Priority Guidance Plan’s refection of the Trump administration’s deregulatory agenda presenting both opportunities and risks for taxpayers | Bloomberg Tax Management Memorandum
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How Uncertain and Unexpectedly High Tariffs Will Impact TP
In this article, the authors analyze how the imposition of tariffs may affect multinationals pricing their intercompany transactions and the additional risk of tax authority disputes in ““How Uncertain and Unexpectedly High Tariffs Will Impact TP | Tax Management International Journal
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Supply Chains May Be Strengthened With Agile Global Mobility
In this article, the authors provide insights into how companies can adapt their global talent and mobility management to sustain supply chain resilience due to tariff-induced challenges. | Tax Management International Journal
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Recent Developments in Research Credit Audits and Compliance
In the rapidly changing landscape of the section 41 research credit, staying updated is essential for both taxpayers and practitioners.
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IRS Focus on High-Income and High-Wealth Individuals: An Update
April 9, 2025 | In this article, the authors update their prior article on the IRS’s renewed focus on audits of high-income and high-wealth individuals by discussing recent IRS activity and experiences in these audits. | Tax Notes Federal
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Unraveling the Timing and Character of Revolver Net-back Payments
The humble revolving credit facility has become an increasingly popular investment for credit-orientated private investment funds
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Did the Tax Treatment of Your Futures Contracts Just Change?
The Internal Revenue Service (“IRS”) recently released Rev. Rul. 2024-22,1 which designated the Bourse de Montreal (“MX”) as a qualified board or exchange (“QBE”), and Rev. Rul. 2024-23,2 which designated the European Energy Exchange (“EEE”) as a QBE.
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A Conversation on Debt Workouts in Commercial Real Estate
In this article, the author explains the income tax consequences for borrowers that are looking to refinance their properties, restructure existing debt, or walk away from an asset. | Tax Notes Federal
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New Year Old Tax Law Will Section 199 Make a Comeback
In this article, the authors consider the possibility that Congress will restore the former section 199 domestic production activities deduction, and they explain the changes necessary for it to work effectively with current provisions. | Tax Notes Federal
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Risks Abound for Corporate Minimum Tax Proposal's Early Adopters
In this article, the authors analyze proposed regulations for corporate alternative minimum tax, saying that applying them early to the 2024 tax year risks companies locking into unfavorable rules | Bloomberg Tax Insights
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The Effect of Digital IP on Taxation and Transfer Pricing
March 3, 2025 | In this article, the authors highlight examples of the digital transformation that is creating transfer pricing issues for multinational enterprises unique to the transfer or licensing of digital intangible property, and explain how investments in digital can address these issues and create value. | Tax Notes International
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How Can GenAI Improve My Transfer Pricing Process?
March 26, 2025 | In this article, the authors analyze some challenges and opportunities that firms should consider when deciding whether to use GenAI in the transfer pricing process. | Bloomberg Tax Management International Journal
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Does Transfer Pricing Have a Loper Bright Problem?
April 8, 2025 | In this article, the authors consider how the Supreme Court’s decision in Loper Bright may affect the application of section 482, the first sentence of which serves as the basis for the entire U.S. transfer pricing system but does not squarely address one of Loper Bright’s guardrails — the question of delegation. | Tax Notes Federal
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IRS Furloughs Demand Tax Pros’ Close Documentation and Patience
October 10, 2025 | In this article, the author shares practical insights on navigating the uncertainties caused by the furlough of IRS employees not performing essential activities, which has raised concerns among tax professionals trying to meet the Oct 15 filing deadline. | Bloomberg Tax Insights
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New Notices Make CAMT Regime More Favorable But More Complex
October 7, 2025 | In this article, the authors say that new IRS notices bring welcome guidance for taxpayers facing CAMT woes and many applicable corporations will be able to use the new (and optional) adjustments, methods, and elections to reduce their CAMT liabilities; nevertheless, notwithstanding these changes, the CAMT regime remains a complex and parallel minimum tax regime | Tax Management Memorandum
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Dispute Prevention and Resolution Options: Postfiling Update
November 10, 2025 | In this article, the authors revisit the IRS’s options for dispute resolution and provide updates and insights on the Large Business and International Division examination process and the fast-track settlement, accelerated issue resolution, and rapid Appeals process programs. | Tax Notes Federal
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How Will Generative AI Affect Value Chains and Transfer Pricing?
As GenAI continues to evolve, companies should monitor potential changes in their business models and value chains to understand the impact on existing transfer pricing structures and policies.
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Tariffs and Advance Pricing Agreements
November 21, 2025 | In this article, the authors examine the considerations specific to advance pricing agreements that arise when transfer pricing covered by an APA is materially affected by tariffs. | Tax Notes Federal
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2024
The Commensurate With Income Standard in Transfer Pricing
In this article, the authors examine the evolution of the commensurate with income standard, its current and prospective application, and its practical implications for taxpayers. | Tax Notes International
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Transfer Pricing: One-Way Street or a Dead End?
In this article, the authors examine the United Kingdom’s “one-way street” transfer pricing rule and weigh the benefit of maintaining this approach versus providing greater flexibility for taxpayers to make self-initiated downward adjustments. | Tax Notes International
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KPMG Picks Its 2023 Advance Pricing Agreement Award Winners
In this article the authors talk about how for the first time ever, the OECD released country-specific APA statistics for 2023 that provide insight on the times required to complete APAs and the size of jurisdictions’ APA programs, including many jurisdictions that do not otherwise publish APA statistics. | Tax Management International Journal
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Italian Audits and TP: Jump Out of the Frying Pan into the Fire?
Italian Audits and TP: Jump Out of the Frying Pan into the Fire?
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US-Chile Treaty Builds Tax Certainty for MNEs with MAPs and APAs
In this article, the authors advise that with Chilean tax authorities increasing audits, MNEs should consider using MAPs and APAs under the newly ratified US-Chile income tax treaty to avoid double taxation and achieve tax certainty. | Tax Management International Journal
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Charting a Course Through the IRS’s Business Aircraft Campaign
Justin Donatello and Andrew R. Roberson are principals and Rachel A. Garcia is a senior associate in the tax controversy and dispute resolution group of the Washington National Tax Practice of KPMG LLP.
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SN Worthington: Another Tool for Statutory and Regulatory Construction
By Andrew R. Roberson, Gregory T. Armstrong and Rebecca Rochelle
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Subchapter K in a Historic Tax Year: Preexisting Proposals as Menu Options
In this article, the authors Tucker review a menu of potential subchapter K changes on the table and consider the probability of their passage in 2025, when some provisions of the Tax Cuts and Jobs Act expire. | Tax Notes Federal
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AI May Take Transfer Pricing Up a Notch but Carries Some Risk
Transfer pricing is unique among all tax areas in that it requires very different data from a wider variety of sources.
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How LATAM's Principal Purpose Tests Impact Holding Companies
In this article, the authors say that the adoption of anti-treaty shopping measures like the principal purpose test in Latin American jurisdictions complicates the analysis of whether treaty benefits will continue to be available for holding companies, and the scope of protection for a grandfathered holding structure remains unclear. | Tax Management International
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Federal Credit Sales May Create Unexpected State Tax Headaches
In this article, the authors warn that taxpayers generating, selling, and using federal renewable energy credits should beware of potential state tax liability if a state doesn’t conform to federal income exclusions | Tax Management Memorandum
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Tax Incentives Help Firms Harness Cost Reduction Opport
In this article, the authors say that companies should strategize identifying and understanding the appropriate tax incentives established under The Inflation Reduction Act, CHIPS Act, and the US Foreign-Trade Zones Program in order to promote their financial goals. | Tax Management International Journal
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CAMTyland Adventures, Part V Coping With CAMTyland Grief
by Monisha Santamaria, Natalie Tucker,
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Worldwide Trends in Transfer Pricing
September 30, 2024 | In this article, the authors examine common transfer pricing issues arising in audits across the globe and emphasize the importance of maintaining comprehensive local files to document factual, functional, and economic analyses to ensure compliance and reduce risk. | Tax Notes International
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A Global Survey on the Application of the Control of Risk and DEMPE Frameworks: Japan
by Koichiro Fujimori, Nicolas A. Karolewicz, Jessie Coleman, and Alistair Pepper
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Reconsidering Maquiladoras in Light of Recent Reforms
by Eduardo Mendez, Cameron Taheri, and Thomas D. Bettge
September 23, 2024 | In this article, the author explains recent Mexican tax reforms and why businesses may need to reconsider the structure of Mexican manufacturing operations. | Tax Notes International
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A Global Survey on the Application of the Control of Risk and DEMPE Frameworks: India and South Korea
Aug 26, 2024 | In this article, the author summarize findings from a KPMG member firm survey of how tax authorities around the world are applying the OECD control of risk framework and the transfer pricing guidelines on development, enhancement, maintenance, protection, and exploitation of intangibles. | Tax Notes International
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A Cause for Distress? Allocation of Payments in Insolvency Workouts
Aug 26, 2024 | In this article, the authors examine the history of payment allocation in the context of distressed debt and explain why the payment ordering rules are best interpreted as inapplicable to a distressed debt satisfaction. | Tax Notes Federal
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Businesses Tax Liabilities Would Face Change Under UN Tax Treaty
Aug 21, 2024 | In this article, the authors review the UN’s efforts to create a new tax treaty and say that given the potential impacts of the negotiations, businesses should monitor the UN process and engage to ensure policymakers in all countries understand the potential consequences of the different policy choices that are on the table. | Bloomberg Tax Insights
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Controlled Foreign Corporations as Collateral After the TCJA
In this article, the author explores situations in which U.S. multinational borrowers might incur a section 956 inclusion as a result of using controlled foreign corporation stock or assets as collateral, and he describes the factors that must be evaluated when providing such collateral as well as the strategies that can be undertaken to avoid the inclusion | Tax Notes Federal
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Record APA Execution Rates Indicate Return to Prepandemic Operations
July 22, 2024 | In this article the authors examine the IRS’s annual report on advance pricing agreements and offer insights for taxpayers navigating the changes
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BEPS and Pillar 2 Are Here — Where in the GLOBE Are Your Employees
July 22, 2024 | In this article, the authors examine how correctly reporting employee numbers, locations, and costs will benefit multinational enterprises under Pillar 2
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Transfer Pricing in Brazil: Timing is Everything
July 10, 2024 | In this article, the authors discuss that with the shift in Brazil to a transfer pricing system that is largely consistent with the OECD Guidelines, multinational enterprises operating in Brazil should quickly work to analyze and carefully document their Brazil operations for TP purposes—and try to minimize year-end TP adjustments
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Lessons from SN Worthington (part 2)
July 8, 2024 | In this article, the author continues his discussion of SN Worthington, saying the court’s analysis in the case can be instructive as the IRS continues to emphasize partnership compliance
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IRS Rewards Credit Card Banks With Earlier Deductions
July 8, 2024 | In this Article, the authors advice regarding a bank’s tax accounting for its credit card rewards program and the implications for the rewards programs of other businesses | Tax Notes Federal
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SN Worthington: Electing Into the Centralized Partnership Audit Regime
July 5, 2024 | In this article, the author discusses a Tax Court case that addressed for the first time the application of the Bipartisan Budget Act centralized partnership audit regime to a partnership that elected to be subject to that regime early | Tax Notes: Procedurally Taxing
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The New Proposed Excise Tax Regulations
July 1, 2024 | In this article, the author gives an overview of certain rules in proposed regulations on the excise tax imposed on stock repurchases, as those rules relate to financial products. | Journal of Taxation of Financial Products
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energy-tax-credit-monetization-challenges
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The Tax Adviser Tax Clinic
July 1, 2024 | In this article, the author covers the new clean fuel credit, BBA partnership adjustments, R&D credit nuances, expatriation tax enforcement, VAT for remote sellers, and state tax code conformity.| The Tax Adviser
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Mortar in the Cracks: New Amount B Guidance
June 20, 2024 | In this article, the authors discuss how recent guidance from the OECD/G20 Inclusive Framework fills gaps in the Amount B architecture and provides valuable insight into which jurisdictions may implement Amount B | Tax Management International Journal article.
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Mexican GAAR: Recent Ruling Leads to More Questions Than Answers
June 14, 2024 | In this article, the authors say that companies should prepare robust defense files and documentation to show business purpose in their transactions in light of a recent Mexican court ruling on the General Anti-Abuse Rule in | Tax Management International Journal
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Assessing the Impact of Amount B
June 3, 2024 | In this article, the authors discuss the challenges businesses may face when implementing the OECD’s Amount B initiative. | Tax Management International Journal
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IRS Removal of Automatic Accounting Methods Sure to Disappoint
June 3, 2024 | In this article, the authors review revised automatic accounting method procedures and encourage taxpayers to revisit their timetables for implementation of certain accounting method changes. | Bloomberg Tax Insights
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Tax Court Invalidates Treasury Reg in Extension Case of First Impression
May 15, 2024 | In this article, the authors discuss Abdo v. Commissioner, a case in which the Tax Court invalidated a Treasury regulation interpreting section 7508A(d)’s automatic and mandatory extension for filing a Tax Court petition. | Tax Notes: Procedurally Taxing
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Treasury’s Stock Buyback Rule Offers Corporations Little Clarity
April 30, 2024 | In this article, the author highlights that if Treasury finalizes regulations proposed earlier this month addressing the 1% excise tax on corporate stock repurchases without any changes, foreign-parented multinational groups likely would face significant challenges in determining their excise tax liability. | Bloomberg Tax Insights
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CAMTyland Adventures, Part IV: Retroactive Tax Extenders—Planning for a Move-Backward Card
April 22, 2024 | In this article, the authors reference the familiar game Candy Land as a guide to help taxpayers navigate the corporate alternative minimum tax system. This fourth installment of a series explains the effects of H.R. 7024 on the corporate alternative minimum tax and offer suggestions for companies preparing tax strategies under the possibility of the bill’s enactment. | Tax Notes Federal
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Saving Private Equity: Avoiding Phantom Inversions
April 22, 2024 | In this article, the authors explain how the rules concerning disqualified stock and non-ordinary-course distributions can inappropriately create an inversion under section 7874, and they argue that the IRS should amend the safe harbor de minimis exception. | Tax Notes Federal
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Considering and Negotiating an Advance Pricing Agreement
April 12, 2024 | In this article, the authors provide an overview of advance pricing agreements (APAs), including the different types of APAs taxpayers may consider and a description of the US Advance Pricing and Mutual Agreement program. | Bloomberg’s Tax Management International Journal
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Global C-Suite Must Adapt to Booming Digital Reporting Mandates
April 8, 2024 | In this article, the author discusses the significance of e-invoicing and digital reporting as mandates by tax authorities worldwide is sparking major change for digital tax compliance. | Bloomberg Tax Insights
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Recent DCL and Pillar 2 Guidance: Comments and Recommendations
April 2, 2024 | In this article, the author discusses how Treasury must make significant changes to the U.S. dual consolidated loss rules to avoid unintended consequences created by the Pillar 2 rules. | Tax Management International Journal
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Unexpected Coordination: Partnership Audit Rules and Specific IRS Forms
April 1, 2024 | In this article, the authors examine income tax form instructions for partnerships and demonstrate how taking into account prior year adjustments under the Bipartisan Budget Act of 2015 in accordance with those instructions can lead to surprising outcomes. | Tax Notes Federal
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Transfer Pricing and ESG, Part 2: Improving Governance by Operationalizing Transfer Pricing
March 25, 2024 | In this article, the second installment in a three-part series on the intersection between tax and environmental, social, and governance policies, the authors focus on ways multinational corporations can use operational transfer pricing as a mechanism to ensure compliance with their transfer pricing approach and their tax policy. | Tax Notes International
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The New Proposed Bad Debt Regulations
March 11, 2024| In this article, the author gives an overview of the rules in the proposed regulations under section 166 which provides rules addressing bad debt deductions for certain qualifying entities. | Journal of Financial Products
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Chile and Hungary Treaty Status Changes: Potential FATCA Impacts
March 4, 2024 | In this article, the author discusses how the changes to the statuses of the US-Chile Treaty and US-Hungary Treaty could have substantial FATCA implications for withholding agents, foreign financial institutions, and their counterparties. | Bloomberg’s Tax Management International Journal.
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Post-Pandemic State Tax Policies Are a Kaleidoscope in Motion
February 26, 2024 | In this article, the authors examine factors taxpayers should consider as the state fiscal policy landscape shifts in response to falling state tax revenue. | Bloomberg Tax Insights
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CAMTyland Adventures, Part III: 2023 Scope Bubble Corporations —Lost in Lollipop Woods
February 26, 2024 | In this article, the authors reference the familiar game Candy Land as a guide to help taxpayers navigate the corporate alternative minimum tax system. This third installment of a series focuses on the uncertain rules for the 2023 tax year. | Tax Notes Federal
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HMRC Guidance: A New Transfer Pricing Risk to Control
February 21, 2024 | In this article, the authors discuss how businesses should review HMRC’s recent guidance clarifying their interpretation of the OECD’s control of risk framework to determine what risks they might face. | Bloomberg's Tax Management International Journal
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IRS User Fees for APAs Increase but Remain Attractive
February 23, 2024 | In this article, the authors discuss recent increases in user fees for advance pricing agreement applications. | Tax Notes
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Fixing Federal Tax Return Mistakes: Taxpayer Options
February 19, 2024 | In this article, the author explains self-help options for handling tax mistakes in different contexts. | Tax Notes Federal
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2023
California Court Ruling on Interstate Tax Law Will Make Waves
February 12, 2024 | Shirley Sicilian explains why a California court hearing could determine the role of a federal law involving state taxation of interstate businesses in the era of online commerce. | Bloomberg Tax Insights
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Mexican Rulings: Exportation of Services Eligible for 0% VAT
February 2, 2024 | In this article, the authors discuss how MNEs who are deciding whether to migrate certain service-intensive functions to Mexico to qualify for the 0% VAT rate should perform a case-by-case analysis to determine where the place of “enjoyment” of the particular transaction occurs. | Bloomberg Tax, Tax Management International Journal
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Proposals to De Minimis Customs Rules Spike US Importer Interest
While Congress is reexamining the de minimis customs rules, US importers should prepare for potential changes and optimize their operations and compliance programs in conformity with the evolving landscape, say KPMG practitioners.
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Avoiding Common Pitfalls in Oil and Gas Reserve Valuations
January 29, 2024 | In this article, the authors discuss how the key to an oil and gas company’s compliance with U.S. tax reporting requirements is performing impartial valuations of the fair market value of its assets. | Bloomberg’s Tax Management Memorandum
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Navigating the Shifting Landscape of Research Credit Audits
January 22, 2024 | In this article, the authors examine the IRS’s audit efforts related to the research credit under section 41, what can be expected in that type of audit, and options for resolving a research credit audit. | Tax Notes Federal
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Advice memorandum shows IRS approach to intercompany debt pricing
January 15, 2024 | In this article, the authors discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt. | International Tax Review
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The Practical Tax Mechanics of Implementing SEC Clawbacks
January 15, 2024 | In this article, the authors examine the SEC’s new clawback rules that went into effect on December 1, 2023, and the mechanics of repaying previously paid compensation to employers. | Tax Notes Federal
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Treaty notifications and MAP access: a small filing with a big impact
In this article, the authors discuss how multinationals companies face numerous year end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties. | International Tax Review
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Foreign Tax Credits for Multinationals Involve a Winding Path
In this article, the authors analyze businesses’ ability to credit qualified domestic minimum top-up taxes, based on new IRS and US Treasury guidance | Bloomberg Tax Insights
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The Death of the Indirect Tax Return
In this article, the authors explore the future of indirect taxation and the indirect tax return, explaining how technology will play a major role in the development of future tax reporting regimes. | Tax Notes International
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Pillar 2 Watch Out: Is there a US Sandwich in Your Structure?
November 21, 2023 | In this article, the authors discuss that US MNEs should review their org chart to identify US sandwich entities held through foreign entities located in jurisdictions that will have an income inclusion rule in effect in 2024. | Tax Management International Journal
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Transfer Pricing Implications of the Pillar Two Minimum Tax Rules
December 14, 2023 | KPMG professionals discuss four reasons why businesses would benefit from involving their transfer pricing teams more closely as they prepare for Pillar Two. | Tax Management International Journal
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IRS Refocuses on Enforcement of High-Income and High-Wealth Individuals
December 4, 2023 | In this article, the authors examine the evolution of the IRS Global High Wealth Industry Group, the renewed focus on audits of high-income and high-wealth individuals, and what can be expected in that type of audit. | Tax Notes Federal
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Tax-Free Fixed Indemnity Healthcare for Employees: End of a Dream
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Transfer Pricing Takeaways from 2022's MAP Statistics
November 22, 2023 | KPMG Tax professionals discuss the OECD’s 2022 MAP statistics which provide taxpayers insight into the effectiveness of the MAPs around the world, allowing taxpayers to gauge whether a particular case will be resolved in an efficient and timely manner. | Tax Management International Journal
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Adjusting Closed-Year Partnership-Related Items
October 30, 2023 | In this article, the authors examine important statute of limitations issues raised by the partnership rules in the Bipartisan Budget Act of 2015, including dealing with errors or omissions discovered by the IRS or taxpayers more than three years after a partnership return has been filed, and how those items may affect future, open tax years. | Tax Notes Federal
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Mexico’s Reference Effective Tax Rates Aid Voluntary Compliance
October 17, 2023 | The Mexican Tax Authority has published reference effective tax rates for large taxpayers as a tool to support tax collection, reach administrative efficiency, and improve transfer pricing compliance. This article discusses why large taxpayers should use the reference effective tax rates. | Bloomberg Tax Insight
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New IRS Large Partnership Audits Coming, This Time With AI Help
October 16, 2023 | This article highlights the continued compliance issues involving large partnerships and that the IRS has announced an audit initiative, this time assisted with artificial intelligence. | Tax Management Memo
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Code Sec. 367(d) and “Commensurate with Income”: Old Rules in a New Era
October 12, 2023 | In this article, the authors consider the scope and continued viability of commensurate with income (CWI) in the context of a transfer of intangible property subject to Code Sec. 367(d). | International Tax Journal
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Implications of New Mexican-Sourced Technical Assistance Ruling
October 5, 2023 | The authors of this article analyze the Mexican Federal Tax Court’s ruling that technical assistance payments do not qualify as business profits under the Convention for the Avoidance of Double Taxation between Mexico and the Netherlands | Tax Management International Journal
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Reflections on the 10th Anniversary of Rev. Proc. 2013-30
October 2, 2023 | In this article, the authors explain the evolution and relief provisions of Rev. Proc. 2013-30, the uniform late S corporation election relief revenue procedure, and they examine situations in which it could and could not be used over the past decade, highlighting some unintended consequences. | Tax Notes Federal
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To Disclose or Not to Disclose (and How and When)
October 2, 2023 | In this article, the authors explain how recently updated rules and forms affect various mandatory and voluntary disclosures on tax returns. | Tax Notes Federal
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Resolving disputes in IRS Appeals
October 1, 2023 | In this article, the authors discuss the IRS Appeals process, including recent developments that affect how Appeals functions. | International Tax Review
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Recent Issues and Practical Solutions for Estimating an Arm’s-Length Range for North American Retailers
In this article, the authors explain the challenges transfer pricing practitioners are currently facing with developing an arm’s length transfer pricing range for North American retail distribution companies and offer some practical solutions.
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Legislative Update: Select Financial Product Provisions in the Biden Administration’s 2024 Revenue Proposals
The authors of this article provide an overview of select proposals included in Treasury’s General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (the "Green Book”) that would affect the taxation of financial products.
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Amount B and the Quest for Tax Certainty
In this article, the authors discuss the latest consultation document on Amount B, which aims to simplify transfer pricing for baseline distribution activities and reduce disputes.
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The Accelerated Competent Authority Procedure: Rolling Forward MAP Resolutions
In this initial installment of Practically Speaking: Tax Controversy, the authors explain how the accelerated competent authority procedure and its analogues allow for case resolutions to be rolled forward to subsequent years.
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CAMTyland Adventures, Part II: ‘Right-Sizing’ in the Licorice Lagoon
This article is the second of two parts that uses the classic game Candy Land to assist taxpayers in understanding the corporate alternative minimum tax. This installment is focused on right-sizing for differences between a taxpayer’s book consolidated group, tax consolidated group, and single-employer group.
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Life Insurance Industry Needs CPA-Quality Advice More Than Ever
The authors of this article addresses how certain best practices and ethical standards from the certified public accountant profession could greatly benefit life insurance policy issuers and policy holders alike.
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OECD’s Effort to Simplify Transfer Pricing Is an Important Step
July 25, 2023 | In this article, the authors discuss whether the latest OECD guidance on Amount B, which covers baseline marketing and distribution activities, is successful in its intention of making transfer pricing rules simpler. | Bloomberg Tax
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CAMTyland Adventures, Part I: How to Play the Game – Corporate Alternative Minimum Tax Basics
In first part of a series of articles using the Candy Land game as a guide to help taxpayers navigate the corporate alternative minimum tax system, this article focuses on the basics and initial steps.
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Despite Relief, Pillar Two Problem Remains for US Multinationals
July 19, 2023 | The authors of this article explain that the temporary relief offered by the latest OECD guidance delays—not resolves—the concerns of many U.S. businesses. | Bloomberg Tax
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Increasing IRS enforcement of TP penalties
July 1, 2023 | In this article, the authors discuss the TP penalty regime and a recent shift towards more aggressive penalty enforcement by the IRS. | International Tax Review
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Underutilisation of ADR Programmes Harms Tax Administration in the U.S.
July 2023 | In this article, the authors discuss IRS alternative dispute resolution (ADR) and prevention programmes and how their underutilisation impedes effective tax administration. | International Tax Review
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Why REITs Should Be Paying Attention to the Corporate AMT
June 26, 2023 | This article examines real estate investment trusts (REITs) and the Inflation Reduction Act’s corporate alternative minimum tax, pointing out that while the tax does not apply directly to REITs, their subsidiaries may be within its scope. | Tax Notes Federal
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Transfer Pricing of Asset Management Sub-Advisers
June 12, 2023 | In this article, the authors explain asset management companies’ options for remunerating sub-advisers and the preferred structure’s effect on transfer pricing method selection. | Tax Notes International
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Transfer Pricing Considerations for ESG-Related Intangible Assets
June 5, 2023 | In this article, the authors examine the transfer pricing issues that companies should take into account in their environmental, social, and governance-related tax planning. | Tax Notes International
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A Global Survey on the Application of the Control of Risk and DEMPE Frameworks: France, Italy, and Spain
June 5, 2023 | In this article, the second in a series, the authors focus on how tax authorities in France, Italy, and Spain are applying the OECD control of risk framework and the transfer pricing guidelines on development, enhancement, maintenance, protection, and exploitation of intangibles. | Tax Notes International
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IRS Introduces New Review Procedures for APAs
June 2023 | In this article, the authors discuss the recently announced IRS procedures for reviewing advance pricing agreement (APA) requests and what these procedures mean for taxpayers. | International Tax Review
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Brazil’s Proposed Transfer Pricing Rules: A New Era for Financial Transactions
May 29, 2023 | In this article, the authors explain how Brazil’s proposed changes to its transfer pricing regime will affect intercompany financial transactions. | Tax Notes International
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The Future of Automotive Innovation: A Transfer Pricing Perspective
May 22, 2023 | In this article, the authors examine how transfer pricing considerations may be triggered by the increased focus on the development of electric vehicles, which has led to collaboration between traditional automotive manufacturers and the technology industry. | Tax Notes International
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Practical Transfer Pricing Compliance in a Complex World
May 15, 2023 | In this article, the authors explore the complexity of today’s transfer pricing environment andprovide suggestions for multinational corporations to take a practical, commonsense approach inanalyzing, benchmarking, and defending their related-party transactions. | Tax Notes International
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2022 Colombian Tax Reform – Some Preliminary Remarks on U.S. FTC Issues Arising from the SEP Rule and the Corporate Residency Test
July 2, 2023 | The authors of this article outline two new tax reforms in Colombia that may challenge inbound investors: (i) the Significant Economic Presence (SEP) rule and (ii) a modified corporate tax residency test. | Tax Management International Journal
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A Global Survey on the Application of the Control of Risk and DEMPE Frameworks: The U.S. and U.K.
May 8, 2023 | In this article, the authors summarize their findings from a KPMG member firm survey of how tax authorities around the world are applying the OECD control of risk framework and the transfer pricing guidelines on DEMPE. This installment is focused on the United States and the United Kingdom. | Tax Notes International
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Could the OECD’s Amount B Approach Be Useful for SALT?
May 8, 2023 | In this article, the authors explore how U.S. states might benefit from the work the OECD has done regarding base erosion and profit shifting and uniformity. | Tax Notes State
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The Stock Buyback Excise Tax: Practical Considerations for Retirement Plans and Equity-Based Compensation Arrangements
May 5, 2023 │In this article, the authors address planning considerations for employers and issues raised by the new stock buyback excise tax. │Bloomberg Tax Management Compensation Planning Journal
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Where, Oh Where, Did My Tax Home Go?
May 1, 2023 | In this edition of Tax Notes Federal, the authors examine the definition of tax home for federal income tax purposes and explores the tax consequences that may arise from employees being “away from home” for business travel. | Tax Notes Federal
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Defining Insurance for Federal Income Tax Purposes: Facts and Circumstances Are the Key
May 2023 | For the past several years, the IRS has focused its challenges captive insurance arrangements on so-called “micro captives” that have elected special tax treatment under Code Sec. 831(b). This article discusses the importance of considering all facts and circumstances for each individual captive arrangement to determine if that captive should be taxed as an insurance company. | Journal of Taxation of Financial Institutions and Products
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2022 U.S. APA Statistics Show After-Effects of the COVID Pandemic
May 2023 | The authors of this article discuss the IRS's APA statistics for 2022, and the state of the IRA APA program. | International Tax Review
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U.S. Treasury’s 2024 Proposals Reveal IRS Enforcement Focus
April 2023 | In this article, the authors discuss enforcement-related proposals in U.S. Treasury’s latest Green Book, and how they would change the tax compliance and enforcement landscape for large businesses. | International Tax Review
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Mutual Agreement Procedure: Progress Without Perfection
April 24, 2023 | In this article, the authors review the OECD’s efforts to improve tax certainty, with a particular focus on the role of mutual agreement procedures. | Tax Notes International
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Transfer Pricing and ESG, Part 1: Public Tax Strategies and Tax Transparency
April 10, 2023 | In this article, the first installment in a three-part series on tax and environmental, social, and corporate governance, the authors focus on the role of transfer pricing in responsible tax practices and suggest what multinational corporations should be doing to improve transparency in transfer pricing. | Tax Notes International
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Evaluating the Equivalence of Cost-Sharing Arrangements and Cost Contribution Arrangements
March 13, 2023 | In this article, the authors compare the U.S. cost-sharing arrangement rules and OECD cost contribution arrangement guidance, and they discuss the circumstances under which those can be considered equivalent. | Tax Notes International
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The Impact of the New Foreign Tax Credit Regs on Individual Taxpayers
March 6, 2023 | The authors of this article examine the creditability criteria of the new U.S. foreign tax credit final regulations and the impact on tax return filings by individual taxpayers. |Tax Notes Federal
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The Evolving Semiconductor Industry: Transfer Pricing Implications
March 6, 2023 | In this article, the authors consider the transfer pricing implications of increased but changing demand and government assistance in the semiconductor industry. | Tax Notes International
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Current Events Roundup: Stock Buyback Excise Tax, Corporate AMT, and Digital Asset Guidance
March 2023 | This article provides a brief overview of recent events pertinent to the taxation of financial products. It covers recent guidance on the stock buyback excise tax and corporate alternative minimum tax, Chief Counsel Advice memos 202302011 and 202302012 on digital asset issues, the status of digital asset broker reporting regulations, and the recently released changes to the digital asset question on Form 1040. | Journal of Taxation of Financial Products
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What the EU’s ‘Unshell’ Directive Means for Private Equity Firms
March 9, 2023 | The authors of this article suggest that with the latest installment of the EU’s anti-tax avoidance directive likely to become its next tax focus area, private equity firms should prepare for more questions about whether their structures are genuine and whether decisions on where to locate holding companies reflect reality. | Bloomberg Tax
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Code Sec. 367(b): Where Do We Go from Here?
March 2023 | The article focuses on the core provisions in the section 367(b) regulations relating to inbound and foreign-to-foreign nonrecognition transactions. | Taxes - The Tax Magazine
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Intercompany Fees for Internal Carbon Pricing: The Next Frontier?
February 13, 2023 | In this article, the authors explain how companies are measuring internal carbon pricing (ICP) and suggest how transfer pricing practitioners can support ICP and the associated allocations of intercompany carbon fees. | Tax Notes International
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Effects of the Inflation Reduction Act on the Pharmaceutical Industry
February 20, 2023 | This article reviews the Inflation Reduction Act provisions that have significant accounting and tax implications for the pharmaceutical industry. | Tax Notes Federal
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TCJA Changes to R&E Related Costs: Section 174 Update
February 27, 2023 | Absent legislative relief from mandatory capitalization and amortization of research and experimentation expenditures, taxpayers must now consider the §174-related issues highlighted in this article for their tax return, financial statement provision, and quarterly estimated tax payments for tax years beginning after December 31, 2021. | Tax Management Memorandum
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Brazilian Transfer Pricing: Timing Is Everything
February 3, 2023 | In this article, the authors discuss the impact of the Brazilian tax authority's issuance of Provisional Measure 1152, bringing Brazil’s historical, formula-based transfer pricing rules ever closer to an arm’s length standard consistent with the OECD Guidelines. | Bloomberg Tax
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Top Three State Tax Questions About Crypto and NFTs for Business
February 3, 2023 | This article discusses the most common client questions from those who are struggling to understand the state tax implications of digital currency. | Bloomberg Tax
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Tax Notes State - Not Shocking: The Business of EV Charging Raises State Tax Issues
January 30, 2023 | In this article, the authors discuss the potential sales and excise tax implications of electric vehicle charging stations, including the two areas in which tax issues are likely to arise: the build-out or installation of those stations and electricity sales through them. | Tax Notes State
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Where is the TRA? Extracting Value in an UP-C Without a TRA
January 23, 2023 | This article provides a general overview of the UP-C structure as well as mechanics of a TRA and presents reasons why energy companies valued on yield using the UP-C structure in a public offering may be discouraged from entering into a TRA. | Tax Notes Federal
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Gold and Coal Found in Corporate Alternative Minimum Tax Guidance
January 23, 2023 | The authors of this article discuss new guidance addressing the corporate alternative minimum tax (CAMT) that suggests Treasury will build out an extensive and complicated CAMT regime. | Bloomberg Tax
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Carbon Trading and Transfer Pricing: The Next Frontier?
January 16, 2023 | In this article, the authors explain what carbon trading is, why it exists, why it is important, why some companies are doing it, and ways in which multinational corporations can think about the transfer pricing aspects of a carbon trading function. | Tax Notes State
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Four Takeaways from Treasury's Corporate Stock Buyback Guidance
January 10, 2023 | This article breaks down the highlights of the U.S. Treasury guidance in Notice 2023-2 on excise tax on buybacks of corporate tax and discusses next steps affected taxpayers should consider. | Bloomberg Tax
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2022
The Reinstated Superfund Excise Taxes
December 22, 2022 | This article provides an illustration of the challenges faced by the oil and gas industry in applying one of these special rules related to two products derived from natural gas: methane and butane. | ABA Tax Times
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Adventures in CAMTyland: The Partnership 'Distributive Share Only' Rule in the Corporate Alternative Minimum Tax
December 19, 2022 | This article addresses some of the issues raised by the new corporate alternative minimum tax in determining whether certain entities are subject to the CAMT regime, which requires partnerships to calculate extensive information for corporate partners. | Tax Management Memorandum
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Navigating the Turbulent Waters of Section 704(c): The Ceiling Rule
December 5, 2022 | This article examines the core principles of section 704(c) and how the ceiling rule may result in unanticipated consequences for taxpayers. It also provides a numerical illustration of the application of the traditional method and the effect of the ceiling rule. | Tax Notes Federal
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MAP and the Exhaustion of Remedies for FTC Purposes
December 2, 2022 | The authors of this article revisit the role of mutual agreement procedure (MAP) requests in compulsory payment determinations under the foreign tax credit rules. | Tax Management International Journal
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Year-End Tax Considerations for Cryptocurrency Investors
December 2022 | This article discusses IRS guidance on classifying cryptocurrencies for U.S. federal income tax purposes; describes lot relief methodologies available to cryptocurrency investors and best practices for tracking and documenting tax basis; provides an overview of the tax considerations related to cryptocurrency losses; considers the tax consequences of updates to the Ethereum blockchain; and provides an update on the information reporting provisions in the Infrastructure Act. | Journal of Taxation of Financial Products
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Current Events Roundup: The New Stock Buyback Excise Tax, ILM 202224010, and Deitch v. Commissioner
December 2022 | This article highlights recent events, including the new stock buyback transactions excise tax, an IRS memo on merger termination fees, and a Tax Court case considering the tax characterization of a loan with certain equity-like features, pertinent to the taxation of financial products. | Journal of Taxation of Financial Products
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Administrative Law Basics for Transfer Pricing Practitioners
November 28, 2022 | In this article, the author explores the aspects of administrative law that may be most useful to transfer pricing practitioners by examining the leading cases, relevant Treasury regulations, and avenues for regulatory challenges. | Tax Notes Federal
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Transfer Pricing in the Soccer Field Is Bigger Than You Think
November 23, 2022 | In this article, the author explains how soccer's global importance, plus recent moves by multinational enterprises into the industry, may bring closer attention from tax authorities. | Bloomberg Tax
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Expanding Access to Retroactive QEFs: A Biden Proposal That Deserves Swift Enactment
November 14, 2022 | This article examines the Biden administration’s proposal to expand access to retroactive qualified electing fund elections and explaining why that reform is needed. | Tax Notes Federal
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The Ceiling Rule and Sales of Oil or Gas Partnership Property
October 31, 2022 | This article addresses the partnership rules applicable to oil and gas property sales, and how the choice of section 704(c) method affects partnership sharing from sales of oil or gas property—particularly situations in which the partnership uses the traditional method for section 704(c). | State Tax Notes
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Expedition Section 965(k): A Journey Through the Extended Statute of Limitations
October 19, 2022 | The authors of this article takes practitioners through the background on the section 965 transition tax, which allows for an extended six-year statute of limitations on assessment under section 965(k), and delves into a recently issued interim guidance memo issued by the IRS Large Business & International division. The article addresses applying the section 965 extended assessment period to Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and Bipartisan Budget Act of 2015 (BBA) partnership examinations. | Tax Management Real Estate Journal
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Transfer Pricing Considerations in the Age of Precision Medicine
October 7, 2022 | In this article, the authors discuss the disruption caused by chimeric antigen receptor T-cell (CAR T) therapy, a type of cell and gene therapy, to standard business models in the life sciences industry and its implications for transfer pricing. | Tax Management International Journal
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Current State and Trends in Intercompany Financial Transactions
October 7, 2022 | In this article the authors review a recent KPMG survey that highlights commonalities in how 16 major jurisdictions address some common issues pertaining to transfer pricing analyses of intercompany loans and guarantees. | Tax Management International Journal
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Chile's 2022 Tax Reform Proposals: A New Normal for Investos?
October 7, 2022 | The authors of this article discuss the most significant pieces of Chile’s tax reform bill that affect U.S. cross-border investors. | Tax Management International Journal
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The Arm's-Length Standard After the Pillars
The authors of this article explores the potential impact of the OECD’s current work program on how to approach transfer pricing. First, they focus on the impact of BEPS 2.0, and then, they consider the threats and opportunities created by the OECD’s ongoing work on article 9 of the model tax convention and potential improvements to dispute resolution mechanisms.
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A Primer on Wash Sale Reporting in a Volatile Market
September 26, 2022 | Market volatility can create opportunities for traders but it can also be a source of angst. As the year winds toward its final quarter, investors that may be thinking about taking losses for tax purposes (or reading advice on ‘‘loss harvesting’’) should also consider some of the tax imponderables that come with loss sales — most particularly the possibility of triggering tax wash sale rules. What are the rules, and how can investors avoid inadvertently subjecting themselves to their impact? | Tax Management Memorandum
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In Defense of the Arm’s-Length Principle
September 22, 2022 | In a follow-up to their August 22 “Why It’s Still Not Time for Global Formulary Apportionment” article, the authors argue in this article that all the proposed alternatives to the arm’s-length principle lack its two key benefits of neutrality and flexibility and looks ahead to what the future may bring. | Tax Notes International
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The Inconsistent Tax Treatment of Cryptocurrency and the Challenges of Cross-Border Reporting
September 19, 2022 | In this article, the author examines how the OECD and tax authorities worldwide have addressed the taxation of cryptocurrency in unique and often conflicting ways and considers the challenges of establishing and coordinating an effective exchange of information and enforcement of international cryptocurrency taxation stemming from the technologies’ sui generis nature and its potential to disrupt international monetary and financial systems. | Tax Notes International
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Renewed IRS Focus on Foreign Corporations' U.S. Tax Return Obligations
September 2022 | The authors of this article review IRS enforcement efforts regarding foreign corporations’ U.S. income tax returns and discuss the process by which taxpayers with untimely returns can request waivers allowing them to claim the benefit of credits and deductions. I International Tax Review
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Why It's Still Not Time for Global Formulary Apportionment
August 22, 2022 | The international tax system is in a state of flux, with potentially significant changes being driven by the OECD’s BEPS 2.0 project. Academics and the European Commission are (again) asking whether it is time for global formulary apportionment. The authors of this article explain why this time hasn’t arrived and explore the problems countries that chose to adopt formulary apportionment would face. | Tax Notes International
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Related-Party Wash Sale Transactions: An Evaluation of the Current State of the Law and Recent Legislative Proposals
August 2022 | The authors of this article analyze the state of the law on related-party wash sale transactions and the Build Back Better Act wash sale proposals. They provides a brief background on the current wash sale rules; a discussion of the prior application (or non-application) of the wash sale rules to related-party transactions by the courts; an overview and analysis of IRS guidance on related-party wash sale transactions; and a review of the Build Back Better Act’s proposed amendments to the wash sale rules. | Journal of Taxation of Financial Products
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The Application of Payments on Distressed Debt, Considering Howland v. Commissioner
August 2022 | The U.S. Tax Court released on June 13, a memorandum opinion, Howland v. Commissioner, which considered whether a couple was entitled to a home mortgage interest deduction after the foreclosure of their home. In this article, the author explores discussion in the opinion that may indicate the Tax Court’s position on applying payments on distressed debt instruments to principal and interest. How the Tax Court decision raises the question of how a taxpayer can demonstrate how the lender applied payments between principal and interest in cases where the lender does not issue a Form 1098, Mortgage Interest Statement, is also discussed. | Journal of Taxation of Financial Products
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U.S. Foreign Tax Credit Regulations: The Last Straw for Brazil's Transfer Pricing Regime?
August 15, 2022| In this article, the authors examine potential double taxation of U.S. multinationals operating in Brazil resulting from the U.S. final foreign tax credit regulations and Brazil’s transfer pricing regime, which is not aligned with the arm’s-length standard. The article considers whether this outcome might accelerate Brazil’s accession to the OECD and adoption of the arm’s-length standard. | Tax Notes International
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FTC Regs: Constructing A Path Forward
August 8, 2022 | The authors of this article explore how the recent changes in the foreign tax credit regulations have introduced several possibly unintended consequences to the engineering and construction industry. | Tax Notes International
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What Changes Are On the Horizon for US MAP and APA Procedures?
August 2, 2022 | In this article, the authors discuss possible updates to the IRS’s mutual agreement procedure (MAP) and advance pricing agreement (APA) revenue procedures, and considers how successor guidance could further improve the MAP and APA programs. | International Tax Review
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Answers to Your Burning R&E Expenditure and R&D Tax Credit Questions
August 1, 2022 | Tax professionals from four firms provide answers to frequently asked questions on trending topics in the research and experimental (R&E) and research and development (R&D) tax credits space. The issues addressed include the effect of mandatory capitalization of R&E expenditures, potential for guidance and legislation, practice pointers for taxpayers implementing the changes, state-by-state conformity, the additional information requirement, refund claims filed before the effective date, potential procedural challenges for disallowed refund claims, and whether the change under section 174 makes it more advantageous to claim the R&D credit under section 41. | Tax Management Memorandum
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Amount B: The Forgotten Piece of the Pillar 1 Jigsaw
July 11, 2022 | This article examines a significant but frequently overlooked piece of the OECD’s Pillar 1 proposal, Amount B. The authors explain how Amount B could work, discuss implementation challenges, and consider how businesses can prepare. | Tax Notes International
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The Diverging Paths of Pillars 1 and 2
July 4, 2022 | In this article, the authors examine the status of the OECD’s two-pillar approach to modernizing the international tax system and consider the international implications of the different paths countries are taking to implement Pillars 1 and 2. | Tax Notes International
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Open Items in the OECD Tax Certainty Consultations
July 11, 2022 | In this article, the authors discuss the recent OECD public consultation documents on tax certainty for Amount A of pillar one and related issues, and review key areas that remain undecided. | International Tax Review
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Trade and Tax Considerations in a Transforming Supply Chain Environment
July 4, 2022 | In this article, the authors examine how the impacts of an unprecedented pandemic, widespread disruptions in supply chains, and related policy developments are affecting trade and tax considerations, with the goal of helping multinational corporations decide how to structure their supply chains. | Bloomberg Tax
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Lack of Critical Minerals Prompts Increased Interest in U.S. Mining
June 13, 2022 | In this article, the authors provide an overview of the growing demand for critical minerals needed to make the batteries in electric vehicles and examines tax issues involving common funding structures for mineral interests. | Tax Notes Federal
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Proposed Changes to the Qualified Intermediary (QI) Agreement
June 15, 2022 | In this article, the authors provide an overview of the IRS Notice 2022-23 proposing changes to the qualified intermediary agreement, as well as some observations. | Tax Management Real Estate Journal
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Brazilian Transfer Pricing: Here Today, Gone Tomorrow?
June 3, 2022 | In this article, the authors provide an overview of the new Brazilian transfer pricing system envisioned by the OECD and the Brazilian Federal Tax Authorities, which represents a complete departure from Brazil’s old system. The newly announced transfer pricing regulations would be an improvement for U.S.-based multinationals — particularly those seeking foreign tax credits under the new regulations — but there is still uncertainty whether holistic consistency between the Brazilian and U.S. income tax systems (and correlative creditability) can be achieved. | Tax Management International Journal
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Tax Clinic: Practical Advice on Current Issues
June 2022 | In this Tax Clinic, find nine short articles spanning a variety of practice areas, including digital asset cost basis reporting; transfer pricing—mutual agreement procedure, secondary adjustments, and DEMPE; influencers and noncash compensation; global mobility—Social Security, tax compliance, and foreign tax credits; and Tennessee taxation of passthrough entities. | The Tax Adviser
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The Post-TCJA Interplay Between NOLs and Charitable Dedecutions
May 30, 2022 | The authors of this article explore the complexities that corporations face (and the potential benefits they may enjoy) if they have charitable contributions and net operating loss carryovers available for deduction on their 2021 returns. | Tax Notes Federal
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Stock Repurchases Under the Build Back Better Act's Excise Tax
May 9, 2022 | The authors explain the provisions of the proposed excise tax on some stock repurchases by corporations and how the tax might apply to various transactions. | Tax Notes Federal
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No Notice: Why Unilateral IRS Rulemaking Is Obsolete
May 2, 2022 | The IRS and Treasury have long claimed that subregulatory published guidance is exempt from notice and comment requirements established by the Administrative Procedure Act. Two recent cases, Mann Construction and CIC Services, however, rejected this claim in the context of two IRS notices, paving the way for taxpayers to wage similar successful attacks. The authors of this article focus on IRS rules carrying the force of law that were issued without any notice and comment procedures. It also reviews court opinions addressing those rules and the Administrative Procedure Act and explains how taxpayers may use the opinions in future disputes. | Tax Notes Federal
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The Whirlpool Case and Subpart F
May 2022 | In this article, the authors describe the Whirlpool case and its implications for Subpart F planning and controversy. | International Tax Review
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U.S.: 2021 Statistics Show an Uptick in Demand for APAs
May 2022 | In this article, the authors discuss the Internal Revenue Service’s (IRS) advance pricing agreement (APA) statistics for 2021, and the state of the IRS APA programme. | International Tax Review
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Why Operationalizing Transfer Pricing Is More Important Than Ever
April 18, 2022 | In this article, KPMG authors provide perspective on how companies can better use transfer pricing processes and technology to address recent regulatory and reporting changes and prepare for additional changes to come. | Tax Notes International
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Proof of Stake – What's Really at Stake on the Tax Front?
April 2022 | Growing investment and recent tax developments have generated increased interest in cryptocurrency staking. In this article, the authors provide a general overview of staking and consider the different potential tax characterizations of staking and the general U.S. income characterizations. They then provide several considerations for special classes of investors, such as foreign and U.S. tax-exempt investors | Journal of Taxation of Financial Products
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Inversion 2.0: The Proposal to Expand the Scope of Section 7874
April 4, 2022 | In this article, the authors examine the changes to section 7874 proposed by the Senate Finance Committee in connection with the Build Back Better Act from an historical perspective, and they explain how the proposal could be fine-tuned to address the government’s underlying policy objectives without producing unintended, counterproductive results. | Tax Notes International
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States Will Soon Be Looking to Collect on NFT Sales
March 21, 2022 | The authors of this article examine the concept of nonfungible tokens (NFTs), analyze some of the key sales and use tax issues that have emerged regarding their sale, and provide first steps for NFT marketplaces and sellers to take to protect themselves in potential sales tax disputes. | Tax Notes State
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Controlled Technologies and Third Parties: Mitigating the Risk
March 2022 | In this article, the authors review common compliance activities that can help drive export compliance as it relates to high-risk third parties and handling controlled technology. | Export Compliance Manager
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Transfer Pricing and the New R&D Capitalization Rules
March 14, 2022 | In this article, the authors examine significant developments with the section 174 amendments and how they affect common transfer pricing arrangements. | Tax Notes Federal
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Section 409A Valuations Aren't An All-Purpose Insurance Policy
March 7, 2022 | In this article, the author examines various aspects of the section 409A private corporation stock valuation regulations, and explains why businesses may be tempted to adopt an overbroad reading of the rules. | Tax Notes Federal
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Recent Changes to Section 174 of the US Internal Revenue Code
March 2022 | The authors describe changes to section 174 and what this may mean for entities that provide contract research and development services to related parties. | International Tax Review
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Transfer pricing Considerations for Lease Structuring: COVID-19 Lessons
February 28, 2022 | In this article, the author examines how the pandemic affected the real estate investment trust industry and various lease restructuring options from a transfer pricing perspective, and recommends leading practices to minimize the effect of economic downturns on operations. | Tax Notes Federal
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Automatic Changes for Simplified Tax Accounting Methods Provide Relief for Small Business Taxpayers: Rev. Proc. 2022-9 Overview
February 28, 2022 | The authors provide an overview of recent revenue procedures modifying the small business taxpayer exemption method changes. | Tax Management Memorandum
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New Regulations Apply Nexus Rule Restricting Eligibility for U.S. Foreign Tax Credits
February 2022 | The United States column in the February issue of International Tax Review discusses certain aspects of recent U.S. Treasury final regulations regarding foreign tax creditability. | International Tax Review
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Navigating U.S. Russian Sanctions: What TO Consider
February 2022 | In this article, the authors evaluate the potential impact of emerging U.S. restrictions against Russia. | Export Compliance Manager
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The Enduring Mysteries of Compensatory Partnership Internships
Jan/Feb 2022 | This article highlights some of the issues arising from the limited IRS guidance that has been issued in the compensatory partnership interests area from the perspective of a compensation and benefits advisor. Given the exponential growth of partnership structures and resulting use of compensatory partnership interests, with limited definitive guidance from Treasury and the IRS, working with compensatory partnership interests has become equal parts technical expertise and risk management. | Corporate Taxation
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Beware of Extended Limitations Period for Subpart F Omissions
January 24, 2022 | The authors of this article consider the implications of a recent IRS legal memorandum concerning the statute of limitations on assessments involving subpart F and how that could affect a taxpayer’s overall return. | Tax Notes International
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The Use of Assignment Agreements for Hedging by Treasury Centers
Winter - January 2022 | This article looks at a centralized risk management model in which a single domestic treasury center enters into derivatives (ISDA transactions) under one or more ISDA Master Agreements with domestic banks in order to manage risks of affiliates (domestic and/or foreign). After setting assumptions, the article discusses the basic tax issues raised by assignment/delegation and concludes that authorities can provide support in favor of the position that an assignment agreement of the type discussed, under which the Treasury Center acts as a conduit or a “secret” agent for its affiliates under an undisclosed internal assignment agreement, can be respected for federal income tax purposes even if the tax position taken by the Treasury Center appears to violate representations made to its counterparty with respect to the trades. | Journal of Taxation of Financial Products
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Foreign Insurance Excise Tax
Winter - January 2022 | Congress imposes an excise tax on certain premiums paid to foreign insurers and reinsurers. The Internal Revenue Service has a long history of being assertive when applying this excise tax. The authors of this article provide the background and summarizes the IRS’s historical positions regarding the premium excise tax. Then, the article discusses the most recent IRS audit activity and proposes ways that taxpayers may address the IRS’s questions. | Journal of Taxation of Financial Products
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2021: U.S. Transfer Pricing Year in Review
January 26, 2022 | Authors of this article recap and reflect on US transfer pricing developments from 2021. | International Tax Review
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Tax Certainty: The March Goes On
January 25, 2022 | The authors of this article review recent developments in 'tax certainty'. | International Tax Review
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TCJA Changes to R&E Related Code Sections Kick In
January 24, 2022 | The authors of this article highlights issues taxpayers must consider now that the scheduled changes to the treatment of research and experimentation (R&E) expenditures—mandatory amortization—have taken effect beginning January 1, 2022. | Tax Management Memorandum
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Minimum Tax Credit Carryforwards After the Build Back Better Act
January 10, 2022 | In this article, the authors examine a potential and overlooked consequence of the Build Back Better Act for corporate taxpayers continuing to carry forward minimum tax credits under the old alternative minimum tax regime. | Tax Notes Federal
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A Decade of India's APA Program: Why It Still Makes Sense
January 10, 2022 | In this article, the authors provide an overview of India’s advance pricing agreement program, including key benefits to taxpayers and some of the difficulties being addressed by tax authorities. | Tax Notes International
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BEPS 2.0: Issues and Implications for Latin America
January 7, 2022 | The article provides an overview of the Organization for Economic Cooperation and Development’s (OECD) Pillars 1 and 2, and describes some of the most immediate issues implicated by BEPS 2.0 in Latin America as identified by authors from Argentina, Brazil, Chile, Colombia, Costa Rica, Dominican Republic, Mexico, Panama, Peru, and Uruguay. | Tax Management International Journal
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