Recent Articles
May 2023
May 25 - IRS announces tax relief for taxpayers affected by Typhoon Mawar (Guam and Northern Mariana Islands)
May 25 - Minnesota: Omnibus tax package with revenue raisers enacted
May 24 - IRS expanding determination letter program to include certain section 403(b) plans
May 22 - U.S. Tax Court: Gift tax assessment time-barred (updated with KPMG observations)
May 22 - KPMG report: Domestic content bonus credit guidance under Notice 2023-38
May 22 - KPMG report: Treatment of captive insurance arrangements as insurance companies for tax purposes
May 19 - U.S. Supreme Court: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers upheld
May 16 - Rev. Proc. 2023-23: HSA inflation-adjusted amounts for 2024
May 16 - IRS report on potential free e-filing system; pilot program for 2024 filing season
May 15 - Interim final rule pending OIRA review: State and local fiscal recovery funds (COVID-19)
May 15 - KPMG report: Taxation of paid or reimbursed travel expenses and determination of employee’s tax home
May 12 - Notice 2023-38: Domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E
May 10 - U.S. Tax Court: “Qualified research” test under section 41, summary judgment denied
May 10 - Maryland Supreme Court dismisses challenge to digital advertising tax
May 8 - Third quarter update to IRS 2022-2023 Priority Guidance Plan
May 8 - KPMG report: Progress on improving mutual agreement procedure
May 5 - IRS provides tax relief for taxpayers in California affected by February storms
May 4 - Notice 2023-36: Request for recommendations for IRS 2023-2024 Priority Guidance Plan
May 3 - U.S. Tax Court: Receipt of profits interest in partnership in exchange for services not taxable
May 3 - KPMG report: COVID-19 disaster relief payments under section 139
May 2 - Proposed regulations: Section 367(d) rules for certain repatriations of intangible property
May 2 - IRS provides tax relief for taxpayers in Florida affected by tornadoes, severe storms, and flooding
April 2023
Apr 28 - KPMG report: State and local tax, technology-related developments (table, first quarter 2023)
Apr 24 - KPMG report: Effect of IRS funding on information reporting
Apr 21 - Rev. Proc. 2023-22: Nationwide average purchase price, residences located in United States
Apr 20 - Rev. Proc. 2023-21: Foreign insurance companies; effectively connected net investment income (2022)
Apr 18 - IRS provides tax relief for taxpayers in Indiana affected by tornadoes and severe storms
Apr 14 - IRS releases tax collection data for fiscal year 2022
Apr 10 - Proposed regulations: Micro-captive listed transactions and micro-captive transactions of interest
Apr 10 - Proposed regulations: Rules for supervisory approval of penalties
Apr 10 - Notice 2023-30: Safe harbor deed language for charitable conservation easements under Secure Act 2.0
Apr 10 - IRS provides tax relief for taxpayers in Tennessee affected by tornadoes and severe storms
Apr 7 - Announcement 2023-12: Revised Form 3115 for applications for change in accounting method
Apr 7 - U.S. Treasury release: No change to list of countries cooperating with international boycott
Apr 6 - IRS releases strategic operating plan for use of IRA funds
Apr 3 - IRS provides tax relief for taxpayers in Arkansas affected by tornadoes and severe storms
March 2023
Mar 31 - Proposed regulations: Guidance on new clean vehicle credit
Mar 29 - Announcement 2023-10: APMA program, APA statistics for 2022
Mar 28 - IRS provides tax relief for taxpayers in Mississippi affected by tornadoes and severe storms
Mar 28 - KPMG report: State, local tax changes (first quarter 2023, table format)
Mar 27 - Proposed regulations: Reinstated Superfund chemical tax and Superfund imported substance tax
Mar 27 - Notice 2023-28: Superfund excise taxes, extension of relief regarding failure to deposit penalties
Mar 27 - Rev. Proc. 2023-20: Clarification of date on which substances added or removed from Superfund list
Mar 27 - IRS guidance on electronic filing of Form 8038-CP for bond issuers requesting tax credit payments
Mar 27 - KPMG report: Stock repurchase excise tax and funding rule considerations for inbound taxpayers
Mar 24 - Beneficial ownership information reporting guidance
Mar 24 - IRS provides tax relief for taxpayers in New York affected by winter storms, snowstorms
Mar 22 - IRS provides revised FAQs on Form 1099-K
Mar 21 - Proposed regulations: Investment tax credit for investments in semiconductor manufacturing
Mar 17 - IRS provides FAQs on whether nutrition, wellness, and general health costs are medical expenses
Mar 17 - KPMG report: Crypto crackdown—information reporting in a digital asset world
Mar 15 - California: Guidance concerning unclaimed property voluntary compliance program
Mar 14 - Notice 2023-26: Housing expense limit adjustments, foreign locations for 2023
Mar 13 - Werfel sworn in as new IRS Commissioner
Mar 13 - Rev. Proc. 2023-19: Waiver for individuals electing to exclude foreign earned income
Mar 9 - Senate confirms Werfel to be IRS Commissioner
Mar 7 - Notice 2023-23: Relief for reporting required minimum distributions for 2023
Mar 7 - Seventh Circuit: Research tax credit disallowed, Tax Court affirmed
Mar 2 - Finance Committee advances Werfel to be next IRS Commissioner
February 2023
Feb 28 - U.S. Supreme Court: Penalty for FBAR violation applies on per-report, not per-account basis
Feb 24 - Proposed regulations: Use of forfeitures in qualified retirement plans
Feb 24 - Proposed regulations concerning information returns of cryptocurrency brokers; OIRA review completed
Feb 24 - IRS provides tax relief for “disaster area taxpayers” in Alabama, California, Georgia
Feb 23 - Final versions of Form 5500 series, annual employee benefit plan reports
Feb 21 - Final regulations: Electronic-filing requirements for specific tax returns, other documents
Feb 13 - IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program
Feb 13 - IRS guidance on state tax refunds, general welfare and disaster relief payments
Feb 13 - Notice 2023-18: Guidance on qualifying advanced energy project credit under section 48C
Feb 10 - KPMG report: Accounting for income taxes handbook
Feb 6 - KPMG report: State and local tax changes affecting entities in asset management industry in 2022
Feb 3 - Notice 2023-13: Service industry tip compliance agreement program
Feb 3 - Notice 2023-16: Updated FAQs for clean vehicle credit under section 30D
Feb 2 - KPMG report: Accounting questions related to new GloBE rules
Feb 2 - KPMG report: Summary and observations of tax provisions under SECURE Act 2.0
January 2023
Jan 26 - IRS annual revenue procedures for 2023
Jan 25 - KPMG report: Third reinstated Superfund tax adds complexity
Jan 24 - IRS provides tax relief for taxpayers in California affected by December storms, flooding, mudslides
Jan 24 - KPMG report: Form 1099-K delayed reporting thresholds
Jan 24 - KPMG report: State and local tax, technology-related developments (table, fourth quarter 2022)
Jan 20 - Eleventh Circuit: Permanent injunction against “tax mandate” in American Rescue Plan Act upheld
Jan 20 - IRS extends due date for QI withholding agreement to May 1, 2023
Jan 19 - IRS provides tax relief for taxpayers in Georgia and Alabama affected by storms
Jan 18 - IRS practice units: Changes in accounting methods
Jan 18 - IRS reminder: Employers must file Forms W-2 and provide Forms 1099-NEC by January 31, 2023
Jan 18 - Rev. Proc. 2023-14: Automobile depreciation deduction limits for 2023
Jan 18 - KPMG report: SEC comments on accounting for income taxes
Jan 12 - Proposed regulations pending OIRA review: Information returns of cryptocurrency brokers
Jan 12 - U.S. tax season starts January 23, 2023; most individual returns due April 18, 2023
Jan 10 - IRS provides tax relief for taxpayers in California affected by storms, flooding, mudslides
Jan 5 - KPMG report: Initial observations on guidance relating to clean vehicle credit under section 30D
Jan 5 - KPMG report: Analysis of safe harbor for “incremental cost” under section 45W in Notice 2023-9
Jan 4 - KPMG report: Initial observations on round 1 of CAMT guidance in Notice 2023-7
2022 Articles
December 2022
Dec 30 - KPMG report: Analysis and observations on initial guidance on new 1% stock repurchase excise tax
Dec 30 - IRS provides tax relief for taxpayers in New York affected by winter storm
Dec 30 - Notice of filing of petition for addition of polyphenylene sulfide to Superfund list
Dec 30 - Notice 2023-11: Temporary relief for foreign financial institutions required to report U.S. TINs
Dec 30 - Deadline for renewal of QI agreements covering 2023 through 2028
Dec 30 - TTB guidance: Industry circular on calculating tax rates for distilled spirits
Dec 29 - Proposed regulations concerning electronically filed returns; OIRA review completed
Dec 29 - IRS provides FAQs on clean vehicle credits for new, previously owned and commercial vehicles
Dec 29 - Rev. Proc. 2023-11: Updated guidelines for accounting method changes for specified R&E expenditures
Dec 29 - Notice 2023-3: Standard mileage rates for 2023
Dec 28 - IRS provides updated FAQs on Form 1099-K
Dec 28 - Notice of filing of petition for addition of polyoxymethylene to Superfund list
Dec 27 - Notice 2023-7: Interim guidance on new corporate alternative minimum tax (CAMT)
Dec 27 - Notice 2023-2: Interim guidance on new 1% excise tax on repurchases of corporate stock
Dec 23 - Announcement 2023-2: Transitional guidance for broker reporting on digital assets
Dec 23 - Notice 2023-10: Delay of implementation of $600 reporting threshold for Forms 1099-K
Dec 23 - Rev. Proc. 2023-10: Insurance companies, unpaid loss discount factors for 2022 accident year
Dec 22 - U.S. Treasury release: No change to list of countries cooperating with international boycott
Dec 21 - Notice 2023-8: Guidance regarding withholding on transfers of publicly traded partnership interests
Dec 20 - Notice 2023-4: Indexing factor for use by group health plans and health insurance issuers in 2023
Dec 19 - Notice 2023-6: Guidance on new sustainable aviation fuel credits
Dec 19 - Treasury timeline for providing guidance on “Inflation Reduction Act” tax provisions
Dec 19 - IRS provides tax relief for taxpayers in Florida affected by Hurricane Nicole
Dec 19 - KPMG report: Navigating the turbulent waters of the section 704(c) ceiling rule
Dec 19 - KPMG report: State, local tax changes (year-end checklist and fourth quarter 2022)
Dec 16 - KPMG report: Recent developments in taxation of financial products
Dec 13 - Rev. Proc. 2022-43: Final QI withholding agreement applicable beginning 2023
Dec 13 - KPMG report: Partnership “distributive share only” rule in corporate alternative minimum tax
Dec 13 - KPMG report: Periodic and nonperiodic withholding certificates
Dec 12 - Rev. Proc. 2023-8: Automatic changes to accounting methods to comply with section 174
Dec 9 - FBAR filings: Extended deadline is April 15, 2024, for individuals with signature authority
Dec 8 - Final regulations: Special enforcement matters, centralized partnership audit regime
Dec 8 - Rev. Rul. 2022-24: Covered compensation tables for 2023 plan year
Dec 7 - United States and Croatia sign income tax treaty
Dec 7 - KPMG report: MAP and the exhaustion of remedies for FTC purposes
Dec 6 - KPMG report: EITF consensus to expand use of proportional amortization method
Dec 2 - KPMG report: Analysis and observations about prevailing wage and apprenticeship requirements
Dec 2 - IRS provides tax relief for certain taxpayers affected by snowstorm in New York
November 2022
Nov 28 - Tier 2 tax rates for railroads, no changes for 2023
Nov 22 - Ninth Circuit: Rehearing en banc denied in section 965 case
Nov 21 - KPMG report: Proposed foreign tax credit regulations
Nov 21 - Notice 2022-62: Required amendments list (2022) for qualified retirement plans and 403(b) plans
Nov 21 - New York State: Guidance on New York City passthrough entity tax for 2022-2023
Nov 18 - Proposed regulations: Guidance relating to the foreign tax credit (text of regulations)
Nov 18 - Treasury to allocate $5 billion in New Markets Tax Credit (NMTC) authority for 2022
Nov 17 - IRS provides tax relief for certain taxpayers affected by storm and flooding in Illinois
Nov 16 - Rev. Proc. 2022-39: Procedures for eligible taxpayers to file qualified amended returns
Nov 16 - KPMG report: Year-end tax discussion ideas for international tax and transfer pricing
Nov 16 - KPMG report: Accounting for tax credits
Nov 14 - Notice 2022-59: Self-insured health insurance annual fee
Nov 10 - Announcement 2022-23: New renewable electricity production credit amounts for calendar year 2022
Nov 10 - President Biden to nominate Daniel Werfel as IRS Commissioner
Nov 10 - KPMG report: Corporate Alternative Minimum Tax considerations and FAQs
Nov 7 - Rev. Proc. 2022-40: Program for approving 403(b) retirement plans
Nov 4 - IRS Priority Guidance Plan for 2022-2023
Nov 3 - IRS notices: Additional requests for comments on upcoming clean energy tax guidance
Nov 2 - KPMG report: Year-end tax topics for cryptocurrency investors
October 2022
Oct 31 - KPMG report: Combined federal state filing program
Oct 28 - O’Donnell appointed IRS “Acting Commissioner”
Oct 28 - Treasury awards $5 billion in New Markets Tax Credit (NMTC) allocations
Oct 28 - IRS issues FAQ on WP / WT renewals
Oct 25 - TTB announcement: Foreign alcohol producers may now register with online TTB system for 2023
Oct 21 - Notice 2022-55: Pension plans, cost-of-living adjustments for 2023
Oct 21 - KPMG report: Examination of extended statute of limitations under section 965
Oct 20 - Proposed regulations withdrawn: Exclusion from gross income of PTEP and related basis adjustments
Oct 19 - KPMG report: State and local tax, technology-related developments (table, third quarter 2022)
Oct 19 - KPMG report: “Superfund” tax refunds for exported chemicals and listed substances
Oct 18 - Rev. Proc. 2022-38: Inflation adjustments for 2023, individual taxpayers
Oct 18 - IRS practice unit: “Report of Foreign Bank and Financial Accounts” (FBAR)
Oct 13 - U.S. Tax Court: Partnership distribution of “clients” was distribution of intangible assets
Oct 12 - IRS updates FAQs on QI / WP / WT website, certifications and periodic reviews
Oct 12 - Illinois: Calendar year corporate income tax return filing deadline extended to November 15, 2022
Oct 11 - Notice 2022-41: Additional permitted election changes for health coverage under “cafeteria plans”
Oct 11 - Rev. Proc. 2022-19: Taxpayer assistance procedures for S corporations under section 1362(f)
Oct 11 - IRS expands penalty relief for dyed diesel fuel in Florida; hurricane-related relief
Oct 10 - Washington State: Penalties on unified annual reconciliation of apportionable income
Oct 7 - Notice 2022-52: Extended temporary relief, low-income housing credit under section 42
Oct 7 - Notice 2022-53: Required minimum distributions
Oct 6 - FBAR filing deadline relief for persons affected by certain natural disasters
Oct 5 - IRS notices: Requests for comments on upcoming clean energy tax guidance
Oct 5 - IRS provides tax relief for taxpayers affected by Hurricane Ian (North Carolina and South Carolina)
Oct 3 - IRS announces new sign-in system for QI / WP / WT application and account management system (QAAMS)
Oct 3 - KPMG report: Tax treatment of cryptocurrency and challenges of cross-border reporting
September 2022
Sep 30 - IRS to waive dyed diesel fuel penalty in Florida; hurricane-related relief
Sep 30 - Final regulations concerning low-income housing credit average income test; OIRA review completed
Sep 30 - U.S. Treasury release: No change to list of countries cooperating with international boycott
Sep 29 - Final regulations: Beneficial ownership information reporting
Sep 29 - IRS provides tax relief for taxpayers in Florida affected by Hurricane Ian
Sep 29 - Puerto Rico: Tax-related hurricane relief
Sep 28 - Notice 2022-43: Farmers, ranchers affected by drought allowed more time to replace livestock
Sep 27 - IRS provides tax relief for certain taxpayers affected by storms in Alaska
Sep 26 - Notice 2022-44: Per diem rates, substantiation of employee lodging, meals, incidentals (2022-2023)
Sep 26 - U.S. Tax Court: Excess loss account included in income of consolidated group member
Sep 22 - Rev. Proc. 2022-35: Updated list of countries, deposit interest paid to nonresident aliens (Turkey)
Sep 22 - Final regulations concerning beneficial ownership information reporting; OIRA review completed
Sep 22 - KPMG report: State, local tax changes (third quarter 2022, table format)
Sep 21 - Puerto Rico: Extension of sales and use tax returns, payments as hurricane relief
Sep 21 - KPMG report: A primer on wash sale reporting in a volatile market (updated September 2022)
Sep 20 - U.S. SEC signals support for country-by-country reporting
Sep 19 - IRS provides tax relief for taxpayers in Puerto Rico affected by Hurricane Fiona
Sep 19 - Final regulations pending OIRA review: Guidance under section 36B regarding premium tax credit
Sep 16 - California: Unclaimed property voluntary compliance program legislation enacted
Sep 16 - PLR: REIT status regarding certain marina properties
Sep 16 - KPMG report: Student loan forgiveness and state reporting
Sep 15 - IRS opens application period for 2023 Compliance Assurance Process (CAP) program
Sep 14 - Rev. Proc. 2022-36: Foreign insurance companies; effectively connected net investment income (2021)
Sep 13 - Notice 2022-39: Guidance regarding one-time claim for alternative fuels excise tax credits
Sep 13 - Final regulations pending OIRA review: Low-income housing credit average income test
Sep 9 - Proposed regulations: Guidance relating to IRS Independent Office of Appeals (text of regulations)
Sep 8 - IRS provides tax relief for certain taxpayers affected by storms in Arizona
Sep 2 - New York State: Economic nexus for corporations in New York City, passthrough entity tax for 2022
Sep 2 - IRS provides tax relief for taxpayers affected by water crisis (Mississippi)
August 2022
Aug 30 - IRS practice unit: Rules for determining stock ownership under section 958
Aug 24 - Final regulations: Requirements related to “surprise” medical billing
Aug 24 - KPMG report: Foreign tax credit regulations; constructing a path forward
Aug 23 - Notice 2022-37: Further extended phase-in provisions under section 871(m) regulations
Aug 23 - KPMG report: Form 1099-K and state reporting issues
Aug 18 - U.S. Tax Court: Determination of transfer pricing method, on remand from Eighth Circuit
Aug 18 - IRS Appeals invites input on enhancing video conferences
Aug 17 - Guidance on changes to electric vehicles tax credit under "Inflation Reduction Act"
Aug 17 - Proposed regulations pending OIRA review: Electronically filed returns
Aug 16 - President signs budget reconciliation legislation; KPMG’s report on tax law changes
Aug 15 - Notice 2022-34: Deferred applicability dates for foreign currency guidance under section 987
Aug 10 - IRS provides tax relief for taxpayers affected by storms in Missouri
Aug 9 - KPMG report: Overview of investment tax credit for investments in semiconductor manufacturing
Aug 5 - Eighth Circuit: Deductions denied for deferred cash payments of $51 million made to former spouse
Aug 4 - Final regulations: Removal of signature requirement for section 754 elections
Aug 3 - Notice 2022-33: Extended deadline of December 31, 2025, for amending retirement plans or IRAs
Aug 3 - Deadline for QI / WP / WT applications for 2022 is September 30, 2022
Aug 3 - IRS extends tax relief for taxpayers affected by wildfires in New Mexico
Aug 3 - IRS provides tax relief for taxpayers affected by water issues in U.S. Virgin Islands (St. Croix)
Aug 2 - IRS provides tax relief for taxpayers affected by storms in Kentucky
July 2022
Jul 28 - KPMG report: A primer on wash sale reporting in a volatile market
Jul 27 - KPMG report: Correcting amendments to final foreign tax credit regulations
Jul 26 - IRS practice unit: Allowance of deductions and credits on Form 1120-F delinquent returns
Jul 22 - KPMG report: Tax home and the rise of telecommuters
Jul 20 - KPMG report: State and local tax, technology-related developments (table, second quarter 2022)
Jul 16 - Tax treaty update: United States terminates treaty with Hungary
Jul 11 - Tax treaty update: U.S. income tax treaty with Hungary reportedly being terminated
Jul 11 - Pennsylvania: Changes to corporate net income tax laws, other tax changes
Jul 8 - Fourth Circuit: IRS summons to taxpayer not quashed despite criminal referral of taxpayer’s agent
Jul 6 - IRS provides tax relief for taxpayers affected by storms in Montana and Oklahoma
Jul 1 - New York State: Appeals court holds vacation home is not permanent place of abode
June 2022
Jun 27 - KPMG report: State, local tax changes (second quarter 2022, table format)
Jun 24 - IRS announces Superfund chemical excise tax rates
Jun 24 - IRS provides FAQs on the reinstated Superfund chemical excise tax
Jun 24 - IRS practice unit: Energy efficient commercial buildings deduction
Jun 22 - KPMG report: Tax information reporting on crypto-assets
Jun 16 - New Jersey: Transfer pricing settlement initiative program for corporate taxpayers
Jun 15 - Texas: Proposed changes to R&D regulations address federal conformity; combined group changes
Jun 14 - KPMG report: Post-TCJA interplay between NOLs and charitable deductions
Jun 13 - California: Reminder that PTET elections and payment due June 15
Jun 9 - Announcement 2022-13: Increased mileage rates for remainder of 2022
Jun 7 - Ninth Circuit: Mandatory repatriation tax under section 965 is constitutional
Jun 7 - KPMG report: Future of consumer and retail—tax perspective
Jun 1 - KPMG report: Comments submitted to IRS regarding plans to update MAP and APA guidelines
May 2022
May 26 - IRS releases tax collection data for fiscal year 2021
May 23 - KPMG report: Backup withholding; IRS notices and payor responsibilities
May 20 - Final versions of Form 5500 series, annual employee benefit plan reports
May 20 - PLR: Tax treatment of REIT’s section 481(a) adjustment
May 18 - KPMG report: Potential tax benefits under section 1341
May 18 - KPMG report: Proposed changes to qualified intermediary (QI) agreement (Notice 2022-23)
May 17 - Tenth Circuit: Taxpayer did not qualify as small insurance company; Tax Court decision affirmed
May 12 - IRS provides tax relief for taxpayers affected by wildfires in New Mexico
May 11 - Ninth Circuit: Tax return considered filed when sent in response to IRS inquiry; Tax Court reversed
May 5 - IRS corrects renewable electricity production inflation factors, reference prices for 2022
April 2022
Apr 29 - Rev. Proc. 2022-24: HSA inflation-adjusted amounts for 2023
Apr 27 - Notice 2022-22: Mortality rates, tables for defined benefit pension plans (2023)
Apr 26 - Proposed regulations: Basic exclusion amount, estate and gift taxes
Apr 26 - Notice 2022-21: Request for recommendations for IRS 2022-2023 Priority Guidance Plan
Apr 26 - IRS practice unit: Country-by-country (CbC) report in the transfer pricing risk analysis process
Apr 22 - Sixth Circuit: Tax credit applied against fuel excise tax reduces excise tax liability
Apr 18 - IRS reminds employers of penalty relief related to claims for employee retention credit (COVID-19)
Apr 18 - U.S. Supreme Court: Certiorari denied in states’ challenge to 2017 tax law limiting SALT deduction
Apr 18 - KPMG report: State and local tax, technology-related developments (table, first quarter 2022)
Apr 15 - Notice 2022-15: Superfund excise taxes, relief regarding failure to deposit penalties
Apr 15 - Kentucky: Comprehensive tax bill enacted over governor’s veto
Apr 13 - Brazil takes steps toward OECD transfer pricing guidelines
Apr 13 - New York City: SALT cap “workaround” enacted for 2023
Apr 13 - Puerto Rico: Postponed due date for income tax returns, corporate annual reports, LLC annual fees
Apr 13 - Renewable electricity production inflation factors, reference prices for 2022
Apr 12 - U.S. Tax Court: At-home private nurses were employees for federal employment tax purposes
Apr 12 - IRS announces taxpayers may soon receive letters relating to qualified opportunity funds
Apr 8 - Maryland: Digital advertising services tax, estimated tax payment form is released
Apr 6 - Fourth Circuit: Payments to Russian scientist—taxable compensation or exempt from tax as a grant?
Apr 6 - U.S. Tax Court: Accounting for deferred fees using GAAP by retirement community upheld
Apr 5 - Temporary regulations under section 245A held invalid (federal district court)
Apr 4 - U.S. Treasury release: No change to list of countries cooperating with international boycott
March 2022
Mar 31 - IRS practice unit: Deferred compensation received by nonresident alien individuals
Mar 31 - IRS provides tax relief for taxpayers affected by storms in Puerto Rico
Mar 31 - U.S. Tax Court: Fees for use of securities exchanges not deductible under section 199
Mar 30 - Announcement 2022-7: APMA program, APA statistics for 2021
Mar 30 - Rev. Proc. 2022-21: Nationwide average purchase price, residences located in United States
Mar 29 - Tax treaty update: Senate Foreign Relations Committee approves income tax treaty with Chile
Mar 29 - KPMG report: State, local tax changes (first quarter 2022, table format)
Mar 25 - Proposed regulations: Multiple employer plans (text of regulations)
Mar 25 - KPMG report: Evolving Form 1099-K thresholds
Mar 25 - Texas: Comptroller’s sourcing position in satellite radio case rejected by state’s high court
Mar 23 - KPMG report: Federal district court vacates Notice 2016-66 (microcaptive insurance transactions)
Mar 22 - IRS practice unit: Penalties for erroneous claims for refund or credit
Mar 21 - U.S. Tax Court: Initial determination of penalties, after IRS supervisory approval was obtained
Mar 18 - Notice 2022-11: Indexing factor for provisions aimed at preventing surprise medical bills
Mar 17 - KPMG report: Updated list of automatic changes (Rev. Proc. 2022-14)
Mar 16 - Rev. Proc. 2022-17: Automobile depreciation deduction limits for 2022
Mar 16 - KPMG report: Understanding the excess business loss limitation
Mar 15 - Notice 2022-13: Waiver of addition to tax under section 6654 for certain farmers, fishermen
Mar 14 - Announcement 2022-6: Temporary suspension of prototype IRA opinion letter program
Mar 14 - Proposed regulations pending OIRA review: Guidance under section 36B regarding premium tax credit
Mar 9 - KPMG report: Reminder about partnership reporting for tax year 2021
Mar 4 - Notice 2022-10: Housing expense limit adjustments, foreign locations for 2022
Mar 3 - Sixth Circuit: Rehearing en banc denied in subpart F income case
Mar 3 - IRS updates FAQs on paid sick and family leave credits (COVID-19)
Mar 1 - KPMG report: Avoid common errors when filing Forms series 1099
Mar 1 - KPMG report: Form 1099-K and section 6050W reporting updates
February 2022
Feb 28 - U.S. Tax Court: Cash-surrender value of life insurance policies not includible in estate
Feb 24 - Federal Circuit: Request for Section 1603 grants denied; facilities not placed in service in 2009
Feb 23 - Proposed regulations: Required minimum distributions (text of regulations)
Feb 22 - U.S. government’s comments opposing Canada’s digital services tax proposal
Feb 21 - KPMG report: State-level passthrough entity tax; election considerations and upcoming deadlines
Feb 18 - KPMG report: Initial impressions of draft rules for tax base determinations under Pillar One
Amount A
Feb 14 - KPMG report: Treasury examines QOZ investments for reporting deficiencies
Feb 9 - IRS adds a new compliance campaign (LB&I division)
Feb 7 - Delaware: Unclaimed property, voluntary disclosure agreement invitations to be mailed for 2022
January 2022
Jan 31 - Rev. Proc. 2022-14: List of automatic changes, accounting methods
Jan 31 - U.S. Tax Court: Constructive transfer of intangible property in reorganization
Jan 28 - Notice 2022-8: Defined benefit plans, 2022 cumulative list for plan qualification requirements
Jan 26 - Final regulations implementing funding to support state and local governments (COVID-19)
Jan 24 - KPMG report: Certain states currently accepting Form 1099-NEC under CF/SF program
Jan 20 - IRS provides tax relief for taxpayers affected by Tennessee storms, tornadoes
Jan 19 - Rev. Proc. 2022-13: Tax Court review of employment tax determinations under section 7436
Jan 18 - Notice 2022-6: Determination of substantially equal periodic payments
Jan 12 - National Taxpayer Advocate report to Congress identifying taxpayer challenges
Jan 11 - IRS provides tax relief for taxpayers affected by Washington State flooding, mudslides
Jan 11 - Notice 2022-5: Extended temporary relief, low-income housing credit under section 42 (COVID-19)
Jan 10 - U.S. tax season starts January 24, 2022; most individual returns due April 18, 2022
Jan 10 - Puerto Rico: Program for taxpayers to resolve unpaid real property taxes offers relief, discounts
Jan 7 - Sixth Circuit: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers
Jan 6 - IRS provides FAQs regarding research credit claims
Jan 6 - KPMG report: Determining control in public M&A transactions
Jan 5 - Rev. Rul. 2022-2: Covered compensation tables for 2022 plan year
Jan 5 - KPMG report: Recent SEC and FASB comments on accounting for income taxes
Jan 5 - KPMG report: Initial analysis of final regulations concerning foreign tax credit
Jan 4 - IRS practice unit: Overview of section 245A dividends received deduction
Jan 4 - IRS modifies Hurricane Ida-related tax relief for taxpayers in six states
Jan 3 - IRS provides tax relief for taxpayers affected by Colorado wildfires
2021 Articles
December 2021
Dec 31 - KPMG report: Outline of measures in IBOR final regulations
Dec 31 - IRS releases annual revenue procedures for 2022
Dec 31 - KPMG report: State, local tax changes (fourth quarter 2021, table format)
Dec 30 - Final regulations: Tax consequences of transition from IBOR to other rates (text of regulations)
Dec 30 - U.S. Treasury release: Countries cooperating with international boycott; no changes
Dec 28 - Final regulations: Foreign tax credit and clarifying FDII (text of regulations)
Dec 28 - IRS provides tax relief for taxpayers affected by storms in Alabama
Dec 28 - IRS provides tax relief for taxpayers affected by tornadoes in Arkansas
Dec 22 - KPMG report: R&E changes from TCJA effective for tax years beginning after December 31, 2021
Dec 22 - IRS extends Hurricane Ida tax relief to taxpayers in six states to February 15, 2022
Dec 21 - Notice 2022-1: Guidance for lenders and loan servicers regarding student loan forgiveness
Dec 21 - Notice 2022-4: Self-insured health insurance annual fee
Dec 21 - U.S. competent authority arrangement concerning pension fund retirement schemes in Malta
Dec 20 - IRS provides tax relief for taxpayers affected by tornadoes in Illinois and Tennessee
Dec 20 - KPMG report: State identification numbers for Forms 1099-MISC and 1099-NEC
Dec 20 - KPMG report: Survey of 2021 insurance tax developments
Dec 20 - OECD: Pillar Two model rules for domestic implementation of 15% global minimum tax
Dec 17 - Notice 2022-3: Standard mileage rates for 2022
Dec 17 - PLR: Payments for use of storage terminal facilities and pipelines qualify under REIT income tests
Dec 16 - Rev. Proc. 2022-9: Automatic consent to change methods of accounting (text of guidance)
Dec 15 - TTB guidance: Updated FAQs regarding craft beverage modernization and tax reform
Dec 14 - Notice 2021-66: Excise taxes reimposed, list of “Superfund” taxable chemical substances
Dec 14 - D.C. Circuit: Airline’s claims for refunds of ticket-related security fees from TSA
Dec 14 - IRS provides tax relief for taxpayers affected by tornadoes in Kentucky
Dec 14 - IRS releases five practice units, covering topics including BEAT and foreign tax credit
Dec 13 - Final regulations on foreign tax credit, clarification of FDII; OIRA review completed
Dec 13 - Rev. Proc. 2021-54: Insurance companies, unpaid loss discount factors for 2021 accident year
Dec 10 - TTB reminder: Due date for tax returns, payments for alcohol industry annual filers
Dec 7 - Sixth Circuit: U.S. taxpayer realized subpart F income on sales of appliances manufactured in Mexico
Dec 1 - Delaware: NOL limitation policy not supported by statute (court decision)
Dec 1 - Fifth Circuit: Penalty for FBAR violation applies on per-account basis, not on per-form basis
Dec 1 - Rev. Rul. 2021-20, Rev. Proc. 2021-43: Guidance concerning low-income housing tax credit
November 2021
Nov 30 - Notice 2021-64: Required amendments list (2021) for qualified retirement plans and 403(b) plans
Nov 30 - North Carolina: Tax changes in budget legislation
Nov 29 - Final regulations pending OIRA review: Foreign tax credit, clarification of FDII
Nov 24 - United States and India reach agreement regarding “equalization levy” (digital services tax)
Nov 22 - United States and Turkey (Türkiye) announce digital services tax agreement
Nov 22 - Proposed regulations: “Minimum essential coverage” regarding health insurance (text of regulations)
Nov 18 - Tier 2 tax rates for railroads, no changes for 2022
Nov 17 - IRS expands tax relief to all taxpayers in Mississippi affected by Hurricane Ida
Nov 16 - KPMG report: Inflation adjustments for information return penalties (Rev. Proc. 2021-45)
Nov 15 - President signs bipartisan infrastructure bill, tax provisions are enacted
Nov 15 - IRS launches quality review tool for Form 1042-S data
Nov 15 - IRS extends tax relief for taxpayers affected by California wildfires
Nov 10 - Rev. Proc. 2021-45: Inflation adjustments for 2022, individual taxpayers
Nov 10 - Deadline for QI / WP / WT applications for 2021 is November 26, 2021
Nov 4 - Notice 2021-61: Pension plans, cost-of-living adjustments for 2022
Nov 4 - Treasury to allocate $5 billion in New Markets Tax Credit (NMTC) authority for 2021
Nov 3 - IRS releases FAQs as reporting guidance for “carried interests”
Nov 3 - IRS filing, payment relief for taxpayers affected by Hurricane Ida (Connecticut)
Nov 1 - Puerto Rico: New consolidated form for monthly reporting of sales and use tax and tax on imports
October 2021
Oct 27 - IRS expands tax relief, certain taxpayers in Mississippi affected by Hurricane Ida
Oct 25 - KPMG reports: Illinois (marketplace facilitators); Louisiana (pending tax-related referendum)
Oct 20 - KPMG report: State and local tax, technology-related developments (table, third quarter 2021)
Oct 20 - KPMG report: Year-end tax considerations for cryptocurrency investors
Oct 18 - LB&I video-conferencing for large business taxpayers
Oct 15 - IRS clarifies FAQs may offer reasonable cause for penalty protection, but are not precedential
Oct 15 - Rev. Rul. 2021-19: Fringe benefit aircraft valuations, second half of 2021
Oct 12 - Notice 2021-59: Deferred applicability dates for foreign currency guidance under section 987
Oct 9 - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
Oct 8 - OECD: Agreement for global minimum tax, to resolve international taxation of digital economy
Oct 7 - KPMG report: Form 1099-NEC added to the combined federal-state filing program
Oct 7 - Texas: Revised R&D rules for state tax purposes
Oct 7 - U.S. Treasury release: No change to list of countries cooperating with international boycott
Oct 6 - FBAR filing deadline relief for persons affected by certain natural disasters
Oct 6 - Notice 2021-58: Application of certain extensions under COBRA (COVID-19)
Oct 4 - IRS practice unit: Examining a reseller’s section 263A computation
September 2021
Sep 30 - Regulations: Measures to address “surprise” medical billing
Sep 30 - Washington State: High court upholds B&O tax surcharge on banks
Sep 27 - Final regulations: Process, user fee for requesting estate tax closing letter
Sep 24 - KPMG report: State, local tax changes (third quarter 2021, table format)
Sep 24 - Notice 2021-55: Farmers, ranchers affected by drought allowed more time to replace livestock
Sep 22 - IRS webpage: Resource and information about refunds subject to review by Joint Committee on Taxation
Sep 22 - Senate approves Assistant Secretary for Tax Policy
Sep 21 - Final regulations: Distributions of property by corporations to shareholders
Sep 15 - IRS extends dyed diesel fuel penalty relief in Louisiana, response to hurricanes
Sep 14 - Proposed regulations: Changes to Form 5500 annual returns filed for employee pension plans
Sep 14 - Tax relief for taxpayers in Pennsylvania affected by Hurricane Ida
Sep 13 - Rev. Proc. 2021-41: Foreign insurance companies; effectively connected net investment income (2020)
Sep 13 - IRS provides tax relief for taxpayers in North Carolina affected by Tropical Storm Fred
Sep 13 - KPMG report: Marketplace facilitator updates (California, Illinois, Texas)
Sep 10 - IRS Priority Guidance Plan for 2021-2022
Sep 10 - Tax relief for taxpayers in Mississippi affected by Hurricane Ida
Sep 8 - IRS provides tax relief for taxpayers affected by Hurricane Ida (New York and New Jersey)
Sep 8 - KPMG report: Like-kind exchange relief for taxpayers affected by Hurricane Ida
Sep 7 - Notice 2021-53: Reporting qualified sick leave, qualified family leave wages (COVID-19)
Sep 7 - KPMG report: Draft forms and instructions in W-8 series
Sep 3 - Notice 2021-52: Per diem rates, substantiation of employee lodging, meals, incidentals (2021-2022)
Sep 3 - Penalty for failure to deposit taxes under CARES Act (Chief Counsel legal advice memo)
Sep 1 - Rev. Proc. 2021-37, Rev. Proc. 2021-38: Pre-approved retirement plans
Sep 1 - Treasury awards $5 billion in New Markets Tax Credit (NMTC) allocations
Sep 1 - IRS practice unit: Foreign tax credit (business) general principles
Sep 1 - IRS to waive dyed fuel penalty in Louisiana; hurricane-related relief
August 2021
Aug 31 - Rev. Proc. 2021-39: Further extension of relief regarding tax-exempt bonds (COVID-19)
Aug 31 - IRS provides tax relief for taxpayers in Louisiana affected by Hurricane Ida
Aug 27 - IRS provides tax relief for taxpayers affected by August 2021 storms in Tennessee
Aug 27 - Tax relief for taxpayers in California affected by wildfires
Aug 25 - Seventh Circuit: Safe harbor relief from federal excise tax, refurbished heavy truck tractors
Aug 24 - KPMG report: Employee retention credit—additional guidance ties up many loose ends
Aug 23 - IRS opens application period for 2022 Compliance Assurance Process (CAP) program
Aug 16 - KPMG report: Tax updates for facilitators of accommodations (New Hampshire, Virginia)
Aug 10 - Notice 2021-43: Relief for certain employers claiming the Work Opportunity Tax Credit
Aug 9 - KPMG report: Second set of corrective amendments to qualified opportunity fund regulations
Aug 6 - Notice 2021-47: Enhanced oil recovery credit for 2021
Aug 6 - Rev. Proc. 2021-31: Automobile depreciation deduction limits for 2021
Aug 4 - IRS practice unit: Penalty for failure to include reportable transaction information
Aug 3 - Updated FAQs concerning PPP loans, SBA discontinues “loan necessity questionnaire”
Aug 2 - Notice 2021-48: Guidance on single-employer defined benefit pension plan funding changes
Aug 2 - KPMG report: Expiring nexus and withholding relief in multiple states (COVID-19)
Aug 2 - KPMG report: Marketplace facilitator updates (Alabama, Missouri, New Mexico)
July 2021
Jul 28 - Interim final rule: PPP loan forgiveness process, appeals deferment (COVID-19)
Jul 28 - IRS practice unit: Overview of section 987 and branch operations in a foreign currency
Jul 28 - KPMG report: Employers helping employees—disaster relief
Jul 28 - KPMG report: Treaty claims and Form W-8BEN-E
Jul 26 - IRS revises system for filing information returns electronically
Jul 26 - Notice 2021-46: Additional IRS guidance on premium assistance for COBRA benefits
Jul 26 - KPMG reports: Indiana (franchise fee litigation); Michigan (advertising materials)
Jul 22 - U.S. list of countries cooperating with international boycott; no change
Jul 21 - Proposed regulations: Electronic-filing requirements for specific tax returns, other documents
Jul 21 - IRS provides tax relief for taxpayers affected by June 2021 storms in Michigan
Jul 19 - KPMG report: Treatment of PPP loans (California, Hawaii, Minnesota, Rhode Island)
Jul 16 - Rev. Proc. 2021-30: Employee plans correction methods, updated
Jul 16 - KPMG report: State and local tax, technology-related guidance (table, second quarter 2021)
Jul 10 - G20 Finance Ministers conclude meeting with agreement for global minimum tax, other measures
Jul 9 - IRS practice units: FDII and computing qualified research expenses
Jul 6 - Regulations: Implementing “no surprises” measures, medical and health-related bills
Jul 2 - Delaware: New unclaimed property enforcement provisions are enacted
Jul 2 - IRS practice unit: Foreign tax redeterminations
Jul 2 - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
Jul 1 - Rev. Rul. 2021-13: Credit for carbon oxide sequestration under section 45Q
June 2021
Jun 30 - Notice 2021-42: Employer leave-based donation programs, extended for 2021 (COVID-19)
Jun 30 - Rev. Proc. 2021-14: Guidance on NOL elections and revocations, farming losses
Jun 30 - IRS practice unit: Allocation methods of personal use of aircraft
Jun 29 - Notice 2021-41: Continuity safe harbor is extended, renewable energy projects
Jun 29 - KPMG report: State, local tax changes (second quarter 2021, table format)
Jun 24 - CDC extends temporary eviction moratorium through July 2021 (COVID-19)
Jun 24 - IRS releases tax collection data for fiscal year 2020
Jun 23 - TTB guidance: Extended tax-free withdrawal of distilled spirits for hand sanitizers (COVID-19)
Jun 18 - IRS practice unit: Concepts of GILTI
Jun 18 - Puerto Rico: “Back to school” sales and use tax exemption
Jun 17 - U.S. Supreme Court: Implications for protective refund claims for ACA-related taxes and fees
Jun 14 - KPMG report: Permanent establishment-related considerations, employees working remotely
Jun 14 - KPMG report: Planning in advance for Biden Administration’s proposed increased tax rates
Jun 14 - KPMG report: Treasury releases the American Families Plan tax compliance agenda
Jun 14 - Updated FAQs concerning PPP loans, nonprofits in Puerto Rico
Jun 11 - IRS practice unit: Partner’s outside basis
Jun 11 - IRS provides FAQs provide guidance for individuals, SMEs under “American Rescue Plan” (COVID-19)
Jun 11 - Rev. Rul. 2021-11: Fringe benefit aircraft valuations, first half of 2021
Jun 10 - Final regulations: Mandatory 60-day postponement of tax deadlines, federally declared disasters
Jun 10 - IRS provides tax relief for taxpayers affected by May 2021 storms in Louisiana
Jun 10 - IRS adds a new compliance campaign (LB&I division)
Jun 7 - Puerto Rico: Reduced sales and use tax for prepared foods involving marketplace facilitators
Jun 7 - KPMG report: Analysis and observations about tax measures in G7 communique
Jun 5 - Communique from meeting of G7 finance ministers and central bank governors
Jun 3 - Illinois: Budget agreement includes corporate tax revenue raisers
Jun 2 - Fifth Circuit: Taxpayer not a “bank” and thus not allowed to deduct certain losses
Jun 2 - Ninth Circuit: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed)
Jun 2 - United States suspends tariffs on goods from six countries, digital services tax investigations
Jun 1 - IRS provides tax relief for taxpayers affected by February 2021 storms in West Virginia
Jun 1 - KPMG report: Accounting considerations for the UK “super-deduction”
May 2021
Year in Review (2018-2022)
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