Recent Articles

May 2024

May 23 - KPMG report: Income tax disclosures—applying recent disaggregation enhancements

May 22 - Notice 2024-43: Further deferral of provisions under section 59A and 6038A regulations relating to reporting of qualified derivative payments

May 22 - Notice 2024-44: Further extended phase-in provisions under section 871(m) regulations

May 22 - U.S. Tax Court: Option granted to related entity with respect to real property not a sham

May 20 - U.S. Tax Court: No gift tax liability following termination of marital trusts

May 20 - U.S. Treasury release: No change to list of countries cooperating with international boycott

May 20 - IRS provides tax relief for taxpayers affected by storms and tornadoes in Iowa

May 20 - IRS provides tax relief for taxpayers affected by storms and tornadoes in Nebraska

May 20 - KPMG reports: Alabama (accommodations intermediaries legislation); California (budget revisions); Tennessee (local sales taxes on food)

May 17 - Announcement 2024-24: Updated applicable reference standard for energy efficient commercial building property deduction

May 17 - Announcement 2024-25: Capacity limitation carryover amounts for 2024 Low-Income Communities Bonus Credit program year

May 16 - Notice 2024-41: Modified domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E, including new elective safe harbor

May 16 - IRS announces tax relief for taxpayers affected by tornadoes in Ohio

May 15 - Notice 2024-42: Mortality tables for defined benefit pension plans (2025)

May 14 - Proposed regulations: Interest capitalization requirements for improvements to designated property

May 13 - Application period for second year of environmental justice solar and wind capacity limitation program opening May 28

May 13 - KPMG reports: Colorado (combined reporting changes); Nevada (proposed changes for marketplace facilitators); Tennessee (franchise tax refunds)

May 10 - KPMG report: Accelerating Form 1099 deadlines, prioritizing taxpayer efficiency

May 9 - Rev. Proc. 2024-25: HSA inflation-adjusted amounts for 2025

May 9 - Rev. Rul. 2024-11: Interest rates, tax underpayments and overpayments remain same for third quarter 2024

May 7 - Proposed regulations: Guidance on information reporting on transactions with foreign trusts and large foreign gifts and transactions with foreign trusts

May 6 - Eighth Circuit: Taxpayer’s research was “funded” and thus ineligible for research tax credits under section 41; Tax Court affirmed

May 6 - IRS announces tax relief for taxpayers in Oklahoma affected by severe weather

May 6 - KPMG report: Interplay of potential enactment of extenders with CAMT

May 6 - KPMG report: Phantom inversions under section 7874

May 6 - KPMG reports: Kansas (changes to sales and use tax laws); Nebraska (expensing of R&E expenditures); multistate (draft legislation amending P.L. 86-272)

May 3 - Final regulations: Guidance on clean vehicle credits

May 3 - Final regulations: Guidance on extensions to make certain exemption allocations and elections related to generation-skipping transfer tax

May 3 - D.C. Circuit: IRS has statutory authority to assess penalties under section 6038(b) for willful failure to file Form 5471; Tax Court reversed

May 3 - IRS issues FAQs regarding disaster relief related to retirement plans and IRAs

May 2 - KPMG report: Analysis and observations of final transferable credit regulations

May 2 - IRS releases annual update to strategic operating plan

May 2 - Rev. Proc. 2024-24 and Notice 2024-38: Updated procedures for section 355 private letter rulings

April 2024

Apr 30 - Notice 2024-37: Additional guidance and safe harbors for sustainable aviation fuel credit

Apr 30 - Rev. Proc. 2024-23: Updated annual list of automatic accounting method changes

Apr 29 - Notice 2024-36: Announcement of 2024 allocation round and updated guidance on qualifying advanced energy project credit under section 48C(e)

Apr 29 - Reference price for nonconventional source production credit for 2023

Apr 29 - KPMG reports: Alabama (additional sales tax on adult websites); Arkansas (sales tax on sightseeing flights); Colorado (no sales tax on streaming services); South Carolina (admissions tax on parasailing); Tennessee (franchise tax changes); Virginia (corporate income tax related-party expense disallowance rules)

Apr 26 - Tennessee: Franchise tax refund agreement reached

Apr 25 - Final regulations: Guidance on transfer of certain tax credits under IRA

Apr 24 - Final regulations: Definition of domestically controlled qualified investment entity under section 897

Apr 24 - IRS Independent Office of Appeals announces formation of alternative dispute resolution program management office

Apr 22 - KPMG reports: Georgia (income tax rate changes); Illinois (retailer’s occupation tax); New Jersey (sourcing for corporation business tax)

Apr 18 - Rev. Proc. 2024-20: Foreign insurance companies; effectively connected net investment income (2023)

Apr 17 - IRS updates FAQs for energy efficient home improvement and residential clean energy property credits

Apr 17 - KPMG report: Initial analysis of stock repurchase excise tax proposed regulations

Apr 16 - IRS issues FAQs related to tax treatment of work-life referral services provided to employees

Apr 16 - IRS updates FAQs on new, previously owned, and qualified commercial clean vehicle credits

Apr 16 - Notice 2024-35: Relief with respect to certain required minimum distributions

Apr 16 - Rev. Proc. 2024-21: Nationwide average purchase price, residences located in United States

Apr 15 - KPMG reports: Florida (sales tax rate on use of real property); Pennsylvania (sales tax on SaaS); New York (challenge to P.L. 86-272 regulations)

Apr 15 - Notice 2024-33: Limited relief from underpayment of estimated tax attributable to CAMT liability

Apr 15 - KPMG report: Partnership audit rules and specific IRS forms

Apr 12 - IRS corrects appendices to Notice 2024-20, census tracts for credit under section 30C

Apr 11 - KPMG report: CAMT recent developments—changes to instructions for Schedule K-1

Apr 10 - Supplemental proposed regulations: Clean hydrogen production credit under section 45V and related energy credit under section 48(a)(15)

Apr 10 - KPMG report: State, local tax changes (first quarter 2024, table format)

Apr 9 - Proposed regulations: Guidance on new 1% excise tax on repurchases of corporate stock

Apr 8 - KPMG reports: Arizona (sales tax nexus); Kentucky (unitary combined reporting); Minnesota (corporate NOL limit change)

Apr 5 - KPMG report: Comments on expanding tax certainty and issue resolution programs for business taxpayers

Apr 5 - Announcement 2024-19: Tax treatment of amounts paid as rebates for energy efficient property and improvements

Apr 4 - IRS provides tax relief for taxpayers in Maine and Rhode Island affected by severe storms, flooding

Apr 2 - KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations

Apr 2 - U.S. Tax Court: Taxpayers automatically entitled to extension to file petition by reason of COVID-19 disaster declaration

Apr 1 - KPMG reports: Arkansas (sales tax on temporarily used vehicles); Idaho (unclaimed property law changes); multistate (tax rate changes)

March 2024

Mar 29 - Announcement 2024-16: APMA program, APA statistics for 2023

Mar 29 - Rev. Proc. 2024-19: Guidance on environmental justice solar and wind capacity limitation program for 2024

Mar 28 - Final regulations: Definitions of short-term, limited-duration insurance and excepted benefits coverage

Mar 28 - Proposed regulations: Disclosure of specified return information to Bureau of the Census for statistical purposes

Mar 28 - U.S. Tax Court: Conservation easement contribution regulations held invalid under APA because of failure to respond to significant comment

Mar 27 - IRS extends tax relief for taxpayers affected by wildfires in Hawaii

Mar 26 - IRS announces tax relief for taxpayers in Alaska affected by severe storms

Mar 25 - Notice 2024-32: Guidance for qualified student loan and qualified mortgage bonds

Mar 25 - KPMG reports: Louisiana (exempt cable services); Wisconsin (property tax exemption)

Mar 22 - Proposed regulations: Certain charitable remainder annuity trust transactions identified as listed transactions

Mar 22 - IRS updates FAQ on QI/WP/WT website to provide guidance on WP/WT agreement renewals

Mar 22 - Notice 2024-30: Expanded rules for energy community production and investment tax credits under IRA

Mar 22 - Third Circuit: Taxpayer’s petition cannot be dismissed by Tax Court on grounds of mootness

Mar 21 - Proposed regulations: Taxpayer notification in advance of IRS contact with third parties

Mar 20 - Notice 2024-31: Housing expense limit adjustments, foreign locations for 2024

Mar 20 - Second quarter update to IRS 2023-2024 Priority Guidance Plan

Mar 19 - Rev. Proc. 2024-17: Waiver of time requirements for individuals electing to exclude foreign earned income because of adverse conditions

Mar 19 - KPMG report: CHIPS Act tax credit—direct pay final regulations

Mar 18 - KPMG report: Accounting for tax credits generated by pass-through entities

Mar 18 - KPMG report: Tax and trade considerations for U.S. inbound investment

Mar 18 - KPMG reports: Montana (water’s-edge election); Oregon (guidance for “foreign” corporations); Tennessee (franchise tax refunds); multistate (short-term rental obligations)

Mar 14 - KPMG report: Analysis and observations of tax proposals in Biden Administration’s FY 2025 budget

Mar 14 - Final rule: Responsibility for administering alcohol taxes moved from CBP to Treasury

Mar 14 - IRS adds FAQ to QI / WP / WT FAQs website

Mar 14 - KPMG report: New beneficial ownership information reporting requirements

Mar 13 - KPMG report: Final regulations on direct pay of certain tax credits under IRA, observations and analysis (updated March 15)

Mar 13 - KPMG report: New proposed regulations on bad debt deductions for certain qualifying entities

Mar 12 - United States and Turkey announce updated digital services tax agreement

Mar 11 - KPMG reports: Colorado (manufacturing exemption); New Mexico (individual and corporate income tax changes); New York (taxable information services)

Mar 8 - Arizona: Guidance on refund claims for invalidated Pinal County tax

Mar 7 - Notice 2024-28: Request for recommendations for IRS 2024-2025 Priority Guidance Plan

Mar 7 - IRS to waive dyed diesel fuel penalty in parts of Texas; wildfire-related relief

Mar 5 - Treasury and IRS issue final regulations, other guidance on direct pay of certain tax credits under IRA and CHIPS

Mar 4 - KPMG report: Taxpayer options for fixing federal tax return mistakes

Mar 4 - KPMG reports: California (dividends fully included in sales factor); Minnesota (retail delivery fee); Oklahoma (food sales tax); South Carolina (combined reporting)

February 2024

Feb 29 - Senate confirms Marjorie Rollinson to be IRS Chief Counsel

Feb 29 - Rev. Proc. 2024-15: Guidance on qualifying securitizations by public utilities

Feb 29 - IRS announces new effort focused on high-income non-filers

Feb 29 - IRS LB&I division adds new compliance campaign (business aircraft)

Feb 28 - IRS provides tax relief for taxpayers in Washington State affected by wildfires

Feb 27 - Notice 2024-26: Administrative exemption from requirement to electronically file Form 1042

Feb 27 - IRS provides tax relief for taxpayers in California affected by severe storms, flooding

Feb 27 - KPMG report: Post-pandemic state tax policies

Feb 26 - Notice of filing of petition for addition of iso-butanol to Superfund list

Feb 26 - KPMG report: Challenges and opportunities faced by CAMT “scope bubble corporations”

Feb 26 - KPMG reports: Alaska (marketplace facilitators sales tax); Louisiana (industrial tax exemption program); New York (wine producer as qualified manufacturer); Wisconsin (withholding on software licensing income)

Feb 22 - IRS announces plans to begin audits on personal use of business aircraft

Feb 21 - Filing of petitions for additions of caprolactam and nylon 6 to Superfund list

Feb 21 - IRS practice unit: Allocation and apportionment of R&E expenses for tax years beginning before January 1, 2020

Feb 21 - Rev. Rul. 2024-6: Interest rates, tax underpayments and overpayments remain same for second quarter 2024

Feb 21 - U.S. Tax Court: Decision in favor of IRS in case regarding limited partner exception to self-employment income

Feb 21 - U.S. Tax Court: Financing costs, including bond fees, properly included in eligible basis for purposes of low-income housing tax credit

Feb 20 - U.S. Treasury launches website tracking tax guidance under “Inflation Reduction Act”

Feb 20 - KPMG reports: New Jersey (substantiation of sales tax refund claims); Washington State (B&O tax on reimbursements); Wisconsin (pre-combined reporting NOLs)

Feb 16 - Correction to proposed regulations on energy credit under section 48, relating to certain gas upgrading equipment

Feb 16 - Final Form 4626 and instructions for corporate alternative minimum tax (CAMT)

Feb 16 - GLAM: Liability of third-party payers for improperly claimed employee retention credits

Feb 15 - U.S. Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

Feb 15 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Feb 15 - IRS provides tax relief for taxpayers in Michigan affected by severe storms, tornadoes and flooding

Feb 15 - KPMG report: California court decision on interstate tax law

Feb 13 - Application period for environmental justice solar and wind capacity limitation program closing February 29

Feb 12 - Rev. Proc. 2024-14: Indexing adjustments for amounts used to calculate employer shared responsibility payments

Feb 12 - KPMG reports: Delaware (unclaimed property voluntary disclosure agreement program); Illinois (tax treatment when mobile app used to purchase fuel); South Dakota (use tax on equipment)

Feb 8 - KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups

Feb 8 - KPMG report: Implications of proposed changes to sections 174 and 280C in bipartisan tax extenders legislation

Feb 8 - KPMG report: State and local tax, technology-related developments (table, fourth quarter 2023)

Feb 7 - Rev. Proc. 2024-12: Temporary extension of time to submit seller reports for transfers of clean vehicle credits

Feb 7 - IRS provides tax relief for taxpayers in West Virginia affected by severe storms, flooding, landslides, and mudslides

Feb 6 - IRS provides revised FAQs on Form 1099-K

Feb 6 - Rev. Proc. 2024-13: Automobile depreciation deduction limits for 2024

Feb 5 - IRS provides tax relief for taxpayers in Maine affected by severe storms, flooding

Feb 5 - KPMG report: Navigating the shifting landscape of research credit audits

Feb 5 - KPMG report: State and local tax changes affecting entities in asset management industry in 2023

Feb 5 - KPMG reports: Missouri (REIT dividends deductible); New York (qualified emerging technology company); multistate (worldwide combined reporting)

Feb 2 - KPMG report: Mexican rulings on exportation of services eligible for 0% VAT

January 2024

Jan 31 - KPMG report: New year, changing information reporting and withholding (IRW) requirements

Jan 30 - KPMG report: SEC comments on accounting for income taxes

Jan 29 - KPMG report: Practical tax mechanics of implementing SEC clawbacks

Jan 29 - KPMG reports: Colorado (sales and use tax); New York (property tax exclusion); multistate (online marketplace sales)

Jan 26 - IRS provides tax relief for taxpayers in Rhode Island affected by severe storms, flooding, and tornadoes

Jan 26 - KPMG report: Avoiding common pitfalls in oil and gas reserve valuations for U.S. tax purposes

Jan 25 - Notice 2024-23: Special relief for certain rollovers to or from Maryland prepaid college trust accounts

Jan 25 - Tennessee: Proposed legislation authorizing franchise tax refunds

Jan 22 - Comment period reopened for proposed regulations on federal independent dispute resolution (IDR) process

Jan 22 - IRS provides tax relief for taxpayers in Connecticut affected by severe storms

Jan 22 - KPMG report: Resurgence of transfer pricing penalties

Jan 22 - KPMG reports: Florida (sales factor litigation); Massachusetts (corporate excise tax changes); Washington State (capital gains as excise tax case)

Jan 19 - Notice 2024-20: Guidance on qualified alternative fuel vehicle refueling property credit under section 30C

Jan 19 - IRS LB&I division adds a new compliance campaign (sports industry losses)

Jan 18 - Final regulations: Guidance on minimum present value requirements for certain defined benefit plans

Jan 18 - KPMG report: Reporting and paying the stock repurchase excise tax—not quite yet

Jan 18 - KPMG report: Updated accounting method change procedures and clarification of rules addressing capitalization of research and experimentation costs under section 174

Jan 17 - KPMG report: Key takeaways from recent CAMT releases

Jan 16 - Announcement 2024-4: Transitional guidance on reporting of information on receipt of digital assets

Jan 16 - KPMG reports: Connecticut (solar electricity property tax exemption); Pennsylvania (sourcing); Michigan (income tax nexus)

Jan 12 - IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships

Jan 12 - Notice 2024-18: Updated guidance on availability of administrative exemptions from requirement to file electronically

Jan 12 - Notice 2024-22: Initial guidance on pension-linked emergency savings accounts

Jan 12 - Updated beneficial ownership information reporting FAQs

Jan 11 - Notice 2024-19: Additional time and penalty relief for partnerships to provide complete Forms 8308 for 2023 section 751(a) exchanges

Jan 11 - IRS announces changes to QI / WP / WT FAQs website

Jan 10 - Fourth Circuit: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed

Jan 10 - National Taxpayer Advocate report to Congress identifying taxpayer problems

Jan 9 - KPMG report: Accounting for income taxes considerations for the implementation of the Bermuda corporate income tax

Jan 8 - KPMG reports: Florida (sales and use tax); New York (corporate franchise tax reforms); multistate (P.L. 86-272)

Jan 5 - KPMG report: Proposed regulations on clean hydrogen production credit and related energy credit

Jan 5 - IRS announces more time for dealers and sellers of clean vehicles to submit time-of-sale reports

Jan 3 - Federal Circuit: Butane not eligible for alternative fuel mixture tax credit

Jan 2 - Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)

Jan 2 - IRS annual revenue procedures for 2024

2023 Articles

December 2023

Dec 29 - Announcement 2024-5: Termination of United States-Hungary tax treaty effective January 1, 2024

Dec 29 - Notice 2024-13: Request for comments on product identification number requirement for energy efficiency home improvement

Dec 28 - Notice 2024-9: Transitional procedures for applicable entities to claim statutory exceptions to phaseouts for clean energy credits if domestic content requirements not met

Dec 28 - Notice 2024-11: Updated list of treaties meeting qualified dividend requirements adds Chile, removes Hungary and Russia

Dec 28 - Notice 2024-16: Guidance on the application of section 961 to certain inbound nonrecognition transactions

Dec 27 - Proposed regulations: Guidance on bad debt deductions for regulated financial companies and members of regulated financial groups

Dec 26 - IRS updates FAQs on clean vehicle credits

Dec 26 - IRS extends QI/WP/WT certification due date

Dec 22 - Proposed regulations: Guidance on clean hydrogen production credit under section 45V and related energy credit under section 48(a)(15)

Dec 22 - Announcement 2024-3: New voluntary disclosure program for employee retention credit

Dec 22 - IRS announces tool for elective payment or transfer of credits under IRA and CHIPS

Dec 22 - IRS provides tax relief for taxpayers in Tennessee affected by tornadoes and severe storms

Dec 22 - Notice 2024-12 and Rev. Proc. 2024-9: Modified guidance on application of section 174

Dec 22 - KPMG report: Foreign tax credits for multinationals

Dec 22 - KPMG report: Proposed regulations on advanced manufacturing production credit under section 45X

Dec 20 - Notice 2024-2: Guidance on certain provisions of Secure Act 2.0

Dec 20 - Notice 2024-3: 2023 cumulative list of changes in plan qualification requirements for defined contribution qualified pre-approved plans

Dec 20 - Notice 2024-5: Safe harbor for “incremental cost” of commercial clean vehicles eligible for tax credit under section 45W

Dec 20 - Notice 2024-7: Relief from additions to tax for failure to pay with respect to certain 2020 and 2021 income tax returns (COVID-19)

Dec 20 - FBAR filings: Extended deadline is April 15, 2025, for individuals with signature authority

Dec 20 - KPMG report: Preparing for the new excise tax under section 5000D on sales of specified drugs

Dec 19 - Tax treaty update: Income tax treaty with Chile enters into force

Dec 19 - Notice 2024-1: Indexing factor for use by group health plans and health insurance issuers in 2024 under “No Surprises Act” provisions

Dec 19 - KPMG report: Accounting standards update includes improvements to income tax disclosures

Dec 18 - Final regulations: De minimis error safe harbor exceptions to penalties for failure to file correct information returns or furnish correct payee statements

Dec 18 - Final regulations: Federal independent dispute resolution (IDR) process administrative fee and certified IDR entity fee ranges

Dec 18 - Rev. Proc. 2023-36: Updated list of jurisdictions for exchanging deposit interest information

Dec 18 - Rev. Rul. 2024-1: Covered compensation tables for 2024 plan year

Dec 18 - KPMG report: IRS enforcement on high-income and high-wealth individuals

Dec 18 - KPMG report: State, local tax changes (year-end checklist and fourth quarter 2023)

Dec 15 - Notice 2024-10: Additional interim guidance on new corporate alternative minimum tax (CAMT)

Dec 15 - Notice 2024-6: Additional guidance on new sustainable aviation fuel credits

Dec 14 - Proposed regulations: Implementation of advanced manufacturing production credit under section 45X

Dec 14 - Notice 2024-8: Standard mileage rates for 2024

Dec 13 - IRS announces plans for new leadership structure

Dec 12 - Updated beneficial ownership information reporting FAQs

Dec 11 - Notice 2023-80: Guidance on application of FTC and DCL rules to Pillar Two taxes, extension and modification of temporary FTC relief

Dec 11 - KPMG report: Tax-free fixed indemnity healthcare for employees

Dec 11 - KPMG reports: New York (sales tax on party platters); Pennsylvania (Philadelphia voluntary disclosure program); Washington State (B&O and sales tax guidance)

Dec 8 - Notice 2023-79: Required amendments list (2023) for qualified retirement plans and 403(b) plans

Dec 7 - Rev. Proc. 2023-41: Insurance companies, unpaid loss discount factors for 2023 accident year

Dec 6 - IRS announces continued increased scrutiny of employee retention credit claims

Dec 6 - KPMG report: Transitory relief for Forms 1099-K

Dec 4 - KPMG report: Proposed regulations on investment tax credit for energy property under section 48

Dec 4 - KPMG reports: Illinois (constitutionality of retailer’s occupation tax); Minnesota (goodwill gain is apportionable business income); Washington State (sales and B&O tax)

Dec 1 - Proposed regulations and Rev. Proc. 2023-38: Guidance on excluded entity provisions under section 30D clean vehicle credit

Dec 1 - IRS practice unit: Taxation of beneficiary of a foreign non-grantor trust

Dec 1 - Updated guidance on beneficial ownership information reporting requirements

November 2023

Nov 29 - Final regulations: Extended filing deadline for initial beneficial ownership information reports

Nov 28 - U.S. Tax Court: Court has jurisdiction to determine in partnership-level proceeding application of limited partner exception to self-employment income

Nov 27 - IRS provides tax relief for taxpayers in Illinois affected by storms

Nov 27 - IRS provides tax relief for taxpayers in St. Croix affected by elevated levels of lead and copper in water supply

Nov 27 - Tier 2 tax rates for railroads, no changes for 2024

Nov 24 - Proposed regulations: Amendments to apply entity approach to partnership loss disallowance rules under sections 267 and 707

Nov 24 - Proposed regulations: Guidance under section 401(k) for long-term, part-time employees

Nov 21 - Notice 2023-74: Further delay of implementation of $600 reporting threshold for Forms 1099-K; $5000 threshold for 2024 to phase in implementation

Nov 21 - Rev. Proc. 2023-37: Rules for qualified pre-approved plans and 403(b) pre-approved plans

Nov 21 - KPMG report: IRS hearing on digital asset proposed regulations

Nov 20 - KPMG reports: California (inclusion of dividends in sales factor); Florida (proposed sales tax holiday); Louisiana (sales tax on online car sharing)

Nov 17 - Proposed regulations: Disallowance of deductions for certain conservation easement contributions by partnerships, S corporations

Nov 17 - Proposed regulations: Guidance on energy credit under section 48 as amended by “Inflation Reduction Act”

Nov 17 - Proposed regulations: Guidance on various issues under “Affordable Care Act”

Nov 17 - Interim final rule: Amended definition of “obligation” regarding state and local fiscal recovery funds (COVID-19)

Nov 17 - Rev. Rul. 2023-22: Interest rates, tax underpayments and overpayments remain same for first quarter 2024

Nov 17 - Updated draft CAMT form

Nov 16 - Reply brief for petitioners in Moore case

Nov 16 - Updated beneficial ownership information reporting FAQs

Nov 16 - Delaware: Notices requesting “verified reports” of unclaimed property

Nov 16 - KPMG report: U.S. Tax Court decision upholding IRS determination that fund engaged in U.S. trade or business

Nov 15 - U.S. Tax Court: Partnership engaged in U.S. trade or business based on activities of asset manager

Nov 13 - KPMG report: Adjusting closed-year partnership-related items

Nov 13 - KPMG reports: Maine (service receipts); Missouri (resale exemption for use tax); Ohio (agent exclusion from CAT base); Texas (increase in franchise tax exemption)

Nov 11 - KPMG report: Proposed regulations under section 987, initial observations and analysis

Nov 9 - Proposed regulations: Income, currency gain or loss of QBU (section 987); comment period reopening for 2016 proposed regulations

Nov 9 - Rev. Proc. 2023-34: Inflation adjustments for 2024, individual taxpayers

Nov 8 - U.S. Tax Court: Brazilian legal restriction not taken into account in determining arm’s length transfer price under section 482

Nov 8 - U.S. Tax Court: Section 904(f)(3)(A) does not prevent recognition of gain in excess of overall foreign loss account or recharacterize such gain as foreign source income

Nov 8 - KPMG report: Section 451(b) and specified fees

Nov 6 - KPMG reports: New Jersey (corporation business tax); New York (new employee displacement tax); Texas (data processing services)

Nov 2 - Hearing on proposed regulations concerning digital asset transactions rescheduled to November 13

Nov 2 - U.S. Tax Court: Exchange of variable prepaid forward contracts (VPFCs) taxable under section 1234A as short-term capital gain

Nov 1 - Notice 2023-75: Pension plans, cost-of-living adjustments for 2024

October 2023

Oct 30 - IRS extends acceptance of digital signatures, encrypted emails

Oct 30 - IRS adds two FAQs to QI / WP / WT FAQs website

Oct 30 - KPMG reports: California (Proposition 39 upheld); Kansas (corporate income tax rate reduction); New York (sales tax on clothing); Utah (sales tax on bundled digital subscription fees)

Oct 27 - Proposed regulations: Guidance under No Surprises Act, including federal independent dispute resolution (IDR) process

Oct 27 - KPMG report: Transfer pricing and international tax year-end considerations

Oct 27 - KPMG report: State and local tax, technology-related developments (table, third quarter 2023)

Oct 24 - Extension of comment period for proposed regulations on digital asset transactions

Oct 23 - U.S. Treasury to allocate $5 billion in New Markets Tax Credit (NMTC) authority for 2023

Oct 23 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Oct 23 - KPMG reports: Impact of proposed U.S. broker digital asset tax reporting regulations on industry verticals (updated with new reports)

Oct 23 - KPMG reports: Illinois (Chicago real estate transfer tax); Florida (communications services tax); Massachusetts (local option real estate transfer fees); New Mexico (taxation of digital advertising)

Oct 20 - IRS announces new compliance initiatives aimed at large corporations

Oct 20 - IRS LB&I division memorandum to employees on compliance priorities

Oct 19 - Final and proposed regulations: Mortality tables for determining present value under defined benefit pension plans

Oct 19 - Notice 2023-73: Mortality table for use in determining minimum present value for 2024

Oct 19 - IRS announces special withdrawal process for employee retention credit claims

Oct 19 - KPMG report: Questions remain on Superfund excise tax compliance

Oct 18 - Notice 2023-70: Self-insured health insurance annual fee

Oct 17 - Government files brief in Moore case

Oct 16 - FBAR filing deadline relief for filers affected by terroristic action in Israel

Oct 16 - IRS provides tax relief for taxpayers in California affected by winter natural disasters

Oct 16 - KPMG report: Analysis of relief provisions of Rev. Proc. 2013-30 for late S corporation elections

Oct 16 - KPMG report: IRS announcement of new large partnership audits

Oct 16 - KPMG report: Voluntary and mandatory disclosure requirements and options

Oct 16 - KPMG reports: New Jersey (guidance on various corporation business tax issues); Wisconsin (transfer of title constituted sale for sales tax purposes)

Oct 13 - Notice 2023-71: IRS provides relief for taxpayers affected by terroristic action in Israel

Oct 13 - KPMG reports: Impact of proposed U.S. broker digital asset tax reporting regulations on industry verticals

Oct 13 - IRS updates FAQ on QI / WP / WT website to provide guidance on WP / WT agreement renewals

Oct 12 - U.S. Supreme Court schedules oral arguments in Moore case for December 5

Oct 12 - Disallowance of section 168(k) additional first-year allowance for depreciation for “excepted trade or business” (Chief Counsel legal advice memo)

Oct 9 - KPMG reports: California (application of P.L. 86-272 to internet sellers); Florida (electronically delivered software not subject to sales tax); Massachusetts (corporate excise tax); Tennessee (sales tax on place of amusement)

Oct 6 - Proposed regulations, Rev. Proc. 2023-33, and updated FAQs: Guidance on transfer of clean vehicle credits under sections 25E and 30D

Oct 5 - Proposed regulations: Guidance under section 367(b) relating to certain triangular reorganizations and inbound nonrecognition transactions

Oct 5 - Purchaser of foreign goods not an “importer” liable for excise tax under section 4071 (federal district court)

Oct 4 - Washington State: Penalties on unfiled annual reconciliation of apportionable income

Oct 3 - IRS request for information on requiring health insurance coverage of over-the-counter preventive items under Affordable Care Act

Oct 2 - IRS practice unit: Foreign tax credit—categorization of income and taxes into proper basket (updated August 1)

Oct 2 - KPMG reports: Iowa (reduced corporate income tax rates); Massachusetts (pending tax law changes, including for corporate excise tax); Oregon (Portland business license tax credit); Texas (sales and use tax guidance for electronic games)

September 2023

Sep 29 - IRS Priority Guidance Plan for 2023-2024

Sep 29 - IRS provides tax relief for taxpayers in Louisiana affected by seawater intrusion

Sep 29 - Rev. Proc. 2023-35: Wash sale relief for certain redemptions of shares in money market funds

Sep 29 - Additional guidance on beneficial ownership information reporting requirements

Sep 28 - IRS contingency plan during possible government shutdown

Sep 28 - Notice 2023-69: Guidance on employer leave-based donation programs aiding Hawaii wildfire victims

Sep 28 - KPMG report: New CAMT guidance in Notice 2023-64 expands scope, increases compliance burdens

Sep 27 - Application period for environmental justice solar and wind capacity limitation program opens October 19

Sep 27 - Proposed regulations: Guidance on procedural requirements for section 5000D excise tax on sales of “designated drugs”

Sep 27 - Proposed regulations: Extended filing deadline for certain beneficial ownership information reports

Sep 27 - U.S. Tax Court: 30-day time limit for requesting collection due process hearing subject to equitable tolling

Sep 27 - Notice 2023-67: Farmers, ranchers affected by drought allowed more time to replace livestock

Sep 27 - Notice 2023-65: Guidance on new energy efficient home credit under section 45L

Sep 26 - Notice of hearing: Proposed regulations on reinstated Superfund chemical tax and Superfund imported substance tax

Sep 25 - Notice 2023-68: Per diem rates, substantiation of employee lodging, meals, incidentals (2023-2024)

Sep 25 - IRS provides tax relief for taxpayers in Maine and Massachusetts affected by Hurricane Lee

Sep 25 - KPMG report: State, local tax changes (third quarter 2023, table format)

Sep 25 - KPMG reports: Missouri (sales tax collection); North Carolina (sourcing rules); Tennessee (sales and use tax industrial machinery exemption); Washington State (manufacturing B&O tax)

Sep 25 - KPMG report: Initial observations on round 4 of CAMT guidance in Notice 2023-64

Sep 22 - Treasury awards $5 billion in New Markets Tax Credit (NMTC) allocations

Sep 21 - Proposed regulations: Federal independent dispute resolution (IDR) process administrative fee and certified IDR entity fee ranges

Sep 21 - Federal Circuit: Claims court erred in applying hybrid legal standard conflating step transaction and economic substance doctrines

Sep 20 - IRS announces new work unit focused on large or complex passthrough entities to help with high-income compliance efforts

Sep 19 - Interim final rule concerning state and local fiscal recovery funds (COVID-19)

Sep 18 - KPMG reports: Arkansas (proposed reduction in income tax rates); Florida (guidance on sales and use tax audit program); Kansas (reduction in corporate income tax rate); Oregon (guidance on P.L. 86-272); Tennessee (industrial machinery sales tax exemption)

Sep 15 - IRS request for comments on expanding tax certainty and issue resolution programs for business taxpayers

Sep 15 - IRS request for feedback on proposed changes to Form 6765, Credit for Increasing Research Activities

Sep 14 - IRS announces moratorium on processing new employee retention credit claims

Sep 13 - KPMG report: Initial observations and analysis of Notice 2023-63 providing guidance on section 174

Sep 13 - IRS provides tax relief for taxpayers in Georgia affected by Hurricane Idalia

Sep 12 - Notice 2023-64: Additional interim guidance on new corporate alternative minimum tax (CAMT)

Sep 12 - FBAR filing deadline relief for persons affected by certain natural disasters (Hawaii wildfires and Hurricane Idalia)

Sep 11 - First Circuit: Immediate recognition of income upon constructive transfer of intangible property in reorganization; Tax Court affirmed

Sep 11 - KPMG reports: California (marketplace facilitator law); California (mutual fund service provider sourcing rule); New Jersey (corporation business tax nexus); New York (broker-dealer sourcing rule)

Sep 8 - KPMG report: Proposed regulations on prevailing wage and apprenticeship requirements under clean energy tax incentives

Sep 8 - IRS announces new compliance effort focused on high-income individuals, partnerships, and large corporations

Sep 8 - IRS announces all QI / WP / WT applications for 2023 must be submitted through QAAMS by October 27

Sep 8 - Notice 2023-63: Guidance on application of section 174

Sep 6 - IRS opens application period for 2024 Compliance Assurance Process (CAP) program

Sep 6 - IRS provides tax relief for taxpayers in South Carolina affected by Hurricane Idalia

Sep 5 - IRS releases FAQ for pass-through entities for electronically filing Schedules K-2 and K-3 to report negative amounts

August 2023

Aug 31 - IRS provides tax relief for taxpayers in Florida affected by Hurricane Idalia

Aug 30 - Notice 2023-56: Guidance on state and local tax refunds and other payments to individuals

Aug 30 - KPMG report: Proposed regulations expand tax information reporting on digital asset transactions

Aug 30 - IRS provides tax relief for taxpayers in Alaska affected by flooding

Aug 29 - Proposed regulations: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

Aug 28 - KPMG reports: Louisiana (sales and use tax); New Jersey (corporation business tax)

Aug 25 - Proposed regulations: Information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions

Aug 25 - Notice 2023-62: Guidance on new Roth catch-up requirement, including administrative transition period

Aug 25 - Rev. Rul. 2023-17: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2023)

Aug 25 - IRS updates 2023 Form 1042-S instructions

Aug 25 - KPMG report: Potential U.S. tax implications of proposed Bermuda corporate income tax

Aug 24 - Fourth quarter update to IRS 2022-2023 Priority Guidance Plan

Aug 24 - IRS updates FAQ extending penalty relief, Forms 1042 and 1042-S

Aug 23 - Rev. Proc. 2023-29: Premium tax credit percentage table for 2024

Aug 22 - KPMG report: Origin of the qualified intermediary (QI) program

Aug 21 - IRS provides tax relief for taxpayers affected by wildfires in Hawaii

Aug 21 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Aug 21 - KPMG reports: Pennsylvania (lookback period for voluntary disclosure agreement program); Tennessee (employment services not subject to sales and use tax)

Aug 18 - IRS notices: Oil and gas—reference prices for 2023, inflation adjustment factor and phase-out for enhanced oil recovery credit

Aug 16 - IRS provides tax relief for taxpayers in Illinois affected by storms

Aug 15 - KPMG report: Select financial product provisions in Biden Administration’s FY 2024 budget

Aug 15 - IRS provides tax relief for taxpayers in Mississippi affected by storms

Aug 14 - KPMG reports: Navigating CAMT

Aug 14 - KPMG reports: New Jersey (convenience of employer rule); New York (corporate franchise tax); South Carolina (method of apportionment)

Aug 11 - Notice 2023-60: Availability of administrative exemptions from requirement to file electronically

Aug 10 - Final regulations and Rev. Proc. 2023-27: Guidance on environmental justice solar and wind capacity limitation

Aug 9 - Seventh Circuit: Deduction for assumed deferred compensation liabilities not allowed when not paid; Tax Court affirmed

Aug 9 - Interim final rule concerning state and local fiscal recovery funds; OIRA review completed (COVID-19)

Aug 8 - D.C. Circuit: Exaction related to employer mandate under Affordable Care Act is a tax for jurisdictional purposes

Aug 8 - IRS adds a new compliance campaign (LB&I division)

Aug 7 - KPMG reports: California (apportionment formula); Michigan (sales factor, taxation of digital goods); New Hampshire (deduction for disallowed interest); Ohio (oil and gas sales and use tax exemption)

Aug 4 - Proposed regulations: Amendments to consolidated return regulations to reflect statutory changes, modernize language, and enhance clarity

Aug 4 - Notice 2023-59: Guidance on qualification of home energy audits for energy efficient home improvement credit under section 25C

Aug 4 - Notice 2023-52: Guidance on section 5000D excise tax on sales of “designated drugs”

Aug 3 - KPMG report: Draft forms provide insight into compliance burden imposed by new CAMT

Aug 3 - Proposed regulations: Monetized installment sale transactions identified as listed transactions

Aug 1 - KPMG report: Validating Form W-8BEN and BEN-E treaty claims

July 2023

Jul 31 - Proposed regulations: Implementation of amended nonquantitative treatment limitation comparative analyses requirements for health plans

Jul 31 - Rev. Rul. 2023-14: Cryptocurrency rewards included in income when taxpayer gains dominion and control over rewards

Jul 31 - KPMG reports: California (sales tax audit methods); New Jersey (convenience of employer rule); Oklahoma (franchise tax returns): Texas (franchise tax reports)

Jul 28 - IRS clarifies position on employee retention credit supply chain disruptions (generic legal advice memorandum)

Jul 27 - IRS request for comments on dispute resolution programs

Jul 27 - Third Circuit: Legal expenses for defending patent infringement suits are deductible

Jul 27 - KPMG report: Accounting for income taxes considerations for foreign tax credits following Notice 2023-55

Jul 27 - KPMG report: State and local tax, technology-related developments (table, second quarter 2023)

Jul 25 - IRS notices: Percentage depletion for oil and gas produced from marginal properties; electricity production credit

Jul 24 - Final regulations: Recapture of excess employment tax credits under COVID-19 legislation

Jul 24 - KPMG reports: California (tax on lease of tangible personal property); Mississippi (computer software direct pay permits)

Jul 21 - Notice 2023-55: Temporary relief for foreign tax credit under sections 901 and 903

Jul 19 - Third Circuit: 90-day time limit to file deficiency petition is not jurisdictional and thus subject to equitable tolling

Jul 18 - Delaware: Letters sent inviting companies to join unclaimed property voluntary disclosure agreement program, 90 days to respond

Jul 18 - KPMG report: Underutilization of alternative dispute resolution programs

Jul 17 - KPMG reports: Hawaii (fuel tax replacement); Maryland (digital advertising tax); Massachusetts (software providers as manufacturing corporations); New Jersey (corporation business tax changes)

Jul 14 - Notice 2023-54: Transition relief and guidance related to certain required minimum distributions

Jul 14 - Notice of filing of petition for addition of methyl ethyl ketoxime to Superfund list

Jul 13 - IRS practice unit: Expatriation on or after June 17, 2008—mark-to-market tax regime

Jul 13 - IRS provides tax relief for taxpayers in Vermont affected by flooding

Jul 13 - KPMG report: State conformity to federal treatment of section 174 R&E costs

Jul 13 - KPMG report: Tax credits for sustainable aviation fuel

Jul 10 - Final regulations: Carryback of consolidated net operating losses

Jul 10 - New Jersey: Corporation business tax changes enacted

Jul 10 - KPMG report: REITs and the new corporate alternative minimum tax

Jul 7 - Proposed regulations: Definitions of short-term, limited-duration insurance and excepted benefits coverage, tax treatment of certain accident and health insurance

Jul 6 - U.S. Tax Court: Section 41 research tax credit denied, accuracy-related penalties imposed

Jul 6 - Ninth Circuit: Partnership losses claimed on unsigned, unfiled tax returns disallowed; Tax Court reversed

Jul 3 - U.S. Tax Court: Period of limitations for assessing tax on partnership items expired

June 2023

Jun 29 - Final regulations: Additional guidance on transition from interbank offered rates (IBORs) to other reference rates for foreign banks with ECI

Jun 29 - Announcement 2023-18: Taxpayers not required to report or pay stock repurchase excise tax before time specified in forthcoming regulations

Jun 27 - KPMG report: Analysis and observations of direct pay and transferable credit proposed regulations

Jun 26 - U.S. Supreme Court grants certiorari, whether mandatory repatriation tax under section 965 is constitutional

Jun 26 - IRS practice unit: Foreign tax credit—categorization of income and taxes into proper basket

Jun 26 - KPMG report: State, local tax changes (second quarter 2023, table format)

Jun 26 - KPMG reports: Alabama (monthly sales tax filing threshold); Michigan (memo not a request for refund); Texas (sales and use tax exemptions); Washington State (data processing)

Jun 23 - Notice 2023-37: Guidance related to COVID-19 for purposes of high-deductible health plans

Jun 23 - Notice 2023-46: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2023

Jun 23 - Notice 2023-49: Reference price for enhanced oil recovery credit, marginal oil and gas production

Jun 23 - U.S. Court of Federal Claims: Value of anticipated cash grants are separate intangible assets for purchase price allocation purposes

Jun 22 - Tax treaty update: Senate votes to approve income tax treaty with Chile

Jun 21 - Tax treaty update: Senate votes to invoke cloture on income tax treaty with Chile

Jun 21 - U.S. Tax Court: Passthrough net operating loss carryovers disallowed due to insufficient basis

Jun 21 - National Taxpayer Advocate mid-year report to Congress identifying key objectives for upcoming fiscal year

Jun 20 - Renewable electricity production inflation factors, reference prices for 2023

Jun 16 - KPMG report: State tax implications of “Inflation Reduction Act”

Jun 15 - Notices 2023-45 and 2023-47: Updated guidance on requirements for energy community production and investment tax credits

Jun 15 - Rev. Proc. 2023-24: Updated annual list of automatic accounting method changes

Jun 14 - Treasury and IRS release guidance on direct pay and transferable tax credits

Jun 12 - Treasury, OMB agreement no longer requires OIRA review for tax regulatory actions issued by IRS

Jun 12 - Tax treatment of employer-funded, fixed-indemnity insurance policy (Chief Counsel legal advice memo)

Jun 12 - KPMG reports: Connecticut (corporate surcharge extension); Illinois (investment partnership status changes); Louisiana (sales tax economic nexus threshold change); Mississippi (no good faith basis for exempt sales); Oklahoma (franchise tax repealed)

Jun 7 - Notice 2023-42: Estimated tax penalty relief for corporations subject to CAMT

Jun 7 - KPMG report: U.S. foreign tax credit issues arising from 2022 Colombian tax reform

Jun 6 - Proposed regulations: Malta personal retirement scheme transactions identified as listed transactions

Jun 6 - KPMG report: State nil reporting and penalty notices

Jun 5 - Eighth Circuit: Value of stock held by estate included life insurance proceeds intended for redemption of such stock

Jun 5 - Notice 2023-41: Reference price for section 45I credit for production of natural gas from marginal wells

Jun 5 - President Biden to nominate Marjorie Rollinson as IRS Chief Counsel

Jun 5 - KPMG reports: Colorado (commercial property tax valuations); Minnesota (retail delivery fee); Nebraska (corporate income tax rate reduction); Virginia (manufacturer’s apportionment formula)

Jun 2 - KPMG report: Accounting for tax credits handbook

Jun 1 - Final regulations: Updated actuarial tables for valuing annuities, terms of years, and remainder interests

Jun 1 - Tax treaty update: Senate Foreign Relations Committee votes to advance income tax treaty with Chile to full Senate vote

May 2023

May 31 - Proposed regulations: Additional guidance on environmental justice solar and wind capacity limitation under section 48(e)

May 31 - Notice 2023-44: Additional guidance on qualifying advanced energy project credit under section 48C(e)

May 31 - Minnesota: Retail delivery fee imposed on retailers effective July 1, 2024

May 31 - New York State: Changes to metropolitan commuter transportation mobility tax self-employment tax

May 25 - Notice 2023-43: Guidance regarding expansion of employee plans compliance resolution system under Secure Act 2.0

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 - KPMG report: Analysis and observations of proposed section 367(d) regulations addressing certain intangible property repatriations

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 - Application of the FIRPTA regularly traded exception to stock held by partnerships (Chief Counsel legal advice memo)

May 22 - Rev. Rul. 2023-11: Interest rates, tax underpayments and overpayments remain same for third quarter 2023

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 22 - KPMG reports: Minnesota (omnibus tax package); Montana (bill to exclude tax haven entities); Tennessee (tax changes enacted)

May 19 - U.S. Supreme Court: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers upheld

May 17 - U.S. Tax Court: Expenses under orphan drug credit under section 45C must also be taken in account in determining research credit under section 41

May 16 - Rev. Proc. 2023-23: HSA inflation-adjusted amounts for 2024

May 16 - IRS practice units: Interest expense limitations under sections 267(a)(3) and 163(j); dividend distribution with a debt

May 16 - IRS report on potential free e-filing system; pilot program for 2024 filing season

May 16 - U.S. Tax Court: Cost of goods sold includes only excise taxes actually paid in determining excise tax liability

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 15 - KPMG reports: Colorado (retail delivery fee); Florida (federal conformity, sales and use tax); Indiana (corporate income tax, sales and use tax)

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 - Notice 2023-39: Forthcoming proposed regulations regarding arbitrage treatment of certain guarantee funds under section 148

May 10 - Maryland Supreme Court dismisses challenge to digital advertising tax

May 9 - Proposed regulations: Information reporting and transfer for valuable consideration rules for section 1035 exchanges

May 8 - Third quarter update to IRS 2022-2023 Priority Guidance Plan

May 8 - KPMG report: Progress on improving mutual agreement procedure

May 8 - KPMG reports: Minnesota (proposed mandatory worldwide combined reporting); New York (business income and capital tax changes); Pennsylvania (treatment of electricity for income apportionment purposes)

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 - IRS announces QI / WP / WT application and account management system (QAAMS) fully transitioning to new sign-in system

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

May 1 - KPMG reports: Arizona (sales tax processing exemption); Michigan (delivery and installation charges subject to sales or use tax); Tennessee (excise and franchise tax changes pending enactment)

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 24 - KPMG reports: Colorado (effect of CARES Act); Missouri (sales and use tax manufacturing exemption); Virginia (federal conformity)

Apr 24 - IRS provides tax relief for taxpayers in Oklahoma affected by storms, straight-line winds, and tornadoes

Apr 21 - Rev. Proc. 2023-22: Nationwide average purchase price, residences located in United States

Apr 20 - U.S. Tax Court: Annuity payments received from charitable remainder trusts taxable as ordinary income

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 17 - KPMG reports: Arkansas (corporate rate reduction, throwback rule phase out); Kentucky (definition of telemarketing services); Washington State (B&O deduction for investment income)

Apr 14 - IRS releases tax collection data for fiscal year 2022

Apr 14 - Rev. Proc. 2023-15: Safe harbor method of accounting for expenses related to natural gas transmission and distribution property

Apr 13 - KPMG report: Initial observations on Notice 2023-29 guidance on determining energy communities for IRA tax credits

Apr 12 - Rev. Rul. 2023-8: Prior ruling relating to expensing of research and experimentation expenditures obsolete

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 10 - KPMG reports: Colorado (notice of tax credits to employees); Georgia (federal tax conformity); New Mexico (tax package vetoed); West Virginia (apportionment changes)

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 5 - Foreign taxes paid on accumulated earnings offset under section 965 are creditable (federal district court)

Apr 4 - Notice 2023-29: Guidance on requirements for energy community production and investment tax credits under IRA

Apr 3 - Notice 2023-31: Extension of transition period for single-country exception documentation requirement under section 903

Apr 3 - U.S. Tax Court: IRS lacks statutory authority to assess penalties under section 6038(b) for willful failure to file Form 5471

Apr 3 - IRS provides tax relief for taxpayers in Arkansas affected by tornadoes and severe storms

Apr 3 - KPMG reports: Kentucky (sales and use tax); Mississippi (changes related to section 174); Mississippi (sales tax treatment of computer software); Washington State (capital gains tax is permissible excise tax)

March 2023

Mar 31 - Proposed regulations: Guidance on new clean vehicle credit

Mar 29 - Announcement 2023-10: APMA program, APA statistics for 2022

Mar 29 - Rev. Rul. 2023-2: No basis step-up for assets of irrevocable grantor trust not included in grantor’s estate

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: Notable highlights from section 48D proposed regulations (advanced manufacturing investment credit)

Mar 27 - KPMG report: Stock repurchase excise tax and funding rule considerations for inbound taxpayers

Mar 27 - KPMG reports: New Jersey (proposed changes to corporate tax law); Rhode Island (virtual services subject to sales and use tax); South Dakota (temporary reduction in sales tax rate)

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 21 - Notice 2023-27: Guidance and request for comments on treatment of certain NFTs as section 408(m) collectibles

Mar 20 - KPMG reports: California (unclaimed property); Colorado (real estate sales and receipts factor); Florida (costs of performance sourcing rule); Louisiana (sales and use tax informational report); Montana (single receipts factor)

Mar 17 - IRS provides FAQs on whether nutrition, wellness, and general health costs are medical expenses

Mar 17 - IRS provides tax relief for taxpayers in California affected by March storms, flooding, landslides, mudslides

Mar 17 - KPMG report: Crypto crackdown—information reporting in a digital asset world

Mar 17 - KPMG report: FASB proposed accounting standards update addresses requests for improved tax disclosures

Mar 15 - Notice of filing of petition for addition of cellulose acetate (degree of substitution = 1.5 – 2.0) to Superfund list

Mar 15 - California: Guidance concerning unclaimed property voluntary compliance program

Mar 14 - Notice 2023-26: Housing expense limit adjustments, foreign locations for 2023

Mar 14 - Proposed regulations concerning Superfund chemical tax and Superfund imported substance tax; OIRA review completed

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 13 - KPMG reports: Minnesota (sales tax guidance for marketplace providers); Texas (apportionment for franchise tax); Wisconsin (online ticket marketplace liable for sales and use tax)

Mar 10 - AOD 2023-1: IRS acquiescence to Fifth Circuit decision, tax on exports of domestic crude oil held unconstitutional

Mar 10 - Ninth Circuit: Tax return not considered filed when sent in response to IRS inquiry; Tax Court affirmed

Mar 9 - Notice 2023-24: Credit for production of electricity from advanced nuclear power facilities under section 45J

Mar 9 - Rev. Proc. 2023-17: Indexing adjustments for amounts used to calculate employer shared responsibility payments

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 6 - KPMG reports: District of Columbia (sales tax on resold items); multistate (escheatment of abandoned property); multistate (corporate surtaxes)

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 27 - Notice 2023-21: Relief with respect to lookback periods for returns with postponed due dates (COVID-19)

Feb 27 - KPMG report: Corporate Alternative Minimum Tax considerations and FAQs (updated after Notices 2023-7 and 2023-20)

Feb 27 - KPMG reports: Mississippi (decoupling from section 174); Pennsylvania (income-producing activity test); Washington State (capital gains excise tax); multistate (federal tax conformity)

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 23 - Pennsylvania: “Benefits-received” interpretation of income-producing activity test upheld (Supreme Court decision)

Feb 22 - Final regulations: Single-entity treatment of consolidated groups for purposes of section 951(a)(2)(B) in context of section 959(b) distributions

Feb 21 - Final regulations: Electronic-filing requirements for specific tax returns, other documents

Feb 21 - KPMG report: Observations from Notice 2023-20 (guidance regarding certain insurance related issues under corporate alternative minimum tax)

Feb 20 - KPMG report: Observations from Notice 2023-18 (guidance on qualifying advanced energy project credit under section 48C)

Feb 20 - KPMG reports: California (unclaimed brokerage accounts); Louisiana (cloud-based storage plans not subject to sales tax); Louisiana (manufacturing machinery and equipment sales tax exclusion); Tennessee (deduction for FDII)

Feb 17 - Notice 2023-20: Interim guidance regarding certain insurance related issues under corporate alternative minimum tax (CAMT)

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 2023-17: Guidance on environmental justice solar and wind capacity limitation under section 48(e)

Feb 13 - Notice 2023-18: Guidance on qualifying advanced energy project credit under section 48C

Feb 13 - Proposed regulations pending OIRA review: Superfund chemical tax and Superfund imported substance tax

Feb 13 - Rev. Rul. 2023-4: Interest rates, tax underpayments and overpayments remain same for second quarter 2023

Feb 13 - KPMG reports: Minnesota (retail delivery fee); Missouri (resale tax exemption); multistate (taxation of digital products and services and software)

Feb 10 - KPMG report: Accounting for income taxes handbook

Feb 9 - U.S. Tax Court: Regulation under section 482 relating to consideration of foreign legal restrictions upheld

Feb 8 - Announcement 2023-6: Updates on third six-year remedial amendment cycle for pre-approved defined benefit plans

Feb 8 - KPMG report: New section 174 mandatory capitalization regime, issues for engineering and construction industry

Feb 7 - U.S. Tax Court: Gain recognized on sale of partnership interest attributable to inventory may be U.S.-source income

Feb 6 - KPMG report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation (updated)

Feb 6 - KPMG report: State and local tax changes affecting entities in asset management industry in 2022

Feb 6 - KPMG reports: Arizona (transaction privilege tax); Michigan (rolling stock use tax exemption); Texas (sourcing of local sales tax on internet orders); Wisconsin (nonconformity with section 174 changes)

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

Feb 1 - KPMG report: FERC orders allow public utility to defer sales tax through use of procurement subsidiary (multistate)

January 2023

Jan 31 - KPMG report: Proposed regulations providing definition of domestically controlled real estate investment trust, initial analysis and observations

Jan 31 - KPMG report: Year-in-review list of U.S. federal tax developments for 2022 (as reported in TaxNewsFlash)

Jan 30 - Proposed regulations: Rescission of “moral exemption rule” to coverage of certain contraceptive services under Affordable Care Act

Jan 30 - KPMG reports: Illinois (amended return was timely filed); Texas (taxpayer may not amend franchise tax report); multistate (combined reporting)

Jan 27 - Rev. Proc. 2023-9: New rules and conditions for implementing alternative cost method for real estate developers

Jan 26 - KPMG report: IRA stock buyback, practical considerations for retirement plans and equity-based compensation arrangements

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 23 - KPMG reports: Florida (sales tax refunds on software and hardware); Texas (margin tax apportionment); Virginia (NOL carryback)

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 - Notice of filing of petition for addition of 4,4’–isopropylidenediphenol-epichlorohydrin copolymer to Superfund list

Jan 18 - Rev. Proc. 2023-14: Automobile depreciation deduction limits for 2023

Jan 18 - KPMG report: SEC comments on accounting for income taxes

Jan 18 - KPMG reports: Minnesota (federal tax conformity); Missouri (sales and use tax changes); Ohio (tax and fee amnesty); Washington State (bad debt sales tax credit and B&O tax deduction)

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 11 - KPMG report: Final regulations on exception for U.S. real property interests held by foreign pension funds, initial impressions and observations

Jan 11 - KPMG report: Section 163(j) considerations on the disposition of partnership property and partnership interests

Jan 11 - National Taxpayer Advocate report to Congress identifying taxpayer challenges, describing better outlook for 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: Year-end state and local tax updates (Kentucky, Massachusetts, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania)

Jan 4 - KPMG report: Initial observations on round 1 of CAMT guidance in Notice 2023-7

Jan 1 - KPMG report: Analysis and observations on Rev. Procs. 2023-8 and 2023-11, guidance for accounting method changes under section 174

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: Use of an electronic medium to make participant elections and spousal consents (text of regulations)

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 - Treasury releases white paper on critical mineral and battery component requirements for clean vehicle tax credits

Dec 29 - Notice 2023-1: Intention to propose regulations on requirements of clean vehicle credit under section 30D

Dec 29 - Notice 2023-3: Standard mileage rates for 2023

Dec 29 - Notice 2023-9: Safe harbor for “incremental cost” of commercial clean vehicles eligible for tax credit under section 45W

Dec 28 - IRS provides updated FAQs on Form 1099-K

Dec 28 - Final regulations: Exception for U.S. real property interests held by foreign pension funds (text of regulations)

Dec 28 - Proposed regulations: Foreign government income exception and definition of domestically controlled qualified investment entities (text of regulations)

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 2023-1: Applicable reference standard for energy efficient commercial building property deduction

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 - IRS provides FAQs on energy efficient home improvements and residential clean energy property credits

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 19 - KPMG reports: Florida (online learning services subject to communications services tax); Ohio (expanded sales tax deduction for bad debts); multistate (reduced sales tax rates on food)

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 - Final regulations: Health insurance coverage limited to testing, diagnosis not “minimum essential coverage” (COVID-19)

Dec 12 - Rev. Proc. 2023-8: Automatic changes to accounting methods to comply with section 174

Dec 12 - Rev. Proc. 2022-42: Procedures for manufacturers and sellers of clean vehicles to qualify for tax incentives

Dec 12 - KPMG reports: California (franchise fees subject to sales and use tax); Louisiana (electric charging station subject to sales tax); Michigan (section 163(j) changes and unitary business group guidance); Missouri (drop shipments subject to sales tax, FAQs on economic nexus law)

Dec 9 - Proposed regulations: Single-entity treatment of consolidated groups for purposes of section 951(a)(2)(B) in context of section 959(b) distributions

Dec 9 - FBAR filings: Extended deadline is April 15, 2024, for individuals with signature authority

Dec 9 - New York State: Qualified emerging technology company determination does not apply at combined group level

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 8 - IRS announces mortality tables for defined benefit pension plans under Notice 2022-22 will apply in 2023

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 - Proposed regulations: Certain syndicated conservation easement transactions identified as listed transactions (text of regulations)

Dec 6 - KPMG report: EITF consensus to expand use of proportional amortization method

Dec 5 - KPMG reports: California (proposed guidance on marketplace sales); Florida (sourcing of receipts from sales of services); Ohio (sourcing of receipts from use of intellectual property); Tennessee (provision of nontaxable services versus taxable computer software)

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 29 - Notice 2022-61: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

Nov 29 - Rev. Rul. 2022-23: Interest rates, tax underpayments and overpayments (increase for first quarter 2023)

Nov 29 - U.S. Tax Court: 90-day time limit to file deficiency petition is jurisdictional deadline not subject to equitable tolling

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 21 - KPMG reports: Colorado (federal retroactive changes applied; includible corporation in unitary combined group); Wisconsin (unclaimed property voluntary disclosure program); Wyoming (roadside services not subject to excise tax)

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 15 - KPMG report: Comments on proposed regulations providing guidance on IRS Independent Office of Appeals

Nov 14 - Notice 2022-59: Self-insured health insurance annual fee

Nov 14 - KPMG report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation (updated)

Nov 14 - KPMG reports: Georgia (“safe rides fee” subject to sales and use tax); Wisconsin (guidance on taxation of NFTs); multistate (income tax changes approved on election day)

Nov 14 - Texas: Fair value analysis under satellite radio sourcing rules for franchise tax purposes (appeals court decision)

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 9 - U.S. Tax Court: Listing notice is legislative rule improperly issued under the Administrative Procedure Act

Nov 7 - Rev. Proc. 2022-40: Program for approving 403(b) retirement plans

Nov 7 - KPMG reports: Missouri (club membership dues subject to sales tax); Oregon (market-based sourcing); Wisconsin (manufacturing credit); multiple states (escheatment rules)

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 31 - KPMG reports: Pennsylvania (sourcing of digital audio book sales); South Carolina (fees subject to sales and use tax); Washington State (sourcing of patent procurement services income)

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 26 - DOJ will not seek U.S. Supreme Court review of case concerning crude oil tax imposed by section 4611(b)

Oct 25 - TTB announcement: Foreign alcohol producers may now register with online TTB system for 2023

Oct 24 - KPMG reports: Illinois (guidance on taxation of cryptocurrency); Maryland (digital advertising tax struck down); multiple states (tax rate changes on ballots)

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 - IRS reminder: Deadline to file 2019 and 2020 tax returns to get penalty relief postponed in declared disaster areas (COVID-19)

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 17 - KPMG reports: Mississippi (digital photography service); Tennessee (sales of subscriptions to electronic publications); Texas (web-based weather forecasting service); multiple states (nexus)

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 - Final regulations providing guidance under section 36B regarding premium tax credit, employer coverage for employee family members

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 10 - KPMG reports: Colorado (streaming platform credits); New York (nontaxable information services); Oregon (business license tax law); South Dakota (bank franchise tax)

Oct 7 - Final, temporary, and proposed regulations: Low-income housing credit average income test (text of regulations)

Oct 7 - Notice 2022-52: Extended temporary relief, low-income housing credit under section 42

Oct 7 - Notice 2022-53: Required minimum distributions

Oct 7 - Final regulations providing guidance under section 36B regarding premium tax credit; OIRA review completed

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

Oct 3 - KPMG reports: Colorado (retail delivery fee guidance); Iowa (corporate income tax rate reduction); Texas (R&D credit); West Virginia (tax preparer must collect sales tax)

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 30 - KPMG report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation

Sep 29 - Final regulations: Beneficial ownership information reporting

Sep 29 - California: Other state tax credit for resident owners of entities that elect PTET legislation enacted

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 - Notice 2022-45: Extension of time to amend certain eligible retirement plans for qualifying distributions (COVID-19)

Sep 26 - LB&I memo providing updated guidance on the statute of limitations with respect to section 965 examinations

Sep 26 - U.S. Tax Court: Excess loss account included in income of consolidated group member

Sep 26 - KPMG reports: Colorado (cryptocurrency as payment for taxes); Illinois (abatement of late penalties); Louisiana (manufacturing allocation formula)

Sep 23 - Notice 2022-38: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2022, final year for pre-BBA equipment

Sep 23 - TTB temporary and proposed regulations: Implementation of refund procedures for federal excise tax benefits applicable to imported alcohol

Sep 23 - KPMG report: Tax provisions in the “Inflation Reduction Act of 2022” relevant to the banking industry; potential implications

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 - IRS guidance on tax treatment of PPP loan forgiveness based on misrepresentations or omissions (COVID-19)

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 updates information on pre-screening and certification process of Work Opportunity Tax Credit (WOTC)

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 19 - KPMG reports: Missouri (sales and use tax manufacturing exemption); North Carolina (service contract subject to sales and use tax); Pennsylvania (sales and use tax collection by out-of-state sellers); South Carolina (bookstore membership fees subject to sales and use tax)

Sep 16 - California: Unclaimed property voluntary compliance program legislation enacted

Sep 16 - Notice 2022-42: Intent to amend noncompulsory payment regulations under section 901 with respect to amended Puerto Rico tax decrees

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 14 - Request for information: Advanced explanation of benefits and good faith estimate for covered individuals under “no surprises” provisions

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 12 - KPMG reports: Colorado (retail delivery fees exempt from Denver sales and use tax); Idaho (rate reductions); Illinois (subject to tax in foreign country); New Jersey (convenience of employer rule)

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 29 - KPMG reports: California (unclaimed property); District of Columbia (payroll factor); Michigan (nexus under Wayfair); Minnesota (sales and use taxation of NFTs); Oregon (Pub. L. No. 86-272); Texas (sales factor)

Aug 26 - California: Erroneously issued refunds of 2022 pass-through entity tax must be returned by taxpayers ASAP to secure elections

Aug 25 - U.S. Tax Court: Partnership’s payments to lender were deductible interest, and not payments on an equity interest

Aug 25 - Sixth Circuit: Tax Court decision affirmed, taxpayer not liable for 40% penalty upon cancellation of APAs

Aug 24 - Notice 2022-36: Penalty relief for certain taxpayers filing returns for tax years 2019 and 2020 (COVID-19)

Aug 24 - Final regulations: Requirements related to “surprise” medical billing

Aug 24 - Second Circuit: Early distribution 10% exaction is tax, not a penalty requiring written supervisory approval; Tax Court affirmed

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 15 - Rev. Rul. 2022-15: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2022)

Aug 15 - New York State: Passthrough entity tax implications for New York City businesses; revised draft regulations on sourcing of investment management services

Aug 15 - KPMG reports: Arkansas (corporate rate reduction accelerated); California (pending vote on full sales and use tax exemption for equipment); New Mexico (digital advertising services)

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 8 - KPMG reports: Alabama (related-party addback rules); Alaska (combined reporting, foreign entities); Colorado (retail delivery fee); Idaho (guidance under revised sourcing laws)

Aug 5 - D.C. Circuit: Partnership upheld as valid, despite IRS claims it never would have been profitable without refined-coal tax credits

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 4 - Fifth Circuit: Credit for renewable fuels reduces excise tax, but deduction limited to excise tax actually paid

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

Aug 1 - KPMG reports: Michigan (sales and use tax exemption, industrial processing); Texas (franchise tax credit, R&D activities)

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 - Eleventh Circuit: Taxpayer’s claim for reimbursement of “protest payments” denied, no statutory basis for refund

Jul 26 - IRS practice unit: Allowance of deductions and credits on Form 1120-F delinquent returns

Jul 25 - KPMG reports: New York (federal items reported on combined returns); Tennessee (sales and use taxes on marketplace facilitator)

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 18 - KPMG reports: Connecticut (investment tax credits); Delaware (unclaimed property laws); New Jersey (litter fee); Washington State (sales and B&O tax treatment of NFTs)

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 8 - PLR: IRS grants consent to taxpayer’s request regarding cost-sharing arrangement and intangible development costs

Jul 8 - Rev. Proc. 2022-32: Simplified method to obtain extension of time to make “portability” election with respect to decedent’s unused exclusion amount

Jul 7 - Rev. Rul. 2022-13: Multiemployer defined benefit plan receiving special financial assistance not deemed in “critical status” under section 432(b)(7) following merger

Jul 6 - IRS provides tax relief for taxpayers affected by storms in Montana and Oklahoma

Jul 5 - Proposed regulations: Foreign currency contract under section 1256 includes only foreign currency forward contracts (text of regulations)

Jul 1 - New York State: Appeals court holds vacation home is not permanent place of abode

June 2022

Jun 29 - Notice 2022-31: Defined benefit pension plans sponsored by newspapers, alternative minimum funding standards

Jun 28 - Rev. Proc. 2022-26: Procedures for requesting that substances be added or removed from Superfund list

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

Jun 27 - KPMG report: State, local tax changes (second quarter 2022, table format)

Jun 27 - KPMG reports: Iowa (sales and use tax changes); Oregon (certiorari denied in case concerning VoIP collection of E-911 tax); Washington State (Seattle payroll expense tax upheld, certiorari denied in case concerning B&O tax surcharge financial institutions)

Jun 24 - Proposed regulations: Administration expenses, claims against estates, interest expense on amounts owed by estates (text of regulations)

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 21 - Rev. Proc. 2022-28: No rulings to be issued regarding whether transactions result in employer reversion from qualified plan

Jun 21 - U.S. Supreme Court grants certiorari, whether penalty for FBAR violation applies on per-account or per-form basis

Jun 16 - Form 4419 relating to transmitter control codes for filing information returns electronically phased out beginning August 2022

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 15 - U.S. Tax Court: “Innocent spouse relief” not available as defense for trust fund recovery penalty liability

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 13 - KPMG reports: California (sale of S corporation stock); Pennsylvania (NFTs); Tennessee (sales tax holiday); Texas (electronic payment transactions); Wisconsin (sales of services)

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 6 - KPMG reports: Arkansas (leased vehicles); Massachusetts (apportioning sales and use tax); Vermont (corporate income tax); multiple states (nexus)

Jun 1 - KPMG report: Comments submitted to IRS regarding plans to update MAP and APA guidelines

Archives (2018 - 2023)

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.