General international tax guidance & other
General international tax guidance & other
KPMG reports
- Oct 5, 2020 - KPMG report: Final regulations on source of income for certain sales of personal property, including inventory
- Jul 12, 2019 - KPMG report: Proposed passive foreign investment company (PFIC) regulations; initial impressions and observations
- Dec 21, 2018 - KPMG report: Preliminary analysis and observations regarding certain international provisions in JCT Bluebook
- Oct 8, 2018 - KPMG report: Cross-border income inclusions (including GILTI) treated as REIT qualifying income
- Jul 17, 2018 - KPMG report: Transfer pricing in the age of tax reform
Final regulations
Oct 5, 2020 - KPMG report: Final regulations on source of income for certain sales of personal property, including inventory
Sep 29, 2020 - Final regulations: Source of income for certain sales of personal property, inventory (text of regulations)
Aug 8, 2020 - Regulations under section 954, coordinating rules under sections 245A and 951A; OIRA review completed
Jul 17, 2020 - Regulations pending OIRA review: Section 954, and coordinating rules under sections 245A and 951A
Proposed regulations
Aug 8, 2020 - Regulations under section 954, coordinating rules under sections 245A and 951A; OIRA review completed
Dec 23, 2019 - Proposed regulations: Source of income for certain sales of personal property, inventory (text of regulations)
Jul 17, 2020 - Regulations pending OIRA review: Section 954, and coordinating rules under sections 245A and 951A
Jul 12, 2019 - KPMG report: Proposed passive foreign investment company (PFIC) regulations; initial impressions and observations
Jul 10, 2019 - Proposed regulations: Passive foreign investment companies (PFICs) and PFIC insurance exception (text of regulations)
May 23, 2019 - Proposed regulations: Passive income exception for foreign insurance companies (OIRA review completed)
Apr 5, 2019 - Proposed regulations pending OIRA review: Passive income exception under section 1297 for foreign insurance companies
FAQs, forms, and other developments
Aug 1, 2019 - IRS practice unit: Source of income, nonresident alien individuals (reflecting U.S. tax legislative changes)
Jan 23, 2019 - IRS final forms, instructions: Implementing U.S. tax law changes
Jan 7, 2019 - IRS final forms, instructions for implementing U.S. tax law changes
Dec 13, 2018 - IRS releases Form 5471 and draft instructions for 2018