In this section, we provide a summary of brief updates from the previous quarter on legislative, judicial, and administrative developments in tax that may impact Japanese companies operating in the United States.

Proposed regulations: Guidance relating to the foreign tax credit (text of regulations)

November 18, 2022

The U.S. Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-112096-22) relating to the foreign tax credit (FTC)

TaxNewsFlash No. 2022-350  (PDF)

International tax and transfer pricing ideas for year-end discussions

November 16, 2022

Conversations between taxpayers and their tax advisors for year-end planning purposes could include discussions about the key international tax and transfer pricing issues addressed in this article.

International Tax and Transfer Pricing Ideas for Year-End Discussions  (PDF)

KPMG report: Accounting for tax provisions in the "Inflation Reduction Act of 2022" and CHIPS legislation (updated)

November 14, 2022

H.R. 5376, commonly called the “Inflation Reduction Act of 2022” (IRA), and H.R. 4346, “The CHIPS and Science Act of 2022” (CHIPS), introduce new options for monetizing certain credits, a corporate alternative minimum tax, and a stock repurchase excise tax.

TaxNewsFlash No. 2022-341  (PDF)

KPMG report: Corporate alternative minimum tax considerations and FAQs

November 10, 2022

The IRA introduced a new Corporate Alternative Minimum Tax (CAMT)—a minimum tax based on financial statement income that applies to "applicable corporations"—effective for tax years beginning in 2023.

TaxNewsFlash No. 2022-339  (PDF)

Year-end tax topics for cryptocurrency investors

November 2, 2022

Now is the time for investors in cryptocurrencies to recognize approaching year-end considerations

and possible planning opportunities.

Year-end tax topics for cryptocurrency investors  (PDF)

"Superfund" tax refunds for exported chemicals and listed substances

October 19, 2022

Exporters of chemicals and chemical derivatives may be entitled to significant refunds of the

Superfund excise taxes, but only if the exported product is a “listed” taxable chemical or substance.

"Superfund" tax refunds for exported chemicals and listed substances (PDF)

IRS updates FAQs on QI/WP/WT website, certifications and periodic reviews

October 12, 2022

The IRS today updated the "frequently asked questions" (FAQs) on the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) FAQs website, under the heading "Certifications and Periodic Reviews."

TaxNewsFlash - 2022-313 (PDF)

KPMG report: Tax treatment of cryptocurrency and challenges of cross-border reporting

October 3, 2022

Bitcoin and other cryptocurrencies have come a long way from their exchanges on the Silk Road in the early 2000s.

TaxNewsFlash - 2022-297 (PDF)

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

September 30, 2022

H.R. 5376, commonly called the “Inflation Reduction Act of 2022” (IRA), and H.R. 4346, “The CHIPS and Science Act of 2022” (CHIPS), were recently signed into law by President Biden.

TaxNewsFlash - 2022-294 (PDF)

Notice 2022-44: Per diem rates, substantiation of employee lodging, meals, incidentals 2022-2023

September 26, 2022

Amount of ordinary and necessary business expenses incurred while traveling away from home

TaxNewsFlash - 2022-280 (PDF)

Tax provisions in the "Inflation Reduction Act of 2022" relevant to the banking industry; potential implications

September 23, 2022

Preliminary observations regarding certain tax provisions in the IRA that could be relevant to the banking industry

Tax provisions in the "Inflation Reduction Act of 2022" relevant to the banking industry; potential implications (PDF)

KPMG report: A primer on wash sale reporting in a volatile market (updated September 2022)

September 21, 2022

Market volatility can create opportunities for trad­ers but it can also be a source of angst. And this is true in the world of tax as in the wider world.

TaxNewsFlash 2022-273 (PDF)

California: Unclaimed property voluntary compliance program legislation enacted

September 16, 2022

California Assembly Bill 2280, which authorizes the California Controller to establish an unclaimed property voluntary compliance program (VCP), was signed into law on September 13, 2022.

TaxNewsFlash - 2022-263 (PDF)

Accounting for tax credits

September 14, 2022

There are many different types of tax credits available to entities, including several credits that have been created, modified, or extended as a result of recent federal legislation enacted in the United States.

Accounting for tax credits (PDF)

KPMG report: Foreign tax credit regulations; constructing a path forward

August 24, 2022

Recent changes in the foreign tax credit (FTC) regulations have introduced several possibly unintended consequences to the engineering and construction industry.

TaxNewsFlash 2022-246 (PDF)

For more information, please contact:

Tai Kimura | +1 408 367 2204 | tkimura@kpmg.com