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.
Notice 2023-20: Interim guidance regarding certain insurance related issues under corporate alternative minimum tax (CAMT)
February 17, 2023
Intended to help avoid substantial unintended adverse consequences to the insurance industry
TaxNewsFlash No. 2023-059 (PDF)
IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program
February 13, 2023
IRS made significant changes to CAP program to improve its operation and promote best use of limited government resources
TaxNewsFlash No. 2023-055 (PDF)
IRS guidance on state tax refunds, general welfare and disaster relief payments
February 13, 2023
Federal tax status involving special payments made by 21 states in 2022
TaxNewsFlash No. 2023-051 (PDF)
Notice 2023-18: Guidance on qualifying advanced energy project credit under section 48C
February 13, 2023
Program to allocate credits for qualified investments in eligible qualifying advanced energy projects
TaxNewsFlash No. 2023-056 (PDF)
Proposed regulations pending OIRA review: Superfund chemical tax and Superfund imported substance tax
February 13, 2023
OMB’s Office of Information and Regulatory Affairs (OIRA) received for review proposed regulations
TaxNewsFlash No. 2023-052 (PDF)
Handbook: Accounting for income taxes
February 10, 2023
Designed to assist in an understanding of the application of ASC 740
Handbook: Accounting for Income Taxes (PDF)
The New section 174 mandatory capitalization regime: Implementation considerations for engineering and construction companies
February 8, 2023
A discussion of issues presented by the TCJA provision requiring mandatory capitalization of section 174 costs for taxpayers
The New section 174 mandatory capitalization regime: Implementation considerations for engineering and construction companies (PDF)
Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation (updated)
February 6, 2023
Updated to address IFRS considerations
TaxNewsFlash No. 2023-041 (PDF)
Notice 2023-16: Updated FAQs for clean vehicle credit under section 30D
February 3, 2023
IRS Notice 2023-16 modifies definitions of certain vehicle classifications under section 30D
TaxNewsFlash No. 2023-039 (PDF)
Accounting questions related to new GloBE rules
February 2, 2023
A KPMG report concerning accounting questions related to new GloBE rules
Accounting questions related to new GloBE rules
Summary and observations of tax provisions under SECURE Act 2.0
February 2, 2023
KPMG report on the more significant and broadly applicable changes
Summary and observations of tax provisions under SECURE Act 2.0 (PDF)
Year-in-review list of U.S. federal tax developments for 2022
January 31, 2023
KPMG LLP has compiled an easy-to-use list of many 2022 U.S. federal tax developments
2022: TaxNewsFlash Year in Review (PDF)
Third reinstated “superfund” tax adds complexity
January 25, 2023
Effective January 1, 2023, the Inflation Reduction Act1 modified section 4611 by reinstating the
Hazardous Substances Superfund tax (“Petroleum Superfund tax”), which had expired December 31, 1995.
Third Reinstated "Superfund" Tax Adds Complexity (PDF)
U.S. tax season starts January 23, 2023; most individual returns due April 18, 2023
January 12, 2023
The IRS today announced that the “tax season” for individual taxpayers will start January 23, 2023, at which time the IRS will begin accepting and processing individual income tax returns for 2022.
TaxNewsFlash No. 2023-013 (PDF)
Section 163(j) considerations on the disposition of partnership property and partnership interests
January 11, 2023
Transactions that involve the disposition of partnership property or partnership interests may trigger rules that limit business interest expense deductions.
TaxNewsFlash No. 2023-009 (PDF)
Initial observations on round 1 of CAMT guidance in Notice 2023-7
January 4, 2023
The Treasury Department and IRS on December 27, 2022, released an advance version of Notice 2023-7 [PDF 248 KB] (50 pages), providing taxpayers with interim guidance on the corporate alternative minimum tax (CAMT).
Initial observations on round 1 of CAMT guidance in Notice 2023-7 (PDF)
Analysis and observations on Rev. Procs. 2023-8 and 2023-11, guidance for accounting method changes under section 174
January 1, 2023
The IRS on December 12, 2022, released an advance copy of Rev. Proc. 2023-8 [PDF 133 KB] that provides accounting method change procedures applicable to companies required to capitalize and amortize specified research and experimental (R&E) expenses under section 174.
TaxNewsFlash No. 2023-001 (PDF)
Analysis and observations on initial guidance on new 1% stock repurchase excise tax
December 30, 2022
The U.S. Treasury Department and IRS on December 27, 2022, released an advance version of Notice 2023-2 [PDF 312 KB] (52 pages), providing taxpayers with interim guidance on the new 1% excise tax on repurchases of corporate stock under section 4501, created by Pub. L. No. 117-169 (commonly called the “Inflation Reduction Act of 2022” (IRA)), which takes effect January 1, 2023.
TaxNewsFlash No. 2022-416 (PDF)
Deadline for renewal of QI agreements covering 2023 through 2028
December 30, 2022
The IRS issued an alert providing the deadline for all qualified intermediaries (QIs) (including QIs acting as qualified derivatives dealers) to renew QI agreements covering years 2023 through 2028.
TaxNewsFlash No. 2022-413 (PDF)
Rev. Proc. 2023-11: Updated guidelines for accounting method changes for specified R&E expenditures
December 29, 2022
Updated guidelines for accounting method changes for specified research or experimental expenditures to comply with section 174
TaxNewsFlash No. 2022-412 (PDF)
Treasury releases white paper on critical mineral and battery component requirements for clean vehicle tax credits
December 29, 2022
Treasury announced various sources of additional information on clean vehicle provisions
TaxNewsFlash No. 2022-409 (PDF)
Notice 2023-3: Standard mileage rates for 2023
December 29, 2022
Notice 2023-3 provides standard mileage rates for taxpayers to use in computing deductible costs
TaxNewsFlash No. 2022-411 (PDF)
Notice 2023-7: Interim guidance on new corporate alternative minimum tax (CAMT)
December 27, 2022
IRS Notice 2023-7 provides taxpayers with interim guidance on the new corporate alternative minimum tax
TaxNewsFlash No. 2022-400 (PDF)
Treasury timeline for providing guidance on “Inflation Reduction Act” tax provisions
December 19, 2022
Before year’s end, Treasury will provide information on tax provisions of the “Inflation Reduction Act of 2022.”
TaxNewsFlash No. 2022-387 (PDF)
Recent developments in taxation of financial products
December 16, 2022
A KPMG report that discusses recent developments pertinent to taxation of financial products
Current Events Roundup: The New Stock Buyback Excise Tax, ILM 202224010, and Deitch v. Commisioner (PDF)
U.S. amendments to Export Administration Regulations (EAR) entity list (China and Japan)
December 15, 2022
Determined by the U.S. government to be acting contrary to the national security or foreign policy interests of the United States
U.S. amendments to Export Administration Regulations (EAR) entity list (China and Japan)
Rev. Proc. 2023-8: Automatic changes to accounting methods to comply with section 174
December 12, 2022
Procedures to obtain automatic consent to change methods of accounting for specified research or experimental expenditures to comply with section 174
TaxNewsFlash No. 2022-376 (PDF)
MAP and the exhaustion of remedies for FTC purposes
December 7, 2022
The role of mutual agreement procedure (MAP) requests in compulsory payment determinations under the foreign tax credit rules
MAP and the Exhaustion of Remedies for FTC Purposes (PDF)
Proposed foreign tax credit regulations
November 21, 2022
On November 18, 2022, the U.S. Treasury Department and IRS (collectively, “Treasury”) released proposed regulations [PDF 371 KB] (REG-112096-22) (“2022 Proposed Regulations”) that provide additional guidance relating to the foreign tax credit (“FTC”).
TaxNewsFlash No. 2022-355 (PDF)
For more information, please contact:
Tai Kimura | +1 408 367 2204 | tkimura@kpmg.com
The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser. This article represents the views of the authors only, and do not necessarily represent the views or professional advice of KPMG.