KPMG Week in Tax—published weekly to provide an overview of tax developments as reported in TaxNewsFlash—includes summaries of select tax-related news followed by a full list of reports (more information can be found at the links provided).
- United States: The U.S. Supreme Court affirmed a 2022 decision of the U.S. Court of Appeals for the Ninth Circuit upholding the constitutionality of the mandatory repatriation tax under section 965. Read TaxNewsFlash
- United States: Treasury and the IRS released three guidance documents—a notice, proposed regulations, and a revenue ruling—related to certain “basis-shifting” transactions involving partnerships and related parties. Read TaxNewsFlash
- United States: Final regulations provide guidance on the increased credit amounts or the increased deduction amount available for taxpayers satisfying prevailing wage and registered apprenticeship (PWA) requirements. Read TaxNewsFlash
- OECD: The OECD/G20 Inclusive Framework (IF) released further guidance on Amount B of Pillar One and the global minimum tax under Pillar Two. KPMG reports provide initial analysis and observations of the Pillar Two GloBE model rules (read TaxNewsFlash) and the Amount B simplified approach (read TaxNewsFlash).
Additional reports
United States
- U.S. Supreme Court: Mandatory repatriation tax under section 965 held constitutional
- Final regulations: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives
- Notice 2024-45: Clean hydrogen production credit under section 45V, inflation adjustment factors and applicable amounts for 2023 and 2024
- Notice 2024-55: Guidance on exceptions to 10% additional tax on early retirement plan distributions
- IRS releases revised draft Form 6765, Credit for Increasing Research Activities
- Treasury announces suspension, by mutual agreement, of the Russia income tax treaty
- Treasury and IRS release guidance on partnership “basis shifting” transactions
- IRS issues FAQs regarding educational assistance programs
- KPMG reports: California (tax measures in budget legislation); Rhode Island (single-sales factor apportionment); South Carolina (sales tax on installed materials)
Transfer Pricing
- OECD: Further guidance on Pillar One Amount B and Pillar Two global minimum tax
- KPMG report: Further guidance on Pillar Two GloBE model rules
- KPMG report: New Amount B guidance expands on definitions
- KPMG report: OECD unveils further details on Amount B simplified approach
- Luxembourg: Draft law amending Pillar Two law introduced to Parliament
Asia Pacific
- Australia: ATO clarifies “working from home” compliance guidance
- Australia: Housing and employment support bill passes parliament (Tasmania)
- Australia: Increased foreign property investor surcharges, land tax thresholds (New South Wales)
- Australia: Paid parental leave payments are not liable to payroll tax (Victoria)
- Australia: Tax measures in 2024 budget (New South Wales)
- India: General anti-avoidance rule may apply even if not within scope of specific anti-avoidance rule (High Court decision)
- Sri Lanka: New proposed tax measures following IMF review of “extended fund facility”
Europe
- Channel Islands: Super-deduction for regulatory compliance technology expenditures of financial services companies (Jersey)
- EU: EC concludes Germany’s special tax rules for public casino operators are illegal State aid
- EU: Toll manufacturer does not constitute a fixed establishment for VAT purposes (CJEU judgment)
- Germany: Ministry of Finance releases draft regulation for implementing e-invoicing mandate
- Poland: Draft legislation amending VAT for small enterprises
- Poland: Draft legislation amending real estate tax regime published
- Spain: Corporate and nonresident income tax forms for 2023
- UK: Reflection of withholding tax risk in pricing of securities transactions not treaty anti-avoidance (Upper Tribunal decision)
- UK: Tax statements of political parties ahead of general election 2024
Read TaxNewsFlash-Europe
FATCA / IGA / CRS
- Barbados: AEOI portal re-open for prior year submissions beginning 1 August 2024
- Japan: Updated CRS FAQs for automatic exchange of information process for nonresidents
Trade & Customs
- U.S. BIS imposes three-year export ban on U.S. package forwarding company for continued violations of EAR
Exempt Organizations
- IRS provides enhanced access to Form 990 series data
The items described above are also reported as editions of TaxNewsFlash:
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