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: Proposed regulations on previously taxed earnings and profits (PTEP) of foreign corporations address longstanding issues under sections 959 and 961, incorporate changes from the “Tax Cuts and Jobs Act” (TCJA), and implement guidance from Notices 88-71 and 2019-01 regarding foreign currency gains or losses and PTEP account maintenance. Read TaxNewsFlash
- United States: Final regulations under section 752 concern partnership recourse liabilities and special rules for related persons, adopting and modifying proposed regulations from December 2013. These regulations, effective for liabilities incurred or assumed on or after December 2, 2024, allocate a partnership's liability to the partner directly bearing the economic risk of loss. Read TaxNewsFlash
- United States: Notice 2024-85 outlines a revised timeline for third-party settlement organizations (TPSOs) to meet new reporting thresholds under section 6050W(e), with reporting required for transactions exceeding $5,000 in 2024, $2,500 in 2025, and $600 from 2026 onward. The notice also provides transitional relief by not imposing penalties for failure to withhold and pay backup withholding tax in 2024, with penalties commencing in 2025, and mandates TPSOs that performed backup withholding in 2024 to file Forms 945 and 1099-K. Read TaxNewsFlash
- Germany: Effective January 1, 2025, transfer pricing documentation must be submitted within 30 days of a tax audit notification or upon request by the tax authority, compared to the previous 60-day timeframe and only during audits. Additionally, a new “transaction matrix” is now required as a key component of the documentation. Read TaxNewsFlash
- Australia: Legislation implementing a15% global minimum tax and domestic minimum tax on certain multinational enterprises (MNEs) with annual global revenue of at least €750 million passed the Senate. Read TaxNewsFlash