United States

KPMG TaxNewsFlash reports of tax developments in the United States

February 2025
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KPMG report: Effective dates and early reliance requirements in proposed CAMT regulations

Advantages and disadvantages of early adoption of proposed regulations

February 26, 2025

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O’Donnell resigns as acting IRS Commissioner; Krause to serve until nominee is confirmed

Melanie Krause will become the acting IRS Commissioner following Doug O'Donnell's retirement.

February 26, 2025

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KPMG report: Partnership related-party basis adjustment transactions of interest

Reporting requirements imposed on both taxpayers and material advisors

February 26, 2025

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IRS provides tax relief for taxpayers affected by storms in Kentucky

Taxpayers in the entire state of Kentucky have until November 3, 2025, to file various federal tax returns and make payments.

February 25, 2025

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White House announces directive to counter digital service taxes (DSTs)

President Trump signed a memorandum to respond to the enactment by foreign governments of DSTs.

February 24, 2025

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White House memorandum on U.S. tax and trade policies focuses on China

Including review of whether to suspend or terminate 1984 U.S.-China income tax treaty

February 24, 2025

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U.S. Tax Court: U.S. parent company not allowed foreign tax credits under former section 902 and section 960

Non-U.S. partnership interposed between two tiers of non-U.S. corporations made no distributions and no income inclusion at U.S. parent company level

February 24, 2025

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Notice 2025-15: Guidance regarding health coverage reporting required by sections 6055 and 6056

Guidance regarding alternative manner of furnishing health coverage statements under sections 6055(c)(3) and 6056(c)(3)

February 21, 2025

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KPMG report: Accounting for income taxes considerations of the issuance of the section 987 final regulations

Overview of final regulations under section 987 and their impact on accounting for income taxes.

February 19, 2025

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Rev. Proc. 2025-15: Insurance companies, unpaid loss discount factors for 2024 accident year

For use in computing discounted unpaid losses under section 846 and discounted estimated salvage recoverable under section 832

February 13, 2025

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Trump signs executive orders reconfirming standing hiring freeze for IRS, requiring OIRA review of tax regulations

Executive orders aimed at reducing size of federal government’s workforce and regulatory burdens

February 12, 2025

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Rev. Proc. 2025-16: Automobile depreciation deduction limits for 2025

Section 280F limitations are required to be adjusted for inflation for automobiles placed in service after 2018

February 12, 2025

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KPMG report: Observations on the final Form 4626 Instructions for CAMT

Final Instructions for 2024 Form 4626, “Alternative Minimum Tax – Corporations”

February 12, 2025

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KPMG report: State and local tax changes affecting 2024 filing and payment obligations of entities taxed as partnerships

Summary of significant state and local tax changes affecting entities taxed as partnerships

February 6, 2025

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IRS practice units: Partnership liabilities, outside basis, and liquidating distributions; partial disposition of a building

Five LB&I practice units covering partnerships and deductible and capital expenditures

February 4, 2025

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KPMG report: Final regulations on clean hydrogen production credit and related energy credit

Initial observations and analysis on the final regulations

February 4, 2025

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KPMG article: Possible comeback of section 199 domestic production activities deduction (DPAD)

Possibility that Congress revives the former section 199 deduction, or a variation of it

February 3, 2025

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    January 2025
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    IRS practice units: Foreign tax credit categorization of income and taxes, carryback and carryover, sourcing of income

    Three “practice units” related to foreign tax credits

    January 29, 2025

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    Senate confirms Scott Bessent as Treasury Secretary

    U.S. Senate vote was 68-29

    January 28, 2025

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    California: Property tax relief due to wildfires

    Taxpayers generally must apply for reassessment within 12 months

    January 28, 2025

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    KPMG report: Employers providing employee assistance for victims of Los Angeles wildfires

    KPMG report reviews the options for employers, and some of the advantages and disadvantages of each.

    January 28, 2025

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    KPMG report: SEC comments on accounting for income taxes

    Examples of comments about accounting for income taxes recently issued by the U.S. Securities and Exchange Commission

    January 28, 2025

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    KPMG report: Initial observations on a second Trump presidency and the implications for U.S. infrastructure investment

    Presidential actions and orders that may have implications for infrastructure investment in the United States

    January 24, 2025

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    KPMG article: Debt workouts in commercial real estate

    Tax ramifications to borrowers looking to refinance properties

    January 22, 2025

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    White House announcement on OECD “Global Tax Deal”

    A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”

    January 21, 2025

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    Trump signs executive order placing hiring freeze for federal civilian employees with no expiration date for IRS

    Hiring freeze will remain in effect for IRS until lift determined to be in national interest

    January 21, 2025

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    Daniel Werfel resigns as IRS Commissioner, Trump formally nominates William Long to replace him

    The current Deputy Commissioner will serve as the Acting Commissioner until a nominee is confirmed.

    January 21, 2025

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    KPMG report: Regulations regarding digital content and cloud transactions

    Analysis and observations on the final and proposed regulations

    January 21, 2025

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    KPMG report: Proposed regulations on additional five highest compensated employees subject to section 162(m)

    The proposed regulations are proposed to apply for tax years beginning after the later of December 31, 2026, or the date of publication of the final regulations.

    January 21, 2025

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    Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations

    Legal advice memorandum from the Office of Chief Counsel

    January 21, 2025

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    Notices of filing of petitions for addition of cyanuric acid, potassium carbonate, potassium bicarbonate, and sodium chlorite to Superfund list

    Petitions have been filed by a single petitioner requesting that four substances be added to the list of taxable substances under section 4672(a)

    January 17, 2025

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    IRS updates FAQs for energy efficient home improvement and residential clean energy property credits

    Supersede earlier FAQs posted in April 2024

    January 17, 2025

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    Notice 2025-8: Updated elective safe harbor for domestic content bonus credit guidance amounts under sections 45, 45Y, 48, and 48E

    Modification to safe harbor provided in Notice 2024-41

    January 16, 2025

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    Rev. Rul. 2025-4: Guidance for states that have paid family and medical leave programs

    Includes transition relief for state paid medical leave benefits paid made during calendar year 2025

    January 16, 2025

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    KPMG report: Implications of Denham Capital Management LP v. Commissioner Tax Court Opinion

    Partners were more akin to employees than passive investors and all the partnership allocations at issue were subject to self-employment

    January 16, 2025

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    Notice 2025-9: Safe harbors regarding incremental cost and retail price equivalent of certain qualified commercial clean vehicles for purposes of section 45W credit

    Notice is effective on January 15, 2025

    January 15, 2025

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    Announcement 2025-6: Pilot program to test changes to alternative dispute resolution (ADR) programs

    IRS is requesting comments on the pilot changes

    January 15, 2025

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    Rev. Proc. 2025-14: List of qualifying technologies for clean electricity credits

    First annual table that provides greenhouse gas emissions rates for certain types or categories of facilities that are eligible for the clean electricity production

    January 15, 2025

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    KPMG article: Tax issues raised by development of valuable digital IP and data assets

    Including transfer pricing issues

    January 15, 2025

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    Michigan: Research and development credit law enacted

    New R&D tax credit effective for tax years beginning on or after January 1, 2025

    January 15, 2025

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    Final regulations: Guidance relating to IRS Independent Office of Appeals

    Final regulations provide that while Appeals resolution process is generally available to all taxpayers, there are certain exceptions.

    January 14, 2025

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    Proposed regulations: Limitation of deduction for certain employee remuneration under section 162(m)

    Proposed regulations implement amendments made to section 162(m) by American Rescue Plan Act of 2021

    January 14, 2025

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    Notice 2025-12: Indexing factor for use by group health plans and health insurance issuers in 2025 under “No Surprises Act” provisions

    Indexing factor used to calculate “qualifying payment amount”

    January 14, 2025

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    Rev. Proc. 2025-13: Streamlined procedure for taxpayers to revoke election to apply alternative tax for non-life insurance companies under section 831(b)

    Procedure provided in response to comments received on regulations identifying micro-captive listed transactions and micro-captive transactions of interest

    January 14, 2025

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    Reporting deadlines for certain partnership “basis shifting” transactions identified as transactions of interest

    Published version of the final rule provides reporting deadlines.

    January 14, 2025

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    Proposed regulations: Guidance on corporate separations, incorporations, and reorganizations qualifying for nonrecognition of gain or loss

    Including proposed regulations that would require multi-year tax reporting for corporate separations and related transactions

    January 13, 2025

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    Proposed regulations withdrawn: Amendments to coverage of certain preventive services under Affordable Care Act

    Notice of proposed rulemaking that appeared in the Federal Register on October 28, 2024, will be withdrawn.

    January 13, 2025

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    Final regulations: Guidance regarding certain disregarded payments and dual consolidated losses (DCLs)

    Rules from proposed regulations relating to disregarded payment losses (DPLs) finalized, additional transition relief for application of DCL rules to Pillar Two rules

    January 10, 2025

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    Final regulations: Certain partnership “basis shifting” transactions identified as transactions of interest

    Final regulations adopt proposed regulations issued in June 2024 with certain changes in response to comments received

    January 10, 2025

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    Final regulations: Micro-captive listed transactions and micro-captive transactions of interest

    Final regulations identify certain micro-captive transactions as reportable transactions

    January 10, 2025

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    Proposed regulations: Base erosion and anti-abuse tax (BEAT) rules for qualified derivative payments (QDPs) on securities lending transactions

    Guidance under section 59A BEAT rules regarding how QDPs in connection with securities lending transactions are determined and reported

    January 10, 2025

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    Proposed regulations: Guidance on section 45W credit for qualified commercial clean vehicles

    Proposed regulations providing guidance on the qualified commercial clean vehicle credit under section 45W

    January 10, 2025

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    Proposed regulations: Guidance on catch-up contributions to retirement plans

    Proposed regulations reflect statutory changes made by the “SECURE 2.0 Act of 2022”

    January 10, 2025

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    Proposed regulations: Automatic enrollment requirements under section 414A

    Guidance with respect to the automatic enrollment requirements that apply to certain retirement plans under section 414A

    January 10, 2025

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    Treasury and IRS release guidance on clean fuel production credit under section 45Z

    Guidance includes notice of intent to propose regulations and notice providing annual emissions rate table

    January 10, 2025

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    IRS provides tax relief for taxpayers affected by California wildfires

    Affected taxpayers have until October 15, 2025, to file various tax returns and make tax payments.

    January 10, 2025

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    Final and proposed regulations: Classification of digital content and cloud transactions for purposes of international provisions of the Code

    Comments requested under Notice 2025-6 on extending rules to all provisions of the Code

    January 10, 2025

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    Final regulations: Guidance under section 2801 regarding the imposition of tax on certain gifts and bequests from covered expatriates

    Apply to covered gifts and bequests received on or after January 1, 2025

    January 10, 2025

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    KPMG report: Analysis and observations on investment tax credit for energy property under section 48

    Rules for determining whether investments in energy property are eligible for the energy credit and for defining an energy project

    January 9, 2025

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    Final regulations and Rev. Proc. 2025-11: Guidance on environmental justice clean electricity capacity limitation program

    Program provides an increase to the new clean electricity investment tax credit rate available under section 48E

    January 8, 2025

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    Rev. Rul. 2025-3 and Rev. Proc. 2025-10: Guidance on definition of employee under section 530 of the Revenue Act of 1978

    Clarifications and modifications regarding the application of section 530 of the Revenue Act of 1978

    January 8, 2025

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    IRS announces extra day for taxpayers to file any returns, pay any tax due January 9

    Extra day granted because of Carter remembrance day

    January 8, 2025

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    National Taxpayer Advocate report to Congress identifying taxpayer problems

    Administrative and legislative recommendations to address problems

    January 8, 2025

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    KPMG report: Observations on amendments to section 52 regulations as part of amendments to consolidated return regulations

    Changes to the constructive ownership rules

    January 8, 2025

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    Final regulations: Clean electricity production and investment credits under sections 45Y and 48E

    Clean electricity production and clean electricity investment credits as established by the “Inflation Reduction Act of 2022”

    January 7, 2025

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    KPMG article: Commensurate with income standard in transfer pricing

    Evolution of the commensurate with income (CWI) standard, its current and prospective application, and its practical implications for taxpayers

    January 6, 2025

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    Final regulations: Clean hydrogen production credit and related energy credit

    Final regulations apply to tax years beginning after December 26, 2023

    January 3, 2025

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    IRS annual revenue procedures for 2025

    Six annual revenue procedures

    January 3, 2025

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    U.S. Treasury release: No change to list of countries cooperating with international boycott

    No new countries are added, and no countries are removed from the prior list.

    January 2, 2025

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      Latest tax developments from the United States and from KPMG member firms around the globe

      December 2024
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      Proposed regulations and Rev. Proc. 2025-9: Excise tax under section 5000D on designated drugs

      Proposed regulations adopt rules consistent with substantive rules described in Notice 2023-52

      December 31, 2024

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      Announcement 2025-5: Partial suspension by mutual agreement of income tax treaty with USSR as it relates to Belarus

      Suspension is effective December 17, 2024, until December 31, 2026

      December 31, 2024

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      Notice 2025-7: Temporary relief for making adequate identification of units of digital assets held in broker’s custody

      Allows reliance on alternative methods for making an adequate identification during the period beginning on January 1, 2025, and ending on December 31, 2025

      December 31, 2024

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      Final and proposed regulations: Amendments to consolidated return regulations to reflect statutory changes, modernize language, and enhance clarity

      Final and proposed consolidated return regulations

      December 27, 2024

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      Final regulations: Treatment of tax-exempt bonds as retired

      Final regulations address when tax-exempt bonds are treated as retired for purposes of sections 103 and 141 through 150

      December 27, 2024

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      Information reporting by non-custodial brokers of digital asset transactions

      Final regulations requiring information reporting by non-custodial digital asset brokers and transitional relief under Notice 2025-3

      December 27, 2024

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      Technical corrections to proposed regulations on corporate alternative minimum tax (CAMT)

      Comments on the proposed regulations are still being accepted until January 16, 2025.

      December 23, 2024

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      Proposed regulations withdrawn: Rescission of “moral exemption rule” to coverage of certain contraceptive services under Affordable Care Act

      The notice of proposed rulemaking that appeared in the Federal Register on February 2, 2023, is withdrawn.

      December 23, 2024

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      U.S. Tax Court: Active partners’ income subject to self-employment tax

      The court upheld the IRS's adjustments.

      December 23, 2024

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      Final regulations: Rules for supervisory approval of penalties

      Proposed regulations adopted with minor modifications

      December 20, 2024

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      Proposed regulations: Updated rules contained in Circular 230 for tax professionals who can practice before IRS

      The proposed regulations would incorporate new provisions that better align Circular 230 with the current practice environment.

      December 20, 2024

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      IRS contingency plan during possible government shutdown

      The IRS updates its contingency plan in anticipation of a possible government shutdown.

      December 20, 2024

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      IRS seeks feedback on draft Instructions for Form 6765, Credit for Increasing Research Activities

      The IRS is seeking feedback on the draft instructions until June 30, 2025.

      December 20, 2024

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      Rev. Proc. 2024-42: Updated list of jurisdictions for exchanging deposit interest information

      The IRS periodically issues guidance that updates and adds countries.

      December 20, 2024

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      Rev. Rul. 2025-2: Covered compensation tables for 2025 plan year

      The IRS provided tables of covered compensation under section 401(l)(5)(E) for the 2025 plan year.

      December 20, 2024

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      KPMG report: Determination under section 987 of taxable income or loss and foreign currency gain or loss with respect to a QBU

      Analysis and observations of final and proposed regulations

      December 19, 2024

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      KPMG report: Proposed PTEP regulations

      Analysis and observations

      December 19, 2024

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      KPMG report: Proposed adoption of Amount B in the United States

      Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.

      December 19, 2024

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      Source of gain under section 937 from certain dispositions of stock (IRS Chief Counsel memorandum)

      Memorandum addresses source of gain from certain sales of stock by U.S. citizen who becomes resident of Puerto Rico

      December 19, 2024

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      Notice 2025-5: Standard mileage rates for 2025

      Standard mileage rates for taxpayers to use in computing the deductible costs of operating an automobile for business, charitable, medical, or moving purposes

      December 19, 2024

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      Notice 2025-4: Application of Pillar One Amount B simplified and streamlined approach

      Treasury and IRS announce intention to issue proposed regulations applicable to tax years beginning on or after January 1, 2025.

      December 18, 2024

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      Announcement 2025-2: Certain portions of proposed regulations on required minimum distributions under section 401(a)(9) will not apply until 2026

      Proposed regulations were generally proposed to apply beginning 2025

      December 18, 2024

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      Rev. Proc. 2025-8: Expanded waiver of eligibility rules to accounting method changes to comply with section 174

      The revenue procedure is generally effective for Forms 3115 filed on or after December 17, 2024.

      December 17, 2024

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      Final regulations: Definition of the term “coverage month” for computing premium tax credit

      The final regulations apply to tax years beginning on or after January 1, 2025.

      December 17, 2024

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      IRS announces tax relief for taxpayers in West Virginia affected by Post-Tropical Storm Helene

      Various deadlines postponed to May 1, 2025

      December 17, 2024

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      Washington State: Insurance company affiliate qualifies for insurance business B&O tax exemption (Supreme Court decision)

      Affiliate qualifies for exemption on income earned from providing services to insurance company

      December 17, 2024

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      Notice 2025-2: Penalty relief for partnerships to provide complete Forms 8308 for section 751(a) exchanges

      The IRS will not impose penalties for failing to furnish a completed Part IV of Form 8308 by the due date, provided that the partnership meets specific conditions.

      December 13, 2024

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      IRS provides new tax penalty relief for Maui wildfire victims

      Relief is separate from disaster relief announced in August 2023

      December 12, 2024

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      Louisiana: Several tax bills approved

      Bills present significant reform of state tax structure.

      December 12, 2024

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      U.S. Tax Court: Taxpayer entitled to section 199 deductions

      Tax Court held that taxpayer qualified for section 199 deductions, but found the taxpayer’s allocation of gross receipts and related expenses unreasonable.

      December 11, 2024

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      Final and proposed regulations: Taxable income or loss and foreign currency gain or loss with respect to a QBU

      Final and proposed regulations under section 987

      December 10, 2024

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      Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies

      Competent authorities agree that Article 20 (investment or holding companies) is not applicable to regulated investment companies

      December 9, 2024

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      KPMG report: Implications of designations of Bourse de Montreal and European Energy Exchange as “qualified boards of exchange”

      The designations will cause certain contracts traded through these exchanges to be treated as section 1256 contracts.

      December 9, 2024

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      IRS practice unit: Examining a reseller’s 263A computation

      IRS Large Business and International division publicly released a “practice unit”

      December 6, 2024

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      Notice 2024-82: Required amendments list (2024) for qualified retirement plans and 403(b) plans

      List of changes to qualification requirements with which a plan must comply

      December 5, 2024

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      Trump to nominate Scott Bessent as Treasury Secretary, Billy Long as IRS Commissioner

      President-elect Donald Trump announced nominations for Treasury Secretary and IRS Commissioner

      December 5, 2024

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      Final regulations: Definition of energy property and rules applicable to energy credit under section 48

      Final regulations adopt proposed regulations issued in November 2023

      December 4, 2024

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      Comment period extended for proposed regulations on corporate alternative minimum tax (CAMT)

      Comment period extended from December 12, 2024, to January 16, 2025

      December 3, 2024

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      Proposed regulations: Unmarked vehicles used by emergency responders treated as qualified nonpersonal use vehicles under sections 274 and 280F

      Rules would allow such vehicles to be excepted from the substantiation requirements for deductibility of related expenses

      December 2, 2024

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        State and Local Tax

        November 2024
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        Proposed regulations: Previously taxed earnings and profits and related basis adjustments

        Rules would address longstanding issues under sections 959 and 961

        November 29, 2024

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        Final regulations: Recourse partnership liabilities and related party rules under section 752

        Final rules adopt proposed regulations issued in December 2013

        November 29, 2024

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        Notices of filing of petitions for addition of di-isobutyl carbinol, di-isobutyl ketone, and methyl isobutyl carbinol to Superfund list

        Petitions have been filed requesting that three substances made from propylene be added to the list of taxable substances under section 4672(a)

        November 27, 2024

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        Announcement 2024-40: Treatment of amounts paid under agreements with Commerce Department for purposes of section 48D advance manufacturing investment credit

        Such amounts will not fail to constitute a “qualified investment” provided requirements of section 48D are otherwise satisfied

        November 26, 2024

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        Notice 2024-85: Form 1099-K transition relief for calendar year 2024 and 2025 transactions

        Form 1099-K threshold is $5,000 for calendar year 2024 and $2500 for calendar year 2025

        November 26, 2024

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        Final regulations: Disclosure of specified return information to Bureau of the Census for statistical purposes

        Final rules adopt proposed regulations with minor changes

        November 25, 2024

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        Tier 2 tax rates for railroads, no changes for 2025

        Imposed on railroad employees, employers, and employee representatives

        November 25, 2024

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        IRS practice units: Producer’s section 263A computation and LIFO pooling requirements

        IRS Large Business and International division released two updated “practice units”

        November 25, 2024

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        Notice 2024-84: Extension of transitional process for applicable entities to claim statutory exceptions to phaseouts for clean energy credits if domestic content requirements not met

        Application of phaseouts for credits determined under sections 45 (renewable electricity production), 45Y (clean electricity production), 48 (energy), and 48E (clean electricity investment)

        November 22, 2024

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        Announcement 2024-38: Updates on second remedial amendment cycle for section 403(b) pre-approved plans

        The IRS intends to issue opinion letters for section 403(b) pre-approved plans that were updated for changes.

        November 22, 2024

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        IRS provides tax relief to taxpayers in the Crow Tribe of Montana affected by severe storms and straight-line winds

        Various deadlines postponed to February 3, 2025

        November 21, 2024

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        FBAR filings: Extended deadline is April 15, 2026, for individuals with signature authority

        For all other U.S. individuals with an FBAR filing obligation, the filing due date remains April 15, 2025.

        November 20, 2024

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        IRS practice unit: Land developers and subcontractors—proper method of accounting

        IRS Large Business and International division publicly released a “practice unit”

        November 20, 2024

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        Final and proposed regulations: Access to clean energy tax credits for co-owned projects through elective pay (“direct pay”)

        Allows certain unincorporated organizations to opt out of partnership tax rules, facilitating the use of clean energy tax credits

        November 19, 2024

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        U.S. Treasury to allocate $10 billion in New Markets Tax Credit (NMTC) authority for 2024 and 2025

        Encourages private sector investment in distressed communities

        November 19, 2024

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        U.S. Tax Court: IRS does not have statutory authority to assess penalties for willful failure to file Form 5471

        U.S. Tax Court reaffirmed its original decision

        November 18, 2024

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        Rev. Rul. 2024-25: Interest rates, tax underpayments and overpayments decrease for first quarter 2025

        Interest rates for the calendar quarter beginning January 1, 2025

        November 18, 2024

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        KPMG report: Notable highlights from section 48D final regulations (advanced manufacturing investment credit)

        KPMG observations and analysis of the final regulations

        November 14, 2024

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        KPMG report: Final regulations on advanced manufacturing production credit under section 45X

        KPMG observations and analysis of the final regulations

        November 14, 2024

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        IRS announces tax relief for taxpayers affected by storms and flooding in Chaves County, New Mexico

        Various deadlines postponed to May 1, 2025

        November 13, 2024

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        IRS provides tax relief for taxpayers in Cheyenne River Sioux Tribe in South Dakota affected by storms

        Various deadlines postponed to February 3, 2025

        November 13, 2024

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        Deductibility of FDIC special assessments not limited under section 162(r)

        IRS Chief Counsel memorandum

        November 12, 2024

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        IRS announces tax relief for taxpayers in Saint Regis Mohawk Tribe in New York affected by storms and flooding

        Various deadlines postponed to February 3, 2025

        November 12, 2024

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        KPMG article: IRS’s personal use of business aircraft campaign

        IRS plans to begin auditing the personal use of business aircraft with its business aircraft campaign

        November 11, 2024

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        Extension of certain timeframes for employee benefit plans and participants affected by Hurricane Helene, Tropical Storm Helene, or Hurricane Milton

        Extension generally suspends until May 1, 2025, the tolling of various periods and dates under ERISA and the Code applicable to employee benefit plans and their participants

        November 7, 2024

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        IRS grants tax relief for taxpayers in Havasupai Tribe in Arizona affected by flooding

        Deadlines extended to February 3, 2025

        November 7, 2024

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        KPMG report: Election results, preliminary observations regarding effect on future tax agenda

        Preliminary observations regarding effect of yesterday’s election results on future tax agenda

        November 6, 2024

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        KPMG article: Tax Court’s application of strict construction rule in interpreting Treasury regulations

        The Tax Court applied the strict construction rule to decide in the taxpayer’s favor.

        November 5, 2024

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        KPMG article: Subchapter K changes as possible revenue raisers in addressing 2025 “Tax Cliff”

        Changes affecting the taxation of partnerships may be considered by lawmakers.

        November 4, 2024

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        Notice 2024-80: Pension plans, cost-of-living adjustments for 2025

        Amount individuals can contribute to their 401(k) plans in 2025 has increased to $23,500, up from $23,000 for 2024.

        November 1, 2024

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          Archived reports

          Tax law changes in the "Inflation Reduction Act"

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          KPMG reports (2018-2024)

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          October 2024
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          U.S. Tax Court: Loss under section 1256(c) on foreign currency option transaction disallowed under section 165(c) for lack of profit motive

          Tax Court agreed with IRS that the taxpayers did not establish any profit motive for entering into the foreign currency option transactions

          October 31, 2024

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          U.S. Tax Court: Basis in partnership interest must be decreased by losses deducted in prior closed tax years

          Tax Court agreed with IRS that taxpayer must decrease its basis in partnership for previously deducted passthrough losses

          October 30, 2024

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          IRS practice unit: Section 250 deduction—foreign-derived intangible income (FDII)

          Updated to remove references to resources that are no longer available

          October 30, 2024

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          U.S. Treasury announces the beginning of negotiation of a tax agreement with Taiwan

          United States and Taiwan will begin negotiations on a comprehensive agreement to address double taxation issues.

          October 29, 2024

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          Notice 2024-78: Extension of temporary relief for foreign financial institutions required to report U.S. TINs

          Notice 2024-78 extends the temporary relief provided in Notice 2023-11

          October 28, 2024

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          IRS provides tax relief to taxpayers affected by floods in Juneau, Alaska

          Deadlines extended to May 1, 2025

          October 25, 2024

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          Final regulations: Guidance on advanced manufacturing production credit under section 45X

          The final regulations retain the same basic structure as proposed regulations issued in December 2023, with certain revisions.

          October 24, 2024

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          Proposed regulations and Rev. Proc. 2024-31: Guidance on energy efficient home improvement credit under section 25C

          General guidance on the section 25C credit, including what property qualifies and rules for manufacturers to register to be qualified manufacturers

          October 24, 2024

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          Proposed regulations: Amendments to coverage of certain preventive services under Affordable Care Act

          Proposed rules would enhance coverage of preventive services, including contraceptive items.

          October 23, 2024

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          Treasury, IRS grant tax-exempt organizations exception from filing CAMT form for 2023

          Exception from filing Form 4626 for tax year 2023

          October 23, 2024

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          United States: IRS issuing manual IDES notifications through October 31

          Delayed distribution due to recent hurricanes

          October 23, 2024

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          Final regulations: Advanced manufacturing investment credit rules under sections 48D and 50

          The final regulations adopt with certain modifications proposed regulations issued in March 2023.

          October 22, 2024

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          Rev. Proc. 2024-40: Inflation adjustments for 2025, individual taxpayers

          Amounts to be used by individual taxpayers on their 2025 returns

          October 22, 2024

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          KPMG reports: California (bad debt deductions for sales and use tax purposes); Ohio (debit authorization services not subject to sales tax); Washington State (B&O apportionable services reconciliation)

          KPMG This Week in State Tax focuses on recent state and local tax developments.

          October 21, 2024

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          Notice 2024-74: Additional guidance on safe harbors for sustainable aviation fuel credit

          Guidance applies as of October 18, 2024.

          October 18, 2024

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          Final regulations: Withholding under sections 3405(a) and (b) on certain payments and distributions from retirement plans

          The final regulations adopt proposed regulations issued in May 2019 with no substantive modifications except a changed applicability date.

          October 18, 2024

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          Notices related to treatment of amounts paid for contraceptives under health savings accounts and high deductible health plans

          Expenditures for breast cancer screenings, glucose monitors, and certain insulin products also addressed

          October 17, 2024

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          Delaware: Changes to unclaimed property law

          Many immediate and some retroactive changes

          October 16, 2024

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          Notice 2024-77: Guidance under sections 414(aa) and 402(c)(12) regarding correction of inadvertent benefit overpayments

          Comments on the guidance are due by December 16, 2024.

          October 15, 2024

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          KPMG reports: South Dakota (use tax on construction equipment); Virginia (disregarded entity not subject to BPOL tax); multistate (tax-related ballot measures, manufacturing sales and use tax exemption rulings)

          KPMG This Week in State Tax focuses on recent state and local tax developments.

          October 15, 2024

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          Section 250 deduction subject to limitation under each of section 250(a)(2), 246(b)(3)(A), and 246(b)(3)(B)

          IRS Chief Counsel memorandum

          October 11, 2024

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          IRS provides tax relief for taxpayers of San Carlos Apache Tribe in Arizona affected by Watch Fire

          Affected taxpayers have until February 3, 2025, to file various tax returns and make tax payments.

          October 11, 2024

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          IRS provides tax relief for taxpayers in Florida affected by Hurricane Milton

          Tax relief until May 1, 2025, for individuals and businesses in Florida affected by Hurricane Milton

          October 11, 2024

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          IRS announces dyed diesel penalty relief in Florida due to Hurricane Milton

          The relief begins on October 9, 2024, and will remain in effect through October 30, 2024.

          October 11, 2024

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          Final regulations: Section 367(d) rules for certain repatriations of intangible property

          The final regulations adopt proposed regulations issued in May 2023 with certain revisions.

          October 9, 2024

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          KPMG article: New York City corporate tax regulations may deviate from state regulations

          An article that discusses how the City’s update on how it may deviate from the state’s corporate tax regulations may simplify sourcing determinations for corporate taxpayers.

          October 9, 2024

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          Final regulations: Certain syndicated conservation easement transactions identified as listed transactions

          The final regulations adopt proposed regulations published in December 2022 with certain revisions.

          October 7, 2024

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          Proposed regulations: Federal tax classification of entities wholly owned by Indian Tribal governments

          Entities wholly owned by Indian Tribal governments generally would not recognized as separate entities

          October 7, 2024

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          KPMG reports: California (sales tax agreement reports); Nevada (voluntary disclosure agreement program); New York (sales tax on electronic currency trading, web-based document processing)

          KPMG This Week in State Tax focuses on recent state and local tax developments.

          October 7, 2024

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          KPMG report: Analysis and observations on the proposed CAMT regulations

          A report that summarizes a number of key issues from the proposed regulations and provides observations.

          October 4, 2024

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          KPMG report: Exceptions under final broker digital asset reporting regulations

          Closed loop transactions and limited access regulated networks

          October 4, 2024

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          IRS Priority Guidance Plan for 2024-2025

          The U.S. Treasury Department and IRS released the 2024-2025 Priority Guidance Plan.

          October 4, 2024

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          United States: IRS issues list of qualified intermediary (QI) entities and branches

          QIs need to review the list and update any inaccurate information.

          October 4, 2024

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          Notice 2024-73: Guidance on long-term, part-time employees in 403(b) retirement plans

          Comments requested on or before December 20, 2024

          October 3, 2024

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          IRS provides tax relief for taxpayers in parts of Washington State affected by wildfires

          Affected taxpayers have until February 3, 2025, to file various tax returns and make tax payments.

          October 3, 2024

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          KPMG article: Tax incentives under IRA, CHIPS Act, and U.S. FTZ Program

          Such incentives may result in significant benefits to qualifying companies

          October 3, 2024

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          Rev. Rul. 2024-23: European Energy Exchange held “qualified board or exchange”

          The revenue ruling is effective for European Energy Exchange contracts entered into on or after November 1, 2024.

          October 2, 2024

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          Treasury statement on implementation of IRA’s clean energy provisions

          Progress to date, and future plans, for implementation of the clean energy provisions of the “Inflation Reduction Act”

          October 2, 2024

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          KPMG article: State income tax consequences of green energy tax credit sales

          Some states may not conform to the rules allowing taxpayers to monetize green energy tax credits, potentially creating surprising state income tax liabilities.

          October 2, 2024

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          IRS provides tax relief for taxpayers in all or parts of seven states affected by Hurricane Helene

          Tax relief for individuals and businesses in all of Alabama, Georgia, North Carolina, and South Carolina, and parts of Florida, Tennessee, and Virginia, affected by Hurricane Helene

          October 1, 2024

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          IRS provides dyed diesel penalty relief due to Hurricane Helene

          The relief is retroactive from September 26, 2024, and will last until October 15, 2024.

          October 1, 2024

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          Notice 2024-72: IRS provides new relief for taxpayers affected by terroristic action in Israel

          New relief for persons that the Secretary of the Treasury has determined to be affected by the terroristic action in the State of Israel.

          October 1, 2024

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          IRS provides tax relief for taxpayers in parts of Illinois affected by severe storms, tornadoes

          Tax relief for individuals and businesses in parts of Illinois affected by severe storms, tornadoes, straight-line winds, and flooding that began on July 13, 2024.

          October 1, 2024

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            September 2024
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            IRS requests comments on draft Form 7217, Partners Report of Property Distributed by a Partnership

            The purpose of Form 7217 is to report all distribution of property that a partner receives from a partnership.

            September 30, 2024

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            U.S. Treasury release: No change to list of countries cooperating with international boycott

            No new countries are added, and no countries are removed from the prior list.

            September 30, 2024

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            KPMG reports: California (manufacturing equipment tax credit vetoed); Massachusetts (tax amnesty); Oregon (sales factor treatment of repatriation income); Washington State (taxable digital automated services)

            Recent state and local tax developments

            September 30, 2024

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            Rev. Rul. 2024-22: Bourse de Montreal held “qualified board or exchange”

            The revenue ruling is effective for Bourse de Montréal contracts entered into on or after November 1, 2024.

            September 26, 2024

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            IRS announces new process for third-party payers to resolve incorrect employee retention credit claims

            Third-party payers must submit a supplemental claim by November 22, 2024.

            September 26, 2024

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            United States: IRS announces manual IDES confirmations will be sent by October 15

            Additional updates on IRS public key and configuring SFTP connection

            September 26, 2024

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            KPMG report: U.S. transfer pricing and international tax year-end considerations

            A report that includes key year-end transfer pricing and international tax issues.

            September 25, 2024

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            Rev. Proc. 2024-38: Guidance on income requirements for residential rental projects financed with exempt bonds and low-income housing projects

            Guidance on the effect on the income requirements under section 142(d) and section 42 of the alternative income eligibility requirements

            September 25, 2024

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            Application period for 2024 environmental justice solar and wind capacity limitation program closing soon

            Application period will close for most low-income community projects on October 10, and for projects located on Indian Lands on November 12.

            September 24, 2024

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            KPMG reports: California (sourcing rules for professional services); New York (NYC business corporation tax); Texas (sales and use tax on data process services)

            KPMG This Week in State Tax focuses on recent state and local tax developments.

            September 23, 2024

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            KPMG report: State, local tax changes (third quarter 2024, table format)

            Summary of state and local tax developments for the third quarter of 2024

            September 23, 2024

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            Notice 2024-68: Per diem rates, substantiation of employee lodging, meals, incidentals (2024-2025)

            Special per diem rates for taxpayers to use in substantiating the amount of ordinary and necessary business expenses incurred while traveling

            September 20, 2024

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            U.S. Treasury awards $5 billion in New Markets Tax Credit (NMTC) allocations

            NMTC awards made to 104 community development entities made through the calendar year 2023 round

            September 19, 2024

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            KPMG report: Draft instructions for Form 1099-DA, Digital Asset Proceeds from Broker Transactions

            Overview of draft instructions as they relate to the final U.S. broker digital asset reporting regulations

            September 19, 2024

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            KPMG report: Treatment of nonfungible tokens under the final broker reporting regulations

            Overview of NFTs in final regulations

            September 19, 2024

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            Proposed regulations and Notice 2024-64: Guidance on qualified alternative fuel vehicle refueling property credit under section 30C

            Property placed in service in eligible census tracts, which include low-income communities and non-urban census tracts

            September 18, 2024

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            U.S. Tax Court: Commutation of marital trust results in gifts to surviving spouse of remainder interests in trust

            Commutation of a QTIP marital trust to other trusts for the benefit of children in exchange for promissory notes payable to the surviving spouse

            September 18, 2024

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            U.S. House Republican leadership, Ways and Means members express opposition to Pillar Two deal in letter to OECD

            Sent a letter to the OECD Secretary-General expressing their opposition

            September 18, 2024

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            Rev. Proc. 2024-37: Guidance on filing claims for recovery of overpayments related to tax-exempt and other tax-advantaged bonds

            Claims must be filed using Form 8038-R

            September 18, 2024

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            IRS provides tax relief for taxpayers in Pennsylvania affected by Tropical Storm Debby

            Taxpayers now have until February 3, 2025, to file various individual and business tax returns and make tax payments.

            September 18, 2024

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            KPMG article: Understanding and navigating requirements of the corporate alternative minimum tax (CAMT) and proposed regulations

            Taxpayers and tax professionals alike are still struggling with both the idea that it might affect them and how to deal with the innumerable requirements of the new regime.

            September 17, 2024

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            KPMG report: Initial observations on proposed CAMT regulations

            Proposed regulation package created a host of questions for taxpayers and tax practitioners

            September 16, 2024

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            Final regulations: Consistent basis reporting between estate and person acquiring property from decedent

            Guidance on the statutory requirement for a recipient’s basis in certain property acquired from a decedent

            September 16, 2024

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            Proposed regulations: Definition of the term “coverage month” for computing premium tax credit

            Would revise certain rules related to the computation of an individual taxpayer’s premium tax credit

            September 16, 2024

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            KPMG reports: California (potential gross receipts tax changes in San Francisco); California (credit for taxes paid to another state); Washington State (digital ad exchange subject to B&O tax)

            KPMG This Week in State Tax focuses on recent state and local tax developments.

            September 16, 2024

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            Final regulations: Requirements related to the Mental Health Parity and Addiction Equity Act

            Implements the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA)

            September 13, 2024

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            Proposed regulations: Exclusion from gross income under section 139E of Tribal general welfare benefits

            Requirements for benefits that an Indian Tribal government program provides to qualify as Tribal general welfare benefits

            September 13, 2024

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            IRS provides tax relief for taxpayers in entire state of Louisiana affected by Tropical Storm Francine

            Affected taxpayers have until February 3, 2025, to file various individual and business tax returns and make tax payments.

            September 13, 2024

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            United States: IRS issues new FAQ regarding credit forward framework described in Notice 2010-46

            Provides clarification on the availability of the credit forward framework

            September 13, 2024

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            Proposed regulations: Guidance on corporate alternative minimum tax (CAMT) confers exceptionally complex regime

            Key highlights of the proposed regulations

            September 12, 2024

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            Notice 2024-66: Additional limited relief from underpayment of estimated tax attributable to CAMT liability

            Extends relief provided in Notice 2024-33 and Notice 2024-47

            September 12, 2024

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            United States: IRS delaying manual email notifications for FATCA IDES transmissions

            Due to system error, manual IDES confirmations will be sent during second week of September

            September 12, 2024

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            IRS provides tax relief for taxpayers affected by severe storms, flooding in Connecticut and New York

            Tax relief for individuals and businesses in Connecticut and New York affected by severe storms and flooding that began on August 18, 2024.

            September 10, 2024

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            CFC not entitled to section 245A dividends received deduction (IRS Chief Counsel memorandum)

            The IRS concluded in Office of Chief Counsel memorandum that a controlled foreign corporation is not entitled to a dividends received deduction under section 245A.

            September 9, 2024

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            Fourth quarter update to IRS 2023-2024 Priority Guidance Plan

            The U.S. Treasury Department and IRS released the fourth quarter update to the 2023-2024 Priority Guidance Plan.

            September 9, 2024

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            KPMG reports: California (sales and use tax); Massachusetts (research credit); Nebraska (dividends received deduction); Virginia (manufacturing exemption); multistate (sales and use tax on leased property)

            KPMG reports focus on recent state and local tax developments

            September 9, 2024

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            Notice 2024-65: Comments requested regarding saver’s match contributions under section 6433

            U.S. Treasury Department and IRS released Notice 2024-65 requesting comments on all aspects of saver’s match contributions.

            September 6, 2024

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            Rev. Proc. 2024-35: Premium tax credit percentage table for 2025

            Rev. Proc. 2024-35 provides the applicable percentage table used to calculate an individual’s premium tax credit under section 36B for tax years beginning in calendar year 2025.

            September 6, 2024

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            KPMG report: Tax provisions expiring in 2025 affecting individuals and families

            A KPMG report outlining the many provisions that are set to expire that will have a particular impact on individual taxpayers.

            September 4, 2024

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            Comment period reopened for proposed regulations on payment of tax by commercially acceptable means

            An update to proposed regulations regarding the payment of tax by commercially acceptable means that reopens the period to submit comments or request a public hearing

            September 4, 2024

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            Correction to proposed regulations on elections relating to foreign currency gains and losses

            A correction to proposed regulations regarding the time for making and revoking certain elections relating to foreign currency gain or loss

            September 3, 2024

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            United States: IRS requests certain FATCA IDES users to retransmit files

            IRS requests certain FATCA International Data Exchange Services users to inform the IRS if they are still not receiving the system alerts and notifications properly.

            September 3, 2024

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              August 2024
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              Notices of filing of petitions for addition of seven glycol ethers to Superfund list

              Petitions have been filed requesting that seven glycol ethers be added to the list of taxable substances under section 4672(a)

              August 30, 2024

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              Proposed regulations: Guidance on environmental justice clean electricity capacity limitation program

              Program provides an increase to the new clean electricity investment tax credit rate available under section 48E

              August 30, 2024

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              Rev. Proc. 2024-34: Expanded waiver of eligibility rules to accounting method changes to address short tax years

              Obtaining automatic consent to change accounting methods for expenditures paid or incurred in tax years starting after December 31, 2021

              August 29, 2024

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              Full applications for qualifying advanced energy project tax credit due by October 18

              Applicants who submitted a concept paper can now submit full applications on the 48C portal.

              August 29, 2024

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              IRS provides tax relief for taxpayers throughout U.S. Virgin Islands affected by Tropical Storm Ernesto

              Tax relief for individuals and businesses throughout the U.S. Virgin Islands affected by Tropical Storm Ernesto.

              August 28, 2024

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              KPMG reports: Delaware (notices requesting “verified reports” of unclaimed property); Tennessee (sales and use tax); multistate (property tax relief)

              KPMG reports focus on recent state and local tax developments

              August 26, 2024

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              KPMG report: Allocation of payments in context of distressed debt satisfaction

              Why the payment ordering rules are best interpreted as inapplicable to a distressed debt satisfaction

              August 26, 2024

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              U.S. Tax Court: Taxpayer entitled to dividends received deduction under section 245A, but not foreign tax credits, on amounts treated as dividends under section 78

              U.S. Tax Court case concerning dividends received deduction under section 245A

              August 26, 2024

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              USTR request for comments on WTO dispute initiated by China over IRA tax credits

              China has requested a WTO dispute settlement panel, alleging that certain clean energy tax credits violate WTO agreements

              August 26, 2024

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              Corporations subject to CAMT must file Form 2220 to qualify for estimated tax penalty relief

              Updated forms clarify that affected corporations must file Form 2220 with their federal income tax returns to qualify for relief from penalties

              August 23, 2024

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              IRS provides tax relief for taxpayers affected by severe storms, straight-line winds, flooding in South Dakota

              Tax relief for individuals and businesses in South Dakota affected by severe storms

              August 23, 2024

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              IRS provides tax relief for taxpayers throughout Puerto Rico affected by Tropical Storm Ernesto

              Tax relief for individuals and businesses throughout Puerto Rico affected by Tropical Storm Ernesto

              August 23, 2024

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              Delaware: Notices requesting “verified reports” of unclaimed property

              The notices give companies 30 days to respond to the correspondence.

              August 22, 2024

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              Rev. Rul. 2024-18: Interest rates, tax underpayments and overpayments remain same for fourth quarter 2024

              Interest rates for the calendar quarter beginning October 1, 2024

              August 22, 2024

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              KPMG report: Information reporting for U.S. digital asset brokers

              Requirements for a digital asset broker to file information returns and furnish payee statements that report gross proceeds on sales of digital assets

              August 21, 2024

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              Proposed regulations: Revising qualified domestic trust regulations to update outdated references, procedures

              Update current regulations under section 2056A

              August 20, 2024

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              Proposed regulations: Guidance regarding elections relating to foreign currency gains and losses

              Time for making and revoking certain elections relating to foreign currency gain or loss

              August 19, 2024

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              KPMG reports: Arizona, Illinois, Kansas, New Jersey, Washington State

              KPMG reports focus on recent state and local tax developments

              August 19, 2024

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              KPMG report: Controlled foreign corporations as collateral post-TCJA

              There is often a significant possibility that a section 956 inclusion might occur as a result of CFC collateral.

              August 19, 2024

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              Interim guidance on employer matching contributions made to retirement plans related to employee student loan payments

              Notice 2024-63 implements section 110 of the SECURE 2.0 Act of 2022

              August 19, 2024

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              Notice 2024-61: Inflation adjustment factor and phase-out for enhanced oil recovery credit

              The enhanced oil recovery credit for qualified costs paid or incurred in 2024 is phased-out completely.

              August 19, 2024

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              Proposed regulations: Guidance regarding elections relating to foreign currency gains and losses

              Time for making and revoking certain elections relating to foreign currency gain or loss

              August 19, 2024

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              Vice President Harris releases partial economic plan that includes tax proposals

              Elements of economic plan include several new tax incentives and preferences

              August 16, 2024

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              Announcement 2024-30: Second voluntary disclosure program for employee retention credit

              Employers must apply by November 22, 2024

              August 15, 2024

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              IRS accepting applicants for 2025 CAP program beginning September 4, with expanded eligibility criteria

              The IRS will inform applicants if they are accepted into the program in February 2025.

              August 15, 2024

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              IRS strongly urges pre-filing registration now for 2023 elective payment or transfer claims

              IRS recommends submitting the pre-filing registration at least 120 days before the planned filing date

              August 14, 2024

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              IRS expands Hurricane Debby tax relief to taxpayers in Vermont

              Affected taxpayers have until February 3, 2025, to file various federal individual and business tax returns and make tax payments.

              August 13, 2024

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              IRS provides tax relief for taxpayers affected by severe storms and flooding in Minnesota

              Tax relief for taxpayers affected by severe storms and flooding in Minnesota

              August 12, 2024

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              KPMG report: Documentation rules under final digital asset reporting regulations

              Overview of tax documentation required to be collected by U.S. digital asset brokers under final U.S. broker digital asset reporting regulations

              August 12, 2024

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              KPMG reports: Illinois, Massachusetts, Minnesota, Texas

              KPMG reports focus on recent state and local tax developments

              August 12, 2024

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              U.S. Tax Court: Participation interest may constitute partnership interest regardless of subjective intent to be a partner

              Tax Court held that the taxpayer did not meet its burden of proof

              August 9, 2024

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              IRS announces end to moratorium on processing new employee retention credit claims

              The IRS announced an end to its moratorium on processing employee retention credit claims filed after September 14, 2023.

              August 9, 2024

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              IRS provides tax relief for taxpayers affected by Hurricane Debby in four states

              Tax relief for individuals and businesses in four states affected by Hurricane Debby

              August 9, 2024

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              IRS releases draft updated Form 1099-DA for digital assets proceeds from broker transactions, requests comments

              New draft of Form 1099-DA reflects final regulations for custodial broker reporting and includes transitional relief

              August 9, 2024

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              Proposed regulations: DCL rules, including treatment of intercompany transactions, Pillar Two taxes, and certain disregarded payments

              Proposed regulations address certain issues arising under the dual consolidated loss (DCL) rules

              August 6, 2024

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              KPMG reports: Colorado (local sales tax dispute settled); Illinois (updated investment partnership regulations); Oregon (potential corporate minimum tax increase); South Carolina (bank tax)

              KPMG This Week in State Tax focuses on recent state and local tax developments.

              August 5, 2024

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              United States: IRS issues new FAQ for QI/WP/WT

              Provisions for 2023 QI agreement

              August 1, 2024

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                July 2024
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                IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, landslides, and mudslides in Kentucky

                Various deadlines postponed to February 3, 2025

                July 31, 2024

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                KPMG reports: District of Columbia (FY 2025 budget includes increase in sales and use tax rate); New Mexico (gross receipts tax); Pennsylvania (taxation of electricity used to power vehicles); multistate (tax reform proposals)

                KPMG reports focus on recent state and local tax developments

                July 30, 2024

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                Senate Finance hearing on tax incentives for economic development and financing; JCT description of present law

                The Senate Finance Committee held a hearing titled “Tax Tools for Local Economic Development.”

                July 30, 2024

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                United States: IRS announces all QI / WP / WT applications for 2024 must be submitted by September 30

                Applications submitted after September 30, 2024, will not be processed.

                July 30, 2024

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                Senate Majority Leader Schumer files motion to proceed on tax extenders bill

                H.R. 7024, the “Tax Relief for American Families and Workers Act”

                July 29, 2024

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                KPMG report: Expiring provisions in the 2025 “Tax Cliff”

                Outline of many tax provisions set to expire

                July 29, 2024

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                KPMG report: State and local tax, technology-related developments (table, second quarter 2024)

                Covers topics such as web-based services, data center exemptions, streaming services, and telecommunications services

                July 29, 2024

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                IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Missouri

                Affected taxpayers now have until February 3, 2025, to file various tax returns and make tax payments

                July 29, 2024

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                KPMG report: Final regulations on prevailing wage and apprenticeship requirements under clean energy tax incentives

                A summary of the rules and observations of the final regulations on prevailing wage and apprenticeship requirements under clean energy tax incentives.

                July 26, 2024

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                IRS updates FAQs on new, previously owned, and qualified commercial clean vehicle credits

                Guidance related to new, previously owned, and qualified commercial clean vehicle credits

                July 26, 2024

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                Notice 2024-60: Required procedures to claim section 45Q credit for sequestration of carbon oxide

                Guidance on the credit for the sequestration of carbon oxide under section 45Q

                July 24, 2024

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                KPMG report: Planning implementation of broker digital asset reporting regulations

                Key timeline considerations for brokers subject to a reporting requirement under final regulations

                July 24, 2024

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                Gain recognized on sale of partnership interest attributable to inventory not U.S.-source income subject to U.S. tax

                A D.C. Circuit decision concerning gain recognized on sale of partnership interest.

                July 23, 2024

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                IRS provides tax relief for taxpayers in Texas affected by Hurricane Beryl

                Tax relief for taxpayers in Texas affected by Hurricane Beryl

                July 22, 2024

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                KPMG reports: Texas, Wisconsin, multistate

                KPMG This Week in State Tax focuses on recent state and local tax developments.

                July 22, 2024

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                KPMG report: APMA program annual report on APA statistics for 2023

                Examination of the report and insights for taxpayers

                July 22, 2024

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                Notice 2024-58: Percentage depletion for oil and gas produced from marginal properties for 2024

                Percentage depletion for oil and gas produced from marginal properties is 15%

                July 22, 2024

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                Final and proposed regulations: Required minimum distributions under section 401(a)(9)

                Final regulations reflect amendments made to section 401(a)(9) by provisions of the SECURE Act

                July 18, 2024

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                Final regulations: Guidance under section 367(b) relating to certain triangular reorganizations and inbound nonrecognition transactions

                Final regulations finalize proposed regulations released in October 2023 without substantive change

                July 17, 2024

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                KPMG reports: Florida, New Jersey, Oregon, Pennsylvania

                KPMG reports focus on recent state and local tax developments

                July 15, 2024

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                KPMG report: Final regulations on information reporting on digital asset transactions

                The U.S. Treasury Department and IRS issued final regulations on digital asset tax information reporting requirements.

                July 12, 2024

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                IRS provides tax relief for taxpayers affected by storms, flooding, landslides, and mudslides in West Virginia

                Affected taxpayers now have until November 1, 2024, to file various federal tax returns

                July 11, 2024

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                Proposed regulations: Certain basket contract transactions identified as listed transactions

                Identify certain “basket contract” transactions and substantially similar transactions as listed transactions, a type of reportable transaction

                July 11, 2024

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                Renewable electricity production inflation factors, reference prices for 2024

                Used in determining the availability of the credit for renewable electricity production under section 45

                July 10, 2024

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                IRS issues FAQs regarding registration for clean fuel production credit

                FAQs address which entity must apply for registration pursuant to Notice 2024-49

                July 10, 2024

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                KPMG reports: Application of BBA centralized partnership audit regime

                Partnership’s ability, or lack thereof, to pay a potential partnership-level liability determined under the BBA

                July 8, 2024

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                KPMG report: IRS rewards credit card banks with earlier deductions

                IRS chief counsel advice regarding a bank’s rewards program for its credit card customers

                July 8, 2024

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                KPMG report: IRS steps up enforcement of the individual expatriation tax

                IRS appears to be sharpening its enforcement efforts for potentially substantial exit tax liabilities

                July 5, 2024

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                KPMG report: Inconsistency in state conformity to the Code

                Overlooked complexities imposed by state incorporation of the Code

                July 3, 2024

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                KPMG report: Recent litigation regarding sales tax collection and remittance obligations in Illinois

                Lawsuits have alleged that the sales tax collection and remittance obligations imposed by a state or locality post-Wayfair were unduly burdensome

                July 3, 2024

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                Final regulations: Guidance on procedural requirements for section 5000D excise tax on sales of “designated drugs”

                Final regulations adopt proposed regulations with three non-substantive modifications

                July 3, 2024

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                KPMG report: Reporting and paying the stock repurchase excise tax

                The government has answered when taxpayers need to submit payments for the stock repurchase excise tax.

                July 2, 2024

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                KPMG report: Specified research and experimentation expenditures under section 174

                Similarities and differences between specified research expenditure product rights

                July 2, 2024

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                Rev. Proc. 2024-30: Procedures for obtaining automatic consent to change methods of accounting to the Allowance Charge-off Method

                The change is effective for charge-offs occurring in tax years ending on or after December 28, 2023.

                July 2, 2024

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                KPMG report: Clean fuel production credit—a new incentive regime

                Taxpayers may need to begin preparing now for the transition to the one-size-fits-all, technology-neutral clean fuel production credit

                July 2, 2024

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                Proposed regulations: Amended guidance regarding payment of tax by commercially acceptable means

                Would allow the IRS to directly accept payments of tax by credit or debit card

                July 1, 2024

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                Proposed regulations: Recapture of interest on erroneous refunds of COVID-19 relief employment tax credits

                Would apply to all interest amounts paid under section 6611 for any erroneous refund of COVID-19-related ETCs

                July 1, 2024

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                Notice 2024-52: Reference price for section 45I credit for production of natural gas from marginal wells

                Applicable reference price is $2.04 per 1,000 cubic feet

                July 1, 2024

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                California: Budget tax changes enacted

                Details on key changes affecting business taxpayers

                July 1, 2024

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                  June 2024
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                  U.S. Supreme Court: Chevron overruled

                  Courts will no longer be bound to uphold IRS regulations as authoritative interpretations of ambiguous provisions under the Code.

                  June 28, 2024

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                  Information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions

                  Regarding information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions

                  June 28, 2024

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                  Final regulations: Guidance on reporting and payment of new 1% excise tax on repurchases of corporate stock

                  Guidance regarding reporting and payment of the new 1% excise tax on repurchases of corporate stock

                  June 28, 2024

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                  South Carolina: Durable medical equipment sales and use tax exemption prospectively invalidated (Supreme Court decision)

                  A Supreme Court decision concerning the state’s durable medical equipment sales and use tax exemption.

                  June 28, 2024

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                  KPMG report: Treasury and IRS guidance on partnership “basis shifting” transactions

                  Initial analysis and observations

                  June 27, 2024

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                  KPMG report: State, local tax changes (second quarter 2024, table format)

                  Report prepared by the KPMG State and Local Tax practice

                  June 27, 2024

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                  IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Mississippi

                  Tax relief for individuals and businesses in Mississippi affected by severe storms, straight-line winds, tornadoes and flooding.

                  June 27, 2024

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                  IRS provides tax relief for taxpayers affected by storms, flooding, winds, and tornadoes in Iowa

                  Tax relief for taxpayers affected by storms, flooding, winds, and tornadoes in Iowa

                  June 27, 2024

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                  Third quarter update to IRS 2023-2024 Priority Guidance Plan

                  The U.S. Treasury Department and IRS released the third quarter update to the 2023-2024 Priority Guidance Plan.

                  June 26, 2024

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                  National Taxpayer Advocate mid-year report to Congress

                  The National Taxpayer Advocate Erin M. Collins released her mid-year report to Congress.

                  June 26, 2024

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                  IRS provides tax relief for taxpayers affected by fire and flooding in southern New Mexico

                  Tax relief for taxpayers affected by fire and flooding in New Mexico

                  June 26, 2024

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                  IRS provides tax relief for taxpayers affected by storms, tornadoes, and flooding in Oklahoma

                  Affected taxpayers now have until November 1, 2024, to file various federal individual and business tax returns and make tax payments.

                  June 25, 2024

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                  IRS provides tax relief for taxpayers affected by storms and tornadoes in Florida

                  Affected taxpayers have until November 1, 2024, to file various federal individual and business tax returns and make tax payments.

                  June 25, 2024

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                  Final regulations: Disallowance of deductions for certain conservation easement contributions by partnerships, S corps

                  Final regulations introduce several new concepts to implement the statutory disallowance rule

                  June 24, 2024

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                  KPMG reports: Arkansas (corporate income tax rate); Oklahoma (sales and use tax exemption); Vermont (taxation of remotely accessed software)

                  KPMG This Week in State Tax focuses on recent state and local tax developments.

                  June 24, 2024

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                  IRS releases revised draft Form 6765, Credit for Increasing Research Activities

                  Revised Section G will be optional for all filers for tax year 2024 and will become effective for tax year 2025

                  June 21, 2024

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                  Notice 2024-55: Guidance on exceptions to 10% additional tax on early retirement plan distributions

                  Exceptions were added by the SECURE 2.0 Act of 2022 and became effective on January 1, 2024

                  June 21, 2024

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                  Notice 2024-45: Clean hydrogen production credit under section 45V, inflation adjustment factors and applicable amounts

                  Inflation adjustment factors and applicable amounts are used to determine the amount of the credit allowable under section 45V

                  June 21, 2024

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                  U.S. Supreme Court: Mandatory repatriation tax under section 965 held constitutional

                  A U.S. Supreme Court decision concerning mandatory repatriation tax under section 965.

                  June 20, 2024

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                  U.S. Treasury announces suspension, by mutual agreement, of the Russia income tax treaty

                  The suspension will take effect both for taxes withheld at source and in respect of other taxes on August 16, 2024.

                  June 18, 2024

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                  Final regulations: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

                  Increased credit amounts or increased deduction amount available for taxpayers satisfying prevailing wage and registered apprenticeship requirements

                  June 18, 2024

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                  IRS issues FAQs regarding educational assistance programs

                  Tax-free benefits up to $5,250 per calendar year

                  June 18, 2024

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                  Treasury and IRS release guidance on partnership “basis shifting” transactions

                  Guidance documents related to certain “basis-shifting” transactions involving partnerships and related parties

                  June 17, 2024

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                  KPMG reports: California, Rhode Island, South Carolina

                  KPMG This Week in State Tax focuses on recent state and local tax developments.

                  June 17, 2024

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                  Notice 2024-47: Additional limited relief from underpayment of estimated tax attributable to CAMT liability

                  Extends relief provided in Notice 2024-33

                  June 13, 2024

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                  Corrections to final regulations under section 1061 include change to capital interest allocations exception

                  Borrowed proceeds will be excluded only if they are borrowed from the partnership or another partner (or a person related to such persons)

                  June 13, 2024

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                  IRS provides tax relief for taxpayers affected by severe storms, straight-line winds, tornadoes, and flooding in Arkansas

                  Tax relief for taxpayers affected by severe storms in Arkansas

                  June 12, 2024

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                  KPMG report: Section 45Y clean electricity production credit and section 48E clean electricity investment credit proposed regulations

                  KPMG report provides initial analysis and observations

                  June 12, 2024

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                  IRS adds new FAQs to provide guidance to qualified intermediaries (QIs)

                  FAQs under the heading “Certifications and Periodic Reviews”

                  June 10, 2024

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                  KPMG reports: Connecticut, Florida, South Carolina

                  KPMG This Week in State Tax focuses on recent state and local tax developments.

                  June 10, 2024

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                  IRS practice unit: Lower of cost or market (LCM)

                  IRS examiner “job aides” and training materials intended to describe for IRS agents leading practices about tax concepts

                  June 10, 2024

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                  Notice 2024-48: Guidance for the energy community bonus credit under IRA

                  Information taxpayers may use to determine whether they meet certain requirements under the Statistical Area Category or the Coal Closure Category

                  June 7, 2024

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                  Notice 2024-39: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2024

                  The inflation adjustment factor for the carbon oxide sequestration credit under section 45Q for calendar year 2024 is 1.3877.

                  June 7, 2024

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                  IRS provides tax relief for taxpayers affected by storms in Kentucky and West Virginia

                  Affected taxpayers have until November 1, 2024, to file various federal tax returns and make tax payments.

                  June 7, 2024

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                  Rev. Proc. 2024-26: Procedures for qualified manufacturers, dealers and sellers of certain qualified clean vehicles under IRA

                  IRS updates procedures for qualified manufacturers, dealers and sellers of certain qualified clean vehicles under the Inflation Reduction Act

                  June 7, 2024

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                  IRS issues new FAQ for qualified intermediaries (QIs)

                  FAQ 3 provides guidance to QIs acting as intermediaries for payments of substitute dividends

                  June 6, 2024

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                  IRS announces tax relief for taxpayers in Iowa affected by storms, tornadoes, and flooding

                  Taxpayers have until November 1 to file various federal individual and business tax returns and make tax payments

                  June 6, 2024

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                  U.S. Supreme Court: Estate tax value of stock is not reduced by contractual obligation to redeem shares

                  Supreme Court unanimously affirmed the U.S. Court of Appeals for the Eighth Circuit

                  June 6, 2024

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                  Notice 2024-46: Treatment of relief payments made to individuals affected by East Palestine, Ohio train derailment

                  The IRS determined that the February 2023 derailment qualifies as “an event of a catastrophic nature.”

                  June 5, 2024

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                  Eleventh Circuit: IRS violated APA notice and comment procedures in issuing Notice 2017-10

                  The IRS must follow APA notice and comment procedures unless explicitly exempted by Congress.

                  June 4, 2024

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                  KPMG reports: Illinois (tax changes in budget bill); Tennessee (guidance on sales and use tax sourcing rules); Washington State (amended apportionment rule)

                  KPMG This Week in State Tax focuses on recent state and local tax developments.

                  June 3, 2024

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                  KPMG report: IRS removal of automatic accounting methods

                  Reviews revised automatic accounting method procedures and encourages taxpayers to revisit their timetables for implementation

                  June 3, 2024

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                    May 2024
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                    IRS provides tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Texas (updated)

                    Tax relief for taxpayers affected by storms, winds, tornadoes, and flooding in Texas

                    June 12, 2024

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                    IRS provides tax relief for taxpayers in Massachusetts affected by severe storms, flooding

                    Tax relief for individuals and businesses in parts of Massachusetts affected by severe storms and flooding that began on September 11, 2023.

                    May 31, 2024

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                    Notice 2024-49: Registration requirements for section 45Z clean transportation fuel production credit

                    Taxpayer must have signed registration letter dated on or before January 1, 2025, to be eligible to claim the credit

                    May 31, 2024

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                    Polyoxymethylene added to Superfund list

                    Effective date for tax purposes generally is October 1, 2024, and the effective date for purposes of refund claims is July 1, 2022

                    May 30, 2024

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                    U.S. Tax Court decision interpreting section 7508A(d)’s automatic and mandatory extension for filing a petition

                    KPMG report discusses the Tax Court’s decision in Abdo & Farah v. Commissioner

                    May 29, 2024

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                    Proposed regulations: Clean electricity production and investment credits under sections 45Y and 48E

                    Clean electricity production and clean electricity investment credits as established by the “Inflation Reduction Act of 2022”

                    May 29, 2024

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                    Notice 2024-44: Further extended phase-in provisions under section 871(m) regulations

                    Treasury and the IRS continue to evaluate the section 871(m) regulations

                    May 22, 2024

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                    Notice 2024-43: Deferral of provisions under section 59A and 6038A regulations relating to reporting of qualified derivative payments

                    Tax years beginning on or after January 1, 2027

                    May 22, 2024

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                    U.S. Tax Court: Option granted to related entity with respect to real property not a sham

                    U.S. Tax Court memorandum opinion rejecting IRS’ contention that taxpayer engaged in sham transaction

                    May 22, 2024

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                    IRS provides tax relief for taxpayers affected by storms and tornadoes in Nebraska

                    Tax relief for individuals and businesses in Nebraska affected by severe storms

                    May 20, 2024

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                    IRS provides tax relief for taxpayers affected by storms and tornadoes in Iowa

                    Affected taxpayers now have until October 15, 2024, to file federal tax returns and make tax payments.

                    May 20, 2024

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                    KPMG reports: Alabama, California, Tennessee

                    KPMG This Week in State Tax focuses on recent state and local tax developments.

                    May 20, 2024

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                    U.S. Tax Court: No gift tax liability following termination of marital trusts

                    Estate was not liable for gift tax under sections 2501 and 2519

                    May 20, 2024

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                    U.S. Treasury release: No change to list of countries cooperating with international boycott

                    A current list of countries that require (or may require) participation in, or cooperation with, an international boycott.

                    May 20, 2024

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                    Announcement 2024-25: Capacity limitation carryover amounts for 2024 Low-Income Communities Bonus Credit program year

                    The total amount of unallocated capacity limitation from the 2023 program year is 324.785 megawatts (MW).

                    May 17, 2024

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                    Announcement 2024-24: Updated applicable reference standard for energy efficient commercial building property deduction

                    Reference Standard 90.1-2022 is the applicable reference standard required under section 179D(c)(2)

                    May 17, 2024

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                    IRS announces tax relief for taxpayers affected by tornadoes in Ohio

                    Taxpayers have until September 3, 2024, to file federal individual and business tax returns and make tax payments.

                    May 16, 2024

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                    Ways and Means votes bills relating to disclosure requirements and foreign donations and grants of tax-exempt organizations out of committee

                    The full House may consider the legislation.

                    May 16, 2024

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                    Notice 2024-41: Modified domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E

                    Including new elective safe harbor

                    May 16, 2024

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                    Notice 2024-42: Mortality tables for defined benefit pension plans (2025)

                    Calculating the funding target and other items for valuation dates occurring during the 2025 calendar year

                    May 15, 2024

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                    Proposed regulations: Interest capitalization requirements for improvements to designated property

                    Remove the “associated property rule,” modify and amend the definition of “improvement”

                    May 14, 2024

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                    Information reporting on transactions with foreign trusts and large foreign gifts, transactions with foreign trusts

                    Potentially relevant for tax-exempt organizations that control foreign trusts used for fundraising abroad

                    May 13, 2024

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                    KPMG reports: Colorado (combined reporting); Nevada (marketplace facilitators); Tennessee (franchise tax )

                    KPMG This Week in State Tax focuses on recent state and local tax developments.

                    May 13, 2024

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                    Application period for second year of environmental justice solar and wind capacity limitation program opening May 28

                    Treasury and IRS announced that applications for 2024 program year for “Low-Income Communities Bonus Credit program” will open on May 28, 2024.

                    May 13, 2024

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                    KPMG report: Accelerating Form 1099 deadlines, prioritizing taxpayer efficiency

                    Reasons for change and administrative issues that payors will need to address

                    May 10, 2024

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                    Rev. Rul. 2024-11: Interest rates, tax underpayments and overpayments remain same for third quarter 2024

                    The rates of interest will remain the same for the calendar quarter beginning July 1, 2024.

                    May 9, 2024

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                    Rev. Proc. 2024-25: HSA inflation-adjusted amounts for 2025

                    Inflation-adjusted limits related to health savings accounts and high deductible health plans for calendar year 2025

                    May 9, 2024

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                    IRS announces tax relief for taxpayers in Oklahoma affected by severe weather

                    Taxpayers now have until September 3, 2024, to file federal individual and business tax returns and make tax payments.

                    May 6, 2024

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                    KPMG article: Interplay of potential enactment of extenders with CAMT

                    A KPMG article explains the effects of H.R. 7024 on CAMT

                    May 6, 2024

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                    KPMG report: Phantom inversions under section 7874

                    How rules concerning disqualified stock and non-ordinary-course distributions can create an inversion under section 7874

                    May 6, 2024

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                    Eighth Circuit: Taxpayer’s research was “funded” and thus ineligible for research tax credits ; Tax Court affirmed

                    The Eighth Circuit affirmed a decision of the Tax Court that the taxpayer was not entitled to research tax credits.

                    May 6, 2024

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                    KPMG reports: Kansas (sales and use tax laws); Nebraska (R&E expenditures); multistate (draft legislation amending P.L. 86-272)

                    KPMG This Week in State Tax focuses on recent state and local tax developments.

                    May 6, 2024

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                    D.C. Circuit: IRS has statutory authority to assess penalties for willful failure to file Form 5471; Tax Court reversed

                    D.C. Circuit decision reversed Tax Court’s holding that IRS did not have statutory authority to assess penalties under section 6038(b)

                    May 3, 2024

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                    IRS issues FAQs regarding disaster relief related to retirement plans and IRAs

                    Rules for distributions from retirement plans and IRAs and for retirement plan loans

                    May 3, 2024

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                    Final regulations: Guidance on clean vehicle credits

                    Clean vehicle tax credits under sections 25E and 30D for the purchase of qualifying new and previously-owned clean vehicles

                    May 3, 2024

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                    IRS releases annual update to strategic operating plan

                    Future plans for the agency’s transformation and improvements for taxpayers since passage of the “Inflation Reduction Act of 2022”

                    May 2, 2024

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                    KPMG report: Analysis and observations of final transferable credit regulations

                    A KPMG report that provides analysis and observations of the final section 6418 regulations.

                    May 2, 2024

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                    Rev. Proc. 2024-24 and Notice 2024-38: Updated procedures for section 355 private letter rulings

                    Updated procedures for taxpayers requesting private letter rulings from the IRS regarding certain matters pertaining to section 355 transactions

                    May 2, 2024

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                      April 2024
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                      Treasury Secretary Yellen testifies at House Ways and Means Committee hearing on administration’s FY 2025 tax proposals

                      Written testimony from Secretary of the Treasury

                      April 30, 2024

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                      Rev. Proc. 2024-23: Updated annual list of automatic accounting method changes

                      Effective immediately for Forms 3115 filed on or after April 30, 2024, for a year of change ending on or after September 30, 2023

                      April 30, 2024

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                      Notice 2024-37: Additional guidance and safe harbors for sustainable aviation fuel credit

                      SAF credit applies to a qualified fuel mixture containing sustainable aviation fuel for certain sales or uses in calendar years 2023 and 2024

                      April 30, 2024

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                      Reference price for nonconventional source production credit for 2023

                      Reference price under section 45K(d)(2)(C) for calendar year 2023 is $76.10

                      April 29, 2024

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                      KPMG reports: Alabama, Arkansas, Colorado, South Carolina, Tennessee, Virginia

                      KPMG This Week in State Tax focuses on recent state and local tax developments.

                      April 29, 2024

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                      Notice 2024-36: Announcement of 2024 allocation round and updated guidance on qualifying advanced energy project credit

                      Guidance for upcoming 2024 allocation round of qualifying advanced energy project credit program under section 48C(e)

                      April 29, 2024

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                      Tennessee: Franchise tax refund agreement reached

                      The governor is expected to sign the legislation.

                      April 26, 2024

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                      Final regulations: Guidance on transfer of certain tax credits under IRA

                      Rules for the election to transfer eligible credits in a tax year and required IRS pre-filing registration process

                      April 25, 2024

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                      Final regulations: Definition of domestically controlled qualified investment entity under section 897

                      When foreign persons are considered to directly or indirectly hold stock in a QIE

                      April 24, 2024

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                      IRS Independent Office of Appeals announces formation of alternative dispute resolution program management office

                      Collaboration with IRS business operating divisions to help taxpayers resolve tax disputes

                      April 24, 2024

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                      KPMG reports: Georgia, Illinois, New Jersey

                      KPMG reports focus on recent state and local tax developments

                      April 22, 2024

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                      Rev. Proc. 2024-20: Foreign insurance companies; effectively connected net investment income (2023)

                      IRS provides domestic asset / liability percentages and domestic investment yields needed by foreign life insurance companies

                      April 18, 2024

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                      KPMG report: Initial analysis of stock repurchase excise tax proposed regulations

                      A report that provides initial analysis of the proposed regulations

                      April 17, 2024

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                      IRS updates FAQs for energy efficient home improvement and residential clean energy property credits

                      Supersede earlier FAQs posted in December 2022

                      April 17, 2024

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                      IRS issues FAQs related to tax treatment of work-life referral services provided to employees

                      Employer-funded fringe benefit that provides work-life referral services

                      April 16, 2024

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                      IRS updates FAQs on new, previously owned, and qualified commercial clean vehicle credits

                      Guidance related to new, previously owned, and qualified commercial clean vehicle credits

                      April 16, 2024

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                      Notice 2024-35: Relief with respect to certain required minimum distributions

                      Relief with respect to certain required minimum distributions under section 401(a)(9)

                      April 16, 2024

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                      Rev. Proc. 2024-21: Nationwide average purchase price, residences located in United States

                      Provided for issuers of qualified mortgage bonds and issuers of mortgage credit certificates

                      April 16, 2024

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                      KPMG reports: Florida, Pennsylvania, New York

                      KPMG reports focus on recent state and local tax developments

                      April 15, 2024

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                      KPMG report: Partnership audit rules and specific IRS forms

                      Partnership audit rules enacted by the BBA have altered how partners report and pay tax on adjustments

                      April 15, 2024

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                      Notice 2024-33: Limited relief from underpayment of estimated tax attributable to CAMT liability

                      Underpayment of the 2024 first quarterly installment of estimated income tax

                      April 15, 2024

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                      IRS corrects appendices to Notice 2024-20, census tracts for credit under section 30C

                      IRS correction to appendices in Notice 2024-20

                      April 12, 2024

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                      KPMG report: CAMT recent developments—changes to instructions for Schedule K-1

                      Updated instructions raise questions and may provide tea leaves with respect to the CAMT proposed regulation package expected later this year

                      April 11, 2024

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                      Supplemental proposed regulations: Clean hydrogen production credit and related energy credit

                      30-day period for comments on the DOE’s emissions value request process

                      April 10, 2024

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                      KPMG report: State, local tax changes (first quarter 2024, table format)

                      Summary of state and local tax developments for the first quarter of 2024

                      April 10, 2024

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                      United States: Updated instructions highlight potential need to request CAMT information from partnerships

                      Many sovereign wealth funds and large public pensions plans have begun the complex task of analyzing their investment structures

                      April 9, 2024

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                      Proposed regulations: Guidance on new 1% excise tax on repurchases of corporate stock

                      Reporting and payment of the new excise tax

                      April 9, 2024

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                      KPMG reports: Arizona, Kentucky, Minnesota

                      KPMG reports focus on recent state and local tax developments

                      April 8, 2024

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                      KPMG report: Comments on expanding tax certainty and issue resolution programs for business taxpayers

                      KPMG comments with recommended potential changes

                      April 5, 2024

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                      Announcement 2024-19: Tax treatment of amounts paid as rebates for energy efficient property and improvements

                      Amounts received from home energy rebate programs to be treated as reduction in purchase price or cost of property for eligible upgrades and projects

                      April 5, 2024

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                      IRS provides tax relief for taxpayers in Maine and Rhode Island affected by severe storms, flooding

                      Affected taxpayers now have until July 15, 2024, to file various tax returns and make tax payments.

                      April 4, 2024

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                      KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations

                      Interaction of U.S. dual consolidated loss (DCL) rules and the OECD Pillar Two rules may result in unintended consequences

                      April 2, 2024

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                      Taxpayers automatically entitled to extension to file petition by reason of COVID-19 disaster declaration

                      A U.S. Tax Court case concerning whether taxpayers were entitled to an extension to file a petition by reason of COVID-19 disaster declaration

                      April 2, 2024

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                      KPMG reports: Arkansas, Idaho, multistate

                      KPMG reports focus on recent state and local tax developments

                      April 1, 2024

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                        March 2024
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                        Rev. Proc. 2024-19: Guidance on environmental justice solar and wind capacity limitation program for 2024

                        Guidance applicable to the program to allocate environmental justice solar and wind capacity limitation

                        March 29, 2024

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                        Announcement 2024-16: APMA program, APA statistics for 2023

                        25th report describing the experience, structure, and activities of the APMA program

                        March 29, 2024

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                        Proposed regulations: Disclosure of specified return information to Bureau of the Census for statistical purposes

                        Amendments proposed to apply to disclosures of return information under section 6103(j)(1)(A)

                        March 28, 2024

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                        Final regulations: Definitions of short-term, limited-duration insurance and excepted benefits coverage

                        Intended to more clearly distinguish STLDI and fixed indemnity excepted benefits coverage from comprehensive coverage

                        March 28, 2024

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                        U.S. Tax Court: Conservation easement contribution regulations held invalid under APA

                        A U.S. Tax Court case concerning conservation easement contribution regulations under Administrative Procedure Act

                        March 28, 2024

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                        IRS extends tax relief for taxpayers affected by wildfires in Hawaii

                        Various tax-filing and tax-payment deadlines are further postponed until August 7, 2024.

                        March 27, 2024

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                        IRS announces tax relief for taxpayers in Alaska affected by severe storms

                        Affected taxpayers now have until July 15, 2024, to file various tax returns and make tax payments.

                        March 26, 2024

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                        Notice 2024-32: Guidance for qualified student loan and qualified mortgage bonds

                        Clarifying certain requirements for tax-exempt bond financing for loan programs of general application approved by a state

                        March 25, 2024

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                        KPMG reports: Louisiana (exempt cable services); Wisconsin (property tax exemption)

                        KPMG This Week in State Tax focuses on recent state and local tax developments.

                        March 25, 2024

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                        United States: IRS updates FAQ on QI/WP/WT website to provide guidance on WP/WT agreement renewals

                        Qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) FAQs website

                        March 22, 2024

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                        Third Circuit: Taxpayer’s petition cannot be dismissed by Tax Court on grounds of mootness

                        Third Circuit vacated a decision of U.S. Tax Court dismissing taxpayer’s petition on grounds of mootness because IRS had already withheld tax refunds

                        March 22, 2024

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                        Notice 2024-30: Expanded rules for energy community production and investment tax credits under IRA

                        The IRS also updated the frequently asked questions for energy communities.

                        March 22, 2024

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                        Proposed regulations: Certain charitable remainder annuity trust transactions identified as listed transactions

                        Identifying certain charitable remainder annuity trust transactions and substantially similar transactions as listed transactions

                        March 22, 2024

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                        Proposed regulations: Taxpayer notification in advance of IRS contact with third parties

                        Determination or collection of the taxpayer’s tax liability

                        March 21, 2024

                        News News
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                        Second quarter update to IRS 2023-2024 Priority Guidance Plan

                        Guidance projects published or released from October 1 through December 31, 2023

                        March 20, 2024

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                        Notice 2024-31: Housing expense limit adjustments, foreign locations for 2024

                        Adjustments made on the basis of geographic differences in housing costs relative to housing costs in the United States

                        March 20, 2024

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                        Waiver of time requirements for individuals electing to exclude foreign earned income because of adverse conditions

                        Rev. Proc. 2024-17 provides information to any individual who failed to meet the eligibility requirements of section 911(d)(1)

                        March 19, 2024

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                        KPMG report: CHIPS Act tax credit—direct pay final regulations

                        Notable updates and deviations from the proposed regulations

                        March 19, 2024

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                        KPMG report: Tax and trade considerations for U.S. inbound investment

                        Insights on U.S. real property investment and existing U.S. operations acquisition

                        March 18, 2024

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                        KPMG reports: Montana, Oregon, Tennessee, multistate

                        KPMG This Week in State Tax focuses on recent state and local tax developments.

                        March 18, 2024

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                        KPMG report: Accounting for tax credits generated by pass-through entities

                        Accounting considerations when evaluating the impact of tax credits generated by pass-through entities

                        March 18, 2024

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                        KPMG report: Final regulations on direct pay of certain tax credits under IRA, observations and analysis

                        A KPMG report that provides analysis and observations of the final regulations on direct pay of certain tax credits.

                        March 15, 2024

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                        KPMG report: Analysis and observations of tax proposals in Biden Administration’s FY 2025 budget

                        Proposals will likely serve as the basis of the Biden Campaign tax plan

                        March 14, 2024

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                        Final rule: Responsibility for administering alcohol taxes moved from CBP to Treasury

                        Treasury is responsible for administering refunds, reduced tax rates, and tax credits on imported alcohol

                        March 14, 2024

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                        IRS adds FAQ to QI / WP / WT FAQs website

                        Guidance on an administrative exemption from the requirement to electronically file Forms 1042 for calendar years 2024 and 2025

                        March 14, 2024

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                        KPMG report: New beneficial ownership information reporting requirements

                        Origin of the new BOI reporting rule and new due diligence requirements

                        March 14, 2024

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                        KPMG report: New proposed regulations on bad debt deductions for certain qualifying entities

                        Overview of rules in proposed regulations

                        March 13, 2024

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                        United States and Turkey announce updated digital services tax agreement

                        Summary of political agreement between United States and Turkey

                        March 12, 2024

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                        KPMG reports: Colorado, New Mexico, New York

                        KPMG reports focus on recent state and local tax developments

                        March 11, 2024

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                        Treasury releases “Green Book” explanation of tax proposals in FY 2025 budget

                        “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals”

                        March 11, 2024

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                        Arizona: Guidance on refund claims for invalidated Pinal County tax

                        Under Arizona law, an excise tax is assessed on the privilege or right to engage in an occupation or business and is not a tax upon the sale itself.

                        March 8, 2024

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                        IRS to waive dyed diesel fuel penalty in parts of Texas; wildfire-related relief

                        Penalty relief from February 23, 2024, through March 22, 2024

                        March 7, 2024

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                        Notice 2024-28: Request for recommendations for IRS 2024-2025 Priority Guidance Plan

                        The IRS invites recommendations for items to be included on the 2024-2025 Priority Guidance Plan.

                        March 7, 2024

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                        Treasury and IRS issue final regulations, other guidance on direct pay of certain tax credits under IRA and CHIPS

                        Final regulations and other guidance relating to direct pay of certain tax credits available under IRA and CHIPS

                        March 5, 2024

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                        Treasury and IRS issue final regulations, other guidance on direct pay of certain tax credits under IRA

                        Final regulations and other guidance relating to direct pay of certain tax credits available under IRA

                        March 5, 2024

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                        KPMG report: Taxpayer options for fixing federal tax return mistakes

                        A report that discusses how to handle tax mistakes in a variety of contexts.

                        March 4, 2024

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                        KPMG reports: California, Minnesota, Oklahoma, South Carolina

                        KPMG reports focus on recent state and local tax developments

                        March 4, 2024

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                          February 2024
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                          Rev. Proc. 2024-15: Guidance on qualifying securitizations by public utilities

                          Addressing securitization that involves issuance of debt instruments by a “qualifying State financing entity"

                          February 29, 2024

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                          Senate confirms Marjorie Rollinson to be IRS Chief Counsel

                          IRS has been without a chief counsel since the start of the Biden Administration.

                          February 29, 2024

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                          IRS announces new effort focused on high-income non-filers

                          New initiative will begin with IRS compliance letters going out this week

                          February 29, 2024

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                          IRS LB&I division adds new compliance campaign (business aircraft)

                          Addresses compliance concerns related to business aircraft usage by large corporations, large partnerships, and high-income taxpayers

                          February 29, 2024

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                          IRS provides tax relief for taxpayers in Washington State affected by wildfires

                          Tax relief for taxpayers in Washington State affected by wildfires

                          February 28, 2024

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                          IRS provides tax relief for taxpayers in California affected by severe storms, flooding

                          Tax relief for taxpayers in California affected by severe storms and flooding

                          February 27, 2024

                          News News
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                          Notice 2024-26: Administrative exemption from requirement to electronically file Form 1042

                          Withholding agents are administratively exempt from the requirements to electronically file Forms 1042 required to be filed in calendar year 2024

                          February 27, 2024

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                          KPMG report: Post-pandemic state tax policies

                          Factors to consider as the state fiscal policy landscape shifts in response to falling state tax revenue

                          February 27, 2024

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                          Notice of filing of petition for addition of iso-butanol to Superfund list

                          A petition has been filed requesting that iso-butanol be added to the list of taxable substances under section 4672(a).

                          February 26, 2024

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                          KPMG reports: Alaska, Louisiana, New York, Wisconsin

                          KPMG This Week in State Tax focuses on recent state and local tax developments.

                          February 26, 2024

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                          KPMG article: Challenges and opportunities faced by CAMT “scope bubble corporations”

                          It remains uncertain whether certain corporations close to the $1 billion average annual AFSI threshold are within the scope of CAMT.

                          February 26, 2024

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                          IRS TE/GE division provides new technical guide on fraternal societies under sections 501(c)(8) and 501(c)(10)

                          Law, regulations, and federal income tax issues with respect to fraternal beneficiary societies and domestic fraternal societies

                          February 22, 2024

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                          IRS announces plans to begin audits on personal use of business aircraft

                          Part of ongoing efforts to improve tax compliance by large corporations, large partnerships, and high-income taxpayers

                          February 22, 2024

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                          Rev. Rul. 2024-6: Interest rates, tax underpayments and overpayments remain same for second quarter 2024

                          The rates of interest will remain the same for the second calendar quarter of 2024.

                          February 21, 2024

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                          U.S. Tax Court: Decision in favor of IRS in case regarding limited partner exception to self-employment income

                          Taxpayer may proceed with its appeal of the court’s holding in the U.S. Court of Appeals for the Fifth Circuit

                          February 21, 2024

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                          Filing of petitions for additions of caprolactam and nylon 6 to Superfund list

                          Petitions filed requesting that caprolactam and nylon 6 be added to the list of taxable substances under section 4672(a)

                          February 21, 2024

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                          Financing costs, including bond fees, properly included in eligible basis for purposes of low-income housing tax credit

                          U.S. Tax Court opinion

                          February 21, 2024

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                          IRS practice unit: Allocation and apportionment of R&E expenses for tax years beginning before January 1, 2020

                          Part of a series of IRS examiner “job aides” and training materials

                          February 21, 2024

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                          KPMG reports: New Jersey, Washington State, Wisconsin

                          KPMG This Week in State Tax focuses on recent state and local tax developments.

                          February 20, 2024

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                          U.S. Treasury launches website tracking tax guidance under “Inflation Reduction Act”

                          Website tracking tax guidance issued under H.R. 5376

                          February 20, 2024

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                          Final Form 4626 and instructions for corporate alternative minimum tax (CAMT)

                          IRS released final Form 4626 and accompanying instructions for the new corporate alternative minimum tax

                          February 16, 2024

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                          GLAM: Liability of third-party payers for improperly claimed employee retention credits

                          Certain categories of third-party payers are liable for any underpayments resulting from improperly claimed employment tax credit

                          February 16, 2024

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                          Correction to proposed regulations on energy credit under section 48, relating to certain gas upgrading equipment

                          Comment period for the November 2023 proposed regulations is also reopened

                          February 16, 2024

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                          IRS provides tax relief for taxpayers in Michigan affected by severe storms, tornadoes and flooding

                          Tax relief for taxpayers in Michigan affected by severe storms

                          February 15, 2024

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                          U.S. Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

                          Extended political agreement regarding unilateral measures concerning the imposition of digital services taxes (DSTs)

                          February 15, 2024

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                          U.S. Treasury release: No change to list of countries cooperating with international boycott

                          No new countries are added, and no countries are removed from the prior list

                          February 15, 2024

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                          KPMG report: California court decision on interstate tax law

                          San Francisco Superior Court decision concerning a federal law that levies restrictions on state taxes of interstate businesses

                          February 15, 2024

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                          Application period for environmental justice solar and wind capacity limitation program closing February 29

                          Applications for 2023 program year for “Low-Income Communities Bonus Credit program” will close on February 29, 2024

                          February 13, 2024

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                          KPMG reports: Delaware, Illinois, South Dakota

                          KPMG This Week in State Tax focuses on recent state and local tax developments.

                          February 12, 2024

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                          Rev. Proc. 2024-14: Indexing adjustments for amounts used to calculate employer shared responsibility payments

                          Effective for tax years and plan years beginning after December 31, 2024

                          February 12, 2024

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                          KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups

                          Examples of how U.S. entities’ transfer pricing true-ups may affect GloBE ETR in the United States or a foreign jurisdiction

                          February 8, 2024

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                          KPMG report: State and local tax, technology-related developments (table, fourth quarter 2023)

                          A KPMG report of state and local technology-related tax developments for the fourth quarter of 2023.

                          February 8, 2024

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                          KPMG report: Implications of proposed changes to sections 174 and 280C in bipartisan tax extenders legislation

                          Common questions taxpayers have regarding the proposed changes

                          February 8, 2024

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                          IRS provides tax relief for taxpayers in West Virginia affected by severe storms, flooding, landslides, and mudslides

                          Tax relief for taxpayers in West Virginia affected by severe storms

                          February 7, 2024

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                          Rev. Proc. 2024-12: Temporary extension of time to submit seller reports for transfers of clean vehicle credits

                          Required information about a qualifying clean vehicle sale must be submitted to the IRS by February 15, 2024

                          February 7, 2024

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                          Rev. Proc. 2024-13: Automobile depreciation deduction limits for 2024

                          Section 280F limitations are required to be adjusted for inflation for automobiles placed in service after 2018

                          February 6, 2024

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                          IRS provides revised FAQs on Form 1099-K

                          Revised FAQs provide more general information for taxpayers, including common situations, and what organizations must send Forms 1099-K

                          February 6, 2024

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                          IRS provides tax relief for taxpayers in Maine affected by severe storms, flooding

                          Taxpayers now have until June 17, 2024, to file various federal individual and business tax returns and make tax payments.

                          February 5, 2024

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                          KPMG reports: Missouri, New York, multistate

                          KPMG reports focus on recent state and local tax developments

                          February 5, 2024

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                          KPMG report: State and local tax changes affecting entities in asset management industry in 2023

                          Significant state and local tax developments that may affect return and/or payment obligations of companies engaged in the asset management industry

                          February 5, 2024

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                          KPMG report: Navigating the shifting landscape of research credit audits

                          Developments in the research credit area, including recent guidance and case law

                          February 5, 2024

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                          KPMG report: Mexican rulings on exportation of services eligible for 0% VAT

                          Multinational corporations with Mexican subsidiaries need to properly assess VAT treatment of cross-border operations

                          February 2, 2024

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                            January 2024
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                            KPMG report: New year, changing information reporting and withholding (IRW) requirements

                            How organizations can prepare for electronic filing requirement threshold changes

                            January 31, 2024

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                            KPMG report: SEC comments on accounting for income taxes

                            Examples of comments about accounting for income taxes recently issued by the U.S. Securities and Exchange Commission to registrants

                            January 30, 2024

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                            KPMG reports: Colorado, New York, multistate

                            KPMG reports focus on recent state and local tax developments

                            January 29, 2024

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                            KPMG report: Practical tax mechanics of implementing SEC clawbacks

                            Tax mechanics of implementing a repayment to the employer of previously paid compensation

                            January 29, 2024

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                            IRS provides tax relief for taxpayers in Rhode Island affected by severe storms, flooding, and tornadoes

                            Taxpayers affected by severe storms, flooding, and tornadoes, now have until June 17 to file various federal individual and business tax returns

                            January 26, 2024

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                            IRS TE/GE division releases summary of “FY 2023 accomplishments”

                            TE/GE’s contributions to the tax administration system and each TE/GE function’s accomplishments

                            January 26, 2024

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                            KPMG report: Avoiding common pitfalls in oil and gas reserve valuations for U.S. tax purposes

                            The key to an oil and gas company’s compliance with U.S. tax reporting requirements is performing impartial valuations of the FMV of its assets.

                            January 26, 2024

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                            Tennessee: Proposed legislation authorizing franchise tax refunds

                            Certain business in Tennessee are subject to the state’s franchise and excise taxes

                            January 25, 2024

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                            Notice 2024-23: Special relief for certain rollovers to or from Maryland prepaid college trust accounts

                            Relief from 12-month limitation for taxpayers making rollovers to or from Maryland prepaid college trust for taxpayers affected by system issues

                            January 25, 2024

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                            KPMG reports: Florida, Massachusetts, Washington State

                            Recent state and local tax developments

                            January 23, 2024

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                            KPMG report: Resurgence of transfer pricing penalties

                            IRS shift toward increased penalty assertion; procedural considerations for taxpayers

                            January 23, 2024

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                            IRS provides tax relief for taxpayers in Connecticut affected by severe storms

                            Taxpayers affected by severe storms, flooding, and a potential dam breach, now have until June 17, 2024, to file various returns and payments

                            January 22, 2024

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                            Comment period reopened for proposed regulations on federal independent dispute resolution (IDR) process

                            The comment period is reopened from January 22, 2024, to February 5, 2024.

                            January 22, 2024

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                            Notice 2024-20: Guidance on qualified alternative fuel vehicle refueling property credit under section 30C

                            Taxpayers may rely on the notice until proposed regulations are published.

                            January 19, 2024

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                            IRS LB&I division adds a new compliance campaign (sports industry losses)

                            Partnerships within the sports industry that report significant tax losses

                            January 19, 2024

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                            Final regulations: Guidance on minimum present value requirements for certain defined benefit plans

                            IRS guidance relating to minimum present value requirements applicable to certain defined benefit pension plans

                            January 18, 2024

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                            KPMG report: Updated accounting method change procedures and clarification of rules under section 174

                            A KPMG report concerning two forms of guidance addressing section 174.

                            January 18, 2024

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                            KPMG report: Reporting and paying the stock repurchase excise tax—not quite yet

                            KPMG report examining when to file and pay the stock repurchase excise tax

                            January 18, 2024

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                            Ways and Means Chairman releases text and schedules markup of bipartisan tax legislation; JCT description and estimates

                            House Ways and Means Committee Chairman Jason Smith released H.R. 7024, the “Tax Relief for American Families and Workers Act of 2024.”

                            January 18, 2024

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                            KPMG report: Key takeaways from recent CAMT releases

                            Summary of notable provisions and KPMG observations

                            January 17, 2024

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                            Announcement 2024-4: Transitional guidance on reporting of information on receipt of digital assets

                            Digital assets are not required to be included when determining whether cash received meets the reporting threshold

                            January 16, 2024

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                            KPMG reports: Connecticut, Pennsylvania, Michigan

                            KPMG reports focus on recent state and local tax developments

                            January 16, 2024

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                            Notice 2024-18: Updated guidance on availability of administrative exemptions from requirement to file electronically

                            Availability of administrative exemptions from requirement to file certain returns and other documents in electronic form

                            January 12, 2024

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                            Notice 2024-22: Initial guidance on pension-linked emergency savings accounts

                            Guidance regarding anti-abuse rules, which provides for creation of pension-linked emergency savings accounts

                            January 12, 2024

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                            Updated beneficial ownership information reporting FAQs

                            Updated FAQs include new information about companies, beneficial owners, company applicants, requirements, and company exemptions

                            January 12, 2024

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                            IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships

                            The IRS announced continued progress to expand enforcement efforts related to high-income individuals, large corporations, and complex partnerships.

                            January 12, 2024

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                            IRS announces changes to QI / WP / WT FAQs website

                            Qualified intermediary, withholding foreign partnership, and withholding foreign trust FAQs website

                            January 12, 2024

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                            Additional time and penalty relief for partnerships to provide complete Forms 8308 for 2023 section 751(a) exchanges

                            Notice 2024-19 provides relief from penalties under section 6722 for partnerships

                            January 11, 2024

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                            National Taxpayer Advocate report to Congress identifying taxpayer problems

                            Administrative and legislative recommendations to address problems

                            January 10, 2024

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                            Fourth Circuit: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed

                            A Fourth Circuit case concerning Maryland’s tax on digital advertising

                            January 10, 2024

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                            Accounting for income taxes considerations for the implementation of the Bermuda corporate income tax

                            KPMG report highlights selected accounting for income taxes considerations of the enactment of the regime under US GAAP

                            January 9, 2024

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                            KPMG reports: Florida, New York, multistate

                            KPMG reports focus on recent state and local tax developments

                            January 8, 2024

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                            IRS announces more time for dealers and sellers of clean vehicles to submit time-of-sale reports

                            Dealers and sellers have until January 19, 2024, to submit a time-of-sale report for vehicles sold January 1 through January 16, 2024.

                            January 5, 2024

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                            KPMG report: Proposed regulations on clean hydrogen production credit and related energy credit

                            Initial observations and analysis on the proposed regulations

                            January 5, 2024

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                            Federal Circuit: Butane not eligible for alternative fuel mixture tax credit

                            Butane is not an “alternative fuel” for purposes of section 6426

                            January 3, 2024

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                            Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)

                            Legal advice memorandum from the Office of Chief Counsel

                            January 2, 2024

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                            IRS annual revenue procedures for 2024

                            Internal Revenue Bulletin 2024-1

                            January 2, 2024

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                            IRS annual revenue procedures for 2024

                            Internal Revenue Bulletin 2024-1

                            January 2, 2024

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