KPMG TaxNewsFlash reports of tax developments in the United States
KPMG report: Effective dates and early reliance requirements in proposed CAMT regulations
Advantages and disadvantages of early adoption of proposed regulations
February 26, 2025
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
KPMG report: Partnership related-party basis adjustment transactions of interest
Reporting requirements imposed on both taxpayers and material advisors
February 26, 2025
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
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
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
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
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
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
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
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
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
KPMG report: Observations on the final Form 4626 Instructions for CAMT
Final Instructions for 2024 Form 4626, “Alternative Minimum Tax – Corporations”
February 12, 2025
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
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
KPMG report: Final regulations on clean hydrogen production credit and related energy credit
Initial observations and analysis on the final regulations
February 4, 2025
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
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
Senate confirms Scott Bessent as Treasury Secretary
U.S. Senate vote was 68-29
January 28, 2025
California: Property tax relief due to wildfires
Taxpayers generally must apply for reassessment within 12 months
January 28, 2025
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
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
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
KPMG article: Debt workouts in commercial real estate
Tax ramifications to borrowers looking to refinance properties
January 22, 2025
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
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
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
KPMG report: Regulations regarding digital content and cloud transactions
Analysis and observations on the final and proposed regulations
January 21, 2025
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
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
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
IRS updates FAQs for energy efficient home improvement and residential clean energy property credits
Supersede earlier FAQs posted in April 2024
January 17, 2025
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
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
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
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
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
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
KPMG article: Tax issues raised by development of valuable digital IP and data assets
Including transfer pricing issues
January 15, 2025
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
National Taxpayer Advocate report to Congress identifying taxpayer problems
Administrative and legislative recommendations to address problems
January 8, 2025
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
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
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
Final regulations: Clean hydrogen production credit and related energy credit
Final regulations apply to tax years beginning after December 26, 2023
January 3, 2025
IRS annual revenue procedures for 2025
Six annual revenue procedures
January 3, 2025
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
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
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
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
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
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
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
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
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
U.S. Tax Court: Active partners’ income subject to self-employment tax
The court upheld the IRS's adjustments.
December 23, 2024
Final regulations: Rules for supervisory approval of penalties
Proposed regulations adopted with minor modifications
December 20, 2024
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
IRS contingency plan during possible government shutdown
The IRS updates its contingency plan in anticipation of a possible government shutdown.
December 20, 2024
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
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
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
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
KPMG report: Proposed PTEP regulations
Analysis and observations
December 19, 2024
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
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
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
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
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
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
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
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
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
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
IRS provides new tax penalty relief for Maui wildfire victims
Relief is separate from disaster relief announced in August 2023
December 12, 2024
Louisiana: Several tax bills approved
Bills present significant reform of state tax structure.
December 12, 2024
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
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
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
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
IRS practice unit: Examining a reseller’s 263A computation
IRS Large Business and International division publicly released a “practice unit”
December 6, 2024
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
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
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
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
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
SALT Technology Checklist
A quarterly publication that summarizes technology-related state tax guidance and legislative developments
TWIST-Q
A quarterly roundup of This Week in State Tax (TWIST) podcasts which includes a detailed checklist of state tax legislative updates.
Proposed regulations: Previously taxed earnings and profits and related basis adjustments
Rules would address longstanding issues under sections 959 and 961
November 29, 2024
Final regulations: Recourse partnership liabilities and related party rules under section 752
Final rules adopt proposed regulations issued in December 2013
November 29, 2024
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
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
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
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
Tier 2 tax rates for railroads, no changes for 2025
Imposed on railroad employees, employers, and employee representatives
November 25, 2024
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
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
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
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
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
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
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
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
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
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
KPMG report: Notable highlights from section 48D final regulations (advanced manufacturing investment credit)
KPMG observations and analysis of the final regulations
November 14, 2024
KPMG report: Final regulations on advanced manufacturing production credit under section 45X
KPMG observations and analysis of the final regulations
November 14, 2024
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
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
Deductibility of FDIC special assessments not limited under section 162(r)
IRS Chief Counsel memorandum
November 12, 2024
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
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
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
IRS grants tax relief for taxpayers in Havasupai Tribe in Arizona affected by flooding
Deadlines extended to February 3, 2025
November 7, 2024
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
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
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
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
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
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
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
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
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
IRS provides tax relief to taxpayers affected by floods in Juneau, Alaska
Deadlines extended to May 1, 2025
October 25, 2024
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
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
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
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
United States: IRS issuing manual IDES notifications through October 31
Delayed distribution due to recent hurricanes
October 23, 2024
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
Rev. Proc. 2024-40: Inflation adjustments for 2025, individual taxpayers
Amounts to be used by individual taxpayers on their 2025 returns
October 22, 2024
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
Notice 2024-74: Additional guidance on safe harbors for sustainable aviation fuel credit
Guidance applies as of October 18, 2024.
October 18, 2024
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
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
Delaware: Changes to unclaimed property law
Many immediate and some retroactive changes
October 16, 2024
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
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
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
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
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
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
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
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
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
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
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
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
KPMG report: Exceptions under final broker digital asset reporting regulations
Closed loop transactions and limited access regulated networks
October 4, 2024
IRS Priority Guidance Plan for 2024-2025
The U.S. Treasury Department and IRS released the 2024-2025 Priority Guidance Plan.
October 4, 2024
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
KPMG report: Treatment of nonfungible tokens under the final broker reporting regulations
Overview of NFTs in final regulations
September 19, 2024
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
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
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
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
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
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
KPMG report: Initial observations on proposed CAMT regulations
Proposed regulation package created a host of questions for taxpayers and tax practitioners
September 16, 2024
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
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
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
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
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
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
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
Proposed regulations: Guidance on corporate alternative minimum tax (CAMT) confers exceptionally complex regime
Key highlights of the proposed regulations
September 12, 2024
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Delaware: Notices requesting “verified reports” of unclaimed property
The notices give companies 30 days to respond to the correspondence.
August 22, 2024
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
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
Proposed regulations: Revising qualified domestic trust regulations to update outdated references, procedures
Update current regulations under section 2056A
August 20, 2024
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
KPMG reports: Arizona, Illinois, Kansas, New Jersey, Washington State
KPMG reports focus on recent state and local tax developments
August 19, 2024
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
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
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
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
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
Announcement 2024-30: Second voluntary disclosure program for employee retention credit
Employers must apply by November 22, 2024
August 15, 2024
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
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
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
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
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
KPMG reports: Illinois, Massachusetts, Minnesota, Texas
KPMG reports focus on recent state and local tax developments
August 12, 2024
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
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
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
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
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
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
United States: IRS issues new FAQ for QI/WP/WT
Provisions for 2023 QI agreement
August 1, 2024
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
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
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
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
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
KPMG report: Expiring provisions in the 2025 “Tax Cliff”
Outline of many tax provisions set to expire
July 29, 2024
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
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
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
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
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
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
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
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
KPMG reports: Texas, Wisconsin, multistate
KPMG This Week in State Tax focuses on recent state and local tax developments.
July 22, 2024
KPMG report: APMA program annual report on APA statistics for 2023
Examination of the report and insights for taxpayers
July 22, 2024
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
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
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
KPMG reports: Florida, New Jersey, Oregon, Pennsylvania
KPMG reports focus on recent state and local tax developments
July 15, 2024
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
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
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
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
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
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
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
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
KPMG report: Inconsistency in state conformity to the Code
Overlooked complexities imposed by state incorporation of the Code
July 3, 2024
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
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
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
KPMG report: Specified research and experimentation expenditures under section 174
Similarities and differences between specified research expenditure product rights
July 2, 2024
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
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
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
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
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
California: Budget tax changes enacted
Details on key changes affecting business taxpayers
July 1, 2024
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
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
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
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
KPMG report: Treasury and IRS guidance on partnership “basis shifting” transactions
Initial analysis and observations
June 27, 2024
KPMG report: State, local tax changes (second quarter 2024, table format)
Report prepared by the KPMG State and Local Tax practice
June 27, 2024
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
IRS issues FAQs regarding educational assistance programs
Tax-free benefits up to $5,250 per calendar year
June 18, 2024
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
KPMG reports: California, Rhode Island, South Carolina
KPMG This Week in State Tax focuses on recent state and local tax developments.
June 17, 2024
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
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
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
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
IRS adds new FAQs to provide guidance to qualified intermediaries (QIs)
FAQs under the heading “Certifications and Periodic Reviews”
June 10, 2024
KPMG reports: Connecticut, Florida, South Carolina
KPMG This Week in State Tax focuses on recent state and local tax developments.
June 10, 2024
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
KPMG reports: Alabama, California, Tennessee
KPMG This Week in State Tax focuses on recent state and local tax developments.
May 20, 2024
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
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
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
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
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
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
Notice 2024-41: Modified domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E
Including new elective safe harbor
May 16, 2024
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
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
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
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
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
KPMG report: Accelerating Form 1099 deadlines, prioritizing taxpayer efficiency
Reasons for change and administrative issues that payors will need to address
May 10, 2024
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Tennessee: Franchise tax refund agreement reached
The governor is expected to sign the legislation.
April 26, 2024
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
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
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
KPMG reports: Georgia, Illinois, New Jersey
KPMG reports focus on recent state and local tax developments
April 22, 2024
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
KPMG report: Initial analysis of stock repurchase excise tax proposed regulations
A report that provides initial analysis of the proposed regulations
April 17, 2024
IRS updates FAQs for energy efficient home improvement and residential clean energy property credits
Supersede earlier FAQs posted in December 2022
April 17, 2024
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
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
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
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
KPMG reports: Florida, Pennsylvania, New York
KPMG reports focus on recent state and local tax developments
April 15, 2024
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
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
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
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
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
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
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
Proposed regulations: Guidance on new 1% excise tax on repurchases of corporate stock
Reporting and payment of the new excise tax
April 9, 2024
KPMG reports: Arizona, Kentucky, Minnesota
KPMG reports focus on recent state and local tax developments
April 8, 2024
KPMG report: Comments on expanding tax certainty and issue resolution programs for business taxpayers
KPMG comments with recommended potential changes
April 5, 2024
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
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
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
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
KPMG reports: Arkansas, Idaho, multistate
KPMG reports focus on recent state and local tax developments
April 1, 2024
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
Announcement 2024-16: APMA program, APA statistics for 2023
25th report describing the experience, structure, and activities of the APMA program
March 29, 2024
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
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
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
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
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
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
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
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
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
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
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
Proposed regulations: Taxpayer notification in advance of IRS contact with third parties
Determination or collection of the taxpayer’s tax liability
March 21, 2024
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
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
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
KPMG report: CHIPS Act tax credit—direct pay final regulations
Notable updates and deviations from the proposed regulations
March 19, 2024
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
KPMG reports: Montana, Oregon, Tennessee, multistate
KPMG This Week in State Tax focuses on recent state and local tax developments.
March 18, 2024
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
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
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
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
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
KPMG report: New beneficial ownership information reporting requirements
Origin of the new BOI reporting rule and new due diligence requirements
March 14, 2024
KPMG report: New proposed regulations on bad debt deductions for certain qualifying entities
Overview of rules in proposed regulations
March 13, 2024
United States and Turkey announce updated digital services tax agreement
Summary of political agreement between United States and Turkey
March 12, 2024
KPMG reports: Colorado, New Mexico, New York
KPMG reports focus on recent state and local tax developments
March 11, 2024
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
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
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
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
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
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
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
KPMG reports: California, Minnesota, Oklahoma, South Carolina
KPMG reports focus on recent state and local tax developments
March 4, 2024
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
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
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
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
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
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
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
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
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
KPMG reports: Alaska, Louisiana, New York, Wisconsin
KPMG This Week in State Tax focuses on recent state and local tax developments.
February 26, 2024
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
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
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
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
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
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
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
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
KPMG reports: New Jersey, Washington State, Wisconsin
KPMG This Week in State Tax focuses on recent state and local tax developments.
February 20, 2024
U.S. Treasury launches website tracking tax guidance under “Inflation Reduction Act”
Website tracking tax guidance issued under H.R. 5376
February 20, 2024
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
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
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
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
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
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
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
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
KPMG reports: Delaware, Illinois, South Dakota
KPMG This Week in State Tax focuses on recent state and local tax developments.
February 12, 2024
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
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
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
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
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
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
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
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
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
KPMG reports: Missouri, New York, multistate
KPMG reports focus on recent state and local tax developments
February 5, 2024
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
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
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
KPMG report: New year, changing information reporting and withholding (IRW) requirements
How organizations can prepare for electronic filing requirement threshold changes
January 31, 2024
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
KPMG reports: Colorado, New York, multistate
KPMG reports focus on recent state and local tax developments
January 29, 2024
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
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
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
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
Tennessee: Proposed legislation authorizing franchise tax refunds
Certain business in Tennessee are subject to the state’s franchise and excise taxes
January 25, 2024
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
KPMG reports: Florida, Massachusetts, Washington State
Recent state and local tax developments
January 23, 2024
KPMG report: Resurgence of transfer pricing penalties
IRS shift toward increased penalty assertion; procedural considerations for taxpayers
January 23, 2024
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
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
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
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
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
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
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
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
KPMG report: Key takeaways from recent CAMT releases
Summary of notable provisions and KPMG observations
January 17, 2024
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
KPMG reports: Connecticut, Pennsylvania, Michigan
KPMG reports focus on recent state and local tax developments
January 16, 2024
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
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
Updated beneficial ownership information reporting FAQs
Updated FAQs include new information about companies, beneficial owners, company applicants, requirements, and company exemptions
January 12, 2024
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
IRS announces changes to QI / WP / WT FAQs website
Qualified intermediary, withholding foreign partnership, and withholding foreign trust FAQs website
January 12, 2024
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
National Taxpayer Advocate report to Congress identifying taxpayer problems
Administrative and legislative recommendations to address problems
January 10, 2024
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
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
KPMG reports: Florida, New York, multistate
KPMG reports focus on recent state and local tax developments
January 8, 2024
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
KPMG report: Proposed regulations on clean hydrogen production credit and related energy credit
Initial observations and analysis on the proposed regulations
January 5, 2024
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
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
IRS annual revenue procedures for 2024
Internal Revenue Bulletin 2024-1
January 2, 2024
IRS annual revenue procedures for 2024
Internal Revenue Bulletin 2024-1
January 2, 2024
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