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
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