Recent Articles

March 2024

Mar 18 - KPMG report: Accounting for tax credits generated by pass-through entities

Mar 18 - KPMG report: Tax and trade considerations for U.S. inbound investment

Mar 18 - KPMG reports: Montana (water’s-edge election); Oregon (guidance for “foreign” corporations); Tennessee (franchise tax refunds); multistate (short-term rental obligations)

Mar 14 - Final rule: Responsibility for administering alcohol taxes moved from CBP to Treasury

Mar 14 - IRS adds FAQ to QI / WP / WT FAQs website

Mar 14 - KPMG report: New beneficial ownership information reporting requirements

Mar 13 - KPMG report: Final regulations on direct pay of certain tax credits under IRA, observations and analysis (updated March 15)

Mar 13 - KPMG report: New proposed regulations on bad debt deductions for certain qualifying entities

Mar 12 - United States and Turkey announce updated digital services tax agreement

Mar 11 - KPMG reports: Colorado (manufacturing exemption); New Mexico (individual and corporate income tax changes); New York (taxable information services)

Mar 8 - Arizona: Guidance on refund claims for invalidated Pinal County tax

Mar 7 - Notice 2024-28: Request for recommendations for IRS 2024-2025 Priority Guidance Plan

Mar 7 - IRS to waive dyed diesel fuel penalty in parts of Texas; wildfire-related relief

Mar 5 - Treasury and IRS issue final regulations, other guidance on direct pay of certain tax credits under IRA and CHIPS

Mar 4 - KPMG report: Taxpayer options for fixing federal tax return mistakes

Mar 4 - KPMG reports: California (dividends fully included in sales factor); Minnesota (retail delivery fee); Oklahoma (food sales tax); South Carolina (combined reporting)

February 2024

Feb 29 - Senate confirms Marjorie Rollinson to be IRS Chief Counsel

Feb 29 - Rev. Proc. 2024-15: Guidance on qualifying securitizations by public utilities

Feb 29 - IRS announces new effort focused on high-income non-filers

Feb 29 - IRS LB&I division adds new compliance campaign (business aircraft)

Feb 28 - IRS provides tax relief for taxpayers in Washington State affected by wildfires

Feb 27 - Notice 2024-26: Administrative exemption from requirement to electronically file Form 1042

Feb 27 - IRS provides tax relief for taxpayers in California affected by severe storms, flooding

Feb 27 - KPMG report: Post-pandemic state tax policies

Feb 26 - Notice of filing of petition for addition of iso-butanol to Superfund list

Feb 26 - KPMG report: Challenges and opportunities faced by CAMT “scope bubble corporations”

Feb 26 - KPMG reports: Alaska (marketplace facilitators sales tax); Louisiana (industrial tax exemption program); New York (wine producer as qualified manufacturer); Wisconsin (withholding on software licensing income)

Feb 22 - IRS announces plans to begin audits on personal use of business aircraft

Feb 21 - Filing of petitions for additions of caprolactam and nylon 6 to Superfund list

Feb 21 - IRS practice unit: Allocation and apportionment of R&E expenses for tax years beginning before January 1, 2020

Feb 21 - Rev. Rul. 2024-6: Interest rates, tax underpayments and overpayments remain same for second quarter 2024

Feb 21 - U.S. Tax Court: Decision in favor of IRS in case regarding limited partner exception to self-employment income

Feb 21 - U.S. Tax Court: Financing costs, including bond fees, properly included in eligible basis for purposes of low-income housing tax credit

Feb 20 - U.S. Treasury launches website tracking tax guidance under “Inflation Reduction Act”

Feb 20 - KPMG reports: New Jersey (substantiation of sales tax refund claims); Washington State (B&O tax on reimbursements); Wisconsin (pre-combined reporting NOLs)

Feb 16 - Correction to proposed regulations on energy credit under section 48, relating to certain gas upgrading equipment

Feb 16 - Final Form 4626 and instructions for corporate alternative minimum tax (CAMT)

Feb 16 - GLAM: Liability of third-party payers for improperly claimed employee retention credits

Feb 15 - U.S. Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

Feb 15 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Feb 15 - IRS provides tax relief for taxpayers in Michigan affected by severe storms, tornadoes and flooding

Feb 15 - KPMG report: California court decision on interstate tax law

Feb 13 - Application period for environmental justice solar and wind capacity limitation program closing February 29

Feb 12 - Rev. Proc. 2024-14: Indexing adjustments for amounts used to calculate employer shared responsibility payments

Feb 12 - KPMG reports: Delaware (unclaimed property voluntary disclosure agreement program); Illinois (tax treatment when mobile app used to purchase fuel); South Dakota (use tax on equipment)

Feb 8 - KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups

Feb 8 - KPMG report: Implications of proposed changes to sections 174 and 280C in bipartisan tax extenders legislation

Feb 8 - KPMG report: State and local tax, technology-related developments (table, fourth quarter 2023)

Feb 7 - Rev. Proc. 2024-12: Temporary extension of time to submit seller reports for transfers of clean vehicle credits

Feb 7 - IRS provides tax relief for taxpayers in West Virginia affected by severe storms, flooding, landslides, and mudslides

Feb 6 - IRS provides revised FAQs on Form 1099-K

Feb 6 - Rev. Proc. 2024-13: Automobile depreciation deduction limits for 2024

Feb 5 - IRS provides tax relief for taxpayers in Maine affected by severe storms, flooding

Feb 5 - KPMG report: Navigating the shifting landscape of research credit audits

Feb 5 - KPMG report: State and local tax changes affecting entities in asset management industry in 2023

Feb 5 - KPMG reports: Missouri (REIT dividends deductible); New York (qualified emerging technology company); multistate (worldwide combined reporting)

Feb 2 - KPMG report: Mexican rulings on exportation of services eligible for 0% VAT

January 2024

Jan 31 - KPMG report: New year, changing information reporting and withholding (IRW) requirements

Jan 30 - KPMG report: SEC comments on accounting for income taxes

Jan 29 - KPMG report: Practical tax mechanics of implementing SEC clawbacks

Jan 29 - KPMG reports: Colorado (sales and use tax); New York (property tax exclusion); multistate (online marketplace sales)

Jan 26 - IRS provides tax relief for taxpayers in Rhode Island affected by severe storms, flooding, and tornadoes

Jan 26 - KPMG report: Avoiding common pitfalls in oil and gas reserve valuations for U.S. tax purposes

Jan 25 - Notice 2024-23: Special relief for certain rollovers to or from Maryland prepaid college trust accounts

Jan 25 - Tennessee: Proposed legislation authorizing franchise tax refunds

Jan 22 - Comment period reopened for proposed regulations on federal independent dispute resolution (IDR) process

Jan 22 - IRS provides tax relief for taxpayers in Connecticut affected by severe storms

Jan 22 - KPMG report: Resurgence of transfer pricing penalties

Jan 22 - KPMG reports: Florida (sales factor litigation); Massachusetts (corporate excise tax changes); Washington State (capital gains as excise tax case)

Jan 19 - Notice 2024-20: Guidance on qualified alternative fuel vehicle refueling property credit under section 30C

Jan 19 - IRS LB&I division adds a new compliance campaign (sports industry losses)

Jan 18 - Final regulations: Guidance on minimum present value requirements for certain defined benefit plans

Jan 18 - KPMG report: Reporting and paying the stock repurchase excise tax—not quite yet

Jan 18 - KPMG report: Updated accounting method change procedures and clarification of rules addressing capitalization of research and experimentation costs under section 174

Jan 17 - KPMG report: Key takeaways from recent CAMT releases

Jan 16 - Announcement 2024-4: Transitional guidance on reporting of information on receipt of digital assets

Jan 16 - KPMG reports: Connecticut (solar electricity property tax exemption); Pennsylvania (sourcing); Michigan (income tax nexus)

Jan 12 - IRS announces continued enforcement efforts related to high-income individuals, large corporations, complex partnerships

Jan 12 - Notice 2024-18: Updated guidance on availability of administrative exemptions from requirement to file electronically

Jan 12 - Notice 2024-22: Initial guidance on pension-linked emergency savings accounts

Jan 12 - Updated beneficial ownership information reporting FAQs

Jan 11 - Notice 2024-19: Additional time and penalty relief for partnerships to provide complete Forms 8308 for 2023 section 751(a) exchanges

Jan 11 - IRS announces changes to QI / WP / WT FAQs website

Jan 10 - Fourth Circuit: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed

Jan 10 - National Taxpayer Advocate report to Congress identifying taxpayer problems

Jan 9 - KPMG report: Accounting for income taxes considerations for the implementation of the Bermuda corporate income tax

Jan 8 - KPMG reports: Florida (sales and use tax); New York (corporate franchise tax reforms); multistate (P.L. 86-272)

Jan 5 - KPMG report: Proposed regulations on clean hydrogen production credit and related energy credit

Jan 5 - IRS announces more time for dealers and sellers of clean vehicles to submit time-of-sale reports

Jan 3 - Federal Circuit: Butane not eligible for alternative fuel mixture tax credit

Jan 2 - Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)

Jan 2 - IRS annual revenue procedures for 2024

2023 Articles

December 2023

Dec 29 - Announcement 2024-5: Termination of United States-Hungary tax treaty effective January 1, 2024

Dec 29 - Notice 2024-13: Request for comments on product identification number requirement for energy efficiency home improvement

Dec 28 - Notice 2024-9: Transitional procedures for applicable entities to claim statutory exceptions to phaseouts for clean energy credits if domestic content requirements not met

Dec 28 - Notice 2024-11: Updated list of treaties meeting qualified dividend requirements adds Chile, removes Hungary and Russia

Dec 28 - Notice 2024-16: Guidance on the application of section 961 to certain inbound nonrecognition transactions

Dec 27 - Proposed regulations: Guidance on bad debt deductions for regulated financial companies and members of regulated financial groups

Dec 26 - IRS updates FAQs on clean vehicle credits

Dec 26 - IRS extends QI/WP/WT certification due date

Dec 22 - Proposed regulations: Guidance on clean hydrogen production credit under section 45V and related energy credit under section 48(a)(15)

Dec 22 - Announcement 2024-3: New voluntary disclosure program for employee retention credit

Dec 22 - IRS announces tool for elective payment or transfer of credits under IRA and CHIPS

Dec 22 - IRS provides tax relief for taxpayers in Tennessee affected by tornadoes and severe storms

Dec 22 - Notice 2024-12 and Rev. Proc. 2024-9: Modified guidance on application of section 174

Dec 22 - KPMG report: Foreign tax credits for multinationals

Dec 22 - KPMG report: Proposed regulations on advanced manufacturing production credit under section 45X

Dec 20 - Notice 2024-2: Guidance on certain provisions of Secure Act 2.0

Dec 20 - Notice 2024-3: 2023 cumulative list of changes in plan qualification requirements for defined contribution qualified pre-approved plans

Dec 20 - Notice 2024-5: Safe harbor for “incremental cost” of commercial clean vehicles eligible for tax credit under section 45W

Dec 20 - Notice 2024-7: Relief from additions to tax for failure to pay with respect to certain 2020 and 2021 income tax returns (COVID-19)

Dec 20 - FBAR filings: Extended deadline is April 15, 2025, for individuals with signature authority

Dec 20 - KPMG report: Preparing for the new excise tax under section 5000D on sales of specified drugs

Dec 19 - Tax treaty update: Income tax treaty with Chile enters into force

Dec 19 - Notice 2024-1: Indexing factor for use by group health plans and health insurance issuers in 2024 under “No Surprises Act” provisions

Dec 19 - KPMG report: Accounting standards update includes improvements to income tax disclosures

Dec 18 - Final regulations: De minimis error safe harbor exceptions to penalties for failure to file correct information returns or furnish correct payee statements

Dec 18 - Final regulations: Federal independent dispute resolution (IDR) process administrative fee and certified IDR entity fee ranges

Dec 18 - Rev. Proc. 2023-36: Updated list of jurisdictions for exchanging deposit interest information

Dec 18 - Rev. Rul. 2024-1: Covered compensation tables for 2024 plan year

Dec 18 - KPMG report: IRS enforcement on high-income and high-wealth individuals

Dec 18 - KPMG report: State, local tax changes (year-end checklist and fourth quarter 2023)

Dec 15 - Notice 2024-10: Additional interim guidance on new corporate alternative minimum tax (CAMT)

Dec 15 - Notice 2024-6: Additional guidance on new sustainable aviation fuel credits

Dec 14 - Proposed regulations: Implementation of advanced manufacturing production credit under section 45X

Dec 14 - Notice 2024-8: Standard mileage rates for 2024

Dec 13 - IRS announces plans for new leadership structure

Dec 12 - Updated beneficial ownership information reporting FAQs

Dec 11 - Notice 2023-80: Guidance on application of FTC and DCL rules to Pillar Two taxes, extension and modification of temporary FTC relief

Dec 11 - KPMG report: Tax-free fixed indemnity healthcare for employees

Dec 11 - KPMG reports: New York (sales tax on party platters); Pennsylvania (Philadelphia voluntary disclosure program); Washington State (B&O and sales tax guidance)

Dec 8 - Notice 2023-79: Required amendments list (2023) for qualified retirement plans and 403(b) plans

Dec 7 - Rev. Proc. 2023-41: Insurance companies, unpaid loss discount factors for 2023 accident year

Dec 6 - IRS announces continued increased scrutiny of employee retention credit claims

Dec 6 - KPMG report: Transitory relief for Forms 1099-K

Dec 4 - KPMG report: Proposed regulations on investment tax credit for energy property under section 48

Dec 4 - KPMG reports: Illinois (constitutionality of retailer’s occupation tax); Minnesota (goodwill gain is apportionable business income); Washington State (sales and B&O tax)

Dec 1 - Proposed regulations and Rev. Proc. 2023-38: Guidance on excluded entity provisions under section 30D clean vehicle credit

Dec 1 - IRS practice unit: Taxation of beneficiary of a foreign non-grantor trust

Dec 1 - Updated guidance on beneficial ownership information reporting requirements

November 2023

Nov 29 - Final regulations: Extended filing deadline for initial beneficial ownership information reports

Nov 28 - U.S. Tax Court: Court has jurisdiction to determine in partnership-level proceeding application of limited partner exception to self-employment income

Nov 27 - IRS provides tax relief for taxpayers in Illinois affected by storms

Nov 27 - IRS provides tax relief for taxpayers in St. Croix affected by elevated levels of lead and copper in water supply

Nov 27 - Tier 2 tax rates for railroads, no changes for 2024

Nov 24 - Proposed regulations: Amendments to apply entity approach to partnership loss disallowance rules under sections 267 and 707

Nov 24 - Proposed regulations: Guidance under section 401(k) for long-term, part-time employees

Nov 21 - Notice 2023-74: Further delay of implementation of $600 reporting threshold for Forms 1099-K; $5000 threshold for 2024 to phase in implementation

Nov 21 - Rev. Proc. 2023-37: Rules for qualified pre-approved plans and 403(b) pre-approved plans

Nov 21 - KPMG report: IRS hearing on digital asset proposed regulations

Nov 20 - KPMG reports: California (inclusion of dividends in sales factor); Florida (proposed sales tax holiday); Louisiana (sales tax on online car sharing)

Nov 17 - Proposed regulations: Disallowance of deductions for certain conservation easement contributions by partnerships, S corporations

Nov 17 - Proposed regulations: Guidance on energy credit under section 48 as amended by “Inflation Reduction Act”

Nov 17 - Proposed regulations: Guidance on various issues under “Affordable Care Act”

Nov 17 - Interim final rule: Amended definition of “obligation” regarding state and local fiscal recovery funds (COVID-19)

Nov 17 - Rev. Rul. 2023-22: Interest rates, tax underpayments and overpayments remain same for first quarter 2024

Nov 17 - Updated draft CAMT form

Nov 16 - Reply brief for petitioners in Moore case

Nov 16 - Updated beneficial ownership information reporting FAQs

Nov 16 - Delaware: Notices requesting “verified reports” of unclaimed property

Nov 16 - KPMG report: U.S. Tax Court decision upholding IRS determination that fund engaged in U.S. trade or business

Nov 15 - U.S. Tax Court: Partnership engaged in U.S. trade or business based on activities of asset manager

Nov 13 - KPMG report: Adjusting closed-year partnership-related items

Nov 13 - KPMG reports: Maine (service receipts); Missouri (resale exemption for use tax); Ohio (agent exclusion from CAT base); Texas (increase in franchise tax exemption)

Nov 11 - KPMG report: Proposed regulations under section 987, initial observations and analysis

Nov 9 - Proposed regulations: Income, currency gain or loss of QBU (section 987); comment period reopening for 2016 proposed regulations

Nov 9 - Rev. Proc. 2023-34: Inflation adjustments for 2024, individual taxpayers

Nov 8 - U.S. Tax Court: Brazilian legal restriction not taken into account in determining arm’s length transfer price under section 482

Nov 8 - U.S. Tax Court: Section 904(f)(3)(A) does not prevent recognition of gain in excess of overall foreign loss account or recharacterize such gain as foreign source income

Nov 8 - KPMG report: Section 451(b) and specified fees

Nov 6 - KPMG reports: New Jersey (corporation business tax); New York (new employee displacement tax); Texas (data processing services)

Nov 2 - Hearing on proposed regulations concerning digital asset transactions rescheduled to November 13

Nov 2 - U.S. Tax Court: Exchange of variable prepaid forward contracts (VPFCs) taxable under section 1234A as short-term capital gain

Nov 1 - Notice 2023-75: Pension plans, cost-of-living adjustments for 2024

October 2023

Oct 30 - IRS extends acceptance of digital signatures, encrypted emails

Oct 30 - IRS adds two FAQs to QI / WP / WT FAQs website

Oct 30 - KPMG reports: California (Proposition 39 upheld); Kansas (corporate income tax rate reduction); New York (sales tax on clothing); Utah (sales tax on bundled digital subscription fees)

Oct 27 - Proposed regulations: Guidance under No Surprises Act, including federal independent dispute resolution (IDR) process

Oct 27 - KPMG report: Transfer pricing and international tax year-end considerations

Oct 27 - KPMG report: State and local tax, technology-related developments (table, third quarter 2023)

Oct 24 - Extension of comment period for proposed regulations on digital asset transactions

Oct 23 - U.S. Treasury to allocate $5 billion in New Markets Tax Credit (NMTC) authority for 2023

Oct 23 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Oct 23 - KPMG reports: Impact of proposed U.S. broker digital asset tax reporting regulations on industry verticals (updated with new reports)

Oct 23 - KPMG reports: Illinois (Chicago real estate transfer tax); Florida (communications services tax); Massachusetts (local option real estate transfer fees); New Mexico (taxation of digital advertising)

Oct 20 - IRS announces new compliance initiatives aimed at large corporations

Oct 20 - IRS LB&I division memorandum to employees on compliance priorities

Oct 19 - Final and proposed regulations: Mortality tables for determining present value under defined benefit pension plans

Oct 19 - Notice 2023-73: Mortality table for use in determining minimum present value for 2024

Oct 19 - IRS announces special withdrawal process for employee retention credit claims

Oct 19 - KPMG report: Questions remain on Superfund excise tax compliance

Oct 18 - Notice 2023-70: Self-insured health insurance annual fee

Oct 17 - Government files brief in Moore case

Oct 16 - FBAR filing deadline relief for filers affected by terroristic action in Israel

Oct 16 - IRS provides tax relief for taxpayers in California affected by winter natural disasters

Oct 16 - KPMG report: Analysis of relief provisions of Rev. Proc. 2013-30 for late S corporation elections

Oct 16 - KPMG report: IRS announcement of new large partnership audits

Oct 16 - KPMG report: Voluntary and mandatory disclosure requirements and options

Oct 16 - KPMG reports: New Jersey (guidance on various corporation business tax issues); Wisconsin (transfer of title constituted sale for sales tax purposes)

Oct 13 - Notice 2023-71: IRS provides relief for taxpayers affected by terroristic action in Israel

Oct 13 - KPMG reports: Impact of proposed U.S. broker digital asset tax reporting regulations on industry verticals

Oct 13 - IRS updates FAQ on QI / WP / WT website to provide guidance on WP / WT agreement renewals

Oct 12 - U.S. Supreme Court schedules oral arguments in Moore case for December 5

Oct 12 - Disallowance of section 168(k) additional first-year allowance for depreciation for “excepted trade or business” (Chief Counsel legal advice memo)

Oct 9 - KPMG reports: California (application of P.L. 86-272 to internet sellers); Florida (electronically delivered software not subject to sales tax); Massachusetts (corporate excise tax); Tennessee (sales tax on place of amusement)

Oct 6 - Proposed regulations, Rev. Proc. 2023-33, and updated FAQs: Guidance on transfer of clean vehicle credits under sections 25E and 30D

Oct 5 - Proposed regulations: Guidance under section 367(b) relating to certain triangular reorganizations and inbound nonrecognition transactions

Oct 5 - Purchaser of foreign goods not an “importer” liable for excise tax under section 4071 (federal district court)

Oct 4 - Washington State: Penalties on unfiled annual reconciliation of apportionable income

Oct 3 - IRS request for information on requiring health insurance coverage of over-the-counter preventive items under Affordable Care Act

Oct 2 - IRS practice unit: Foreign tax credit—categorization of income and taxes into proper basket (updated August 1)

Oct 2 - KPMG reports: Iowa (reduced corporate income tax rates); Massachusetts (pending tax law changes, including for corporate excise tax); Oregon (Portland business license tax credit); Texas (sales and use tax guidance for electronic games)

September 2023

Sep 29 - IRS Priority Guidance Plan for 2023-2024

Sep 29 - IRS provides tax relief for taxpayers in Louisiana affected by seawater intrusion

Sep 29 - Rev. Proc. 2023-35: Wash sale relief for certain redemptions of shares in money market funds

Sep 29 - Additional guidance on beneficial ownership information reporting requirements

Sep 28 - IRS contingency plan during possible government shutdown

Sep 28 - Notice 2023-69: Guidance on employer leave-based donation programs aiding Hawaii wildfire victims

Sep 28 - KPMG report: New CAMT guidance in Notice 2023-64 expands scope, increases compliance burdens

Sep 27 - Application period for environmental justice solar and wind capacity limitation program opens October 19

Sep 27 - Proposed regulations: Guidance on procedural requirements for section 5000D excise tax on sales of “designated drugs”

Sep 27 - Proposed regulations: Extended filing deadline for certain beneficial ownership information reports

Sep 27 - U.S. Tax Court: 30-day time limit for requesting collection due process hearing subject to equitable tolling

Sep 27 - Notice 2023-67: Farmers, ranchers affected by drought allowed more time to replace livestock

Sep 27 - Notice 2023-65: Guidance on new energy efficient home credit under section 45L

Sep 26 - Notice of hearing: Proposed regulations on reinstated Superfund chemical tax and Superfund imported substance tax

Sep 25 - Notice 2023-68: Per diem rates, substantiation of employee lodging, meals, incidentals (2023-2024)

Sep 25 - IRS provides tax relief for taxpayers in Maine and Massachusetts affected by Hurricane Lee

Sep 25 - KPMG report: State, local tax changes (third quarter 2023, table format)

Sep 25 - KPMG reports: Missouri (sales tax collection); North Carolina (sourcing rules); Tennessee (sales and use tax industrial machinery exemption); Washington State (manufacturing B&O tax)

Sep 25 - KPMG report: Initial observations on round 4 of CAMT guidance in Notice 2023-64

Sep 22 - Treasury awards $5 billion in New Markets Tax Credit (NMTC) allocations

Sep 21 - Proposed regulations: Federal independent dispute resolution (IDR) process administrative fee and certified IDR entity fee ranges

Sep 21 - Federal Circuit: Claims court erred in applying hybrid legal standard conflating step transaction and economic substance doctrines

Sep 20 - IRS announces new work unit focused on large or complex passthrough entities to help with high-income compliance efforts

Sep 19 - Interim final rule concerning state and local fiscal recovery funds (COVID-19)

Sep 18 - KPMG reports: Arkansas (proposed reduction in income tax rates); Florida (guidance on sales and use tax audit program); Kansas (reduction in corporate income tax rate); Oregon (guidance on P.L. 86-272); Tennessee (industrial machinery sales tax exemption)

Sep 15 - IRS request for comments on expanding tax certainty and issue resolution programs for business taxpayers

Sep 15 - IRS request for feedback on proposed changes to Form 6765, Credit for Increasing Research Activities

Sep 14 - IRS announces moratorium on processing new employee retention credit claims

Sep 13 - KPMG report: Initial observations and analysis of Notice 2023-63 providing guidance on section 174

Sep 13 - IRS provides tax relief for taxpayers in Georgia affected by Hurricane Idalia

Sep 12 - Notice 2023-64: Additional interim guidance on new corporate alternative minimum tax (CAMT)

Sep 12 - FBAR filing deadline relief for persons affected by certain natural disasters (Hawaii wildfires and Hurricane Idalia)

Sep 11 - First Circuit: Immediate recognition of income upon constructive transfer of intangible property in reorganization; Tax Court affirmed

Sep 11 - KPMG reports: California (marketplace facilitator law); California (mutual fund service provider sourcing rule); New Jersey (corporation business tax nexus); New York (broker-dealer sourcing rule)

Sep 8 - KPMG report: Proposed regulations on prevailing wage and apprenticeship requirements under clean energy tax incentives

Sep 8 - IRS announces new compliance effort focused on high-income individuals, partnerships, and large corporations

Sep 8 - IRS announces all QI / WP / WT applications for 2023 must be submitted through QAAMS by October 27

Sep 8 - Notice 2023-63: Guidance on application of section 174

Sep 6 - IRS opens application period for 2024 Compliance Assurance Process (CAP) program

Sep 6 - IRS provides tax relief for taxpayers in South Carolina affected by Hurricane Idalia

Sep 5 - IRS releases FAQ for pass-through entities for electronically filing Schedules K-2 and K-3 to report negative amounts

August 2023

Aug 31 - IRS provides tax relief for taxpayers in Florida affected by Hurricane Idalia

Aug 30 - Notice 2023-56: Guidance on state and local tax refunds and other payments to individuals

Aug 30 - KPMG report: Proposed regulations expand tax information reporting on digital asset transactions

Aug 30 - IRS provides tax relief for taxpayers in Alaska affected by flooding

Aug 29 - Proposed regulations: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

Aug 28 - KPMG reports: Louisiana (sales and use tax); New Jersey (corporation business tax)

Aug 25 - Proposed regulations: Information reporting, determination of amount realized and basis, and backup withholding for digital asset transactions

Aug 25 - Notice 2023-62: Guidance on new Roth catch-up requirement, including administrative transition period

Aug 25 - Rev. Rul. 2023-17: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2023)

Aug 25 - IRS updates 2023 Form 1042-S instructions

Aug 25 - KPMG report: Potential U.S. tax implications of proposed Bermuda corporate income tax

Aug 24 - Fourth quarter update to IRS 2022-2023 Priority Guidance Plan

Aug 24 - IRS updates FAQ extending penalty relief, Forms 1042 and 1042-S

Aug 23 - Rev. Proc. 2023-29: Premium tax credit percentage table for 2024

Aug 22 - KPMG report: Origin of the qualified intermediary (QI) program

Aug 21 - IRS provides tax relief for taxpayers affected by wildfires in Hawaii

Aug 21 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Aug 21 - KPMG reports: Pennsylvania (lookback period for voluntary disclosure agreement program); Tennessee (employment services not subject to sales and use tax)

Aug 18 - IRS notices: Oil and gas—reference prices for 2023, inflation adjustment factor and phase-out for enhanced oil recovery credit

Aug 16 - IRS provides tax relief for taxpayers in Illinois affected by storms

Aug 15 - KPMG report: Select financial product provisions in Biden Administration’s FY 2024 budget

Aug 15 - IRS provides tax relief for taxpayers in Mississippi affected by storms

Aug 14 - KPMG reports: Navigating CAMT

Aug 14 - KPMG reports: New Jersey (convenience of employer rule); New York (corporate franchise tax); South Carolina (method of apportionment)

Aug 11 - Notice 2023-60: Availability of administrative exemptions from requirement to file electronically

Aug 10 - Final regulations and Rev. Proc. 2023-27: Guidance on environmental justice solar and wind capacity limitation

Aug 9 - Seventh Circuit: Deduction for assumed deferred compensation liabilities not allowed when not paid; Tax Court affirmed

Aug 9 - Interim final rule concerning state and local fiscal recovery funds; OIRA review completed (COVID-19)

Aug 8 - D.C. Circuit: Exaction related to employer mandate under Affordable Care Act is a tax for jurisdictional purposes

Aug 8 - IRS adds a new compliance campaign (LB&I division)

Aug 7 - KPMG reports: California (apportionment formula); Michigan (sales factor, taxation of digital goods); New Hampshire (deduction for disallowed interest); Ohio (oil and gas sales and use tax exemption)

Aug 4 - Proposed regulations: Amendments to consolidated return regulations to reflect statutory changes, modernize language, and enhance clarity

Aug 4 - Notice 2023-59: Guidance on qualification of home energy audits for energy efficient home improvement credit under section 25C

Aug 4 - Notice 2023-52: Guidance on section 5000D excise tax on sales of “designated drugs”

Aug 3 - KPMG report: Draft forms provide insight into compliance burden imposed by new CAMT

Aug 3 - Proposed regulations: Monetized installment sale transactions identified as listed transactions

Aug 1 - KPMG report: Validating Form W-8BEN and BEN-E treaty claims

July 2023

Jul 31 - Proposed regulations: Implementation of amended nonquantitative treatment limitation comparative analyses requirements for health plans

Jul 31 - Rev. Rul. 2023-14: Cryptocurrency rewards included in income when taxpayer gains dominion and control over rewards

Jul 31 - KPMG reports: California (sales tax audit methods); New Jersey (convenience of employer rule); Oklahoma (franchise tax returns): Texas (franchise tax reports)

Jul 28 - IRS clarifies position on employee retention credit supply chain disruptions (generic legal advice memorandum)

Jul 27 - IRS request for comments on dispute resolution programs

Jul 27 - Third Circuit: Legal expenses for defending patent infringement suits are deductible

Jul 27 - KPMG report: Accounting for income taxes considerations for foreign tax credits following Notice 2023-55

Jul 27 - KPMG report: State and local tax, technology-related developments (table, second quarter 2023)

Jul 25 - IRS notices: Percentage depletion for oil and gas produced from marginal properties; electricity production credit

Jul 24 - Final regulations: Recapture of excess employment tax credits under COVID-19 legislation

Jul 24 - KPMG reports: California (tax on lease of tangible personal property); Mississippi (computer software direct pay permits)

Jul 21 - Notice 2023-55: Temporary relief for foreign tax credit under sections 901 and 903

Jul 19 - Third Circuit: 90-day time limit to file deficiency petition is not jurisdictional and thus subject to equitable tolling

Jul 18 - Delaware: Letters sent inviting companies to join unclaimed property voluntary disclosure agreement program, 90 days to respond

Jul 18 - KPMG report: Underutilization of alternative dispute resolution programs

Jul 17 - KPMG reports: Hawaii (fuel tax replacement); Maryland (digital advertising tax); Massachusetts (software providers as manufacturing corporations); New Jersey (corporation business tax changes)

Jul 14 - Notice 2023-54: Transition relief and guidance related to certain required minimum distributions

Jul 14 - Notice of filing of petition for addition of methyl ethyl ketoxime to Superfund list

Jul 13 - IRS practice unit: Expatriation on or after June 17, 2008—mark-to-market tax regime

Jul 13 - IRS provides tax relief for taxpayers in Vermont affected by flooding

Jul 13 - KPMG report: State conformity to federal treatment of section 174 R&E costs

Jul 13 - KPMG report: Tax credits for sustainable aviation fuel

Jul 10 - Final regulations: Carryback of consolidated net operating losses

Jul 10 - New Jersey: Corporation business tax changes enacted

Jul 10 - KPMG report: REITs and the new corporate alternative minimum tax

Jul 7 - Proposed regulations: Definitions of short-term, limited-duration insurance and excepted benefits coverage, tax treatment of certain accident and health insurance

Jul 6 - U.S. Tax Court: Section 41 research tax credit denied, accuracy-related penalties imposed

Jul 6 - Ninth Circuit: Partnership losses claimed on unsigned, unfiled tax returns disallowed; Tax Court reversed

Jul 3 - U.S. Tax Court: Period of limitations for assessing tax on partnership items expired

June 2023

Jun 30 - U.S. Tax Court: Period of limitations for assessing tax on partnership items expired

Jun 29 - Final regulations: Additional guidance on transition from interbank offered rates (IBORs) to other reference rates for foreign banks with ECI

Jun 29 - Announcement 2023-18: Taxpayers not required to report or pay stock repurchase excise tax before time specified in forthcoming regulations

Jun 27 - KPMG report: Analysis and observations of direct pay and transferable credit proposed regulations

Jun 26 - U.S. Supreme Court grants certiorari, whether mandatory repatriation tax under section 965 is constitutional

Jun 26 - IRS practice unit: Foreign tax credit—categorization of income and taxes into proper basket

Jun 26 - KPMG report: State, local tax changes (second quarter 2023, table format)

Jun 26 - KPMG reports: Alabama (monthly sales tax filing threshold); Michigan (memo not a request for refund); Texas (sales and use tax exemptions); Washington State (data processing)

Jun 23 - Notice 2023-37: Guidance related to COVID-19 for purposes of high-deductible health plans

Jun 23 - Notice 2023-46: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2023

Jun 23 - Notice 2023-49: Reference price for enhanced oil recovery credit, marginal oil and gas production

Jun 23 - U.S. Court of Federal Claims: Value of anticipated cash grants are separate intangible assets for purchase price allocation purposes

Jun 22 - Tax treaty update: Senate votes to approve income tax treaty with Chile

Jun 21 - Tax treaty update: Senate votes to invoke cloture on income tax treaty with Chile

Jun 21 - U.S. Tax Court: Passthrough net operating loss carryovers disallowed due to insufficient basis

Jun 21 - National Taxpayer Advocate mid-year report to Congress identifying key objectives for upcoming fiscal year

Jun 20 - Renewable electricity production inflation factors, reference prices for 2023

Jun 16 - KPMG report: State tax implications of “Inflation Reduction Act”

Jun 15 - Notices 2023-45 and 2023-47: Updated guidance on requirements for energy community production and investment tax credits

Jun 15 - Rev. Proc. 2023-24: Updated annual list of automatic accounting method changes

Jun 14 - Treasury and IRS release guidance on direct pay and transferable tax credits

Jun 12 - Treasury, OMB agreement no longer requires OIRA review for tax regulatory actions issued by IRS

Jun 12 - Tax treatment of employer-funded, fixed-indemnity insurance policy (Chief Counsel legal advice memo)

Jun 12 - KPMG reports: Connecticut (corporate surcharge extension); Illinois (investment partnership status changes); Louisiana (sales tax economic nexus threshold change); Mississippi (no good faith basis for exempt sales); Oklahoma (franchise tax repealed)

Jun 7 - Notice 2023-42: Estimated tax penalty relief for corporations subject to CAMT

Jun 7 - KPMG report: U.S. foreign tax credit issues arising from 2022 Colombian tax reform

Jun 6 - Proposed regulations: Malta personal retirement scheme transactions identified as listed transactions

Jun 6 - KPMG report: State nil reporting and penalty notices

Jun 5 - Eighth Circuit: Value of stock held by estate included life insurance proceeds intended for redemption of such stock

Jun 5 - Notice 2023-41: Reference price for section 45I credit for production of natural gas from marginal wells

Jun 5 - President Biden to nominate Marjorie Rollinson as IRS Chief Counsel

Jun 5 - KPMG reports: Colorado (commercial property tax valuations); Minnesota (retail delivery fee); Nebraska (corporate income tax rate reduction); Virginia (manufacturer’s apportionment formula)

Jun 2 - KPMG report: Accounting for tax credits handbook

Jun 1 - Final regulations: Updated actuarial tables for valuing annuities, terms of years, and remainder interests

Jun 1 - Tax treaty update: Senate Foreign Relations Committee votes to advance income tax treaty with Chile to full Senate vote

May 2023

May 31 - Proposed regulations: Additional guidance on environmental justice solar and wind capacity limitation under section 48(e)

May 31 - Notice 2023-44: Additional guidance on qualifying advanced energy project credit under section 48C(e)

May 31 - Minnesota: Retail delivery fee imposed on retailers effective July 1, 2024

May 31 - New York State: Changes to metropolitan commuter transportation mobility tax self-employment tax

May 25 - Notice 2023-43: Guidance regarding expansion of employee plans compliance resolution system under Secure Act 2.0

May 25 - IRS announces tax relief for taxpayers affected by Typhoon Mawar (Guam and Northern Mariana Islands)

May 25 - Minnesota: Omnibus tax package with revenue raisers enacted

May 24 - KPMG report: Analysis and observations of proposed section 367(d) regulations addressing certain intangible property repatriations

May 24 - IRS expanding determination letter program to include certain section 403(b) plans

May 22 - U.S. Tax Court: Gift tax assessment time-barred (updated with KPMG observations)

May 22 - Application of the FIRPTA regularly traded exception to stock held by partnerships (Chief Counsel legal advice memo)

May 22 - Rev. Rul. 2023-11: Interest rates, tax underpayments and overpayments remain same for third quarter 2023

May 22 - KPMG report: Domestic content bonus credit guidance under Notice 2023-38

May 22 - KPMG report: Treatment of captive insurance arrangements as insurance companies for tax purposes

May 22 - KPMG reports: Minnesota (omnibus tax package); Montana (bill to exclude tax haven entities); Tennessee (tax changes enacted)

May 19 - U.S. Supreme Court: IRS summonses issued to banks of taxpayer’s wife and taxpayer’s lawyers upheld

May 17 - U.S. Tax Court: Expenses under orphan drug credit under section 45C must also be taken in account in determining research credit under section 41

May 16 - Rev. Proc. 2023-23: HSA inflation-adjusted amounts for 2024

May 16 - IRS practice units: Interest expense limitations under sections 267(a)(3) and 163(j); dividend distribution with a debt

May 16 - IRS report on potential free e-filing system; pilot program for 2024 filing season

May 16 - U.S. Tax Court: Cost of goods sold includes only excise taxes actually paid in determining excise tax liability

May 15 - Interim final rule pending OIRA review: State and local fiscal recovery funds (COVID-19)

May 15 - KPMG report: Taxation of paid or reimbursed travel expenses and determination of employee’s tax home

May 15 - KPMG reports: Colorado (retail delivery fee); Florida (federal conformity, sales and use tax); Indiana (corporate income tax, sales and use tax)

May 12 - Notice 2023-38: Domestic content bonus credit guidance under sections 45, 45Y, 48, and 48E

May 10 - U.S. Tax Court: “Qualified research” test under section 41, summary judgment denied

May 10 - Notice 2023-39: Forthcoming proposed regulations regarding arbitrage treatment of certain guarantee funds under section 148

May 10 - Maryland Supreme Court dismisses challenge to digital advertising tax

May 9 - Proposed regulations: Information reporting and transfer for valuable consideration rules for section 1035 exchanges

May 8 - Third quarter update to IRS 2022-2023 Priority Guidance Plan

May 8 - KPMG report: Progress on improving mutual agreement procedure

May 8 - KPMG reports: Minnesota (proposed mandatory worldwide combined reporting); New York (business income and capital tax changes); Pennsylvania (treatment of electricity for income apportionment purposes)

May 5 - IRS provides tax relief for taxpayers in California affected by February storms

May 4 - Notice 2023-36: Request for recommendations for IRS 2023-2024 Priority Guidance Plan

May 3 - U.S. Tax Court: Receipt of profits interest in partnership in exchange for services not taxable

May 3 - IRS announces QI / WP / WT application and account management system (QAAMS) fully transitioning to new sign-in system

May 3 - KPMG report: COVID-19 disaster relief payments under section 139

May 2 - Proposed regulations: Section 367(d) rules for certain repatriations of intangible property

May 2 - IRS provides tax relief for taxpayers in Florida affected by tornadoes, severe storms, and flooding

May 1 - KPMG reports: Arizona (sales tax processing exemption); Michigan (delivery and installation charges subject to sales or use tax); Tennessee (excise and franchise tax changes pending enactment)

April 2023

Apr 28 - KPMG report: State and local tax, technology-related developments (table, first quarter 2023)

Apr 24 - KPMG report: Effect of IRS funding on information reporting

Apr 24 - KPMG reports: Colorado (effect of CARES Act); Missouri (sales and use tax manufacturing exemption); Virginia (federal conformity)

Apr 24 - IRS provides tax relief for taxpayers in Oklahoma affected by storms, straight-line winds, and tornadoes

Apr 21 - Rev. Proc. 2023-22: Nationwide average purchase price, residences located in United States

Apr 20 - U.S. Tax Court: Annuity payments received from charitable remainder trusts taxable as ordinary income

Apr 20 - Rev. Proc. 2023-21: Foreign insurance companies; effectively connected net investment income (2022)

Apr 18 - IRS provides tax relief for taxpayers in Indiana affected by tornadoes and severe storms

Apr 17 - KPMG reports: Arkansas (corporate rate reduction, throwback rule phase out); Kentucky (definition of telemarketing services); Washington State (B&O deduction for investment income)

Apr 14 - IRS releases tax collection data for fiscal year 2022

Apr 14 - Rev. Proc. 2023-15: Safe harbor method of accounting for expenses related to natural gas transmission and distribution property

Apr 13 - KPMG report: Initial observations on Notice 2023-29 guidance on determining energy communities for IRA tax credits

Apr 12 - Rev. Rul. 2023-8: Prior ruling relating to expensing of research and experimentation expenditures obsolete

Apr 10 - Proposed regulations: Micro-captive listed transactions and micro-captive transactions of interest

Apr 10 - Proposed regulations: Rules for supervisory approval of penalties

Apr 10 - Notice 2023-30: Safe harbor deed language for charitable conservation easements under Secure Act 2.0

Apr 10 - IRS provides tax relief for taxpayers in Tennessee affected by tornadoes and severe storms

Apr 10 - KPMG reports: Colorado (notice of tax credits to employees); Georgia (federal tax conformity); New Mexico (tax package vetoed); West Virginia (apportionment changes)

Apr 7 - Announcement 2023-12: Revised Form 3115 for applications for change in accounting method

Apr 7 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Apr 6 - IRS releases strategic operating plan for use of IRA funds

Apr 5 - Foreign taxes paid on accumulated earnings offset under section 965 are creditable (federal district court)

Apr 4 - Notice 2023-29: Guidance on requirements for energy community production and investment tax credits under IRA

Apr 3 - Notice 2023-31: Extension of transition period for single-country exception documentation requirement under section 903

Apr 3 - U.S. Tax Court: IRS lacks statutory authority to assess penalties under section 6038(b) for willful failure to file Form 5471

Apr 3 - IRS provides tax relief for taxpayers in Arkansas affected by tornadoes and severe storms

Apr 3 - KPMG reports: Kentucky (sales and use tax); Mississippi (changes related to section 174); Mississippi (sales tax treatment of computer software); Washington State (capital gains tax is permissible excise tax)

March 2023

Mar 31 - Proposed regulations: Guidance on new clean vehicle credit

Mar 29 - Announcement 2023-10: APMA program, APA statistics for 2022

Mar 29 - Rev. Rul. 2023-2: No basis step-up for assets of irrevocable grantor trust not included in grantor’s estate

Mar 28 - IRS provides tax relief for taxpayers in Mississippi affected by tornadoes and severe storms

Mar 28 - KPMG report: State, local tax changes (first quarter 2023, table format)

Mar 27 - Proposed regulations: Reinstated Superfund chemical tax and Superfund imported substance tax

Mar 27 - Notice 2023-28: Superfund excise taxes, extension of relief regarding failure to deposit penalties

Mar 27 - Rev. Proc. 2023-20: Clarification of date on which substances added or removed from Superfund list

Mar 27 - IRS guidance on electronic filing of Form 8038-CP for bond issuers requesting tax credit payments

Mar 27 - KPMG report: Notable highlights from section 48D proposed regulations (advanced manufacturing investment credit)

Mar 27 - KPMG report: Stock repurchase excise tax and funding rule considerations for inbound taxpayers

Mar 27 - KPMG reports: New Jersey (proposed changes to corporate tax law); Rhode Island (virtual services subject to sales and use tax); South Dakota (temporary reduction in sales tax rate)

Mar 24 - Beneficial ownership information reporting guidance

Mar 24 - IRS provides tax relief for taxpayers in New York affected by winter storms, snowstorms

Mar 22 - IRS provides revised FAQs on Form 1099-K

Mar 21 - Proposed regulations: Investment tax credit for investments in semiconductor manufacturing

Mar 21 - Notice 2023-27: Guidance and request for comments on treatment of certain NFTs as section 408(m) collectibles

Mar 20 - KPMG reports: California (unclaimed property); Colorado (real estate sales and receipts factor); Florida (costs of performance sourcing rule); Louisiana (sales and use tax informational report); Montana (single receipts factor)

Mar 17 - IRS provides FAQs on whether nutrition, wellness, and general health costs are medical expenses

Mar 17 - IRS provides tax relief for taxpayers in California affected by March storms, flooding, landslides, mudslides

Mar 17 - KPMG report: Crypto crackdown—information reporting in a digital asset world

Mar 17 - KPMG report: FASB proposed accounting standards update addresses requests for improved tax disclosures

Mar 15 - Notice of filing of petition for addition of cellulose acetate (degree of substitution = 1.5 – 2.0) to Superfund list

Mar 15 - California: Guidance concerning unclaimed property voluntary compliance program

Mar 14 - Notice 2023-26: Housing expense limit adjustments, foreign locations for 2023

Mar 14 - Proposed regulations concerning Superfund chemical tax and Superfund imported substance tax; OIRA review completed

Mar 13 - Werfel sworn in as new IRS Commissioner

Mar 13 - Rev. Proc. 2023-19: Waiver for individuals electing to exclude foreign earned income

Mar 13 - KPMG reports: Minnesota (sales tax guidance for marketplace providers); Texas (apportionment for franchise tax); Wisconsin (online ticket marketplace liable for sales and use tax)

Mar 10 - AOD 2023-1: IRS acquiescence to Fifth Circuit decision, tax on exports of domestic crude oil held unconstitutional

Mar 10 - Ninth Circuit: Tax return not considered filed when sent in response to IRS inquiry; Tax Court affirmed

Mar 9 - Notice 2023-24: Credit for production of electricity from advanced nuclear power facilities under section 45J

Mar 9 - Rev. Proc. 2023-17: Indexing adjustments for amounts used to calculate employer shared responsibility payments

Mar 9 - Senate confirms Werfel to be IRS Commissioner

Mar 7 - Notice 2023-23: Relief for reporting required minimum distributions for 2023

Mar 7 - Seventh Circuit: Research tax credit disallowed, Tax Court affirmed

Mar 6 - KPMG reports: District of Columbia (sales tax on resold items); multistate (escheatment of abandoned property); multistate (corporate surtaxes)

Mar 2 - Finance Committee advances Werfel to be next IRS Commissioner

February 2023

Feb 28 - U.S. Supreme Court: Penalty for FBAR violation applies on per-report, not per-account basis

Feb 27 - Notice 2023-21: Relief with respect to lookback periods for returns with postponed due dates (COVID-19)

Feb 27 - KPMG report: Corporate Alternative Minimum Tax considerations and FAQs (updated after Notices 2023-7 and 2023-20)

Feb 27 - KPMG reports: Mississippi (decoupling from section 174); Pennsylvania (income-producing activity test); Washington State (capital gains excise tax); multistate (federal tax conformity)

Feb 24 - Proposed regulations: Use of forfeitures in qualified retirement plans

Feb 24 - Proposed regulations concerning information returns of cryptocurrency brokers; OIRA review completed

Feb 24 - IRS provides tax relief for “disaster area taxpayers” in Alabama, California, Georgia

Feb 23 - Final versions of Form 5500 series, annual employee benefit plan reports

Feb 23 - Pennsylvania: “Benefits-received” interpretation of income-producing activity test upheld (Supreme Court decision)

Feb 22 - Final regulations: Single-entity treatment of consolidated groups for purposes of section 951(a)(2)(B) in context of section 959(b) distributions

Feb 21 - Final regulations: Electronic-filing requirements for specific tax returns, other documents

Feb 21 - KPMG report: Observations from Notice 2023-20 (guidance regarding certain insurance related issues under corporate alternative minimum tax)

Feb 20 - KPMG report: Observations from Notice 2023-18 (guidance on qualifying advanced energy project credit under section 48C)

Feb 20 - KPMG reports: California (unclaimed brokerage accounts); Louisiana (cloud-based storage plans not subject to sales tax); Louisiana (manufacturing machinery and equipment sales tax exclusion); Tennessee (deduction for FDII)

Feb 17 - Notice 2023-20: Interim guidance regarding certain insurance related issues under corporate alternative minimum tax (CAMT)

Feb 13 - IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program

Feb 13 - IRS guidance on state tax refunds, general welfare and disaster relief payments

Feb 13 - Notice 2023-17: Guidance on environmental justice solar and wind capacity limitation under section 48(e)

Feb 13 - Notice 2023-18: Guidance on qualifying advanced energy project credit under section 48C

Feb 13 - Proposed regulations pending OIRA review: Superfund chemical tax and Superfund imported substance tax

Feb 13 - Rev. Rul. 2023-4: Interest rates, tax underpayments and overpayments remain same for second quarter 2023

Feb 13 - KPMG reports: Minnesota (retail delivery fee); Missouri (resale tax exemption); multistate (taxation of digital products and services and software)

Feb 10 - KPMG report: Accounting for income taxes handbook

Feb 9 - U.S. Tax Court: Regulation under section 482 relating to consideration of foreign legal restrictions upheld

Feb 8 - Announcement 2023-6: Updates on third six-year remedial amendment cycle for pre-approved defined benefit plans

Feb 8 - KPMG report: New section 174 mandatory capitalization regime, issues for engineering and construction industry

Feb 7 - U.S. Tax Court: Gain recognized on sale of partnership interest attributable to inventory may be U.S.-source income

Feb 6 - KPMG report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation (updated)

Feb 6 - KPMG report: State and local tax changes affecting entities in asset management industry in 2022

Feb 6 - KPMG reports: Arizona (transaction privilege tax); Michigan (rolling stock use tax exemption); Texas (sourcing of local sales tax on internet orders); Wisconsin (nonconformity with section 174 changes)

Feb 3 - Notice 2023-13: Service industry tip compliance agreement program

Feb 3 - Notice 2023-16: Updated FAQs for clean vehicle credit under section 30D

Feb 2 - KPMG report: Accounting questions related to new GloBE rules

Feb 2 - KPMG report: Summary and observations of tax provisions under SECURE Act 2.0

Feb 1 - KPMG report: FERC orders allow public utility to defer sales tax through use of procurement subsidiary (multistate)

January 2023

Jan 31 - KPMG report: Proposed regulations providing definition of domestically controlled real estate investment trust, initial analysis and observations

Jan 31 - KPMG report: Year-in-review list of U.S. federal tax developments for 2022 (as reported in TaxNewsFlash)

Jan 30 - Proposed regulations: Rescission of “moral exemption rule” to coverage of certain contraceptive services under Affordable Care Act

Jan 30 - KPMG reports: Illinois (amended return was timely filed); Texas (taxpayer may not amend franchise tax report); multistate (combined reporting)

Jan 27 - Rev. Proc. 2023-9: New rules and conditions for implementing alternative cost method for real estate developers

Jan 26 - KPMG report: IRA stock buyback, practical considerations for retirement plans and equity-based compensation arrangements

Jan 26 - IRS annual revenue procedures for 2023

Jan 25 - KPMG report: Third reinstated Superfund tax adds complexity

Jan 24 - IRS provides tax relief for taxpayers in California affected by December storms, flooding, mudslides

Jan 24 - KPMG report: Form 1099-K delayed reporting thresholds

Jan 24 - KPMG report: State and local tax, technology-related developments (table, fourth quarter 2022)

Jan 23 - KPMG reports: Florida (sales tax refunds on software and hardware); Texas (margin tax apportionment); Virginia (NOL carryback)

Jan 20 - Eleventh Circuit: Permanent injunction against “tax mandate” in American Rescue Plan Act upheld

Jan 20 - IRS extends due date for QI withholding agreement to May 1, 2023

Jan 19 - IRS provides tax relief for taxpayers in Georgia and Alabama affected by storms

Jan 18 - IRS practice units: Changes in accounting methods

Jan 18 - IRS reminder: Employers must file Forms W-2 and provide Forms 1099-NEC by January 31, 2023

Jan 18 - Notice of filing of petition for addition of 4,4’–isopropylidenediphenol-epichlorohydrin copolymer to Superfund list

Jan 18 - Rev. Proc. 2023-14: Automobile depreciation deduction limits for 2023

Jan 18 - KPMG report: SEC comments on accounting for income taxes

Jan 18 - KPMG reports: Minnesota (federal tax conformity); Missouri (sales and use tax changes); Ohio (tax and fee amnesty); Washington State (bad debt sales tax credit and B&O tax deduction)

Jan 12 - Proposed regulations pending OIRA review: Information returns of cryptocurrency brokers

Jan 12 - U.S. tax season starts January 23, 2023; most individual returns due April 18, 2023

Jan 11 - KPMG report: Final regulations on exception for U.S. real property interests held by foreign pension funds, initial impressions and observations

Jan 11 - KPMG report: Section 163(j) considerations on the disposition of partnership property and partnership interests

Jan 11 - National Taxpayer Advocate report to Congress identifying taxpayer challenges, describing better outlook for 2023

Jan 10 - IRS provides tax relief for taxpayers in California affected by storms, flooding, mudslides

Jan 5 - KPMG report: Initial observations on guidance relating to clean vehicle credit under section 30D

Jan 5 - KPMG report: Analysis of safe harbor for “incremental cost” under section 45W in Notice 2023-9

Jan 4 - KPMG report: Year-end state and local tax updates (Kentucky, Massachusetts, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania)

Jan 4 - KPMG report: Initial observations on round 1 of CAMT guidance in Notice 2023-7

Jan 1 - KPMG report: Analysis and observations on Rev. Procs. 2023-8 and 2023-11, guidance for accounting method changes under section 174

2022 Articles

December 2022

Dec 30 - KPMG report: Analysis and observations on initial guidance on new 1% stock repurchase excise tax

Dec 30 - IRS provides tax relief for taxpayers in New York affected by winter storm

Dec 30 - Notice of filing of petition for addition of polyphenylene sulfide to Superfund list

Dec 30 - Notice 2023-11: Temporary relief for foreign financial institutions required to report U.S. TINs

Dec 30 - Deadline for renewal of QI agreements covering 2023 through 2028

Dec 30 - TTB guidance: Industry circular on calculating tax rates for distilled spirits

Dec 29 - Proposed regulations: Use of an electronic medium to make participant elections and spousal consents (text of regulations)

Dec 29 - Proposed regulations concerning electronically filed returns; OIRA review completed

Dec 29 - IRS provides FAQs on clean vehicle credits for new, previously owned and commercial vehicles

Dec 29 - Rev. Proc. 2023-11: Updated guidelines for accounting method changes for specified R&E expenditures

Dec 29 - Treasury releases white paper on critical mineral and battery component requirements for clean vehicle tax credits

Dec 29 - Notice 2023-1: Intention to propose regulations on requirements of clean vehicle credit under section 30D

Dec 29 - Notice 2023-3: Standard mileage rates for 2023

Dec 29 - Notice 2023-9: Safe harbor for “incremental cost” of commercial clean vehicles eligible for tax credit under section 45W

Dec 28 - IRS provides updated FAQs on Form 1099-K

Dec 28 - Final regulations: Exception for U.S. real property interests held by foreign pension funds (text of regulations)

Dec 28 - Proposed regulations: Foreign government income exception and definition of domestically controlled qualified investment entities (text of regulations)

Dec 28 - Notice of filing of petition for addition of polyoxymethylene to Superfund list

Dec 27 - Notice 2023-7: Interim guidance on new corporate alternative minimum tax (CAMT)

Dec 27 - Notice 2023-2: Interim guidance on new 1% excise tax on repurchases of corporate stock

Dec 23 - Announcement 2023-1: Applicable reference standard for energy efficient commercial building property deduction

Dec 23 - Announcement 2023-2: Transitional guidance for broker reporting on digital assets

Dec 23 - Notice 2023-10: Delay of implementation of $600 reporting threshold for Forms 1099-K

Dec 23 - Rev. Proc. 2023-10: Insurance companies, unpaid loss discount factors for 2022 accident year

Dec 22 - IRS provides FAQs on energy efficient home improvements and residential clean energy property credits

Dec 22 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Dec 21 - Notice 2023-8: Guidance regarding withholding on transfers of publicly traded partnership interests

Dec 20 - Notice 2023-4: Indexing factor for use by group health plans and health insurance issuers in 2023

Dec 19 - Notice 2023-6: Guidance on new sustainable aviation fuel credits

Dec 19 - Treasury timeline for providing guidance on “Inflation Reduction Act” tax provisions

Dec 19 - IRS provides tax relief for taxpayers in Florida affected by Hurricane Nicole

Dec 19 - KPMG report: Navigating the turbulent waters of the section 704(c) ceiling rule

Dec 19 - KPMG report: State, local tax changes (year-end checklist and fourth quarter 2022)

Dec 19 - KPMG reports: Florida (online learning services subject to communications services tax); Ohio (expanded sales tax deduction for bad debts); multistate (reduced sales tax rates on food)

Dec 16 - KPMG report: Recent developments in taxation of financial products

Dec 13 - Rev. Proc. 2022-43: Final QI withholding agreement applicable beginning 2023

Dec 13 - KPMG report: Partnership “distributive share only” rule in corporate alternative minimum tax

Dec 13 - KPMG report: Periodic and nonperiodic withholding certificates

Dec 12 - Final regulations: Health insurance coverage limited to testing, diagnosis not “minimum essential coverage” (COVID-19)

Dec 12 - Rev. Proc. 2023-8: Automatic changes to accounting methods to comply with section 174

Dec 12 - Rev. Proc. 2022-42: Procedures for manufacturers and sellers of clean vehicles to qualify for tax incentives

Dec 12 - KPMG reports: California (franchise fees subject to sales and use tax); Louisiana (electric charging station subject to sales tax); Michigan (section 163(j) changes and unitary business group guidance); Missouri (drop shipments subject to sales tax, FAQs on economic nexus law)

Dec 9 - Proposed regulations: Single-entity treatment of consolidated groups for purposes of section 951(a)(2)(B) in context of section 959(b) distributions

Dec 9 - FBAR filings: Extended deadline is April 15, 2024, for individuals with signature authority

Dec 9 - New York State: Qualified emerging technology company determination does not apply at combined group level

Dec 8 - Final regulations: Special enforcement matters, centralized partnership audit regime

Dec 8 - Rev. Rul. 2022-24: Covered compensation tables for 2023 plan year

Dec 8 - IRS announces mortality tables for defined benefit pension plans under Notice 2022-22 will apply in 2023

Dec 7 - United States and Croatia sign income tax treaty

Dec 7 - KPMG report: MAP and the exhaustion of remedies for FTC purposes

Dec 6 - Proposed regulations: Certain syndicated conservation easement transactions identified as listed transactions (text of regulations)

Dec 6 - KPMG report: EITF consensus to expand use of proportional amortization method

Dec 5 - KPMG reports: California (proposed guidance on marketplace sales); Florida (sourcing of receipts from sales of services); Ohio (sourcing of receipts from use of intellectual property); Tennessee (provision of nontaxable services versus taxable computer software)

Dec 2 - KPMG report: Analysis and observations about prevailing wage and apprenticeship requirements

Dec 2 - IRS provides tax relief for certain taxpayers affected by snowstorm in New York

November 2022

Nov 29 - Notice 2022-61: Guidance on prevailing wage and apprenticeship requirements under clean energy tax incentives

Nov 29 - Rev. Rul. 2022-23: Interest rates, tax underpayments and overpayments (increase for first quarter 2023)

Nov 29 - U.S. Tax Court: 90-day time limit to file deficiency petition is jurisdictional deadline not subject to equitable tolling

Nov 28 - Tier 2 tax rates for railroads, no changes for 2023

Nov 22 - Ninth Circuit: Rehearing en banc denied in section 965 case

Nov 21 - KPMG report: Proposed foreign tax credit regulations

Nov 21 - Notice 2022-62: Required amendments list (2022) for qualified retirement plans and 403(b) plans

Nov 21 - New York State: Guidance on New York City passthrough entity tax for 2022-2023

Nov 21 - KPMG reports: Colorado (federal retroactive changes applied; includible corporation in unitary combined group); Wisconsin (unclaimed property voluntary disclosure program); Wyoming (roadside services not subject to excise tax)

Nov 18 - Proposed regulations: Guidance relating to the foreign tax credit (text of regulations)

Nov 18 - Treasury to allocate $5 billion in New Markets Tax Credit (NMTC) authority for 2022

Nov 17 - IRS provides tax relief for certain taxpayers affected by storm and flooding in Illinois

Nov 16 - Rev. Proc. 2022-39: Procedures for eligible taxpayers to file qualified amended returns

Nov 16 - KPMG report: Year-end tax discussion ideas for international tax and transfer pricing

Nov 16 - KPMG report: Accounting for tax credits

Nov 15 - KPMG report: Comments on proposed regulations providing guidance on IRS Independent Office of Appeals

Nov 14 - Notice 2022-59: Self-insured health insurance annual fee

Nov 14 - KPMG report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation (updated)

Nov 14 - KPMG reports: Georgia (“safe rides fee” subject to sales and use tax); Wisconsin (guidance on taxation of NFTs); multistate (income tax changes approved on election day)

Nov 14 - Texas: Fair value analysis under satellite radio sourcing rules for franchise tax purposes (appeals court decision)

Nov 10 - Announcement 2022-23: New renewable electricity production credit amounts for calendar year 2022

Nov 10 - President Biden to nominate Daniel Werfel as IRS Commissioner

Nov 10 - KPMG report: Corporate Alternative Minimum Tax considerations and FAQs

Nov 9 - U.S. Tax Court: Listing notice is legislative rule improperly issued under the Administrative Procedure Act

Nov 7 - Rev. Proc. 2022-40: Program for approving 403(b) retirement plans

Nov 7 - KPMG reports: Missouri (club membership dues subject to sales tax); Oregon (market-based sourcing); Wisconsin (manufacturing credit); multiple states (escheatment rules)

Nov 4 - IRS Priority Guidance Plan for 2022-2023

Nov 3 - IRS notices: Additional requests for comments on upcoming clean energy tax guidance

Nov 2 - KPMG report: Year-end tax topics for cryptocurrency investors

October 2022

Oct 31 - KPMG report: Combined federal state filing program

Oct 31 - KPMG reports: Pennsylvania (sourcing of digital audio book sales); South Carolina (fees subject to sales and use tax); Washington State (sourcing of patent procurement services income)

Oct 28 - O’Donnell appointed IRS “Acting Commissioner”

Oct 28 - Treasury awards $5 billion in New Markets Tax Credit (NMTC) allocations

Oct 28 - IRS issues FAQ on WP / WT renewals

Oct 26 - DOJ will not seek U.S. Supreme Court review of case concerning crude oil tax imposed by section 4611(b)

Oct 25 - TTB announcement: Foreign alcohol producers may now register with online TTB system for 2023

Oct 24 - KPMG reports: Illinois (guidance on taxation of cryptocurrency); Maryland (digital advertising tax struck down); multiple states (tax rate changes on ballots)

Oct 21 - Notice 2022-55: Pension plans, cost-of-living adjustments for 2023

Oct 21 - KPMG report: Examination of extended statute of limitations under section 965

Oct 20 - Proposed regulations withdrawn: Exclusion from gross income of PTEP and related basis adjustments

Oct 19 - IRS reminder: Deadline to file 2019 and 2020 tax returns to get penalty relief postponed in declared disaster areas (COVID-19)

Oct 19 - KPMG report: State and local tax, technology-related developments (table, third quarter 2022)

Oct 19 - KPMG report: “Superfund” tax refunds for exported chemicals and listed substances

Oct 18 - Rev. Proc. 2022-38: Inflation adjustments for 2023, individual taxpayers

Oct 18 - IRS practice unit: “Report of Foreign Bank and Financial Accounts” (FBAR)

Oct 17 - KPMG reports: Mississippi (digital photography service); Tennessee (sales of subscriptions to electronic publications); Texas (web-based weather forecasting service); multiple states (nexus)

Oct 13 - U.S. Tax Court: Partnership distribution of “clients” was distribution of intangible assets

Oct 12 - IRS updates FAQs on QI / WP / WT website, certifications and periodic reviews

Oct 12 - Illinois: Calendar year corporate income tax return filing deadline extended to November 15, 2022

Oct 11 - Final regulations providing guidance under section 36B regarding premium tax credit, employer coverage for employee family members

Oct 11 - Notice 2022-41: Additional permitted election changes for health coverage under “cafeteria plans”

Oct 11 - Rev. Proc. 2022-19: Taxpayer assistance procedures for S corporations under section 1362(f)

Oct 11 - IRS expands penalty relief for dyed diesel fuel in Florida; hurricane-related relief

Oct 10 - Washington State: Penalties on unified annual reconciliation of apportionable income

Oct 10 - KPMG reports: Colorado (streaming platform credits); New York (nontaxable information services); Oregon (business license tax law); South Dakota (bank franchise tax)

Oct 7 - Final, temporary, and proposed regulations: Low-income housing credit average income test (text of regulations)

Oct 7 - Notice 2022-52: Extended temporary relief, low-income housing credit under section 42

Oct 7 - Notice 2022-53: Required minimum distributions

Oct 7 - Final regulations providing guidance under section 36B regarding premium tax credit; OIRA review completed

Oct 6 - FBAR filing deadline relief for persons affected by certain natural disasters

Oct 5 - IRS notices: Requests for comments on upcoming clean energy tax guidance

Oct 5 - IRS provides tax relief for taxpayers affected by Hurricane Ian (North Carolina and South Carolina)

Oct 3 - IRS announces new sign-in system for QI / WP / WT application and account management system (QAAMS)

Oct 3 - KPMG report: Tax treatment of cryptocurrency and challenges of cross-border reporting

Oct 3 - KPMG reports: Colorado (retail delivery fee guidance); Iowa (corporate income tax rate reduction); Texas (R&D credit); West Virginia (tax preparer must collect sales tax)

September 2022

Sep 30 - IRS to waive dyed diesel fuel penalty in Florida; hurricane-related relief

Sep 30 - Final regulations concerning low-income housing credit average income test; OIRA review completed

Sep 30 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Sep 30 - KPMG report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation

Sep 29 - Final regulations: Beneficial ownership information reporting

Sep 29 - California: Other state tax credit for resident owners of entities that elect PTET legislation enacted

Sep 29 - IRS provides tax relief for taxpayers in Florida affected by Hurricane Ian

Sep 29 - Puerto Rico: Tax-related hurricane relief

Sep 28 - Notice 2022-43: Farmers, ranchers affected by drought allowed more time to replace livestock

Sep 27 - IRS provides tax relief for certain taxpayers affected by storms in Alaska

Sep 26 - Notice 2022-44: Per diem rates, substantiation of employee lodging, meals, incidentals (2022-2023)

Sep 26 - Notice 2022-45: Extension of time to amend certain eligible retirement plans for qualifying distributions (COVID-19)

Sep 26 - LB&I memo providing updated guidance on the statute of limitations with respect to section 965 examinations

Sep 26 - U.S. Tax Court: Excess loss account included in income of consolidated group member

Sep 26 - KPMG reports: Colorado (cryptocurrency as payment for taxes); Illinois (abatement of late penalties); Louisiana (manufacturing allocation formula)

Sep 23 - Notice 2022-38: Carbon oxide sequestration credit under section 45Q, inflation adjustment factor for 2022, final year for pre-BBA equipment

Sep 23 - TTB temporary and proposed regulations: Implementation of refund procedures for federal excise tax benefits applicable to imported alcohol

Sep 23 - KPMG report: Tax provisions in the “Inflation Reduction Act of 2022” relevant to the banking industry; potential implications

Sep 22 - Rev. Proc. 2022-35: Updated list of countries, deposit interest paid to nonresident aliens (Turkey)

Sep 22 - Final regulations concerning beneficial ownership information reporting; OIRA review completed

Sep 22 - KPMG report: State, local tax changes (third quarter 2022, table format)

Sep 21 - IRS guidance on tax treatment of PPP loan forgiveness based on misrepresentations or omissions (COVID-19)

Sep 21 - Puerto Rico: Extension of sales and use tax returns, payments as hurricane relief

Sep 21 - KPMG report: A primer on wash sale reporting in a volatile market (updated September 2022)

Sep 20 - U.S. SEC signals support for country-by-country reporting

Sep 19 - IRS updates information on pre-screening and certification process of Work Opportunity Tax Credit (WOTC)

Sep 19 - IRS provides tax relief for taxpayers in Puerto Rico affected by Hurricane Fiona

Sep 19 - Final regulations pending OIRA review: Guidance under section 36B regarding premium tax credit

Sep 19 - KPMG reports: Missouri (sales and use tax manufacturing exemption); North Carolina (service contract subject to sales and use tax); Pennsylvania (sales and use tax collection by out-of-state sellers); South Carolina (bookstore membership fees subject to sales and use tax)

Sep 16 - California: Unclaimed property voluntary compliance program legislation enacted

Sep 16 - Notice 2022-42: Intent to amend noncompulsory payment regulations under section 901 with respect to amended Puerto Rico tax decrees

Sep 16 - PLR: REIT status regarding certain marina properties

Sep 16 - KPMG report: Student loan forgiveness and state reporting

Sep 15 - IRS opens application period for 2023 Compliance Assurance Process (CAP) program

Sep 14 - Rev. Proc. 2022-36: Foreign insurance companies; effectively connected net investment income (2021)

Sep 14 - Request for information: Advanced explanation of benefits and good faith estimate for covered individuals under “no surprises” provisions

Sep 13 - Notice 2022-39: Guidance regarding one-time claim for alternative fuels excise tax credits

Sep 13 - Final regulations pending OIRA review: Low-income housing credit average income test

Sep 12 - KPMG reports: Colorado (retail delivery fees exempt from Denver sales and use tax); Idaho (rate reductions); Illinois (subject to tax in foreign country); New Jersey (convenience of employer rule)

Sep 9 - Proposed regulations: Guidance relating to IRS Independent Office of Appeals (text of regulations)

Sep 8 - IRS provides tax relief for certain taxpayers affected by storms in Arizona

Sep 2 - New York State: Economic nexus for corporations in New York City, passthrough entity tax for 2022

Sep 2 - IRS provides tax relief for taxpayers affected by water crisis (Mississippi)

August 2022

Aug 30 - IRS practice unit: Rules for determining stock ownership under section 958

Aug 29 - KPMG reports: California (unclaimed property); District of Columbia (payroll factor); Michigan (nexus under Wayfair); Minnesota (sales and use taxation of NFTs); Oregon (Pub. L. No. 86-272); Texas (sales factor)

Aug 26 - California: Erroneously issued refunds of 2022 pass-through entity tax must be returned by taxpayers ASAP to secure elections

Aug 25 - U.S. Tax Court: Partnership’s payments to lender were deductible interest, and not payments on an equity interest

Aug 25 - Sixth Circuit: Tax Court decision affirmed, taxpayer not liable for 40% penalty upon cancellation of APAs

Aug 24 - Notice 2022-36: Penalty relief for certain taxpayers filing returns for tax years 2019 and 2020 (COVID-19)

Aug 24 - Final regulations: Requirements related to “surprise” medical billing

Aug 24 - Second Circuit: Early distribution 10% exaction is tax, not a penalty requiring written supervisory approval; Tax Court affirmed

Aug 24 - KPMG report: Foreign tax credit regulations; constructing a path forward

Aug 23 - Notice 2022-37: Further extended phase-in provisions under section 871(m) regulations

Aug 23 - KPMG report: Form 1099-K and state reporting issues

Aug 18 - U.S. Tax Court: Determination of transfer pricing method, on remand from Eighth Circuit

Aug 18 - IRS Appeals invites input on enhancing video conferences

Aug 17 - Guidance on changes to electric vehicles tax credit under "Inflation Reduction Act"

Aug 17 - Proposed regulations pending OIRA review: Electronically filed returns

Aug 16 - President signs budget reconciliation legislation; KPMG’s report on tax law changes

Aug 15 - Notice 2022-34: Deferred applicability dates for foreign currency guidance under section 987

Aug 15 - Rev. Rul. 2022-15: Interest rates, tax underpayments and overpayments (increase for fourth quarter 2022)

Aug 15 - New York State: Passthrough entity tax implications for New York City businesses; revised draft regulations on sourcing of investment management services

Aug 15 - KPMG reports: Arkansas (corporate rate reduction accelerated); California (pending vote on full sales and use tax exemption for equipment); New Mexico (digital advertising services)

Aug 10 - IRS provides tax relief for taxpayers affected by storms in Missouri

Aug 9 - KPMG report: Overview of investment tax credit for investments in semiconductor manufacturing

Aug 8 - KPMG reports: Alabama (related-party addback rules); Alaska (combined reporting, foreign entities); Colorado (retail delivery fee); Idaho (guidance under revised sourcing laws)

Aug 5 - D.C. Circuit: Partnership upheld as valid, despite IRS claims it never would have been profitable without refined-coal tax credits

Aug 5 - Eighth Circuit: Deductions denied for deferred cash payments of $51 million made to former spouse

Aug 4 - Final regulations: Removal of signature requirement for section 754 elections

Aug 4 - Fifth Circuit: Credit for renewable fuels reduces excise tax, but deduction limited to excise tax actually paid

Aug 3 - Notice 2022-33: Extended deadline of December 31, 2025, for amending retirement plans or IRAs

Aug 3 - Deadline for QI / WP / WT applications for 2022 is September 30, 2022

Aug 3 - IRS extends tax relief for taxpayers affected by wildfires in New Mexico

Aug 3 - IRS provides tax relief for taxpayers affected by water issues in U.S. Virgin Islands (St. Croix)

Aug 2 - IRS provides tax relief for taxpayers affected by storms in Kentucky

Aug 1 - KPMG reports: Michigan (sales and use tax exemption, industrial processing); Texas (franchise tax credit, R&D activities)

July 2022

Jul 28 - KPMG report: A primer on wash sale reporting in a volatile market

Jul 27 - KPMG report: Correcting amendments to final foreign tax credit regulations

Jul 26 - Eleventh Circuit: Taxpayer’s claim for reimbursement of “protest payments” denied, no statutory basis for refund

Jul 26 - IRS practice unit: Allowance of deductions and credits on Form 1120-F delinquent returns

Jul 25 - KPMG reports: New York (federal items reported on combined returns); Tennessee (sales and use taxes on marketplace facilitator)

Jul 22 - KPMG report: Tax home and the rise of telecommuters

Jul 20 - KPMG report: State and local tax, technology-related developments (table, second quarter 2022)

Jul 18 - KPMG reports: Connecticut (investment tax credits); Delaware (unclaimed property laws); New Jersey (litter fee); Washington State (sales and B&O tax treatment of NFTs)

Jul 16 - Tax treaty update: United States terminates treaty with Hungary

Jul 11 - Tax treaty update: U.S. income tax treaty with Hungary reportedly being terminated

Jul 11 - Pennsylvania: Changes to corporate net income tax laws, other tax changes

Jul 8 - Fourth Circuit: IRS summons to taxpayer not quashed despite criminal referral of taxpayer’s agent

Jul 8 - PLR: IRS grants consent to taxpayer’s request regarding cost-sharing arrangement and intangible development costs

Jul 8 - Rev. Proc. 2022-32: Simplified method to obtain extension of time to make “portability” election with respect to decedent’s unused exclusion amount

Jul 7 - Rev. Rul. 2022-13: Multiemployer defined benefit plan receiving special financial assistance not deemed in “critical status” under section 432(b)(7) following merger

Jul 6 - IRS provides tax relief for taxpayers affected by storms in Montana and Oklahoma

Jul 5 - Proposed regulations: Foreign currency contract under section 1256 includes only foreign currency forward contracts (text of regulations)

Jul 1 - New York State: Appeals court holds vacation home is not permanent place of abode

June 2022

Jun 29 - Notice 2022-31: Defined benefit pension plans sponsored by newspapers, alternative minimum funding standards

Jun 28 - Rev. Proc. 2022-26: Procedures for requesting that substances be added or removed from Superfund list

Jun 27 - Notice 2022-30: Deferral of provisions under section 59A and 6038A regulations relating to reporting of qualified derivative payments

Jun 27 - KPMG report: State, local tax changes (second quarter 2022, table format)

Jun 27 - KPMG reports: Iowa (sales and use tax changes); Oregon (certiorari denied in case concerning VoIP collection of E-911 tax); Washington State (Seattle payroll expense tax upheld, certiorari denied in case concerning B&O tax surcharge financial institutions)

Jun 24 - Proposed regulations: Administration expenses, claims against estates, interest expense on amounts owed by estates (text of regulations)

Jun 24 - IRS announces Superfund chemical excise tax rates

Jun 24 - IRS provides FAQs on the reinstated Superfund chemical excise tax

Jun 24 - IRS practice unit: Energy efficient commercial buildings deduction

Jun 22 - KPMG report: Tax information reporting on crypto-assets

Jun 21 - Rev. Proc. 2022-28: No rulings to be issued regarding whether transactions result in employer reversion from qualified plan

Jun 21 - U.S. Supreme Court grants certiorari, whether penalty for FBAR violation applies on per-account or per-form basis

Jun 16 - Form 4419 relating to transmitter control codes for filing information returns electronically phased out beginning August 2022

Jun 16 - New Jersey: Transfer pricing settlement initiative program for corporate taxpayers

Jun 15 - Texas: Proposed changes to R&D regulations address federal conformity; combined group changes

Jun 15 - U.S. Tax Court: “Innocent spouse relief” not available as defense for trust fund recovery penalty liability

Jun 14 - KPMG report: Post-TCJA interplay between NOLs and charitable deductions

Jun 13 - California: Reminder that PTET elections and payment due June 15

Jun 13 - KPMG reports: California (sale of S corporation stock); Pennsylvania (NFTs); Tennessee (sales tax holiday); Texas (electronic payment transactions); Wisconsin (sales of services)

Jun 9 - Announcement 2022-13: Increased mileage rates for remainder of 2022

Jun 7 - Ninth Circuit: Mandatory repatriation tax under section 965 is constitutional

Jun 7 - KPMG report: Future of consumer and retail—tax perspective

Jun 6 - KPMG reports: Arkansas (leased vehicles); Massachusetts (apportioning sales and use tax); Vermont (corporate income tax); multiple states (nexus)

Jun 1 - KPMG report: Comments submitted to IRS regarding plans to update MAP and APA guidelines

May 2022

May 26 - IRS releases tax collection data for fiscal year 2021

May 23 - KPMG report: Backup withholding; IRS notices and payor responsibilities

May 23 - KPMG reports: Colorado (SALT Parity Act); Tennessee (wholesaler/retailer certificates); Washington State (B&O tax on damages received)

May 20 - Final versions of Form 5500 series, annual employee benefit plan reports

May 20 - IRS notices: Electricity production credit; percentage depletion for oil and gas produced from marginal properties

May 20 - PLR: Tax treatment of REIT’s section 481(a) adjustment

May 20 - Rev. Rul. 2022-11: Interest rates, tax underpayments and overpayments (increase for third quarter 2022)

May 18 - KPMG report: Potential tax benefits under section 1341

May 18 - KPMG report: Proposed changes to qualified intermediary (QI) agreement (Notice 2022-23)

May 17 - Tenth Circuit: Taxpayer did not qualify as small insurance company; Tax Court decision affirmed

May 17 - Massachusetts: Taxpayer prevails in capital gain tax dispute on statutory, but not constitutional grounds

May 16 - KPMG report: Wind facilities can requalify for another 10 years of production tax credit (PTC) after previously claiming PTC

May 16 - KPMG reports: Colorado (retail delivery fees form); Kansas (sales tax on passed-through costs); Vermont (proposed corporate income tax changes); multiple states (sales tax legislative updates)

May 13 - Notice 2022-27: Six-month extension allowing retirement plan elections and spousal consents to be signed remotely (COVID-19)

May 12 - IRS provides tax relief for taxpayers affected by wildfires in New Mexico

May 11 - Ninth Circuit: Tax return considered filed when sent in response to IRS inquiry; Tax Court reversed

May 9 - KPMG reports: California (franchise tax); Colorado (retail delivery fees); New York (revised franchise tax regulations and Public Law 86-272)

May 6 - GLAM: Allocation and apportionment of deferred compensation expense for purposes of calculating FDII—departure from prior IRS legal advice

May 5 - IRS corrects renewable electricity production inflation factors, reference prices for 2022

May 4 - Proposed regulations: Updated actuarial tables for valuing annuities, terms of years, and remainder interests

May 3 - Notice 2022-23: Proposed changes to QI withholding agreement for dispositions of publicly traded partnership interests

May 2 - KPMG reports: Minnesota (credit card surcharges subject to sales tax); New York (free gift cards subject to sales tax); Oklahoma (expanded marketplace facilitator definition)

April 2022

Apr 29 - IRS notices: Oil and gas—reference prices for 2021, inflation adjustment factor and phase-out for enhanced oil recovery credit

Apr 29 - Rev. Proc. 2022-24: HSA inflation-adjusted amounts for 2023

Apr 27 - Proposed regulations: Mortality tables for determining present value under defined benefit pension plans

Apr 27 - Notice 2022-22: Mortality rates, tables for defined benefit pension plans (2023)

Apr 26 - Proposed regulations: Basic exclusion amount, estate and gift taxes

Apr 26 - Notice 2022-21: Request for recommendations for IRS 2022-2023 Priority Guidance Plan

Apr 26 - Eighth Circuit: Expert witness testimony excluded and deductions for management fees denied; Tax Court affirmed

Apr 26 - IRS practice unit: Country-by-country (CbC) report in the transfer pricing risk analysis process

Apr 25 - KPMG reports: Texas (use tax on promotional items); Virginia (interest deduction, SALT cap workaround); West Virginia (unclaimed property)

Apr 22 - Sixth Circuit: Tax credit applied against fuel excise tax reduces excise tax liability

Apr 21 - U.S. Supreme Court: 30-day time limit to petition for review of collection determination subject to equitable tolling

Apr 19 - Rev. Proc. 2022-23: Late elections for depreciation of Indian reservation and biofuel property and accounting for film, TV and theater production costs

Apr 18 - IRS reminds employers of penalty relief related to claims for employee retention credit (COVID-19)

Apr 18 - U.S. Supreme Court: Certiorari denied in states’ challenge to 2017 tax law limiting SALT deduction

Apr 18 - KPMG report: State and local tax, technology-related developments (table, first quarter 2022)

Apr 18 - KPMG reports: Kentucky (House Bill 8 enacted over governor’s veto); New Jersey (P.L. 86-272 application); New York (admission of nexus); Texas (“sale for resale” exemption)

Apr 15 - Notice 2022-15: Superfund excise taxes, relief regarding failure to deposit penalties

Apr 15 - Kentucky: Comprehensive tax bill enacted over governor’s veto

Apr 13 - Brazil takes steps toward OECD transfer pricing guidelines

Apr 13 - New York City: SALT cap “workaround” enacted for 2023

Apr 13 - Puerto Rico: Postponed due date for income tax returns, corporate annual reports, LLC annual fees

Apr 13 - Renewable electricity production inflation factors, reference prices for 2022

Apr 12 - U.S. Tax Court: At-home private nurses were employees for federal employment tax purposes

Apr 12 - IRS announces taxpayers may soon receive letters relating to qualified opportunity funds

Apr 11 - KPMG reports: Maryland (no tax liability for tribe); Oklahoma (date for refund claim); Washington State (B&O tax apportionment for Tacoma)

Apr 8 - Maryland: Digital advertising services tax, estimated tax payment form is released

Apr 6 - Fourth Circuit: Payments to Russian scientist—taxable compensation or exempt from tax as a grant?

Apr 6 - U.S. Tax Court: Accounting for deferred fees using GAAP by retirement community upheld

Apr 5 - Proposed regulations: Guidance under section 36B regarding premium tax credit, employer coverage for employee family members (text of regulations)

Apr 5 - Temporary regulations under section 245A held invalid (federal district court)

Apr 4 - U.S. Treasury release: No change to list of countries cooperating with international boycott

Apr 4 - KPMG reports: Arkansas (nexus and apportionment); Kentucky (corporate, individual and indirect tax measures); Oregon (source of receipts)

March 2022

Mar 31 - IRS practice unit: Deferred compensation received by nonresident alien individuals

Mar 31 - IRS provides tax relief for taxpayers affected by storms in Puerto Rico

Mar 31 - U.S. Tax Court: Fees for use of securities exchanges not deductible under section 199

Mar 30 - Announcement 2022-7: APMA program, APA statistics for 2021

Mar 30 - Proposed regulations providing guidance under section 36B regarding premium tax credit; OIRA review completed

Mar 30 - Rev. Proc. 2022-21: Nationwide average purchase price, residences located in United States

Mar 29 - Tax treaty update: Senate Foreign Relations Committee approves income tax treaty with Chile

Mar 29 - KPMG report: State, local tax changes (first quarter 2022, table format)

Mar 28 - Fifth Circuit: Butane not eligible for tax credit; tax on exports of domestic crude oil held unconstitutional

Mar 28 - KPMG reports: Colorado (online marketplaces); Iowa (software, NOLs); Missouri (digital clubs); New Jersey (virtual currency); Tennessee (R&D expenses)

Mar 25 - Proposed regulations: Multiple employer plans (text of regulations)

Mar 25 - Ninth Circuit: Prior supervisory approval for penalty assessment for listed transaction; Tax Court reversed

Mar 25 - KPMG report: Evolving Form 1099-K thresholds

Mar 25 - Texas: Comptroller’s sourcing position in satellite radio case rejected by state’s high court

Mar 23 - KPMG report: Federal district court vacates Notice 2016-66 (microcaptive insurance transactions)

Mar 22 - IRS practice unit: Penalties for erroneous claims for refund or credit

Mar 21 - Rev. Rul. 2022-7: Federal, state, and local government employees also subject to disclosure restrictions regarding returns

Mar 21 - U.S. Tax Court: Initial determination of penalties, after IRS supervisory approval was obtained

Mar 21 - KPMG reports: California (acceleration of installment payments); Ohio (computer software); New York State (purchase for resale exemption)

Mar 18 - AOD 2022-2: IRS nonacquiescence to Eleventh Circuit’s decision, relocation benefits provided by railroad to employees

Mar 18 - Notice 2022-11: Indexing factor for provisions aimed at preventing surprise medical bills

Mar 18 - PLR: Liability-waiver payments received from tenants, relating to self-storage facilities, deemed rents from real property for REIT income tests

Mar 18 - Rev. Proc. 2022-20: Teleconferences satisfying the public approval requirements for tax-exempt qualified private activity bonds

Mar 18 - KPMG report: Updated analysis of Pillar Two model rules for 15% global minimum tax following release of commentary

Mar 17 - KPMG report: Updated list of automatic changes (Rev. Proc. 2022-14)

Mar 16 - Rev. Proc. 2022-17: Automobile depreciation deduction limits for 2022

Mar 16 - U.S. Tax Court: Compute foreign tax credit using same method that CFC used to apportion interest expense

Mar 16 - KPMG report: Understanding the excess business loss limitation

Mar 15 - Notice 2022-13: Waiver of addition to tax under section 6654 for certain farmers, fishermen

Mar 14 - Announcement 2022-6: Temporary suspension of prototype IRA opinion letter program

Mar 14 - Proposed regulations pending OIRA review: Guidance under section 36B regarding premium tax credit

Mar 14 - Sixth Circuit: Regulations on charitable donation of conservation easement upheld as valid; Tax Court affirmed

Mar 14 - KPMG reports: Idaho (sales-factor apportionment); New Jersey (employee retention credit); New Mexico (gross receipts tax); New York (broker-dealer sourcing rules); Pennsylvania (employee retention credit)

 

Archives (2018 - 2023)

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