KPMG’s Week in Tax: August 17-21

KPMG’s Week in Tax: August 17-21

U.S. tax developments reported this week include the following:

Related content

  • The Insurance Branch of IRS Chief Counsel-FIP publicly released a legal memorandum concluding that 10-year excess loss policies issued by a captive insurance company to affiliated (brother-sister) companies did not qualify as insurance for federal income tax purposes.
  • An IRS release provided a reminder to truckers and owners of heavy highway vehicles that, for most, the federal highway use tax return is due Monday, August 31, 2015.

Read more at TaxNewsFlash-United States

  • KPMG explanations of two revenue procedures, issued in earlier in August 2015, that provide guidance for requesting competent authority (CA) assistance, and concerning the process for requesting and obtaining advance pricing agreements (APAs) and the administration of executed APAs. 

Read TaxNewsFlash-Transfer Pricing

  • USTR announced that petitions seeking duty-free treatment of imports under the Generalized System of Preferences (GSP) program or seeking GSP status for certain beneficiary developing countries are due by October 16, 2015.

Read TaxNewsFlash-Trade & Customs

FATCA developments

  • Barbados; St. Vincent and the Grenadines: Intergovernmental agreements (IGAs) signed with the United States, following the Model 1 IGA for implementing the FATCA regime. 
  • US: The Treasury Department posted an updated notification of “more favorable terms” concerning “certain alternative procedures” under the Model 1 IGA.
  • US: A new FAQ on form and documentary evidence received by facsimile or email as well as updated IDES user guide and XML schema were released.

Read TaxNewsFlash-FATCA

International tax news

  • Canada: SLFIs that recently filed their 2014 indirect tax returns need to review their processes to improve efficiency and reduce risks for their 2015 returns. It is essential that these systems and processes not only meet operational and business requirements, but also help meet GST/HST and QST reporting obligations efficiently and effectively. Read TaxNewsFlash-Americas
  • Korea: A matter pending before an appellate court in South Korea could allow refunds of certain amounts of tax withheld on payments distributed to Luxembourg SICAVs. If the appeals are ultimately decided in favor of the SICAVs, they could be entitled to a refund of the difference between the withholding tax paid at a “standard” rate and the treaty-related rate of withholding tax. Read TaxNewsFlash-Asia Pacific
  • Finland: The Helsinki administrative court granted a refund of taxes to a German real estate investment fund. The decision may also benefit non-UCITS funds and allow them a refund of taxes based on EU law. Read TaxNewsFlash-Europe


Read these and other items reported this week at the TaxNewsFlash United States and Global websites.

© 2016 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal



KPMG's new digital platform

KPMG's new digital platform