KPMG’s Week in Tax: 31 August - 4 September

KPMG’s Week in Tax: 31 August - 4 September

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


Related content

  • Regulations address a number of issues under the “Subpart F” regime applicable to controlled foreign corporations (CFCs) and their U.S. shareholders. In general, the regulations expand application of the rules to CFC acquisitions of “United States Property,” certain partnership distributions, and certain transactions involving rents and royalties. The new rules also explicitly state that for investments in United States Property, a deemed exchange pursuant to section 1001 constitutes a new acquisition of the property.
  • Proposed regulations address the health insurance premium tax credit under section 36B. 
  • Regulations provide rules and procedures to be followed by multiemployer plans that are projected to have insufficient funds to pay full benefits that plan participants would otherwise be entitled, when such plans are in “critical and declining status.”
  • In Puerto Rico, guidance regarding the sales and use tax (IVU) treatment of designated professional services and business-to-business services was issued. Beginning 1 October 2015, business-to-business services (B2B) that currently are not subject to IVU, and designated professional services will be subject to a commonwealth IVU at a rate of 4%.
  • A Puerto Rico tax commission advised moving forward to implement a value added tax (VAT) system.

Read more at TaxNewsFlash-United States

FATCA developments

  • Luxembourg: Tax authorities released a final version of an administrative circular and an updated administrative circular to implement provisions under the FATCA regime concerning the automatic exchange of information between Luxembourg and the United States.
  • St. Kitts and Nevis: U.S. Treasury reported the signing of a Model 1 IGA.

Read more at TaxNewsFlash-FATCA

International tax news

  • France: A judgment by the Court of Justice of the European Union (CJEU) concludes that the French rules providing different tax treatment of dividends received by parent companies of tax-integrated groups, with the treatment depending on where the subsidiaries are established, is contrary to EU law. Read TaxNewsFlash-Europe
  • Mexico: Taxpayers in Mexico prevailed in district court actions, with respect to their challenges to rules requiring taxpayers to provide monthly information accounting statements to the tax authorities. The decisions, however, are not seen as being final, and it is anticipated that the tax authorities will appeal. Read TaxNewsFlash-Americas

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

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 International has created a state of the art digital platform that enhances your experience, optimized to discover new and related content.