United States
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Latest tax developments from the United States and from KPMG member firms around the globe
News
Notice 2025-32: Inflation adjustment factor and phase-out for enhanced oil recovery credit
The enhanced oil recovery credit for qualified costs paid or incurred in 2025 is phased-out completely.
June 30, 2025
News
Notice 2025-34: Reference price for section 45I credit for production of natural gas from marginal wells
Applicable reference price is $1.64 per 1,000 cubic feet
June 30, 2025
News
Senate Budget Committee Chairman releases updated legislative text for budget reconciliation bill
This legislation could change yet again as the Senate considers the bill.
June 28, 2025
News
Senate confirms Kies to be Treasury Assistant Secretary (Tax Policy)
Confirmed by a vote of 53-45
June 27, 2025
News
Treasury announces agreement with G7 countries to exclude U.S. companies from Pillar Two taxes in exchange for removing proposed new section 899 from OBBB
Treasury’s announcement only addresses Pillar Two taxes.
June 26, 2025
News
Washington State: Temporary expansion of voluntary disclosure agreement (VDA) program for investment income subject to B&O tax
Qualifying taxpayer can avoid penalties and interest on past due amounts
June 26, 2025
News
IRS announces tax relief for taxpayers affected by storms in Missouri
Taxpayers in parts of Missouri have until November 3, 2025, to file various federal tax returns and make payments.
June 25, 2025
News
National Taxpayer Advocate mid-year report to Congress
The National Taxpayer Advocate Erin M. Collins released her mid-year report to Congress.
June 25, 2025
News
KPMG article: Proposed new SALT regime and passthroughs
Examination of proposed new SALT regime under H.R. 1 and effects on passthroughs and partnerships
June 24, 2025
News
Notice 2025-31: Guidance for energy community bonus credit under sections 45, 45Y, 48, and 48E
Information taxpayers may use to determine whether they meet certain requirements under the Statistical Area Category or the Coal Closure Category
June 23, 2025
News
KPMG article: “Materiality” limits on deductions for services in Mexico
Tax assessments based on “materiality” often presented and negotiated like transfer pricing adjustments.
June 23, 2025
News
U.S. Tax Court: Taxpayer not required to treat payment as a result of failed merger as capital loss under section 1234A(1)
Section 1234A(1) did not apply because taxpayer did not have a right or obligation with respect to property.
June 17, 2025
News
IRS announces improvements to pre-filing agreement program
Improved guidance on procedures and program administration
June 17, 2025
News
KPMG article: Evaluating revised retaliatory measures in House bill
House bill would add new section 899 which would provide two retaliatory mechanisms.
June 17, 2025
News
KPMG report: Section 83(b) elections
Overview of section 83(b) elections, eligibility, filing requirements, and implications
June 16, 2025
News
Announcement 2025-16: Competent authority arrangement under U.S.-Denmark treaty listing entities treated as “pension funds”
CAA is effective for dividends paid on or after February 1, 2008.
June 13, 2025
News
Senate confirms Long to be IRS Commissioner
Confirmed by a vote of 53-44
June 12, 2025
News
U.S. Supreme Court: Taxpayer’s petition may be dismissed by Tax Court on grounds of mootness
Supreme Court reversed U.S. Court of Appeals for the Third Circuit
June 12, 2025
News
Notice 2025-33: Extended transitional relief from reporting and backup withholding rules for custodial brokers effectuating digital asset transactions
Notice 2025-33 extends for an additional year and modifies the transitional relief provided in Notice 2024-56.
June 12, 2025
News
KPMG article: Common transfer pricing challenges in cash pooling
Cash pooling is not observed between unrelated parties, which presents challenges.
June 12, 2025
News
IRS announces tax relief for taxpayers affected by storms in Mississippi
Taxpayers in parts of Mississippi have until November 3, 2025, to file various federal tax returns and make payments.
June 11, 2025
News
IRS provides tax relief for taxpayers affected by storms in Texas
Taxpayers in parts of Texas have until November 3, 2025, to file various federal tax returns and make payments.
June 10, 2025
News
U.S. Treasury release: No change to list of countries cooperating with international boycott
No new countries are added, and no countries are removed from the prior list.
June 9, 2025
News
IRS grants tax relief for taxpayers affected by storms in Missouri and Oklahoma
Deadlines falling on or after March 14, 2025, and before November 3, 2025, are extended to November 3, 2025.
June 9, 2025
News
Eighth Circuit: Taxpayer changed method of accounting when it first began amortizing “base acres”
Change in method of accounting required IRS approval under section 446(e)
June 6, 2025
News
Rev. Proc. 2025-23: Updated annual list of automatic accounting method changes
Generally effective for Forms 3115 filed on or after June 9, 2025, for a year of change ending on or after October 31, 2024
June 6, 2025
News
KPMG article: Analysis of New York State trial court decision on out-of-state online retailers
Court failed to adequately consider the legislative intent of P.L. 86-272.
June 6, 2025
News
Ninth Circuit: Discharged debt resulting in COD income not presumed worthless for purposes of claiming section 166 bad debt deduction
Tax Court did not err in requiring taxpayer to prove worthlessness of discharged debt.
June 5, 2025
News
JCT releases “Bluebook” on tax legislation in 118th Congress
Bluebook provides explanations and estimated budget effects of tax legislation.
June 4, 2025
News
KPMG article: Notice 2025-27 provides CAMT relief to taxpayers
Notice provides taxpayer-favorable safe harbor for determining whether taxpayers are subject to CAMT
June 4, 2025
News
KPMG article: Analysis of AM 2025-001 and the IRS’ imposition of periodic adjustments under Treas. Reg. § 1.482-4
AM 2025-001 appears to be a change in the IRS’ position on the application of commensurate with income (CWI) standard.
June 3, 2025
News
KPMG report: Notice 2025-27 provides additional CAMT interim guidance
Initial analysis and observations on guidance regarding application of CAMT
June 2, 2025
State and Local Tax
Insight
June 23, 2025 | TWIST – This Week in State Tax
Recent state tax news for the week of June 23rd includes the Florida Legislature approving a budget with significant state tax changes, the Maryland Comptroller releasing guidance on new IT and data services taxes, a CAT ruling by the Ohio Supreme Court, and, in Pennsylvania, the Philadelphia City Council approving its FY2026 budget.
Insight
TWIST - This Week in State Tax
What’s included: Discussion on noteworthy developments with broad applicability to taxpayers across the country. Brought to you by: KPMG Washington National Tax – State and Local Tax practice.
Insight
SALT Technology Checklist
A quarterly publication that summarizes technology-related state tax guidance and legislative developments
Insight
TWIST-Q
A quarterly roundup of This Week in State Tax (TWIST) podcasts which includes a detailed checklist of state tax legislative updates.
News
Ways and Means Republicans reintroduce OECD Pillar Two reciprocity bill
“Unfair Tax Prevention Act” would increase the U.S. BEAT where foreign countries adopt Pillar Two’s UTPR
March 28, 2025
News
Senate confirms Michael Faulkender as Deputy Treasury Secretary
Confirmed by a vote of 53-43
March 27, 2025
News
Senate passes joint resolution overturning digital asset information reporting regulations
The resolution now goes to President Trump, who is expected to sign it.
March 27, 2025
News
Announcement 2025-13: U.S. APMA program, APA statistics for 2024
26th report describing the experience, structure, and activities of the APMA program
March 27, 2025
News
IRS practice unit: Section 179D energy efficient commercial buildings deduction
LB&I practice unit about section 179D energy efficient commercial buildings deduction
March 27, 2025
News
KPMG article: How generative AI can improve transfer pricing processes
Questions and points to consider when using GenAI
March 26, 2025
News
KPMG report: Accounting for indemnification arrangements associated with transferable credits
Overview of accounting for indemnification arrangements associated with the acquisition of transferable credits
March 25, 2025
News
IRS practice units: Various partnership, foreign tax credit, and compensation issues
Eight LB&I practice units covering various partnership, foreign tax credit, and compensation issues
March 24, 2025
News
Federal Circuit: “Hatch-Waxman” litigation expenses not capital expenses and may be deducted in year incurred
Federal Circuit affirms Court of Federal Claims decision allowing taxpayer to deduct expenses in year incurred
March 21, 2025
News
Announcement 2025-8: Competent authority arrangement under U.S.-Switzerland treaty regarding dividends received by retirement plans
CAA is operative for dividends paid on or after January 1, 2020
March 21, 2025
News
KPMG report: Final regulations on clean electricity production and investment credits under sections 45Y and 48E
A KPMG report that provides analysis and observations of the final regulations on clean electricity production and investment credits.
March 20, 2025
News
KPMG article: Effect of digital transformation on transfer pricing
Examples of how digital transformation is creating transfer pricing issues for multinational enterprises
March 18, 2025
News
IRS provides tax relief for taxpayers affected by storms in West Virginia
Taxpayers in parts of West Virginia have until November 3, 2025, to file various federal tax returns and make payments.
March 14, 2025
News
Connecticut: Extended filing and payment deadline for 2024 composite income tax and passthrough entity tax returns
New forms not yet integrated into tax authority platform
March 11, 2025
News
KPMG report: Clean fuel production credit under section 45Z
Analysis and observations on Notices 2025-10 and 2025-11
March 10, 2025
News
Rev. Rul. 2025-7: Interest rates, tax underpayments and overpayments remain the same for second quarter 2025
Interest rates for the calendar quarter beginning April 1, 2025
March 6, 2025
News
Waiver of time requirements for individuals electing to exclude foreign earned income because of adverse conditions
Rev. Proc. 2025-17 provides information to any individual who failed to meet the eligibility requirements of section 911(d)(1)
March 5, 2025
News
Notice 2025-16: Housing expense limit adjustments, foreign locations for 2025
Increased amount that a qualified individual can elect to exclude from gross income as a housing cost amount
March 5, 2025
News
KPMG report: Forms 1042 and 1042-S reporting updates
Practical tips for navigating 2025 filing season
March 5, 2025
Tax Services
News
IRS practice units: Foreign tax credit categorization of income and taxes, carryback and carryover, sourcing of income
Three “practice units” related to foreign tax credits
January 29, 2025
News
Senate confirms Scott Bessent as Treasury Secretary
U.S. Senate vote was 68-29
January 28, 2025
News
California: Property tax relief due to wildfires
Taxpayers generally must apply for reassessment within 12 months
January 28, 2025
News
KPMG report: Employers providing employee assistance for victims of Los Angeles wildfires
KPMG report reviews the options for employers, and some of the advantages and disadvantages of each.
January 28, 2025
News
KPMG report: SEC comments on accounting for income taxes
Examples of comments about accounting for income taxes recently issued by the U.S. Securities and Exchange Commission
January 28, 2025
News
KPMG report: Initial observations on a second Trump presidency and the implications for U.S. infrastructure investment
Presidential actions and orders that may have implications for infrastructure investment in the United States
January 24, 2025
News
KPMG article: Debt workouts in commercial real estate
Tax ramifications to borrowers looking to refinance properties
January 22, 2025
News
White House announcement on OECD “Global Tax Deal”
A memorandum from President Trump’s White House regarding the OECD “Global Tax Deal”
January 21, 2025
News
Trump signs executive order placing hiring freeze for federal civilian employees with no expiration date for IRS
Hiring freeze will remain in effect for IRS until lift determined to be in national interest
January 21, 2025
News
Daniel Werfel resigns as IRS Commissioner, Trump formally nominates William Long to replace him
The current Deputy Commissioner will serve as the Acting Commissioner until a nominee is confirmed.
January 21, 2025
News
KPMG report: Regulations regarding digital content and cloud transactions
Analysis and observations on the final and proposed regulations
January 21, 2025
News
KPMG report: Proposed regulations on additional five highest compensated employees subject to section 162(m)
The proposed regulations are proposed to apply for tax years beginning after the later of December 31, 2026, or the date of publication of the final regulations.
January 21, 2025
News
Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations
Legal advice memorandum from the Office of Chief Counsel
January 21, 2025
News
Notices of filing of petitions for addition of cyanuric acid, potassium carbonate, potassium bicarbonate, and sodium chlorite to Superfund list
Petitions have been filed by a single petitioner requesting that four substances be added to the list of taxable substances under section 4672(a)
January 17, 2025
News
IRS updates FAQs for energy efficient home improvement and residential clean energy property credits
Supersede earlier FAQs posted in April 2024
January 17, 2025
News
Notice 2025-8: Updated elective safe harbor for domestic content bonus credit guidance amounts under sections 45, 45Y, 48, and 48E
Modification to safe harbor provided in Notice 2024-41
January 16, 2025
News
Rev. Rul. 2025-4: Guidance for states that have paid family and medical leave programs
Includes transition relief for state paid medical leave benefits paid made during calendar year 2025
January 16, 2025
News
KPMG report: Implications of Denham Capital Management LP v. Commissioner Tax Court Opinion
Partners were more akin to employees than passive investors and all the partnership allocations at issue were subject to self-employment
January 16, 2025
News
Notice 2025-9: Safe harbors regarding incremental cost and retail price equivalent of certain qualified commercial clean vehicles for purposes of section 45W credit
Notice is effective on January 15, 2025
January 15, 2025
News
Announcement 2025-6: Pilot program to test changes to alternative dispute resolution (ADR) programs
IRS is requesting comments on the pilot changes
January 15, 2025
News
Rev. Proc. 2025-14: List of qualifying technologies for clean electricity credits
First annual table that provides greenhouse gas emissions rates for certain types or categories of facilities that are eligible for the clean electricity production
January 15, 2025
News
KPMG article: Tax issues raised by development of valuable digital IP and data assets
Including transfer pricing issues
January 15, 2025
News
Michigan: Research and development credit law enacted
New R&D tax credit effective for tax years beginning on or after January 1, 2025
January 15, 2025
News
Final regulations: Guidance relating to IRS Independent Office of Appeals
Final regulations provide that while Appeals resolution process is generally available to all taxpayers, there are certain exceptions.
January 14, 2025
News
Proposed regulations: Limitation of deduction for certain employee remuneration under section 162(m)
Proposed regulations implement amendments made to section 162(m) by American Rescue Plan Act of 2021
January 14, 2025
News
Notice 2025-12: Indexing factor for use by group health plans and health insurance issuers in 2025 under “No Surprises Act” provisions
Indexing factor used to calculate “qualifying payment amount”
January 14, 2025
News
Rev. Proc. 2025-13: Streamlined procedure for taxpayers to revoke election to apply alternative tax for non-life insurance companies under section 831(b)
Procedure provided in response to comments received on regulations identifying micro-captive listed transactions and micro-captive transactions of interest
January 14, 2025
News
Reporting deadlines for certain partnership “basis shifting” transactions identified as transactions of interest
Published version of the final rule provides reporting deadlines.
January 14, 2025
News
Proposed regulations: Guidance on corporate separations, incorporations, and reorganizations qualifying for nonrecognition of gain or loss
Including proposed regulations that would require multi-year tax reporting for corporate separations and related transactions
January 13, 2025
News
Proposed regulations withdrawn: Amendments to coverage of certain preventive services under Affordable Care Act
Notice of proposed rulemaking that appeared in the Federal Register on October 28, 2024, will be withdrawn.
January 13, 2025
News
Final regulations: Guidance regarding certain disregarded payments and dual consolidated losses (DCLs)
Rules from proposed regulations relating to disregarded payment losses (DPLs) finalized, additional transition relief for application of DCL rules to Pillar Two rules
January 10, 2025
News
Final regulations: Certain partnership “basis shifting” transactions identified as transactions of interest
Final regulations adopt proposed regulations issued in June 2024 with certain changes in response to comments received
January 10, 2025
News
Final regulations: Micro-captive listed transactions and micro-captive transactions of interest
Final regulations identify certain micro-captive transactions as reportable transactions
January 10, 2025
News
Proposed regulations: Base erosion and anti-abuse tax (BEAT) rules for qualified derivative payments (QDPs) on securities lending transactions
Guidance under section 59A BEAT rules regarding how QDPs in connection with securities lending transactions are determined and reported
January 10, 2025
News
Proposed regulations: Guidance on section 45W credit for qualified commercial clean vehicles
Proposed regulations providing guidance on the qualified commercial clean vehicle credit under section 45W
January 10, 2025
News
Proposed regulations: Guidance on catch-up contributions to retirement plans
Proposed regulations reflect statutory changes made by the “SECURE 2.0 Act of 2022”
January 10, 2025
News
Proposed regulations: Automatic enrollment requirements under section 414A
Guidance with respect to the automatic enrollment requirements that apply to certain retirement plans under section 414A
January 10, 2025
News
Treasury and IRS release guidance on clean fuel production credit under section 45Z
Guidance includes notice of intent to propose regulations and notice providing annual emissions rate table
January 10, 2025
News
IRS provides tax relief for taxpayers affected by California wildfires
Affected taxpayers have until October 15, 2025, to file various tax returns and make tax payments.
January 10, 2025
News
Final and proposed regulations: Classification of digital content and cloud transactions for purposes of international provisions of the Code
Comments requested under Notice 2025-6 on extending rules to all provisions of the Code
January 10, 2025
News
Final regulations: Guidance under section 2801 regarding the imposition of tax on certain gifts and bequests from covered expatriates
Apply to covered gifts and bequests received on or after January 1, 2025
January 10, 2025
News
KPMG report: Analysis and observations on investment tax credit for energy property under section 48
Rules for determining whether investments in energy property are eligible for the energy credit and for defining an energy project
January 9, 2025
News
Final regulations and Rev. Proc. 2025-11: Guidance on environmental justice clean electricity capacity limitation program
Program provides an increase to the new clean electricity investment tax credit rate available under section 48E
January 8, 2025
News
Rev. Rul. 2025-3 and Rev. Proc. 2025-10: Guidance on definition of employee under section 530 of the Revenue Act of 1978
Clarifications and modifications regarding the application of section 530 of the Revenue Act of 1978
January 8, 2025
News
IRS announces extra day for taxpayers to file any returns, pay any tax due January 9
Extra day granted because of Carter remembrance day
January 8, 2025
News
National Taxpayer Advocate report to Congress identifying taxpayer problems
Administrative and legislative recommendations to address problems
January 8, 2025
News
KPMG report: Observations on amendments to section 52 regulations as part of amendments to consolidated return regulations
Changes to the constructive ownership rules
January 8, 2025
News
Final regulations: Clean electricity production and investment credits under sections 45Y and 48E
Clean electricity production and clean electricity investment credits as established by the “Inflation Reduction Act of 2022”
January 7, 2025
News
KPMG article: Commensurate with income standard in transfer pricing
Evolution of the commensurate with income (CWI) standard, its current and prospective application, and its practical implications for taxpayers
January 6, 2025
News
Final regulations: Clean hydrogen production credit and related energy credit
Final regulations apply to tax years beginning after December 26, 2023
January 3, 2025
News
IRS annual revenue procedures for 2025
Six annual revenue procedures
January 3, 2025
News
U.S. Treasury release: No change to list of countries cooperating with international boycott
No new countries are added, and no countries are removed from the prior list.
January 2, 2025
News
Proposed regulations and Rev. Proc. 2025-9: Excise tax under section 5000D on designated drugs
Proposed regulations adopt rules consistent with substantive rules described in Notice 2023-52
December 31, 2024
News
Announcement 2025-5: Partial suspension by mutual agreement of income tax treaty with USSR as it relates to Belarus
Suspension is effective December 17, 2024, until December 31, 2026
December 31, 2024
News
Notice 2025-7: Temporary relief for making adequate identification of units of digital assets held in broker’s custody
Allows reliance on alternative methods for making an adequate identification during the period beginning on January 1, 2025, and ending on December 31, 2025
December 31, 2024
News
Final and proposed regulations: Amendments to consolidated return regulations to reflect statutory changes, modernize language, and enhance clarity
Final and proposed consolidated return regulations
December 27, 2024
News
Final regulations: Treatment of tax-exempt bonds as retired
Final regulations address when tax-exempt bonds are treated as retired for purposes of sections 103 and 141 through 150
December 27, 2024
News
Information reporting by non-custodial brokers of digital asset transactions
Final regulations requiring information reporting by non-custodial digital asset brokers and transitional relief under Notice 2025-3
December 27, 2024
News
Technical corrections to proposed regulations on corporate alternative minimum tax (CAMT)
Comments on the proposed regulations are still being accepted until January 16, 2025.
December 23, 2024
News
Proposed regulations withdrawn: Rescission of “moral exemption rule” to coverage of certain contraceptive services under Affordable Care Act
The notice of proposed rulemaking that appeared in the Federal Register on February 2, 2023, is withdrawn.
December 23, 2024
News
U.S. Tax Court: Active partners’ income subject to self-employment tax
The court upheld the IRS's adjustments.
December 23, 2024
News
Final regulations: Rules for supervisory approval of penalties
Proposed regulations adopted with minor modifications
December 20, 2024
News
Proposed regulations: Updated rules contained in Circular 230 for tax professionals who can practice before IRS
The proposed regulations would incorporate new provisions that better align Circular 230 with the current practice environment.
December 20, 2024
News
IRS contingency plan during possible government shutdown
The IRS updates its contingency plan in anticipation of a possible government shutdown.
December 20, 2024
News
IRS seeks feedback on draft Instructions for Form 6765, Credit for Increasing Research Activities
The IRS is seeking feedback on the draft instructions until June 30, 2025.
December 20, 2024
News
Rev. Proc. 2024-42: Updated list of jurisdictions for exchanging deposit interest information
The IRS periodically issues guidance that updates and adds countries.
December 20, 2024
News
Rev. Rul. 2025-2: Covered compensation tables for 2025 plan year
The IRS provided tables of covered compensation under section 401(l)(5)(E) for the 2025 plan year.
December 20, 2024
News
KPMG report: Determination under section 987 of taxable income or loss and foreign currency gain or loss with respect to a QBU
Analysis and observations of final and proposed regulations
December 19, 2024
News
KPMG report: Proposed PTEP regulations
Analysis and observations
December 19, 2024
News
KPMG report: Proposed adoption of Amount B in the United States
Notice 2025-4 would allow the U.S. application of Amount B—an OECD-initiative to simplify transfer pricing for baseline marketing and distribution activities.
December 19, 2024
News
Source of gain under section 937 from certain dispositions of stock (IRS Chief Counsel memorandum)
Memorandum addresses source of gain from certain sales of stock by U.S. citizen who becomes resident of Puerto Rico
December 19, 2024
News
Notice 2025-5: Standard mileage rates for 2025
Standard mileage rates for taxpayers to use in computing the deductible costs of operating an automobile for business, charitable, medical, or moving purposes
December 19, 2024
News
Notice 2025-4: Application of Pillar One Amount B simplified and streamlined approach
Treasury and IRS announce intention to issue proposed regulations applicable to tax years beginning on or after January 1, 2025.
December 18, 2024
News
Announcement 2025-2: Certain portions of proposed regulations on required minimum distributions under section 401(a)(9) will not apply until 2026
Proposed regulations were generally proposed to apply beginning 2025
December 18, 2024
News
Rev. Proc. 2025-8: Expanded waiver of eligibility rules to accounting method changes to comply with section 174
The revenue procedure is generally effective for Forms 3115 filed on or after December 17, 2024.
December 17, 2024
News
Final regulations: Definition of the term “coverage month” for computing premium tax credit
The final regulations apply to tax years beginning on or after January 1, 2025.
December 17, 2024
News
IRS announces tax relief for taxpayers in West Virginia affected by Post-Tropical Storm Helene
Various deadlines postponed to May 1, 2025
December 17, 2024
News
Washington State: Insurance company affiliate qualifies for insurance business B&O tax exemption (Supreme Court decision)
Affiliate qualifies for exemption on income earned from providing services to insurance company
December 17, 2024
News
Notice 2025-2: Penalty relief for partnerships to provide complete Forms 8308 for section 751(a) exchanges
The IRS will not impose penalties for failing to furnish a completed Part IV of Form 8308 by the due date, provided that the partnership meets specific conditions.
December 13, 2024
News
IRS provides new tax penalty relief for Maui wildfire victims
Relief is separate from disaster relief announced in August 2023
December 12, 2024
News
Louisiana: Several tax bills approved
Bills present significant reform of state tax structure.
December 12, 2024
News
U.S. Tax Court: Taxpayer entitled to section 199 deductions
Tax Court held that taxpayer qualified for section 199 deductions, but found the taxpayer’s allocation of gross receipts and related expenses unreasonable.
December 11, 2024
News
Final and proposed regulations: Taxable income or loss and foreign currency gain or loss with respect to a QBU
Final and proposed regulations under section 987
December 10, 2024
News
Announcement 2024-42: U.S.-Norway competent authority arrangement regarding regulated investment companies
Competent authorities agree that Article 20 (investment or holding companies) is not applicable to regulated investment companies
December 9, 2024
News
KPMG report: Implications of designations of Bourse de Montreal and European Energy Exchange as “qualified boards of exchange”
The designations will cause certain contracts traded through these exchanges to be treated as section 1256 contracts.
December 9, 2024
News
IRS practice unit: Examining a reseller’s 263A computation
IRS Large Business and International division publicly released a “practice unit”
December 6, 2024
News
Notice 2024-82: Required amendments list (2024) for qualified retirement plans and 403(b) plans
List of changes to qualification requirements with which a plan must comply
December 5, 2024
News
Trump to nominate Scott Bessent as Treasury Secretary, Billy Long as IRS Commissioner
President-elect Donald Trump announced nominations for Treasury Secretary and IRS Commissioner
December 5, 2024
News
Final regulations: Definition of energy property and rules applicable to energy credit under section 48
Final regulations adopt proposed regulations issued in November 2023
December 4, 2024
News
Comment period extended for proposed regulations on corporate alternative minimum tax (CAMT)
Comment period extended from December 12, 2024, to January 16, 2025
December 3, 2024
News
Proposed regulations: Unmarked vehicles used by emergency responders treated as qualified nonpersonal use vehicles under sections 274 and 280F
Rules would allow such vehicles to be excepted from the substantiation requirements for deductibility of related expenses
December 2, 2024
News
Proposed regulations: Previously taxed earnings and profits and related basis adjustments
Rules would address longstanding issues under sections 959 and 961
November 29, 2024
News
Final regulations: Recourse partnership liabilities and related party rules under section 752
Final rules adopt proposed regulations issued in December 2013
November 29, 2024
News
Notices of filing of petitions for addition of di-isobutyl carbinol, di-isobutyl ketone, and methyl isobutyl carbinol to Superfund list
Petitions have been filed requesting that three substances made from propylene be added to the list of taxable substances under section 4672(a)
November 27, 2024
News
Announcement 2024-40: Treatment of amounts paid under agreements with Commerce Department for purposes of section 48D advance manufacturing investment credit
Such amounts will not fail to constitute a “qualified investment” provided requirements of section 48D are otherwise satisfied
November 26, 2024
News
Notice 2024-85: Form 1099-K transition relief for calendar year 2024 and 2025 transactions
Form 1099-K threshold is $5,000 for calendar year 2024 and $2500 for calendar year 2025
November 26, 2024
News
Final regulations: Disclosure of specified return information to Bureau of the Census for statistical purposes
Final rules adopt proposed regulations with minor changes
November 25, 2024
News
Tier 2 tax rates for railroads, no changes for 2025
Imposed on railroad employees, employers, and employee representatives
November 25, 2024
News
IRS practice units: Producer’s section 263A computation and LIFO pooling requirements
IRS Large Business and International division released two updated “practice units”
November 25, 2024
News
Notice 2024-84: Extension of transitional process for applicable entities to claim statutory exceptions to phaseouts for clean energy credits if domestic content requirements not met
Application of phaseouts for credits determined under sections 45 (renewable electricity production), 45Y (clean electricity production), 48 (energy), and 48E (clean electricity investment)
November 22, 2024
News
Announcement 2024-38: Updates on second remedial amendment cycle for section 403(b) pre-approved plans
The IRS intends to issue opinion letters for section 403(b) pre-approved plans that were updated for changes.
November 22, 2024
News
IRS provides tax relief to taxpayers in the Crow Tribe of Montana affected by severe storms and straight-line winds
Various deadlines postponed to February 3, 2025
November 21, 2024
News
FBAR filings: Extended deadline is April 15, 2026, for individuals with signature authority
For all other U.S. individuals with an FBAR filing obligation, the filing due date remains April 15, 2025.
November 20, 2024
News
IRS practice unit: Land developers and subcontractors—proper method of accounting
IRS Large Business and International division publicly released a “practice unit”
November 20, 2024
News
Final and proposed regulations: Access to clean energy tax credits for co-owned projects through elective pay (“direct pay”)
Allows certain unincorporated organizations to opt out of partnership tax rules, facilitating the use of clean energy tax credits
November 19, 2024
News
U.S. Treasury to allocate $10 billion in New Markets Tax Credit (NMTC) authority for 2024 and 2025
Encourages private sector investment in distressed communities
November 19, 2024
News
U.S. Tax Court: IRS does not have statutory authority to assess penalties for willful failure to file Form 5471
U.S. Tax Court reaffirmed its original decision
November 18, 2024
News
Rev. Rul. 2024-25: Interest rates, tax underpayments and overpayments decrease for first quarter 2025
Interest rates for the calendar quarter beginning January 1, 2025
November 18, 2024
News
KPMG report: Notable highlights from section 48D final regulations (advanced manufacturing investment credit)
KPMG observations and analysis of the final regulations
November 14, 2024
News
KPMG report: Final regulations on advanced manufacturing production credit under section 45X
KPMG observations and analysis of the final regulations
November 14, 2024
News
IRS announces tax relief for taxpayers affected by storms and flooding in Chaves County, New Mexico
Various deadlines postponed to May 1, 2025
November 13, 2024
News
IRS provides tax relief for taxpayers in Cheyenne River Sioux Tribe in South Dakota affected by storms
Various deadlines postponed to February 3, 2025
November 13, 2024
News
Deductibility of FDIC special assessments not limited under section 162(r)
IRS Chief Counsel memorandum
November 12, 2024
News
IRS announces tax relief for taxpayers in Saint Regis Mohawk Tribe in New York affected by storms and flooding
Various deadlines postponed to February 3, 2025
November 12, 2024
News
KPMG article: IRS’s personal use of business aircraft campaign
IRS plans to begin auditing the personal use of business aircraft with its business aircraft campaign
November 11, 2024
News
Extension of certain timeframes for employee benefit plans and participants affected by Hurricane Helene, Tropical Storm Helene, or Hurricane Milton
Extension generally suspends until May 1, 2025, the tolling of various periods and dates under ERISA and the Code applicable to employee benefit plans and their participants
November 7, 2024
News
IRS grants tax relief for taxpayers in Havasupai Tribe in Arizona affected by flooding
Deadlines extended to February 3, 2025
November 7, 2024
News
KPMG report: Election results, preliminary observations regarding effect on future tax agenda
Preliminary observations regarding effect of yesterday’s election results on future tax agenda
November 6, 2024
News
KPMG article: Tax Court’s application of strict construction rule in interpreting Treasury regulations
The Tax Court applied the strict construction rule to decide in the taxpayer’s favor.
November 5, 2024
News
KPMG article: Subchapter K changes as possible revenue raisers in addressing 2025 “Tax Cliff”
Changes affecting the taxation of partnerships may be considered by lawmakers.
November 4, 2024
News
Notice 2024-80: Pension plans, cost-of-living adjustments for 2025
Amount individuals can contribute to their 401(k) plans in 2025 has increased to $23,500, up from $23,000 for 2024.
November 1, 2024
News
U.S. Tax Court: Loss under section 1256(c) on foreign currency option transaction disallowed under section 165(c) for lack of profit motive
Tax Court agreed with IRS that the taxpayers did not establish any profit motive for entering into the foreign currency option transactions
October 31, 2024
News
U.S. Tax Court: Basis in partnership interest must be decreased by losses deducted in prior closed tax years
Tax Court agreed with IRS that taxpayer must decrease its basis in partnership for previously deducted passthrough losses
October 30, 2024
News
IRS practice unit: Section 250 deduction—foreign-derived intangible income (FDII)
Updated to remove references to resources that are no longer available
October 30, 2024
News
U.S. Treasury announces the beginning of negotiation of a tax agreement with Taiwan
United States and Taiwan will begin negotiations on a comprehensive agreement to address double taxation issues.
October 29, 2024
News
Notice 2024-78: Extension of temporary relief for foreign financial institutions required to report U.S. TINs
Notice 2024-78 extends the temporary relief provided in Notice 2023-11
October 28, 2024
News
IRS provides tax relief to taxpayers affected by floods in Juneau, Alaska
Deadlines extended to May 1, 2025
October 25, 2024
News
Final regulations: Guidance on advanced manufacturing production credit under section 45X
The final regulations retain the same basic structure as proposed regulations issued in December 2023, with certain revisions.
October 24, 2024
News
Proposed regulations and Rev. Proc. 2024-31: Guidance on energy efficient home improvement credit under section 25C
General guidance on the section 25C credit, including what property qualifies and rules for manufacturers to register to be qualified manufacturers
October 24, 2024
News
Proposed regulations: Amendments to coverage of certain preventive services under Affordable Care Act
Proposed rules would enhance coverage of preventive services, including contraceptive items.
October 23, 2024
News
Treasury, IRS grant tax-exempt organizations exception from filing CAMT form for 2023
Exception from filing Form 4626 for tax year 2023
October 23, 2024
News
United States: IRS issuing manual IDES notifications through October 31
Delayed distribution due to recent hurricanes
October 23, 2024
News
Final regulations: Advanced manufacturing investment credit rules under sections 48D and 50
The final regulations adopt with certain modifications proposed regulations issued in March 2023.
October 22, 2024
News
Rev. Proc. 2024-40: Inflation adjustments for 2025, individual taxpayers
Amounts to be used by individual taxpayers on their 2025 returns
October 22, 2024
News
KPMG reports: California (bad debt deductions for sales and use tax purposes); Ohio (debit authorization services not subject to sales tax); Washington State (B&O apportionable services reconciliation)
KPMG This Week in State Tax focuses on recent state and local tax developments.
October 21, 2024
News
Notice 2024-74: Additional guidance on safe harbors for sustainable aviation fuel credit
Guidance applies as of October 18, 2024.
October 18, 2024
News
Final regulations: Withholding under sections 3405(a) and (b) on certain payments and distributions from retirement plans
The final regulations adopt proposed regulations issued in May 2019 with no substantive modifications except a changed applicability date.
October 18, 2024
News
Notices related to treatment of amounts paid for contraceptives under health savings accounts and high deductible health plans
Expenditures for breast cancer screenings, glucose monitors, and certain insulin products also addressed
October 17, 2024
News
Delaware: Changes to unclaimed property law
Many immediate and some retroactive changes
October 16, 2024
News
Notice 2024-77: Guidance under sections 414(aa) and 402(c)(12) regarding correction of inadvertent benefit overpayments
Comments on the guidance are due by December 16, 2024.
October 15, 2024
News
KPMG reports: South Dakota (use tax on construction equipment); Virginia (disregarded entity not subject to BPOL tax); multistate (tax-related ballot measures, manufacturing sales and use tax exemption rulings)
KPMG This Week in State Tax focuses on recent state and local tax developments.
October 15, 2024
News
Section 250 deduction subject to limitation under each of section 250(a)(2), 246(b)(3)(A), and 246(b)(3)(B)
IRS Chief Counsel memorandum
October 11, 2024
News
IRS provides tax relief for taxpayers of San Carlos Apache Tribe in Arizona affected by Watch Fire
Affected taxpayers have until February 3, 2025, to file various tax returns and make tax payments.
October 11, 2024
News
IRS provides tax relief for taxpayers in Florida affected by Hurricane Milton
Tax relief until May 1, 2025, for individuals and businesses in Florida affected by Hurricane Milton
October 11, 2024
News
IRS announces dyed diesel penalty relief in Florida due to Hurricane Milton
The relief begins on October 9, 2024, and will remain in effect through October 30, 2024.
October 11, 2024
News
Final regulations: Section 367(d) rules for certain repatriations of intangible property
The final regulations adopt proposed regulations issued in May 2023 with certain revisions.
October 9, 2024
News
KPMG article: New York City corporate tax regulations may deviate from state regulations
An article that discusses how the City’s update on how it may deviate from the state’s corporate tax regulations may simplify sourcing determinations for corporate taxpayers.
October 9, 2024
News
Final regulations: Certain syndicated conservation easement transactions identified as listed transactions
The final regulations adopt proposed regulations published in December 2022 with certain revisions.
October 7, 2024
News
Proposed regulations: Federal tax classification of entities wholly owned by Indian Tribal governments
Entities wholly owned by Indian Tribal governments generally would not recognized as separate entities
October 7, 2024
News
KPMG reports: California (sales tax agreement reports); Nevada (voluntary disclosure agreement program); New York (sales tax on electronic currency trading, web-based document processing)
KPMG This Week in State Tax focuses on recent state and local tax developments.
October 7, 2024
News
KPMG report: Analysis and observations on the proposed CAMT regulations
A report that summarizes a number of key issues from the proposed regulations and provides observations.
October 4, 2024
News
KPMG report: Exceptions under final broker digital asset reporting regulations
Closed loop transactions and limited access regulated networks
October 4, 2024
News
IRS Priority Guidance Plan for 2024-2025
The U.S. Treasury Department and IRS released the 2024-2025 Priority Guidance Plan.
October 4, 2024
News
United States: IRS issues list of qualified intermediary (QI) entities and branches
QIs need to review the list and update any inaccurate information.
October 4, 2024
News
Notice 2024-73: Guidance on long-term, part-time employees in 403(b) retirement plans
Comments requested on or before December 20, 2024
October 3, 2024
News
IRS provides tax relief for taxpayers in parts of Washington State affected by wildfires
Affected taxpayers have until February 3, 2025, to file various tax returns and make tax payments.
October 3, 2024
News
KPMG article: Tax incentives under IRA, CHIPS Act, and U.S. FTZ Program
Such incentives may result in significant benefits to qualifying companies
October 3, 2024
News
Rev. Rul. 2024-23: European Energy Exchange held “qualified board or exchange”
The revenue ruling is effective for European Energy Exchange contracts entered into on or after November 1, 2024.
October 2, 2024
News
Treasury statement on implementation of IRA’s clean energy provisions
Progress to date, and future plans, for implementation of the clean energy provisions of the “Inflation Reduction Act”
October 2, 2024
News
KPMG article: State income tax consequences of green energy tax credit sales
Some states may not conform to the rules allowing taxpayers to monetize green energy tax credits, potentially creating surprising state income tax liabilities.
October 2, 2024
News
IRS provides tax relief for taxpayers in all or parts of seven states affected by Hurricane Helene
Tax relief for individuals and businesses in all of Alabama, Georgia, North Carolina, and South Carolina, and parts of Florida, Tennessee, and Virginia, affected by Hurricane Helene
October 1, 2024
News
IRS provides dyed diesel penalty relief due to Hurricane Helene
The relief is retroactive from September 26, 2024, and will last until October 15, 2024.
October 1, 2024
News
Notice 2024-72: IRS provides new relief for taxpayers affected by terroristic action in Israel
New relief for persons that the Secretary of the Treasury has determined to be affected by the terroristic action in the State of Israel.
October 1, 2024
News
IRS provides tax relief for taxpayers in parts of Illinois affected by severe storms, tornadoes
Tax relief for individuals and businesses in parts of Illinois affected by severe storms, tornadoes, straight-line winds, and flooding that began on July 13, 2024.
October 1, 2024
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