TCJA: Collection of Insights on the 2017 Tax Act

Articles, publications, and videos from KPMG about the implementation of the 2017 tax legislation

John P. Gimigliano

John P. Gimigliano

Principal, Washington National Tax, KPMG US

+1 202-533-4022
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This page archives KPMG insights about the implementation of the 2017 tax legislation – Pub. L. No. 115-97, commonly called the Tax Cuts and Jobs Act (TCJA), starting after the signing of the new tax law by President Trump on December 22, 2017. Click on the down arrows to access past materials buy KPMG professionals.

TCJA insights

Latest insights

2022

  • Capitalization Punishment: The New Rules of Section 174, February 17, 2022

    Mandatory capitalization of R&E is here (for now). In this KPMG Inside International Tax podcast, we turn to this sleeper provision from the TCJA and unpack some of the international tax implications from the provision that might ripple through your financial statements and tax returns.

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  • The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations, February 1, 2022

    As 2021 wound to a close, Treasury and IRS left us with a parting gift to unwrap and analyze. In this KPMG Inside International Tax podcast, we describe select aspects of the final foreign tax credit regulations and consider, among other things, their impact on our understanding of the evolving network of global foreign levies.

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  • KPMG report: Regulations Addressing Tax Treatment of U.S. Partnerships and S Corporations that Own Stock of CFCs and PFICs, January 28, 2022

    This KPMG report provides initial impressions and observations about the final and proposed rules published in the Federal Register on January 25, 2022.

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  • TCJA Changes to R&E Related Code Sections Kick In, Tax Management Memorandum, January 24, 2022

    In this article, the authors highlight issues taxpayers must consider now that the scheduled changes to the treatment of research and experimentation (R&E) expenditures—mandatory amortization—have taken effect beginning January 1, 2022.

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  • KPMG Report: Initial Analysis of Final Regulations Concerning Foreign Tax Credit, January 5, 2022

    This KPMG report provides a discussion and initial analysis of the final regulations released in late 2021 and published in the Federal Register yesterday relating primarily to foreign tax credit (FTC) determination and the allocation and apportionment of deductions (including foreign income taxes) in determining the FTC limitation.

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  • KPMG Report: Foreign Tax Credit and Certain Deductions of Life Insurance Companies, January 4, 2022

    Final regulations published today include provisions that address the allocation and apportionment of section 818(f)(1) items of life insurance companies that are members of consolidated groups. KPMG provides a summary and observation about these provisions.

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2021

December

TCJA insights

  • KPMG Report: R&E Changes from TCJA Effective for Tax Years Beginning after December 31, 2021, December 22

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May

TCJA insights

  • State of Play: State Taxation of Foreign Income After the TCJA, KPMG Inside International Tax podcast, May 24

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January

TCJA insights

  • Final Regulations on Carried Interest, KPMG What's New in Tax, January 25

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  • KPMG Report: Final Regulations under Section 163(j), Limitation on Deductions for Certain Business Interest Expenses, January 19

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  • KPMG Report: Final and Proposed Regulations, Passive Foreign Investment Company (PFIC) Rules, January 15

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  • KPMG Report: Final Regulations on Carbon Oxide Sequestration Credit, January 15

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  • KPMG Report: Final Section 4960 Regulations on Excise Tax for Excess Remuneration and Excess Parachute Payment for Applicable Tax-Exempt Organizations, January 13

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  • KPMG Report: Final Regulations on Changes to Income Recognition Rules; Initial Impressions, January 6

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Volume of select TCJA regulations – View graphic
Number of pages as of January 7, 2021

 

2020

December

Tax reform insights

  • KPMG Report: Final Regulations, Section 162(m) Deduction Limitation on Executive Compensation, December 21

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  • KPMG Report: Final Regulations under Section 1031, Like-Kind Exchanges, December 2

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November

Tax reform insights

  • KPMG Report: Analysis of Final and Proposed Foreign Tax Credit Regulations, November 24

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  • KPMG Report: Final Regulations under Sections 245A and 954(c)(6) and Correcting Amendments, November 24

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October

Tax reform insights

  • KPMG Report: Correcting Amendments to Final Regulations, FDII and GILTI, October 30, 2020

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  • KPMG Report: Final Regulations on Consolidated NOLs, Inclusive of Insurance Company Regulations, October 21

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  • KPMG Report: Initial Impressions of Final Regulations, Withholding and Reporting on Dispositions of Certain Partnership Interests, October 15

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  • KPMG Report: Treasury Responds to Insurance Comments in Proposed and Final Regulations Tax Credit, October 12

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  • KPMG Report: Initial Impressions of Final and Proposed Foreign Tax Credit Regulations, October 5

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  • KPMG Report: Final Regulations on Source of Income for Certain Sales of Personal Property, including Inventory, October 5

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  • KPMG Report: Final Regulations on Deductibility of Meal and Entertainment Expenses (Initial Impressions), October 2

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September

Tax reform insights

  • KPMG Report: Initial Impressions of Final and Proposed Regulations, Relief Concerning Repeal of Section 958(b)(4), September 21

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  • KPMG Report: Final Regulations on Computing and Reporting Life Insurance Reserves (Initial Impressions), September 15

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  • A Wolf in Sheep's Clothing: The IRS Creates a New Safe Harbor in Proposed Like-Kind Exchange Regulations, KPMG What's News in Tax, September 14

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  • Familiar Things Made New: Proposed Regulations Define "Real Property" for Like-Kind Exchanges, KPMG What's News in Tax, September 14

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  • KPMG Report: Regulations under Sections 245A, 951A 954 (GILTI); Treatment of Dividends from Foreign Corporations, September 3

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  • KPMG Report: Highlights of Final BEAT Regulations under Section 59A, September 3

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August

Tax reform insights

  • IRS Releases Proposed Regulations on Qualified Parking Deductions with Some Lane Changes, KPMG What's News in Tax, August 17

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  • KPMG Report: Analysis of Final and Proposed Regulations, High-Tax Exception under GILTI and Subpart F, August 13

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  • Proposed Regulations on Carried Interest, KPMG What's News in Tax, August 12

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  • KPMG Report: Initial Analysis of Regulations, Guidance under Section 163(j), August 4

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July

Tax reform insights

  • KPMG Report: Analysis of Final FDII Regulations – Tax Reform, July 31

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  • KPMG Report: Initial Impressions about Final and Proposed Regulations, High-Tax Exception under GILTI and Subpart F, July 21

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  • KPMG Report: Initial Impressions of Final Regulations Related to the Deduction for FDII and GILTI under Section 250, July 10

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  • KPMG Report: Insurance-related Measures in Consolidated NOL Regulations, July 7

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June

Tax reform insights

  • KPMG Report: Proposed Regulations and Guidance on Qualified Transportation Fringe Benefits, June 23

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May

Tax reform insights

  • A Fresh Look at a Stale Ambiguity in the Subpart F Rules, Tax Notes International, May 11

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April

Tax reform insights

  • KPMG Report: Initial Impressions of Proposed Regulations on Separately Computed UBTI, April 24

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  • KPMG Report: Relief for Taxpayers to Correct, Change QIP Depreciation Methods (Rev. Proc. 2020-25), April 22

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  • A Few Thoughts on REITS and the BEAT, Tax Notes Federal, April 20

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  • KPMG Report: Initial Impressions of Final Regulations Implementing “Anti-hybrid” Provisions, April 9

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January

Tax reform insights

  • Widening the Net – Proposed Regulations Expand Scope of $1 Million Section 162(m) Deduction Limitation on Certain Executive Compensation Paid by Public Companies, KPMG What's News in Tax, January 27

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  • KPMG Report: Transactions in the Age of Tax Reform, January 24

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  • KPMG Report: Analysis and Observations about Final Regulations and Future of Opportunity Zone Investments, January 23

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  • Fundamentals of Tax Reform: BEAT, 2019 Final and Proposed Regulations, Tax Management International Journal, January 10

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  • Transactions in the Age of Tax Reform, KPMG, January

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2019

December

Tax reform insights

  • Many Method for Computing Branch Losses, International Tax Journal, November-December

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  • KPMG Report: Analysis of Final and Proposed Foreign Tax Credit Regulations, December 20

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  • KPMG Report: Proposed Regulations Under Section 162(m) to Address Tax Law Changes (Initial Impressions), December 17

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  • KPMG Report: Analysis of Final Regulations and Additional Proposed Regulations under Section 59A ("BEAT"), December 12

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  • KPMG Report: "BEAT" Final Regulations, Provisions Applicable to Insurance Companies, December 9

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  • KPMG Report: Initial Impressions, Final Regulations and Additional Proposed Regulations under Section 59A ("BEAT"), December 2

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  • KPMG Report: Initial Impressions about Final and Proposed Foreign Tax Regulations, December 3

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November

Tax reform insights

  • BEAT: An Overview of the Statute and Proposed Regulations, Tax Management International Journal, November 8

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October

Tax reform insights

  • Proposed Regulations Address TCJA Gross Income Acceleration Requirement, October 24

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  • KPMG Report: Initial Impressions of Proposed Regulations Addressing Repeal of Section 958(b)(4); Relief Provided by Rev. Proc. 2019-40, October 3

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September

Tax reform insights

  • The GILTI High-Tax Exception: The Good, the Bad, and the Ugly, Tax Notes International, September 30

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  • Direct Lending with a Section 199A Tax Benefit, Tax Notes Federal, September 30

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  • KPMG Report: Proposed Regulations on Treatment of Built-in Items for Section 382 (Initial Impressions), September 13

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  • KPMG Report: Proposed Regulations on Changes to Income Recognition Rules (Initial Impressions), September 6

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  • Podcast | Qualified Transportation Fringes – An Often Overlooked Fringe Benefit, September

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  • Podcast | Meals and Entertainment – Tax Reform Takes a Bite Out of Allowable Deductions, September

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August

Tax reform insights

  • Is Mineral Interest Income Eligible for the Section 199A Deduction under the Final Regulations? It Still Depends, August 26

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July

Tax reform insights

  • Videos: Looking Back and Forth on the U.S. Tax Reform Road, July 30

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  • Privately Speaking: To C-corp of Not to C-corp? That Is the Question, July

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  • IRS Issues Proposed Regulations for University Excise Tax, July 25

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  • KPMG Report: Proposed Passive Foreign Investment Company (PFIC) Regulations; Initial Impressions and Observations, July 12

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  • FDII: Observations on Antiavoidance Uncertainties, Tax Notes, July 1

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June

Tax reform insights

  • Excess Business Losses - One More Hurdle to Clear, June 26

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  • New Limitation on Interest Paid on Related Hybrid Transactions, Tax Notes, June 24

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  • Initial Impressions: Final Regulations under Section 951A (GILTI) and Certain Guidance Related to Foreign Tax Credits, as well as New Proposed Regulations Under 951A and 958 (Rules for Determining Stock Ownership), June 19

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  • Initial Impressions of Temporary Regulations Under Section 254A; Denial of Dividends Received Deduction for Certain Dividends from Current or Former CFCs, June 19

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  • Show Me the Money: Why Is My Cash Still Kept Offshore?, Tax Notes, June 17

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May

Tax reform insights

  • INSIGHT: Fundamental of Tax Reform - BEAT Proposed Regulations, Daily Tax Report, May 28

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  • Video: Tax Reform Implementation – A View from Washington, May 15

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  • New Limitation on Business Interest Expense Deductions, Tax Notes, May 13

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  • Proposed Regulations, Withholding Obligations Incident to Transfers of Interests by Foreign Partners in Partnerships Engaged in U.S. Trade or Business. May 9

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  • Employee or Not—Understanding and Appreciating the Common Law Test in a New Tax Paradigm. May 6

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April

Tax reform insights

  • Twenty Questions About Possible Technical Corrections to the 2017 Tax Act, April 29

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  • Pricing Method and SCM-Eligibility under the BEAT, April 15

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  • No Soup for You! IRS Denies Tax-Favored Employer-Provided Meals in Recent TAM, April 15

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  • In Case You Missed It: "Other: Provisions of the TCJA, April 1

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  • Perspectives on the Treatment of Losses in the Reformed U.S. International Tax System, Journal of Taxation, April

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  • Videos: Section 199A - Big Changes, Important Questions, April

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March

Tax reform insights

  • INSIGHT: Fundamentals of Tax Reform: Domestic Provisions, Common Myths, March 15

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  • KPMG Report: Initial Impressions, Observations on Proposed FDII, GILTI Regulations under Section 250, March 8

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February

Tax reform insights

  • Notice 2018-99: Tax Reform Curbs Parking Deductions and Increases UBTI, February 25

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  • Slowdown and Avoid Payment Acceleration Events for Section 965 Installment Payments and Transfer Agreements, February 11

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  • Section 951(b): Did You Realize the Need to Recognize the Difference?, February 11

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January

Tax reform insights

  • Tax Reform – Tax Administrative Guidance in the First Year Following Enactment, January 28

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  • KPMG Report: Analysis and Observations of Final Section 199A Regulations, January 24

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  • Tax Reform, Supplement to KPMG's Handbook, Accounting for Income Taxes, January 23

  • KPMG Report: Final Regulations relating to "Transition Tax" under Section 965, January 18

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  • Interim Guidance on Taxing "Excess" Executive Compensation of Exempt Organizations, January 16

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  • KPMG Report: Tax Policy and the 116th Congress - Observations and Preliminary Analysis, January 14

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  • Taking Tax Positions Contrary to Proposed Regulations, Tax Notes, January 7

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2018

December

Tax reform insights

  • KPMG Report: Preliminary Analysis and Observations, JCT Bluebook Description on Application of Section 163(j) to Passthrough Entities, December 31

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  • KPMG Report: Initial Impressions, Proposed Regulations Implementing "Anti-Hybrid" Provisions of New Tax Law, December 21

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  • KPMG Report: Initial Impressions of Proposed Regulations under Section 854(c)(8), December 21

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  • KPMG Report: Preliminary Analysis and Observations regarding Certain Passthrough Provisions in JCT Bluebook, December 21

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  • KPMG Report: Preliminary Analysis and Observations regarding Certain International Provisions in JCT Bluebook, December 21

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  • KPMG Report: Analysis and Observations about "BEAT" Proposed Regulations, December 17

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November

Tax reform insights

  • KPMG Report: Initial Impressions of Proposed Regulations on Foreign Tax Credits Under New Law, November 30

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  • KPMG Report: Initial Impressions on Proposed Regulations under Section 163(j), Business Interest Limitation, November 28

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  • Section 199A, REITS, and Real Estate Funds: A Janus Face of Tax Reform, November 19

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  • INSIGHT: Fundamentals of Tax Reform: GILTI, November 16

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  • Tax Reform – Supplement to KPMG Report on New Tax Law, November 15

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  • U.S. Congressional Elections and Tax Policy: Preliminary Observations, November 7

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  • Video | U.S. 2019 Tax Filing Season, Tax Reform. and Globally Mobile Employees, November

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October

Tax reform insights

  • KPMG's Seth Green Offers Insights on Proposed GILTI Regulations, Thomson Reuters, Tax & Accounting Blog, October 26

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  • The Evolution of the UP-C, Tax Notes, October 22

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  • Bad Grandpa: Notice 2018-68 Provides Initial 162(m) Guidance, including a Narrowly Crafted Grandfathering Provision, October 8

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  • Proposed Regulations under Section 199A, October 8

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  • Putting at Ease the GILTI Conscience: IRS Treats Cross-Border Income Inclusions as Qualifying Income, October 8

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September

Tax reform insights

  • The New Section 163(j): Partnerships Issues, September 24

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  • The New Section 163(j): Selected Issues (for non-partnership entities), September 24

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  • INSIGHT: Fundamentals of Tax Reform: BEAT, September 21

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  • Amid Uncertainty, CTOs Navigate the New Tax Law, KPMG's Chief Tax Officer Insights, September

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August

Tax reform insights

  • INSIGHT: Fundamentals of Tax Reform: FDII, August 13

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  • KPMG Report: Issues and Analysis of Section 965 Proposed Regulations, August 10

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  • KPMG's Manal Corwin on U.S. TCJA Implications, Thomson Reuters, Tax & Accounting Blog, August 7

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  • Internal Audit: Addresing Risks Facing the Media Industry - see pg. 14 and 15 for a discussion of how tax reform affects media companies' internal audits, August

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July

Tax reform insights

  • Transfer Pricing in the Age of Tax Reform, July 17

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  • Infographic | Top 10 Tax Reform Impacts on Banks, July 11

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  • Video | International Tax Provisions: Then & Now, July 2

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  • Tax Reform Breathes New Life into the Choice of Entity Decision, July 2

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  • Tax Reform: The Ongoing Road to to Implementation, KPMG's CTO Insights – Issue Spotlight, July

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  • Does NOL Stand for Net Operating Loss or Non Obstante Lamentum? A Discussion of Amendments to Section 172 by H.R. 1, Corporate Taxation, July/August

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June

Tax reform insights

  • Insight: Home Equity Interest May Still Be Deductible, Daily Tax Report®, June 26

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  • An Excess of Uncertainty: The New Tax on Tax-Exempt Compensation, Tax Notes®, June 25

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  • Deciphering the Nebulous NOL Waive-Off Election, Tax Notes®, June 18

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  • Tax Reform and Publicly Traded Partnerships, June 4

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  • Is Mineral Interest Income Eligible for the Section 199A Deduction? It Depends, June 4

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  • Federal Tax Reform: Not So Encouraging for State and Local Incentives, The Tax Adviser®, June 1

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  • Tax Reform and the IRS: Five Takeaways for Tax Practitioners, The Tax Adviser®, June 1

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  • The Intersection of New Sec. 451 and Revenue Recognition, The Tax Adviser®, June 1

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  • U.S. Tax Reform – Accounting Methods and Credits, June 2018

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May

Tax reform insights

  • Tax Reform: Provisions Relevant to Compensation, Benefits & Qualified Plans, May 3

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  • The BEAT and Bilateral Tax Treaties: Where Might the Tension Lead?, ABA Tax Times, May

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April

Tax reform insights

  • U.S. Tax Reform Considerations for Multinational Services Companies, Tax Notes International®, April 30

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  • Employers Get Credit for Paying Employees While on Family of Medical Leave, April 23

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  • New Tax Law: International Provisions and Observations, April 18

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  • Tax Reform and Investment in U.S. Real Estate, Tax Notes®, April 16

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  • Impact of Mandatory Repatriation on 2017 Tax Returns of S Corporations and S Shareholders, April 7

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  • KPMG's 2018 H.R. 1 Survey Report – Potential Impacts on Global Mobility Programs, April

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  • The New Tax Legislation: Impact on M&A, April

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March

Tax reform insights

  • Refreshing Prior-Year Earnings and Profits: Is There a Downside?, Tax Notes©, March 26

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  • Insurance Perspectives: Effects of the Tax Cuts and Jobs Act of 2017 on Captive Insurance Companies, Journal of Taxation of Financial Products, March

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  • Tax Reform: And the Winner Is ... R&D, March 12

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  • Tax Reform and the Potential Impacts to the Banking Industry, March 9

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  • Tax Reform May Be the Epicenter, But Be Wary of the Trade and Customs Aftershocks, Tax Management International Journal™, March 9

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  • Tax Reform Executive Edition: Highlights of the New Tax Law, March 5

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  • Privately Speaking: Success in Succession, March

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February

Tax reform insights

  • Are AMT Credit Refunds Subject to Limitation?, February 26

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  • The Services Cost Method and the New BEAT, February 19

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  • BEAT's Impact on Transfer Pricing Alternative Dispute Resolution, Daily Tax Report®, February 16

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  • A Response to an Off-BEAT Analysis, Tax Notes®, February 12

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  • New Section 1446(f) Withholding—A Possible Outline for Public Guidance, Daily Tax Report®, February 8

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  • Tax Reform – KPMG Report on New Tax Law, Analysis and Observations, February 6

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  • How Does BEAT Apply to Inbound Companies?, February 5

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  • Tax Reform: Issues for Exempt Organizations, February 2

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  • Privately Speaking: What Tax Reform Means for You and Your Privately Held Company, February

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  • Q&A Tax Reform in the US (IFRS)

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January

Tax reform insights

  • New Tax Law: Energy & Natural Resources, January 31

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  • Video | Tax Reform Done? The Process Continues, January 19

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  • Webcast Summary | Tax Cuts and Jobs Act (H.R. 1) – Potential Implications for a Globally Mobile Workforce, January 19

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  • New Tax Law: Issues for Partnerships, S Corporations, and their Owners, January 18

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  • Power and Utility Industry Measures in New Tax Law, January 8

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2017

December

Tax reform insights

  • New Tax Law (H.R. 1)—Initial Observations, December 22

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  • Don't Forget the SALT: State and Local Tax Implications of Federal Tax Reform, December 22

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  • Private Equity Funds—Certain Measures in New Tax Law Affecting Funds and Investors, December 22

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  • Infographic | The Path to Tax Reform, December 22

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