-
The TCJA Five Years Later: Federal Tax Issues, December 8, 2022
Listen to KPMG Washington National Tax principal, Jen Acuna, on this Tax Notes podcast episode, where she discusses how guidance for the Tax Cuts and Jobs Act is still evolving at the federal level five years later.
Listen here
-
The Post-TCJA Interplay Between NOLs and Charitable Deductions, Tax Notes Federal, May 30, 2022
The authors of this article explore the complexities that corporations face (and the potential benefits they may enjoy) if they have charitable contributions and net operating loss carryovers available for deduction on their 2021 returns.
Read more
-
Recent Changes to Section 174 of the US Internal Revenue Code, International Tax Review, March 2022
The authors of this article describe changes to section 174 and what this may mean for entities that provide contract research and development services to related parties.
Read more
-
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.
Read more
-
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.
Read more
-
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.
Read more
-
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.
Read more
-
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.
Read more
-
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.
Read more