Collection of Insights on the 2017 Tax Act

Articles, publications, and videos about the implementation of the 2017 tax legislation—Pub. L. No. 115-97, commonly called the Tax Cuts and Jobs Act (TCJA)

This page archives articles, reports, and videos from KPMG professionals, 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.

John P. Gimigliano

John P. Gimigliano

Principal in Charge, Federal Tax Legislative & Regulatory Services, Washington National Tax, KPMG LLP (U.S.)

+1 202-533-4022
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2019

July - Tax reform insights

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

Get "inside" insights on enactment and implementation of the 2017 tax law from KPMG's John Gimigliano and Jennifer Acuña

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

Takes a business view of the new tax legislation to help you decide whether you should be reconsidering your current business structure

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IRS Issues Proposed Regulations for University Excise Tax, July 25

Summarizes the proposed regulations on new section 4968, which imposes an excise tax on the net investment income of certain private colleges and universities and their related organizations; some questions addressed, but many left unanswered

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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

Examines how much a company can modify its business model to take advantage of the section 250 deduction for foreign-derived intangible income

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June

Tax reform insights

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

Discusses the general application of section 461(l) and explains other areas of ambiguity

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

Discusses the new anti-hybrid rules of section 267A and the related proposed regulations (see part 1 of this article below, dated May 13, 2019)

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Opportunity Zones and REITs - The Latest Guidance from Treasury and the IRS, June 24

Focuses on the application of the opportunity zone provisions to REITs and provides a high-level summary of what is known based on the proposed regulations

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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

Examines the international provisions of the Tax Cuts and Jobs Act, specifically the consequences of keeping excess cash offshore and repatriating that cash to the United States

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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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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

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

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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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Opportunity Zones: Unlock New Opportunities, November

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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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KPMG Report: New Rules for Opportunity Zones, October 22

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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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Opportunity Knocks under Tax Reform (new section 1400Z and qualified opportunity zone investments), February 19

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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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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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