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Tax
Articles
2019
KPMG Flashpoint
Global withholding taxes
Tax policy and the 116th Congress
Section 301-granted exclusions: How your firm can benefit
The tax data dilemma
Looking into the Future of HR and Global Mobility - Polling Results
Section 199A – Big Changes, Important Questions
Duty Drawback
KPMG Spark empowers small and midsized businesses
Videos: OECD's Proposals on Taxing the Digital Economy
2019 Tariff Impact Survey
Tariff Mitigation Roadmap
Taxation of the Digital Economy
Fundamentals of Tax Reform
BEPS Actions 8–10
Video: Tax Reform Implementation—A View from Washington
BEPS for Asset Management
Videos: Looking Back and Forth on the U.S. Tax Reform Road
A framework for OFAC compliance commitments: An overview
Corporate Tax Transparency in the BEPS Era
Tax reform's impact on family offices and the individual taxpayer
2018
Post-BEPS tax controversy
Assessing tax reform’s impact on multinationals and operations planning
Transfer pricing in the age of tax reform
Tax reform done: The process continues
International tax provisions: Then & now
What tax reform means for you and your privately held company
Insights on Trade & Customs
Home equity interest may still be deductible
Chief tax officer survey
The IRS and the APA
How behavioral economics can help corporations and government
Tax changes affect value chain structures
Threading the needle
Blockchain and the future of tax
Medical device companies & tax reform
The final tangible property regulations
International Compliance Assurance Program - oasis or mirage?
The expatriate administrator
Changes and leading practices in unclaimed property compliance
New IRS rules standardize taxability of IRAs
The real deal on tax and transactions
2018 tax dispute resolution benchmarking survey
Opportunity Zones
Tax and Trade Implications for U.S. Inbound Investment Guide
2018 Multistate Nonresident Withholding Survey Report
2018 Tariff update and impact analysis
Developing your Section 301 trade mitigation strategy
Automotive industry tariff mitigation strategy
Blockchain solutions for duty drawback
NAFTA Update
U.S. 2019 Tax Filing Season, Tax Reform, and Globally Mobile Employees
Cincinnati Business Courier - 4 steps to cope with tariff uncertainty
2018 Payroll Year-End Guide and Checklist
2017
The BEPS Ripple Effect
Tax Reform Senate Procedural Requirements Explained
President Trumps Principles for Tax Reform
Preparing for Possible Tax Reform
Two-minute Take on Tax Reform
Commonsense Transfer Pricing in a BEPS World
How to make the case for global trade management systems
Harnessing the Duty Drawback rules for expanded savings
Chief trade officer's first 100 days
Help for piecing together the trade compliance puzzle
U.S. Taxation of Foreign Citizens (2019)
Mobility Matters
The Future of Tax
U.S. Taxation of Americans Abroad (2019)
2016
2x4 Approach to Country-by-Country Reporting
Successfully Deploying Global Trade Management Systems
Foreign Trade Zones - Video
R&D Exchange
KPMG Asset Management Platform
Archive - DO NOT PUBLISH
Events
TaxWatch webcasts
2019
Tax Reform Thursdays: BEAT—Are You Subject to Section 59A?
Quarterly Bank TaxWatch – Tax Reform Developments for Banks
Navigating the TFTEA Drawback Regulations
U.S. Tax Reform Update: Guidance and Hot Topics for the Alcohol Beverage Industry
Tax Reform Thursdays: Final 965 Regulations and International Tax Technical Corrections
Looking into the Future of HR and Global Mobility
The Power of Blockchain Webcast Series: Understanding Blockchain – It’s Not Just About Crypto
Tax Reform Thursdays: Anti-Hybrid Provisions and PTEP
VAT 2018 year in review and 2019 outlook
Tax Reform Thursdays: Final Section 199A Regulations
Update on Trade Trends and Leveraging Global Trade and Supply Chain Technology
The R&D Tax Credit: A 2018 year in review
Taxation of the Digital Economy: What Multinationals Should Know about Recent Developments
Final Section 263A Regulations
Tax Reform Thursdays: Tax Reform’s Impact on Individual Taxpayers/Family Offices
Navigating the Uncertainty around Tariffs and their Impact on Site Selection and Incentives
Eastman-Kodak's Story: Managing Foreign Trade Zones with Global Trade Services
Tax Reform Thursdays: Federal Tax Reform – What’s a State Taxpayer to Do?
Tax Reform: FDII and GILTI Deductions under Section 250
Update on Business Travel Risks and Compliance
Quarterly Bank TaxWatch – Refresher on Mergers and Acquisitions
The New Centralized IRS Partnership Audit Regime
Opportunity Zones
Tax Treatment of IPO Transaction Costs
State & Local Tax Issues in the Asset Management Industry
Future of Global Mobility Technology
Unclaimed Property Compliance & Audit Update
Family Office Fridays: State and Local Tax
Tax Reform Thursdays: GILTI and Related Regulations Released—What Now?
Year One – Lessons Learned in the First Full Year of §301 Tariffs
Quarterly Bank TaxWatch – Legislative and Regulatory Update
Family Office Fridays: Wealth Transfer Tax and Succession Planning Considerations
Understanding The Taxpayer First Act
Taxing the Digital Economy: Update on OECD Efforts to Build Consensus
Tax Reform Thursdays: Emerging Cross-Border M&A Tax Considerations
What’s Shaking in SALT: Summary of Recent State Tax Legislative Developments
Family Office Fridays: Impact of International Tax Reform Provisions on the Individual Taxpayer
Future of Global Rewards: Improving Equity Plan Administration & Process through Technology
Digitalization of global indirect tax compliance
2018
Tax Reform Thursdays: Federal Tax Reform Issues that Affect State Income Tax Compliance
First Sale for Export: Duty Mitigation in a Trade Sanction World
State tax developments, Wayfair reactions, and a SALT asset management update
Down to the wire: Are you ready for responsible officer certifications?
The Wait for Wayfair is Over – What’s Next?
Rules of Origin: Marking, Government Procurement, and Free Trade Agreements
Global Tax Reform: Developments in Digital Economy Taxation and EU Mandatory Disclosure Requirements
Tax Reform: Valuation Considerations
The Short and Long Game on Section 232 tariffs
Tax Reform Thursdays: New Law’s Impact on Treasury Functions
Tax Reform: Transfer Pricing Considerations
Tax Cuts and Jobs Act—Potential Implications for a Globally Mobile Workforce
The IRS and the administrative procedure act
Tax Reform Thursdays: Tax reform and passthroughs
The international trade landscape under the Trump administration—An update
Tax Reform Thursdays: Tax Reform for Exempt Organizations
Tax Reform: Presumed GILTI – A New Default Category for CFC Income
2018 – A New Era of Trade Enforcement: An Update on Post-TFTEA Trade Enforcement Trends
The R&D tax credit: A 2017 year in review and impacts of tax reform
OECD Draft Guidance on Financial Transactions
Update on Tariffs: How Leading Companies are Responding
Tax Governance Institute: Tax Reform 101
Tax Reform: Proposed GILTI Regulations
Tax Reform Thursdays: Federal tax reform – What's a State Taxpayer to Do?
CEO Pay Ratio
Tax Reform: Hot Topics for Banks in 2018
Tax Reform: Inbounds – Competing on a “Level” Playing Field
What does the Supreme Court Wayfair decision mean for tax-exempt organizations
Recent developments affecting the banking industry
KPMG TaxWatch webcast – VAT 2017 year in review and 2018 outlook
Between a Rock and Hardplace – Transfer Pricing in a Post-BEPS and Post-U.S. Tax Reform Environment
Tax Reform: Proposed Section 199A Regulations
Update on Tariffs: How leading companies are responding
Tax Reform: Proposed Section 965 Regulations’ “Transition Tax”
Developing your Section 301 Tariff Mitigation Strategy
How GTS improvements support Free Trade Agreements
KPMG TaxWatch webcast - State tax legislative update
This webcast page
Tax E&C Webcast
Understanding the Trade Implications of the United States-Mexico-Canada Agreement (USMCA)
All SALT: State Reactions to Tax Reform, Wayfair, and Upcoming Ballot Initiatives
Navigating Between a Rock and a Hard Place II
Tax Reform: Opportunity Zones
Tax Reform Thursdays: Midterm Elections Results' Potential Impact on the Tax Agenda
Information Reporting and Withholding: This Year and Next
Tax Reform Thursdays: Update on the Latest International Tax Guidance
Wayfair and Foreign Sellers of Goods and Services
Update on year-end payroll tax planning
TradeWatch: Update on Country of Origin Rules
Tax Reform Thursdays: Proposed 168(k) Regulations
Tax Reform Thursdays: Latest International Guidance – Part 2
Tax Reform Thursdays: Section 163(j) Proposed Regulations Unpacked
2017
A deep dive into IRS R&D ASC 730 Directive and what it means for you
Intelligent automation: Impact on the tax function
Disaster recovery webcast series – Potential tax impacts of hurricanes harvey and irma recovery
Catching up: State unclaimed property and tax update
Transforming the bank tax department in the digital age
The new centralized IRS partnership audit regime: Moving forward now…
Tax considerations for recovery service providers
Employer assistance to employees and postponed IRS filing dates
Podcasts
Archive
TWIST - This Week in State Tax
This week in state tax episodes
TWIST – July 23, 2018
TX: Software used to produce semiconductor chips was not used in manufacturing
WI: Taxpayer was providing taxable laundry services
Multistate: More state reactions to the Wayfair decision
TWIST – August 6, 2018
AL: Department issues report on preliminary guidance on tax cuts and jobs act
VT: State issues guidance on reporting Section 965 Income
Multistate: States continue to respond to the wayfair decision
TWIST – July 30, 2018
CT: Department issues guidance on treatment of GILTI
MI: State high court addresses scope of bad debt deduction
UT: Special session bills address NOLs and section 965 income
Multistate: Additional state responses to the Wayfair decision
TWIST – June 25, 2018
RI: Budget bill imposes tax on vendor hosted prewritten computer software
UT: Taxpayer established that it was a “Sales factor weighted taxpayer”
VA: Personal shopping services subject to sales tax
Multistate: Several states issue post-wayfair guidance
TWIST - May 21, 2018
CO: Market-based sourcing bill passes both houses of legislature
MA: Estimated tax penalty relief for corporations affected by the transition tax...
TN: Bill to decouple from certain aspects of tax reform sent to governor Bill Haslam for signature
Washington: White glove delivery services create substantial nexus
TWIST – July 16, 2018
CA: San Francisco proposition C increases gross receipts tax on lessors of commercial real estate
MO: Bank franchise tax rate reduction legislation enacted
NJ: Amnesty legislation enacted
Multistate: More state reactions to the Wayfair decision
TWIST – July 9, 2018
GA: Policy bulletin addresses exclusion for foreign dividends
MN: Commissioner not barred from requiring use of alternative apportionment
VT: Budget bill includes conformity update
Multistate: States continue to issue guidance on the Wayfair decision
TWIST – June 18, 2018
CO: Guidance issued on reporting section 965 income
NY: Taxpayer was not a qualified new york manufacturer
NC: Budget bill includes IRC conformity update
RI: Proposed regulation issued on corporate tax treatment of section 965 income
TX: Telecom provider not allowed to deduct electricity as COGS
TWIST – June 11, 2018
MI: Guidance issued on michigan corporate income tax treatment of mandatory repatriation and GILTI
PA: Taxpayers are not “referrers” subject to use tax notice and reporting requirements
Multistate: Recently-enacted and pending sales and use tax economic nexus bills
TWIST - June 4, 2018
MO: Optional lease add-ons, including warranties, subject to missouri sales tax
NJ: Taxpayer not entitled to unreasonable exception to related party addback requirement
Washington state: New seattle “hours” tax effective january 1, 2019
Québec: Proposed economic nexus requirements for remote sellers of intangibles...
TWIST – May 14, 2018
HI: Economic nexus bill sent to governor
HI: Conformity bill sent to governor
OH: Despite title transfer occurring in Texas, sales of goods were sitused to Ohio
Washington: Penalties/interest may be imposed for unclaimed property non-compliance
TWIST – May 7, 2018
AL: Guidance issued on reporting Section 965 income
FL: Guidance issued on treatment of IRC Section 965 income
NY: Limited opportunity to withdraw from commonly-owned group election
SC: True object of a transaction was not the provision of bartending services
TX: Federal disregarded LLCs subject to franchise tax
TWIST –July 2, 2018
LA: Temporary additional sales and use tax extended under a reduced rate
MA: Out-of-state taxpayer was a manufacturer required to use single-sales factor apportionment
PA: Tax reform response depreciation legislation signed into law
Multistate: Additional state guidance on South Dakota v. Wayfair, Inc.
RI: Sellers reminded of collect or report requirement Post-Wayfair
TWIST - September 17, 2018
AL: Out-of-state Bookseller Not Required to Collect Alabama Use Tax
MA: Department of Revenue Issues Guidance Addressing Federal Tax Reform
Multistate: States Continue to Respond to Wayfair Decision
TWIST - September 10, 2018
ME: Conformity Legislation Passes During Special Session
NJ: Tax Court Rules in Favor of Division in Sales Tax Sourcing Dispute
OR: Nonresident Pass-Through Entity Owner’s Source Income Not Determined
Multistate: More State Responses to Wayfair Decision
TWIST - August 13, 2018
IN: Hospital Lacked Standing to File Refund Claim
WY: State Supreme Court Addresses What Constitutes a Sale
Multistate: States Continue to Respond to Wayfair Decision
TWIST - August 20, 2018
CO: Department Addresses Tax Treatment of Specially Mixed Condiments
OR: Companies Lacking Physical Presence in Oregon Subject to Corporate Income Tax
TX: Call Tracking and Monitoring Services Not Subject to Sales and Use Tax
VT: State Issues Guidance on Treatment of GILTI, Section 199A Deduction
Multistate: States Continue to Respond to the Wayfair Decision
TWIST - September 24, 2018
India: New Compliance Obligation for Online Platforms Implemented Effective 10/1/18
MN: Tax Court Holds Taxpayer Not Eligible for Capital Equipment, Production Sales Tax Exemptions
TX: Presence of Clothing in State for Try-On Period Creates Substantial Nexus
TWIST - October 1, 2018
CA: Governor Signs Legislation Adopting Federal Partnership Audit Rules
CA: Appeals Court Addresses Scope of Sales and Use Tax Exclusion for Telephone Lines
NY: Tax Tribunal Distinguishes Between Contract Carriers and Common Carriers
Multistate: More Responses to South Dakota v. Wayfair
TWIST - October 8, 2018
CA: Factors of SMLLCs Included in Computing Owners' Apportionment
MA: Sales Tax Holiday Headache Resolved Favorably for Retailer
SC: Conformity Legislation Enacted During Special Session
Multistate: More Responses to South Dakota v. Wayfair
TWIST - October 15, 2018
MO: Farmer Selling Beef over Online Marketplace Does not qualify for Farmer’s Market Exemption
TX: Physical Presence Rule Continues to Apply for Franchise Tax Purposes
UT: Federal section 482 Regulations Apply In Interpreting State Discretionary Authority Statute
Multistate: More Responses to South Dakota v. Wayfair
TWIST - October 22, 2018
CA: Taxpayers Did Not Qualify for Deferral of Gain on an IRC § 1031 Exchange
MA: Pending Legislation Addresses Treatment of GILTI
RI: Substantial Nexus Not Created Due to Presence of Affiliate in State
TX: Online Educational Courses not Subject to Sales Tax
Multistate: More State Responses to Wayfair
TWIST - October 29, 2018
AR: Contributions Made in Exchange for Tangible Personal Property are Subject to Sales and Use Tax
ID: Single, Non-Customer Facing Employee Created Corporate Income Tax Nexus
MA: Indiana Utility Receipts Tax Required to Be Added Back in Computing MA Corporate Excise
Multistate: More State Reactions to Wayfair
TWIST - November 5, 2018
OH: Exemption from Unclaimed Property Extended to Rewards Cards and Additional Gift Cards
SC: Administrative Law Court Holds Banks Cannot Deduct NOL Carryforwards
WA: Video Game Hardware and Software not Like-Kind Property
Multistate: More State Wayfair-Related Developments
TWIST - November 12, 2018
Arkansas: Sediment removal not incidental to nontaxable inspection services
Massachusetts: Taxpayer’s products were prewritten computer software
South Carolina: Court of Appeals affirms decision holding receipts from in-state satellite subscribers
Washington: ALJ addresses various B&O issues Associated with ATM fees
TWIST - November 19, 2018
CA: Mortgage Servicer Was Not a Financial Corporation
KY: Department Issues TAM on Deductibility of State Taxes
Multistate: Wayfair-Related Developments
TWIST - December 3, 2018
CA: Voters Approve General economic Nexus Provisions; Litigation Pending
IN: Department Addresses Software and Scope of P.L. 86-272
OH: Baseball Team Scores a Home Run before the Ohio Supreme Court
UT: Equitable Adjustment Provisions Apply to Avoid Double Taxation of Foreign Business Income
Multistate: States continue to release Wayfair guidance
TWIST - December 10, 2018
LA: Statute Disallowing Residents a Credit for Texas Franchise Taxes Paid Violated the Commerce Clause
Multistate: Recent Unclaimed Property Activity
MS: Statute of Limitations Period Was Constitutional
CO:Grace Period for Certain Retailers to Begin Collecting and Complying with Sourcing Changes Extended
TWIST - December 17, 2018
Illinois (City of Chicago): Ruling addresses collection obligations of facilitators
Missouri: Items used to administer medicines were not 'materials' used or consumed in compounding
Multistate: States continue to respond to Wayfair decision
2019 Episodes
TWIST - January 7, 2019
Iowa: Home improvement retailer required to collect tax on installations
Louisiana: Court affirms decision requiring online retailer to collect local tax on marketplace sales
Missouri: Sales and use tax refund claim barred by statute of limitations
Multistate: Recent Wayfair-related developments
TWIST - January 14, 2019
NJ: Guidance issued on treatment of GILTI and FDII; Combined group composition
NM: Dept. failed to establish deviation from financial institution apportionment factor was warranted
PA: Corporate tax bulletin provides hedging and other receipts are excluded entirely from the sales factor
Multistate: Wayfair-related developments
TWIST - January 21, 2019
Georgia: Two Rulings Address Resale and Manufacturing Exemptions
Missouri: Operator of a Cafeteria in Federal Building Liable for Sales Tax on Meals
Oregon: Proposed Bills Would Make Significant Changes to Oregon’s Corporate Tax Laws
New York: Guidance Issued on Wayfair; Legislation Would Extend Collection Requirement to Marketplaces
New York: Governor Cuomo’s proposed Budget Includes Numerous Income Tax Changes
TWIST - January 28, 2019
Iowa: Department addresses post-Wayfair sales tax nexus standard
New Jersey: Managerial member of combined group must obtain new tax identification number
NYC: General corporation tax imposed on non-unitary corporate partner's sale of an LLC interest
Utah: Ruling addresses taxability of custom storage solutions
Multistate: More state responses to Wayfair
TWIST - February 4, 2019
MS: Guidance Issued on the Tax Cuts and Jobs Act
MO: Kansas City Chiefs deflated; found liable for nearly $1M in sales and use taxes
TX: Hotel operator owed use tax on items provided to guests
TX: Receipts from fuel delivered to foreign vessels were Texas receipts
PA (Philadelphia): BIRT economic nexus regulation filed
TWIST - February 11, 2019
IA: Benefit of Transportation Brokerage Service is received at Delivery Location of Goods
MS: Department Revises Guidance on GILTI
NJ: Computation of Tax Add Back in Determining a Sub's Separate CBT Liability when Taxes Paid by Parent
WA: Company Providing Meals to Schools Subject to Service B&O Rate
TWIST - February 18, 2019
FL: Department Issues Comprehensive Report on Tax Reform
IL: Tax Tribunal Rules Taxpayer Operating a Golf Club Qualified for Governmental Body Exemption
OH: Goods Picked Up in Georgia were Ohio-Sitused Receipts and Created Substantial Nexus
VA: Use of Income-Producing Activity Test did Not Result in Unconstitutional Apportionment
Multi: Recent State Wayfair Developments
TWIST - February 25, 2019
FL: Sales Of Services Sourced Based on the Customer’s Location
NC: Net Economic Losses Must be reduced by Deductible Dividends
VA: Fourth Circuit Rules that Virginia Stormwater Charge is a Fee, Not a Tax
Multi: More State Responses to Wayfair
TWIST - March 4, 2019
AZ: Rental Car Surcharge Permissible Under Federal and State Constitutions
CA: FTB Will Apply IRC section 367 Regulations to Insurance Companies
KS: Internet Tax Freedom Act Does Not Bar Taxation of Equipment
Multi: More State Responses to Wayfair
TWIST - March 11, 2019
MI: Resale Exemption did Not Apply to Credit Card Processor’s Equipment Purchases
NJ: Tax Court Rules in Taxpayer’s Favor in Addback Dispute
WA: Taxpayer’s Receipts Subject to Throwout
MA: E-Fax Services Are Taxable Telecommunication Services
TWIST - March 18, 2019
New York: Broker-Dealer Sourcing Rules do not Extend to Non-Broker SMLLC
New York: Advisory Opinion Concludes that a Marketplace Provider Qualified as a Vendor
Utah: Legislation Pending Signature Would Amend Corporate Nexus Standard
Mobile Workforce State Income Tax Simplification Act of 2019 Introduced in the Senate
Multistate: More State Reactions to Wayfair; Marketplace Facilitator Legislation
TWIST - March 25, 2019
Arkansas: State Liquidation of Unclaimed Securities May Reverse Consumer Protections
Louisiana: Regulation Outlining Local Sales Tax VDA Program Adopted
Multistate: State Income Tax Nexus Bills
Multistate: More State Wayfair-Related Legislation Advances
TWIST - April 1, 2019
Kentucky: FAQ Addresses Corporate Tax Economic Nexus
Oregon: Supermajority Vote not Required for Bill Decoupling from IRC section 199A Deduction
Tennessee: Appeals Court Rules in Taxpayer’s Favor in Business Tax Classification Dispute
Multistate: More state reactions to Wayfair
TWIST - April 8, 2019
Georgia: Department Addresses Computation of Income when Taxpayer Treaty Protected for Federal Purposes
Idaho: Retroactive Legislation Revises Treatment of Section 965 Income, GILTI, and FDII
New York: Budget Agreement Includes Numerous Tax Changes
Oregon: Wholesalers Accepting Returns on Behalf of Taxpayer Caused Loss of Public Law 86-272 Protection
Multistate: More State Responses to Wayfair
TWIST - April 15, 2019
Arkansas: Corporate Tax Legislation Signed Into Law
Indiana: Post-Wayfair Sales Tax Filing Requirements for Seller of Exempt Items
Massachusetts: Appellate Tax Board Reverses Course on Refunds for Multiple Points of Use
Multistate: More State Responses to Wayfair
TWIST - April 22, 2019
Alabama: Tailgater Taxability Addressed by Tax Tribunal
Arkansas: Conformity to Certain IRC Provisions Updated
New Jersey: Guidance Issued on Section 163(j) Limitations
New York: Budget Bills Enacted
TWIST - April 29, 2019
Iowa: Guidance Issued on IRC section 163(j) Limitation
Maryland: Guidance Issued on Apportionment of GILTI
New Jersey: Guidance Issued on GILTI Treatment for Combined Reporting
Multistate: More State Responses to Wayfair
TWIST - May 6, 2019
Oklahoma: New Pass-through Entity Tax Regime Enacted
Pennsylvania: Department Issues Guidance on IRC section 163(j) Limitation
Multistate: More State Reactions to Wayfair
Wisconsin: Department Addresses Post-Wayfair Sales Tax Collection Requirements
Washington State: Tax Increase Bills Sent to Governor
TWIST - May 13, 2019
Massachusetts: Department Amends Corporate Income Tax Nexus Regulation Post-Wayfair
City of San Francisco: New Homelessness Gross Receipts Tax Credits Adopted
Multistate: More State Responses to Wayfair
TWIST - May 20, 2019
Florida: Pending Legislation Adopts GILTI Exclusion; New Reporting Requirements
New Jersey: Revised Guidance Issued on Entities Included in the Combined Group
Tennessee: Governor Signs Bill Addressing GILTI and 965 Income
Multistate: Two States Issue Wayfair-Related Guidance
Hawaii: Bills Presented to Governor Would Adopt Corporate Tax Changes
TWIST - June 3, 2019
Alabama: Canned and Custom Software is Taxable Tangible Personal Property
Multistate: More State Responses to Wayfair
Colorado: Domestic Holding Companies cannot be Forcibly Combined with Affiliates
New Jersey: Guidance Issued on Combined Reporting Filing Options; Application of Joyce and Finnigan
New York: Premiums paid to Captive Insurance Subsidiary are Not Deductible
Ohio: Board of Tax Appeals Adopts Broad interpretation of When Manufacturing Begins
TWIST - June 10, 2019
Arizona: Conformity Legislation Enacted; Guidance Issued on 965 Income
Multistate: More State Responses to Wayfair
Connecticut: Budget Legislation Pending Signature
Illinois: Recently Enacted Bills Include Numerous Tax Changes
TWIST - June 17, 2019
California: Guidance Issued on Alternative Apportionment Requests
New York: Royalty Payments from Foreign Affiliates Included in Entire Net Income Base
Vermont: Market-Based Sourcing Rules Adopted
TWIST - June 24, 2019
Louisiana: NOL Ordering Rules Revised
City of San Francisco: Proposed Mental Health Gross Receipts Tax Likely to be on November Ballot
Texas: Appeals Court Holds Aquarium Not Selling Tangible Personal Property
Multistate: More State Responses to Wayfair
TWIST - July 1, 2019
Louisiana: Elective Pass-Through Entity Level Tax Enacted
Multistate: More State Reactions to Wayfair
Mississippi: Chancery Court Upholds Board of Tax Appeals Decision in Franchise Tax Dispute
Oregon: Pending Legislation Addresses Treatment of GILTI
TWIST - July 15, 2019
Multistate: More State Reactions to Wayfair
Montana: Taxpayer Entitled to Deduct 100 Percent of Dividends Received from 80/20 Corporations
Missouri: Recently-Enacted Legislation Decouples from IRC section 163(j) Limitations
California: Trial Court Rules for City of SF; Super-Majority Vote Not Needed to Approve City Tax Increases
Texas: Proposed Rule Addresses When Taxable Entities Produce Goods for Sale
TWIST - July 22, 2019
Multistate: More State Reactions to Wayfair
Kentucky: Optional Liability Waivers Not Subject to Sales tax
Louisiana: BEAT Not Deductible as an Income Tax
Maine: New Unclaimed Property Law Enacted
Oregon: Opponents of the CAT Appear to Shift Direction
TWIST- July 29, 2019
New Jersey: Guidance Issued on Combined Reporting and Banks
Oregon: CAT Technical Corrections Signed Into Law
Oregon: Legislation Addressing GILTI Enacted
Rhode Island: Ten-Year Statute of Limitations Enacted
Tennessee: Subpart F Income Considered a Dividend
TWIST - August 5, 2019
Arkansas: Yard-Sale Host is not a Marketplace Facilitator
Massachusetts: Remote Seller and Marketplace Facilitator Legislation Enacted
Pennsylvania: Philadelphia Department of Revenue addresses IRC 163(j) limitation
Kansas: Remote Sellers Required to Collect Beginning October 1, 2019
TWIST - August 12, 2019
California: Arizona Resident Owes California Income Tax for Services Performed in Arizona
Illinois: Details Released on Upcoming Tax Amnesty Program
Indiana: Lawsuit Settlement Income Included in the Numerator and Denominator of the Sales Factor
Tennessee: Guidance Issued on Computing IRC section 163(j) Limitation
Texas: Amended Franchise Tax Nexus Regulation Would Adopt Economic Nexus
TWIST - August 19, 2019
New York: Litigation Support Services Receipts were Other Business Receipts
Louisiana: Medical Devices Exempt Under the Constitutional Exemption for Prescription Drugs
Florida: Guidance Issued on GILTI Subtraction and Bonus Depreciation
2020 Episodes
TWIST - March 11, 2019
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In Dispute
Charitable Conservation Easement Program Integrity Act of 2019
The BBA centralized partnership audit regime
The U.K.’s proposed digital services tax
The revision of Code Section 965 under the Tax Cuts and Jobs Act
Wayfair and the corporate income tax
Ninth Circuit Vitiates Common Law Mailbox Rule
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Recap of Financial Services Tax Conference
2018
Recap of May 2018 USCBTC event
Recap of Financial Services Tax Conference
Recap of 2018 Global Financial Reporting and Valuation Conference
2017
Recap of December 2017 event
CorpTax 2018
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TaxNewsFlash-United States
Notice 2019-01: Future regulations, foreign corporations with previously taxed earnings and profits
KPMG report: Initial impressions of Notice 2019-01 and “ PTEP” guidance
KPMG report: State and local responses to “Wayfair” decision (CA, DC, Philadelphia, WI)
KPMG reports: Tax collection by facilitators (Chicago); sales tax exemption for pharmaceutical compounding (Missouri)
Proposed regulations on “BEAT” released to Federal Register
Tax implications, federal district court and constitutionality of Affordable Care Act
KPMG report: Analysis and observations about “BEAT” proposed regulations
Proposed regulations on hybrid dividends, payments provision; OIRA review completed
IRS releases draft instructions for Form 965 series
Puerto Rico: Changes to 2018 information returns, declarations
Puerto Rico: Summary of changes to information reporting, tax withholding
Notice 2019-04: Extension of temporary dyed fuel tax relief, Wisconsin terminals
KPMG report: State, local tax changes (fourth quarter 2018, table)
Entity classification: Withdrawing change request after regulations render election undesirable
KPMG report: “BEAT” proposed regulations, provisions applicable to insurance companies
Rev. Proc. 2019-06: Unpaid loss discount factors, salvage discount factors for 2018 accident year (insurance)
Proposed regulations on hybrid dividends and payments (text of regulations)
Proposed regulations under section 864(c)(8) (text of regulations)
KPMG’s Week in Tax: 17 - 21 December 2018
Rev. Proc. 2019-9: Adequate disclosures to reduce accuracy-related penalty
Notice 2019-06: Future regulations will address centralized partnership audit regime
Notice 2019-05: Hardship exemptions, individual shared responsibility payment and health insurance
Third Circuit: Civil penalty assessment for FBAR violation requires “willful conduct”
Wisconsin: Elective passthrough entity tax regime enacted
Rev. Proc. 2019-08: “Qualified real property” expensing under section 179, alternative depreciation under section 168
US IRS contingency plan during government shutdown
Final regulations: Tax-exempt private activity bonds, “public approval requirement”
IRS releases annual revenue procedures for 2019
KPMG reports: Mississippi, Missouri, Texas, Philadelphia
U.S. Treasury’s quarterly list, countries cooperating with international boycott (no changes)
KPMG report: Initial impressions, observations on proposed FDII, GILTI regulations under section 250
Costa Rica: Income tax treaty with Mexico
Costa Rica: Overview of tax reform law measures
TaxNewsFlash-Tax Reform
Regulations pending OIRA review, section 250 deductions for foreign derived intangible income and GILTI
JCT general explanation of new tax law (Bluebook)
Proposed regulations under section 163(j) released to Federal Register
KPMG report: Initial impressions of proposed regulations under section 864(c)(8)
KPMG report: Preliminary analysis and observations regarding certain international provisions in JCT Bluebook
KPMG report: Initial impressions, proposed regulations implementing “anti-hybrid” provisions of new tax law
KPMG report: Preliminary analysis and observations regarding certain passthrough provisions in JCT Bluebook
Proposed regulations under section 864(c)(8) released to Federal Register
Rev. Proc. 2019-12: Safe harbors, business taxpayer payments for state, local tax credits
KPMG report: Preliminary analysis and observations regarding application of section 163(j) to passthrough entities in JCT Blueblook
Final regulations released to Federal Register, 'transition tax' under sect
Final regulations under section 199A released to Federal Register
KPMG report: Changes in corrected final regulations under section 199A
Regulations: Dividends received deduction limitation when from certain foreign corporations (text of regulations)
Final GILTI regulations, text of regulations
Proposed regulations: Section 958 (determining stock ownership) and section 951A (GILTI) (text of regulations)
TaxNewsFlash-FATCA / IGA / CRS
British Virgin Islands: Amendments to CRS rules
KPMG report: Analysis and observations about proposed regulations, FATCA burden relief
Australia: ATO guidance explains AEOI obligations
Malta: Updated guidelines, implementation of DAC2 and CRS
Australia: Guidance on FATCA and CRS regimes
Japan: Transfer pricing proposals focus on hard-to-value intangibles
Latvia: Transfer pricing documentation requirements apply for 2018
India: Country-by-country reporting deadline extended
Denmark: Landmark transfer pricing decision from Supreme Court
Australia: GST on acquisitions and supplies in retail banking sector
Japan: Corporate and international tax proposals in tax reform package
Poland: VAT and commercial real estate transactions
Luxembourg: Updates on ATDA 1, interest limitation, MLI and tax treaty
Czech Republic: Assessing transfer prices, determining permanent establishment’s tax base
Luxembourg: Refund claims for withholding tax on dividends, new opportunity
Czech Republic: Changes to VAT law proposed for 2019
Czech Republic: Reminder of deadline to register beneficial owners
Netherlands: Consultation on directive for disclosure of cross-border tax arrangements
Italy: Proposal for “web tax” on electronically supplied services
France: Revenue from tax proposals to finance new social measures
Serbia: Tax law measures enacted for 2019
Gibraltar: Anti-tax avoidance measures concerning interest limitation, CFCs, hybrid mismatches
Gibraltar: Corporate tax exemption regime for interest and royalties, EC state aid investigation
Final regulations: Drawback claims, rule changes
EC’s “no-deal” Brexit contingency action plan, customs guidance
U.S. investigations, cast iron soil pipe imported from China
Annual revenue procedures for 2019 for exempt organizations
Notice 2019-09: Interim guidance on excise tax imposed under section 4960, excess remuneration
IRS TE/GE division releases summary of “FY 2018 accomplishments”
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