In this section, we provide a summary of brief updates from the previous quarter on legislative, judicial, and administrative developments in tax that may impact Japanese companies operating in the United States.
August 16, 2022
President Biden on August 16, 2022, signed into law H.R. 5376 (commonly called the "Inflation Reduction Act of 2022")—budget reconciliation legislation that includes significant law changes relating to tax, climate change, energy, and health care.
August 9, 2022
President Biden today signed into law H.R. 4346, “The CHIPS and Science Act of 2022.” The date of enactment is August 9, 2022.
July 28, 2022
An overview of wash sale reporting rules, why they matter, and how investors can avoid inadvertently subjecting themselves to them
July 27, 2022
The U.S. Treasury Department and IRS released two sets of technical corrections that make changes to final regulations relating primarily to the determination of the foreign tax credit (FTC) and the allocation and apportionment of deductions (including foreign income taxes).
July 26, 2022
The IRS Large Business and International (LB&I) division publicly released a "practice unit"—part of a series of IRS examiner "job aides" and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions.
July 22, 2022
"Tax home" rules, on which commute-or-business-trip analysis is based, assume employees have regular offices where they report.
July 16, 2022
The U.S. Treasury Department officially confirmed that the United States on July 8, 2022, notified Hungary of termination of the income tax treaty (1979) between the two countries.
June 28, 2022
The IRS today released an advance version of Rev. Proc. 2022-26 that provides the exclusive procedures for requesting a determination under section 4672 (a)(2) that a substance be added to or removed from the list of substances under section 4672(a) subject to the excise tax imposed by section 4671(a).
June 24, 2022
The IRS today announced the release of a set of "frequently asked questions" (FAQs) regarding the reinstated excise taxes imposed on certain chemicals and substances sections 4661 and 4671 (often referred to as "Superfund" excise taxes).
June 22, 2022
Tax authorities are increasingly on enforcement of tax rules relating to crypto-assets.
June 15, 2022
The Texas Comptroller of Public Accounts on June 10, 2022, published proposed changes to 34 TAC §3.599 to address the franchise tax and development (R&D) activities tax credit.
June 14, 2022
Complexities taxpayers encounter when they have both charitable contributions and NOL carryovers available to deduct
June 1, 2022
Suggestions for how successor guidance to Rev. Proc. 2015-40 and Rev. Proc. 2015-41 could further improve the MAP and APA programs
May 18, 2022
Section 1341 may provide a permanent benefit in the form of rate relief, ability to use otherwise nondeductible capital losses, or an immediate refund for net operating loss positions.
May 18, 2022
The IRS on May 3, 2022 released an advance version of Notice 2022-23 that sets forth the proposed changes to the qualified intermediary (QI) agreement described in Reg. section 1.1441-1(e)(5) and (6).
May 6, 2022
The IRS today publicly released a generic legal advice memorandum (GLAM) that addresses the proper method of allocation and apportionment under the section 861 regulations of deferred compensation expense for purposes of computing a taxpayer’s foreign-derived intangible income (FDII) deduction under section 250.
April 26, 2022
The IRS Large Business and International (LB&I) division publicly released a "practice unit" -part of a series of IRS examiner "job aides" and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions.
For more information, please contact:
Tai Kimura | +1 408 367 2204 | tkimura@kpmg.com