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.
Proposed regulations: Guidance relating to the foreign tax credit (text of regulations)
November 18, 2022
The U.S. Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-112096-22) relating to the foreign tax credit (FTC)
(PDF)
International tax and transfer pricing ideas for year-end discussions
November 16, 2022
Conversations between taxpayers and their tax advisors for year-end planning purposes could include discussions about the key international tax and transfer pricing issues addressed in this article.
(PDF)
乐鱼（Leyu）体育官网 report: Accounting for tax provisions in the "Inflation Reduction Act of 2022" and CHIPS legislation (updated)
November 14, 2022
H.R. 5376, commonly called the “Inflation Reduction Act of 2022” (IRA), and H.R. 4346, “The CHIPS and Science Act of 2022” (CHIPS), introduce new options for monetizing certain credits, a corporate alternative minimum tax, and a stock repurchase excise tax.
(PDF)
乐鱼（Leyu）体育官网 report: Corporate alternative minimum tax considerations and FAQs
November 10, 2022
The IRA introduced a new Corporate Alternative Minimum Tax (CAMT)—a minimum tax based on financial statement income that applies to "applicable corporations"—effective for tax years beginning in 2023.
(PDF)
Year-end tax topics for cryptocurrency investors
November 2, 2022
Now is the time for investors in cryptocurrencies to recognize approaching year-end considerations
and possible planning opportunities.
(PDF)
"Superfund" tax refunds for exported chemicals and listed substances
October 19, 2022
Exporters of chemicals and chemical derivatives may be entitled to significant refunds of the
Superfund excise taxes, but only if the exported product is a “listed” taxable chemical or substance.
(PDF)
IRS updates FAQs on QI/WP/WT website, certifications and periodic reviews
October 12, 2022
The IRS today updated the "frequently asked questions" (FAQs) on the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trust (WT) FAQs website, under the heading "Certifications and Periodic Reviews."
(PDF)
乐鱼（Leyu）体育官网 report: Tax treatment of cryptocurrency and challenges of cross-border reporting
October 3, 2022
Bitcoin and other cryptocurrencies have come a long way from their exchanges on the Silk Road in the early 2000s.
(PDF)
乐鱼（Leyu）体育官网 report: Accounting for tax provisions in the “Inflation Reduction Act of 2022” and CHIPS legislation
September 30, 2022
H.R. 5376, commonly called the “Inflation Reduction Act of 2022” (IRA), and H.R. 4346, “The CHIPS and Science Act of 2022” (CHIPS), were recently signed into law by President Biden.
(PDF)
Notice 2022-44: Per diem rates, substantiation of employee lodging, meals, incidentals 2022-2023
September 26, 2022
Amount of ordinary and necessary business expenses incurred while traveling away from home
(PDF)
Tax provisions in the "Inflation Reduction Act of 2022" relevant to the banking industry; potential implications
September 23, 2022
Preliminary observations regarding certain tax provisions in the IRA that could be relevant to the banking industry
(PDF)
乐鱼（Leyu）体育官网 report: A primer on wash sale reporting in a volatile market (updated September 2022)
September 21, 2022
Market volatility can create opportunities for trad?ers but it can also be a source of angst. And this is true in the world of tax as in the wider world.
(PDF)
California: Unclaimed property voluntary compliance program legislation enacted
September 16, 2022
California Assembly Bill 2280, which authorizes the California Controller to establish an unclaimed property voluntary compliance program (VCP), was signed into law on September 13, 2022.
(PDF)
Accounting for tax credits
September 14, 2022
There are many different types of tax credits available to entities, including several credits that have been created, modified, or extended as a result of recent federal legislation enacted in the United States.
(PDF)
乐鱼（Leyu）体育官网 report: Foreign tax credit regulations; constructing a path forward
August 24, 2022
Recent changes in the foreign tax credit (FTC) regulations have introduced several possibly unintended consequences to the engineering and construction industry.
(PDF)
For more information, please contact:
Tai Kimura | +1 408 367 2204 | [email protected]