KPMG roundup highlights opportunity zones, transfer pricing and tariff relief

KPMG’s June 22 weekly tax roundup compresses a crowded June 15 to 19 agenda into one practical read for tax teams: opportunity zones, a Tax Court ruling on funded research, Singapore transfer pricing guidance on stock-based compensation, and Canada’s tariff-remission proposal all land in the same workflow. The same digest also points to follow-on reports across Belgium, Cyprus, the European Union, Poland, Pakistan, Kenya, FATCA, CRS, CARF, and trade-customs developments.

The workflow signal

For KPMG tax professionals, the real story is not the number of items, but the way they cut across specialties at once. A week like this suggests that leaders need to line up federal tax, transfer pricing, customs, international tax, and controversy earlier in the client cycle, because one transaction can now touch incentive planning, R&D substantiation, payroll treatment, and supply-chain pricing in a single pass. That is an inference from the mix of issues in the roundup, but it is the practical message for teams already balancing provision deadlines and summer deal work.

Opportunity zones become a timing issue, not just a real estate topic

The IRS’s Notice 2026-40 pushes opportunity zones into a transition-heavy phase under sections 1400Z-1 and 1400Z-2, as amended by the One, Big, Beautiful Bill Act. KPMG’s summary says the notice provides transitional guidance for qualifying investments, which matters to practitioners trying to decide whether gains, fund investments, and property placements are governed by the old framework or the new one.

In practice, that means this is not a niche incentive item that can sit with one specialist. Anyone advising on qualified opportunity funds or qualified opportunity zone businesses will want transaction models, legal documents, and timing assumptions reviewed together, because the notice points toward forthcoming proposed regulations and interim compliance rules that can alter how clients underwrite deals.

Singapore’s transfer-pricing FAQ raises the stakes on stock-based compensation

Singapore’s Inland Revenue Authority has issued the ninth edition of its transfer pricing e-Tax Guide, and the new FAQ addresses how stock-based compensation costs should be treated in intercompany recharges, effective for year of assessment 2026. On paper, that is a narrow update; in practice, it can affect multinational groups that rely on regional shared services, secondments, and equity-heavy compensation programs.

For KPMG teams, the immediate task is not just to restate the rule. It is to reconcile payroll data, recharge mechanics, and transfer-pricing documentation so the client can defend the treatment before year-end close and provision work hardens the numbers. That is where compensation, mobility, and transfer-pricing professionals end up in the same meeting, even when the policy change looks technical.

The funded-research ruling tightens the documentation conversation

The U.S. Tax Court’s memorandum decision on section 41(d)(4)(H) adds another data point to a line of cases that make the funded-research exclusion harder to wave away as a technical footnote. KPMG describes the ruling as a detailed analysis of whether research is funded, and the Tax Court’s own site confirms that memorandum opinions are formal written determinations of the court.

For professional-services firms and other taxpayers that rely on research credits, the lesson is blunt: contracts, billing rights, and deliverables need to be documented long before an exam begins. The decision pushes advisers to test not only whether a client paid for work, but whether the right to payment makes the research look funded under the statute.

Canada’s proposed tariff relief gives customs and supply-chain teams a longer runway

Canada’s finance ministry is proposing to extend temporary tariff remissions, also described as horizontal tariff relief, for eligible steel and aluminum products from the United States through June 30, 2027, with a similar extension for eligible steel products subject to derivative tariffs. The proposal would also extend the steel tariff-rate quota regime for imports from non-CUSMA partners, keeping customs planning on the agenda for manufacturers and other import-dependent clients.

Inside KPMG, this is not only a trade issue. Tariff changes spill into transfer pricing, cost recovery, procurement, and supply-chain redesign, so the practical question for tax leaders is which clients need an update now rather than at quarter-end, before sourcing assumptions and landed-cost models go stale.

The broader list points to an integrated tax calendar

The rest of the roundup, which spans Belgium, Cyprus, the European Union, Poland, Pakistan, Kenya, FATCA, CRS, CARF, and trade-customs developments, reinforces the same operating lesson: tax teams are being asked to track more jurisdictions and more regimes at once.

For KPMG professionals, that makes a weekly digest like this a management tool, not just a reading list. It is where leaders can identify which issues belong in client alerts, which need partner escalation, and which require coordination between advisory, compliance, and controversy before the next workstream turns into a bottleneck.