KPMG’s Tax Governance Institute (TGI) will examine the Treasury Department’s proposed regulations under Section 385 of the U.S. tax code on related party indebtedness during a live video webcast on Tuesday, May 24, from 11 a.m. to noon (ET). The regulations, if adopted, would have a wide-ranging impact on the operation of corporate groups’ internal financing strategies and tax planning.
Devon Bodoh, principal-in-charge of the International Mergers & Acquisitions (M&A) group in KPMG’s Washington National Tax practice, will moderate the webcast that will include panelists:
• Robert Stack, deputy assistant secretary for International Tax Affairs, Office of Tax Policy, U.S. Department of the Treasury;
• Ryan Smith, vice president – Global Taxes, VF Corporation; and
• Joseph Pari, national principal-in-charge, Washington National Tax, KPMG LLP.
The 60-minute panel discussion will delve into the far-reaching proposed regulations, issued by the Internal Revenue Service (IRS) and the U.S. Department of the Treasury last month, examining their background, potential impact on corporate taxation of intercompany debt, and possible extensive effect on corporate operations.
The proposed regulations provide rules for when certain related-party interests in a corporation may be treated, for federal tax purposes, in whole or in part, as stock rather than debt.
“The proposed regulations could have a significant effect on the treatment of intercompany debt at both the federal and state tax levels,” said KPMG’s Pari. “The upcoming TGI webcast will be aimed at helping companies better understand these complicated regulations, cope with the uncertainty they could create on various fronts and prepare to address their possible consequences if finalized.”
Part of the KPMG Institute Network, the Tax Governance Institute provides opportunities for board members, corporate management, stakeholders, government representatives and others to share knowledge regarding the identification, oversight, management, and appropriate disclosure of tax risk.
KPMG LLP, the audit, tax and advisory firm (www.kpmg.com/us), is the U.S. member firm of KPMG International Cooperative (“KPMG International”). KPMG International’s member firms have 174,000 professionals, including more than 9,000 partners in 155 countries.
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