http://www.kpmgtaxwatch.com en-us © 2009 KPMG LLP, a U.S. limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a Swiss cooperative. All rights reserved. Selected events from the KPMG TaxWatch Thought Leadership Series archives KPMG LLP (U.S.) KPMG TaxWatch is a series of thought leadership events developed to provide a high-level overview of current tax developments and legislative changes and how those changes could affect business. (© 2009 KPMG LLP, a U.S. limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a Swiss cooperative. All rights reserved.) KPMG TaxWatch is a series of thought leadership events developed to provide a high-level overview of current tax developments and legislative changes and how those changes could affect business. (© 2009 KPMG LLP, a U.S. limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a Swiss cooperative. All rights reserved.) tax, tax issues, tax podcast, tax podcasts, state tax, federal tax, international tax, sarbanes-oxley, section 404, SOX, SALT, webcast, legislative update KPMG LLP us-taxwatch@kpmg.com No http://www.kpmginstitutes.com/xml/tax-watch.xml Thu, 03 Dec 2009 19:00:00 GMT The Webcast provides insights relevant to the new NOL carryback provision and reviews the procedures for obtaining refunds under the new provision (including Rev. Proc. 2009-52), plus other year-end issues related to cash management of taxes. (December 3, 2009) 1367318095-1367319173 56:55 Tue, 24 Nov 2009 19:00:00 GMT This Webcast focused on the recently enacted legislation which allows most taxpayers an extended carryback period from two years to up to five years for net operating losses (NOL) incurred in taxable years beginning or ending in 2008 or 2009. Presenters from KPMG's Washington National Tax Practice, Procedure & Administration, Corporate, International and other groups discussed how this legislation presents a significant opportunity for taxpayers, who can use recent NOLs to offset taxable income for up to five preceding tax years and obtain tax refunds. (November 24, 2009) 1367317619-1367319172 1:57:00 Mon, 23 Nov 2009 19:00:00 GMT During this Webcast on transfer pricing and customs planning considerations, KPMG LLP professionals discuss a number of tax and customs areas that companies with cross-border operations may want to consider at the end of the year and as they look to the future as the global economy moves out of recession. Topics covered included specific year-end transfer pricing issues; customs versus tax related-party pricing; customs related-party pricing risk management; cost reduction considerations in the customs areas; the intersection of U.S. Customs value and tax; and central entrepreneur structure planning. (November 23, 2009) 1367317213-1367319171 1:01:46 Tue, 17 Nov 2009 19:00:00 GMT KPMG LLP's tax professionals provide an in-depth discussion on current R&D trends, developments, and updates, and how they may affect companies. The discussion covers the R&D tax credit extension and other regulatory and administrative guidance; R&D Tax Credit Cases: Union Carbide, FedEx, McFerrin, and Deere; IRS exam and appeals; and global R&D. (November 17, 2009) 1367317045-1367319170 1:44:47 Thu, 12 Nov 2009 19:00:00 GMT KPMG LLP's tax professionals provide an in-depth discussion on the latest developments in tax information reporting as well as compliance issues that should be considered as you prepare for calendar year 2009 information return filings. (November 12, 2009) 1367316859-1367319169 1:14:45 Thu, 12 Nov 2009 14:00:00 GMT Geared toward tax professionals located outside the United States, the topic of this TaxWatch Webcast was the basics of the U.S. sales tax system. Included in the discussion: the basics of U.S. state and local taxation (including the sub-national structure and jurisdictional reach of state taxing authorities), the basics of U.S. sales and use taxes (including tax base, common exemptions and sourcing of transactions), and current developments in U.S. sales taxes. (November 12, 2009) 1367316287-1367319168 1:17:26 Thu, 05 Nov 2009 19:00:00 GMT State tax revenue collections are continuing to face significant challenges due to the current economic environment. Budget shortfalls faced by many states in the U.S. could lead to an increase in state audit related activities. This TaxWatch Webcast focused on current developments in state tax controversies including the fiscal condition of the states, nexus, business purpose/sham transaction doctrine, combined and consolidated reporting, captive REIT legislation, expense disallowance provisions and related party transactions. (November 5, 2009) 1367316280-1367319166 1:01:57 Thu, 08 Oct 2009 17:00:00 GMT This Webcast focused on state tax legislative developments, judicial developments and recent tax controversy developments that could possibly affect the diversified industrials and consumer markets industries, including: tax rate increases and surcharges, expansion of the sales tax base, state amnesty programs, adoption of combined reporting, additional reporting requirements, expanded addback provisions, accelerated payments and tax attributes limitations. (October 8, 2009) 1316827732-1318025724 1:53:44 Wed, 30 Sep 2009 18:00:00 GMT This Webcast focused on global and domestic employment tax and risk management issues. Professionals from KPMG's International Executive Services and Internal Audit practices discussed many of the employment tax issues and risks companies face when dealing with a globally mobile workforce, including: understanding enterprise risk management from the board perspective, drivers of risk management in global mobility, significant exposure areas in global mobility, risk related to intra-country movement, ways to address risk management related to global mobility and U.S. mobility concerns such as non-resident state income tax withholding, multistate withholding and SIT withholding. (September 30, 2009) 1316826891-1316831345 59:06 Thu, 17 Sep 2009 18:00:00 GMT On July 31, 2009, the Treasury Department and IRS released final regulations under section 482 on intercompany services transactions and the allocation of income attributable to intangibles. The preamble to the final regulations indicates that both the format and the substance of the final regulations are generally consistent with the 2006 temporary regulations, and that the changes adopted are intended to make certain clarifications and improvements without fundamentally altering the policies reflected in the 2006 temporary regulations. This Webcast provides an overview of the key provisions of the final regulations, highlighting the significant clarifications and improvements. Taxpayer comments to the temporary regulations that were rejected by the government are also discussed. (September 17, 2009) 1316827507-1316831346 53:01 Thu, 27 Aug 2009 18:00:00 GMT The current recession is forcing tax executives to grapple with unique tax issues and planning considerations surrounding devalued assets and investments. This Webcast takes detailed look at the tax considerations relating to worthless stock deductions under section 165(g), including the valuation requirements for determining worthlessness for purposes of taking those deductions. The discussion also reviews how the determination of whether a worthless deduction is permitted is affected by reorganizations of insolvent companies, and how the consolidated return regulations affect the determination of worthlessness for federal tax purposes. In addition, issues relating to the determination of gross receipts for purposes of determining whether an ordinary deduction is permitted under section 165(g)(3) are discussed. (August 27, 2009) 1274138090-1274169405 1:05:27 Tue, 25 Aug 2009 15:00:00 GMT This Webcast focuses on the most recent tax considerations of interest to Latin American companies entering or expanding their operations in China. Speakers from KPMG in China and KPMG LLP's Americas Tax Center of Excellence discuss key tax concerns when investing in China and includes a discussion of the Chinese value added tax and business tax regulations, which came into effect on January 1, 2009, may have a significant impact on Latin American organizations doing business in China. (August 25, 2009) 1274137832-1274167885 55:40 Wed, 19 Aug 2009 18:00:00 GMT This one-hour Webcast provided an overview of the legislative proposals affecting life insurance companies and property & casualty insurance companies. Professionals from KPMG LLP's Washington National Tax Financial Institutions and Products group discussed the developments relating to IRS adjustment authority under Section 845, the tax and accounting treatment of impaired debt instruments and provided guidance on the sale of life insurance contracts and employer owned life insurance. (August 19, 2009) 1274137840-1274168092 1:00:57 Tue, 18 Aug 2009 18:00:00 GMT This Webcast provided an overview of cash flow planning and compliance using automatic accounting method changes. Government officials from the IRS Office of Chief Counsel and professionals from KPMG LLP's Income Tax and Accounting group discussed the general procedural issues affecting automatic accounting method changes, the pitfalls of automatic depreciation method changes, and the issues affecting automatic accounting method changes involving the uniform capitalization rules under section 263A. (August 18, 2009) 1274138751-1274167888 1:42:58 Wed, 05 Aug 2009 15:00:00 GMT On January 1, 2010, the European Union will implement Value-Added Tax (VAT) legislative changes. This TaxWatch Webcast focused on what the US headquartered company needs to know in advance of these changes such as the details of the EU VAT Package, why it matters to US headquartered businesses and how they might be affected and what affected businesses need to do from a planning, compliance and systems perspective to prepare. (August 5, 2009) 1274129414-1274129911 58:07 Tue, 04 Aug 2009 17:00:00 GMT On this TaxWatch Webcast, partners and professionals from KPMG's Washington National Tax State and Local Tax Group and State Tax Resource Network discussed several income tax issues that are affecting a number of states including, conformity issues, addback legislation and developments, apportionment, rate increases and surcharges, amnesty programs and combined reporting. (August 4, 2009) 1274121745-1274122629 57:27 Mon, 03 Aug 2009 18:00:00 GMT This Webcast covered the compliance issues that should be considered before filing your 2008 federal income tax return. Professionals from KPMG's Washington National Tax practice covered the preparation of corporate and partnership income tax returns, and particularly focused on changes for this filing season. (August 3, 2009) 1274228581-1274231532 1:14:44 Wed, 22 Jul 2009 17:00:00 GMT On May 27, the U.S. Court of Appeals for the Ninth Circuit reversed the U.S. Tax Court's decision in Xilinx, Inc. v. Commissioner. While debate over the case will likely continue, tax executives responsible for intercompany pricing may want to develop a strong understanding of the Xilinx case and its implications, especially taken together with the temporary and proposed Sec. 482 cost sharing regulations that went into effect January 5, 2009. During this Webcast, KPMG LLP professionals discussed the implications of the Xilinx case for taxpayers in the Ninth Circuit with cost sharing agreements; taxpayers in other circuits with cost sharing agreements; the treatment of stock based compensation charges outside the cost sharing context; and the relationship between the arm's-length standard and the IRS's ability to make transfer pricing adjustments. (July 22, 2009) 1233955323-1233956603 47:02 Tue, 21 Jul 2009 17:00:00 GMT This Webcast focused on the issues that companies should be considering prior to the elimination of certain entities. Professionals from KPMG's Washington National Tax practice discussed fact patterns where the elimination of such entities may result in the termination of an entity that has been treated as a partnership for federal tax purposes. Also discussed were reasons for eliminating internal partnerships, IRS Revenue Ruling 99-6, and issues arising when internal partnerships are eliminated. (July 21, 2009) 1246213069-1246215711 1:41:48 Tue, 30 Jun 2009 18:00:00 GMT On this Webcast, KPMG State and Local Tax partners and professionals discussed how improper documentation of Exemption Certificates could cause a company to be non-compliant with tax laws and could potentially result in significant costs. They reviewed the proper procedures and requirements of documenting Exemption Certificates and gave specific state examples. Additionally, there was a discussion on sales tax credits and how ineffective utilization or not converting sales tax refund credits to cash before they expire could affect a company's cash flow. Taxpayer issues surrounding this and specific state examples were also given. (June 30, 2009) 1246204209-1246204843 51:01 Mon, 29 Jun 2009 18:00:00 GMT This Webcast provided listeners with the possible business incentives companies have available to lower costs and raise returns on investment. Even during today's difficult operating environment, routine capital and human resource investments by companies may trigger opportunities to offset investment costs. Partners and professionals from our Global Location and Expansion Services practice discussed monetizing credits and other "cash" opportunities as well as compliance and clawback issues for statutory and negotiated incentives. (June 29, 2009) 1274126520-1274127097 56:23 Thu, 25 Jun 2009 15:00:00 GMT This event addressed the Obama Administration's May 11 budget request which included a number of proposals to reform international tax laws and enhance enforcement. KPMG professionals reviewed the IRS's recent withholding-related enforcement actions and the Administration's proposals, its "Green Book" explanations, and the potential affect of these proposals on USWAs, QIs, and NQIs. (June 25, 2009) 1246165197-1246171541 59:34 Wed, 17 Jun 2009 18:00:00 GMT In part two of this TaxWatch series, professionals from KPMG LLP's Washington National Tax Financial Institutions and Products group continued their discussion on the various tax accounting and character issues arising from investments by financial institutions and their subsidiaries in debt instruments. The program included an overview of the general tax rules that apply to troubled debt held by financial institutions, and the tax consequences and issues that should be considered when a lender forecloses on debt. (June 17, 2009) 1186229313-1186232799 1:04:42 Fri, 12 Jun 2009 17:00:00 GMT The Tax Executives Institute, in cooperation with KPMG LLP, hosted a TaxWatch Webcast designed specifically for Chief Tax Officers to provide insights and information on the American Recovery and Reinvestment Tax Act of 2009, the Obama budget proposals, and the prospects for additional tax legislation in 2009 and 2010. (June 12, 2009) 1186226778-1186232798 1:44:46 Tue, 09 Jun 2009 15:00:00 GMT Increased focus on transfer pricing issues by tax authorities around the world continues unabated, and the risk of tax audit, as jurisdictions attempt to retain their tax revenue base in light of the current economic downturn, may be on the rise. An Advance Pricing Agreement (APA) has long been considered a viable option for multinational companies looking for greater certainty in transfer pricing and reduced audit risk during normal economic times. During this Webcast, Global Transfer Pricing Services (GTPS) professionals from KPMG International member firms in Canada, the United Kingdom, and the United States discussed the continuing value of APAs in the current recession and how the economic downturn is affecting the APA process. Speakers also addressed whether adjustments to transfer pricing methodologies should be considered for negotiating APAs. Case-study examples illustrated how changes in such elements as comparable sets, ranges, and APA terms can affect results. (June 9, 2009) 1186234638-1186244036 1:01:22 Wed, 03 Jun 2009 15:00:00 GMT This event addressed The Obama Administration's May 11 budget request which included a number of proposals to reform international tax laws and enhance enforcement. KPMG professionals reviewed the IRS's recent withholding-related enforcement actions and the Administration's proposals, its "Green Book" explanations, and the potential affect of these proposals on USWAs, QIs, and NQIs. (June 3, 2009) 1185231471-1185234005 1:00:13 Wed, 27 May 2009 18:00:00 GMT This Webcast provided an in-depth discussion on the various tax accounting and character issues arising from investments by funds, traders, and other investors in debt instruments. The program included an overview of the rules governing the accrual of interest income, and the classification of debt instruments as capital or ordinary assets. (May 27, 2009) 1169625857-1169631687 1:02:57 Tue, 19 May 2009 18:00:00 GMT This Webcast covered the latest developments on reporting by U.S. persons of foreign financial accounts on Form TD F 90-22.1 (commonly referred to as the "FBAR"). The discussion will covered who must file the FBAR; what is considered a foreign financial account; what constitutes a financial interest in a financial account; what constitutes signature or other authority over an account; exceptions from the reporting requirement and penalties that may be imposed for reporting failures. (May 19, 2009) 1169606901-1169631684 1:00:49 Wed, 13 May 2009 15:00:00 GMT This Webcast provides a summary of the U.K. 2009 Budget, presented on April 22, 2009, by the United Kingdom's Chancellor of the Exchequer, and the potential implications for U.S. multinationals operating in the United Kingdom. Professionals from KPMG LLP's U.K. Tax Center of Excellence and Washington National Tax practice discuss, among other budget topics, reforms to the taxation of foreign profits, including the introduction of an exemption system for the taxation of dividends received by U.K. companies; limitations on the deductibility of net financing expenses through the introduction of a worldwide debt cap; and new requirements for U.K. holding companies to report certain transactions involving foreign subsidiaries. (May 13, 2009) 1185224406-1185234004 58:28 Tue, 12 May 2009 18:00:00 GMT This Webcast covered the principal components of President Obama's plan to reform international tax laws and improve enforcement as outlined in a May 4 press release and in Treasury's May 11 "Green Book." Speakers from KPMG LLP's Washington National Tax (WNT) and International Corporate Tax Services (ICS) practices discussed, among other matters, proposals to defer deductions supporting deferred (not current taxed) foreign earnings, modify the foreign tax credit rules, and amend the check-the-box rules, and the possible implications of these proposals for multinationals with U.S. operations. (May 12, 2009) 1169625419-1169631686 1:10:19 Thu, 07 May 2009 15:00:00 GMT Recent legislative developments and improved inventory control systems are causing retailers and distributors to take a closer look at how the Foreign Trade Zone (FTZ) program can facilitate financial and supply chain objectives in today's challenging economy. During this Webcast, FTZ-experienced KPMG LLP professionals provided an overview of the FTZ program and the possible economic and supply chain benefits for retailers and distributors. (May 7, 2009) 1169625323-1169631685 57:05 Wed, 06 May 2009 18:00:00 GMT This Webcast provided an overview of the FDIC's resolution process for failing financial institutions and a discussion of the tax and accounting issues arising from the two most common resolution methods -- a purchase and assumption transaction with optional loan or asset pools and a purchase and assumption transaction with a partial loss guarantee provided by the FDIC. (May 6, 2009) 1169606528-1169631683 56:33 Tue, 28 Apr 2009 15:00:00 GMT This event addressed key M&A Tax trends and market conditions of infrastructure projects in the Iberoamerica region. The technical tax discussion included an overview on developments and trends in Brazil, Colombia, Peru, and Spain, and the results of a global survey conducted in cooperation with the Economist Intelligence Unit, highlighting the results for the Iberoamerica region. (April 28, 2009) 1169458998-1169459638 1:25:23 Wed, 22 Apr 2009 17:00:00 GMT This Webcast focused on the deductibility of service charges in different jurisdictions around the world. Senior-level Global Transfer Pricing Services professionals from KPMG International member firms in the Americas, Europe, and Asia examined--from regional and local-country perspectives--definition of benefit, documentation of benefit, shareholder activities, charge-out methods, stock-based compensation, markups on services costs, and withholding tax issues. (April 22, 2009) 1147018828-1147021943 1:50:17 Mon, 13 Apr 2009 15:00:00 GMT Mexico's tax authorities recently released new transfer pricing disclosure requirements that are effective beginning with tax years ending December 31, 2008. The new requirements can affect taxpayers' transfer pricing documentation and may require further disclosures in Mexico's statutory tax audit report. In this Webcast, Global Transfer Pricing Services professionals from KPMG International member firms in the United States and Mexico discuss how to navigate Mexico's new requirements. (April 13, 2009) 1146991484-1147021942 59:32 Thu, 09 Apr 2009 15:00:00 GMT This Webcast featured the recent Value-added Tax, Business Tax and Consumption Tax changes in China. The revised regulations came into effect on January 1, 2009 and may have significant impacts for organizations doing business in China. Professionals from KPMG's Beijing, China office discussed the change of VAT credit rules for fixed assets, the implications of the change of VAT rules on sales of used assets and the implications of the change of Business Tax rules on place of supply of offshore services. (April 9, 2009) 1121365465-1121368556 1:00:12 Thu, 26 Mar 2009 15:00:00 GMT Today, it is more important than ever for companies to assess their global supply chains to help ensure they are responding constantly to evolving market conditions. In this Webcast, senior-level professionals with extensive supply chain experience addressed considerations for international product and service flows, direct and indirect tax planning, and selection of tax efficient global supply chain activities in a challenging global economy. (March 26, 2009) 1169447015-1169447575 1:03:54 Tue, 24 Mar 2009 15:00:00 GMT The sharp drop in demand for autos in the U.S. and European consumer markets has affected the automotive industry up and down the supply chain. Many automakers now sit on the brink of bankruptcy and large scale layoffs. Weathering the current economic storm is crucial to the future existence for many automakers, and understanding new regulations that are globally affecting the auto industry is a potential key for doing so. Of note, the Chinese tax authorities have recently made significant changes to their transfer pricing policies that are expected to radically change the face of transfer pricing in China and have deep implications for automakers. In this Webcast senior transfer pricing professionals from KPMG in the United States and KPMG in China discuss navigating the growing complexity that the new rules pose for automakers in light of the current economic downturn. (March 24, 2009) 1127475255-1127477205 1:00:10 Thu, 19 Mar 2009 18:00:00 GMT With the rapid proliferation of transfer pricing regulations and penalty regimes over the past 10 years, and the growing sophistication of tax authorities, U.S. multinational companies have been faced with an increasingly challenging transfer pricing risk management landscape. High growth markets such as Brazil, Russia, India, and China -- the so-called "BRIC" countries -- are among the countries presenting unique challenges. In this Webcast, guest speakers Richard M. Goldberg, Director of Global Transfer Pricing, Citigroup Inc., and Dennis J. Michaels, Director of Global Transfer Pricing, Johnson & Johnson joined Global Transfer Pricing Services professionals from KPMG LLP professionals to discuss their experience in dealing with the transfer pricing issues in these emerging market countries. (March 19, 2009) 1127100386-1127101151 1:11:40 Tue, 17 Mar 2009 18:00:00 GMT This Webcast provided an in-depth discussion on the changes to Form 1065 with the release of the 2008 version. The revised form requests a significant amount of additional information, including required reporting of direct and indirect ownership interests. Other changes include additional information reporting for Schedule M-3 filers, clarifications to the reporting of ownership interests on Schedule K-1 that mandate numerical ratios be provided, and modifications to Schedule M-3 that will affect partnership filings. (March 17, 2009) 1098947267-1098947296 1:29:11 Wed, 11 Mar 2009 17:00:00 GMT This two-hour Webcast focused on two separate topics. The first hour was an overview of the groundbreaking Wisconsin tax legislation, which was introduced and passed in a little over a week's time. KPMG's State Tax Resource Network professionals who cover Wisconsin discussed a number of the provisions in the bill which affect business taxpayers, including: the adoption of unitary combined reporting, the expansion of Wisconsin's related-party addback provisions, new sourcing rules for receipts from the sale or use of intangibles, the imposition of sales and use tax on digital equivalents and SSUTA conformity. The second hour focused on multi-state developments which companies may need to be aware of for 2008 state and local tax return compliance and for preparing 2009 estimates. Professionals from our Washington National Tax State and Local Tax Group and our State Tax Resource Network discussed the issues resulting from tax law changes in California, Massachusetts, Michigan and Wisconsin, new and expanded state addback provisions and federal conformity issues, including bonus depreciation, IRC Section 199 conformity and federal stimulus provisions. (March 11, 2009) 1098933144-1098940329 1:50:13 Wed, 04 Mar 2009 18:00:00 GMT This Webcast provided an in-depth discussion on certain provisions of the ARRA. The discussion covered business tax incentives, cancellation of indebtedness, original issue discount and selected bond provisions, energy-related, as well as individual and family tax provisions. (March 4, 2009) 1067507444-1084869782 1:26:56 Tue, 03 Mar 2009 16:00:00 GMT The number of countries that have transfer pricing regulations has increased significantly during the past decade. This globalization of transfer pricing has resulted in a range of procedural options for managing transfer pricing and its risks. In this Webcast, professionals from KPMG LLP's Global Transfer Pricing Services (GTPS), Tax Controversy Services, and Washington National Tax practices and a GTPS partner from KPMG in Japan discussed the range of options and the related considerations for resolving transfer pricing disputes. (March 3, 2009) 1067505011-1084869781 1:02:21 Thu, 26 Feb 2009 19:00:00 GMT This Webcast provided listeners with an update on current state and local legislative activity across the United States. Partners and professionals from our Washington National Tax State and Local Tax Group and members of our State Tax Resource Network discussed the current revenue and state budget crisis, the federal stimulus package, California and New York legislative happenings and recent multi-state legislative activities, proposals and enactments. (February 26, 2009) 1067500593-1067502612 1:02:08 Thu, 19 Feb 2009 16:00:00 GMT Professionals from KPMG LLP's Japan and U.K. Tax Centers presented on the tax reform proposals in Japan and the draft legislation in the United Kingdom regarding the taxation of foreign profits. (February 19, 2009) 1067499075-1067502611 54:02 Thu, 05 Feb 2009 19:00:00 GMT This Webcast focused on the challenges that many companies are currently facing due to FAS 5 in the indirect tax area. Subject matter specialists from KPMG's State and Local Tax practice and the firm's Department of Professional Practice gave an overview of FAS 5 and also discussed the potential sources of indirect tax contingent liabilities, measurement and mitigation approaches and updated the audience on proposed revisions to FAS 5 disclosure requirements. (February 5, 2009) 1067494768-1067502609 1:05:33 Wed, 04 Feb 2009 16:00:00 GMT Last fall, the Organisation for Economic Co-operation and Development (OECD) released a draft report on transfer pricing issues raised by business restructurings and its potential impact on multinational companies and, when finalized, the report will add detail to the OECD's existing Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This Webcast discussed key elements of the draft report for multinational companies, and covered the OECD's definition of business restructuring; the report's key concepts; and how various Western European tax authorities' positions align with those of the OECD draft. (February 4, 2009) 1067439246-1067440395 1:02:06 Thu, 22 Jan 2009 19:00:00 GMT Presenters from KPMG LLP's M&A Tax, Advisory Restructuring, and Washington National Tax practices discuss the financial challenges that may require an organization to rework its balance sheet or operational structures, or even to seek bankruptcy in this current economic environment. Many companies are unfamiliar with the restructuring process which, with numerous parties competing for limited rewards, can be highly adversarial by nature. A troubled company entering this arena should be armed with an understanding of the complex financial and tax issues. Topics include: issues facing companies that have debt maturing in the near-to-mid-term and how to satisfy lenders' current requirements, a discussion of financial restructuring alternatives for the highly-leveraged company, an update of recent developments with respect to critical tax issues such as cancellation of indebtedness, limitation on tax attributes, and insolvency reorganizations, an overview of recently finalized intercompany obligation regulations, and a discussion of certain bankruptcy specific tax provisions for the corporate taxpayer. (January 22, 2009) 1067434984-1067440394 1:01:32 Wed, 21 Jan 2009 16:00:00 GMT After much anticipation, China finalized the Administrative Regulations on Special Taxation Adjustments, a set of regulations that will bring the world's third largest trading power closer in line with international practices and is expected to radically change the face of transfer pricing in China. KPMG LLP's Global Transfer Pricing Services (GTPS) practice hosted senior tax and transfer pricing professionals from KPMG in China for a discussion on the impact of the new rules on multinational companies with operations in China. The Webcast covered documentation and disclosure forms; Advance Pricing Arrangements; cost sharing agreements; and conflict resolution. (January 21, 2009) 1067428015-1067440393 1:13:51 Thu, 15 Jan 2009 19:00:00 GMT On December 31, 2008, the Treasury and IRS released, in temporary and proposed form, long-awaited regulations addressing a cost sharing arrangement (CSA) among controlled taxpayers. These new regulations (the "Temporary Regulations") took effect on January 5, 2009. Professionals from KPMG's Washington National Tax practice who focus transfer pricing examined the implications of the Temporary Regulations on multinational companies and discussed transition issues (including actions taxpayers should take to ensure existing CSAs are grandfathered under the 1995 cost sharing regulations), differences between the 2005 proposed CSA regulations and the Temporary Regulations, and how the Temporary Regulations may affect planning for the future development of intangibles. (January 15, 2009) 1067424635-1067440392 1:00:22 Wed, 14 Jan 2009 19:00:00 GMT On December 24, 2008, the IRS issued the final and temporary "contract manufacturing" regulations. The regulations, released in proposed form in February 2008, provide guidance on the foreign base company sales income rules and whether subpart F income is triggered for U.S. shareholders under section 954 by contract manufacturing arrangements of controlled foreign corporations. During this Webcast, professionals from KPMG LLP's Washington National Tax practice, together with guest presenters Ethan Atticks from the IRS's Office of the Associate Chief Counsel (International) and Itai Grinberg from the Treasury's Office of the International Tax Counsel, discussed changes in the final and temporary regulations from the February 2008 proposed regulations, including clarification of the nine substantial contribution factors and revisions to the manufacturing and sales branch rules; effective dates; and the tax implications for multinational companies with global supply chains. (January 14, 2009) 1067421815-1067440391 1:44:48