kpmg global tax webcast...content of this deck can be expected to occur as tax reform moves through...

KPMG Global Tax WebcastGlobal Asset Management and U.S. Tax Reform

What you should know today to help plan for tomorrow

December 19, 2017

1© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International

Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 725143

Notices

The following information is not intended to be “written advice concerning one or more

Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury

Department Circular 230.

The information contained herein is of a general nature and based on authorities that are

subject to change. Applicability of the information to specific situations should be

determined through consultation with your tax adviser.

Tax reform developments have been moving at a fast pace. Developments relevant to the

content of this deck can be expected to occur as tax reform moves through the legislative

process. Thus, some material in this deck may no longer be current at a future date.

Please follow developments through KPMG’s TaxNewsFlash-Tax Reform.



Moderator and speakers

Kevin Valek (Moderator)

Partner

National Segment Leader –

Private Equity Funds

Alternative Investments, KPMG in the U.S.

Deanna Flores

Principal, National Tax Industry Leader, Public

Investment Management,

KPMG in the U.S.

Jay Freedman

Principal, National Tax Industry Leader,

Alternative Investments – Hedge Funds, KPMG

in the U.S.

Carol Kulish

Director, Federal Legislative & Regulatory

Services,

Washington National Tax,

KPMG in the U.S.

David M. Neuenhaus

Principal, Tax, Global Lead, Institutional

Investor Group, KPMG in the U.S.

Sam Riesenberg

Principal, US International Tax, WNT, KPMG in

the U.S.

Chris Turner

Partner, National Tax Industry Leader,

Building, Construction & Real Estate, KPMG in

the U.S.



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Agenda

— Welcome and introductions

— A potential path to tax reform

— Highlights for asset management

— Q&A



CPE question #1

What is the type of your organization?

HedgeA.

Private equityB.

Real estate C.

Regulated investment companyD.

Fund of fundsE.

HybridF.

OtherG.

A potential path to tax reform


Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

A possible path to tax reform

Ways and Means

Chairman releases mark

11/3/17

Markup by Ways and

Means Committee

11/6/17

11/9/17

Ways and

Means

approves

bill

11/9/17House votes and passes11/16/17

Senate

Finance

Chairman

releases

mark

11/10/17

Markup by Senate

Finance Committee

11/14/17

Senate passed 12/2/17

Resolve differences

and send back to House

and Senate for vote on

identical legislation

Final bill sent to

President Trump

for signature

Treasury and Internal

Revenue Service begin

process of implementing

the new law

HouseBill introduced

11/2/17

Senate White House

Joint Conference© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms

affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 721411

Senate Finance Committee approves bill11/16/17

https://home.kpmg.com/us/en/home/insights/2017/11/tnf-ways-and-means-chairmans-mark-released-in-advance-of-markup-november-6.html


https://home.kpmg.com/us/en/home/insights/2017/11/tnf-ways-and-means-chairmans-modified-mark-to-hr-1.html


https://home.kpmg.com/us/en/home/insights/2017/11/tnf-ways-means-chairman-amendments.html


https://home.kpmg.com/us/en/home/insights/2017/11/tnf-ways-means-reports-tax-reform-bill.html?z


https://home.kpmg.com/us/en/home/insights/2017/11/tnf-senate-finance-tax-reform-markup-set-for-monday-afternoon-november-13.html


https://home.kpmg.com/us/en/home/insights/2017/11/tnf-senate-finance-chairman-modified-mark-released.html








https://home.kpmg.com/us/en/home/insights/2017/11/tnf-kpmg-analysis-house-tax-reform-bill.html







https://home.kpmg.com/us/en/home/insights/2017/11/tnf-senate-finance-committee-approves-tax-reform-bill.html

Provisions that may impact asset management



Rate reductionH.R. 1 Senate Bill Conference Bill

Corporate rate 20 percent; effective for taxable

years beginning after December 31,

2017.

20percent; effective for

taxable years beginning

after December 31, 2018.

21 percent; effective for taxable years beginning


Individual

owners of

passthroughs

and sole

proprietorships

“Business income” rate capped at 25

percent.

Rate applicable to net business

income from passive business

activities and to a percentage (the

“capital percentage”) of net business

income from active business

activities.

Default capital percentage is 30

percent, however service

businesses, including financial

service, brokerage firms and those

who invest, trade or deal in certain

securities (“specified service

activities”) generally would have a

deemed capital percentage of zero.

Alternate method may allow the 25

percent rate to apply to a deemed

return (short-term AFR plus 7

percent) on certain property used n

the trade or business.

Creates a 23 percent

deduction to be taken

against “qualified business

income.”

Service businesses

generally excluded.

Limitations apply.

Sunsets after 2025.

Generally follows Senate except:

Creates a 20 percent deduction to be taken against

“qualified business income.”, resulting in a 29.6

percent effective rate.

Service businesses generally excluded, including

performance of services that consist of investing

and investment management trading or dealing in

securities, partnership interest or commodities.

Includes limitations based on greater of 50 percent

of W-2 wages or (25 percent of W-2 plus 2.5

percent of qualified property).

Excluded services and W-2 limitations are not

applicable to income below specified threshold

amounts.

Trust and estates are eligible for the 20 percent

rate.

Rates expire on December 31, 2025.

Individual rates 12%/25%/35%/39.6% 10%/12%/22%/24%/32%/35

%/38.5%

Individual proposals under

the senate plan would expire

on December 31, 2025.

10%/12%/22%/24%/32%/35%/37%

Retains individual Alternative Minimum Tax.

Retains Net Investment Income Tax.

Rates expire on December 31, 2025.



Rate reduction

1. Do asset managers qualify for the reduced partnership tax rates?

2. Choice of entity evaluation in light of proposed tax rates and dividend rates.

3. What is “business” income? Does a trader fund convert income into business income?

4. Active participation by real estate professionals.



Securities identification

H.R. 1 Senate Bill Conference Bill

Securities identification No provision. Requires taxpayers (except for

regulated investment companies

[RICs]) to use the first-in first-out

method to determine cost basis of

specified securities sold,

exchanged, or otherwise disposed

of on or after January 1, 2018 (i.e.,

repeals specific identification

method).

Retains the rule allowing the

average basis method for certain

securities (e.g., stock of a RIC).

No provision.



CPE question #2

What is your organization doing around tax reform planning?

Monitoring onlyA.

Internal modelingB.

Engaged outside consultantsC.

Very littleD.

OtherE.



Interest expense limitation

1. Impact to blocker corporations and leveraged blocker structures

2. Impact on leveraged investment strategies

3. Impact on tax planning (zeroing out taxable income)

4. What is “business” interest? Trader versus investor

5. What is “interest”?

6. Portfolio companies

7. Carryforward provisions


Interest expense

Domestic corporation

interest expense

limitations

Disallows net business interest

deductions in excess of 30 percent

of “adjusted taxable income”;

adjusted taxable income generally

is taxable income without regard to

interest expense, interest income,

net operating loss, depreciation,

amortization, or depletion; would

not apply to small businesses, real

estate businesses, and utilities.

Potentially limits deductions of net

interest expense of certain

domestic corporations that are part

of an “international financial

reporting group”.

Generally the same as the House

proposal; however, the limitation is

generally more restrictive as adjusted

taxable income is reduced for

depreciation and amortization.

Disallows the deductibility of net interest

expense of a domestic corporation by

reference to whether it has excess debt

relative to its worldwide affiliated group.

Generally follows the Senate

but for years beginning after

December 31, 2017 and

before January 1, 2022,

adjusted taxable income is

computed without regard for

depreciation, amortization

and depletion.

Indefinite carryover. Special

rules for partnerships and S

corps.

Not included in Conference

Bill.



Carried interest

1. Impact to private equity

2. Alternatives?


Carried Interest Three-year holding period for long-term capital

gains (LTCG), anything less than three years is

short-term capital gains.

Three-year holding period would be required

for sales of assets held (directly or indirectly)

by the applicable partnership, or, in the case of

the sale of an applicable partnership interest,

the applicable partnership interest itself.

The partnership interest must be transferred to,

or held by, the taxpayer in connection with the

performance of substantial services by the

taxpayer, or a related person, in any

“applicable trade or business”.

Certain interests held by a corporation and

capital interests excluded.

Similar provision. Similar to Senate.

1. Impact to private equity

2. Treatment of partnership interests

3. Section 1256 contracts, Section 1231 gain and qualified dividend income

4. Effective beginning in 2018; no grandfathering



Expensing of assets


Expensing of assets In general, 100 percent expensing

would be allowed for property that

currently qualifies for bonus

depreciation if such property is

acquired or placed in service after

September 27, 2017 and before

January 1, 2023. Would also include

used property.

Property used in a real property

trade or business under Section

469(c)(7)(C) is not eligible for

expensing.

Similar to House, although used

property would not qualify. Also

expanded qualifying Section

179 property to include

personal property used in

hotels and apartment buildings,

as well as certain other

assets/improvements made to

nonresidential real property.

Allowed through 2022, reduced

in 20%, increments 2023-2027.

In general, 100 percent expensing

would be allowed for property that

currently qualifies for bonus

depreciation if such property is

acquired or placed in service after

September 27, 2017 and before

January 1, 2023. Would also

include used property.

Then:

2023 – 80%

2024- 60%

2025 – 40%

2026 – 20%

Increases amounts for longer

production period and certain

aircraft in all years including 2027.



Net operating losses and AMT


Net operating losses

Business losses of non-

corporate taxpayers

Alternative minimum tax

No carryback, indefinite

carryforward, but limited to 90

percent of taxable income.

Carryforwards are increased by

an interest factor annually.

No provision.

Repeal for individual or corporate

taxpayers.

Similar to House. 90 percent

limitation of taxable income

reduced to 80 percent for tax

years beginning on or after

December 31, 2022.

No indexing of carryforward

amounts.

Excess business losses for

individuals are limited to

$500,000/250,000 per year.

Individual AMT retained, but

exemption amounts increased.

Corporate AMT retained.

Similar to the Senate except 80

percent limitation of taxable

income for tax years beginning on

or after December 31, 2017 and

only for NOL’s generated in years


No indexing of carryforward

amounts.

Same as Senate.

Individual AMT retained, but

exemption amounts retained.

Corporate AMT repealed.

.



Tax-exempt investors

1. State pension funds will continue to be exempt from UBTI even though considered a “super” tax-exempt:

a) Investments in funds

b) Investments in management companies


UBTI Unrelated business income tax would

apply to an organization exempt from

tax under section 501(a)—even if the

organization is also exempt or

excludes amounts from gross income

by reason of another provision.

No provision. No provision.

UBTI netting No provision. A tax-exempt organization would

not be allowed to use UBTI losses

from one unrelated trade or

business to offset income from

another unrelated trade or

business.

Such UBTI losses would be

carried over to offset future UBTI

income of that same unrelated

business.

Same as Senate.

Excise tax No provision. Creates new 1.4 percent excise

tax on net investment income of

private colleges and universities.

Creates new 1.4 percent

excise tax on net investment

income of certain private

colleges and universities.



CPE question #3

Which of the following provisions will most change how you do business?

Rate reductionsA.

Interest expense limitationB.

Capital expenditure deductionC.

International provisionsD.

OtherE.

International



InternationalKey proposals


Participation

exemption system

Creates a 100 percent exemption

for dividends received from 10

percent owned foreign

corporations.

Same, except does not apply to

hybrids; clarifies/adds exemption for

1248/964(e) dividends.

Generally the same as the Senate Bill.

Repatriation of existing

earnings and profits

(E&P)

Foreign earnings accumulated

under old system deemed

repatriated; rate of 14 percent for

cash/cash equivalents and 7

percent for illiquid assets; the tax

is payable over eight years; E&P

determined as of November 2 or

December 31 (whichever is

higher).

Foreign earnings accumulated under

old system deemed repatriated; rate

of 14.5 percent for cash/cash

equivalents and 7.5 percent for

illiquid assets; the tax is payable over

eight years; E&P determined as of

November 9 or December 31;

recapture upon inversion within 10

years.

Foreign earnings accumulated under old

system deemed repatriated; rate of 15.5

percent for cash/cash equivalents and 8

percent for illiquid assets; the tax is

payable over eight years; E&P

determined as of November 2 or

December 31; recapture upon inversion

within 10 years.

Gain on sale of

partnership interest

No provision. Gain or loss from the sale of a

partnership interest is effectively

connected with a U.S. trade or

business to the extent the transferor

would have ECI had the partnership

sold all assets.

Generally the same as the Senate Bill

with an effective date for sales after

November 28, 2017 but withholding will

apply to sales after December 31, 2017.

1. U.S. funds or U.S. partners that own 10 percent or more of a specified foreign corporation (foreign corporations with a 10%

U.S. corporate shareholder)

a) Impact to 2017 tax returns

2. Dividends received deduction

3. Repeal of Grecian Mining



Inbound alternatives investors

Tax reform will impact topside fund structuring (that is, how non-U.S. investors

invest into funds with U.S. tax exposure).

How? It depends:

— Federal rate reductions on corporate income compared to individual rates may make blocker

structures more tax effective

— No (apparent) movement on treaties and withholding/branch taxes means interactions with

rate reductions result in new structuring choices

— Restrictions on interest deductibility may mean some existing structures will need to be

modified to achieve optimal tax efficiency

— Elimination or reduction of SALT deduction may impact typical inbound tax planning.

New section 267A will need close consideration

— Applies to “hybrid entities” and “hybrid transactions” –denies royalty or interest deduction

where paid or accrued to a “related party” where paid to or pursuant to such entity

— Law itself somewhat unclear how it applies to basic inbound structuring

— But broad regulatory authority here…

FIRPTA reform – no provisions under either bill

Let us walk through some basic investment structures and the potential rate impact

International proposals



Inbound investors example rates (nontreaty)International proposals

Trust –Direct Trust –Blocker Foreign Corp –

Direct

Foreign Corp –

Blocker

Individual –

Direct

Individual -

Blocker

Income –

Current Law39.6% 54.5% 54.5% 54.5% 39.6% 54.5%

Income –Tax

Reform37% 44.7% 44.7% 44.7% 37% 44.7%

Exit Gains –

Current Law20% 35% 35% 35% 20% 35%

Exit Gains –Tax

Reform20% 21% 21% 21% 20% 21%

Trust Individual

U.S. BlockerU.S. BlockerU.S Blocker

Corp

Fund

United States

Investor

jurisdiction

Fund Fund



Inbound investors example rates (treaty)International proposals

Trust –Direct Trust –Blocker Foreign Corp –

Direct

Foreign Corp –

Blocker

Individual –

Direct

Individual -

Blocker

Income –Current

Law39.6% 35% 38.25% 38.25% 39.6% 44.75%

Income –Tax

Reform37% 21% 24.95% 24.95% 37% 32.85%

Exit Gains –

Current Law20% 35% 35% 35% 20% 35%

Exit Gains –Tax

Reform20% 21% 21% 21% 20% 21%

(0%) (5%) (15%)WHT/BPT Rate:

Trust Individual

U.S.

Blocker

U.S.

Blocker

U.S.

Blocker

Corp

Fund

United States

Investor

jurisdiction

Fund Fund



Outbound U.S. alternatives investors

Most significant immediate impact to existing structures may likely be from CFC

reform (mandatory repatriation in particular).

— For existing holdings: Mandatory repatriation means current tax considerations on existing

structures, possible need for restructuring at fund and investor levels to optimize tax position.

— For new investments in existing structures: structural changes will likely be implemented

to increase tax efficiency for outbound investors coming through fund structures, particularly

in PE, infra and potentially real estate.

For new fund or co-invest structures, will U.S. investors want a U.S. corporate

vehicle now (at least some of the time)?

— What about “GILTI”?

Note, certain structures with U.S. investors may now be more sensitive to local tax

drag (may be less ability to credit in the U.S., where broadly available before with

hybrid planning).

The PFIC regime appears here to stay…




International issues for fund managers

U.S. sub-advisers of non-U.S. managers

― Lowered deductibility of state and local taxes may pass on to employers of, e.g., SF, NY-

based deal professionals:

- May mean cost-plus payments to U.S. sub-advisers could start trending up from higher

employer costs?

- Tax reform may be the catalyst to consider a different TP methodology for your U.S. sub-

adviser.

— BEAT could implicate management payments and recharges for larger AM managers with

U.S. operations

- Restructuring and adjustments may be necessary

- Additional entities may be subject to U.S. tax filing obligations

US headquartered managers

— Deemed repatriation will significantly impact some of the larger managers, probably not the

majority, however.

— Restructuring outbound fund management entities likely to be undertaken:

- Fund management structures may look very different than today.




CPE question #4

What do you consider the most important issue being considered?

Corporate and partnership ratesA.

Carried interestB.

Interest expense limitations and immediate expensingC.

International issues (e.g., territorial tax system and mandatory repatriation)D.

OtherE.

Real estate



Real estate provisions

Like-kind exchanges – Similar provisions in House and Senate proposals

— Section 1031 would only apply with respect to real property (but not dealer property or

domestic/foreign exchanges).

— Applies to exchanges completed after December 31, 2017

— Transition rule would exempt exchanges where the first transaction (either forward or

reverse exchange) occurs on or before December 31, 2017.

REIT dividends – similar provisions in House and Senate proposals

— Would qualify for the 20 percent deduction without W-2 limitation except to the extent that the

dividends qualified for the lower 20 percent rate with respect to capital gain or qualified

dividend income

— Mandatory repatriation provisions (Senate only):

Accumulated foreign income would be excluded from gross income tests

Similar eight-year period as regular corps for meeting distribution requirements.

FIRPTA reform – no provisions under either bill

Nonowner contributions to capital – potentially taxable to owner under House bill

Conference report limits applicability to corporations and excludes contributions in aid of

construction and contributions by government or civic groups.



Recovery periods for real estate


Recovery periods No provision. Recovery period for depreciation

deductions:

— Nonresidential real property – 25

years (ADS – 40 years).

— Residential rental property – 25


— Qualified leasehold improvements,

qualified restaurant, and qualified

retail improvement property – 10

years (though ADS life is 20 years).

— For real property trades or

businesses that elect to be exempt

from the interest expense limitations,

all of the above must be depreciated

under ADS lives.

Recovery period for depreciation

deductions:

— Nonresidential real property – 39


— Residential rental property – 27.5


— Qualified leasehold improvements,

qualified restaurant, and qualified

retail improvement property – 15

years (though ADS life is 20 years).

— For real property trades or

businesses that elect to be exempt

from the interest expense limitations,

all of the above must be depreciated

under ADS lives.

Public investment management



Notable provisions – Conference Bill

Favorable treatment for certain REIT (but not RIC) distributions

— Potential impact on structuring preferences for entities taxed as regulated investment companies

(RICs), including business development companies (BDCs).

Limitation on “net business interest”

— Impact on RICs, including BDCs.

International Tax Provisions

- Reforms international tax rules impacting global asset managers

- Specific provisions for REITs (but not RICs) subject to mandatory repatriation inclusions

- RICs, REITs and S Corporations are not subject to base erosion minimum tax.

Municipal lending

— Terminates advance refunding bonds and tax credit bonds.

Change in income recognition rules

- Requires taxpayers to recognize certain income no later than the tax year in which such income is

taken into account on an applicable financial statement

- New rule will accelerate inclusion in income of certain fees currently treated as original issue discount

(OID) on a debt instrument

- Could significantly impact RICs that originate debt, including BDCs.

Reduces dividends received deduction (DRD) percentages



CPE question #5

When do you believe U.S. tax reform will be enacted?

2017A.

2018B.

2019C.

UnsureD.

Transition planning and things to do now



Proposal Pricing impact

Tax rates Increase in value due to increase in cash flow from reduced tax rates.

Interest deductibility Decrease in value for highly leveraged companies due to decrease in cash flow from reduced

interest deductions.

Expensing Increase in value for asset intensive businesses due to increase in cash flow from

immediate tax deductions

Potential expensing of portion of purchase price in asset acquisitions under House Bill

approach.

International tax Potential benefit for U.S. corporate targets from ability to receive tax free dividends from

foreign subsidiaries, but consider expected amount and allocation of Repatriation Tax cost

and going forward effect of minimum tax on cash flows

For U.S. corporate targets, potential impact of base erosion tax, if applicable, and (under

Senate Bill) FDII deduction.

NOLs, Credits, and Incentives Value of company’s tax attributes or other preference items may be affected.

Current transactions - pricing implications

Pricing models and diligence should take into account the potential effects

of tax reform



Current transactions – other issues

— Analyze whether to close pending deals in 2017 or 2018

— Contractual provisions to allocate tax benefits/detriments related to transition issues, such as

repatriation tax?



General transition planning

GP/management company

- Review management fee arrangements and GP structure to assess qualification for new

pass-through rate/deduction

- Evaluate potential impact on arrangements with respect to foreign offices/affiliates.

Portfolio companies

- Accelerate deductions and defer income, including through accounting method changes

(see next slide)

- If applicable, consider potential impact on deferred tax assets and liabilities

- Evaluate and address affected bank covenants

- Evaluate current leverage levels and take potential reform into account in planning with

respect to incurrence of new debt and refinancings

- Assess potential impact on existing and planned value chain arrangements

- Consider planning to limit earnings and profits of foreign subsidiaries to amounts as of

November 2 so as not to have a larger amount on the December 31 testing date

- Review required tax distributions from pass-through entities in light of deduction vs. rate

reduction.



Accounting method changes

— Accounting method changes are a key planning tool in anticipation of rate reductions

and the repatriation tax

- Lock in benefit of rate reduction

- Optimize earnings and profits in anticipation of repatriation tax.

— Method changes effective for 2017 tax year will be effective as of January 1, 2017 (for

calendar year taxpayers), meaning they will adjust E&P and other tax attributes prior to

the November 2/9 cut-off date.

— Time is running out to make “non-automatic” method changes (must be filed prior to the

end of the “year of change”) and for transactional planning (such as changing bonus

plans, pension contributions, and prepayments).

— Taxpayers have more time for automatic method changes, allowing more time to

assess what actually happens legislatively prior to having to formally change

accounting methods.



Today’s presenters

Kevin Valek +1 212-872-5520 [email protected]

Deanna Flores +1 858-342-7661 [email protected]

Jay Freedman +1 212-954-3693 [email protected]

Carol Kulish +1 202-533-5829 [email protected]

David Neuenhaus +1 973-912-6348 [email protected]

Sam Riesenberg +44 20 7694 1669 [email protected]

Chris Turner +1 404-222-3334 [email protected]

For more information on the House bill and the Senate Bill, read:

— KPMG’s report [119 pages] providing initial observations and analysis on the House

bill

— KPMG’s report [175 pages] providing initial observations and analysis on the Senate

Finance Committee bill (based on “conceptual” documents available as of December

4th

— KPMG report [165 pages] Initial analysis, observations of tax reform conference

agreement

See TNF-Tax Reform for coverage of current developments regarding tax reform.

https://home.kpmg.com/content/dam/kpmg/us/pdf/2017/11/tnf-house-passed-bill-booklet-nov16-2017.pdf

hhttps://home.kpmg.com/content/dam/kpmg/us/pdf/2017/12/tnf-senate-passed-bill-dec4-2017.pdf

https://home.kpmg.com/us/en/home/insights/2017/12/tnf-kpmg-report-initial-analysis-observations-of-tax-reform-conference-agreement.html

https://home.kpmg.com/us/en/home/insights/2016/12/tnf-tax-reform-expectations-for-2017.html

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The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide

accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one

should act on such information without appropriate professional advice after a thorough examination of the particular situation.

© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International

Cooperative (“KPMG International”), a Swiss entity.

All rights reserved. NDPPS 725143

The KPMG name and logo are registered trademarks or trademarks of KPMG International.

© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of

independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.

All rights reserved. NDPPS 725143

The KPMG name and logo are registered trademarks or trademarks of KPMG International.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular

individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such

information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on

such information without appropriate professional advice after a thorough examination of the particular situation.

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kpmg global tax webcast...content of this deck can be expected to occur as tax reform moves through...

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