Jun 07, 2016
From the Tax Governance Institute
On April 4, 2016, the U.S. Treasury Department released proposed regulations (the “385 Regulations” or the “rules”) that would fundamentally alter the U.S. tax treatment of intercompany financing within U.S.- and non-U.S.-parented multinational groups.
If enacted in their current form, the rules will significantly affect many group’s cash management and corporate development activities and could be the most profound change to the U.S. international tax system in the last 20 years. Treasury Department officials have repeatedly stated their intention to finalize the rules before year-end.
Taxpayers are therefore well advised to begin preparing for the new rules to take effect in the coming months. KPMG LLP’s Tax professionals with experience in international tax planning, transfer pricing, mergers and acquisitions, and other areas can help you evaluate the potential impact of the 385 Regulations and address compliance challenges. For more information, contact your local KPMG adviser. For more insights about the 385 Regulations, visit www.kpmg.com/us/385regs.