Retrofitting Cross-Border Structures for U.S. and Global Tax Reform

Video: Part 1 of 2, Overview of key drivers

Bruce Stelzner

Bruce Stelzner

Partner, International Tax, KPMG US

+1 858-750-7248

Kees van Meel

Kees van Meel

Seconded Partner, Head of Netherlands Tax Center , KPMG US


Thomas Zollo

Thomas Zollo

Principal, International Tax, Washington National Tax, KPMG US

+1 312-665-8387

Historically, many multinational groups implemented common cross-border structures to manage their global effective tax rate and cash tax liability. As a result of U.S. and global tax reforms, many of these structures are no longer tax efficient.


This part 1 video discussion highlights several U.S. and global tax reform developments that may have detrimentally affected certain common structures. Hear from KPMG professionals Bruce Stelzner, Tom Zollo, and Kees Van Meel with the firm's International Tax practice to refresh your understanding of how the following developments affected tax structuring for U.S. multinationals:

  • U.S. tax reform under the 2017 Tax Cuts and Jobs Act
  • EU tax reform in the European Union, specifically ATAD 1 and ATAD2
  • The OECD’s multilateral treaty instrument.

Stay tuned for additional discussions that highlight considerations companies should bear in mind when replacing or retrofitting structures that are now vulnerable due to recent (and possible future) tax legislative changes.


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This video has been edited from a KPMG presentation that was made on February 10, 2021.