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

Video: Part 2 of 2, More key drivers of change

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.


In this Part 2 video, KPMG professionals Bruce Stelzner, Mark Martin, Kees Van Meel, and Tom Zollo continue to discuss U.S. and global tax developments that may have detrimentally affected certain common structures. In this video, the following key developments are examined:

  • BEPS 2.0 Pillar One and Pillar Two*
  • DEMPE (development, enhancement, maintenance, protection, and exploitation) rules
  • CIGA (core income-generating activities) concept.

Common tax structures used by U.S. multinationals that may need reconsideration in light of these developments are also examined.

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 26, 2021.
As BEPS 2.0 Pillar One and Pillar Two developments have continued, this section of this video was
updated on January 14, 2022, to reflect the current landscape. Stay abreast of the latest changes by 
visiting the KPMG Tax Challenges of Digitization webpage.