U.S. Tax in Europe

Providing KPMG U.S. tax consulting and compliance services across Europe

Howard Wiener

Howard Wiener

Principal, International Tax, KPMG U.S. Tax Services (London) LLP

+44 (0) 7796 306170
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The New Corporate Alternative Minimum Tax in the United States: Potential Impact on U.K.-headed Groups with U.S. Subsidiaries
On August 16, 2022, President Biden signed H.R. 5376, commonly called the Inflation Reduction Act of 2022, which includes a new corporate alternative minimum tax (Corporate AMT) based on 15 percent of adjusted financial statement income (AFSI) for applicable corporations. As the U.S. subsidiary corporations of U.K.-headed groups that meet the AFSI criteria will be subject to the Corporate AMT, in-scope groups should quickly assess the potential impact of the new tax. Read this summary to learn more.
U.S. Tax Guide: U.S. Expansion Considerations for European Corporations
To help European corporations make decisions on how to expand into the United States, this paper provides an overview of the potentially relevant tax regimes. | December 10, 2021
The U.S. tax landscape is complex, multilayered, challenging to comply with and subject to almost continuous change. How a multinational enterprise navigates this shifting landscape can be one of the more daunting and complex business issues it faces.

Whether you are a multinational, financial institution, fund, or investor with U.S. operations or investments, the U.S. Tax practice in Europe offers real-time access to services that can help tax and finance executives located in Europe address their business's U.S. international tax challenges and help achieve cross-border tax efficiencies, mitigate cross-border tax risks, and meet international tax compliance requirements.

Services

Our services include, but are not limited to, tax advice and guidance in the following areas:

Fund and alternative investments           

  • Tax planning and compliance for hedge funds, private equity funds, real estate funds, and alternative energy funds
  • Structuring and financing portfolio investments and dispositions

Derivatives and complex financial instruments  

  • Structuring and financing complex financial arrangements, including repos, stock loans, forwards, futures, options, and swaps in both inbound and outbound contexts

Merger and acquisitions              

  • Diligence, structuring, and financing cross-border acquisitions, financings, dispositions, and divestures

Inbound investment into the United States        

  • Structuring and financing various types of investments, including equity, debt, property, and derivatives
  • Tax treaty eligibility, interpretation, and analysis
  • FIRPTA issues and requirements

Outbound investment from the United States  

  • International tax planning for CFCs, foreign tax credits, and related transactions
  • Intellectual property transactions and management
  • Supply chain tax management structuring

Tax-exempt investors into the United States     

  • Pension funds, sovereign wealth funds, and other tax-exempt investments

Benefits

Global reach – The U.S. Tax Practice in Europe works with KPMG International's global network of independent member firms.

Technical specialization – Our network includes professionals from the U.S. member firm's Washington National Tax practice, a group comprised of senior-level professionals with noteworthy experience in international tax and the taxation of transactions and financial products.

Cost effectiveness – The U.S. Tax Practice in Europe charges competitive rates commensurate with U.S.-based practitioners and are committed to being responsive to your needs in a cost-efficient manner.