Tax Attribute Services

Undergoing a transaction or restructuring in the ever-changing tax landscape can be overwhelming. To fully realize the tax benefits of any transaction, sellers and buyers need tax professionals with deep knowledge and real-world experience to provide efficient tax planning and quantitative tax information to implement tax-efficient transactions. 

The KPMG M&A Tax Attribute Services Group assists with complex analyses to ensure each transaction is undertaken as efficiently as possible. The group also performs analyses necessary to support general tax planning and compliance. Because every transaction is unique, our tax professionals use market-leading internal software that we have developed to obtain quantitative tax information for the key-decision makers.

Our tax attribute services include:

Change-of-control studies and tax attribute limitation analyses

• Determine whether an ownership change under section 382 has occurred, and if it has, we determine the consequences of that change with respect to the company’s ability to use its tax attributes in the future.

Stock basis studies and transaction planning

• Determine the gain or loss from the sale of a subsidiary out of a consolidated group, determine deferred intercompany gain or loss from a sale within a consolidated group, and evaluate tax planning in connection with transactions such as leveraged distributions or tax-free spin-offs.
• We help to determine the gain or loss upon the sale of a subsidiary out of a consolidated group, to compute the amount of a worthless stock deduction with respect to a consolidated group subsidiary, to calculate the reduction in tax attributes following certain cancellation of debt events, to monitor potential income triggering due to so-called excess loss accounts (negative stock basis), and other tax planning in connection with transactions.  

Earnings and profits analysis and shareholder value

• Assist in evaluation of the tax character (capital gain, return of basis, dividend) of distributions made to shareholders and the corresponding tax reporting requirements. 

Transaction Cost Analysis

• Provide guidance regarding the tax treatment of various types of costs incurred with certain transactions and assist in compiling documentation within a specified time to evidence the deductibility of transaction costs. 

Various other transactional planning and computations

Do you want to deal with every quantitative detail required to successfully complete a transaction—or do you want to move on to the next transaction? The Attribute Services Group within the KPMG M&A Tax practice can help position you for success by helping plan efficiently as well as monetize and track tax attributes.