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This recorded webinar will discuss the classic tools necessary to repatriate cash from a foreign-owned U.S. company while providing some new techniques, updates and regulatory guidance.
Kevin Cunningham from KPMG LLP Washington National Tax Office will discuss:
- Covered asset acquisition/foreign tax credit splitter rules
- Offshore acquisitions: Debt versus equity financing
- Repatriation examples
- Loans to US parent
- Loans to US parent indirectly through partnerships
- Upstream loans/leveraged distributions
Prerequisite: Knowledge of international taxation
Recommended CPE Credit(s): There are no CPE Credits for Self-Study at this time
Kevin Cunningham is a managing director in the International Tax group of KPMG’s Washington National Tax office. Kevin practices in all areas of international taxation with an emphasis on U.S. multinational tax planning. He also has represented clients in audits and appeals before the Internal Revenue Service. Some of Kevin’s recent engagements include the following: Prepared detailed recommendations to restructure the operations of a number of large businesses including (1) an offshore drilling contractor and (2) a manufacturing company. After the recommendations were accepted by upper management, Kevin had a leading role in implementing the plans. In that capacity, Kevin advised these companies and their attorneys in connection with a variety of legal implementation issues. As part of the restructurings, Kevin consulted with the companies on issues such as (i) tax-efficient financing, (ii) choice of holding company jurisdiction, (iii) local thin-cap and distributable reserve planning, (iv) the impact of U.S. international tax reform on the companies, and (v) U.S. foreign tax credit planning. Kevin has written a number of articles and spoken on a variety of international tax subjects. He has authored articles in Tax Notes International on cross-border financing transactions, the worthless stock deduction, and the worldwide interest expense apportionment election. Before joining KPMG, Kevin was with a leading international tax law firm. Kevin also received an award for achieving the second-highest score on the District of Columbia Certified Public Accounting Exam. Kevin earned his LL.M in taxation, with distinction from Georgetown University; his JD from University of Virginia; and his BS in accounting, magna cum laude, from Georgetown University.