Modeling a World of Tax

The outcome of OECD international tax framework initiatives may present a new set of tax planning and compliance pressures. The KPMG BEPS 2.0 Model can help you understand, communicate, and evaluate actions considering the BEPS 2.0 initiative, across both Pillar One and Pillar Two proposals.

Our BEPS 2.0 Model:

• Allows users to evaluate the cash tax and effective tax rate impact of Pillar One and Pillar Two proposals for 1 to 10 years
• Allows flexible modeling based on different tax rules, allocation keys, and other parameters of the evolving proposals
• Is scalable for both initial assessments and in-depth modeling.

Complex and evolving previously taxed earnings and profits (PTEP) rules have become the centerpiece of cross-border cash management and attribute-tracking. The KPMG PTEP Analyzer allows users to model distribution scenarios, seamlessly track PTEP, understand the potential tax implications, and facilitate decision-making.

Our PTEP Analyzer drives robust scenario planning and can be used to:

• Run complex distribution ordering rules on PTEP layers and income categories
• Take into account various withholding tax implications
• Determine creditable foreign taxes attributable to PTEP
• Calculate section 986(c) foreign currency exchange gains and losses
• Track creditable PTEP balances.

Section 987 gain/loss calculations and tracking are complicated and time-consuming. The KPMG Section 987 Model helps clients understand the potential impact of gain/loss transactions, supports efficient tax return preparation, and facilitates informed tax planning decisions.

Our Section 987 Model provides:

• Equity and basis pool tracking
• Section 987 gain/(loss) planning
• Calculation methodology flexibility
• Report analysis to determine the tax impact of specific contributions and remittances.