Kyle Phillips
Managing Director, Tax - International Tax
Background
Kyle is a Managing Director in the San Francisco office of the International Tax practice of KPMG. He advises alternative investment funds and multinational organizations on a wide range of international inbound and outbound transactions, including acquisition and disposition strategies, repatriation planning, choice of entity and tax-efficient holding structures.
Prior to rejoining KPMG in 2016, Kyle was an associate in the Menlo Park office of Shearman & Sterling LLP. Kyle began his career in the Real Estate and International Tax practice in KPMG’s New York office.
Professional and Industry Experience
Kyle has assisted alternative investment funds and multinational organizations in the following areas of domestic and international tax:
- The impact of the Foreign Investment in Real Property Tax Act (FIRPTA) on fund structures including acquisition and disposition strategies;
- Structuring investments into real estate investment trusts (REITs);
- Section 892 exemption for sovereign wealth fund investors;
- U.S. trade or business determinations;
- U.S. income tax treaty planning;
- Tax-free reorganizations;
- Identifying the impact and requirements of withholding tax under Chapter 3 and Chapter 4 (FATCA);
- Subpart F and passive foreign investment corporation (PFIC) planning;
- U.S. “check-the-box” regulations; and
- Inversion transactions.