--000000000000176a5c063ec707f5 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Thank you *Michael Jichetti* Head of Tax Email: Michael.Jichetti@thekey.com [image: TheKey] On Sat, Sep 13, 2025 at 8:19=E2=80=AFPM Hoffman, Michael D wrote: > Hi Michael, > > > > We will coordinate with KPMG-US and prepare a PBC list this week with > suggested timing. > > > > Michael > > > > > > *From:* Michael Jichetti > *Sent:* Thursday, September 11, 2025 1:43 PM > *To:* Johanson, Austin > *Cc:* Rubinstein, Brian ; Hoffman, Michael D mdhoffman@kpmg.ca>; natalie.cahoone@thekey.com; Alyssa Robles alyssa.robles@thekey.com>; kartik.sheth@thekey.com; > geraldine.nath@thekey.com; Hayes, Monica S ; > sara.stuhlsatz@thekey.com; eve.malishevski@thekey.com; Timothy Thomas tt@thekey.com> > *Subject:* Re: TheKey-KPMG Canadian TP discussion [EXTERNAL] > > > > Hi > > > > Hope all is well. Thank you for the recap. I was wondering if it would be > possible to send out a PBC list for exactly what is needed in regard to t= he > study similar to what is sent out for the tax returns. If possible can yo= u > include dates so we can track on our end as well. Appreciate your help. > Thank you > > > > On Mon, Sep 8, 2025 at 6:40=E2=80=AFPM Johanson, Austin wrote: > > Hi Everyone, please see below for a recap of last week's meeting. > > > TheKey-KPMG Canadian TP discussion - Recap > > Meeting notes: > > - *Franchise Arrangements and Operations in Canada: *Michele, Tim, > Monica, Michael Hoffman, and Brian discussed the structure and operati= ons > of franchise arrangements in Canada, clarifying the distinction betwee= n > traditional franchisees and company-owned entities, and the support > provided to each. > > > - *Current Franchise Structure: *Michele explained that there are > currently two franchisees in Canada, located in Alberta and Ontario= , > operating under traditional franchise agreements with regular busin= ess > coaching, use of the brand, and payment of a 5% royalty on revenue. > - *Support and Training for Franchisees: *Michele detailed the > extensive training and ongoing business coaching provided to franch= isees, > including operational manuals, marketing guidance, and advice on re= cruiting > and client management, but clarified that no medical or clinical tr= aining > is provided. > - *Transition from Franchise to Company-Owned: *The group clarified > that when a franchise is acquired, the franchise agreement is termi= nated, > and the entity becomes company-owned under Tim's management, with s= upport > shifting from franchise-focused to broader corporate initiatives. > - *Legal Entity Distinctions: *Monica emphasized the importance of > distinguishing between HCA Franchise US and The Key Holdings for tr= ansfer > pricing and intellectual property purposes, noting that all intangi= bles are > held by The Key Holdings and not the franchise entity. > > > - *Transfer Pricing and Intercompany Arrangements: *Michael Hoffman, > Brian,