--000000000000d36e6a063e8bbe2b Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable 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 the study similar to what is sent out for the tax returns. If possible can you 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, Monica, and Tim discussed the transfer pricing framework for > services and intangibles provided from the US to Canadian entities, > focusing on cost allocation, royalty mechanisms, and the avoidance of > withholding tax. > - Service and Royalty Fee Structure: Michael Hoffman outlined the > approach of charging Canadian entities for back office and operatio= nal > services on a cost-plus basis, and discussed the potential for addi= tional > royalties for the use of know-how and brand, aiming to avoid withho= lding > tax by structuring payments as service fees or royalties for know-h= ow > rather than franchise fees. > - Benchmarking and Documentation: The team will consider the > franchise agreements that were in place in Canada (that had the 5% > royalty), but we understand the support provided by the