HI Nina,
Unfortunately, no. The billing team has reverted back that since these are Canadian entities we are servicing, we need to bill the Canadian entity directly.
Regards,
Renee Ip
Senior Manager, Indirect Tax
KPMG LLP
Vaughan Metropolitan Centre
100 New Park Place, Suite 1400
Vaughan, ON L4K 0J3
Tel: 416-228-7027
Fax: 905-265-6390
Reneeip@kpmg.ca<mailto:Reneeip@kpmg.ca>
Any advice herein is based on the facts provided to us and on current tax law including judicial and administrative interpretation. Tax law is subject to continual change, at times on a retroactive basis and may result in incremental taxes, interest or penalties. Should the facts provided to us be incorrect or incomplete or should the law or its interpretation change, our advice may be inappropriate. We are not responsible for updating our advice for changes in law or interpretation after the date hereof.
Québec announced through its November 10, 2017 economic plan that it intends to introduce legislation that will prohibit a taxpayer who has carried out a transaction, or series of transactions, subject to a Revenu Québec final assessment based on the general anti-avoidance rule from being able to obtain authorization from the Autorité des marchés financiers (AMF) to bid for or obtain public contracts. The taxpayer will be listed in the Register of Enterprises Ineligible for Public Contracts.
Our advice is limited to the conclusions specifically set forth herein and KPMG expresses no opinion with respect to any other federal, provincial or foreign tax or legal aspect of the transactions described herein. It should be noted that the Canada Revenue Agency and/or the relevant provincial tax authority and/or a foreign tax authority and/or any other governmental tax authority (collectively a Tax or Revenue Authority) could take a different position with respect to these transactions in which case it may be necessary for you to defend this position on appeal from an assessment or litigate the dispute before the courts, including one or more appellate courts, in order for our conclusions to prevail. If a settlement were reached with a Tax or Revenue Authority or if such appeal and litigation were not, or were not entirely, successful, the result would likely be different from the views we express herein. Unless expressly provided for, KPMG’s services do not include representing Client in the event of a challenge by a Tax or Revenue Authority or litigation before any court.
KPMG's advice is for the sole use of KPMG's client. The advice is based on the specific facts and circumstances and the scope of KPMG’s engagement and is not intended to be relied upon by any other person. KPMG disclaims any responsibility or liability for any reliance that any person other than the client may place on this advice.
From: Nina Kani <nkani@thekey.com>
Sent: Wednesday, November 22, 2023 1:04 PM
To: Ip, Renee <reneeip@kpmg.ca>
Cc: nkani@thekey.com; brian.fialko@thekey.com; steven.kearley@thekey.com; Sam Naffaa <hcao.accounting@thekey.com>; Timothy Thomas <tt@thekey.com>; Williams, Traci <traciwilliams@kpmg.ca>; michael.jichetti@thekey.com; Tammi Franzese <tammi.franzese@thekey.com>
Subject: Re: TheKey Billing Process [EXTERNAL]
Can’t you bill us as the parent?
On Nov 22, 2023, at 9:39 AM, Ip, Renee <reneeip@kpmg.ca<mailto:reneeip@kpmg.ca>> wrote:
Hi Nani,
We are looking for the billing address for us to issue the bill.
Thanks!
Renee Ip
Senior Manager, Indirect Tax
KPMG LLP
Vaughan Metropolitan Centre
100 New Park Place, Suite 1400
Vaughan, ON L4K 0J3
Tel: 416-228-7027
Fax: 905-265-6390
Reneeip@kpmg.ca<mailto:Reneeip@kpmg.ca>
Any advice herein is based on the facts provided to us and on current tax law including judicial and administrative interpretation. Tax law is subject to continual change, at times on a retroactive basis and may result in incremental taxes, interest or penalties. Should the facts provided to us be incorrect or incomplete or should the law or its interpretation change, our advice may be inappropriate. We are not responsible for updating our advice for changes in law or interpretation after the date hereof.
Québec announced through its November 10, 2017 economic plan that it intends to introduce legislation that will prohibit a taxpayer who has carried out a transaction, or series of transactions, subject to a Revenu Québec final assessment based on the general anti-avoidance rule from being able to obtain authorization from the Autorité des marchés financiers (AMF) to bid for or obtain public contracts. The taxpayer will be listed in the Register of Enterprises Ineligible for Public Contracts.
Our advice is limited to the conclusions specifically set forth herein and KPMG expresses no opinion with respect to any other federal, provincial or foreign tax or legal aspect of the transactions described herein. It should be noted that the Canada Revenue Agency and/or the relevant provincial tax authority and/or a foreign tax authority and/or any other governmental tax authority (collectively a Tax or Revenue Authority) could take a different position with respect to these transactions in which case it may be necessary for you to defend this position on appeal from an assessment or litigate the dispute before the courts, including one or more appellate courts, in order for our conclusions to prevail. If a settlement were reached with a Tax or Revenue Authority or if such appeal and litigation were not, or were not entirely, successful, the result would likely be different from the views we express herein. Unless expressly provided for, KPMG’s services do not include representing Client in the event of a challenge by a Tax or Revenue Authority or litigation before any court.
KPMG's advice is for the sole use of KPMG's client. The advice is based on the specific facts and circumstances and the scope of KPMG’s engagement and is not intended to be relied upon by any other person. KPMG disclaims any responsibility or liability for any reliance that any person other than the client may place on this advice.
From: Nina Kani <nkani@thekey.com<mailto:nkani@thekey.com>>
Sent: Wednesday, November 22, 2023 12:31 PM
To: brian.fialko@thekey.com<mailto:brian.fialko@thekey.com>
Cc: Ip, Renee <reneeip@kpmg.ca<mailto:reneeip@kpmg.ca>>; nkani@thekey.com<mailto:nkani@thekey.com>; steven.kearley@thekey.com<mailto:steven.kearley@thekey.com>; Sam Naffaa <hcao.accounting@thekey.com<mailto:hcao.accounting@thekey.com>>; Timothy Thomas <tt@thekey.com<mailto:tt@thekey.com>>; Williams, Traci <traciwilliams@kpmg.ca<mailto:traciwilliams@kpmg.ca>>; michael.jichetti@thekey.com<mailto:michael.jichetti@thekey.com>; Tammi Franzese <tammi.franzese@thekey.com<mailto:tammi.franzese@thekey.com>>
Subject: Re: TheKey Billing Process [EXTERNAL]
Are you looking for physical address or address for service of process?
On Nov 22, 2023, at 8:42 AM, brian.fialko@thekey.com<mailto:brian.fialko@thekey.com> wrote:
Hi Renee,
I am adding Nina to the email. Nina, when you have a chance can you please provide the addresses for the entities below. Thank you!
<image001.png>
From: Ip, Renee <reneeip@kpmg.ca<mailto:reneeip@kpmg.ca>>
Sent: Wednesday, November 22, 2023 11:34 AM
To: brian.fialko@thekey.com<mailto:brian.fialko@thekey.com>
Cc: steven.kearley@thekey.com<mailto:steven.kearley@thekey.com>; 'Sam Naffaa' <hcao.accounting@thekey.com<mailto:hcao.accounting@thekey.com>>; 'Timothy Thomas' <tt@thekey.com<mailto:tt@thekey.com>>; Williams, Traci <traciwilliams@kpmg.ca<mailto:traciwilliams@kpmg.ca>>
Subject: RE: TheKey Billing Process
HI Brian,
We just wanted to follow up on the below if you can let us know at your earliest convenience.
Regards,
Renee Ip
Senior Manager, Indirect Tax
KPMG LLP
Vaughan Metropolitan Centre
100 New Park Place, Suite 1400
Vaughan, ON L4K 0J3
Tel: 416-228-7027
Fax: 905-265-6390
Reneeip@kpmg.ca<mailto:Reneeip@kpmg.ca>
Any advice herein is based on the facts provided to us and on current tax law including judicial and administrative interpretation. Tax law is subject to continual change, at times on a retroactive basis and may result in incremental taxes, interest or penalties. Should the facts provided to us be incorrect or incomplete or should the law or its interpretation change, our advice may be inappropriate. We are not responsible for updating our advice for changes in law or interpretation after the date hereof.
Québec announced through its November 10, 2017 economic plan that it intends to introduce legislation that will prohibit a taxpayer who has carried out a transaction, or series of transactions, subject to a Revenu Québec final assessment based on the general anti-avoidance rule from being able to obtain authorization from the Autorité des marchés financiers (AMF) to bid for or obtain public contracts. The taxpayer will be listed in the Register of Enterprises Ineligible for Public Contracts.
Our advice is limited to the conclusions specifically set forth herein and KPMG expresses no opinion with respect to any other federal, provincial or foreign tax or legal aspect of the transactions described herein. It should be noted that the Canada Revenue Agency and/or the relevant provincial tax authority and/or a foreign tax authority and/or any other governmental tax authority (collectively a Tax or Revenue Authority) could take a different position with respect to these transactions in which case it may be necessary for you to defend this position on appeal from an assessment or litigate the dispute before the courts, including one or more appellate courts, in order for our conclusions to prevail. If a settlement were reached with a Tax or Revenue Authority or if such appeal and litigation were not, or were not entirely, successful, the result would likely be different from the views we express herein. Unless expressly provided for, KPM