This is a multipart message in MIME format. ------=_NextPart_000_0C0A_01DA220C.D9ED4B10 Content-Type: text/plain; charset="utf-8" Content-Transfer-Encoding: quoted-printable Hi Tim, =20 Are you okay with KPMG billing HCA Canada for tax services completed and = then Accounting allocating the expense to appropriate Canada entities? =20 Thanks! =20 From: Ip, Renee =20 Sent: Tuesday, November 28, 2023 3:07 PM To: nkani@thekey.com Cc: nkani@thekey.com; brian.fialko@thekey.com; = steven.kearley@thekey.com; Sam Naffaa ; = Timothy Thomas ; Williams, Traci ; = michael.jichetti@thekey.com; Tammi Franzese Subject: RE: TheKey Billing Process=20 =20 HI Nina, Brian, =20 We would like to follow up on the below. =20 Thanks! =20 Renee Ip=20 Senior Manager, Indirect Tax KPMG LLP =20 Vaughan Metropolitan Centre 100 New Park Place, Suite 1400 Vaughan, ON L4K 0J3 Tel: 416-228-7027 Fax: 905-265-6390 Reneeip@kpmg.ca =20 =20 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. Qu=C3=A9bec 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 Qu=C3=A9bec final assessment based on the general anti-avoidance = rule from being able to obtain authorization from the Autorit=C3=A9 des = march=C3=A9s 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=E2=80=99s = services do not include represen