RE: TheKey Canadian Entity T2s

From
Geraldine Nath <geraldine.nath@thekey.com>
To
"Woolley, Jessica A" <jwoolley@kpmg.ca>, Brian Fialko <brian.fialko@thekey.com>, Steven Kearley <steven.kearley@thekey.com>
CC
"Towns Lewis, Ashley" <atowns@kpmg.ca>, "Rubinstein, Brian" <brubinstein@kpmg.ca>, Timothy Thomas <tt@thekey.com>, Geraldine Nath <geraldine.nath@thekey.com>
Date
Wed, 28 Jun 2023 18:50:33 -0500
Folder
INBOX
--000000000000e8e13705ff393fe7 Content-Type: multipart/alternative; boundary="000000000000e8e13705ff393fe5" --000000000000e8e13705ff393fe5 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable All: I have reviewed and have the questions noted on the attached file. I think we need to meet tomorrow because I think the problem is likely that the costs were not allocated from the parent down to the subsidiaries in Canada. If we allocate it will change all the returns. Can we meet at 9AM central time tomorrow =E2=80=93 Tim as optional? *gerri nath* Chief Accounting Officer, The Key Mobile: 561-879-0132 [image: TheKey] *From:* Woolley, Jessica A *Sent:* Tuesday, June 27, 2023 9:45 PM *To:* geraldine.nath@thekey.com; brian.fialko@thekey.com; steven.kearley@thekey.com; Timothy Thomas *Cc:* Towns Lewis, Ashley ; Rubinstein, Brian *Subject:* TheKey Canadian Entity T2s Hi everyone, Please see attached for the various TheKey entity T2 tax returns. I have also attached a document called *Documents to Sign* for each entity. Once you have reviewed the returns and are comfortable with the information presented, please sign the documents within each of these files. Once we receive them back, we will submit the returns for efiling. If it=E2=80=99s = at all possible to get signatures back by Thursday that would be great, as there is often a long line of returns waiting to be filed on the deadline which I would like to keep us out of. Please note that the tax payable figures outlined within the returns may be smaller than indicated, given that we don=E2=80=99t have a full understandi= ng of the instalments made in the year. And once again, it was a pleasure working with you and we really appreciate all your efforts trying to get info in the midst of learning curves, new systems, and not being able to access all of the data required. We look forward to assisting you in the future in addressing risks and opportunities as you build out the Canadian business and begin to put strategy around data, the treasury function, etc. As requested, and for your files, here is a summary of some of the key areas for which we couldn=E2=80=99t quite get perfect information on. As we= have discussed, if you are able to get any additional information that suggests what we have filed is incorrect, we are happy to revisit these and file amendments in the summer. - It looks like push-down accounting has been used to account for acquisitions, whereby HCA is buying the shares of the subsidiaries, and then the cost of those shares is being pushed down to the individual ass= ets held by the subsidiaries with a corresponding offset credit to =E2=80=98= interco due to=E2=80=99. As such, it is our understanding that the intangible asset = additions in the two Arya entities are not true additions for Canadian tax purpose= s, and so we have not presented them on Sch 8. Going forward, and now that = you have Canada on the group=E2=80=99s ERP we recommend implementing 

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