Tei regions v vi irs liaison meeting
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TEI Regions V & VI IRS Liaison Meeting. Kathy Robbins, Acting NRC Industry Director May 14, 2012. LB&I International Function Recently revised structure. Douglas Shulman, IRS Commissioner. Commissioner Large Business & International.

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TEI Regions V & VI IRS Liaison Meeting

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Tei regions v vi irs liaison meeting

TEI Regions V & VI IRS Liaison Meeting

Kathy Robbins,

Acting NRC Industry Director

May 14, 2012


Tei regions v vi irs liaison meeting

LB&I International Function

Recently revised structure

Douglas Shulman, IRS Commissioner

Commissioner

Large Business &

International

Steve Miller, IRS Deputy Commissioner for Services & Enforcement

EOI Program

Treaty Unit

JITSIC

Michael Danilack, Deputy Commissioner (International)

Doug O’Donnell, Assistant Deputy Comm’r (Int’l)

Foreign Posts

Service-wide

Strategy

Sam Maruca, Director, Transfer Pricing Operations

Kathy Robbins, Director, International Business Compliance

(IBC)

Rosemary Sereti, Director, International Individual Compliance (IIC)


Tei regions v vi irs liaison meeting

LMSB International

Large Business and International Division

Director International Individual Compliance (IIC)

IRS Commissioner

Commissioner

Large Business &

International

Dep. Comm. for Services & Enforcement

Deputy Commissioner (International)

Director, International Individual Compliance (IIC)

EA

Tech. Coord. & Training

Campus Compliance Unit

Nonresident Compliance Initiatives

Offshore Compliance

Initiatives

Central Withholding Program

DFO, IIC

Terr Mgr Territory 1

Terr Mgr Territory 2

Terr Mgr Territory 3

Terr Mgr Territory 4

Terr Mgr Territory 5

Future Territory 6


Tei regions v vi irs liaison meeting

LB&I International Function

Revised structure

EOI Program

Treaty Unit

JITSIC

Deputy Commissioner (International)

Assistant Deputy Comm’r (Int’l)

Foreign Posts

Service-wide

Strategy

Sam Maruca,

Director, Transfer Pricing Operations

Nancy Bronsen, West

Director, APMA

Deputy Director

Tom Ralph, Central

Matt Hartman, East

Combined MAP/APA team

4


Tei regions v vi irs liaison meeting

Large Business and International Division

Director, International Business Compliance (IBC)

Draft Structure as of 2/6/2012

Director, International Business Compliance

Kathy Robbins

Washington DC

EA – Operations

Margie Maxwell

Washington DC

EA – Technical

Donald Murray

Columbus OH

DFO, IBC East

Howard Martin

Downers Grove IL

DFO, IBC West

Carol Poindexter

Downers Grove IL

Foreign Payments Program

Stuart Mann

Iselin NJ

Training

Nieves Narvaez

Houston TX

International Practice Networks

Nanette Hamilton

San Jose CA

Territory 1

Theodore Setzer

New York NY

Territory 8

John Hinman

Troy MI

Inbound

Martha Regan

Phoenix AZ

Territory 9

David Oyler

Downers Grove IL

Territory 2

Anna Petinova

New York NY

Outbound

Violette Walter

Bloomington MN

Territory 10

Glen Duncan

Farmers Branch TX

Territory 3

John Evancho

Edison NJ

Territory 11

Jackie Topping

Phoenix AZ

Territory 4

Orrin Byrd

Atlanta GA

Territory 5

(Foreign Payments)

Vacant

Territory 12

Vacant

Territory 7 (Economists)

Lynn Redmond

Indianapolis IN

Territory 14 (Economists)

Dave Jackson

Farmers Branch TX


Integrated international program

Integrated International Program

Strategy

Metrics

Training

Networks

Data

INTERNATIONAL MATRIX


The international matrix

The International Matrix

The suite of core technical areas that serve as the foundation by which our strategy, training, networks, and data management are developed and utilized


Tei regions v vi irs liaison meeting

Information

Gathering

Foreign

Currency

Treaties

The “Four Faces” of the Matrix

Income Shifting

Deferral Planning

FTC Management

Repatriation

BUSINESS OUTBOUND

Income Shifting

Repatriation/ Withholding

Jurisdiction to Tax

Inbound Financing

BUSINESS INBOUND

Jurisdiction

to Tax

Offshore

Arrange-

Ments

Foreign

Tax

Credit

Pass-Thru

Entities

Foreign

Corporations

INDIVIDUAL OUTBOUND

Jurisdiction to Tax

US Business

Activities

US Investment Activities

INDIVIDUAL INBOUND

Corporate Organizations/

Transactions


Ibc focus for 2012

IBC Focus for 2012

  • International Practice Networks

  • Training

    • Phase Training

    • Monthly Centras – Continued CPE

  • Hiring

    • IBC has internal authorization to move 200 domestic agents to International

    • International has external authority to hire 100


Program areas of focus

Program Areas of Focus:

Three of the areas IBC is currently focusing:

  • Forms 1120F

  • Joint Audits

  • Withholding and FATCA


Forms 1120f

Forms 1120F

  • Three categories of Forms 1120F we are addressing

    • Filed Forms 1120F

    • Protective Forms 1120F

    • Non Filers


Forms 1120f1

Forms 1120F

  • Have created 1120F Task Team to look at all areas and develop strategies.


Protective 1120fs

Protective 1120Fs

  • Ability to claim deductions

  • Statute date


Joint audit definition

Joint Audit – Definition

Joint Audit is where:

Two or more countries

Join together to form a single team to

Examine issue(s) or transaction(s)

Of one or more related taxable persons

With cross-border business activities.

14


Joint audit definition1

Joint Audit – Definition

Taxpayer jointly makes presentations and shares information with the countries

The joint audit team will include Competent Authority representatives, joint audit team leaders and examiners from each country.

15


Joint audit process

Joint Audit Process

  • Benefit taxpayers by reducing time and cost to address multiple audits with common factual issues

  • Fully coordinated audit from start to finish for all compliance activities

  • Allows for acceleration of the Mutual Agreement procedure by early involvement of the Competent Authority where double taxation involved.


Joint audit process1

Joint Audit Process

  • Important to keep open channels of communication with the taxpayer throughout the joint audit process.

  • Cooperation of taxpayer and their advisors will be a key factor in securing a satisfactory outcome.

  • Best if examination years/cycles and processes of countries are the same.


Joint audit benefits

Joint Audit Benefits

  • Development of enhanced relationships between revenue bodies and taxpayers

  • Providing certainty for taxpayers

  • Reduction in compliance costs for taxpayer

  • More effective management of tax issues in real time


Withholding and fatca

Withholding and FATCA

  • Creation of new Territory to address Chapter 3 Withholding

  • Currently have QI and USWA groups in New York

  • Territory to also be first responders to issues relating to FATCA


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