Session 6 - Sam Maruca TEI IRS Houston

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Transfer Pricing Operations
TEI-LB&I Liaison Meeting
May 14, 2012
1
LB&I International Function
Overview
Commissioner
Large Business &
International
EOI Program
Treaty Unit
Michael Danilack, Deputy
Commissioner
(International)
Doug O’Donnell, Assistant
Deputy Comm’r (Int’l)
Sam Maruca, Director, Transfer
Pricing Operations
2
Carol Poindexter, Acting
Director, International
Business Compliance
(IBC)
JITSIC
Foreign Posts
Service-wide
Strategy
Rosemary Sereti, Director,
International Individual
Compliance (IIC)
2
LB&I International Function
Transfer Pricing Operations
Deputy
Commissioner
International
Senior Tax Advisor
Senior Econ Advisor
Director, Transfer
Pricing Operations
EA Operations
Special Project Deps.
EA Technical
Director
APMA
Deputies
12 Mgrs.
3
IPN Manager
Transfer Pricing Practice
TTM
West
TTM
Central
TTM
East
2 Mgrs.
2 Mgrs.
2 Mgrs.
TPO – A Single Practice
• TPO will operate as a single, unified practice
• Two program segments:
– Advance Pricing and Mutual Agreement (APMA)
– Transfer Pricing Practice (TPP)
• APMA - external focus; TPP - internal focus
– But nearly complete substantive overlap
• One knowledge base
– Income shifting IPNs
– Sharing information, experience and skills
4
TPO – A Single Practice
• Why a single practice?
– Necessity of global perspective in treaty cases
– Ensure cases steered to proper forum
– Demand for two-way, end-to-end visibility
– Need to share experience/expertise to ensure optimal
case selection and development
– Common understanding of MNE behaviors and
planning strategies - CONTEXT
– Common skills, common training
5
TPO – A Single Practice
• Steps to achieving an efficient, integrated practice that
produces quality positions
– Recruit the best
– Ensure that managers are experts, equipped to
provide substantive review and mentoring
– Provide training in case development and negotiation,
especially oral/written presentation
– Communication and collaboration through IPNs and
in day-to-day work
6
TPO – A Single Practice
• Steps to achieving an efficient, integrated practice that
produces quality positions (cont’d)
– Build knowledge base, including searchable skills
inventories and case databases (KTK basis)
– Joint meetings and training sessions
– Coordination with LB&I units, especially IBC, IIC and
Field Specialists
– Coordination with TAIT
7
APMA – Special Considerations
• APMA’s immediate focus is external (resolving issues
with treaty partners) but must be informed by
understanding of broader context
– Inbound/outbound
– Taxpayer’s overall tax position and planning
objectives
– Collateral proceedings (such as domestic audits)
– Sourcing issues and their significance
– Where is matter best resolved?
• So APMA practitioner needs broad perspective
8
APMA – Special Considerations
• Skill-building
– Legacy APA personnel have strong case development
skills; legacy CA personnel have strong negotiation
skills
– Individuals have specific industry/taxpayer experience
– We need to leverage off one another’s strengths
• Heightened importance of presentation
– Arbitration
9
TPP – Special Considerations
• On-going activities
– Pilot cases
– Pre-2009 cost share buy-in triage project
– Build-out
• Re-engineering risk assessment/audit process
– Coordination with PAIR
– Assessment of UTP filings
– “Roadmap” – building on QEP
– Dialogue with Appeals
– Coordination with APMA
10
TPO – The Way Forward
• Earlier and more proactive participation by APMA in field
audits of treaty cases
• Concentration by TPP on tax haven activity and
recalcitrant taxpayers
• Closer collaboration with IBC and field operation in
general
• Creative solutions – “expanded” APAs, joint audits,
multilateral collaboration among jurisdictions, increased
dialogue among CAs
11
TPO – The Way Forward
• Substantive areas of strategic importance - TPP
– Continued attention to outbound IP migration – new
cost-sharing regulations
– High-value services
– Middle market MNEs
– Financial sector
– Inbound activity
• Commitment to enhancing transfer pricing administration
globally
– FTA Guidelines
12
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