TEI Regions V & VI
IRS Liaison Meeting
Kathy Robbins,
Acting NRC Industry Director
May 14, 2012
1
LB&I International Function
Recently revised structure
Douglas Shulman, IRS
Commissioner
Steve Miller, IRS Deputy
Commissioner for
Services & Enforcement
Commissioner
Large Business &
International
Treaty Unit
Michael Danilack, Deputy
Commissioner
(International)
Doug O’Donnell, Assistant
Deputy Comm’r (Int’l)
Sam Maruca, Director, Transfer
Pricing Operations
2
EOI Program
Kathy Robbins, Director,
International Business
Compliance
(IBC)
JITSIC
Foreign Posts
Service-wide
Strategy
Rosemary Sereti, Director,
International Individual
Compliance (IIC)
LMSB International
Large Business and International Division
Director International Individual Compliance (IIC)
Commissioner
Large Business &
International
IRS Commissioner
Dep. Comm. for
Services &
Enforcement
EA
Deputy
Commissioner
(International)
Director, International
Individual Compliance (IIC)
Tech. Coord. & Training
DFO,
IIC
Campus
Compliance Unit
Terr Mgr Territory 1
Terr Mgr Territory 2
Terr Mgr Territory 3
Terr Mgr Territory 4
Terr Mgr Territory 5
Future Territory 6
Offshore Compliance
Initiatives
Nonresident
Compliance Initiatives
Central Withholding
Program
LB&I International Function
Revised structure
EOI Program
Treaty Unit
Deputy Commissioner
(International)
JITSIC
Foreign Posts
Assistant Deputy
Comm’r (Int’l)
Service-wide
Strategy
Sam Maruca,
Director, Transfer
Pricing Operations
Director, APMA
Deputy Director
Combined MAP/APA team
4
Matt Hartman,
East
Tom Ralph,
Central
Nancy Bronsen,
West
Large Business and International Division
Director, International Business Compliance (IBC)
Draft Structure as of 2/6/2012
EA – Operations
Margie Maxwell
Washington DC
International Practice
Networks
Nanette Hamilton
San Jose CA
Inbound
Martha Regan
Phoenix AZ
Outbound
Violette Walter
Bloomington MN
DFO, IBC East
Howard Martin
Downers Grove IL
Territory 1
Theodore Setzer
New York NY
Territory 2
Anna Petinova
New York NY
Territory 3
John Evancho
Edison NJ
Director, International
Business Compliance
Kathy Robbins
Washington DC
DFO, IBC West
Carol Poindexter
Downers Grove IL
Territory 8
John Hinman
Troy MI
Territory 9
David Oyler
Downers Grove IL
Territory 10
Glen Duncan
Farmers Branch TX
Territory 4
Orrin Byrd
Atlanta GA
Territory 11
Jackie Topping
Phoenix AZ
Territory 5
(Foreign Payments)
Vacant
Territory 12
Vacant
Territory 7
(Economists)
Lynn Redmond
Indianapolis IN
Territory 14
(Economists)
Dave Jackson
Farmers Branch TX
EA – Technical
Donald Murray
Columbus OH
Foreign Payments
Program
Stuart Mann
Iselin NJ
Training
Nieves Narvaez
Houston TX
Integrated International Program
Strategy
Metrics
Networks
Training
Data
INTERNATIONAL MATRIX
The International Matrix
Strategy
Metrics
Networks
Training
Income
Shifting
Data
IBC MATRIX
FTC
Deferral
Planning
Management
Repatriation
BUSINESS OUTBOUND
BUSINESS INBOUND
INDIVIDUAL OUTBOUND
INDIVIDUAL INBOUND
7
The suite of core
technical areas that
serve as the foundation
by which our strategy,
training, networks, and
data management are
developed and utilized
The “Four Faces” of the Matrix
Income
Shifting
Deferral
Planning
FTC
Management
Repatriation
BUSINESS OUTBOUND
Jurisdiction
to Tax
Income
Shifting
Inbound
Financing
Repatriation/
Withholding
BUSINESS INBOUND
Jurisdiction
to Tax
Offshore
ArrangeMents
Foreign
Tax
Credit
Pass-Thru
Entities
Foreign
Corporations
INDIVIDUAL OUTBOUND
Jurisdiction
to Tax
US Business
Activities
US Investment
Activities
INDIVIDUAL INBOUND
Treaties
Information
Gathering
Foreign
Currency
Corporate
Organizations/
Transactions
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:
Three of the areas IBC is currently focusing:
• Forms 1120F
• Joint Audits
• Withholding and FATCA
Forms 1120F
• Three categories of Forms 1120F we are
addressing
– Filed Forms 1120F
– Protective Forms 1120F
– Non Filers
Forms 1120F
• Have created 1120F Task Team to look at
all areas and develop strategies.
Protective 1120Fs
• Ability to claim deductions
• Statute date
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 – 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
• 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 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
• 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
• 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