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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. - PowerPoint PPT Presentation
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TEI Regions V & VI IRS Liaison Meeting
Kathy Robbins, Acting NRC Industry Director
May 14, 2012
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Sam Maruca, Director, Transfer Pricing Operations
Sam Maruca, Director, Transfer Pricing Operations
Kathy Robbins, Director, International Business
Compliance(IBC)
Kathy Robbins, Director, International Business
Compliance(IBC)
CommissionerLarge Business &
International
Rosemary Sereti, Director, International Individual
Compliance (IIC)
Rosemary Sereti, Director, International Individual
Compliance (IIC)
Michael Danilack, Deputy Commissioner (International)
Doug O’Donnell, Assistant Deputy Comm’r (Int’l)
Douglas Shulman, IRS Commissioner
Treaty UnitSteve Miller, IRS Deputy
Commissioner for Services & Enforcement
Foreign Posts
Service-wide Strategy
JITSIC
EOI Program
LB&I International FunctionRecently revised structure
DFO, IIC
Director, International Individual Compliance (IIC)
EA
Terr Mgr Territory 1
Terr Mgr Territory 2
Terr Mgr Territory 3
Terr Mgr Territory 5
Nonresident Compliance Initiatives
Campus Compliance Unit
Terr Mgr Territory 4
LMSB InternationalLMSB International
Large Business and International Division Director International Individual Compliance (IIC)
Offshore Compliance Initiatives
Central Withholding Program
Future Territory 6
Tech. Coord. & Training
IRS Commissioner
Dep. Comm. for Services &
Enforcement
CommissionerLarge Business &
International
Deputy Commissioner (International)
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Sam Maruca, Director, Transfer Pricing Operations
Sam Maruca, Director, Transfer Pricing Operations
Deputy Commissioner (International)
Assistant Deputy Comm’r (Int’l)
Deputy Commissioner (International)
Assistant Deputy Comm’r (Int’l)
Treaty Unit
Foreign Posts
Service-wide Strategy
JITSIC
EOI Program
LB&I International FunctionRevised structure
Director, APMA
Deputy Director
Director, APMA
Deputy Director
Combined MAP/APA team
Matt Hartman, East
Tom Ralph, Central
Nancy Bronsen, West
Territory 8John Hinman
Troy MI
Territory 9David Oyler
Downers Grove IL
Territory 10Glen Duncan
Farmers Branch TX
Large Business and International DivisionDirector, International Business Compliance (IBC)
Draft Structure as of 2/6/2012
Director, International Business Compliance
Kathy RobbinsWashington DC
Director, International Business Compliance
Kathy RobbinsWashington DC
EA – OperationsMargie MaxwellWashington DC
EA – TechnicalDonald MurrayColumbus OH
Foreign Payments Program
Stuart MannIselin NJ
TrainingNieves Narvaez
Houston TX
International Practice Networks
Nanette HamiltonSan Jose CA
Territory 11Jackie Topping
Phoenix AZ
Territory 12Vacant
DFO, IBC WestCarol Poindexter
Downers Grove IL
DFO, IBC WestCarol Poindexter
Downers Grove IL
Territory 1Theodore Setzer
New York NY
Territory 2Anna PetinovaNew York NY
Territory 3John Evancho
Edison NJ
Territory 4Orrin ByrdAtlanta GA
Territory 7 (Economists)
Lynn RedmondIndianapolis IN
DFO, IBC EastHoward Martin
Downers Grove IL
DFO, IBC EastHoward Martin
Downers Grove IL
Territory 14 (Economists)Dave Jackson
Farmers Branch TX
Territory 5(Foreign Payments)
Vacant
InboundMartha Regan
Phoenix AZ
InboundMartha Regan
Phoenix AZ
OutboundViolette Walter
Bloomington MN
OutboundViolette Walter
Bloomington MN
Integrated International Program
Training
Networks
Strategy
Data
INTERNATIONAL MATRIX
Metrics
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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
IBC MATRIX
Training
Networks
Strategy
Data
INDIVIDUAL INBOUND
INDIVIDUAL OUTBOUND
BUSINESS INBOUND
BUSINESS OUTBOUND
Income Shifting
Deferral Planning
FTC Management
Repatriation
Metrics
INDIVIDUAL INBOUND
US Business Activities
US Investment Activities
Jurisdiction to Tax
INDIVIDUAL OUTBOUND
Foreign Tax
Credit
Pass-ThruEntities
ForeignCorporations
OffshoreArrange-
Ments
Jurisdictionto Tax
Income Shifting
Inbound Financing
Repatriation/ Withholding
Income Shifting
Deferral Planning
FTC Management
Repatriation
TreatiesTreaties Information Gathering
Information Gathering
Foreign CurrencyForeign Currency
BUSINESS OUTBOUND
Jurisdiction to Tax
BUSINESS INBOUND
Corporate Organizations/Transactions
Corporate Organizations/Transactions
The “Four Faces” of the Matrix
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
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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.
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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.
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
