22nd Annual High Technology Tax Institute

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22nd Annual High TechnologyTax Institute

• IRS
• Practice and Procedures

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IRS Practice Procedures

• LMSB Organization
• LMSB Culture and Philosophy
• LMSB Significant Issues
• LMSB Initiatives
• Effect of e-filing

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LMSB Organized By Industry
Deborah Nolan - Commissioner Bruce Ungar
Deputy Commissioner Frank Ng - Deputy
Commissioner International
LMSB Commissioner Deputy Commissioners
LMSB Division Counsel
International (U.S. Competent Authority)
Division Information Officer
Frank Ng , Director
Equal Employment Opportunity Diversity
William Williams, Acting Director
Heavy Manufacturing Transportation
Financial Services
Retailers, Food, Pharmaceuticals, Healthcare
Natural Resources Construction
Field Specialists
Communications, Technology, Media
Field
Director
Walter Harris
Barry Shott
Patricia Chaback
Henry Singleton
John Risacher
Keith Jones
Strategy, Research Program Planning
Management Finance
Communications Liaison
Headquarters
Pre-filing Technical Guidance
Performance, Quality Assurance, Audit Assistance
Business Systems Planning
Director
Paul DeNard
Don McPartland
Helen Bolton
Kelly Cables
Lavena Williams, Acting
Dave Bass
Revised 08/24/06
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LMSB Industry Structure
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Communications, Technology Media Industry
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Communications, Technology Media Industry
Territory Manager
DFO Audit Team Located
In State (DFO-East)
Audit Team Located In State
(DFO-West)
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IRSPractice Procedures LMSB Culture and
Philosophy

• LMSB VISION STATEMENT
• We are a world class organization responsive to
  the needs of our customers in a global
  environment while applying innovative approaches
  to customer service and compliance.
• We apply the tax laws with integrity and
  fairness through a highly skilled and satisfied
  workforce, in an environment of inclusion where
  each employee can make a contribution to the
  mission of the team.

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IRSPractice Procedures LMSB Culture and
Philosophy

• LMSB CULTURAL BELIEFS
• We are a World Class Organization
• We Apply Innovative Approaches to Achieve
  Compliance
• We Apply the Tax Laws with Integrity and Fairness
• We Create an Environment of Inclusion and Have a
  High Level of Employee Engagement

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IRSPractice Procedures LMSB Culture and
Philosophy

• LMSB CULTURAL BELIEFS
• We are a World Class Organization.
• We Apply Innovative Approaches to Achieve
  Compliance.
• I improve compliance through the use of pre-and
  post-filing tools and treatment.
• We Apply the Tax Laws with Integrity and
  Fairness.
• I ensure compliance with the tax laws and treat
  taxpayers in a fair and equitable manner. I use
  appropriate service and enforcement tools
  commensurate with taxpayer behaviors.
• We Create an Environment of Inclusion and Have a
  high Level of Employee Engagement

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IRSPractice Procedures LMSB Significant Issues

• Represents issues that require organizational
  focus and emphasis
• Issues with significant direct exam time
• Issues resulting in controversy with taxpayers
• Material issues with high tax impact
• Issues with significant future impact on
  resources

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IRSPractice Procedures LMSB Top Compliance
Issues

• Transfer of Intangibles Offshore Abusive Hybrids
  
• Universal Fund Service FTC Generators
• 199 Domestic Production Transfer Pricing
• 965 Foreign Earnings Repatriation RE Credit
  Claims
• 409A Executive Compensation Mixed Service Costs
  
• Tax Shelters Promoters

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IRSPractice Procedures LMSB Tax
Administration

• Currency Initiative
• Strategic Specialization
• Schedule M-3
• E-file Mandate
• Compliance Initiative Projects

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IRSPractice Procedures LMSB Initiatives

• Tools to Provide Certainty in the Uncertain World
• Industry Issue Resolution (IIR)
• Pre-Filing Agreements (PFA)
• FIN 48
• Compliance Assurance Program (CAP)
• Fast Track Appeals
• Early Referrals
• LIFE

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IRSPractice Procedures EFFECT of E-File

• Reducing Burden
• Re-value information requested on Tax Forms
• Continued Collaboration with External including
  expansion 10 to 50 million market segmetn
• Significantly Improved Data Analysis
• Legislation