advancing the vision lmsb 1 22 nd annual high technology tax institute irs practice and procedures

Advancing the VisionAdvancing the VisionLMSBLMSB

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22nd Annual High TechnologyTax Institute

IRS IRS

Practice and ProceduresPractice and Procedures


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IRS Practice & Procedures

LMSB Organization LMSB Organization

LMSB Culture and Philosophy LMSB Culture and Philosophy

LMSB Significant IssuesLMSB Significant Issues

LMSB InitiativesLMSB Initiatives

Effect of Effect of e-filinge-filing

LMSB Commissioner

Deputy Commissioners

International (U.S. Competent Authority)

Financial Services

Retailers, Food, Pharmaceuticals, &

HealthcareNatural Resources

& Construction

Communications, Technology, &

Media

Heavy Manufacturing & Transportation

Field

Headquarters:

Strategy, Research & Program Planning

Performance, Quality Assurance, & Audit

Assistance

Management& Finance

Equal Employment Opportunity & Diversity

Business Systems Planning

Pre-filing & Technical Guidance

Communications & Liaison

Field Specialists

Frank Ng , Director

Deborah Nolan - CommissionerBruce Ungar – Deputy Commissioner

Frank Ng - Deputy Commissioner International

Walter HarrisDirector:

Barry Shott John Risacher

Keith Jones Patricia Chaback

Henry Singleton

Paul DeNard Don McPartland Helen Bolton

Kelly Cables

Lavena Williams, Acting

Dave Bass

William Williams, Acting Director

Director:

LMSB Organized By Industry

Revised: Revised: 08/24/0608/24/06

LMSB Division Counsel

Division Information Officer


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LMSB Industry Structure

Industry DirectorIndustry Director

Director, Field Operations Director, Field Operations

Executive Assistant Executive Assistant

Territory ManagerTerritory Manager

Team ManagerTeam Manager

Headquarters StaffHeadquarters Staff

Revenue AgentRevenue Agent


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Patricia ChabackIndustry Director

Oakland, CA

JoAnn BankDirector of Field Operations West

Oakland, CA

Cheryl ClayboughDirector of Field Operations East

Iselin, NJ

Kay FentonExecutive Assistant,

Oakland, CA

VacantTerritory Manager, San Francisco

8 Teams

Maria HwangTerritory Manager, San Jose

7 Teams

Ramona FelicianoTerritory Manager, Denver

6 Teams

Maureen SzoztakTerritory Manager, Seattle

7 Teams

Nancy BronsonInt’l Territory Manager, San Francisco

8 Teams

Paul RinaldiTerritory Manager, New York

10 Teams

Carl StewartTerritory Manager, NJ North

7 Teams

Woody HowellTerritory Manager, Stoneham

8 Teams

Lavena WilliamsTerritory Manager, Atlanta

7 Teams

Mark ChanTerritory Manager, Boston

8 Teams

Communications, Communications, Technology & Media Technology & Media

IndustryIndustry


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Communications, Technology Communications, Technology & Media Industry& 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 STATEMENTLMSB VISION STATEMENT

We are a world class organization responsive to We are a world class organization responsive to the needs of our customers in a global the needs of our customers in a global environment while applying innovative environment while applying innovative approaches to customer service and compliance. approaches to customer service and compliance.

We apply the tax laws with integrity and fairness We apply the tax laws with integrity and fairness through a highly skilled and satisfied workforce, through a highly skilled and satisfied workforce, in an environment of inclusion where each in an environment of inclusion where each employee can make a contribution to the mission employee can make a contribution to the mission of the team.of the team.


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LMSB Culture and Philosophy

LMSB CULTURAL BELIEFS:LMSB CULTURAL BELIEFS:

• We are a World Class OrganizationWe are a World Class Organization

• We Apply Innovative Approaches to Achieve ComplianceWe Apply Innovative Approaches to Achieve Compliance

• We Apply the Tax Laws with Integrity and FairnessWe Apply the Tax Laws with Integrity and Fairness

• We Create an Environment of Inclusion and Have a High We Create an Environment of Inclusion and Have a High Level of Employee EngagementLevel of Employee Engagement


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LMSB Culture and PhilosophyLMSB CULTURAL BELIEFS:LMSB CULTURAL BELIEFS:• We are a World Class Organization.We are a World Class Organization.

• We Apply Innovative Approaches to Achieve Compliance.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.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 We Create an Environment of Inclusion and Have a high Level of Employee EngagementEmployee Engagement


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LMSB Significant Issues

Represents issues that require organizational Represents issues that require organizational focus and emphasisfocus and emphasis

Issues with significant direct exam timeIssues with significant direct exam time

Issues resulting in controversy with taxpayersIssues resulting in controversy with taxpayers

Material issues with high tax impactMaterial issues with high tax impact

Issues with significant future impact on Issues with significant future impact on resourcesresources


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LMSB Top Compliance Issues

Transfer of Intangibles OffshoreTransfer of Intangibles Offshore Abusive Hybrids Abusive Hybrids

Universal Fund Service Universal Fund Service FTC Generators FTC Generators

§199 Domestic Production §199 Domestic Production Transfer PricingTransfer Pricing

§965 Foreign Earnings Repatriation §965 Foreign Earnings Repatriation R&E Credit R&E Credit Claims Claims

§409A Executive Compensation§409A Executive Compensation Mixed Service Costs Mixed Service Costs

Tax Shelters & PromotersTax Shelters & Promoters


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LMSB Tax Administration

• Currency Initiative Currency Initiative

• Strategic SpecializationStrategic Specialization

• Schedule M-3Schedule M-3

• E-file E-file MandateMandate

• Compliance Initiative ProjectsCompliance Initiative Projects


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LMSB Initiatives

Tools to Provide Certainty in the Uncertain WorldTools to Provide Certainty in the Uncertain World

• Industry Issue Resolution (IIR)Industry Issue Resolution (IIR)

• Pre-Filing Agreements (PFA)Pre-Filing Agreements (PFA)

• FIN 48

• Compliance Assurance Program (CAP)Compliance Assurance Program (CAP)

• Fast Track AppealsFast Track Appeals

• Early ReferralsEarly Referrals

• LIFE LIFE


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EFFECT of E-File Reducing BurdenReducing Burden

Re-value information requested on Tax FormsRe-value information requested on Tax Forms

Continued Collaboration with External including Continued Collaboration with External including expansion $10 to $50 million market segmetnexpansion $10 to $50 million market segmetn

Significantly Improved Data AnalysisSignificantly Improved Data Analysis

LegislationLegislation

advancing the vision lmsb 1 22 nd annual high technology tax institute irs practice and procedures

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