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22 nd Annual High Technology Tax Institute

22 nd Annual High Technology Tax Institute. IRS Practice and Procedures. IRS Practice & Procedures. LMSB Organization LMSB Culture and Philosophy LMSB Significant Issues LMSB Initiatives Effect of e-filing. LMSB Organized By Industry. Deborah Nolan - Commissioner

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22 nd Annual High Technology Tax Institute

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  1. 22nd Annual High TechnologyTax Institute IRS Practice and Procedures

  2. IRS Practice & Procedures • LMSB Organization • LMSB Culture and Philosophy • LMSB Significant Issues • LMSB Initiatives • Effect of e-filing

  3. LMSB Organized By Industry Deborah Nolan - Commissioner Bruce Ungar – Deputy Commissioner Frank Ng - Deputy Commissioner International LMSB Division Counsel LMSB Commissioner Deputy Commissioners International (U.S. Competent Authority) Division Information Officer Frank Ng , Director Equal Employment Opportunity & Diversity William Williams, Acting Director Heavy Manufacturing & Transportation Field Specialists Financial Services Retailers, Food, Pharmaceuticals, & Healthcare Natural Resources & Construction Field Communications, Technology, & Media 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

  4. LMSB Industry Structure

  5. Communications, Technology & Media Industry

  6. Communications, Technology & Media Industry Territory Manager DFO Audit Team Located In State (DFO-East) Audit Team Located In State (DFO-West)

  7. 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.

  8. 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

  9. 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

  10. 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

  11. 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 R&E Credit Claims §409A Executive Compensation Mixed Service Costs Tax Shelters & Promoters

  12. IRSPractice & Procedures LMSB Tax Administration • Currency Initiative • Strategic Specialization • Schedule M-3 • E-file Mandate • Compliance Initiative Projects

  13. 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

  14. 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

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