Tax Executives Institute-U.S. Department of Treasury Liaison Meeting.

On December 1, 1994, Tax Executives Institute held a liaison meeting with the Assistant Secretary of the Treasury and other officials of the Treasury Department's Office of Tax Policy. Reprinted below is the written agenda for the meeting, which was submitted to the Treasury in mid-November. To avoid duplication, there are cross references to items in the agenda for TEI's December 2, 1994, liaison meeting with the Internal Revenue Service, which while not identical are substantial similar to items in the Treasury agenda. (The IRS agenda was reprinted in the November-December 1994 issue of The Tax Executive.) Individuals wishing copies of the complete Treasury agenda should send a written request to TEI Headquarters. The results of the liaison meeting will be reported in a future issue of The Tax Executive.

  1. Introduction

    Tax Executives Institute is pleased to have this opportunity to meet with Assistant Secretary Samuels, Deputy Assistant Secretary Beerbower, and other senior officials of the U.S. Department of Treasury's Office of Tax Policy. Our periodic meetings give both organizations an opportunity to articulate policy and administrative concerns and considerations. We are especially pleased that the timing of the meeting has been advanced from February to December. By scheduling the meeting earlier in the government's (and the Institute's) fiscal year, there will be ample opportunity for productive follow-through on various agenda items. The scheduling of this year's meeting may be especially propitious given the monumental changes worked by the 1994 election and what they may portend for tax policy and administration. During the liaison meeting, we hope to identify a number of items (relating to the guidance and legislative process) on which we can arrange follow-up meetings and pursue real progress.

    In a recent speech before the New York State Bar Association, Deputy Assistant Secretary Beerbower outlined six fundamental issues that affect, and cannot help but circumscribe, the further development of the tax law: (1) the burgeoning irrelevancy of legal ownership; (2) the differentiation of capital (or principal) from the income on that capital; (3) the hoary distinction between debt and equity; (4) the treatment of limited liability companies and other emerging business structures; (5) the differing tax treatment of financial intermediaries; and (6) the characterization of technological developments (such as customized software). She called on taxpayers to help Treasury fiesh out and, ultimately, resolve these issues.

    TEI agrees that the time is ripe - indeed, overdue - to address "real world" changes in entity structures and other emerging issues and how the tax treatment of those structures and issues affect the ability of business to do business. We strongly believe that tax...

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