How Prepared Are You?

• Date: 01 May 2019
• Author: Silvestri, James

As we gaveled to a close TEI's 69th Midyear Conference, I wanted to express my gratitude and appreciation to the 500-plus in-house professionals who joined us in Washington, D.C., to our outstanding speaker and moderator cadre who guided us through our program agenda, and to our sponsors for their continuing support of TEI's educational mission. Together, we explored the broad range of issues that confront us as we manage our day-to-day portfolios as well as continue to navigate the questions and quandaries of the Tax Cuts and Jobs Act (TCJA). That journey will no doubt continue to present challenges for us and the departments we serve, most immediately in terms of TCJA interpretation, implementation, and compliance.

Yet beyond the near-term challenges of "what number goes on line x of form y," "how to file," and "what to report" type of questions, what looms ahead in the long term may be just as challenging. How ready are we to defend the inevitable disputes that will arise several years down the road about the positions and interpretative decisions we have taken today? Put another way, how well have we documented and memorialized our decision making about our TCJA-related return positions? How effective are we being to manage, store, retrieve, and analyze the volume of data that support those decisions? TCJA-related tax disputes are inevitable, from all the...