On September 21 and 22, the New York Chapter in conjunction with the Internal Revenue Service's Large and Mid-Size Business Division held the 10th Annual Financial Services Industry Conference at the Westin Times Square Hotel in New York City.
The conference, which attracted an audience of more than 200 (including 10 members of the media and more than 70 government personnel), featured many high-ranking IRS and Treasury officials as well as top-notch practitioners and tax executives. In the opening session, LMSB Commissioner Heather Maloy forecast the coming 10 years for the IRS Large and Midsize Business Division, predicting that ongoing globalization required the IRS both to select better cases to examine and to retool how those cases are worked. Commissioner Maloy also said LMSB was nearing completion of its review of the Tiered Issue Process. "We're looking at all the Tier I issues to determine if they should be sunsetted or moved in the Tiering Process," she said.
Among the other highlights was the unveiling of the IRS new, International organization by Michael Danilack, LMSB's Deputy Commissioner (International). The restructuring follows the IRS's announcement in August that, as of October 1, LMSB would be reconfigured and renamed the Large Business & International (LB&I) Division, with a greater emphasis on international tax matters. Mr. Danilack will head LB&I's international arm, which will be made up of the Competent Authority & International Coordination (CA&IC), International Business Compliance (IBC), and International Individual Compliance (IIC) units.
Mr. Danilack said the international realignment is the culmination of longstanding efforts by the IRS to sharpen its focus on cross-border activity, and is driven less by policy and more by practice. "There's been a real change in terms of focus on tax administration in a cooperative mode," he said, adding that "the IRS is adapting to a global environment, one of cooperative tax administration and information exchange." In another panel, tax professionals integral to the development of the Large and Midsize Business Division reflected on how Schedule UTP disclosures may shape the Division's future. Barry Shott, former LMSB Deputy Commissioner (International), said he is convinced that the new Schedule UTP will help the IRS better determine which returns to review and which staff to assign in order to reach the correct answer. "If it's managed properly--and I believe it will...