TEI Canadian issues dominate TEI's winter scene: TEI meets with Canada Revenue Agency, Finance Department; comments on IRS notice 2008-91 and appeals approach to foreign tax credit 'generators'.

• Position: Recent Activities

Tax Executives Institute's annual liaison meetings with Canadian tax officials, an IRS notice to permit temporary investments in U.S. property, and a meeting with the IRS Office of Appeals on foreign tax credit transactions were the focus of the organization's recent technical activities. The Institute is also preparing for its annual liaison meetings with U.S. representatives.

Canadian Liaison Meetings

On December 9 and 10, a delegation of TEI members led by Institute President Vincent Alicandri of Hydro One Networks, Inc. headed to snowy Ottawa, Ontario, to meet with representatives of Canada Revenue Agency and the Canadian Department of Finance on income and excise tax issues. Joining Mr. Alicandri were Vice President for Canadian Affairs Sherrie Ann Pollock of RBC Dexia Investor Services; Institute Treasurer David M. Penney of General Motors of Canada Limited; Canadian Income Tax Committee Chair Rod C. Bergen of The Jim Pattison Group; and Canadian Commodity Tax Committee Vice Chair Diana M. Spagnuolo of Imperial Oil Limited. The delegation also included members of the Canadian Income and Commodity Tax Committees, as well as members of TEl.

The first meeting on December 9 with CRA addressed a panoply of income tax issues. Later that day, there was a separate meeting with CRA on commodity and excise tax matters. The next day, two contingents of members met with the Department of Finance on income and excise tax matters.

"The meetings with Canadian officials each year are some of the most productive liaison activities in which the Institute participates," Mr. Alicandri said. "We've met for more than three decades with CRA and the Department of Finance and the discussions have always been frank, pragmatic, and lively. This year's meetings were no exception and I'm pleased to have been part of the delegation."

Mr. Alicandri also reported that the Institute is busy preparing for its annual liaison meetings with the Internal Revenue Service and its Large and Mid-Size Business Division. He stated that the annual meetings, which will be held February 12-13 in Washington, D.C., provide the perfect opportunity to discuss TEI's submissions and to work toward making the rules more administrable for taxpayers and the government alike.

"The give-and-take at these meetings help both parties focus on ways to understand each other's concerns and resolve issues," Mr. Alicandri stated, encouraging members to "dare to get involved" by suggesting topics for...