TEI gives e-filing frosty reception: TEI discusses e-filing mandate, 2004 Act Guidance, and other key issues during Washington liaison meetings; files comments on Canada's Technical Tax Bill; and testifies at IRS Oversight Board hearing.

• Position: Recent Activities

A mild and unseasonably warm start to January gave way to mid-month frigid weather in Washington, D.C., as corporate taxpayers came to grips with a chilling IRS "forecast"--a requirement that corporations with total assets of $50 million or more will be filing their Forms 1120 electronically beginning in 2006. While acknowledging the potential benefits of e-filling to the IRS, Tax Executives Institute expressed significant reservations about the mandate, in2 terms of both its practicality and cost and because the IRS's pronouncement (which took the form of immediately effective temporary regulations) was not preceded by consultations with taxpayers and taxpayer groups (as occurred, for example, with the new Schedule M-3).

TEI expressed its views in several forums, most notably in its annual liaison meetings with officials of both the IRS National Office and the Large and Mid-Size Business Division. Following the LMSB meeting on February 9, a group of members met separately with the IRS to discuss the practical implications of the e-filing mandate. These included TEI's concerns that, the assurances of software vendors notwithstanding, significant doubt existed whether the mandate could be successfully implemented within the time frame specified by the IRS.

Liaison Agendas

In addition to e-filing, TEI discussed other vital topics at its annual liaison meeting with IRS's Large and Mid-Size Business Division held on February 9. TEI and LMSB have met together every year since the division became operational in 1999. TEI's delegation to the liaison meeting was led by Judy Zelisko, Institute President. LMSB's delegation was chaired by LMSB Commissioner Deborah Nolan and Deputy Commissioner Bruce Ungar. The discussion covered topics such as "currency," the Compliance Assurance Process, Appeals, Schedule M-3, Circular 230, and the interaction among IRS, SEC, and FASB. TEI also took the opportunity afforded by the meeting to express its appreciation to the IRS and Treasury for their expeditious and creditable work in providing guidance on several provisions of the Jobs Creation Act of 2004.

The Institute's agenda for LMSB meeting is reprinted in this issue, beginning on page 72. Minutes of the meeting will be published in a future issue.

TEI also held a liaison meeting with IRS Commissioner Mark Everson and other IRS National Office officials, with many of the same topics being discussed.

Finally, TEI was scheduled to meet with the Treasury...