TEI-IRS large and mid-size business division liaison meeting minutes.

• Position: Tax Executives Institute

March 10, 2010

On March 10, 2010, a delegation from Tax Executives Institute met with Heather C. Maloy, Commissioner of the IRS's Large and Mid-Size Business Division, and other representatives of the Internal Revenue Service. The following minutes were prepared by Tax Executives Institute and, although reviewed by LMSB, they have not been formally approved by the agency. The agenda for the meeting was submitted in advance and has been published in The Tax Executive magazine and on TEI's website.

LMSB Commissioner Maloy welcomed TEI President Neil D. Traubenberg and the TEI delegation. She noted the importance of the liaison meetings to facilitate open discussion on issues of common interest, which promotes better tax administration. On behalf of TEI, Mr. Traubenberg expressed the Institute's thanks for the IRS's ongoing commitment to active dialogue. The IRS and TEI delegations are set forth below.

IRS Delegation

Heather C. Maloy, LMSB Commissioner

Paul D. DeNard, LMSB Deputy Commissioner (Operations)

Michael Danilack, LMSB Deputy Commissioner (International)

Cheryl Claybough, Director, Pre-Filing and Technical Guidance

Robert Adams, Special Adviser to LMSB Deputy Commissioner (International)

Elizabeth Wagner, Senior Adviser to the Commissioner

Linda Kroening, LMSB Division Counsel

Drita Tonuzi, Deputy Division Counsel

Donald McPartland, Director, Research and Issue Identification (BY PHONE)

Caryl Grant, Program Manager, National Public Liaison (Communications & Liaison)

Kathryn Gregg, LMSB Stakeholder Liaison Program Manager

TEI Delegation

Neil D. Traubenberg, TEI International President

Paul O'Connor, Millipore Corporation, TEI Senior Vice President

David M. Penney, General Motors of Canada Limited, TEI Secretary

Carita R. Twinem, Briggs & Stratton Corporation, TEI Treasurer

Michael J. Bernard, Microsoft Corporation, TEI Executive Committee

Paul Heller, Royal Bank of Canada, TEI Executive Committee

Lynn B. Jordan, Performance Food Group Company, TEI Executive Committee

Janice L. Lucchesi, Akzo Nobel, Inc., TEI Executive Committee

Kelly A. Nall, Hewlett-Packard Company, TEI Executive Committee

Daniel R. Goff, Xilinx, Inc., Chair, TEI International Tax Committee

John A. Mann, Walgreen Co., Chair, TEI Federal Tax Committee

Mark C. Silbiger, The Lubrizol Corporation, Chair, TEI IRS Administrative

Affairs Committee

Terilea J. Wielenga, Allergan, Inc., Chair, TEI Financial Reporting Committee

Timothy J. McCormally, TEI Executive Director

Eli J. Dicker, TEI Chief Tax Counsel

Mary L. Fahey, TEI General Counsel

Jeffery P. Rasmussen, TEI Tax Counsel

Announcement 2010-9: Schedule UTP

Mr. Traubenberg observed that Announcement 2010-9 has been met with considerable emotion--shock and awe"--in the corporate tax community, and that taxpayers are only beginning to understand the implications of a new schedule linked to their FIN48 uncertain tax positions. He commended Ms. Maloy and other IRS officials for getting out into the field (and speaking on various panels, including TEI programs) to discuss the Announcement and to ad dress taxpayer questions. Mr. Traubenberg also expressed the Institute's appreciation for the extension of time within which to file comments; he noted that the additional time will enable taxpayers and other affected parties the opportunity to better understand and offer constructive comments on the Announcement.

Ms. Maloy noted that there was no action required by taxpayers with regard to current (2009) tax returns. Rather, the IRS was working toward issuing...