TEI comments on proposed regionalization of customs functions: May 12, 2005.

• Position: Tax Executive Institute

On May 12, 2005, TEI President Judith P. Zelisko sent the following letter to Michael Chertoff, Secretary of the U.S. Department of Homeland Security. The letter was prepared under the auspices of the Institute's International Tax Committee, whose chair is John J. Herson of Neenah Paper, Inc. Roger D. Wheeler of General Motors Corporation contributed substantially to the preparation of the letter.

On behalf of Tax Executives Institute, I congratulate you on your appointment as Secretary of Homeland Security. We understand that you are undertaking a comprehensive review of the operations of the Department of Homeland Security (DHS). As an organization of tax and customs professionals, TEI is writing to provide our views on an important organizational issue concerning Custom and Border Protection (CBP).

TEI is the preeminent professional organization of business executives who are responsible for tax matters on an administrative and policy-making level. TEI's nearly 5,700 TEI members are accountants, lawyers, and other corporate and business employees who are responsible for the tax affairs of more than 2,700 leading businesses in the United States and throughout the world, with a significant number of our members also having responsibility for customs matters. TEI is dedicated to the development of sound policy, compliance with and uniform enforcement of those laws, and minimization of administration and compliance costs to the benefit of the government, taxpayers, and importers and exporters.

TEI strongly supports border security initiatives and believes that security and trade facilitation are fully compatible. Many TEI members have worked closely with CBP on numerous security initiatives (such as the Container Security Initiative (CSI), Advanced Manifest Filing, and Customs-Trade Partnership Against Terrorism (C-TPAT)). In working together, government and industry have realized improvements in both security and trade facilitation. For example, security initiatives like CTPAT have accelerated the clearance of cargo that has been pre-screened and confirmed to be low risk.

TEI recognizes the challenge in merging 22 disparate agencies and programs into a cohesive department with centralized leadership. Recognizing that most of the legacy agencies already had regional structures, we acknowledge that moving forward with a single, regional model makes sense. While we do not oppose a regional structure for DHS, we are concerned that the...