Tax Executives Institute--U.S. Department of Treasury Office of Tax Policy liaison meeting; February 6, 2002.

On February 6, 2002, Tax Executives Institute held its liaison meeting with Assistant Treasury Secretary Mark Weinberger and other representatives of the Office of Tax Policy. The agenda for the meeting is reprinted below; topics that overlap with the IRS agenda (reprinted elsewhere) have been deleted. Minutes of the meeting will be published in a future issue of the magazine.

1. Introduction

2. Regulatory Issues

   a. Business Plan

   i. Important Projects on 6/30/02 Priority Guidance Plan

   * Guidance regarding active trade or business requirement of section 355(b)

   * Guidance relating to the Extraterritorial Income Exclusion Act

   * Update Rev. Porch. 96-30 regarding requests for rulings under section 355

   * Revision of Circular 230

   * Proposed regulations under sections 6662 and 6664 regarding penalties relating to tax shelters

   ii. Priority Additions for 6/30/03 Priority Guidance Plan

   * Revision of Rev. Porch. 98-25

   * Final regulations on allocation and apportionment of charitable contributions under section 861

   * Final regulations under section 163(j)

   * Guidance on treatment of stock options on subsidiary stock in the hands of parent employees

   b. Specific Projects

   i. Research Tax Credit Regulations

   ii. Capitalization Issues

   iii. IRS-Initiated Changes to Improper Methods of Accounting

   iv. Compensation-Related Guidance

1. ESPP Payroll Tax Withholding

2. Code V Reporting

   v. Circular 230

   vi. Tax Shelter Disclosure Initiative

3. Legislative Issues

   a. Budget Submission

   * The 2003FY Budget is due to be released the week of the liaison meeting. TEI requests a status report on business-related items that will be included in the Budget.

   Will the provisions of the economic stimulus package be re-introduced in this session of Congress? Will the Budget include the repeal of the alternative minimum tax, an extension of the net operating loss carryback provision, or bonus depreciation?

   b. Research Tax Credit

   * Several temporary provisions of the Internal Revenue Code have been extended (or re-enacted -- even retroactively -- following expiration) with such regularity that "the extenders" have become a permanent component of the annual legislative agenda. Most notable among the expiring provisions is the research tax credit set forth in section 41 of the Code. TEI has long contended that this provision cannot effectively serve its legislative purpose if taxpayers are unable to know whether it will remain in effect from year to year. Taxpayers need stability in their...