The value of engagement.

• Author: O'Connor, Paul
• Position: President's Corner

If you want evidence of the scope of TEI's advocacy activity, you need to look no further than the Table of Contents of this issue of The Tax Executive. The issue contains high-quality submissions on several topics of keen interest to TEI members and their companies--from business 1099s, to the OECD's intangibles transfer pricing initiative, to Washington State's emergency rules relating to nexus and sales factor sourcing.

The Institute prepared position papers on these subjects because our committees--respectively, the Federal Tax Committee, chaired by John Mann of the Chicago Chapter; the European Direct Tax Committee, chaired by An Theeuwes of the EMEA Chapter; and the State and Local Tax Committee, chaired by Linda Dickens of the Dallas Chapter--determined that the issues involved transcended individual taxpayers or industries and demanded attention. Upon reviewing the submissions (which are available on our website on a real-time basis), I'm confident you will agree that the Institute's committees and legal staff have done an exemplary job of analyzing government actions, identifying policy flaws and administrative concerns, and developing alternatives to address the government's legitimate concerns in less burdensome ways.

The effectiveness of TEI's advocacy work, of course, is not proven by how long or well written its comments, briefs, and testimony are; it's demonstrated by whether they are persuasive, that is to say, how policy-makers respond to the Institute's comments and proposals for change. And that is also demonstrated by this issue's Table of Contents, specifically, by Michael Desmond and Ronald Buch's article entitled "Practical Considerations for Schedule UTP ... an Addendum." The article, which follows up on Mike and Ron's article in the July-August issue, discusses the changes the Internal Revenue Service made to Schedule UTP (and the draft instructions) to take into account comments made by TEI and others. I commend it to you, not only as guidance on what taxpayers must disclose and other aspects of the IRS's latest "game-changing" initiative but as an example of the value of the Institute's advocacy.

As TEI members know, Announcement 2010-9 and Schedule UTP struck a real nerve in the corporate community, prompting the largest outpouring of comments since the Tax Reform Act of 1986. While few of us welcomed the Announcement 2010-9 and draft schedule UTP--and many of us would still wish it away--fairness requires that...