Session 6 - Sam Maruca TEI IRS Houston

January 5, 2018 | Author: Anonymous | Category: Business, Management
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Transfer Pricing Operations TEI-LB&I Liaison Meeting May 14, 2012

1

LB&I International Function Overview

Commissioner Large Business & International

EOI Program Treaty Unit

Michael Danilack, Deputy Commissioner (International) Doug O’Donnell, Assistant Deputy Comm’r (Int’l)

Sam Maruca, Director, Transfer Pricing Operations

2

Carol Poindexter, Acting Director, International Business Compliance (IBC)

JITSIC Foreign Posts Service-wide Strategy

Rosemary Sereti, Director, International Individual Compliance (IIC)

2

LB&I International Function Transfer Pricing Operations Deputy Commissioner International Senior Tax Advisor Senior Econ Advisor

Director, Transfer Pricing Operations

EA Operations

Special Project Deps.

EA Technical Director APMA Deputies

12 Mgrs.

3

IPN Manager

Transfer Pricing Practice TTM West

TTM Central

TTM East

2 Mgrs.

2 Mgrs.

2 Mgrs.

TPO – A Single Practice

• TPO will operate as a single, unified practice • Two program segments: – Advance Pricing and Mutual Agreement (APMA) – Transfer Pricing Practice (TPP) • APMA - external focus; TPP - internal focus – But nearly complete substantive overlap • One knowledge base – Income shifting IPNs – Sharing information, experience and skills

4

TPO – A Single Practice • Why a single practice? – Necessity of global perspective in treaty cases – Ensure cases steered to proper forum – Demand for two-way, end-to-end visibility – Need to share experience/expertise to ensure optimal case selection and development – Common understanding of MNE behaviors and planning strategies - CONTEXT – Common skills, common training

5

TPO – A Single Practice

• Steps to achieving an efficient, integrated practice that produces quality positions – Recruit the best – Ensure that managers are experts, equipped to provide substantive review and mentoring – Provide training in case development and negotiation, especially oral/written presentation – Communication and collaboration through IPNs and in day-to-day work

6

TPO – A Single Practice

• Steps to achieving an efficient, integrated practice that produces quality positions (cont’d) – Build knowledge base, including searchable skills inventories and case databases (KTK basis) – Joint meetings and training sessions – Coordination with LB&I units, especially IBC, IIC and Field Specialists – Coordination with TAIT

7

APMA – Special Considerations

• APMA’s immediate focus is external (resolving issues with treaty partners) but must be informed by understanding of broader context – Inbound/outbound – Taxpayer’s overall tax position and planning objectives – Collateral proceedings (such as domestic audits) – Sourcing issues and their significance – Where is matter best resolved? • So APMA practitioner needs broad perspective 8

APMA – Special Considerations

• Skill-building – Legacy APA personnel have strong case development skills; legacy CA personnel have strong negotiation skills – Individuals have specific industry/taxpayer experience – We need to leverage off one another’s strengths • Heightened importance of presentation – Arbitration

9

TPP – Special Considerations

• On-going activities – Pilot cases – Pre-2009 cost share buy-in triage project – Build-out • Re-engineering risk assessment/audit process – Coordination with PAIR – Assessment of UTP filings – “Roadmap” – building on QEP – Dialogue with Appeals – Coordination with APMA 10

TPO – The Way Forward • Earlier and more proactive participation by APMA in field audits of treaty cases • Concentration by TPP on tax haven activity and recalcitrant taxpayers • Closer collaboration with IBC and field operation in general • Creative solutions – “expanded” APAs, joint audits, multilateral collaboration among jurisdictions, increased dialogue among CAs

11

TPO – The Way Forward

• Substantive areas of strategic importance - TPP – Continued attention to outbound IP migration – new cost-sharing regulations – High-value services – Middle market MNEs – Financial sector – Inbound activity • Commitment to enhancing transfer pricing administration globally – FTA Guidelines 12

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