Competent authority process should be faster, provide for more taxpayer input, TEI tells IRS.Speedier resolution of cross-border disputes is a must in today's economy, Tax Executives Institute recently told the Internal Revenue Service. In a letter on the proposed revision of Rev. Proc. 96-13, relating to relating to relate prep → concernant relating to relate prep → bezüglich +gen, mit Bezug auf +acc the IRS's Competent Authority function, TEI 1. (communications) TEI - Terminal Endpoint Identifier. 2. (text, project) TEI - Text Encoding Initiative. President Charles W. Shewbridge, III urged the IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. to set a goal of one year in which to settle international controversies. (Currently, the process now lasts longer than 700 days on average.) The July 19 letter elaborated on comments TEI representatives made during a March meeting with the IRS. More taxpayer involvement in the process is also needed, Mr. Shewbridge stated. Otherwise, taxpayers may view the process "as a black hole where cases enter the system and never leave." Noting that Institute members report that taxpayers are becoming more and more involved in the processing of the cases, TEI urged the IRS to continue the trend, which will facilitate the negotiation of a settlement. The organization also urged the IRS to institute an arbitration procedure to put additional pressure on treaty partners to negotiate in good faith and present reasonable positions. The Institute suggested that the United States United States, officially United States of America, republic (2005 est. pop. 295,734,000), 3,539,227 sq mi (9,166,598 sq km), North America. The United States is the world's third largest country in population and the fourth largest country in area. adopt a consensual CONSENSUAL, civil law. This word is applied to designate one species of contract known in the civil laws; these contracts derive their name from the consent of the parties which is required in their formation, as they cannot exist without such consent. 2. arbitration procedure where both Competent Authorities agree to binding arbitration, with taxpayer consent, if they are otherwise unable to reach agreement after two years. Referring to the recent move of the Competent Authority function to the IRS's new Large and Mid-Size Business Division, Mr. Shewbridge stressed that the reorganization of the IRS should not diminish either the significance or the autonomy of the Competent Authority function. "The Competent Authority function has traditionally been separate from the IRS's Examination function," he stated, "and its placement within the LMSB LMSB Large and Mid-Size Business organization should not be allowed to compromise that autonomy." The Institute also commented on the interaction of Competent Authority with Appeals and the treatment of deficiency interest and currency gains and losses. The Institute's comments, which were drafted under the aegis aegis (ē`jĭs), in Greek mythology, weapon of Zeus and Athena. It possessed the power to terrify and disperse the enemy or to protect friends. of its International Tax Committee, are reprinted in this issue, beginning on page 325. |
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