More than 600 tax executives meet in nation's capital.

More than 600 TEI members and guests gathered in Washington, D.C. in March for TEI's 56th Midyear Conference. The three-day conference held March 27-29 at the Grand Hyatt Hotel included sessions on preventing material weaknesses in tax department internal controls, managing the audit relationship, tax accounting developments, financial reporting issues at the state and local level, and the "public part" of IRS audits.

The program began on Monday morning with a valedictory address by Congressman Bill Thomas, chairman of the House Ways and Means Committee, who has announced his retirement from Congress. The chairman focused on the need to reform the tax system, noting that the opportunity for meaningful change may well have been lost. Referring to the American Jobs Creation Act of 2004, Mr. Thomas lamented that the legislation, though a "decent" bill, did not go far enough in reforming the system.

A legislative update followed with John L. Buckley, Chief Tax Counsel (Democratic Staff), and Bob Winters, Chief Tax Counsel (Republican Staff), both of the House Ways and Means Committee; and Patrick G. Heck, Chief Tax Counsel (Democratic Staff), and Mark A. Prater, Chief Tax Counsel (Republican Staff), both of the Senate Finance Committee.

Later that day, IRS Commissioner Mark W. Everson addressed issues related to tax shelters, currency, and international tax matters. He reported that a recent tax shelter notice setting forth settlement options for 21 transactions had attracted more than 2,000 participants and will produce an estimated $2 billion in additional taxes. He also discussed the IRS's recent electronic filing initiative, noting that approximately 220,000 taxpayers had successfully e-filed their returns as of March 2. Mr. Everson announced that about 50 waiver applications had been received, adding that the IRS will grant waivers on a case-by-case basis. We are not trying to be unreasonable, he stated, but we need to be fair to those who are trying to comply.

In response to a question concerning recent public statements on the public disclosure of tax returns, the Commissioner acknowledged that there are many valid reasons to keep parts of the returns confidential. He suggested, however, that there should be a discussion whether the increased transparency of releasing, for example, all or a portion of Schedule M-3 would be beneficial.

On Tuesday, Treasury Secretary John W. Snow continued the discussion of tax reform, noting that it is often difficult to get agreement. "It's easy to say fairer, simpler, more growth-oriented, but the devil is always in the details," he continued in an address that would become his final appearance before TEI. (Secretary Snow subsequently submitted his resignation to the President.)

"Your counsel is important," Secretary Snow told the assembled tax executives in March. He urged the group to make its voices heard, acknowledging that Justice Holmes got it right: tax-payers should pay what they owe, but there is also lawful tax minimization permitted. Calling the participants the "gatekeepers of corporate capitalism," the Secretary encouraged them to enter into the fray by making their views known on corporate tax reform.

Tuesday also brought the first address to TEI by the Multistate Tax Commission's new Executive Director. Joe B. Huddleston (who had participated in previous conferences before joining the MTC), briefed the participants on the MTC's national nexus program, Streamlined Sales Tax Program, and audit processes, and other initiatives.

The conference also included sessions on acquiring private companies and disposing of other, non-performing ones; partnership and LLC developments; fringe benefits; modern tax research techniques; and the federal government's mandatory electronic filing program, followed by a panel on e-filing issues at the state level. International topics ranged from foreign tax audits; to tax planning for permanent establishments; to the taxation of cross licensing agreements. For state and local tax practitioners, there were panels on valid business purposes for restructurings and reorganizations and unclaimed property issues. Finally, management issues were highlighted in programs on scorecarding, TEI's corporate tax department survey, and utilizing and motivating staff.

A highlight of the program was the Tuesday night banquet with comedian Mark Russell entertaining participants with his unique blend of humor and song parodies.