Streamlining corporate filing requirements.

On August 29, 1995, Tax Executives Institute submitted the following comments to William Zachery, IRS Assistant Examination Chief in Atlanta, and Sharon Lovell, IRS Director, Corporate Specialties in Washington, who co-chair an Internal Revenue Service workgroup on streamlining corporate filing requirements and developing a business case for electronic filing of Form 1120. The comments were developed under the aegis of TEI's IRS Administrative Affairs Committee and Tax Information Systems Committee, which are chaired respectively by Robert L. Ashby of Northern Telecom, Inc. and Bill Zornes of Western Auto Supply Company. Messrs. Ashby and Zornes met with the IRS workgroup on August 21. The following members of the Institute also contributed to the development of the Institute's submission: Robert D. Adams of Halliburton Company; Sheldon A. Kimel of Brunswick Corp.; Louis J. Manetti of Bell & Howell Co.; Lonnie Nicol of the Aluminum Company of America; Donald L.R. Ouimet of IVAX Corp.; Jeffrey D. Peterson of AFG Industries, Inc.; Mark C. Silbiger of Sherwin-Williams Company; Joseph Von Der Vellen of Kohler Co.; and Barbara S. Walker of The Stop & Shop Companies.

On behalf of Tax Executives Institute, I am pleased to submit the following comments to the Internal Revenue Service's Corporate Return Streamlining and Electronic Filing Workgroup. Tax Executives Institute supports the objectives of the workgroup (1) to streamline the current filing requirements for Form 1120 -- Corporation Income Tax Return, and (2) to support the planned development of corporate electronic filing systems. TEI appreciated the opportunity to meet on August 21 with Tom Wilson, Sharon Lovell, and other members of the workgroup to provide the Institute's preliminary comments and recommendations concerning the streamlining efforts. In this letter, we summarize those comments and our recommendations.

Background

Tax Executives Institute is a volunteer, professional association of approximately 5,000 accountants, lawyers, and other professionals who are responsible for managing the tax affairs of their companies. The Institute is firmly committed to maintaining a tax system that works -- both for taxpayers and tax administrators. TEI represents a cross-section of the in-house business tax community, including most of the companies that are examined as part of the Coordinated Examination (CIMP) Program, as well as numerous non-CEP taxpayers. Our members must contend daily with the tax law's myriad and complex recordkeeping, compliance, and filing requirements. We believe the diversity, training, and experience of our members enable us to bring a uniquely balanced and practical perspective to your attention. We look forward to working with the workgroup in reducing the cost and burden of tax administration and compliance to the mutual benefit of taxpayers and the government.

General Comments

Perhaps more than any other stakeholder group, TEI knows the price -- in financial terms and in terms of opportunity costs -- of today's filing requirements. Hence, we strongly believe that the first inquiry of the workgroup should be whether particular filing requirements or procedures "add value." Despite the synergies that undeniably exist between a corporation's compliance and planning functions, the compliance activities of corporate tax departments are properly viewed as "overhead." As such, every effort should be made to minimize the burden on taxpayers and to ensure that the burdens that are imposed further the IRS's goal of ensuring compliance with the tax laws.

Accordingly, TEI is very much interested in working with the IRS in streamlining corporate filing requirements. We believe there is much to be accomplished in both the short and the long term from the workgroup's efforts. During our meeting on August 21, we were advised that there is little likelihood that any changes recommended by the workgroup could be implemented in time for the 1996 filing season (i.e., the filing of 1995 returns), because of the long lead time required to revise, review, print, and disseminate the forms, schedules, and attendant instructions. Even if the short term is frustratingly long, however, it should not dissuade the workgroup from expeditiously recommending bold action. Indeed, it should impel the group to redouble its efforts, for if the process is never begun, it will never culminate in positive change. In this regard, too, we urge the group to resist calls to defer action until the shape of fundamental tax reform becomes clear, since the outcome of that debate is likely not to be known until well into 1997 (if then). Because of the incremental benefits that can accrue from streamlining corporate filing requirements (even in the face of anticipated, yet still inchoate, changes), we urge the workgroup to proceed apace.

We caution, however, that taxpayers and the IRS have come this way before. In connection with a 1991 strategic initiative, Balancing Efficiency and Effectiveness (BEE)-12, to improve tax forms and publications, Tax Executives Institute's Philadelphia Chapter (among others) submitted a number of thoughtful recommendations to the IRS. The recommendations were compiled in an excellent report, and yet more than four years after the BEE-12 report was filed, few of the recommendations have been implemented. Why did they languish? Were they too ambitious? Were they too idealistic? We do not know, but submit that the answer should be found before asking internal and external stakeholders to devote considerable time and effort to developing detailed recommendations. We also submit that, given current political resonance of government reinvention efforts, what might have seemed too bold in 1991 could be squarely in the mainstream in 1995.

Candor requires us to report that many taxpayers are concerned that the costs of switching to a new system may outweigh the benefits. We recommend that the workgroup, with equal candor, acknowledge that substantial transition costs will, of necessity, be imposed by changing corporate filing requirements. The IRS must understand that for many (if not most taxpayers) change is disruptive and not particularly welcome, even if it is ultimately for the better. This is because corporations -- perhaps especially the large-case taxpayers that constitute the bulk of TEI's membership -- currently contend with the overwhelming reporting burdens of current law. They have acquired or developed the computer programs, the internal procedures, and the skilled personnel required to comply. They have committed the resources to cope with the current regime. Thus, although they collectively agree that corporate filing requirements can be efficaciously changed, they also know from experience that every change will impose a cost. They thus need assurance that the effect of the changes will be balanced -- not only providing the IRS with the required information in a format that makes it easier for the IRS, but also producing enduring, long-term benefits to taxpayers in terms of compliance costs.

Identification of Minimum Requirements: Toward a Financial Statement Return

In our view, the starting point for streamlining Form 1120 should be for the IRS to identify its minimum requirements in respect of tax return information and formatting. Conforming tax return filings with financial statements (e.g., as reported to the Securities and Exchange Commission) should save taxpayers considerable resources. Our inclination, therefore, is to recommend that a taxpayer's basic financial statement information be utilized to the fullest extent possible and that reclassification of data be minimized, if not eliminated altogether.

Would the development and use of such a Form 1120 FS [Financial Statement] impede the IRS's ability to identify taxpayers for audit or to conduct quality examinations? We think not, but if the IRS is to conclude ultimately that it cannot accept such a change, it makes no sense for the workgroup (and stakeholders) to develop such a proposal. Hence, we recommend that the workgroup go through Form 1120 on a line-by-line basis (if it has not done so already). It should ask the following questions:

* Is the requested information really needed and is value added by requiring its submission at the time the return is filed? For example, does it enable the processing of the return at the Service Center and the posting of necessary information to the taxpayer's account? Does it facilitate the selection of returns for examination?(1)

* Is the information already available or can it be provided in a less burdensome manner (e.g., in a format already developed for other government agencies, such as the Securities and Exchange Commission)?

We also believe that the workgroup should strive to root out of Form 1120 requests for information that is already contained in the IRS's files. For example, many of our members question the need for the taxpayer to file a Form 851 (Schedule of Affiliates) every year. They believe it would be less burdensome, and no less informative, to require the taxpayer to report only intervening changes to its affiliated group. Similarly, we see no benefit in the IRS's requiring the taxpayer to report (on Line C of page 1) its date of incorporation every year (after all, the information does not change), or to report its total assets on Line D of page 1 since total assets are reported on Line 15 of Schedule L (on page 4).(2)

Auditing the Financial Statements, Not Lines 1 through 26

The structure of Form 1120 is important, but in our mind's eye there is an even more fundamental question that must be addressed: In determining how the corporate return can be streamlined, is the IRS willing to consider significant changes not only in the information that is required to be reported, but in how the agents go about auditing compliance with the tax law? The answer should be yes, for an affirmative response holds the promise of liberating taxpayers from needless burdens and concomitantly enhancing IRS productivity.

Specifically, we believe the IRS should eliminate the reconciliation of the taxpayer's detailed general ledger to specific line items on the tax return. Too frequently, taxpayers encounter agents who spend substantial amounts of time reconciling specific line items on the general ledger to specific line items on the tax return. But what is the value-added by such a process where the company has sound, verifiable internal controls that are complemented by externally audited and certified financial statements?

We believe that to ask the question is to answer it: There is little, if any, value in requiring taxpayers to shoehorn their thousands of general ledger accounts into Lines 1 through 26 on page 1.(3) Indeed, is there any need for the line number grouping on page 1 of the return? We think not, and submit that the IRS's better large-case agents recognize this themselves: they do not use page 1 in their examinations. Stated differently, they currently do not audit the tax return i.e., Lines 1 through 26); they audit the company's financial records.(4) If the IRS acknowledged this and consequently redesigned Form 1120 to conform to financial statements, taxpayer burden could be materially reduced without diminishing the IRS's ability to ensure compliance with the tax laws.(5)

Use of Tax Return Data for Non-Examination Purposes

During our August 21 meeting, we discussed the use of information contained on Form 1120 for other than tax administration purposes -- that is to say, for purposes other than determining the company's tax liability. Specifically, members of the workgroup confirmed that much of the data reported on the tax return is sought by the Treasury Department's Office of Tax Analysis (among others), for example, to estimate the revenue effects of proposed legislative changes and for other statistical purposes. Although we acknowledge that legitimate needs may exist for such information, we believe those seeking to impose generalized reporting requirements on all corporations bear a heavy burden of demonstrating that their requests should be granted. Hence, we believe three core questions must be posed in respect of such requests:

What value is added by the information? To what use is the information put? Is that use justifiable? In this regard, we recommend that information requests should be "zero-based budgeted"; hence, OTA and the other agencies seeking information through the Form 1120 should be required to make an affirmative showing that information will advance some definite tax policy or tax administration goal, not simply that it would be "nice" to have it. With government at all levels seeking means of reducing the intrusiveness and burden of regulation, such an approach seems especially prudent.

* At what cost is the information to be secured? The greater the cost to taxpayers in securing the information (or in recasting it in the required format), the greater the need that should be demonstrated.

* Do alternative means exist of collecting the same or comparable information? Alternative means to securing desired information in a less intrusive, less burdensome manner should be explored. For example, if is it possible for OTA to secure information of comparable worth by surveying selected taxpayers, rather than imposing recordkeeping and reporting requirements on all taxpayers, then we believe such an alternative path should be taken.(6) Alternatively, consideration should be given to consolidating all requests for extraneous information in a separate schedule.

In summary, TEI believes there are real benefits to be achieved in streamlining corporate filing requirements. We consequently urge the workgroup not to permit needs (or desires) unrelated to the determination of tax liability to impede the adoption of a financial statement approach to Form 1120.

Electronic Filing Initiative

Before turning to our specific recommendations for streamlining Form 1120 (recommendations that, if adopted, would move the IRS toward a financial statement-oriented return), we offer the following brief comments on the workgroup's second objective -- supporting the planned development of corporate electronic filing systems.

TEI supports the initiative to move corporate taxpayers toward electronic filing. We were pleased to have met with IRS representatives several years ago to press for such an initiative, and encourage the workgroup to move forward on this aspect of its charter. Electronic filing by itself, however, offers no salvation to taxpayers; the key lies in streamlining the core reporting requirements (whether the information is reported on paper or electronically). Hence, the goal should not simply be to push formatting requirements down to taxpayers (from the IRS), but to reduce the formatting that must be done (or redone) in any event by migrating to a financial statement-based return -- that is to say, a simplified two-page Form 1120 that contains only summary and reconciling information on the ground that other necessary information is set forth in the taxpayer's financial statements. Once that migration is complete, corporate taxpayers will find the transition to electronic filing not only painless, but beneficial.

As a general matter, we believe that if electronic filing is going to work, the IRS needs to define its general requirements. We remain chary, however, of attempts to compel taxpayers to use one particular type of software. Indeed, we submit there would be merit in piggybacking on other electronic reports, such as those required by the Securities and Exchange Commission, which uses the so-called Edgar system.

Specifically, we note that publicly traded corporations are already filing electronically with the SEC their Annual Report, 10-K, and Proxy Statement within 90 days of their year-end. Consideration should be given to having the tax return build upon and complement these extant electronic reports. Hence, the taxpayer could supplement the SEC-electronic documents with schedules eliminating entities not included in the tax return, Schedule M-1, and required election and disclosure statements. Corporations that are not publicly traded but retain certified public accountants to prepare their financial statements (whether audited or unaudited) could have their financial statements electronically formatted (presumably by their CPAs) in accordance with SEC (and IRS) specifications. Other corporations would have to rely on commercially available software that, assuming a reasonable transition period were provided, we are confident would eventually be developed and marketed.

Specific Recommendations

TEI is pleased to offer the following recommendations on how the current corporate filing burden can be reduced. If there are common themes that run throughout our recommendations, they are, first, that the income tax return should key off of the taxpayer's financial statements and, secondly, that the IRS should not seek, on the Form 1120, information that is not necessary either to process the taxpayer's returns (and make the necessary entries to its account) or to determine whether the return should be audited. The first theme is not at all surprising given our general recommendation that the IRS develop a Form 1120 FS. The second theme merely reflects the belief that incremental changes to Form 1120 are possible that will materially reduce taxpayer burdens without impairing the IRS's ability to audit the taxpayer.(7)

1. Form 851 -- Affiliations Schedule. This form requires a substantial amount of information, especially when the taxpayer files a consolidated return with a significant number of subsidiaries, and consequently is very time consuming to complete. TEI questions whether most of the information reported on the form materially enhances the IRS agent's ability to conduct a better, or more efficient, audit of the tax return. The form should be modified to require only information that could affect the audit process; redundant and extraneous information being requested should be eliminated. Consequently, we recommend that the taxpayer be asked to attach a list of the members of its affiliated group and to provide detailed information only in respect of changes to the group since the filing of the previous year's return. Similar comments could be made about Page 3, Schedule K, Question 2.

Currently, taxpayers are required to file statements in conjunction with sections 351, 367, 368, and 1033-type transactions. We question whether the requested information is vital to the tax return itself. A summary disclosure of the transaction should suffice, with the agent requesting any additional requested information during the ensuing examination. Form 851 might be revised to seek information on acquisitions, mergers, and similar transactions, with the agreement that related information will be available on audit. A separate schedule to Form 851 could be develop to report the pertinent information for companies not included in the affiliated group (i.e., foreign corporations.).

2. Form 926 -- Return by a U.S. Transferor of Property to a Foreign Corporation, Foreign Estate or Trust, or Foreign Partnership. This form, including attachments, imposes a significant burden on taxpayers. The form could be shortened to capture only the essential information, and the amount of attachments required could be reduced or eliminated.

3. Form 1120, Page 1. We believe that Lines C (Date Incorporated) and D (Total Assets) can be eliminated since they seek information already contained in the IRS's database or, with respect to Line D, that is reported elsewhere on the return (Line 15 of Schedule L).

4. Form 1120, Schedule A -- Costs of Goods Sold and/or Operations. This schedule should be eliminated. Fewer and fewer taxpayers compute costs of goods sold (CGS) in this format, for extant cost accounting systems derive CGS directly. Since the format prescribed on Schedule A is inconsistent with the financial accounting format (as well as the format used for management accounting purposes), the burden on taxpayers of preparing Schedule A is substantial -- and unnecessary.

At a minimum, Lines 9(a) through 9(e) should be moved to Schedule K -- Other Information since they request non-numeric information. Indeed, we suggest that the IRS move all requests for non-numeric data to Schedule K.

5. Form 1120, Schedule C -- Dividends and Special Deductions. Because it only has relevance for taxpayers that operate in the environment of consolidated returns with multiple domestic and foreign affiliates, this schedule should be removed from Form 1120 and set up as a separate schedule. Concededly, the bulk of TEI members may have to complete the schedule in any event, but we believe there is merit in not "cluttering up" the basic return.

6. Form 1120, Schedule E -- Compensation of Officers. TEI questions the reason for requiring the information sought by Schedule E to be filed as part of the tax return, especially since taxpayers filing a consolidated tax return must file such a schedule for all of the officers of each company in the consolidated group. (Schedule E is also problematic for taxpayers because it involves sensitive, confidential information.) The basic issues that can be generated in respect of the information reported on Schedule E are the deductibility of compensation in excess of $1 million and the question of unreasonable compensation. The unreasonable compensation issue, however, will not necessarily be evident from the information contained in this schedule; rather, an examination will be required to ascertain whether the issue should be developed. TEI submits that the IRS can secure the information in a more efficient, summary fashion and at a more opportune time (such as during the audit).

7. Form 1120, Schedule J -- Tax Computation. This schedule should be expanded to include all information related to the tax calculation (including that currently reported on Form 3800 and on Lines 30-36 of page 1). Consolidate the entire tax calculation on one schedule rather than having tax calculations on many different schedules (e.g., Schedule J, Form 3800, and Form 5884).

8. Form 1120, Schedule L -- Balance Sheets. TEI questions whether agents use the information presented on Schedule L in their examinations of large-case (generally, publicly held) taxpayers. Rather, they rely on the taxpayer's audited financial statements. Accordingly, we believe Schedule L can be streamlined to request only summary data. Indeed, since Schedule L is based on the audited financial statements, taxpayers could simply supply the balance sheet as part of the examination. Since most taxpayers are likely filing financial statements with other government agencies (such as the SEC) in an electronic format, the IRS should coordinate the development of its own electronic filing specifications with those other agencies. Concededly, audited financial statements may include non-U.S entities that are not included in the return, but we do not believe this limitation should mandate the generation of Schedule L-type data (especially since, upon examination, the agents seem to spend little time working with the schedule but rather work directly with the general ledger in testing for nondeductible accruals and similar items). Eliminating Schedule L would remove the burden of dissecting the audited financial statements and having the tax department wait for the year-end closing adjustments, which are made at the consolidated level and then pushed back" to the pertinent entity. Moreover, if Schedule L is eliminated, there would be no need for Schedule M-2 -- Analysis of Unappropriated Retained Earnings per Books to be included with the return. Hence, to the extent a Schedule M-2 reconciliation is necessary, it can be provided at the time of audit.

9. Form 1120, Schedule M-1--Reconciliation of Income (Loss) per Books and Income per Return. We believe that this schedule should be expanded to provide additional space for more detailed reporting. Alternatively, the preprinted lines (e.g., for depreciation and tax-exempt interest) should be eliminated because they complicate the use of software packages and completion of the schedule. Indeed, we understand that currently many companies simply attached a separate schedule.

10. Forms 4562 -- Depreciation and Amortization. The requirement that taxpayers report the amount of depreciation for each type of property such as three-year property, five-year property, etc., is quite burdensome to satisfy. Much time is spent computing the numbers that relate to each type of property. Experience teaches that the IRS agents do not use this form to audit because the information is presented in such summary fashion that it is meaningless to them; hence, they conduct their examination using information derived from other sources. Is it really necessary for taxpayers to spend time accumulating the data and massaging it to fit Form 4562 if the information so presented is not really used by the agents?

11. Form 5452 -- Corporate Report of Nondividend Distributions. Many taxpayers report that this form is difficult and time consuming to fill out. What does the IRS do with this form when completed? Would anything be lost by permitting the taxpayer to do their own workpaper calculations? The tax return itself could simply ask whether there have been any nondividend distributions. When the taxpayer is audited, the taxpayer can supply the calculation supporting the nondividend distribution if so requested. Why should a taxpayer have to go through the process of filling out this form where the results have no effect on the taxpayer's taxable income?(8)

12. Form 5471 -- Information Return of U.S. Persons With Respect to Certain Foreign Corporations. Completion of this form, especially when coupled with Form 1118 -- Foreign Tax Credit-Corporations, may consume more time than anything else in preparing the tax return. Where the taxpayer has multiple foreign entities, the burden of completing Forms 5471 becomes substantial. Over the years, TEI has worked productively with the IRS to refine Form 5471, and we are pleased that many (though by no means all) of our recommended changes have been adopted. We continue to believe that the volume or format of the information requested on the form can be streamlined (including, for example, the reporting of information in functional currency) without adversely affecting the IRS's ability to identify taxpayers for audit or to conduct meaningful examinations.

We believe that there is an overlap between the information reported on Form 5471 and that reported on Form 8621 -- Return by a Shareholder of a Passive Foreign Investment Company of Qualified Electing Fund; the redundancy needs to be eliminated.

In addition, we believe there is merit in developing a consolidated Form 1 1 18, so taxpayers would not be required to complete a separate foreign tax credit form for each affiliate. Indeed, since section 1.861-8 allocations and apportionment calculations must be done on a consolidated basis, we submit that a consolidated Form 1118 would be far more helpful than the current form.

13. Form 5713 -- Tax Effect of the International Boycott Provisions. There is a significant amount of information requested on this form that duplicates information requested elsewhere (e.g., Form 5713, page 3, questions 11 and 12). In addition, the volume of information required is substantial. Is there any reason the IRS cannot require the reporting of less information and still accomplish the results desired?

14. Form 8697 -- Interest Computation Under the Look-Back Method for Completed Long-Term Contracts. This form requires a substantial amount of time to prepare, especially in comparison to the dollar amounts involved.

15. Elections.

A. TEI recommends that the IRS develop a single consolidated elections schedule (which utilizes a cheek-the-box" format), which would be accompanied by an attestation that the required supporting information is available and will be provided upon request.

B. We also believe that taxpayers should not be required to continually make elections, such as those in respect of apportionment or tax brackets, or to amortize start-up costs and organizational expenses. Rather, such elections should be required only in the year of adoption. (We recognize that, with respect to certain elections, a statutory change may be necessary to effect this recommendation.

C. The information required to be attached to the tax return with respect to the Election Pursuant to Internal Revenue Code Section 404A is time consuming to prepare and update. Does this information really need to be submitted with the tax return? If the IRS deems this information important, we submit that it is sufficient that it be supplied upon audit.

D. The mandatory election under the Dollar Approximate Separate Transaction Method (DASTM) regulations require that a voluminous amount of information be supplied with the tax return. A reduction of the required calculations (which frequently require the development of in-house programs) would be most welcome.

Conclusion

Tax Executives Institute appreciates the opportunity to submit these comments on streamlining corporate filing requirements. If you should have any questions about the Institute's position, or if we can be of further assistance, please do not hesitate to call either Robert L. Ashby, chair of TEI's IRS Administrative Affairs Committee, at [phone] or Timothy J. McCormally of the Institute's legal staff at [phone]. (1) TEI recommends, that the workgroup address whether filing requirements should vary depending on the type of return or size of company and whether the company is part of the Coordinated Examination Program. If it is clear at the time the return is being prepared and filed that it will be examined, "markers" designed to facilitate the selection of returns for audit would not be necessary. (2) Concededly, none of these items is by itself monumentally important, but the cumulative effect of a whole plethora of minor changes could well be significant. (3) As previously intimated, since most (if not all) large-case taxpayers utilize computer programs to categorize general ledger accounts for tax return purposes, the burden reduction associated with adopting TEI's Form 1120 FS recommendation may be modest in nature, obviating the mapping of new general ledger accounts to specific lines on the return but otherwise not substantially reducing return preparation burden. To the extent changes in the form are accompanied by a change in how the IRS audits the return, however, the burden reduction will be both material and enduring. Consequently, TEI believes the IRS should simultaneously pursue the twin goals of developing a financial statement-based tax return that reflects substantial incremental changes to Form 1120 and refining how its agents examine those returns. (4) Granted, information presented on the current Form 1120 is used during the examination. CEP examinations, however, principally involve a review of corporate minutes, the external audit report, the general ledger and accounts payable systems, and Schedule M-1. None of these tests pertain to "tax" data; rather, they relate to "book" information. (5) TEI recognizes that not all corporate taxpayers currently have audited financial statements, though most assuredly the corporations that account for the largest bulk of corporate income taxes do (whether or not they are publicly traded). Consequently, we believe that corporations without audited financial statements should be accorded an election either to report their income based on internally generated financial statements or to use Form 1120 (in more or less its current form). (6) The goal, of course, is to reduce the aggregate burden imposed on taxpayers. Consequently, removing the requests for extraneous information from Form 1120 should not be accompanied, tit for tat, by the issuance of independent requests for the same information, which might well prove even more burdensome. This is especially the case if the removal of the information requests from the tax return were to prompt programming changes to commercial available software that otherwise would have facilitated the taxpayer's responding to the request. (7) Several of our recommendations link the elimination of a requirement that information be provided on the return with a taxpayer commitment to make the information available upon audit. Such a "provided upon examination' approach holds much promise for reducing taxpayer burden without imperiling the IRS's ability to audit, though we do not believe it in any way vitiates a taxpayer's obligation to adequately document the positions taken on the return. Hence, we believe a taxpayer could be reasonably required to attest on the streamlined Form 1120 that the information will be available upon request. (8) If the information on Form 5452 is used in confirming the taxable income of the recipients of such nondividend distributions (rather than the payee's tax liability), consideration should be given to separating the information request from the corporate filing requirement (as is the case in respect of other information returns).