TEI Consults on Draft Information Circular for APAs.

At the invitation of the Canadian government, members of TEI's Canadian Income Tax Committee met with representatives of Canada Customs and Revenue Agency (CCRA) in Toronto, Ontario, on July 5, 2000. The purpose of the meeting was to engage in private consultations on a draft information circular relating to Advance Pricing Arrangements (APAs). Upon release, the circular will replace IC 94-4.

Following the meeting, TEI provided written comments on the policy and administrative issues raised by the draft information circular. The comments, which took the form of a 14-page letter from TEI President Betty M. Wilson to Gary Zed, Director of the Transfer Pricing and Competent Authority Division for CCRA, were submitted on September 15, 2000.

In his position with CCRA, Mr. Zed serves as the Canadian government's representative in competent authority negotiations. Mr. Zed, along with Carol A. Dunahoo, the IRS's Director of International (and U.S. competent authority representative), will jointly address TEI on Monday, October 23rd during the Institute's 55th Annual Conference in San Diego. The Canadian government anticipates releasing the revised APA circular sometime this year, but it is unclear whether the document will be released in time for TEI's Conference.

In keeping with customary practice, CCRA has not released the draft APA circular for public comment. Moreover, as a condition for participating in private consultations, TEI agreed to preserve the confidentiality of the draft circular and the discussions. As a result, the written comments will not be published in The Tax Executive. Following release of the circular, "TEI will review the public document and, if warranted, comment again," according to a joint statement by Ms. Wilson and David M. Penney, the 2000-2001 Chair of TEI's Canadian Income Tax Committee.

In addition to Mr. Penney, TEI's delegation to the July meeting with CCRA included Vincent Alicandri, Pierre M. Bocti, Marlene Gilbert, D. Paul Revell, Monika Siegmund, Debera Tomalty, and Alan Wheable. Ms. Gilbert also took the lead in compiling committee members' comments and drafting TEI's written submission.

New Administrative Assistant

Tandiwei C. Lowe became the newest member of TEI's staff when she became the Administrative Assistant to the Institute's three lawyers. Ms. Lowe is a New York native who moved to the Washington area in 1994. She came to the Institute with solid computer skills, and her previous experience includes assisting in the promotion and marketing of heavyweight boxer Riddick Bowe, which may prove invaluable in helping her manage the workload of TEI's sometimes pugnacious legal staff. Her work area features photographs of not only her daughter and husband, but also several sporting personalities. Ms. Lowe is working toward a communications degree at Trinity College.