Tax Executives Institute-large and mid-size business division-liaison meeting minutes: February 7, 2006.

On February 7, 2006, The Tax Executives Institute met with Deborah M. Nolan, Commissioner of the IRS' Large and Mid-Size Business Division, and other representatives of LMSB. TEI President Michael M. Boyle led the Institute's delegation to the meeting. Note: These minutes were prepared by Tax Executives Institute, and although reviewed by the IRS Large and Mid-Size Business Division, they have not been formally approved by the agency.

On behalf of the Large and Mid-Size Business (LMSB) Division of the Internal Revenue Service, Commissioner Deborah M. Nolan welcomed TEI President Michael P. Boyle and the other members of the delegation from Tax Executives Institute to the liaison meeting. LMSB's delegation to the liaison meeting are set forth below. TEI's delegation is listed on page 253.

1. Opening Comments

Mr. Boyle expressed his appreciation to LMSB Commissioner Nolan and other LMSB officials for meeting with TEI. He noted that TEI and LMSB do not always agree with each other, but appreciate the opportunity to discuss matters in a professional manner. Ms. Nolan expressed her appreciation for LMSB's good relationship with TEI, adding that if the two parties always agreed, the value of TEI's input would not be as great.

2. Schedule M-3

Mr. Traubenberg commended the government for the recent issuance of Notice 2006-6, which provides that the book-tax difference category of reportable transactions under Treas. Reg. 1.6011-4 is no longer necessary. As a result, he noted, taxpayers that complete Schedule M-3 and disclose their financial and tax accounting reporting differences are no longer required to file Form 8886 and separately report significant book-tax differences.

Mr. Traubenberg raised a question about the effective date of the notice, which refers to transactions occurring on or after January 6, 2006. He suggested that the IRS and Treasury Department consider making the effective date be for transactions occurring after December 31, 2005 (or, for taxpayers with 52-53 week fiscal periods, the end of the taxpayer's applicable fiscal period). He explained that as long as a taxpayer's tax period and return encompasses the effective date of the change, significant book-tax differences preceding the effective date will be disclosed on the taxpayer's return and Schedule M-3, making the filing of Forms 8886 occurring in the five-day stub period redundant.

Ms. Petronchak acknowledged that some confusion exists concerning the effective date of the notice. She explained that taxpayers filing a return after January 6, 2006, are not required to file the Form 8886. She added that the IRS will issue an FAQ soon to clarify the matter. Mr. Traubenberg thanked the IRS for its sensible approach to the issue.

Mr. Traubenberg inquired whether the information gleaned from the Schedule M-3 meets LMSB's needs, or alternatively, whether there are other initiatives under consideration to enhance disclosures, curb tax shelter activities, or promote settlement of outstanding disputes. Ms. Nolan responded that the division is still evaluating the information submitted on the returns filed to date so LMSB is not in a position to say whether changes to the current Schedule M-3 filters are warranted. When the statistical analysis is completed, LMSB will review whether the lines on Schedule M-3 should be refined and also determine whether page 4 should be added to the schedule in order to pose questions to obtain additional information that would be helpful in identifying higher-risk tax returns or transactions.

Mr. McCormally inquired whether LMSB has identified any trends that would limit the scope of examinations for certain taxpayers. Ms. Nolan emphasized that the Schedule M-3 is to be used as a "select and de-select" tool for future examinations. She noted that the IRS has already identified approximately 500 returns for further examination based on their 2005 Schedule M-3s. In addition, another 100 cases scored high for further examination under the old legacy system, but based on their Schedule M-3 did not warrant further examination. She offered to share any data from the review with TEI, adding that the division is still considering what follow-up is needed in respect of incomplete disclosures.

Ms. Nolan invited feedback from TEI concerning the process. Mr. Traubenberg said that the cost of complying with the Schedule M-3 is significant, noting that the cost to his company of outsourcing preparation of the form was approximately $100,000. He asked whether other forms, such as a Schedule M-4 or M-5, were under consideration. Ms. Nolan replied that the IRS has no plans to require additional schedules other than adding Schedule M-3 to the returns for partnerships (Form 1065), Subchapter S Corporations (Form 1120-S), life insurance companies (Form 1120-L), and property and casualty insurance companies (Form 1120-PC).

3. Sarbanes-Oxley Documentation

Ms. Twinem referred to section 404 of the Sarbanes-Oxley Act of 2002, which requires companies to document and support the tax benefits that are reflected in their financial statements. She asked whether LMSB anticipates issuing standard information document requests (IDRs) to request taxpayers' section 404 documentation.

Ms. Nolan said that the IRS is strengthening its relationship with the Securities and Exchange Commission, noting that the IRS Commissioner and SEC Chairman have met to discuss various issues. She emphasized that, because of section 6103 of the Internal Revenue Code, the discussions have not been taxpayer-specific. The tax agency is also reviewing the effect of changes to SFAS 109, Accounting for Income Taxes, on tax administration, as well as whether LMSB may be able to leverage the greater transparency prompted by Sarbanes-Oxley. In addition, LMSB has had preliminary discussions with the Office of Chief Counsel concerning whether the information in the section 404 workpapers might be useful to the audit team. She invited feedback from TEI concerning what documentation, if any, would further the IRS's goal of increased taxpayer transparency. The IRS has little experience in this area, she added.

Ms. Nall remarked that her audit team recently requested all of the company's section 404 workpapers. Believing that the voluminous information would not be helpful, she worked with the team by reviewing the scope of the section 404 workpapers with them and providing a copy of the management letter summarizing internal control items. The matter was ultimately resolved when the IRS auditors decided that the information would not be relevant to the issues under examination.

Ms. Nolan stated that it is too early to determine whether issuing a standard IDR for such documentation would be useful, adding that the IRS would not be well served by the production of massive amounts of irrelevant data. The agency wants a more practical approach. She suggested that it would be helpful for a small group of TEI members to meet with LMSB to explore the issue. The Institute agreed.

Mr. Boyle requested a status report on the IRS's requests for tax accrual workpapers. Ms. Nolan stated that the IRS continues to implement its current policy of requesting the papers only in certain limited circumstances. Mr. McCormally asked whether any summonses have been issued for the documents. Ms. Nolan said that a suit to enforce a summons may be initiated soon. Ms. Petronchak added that an IRS educational program will be held in March on the availability of public information, such as 10-Ks, to assist in audits.

4. T.D. 9229: Time for Filing Partnership Returns

Ms. Nall referred to the recent final and temporary regulations providing a simplified procedure for automatically obtaining extensions of time to file certain returns. The regulations permit taxpayers to file a single request to obtain a six-month extension of time in which to file a return. The automatic procedure applies to individuals, partnerships, real estate mortgage investment conduits, and certain trusts. The preamble to the regulations requested comments on whether the availability of a six-month extension of time to file for pass-through entities may result in an increase in the number of amended income tax returns.

Ms. Nall commended the IRS and Treasury Department for attempting to simplify the process for obtaining an extension of time. She expressed concern, however, that affording pass-through entities an automatic six-month extension of time may add to the delays in receiving the information necessary for companies to prepare their Forms 1120 (including Schedule M-3) and lead to an increase in the filing of amended returns. She added that the partnership return may contain a reportable or listed transaction, the disclosure of which must be filed with the partner's original return in order to protect the partner from failure-to-disclose penalties.

Ms. Nolan stated that the focus of the more streamlined process is on individuals, not corporations. The IRS recognizes that the procedure may cause additional burdens for corporate taxpayers. If there is an adverse effect on the completeness of returns, the IRS will review its position. She invited feedback on any problems taxpayers may encounter with the new rules.

5. Currency Initiatives

A. Compliance Assurance Process. Mr. Boyle referred to LMSB's new Compliance Assurance Process (CAP), which employs real-time issue resolution to improve overall compliance and to enhance customer service. He referred to Ms. Nolan's recent article on the program in the January-February 2006 issue of The Tax Executive, noting that it answered many questions about the process. He invited a status report on CAP.

Mr. Ungar explained that the IRS is in the process of soliciting volunteers to participate in the second year of the program. More than 20 taxpayers have been invited to participate, plus most of the taxpayers in the "class of 2005" have expressed a desire to remain in the program. A meeting of the new group was held in January.

The IRS is pleased with the results from the first year of the program. Mr. Ungar reported that of the 17 taxpayers in the program, one has already ready received a full acceptance of its 2005 return. CAP makes the relationship between the IRS and taxpayers more transparent, with taxpayers raising material issues with the audit team on a real-time basis. He noted that one taxpayer commented that, because of its willingness to share information with the IRS, other company personnel have approached the tax department with information about proposed transactions earlier in the planning process.

Mr. Ungar stated that the number of issues considered under CAP corresponded with the government's expectations. Not surprisingly, many issues were raised concerning the recent American Jobs Creation Act.

Mr. Ungar cautioned that the IRS must be careful in measuring success in respect of the CAP program. He noted that agent performance measures, such as yield, assessments, and issues raised, may not harmonize with the CAP process. The IRS must ensure that it is not missing issues and that it evaluates its agents properly. The goal of the program is not to raise a greater amount of tax, but rather to reach a resolution of issues in a shorter time period, he concluded.

Mr. Boyle asked whether the CAP taxpayers also had ongoing audits from prior years. Mr. Ungar explained that the majority had prior open years, which were assigned to a separate audit team. The IRS is satisfied with the progress being made on the audit of the intervening years, he said. CAP is resource intensive for both parties, which caused one taxpayer to withdraw from the program. He acknowledged that there are significant upfront costs, adding that the costs should decrease as the program progresses. In addition, although there was some use of the Fast Track procedures, more experience is needed to assess the involvement of Appeals or Counsel in the program.

Ms. Nolan said the use of Fast Track itself as a means of resolving issues is a big success. She added that agents have been encouraged to use the Limited Issue Focused Examination (LIFE) process to resolve issues in intervening years. Mr. Ng added that both parties have learned to marshal resources more efficiently. One useful procedure was to set milestones to resolve issues in the intervening years, he noted.

In response to a question, Mr. Ungar explained that in inviting taxpayers to participate in CAP, the IRS attempted to achieve diversity, but also took into account the taxpayer's history of compliance. As the program matures, he stated, the IRS hopes to take on the more difficult cases. We need to be conservative about expanding the program for the first few years, he added.

Ms. Tonuzi noted that Counsel is assigned to each CAP taxpayer, as well as to the audits of the intervening years, to assist in identifying issues and developing facts. Counsel are encouraged to resolve issues at their level, although for certain issues (such as section 199), they needed to seek assistance from Washington.

Ms. Nolan concluded that CAP taxpayers have identified concerns relating to the involvement of specialists and Counsel in the process. Specifically, a cultural change to instill a greater sense of urgency is necessary, she said, to ensure that issues are addressed timely.

B. Other Currency Initiatives. Ms. Nall referred to several other innovative procedures--such as the Joint Audit Planning Process, LIFE, Pre-Filing Agreements, Fast Track Mediation and Settlement, Accelerated Issue Resolution, Advance Pricing Agreements, and Early Referral to Appeals--that seek to improve the examination process and promote currency. She noted that during last year's liaison meeting, TEI expressed concern that the drive to become current at the Examination level may in some cases be pushing more cases to Appeals. At that time, however, the IRS's statistics did not show an increase in the number of issues going to Appeals. Ms. Nall asked whether any pattern has emerged concerning the number of unagreed issues and premature referrals to Appeals.

Mr. Robison reported that the Office of Appeals is not seeing an increase in the number of cases or issues. Indeed, he noted a decrease over the last decade in the number of issues going to Appeals. Appeals averages approximately 4 issues per case, compared to 20 or 25 issues several years ago. We do not expect this number to change significantly, he added.

Ms. Nolan emphasized that the number of cases at Appeals involving Coordinated Industry Case (CIC) taxpayers has increased slightly, though the number is down thus far for 2006. If the IRS is successful in identifying high-risk transactions, she added, the number of unagreed cases in Appeals may well increase. Mr. Robison noted that some concerns had been expressed that the IRS's currency initiative might result in a surge of cases in Appeals, but no such surge has materialized.

Mr. Boyle asked whether other new initiatives are under consideration. Ms. Nolan noted that the IRS is shifting more to a pre-filing environment with procedures such as PFAs and APAs. A more efficient process, which she termed "CAP-lite," may be possible. Mr. Ungar stated that the IRS has seen a growth in the use of its pre-filing initiatives, but added that the overall usage is not high. PFAs, for example, number in the hundreds, not the thousands. He invited suggestions for how the IRS could increase the use of these programs. Noting that IRS Commissioner Mark Everson will be a featured speaker at TEI's Midyear Conference in March, Mr. Boyle suggested that he address the use of the processes in his remarks.

6. Office of Appeals

A. Announcement 2005-80. Mr. Bernard referred to TEI's recent comments about the effect of Announcement 2005-80 on the independence of Appeals. (The announcement sets out concession terms for 21 transactions for which the IRS has determined the accuracy-related penalty is applicable.) He asked what specific steps are being taken to address TEI's concerns and to reaffirm the independence of Appeals.

Mr. Robison explained that Appeals continues to reach agreement in approximately 85 percent of the cases it reviews. The sustention rate has also remained stable at approximately 30 percent of proposed deficiencies. In short, he noted, Appeals continues to do business with the same outcomes as it has obtained for many years.

Mr. Robison stated that Announcement 2005-80 propounds an administrative solution for several transactions in a manner similar to the way in which issues have been resolved in the past. The announcement represents another tool to resolve issues in the tax shelter context. Taxpayers may continue to seek Appeals' review of a particular transaction and Appeals will complete an independent review of the facts and circumstances, but there is no assurance that the review will produce a different outcome. (He acknowledged that this is always the case.)

Mr. Robison pointed out that 80-90 percent of taxpayers involved in specific listed transactions have accepted the settlement option. He said that his office's experience in respect of other listed transactions is that while in some cases Appeals may reach a better resolution for the taxpayer, in many others, the outcome is less favorable than if the taxpayer had accepted the original settlement offer. The selection of the settlement terms offered in Announcement 2005-80 is one more variable the taxpayer must consider in determining whether to pursue an issue in Appeals. He added that the announcement offered a reduction in the interest rate of an item that Appeals is not permitted to compromise.

Mr. Robison concluded that Appeals' traditional role in resolving issues has not changed. Some of the new tools, such as Fast Track Settlement, however, may make taxpayers uncomfortable. He suggested that he follow up with Mr. McCormally concerning how best to communicate Appeals' mission--and the circumscribed effect of Announcement 2005-80--to TEI's members.

B. RAPID Appeals. Ms. Nall said that she and several other TEI members participated in an Appeals training program in Dallas in the summer of 2005 at which a proposal for a new RAPID Appeals process was discussed. Among the requirements of the RAPID Appeals were that (i) Appeals accept only cases that were "fit for use," i.e., fully developed; (ii) one issue be resolved in one conference; and (iii) Examination be involved in all Appeals conferences. Ms. Nall said that several features of the program give pause because they might undermine the prohibition on ex parte communication between Appeals and Examination, reduce access to the technical advice memorandum process, or limit the scope of issues considered by Appeals.

Mr. Robison explained that the "fit for use" concept has been employed by Appeals for more than 70 years. For the Appeals Division to fulfill its role, it must understand both the government's and taxpayer's positions. Where a case or issue is not fully developed, it must be sent back to the field for additional review. Appeals does not send many cases back to the Examination Division, but it must do so in some challenging cases. The notion of resolving "one issue in one conference," he said, is a new concept that Appeals is attempting to implement. The Fast Track process demonstrates that where both parties focus on a single issue the resolution of that issue is generally quicker since both parties are well prepared for the discussion. Ms. Nall suggested that one approach may not fit all cases, especially where multiple issues are intertwined and difficult to separate. Mr. Robison said that limiting discussion to one issue per conference is not mandatory; Appeals is simply attempting to incorporate its Fast Track experience into its traditional process. Next, he said, the ban on "ex parte" communications is alive and well. Appeals sometimes benefits from input from the Examination team and any time their input is solicited the taxpayer is invited to participate. The notion that Examination teams would be present in every meeting in every case, though, is a misunderstanding.

7. Mandated E-filing

A. Prospect for Phased-In Implementation. Mr. Bernard noted that large taxpayers will be required to e-file their corporate Form 1120s this year for the first time. He said there is considerable concern in the corporate tax community about (1) the readiness of the software vendors to supply workable products and (2) whether taxpayers have done their homework sufficiently to implement the software. The e-filing mandate, he said, came on the heels of the documentation requirements of section 404 of Sarbanes-Oxley as well as the Schedule M-3 reporting changes and tax department resources have been stretched to the limit. As a result, TEI continues to recommend that e-filing be voluntary for 2006. Ms. Bauer added that a standard term in the license agreement from her company's software vendor is a waiver of liability from damages if the return is not considered properly transmitted or filed. The vendor's insistence on the limitation makes her, and likely other tax directors using the software, concerned about its reliability. She noted that one of the Big-4 accounting firms estimates that the e-filing requirement will require corporate taxpayers to increase the resources devoted to the preparation of their returns by 30 percent.

Mr. Hedgpeth reported on a recent meeting with representatives of the AICPA and the software vendors. He noted that two companies--Vertex and Tax Technologies--are developing aggregation programs to facilitate combining output from different software programs into a single XML file suitable for e-filing, though they are not currently available. In addition, the four principal software vendors for the corporate community are completing the testing of their software updates and should release them by the end of the month. All the programs will permit taxpayers to view the XML data in tax return format prior to filing. The IRS will provide additional style sheets as the 2005 forms are finalized. He noted that agents will be able to view taxpayer's returns on their laptops soon after the returns are filed. The Office of Tax Shelter Analysis, however, will not be able to view the Forms 8886 until some issues are addressed. By next year, he said, the system might permit the IRS to eliminate the requirement to file a duplicate copy of Form 8886 with OTSA.

B. Additional Guidance on Waivers. Mr. Hedgpeth next explained that the Office of Chief Counsel is developing additional language providing guidance for waivers in four areas: (1) new entities entering a taxpayer's return as a result of merger and acquisition activity; (2) the effect of net operating loss carrybacks; (3) Chapter 7 bankruptcy proceedings; and (4) final entity tax returns. He said the additional guidance would likely be released in two to three weeks.

Mr. Bernard inquired whether the IRS has considered issuing guidance on waivers where a taxpayer makes a concerted effort to e-file its return, but determines at the 11th hour that the software will not transmit a correct return. Mr. Hedgpeth said that, if taxpayers can demonstrate that they have been diligent in their efforts to comply with the mandate, the IRS will likely be reasonable in granting waivers. One issue affecting that determination is when the software becomes available and whether a taxpayer takes reasonable steps to implement it. Mr. Boyle noted that the software vendors may be telling the IRS one thing about their software's readiness, but telling taxpayers something else. Mr. Bernard said that as members become aware of the issue, they take it very seriously and TEI has been very active in spreading the word through educational sessions, articles in The Tax Executive, and monthly email updates. Mr. Hedgpeth said that the Big-4 accounting firms are undertaking weekly updates in order to get the word out to all their employees and clients.

Mr. McCormally noted that a recent press report indicated that 10 corporate taxpayers subject to the e-filing mandate had filed their returns electronically. He said that there is some skepticism among TEI members about the relevance of that fact to their situations because the vendors have not released their software updates for 2005 tax returns. In addition, the IRS might wish to consider its communications strategy in respect of e-filing success stories because there is a wide divergence in the complexity of taxpayers' returns. Ms. Nolan acknowledged that the successfully e-filed returns have been generated by smaller taxpayers and the IRS recognizes that there are significant risks involved in the transition to e-filing of returns. Among the risks is testing the software upon its release by the vendors. Mr. McCormally said that TEI is ready to convey any information to its members about e-filing that the IRS wishes to share.

Mr. Dicker asked whether the IRS has developed the capability for analyzing the e-filed tax return information. Ms. Nolan said the highest priority is to move the return data to the agents as quickly as possible. The software tools to convert the taxpayer's XML files into analytical reports, she said, are being developed on a parallel track with the filing system. Agents will be able to begin their pre-audit planning and analysis shortly after returns are filed. Mr. Dicker inquired whether the IRS has projected the costs and benefits of e-filing. Ms. Nolan said that a return-on-investment analysis has been performed. A number of metrics, such as data keypunching time, errors in transcribing data from paper to electronic forms, and the timeliness of data availability, were included in the analysis. Increased taxpayer burdens, she concluded, was also one of the factors considered.

C. Registration Process. Mr. Hedgpeth reported that he and several other IRS representatives participated in a webcast sponsored by a Big-4 accounting firm that walked participants through the e-filing registration process. A PowerPoint slide presentation developed for the webcast will be made available on the IRS website. In addition, the instructions for large corporations e-filing their own returns have been re-written and should be issued in the coming weeks.

D. Data Warehousing. Mr. Hedgpeth reported that the data-warehousing initiative (where the IRS would store all tax information related to a particular taxpayer in a single repository) is not on a fast track because there is no funding for the project. He said that a higher priority project was the FIRE (Filing Information Returns Electronically) project, which will permit the filing of all Forms 1098 and 1099 in the Martinsburg, West Virginia Service Center. The IRS and taxpayers will benefit from the consolidation of the 1098 and 1099 reporting.

8. International Tax Issues

A. Advance Pricing Agreements. Ms. Norton noted that TEI had testified at an IRS hearing last February on the Advance Pricing Agreement (APA) program. In the wake of that hearing, the IRS issued new case management procedures that are designed to speed up the process and increase consistency. In addition, the IRS has issued Rev. Proc. 2006-9, which updates the procedures for obtaining an APA. Ms. Norton also noted that the Senate Finance Committee had held a hearing on the APA program. She requested an update on changes to the APA program and the status of the Senate Finance Committee's report. Mr. Ng said that he did not know when the Senate Finance Committee might issue its report. As for program changes, he said that the Office of Chief Counsel has hired additional staff to support the APA program. In addition, the new process guidelines were issued in order to address the comments made at the IRS hearing. Mr. Ng reported that the inventory of APA cases is stable, averaging between 50 and 60 cases on hand at any one time. The competent authority process is being reviewed for possible improvements, he said, because it requires nearly 40 months to obtain a bilateral APA.

B. Cost Sharing Arrangements. Ms Lucchesi noted that there are a significant number of cases in competent authority discussions involving buy-in payments in cost sharing arrangements. She inquired whether the IRS has studied whether there are common issues that might be susceptible to the development of settlement guidelines in order to resolve cases more quickly. Mr. Ng said the IRS has undertaken a review of the cases, but it will not be easy to develop or issue guidance, he said. The IRS recently refocused the project and is gathering more quantitative data in order to develop a baseline of issues, dollar amounts in controversy, and settlements reached. He said that taxpayers should anticipate more field activity on cost sharing arrangements. In addressing cases in open tax years, the IRS will, despite the differences with the recently proposed regulations, strive to apply the current regulations. Mr. Robison added that Appeals will not be developing an Appeals Settlement Guideline to address cost sharing arrangements because one size will not fit all such arrangements.

C. Globalization. Ms. Norton noted that several TEI members met with the IRS in September 2005 to discuss the business drivers of globalization and the strategies companies have developed in response. She invited a status report on the IRS initiative. Ms. Nolan said that the purpose of the initiative is to gather information and gain an understanding of how businesses are responding to the effects of globalization. One of the Commissioner's priorities, she said, is to build a tax administration system that reflects and adapts to individuals' and business' behavior in a global environment. Just as businesses restructure to respond to global challenges, the IRS may require a different organizational structure to address globalization. The goal is to focus on high-risk international compliance areas. Mr. Ng added that there will be increased efforts to coordinate issues with other tax authorities and enhance the efficiency of the exchange of information process under tax treaties.

D. Cross-Licensing Agreements. Mr. Boyle inquired whether the IRS is considering changing its treatment of cross-licensing agreements (CLAs). Taxpayers generally follow the treatment of CLAs set forth in a longstanding Technical Advice Memorandum. A change in the treatment of CLAs would be extremely unsettling. Mr. Ng said that the issue was raised by an examination team and that LMSB is working with the Office of Chief Counsel to develop the IRS's technical position. He said that LMSB is not interested in opening a lot of cases for Appeals to resolve. Once a sound technical position is developed, the IRS will be in a position to move forward on the case and others. [Note: On March 15, 2006, the IRS issued Notice 2006-34 soliciting comments about various issues in respect of cross-license agreements.]

9. Conclusion

Mr. Boyle thanked Ms. Nolan and the LMSB representatives for their participation in the meeting. Ms. Nolan thanked TEI for its preparation for the meeting.

LMSB Delegation

Deborah M. Nolan

LMSB Commissioner

David B. Robison

Chief, Appeals

Drita Tonuzi

LMSB Deputy Division Counsel

Bruce B. Ungar

LMSB Deputy Commissioner

Frank Y. Ng

Acting Director, International

Elvin T. Hedgpeth

Deputy Director, International

Kathy K. Petronchak

Director, Pre-Filing & Technical Guidance

Keith Walker

Manager, Human Capital Management

Christopher Johnson

Director, LMSB Communications & Liaison