Comments on tax provisions of the Budget Reconciliation Act of 1989.
October 6, 1989
On October 6, 1989, Tax Executives Institute submitted the following comments on the tax provisions of the Budget Reconciliation Act (H.R. 3299) to the House Committee on Ways and Means, the Senate Committee on Finance, and the House and Senate Budget Committees. Copies of the submission, which took the form of a letter from TEI President William M. Burk, were also provided to the members of those congressional committees. Preparation of the Institute's comments on the tax bill was coordinated by the Institute's Federal and International Tax Committees, whose respective chairs are Lester D. Ezrati and Bernard J. Jerlstrom.
On behalf of Tax Executives Institute, I am pleased to submit the following comments on the tax provisions of the pending Budget Reconciliation Act of 1989. The proposals referred to in this letter are contained in title XI (Revenue Reconciliation Act of 1989) of H.R. 3299, which the House of Representatives approved on October 5, 1989. Where appropriate, cross-references will be made to the proposals approved or under consideration by the Senate Committee on Finance.
Scope of These Comments
Certain revenue provisions in the Budget Reconciliation Act, of course, have been the subject of substantial comment and debate by Congress and the Administration, the tax community, and the public at large. Most notable among these are the proposals to reestablish a capital gains differential, to expand the Internal Revenue Code's individual retirement account (IRA) provisions, and to address the mind-numbing complexity of section 89's nondiscrimination rules in respect of certain employee benefit plans.
TEI applauds efforts to adequately address the tax law's proper role in encouraging capital formation and savings and in minimizing compliance burdens spawned by section 89. In these comments, however, we focus on other provisions of the legislation that, while perhaps not garnering a substantial amount of public attention, merit considerable attention. As is the Institute's custom, we devote considerable attention to the "administrability" of certain provisions as well as to provisions that implicate long-standing tax law principles or international norms. We respectfully submit that the tenor and urgency of the current debate over section 89 in particular underscore the importance of addressing administrative and compliance concerns before legislation is enacted.
Corporate Alternative Minimum Tax
Sections 11611 and 11612 of the House Bill would amend the corporate alternative minimum tax (AMT) provisions of the Internal Revenue Code to address several administrative issues raised by current law. The House provisions do not address all the problems with the corporate AMT, but their enactment would ameliorate the harshest compliance burdens otherwise posed by current law. Consequently, TEI recommends that the corporate AMT provisions be enacted.
There can be no doubt that the AMT provisions of current law are unduly complex. Such complexity and the associated compliance burdens will be exacerbated by the mandated 1990 switch from current law's "book income" adjustment to an "adjusted current earnings (ACE)" concept. The turbidity of the ACE adjustment is compounded by tangled limitations which rely on "book deductions" for depreciation and depletion. The enactment of corrective legislation would be consistent with one of the original goals of tax reform: simplification.
Although legitimate tax policy and technical concerns remain about the legislation (as well as about the AMT in general), TEI believes there can be no serious doubt that some corrective legislation should be enacted before the ACE provisions go into effect. The House Bill would streamline the structure of the AMT provisions for 1990 and subsequent years, thereby reducing compliance burdens. We especially endorse the deletion of references to the book income treatment of certain items (the so-called book income "backstop") and the removal of related onerous depreciation computations. Unfortunately, the House Bill does not address the unanticipated $3.5 billion "windfall" that the Treasury has acknowledged as attendant to the switch to ACE -- and the negative implications that it has for the overall competitive posture of U.S. business.
Civil Penalty Reform
Sections 11701-11715 of the House Bill, which is captioned the Improved Penalty Administration and Compliance Tax Act, would amend the civil penalty provisions of the Internal Revenue Code. (The Senate Finance Committee has approved similar provisions.)
TEI strongly supports enactment of the penalty reform provisions. We believe the House Bill represents a definite improvement over current law, and although we believe some refinements are necessary, we are convinced that it represents a long and much needed step forward. We submit, moreover, that the penalty reform package can be significantly improved by addressing the following three points.
1. Clarification of "Reasonable Cause" and "Good Faith" Standards
Under proposed new section 6664(c)(1) of the Code, no penalty will be imposed if the taxpayer acts in good faith and with reasonable cause. TEI supports the enactment of section 6664(c)(1) and strongly recommends that the Conference Report include the following example of what constitutes reasonable cause for purposes of filing information returns and payee statements, as well as for purposes of the Code's delinquency and substantial understatement penalties:
Reasonable cause will be
deemed to exist where (i) a
reasonable business procedures to
ensure compliance with its
obligation, and (ii) the
taxpayer makes a good faith
effort to comply with those
Additionally, the Committee Report should confirm that in the case of large companies, the reasonable cause and good faith standards can be satisfied without requiring the taxpayer to discover all the tax law issues that may exist in respect of its return. Moreover, the Committee Report should state that, in determining whether a corporate taxpayer has exercised good faith, the inquiry should be directed to those persons within the company who have tax responsibility or such outside tax advisers as the company may retain. Thus, the action of a non-tax responsible employee that results in an error in the corporation's tax return should not impugn the good faith of the corporation, absent knowledge by those persons charged with tax responsibility.
2. Substantial Understatement Penalty: Reliance on "Secretarial List"
Section 11721 of the House Bill (new section 6662(d)(1)(D) of the Code) would require the Secretary of the Treasury (or his designate) to prescribe a list of positions affecting a significant number of taxpayers for which the Secretary believes there is not substantial authority. TEI recommends that taxpayers be accorded the right to rely on the so-called Secretarial list.
TEI understands that the IRS opposes the proposal to accord taxpayers the right to rely on the Secretarial list. We submit, however, such a proposal represents an opportunity for Congress and the IRS to underscore the shared responsibility that tax administrators, taxpayers, and tax advisers have in maintaining a viable self-assessment tax system. By requiring the IRS to publish a list of those current tax issues with respect to which "gamesmanship" is suspected and with respect to which the IRS believes there is no substantial authority, taxpayers and their advisers would be placed on notice of those provisions to which they should devote special attention.
3. Corporate Estimated Tax Penalty
The House Bill does not address the Internal Revenue Code's corporate estimated tax penalty for those large corporations with taxable income of more than $1 million in any of the preceding three years. TEI submits that current law effectively requires such corporations to overpay their estimated taxes, without the benefit of interest, in order to avoid an underpayment penalty under section 6655. This Hobson's choice does not confront other taxpayers because they may generally avoid the section 6655 penalty by availing themselves of a statutory safe harbor.
TEI recommends that the House Bill be amended to address this particularly odious and unfair situation. Specifically, we recommend enactment of an estimated tax safe harbor for large corporations -- for example, one based on 120 percent of the average of a taxpayer's tax liability in the preceding three years (after taking into account credits).
Alternatively, the Code's interest-on-overpayment rules could be amended to provide for the payment of interest in respect of overpayments. A less desirable approach would be for Congress to instruct the Treasury Department to conduct a study of the need for corporate estimated tax relief for large taxpayers.
Educational Assistance Payments
Section 11101 of the House Bill would retroactively extend section 127 of the Code, which excludes from taxation employer-provided educational assistance for non-graduate level courses. Under the House Bill, section 127 would expire for taxable years beginning after December 31, 1991. (The Senate Finance Committee has approved a similar provision.)
Since its enactment in 1978, section 127's income exclusion has expired and been extended three times (twice retroactively). The uncertainty and confusion created by the "sunsetting" of the exclusion diminishes the incentive effect of the provision and spawns substantial administrative burdens. For example, employers have been required to design and implement programs to tax and withhold upon the value of employer-provided assistance only to have to modify (or undo completely) those programs on an after-the-fact basis. Employees, too, have been subject to confusion and hardship.
In order to minimize the administrative and compliance burdens associated with temporary extensions of section 127, TEI recommends that any extension of the employer-provided educational assistance provision should be permanent.
Research Tax Credit
Section 11113 of the House Bill would make the Code's research and experimentation tax credit permanent and would also make several modifications to the provision. (The Senate Finance Committee has approved similar provisions.)
TEI strongly supports the decision to make the research credit permanent because of the administrative difficulties, as well as the adverse incentive effect, that a mere temporary extension of the credit would bring. Planning for research and experimental expenditures is, almost without exception, a multi-year effort by taxpayers and the enactment of a permanent credit would provide certainty and consistency in that process. We also believe a permanent credit will operate as a more effective incentive than the temporary credit which has been in effect since 1981.(1)
The House Bill would amend section 174(e) of the Code to provide that a deduction for research expenditures will be allowed "only to the extent that the amount thereof is reasonable under the circumstances." Although the House Report states that the standard is aimed only at disguised dividends, loans, or gifts, the House Bill itself contains no such limitation. TEI is concerned that the statutory provision could lead to increased conflicts and litigation between taxpayers and the IRS.(2)
The "reasonableness" of any expenditure may always be subject to conflict, but we submit that such a standard creates particular difficulties in the research area. What may seem to be a promising path at the beginning of a research project may come to an abrupt dead-end with no quantifiable results. By their very nature, many such expenditures do not result in a new product or process, and in hindsight may appear to others to be unreasonable. To the taxpayer, however, the search for a new product or process has been narrowed or the pool of useful knowledge has been otherwise increased.
Taxpayers should not be placed in the position of proving that each and every step in a research project is warranted or unwarranted; such a requirement cannot help but inhibit the very research the credit is intended to encourage. We fear that the reasonableness limitation will lead to a greater administrative burden on taxpayers who may have to prove not only that the expenditures are for qualified research, but also that the expenditures are reasonable. Since the IRS has the ample authority to attack disguised dividends or other compensation as sham transactions, the "reasonableness" provision is unnecessary and should be deleted.
Treatment of Foreign Research and Experimental Expenditures
Section 11406 of the House Bill would require foreign research and experimental (R&E) expenditures, which are currently deductible under section 174 of the Code, to be capitalized and deducted ratably over a minimum of 60 months. TEI opposes the amortization provision as ill-conceived and we recommend its deletion from the legislation.(3)
The House Report seeks to justify the amortization provision by stating that "it is not appropriate to permit expensing under section 174 of expenditures incurred with respect to research or experimental activities conducted outside the United States. The tax benefits provided by the Code to encourage research activities should be targeted to, and seek to encourage, research performed within the United States." TEI strongly supports the encouragement of research activities within the United States. Thus, we believe that section 11114 of the House Bill (relating to the allocation of research expenditures under section 861) strikes a proper balance between that goal and basic tax principles.
We submit, however, that the tax code must give due deference both to the unique nature of research expenditures and to economic reality. Stated simply, research costs cannot be equated with those costs that are currently subject to amortization and depreciation under the Code (such as expenditures for buildings and other tangible property). Rather, they are sui generis: research is an inherently risky, ongoing process, and it cannot be assumed that a taxpayer will recover a specific benefit from a particular research activity.
From an economic standpoint, too, it is clear research expenditures -- including those incurred in respect of foreign research -- should remain currently deductible. U.S. companies operate in an international marketplace, and research must be conducted both at home and abroad if those companies are to remain internationally competitive.
Virtually all major industrialized countries allow a current deduction for research costs. The amortization proposal, therefore, could be at variance with international tax norms and could invite retaliation by other countries for research conducted in the United States. We also suggest that the proposal might contravene free-trade agreements with respect to research conducted in Canada and Israel.
In addition, the amortization proposal could effectively impair the ability of multinational companies to use cost-sharing agreements and could well be counterproductive by encouraging research to be conducted abroad. Under a cost-sharing arrangement, coordinated research is conducted in the United States and abroad. From an administrative viewpoint, these agreements benefit the IRS as well as taxpayers by providing certainty and minimizing audit disputes. If research costs cannot be deducted currently in the United States, however, U.S. companies may well forgo participation in foreign cost-sharing or other research arrangements; thus, foreign corporations will perform the research overseas (for which they will receive a current deduction) and then license the technology to the U.S. subsidiary in return for a royalty that would be currently deductible for U.S. tax purposes. Thus, by requiring the U.S. portion of the research to be amortized, the House Bill would discourage U.S. participation in research activities and impair the development of research capabilities by U.S. companies.
In summary, TEI believes that the amortization provision is an ill-conceived proposal that could regrettably compel companies to conduct research activities abroad. We recommend its deletion from the bill.
Enforceability of Section 482
Section 11403 of the House Bill would impose new recordkeeping requirements on U.S. subsidiaries of foreign corporations and would increase the penalties for non-compliance by 1,000 percent. The House Report states that the purpose of the proposal is to improve enforcement of section 482 of the Internal Revenue Code (which requires related entities to conduct transactions at arm's length). (The Senate Finance Committee has approved similar provisions.)
TEI submits that the need for additional legislation to enforce section 482 has not been established. Section 6038A of the Code currently requires certain foreign-owned U.S. corporations to furnish certain information (including related-party transactions) upon request. Similarly, section 982 of the Code denies a taxpayer the right to introduce foreign-based documentation as evidence if the taxpayer has failed to timely comply with a document request. In addition, income tax treaties with approximately 35 countries provide another mechanism for obtaining information from foreign parents.
In other words, the IRS has ample tools with which to enforce the tax laws in respect of foreign corporations and the U.S. subsidiaries of foreign-controlled corporate groups. The House Report cites no example where the IRS's enforcement efforts have been hampered. This provision constitutes overkill. In the absence of any evidence showing that current law has proven inadequate, TEI opposes the imposition of additional and onerous documentation requirements on U.S. corporations.(4)
TEI also protests the substantial increase in penalties proposed by section 11403. The proposal to expand the scope and dramatically increase the amount of the penalties imposed under section 6038A of the Code is not part of subtitle G of title XI of the House Bill (the Improved Penalty Administration and Compliance Act). Thus, it did not arise from the systematic review of the Code's penalty provisions by the tax-writing committees. Rather, the section 6038A proposal seems to portend a return to the helter-skelter ("business as usual") enactment of, or increases in, penalties without regard to their efficacy. Quite simply, at a time when Congress is on the verge of making commendable progress to simplify and make rational the Code's penalty provisions, targeting one issue for special enforcement is unwarranted and ill-advised.
Conformity of Taxable Years
Section 11401 of the House Bill would require a controlled foreign corporation (CFC) and a foreign personal holding company (FPHC) to adopt the same taxable year as the majority of its U.S. shareholders. The provision would generally be effective for taxable years beginning after July 10, 1989. (The Senate Finance Committee has approved a similar provision.)
TEI opposes the CFC/FPHC conformity provision and recommends its deletion from the bill. The House Bill would ignore the valid business reasons for U.S. corporations and their foreign affiliates having different taxable years and impose a hard and fast rule that creates inequities. A foreign subsidiary is often organized with a fiscal year-end different from the taxable year-end of its U.S. parent in order to enable the subsidiary to close its books and transmit its financial information to the parent in a timely fashion for preparation of consolidated financial statements for the year. This orderly process would not be available if the House provision is enacted.
Moreover, several foreign jurisdictions (e.g., Portugal, Brazil, Colombia, and Ecuador) require corporations to conduct business on a calendar-year basis. Requiring CFCs and FHPCs operating in those countries to adopt a different year-end for U.S. tax purposes would entail additional bookkeeping costs. Indeed, the cost of dual closings (one for financial statement purposes and one for U.S. tax purposes), as well as the difficulty inherent in reconciling the different year-ends, would no doubt exceed any revenues flowing to the fisc from the proposal.(5) One measure of the proposal's complexity is the nearly six pages that the House Report devotes to explaining it. Another measure is the broad delegation of authority to the Treasury Department to issue regulations implementing the provision.
The House Report suggests that the CFC/FPHC conformity rule is necessary to prevent the "improper deferral of income to U.S. shareholders of controlled foreign corporations and foreign personal holding companies." We submit, however, that any perceived abuses could be more than adequately addressed with a more targeted provision. At a minimum, the statute should permit a CFC's (or FPHC's) fiscal year to end within one month of its U.S. shareholders' year-end. A one-month differential would ameliorate the administrative burdens spawned by the proposal without permitting any perceived "improper deferral of income."(6)
For the foregoing reasons, TEI recommends the rejection of the proposal. We further recommend, that if the CFC/FPHC conformity rule is enacted, a majority U.S. shareholder should be permitted to elect the application of the provision to its first taxable year ending after July 10, 1989. (As drafted, the effective date is keyed to the CFC's or FPHC's taxable year.) This would enable taxpayers to conform their taxable years before the mandatory effective date without filing a request for change of accounting period. The earlier automatic consent to a change in taxable years would also ease the administrative burden on the IRS which must process such requests.
Stock Gains of Certain Foreign Investors
Section 11404 of the House Bill would tax the gain realized by foreign persons on the disposition of stock in U.S. corporations. The provision would apply to shareholders who own more than 10 percent of the stock of a U.S. corporation. The tax would be collected through withholding. TEI opposes the proposal because it would violate existing treaties, alter long-standing principles of U.S. tax law concerning the treatment of non-U.S. persons, and needlessly complicate the tax law.
The House Report avers that the proposal is not intended "to impose a penalty on foreign investors" who are substantial stockholders in U.S. corporations or "to discourage foreign investors from making substantial direct investments in the United States." We submit, however, that the House Bill would operate to reduce the attractiveness of foreign investment in the United States. No sound tax policy or economic reason exists to tax the stock gains of foreign investors merely because the property sold is stock in a U.S. company. What is more, the proposal would be contrary to the U.S. Model Income Tax Treaty, as well as the OECD Model Treaty. It would also breach many extant tax treaties between the United States and our trading partners.
The House Bill would suspend the application of the proposal with respect to treaty countries until July 10, 1992, in order to facilitate the Treasury Department's renegotiation of applicable treaty provisions. Such a renegotiation period, however, will not substantially diminish the negative effect this proposal would have on our relations with treaty partners. Retaliation -- the enactment of reciprocal provisions -- is a very real threat. Indeed, the advancement of such a proposal by one of our trading partners would bring howls of protest from the Treasury Department and, it would be hoped, from Congress itself. The estimated revenue effect ($5 million annually for five years) is clearly not substantial enough to warrant such an international upheaval.
Issues of tax policy and international comity aside, the proposal would add yet another layer of administrative complexity to the already intricate corporate tax scheme. Unlike the typical sale under the Foreign Investment in Real Property Tax Act (FIRPTA), the purchaser of stock subject to the proposal -- the party required to collect the withholding tax -- may not be a U.S. resident (nor would the property necessarily be physically located in the United States). If the buyer and seller are both non-U.S. residents, however, there is no compulsion on the purchaser to withhold the tax. The result of the proposal may well be to impose another onerous administrative burden on U.S. corporations as the transfer agent.
In summary, the proposal to tax gains of foreigners on the sale of U.S. company stock is ill-conceived from both a policy and administrative standpoint. It should be deleted from the legislation.
Interest Payments to Related Parties
Section 11210 of the House Bill would limit deductions for interest paid by a U.S. taxpayer to a related foreign person who is not subject to U.S. income taxation on such payments. The bill would define such a foreign person (typically, a foreign parent) as "tax exempt" where the payments are exempt from U.S. tax under the applicable tax treaty even though the foreign person is subject to tax on the interest payments in its country of residence. The House Report states that the provision is necessary to prevent "earnings stripping."
TEI opposes the enactment of the so-called earnings stripping provision. The provision would gerrymander the tax system to fit the seemingly transitory and phantasmal needs of the IRS and lacks a sound policy basis or credibility. The measure should be deleted.
The House Bill stands as a violation of an emerging principle of international taxation that only the country of residence of the taxpayer should tax interest income; the country of source should forgo taxation.(7) This tax policy is reflected in the U.S. Model Income Tax Treaty and the OECD Model Income Tax Treaty, as well as in various treaties with our trading partners. Enactment of the earnings stripping provision would also constitute a breach of the non-discrimination provisions of the U.S. Model Treaty, the OECD Model Treaty, and most bilateral tax treaties. Under the non-discrimination principle, domestic entities must be treated equally, without regard to whether they are owned by domestic or foreign shareholders.
TEI submits that any abuse in this area can be adequately addressed under existing provisions of the Code. Specifically, section 482 accords the IRS broad authority to reallocate revenue and expenses among related parties to clearly reflect income. Section 385 similarly allows the IRS to effect a restructuring with respect to debt and equity. These provisions are equally suited to combat any "earnings stripping" problems in the international arena without penalizing legitimate business operations.
Increase in Dollar Threshold for Joint Committee Review
Under section 6405 of the Code, no refund or credit of any income, estate, gift, or other specified taxes in excess of $200,000 may be made until 30 days after the IRS submits a report in respect of the refund or credit to the Joint Committee on Taxation. Section 11653 of the House Bill would increase the Joint Committee review threshold to $1 million. (The Senate Finance Committee has approved a similar provision.)
TEI has long supported increasing the section 6405 jurisdictional amount to $1 million. The current $200,000 threshold was set by Congress in the Tax Reform Act of 1976. (The threshold had previously been $100,000.) We submit that an increase in the threshold is necessary to reflect the effects of inflation during the intervening 13 years and that the increase would not impair the ability of the Joint Committee to monitor problems in the administration of the tax laws. Such an increase would accelerate the issuance of refunds to many taxpayers and would also permit both taxpayers and the IRS to close out prior years on a more expeditious basis. In addition, increasing the jurisdictional amount will prevent the Joint Committee staff from being overburdened with refund cases.
(1)Section 11114 of the House Bill would add new section 864(f) to the Code and make permanent the research and experimental expense allocation rules that were contained in the Technical and Miscellaneous Revenue Act of 1988. The Senate Finance Committee has approved a similar proposal but provided that it would apply only with respect to taxable years beginning after August 1, 1989, and on or before August 1, 1991. TEI strongly supports the enactment of a permanent solution to the allocation and apportionment of research and experimental expenditures and, thus, urges adoption of the House provision. (2)Our concerned is heightened, moreover, by the omission of the explanatory footnote in the staff description of the identical provision approved by the Senate Committee on Finance. (3)As originally drafted, the amortization of R&E expenses would have begun in the month in which the taxpayer first realized the benefits from the research -- an unworkable and administratively cumbersome requirement that would have led to innumerable disputes between taxpayers and the IRS. TEI commends the House for recognizing the problems inherent with the realization provision, but submits its deletion does not make a silk purse out of a sow's ear -- i.e., the basic R&E amortization proposal. (4)TEI is also concerned that enactment of the section 482 enforcement proposal could lead to the passage of reciprocal provisions in other jurisdictions. Such foreign legislation could require U.S. taxpayers to maintain separate and complete books of account in each country in which any of the company's affiliates conduct business. The compliance burdens posed by such a requirement would be enormous and could well impair the ability of U.S. companies to compete effectively abroad. (5)In addition, a mandated change of year-end could well result in the loss of certain tax benefits (such as loss carryovers or carrybacks) in foreign countries or an increase in local taxes. (6)The provision approved by the Senate Finance Committee would permit a one-month differential. (7)When a similar provision was considered as part of both the Tax Reform Act of 1986 and the tax provisions of the Omnibus Budget Reconciliation Act of 1987, the result was bitter opposition by foreign governments, which threatened retaliation. The Treasury Department also opposed the measure. There are indications that the enactment of the provision as part of the 1989 legislation would prompt similar protests and the passage of retaliatory measures.
PHOTO : The pipes and drums lend a festive air to the opening of TEI's 44th Annual Conference.
PHOTO : Paul H. Frankel, recipient of the President's Award in recognition of his long service to
PHOTO : the Institute and the state tax community in general, poses with his wife, Dee.
PHOTO : Founder and first President of the Harrisburg Chapter Joe Cottonaro accepts the chapter's
PHOTO : charter and congratulations from Institute President Bill Burk.
PHOTO : (left to right) TEI Executive Director Tom Kerester, Neil Wissing of the Seattle Chapter,
PHOTO : TEI President Bill Burk, and Rob Leonard, Chief Counsel and Staff Director of the House
PHOTO : Committee on Ways and Means.
PHOTO : Ken Klein, IRS Associate Chief Counsel (Technical), reviews the IRS's efforts to simplify
PHOTO : the regulatory process.
PHOTO : State and Local Tax Committee Chair Gordon Gilman poses with John Baldwin, Director of the
PHOTO : New Jersey Division of Taxation.
PHOTO : The headtable at President's Banquet. From left to right: (seated) Lynn Perlman, Carol
PHOTO : Bernard, Barbara and Bill Burk, Senator John Chafee of Rhode Island, Larry and Sue
PHOTO : Langdon, Reg and Doreen Kowalchuk; (middle row) Bob Perlman, Mike Bernard, Carolyn and
PHOTO : Mike Browning, Al Ludlam, Cheryl and Art Bannerman, Barbara and Larry Peck; (back row)
PHOTO : Timothy and Judy McCormally, Isobel and Jim Hutchison, Rosemary and George Lewis; Barbara
PHOTO : Lee and Tom Kerester.
PHOTO : Bill Burk listens as Frederick Gorbet, Deputy Minister of the Canadian Department of
PHOTO : Finance, answers a question on the proposed Goods and Services Tax.
PHOTO : IRS Commissioner Fred Goldberg greets TEI President Bill Burk.
PHOTO : Senator John Chafee converses with Sue and Larry Langdon during the Sunday banquet.
PHOTO : TEI President Bill Burk checks over the conference staging guide with Tom Plutz and
PHOTO : Deborah Gaffney of the Institute's staff.
PHOTO : Robert Nixon, Deputy Premier and Treasurer of the Province of Ontario, delivers the Monday
PHOTO : morning keynote address, officially welcoming TEI to Toronto.
PHOTO : Milwaukee District Director Larry Phillips discusses the IRS's efforts to revamp the
PHOTO : Coordinated Examination Program.
PHOTO : At a combined meeting of the Institute's Canadian Income Tax Committee and Canadian
PHOTO : Commodity Tax Committee, members discuss a draft Institute submission.
PHOTO : The Corporate Tax Management Committee meets to review the program sessions and to plan
PHOTO : the 1990 Midyear Conference.
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|Title Annotation:||submission by Tax Executives Institute to Congress on October 6, 1989|
|Date:||Nov 1, 1989|
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