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New York Chapter hosts 9th Annual LMSB Financial Services Conference.

On October 15 and 16, 2009, the New York Chapter in conjunction with the IRS's Large and Mid-Size Business Division held the Ninth Annual LMSB Financial Services Conference at the Westin Times Square. The conference featured many high-ranking IRS and Treasury officials as well as practitioners and tax executives. In the opening session, Richard Harvey, Senior Advisor to the IRS Commissioner noted that "When history looks back at this past year, I expect it will be reported that this is the year when the IRS and tax administrators around the world turned the corner on offshore tax evasion. We've made great strides this year." While Mr. Harvey discussed IRS enforcement actions, he also focused on IRS's efforts to boost taxpayer service.

Among the other highlights was a panel on Withholding Compliance, which included Director of Field Operations (Manhattan) Kathy Robbins; Foreign Payments and Information Reporting Manager Stuart Mann; and Victoria Kanrek from the Office of Chief Counsel who were joined by Michael Danilack of Burt, Staples & Manet and Cheryl McClintock of Deloitte Tax. There was an extensive discussion of the Tier 1 Withholding Tax Issue. Among other items, Ms. Robbins mentioned that LMSB has a subgroup working on a matching effort for Form F471, "Information Return of U.S. Persons With Respect to Certain Foreign Corporations," and Form 1042, "Annual Withholding Tax Return for U.S. Source Income of Foreign Persons." Preliminary results indicate that a high percentage of Forms 1042 have not been filed; consequently, LMSB may increase its enforcement efforts. Taxpayers were cautioned by Mr. Mann that the IRS does not have an amnesty program for late-filed or amended Forms 1042. Ms. Kanrek discussed the intermediary subgroup formed to determine whether total return swaps should be respected or recharacterized. The IRS has come across four paradigms with subtle variations that are of interest and being investigated.

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The luncheon address was given by Steven Miller, then LMSB Commissioner, who was subsequently appointed IRS Deputy Commissioner (Services and Enforcement). Mr. Miller explained that the demographics of LMSB taxpayers had changed considerably, with passthrough entities now constituting the largest group of LMSB taxpayer. (They account for 75 percent of business filings.) This shift will strain tax administration, because the rules relating to passthroughs are very complex.

Mr. Miller also noted that the LMSB workforce is changing. In 2009, LMSB hired 750 new employees, and LMSB's workforce is now dispersed across more than 360 cities. Nearly 20 percent of the staff now has less than five years of IRS experience working, and that figure could reach 50 percent within a few years.

Noting the October 15 deadline for the IRS's offshore voluntary disclosure program, Mr. Miller said efforts to curtail tax haven abuse will continue. For example, the IRS will pursue cooperative efforts with jurisdictions besides Switzerland, which has worked with the United States on USB-related matters.

Other plenary sessions included a panel discussion on Issue Management Strategies with Cheryl Claybough, Director, LMSB Pre-Filing & Technical Guidance; Lavena Williams, DFO of Communications, Technology & Media; and Bryan Inoue, Financial Services DFO. Another session featured Laura Prendergast, then Director, Field Specialists; Steve Whitaker, DFO, Heavy Manufacturing & Transportation; and Charlie Brantley Director, Heavy Manufacturing & Transportation.

The conference also included breakout sessions for the Banking, Insurance, and Securities & Financial Products groups. These sessions discussed varying topics such as financial crisis legislation affecting banks, status of interest expense allocation regulations, tax implications of new reserve requirements for variable annuities, insurance reserve updates, section 1256 creep, the Schering-Plough decision, and hedge fund and other debt equity issues.

Plans are already under way for the 10th Annual Conference for September 2010.
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Title Annotation:Chapter News
Publication:Tax Executive
Article Type:Conference news
Date:Jan 1, 2010
Words:605
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