On behalf of the Tax Executives Institute, I am writing to recommend that the Internal Revenue Service extend the period for submitting comments on Announcement 2010-09. Taking into account the involvement of tax department personnel in the closing of their companies’ financial books, the preparation of Forms 1120 (for those taxpayers whose due date is March 15), and the disruptive effect of this winter’s weather, moving the comment deadline to May 31, 2010, will afford TEI and other taxpayer representatives time to solicit the views of their constituents and to prepare comments.
As discussed during our November 19 meeting, TEI is proud of its record of working with the Internal Revenue Service to improve tax administration generally and, more specifically, the agency’s interactions with the large corporate community that constitutes TEI’s membership and the Large and Mid-Size Business Division. In recent years, the Institute has worked collaboratively with the IRS and LMSB to develop and refine the reportable transaction regime under sections 6011, 6111, and 6112 of the Internal Revenue Code; Schedule M-3; the Compliance Assurance Process program; and the Joint Audit Planning Process. Each of these initiatives (among others) had as its goal increasing the "transparency" of transactions undertaken by corporate taxpayers and hence making the IRS’s examination of those transactions more focused and efficient.
Given TEI’s ongoing involvement with the IRS and our commitment to fair and efficient tax administration, we are keenly interested in the Commissioner’s "conversation with the Boardroom" about tax risk management and, more immediately, the comprehensive disclosure proposal in Announcement 2010-09. The Announcement struck a chord with TEI members, and the seriousness of the topic requires a thoughtful response. To afford the Institute the opportunity to canvass its members and respond to the broad range of questions in the Announcement, we request a brief extension until the end of May.
In all events, we look forward to sharing our preliminary views on the Announcement at our upcoming liaison meetings.
Thank you for your consideration; please do not hesitate to contact either Timothy J. McCormally, TEI’s Executive Director or Eli J. Dicker, the Institute’s Chief Tax Counsel, both on 202.638.5601, if you would like to discuss these matters further.