The Many Masters of the Tax Department: industry sessions shifted to Wednesday to aid networking

Being a tax executive has at no time been easy, but it used to be a more focused profession. No longer is that the case: Far from being beholden solely to tax officials from the IRS, LMSB CRA, FTB DOR, and OECD (as well as to culled officials), tax executives are today increasingly faced with mandates from an alphabet broth of non-tax regulatory agencies and quasi-regulatory bodies including the SEC PCAOB, IASB, and FASB. Sailing between the Scylla of tax and the Charybdis of non-tax demands, tax executives face unparalleled challenges.

"As a arise of a sea change in the tax profession during the past three years," TEI President Mike Boyle observ "CEO and CFO wait for tax departments to mind many more p's and q's, especially as they navigate the unchartered waters of SOX" To make secure that tax executives maintain their bearings, the theme of TEI's 60th Annual discourse is The Many Masters of the Tax Department. The discourse will be held at the Manchester Grand Hyatt in San Diego, California, from October 23rd to the 26th

"The American piece of works Creation Act of 2004 has spawned oceans of guidance from the conduct on a tidal wave of novel provisions," Mr. Boyle said. "At the same time, the IRS has continued to keelhaul tax shelter participants and anchored tax practitioners with of recent origin requirements under Circular 230." Moreover, he added, the Financial Accounting Standards Board has weighed in with an in all senses draft on accounting for uncertain tax positions. "The Annual discourse in San Diego is well timed to provide tax executives with the information they ne to be the Masters and Commanders of their have a title to ships."

Mr Boyle announced that the changing landscape (or seascape) contributed to the Institute's moving the

conference's industry sessions from Monday afternoon to Wednesday morning. "By shifting the industry sessions to the third day of the conference" he explained, "conference registrants will have had an opportunity to learn about the myriad unravellings affecting their work before walking into their choice of our 21 industry sessions. For six decades TEI has serv as a sextant for tax executives, keeping them from going adrift. This year's talk will continue that tradition."

talk Overview

TEI's discourse embarks on Monday morning October 24 with a plenary session devot to the recommendations of the President's Advisory Panel upon Federal Tax Reform. Following a keynote address by the agency of Yale Professor Michael Graetz upon the prospects for a of recent origin course in tax policy, a assemblage of current and former rule officials will address legislative unfoldings in the current Congress as well as the likelihood of additional legislation, including enactment of a technical corrections bill, before the extreme point of the year. Keynote addresses will be delivered by the agency of Charles Rossotti, former IRS Commissioner who subserves on the President's Advisory Panel upon Federal Tax Reform, and Susan Markel, the Chief Accountant for the SEC's Enforcement Division.

Noting that the mantra in real estate is "location, location, location," Mr Boyle observ that the novel mantra in tax and financial reporting circles has become "disclosure, disclosure, disclosure." To address unfoldings in tax and financial reporting, Mr Boyle said conversation planners had scheduled a number of plenary and coincident technical sessions on the fresh realities of disclosure-oriented tax environment. For example, a plenary session upon Tuesday will address why tax executives ne to retain apprised of initiatives of the Securities and Exchange Commission. Another session will focus upon "The Evolving Art of Giving and Receiving Advice" in an environment regulateed by the new Circular 230 rules

Separate technical sessions will be devot to the exposing draft on accounting for uncertain tax positions and its consequences on tax reserves; managing tax risks in an imperfect world; learnings and lamentations below section 404 of Sarbanes-Oxley; the consequence of the reportable transaction sways on IDRs; state reportable transaction rules; and whether--and how--privilege for sensitive documents and tax opinions can be maintained in a disclosure-oriented environment.

Robert verdant Director of International Tax Programs for the IRS Large & Mid-Size Business Division, and Hal Hicks, Associate IRS Chief consultation (International), will participate in a session upon the widely anticipated update of the cost-sharing regulations. In addition, Mary Bennett, newly installed Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division of the Organisation for Economic Cooperation and unfolding in Paris, will brief participants upon OECD developments.

Other international tax sessions will address the novel section 362(e) provision on los importation, global compensation plans (including the result of new section 409A) and the treatment of foreign pension and stock option plans, Canadian cross-border merger and acquisitions, and commodity tax exhibitions Panels of TEI members and practitioners will provide insights and practical guidance upon capturing data to maximize the section 199 deduction; dealing with disclosures affecting stock basis, duplicated losse SRLY and 382 rules; complying with the IRS's mandatory e-filing requirements; mining gold in turn topsy-turvy state audits; and the IRS's fresh Compliance Assurance Process (involving so-called real time audits).