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 directive requires examining agents to raise Part A issues during an examination and to contact an LMSB
Food and Beverage or Retail technical adviser.
Besides Retailers, Food and Pharmaceuticals, LMSB
will be divided into four other special industry segments.
The majority of LMSB
corporate taxpayers are considered "industry cases" as compared with super-large, generally multinational corporations, which are considered "coordinated industry cases.
Deputy Commissioner (Operations)--and acting LMSB
Commissioner at the time of the conference--acknowledged the long and productive relationship between LMSB
and TEI during the Tuesday lunch, adding that the IRS welcomes its continuing dialogue with the Institute.
The new LMSB
model will strive to prevent disputes from occurring and resolve other issues in a much shorter time period -- while still applying the tax laws fully and fairly.
The restructuring follows the IRS's announcement in August that, as of October 1, LMSB
would be reconfigured and renamed the Large Business & International (LB&I) Division, with a greater emphasis on international tax matters.
In the third LMSB
-04-0209-004), issued on March 4, 2009, the industry director took up the issue of how prior-period expenses might result in the creation of DPGR in future years, even though the expenses may have resulted from activities that took place prior to the effective date of section 199.
The strategic initiatives identified by the LMSB
Division for 2007 also identified principal compliance objectives a private company can use to avoid an IRS audit.
division relies heavily on electronic data to differentiate compliant and non-compliant corporate returns.
The Commissioner explained that the National Office appreciates that uncertain tax positions should not automatically be challenged and assured TEI that LMSB
will emphasize this during its training program.
As noted, the elevation of the repairs method change to Tier I status has been widely anticipated by tax professionals, and the new directives reiterate the key points outlined in the previously released LMSB
emerging issue memorandum (LMSB