06 January 2016 LB&I announces new executive assignments in line with its restructuring On December 29, 2015, the IRS's Large Business & International (LB&I) Division announced 32 permanent executive assignments and four acting assignments to put in place its new organizational structure. As discussed in Tax Alert 2015-1809, LB&I is in the process of restructuring into nine practice areas, five subject-matter based and four geographically based. The five subject-matter areas will include: (1) pass-through entities, (2) enterprise (to include financial products and institutions, corporate issues and credits, and penalties), (3) treaty and transfer pricing, (4) withholding and international individual compliance (including FATCA) and (5) cross-border activities (international activities other than those falling under the transfer pricing and withholding areas). The four geographic areas will include: (1) Northeast (New York), (2) East (Downers Grove, Illinois), (3) Central (Houston) and (4) West (Oakland, California). A new EY slide deck (see the Attachment) visually depicts the new LB&I structure. The first page provides the new LB&I organization chart, including the new executive assignments, while the second page provides a map of the new executive assignments for each geographic practice area. According to the December 29 LB&I announcement, the new structure is focused on improving tax compliance by developing an organizational framework to strengthen LB&I's ability to perform activities in support of the changing tax administration landscape. The assignments and organizational changes will be effective February 7, 2016. Taxpayers need to understand the management structure changes and how they will affect ongoing and future examinations and other interactions with LB&I. Specifically, with the potential participation of both geographically based and subject-matter based practice groups in an audit, taxpayers should know who the involved LB&I personnel are and understand the relevant management structures. In addition, as LB&I transitions to its new structure and operating model, taxpayers should proactively establish clear lines of communication and realistic mutual expectations with the LB&I examination personnel.
Document ID: 2016-0021 | |||||||||||
