1. Strategies to Fight against Harmful Tax Planning Douglas O’Donnell Director, Treaty Administration and International Coordination Large and Mid-Size Business Division Internal Revenue Service United States of America April 2010 Inter-American Center of Tax Administration Technical Conference Montevideo, Uruguay

2. 2 Laying the Groundwork Combating Harmful Tax Planning Making Compliance Easier

3. 3 Laying the Groundwork Servicewide Approach to International Tax Administration Senate Finance and Appropriations Committee Testimony Recent Restructuring

4. 4 Combating Harmful Tax Planning Liechtenstein UBS Voluntary Disclosure Program First Data Corporation Transfer Pricing Practice

5. 5 Combating Harmful Tax Planning: Liechtenstein February 26, 2008 Tax commissioners battle against tax evasion Australian Tax Office Media Release * HM Revenue and Customs News Release Agenzia Entrate ha ricevuto informazioni su italiani con depositi in Liechtenstein Agenzia Entrante Communicato Stampa (IT) IRS and Tax Treaty Partners Target Liechtenstein Accounts IR-2008-26, Internal Revenue Service News Release

6. 6 Combating Harmful Tax Planning: UBS June 30, 2008 – “John Doe” Summons August 19, 2009 – Agreement with Switzerland finalized Status of implementation

7. 7 Combating Harmful Tax Planning: Voluntary Disclosure Program March 23, 2009 – Guidance memo issued March 26, 2009 – Program announced September 26, 2009 – Initial deadline October 15, 2009 – Extended deadline 14,700 taxpayers came into compliance

8. 8 Combating Harmful Tax Planning: Voluntary Disclosure Program IRS is serious about…. Its international efforts Piercing the veil of bank secrecy Carrying forward the momentum to address offshore tax evasion

9. 9 Combating Harmful Tax Planning: First Data Corporation April 2009 – “John Doe” summons September 2009 – First Data Corp. agreed to a modified summons Focus: Merchants who use offshore accounts to evade U.S. tax liabilities

10. 10 Combating Harmful Tax Planning: Transfer Pricing Practice Organization Team of experts Leverage expertise Transparency strategies and initiatives Focus on significant non-compliance Ensure accountability thru goals/measures

11. 11 Combating Harmful Tax Planning: Transfer Pricing Practice Goal: Significantly improve how IRS addresses transfer pricing issues with a focus on: Interactions with taxpayers Development of issues Consistent resolution

12. 12 Making Compliance Easier Fast Track Settlement Compliance Assurance Process Pre-Filing Agreements

13. 13 Conclusion IRS Mission Voluntary Compliance Certainty Sooner + Increased Transparency