1. 1 TEI Regions V & VI IRS Liaison Meeting Kathy Robbins, Acting NRC Industry Director May 14, 2012

2. 2 Sam Maruca, Director, Transfer Pricing Operations Kathy Robbins, Director, International Business Compliance (IBC) Kathy Robbins, Director, International Business Compliance (IBC) Commissioner Large Business & International Rosemary Sereti, Director, International Individual Compliance (IIC) Michael Danilack, Deputy Commissioner (International) Doug O’Donnell, Assistant Deputy Comm’r (Int’l) Douglas Shulman, IRS Commissioner Treaty Unit Steve Miller, IRS Deputy Commissioner for Services & Enforcement Foreign Posts Service-wide Strategy JITSIC EOI Program LB&I International Function Recently revised structure

3. DFO, IIC Director, International Individual Compliance (IIC) EA Terr Mgr Territory 1 Terr Mgr Territory 2 Terr Mgr Territory 3 Terr Mgr Territory 5 Nonresident Compliance Initiatives Campus Compliance Unit Terr Mgr Territory 4 LMSB International Large Business and International Division Director International Individual Compliance (IIC) Offshore Compliance Initiatives Central Withholding Program Future Territory 6 Tech. Coord. & Training IRS Commissioner Dep. Comm. for Services & Enforcement Commissioner Large Business & International Deputy Commissioner (International)

4. 4 Sam Maruca, Director, Transfer Pricing Operations Sam Maruca, Director, Transfer Pricing Operations Deputy Commissioner (International) Assistant Deputy Comm’r (Int’l) Deputy Commissioner (International) Assistant Deputy Comm’r (Int’l) Treaty Unit Foreign Posts Service-wide Strategy JITSIC EOI Program LB&I International Function Revised structure Director, APMA Deputy Director Director, APMA Deputy Director Combined MAP/APA team Matt Hartman, East Tom Ralph, Central Nancy Bronsen, West

5. Territory 8 John Hinman Troy MI Territory 9 David Oyler Downers Grove IL Territory 10 Glen Duncan Farmers Branch TX Large Business and International Division Director, International Business Compliance (IBC) Draft Structure as of 2/6/2012 Director, International Business Compliance Kathy Robbins Washington DC Director, International Business Compliance Kathy Robbins Washington DC EA – Operations Margie Maxwell Washington DC EA – Technical Donald Murray Columbus OH Foreign Payments Program Stuart Mann Iselin NJ Training Nieves Narvaez Houston TX International Practice Networks Nanette Hamilton San Jose CA Territory 11 Jackie Topping Phoenix AZ Territory 12 Vacant DFO, IBC West Carol Poindexter Downers Grove IL DFO, IBC West Carol Poindexter Downers Grove IL Territory 1 Theodore Setzer New York NY Territory 2 Anna Petinova New York NY Territory 3 John Evancho Edison NJ Territory 4 Orrin Byrd Atlanta GA Territory 7 (Economists) Lynn Redmond Indianapolis IN DFO, IBC East Howard Martin Downers Grove IL DFO, IBC East Howard Martin Downers Grove IL Territory 14 (Economists) Dave Jackson Farmers Branch TX Territory 5 (Foreign Payments) Vacant Inbound Martha Regan Phoenix AZ Inbound Martha Regan Phoenix AZ Outbound Violette Walter Bloomington MN Outbound Violette Walter Bloomington MN

6. Integrated International Program Training Networks Strategy Data INTERNATIONAL MATRIX Metrics

7. 7 The International Matrix The suite of core technical areas that serve as the foundation by which our strategy, training, networks, and data management are developed and utilized

8. INDIVIDUAL INBOUND US Business Activities US Investment Activities Jurisdiction to Tax INDIVIDUAL OUTBOUND Foreign Tax Credit Pass-Thru Entities Foreign Corporations Offshore Arrange- Ments Jurisdiction to Tax Income Shifting Inbound Financing Repatriation/ Withholding Income Shifting Deferral Planning FTC Management Repatriation Treaties Information Gathering Foreign Currency BUSINESS OUTBOUND Jurisdiction to Tax BUSINESS INBOUND Corporate Organizations/ Transactions The “Four Faces” of the Matrix

9. IBC Focus for 2012 International Practice Networks Training –Phase Training –Monthly Centras – Continued CPE Hiring –IBC has internal authorization to move 200 domestic agents to International –International has external authority to hire 100

10. Program Areas of Focus: Three of the areas IBC is currently focusing: Forms 1120F Joint Audits Withholding and FATCA

11. Forms 1120F Three categories of Forms 1120F we are addressing –Filed Forms 1120F –Protective Forms 1120F –Non Filers

12. Forms 1120F Have created 1120F Task Team to look at all areas and develop strategies.

13. Protective 1120Fs Ability to claim deductions Statute date

14. 14 Joint Audit – Definition Joint Audit is where: Two or more countries Join together to form a single team to Examine issue(s) or transaction(s) Of one or more related taxable persons With cross-border business activities.

15. 15 Joint Audit – Definition Taxpayer jointly makes presentations and shares information with the countries The joint audit team will include Competent Authority representatives, joint audit team leaders and examiners from each country.

16. Joint Audit Process Benefit taxpayers by reducing time and cost to address multiple audits with common factual issues Fully coordinated audit from start to finish for all compliance activities Allows for acceleration of the Mutual Agreement procedure by early involvement of the Competent Authority where double taxation involved.

17. Joint Audit Process Important to keep open channels of communication with the taxpayer throughout the joint audit process. Cooperation of taxpayer and their advisors will be a key factor in securing a satisfactory outcome. Best if examination years/cycles and processes of countries are the same.

18. Joint Audit Benefits Development of enhanced relationships between revenue bodies and taxpayers Providing certainty for taxpayers Reduction in compliance costs for taxpayer More effective management of tax issues in real time

19. Withholding and FATCA Creation of new Territory to address Chapter 3 Withholding Currently have QI and USWA groups in New York Territory to also be first responders to issues relating to FATCA