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Large & Mid-Size Business Division

Large & Mid-Size Business Division. LMSB International Realignment NTEU Briefing. DISCUSSION DOCUMENT. Washington, DC August 2010. CONFIDENTIAL – DO NOT DISTRIBUTE. Executive Summary. Highlights of Proposed Change.

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Large & Mid-Size Business Division

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  1. Large & Mid-Size Business Division LMSB International Realignment NTEU Briefing DISCUSSION DOCUMENT Washington, DC August 2010 CONFIDENTIAL – DO NOT DISTRIBUTE

  2. Executive Summary

  3. Highlights of Proposed Change • The name of the Large and Mid-size Business (LMSB) will change on Oct. 1 to the Large Business and International division (LB&I) • The new LB&I division will realign from Industries and Pre-Filing & Technical Guidance (PFTG). International specialists and issue specialists, field specialist economists, international technical advisors, and related staff—approximately 875 employees in total—will move to the existing International organization, reporting to the Deputy Commissioner, International • The realigned LB&I will continue to serve the same population of taxpayers — corporations, subchapter S corporations and partnerships with assets greater than $10 million as well as certain high wealth individuals • LB&I will include a transfer pricing director, who will continue piloting the new transfer pricing practice, and a chief economist, who will oversee the IRS’s economic positions pertaining to transfer pricing • LB&I is also charged with overseeing the implementation of the recently enacted Foreign Account Tax Compliance Act (FATCA). Signed into law in March, FATCA will substantially improve international information reporting, increasing international transparency and compliance • Heather C. Maloy will continue serving as Commissioner of LB&I. Michael Danilack, Deputy Commissioner, International, will head the realigned global unit. Paul D. DeNard will continue serving as Deputy Commissioner (Operations)

  4. LMSB’s current structure illustrates wide dispersal of international specialists LMSB Organizational Chart – Existing State LMSB Commissioner Deputy Commissioner International (Total Int’l Staff: ~549) Deputy Commissioner Operations (Total Ops Staff: ~6080) EEO CTM 838 TA&IC 92 JITSIC 2 ICS&P 455 M&F 12 RWI (PSP) 86 PQAS 163 BSP 37 PFTG 163 Field Specialists 1222 East 458 West 364 Deputy East 641 West 565 FS 795 NE 386 380 Man. NRC 910 HMT 995 East 451 East 471 West 438 West 501 GHW 43 RFPH 805 East 360 West 424

  5. The realignment directly responds to challenges in the existing structure that make it difficult to link international strategy to frontline expertise

  6. The realigned LB&I international structure will bring IEs, economists, and other international specialists together, supported by executives LB&I International Future State Organization IRS Commissioner Changes from Current State • International specialists and Economists shift to International to emphasize issue focus • Transfer Pricing specialization area includes 482 Issue Specialists, 482 TAs, and a Chief Economist 1 IRS Deputy Commissioner for Services & Enforcement 2 LB&I Commissioner Senior Advisors Deputy Commissioner, International 1 Executive Assistant 1 Director, Int’l Strategy & Service-Wide Coordination 2 Director, Int’l Corporate Taxation (ICT) 2 Director, Int’l Individual Taxation (IIT) 2 EA 1 EA 1 EA 1 2 Competent Authority 18 EOI & JITSIC 26 Service-Wide Strategy Director, Transfer Pricing 2 DFO Int’l Corp Tax East 2 DFO Int’l Corp Tax West 2 Int’l Corporate Tax Strategy 2 Foreign Payments 41 Deputy, Int’l Individual Tax 2 Campus Compliance Unit 45 Int’l Individual Tax Strategy 12 Territories Territories Territories Territories Territories 293 Territories Territories 385 Agreement Coord TBD Int’l TAs 18 Terr Mgr Territory 1 66 IOC / FRC GHW Territories Terr Mgr Territory 2 80 Chief Economist 1 Economists East Economists West Terr Mgr Territory 3 64 482 TAs 8 76 58 Terr Mgr Territory 4 36 482 Issue Specialists 47 Terr Mgr Territory 5 74

  7. The realignment will impact International Examiners and specialists, though most impacted employees will remain in their current group Details on Employee Impact Impacted employees are those assigned to the following Standard Position Descriptions (SPDs): • 91987 - GS-512-12 International Examiner • 91983 - GS-512-13 International Examiner • 96628 - GS-512-14 International Issue Specialist • 94734 - GS-512-14 Senior International Examiner • Most of the impacted employees will remain in their current group and the group will be realigned in its entirety • Employees who are currently in blended groups comprised of both domestic agents and IEs may be realigned to a different group: • If IEs are in a blended group, they will be realigned to an International group • If domestic agents are in a blended group which is managed by a team manager who is assigned to an International team manager SPD, the domestic agents will be realigned to a domestic group and remain in their current industry • International examiners will no longer control cases.

  8. The realignment will impact International Examiners and specialists, though most impacted employees will remain in their current group (cont.) Additional Details on Employee Impact • LMSB foresees no change to employees' workstations, PODs, SPDs (other than organizational locations) or critical job elements as a result of this initiative. Flexi-place and AWS arrangements will likewise remain unchanged • Two domestic groups in Manhattan, Group 1031 and Group 1197, currently part of the Financial Services Industry, will be realigned to the International organization due to the specialized work they do related to qualified intermediaries and withholding respectively. They will function as they do currently and will continue to control their case work • LMSB's Economists, who currently are part of the Field Specialist organization, will be realigned to International, due to the fact that more than 90% of their work is international in nature. Their realignment will provide a uniform and consistent approach to international issues. The two current Economist territories will be realigned in tact under a new executive • The support staff who are assigned to any of the above impacted groups will be realigned with their groups

  9. Several pending decisions related to the international realignment are still being considered Description of Pending Decisions • Migration of International Examiners and Specialists in Non-IE Groups: We are still determining the process and criteria for deciding where and how to migrate international examiners and other international specialists who currently reside in blended groups, including those in the Global High Wealth Industry (Article 15, Section 2A.1) • Transition of IE Case Control for Current Inventory: We are still determining how to best transfer and complete cases that international examiners are currently controlling • Any other potential issues identified during the briefing

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