Remembering auld lang syne

Tax Executive, The, Nov, 1999 by Charles W. Shewbridge, III

December is ordinarily a time of reflection, and in 1999 that is probably more the case than at any other time in the last 1,000 years. I cannot resist the temptation to add my own recollections to the never-ending list of the year-end, decade-end, century-end, and millennium-end retrospectives. I promise, however, to stay focused on recent history and not to use the "M" word again in a column. (To help me keep that promise, I told the TEI staff to limit me to half my normal space.)

Unparalleled Educational Opportunities

TEI sponsored one top-notch educational program after another in 1999. Recently, we held not only an outstanding Annual Conference in Philadelphia, but a sold-out federal tax seminar on select GAAP issues and a well-received week-long course on international taxes. I am especially proud of the Annual Conference, where the Institute demonstrated its ability to combine unparalleled networking opportunities with spectacular technical sessions. The 700-plus people who gathered in Philadelphia learned first hand why dollar for dollar, minute for minute, TEI cannot be beat. That was true in 1999, and it will be true in 2000. Upcoming programs include our audits and appeals seminar and the Midyear Conference.

Continued Advocacy Success

Less than a year ago, the IRS stunned the business tax community by conceding that advance pricing agreements were subject to disclosure under section 6110 of the Code. TEI thought the IRS's action threatened not only taxpayer confidentiality but the future of the APA program. We filed an amicus brief with the U.S. district court in Washington -- a first for us -- and subsequently pressed for a legislative solution. Meeting with Treasury officials, congressional aides, and even representatives of the media (who had pressed for disclosure of APAs), the Institute argued persistently to protect APAs and associated background information from disclosure. I am delighted that the "extenders" bill recently signed by the President does just that.

In addition to our successful efforts to enhance taxpayer confidentiality, TEI also devoted considerable resources in 1999 to the corporate tax shelter issue. I was honored to represent TEI at a Ways and Means Committee hearing in mid-November, and commend the Institute's special task force on corporate tax shelters for their efforts. TEI's position can be distilled, as follows: First, there is no rush to judgment and any legislation should be based on fact, not feelings; second, the definition of corporate tax shelter must be clearer than it is now; and third, all participants in unduly aggressive tax-reduction activities -- including promoters and advisers -- should be subject to either appropriate disclosure requirements or penalties. As the congressional hearing and the various presentations at the Annual Conference made clear, this issue is far from over. Please be assured that TEI will continue to be in the forefront.

Lastly, our liaison efforts with government officials continue to bear fruit. In early December, I had the privilege of travelling to Ottawa to participate in four separate liaison meetings with Canadian officials, and our U.S. committees are getting geared up for similar sessions in Washington.

Improved Member Services

TEI is in the process of replacing its membership database as well as upgrading its presence on the Internet. Among the benefits of these efforts will be the ability of members to register for educational programs and to update their membership information on-line. These initiatives require not only creativity and vision (and no small amount of financial resources), but patience, too. As an interim step, TEI will publish an updated Membership Roster on CD-ROM in March. Your constructive feedback will help us better serve your needs.

Holiday Greetings

I extend best wishes to all TEI members, their families, and their staffs. May all of us approach the new year with good memories of the past and a positive outlook for the future. And may 2000 bring all of us joy, friendship, and professional enjoyment.