Tax Lunch Forum – Discussion Leader, Sean Foley

Date: 12/10/03

To: NFTC Tax Committee


There will be an NFTC Tax Luncheon Forum on Wednesday, December 10th at noon, to discuss the proposed regulations on services.  While another lunch forum was not scheduled for 2003, the proposed regulations certainly warrant a discussion, and Sean Foley, from KPMG LLP, has agreed to lead one.  This is a great opportunity to get a better understanding about the impact of the proposed regulations, particularly since the regulations apply to “controlled services transactions‚Äù which includes any “activity‚Äù performed by one member of a group that results in a benefit to another member.  The proposed regulations cover more transactions and include a new benefit test.


Note on our discussion leader, Sean Foley: Before joining KPMG, Sean was the Director of the Advance Pricing Agreement Program of the IRS from 2000 until 2002.  Prior to that, he was Special Counsel to the IRS Associate Chief Counsel (International).  While there, Sean participated as a front office reviewer in a variety of international regulation and technical advice projects.  Sean will not only lead us in a discussion of the proposed regulations, he can use his IRS experience to help inform us on their possible application.  It will be an interesting discussion, please attend and join in.

This tax lunch forum will be at no charge. 

You must, however, please register in advance so that we can make the necessary lunch arrangements or provide the call in number to you. For those who are outside the Washington Metropolitan area who cannot attend in person, a conference call in number will be provided to you, however, you must return the attached response form to before the call-in information will be sent to you. Please complete the attached response form to attend or participate in the conference call and return it by Monday, December 8th.

Note to conference call in participants: To give our speaker time to eat lunch, we usually start the discussion at approximately 12:15pm; (i.e., the call in number will activate at 12:15pm).  Also, please put your phones on mute unless you are speaking and DO NOT PUT YOUR PHONE ON HOLD AT ANY TIME during the call.