This interview is the second in a series of interviews conducted in partnership with TEI-San Jose State University High Tech Institute. Silicon Valley has an amazing community of tax professionals and this series is one I have personally wanted to do for quite some time on Silicon Valley tax luminaries. Annette Nellen has done an amazing job building this conference to national acclaim. (Please refer to my previous interview of Annette Nellen which kicked off the special interview series on tax luminaries.)

My entire career has evolved around searching for tax executives who are the best in the profession. Spending three decades chasing the best and the brightest, you learn who are the true luminaries in the tax profession. What is a luminary? A luminary is a person who inspires and influences others. Larry Langdon is a well known tax luminary interviewed recently. Larry will be a speaker at the TEI-San Jose State University High Tech Institute and you will want to attend to learn from him. He is an extraordinary man.

Kat: It is my understanding you will be speaking at the TEI-SJSU High Tax Institute Conference on November 13th-14th 2017. In your opinion, what makes this the special event it has grown to be over the years? 

Larry: I have been involved with the TEI-San Jose State University High Tech Institute since its formation many years ago, and it is clearly the premier tax conference on the West Coast because of the current and timely topics presented, the speakers and attendance from the corporate, practitioner, academic and IRS tax communities. Annette Nellen, Tax Dean at San Jose State University, has done an excellent job of leadership with her advisory group from all tax sectors which ensures that the program is outstanding. A key indication of success is the annual attendance of over 300 tax professionals from Silicon Valley, the SF Bay Area and the West Coast.

Kat: Since you will be speaking about Federal Tax Controversies, can you tell us the audit issues large business and international corporate tax executives are facing today?

Larry: The Large Business and International team (LB&I) of the IRS who will be on the panel with several practitioners will describe their campaign emphasis as well as the tools of effective resolution of tax issues at the audit level as well as Appeals settlement initiatives.

Kat: Can you tell us about the disputes corporate tax executives are currently addressing?

Larry: High on the list of current tax controversies are Section 482 pricing and related issues, R&E tax credits, Section 199 provisions and emerging issues relating to tax treatment of employee compensation.

Kat: Is it true that many senior IRS Executives are now in the process of retiring or approaching retirement? 

Larry: For the past dozen years the retirement of seasoned auditors, managers and executives in LB&I has been a challenge in light of the current severe IRS budget restraints. Some hiring of experienced tax professionals has occurred, but the loss of the current talent at the IRS is a real challenge for the agency and corporate tax department having tax audits and disputes.

Kat: What should corporate tax executives prepare for in light of these fact?

Larry: Effective preparation for LB&I audits is key to effective and early resolution of tax disputes, as well as being prepared for further appeals and litigation possibilities. Documentation and legal memo preparation for existing and emerging audit issues needs to occur.

By attending the TEI- SJSU High Tech Conference you will learn about these tax issues and how effective preparation will aid your company in effective defense and dispute resolution.

Kat: Will you provide TEI-SJSU High Tech Tax Institute registered attendees with a copy of the updated IRS Executive organization?

Larry: Yes, as several management changes are occurring right now which will be finalized and available as part of our presentation at the conference.

Kat: Through my sources, I have learned your team of lawyers has an impressive defense track record. Can you tell me about that?

Larry: For more than the past dozen years, the Mayer Brown has been the top ranked (by Chambers, Legal 500, International Tax Review and other rating agencies) tax controversy team in the US. Several members of our tax teams are also acknowledged as “leading individuals” and stars in the profession.  Mayer Brown lawyers have had an outstanding record in IRS Appeals and Tax Court controversies.

Kat: What is the best way to reach you Larry?

Larry: We look forward to assisting you in any way we can. You can contact me direct (650)331-2075, by fax (650) 331-4575, or by email
llangdon@mayerbrown.com.

To learn more about the TEI-SJSU High Tax Institute Conference, read our previous post on the subject.