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<J0"-' «2T« * TAe wew department came into being none too soon since the U.S. law affecting international operations underwent a major overhaul in 1962 and has been in a constant state of evolution ever since. tQue pasa aqui? Who are these people who, when you speak of the Internal Revenue Service, respond by talking of the "fiscal authorities" or the "Board of Inland Revenue"? Mention something as well known to all of us as "taxes" and they, without correcting you, end up speaking of "impuestos," "impots" or even "levies." Most of us face up to the annual chore of preparing our personal income tax returns, even if we do so with some degree of fear and trepidation. But if you think you have it rough, consider the tax specialists in the International Tax Department, based in Executive Office. This group must attempt to be expert in the U.S. tax laws applicable to international operations and at the same time have a working familiarity with the laws of almost a hundred other countries. Headed by partner Frank Oatway, who works closely with partner Dave Bertrand, the department acts as a central source of specialized knowledge, enabling the Firm to provide authoritative answers to the tax questions raised by our multinational clients. The department was organized in the late 1950s to help deal with what was fast becoming one of the most complex areas of the U.S. tax laws. The new department came into being none too soon since the U.S. law affecting international operations underwent a major overhaul in 1962 and has been in a constant state of evolution ever since. Coordinating these laws with those of other countries presents a challenging task to the group of specialists Frank directs. While freely accepting this challenge, he is quick to point out that the department does not pretend to be the sole source of knowledge on the subject. "Many practice offices have their own designated specialists who are as expert as the members of our group. Although we frequently serve clients directly, just as often our 'client' is this domestic practice office tax specialist looking for concurrence. "Each office in the DH&S organization has experts in its geographic area. We do not attempt to duplicate these sources of knowledge. However, many of our clients' problems involve the correlation of a foreign country's laws with our own or the interrelationship of two or more sets of foreign laws. The key to successful planning is often in the ability to bring all of this H&S and DH&S expertise to bear on the one problem. This is the role that we attempt to fill. We become familiar with foreign tax systems and try to help the client make his decision not just in the context of one country, or even of one country in relation to the United States, but in the context of his entire worldwide operation." When foreign offices require information on domestic tax laws, they turn to this department as the authority on the subject unless the inquiry involves a specific client already served by a domestic practice office. "We are specialists in U.S. tax laws first," Frank points out, 'With a particular knowledge of their foreign application." In this capacity the department answers questions from the simple ("What is the amount of the personal exemption?") to the complex ("How do we devise an appropriate structure for the acquisition of a U.S. public company?"). Occasionally it is called upon to exercise diplomatic skills, for example, when a foreign office or client wants to know how the United States can insist that the foreign parent of a U.S. corporation report its subsidiary's inventories on the LIFO basis if LIFO is not an acceptable accounting practice in the parent's home country. While these direct client activities account for about half the department's time and are viewed as the prime responsibility, they are only part of the complement of services it can provide. Another major responsibility involves the coordination of the U.S. tax work of foreign offices as it relates to the program for rendering