11.5.4 Legislative Analysis and Tracking Implementation Services Program

Manual Transmittal

June 19, 2015

Purpose

(1) This transmits new IRM 11.5.4, Legislative Affairs, Legislative Analysis and Tracking Implementation Services (LATIS) Program.

Material Changes

(1) This IRM reflects the current operations of the LATIS program.

Effect on Other Documents

This IRM replaces previously obsoleted IRM 11.53.3.2.14.1 through IRM 11.53.3.2.14.4.

Audience

Governmental Liaisons and Operating Divisions

Effective Date

(07-01-2015)


Leonard Oursler, National Director for Legislative Affairs

LATIS Program Mission and Objectives

  1. The LATIS Program supports the mission of the Office of Legislative Affairs, which is to:

    1. Manage and enhance IRS relationships with Members of Congress and their staffs by timely sharing publicly available information,

    2. Serve as the central coordinating point for the IRS to achieve its legislative objectives, and

    3. Assist in ensuring continued Congressional support for the IRS.

  2. LATIS supports this mission by managing, coordinating and tracking the actions IRS takes to implement legislation that impacts the IRS.

  3. The objectives of the LATIS program are:

    1. Assign ownership of provisions in legislation impacting the IRS to the proper operating division.

    2. Assist and monitor the entry of actions into LATIS. The actions describe the steps the operating division is taking to implement the provision.

    3. Ensure the provision status is updated to reflect current activity.

    4. Provide reports to executives and managers as needed.

Organizational Structure

  1. Implementation of the LATIS program relies on coordinated effort between Legislative Affairs and the Legislative Liaisons in the operating divisions. The operating divisions support LATIS by entering actions into LATIS and ensuring the provision status is updated and current.

Legislative Affairs

  1. At National Headquarters (NHQ), the National Director for Legislative Affairs is the principal advisor to the Chief, Communications and Liaison, the Commissioner, the Deputy Commissioners, and the top executives of the IRS on all legislative and Congressional matters related to tax administration.

  2. For LATIS, Legislative Affairs provides:

    1. Coordination, oversight, and monitoring of the operating divisions to ensure timely updates of provisions and actions.

    2. Analysis and reporting on implementation status as needed.

Legislative Liaisons

  1. Legislative Liaisons are located in each operating division and serve as the contact points for Legislative Affairs. They are the primary relationship managers for the various organizations within their operating divisions. Most of the information and communications regarding the LATIS program is distributed and coordinated with the Legislative Liaisons. Legislative Affairs assists the Legislative liaisons as needed to support the implementation of legislation.

LATIS Program Roles and Responsibilities

Legislative Affairs

  1. The Legislative Affairs Division's role is to:

    1. Track pending tax legislation and communicate with the legislative liaisons as it progresses.

    2. Notify the legislative liaisons when pending legislation becomes law and share the final legislation with them.

    3. Determine ownership of each provision impacting the IRS.

    4. Enter the public law and provisions impacting IRS into LATIS.

    5. Prepare a provision ownership chart and distribute to each legislative liaison.

    6. Hold an implementation meeting. This provides the legislative liaisons an opportunity to discuss the provisions they own and establish communications with the other liaisons that may have implementation actions.

    7. Prepare and distribute LATIS confirming ownership and the initial provision status.

    8. Provide training as needed.

    9. Monitor the provisions and actions; communicate as needed with the liaisons if potential issues are noted.

    10. Respond to any requests from the liaisons for support, meetings, information, or other help with implementation.

    11. Final approval or denial of requests for access to LATIS using the OL 5081 program.

Legislative Liaisons

  1. The Legislative Liaisons are responsible for assisting the Legislative Affairs Division with LATIS by supporting the program. Their role is to:

    1. Distribute information provided from Legislative Affairs (such as pending legislation) within their operating division.

    2. Review the provision ownership chart and notify Legislative Affairs immediately if there may be an ownership issue.

    3. Attend the implementation meeting and discuss their provisions as needed.

    4. Coordinate entry of actions into LATIS by the other liaisons.

    5. Monitor the provision and ensure the status is updated and current.

    6. Notify Legislative Affairs promptly if there are issues with implementation of a provision.

    7. Notify Legislative Affairs if there are problems with the LATIS system.

    8. Approve or deny requests for employees within their operating division for LATIS access, using the OL 5081 program.

LATIS Program-Status Explanations

  1. Status explanations are required anytime the status of an action or provision is updated. Accurate and timely explanations are necessary to quickly provide the operating divisions and executives with implementation information. Also, accurate explanations in LATIS will assist the operating divisions when preparing for TIGTA and GAO audits and the project management teams that may be established to implement major legislation. Contact Legislative Affairs or your Legislative Liaison if you have any questions.

LATIS Program-Guidelines for Action Status Explanations

  1. Action status explanations should provide the most current information on the action, based on the action description. This should include a summary of what has happened (Notice 333 was published) and what will happen (WRN will be submitted). Note: The reader must be able to determine the steps that have been taken to complete the action. Here are some examples currently in LATIS:

    1. Ten Frequently Asked Questions (FAQs) were submitted to ACA Communications for clearance. It is anticipated that they will be posted to IRS.gov in October.

    2. Response approving the UWR as requested (for filing season 2011) is awaiting final sign-off.

    3. CPE will be developed upon the issuance of Regulations which are currently at Treasury for review.

  2. All actions should have an explanation, including actions not due for several years.

  3. If your work on the action is being delayed, that should be documented. We were recently contacted by the Commissioner’s office asking about a provision with no explanation and no actions in LATIS. Upon further research, it was determined the actions were being delayed because IRS is waiting for information from another agency. Time is of the essence when we get these requests. Implementation delays must be documented.

  4. If your explanation is lengthy, consider attaching a document.

  5. Avoid references to sensitive information, such as dollar criteria or tolerances. This is especially applicable if the action item deals with compliance plans.

  6. For some provisions, a negative action should be entered in LATIS. For example, a provision may appear to require a change to a tax form. After review by the Tax Forms Division, they determine that a change is not needed. The provision owner needs to know this and it must be documented in an action.

LATIS Program-Guidelines for Provision Status Explanations

  1. Provision status explanations should include the current status of implementation and brief description of the major implementation activities. A well written provision status explanation will allow the reader to determine where the IRS stands in implementing the provision without having to look at and analyze the actions within the provision. The Legislative Liaisons are responsible for monitoring and updating the provisions.