11.53.5  Stakeholder Liaison (SL) Activities (Cont. 1) 
Continuing Education (CE) Credit  (01-14-2015)
Survey form required

  1. In order to provide CE credits, you must provide a survey document to the event participants. The feedback provided should be used to improve future presentations. The survey Form 14364, Continuing Education Evaluation, has been approved by OMB and should be used for all SL-sponsored CE events. It should be maintained as a part of the recordation of the event. One Form 14364 should be used for program number per event to obtain the most useful feedback on topics and speakers.

  2. The event records should be maintained for four years from the date of the event.  (01-14-2015)
Special guidance for granting CE for webinar participation

  1. In addition to the above requirements, these additional rules apply:

    • The registration instrument must capture the first and last name of the participant as well as their PTIN number. If the webinar system cannot capture the additional information, the SL will have to manually capture the information through another process, such as e-mailed registrations.

    • The webinar system must capture the amount of time that the participant was on-line and that information must be maintained as a part of the CE recordation.

    • The system must include a "pinging mechanism" (i.e.,, a survey, live question and answer session, or polling instrument) to ensure the participant is actually engaged; or phone or web usage reports from the system (i.e., Webinterpoint).

    • CE will be granted according to the length of time the participant was "on-line" based on the system recordation - the 50 minutes contact hour applies.  (01-14-2015)
Reporting program completions

  1. The CE designee for each SL Field area will report the program completion to the responsible analyst in the Return Preparer Continuing Education office who uploads the data into the IRS CE Provider System. The data should be provided to the coordinator on the Excel template with the first and last name of the attendee, the attendee PTIN, program number(s), CE hours awarded, and the CE completion date.  (01-14-2015)
CE credits for Leveraged Small Business Workshop providers

  1. In the past, SL Field has provided CE certificates to some practitioners who have instructed at Small Business Workshops, in accordance with the Circular 230 IRC 10.6(f)(2)(D)(iii).The RPO determined that this activity no longer qualifies for CE Credit.  (01-14-2015)
Partners Page Tax Center Template

  1. Stakeholder LIaisons use tax centers as a marketing tool to help establish and maintain stakeholder relationships.

  2. The Tax Center were developed to assist CSO HQ and SL Field employees to help partners quickly find information related to their particular area of interest, industry, or profession on one page. Go to the Tax Centers page on irs.gov to view the available centers.  (01-14-2015)
Model for Industry/Business SRM

  1. SB/SE recognizes the need to improve compliance by providing education and communication through industry and business stakeholder organizations. SL will directly interact with a very small core of stakeholders. SL will build a better understanding of this stakeholder base according to the role it plays in outreach activities

  2. Stakeholder Liaison will promote the development and maintenance of these relationships with industry/business stakeholders in the small business community. The activities involve liaison, education, and coordination with internal stakeholders. While the liaison activities mirror those with practitioners, the educational activities may vary both in substance and method of delivery (i.e.,, face to face or by virtual delivery). Additional information on SRM and how to build and maintain relationships can be found on MySB/SE Website under Stakeholder Relationships Management Resources and on the SL Field SharePoint under Job Aids Focused Outreach Strategy Guide.  (01-14-2015)
Communication Strategy with Stakeholders

  1. Industry Liaisons communicates strategies with their stakeholders by:

    1. Asking open-ended questions.

    2. Listening effectively.

    3. Maintaining consistent contact with the stakeholder.

    4. Following up on every discussion with action items.

    5. Providing relevant information to the stakeholder (information package, brochures, drop-in articles, Headliners, etc.).

    6. Identifying partnering opportunities to leverage resources or add value to operations.

    7. Using internal and external networking to enhance stakeholder relationships.

    8. Working closely with the Government Laisons on compliance and burden reduction efforts, as needed, to achieve goals.  (01-14-2015)
Potential Partnering Opportunities

  1. Industry Liaisons provides potential partnering opportunities by:

    1. Encouraging stakeholder organizations to establish Tax Centers on their websites or links to irs.gov tax centers.

    2. Speaking at their annual conventions, conference and/or committee meetings either face to face or virtually. Virtual participation in these cases requires 100% support from the partner.

    3. Providing training materials and educational information to support industry schools or training courses.

    4. Providing articles for association newsletters and publications.

    5. Providing lesson plans and materials for Leveraged Small Business Tax Workshops.

    6. Asking external stakeholders to regularly participate in Small Business Forums.

    7. Coordinating IRS small business events for stakeholders.

    8. Completing speaker requests for IRS Headquarters' executives or for national events.  (01-14-2015)
Small Business Forums (SBF)

  1. A Small Business Forum (SBF) is an open forum with industry stakeholders that allows parties to exchange ideas, gather information about emerging stakeholder issues, manage relationships, and maintain a dialogue with stakeholder groups. By engaging local and regional small businesses, trade associations, and organizations, SL is able to identify stakeholders, issues, communicate strategic priorities, reduce taxpayer burden, and increase compliance. The SBF is a platform for building and strengthening partnerships with stakeholders. SBF represents a beneficial alternative to ad hoc meetings. Whether it is a face-to-face or a virtual small business forum with stakeholders, it is an efficient way to reach a diverse group of stakeholders with IRS key messages and introduce small business products and services. The SBF represents a non-threatening platform for stakeholders to elevate their concerns and issues.

  2. SBFs are for stakeholder organizations representing the Small Business/Self Employed taxpayer. This can include the leaders and members of industry, financial, government, and/or minority groups. Practitioners may also be included if they represent SB/SE taxpayers as a leader or member of an association. Similar in concept to practitioner liaison forums, SBFs are leveraged activities that greatly increase the number of small business taxpayers SL can reach.

  3. The national SBF is a model to follow. A forum is planned and conducted by stakeholder organizations in collaboration with CSO HQ as distinct from "support by CSO HQ" , which implies a more passive role. The forum is a co-sponsored event, where SL leverages the influence of lead partners to draw other stakeholders to the event. As an example, national forums are co-sponsored by CSO HQ, US Chamber of Commerce, and National Federation of Independent Businesses. All participants work as a team to ensure a successful forum. The vision is that forums will be recognized for their benefits to stakeholders in SL Field Areas.

  4. It is important to focus on the stakeholders' "interest or needs." Forums are a way for stakeholder groups to gain assistance in navigating the IRS and connecting with the appropriate IRS functions. In addition, forums are powerful vehicles for raising issues and helping stakeholder groups provide their members with the latest Federal tax law information.

  5. In general, audiences include both internal and external stakeholders. In setting up SBFs, each SL Field Area has the option of including a limited number of small business owners as part of those in attendance. Optimally, this would include up to three small business owners per stakeholder in attendance. However, the final determination of the number of small business owners to be included will be made at the Area level by the SL in consultation with their Area Manager. Guidance for including small business owners at a SBF can be found on the SL Field SharePoint site under Job Aids.

  6. ) Consider your area and identify local representatives of financial, minority, professional, trade, and service organizations that represent small business taxpayers. The audiences can also include government agencies. The Small Business Forum (SBF) Toolkit contains a list of National Co-Sponsors and Partners. Refer to the SLF Toolkit for specific information on how to plan and deliver a successful Small Business Forum. The SBF Toolkit is located on the SB/SE Website under Small Business Forums.  (01-14-2015)
Leveraged Small Business Tax Workshops (LSBTW)

  1. Leveraged Small Business Tax Workshops (LSBTW) use instructors provided by SL partners (small business/industry stakeholders and state licensing agencies) to reach small businesses and educate them on their federal tax responsibilities.

  2. The premise of the LSBTW strategy is to support partner and stakeholder efforts by providing educational materials and serving as a resource. Partnerships may include Small Business Development Centers, Service Corps Of Retired Executives (SCORE), other educational institutions and state agencies. Partners use the IRS materials to educate small business and industry stakeholders.

    • The IRS Video portal contains video and audio presentations on topics of interest to small business, individuals and tax professionals. You will find video clips of tax topics, archived versions of live panel discussions and webinars, as well as audio archived of tax practitioner phone forums.

    • Small Business Products ordering on the Small Business Products Online Ordering page on irs.gov.

    • OID View 256 - Leveraged Small Business Tax Workshops at OID View 256http://sbse.web.irs.gov/CL2/SL/outreach_initiatives/rq_view.asp?id=256.

  3. For ordering procedures for SBTW Leveraged partners, please see the Ordering Products for Small Business Tax Workshops section.  (01-14-2015)
Definitions of Leveraged Small Business Tax Workshops

  1. Classroom training: A partnering organization organizes, markets, and staffs (with non-IRS instructors) live classroom training using IRS materials. IRS materials include forms and publications that partners can order. SLs act as facilitators to connect volunteer instructors with partner organizations producing workshops so partners can build and maintain their own instructor cadres.

  2. On-line self-directed learning: A partner organization has a link on its web site to IRS’s online classroom and/or small business workshop products and markets them to their members.

  3. Self-directed learning: A Virtual Small Business Tax Workshop is available at the following link: http://www.irsvideos.gov/SmallBusinessTaxpayer/virtualworkshop  (01-14-2015)

  1. SL Headquarters:

    1. Develops and coordinates all IRS materials for SBTW with representatives from SL Field and Communications.

    2. Markets LSBTW and online materials to partners at the national level.

    3. Coordinates with the National Distribution Center (NDC) to assure partners' ability to order sufficient quantities of workshop materials.

  2. SL Field:

    1. Becomes familiar with the Small Business Tax Workshop (SBTW)presentations and materials.

    2. Markets the features and benefits of the workshop to local partners via irs.gov (30 days advance notice is required).

    3. Conduct demonstrations of IRS products for staff and instructors, including the SBTW and other products.

    4. Establishes new accounts with the NDC for partners who provide SBTW, advises them of their account numbers, and informs them of the current guidelines for ordering products for SBTW.

    5. Explains to partners how to find/link to the Online Classroom and the Virtual SBTW.

    6. Advises partners to market their workshops to use the phrase "In partnership with the Internal Revenue Service, not sponsored by…"

    7. Publicizes partners’ workshops by posting them to the Small Business Events listing on irs.gov.

    8. Refers inquiries from small business owners and stakeholder organizations to partners who produce SBTW and to the Small Business Events listing on irs.gov.

    9. Acts as facilitator to connect volunteer instructors with partner organizations producing workshops so they can build and maintain their own instructor cadres.

    10. Identify bilingual instructors to deliver non-English leveraged SBTW, allowing SLs to assist partners in building and maintaining their own instructor cadres.

  3. Partner Organization:

    1. Organize, market, and staff live workshops using IRS workshop course and/or their own materials.

    2. Link to Small Business Taxes: The Virtual Workshop on irsvideos.gov.

    3. Publicize the IRS's Small Business Workshop.  (01-14-2015)
Leveraged Small Business Tax Workshop Products

  1. Leveraged Small Business Tax Workshop Products include: on-line streaming videos and Virtual SBTW.  (01-14-2015)
Ordering Products for Small Business Tax Workshops

  1. Partner organizations may order SBTW materials by using Form 12196, Small Business Tax Product Order Form for IRS Designated Partners. This form is found on the web at the http://core.publish.no.irs.gov/forms/public/pdf/f12196--2014-01-00.pdf or by calling the Program Telephone number at 1-800-829-2765. See the Small Business Tax Product Distribution Program website at http://publish.no.irs.gov/distsys/smallbus/sbrc.html.

  2. The Stakeholder Liaison initiates contact with the National Distribution Center (NDC) Administrator to establish an account for the partner. The NDC will e-mail Form 12196 to the partners with an assigned account number, and instructions on the ordering process.

  3. The Stakeholder Liaison will initiate the contact to establish a new partner's account by e-mailing the NDC at WI.SB.Administrator@irs.gov.


    A permanent address must be provided for the partner organizations. The National Distribution Center (NDC) cannot process "one time" shipments.

  4. The Stakeholder Liaison must provide the following "partner information" to the Distribution Program Analyst:

    1. Account Type ("I" = Industry Association, "E" = Resource Centers or for those conducting Small Business Tax Workshops on behalf of the Service).

    2. Organization Name.

    3. Attn.: (if appropriate).

    4. Street address (No P.O. Box)

    5. City.

    6. State.

    7. Zip Code.

    8. Partner's Name.

    9. Partner's telephone number including area code.

    10. Partner's fax number including area code.

    11. Partner's e-mail address (mandatory).

  5. The program analyst will send the e-mail letter and attach Form 12196 with certain fields pre-populated. The pre-populated account number field cannot be altered. Once the Form 12196 is receive, the partner can begin placing orders. Be sure the partner understands he/she will need this account number and the Form 12196 for placing future orders.

  6. Partners with account numbers order tax products by completing Form 12196 and e-mailing the order to: pdf.orders@eforms.enterprise.irs.gov. Partners may follow-up on existing orders by calling (800) 829-2765.

  7. The NDC will send workshop materials that are in stock. It will not back-order out of stock items for workshops because of the likelihood the workshop will be over before the item is back in stock.

  8. If any of the materials ordered for a workshop are on back-order, customer service representatives will notify the partner that items will not be in the shipment.

  9. Products must be ordered approximately two to three weeks in advance of the SBTW. The NDC can neither process " Expedite" orders, nor can it promise delivery on a specific date/time.

  10. When an order is accepted, the customer is given a 14 digit Centralized Inventory Distribution System (CIDS) Order Number. This number is included in the acknowledgement e-mail message sent to the partner. When following up on the status of an order, the 14-digit CIDS order number is required.

  11. Products that are shipped to the partner may arrive in multiple shipments.


    Online ordering partners may order a limited selection of products at "Small Business Products Online Ordering" on irs.gov.  (01-14-2015)
Content Publishing Requests (CPR)

  1. The CPR is an application developed to assist Content Providers in completing and submitting their changes to content on the Small Business and Self-Employed pages on irs.gov and on the My SB/SE web pages. All content submissions or change requests must be submitted using the CPR Application. CSO HQ and Field employees can access the CPR application on the Content Publishing Request page of My SB/SE.  (01-14-2015)
SB/SE Excellence in Partnering Recognition Program

  1. The SB/SE "Excellence in Partnering" Recognition effort was established to publicly recognize external stakeholder efforts that support and deliver products, services, and education to the SB/SE customer we serve, with the belief that an informed customer is more likely to be a compliant customer. The award will encourage ongoing productive partnerships, advance new and leveraged partnerships, and support the mission and goals of the SB/SE organization. This process is available to all levels in SB/SE, from employers, to analysts, to managers, directors, and executives. This program addresses two key categories of "external" stakeholders:

    1. Practitioners (CPAs, enrolled agents, or other tax preparers).

    2. Industry stakeholders (such as leveraged partners, Chambers of Commerce, governmental agencies, etc.).

    The "Excellence in Partnering Program" is the only officially sanctioned form of external stakeholder recognition. It is imperative that SB/SE has a consistent process fro granting recognition and that we do not incur excessive cost in doing so. Additional information on the "Excellence in Partnering Program" , including resources, recognition examples and frequently asked questions can be found on MySb/SE Website under Stakeholder Relationship Management.  (01-14-2015)
Information Reporting Program Advisory Committee (IRPAC)

  1. The Omnibus Budget Reconciliation Act of 1989 contained an administrative recommendation that the IRS establish a federal advisory committee to discuss improvements to the Information Reporting Program. As a result, the Information Reporting Program Advisory Committee (IRPAC) was established in 1991.

  2. The IRPAC is administered by the National Public Liaison (NPL) Office under the direction of the Chief, Communications and Liaison. The IRPAC is composed of members who represent various segments of the Information Reporting Program community from major national professional and trade associations to state tax agencies. The committee is divided into the following four subcommittees: Burden Reduction, Emerging Compliance Issues, Employee Benefits & Payroll and International Withholding & Reporting.

  3. The IRPAC advises the IRS on information reporting issues of mutual concern to the private sector and the federal government. The committee works with the Commissioner and other IRS executives to provide recommendations on a wide range of information reporting administration issues. SL HQ partners directly with the NPL for coordination of all SB/SE related issues.  (01-14-2015)
Internal Revenue Service Advisory Council (IRSAC)

  1. The Internal Revenue Service Advisory Council (IRSAC) provides an organized public forum for IRS officials and representatives of the public to discuss relevant tax administration issues. The council is composed of members who advise the IRS Commissioner on issues that have a significant effect on federal tax administration.

  2. Council members represent diverse backgrounds and bring various experiences to bear on the agency's policies, programs, and procedures.

  3. The council is authorized under the Federal Advisory Committee Act; Public Law No. 92-463. The group suggests operational improvements and offers constructive observations about IRS's current or proposed policies, programs, and procedures. It also advises the IRS on particular issues having significant effect on federal tax administration.

  4. The IRSAC is strategically structured into subgroups that mirror three IRS "Services and Enforcement" operating divisions - LB&I, W&I, and SB/SE (TE/GE has its own advisory committee). The IRSAC is administered by the NPL Office under the direction of the Chief, Communications and Liaison.

  5. SL HQ partners directly with NPL to coordinate all SB/SE related issues.  (01-14-2015)
Taxpayer Advisory Panel (TAP)

  1. The Taxpayer Advisory Panel (TAP) is a federal advisory committee made up of citizen volunteers representing all 50 states, the District of Columbia and Puerto Rico. They are dedicated to helping the IRS identify ways to improve customer service and respond to taxpayers' needs. TAP provides a "grass roots" perspective on a number of issues, including setting priorities that often reduce taxpayer burden. TAP works primarily with the SB/SE and W&I on policy and procedures that reduce taxpayer filing and paying burden. SL HQ serves as the gatekeeper for all TAP interactions with the SB/SE and/or any issues that impact the small business communities.  (01-14-2015)
CSO Headquarters Operations Support and Disaster Assistance

  1. The Chief, CSO Headquarters Operation Support and Disaster Assistance (DPO), is a manager in the operating division of SB/SE Communications and Stakeholder Outreach function with overall responsibility for coordinating disaster relief with the appropriate State Disaster Assistance Coordinator (SDAC). When a disaster occurs, the DPO assumes primary responsibility for determining and/or coordinating disaster tax relief, serves as the IRS representative to Federal Emergency Management Agency (FEMA) and other federal agencies, and provides support, as needed, to the SDAC. The DPO serves as the key technical representative on the Disaster Tax Administration Policy Group (DTAPG). See IRM 25.16.1, Disaster Assistance and Emergency Relief - Program Guidelines.  (01-14-2015)
National Disaster Assistance Sponsor Agreement Coordinator Procedures

  1. Background: The Chief, CSO Support and Disaster Assistance is the IRS manager with overall responsibility for IRM 25.16.1, Disaster Assistance and Emergency Relief Program, that contains the guidelines and operating procedures for responding to federally-declared disasters. IRS has entered into partnership agreements with several professional practitioner organizations. These organizations augment IRS resources to provide tax information and assistance to disaster victims at FEMA disaster recovery centers and other disaster locations. The Chief, CSO Support and Disaster Assistance has program responsibility for negotiating, obtaining, and coordinating the process for securing Memorandums of Understanding (MOU) between IRS and national practitioner organizations nationwide.

  2. Securing Agreement: To provide program support in response to federally-declared federal disasters, the Chief, CSO Support and Disaster Assistance:

    1. Contacts national practitioner organizations regarding the IRS Volunteer Disaster Assistance and Emergency Relief Program. This may be achieved through meetings, conference calls, e-mails, or other appropriate means.

    2. Offers and negotiates a MOU, once the practitioner organization has been informed about the program.

    3. Coordinates with C&L Media Relations to develop and issue a news release announcing the agreements with the practitioner organization(s).

    4. Notifies SL Field of the signed MOU.

    5. Provides SL Field contacts to national organization for coordination of local agreements.

  3. To provide program support in response to signed national MOUs, SL Field representatives:

    1. Contact local practitioner organizations regarding the IRS Volunteer Disaster Assistance and Emergency Relief Program. This may be achieved through meetings, conference calls, e-mails, or other appropriate means.

    2. Secure local Sponsor Agreements and notify headquarters of the signed local Sponsor Agreements. Local Sponsor Agreements are maintained by the SL Field office. The Individual Volunteer Agreements are secured and maintained by the local association.

  4. SL Field Coordination with Volunteer Practitioners: When volunteer practitioners support is provided at the FEMA Disaster Recovery Center or other disaster assistance locations, SL Field representatives:

    1. Contact the sponsor organization to inform them of the number of volunteers needed, the location, and hours of service.

    2. Obtain disaster activity reports from volunteer practitioners as described in IRM 25.16.1, Disaster Assistance and Emergency Relief Program.

    3. Record and roll up all disaster-related taxpayer contacts (units) and time expected (hours) on the Disaster Assistance Activity Report (DAAR).

  5. Reporting Requirements: To provide program support and coordination, the SL Field representative adheres to the following reporting requirements:

    1. Maintains ongoing communication with Chief, CSO Support and Disaster Assistance.

    2. Conducts ongoing program monitoring and analysis to evaluate program effectiveness.

    3. Provides periodic reports that identify program strengths and recommendations for program improvement.

    4. Maintains historical files.

    5. Ensures that the individual volunteer agreements are secure and maintained by the local association.  (01-14-2015)
Small Business Regulatory Enforcement and Fairness Act (SBREFA)

  1. Background: The Small Business Regulatory Enforcement and Fairness Act (SBREFA) ensures that Federal regulatory agencies consider the effect of their regulations on small businesses and provides relief to small businesses in certain cases. The Small Business Administration (SBA) provides general oversight of agency compliance with SBREFA. The SBA Office of the National Ombudsman (ONO) provides specific oversight, and submits an annual report to Congress.

  2. SL HQ serves as the IRS contact point for the SBREFA program and supports this work by:

    • Coordinating SBREFA comments.

    • Assuring field coverage of the local Regulatory Fair hearings.

    • Collaborating with SBA ONO and operating divisions within the IRS.

    • Writing semi-annual and annual reports on the IRS's implementation of SBREFA.

  3. Publication 4689, Your Rights as a Small Business owner under the Small Business Regulatory Enforcement Fairness Act (SBREFA), can be used internally as well as externally to educate and provide awareness.  (01-14-2015)
SL HQ Processing SBREFA Comments

  1. SBREFA comments are formal complaints filed through the SBA Office of the National Ombudsman by the small business owner.

  2. There are three types of comments:

    • Case Specific Comments: Involve correspondence indicating the IRS has taken some action to which the taxpayer disagrees. They include complaints about collection actions, account problems, audits, misapplied payments, unpaid accounts, penalties, and tax assessments. Taxpayer Advocate Service (TAS) responds to these comments.

    • Systemic Comments: Involve correspondence identified as systemic problems that happen on a regular basis. TAS responds to these comments.

    • General Comments: Involve correspondence with questions about tax law, regulations, compliance initiatives, complaints about IRS employee misconduct, letters identifying tax frauds, questions about the burden certain laws or procedures have on taxpayers, and information requests. SL responds to these comments.

  3. The SBA ONO will e-mail, fax and will mail the original copy of the formal complaint to the IRS.

  4. The SL HQ SBREFA Coordinator will contact the SBA ONO within seven (7) days of the agency receiving the comment. The SL HQ SBREFA Coordinator will prepare an acknowledgment letter and provide information about the IRS Division or Function that will be assigned the comment.

  5. When the comment is received in CSO HQ, the date and initials are placed at the top of the complaint to document receipt. The comment will contain the specific complaint raised by the taxpayer and substantiating documentation. Taxpayer information (i.e., IRS notices addressed to the taxpayer, tax return information, and audit papers) may be contained within the documentation and must be safeguarded in a manner to prevent unauthorized disclosure.

  6. Review the SBREFA Comment Form - specifically the "Confidentiality/Disclosure " section. This section will have three choices of which the taxpayer will have selected only one:

    Choices Actions
    Choice 1 - My identity and the identity of my small business may be disclosed only to the ONO and the RegFair Board. This will not include the name nor disclose any taxpayer Identification Numbers, which makes it difficult, if not impossible, to provide a response to ONO.
    • The name of the company will be assigned an alias "Company #" by ONO. At a very minimum, provide a general response back to ONO addressing the issue.

    • Assign the comment to the applicable IRS function for a written response. The response should be routed via SL to ONO on IRS letterhead (with proper signature authorizations).

    • Alternatively, the assigned IRS function may choose to respond directly to ONO and provide a courtesy copy to SL.

    Choice 2 - My identity and the identity of my small business may be disclosed only to the relevant federal agency, the ONO and the RegFair Board. Requires a Form 8821, Taxpayer Information Authorization, signed by the taxpayer before IRS may go forward.
    • The IRS is prohibited from discussing any taxpayer issue with a third-party unless there is proper authorizations by the taxpayer to do so (i.e., Form 8821 to discuss a specific tax type/tax year, etc.)

    Choice 3 - My identity and the identity of my small business may be fully disclosed and made public. Requires a Form 8821, Taxpayer Information Authorization, signed by the taxpayer before IRS may go forward.
    • The IRS is prohibited from discussing any taxpayer issue with a third-party unless there is proper authorization by the taxpayer to do so (i.e., Form 8821 to discuss a specific tax type/tax year, etc.)

  7. Obtain Form 8821, Tax Information Authorization, for Choices 2 and 3 if necessary:

    • Typically a signed Form 8821 will not be in the SBREFA Comment package. Fax an interim response to ONO along with the Form 8821 and instructions asking ONO to secure a signed Form 8821 and forward to SL .

    • Request a stay until a signed Form 8821 can be secured. (ONO fax 202–481–5719). Once Form 8821, Tax Information Authorization, is signed, forward or fax the entire package to TAS (Fax 202–622–6113) or any other office that will be working the case.

  8. Store all historical documentation in a secured area, i.e., locked cabinet drawer, to avoid an unauthorized disclosure.

  9. CSO is responsible for general comments cases only. CSO does address any technical aspects of the SBREFA comments.

  10. The CSO HQ SBREFA Coordinator may prepare a written response after researching or forwarding the comment to another Business Unit (BU) that can respond to the comment such as:

    • Office of Professional Responsibility.

    • Office of Communications and Liaisons.

    • Office of Privacy, Government Liaison and Disclosure.

    • Chief Counsel.

  11. If SL is unable to complete the comment within 30 days, an interim response letter is sent by the end of the first 30 days with a contact point identified and an estimated completion date established.  (01-14-2015)
Taxpayer Advocate Service (TAS) Processing of SBREFA Comments

  1. Once the required disclosure authorizations are received, TAS works the issue by coordinating with the local IRS office where the taxpayer's case was handled.

  2. TAS prepares a response and responds directly to the ONO.

  3. TAS' procedures are in the IRM 13.1, Taxpayer Advocate Case Procedures.

  4. The IRS is rated on the timeliness and quality of response to the ONO in its annual report to Congress. The desired time frame is 30 days.  (01-14-2015)
SBREFA Hearings and Roundtables (HQ and Field)

  1. SBA plans it's hearing calendar by Fiscal Year (FY) (October - September). A proposed calendar is released to all federal agencies in early fall. The SBA Calendar is also posted on the ONO Web site at the following: http://www.sba.gov/aboutsba/sbaprograms/ombudsman/index.html .


    Since the SBA calendar often changes, it is very important to periodically check the website for changes.  (01-14-2015)
SL HQ Coordination Responsibilities

  1. SBA will request representation for Reg Fair hearings. Once requested, SL HQ will determine the level of IRS representation needed at the hearing.

    • If it's promotional in nature, the SL Field Manager or an SL Tax Analyst is fine.

    • If there is a tax issue involved, ensure that the SL Area Manager and local TAS representatives (preferably the Associate Advocate) are present .

    • If the issue is about abuse of authority or retaliatory actions by an IRS Compliance employee, notify SB/SE Compliance and request that a SB/SE Compliance Area Manager attend the hearing.

  2. At the beginning of each fiscal year, send a memorandum from the Director, CSO HQ to the Director, SL Field and staff assistant so the SL Field Area Managers or SLs can plan to attend the local hearings. Ask them to provide a local SL point-of-contact who will be handling the events (usually it is an SL Area Manager).

  3. Monitor the SBA Calendar at least once or twice a week. If there is a change on the calendar, immediately notify the affected SL Area Manager of the designated SL Tax Analyst.

  4. Even if there is no change on the calendar, send reminders to SL Area Managers one month in advance of upcoming hearings in their geographic area.

  5. TAS also provides representatives at the hearings. Coordinate at the national level with TAS to ensure local coverage.

  6. SL HQ attendance at the hearings is optional.  (01-14-2015)
SL Field Attendance and Reporting Responsibilities

  1. The description of the SL coordination responsibilities discusses various levels of field involvement.

  2. If a RegFair hearing occurs in an SL Area, the SL Tax Analyst is available to answer questions and let the Area Manager know the details of the event.

  3. The primary SL Field responsibilities are:

    • Add the RegFair Hearings. or Roundtable event to the CSO Calendar of Events.

    • Attend the hearing.

    • Answer questions.

    • Take back questions that cannot be answered.

    • Make a brief presentation if appropriate.

    • Prepare a summary report and e-mail it to the CSO HQ SBREFA coordinator.

    The summary report should include:

    • Date of the hearing.

    • Title of the hearing.

    • Summary.

    • Results (local).

    • Opportunities (national).

    • Attendees list, name, company, e-mail address (optional).

  4. The IRS is "rated" on its level of attendance at RegFair hearings by the SBA ONO in its annual report to Congress.  (01-14-2015)
SBREFA Rating Criteria (SL HQ Only)

  1. The Office of the National Ombudsman (ONO) sends a formal letter to the heads of Federal agencies to announce the SBREFA Rating Criteria with a courtesy copy to CSO HQ.

  2. SL HQ shares the Rating Criteria within the IRS by preparing a memo for the signature of the Director, CSO HQ who will:

    • Attach the incoming letter from the ONO

    • Distribute the memo depending upon the affected IRS areas  (01-14-2015)
SBREFA, ONO Annual Report to Congress (SL HQ Only)

  1. The ONO may also prepare a Report to Congress in the spring with input from the federal agencies to be rated. CSO HQ provides input to the Annual Report to Congress.

  2. Prior to submitting or testifying before Congress, the ONO provides a draft version of the report and allows for comments.  (01-14-2015)
SBREFA Compliance Assistance Resources Report

  1. The ONO prepares a Compliance Assistance Resources and Points of Contact Available to Small Businesses Report that is published in the Federal Register in June. SL provides input to the Compliance Assistance Resources and Point of Contact Report.  (01-14-2015)
SBREFA Hill Hearings and One-On-One Meetings with the SBA National Ombudsman (SL HQ Only)

  1. SBA ONO One-On-One meetings between SBA ONO and the IRS may or may not be requested annually. The last such meeting was in January 2010. Parameters for the meeting:

    • The meeting should be held in downtown (Washington, DC) for 1-2 hours in length.

    • The meeting is typically at the request of the ONO.

    • The ONO will propose an agenda that CSO HQ SBREFA coordinator may modify to meet SB/SE needs.

    • The ONO will coordinate and invite applicable IRS personnel.  (01-14-2015)
Bank Secrecy Act (BSA)/ Anti-Money Laundering (AML) Outreach

  1. In December, 2011, the BSA/Special Programs group assigned to Stakeholder Liaison Headquarters was disbanded.

  2. The Financial Crimes Enforcement (FinCEN) has sole responsibility for BSA/Title31 education and outreach to Money Services Businesses (MSB) and Non-Banking Financial Institutions (NBFI). IRS employees receiving BSA/Title31 speaker requests should forward such request to FinCEN at SpeakingEngagements@fincen.gov.

  3. Communication initiatives, which support the Fraud/BSA strategic plan and, which can be delivered to SB/SE stakeholders by SL Field will continue to be worked by Stakeholder Liaisons: i.e.,, Form 8300, Report of Cash Payments over $10,000 received in Trade or Business, and FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Outreach and educational materials for the Form 8300 (OID View 62) and the FBAR Program (OID View 50) have been developed jointly by Communications and BSA Compliance Policy and are reviewed annually, SL Field refresher training is conducted on a regular basis.

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