Accounting
Barry Melancon: The most important man in accounting
The most important man in accounting originally intended to be a lawyer.
When Barry Melancon — who is retiring at the end of this year after three decades of leading the accounting profession as president and CEO of the American Institute of CPAs — started college at Nicholls State University in Louisiana in 1975, accounting wasn’t even on his radar.
“If you went back to my high school yearbook, I believe it would tell you that I wanted to be a lawyer,” he recalled, and when he started in his first semester, he was majoring in pre-law.
Coming from what he describes as “a very modest family” — his father had been pulled out of school in sixth grade to cut sugarcane by hand on the family farm — he explained that, “There wasn’t a frame of reference for me, really, about the CPA profession.”
That changed in his second semester, though, because he realized that he wanted to know more about business, and he chose accounting as a concentration largely because it offered the most comprehensive introduction to business: “If I majored in accounting, I would take all the other disciplines, because it was required — I would take management and marketing and economics and finance and, of course, accounting. And it just felt like if I wanted to know business — still probably within the back of my mind being a lawyer — that was going to give me the broadest base of knowledge.”
Then, in an epiphany experienced by countless CPAs before and since, he took the entry-level accounting course and was hooked.
“I liked it — I don’t think it’s the right course and we’re talking about changing it today, and I never thought it was the right course then,” he said. “It was way too mechanical to teach accounting. But I grasped the notion of what accountants really were doing, and so I changed my major into accounting after that first year.”
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Having made the choice, he charged ahead at full speed, finishing his undergraduate accounting degree in 3 ½ years, quickly landing a job at a small local firm, Bergeron & Co., and making partner there by the unprecedented age of 25. Not long after that he became the head of the Society of Louisiana CPAs, and seven years later he was named the youngest-ever head of the AICPA at 37. (He was actually hired when he was 36, but they delayed his start date until after his birthday so it would look better in the press release.)
By the time he arrived at the institute, Melancon had long since fully committed himself to accounting — and he had strong ideas about where he wanted to take the profession, and that would mean major changes at its main membership organization.
“Professional bodies in any profession usually have a DNA about saying why a profession couldn’t or shouldn’t do things,” he explained. “And I think what we created and what I had a passion about was to be an organization that led a profession, that worked with the profession to actually give permission to be much broader than what it was, to see those opportunities and what was in the best interest of the profession and the public interest — not to be an organization that tried to figure out why you might want to be really careful, or to say you shouldn’t do these types of things.”
While it’s far from the only thing Melancon has accomplished during his long tenure, shifting the AICPA from being an inhibitor to an enabler — and driving the profession as a whole to be more open to new opportunities and approaches and risks — may well be how he’s had the most influence.
“We need to have a mindset of the things we can do, rather than the reasons why we can’t,” he said, “and I think the profession embodies that today.”
Getting it in writing
To understand how Melancon rose to the level where he was able to wield that kind of influence, it helps to know that he had it written on his list of goals from the get-go.
Early in his career at Bergeron, Melancon started keeping a written list (he still keeps it, only now it’s on his phone), because a partner at the firm suggested it.
“One time this partner and I were going to a client, and the partner was building a new house and we passed in front of his house and he said, ‘You see, even before my house is being built, we have a pool in it. I had a written goal.’ This is what he said: ‘I had a written goal to have a pool, and now I’m able to achieve that.’ And he basically impressed upon me — I might have been 21 at that point — how important written goals were.”
And high on the list Melancon started keeping was a goal that sounds an awful lot like a job description for the head of the AICPA: “Literally I had a written goal to fly around, get off a plane and give speeches,” he said with a laugh. “I mean, it wasn’t worded exactly like that.”
AL POWERS
Also on the list was making partner by 25 — an objective he almost didn’t fulfill, because a client offered him a job at a substantially higher salary than he was making at his firm.
“I was at Bergeron & Co. about nine months, and I was making $15,000 a year, and I had a client offer me a job at $25,000,” he recalled. “And when you’re making $15,000, $25,000 is a big increase, right?”
Feeling tempted, he told the partners of the firm about the offer — and even today, 40 years later, he makes a point of telling firm leaders about their response: “What they did is they said, ‘Let’s go to lunch.’ We had a 2 ½-hour lunch and basically they painted a picture for me of what being a partner was going to be like in the firm — basically what they made — and they painted the picture so well and it was one of my goals, that it caused me to say, ‘I am not doing this.’ I’m not leaving because I will always regret not experiencing that outcome.”
Not every goal on the list gets fulfilled, though; for instance, he originally had a goal to retire at 55: “But when I got later in my career, I said that’s a really dumb goal.”
The people around you
Of course, merely willing a thing (even in writing) isn’t always enough to make it come true. It also takes hard work and determination, which Melancon has always been willing to put in — and it certainly helped that leaders all around him recognized his talent early.
“The people around you in your life really determine who you are, and it’s important to understand that,” he said.
The day he passed the CPA exam, for instance, a partner at Bergeron & Co. congratulated him by taking his own name off an LSCPA committee, and having them put Melancon on it.
“So literally I was on a society or a professional committee the first day I was a CPA in my career,” he said, and he only got more involved, chairing committees and putting his minor in government from Nicholls to good use on advocacy work in the state.
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He was so active, in fact, that when the then-CEO of the society moved to the top spot at the Texas state society, both he and the CPA who succeeded him as head of the LSCPA offered Melancon the No. 2 spot at their respective organizations. Having just made partner at Bergeron, he turned them both down — but three years later when the Louisiana position opened up again and the then-chair made it clear that the job was his for the taking, he said yes.
“Really, what my wife and I talked about was that, in reality, we can go do this, and what’s the worst case? If I don’t like it, I can go back into public practice,” he said. “Those doors aren’t going to be closed to me.”
He couldn’t know that he wouldn’t return to public practice, and that his seven years at the Louisiana society would lead to him being so active with the AICPA that he would be considered a potential candidate to succeed then-president and CEO Phil Chenok in the mid-1990s.
But when the call came from search firm Korn Ferry, Melancon initially turned them down, too. “I told them no,” he recalled. “I said, ‘I’m probably too young for the institute to hire me and I don’t think that’s going to happen, and so I don’t think I’m going to put my name in.’ And about a month later, they called me back and they said, ‘Look, people want you to put your name in, and if you put your name in, I can guarantee you that you will be one of nine that gets interviewed.’ So, at that point, it’s sort of hard to say no to that.”
It wasn’t just the accountants recommending him to Korn Ferry who envisioned Melancon at the head of the institute. Much earlier, one of the leaders of the LSCPA saw it too. One component of his compensation involved deferred comp that would be forfeited if he left before serving for 10 years; at the time the position at the AICPA came open, Melancon had served seven years, but “unbeknownst to me, one of the society leaders had written into my contract a provision that said — and I didn’t ask for this — you forfeit unless you leave to be CEO of the AICPA. And that was written when I was 30.”
“It’s people around you who see things in you, at least in my case, that have been unbelievable in life,” he said. “For someone to see that in you, to me, is about what people around you make of you and what people around you contribute to you. When someone that was around me saw that — what an incredible compliment and support mechanism that was — it is amazing. I’ve had a lot of luck.”
Promising change
Melancon put his name in the ring, but still didn’t think he had a chance, even though he flew to California to meet the recruiter from Korn Ferry.
“We were supposed to have a one-hour dinner in the San Francisco airport,” he recalled. “And essentially I started that dinner off with, ‘Look, I didn’t go to a name-brand university. I’m 36 years old. I never worked in a big firm. I’m not from the Northeast. You and I both know that the institute is not going to hire me in this job. So, let me tell you what I think ought to happen.'”
The one-hour dinner ended four hours later, after Melancon had outlined all the changes he thought should be made at the institute. “And when I ultimately got into the role,” he said, “I did a lot of the stuff that we talked about.”
Despite — or perhaps because of — his candor with Korn Ferry, Melancon got the job, and felt empowered to implement the changes he had suggested. “I went in with the notion that people put me here and I was going to change the place,” he said. “And in the first 90 days I did a massive reorganization, including many people being asked to leave the institute.”
He cut headcount at the AICPA from 863 to below 600 (a level it maintained for 20 years, until it merged with the Chartered Institute of Management Accountants in 2016). He also began to build up the institute’s advocacy muscles, speed up its processes, promote high-potential talent (including current CEO of public accounting Sue Coffey), and to change what the institute meant to firms — particularly those below the Big Four, who had not been as engaged with the AICPA before.
“I knew the profession was changing and I knew that the institute could not be what a lot of people would have said that it was then — an ivory tower institute — and I also knew that we had to be more entrepreneurial and that the profession had to be more entrepreneurial and that’s what drove me, and we did it,” he said.
From there to the future
A wholesale reorganization of the leading organization in the profession would be accomplishment enough for many, but for Melancon, it served to give him a strong platform from which to lead accounting into the future.
The three decades of his tenure have been among the most tumultuous, unpredictable and full of change in accounting’s history, and Melancon has taken the lead in navigating the profession through two recessions, the collapse of Arthur Andersen and the Enron crisis, the creation of major new regulatory regimes in the form of Sarbanes-Oxley and the Public Company Accounting Oversight Board, the rise of the internet and the cloud, a global pandemic, and most recently, the birth of artificial intelligence, through all of which he has charted a proactive course forward, rather than merely reacting.
All that time, Melancon and the institute were pursuing their own agenda — computerizing the CPA exam and taking it international, launching
CPA.com as its technology arm, exploring and proselytizing new services, launching initiatives to boost audit quality, working to promote diversity, aggressively pursuing solutions to the current pipeline program, and, perhaps most ambitiously, merging with CIMA to create an international powerhouse.
With so much to do, it’s easy to see why Melancon has stayed in his role longer than any other leader in AICPA history. “I went in at first with a five-year commitment, so you don’t really know how that is going to play out,” he said. “But I had a passion for the profession and I always have had confidence in myself, so I did not go in to the institute with the notion that this was going to be a short-term process.”
Even with his time at the institute almost up, Melancon is still looking forward, seeing the future course of the profession in his mind, spying out both challenges and opportunities.
He highlights artificial intelligence as a transformational technology that will, like the rise of the internet three decades ago, have repercussions for both society at large and the accounting profession.
“I am not one who’s going to say that with AI, the role of the human is going to be fine, or that it’s always going to be there. I don’t believe that at all,” he said. “I believe that just like a lot of other technologies change jobs, change the quantity of jobs in certain areas, change the expectations of what people do in jobs, it’s going to have an impact; it’s going to change how we define work in society not in the next two years but in the next decade.”
AI’s impact on the profession is going to be tied into an ongoing evolution in the structure of firms and how accountants progress in their careers. “The fundamental change for the profession is that we have been a profession that takes entry-level people … we take in entry-level people and we put them in an environment to progress upward to the middle of the organization,” he explained. “And it takes a while, and the key component of that is a broader set of competencies than just accounting and a broad notion of what you can call business acumen. And when you get to the middle part of an organization, whether it’s a finance function or a firm, your value-add to a client or to your employer is really about those broader skills and your business acumen.”
“Organizations like the AICPA and firms and professional accountancy bodies around the world need to think about how we take an entry-level accountant where technology is going to do the bulk of that entry-level accounting work and how we move them up quickly and get them those broader skills quicker so that they’re value-add players,” he explained. “It is an immense challenge, but we’re going to have to figure it out. And if we figure it out, then starting from human capital, our services are going to change.”
Those challenges will be for the next generation of leaders of the profession to deal with, but Melancon does have some advice for the accountants of the future — and it is, naturally, about taking a broader view of what they, and the profession, can do.
“If we go into every morning and we think, ‘We know accounting,’ we’re not going to have the same future as if we think, ‘We know business information,'” he said. “We really need to take our skills and our competencies and apply it to the broader footprint of business and do it right and effectively, with ethics. And if we do that, we’re going to have a lot of new and different opportunities, and the next generation of our profession is going to be even more successful than the current generation of our profession.”
Much of Melancon’s career can be summed up by a relentless drive to move accounting forward, to improve every aspect of it — but as he looks back, it’s not the impact he has had on the profession that is foremost in his mind, but rather the impact that the people in the profession had on him.
“I would thank the people that I have interacted with, the people in our profession, for how much I’ve learned from so many different people,” he said. “I find it really hard to believe someone can have a career that gets exposed to anything like what I’ve been exposed to, because CPAs and the profession are fantastic, and the people who interact with you and the questions they ask and the contributions they make are just tremendous. … And that knowledge makes one’s life — in my case, my life — so incredibly enjoyable and fulfilled that I’m very appreciative of the profession.”
The Financial Accounting Standards Board met this week to discuss its projects on accounting for transfers of cryptocurrency assets and enhancing the disclosures around certain digital assets, such as stablecoins.
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During Wednesday’s meeting, FASB’s board made certain tentative decisions, according to a
At a future meeting, the board plans to consider clarifying the derecognition guidance for crypto transfer arrangements to assess whether the control of a crypto asset has been transferred.
FASB also began deliberations on the
The board decided to provide illustrative examples in Topic 230, Statement of Cash Flows, to clarify whether certain digital assets such as stablecoins can meet the definition of cash equivalents. It also decided to include the following concepts in the illustrative examples:
- Interpretive explanations that link to the current cash equivalents definition;
- The amount and composition of reserve assets; and,
- The nature of qualifying on-demand, contractual cash redemption rights directly with the issuer.
FASB plans to clarify that an entity should consider compliance with relevant laws and regulations when it’s creating a policy concerning which assets that satisfy the Master Glossary definition of the term “cash equivalents“ will be treated as cash equivalents.
“I agree with the staff suggestion to look at examples,” said FASB vice chair Hillary Salo. “From my perspective, I think that is going to help level the playing field. People have been making reasonable judgments. I agree with that. And I think that this is really going to help show those goalposts or guardrails of what types of stablecoins would be in the scope of cash equivalents, and which ones would not be in the scope of cash equivalents. I certainly appreciate that approach, and I think it has the least potential impact of unintended consequences, because I do agree with my fellow board members that we shouldn’t be changing the definition of cash equivalents, and it’s a high bar to get into the cash equivalent definition.”
“I’m definitely supportive of not changing the definition of cash equivalents,” said FASB chair Richard Jones. “I believe that’s settled GAAP in a way, and we’re not really seeing a call to change it for broader issues. I am supportive of the example-based approach. The challenge with examples, though, is everybody’s going to want their exact pattern, but that’s not what we’re doing.”
The examples will explain the rationale for how digital assets such as stablecoins do or do not qualify as cash equivalents and give a roadmap for other types of digital assets with varying fact patterns to be able to apply.
“We really don’t want to be as a board facing a situation where something was a cash equivalent and then no longer is at a later date,” said Jones. “That’s not good for anyone, so keeping it as a high bar with certain rigid criteria, I think, is fine.”
Stablecoins are supposed to be pegged to fiat currencies such as U.S. dollars and thus provide more stability to investors. “In my view, while a stablecoin may meet the accounting definition established for cash equivalents, not every one of those stablecoins in the cash equivalent classification represents the same level of risk,” said FASB member Joyce Joseph.
She noted that the capital markets recognize the distinctions and have established a Stablecoin Stability Assessment Framework to evaluate a stablecoin’s ability to maintain its peg to a fiat currency. Such assessments look at the legal and regulatory framework associated with the stablecoin, and provide investors with information that could enable them to do forward-looking assessments about the stability of the stablecoin.
“However, for an investor to consider and utilize such information for a company analysis the financial statement disclosures would need to include information about the stablecoin itself,” Joseph added. “In outreach, the staff learned that investors supported classifying certain stablecoins as cash equivalents when transparent information is available about the entities at which the reserve assets are held. Therefore, in my view, taking all of this into consideration a relevant and informative company disclosure would include providing investors with the name of the stablecoin and the amount of the stablecoin that is classified as a cash equivalent, so investors can independently assess the liquidity risks more meaningfully and more comprehensively by utilizing broader information that is available in the capital markets and its emerging information.”
Such information could include the issuer, reserves, governance and management, she noted, so investors would get a more holistic look at the risks that holding the stablecoin would entail for a given company.
The board decided to require all entities to disclose the significant classes and related amounts of cash equivalents on an annual basis for each period that a statement of financial position is presented.
Entities should apply the amendments related to the classification of certain digital assets as cash equivalents on a modified prospective basis as of the beginning of the annual reporting period in the year of adoption.
FASB decided that entities should apply the amendments related to the disclosure of the significant classes and amounts of cash equivalents on a prospective basis as of the date of the most recent statement of financial position presented in the period of adoption.
The board will allow early adoption in both interim and annual reporting periods in which financial statements have not been issued or made available for issuance.
FASB also decided to permit entities to adopt the amendments to be illustrated in the examples related to the classification of certain digital assets as cash equivalents without the need to perform a preferability assessment as described in Topic 250, Accounting Changes and Error Corrections.
The board directed the staff to draft a proposed accounting standards update to be voted on by written ballot. The proposed update will have a 90-day comment period.
Senators introduced several pieces of tax-related legislation this week, including measures aimed at improving customer service at the Internal Revenue Service, cracking down on tax evasion and curbing the carried interest tax break, in addition to efforts in the House to repeal the Corporate Transparency Act.
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Senators Bill Cassidy, R-Louisiana, and Mark Warner, D-Virginia, teamed up on introducing a bipartisan bill, the
The bill would establish a dashboard to inform taxpayers of backlogs and wait times; expand electronic access to information and refunds; expand callback technology and online accounts; and inform individuals facing economic hardship about collection alternatives.
“Taxpayers deserve a simple, stress-free experience when dealing with the IRS,” Cassidy said in a statement Wednesday. “This bill makes the process quicker and easier for taxpayers to get the information they need.”
He also mentioned the bill during a
“I’m happy to meet with the team … and do all I can to make it as good as you want it to be,” said Bisignano.
“My bill would equip the IRS with the legislative mandate to create an online dashboard so that taxpayers can monitor average call wait time and budget time accordingly,” said Cassidy. He noted that the bill would allow a callback for taxpayers that might need to wait longer than five minutes to speak to a representative, and establish a program to identify and support taxpayers struggling to make ends meet by providing information about alternative payment methods, such as installments, partial payments and offers in compromise.
“I know people are kind of desperate and don’t know where to turn for cash, so I think this could really ease anxiety,” he added. “This legislation is bipartisan and is likely to pass this Congress.”
Cassidy and Warner
“Taxpayers shouldn’t have to jump through hoops to get basic answers from the IRS — and in the last year, those challenges have only gotten worse,” Warner said in a statement. “I am glad to reintroduce this bipartisan legislation on Tax Day to ease some of this frustration by increasing clear communication and making IRS resources more readily available.”
Stop CHEATERS Act
Also on Tax Day, a group of Senate Democrats and an independent who usually caucuses with Democrats teamed up to introduce the Stop Corporations and High Earners from Avoiding Taxes and Enforce the Rules Strictly (Stop CHEATERS) Act.
Senate Finance Committee ranking member Ron Wyden, D-Oregon, joined with Senators Angus King, I-Maine, Elizabeth Warren, D-Massachusetts, Tim Kaine, D-Virginia, and Sheldon Whitehouse, D-Rhode Island. The bill would provide additional funding for the IRS to strengthen and expand tax collection services and systems and crack down on tax cheating by the wealthy.
“Wealthy tax cheats and scofflaw corporations are stealing billions and billions from the American people by refusing to pay what they legally owe, and far too many of them are getting a free pass because Republicans gutted the enforcement capacity of the IRS,” Wyden said in a statement. “A rich tax cheat who shelters mountains of cash among a web of shell companies and passthroughs is likelier to be struck by lightning than face an IRS audit, and Republicans want to keep it that way. This bill is about making sure the IRS has the resources it needs to go after wealthy tax cheats while improving customer service for the vast majority of American taxpayers who follow the law every year.”
Earlier this week. Wyden also
The Stop CHEATERS Act would provide the IRS with additional funding for tax enforcement focused upon high-income tax evasion, technology operations support, systems modernization, and taxpayer services like free tax-payer assistance.
“As Congress seeks ways to fund much-needed policy priorities and address our growing national debt, there is one common sense solution that should have unanimous bipartisan support: let’s enforce the tax laws already on the books,” said King in a statement. “Our legislation will make sure the IRS has the resources it needs to confront the gap between taxes owed and taxes paid – while ensuring that our tax enforcement professionals are focused on the high-income earners who account for the most tax evasion. This is a serious problem with an easy solution; let’s pass this legislation and make sure every American pays what they owe in taxes.”
Carried interest
Wyden, King and Whitehouse also teamed up on another bill Thursday to close the carried interest tax break for hedge fund managers that
Carried interest is a form of compensation received by a fund manager in exchange for investment management services, according to a
Under the bill, the
“Our tax code is rigged to favor ultra-wealthy investors who know how to game the system to dodge paying a fair share, and there is no better example of how it works in practice than the carried interest loophole,” Wyden said in a statement. “For several decades now we’ve had a tax system that rewards the accumulation of wealth by the rich while punishing middle-class wage earners, and the effect of that system has been the strangulation of prosperity and opportunity for everybody but the ultra-wealthy. There are a lot of problems to fix to restore fairness and common sense to our tax code, and closing the carried interest loophole is a great place to start.”
Repealing Corporate Transparency Act
The House Financial Services Committee is also planning to markup a bill next Tuesday that would fully repeal the Corporate Transparency Act, which has already been significantly
If enacted, the repeal would eliminate beneficial ownership reporting requirements, removing a transparency measure designed to help law enforcement and national security officials identify who is behind U.S. companies.
“This repeal would turn the United States back into one of the easiest places in the world to set up anonymous shell companies, something Congress worked for years to fix,” said Erica Hanichak, deputy director of the FACT Coalition, in a statement. “These entities are routinely used to facilitate corruption, financial crime, and abuse. Rolling back the CTA doesn’t just weaken transparency, it signals to bad actors around the world that the U.S. is once again open for illicit business.”
The Internal Revenue Service rarely penalizes taxpayers who have high balances in foreign bank accounts and fail to file the proper forms, according to a new report.
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The
Taxpayers with specified foreign financial assets that meet a certain dollar threshold are also required to report the information to the IRS by filing Form 8938. Failure to file the form can result in penalties of up to $60,000. However, TIGTA’s previous reports have demonstrated that the IRS rarely enforces these penalties.
The IRS created an Offshore Private Banking Campaign initiative to address tax noncompliance related to taxpayers’ failure to file Form 8938 and information reporting associated with offshore banking accounts, but it’s had limited success.
Even though the initiative identified hundreds of individual taxpayers with significant foreign bank account deposits who failed to file Forms 8938, the campaign only resulted in relatively few taxpayer examinations and a small number of nonfiling penalties. The campaign identified 405 taxpayers with significant foreign account balances who appeared to be noncompliant with their FATCA reporting requirements.
The IRS used two ways to address the 405 noncompliant taxpayers: referral for examinations and the issuance of letters to them.
- 164 taxpayers (who had an average unreported foreign account balance of $1.3 billion) were referred for possible examination, but only 12 of the 164 were examined, with five having $39.7 million in additional tax and $80,000 in penalties assessed.
- 241 noncompliant taxpayers (who had an average unreported account balance of $377 million) received a combination of 225 educational letters (requiring no response from the taxpayers) and 16 soft letters (requiring taxpayers to respond). None of the 241 taxpayers were assessed the initial $10,000 FATCA nonfiling penalty.
“While taxpayers can hold offshore banking accounts for a number of legitimate reasons, some taxpayers have also used them to hide income and evade taxes,” said the report.
Significant assets and income are factors considered by the IRS when assessing whether taxpayers intentionally evaded their tax responsibilities, the report noted. Given the large size of the average unreported foreign account balances, these taxpayers probably have higher levels of sophistication and an awareness of their obligation to comply with the law.
TIGTA believes the IRS needs to establish specific performance measures to determine the effectiveness of the FATCA program. “If the IRS does not plan to enforce the FATCA provisions even where obvious noncompliance is identified, it should at least quantify the enforcement impact of its efforts,” said the report. “This will ensure that IRS decision makers have the information they need to determine if the FATCA program is worth the investment and improves taxpayer compliance.
TIGTA made three recommendations in the report, including revising Campaign 896 processes to include assessing FATCA failure to file penalties; assessing the viability of using Form 1099 data to identify Form 8938 nonfilers; and implementing additional performance measures to give decision makers comprehensive information about the effectiveness of the FATCA program. The IRS disagreed with two of TIGTA’s recommendations and partially agreed with the remaining recommendation. IRS officials didn’t agree to assess penalties in Campaign 896 or with implementing performance measures to assess the effectiveness of the FATCA program.
“From our perspective, TIGTA’s conclusions regarding IRS Campaign 896 are based, in part, on a misguided premise and overgeneralizations, including the treatment of ‘potential noncompliance’ as tantamount to ‘egregious noncompliance’ that warrants a monetary penalty without contemplating the variety of justifications that may exempt a taxpayer from having to file Form 8938,” wrote Mabeline Baldwin, acting commissioner of the IRS’s Large Business and International Division, in response to the report.
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