Advisory Committee on Tax Exempt and Government Entities (ACT ...

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Governmental Relationship and Communication Between the Internal Revenue Service and Indian Tribal GovernmentsFall of 2004 provides a good starting point for this policy. We particularly like the factthat the draft policy provides that consultation (a) applies to all types of IRS actionsaffecting Tribes, (b) applies to each IRS office, division, and department, and (c) meansthe direct and interactive involvement of the Tribes starting with the development of theIRS action in question and continuing through implementation. ITG should re-circulatethe draft policy to the Tribes (incorporating any revisions made by the joint workinggroup since then) and ask for additional feedback regarding the policy and forvolunteers for a re-constituted joint working group to review the additional feedback.Once that process is complete, we hope that the Commissioner of TE/GE will vigorouslyurge adoption of the policy and take appropriate steps to ensure its full implementation.Recommendation 5: Adjust protocols used in ITG’s listening meetingsThis is a repeat recommendation from last year’s report of the ACT regarding ITG’svoluntary compliance check program. We are concerned that in focusing on listening,ITG is overlooking the fact that meaningful consultation and collaboration is a two-wayprocess, one that necessitates that the IRS inform the Tribes about new programs thatare being considered and actively seek Tribal input as an integral part of the programdevelopment. We believe that the absence of agendas for these listening meetings thatidentify matters that ITG wishes to discuss with the Tribes makes it far less likely thatthere will be meaningful consultation and collaboration. Without an agenda, theappropriate Tribal representatives would not know that it might be appropriate to attendthe meeting, would not hear what ITG is contemplating, and would not have theopportunity to provide their views about what the program should entail. ITG shouldgive strong consideration to establishing and circulating agendas for the consultationlistening meetings. The agendas should preserve the open-ended part of eachmeeting, which should continue to be devoted to listening to the Tribal Governments’important concerns, with more concrete information about the matters that ITG wishesto discuss in the other part of each meeting. The opportunity for meaningful, two-wayconsultation and collaboration between the IRS and the Tribes will be significantlyenhanced by instituting this change. During follow-up interviews with Tribalrepresentatives for this report, Tribal officials confirmed that an agenda could facilitateenhanced consultation.Recommendation 6: Increase cultural awareness training to ITG staffEarly training provided to ITG staff regarding Tribal history, law, and culture was held inhigh regard by ITG specialists. This level of training needs to be re-established, andprovided for existing as well as new staff, to improve communication and thereforecompliance. To reduce costs and improve training, we recommend that ITG considerproviding this type of training at annual regional meetings. Every Tribe and region ofthe country is unique and ITG training should ultimately reflect that fact. Tribalrepresentatives from the region could be invited to talk at these trainings. Taking ayearly regional approach to training would allow all ITG members to remain current onTribal issues that are focused on their region. Training regarding Tribal history, law, andculture also could be included as a component of the CPE training that occurs at theregular national ITG meetings.ADVISORY COMMITTEE ON TAX EXEMPT AND GOVERNMENT ENTITIES (ACT) June 11, 2008 24
Governmental Relationship and Communication Between the Internal Revenue Service and Indian Tribal GovernmentsRecommendation 7: Increase and improve outreach contacts with TribalGovernmentsTribal officials with whom we have spoken would like additional educationalopportunities. We, too, are concerned about the declining number of outreach contactsat ITG. With insufficient outreach, the Tribes’ level of tax compliance will erode overtime, leading to enforcement needs that may be greater than IRS resources will be ableto handle. More outreach, on the other hand, will result in more positive government-togovernmentrelationships between the IRS and the Tribes and better overall taxcompliance. We are encouraged by ITG’s recent announcement in ITG News of itsplans to update its “Tax Tools for Tribes” CD-Rom and its “Helpful Hints to AvoidPenalties” job aid for Tribes, but we hope that these updates will be accompanied byoffers of hands-on demonstrations and explanations of the changes, to help ensure thatthe changes will be understood and reflected in the Tribes’ own compliance efforts. Weare sympathetic with ITG’s budgetary and time constraints that make it difficult orimpossible for ITG to train one Tribal staff at a time. Tribes have similar budgetary andtime constraints that inhibit travel for training. Additional educational opportunities couldbe provided in the form of interactive or noninteractive video or audio training to reducecosts, which we believe Tribal officials would welcome. If these opportunities areappropriately publicized, with the ITG specialists taking the lead in the publicity efforts,we believe they would have the potential to reach a large number of participants from anumber of Tribes.Recommendation 8: Provide Tribal Governments and others the opportunity tosubscribe to ITG News directly from links on ITG’s websiteTribes surveyed find ITG’s regional newsletters to be of great help and encourage itscontinued expansion. Making this newsletter more accessible would enhance itseffectiveness in Indian Country.Recommendation 9: Make the IRS’s protocols for dealing with TribalGovernments available on ITG’s websiteWe believe it would be helpful for Tribal Governments – and contribute to more positivegovernment-to-government relationships – to know about the IRS’s commitment tousing special protocols in its dealings with Tribes on tax administration matters. Thus,the protocols set forth in the Internal Revenue Manual should be available on ITG’swebsite.Recommendation 10: Develop a plan to better ensure that IRS personnel outsideof ITG follow the IRS’s protocols for dealing with Tribal Governments,consistently work within a respectful government-to-government relationshipwith Tribal Governments, and understand their obligations to coordinate with ITGWhile this is a matter that we have not explored in depth with the Director of ITG, we areconcerned about reports suggesting that IRS personnel outside of ITG, particularlySB/SE personnel conducting BSA examinations and Collection personnel, do notADVISORY COMMITTEE ON TAX EXEMPT AND GOVERNMENT ENTITIES (ACT) June 11, 2008 25
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