The success of your tax career is a result of many progressive steps. These steps take you through a myriad of experiences that evolve into your own unique career path and journey. This month we would like to introduce an individual who has positively impacted the tax community and many individual tax careers. In this issue, we have the opportunity to learn about the career path of Larry Langdon. Larry Langdon is currently Tax Partner and Director of the Global Tax Practice at Mayer, Brown, Rowe and Maw in Palo Alto, California. Anyone who has had the opportunity to know or work with Larry Langdon has great respect for him!

Respectfully,
Kathleen Jennings
President, ET Search, Inc.

"A Leader In The Tax Profession"
Larry Langdon, Tax Partner
Mayer, Brown, Rowe & Maw LLP - Palo Alto, CA

Larry also spent eight years at Ford Motor Company in Dearborn, Michigan where he was an Attorney, Advisor of Legislation and Regulations Division as well as Office of Counsel. Larry Langdon holds an L.L.M. in Taxation from New York University, School of Law; a J.D. from Ohio State University, College of Law; and a Bachelors of Science Degree in Administration from Ohio State University. Larry Langdon was admitted to the Bar in the states of: California, Michigan and Ohio and was admitted to the U.S. Supreme Court and the U.S. Tax Court. He is a member of the American Bar Association, Section of Taxation; the Tax Executive Institute (Santa Clara Valley President, 1984 & 1985, International President 1988-1989); Manufacturers Alliance for Productivity and Innovation (Chair, Tax Council I and Tax Council III); Chair, Tax and Fiscal Policy, Joint Venture Silicon Valley (1996-1999); National Tax Association (Vice President, 1999); International Fiscal Association, Council Member and Executive Committee Member [1996-1999] and Executive Vice President [1999]; and member of 1990-1991 IRS Commissioner's Advisory Group. Larry Langdon is a speaker at many tax conferences and industry groups and serves as Chair and a member of several non-profit tax boards.

(KJ) Larry, you have had a very interesting career in taxes. Could you briefly summarize it for our readers?

(LL) Yes, I am one of the few people that I know who has been with the IRS 3 times, 3 different industries, a nonprofit organization and now with Mayer, Brown, Rowe & Maw LLP, a prominent multinational law firm. To me, the interesting thing about a career in taxes over my 40+ years is how the tax profession has evolved in a very professional proactive way, to become an integral part of business decision making. When I started my career, a few people in business, the accounting and legal profession realized the importance of taxes and today it is a very important consideration that effects not only a company’s bottom line, but the multinational economy in a very material way. I learned this especially in my 20+ years with Hewlett Packard and the 8+ years I spent at Ford Motor Company, but now the LMSB (Large Midsize Division of the IRS) and certainly the folks at Treasury, have perceived the importance of the global reach of our tax system and how compliance planning and audit issues are key to the success of multinational enterprises. While at the IRS, for 4 years, I managed tax compliance for corporate and partnership taxpayers with more than $10 million in assets, a segment that collectively pays more than $600 billion in taxes each year. I recruited an internal and external team of 38 executives and led a nationwide workforce of 6,000 employees, with an annual budget of more than $680 million.

(KJ) What do you see as the pertinent developments to date that have changed the tax profession?

(LL) There are several aspects of my experience that are extremely important to the future of the profession. First, the accounting and tax irregularities of the 1990s have resulted in a number of major regulatory initiatives, including the Sarbanes-Oxley legislation and the IRS and Treasury activities against abusive tax shelters. This has impacted not only how companies respond to tax planning initiatives but also the compliance initiatives and the advent of the Wall Street Journal test. Increasingly, companies are concerned about adequate and full disclosure of their financial results, which includes the impact of their tax planning initiatives. The IRS has also become more sophisticated in reviewing transactions and taking appropriate action with regard to creating settlement initiatives. On the positive side, the new initiatives announced by LMSB, which include pre-filing agreements, Limit Issues Focused Exams, early referral and Fast Track appeal processes, as well as the CAP program. There are more opportunities to resolve disputes earlier with the IRS in ways that meet both company and share holder needs for early resolution of tax disputes. The Fast Track Settlement appeals system change I supported, cut appeal times by ninety percent, from an average of 780 days to a mere 70 days. I also helped to introduce innovative issue management strategies such as the Pre-Filing Agreement Program and the Industry Issue Resolution Program, which speeds up the IRS processing of audit issues. These are very constructive developments that need to be included in the portfolio of corporate tax people.

(KJ) Larry, why are you still in the tax business in light of all the changes that have occurred, particularly in the last 5 years?

(LL) I think this is a very exciting time to be a tax professional, especially with regard to dealing with the constant evolutionary change within the profession. I think it is very important that ethics has become a higher priority, but the new resolution tools and techniques are also very important for corporate tax people to take advantage of to satisfy the needs of CEOs, CFOs and the shareholders with regard to getting certainty with regard to the future of the tax business. That is why I certainly really enjoy my role at Mayer, Brown, Rowe & Maw LLP in assisting many clients deal with the IRS in a constructive, proactive way as well as advocating the company’s positions for constructive, effective resolution of their disputes with the IRS.

(KJ) Larry, you are with a premier litigation firm, how do you view the alternative dispute resolution tools?

(LL) I committed to the principles of alternative dispute resolution (ADR) promoting mediation and negotiation as alternatives to litigation – which has saved these diverse clients time and money. Going to court is too expensive, too time consuming and too public forum to deal with many of the complex disputes that a business may encounter. “Witnesses and documents don’t get better with age” a colleague once told me. When I came in, there were some audits as old as 14 years. It is important for taxpayers that the audit and appeals processes move quickly and it is better to resolve them by administrative process rather than in court.

(KJ) Larry, Thank you very much for taking the time to share your views and experiences with us. Your perspective is greatly appreciated!

Kathleen Jennings (KJ)
Editor, The Tax Intelligence Report
kitty@etsearch.com

Larry Langdon (LL)
Tax Partner and Director of Global Tax Practice, Mayer, Brown, Rowe & Maw LLP – Palo Alto, CA
LLangdon@mayerbrownrowe.com

We welcome any comments you may have regarding The Tax Intelligence Report!