To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income.

Tax Legislation HR 1357 HR 3090 S676

Client expense: $100,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

S.992 -- (Nickles, Conrad) A bill to amend the Internal Revenue Code of 1986 to repeal the provision taxing policy holder dividends of mutual life insurance companies and to repeal the policyholders surplus account provisions. S. 676-- (Sen Hatch, Orrin G.)A bill to amend the Internal Revenue Code of 1986 to extend permanently the subpart F exemption for active financing income. S.795 -- (Thompson, Conrad) A bill to amend the Internal Tax Revenue Code of 1986 to allow tax consolidation of life insurance companies with other companies HR 3 – Economic Growth and Tax Relief Act of 2001 HR. 1357-- (McCrery) To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. HR.1836 --2001 Tax RELIEF Act HR.1755 --Reinsurance Tax Equity Act of 2001 (Rep. Johnson R-CT, Rep. Neal, D-GA) A bill to amend the Internal Revenue Code of 1986 to prevent the use of reinsurance with foreign persons to enable domestic nonlife insurance companies to evade U.S. income taxation. HR.1719 -- (Rep. Lewis D-GA) A bill to amend the Internal Revenue Code of 1986 to exclude United States savings bond income from gross income if used to pay long-term care expenses. HR.1675 --Internet Tax Nondiscrimination Act (Rep. Cox R-CA) A bill to permanently extend the moratorium enacted by the Internet Tax Freedom Act. HR.1514 --Structured Settlement Protection Act (Rep. Shaw, R-FL) A bill to amend the Internal Revenue Code of 1986 to impose an excise tax on persons who acquire structured settlement payments in factoring transactions. HR.661 --Life Insurance Tax Simplification Act of 2001 (Rep. Houghton, R-NY) A bill to repeal the provision taxing policyholder dividends of mutual life insurance companies and to repeal the policyholders surplus account provisions. H.R. 3529 – The Economic Security and Worker Assistance Act of 2001 – Provides tax incentives intended to stimulate economic recovery. Contains three-year suspension of Sec. 809 and five-year extension of the active financing income exception from subpart F. H.R. 2884 – the Victims of Terrorism Tax Relief Act of 2001 – Provides tax relief to the victims and families hurt by the terrorist attacks of September 11. Provides tax clarification for insurers that provide structured settlements that may be subsequently factored. H.R. 3320 – the Lifetime Annuity Payout Act. – Imposes a lower tax rate on annuity benefits provided the payments are guaranteed for the life of the beneficiary.

Client expense: $3,030,000 · Firm income: Not reported

H.R. 1357/S.676 - A bill to make permanent the active financial services provision of Subpart F of the Internal Revenue Code H.R. 909/S.795 - To amend the Internal Revenue Code of 1986 to permit the consolidation of life insurance companies with other companies. H.R. 1514 - Structured Settlement Protection Act. H.R. 1789/S.797 - To amend the Internal Revenue Code of 1986 to provide equitable treatment for associations which prepare for or mitigate the effects of natural disasters. H.R. 3090 - Economic Security and Recovery Act of 2001 H.R. 3529 - Economic Security and Worker Assistance Act of 2001 Senate Democratic Economic Stimulus alternative

Client expense: $2,932,000 · Firm income: Not reported

Tax/Sub part F, H.R. 1357.

Client expense: Not reported · Firm income: $100,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

issues related to the extension of Subpart F, particularly HR1357. Amendments to the IRC related to the use of reinsurance by foreign persons to avoid taxation.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the extension of Subpart F, particularly HR1357. Amendments to the IRC related to the use of reinsurance by foreign persons to avoid taxation. Issues related to pension changes and employee benefits.

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.992- 6/6/01 (Nickles, Conrad) A bill to amend the Internal Revenue Code of 1986 to repeal the provision taxing policy holder dividends of mutual life insurance companies and to repeal the policyholders surplus account provisions. Issue/Topic: Repeal of 809/815 sections S. 676- 4/2/01 (Sen Hatch, Orrin G.)A bill to amend the Internal Revenue Code of 1986 to extend permanently the subpart F exemption for active financing income. S.795- 4/26/01 (Thompson, Conrad) A bill to amend the Internal Tax Revenue Code of 1986 to allow tax consolidation of life insurance companies with other companies Issue/Topic: Tax consolidation for tax insurers HR. 3- economic Growth and Tax Relief Act Of 2001 HR. 1357- 4/03/01 (McCrery) To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. HR.2313- Crane Tithe Tax Act of 2001 6/26/01 (Rep. Crane, R-IL) To amend the Internal Revenue Code of 1986 to repeal the income taxation of corporations, to impose a 10 percent tax on the earned income (and only the earned income) of individuals, to repeal the estate and gift taxes, to provide amnesty for all tax liability for prior taxable years. Issue/Topic: Taxes (corporate, individual, estate) HR.2293- 6/21/01 (Ryun) To amend the Internal Revenue Code of 1986 to provide a temporary reduction in the maximum capital gains rate from 20 percent to 15 percent. Issue/Topic: Capital Gains Taxes HR.2316- 6/26/01 (Hulshof) To make permanent the tax benefits enacted by the Economic Growth and Tax Relief Reconciliation Act of 2001. Issue/Topic: Taxes HR.2212- 06/19/01 (Rep. Tiberi R-OH) A bill to make the income tax rate reductions in the Economic Growth and Tax Relief Reconciliation Act of 2001 permanent. Issue/Topic: Taxes HR.2143- Permanent Death Tax Repeal Act of 2001 6/12/01 (Rep. Weldon, R-FL) A bill to make the repeal of the estate tax permanent. Issue/Topic: Estate Tax HR.1836- Economic Growth and Tax Relief Reconcilation Act Of 2001 Issue/Topic: Tax cuts HR.1755- Reinsurance Tax Equity Act of 2001 5/8/01 (Rep. Johnson R-CT, Rep. Neal, D-GA) A bill to amend the Internal Revenue Code of 1986 to prevent the use of reinsurance with foreign persons to enable domestic nonlife insurance companies to evade U.S. income taxation. Issue/Topic: Reinsurance HR.1719- 5/3/01 (Rep. Lewis D-GA) A bill to amend the Internal Revenue Code of 1986 to exclude United States savings bond income from gross income if used to pay long-term care expenses. Issue/Topic: Long-term Care HR.1675- Internet Tax Nondiscrimination Act 5/2/01 (Rep. Cox R-CA) A bill to permanently extend the moratorium enacted by the Internet Tax Freedom Act. Issue/Topic: Internet Tax Moratorium HR.1552- Internet Tax Nondistcrimination Act 4/24/01 (Rep. Cox, R-CA) A bill to extend the moratorium enacted by the Internet Tax Freedom Act through 2006 Issue/Topic: Internet Tax Moratorium HR.1514- Structured Settlement Protection Act 4/4/01 (Rep. Shaw, R-FL) A bill to amend the Internal Revenue Code of 1986 to impose an excise tax on persons who acquire structured settlement payments in factoring transactions. Issue/Topic: Taxes HR.661- Life Insurance Tax Simplification Act of 2001 2/14/01 (Rep. Houghton, R-NY) A bill to repeal the provision taxing policyholder dividends of mutual life insurance companies and to repeal the policyholders surplus account provisions. Issue/Topic: Tax Consolidation

Issues related to the extension of Subpart F dealing with active financing income, particularly HR 1357. Issues related to preventing the use of reinsurance with foreign persons to enable domestic nonlife insurers to evade US income tax, particularly HR 1755.

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the extension of Subpart F, particularly HR 1357. Issues related to preventing the use of reinsurance with foreign persons to enable domestic nonlife insurers to evade US income tax, particularly HR 1755.

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1357/S. 676 - A bill to make permanent the active financial services provision of Subpart F of the Internal Revenue Code. H.R. 909/S. 795 - To amend the Internal Revenue Code of 1986 to permit the consolidation of life insurance companies with other companies. H.R. 1514 - Structured Settlement Protection Act. H.R. 1789/S.797 - To amend the Internal Revenue Code of 1986 to provide equitable treatment for associations which prepare for or mitigate the effects of natural disasters.

Client expense: $1,520,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, State, Dept of (DOS), Treasury, Dept of

Tax/Sub part F, H.R. 1357.

Client expense: Not reported · Firm income: $140,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

FY 2002 Budget, Alternative Minimum Tax (H.R.437), Clean Efficient Automobiles Resulting from Advanced Car Technologies Act (CLEAR ACT), (H.R.1864, S.760), Deferral for Active Financing Income (H.R.1357, S.676), Domestic Loss Recharacterization, ESOP Dividend Deduction (H.R. 1836), Extraterritorial Income (EU Challenge) Group Legal Services Income Exclusion (H.R.1434, S.654), Interest Allocation, International Tax Simplification, Research & Dev. Tax Credit, Subpart F- Commodity Hedging Tax Treaties including mandatory binding arbitration

Client expense: $2,020,000 · Firm income: Not reported