To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts.
Legislative Progress
Introduced
December 19, 2007
Latest Action
December 19, 2007
Primary Sponsor
Richard E. NealDemocratic(MA)
Momentum (last 30 days)
0
score
0 actions · 0 new cosponsors · 0 votes
Speed vs cohort
0pct
0d open
vs 7,255 other HR bills in the 110th — cohort avg 47d
No CRS summary is available for this bill yet. The source title, actions, sponsors, and text versions below come from Congress.gov.
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Filing registrants (25)
Bills with similar content found using semantic analysis.
Sources: Congress.gov
2008 · second_quarter · Taxation/Internal Revenue Code
H.R. 6 - Energy Independence Security Act of 2007; H.R. 878 & S. 601 - broker reporting; H.R. 1509 & S. 940 - Subpart F; H.R. 2136, H.R. 2345 & S. 681 - tax shelters; H.R. 3970 - tax reform/corporate tax; H.R. 3996 - Temporary Tax Relief Act of 2007; H.R. 4912 - prepaid derivatives; H.R. 5351 & S. 1508 - energy tax credit extensions; S. 2 - minimum wage; S. 349 - small business tax issues; S. 2242 - alternative energy tax incentives; (no bill number) - regulations regarding foreign tax credit & continued ... non-compulsory payments; H.R. 5160 - Small Business Adds Value for Employees Act of 2008; H.R. 2167 - Automatic IRA Act of 2007; H.R. 3361 - Pension Protection Technical Corrections Act of 2007; H.r. 6382 - Pension Protection Technical Corrections Act.
Client expense: $920,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · second_quarter · Financial Institutions/Investments/Securities
U.S. competitiveness position in capital markets, Exchange consolidation, Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs), - H.R. 4912, Market data regulation, US financial services regulatory structure, Commodities regulation, SEC regulatory process, Credit default swap trading.
Client expense: $320,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2008 · fourth_quarter · Banking
HR 4912, To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts: prepaid derivatives, taxation. HR 3221, Foreclosure Prevention Act of 2008: bankruptcy, mortgage assistance, municipal bonds.
Client expense: Not reported · Firm income: $50,000
2008 · fourth_quarter · Financial Institutions/Investments/Securities
U.S. competitiveness position in capital markets; Exchange Traded Funds (ETFs); H.R. 4912 To amend Internal Revenue code of 1986 with respect to the treatment of prepaid derivative contracts - ETN taxation; Market data regulation; US financial services regulatory structure; Commodities regulation; SEC regulatory process; Credit default swap trading; Regulation of short sales.
Client expense: $250,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 4912 - To Amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivatives contracts S. 349 - Small Business and Work Opportunity Act of 2007 H.R. 3996 - Temporary Tax Relief Act of 2007 (See addendum page) H.R. 976 - Small Business Tax Relief Act of 2007 H.R. 5140 - Economic Stimulus Act of 2008 S. 2886 - Alternative Minimum Tax and Extenders Tax Relief Act of 2008 H.R. 5749 - Emergency Extended Unemployment Compensation Act of 2008 H.R. 6049 - Energy Improvement and Extension Act of 2008 H.R. 7202 - Temporary Tax Relief Act of 2008 S. 3335 - Jobs, Energy, Families and Disaster Relief Act of 2008
Client expense: $250,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
Legislative issues affecting the mutual fund industry including prepaid derivative contracts (H.R. 4912)
Client expense: Not reported · Firm income: $10,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R.4912 To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts. interest is in effect on the range of products
Client expense: $290,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
Modification and extension of withholding tax provision for foreign persons investing in U.S. mutual funds (IRC section 871(k)); HR. 6049; S. 3098; S. 3125; S.3335; HR.7060; HR.7202; HR.1424; commodity index swaps as qualifying income for mutual funds (Revenue Ruling 2006-1); HR.3996; H.R.4912; tax treatment of exchange traded notes.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
S.940; HR.1509; S.349; HR.6; HR. 2776; renewable energy tax incentives for wind, solar and smart grid; IRC sections 45 and 48; S.6049; S.3098; S.3125; S.3335; HR.7060; HR.7202; HR.1424; S.1370 (sections 4 and 5); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; issues relating to inclusion of arbitration provisions in tax treaties; H.R.4912; tax treatment of exchange traded notes; Deferred compensation; HR. 6049; S.3098; S. 3125; economic stabilization provisions; H.R. 3997; H.R. 1424; tax treatment of REMICS and REITs.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
H.R.4912 To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts. interest is in effect on the range of products
Client expense: $250,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · second_quarter · Taxation/Internal Revenue Code
H.R.4912 To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts. interest is in effect on the range of products HR 3996 EH Temporary Tax Relief Act of 2007 Interest is in Section 601 's effects on US employees of covered firms Higher Education Reauthorization Interest is in deferred compensation provisions No current legislation but interest in possibility of equivalence of US and UK employee stock ownership programs.
Client expense: $570,000 · Firm income: Not reported
Government targets: Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of Thrift Supervision (OTS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · fourth_quarter · Financial Institutions/Investments/Securities
H.R. 4912 and H.R 3185, provisions relating to 401(k) fee disclosure.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 878 Simplification Through Additional Reporting Tax Act of 2007; entire bill H.R. 1810 - To amend the Internal Revenue Code of 1986 to permit the consolidation of life insurance companies with other companies; entire bill H.R. 2419 Food and Energy Security Act of 2007; provisions relating to basis reporting H.R. 2796 Generate Retirement Ownership Through Long-Term Holding Act of 2007, entire bill H.R. 3221 - American Housing Rescue and Foreclosure Prevention Act of 2008; provisions relating to tax H.R. 3501 - To amend the Internal Revenue Code of 1986 relating to application of UBIT rules to U.S.-based investments; entire bill H.R. 3970 - Tax Reduction and Reform Act of 2007; provisions relating to individual and corporate rates and dividends received deduction H.R. 4912 - To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts; provisions relating to exchange traded notes H.R. 5267 - Business Activity Tax Simplification Act of 2008; entire bill H.R. 5719 - Taxpayer Assistance and Simplification Act of 2008; provisions relating to HSA compliance requirements H.R. 5720 - Housing Assistance Tax Act of 2008; provisions relating to individual tax benefits and basis reporting H.R. 6049 - The Energy and Tax Extenders Act of 2008; provisions relating to R&D, small business, and IRA charitable rollovers . H.R. 6110 - Roadmap for America's Future Act; entire bill H.R. 6288 Retiree Health Account Act; entire bill H.R. 7005 The Alternative Minimum Tax Relief Act of 2008; entire bill H.R. 7006 The Disaster Tax Relief Act of 2008; provisions relating to withdrawals from savings vehicles H.R. 7060 - Renewable Energy and Job Creation Tax Act of 2008; provisions relating to basis reporting, IRA charitable rollovers, small business, R&D H.R. 7202 To amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide individual income tax relief, and for other purposes; entire bill S. 601 - Simplification Through Additional Reporting Tax Act of 2007; entire bill S. 636 Reduce Wasteful Tax Forms Act of 2007; entire bill S. 1593 - Defenders of Freedom Tax Relief Act; provisions relating to savings S. 1726 The Business Activity Tax Simplification Act; entire bill S. 2126 - Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007; entire bill S. 2242 - Heartland, Habitat, Harvest, and Horticulture Act of 2007; tax title provision on basis reporting S. 3335 Jobs, Energy, Families and Disaster Relief Act of 2008; provisions relating to basis reporting, IRA charitable rollovers, small business, AMT, R&D, and withdrawals from savings vehicles for disaster relief S. 2886 - The Alternative Minimum Tax and Extenders Tax Relief Act; provisions relating to R&D, small business, and IRA charitable rollovers S. 2933 - Incentives for Older Workers Act; provisions relating to employer-based programs
Client expense: $160,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).
Client expense: $1,320,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Education, Dept of, Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Security Council (NSC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 1424 Emergency Economic Stabilization Act of 2008 (cost basis reporting, flow through) H.R. 2796 Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007 S. 2126 Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007 H.R. 2205 Retirement Security for Life Act of 2007 (lifetime annuity) S. 1010 Retiremet Security for Life Act of 2007 (lifetime annuity) H.R. 4912 Taxation of Prepaid Derivative Contracts (ETN) Modernizing Tax Rules for Regulated Investment Companies
Client expense: $953,384 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
See Addendum S. 14, "Invest in America Act", provision relating to estate tax repeal. S. 158, "Access to Affordable Health Care Act", Section 224 (Premiums on Long-Term Care Qualified Contracts) S. 349, Small Business and Work Opportunity Act of 2007. S. 504, "Long-Term Care Trust Account Act of 2007". S. 601, Simplification Through Additional Reporting Tax Act of 2007 (Broker reporting of customer's basis in mutual fund transactions). S. 1010, "Retirement Security for Life Act of 2007". S. 1753, "Healthy Workforce Act". S. 1809, "Long-Term Care Act of 2007". S. 2044, "Independent Contractor Proper Classification Act of 2007". S. 2126, "Generating Retirement Ownership Through Long-Term Holding (Growth) Act of 2007. S. 2337, "Long-Term Care Affordability and Security Act of 2007". S. 3125, "Energy Independence and Tax Relief Act of 2008", Section 241, Subpart F - Exception for Active Financing Income. S. 3289, "To Permanently Extend the Estate Tax as in Effect in 2009". S. 3327, "Empowered at Home Act of 2008", provision allowing tax deductino for a certain percentage of long-term care premiums. H.R. 46, "Small Business Tax Fairness and Simplification Act of 2007". H.R. 6, "Energy Independance and Security Act of 2007" (mutual fund cost basis reporting). H.R. 411, To amend the Internal Revenue Code of 1986 to make permanent certain expiring provisions..., provision relating to estate tax repeal H.R. 878, Simplification Through Additional Reporting Tax Act of 2007 (S. 601, H.R. 878) (Broker reporting of customer's basis in mutual fund transactions). H.R. 976, "Small Business Tax Relief Act of 2007". H.R. 1424, Division C, "Tax Extenders and Alternative Minimum Relief Act of 2008", Section 301C, subpart F: income extended through 2009) and Section 403, mutual fund cost basis reporting requirements- - became Public Law No. 110-343. H.R. 2205, "Retirement Security for Life Act of 2007". H.R. 2380, "Death Tax Repeal Permanency Act of 2007". H.R. 2582, "Qualified Long-Term Care Fairness Act of 2007". H.R. 2796, "Generate Retirement Ownership through Long-Term Holding Act of 2007". H.R. 3088, "Long-Term Care Act of 2007". H.R. 3125, "Energy Independence and Tax Relief Act of 2008", Section 241, Subpart F - Exception for Active Financing Income. H.R. 3221, "American Housing Rescue and Foreclosure Prevention Act of 2008", Section 641 (related to mutual fund cost basis reporting). H.R. 3363, "Long-Term Care Affordability and Security Act". H.R. 3970, "Tax Reduction and Reform Act of 2007" - Provisions related to modification of unrelated business income tax rules for certain investment partnerships, basis reporting by brokers on sales of stocks, extension of special rules for regulated investment companies, reduction in corporate tax rate. H.R. 3996, "Temporary Tax Relief Act of 2007", Section 622 - Broker Reporting of Customer Basis in Securities Transactions; and Section 201 - Non-qualified Deferred Compensation from Certain Tax Indifferent Parties. H.R. 4912, "To amend the Internal Revenue Code of 1986 with respect to prepaid derivative contracts". H.R. 6049, "Renewable Energy and Job Creation Act of 2008", Section 239, Subpart F, "Exception for Active Financing Income". H.R. 6237, "Tax Relief for Long-Term Care Act of 2008". H.R. 6499, "Sensible Estate Tax Act of 2008". H.R. 7060, "Renewable Energy and Job Creation Act of 2008", Section 403, Broker Reporting of Customer Basis in Securities Transactions. IRS Notice 2008-18 (1/13/08) - Life Insurance Reserves: proposed AG VACARVM and Life PBR. Current tax treatment of Stranger-Originated Life Insurance (STOLI) - no bill number. Dividends Received Deduction for Life Insurers - no bill number. Life Insurance Company Reserves - no bill number. Senate Finance Committee, "Proposed Legislation on the Taxation of Exchange-Traded Notes" - no bill number.
Client expense: $1,030,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 4912 - To Amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivatives contracts S. 349 - Small Business and Work Opportunity Act of 2007 H.R. 3996 - Temporary Tax Relief Act of 2007 (See addendum page) H.R. 976 - Small Business Tax Relief Act of 2007 H.R. 5140 - Economic Stimulus Act of 2008 S. 2886 - Alternative Minimum Tax and Extenders Tax Relief Act of 2008 H.R. 5749 - Emergency Extended Unemployment Compensation Act of 2008 H.R. 6049 - Energy Improvement and Extension Act of 2008 H.R. 7202 - Temporary Tax Relief Act of 2008 S. 3335 - Jobs, Energy, Families and Disaster Relief Act of 2008
Client expense: $250,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Banking
HR 4912, To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts: prepaid derivatives, taxation. HR 3221, Foreclosure Prevention Act of 2008: bankruptcy, mortgage assistance, municipal bonds.
Client expense: Not reported · Firm income: $70,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
General tax issues affecting regulated investment companies, including basis reporting proposals and H.R. 4912. H.R. 3221, American Housing and Rescue and Foreclosure Act of 2008 H.R. 1424, Emergency Economic Stabilization Act of 2008 H.R. 6049, Energy Improvement and Extension Act of 2008 S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008 H.R. 7060, Renewable Energy and Job Tax Creation Act of 2008 H.R. 7242, the Pension Protection Act IRC Amendments of 2008
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
Deferred Compensation - H.R. 3923 provisions included in H.R. 3970, H.R. 3996, H.R, 4195 Exchange Traded Notes- H.R. 4912 Emergency Economic Stabilization Act - H.R. 1424 Implementation
Client expense: $670,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
Legislative issues affecting the mutual fund industry including prepaid derivative contracts (H.R. 4912)
Client expense: Not reported · Firm income: $10,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 6- Energy Independence Security Act of 2007; H.R. 878 & S. 601- broker reporting; H.R. 1509 & S. 940- Subpart F; H.R. 2136, H.R. 2345 & S. 681- tax shelters; H.R. 3970- tax reform/corporate tax; H.R. 3996- Temporary Tax Relief Act of 2007; H.R. 4912- prepaid derivatives; H.R. 5351 & S. 1508- energy tax credit extensions; S. 2- minimum wage; S. 349- small business tax issues; S. 2242- alternative energy tax incentives; (no bill #)- regulations re: foreign tax credit & non-compulsory payments; continued . . . H.R. 5160- Small Business Add Value for Employees Act of 2008; H.R. 2167- Automatic IRA Act of 2007; H.R. 3361- Pension Protection Technical Corrections Act of 2007; H.R. 6382- Pension Protection Technical Corrections Act
Client expense: $1,240,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
Taxation of mutual funds and mutual fund investors, taxation of exchange-traded notes, H.R. 4912
Client expense: Not reported · Firm income: $90,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Financial Institutions/Investments/Securities
U.S. competitiveness position in capital markets, Exchange consolidation, Exchange Traded Funds (ETFs), Market data regulation, US financial services regulatory structure. Commodities regulation, SEC regulation process, credit default swap trading. HR 4912 to amend the Internal Rev.Code of 1986 with respect to treatment of prepaid derivative contracts.
Client expense: Not reported · Firm income: $40,000
Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 976 - Small Business Tax Relief Act of 2007 S. 349 - Small Business and Work Opportunity Act of 2007 H.R. 4912 - Tax Treatment of Prepaid Derivative Contracts H.R. 3996 - The Temporary Tax Relief Plan H.R. 5140 - Economic Stimulus Act of 2008 H.R. 6049 - Energy and Tax Extenders Act of 2008 S. 2886 - Alternative Minimum Tax and Extenders Tax Relief Act of 2008 H.R. 5749 - Emergency Extended Unemployment Compensation Act of 2008 H.R. 7202 - Temporary Tax Relief Act of 2008 S. 3335 - Jobs, Energy, Families, and Disaster Relief Act of 2008 H.R. 1424 - Paul Wellstone Mental Health and Addiction Equity Act of 2007 H.R. 7005 - Alternative Minimum Tax Relief Act of 2008 H.R. 7006 - Disaster Tax Relief Act of 2008 H.R. 7060 - Renewable Energy and Job Creation Tax Act of 2008
Client expense: Not reported · Firm income: $100,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
H.R.4912 To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts. interest is in effect on the range of products
Client expense: $228,198 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).
Client expense: $1,430,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Education, Dept of, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Security Council (NSC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
S.940; HR.1509; S.349; HR.6; HR. 2776; renewable energy tax incentives for wind, solar and smart grid; IRC sections 45 and 48; S.6049; S.3098; S.3125; S.3335; HR.7060; HR.7202; HR.1424; S.1370 (sections 4 and 5); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; issues relating to inclusion of arbitration provisions in tax treaties; H.R.4912; tax treatment of exchange traded notes; Deferred compensation; HR. 6049; S.3098; S. 3125; economic stabilization provisions; H.R. 3997; H.R. 1424; tax treatment of REMICS and REITs.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
Modification and extension of withholding tax provision for foreign persons investing in U.S. mutual funds (IRC section 871(k)); HR. 6049; S. 3098; S. 3125; S.3335; HR.7060; HR.7202; HR.1424; commodity index swaps as qualifying income for mutual funds (Revenue Ruling 2006-1); HR.3996; H.R.4912; tax treatment of exchange traded notes.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
HR 5267 and HR 1956 Business Activity Tax Simplification Act of 2008, regarding establishment of a physical nexus standard; HR 3221/ S 2136 Help Families Save Their Homes in Bankruptcy, regarding interest allocation, merchant payment report, and tax credits; HR 6049/S 3335 Renewable Energy and Job Creation Act, regarding qualified zone academy bonds, wind energy tax credits, solar tax and renewable energy bonds; HR 6275 Alternative Minimum Tax Relief Act, regarding merchant payment reporting; HR 3359 Mobile Workforce State Income Tax Fairness and Simplification Act, regarding state taxation of nonresidents; HR 5719 Taxpayer Assistance and Simplification Act, regarding health savings account payment substantiation; HR 1023/S 777 Witholding Tax Relief Act, regarding TIPRA witholding on government payments; S 1850 Tribal Government Tax-Exempt Bond Parity Act, regarding tribal tax-exempt bonds; HR 2167/S 1141, regarding IRA forms; HR 4912, regarding taxation of derivative instruments; HR 6333/S 3518 Municipal Bond Market Support Act, regarding financial institutions tax exempt interest expense; HR 1424 Emergency Economic Stabilization Act, regarding impact on banking and Trouble Asset Relief Program (TARP) tax issues, subpart F/active financial services income, basis reporting, qualified zone academy bonds, wind energy tax credits, clean renewable energy bonds, new markets tax credit and solar energy tax credits; General issues involving US-Canada income tax treaty; General issues on Dual consolidated loss regulations.
Client expense: $1,010,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Education, Dept of, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
2008 · third_quarter · Financial Institutions/Investments/Securities
U.S. competitiveness position in capital markets; Exchange Traded Funds (ETFs); H.R. 4912 To amend Internal Revenue code of 1986 with respect to the treatment of prepaid derivative contracts - ETN taxation; Market data regulation; US financial services regulatory structure; Commodities regulation; SEC regulatory process; Credit default swap trading; Regulation of short sales.
Client expense: $280,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of
2008 · third_quarter · Financial Institutions/Investments/Securities
U.S. competitiveness position in capital markets, Exchange consolidation, Exchange Traded Funds (ETFs), Market data regulation, US financial services regulatory structure. Commodities regulation, SEC regulation process, credit default swap trading. HR 4912 Exchange Traded Notes (ETNs) to amend the Internal Rev.Code of 1986 with respect to treatment of prepaid derivative contracts.
Client expense: Not reported · Firm income: $40,000
Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC)
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 2796 Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007 S. 2126 Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007 H.R. 2205 Retirement Security for Life Act of 2007 (lifetime annuity) S. 1010 Retirement Security for Life Act of 2007 (lifetime annuity) H.R. 4912 Taxation of Prepaid Derivative Contracts (ETNs) H.R. 3221 American housing Rescue and Foreclosure Prevention Act of 2008 (Cost Basis) S. 3125 Energy Independence and Tax Relief Act of 2008 (Flow-Through) S. 3335 Jobs, Energy, Families, and Disaster Relief Act of 2008 (Flow-Through, Cost Basis) S. 3478 Energy Independence and Investment Act of 2008 (Cost Basis) H.R. 6049 Energy and Tax Extenders Act of 2008 (Flow-Through, Cost Basis) H.R. 7060 Renewable Energy and Job Creation Tax Act of 2008 (flow-Through, Cost Basis) H.R. 7201 Energy Improvement and Extension Act of 2008 (Cost Basis) H.R. 7202 Temporary Tax Relief Act of 2008 (Flow-Through)
Client expense: $1,240,256 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
General tax issues affecting regulated investment companies, including basis reporting proposals and H.R. 4912. H.R. 3221, American Housing and Rescue and Foreclosure Act of 2008 H.R. 1424, Emergency Economic Stabilization Act of 2008 H.R. 6049, Energy Improvement and Extension Act of 2008 S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008 H.R. 7060, Renewable Energy and Job Tax Creation Act of 2008
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 878 - Simplification Through Additional Reporting Tax Act of 2007; entire bill H.R. 1810 - To amend the Internal Revenue Code of 1986 to permit the consolidation of life insurance companies with other companies; entire bill H.R. 2419 - Food and Energy Security Act of 2007; provisions relating to basis reporting H.R. 2796 Generate Retirement Ownership Through Long-Term Holding Act of 2007, entire bill H.R. 3221 - American Housing Rescue and Foreclosure Prevention Act of 2008; provisions relating to tax H.R. 3501 - To amend the Internal Revenue Code of 1986 relating to application of UBIT rules to U.S.-based investments; entire bill H.R. 3970 - Tax Reduction and Reform Act of 2007; provisions relating to individual and corporate rates and dividends received deduction H.R. 4912 - To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts; provisions relating to exchange traded notes H.R. 5267 - Business Activity Tax Simplification Act of 2008; entire bill H.R. 5719 - Taxpayer Assistance and Simplification Act of 2008; provisions relating to HSA compliance requirements H.R. 5720 - Housing Assistance Tax Act of 2008; provisions relating to individual tax benefits and basis reporting H.R. 6049 - The Energy and Tax Extenders Act of 2008; provisions relating to R&D, small business, and IRA charitable rollovers . H.R. 6110 - Roadmap for America's Future Act; entire bill H.R. 6288 Retiree Health Account Act; entire bill H.R. 7005 The Alternative Minimum Tax Relief Act of 2008; entire bill H.R. 7006 The Disaster Tax Relief Act of 2008; provisions relating to withdrawals from savings vehicles H.R. 7060 - Renewable Energy and Job Creation Tax Act of 2008; provisions relating to basis reporting, IRA charitable rollovers, small business, R&D S. 601 - Simplification Through Additional Reporting Tax Act of 2007; entire bill S. 636 Reduce Wasteful Tax Forms Act of 2007; entire bill S. 1593 - Defenders of Freedom Tax Relief Act; provisions relating to savings S. 1726 The Business Activity Tax Simplification Act; entire bill S. 2126 - Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007; entire bill S. 2242 - Heartland, Habitat, Harvest, and Horticulture Act of 2007; tax title provision on basis reporting S. 3335 Jobs, Energy, Families and Disaster Relief Act of 2008; provisions relating to basis reporting, IRA charitable rollovers, small business, AMT, R&D, and withdrawals from savings vehicles for disaster relief S. 2886 - The Alternative Minimum Tax and Extenders Tax Relief Act; provisions relating to R&D, small business, and IRA charitable rollovers S. 2933 - Incentives for Older Workers Act; provisions relating to employer-based programs
Client expense: $180,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Financial Institutions/Investments/Securities
H.R. 4912 and H.R 3185, provisions relating to 401(k) fee disclosure.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
Legislative issues affecting the mutual fund industry including prepaid derivative contracts (H.R. 4912)
Client expense: Not reported · Firm income: $20,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
HR 4912, "To amend the Internal Revenue Code with respect to the treatment of prepaid derivative contracts." HR 6049, "Energy and Tax Extenders Act of 2008." (Including nonqualified deferred compensation) HR 1424, "Emergency Economic Stabilization Act of 2008."(Tax Titles)
Client expense: $140,000 · Firm income: Not reported
Government targets: Education, Dept of, Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 6- Energy Independence Security Act of 2007; H.R. 878 & S. 601- broker reporting; H.R. 1509 & S. 940- Subpart F; H.R. 2136, H.R. 2345 & S. 681- tax shelters; H.R. 3970- tax reform/corporate tax; H.R. 3996- Temporary Tax Relief Act of 2007; H.R. 4912- prepaid derivatives; H.R. 5351 & S. 1508- energy tax credit extensions; S. 2- minimum wage; S. 349- small business tax issues; S. 2242- alternative energy tax incentives; (no bill #)- regulations re: foreign tax credit & non-compulsory payments; continued . . . H.R. 5160- Small Business Add Value for Employees Act of 2008; H.R. 2167- Automatic IRA Act of 2007; H.R. 3361- Pension Protection Technical Corrections Act of 2007; H.R. 6382- Pension Protection Technical Corrections Act
Client expense: $1,240,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
Deferred Compensation - H.R. 3923 provisions included in H.R. 3970, H.R. 3996, H.R, 4195 Exchange Traded Notes- H.R. 4912 Emergency Economic Stabilization Act - H.R. 1424
Client expense: $590,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 4912 - To Amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivatives contracts S. 349 - Small Business and Work Opportunity Act of 2007 H.R. 3996 Temporary Tax Relief Act of 2007 (See addendum page) H.R. 976 Small Business Tax Relief Act of 2007 H.R. 5140 Economic Stimulus Act of 2008 S. 2886 - Alternative Minimum Tax and Extenders Tax Relief Act of 2008 H.R. 5749 - Emergency Extended Unemployment Compensation Act of 2008 H.R. 6049 - Energy Improvement and Extension Act of 2008 H.R. 7202 Temporary Tax Relief Act of 2008 S. 3335 - Jobs, Energy, Families, and Disaster Relief Act of 2008
Client expense: $420,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
See Addendum S. 14, "Invest in America Act", provision relating to estate tax repeal. S. 158, "Access to Affordable Health Care Act", Section 224 (Premiums on Long-Term Care Qualified Contracts) S. 349, Small Business and Work Opportunity Act of 2007. S. 504, "Long-Term Care Trust Account Act of 2007". S. 601, Simplification Through Additional Reporting Tax Act of 2007 (Broker reporting of customer's basis in mutual fund transactions). S. 1010, "Retirement Security for Life Act of 2007". S. 1753, "Healthy Workforce Act". S. 1809, "Long-Term Care Act of 2007". S. 2044, "Independent Contractor Proper Classification Act of 2007". S. 2126, "Generating Retirement Ownership Through Long-Term Holding (Growth) Act of 2007. S. 2337, "Long-Term Care Affordability and Security Act of 2007". S. 3125, "Energy Independence and Tax Relief Act of 2008", Section 241, Subpart F - Exception for Active Financing Income. S. 3289, "To Permanently Extend the Estate Tax as in Effect in 2009". S. 3327, "Empowered at Home Act of 2008", provision allowing tax deductino for a certain percentage of long-term care premiums. H.R. 46, "Small Business Tax Fairness and Simplification Act of 2007". H.R. 6, "Energy Independance and Security Act of 2007" (mutual fund cost basis reporting). H.R. 411, To amend the Internal Revenue Code of 1986 to make permanent certain expiring provisions..., provision relating to estate tax repeal H.R. 878, Simplification Through Additional Reporting Tax Act of 2007 (S. 601, H.R. 878) (Broker reporting of customer's basis in mutual fund transactions). H.R. 976, "Small Business Tax Relief Act of 2007". H.R. 2205, "Retirement Security for Life Act of 2007". H.R. 2380, "Death Tax Repeal Permanency Act of 2007". H.R. 2582, "Qualified Long-Term Care Fairness Act of 2007". H.R. 2796, "Generate Retirement Ownership through Long-Term Holding Act of 2007". H.R. 3088, "Long-Term Care Act of 2007". H.R. 3125, "Energy Independence and Tax Relief Act of 2008", Section 241, Subpart F - Exception for Active Financing Income. H.R. 3221, "American Housing Rescue and Foreclosure Prevention Act of 2008", Section 641 (related to mutual fund cost basis reporting). H.R. 3363, "Long-Term Care Affordability and Security Act". H.R. 3970, "Tax Reduction and Reform Act of 2007" - Provisions related to modification of unrelated business income tax rules for certain investment partnerships, basis reporting by brokers on sales of stocks, extension of special rules for regulated investment companies, reduction in corporate tax rate. H.R. 3996, "Temporary Tax Relief Act of 2007", Section 622 - Broker Reporting of Customer Basis in Securities Transactions; and Section 201 - Non-qualified Deferred Compensation from Certain Tax Indifferent Parties. H.R. 4912, "To amend the Internal Revenue Code of 1986 with respect to prepaid derivative contracts". H.R. 6049, "Renewable Energy and Job Creation Act of 2008", Section 239, Subpart F, "Exception for Active Financing Income". H.R. 6237, "Tax Relief for Long-Term Care Act of 2008". H.R. 6499, "Sensible Estate Tax Act of 2008". H.R. 7060, "Renewable Energy and Job Creation Act of 2008", Section 403, Broker Reporting of Customer Basis in Securities Transactions. IRS Notice 2008-18 (1/13/08) - Life Insrance Reserves: proposed AG VACARVM and Life PBR. Current tax treatment of Stranger-Originated Life Insurance (STOLI) - no bill number. Dividends Received Deduction for Life Insurers - no bill number. Life Insurance Company Reserves - no bill number. Senate Finance Committee, "Proposed Legislation on the Taxation of Exchange-Traded Notes" - no bill number.
Client expense: $780,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
Taxation of mutual funds and mutual fund investors, taxation of exchange-traded notes, H.R. 4912
Client expense: Not reported · Firm income: $10,000
Government targets: SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
HR 4912 To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts
Client expense: Not reported · Firm income: $22,500
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Financial Institutions/Investments/Securities
HR 2868 "Second Tier markets Act" CFTC reauthorization HR 4912 To amend the Internal Revenue Code of 1986 with respect to the treatments of prepaid derivative contracts
Client expense: $43,875 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 976 - Small Business Tax Relief Act of 2007 S. 349 - Small Business and Work Opportunity Act of 2007 H.R. 4912 - Tax Treatment of Prepaid Derivative Contracts H.R. 3996 - The Temporary Tax Relief Plan H.R. 5140 - Economic Stimulus Act of 2008 H.R. 6049 - Energy and Tax Extenders Act of 2008 S. 2886 - Alternative Minimum Tax and Extenders Tax Relief Act of 2008 H.R. 5749 - Emergency Extended Unemployment Compensation Act of 2008 H.R. 6049 - Energy and Tax Extenders Act of 2008 H.R. 7202 - Temporary Tax Relief Act of 2008 S. 3335 - Jobs, Energy, Families, and Disaster Relief Act of 2008
Client expense: Not reported · Firm income: $100,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · second_quarter · Taxation/Internal Revenue Code
HR 6049 Renewable Energy and Job Creation Act, regarding providing new markets, solar credits and interest allocation; HR 6275 Alternative Minimum Tax Relief Act, regarding merchant payment reporting; HR 3359 Mobile Workforce State Income Tax Fairness and Simplification Act, regarding state taxation of nonresidents; HR 5719 Taxpayer Assistance and Simplification Act, regarding health savings account payment substantiation; HR 1023 Withholding Tax Relief Act, regarding TIPRA withholding on government payments; S 1850 Tribal Government Tax-Exempt Bond Parity Act, regarding tribal tax-exempt bonds; Issues involving US-Canada income tax treaty; HR 4912 amend the Internal Revenue Code involving taxation of derivative instruments; HR 6333 Municipal Bond Market Support Act, regarding financial institutions tax exempt interest expense; HR 2419 Food, Conservation, and Energy Act, regarding modifications to IRS section 470.
Client expense: $1,150,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Education, Dept of, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
2008 · second_quarter · Taxation/Internal Revenue Code
Modification and extension of withholding tax provision for foreign persons investing in U.S. mutual funds (IRC section 871(k)); HR. 6049; S. 3098; S. 3125; commodity index swaps as qualifying income for mutual funds (Revenue Ruling 2006-1); HR.3996; H.R.4912; tax treatment of exchange traded notes.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · second_quarter · Taxation/Internal Revenue Code
S.940; HR.1509; S.349; HR.6; HR. 2776; renewable energy tax incentives for wind, solar and smart grid; IRC sections 45 and 48; S.6049; S.3098; S.3125; S.1370 (sections 4 and 5); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; issues relating to inclusion of arbitration provisions in tax treaties; H.R.4912; tax treatment of exchange traded notes; Deferred compensation; HR. 6049; S.3098; S. 3125.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · second_quarter · Taxation/Internal Revenue Code
S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).
Client expense: $1,050,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Education, Dept of, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Security Council (NSC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office