Lifelong Learning Accounts Act of 2008

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Client expense: $2,030,000 · Firm income: Not reported

Government targets: Bureau of Economic Analysis, Bureau of Industry and Security (BIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Central Intelligence Agency (CIA), Commerce, Dept of (DOC), Council of Economic Advisers (CEA), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), Food & Drug Administration (FDA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Agency (NSA), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Vice President of the United States, Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

Proposals related to the treatment of education savings including H.R. 2458/S. 1501, Universal Higher Education Lifetime Learning Act, S. 1230, College Savings Credit Act. Proposals related to Learning Accounts, H.R. 5591, Help Kids Save for College. H.R. 6036, Lifelong Learning Accounts Act. S. 1230, College Savers Credit Act. Proposals to amend the Internal Revenue Code to exclude 529 education savings accounts from means testing. Proposals related to The Definition of qualified higher education expenses. Proposals related to 529 college savings plan investment changes.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Negotiation and Ratification of Bilateral Income Tax Treaties Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification H.R. 4297, Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591, U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 1424, Paul Wellstone Mental Health and Addiction Equity Act of 2007

Proposals related to creation of new savings accounts to finance lifetime learning, including H.R. 6036, Lifelong Learning Accounts Act. H.R. 1820, Tax Equity for Health Plan Beneficiaries Act. S. 1556, Tax Equity for Domestic Partner and Health Plan Beneficiaries Act.

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

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

Negotiation and Ratification of Bilateral Income Tax Treaties U.S.-Canada Tax Treaty Revision of Tax Provisions in U.S. Model Treaty U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section F; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification H.R. 4297, Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591, U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38

H.R. 4137, College Opportunity and Affordability Act of 2008 H.R. 6036, Lifelong Learning Accounts Act of 2008 No Child Left Behind reauthorization

Client expense: $20,600,000 · Firm income: Not reported

Government targets: Bureau of Land Management (BLM), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Minerals Management Service, Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Proposals related to creation of new savings accounts to finance lifetime learning, including H.R. 6036, Lifelong Learning Accounts Act. H.R. 1820, Tax Equity for Health Plan Beneficiaries Act. S. 1556, Tax Equity for Domestic Partner and Health Plan Beneficiaries Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals related to the treatment of education savings including proposals in The President's FY 2009 Budget, H.R. 2458/S. 1501, Universal Higher Education Lifetime Learning Act, S. 1230, College Savings Credit Act. Proposals related to Learning Accounts, H.R. 5591, Help Kids Save for College. H.R. 6036, Lifelong Learning Accounts Act. S. 1230, College Savers Credit Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lifelong Learning Accounts (LiLAs) (H.R. 6036)

Client expense: $10,818 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals related to the treatment of education savings including proposals in The President's FY 2009 Budget, H.R. 2458/S. 1501, Universal Higher Education Lifetime Learning Act, S. 1230, College Savings Credit Act. Proposals related to Learning Accounts, H.R. 5591, Help Kids Save for College. H.R. 6036, Lifelong Learning Accounts Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Negotiation and Ratification of Bilateral Income Tax Treaties U.S.-Canada Tax Treaty Revision of Tax Provisions in U.S. Model Treaty U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section F; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification H.R. 4297, Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591, U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38

Proposals related to creation of new savings accounts to finance lifetime learning, including H.R. 6036, Lifelong Learning Accounts Act. H.R. 1820, Tax Equity for Health Plan Beneficiaries Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE