Foreign Account Tax Compliance Act of 2009

U.S. international tax including deferral, foreign tax credits: H.R. 4213 The American Jobs and Closing Tax loopholes Act 2010; H.R. 5893 Investing in American Jobs and Closing Tax loopholes Act of 2010; S. 3816 Creating Jobs and Ending Offshoring Act; H.R. 1586 FAA AIr Transport and Modernization Act with international offsets; Check the box entity classification Corporate tax reform: S. 3018 Bipartisan Tax Fairness and Simplification Act of 2010; H.R. 3970 Tax Reduction and Reform Act of 2007 (110th Congress) R&D tax credit (alternative simplified credit, ASC): H.R. 422 and S. 1203 to amend IRC to extend research credit through 2010 and increase and make permanent the ASC credit Other Treasury and IRS regulations: Economic substance codification; contract manufacturing; cost-sharing; Subpart F exemptions; S. 1934/H.R. 3933, Foreign Account Tax Compliance Act of 2009 Bilateral income tax treaties: Spain, Singapore, Korea, China, India and Brazil OECD guidelines and U.S. Treasury comments on taxation of intangibles, cross-border services taxation wit VAT/GST, and business restructuring Other bills and regulations: H.R. 2110 Mobile Workforce state income tax fairness; H.R. 5013 Implementing Management for Performance and Related reforms to obtain value in every acquisition Act of 2010; H.R. 5715 Lifelong Learning Accounts Act of 2010; H.R. 1083 BAT Simplifcation Act of 2009 and P.L. 86-272; Support centers excise tax; bonus depreciation

Client expense: $980,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense Advanced Research Projects Agency (DARPA), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Institute of Standards & Technology (NIST), Natl Security Agency (NSA), Natl Security Council (NSC), Office of Science & Technology Policy (OSTP), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

U.S. international tax including deferral, foreign tax credits: H.R. 4213 The American Jobs and Closing Tax loopholes Act 2010; H.R. 5893 Investing in American Jobs and Closing Tax loopholes Act of 2010; S. 3816 Creating Jobs and Ending Offshoring Act; H.R. 1586 FAA AIr Transport and Modernization Act with international offsets; Check the box entity classification Corporate tax reform: S. 3018 Bipartisan Tax Fairness and Simplification Act of 2010; H.R. 3970 Tax Reduction and Reform Act of 2007 (110th Congress) R&D tax credit (alternative simplified credit, ASC): H.R. 422 and S. 1203 to amend IRC to extend research credit through 2010 and increase and make permanent the ASC credit Other Treasury and IRS regulations: Economic substance codification; contract manufacturing; cost-sharing; Subpart F exemptions; S. 1934/H.R. 3933, Foreign Account Tax Compliance Act of 2009 Bilateral income tax treaties: Spain, Singapore, Korea, China, India and Brazil OECD guidelines and U.S. Treasury comments on taxation of intangibles, cross-border services taxation wit VAT/GST, and business restructuring Other bills and regulations: H.R. 2110 Mobile Workforce state income tax fairness; H.R. 5013 Implementing Management for Performance and Related reforms to obtain value in every acquisition Act of 2010; H.R. 5715 Lifelong Learning Accounts Act of 2010; H.R. 1083 BAT Simplifcation Act of 2009 and P.L. 86-272; Support centers excise tax; bonus depreciation

Client expense: $980,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense Advanced Research Projects Agency (DARPA), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Institute of Standards & Technology (NIST), Natl Security Agency (NSA), Natl Security Council (NSC), Office of Science & Technology Policy (OSTP), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

S.1934/H.R.3933, Foreign Account Tax Compliance Act of 2009 - foreign income reporting S.3018, Bipartisan Tax Fairness and Simplification Act of 2010 - tax reform S.3217, Restoring American Financial Stability Act of 2010 - Executive Compensation/Proxy Rules S. 3816, Creating Jobs and Ending Offshoring Act - international tax provisions H.R.1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272 - federal preemption H.R.1586, The FAA Air Transportation Modernization and Safety Improvement Act - Senate amendment 4575 with international tax offsets H.R.2110, Mobile Workforce State Income Tax Fairness and Simplification Act - multistate taxation H.R.4213, The American Jobs and Closing Tax Loopholes Act of 2010 - tax extenders H.R.5013, Implementing Management for Performance and Related Reforms to Obtain Value in Every Acquisition Act of 2010, to repeal S.511 of the Tax Increase and Prevention Act and related IRS notice 2008-38 H.R. 5715, Lifelong Learning Accounts Act of 2010 - employee learning accounts H.R. 5893, Investing in American Jobs and Closing Tax Loopholes Act of 2010 - international tax provisions Deferral, foreign tax credit rules and H.R. 3970 (110th Cong.), "Tax Reduction and Reform act of 2007" Treasury "Check-the-Box" Entity Classification Regulations Treasury Reg. Section 338 on denial of foreign credits for covered asset acquisitions Treasury Reg. Section 956 on foreign tax credit planning Contract manufacturing in 954(d) and Treasury regs 1.954-3 Economic substance doctrine codification and modification Support Centers Excise Tax Treasury cost-sharing regulations under 1.482-7T (g) Bilateral tax treaties for Spain, Singapore, Korea, China, India and Brazil OECD Guidelines on taxation of cross-border services, business restructuring and permanent establishment Bonus depreciation

Client expense: $1,040,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Security Agency (NSA), Office of Science & Technology Policy (OSTP), Office of Special Counsel, Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act H.R.4213 American Workers, State, and Business Relief Act H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $1,090,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Accounting and Tax issues related to Non US Insurers and Reinsurers, Natural Disaster Risk Financing: HR 4213, HR 3424, HR 3933, and S 1934

Client expense: $150,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Accounting and Tax issues related to Non US Insurers and Reinsurers, Natural Disaster Risk Financing HR 4213, HR 3424, HR 3933, and S 1934

Client expense: $150,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act H.R.4213 American Workers, State, and Business Relief Act H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $1,090,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act of 2009 S. 1588 Stop Tax Breaks for Oil Profiteering Act of 2009 H.R. 3933 Foreign Account Tax Compliance Act of 2009 H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act of 2009 H.R.4213 American Workers, State, and Business Relief Act of 2010 H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $1,070,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) Against Anti-Tax Haven Bills (S. 506, H.R. 1265, H.R. 3933 & S.1934).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of

S.292 - Withholding Tax Relief Act of 2009 H.R.275 - To repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities H.R.3933 - Foreign Account Tax Compliance Act of 2009 S.1934 - Foreign Account Tax Compliance Act of 2009

Client expense: $1,680,000 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

Administration's FY2010 International Tax Proposals; Administration's FY2010 and Senate Finance Committee discussion draft offshore tax compliance proposals; H.R. 847 (9/11 Health and Compensation Act)(worker classification rules); H.R. 3408 (Taxpayer Responsibility, Accountability, and Consistency Act of 2009); H.R. 3933 (Foreign Account Tax Compliance Act); H.R. 4173 (Dodd-Frank Wall Street Reform and Consumer Protection Act); H.R. 4213 (American Jobs and Closing Tax Loopholes Act); H.R. 4849 (Small Business and Infrastructure Jobs Tax Act); H.R. 4853 (Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010)(taxation of dividends and capital gains, extension of expiring business provisions); H.R. 5297 (Small Business Jobs Act of 2010); H.R. 6128 (Fair Playing Field Act of 2010)(worker classification); S. 506 (Stop Tax Haven Abuse Act) (Administration's FY2010 dividend withholding proposals); S. 2882 (Taxpayer Responsibility, Accountability and Consistency Act of 2009); S. 2994 (Taxpayer Fairness Act); S. 3350 (Municipal Bond Market Support Act of 2010); S. 3786 (Fair Playing Field Act of 2010)(worker classification); S. 3793 (Job Creation and Tax Cuts Act of 2010); Build America Bonds; Extension of Build America Bonds; Expansion of Build America Bond Rules to Tax Credit Bonds; Tax rules relating to regulation of over-the-counter derivative contracts; Extension of Federal Home Loan Bank Guarantee; Financial Transaction Tax Proposals; Tax issues related to standardization of credit default swaps; Extension of Active Financing Rules; Tax issues related to implementation of charge for failure to deliver Treasury securities; Administration's Financial Crisis Responsibility Fee; Tax issues related to interest expense allocation; Tax treatment of capital gains and dividends; Taxation of independent contractors; Taxation of cross-border equity swaps; Corporate tax reporting rules; Bonus tax proposals; Tax reporting requirements for foreign financial institutions on certain foreign accounts; Foreign Account Tax Compliance Act (FATCA), provisions enacted under the Hiring Incentives to Restore Employment Act (Notice 2010-60); Extension of the Alternative Minimum Tax, tax exemption for private activity bonds; Notice 2010-46 (Tax withholding on substitute dividend payments); Securities cost basis reporting regulations; Tax rules relating to Bearer Bonds.

Client expense: $1,280,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), 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)

H.R. 4213, the Tax Extenders Act of 2009. H.R. 3933/S. 1934, the Foreign Account Tax Compliance Act of 2009. Issues related to the financial crisis responsibility fee.

Client expense: Not reported · Firm income: $150,000

Government targets: Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act S. 3816 Creating American Jobs and Ending Offshoring Act H.R. 4853 Tax Relief, Unemployments Insurance Reauthorization, and Job Creation Act of 2010 H.R. 6467 Middle Class Tax Relief Act of 2010

Client expense: $670,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 436 - Certain Estate Tax Relief Act of 2009; entire bill H.R. 847 - James Zadroga 9/11 Health and Compensation Act of 2010; provisions relating to possible use of workforce classification reforms as the revenue offset (P.L. 111-347, 1/2/2011) H.R. 1083 - The Business Activity Tax Simplification Act of 2009; entire bill H.R. 1935 - To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services; entire bill H.R. 2920 Statutory Pay Go Act of 2009; provisions relating to estate tax and middle class tax benefits H.R. 3408 - Taxpayer Responsibility, Accountability, and Consistency Act of 2009; provisions relating to limitation of independent contractor status for independent broker dealers H.R. 3905 Estate Tax Relief Act; entire bill H.R. 3933 - Foreign Account Tax Compliance Act of 2009; to ensure workable reporting requirements for mutual funds H.R. 4154 - Permanent Estate Tax Relief for Families, Farmers, and Small Businesses Act of 2009; entire bill H.R. 4191 - Let Wall Street Pay for the Restoration of Main Street Act of 2009; entire bill H.R. 4337 - Regulated Investment Company Modernization Act of 2009; entire bill (P.L. 111-325, 12/22/2010) H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010; provisions relating to small business capital gains exclusion and Build America Bonds H.R. 4853 - Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010; provisions relating to individual tax rates/estate tax and extenders, small business incentives relevant to the financial services sector H.R. 5982 Small Business Tax Relief Act of 2010; provisions relating to repeal of 1099 reporting obligations enacted in health care reform H.R. 6128 Fair Playing Field Act of 2010; provisions that would affect use of independent contractors within the securities industry S. 506 - Stop Tax Haven Abuse Act; provision relating to managed and controlled foreign entities S. 567 - A bill to repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gains rates; entire bill S. 651 - Compensation Fairness Act of 2009; entire bill S. 722 - Taxpayer Certainty and Relief Act of 2009; provisions relating to capital gains, dividends, and estate tax S. 1007 - Excessive Pay Capped Deduction Act of 2009; entire bill S. 2784 - A bill to amend the Internal Revenue Code of 1986 to permanently extend the estate tax as in effect in 2009; entire bill S. 2869 Small Business Job Creation and Access to Capital Act of 2009; entire bill S. 2882 - Taxpayer Responsibility, Accountability, and Consistency Act of 2009; provisions relating to independent contractors within the securities industry S. 2927 - Wall Street Fair Share Act; entire bill S. 3513 Bonus Depreciation Extension to Create Jobs Act; entire bill S. 3773 Tax Hike Prevention Act of 2010; provisions relating to capital gains dividends and estate tax S. 3786 Fair Playing Field Act; provisions that would affect use of independent contractors within the securities industry S. 3793 Job Creation and Tax Cuts Act of 2010; entire bill S. 3816 Creating American Jobs and Ending Offshoring Act; entire bill S. 3946 - Small Business Paperwork Relief Act; entire bill Administrations FY 2011 budget proposals relating to Auto IRA retirement savings initiatives, taxation of life insurance companies, international taxation, tax treatment of capital gains and dividends, independent contractor, estate tax, and Financial Crisis Responsibility Fee

Client expense: $270,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax issues affecting foreign-owned banks, including withholding tax issues and proposals for modifications to the Qualified Intermediary rules, and proposals for additional information reporting (H.R.3933, S.1934, H.R.4213, H.R.2847, and new IRC sections 1471-1474).

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

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

Limit Executive Compensation Abuse Act - H.R. 857 The Savings for American Families Future Act of 2009 H.R. 1961 The 401 (k) Fair Disclosure for Retirement Security Act 0f 2009 H.R. 1984 Conflicted Investment Advice Prohibition Act of 2009 H.R. 1988 Savings Recovery Act H.R. 2021 Retirement Security Needs Lifetime Pay Act H.R. 2748 Retirement Savings Transparency Act of 2009 - H.R. 2792 The Defined Contribution Plan Fee Transparency Act H.R. 2779 401 (k) Fair Disclosure and Pension Security Act of 2009 H.R. 2989 Consumer Financial Protection Agency Act of 2009 H.R. 3126 Foreign Account Tax Compliance Act of 2009 H.R. 3933 Preserve Benefits and Jobs Act of 2009 H.R. 3936 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962/Public Law No: 111-192 Retirement Fairness Act H.R. 4126 Sensible Transparency for Retirement Plans Act H.R. 4146 Tax Technical Corrections Act of 2009 H.R. 4169 Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 American Workers, State, and Business Relief Act H.R. 4213/Unemployment Compensation Extension Act of 2010 (tax extenders) Public Law No: 111-205 Small Businesses Add Value for Employees Act of 2009 (SAVE Act) H.R. 4742 Middle Class Tax Cut Act (Senate Amendment 4727) package of tax extensions and other provisions to the defined benefit pension funding relief provisions, and a provision extending parity for employee transit subsidies Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act H.R. 4853 Amendment to a Federal Aviation Administration funding extension bill H.R. 4915 Medicare and Medicaid Extenders Act H.R. 4994 Employee Misclassification Prevention Act (EMPA) H.R. 5107 Small Business Jobs and Credit Act of 2010 H.R. 5297 tax extenders, defined benefit pension plan funding relief - technical corrections from H.R. 3962 Automatic IRA Act of 2010 H.R. 6099 Fair Playing Field Act of 2010 H.R. 6128 (worker classification) Public Employee Pension Transparency Act - H.R. 6484 Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension Funding - additional funding relief and technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, plan termination issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, conversions to Roth 401 (k) plans, automatic IRAs, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures for retirement plans National Commission on Fiscal Responsibility and Reform implications for benefits Senate Cap Executive Officer Pay Act of 2009 - S. 360 The Defined Contribution Fee Disclosure Act of 2009 - S. 401 Shareholder Bill of Rights Act S. 1074 Retirement Security for Life Act of 2009 S. 1297 Pension Benefit Guaranty Corporation (PBGC) Governance Improvement Act of 2009 S. 1544 Foreign Account Tax Compliance Act of 2009 S. 1934 Lifetime Income Disclosure Act S. 2832 Create Jobs and Save Benefits Act of 2010 S. 3157 Restoring American Financial Stability Act/Wall Street Transparency and Accountability Act S. 3217 Employee Misclassification Prevention Act (EMPA) S. 3254 Automatic IRA Act of 2010 S. 3760 Paycheck Fairness Act S. 3772 Fair Playing Field Act of 2010 S. 3786 (worker classification) Job Creation and Tax Cuts Act of 2010 S. 3793 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962, Public Law No: 111-192 American Workers, State, and Business Relief Act /American Jobs and Closing Tax Loopholes Act (tax extenders) H.R. 4213, & Substitute amendments Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Middle Class Tax Cut Act (Senate Amendment 4727) package of tax extensions and other provisions to the defined benefit pension funding relief provisions, and a provision extending parity for employee transit subsidies Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act H.R. 4853 Amendment to a Federal Aviation Administration funding extension bill H.R. 4915 Medicare and Medicaid Extenders Act H.R. 4994 Small Business Jobs and Credit Act of 2010 H.R. 5297 (revised substitute) Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension funding additional funding relief and technical corrections for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, plan termination and governance issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, automatic IRAs, conversions to Roth 401(k) plans, investment advice, investment selection (target date funds), the Savers Credit, lifetime income issues, nondiscrimination rules for retirement plans, plan loans, tax expenditures for retirement plans, long-term disability policies (LTDs) National Commission on Fiscal Responsibility and Reform implications for benefits Pension funding relief - adequacy of defined benefit vehicles, hybrids, proposed hybrid retirement plan regulations, retirement plan designs, and tax treatment of expatriates Investment advice - adequacy of defined contribution vehicles, investment selection (target date funds) and annuity issues, automatic/mandatory individual retirement accounts (IRAs), proposed regulations regarding target date funds (TDFs) and qualified default investment alternatives (QDIAs) Disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers -ERISA Section 408 (b) (2), Fiduciary requirements 401 (k) participant fee disclosure regulations, proposed definition of fiduciary for investment advice arrangements, in-plan Roth conversions issues Defined Benefit (DB) plan year filing issues Form 5500 (EFAST) Cash balance and pension equity plans, market rate of return for hybrid plans Nonqualified deferred compensation (NQDC), new compensation deduction limits on entities receiving health insurance premiums 162 (m) (6) Pension Benefits Guaranty Corporation (PBGC) premium funding target methods (variable rate premiums), premium submission and plan termination issues, proposed regulations - (ERISA Section 4062(e)) Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) Financial services regulatory reform, executive compensation disclosure issues, involvement with employee benefit plans, Swaps, definition of major swap participant and major security-based swap participant, business conduct standards, family offices, Domestic plan asset investment issues Puerto Rican plan trust issues Multiemployer plan issues

Client expense: $272,633 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

HR 1984/1988/289/4146; S.401: 401(k) Fair Disclosure for Retirement Security Act of 2009 HR 4213/S 1934/S 3191/S 3333: Investing in American Jobs and Closing Tax Loopholes Act of 2010; Title II, subsections A, C, D (expiring tax provisions) HR 2897: Bank Accountability and Risk Assessment Act of 2009; PL 111-166 HR 1083: Simplification Act; PL 111-166 HR 989/S. 829: Eagle Employers Act HR 3933/S. 1934: Foreign Account Tax Compliance Act HR 2460/S. 1152: Healthy Families Act HR 1987/1508/S. 803: Healthy Workforce HR 5328: International Tax Cmpetitiveness Act of 2010 HR 1068: Let Wall Street Pay for Wall Street's Bailout Act of 2009 HR 5297: Small Business Jobs and Credit Act of 2010; P.L. 111-499 HR 2098: Corporations Bank Accountability and Risk Assessment Act of 2009; PL 111-166 HR 422: Extend R&D tax credit to through 2010, increase & make permanent alternative simplified credit (R&D Tax credit) HR 1542: TARP Bonus Tax HR 1944/HR 2089: Subpart F Extension HR 2158/HR 3530/S. 929: Nonroad Alternative Powered Equipment Tax Credits HR 3135: To amend the Internal Revenue Code of 1986 to provide additional incentives for facilities producing electricity from wind HR 3136/S. 2899: To extend the program to provide grants for specified energy property in lieu of tax credits HR 275/S. 392: Repeal of 3% witholding on certain payments to vendors by government entities S. 2927: A bill to amend the Internal Revenue Code of 1986 to impose a tax on certain securities transactions to fund job creation and deficit reduction, and for other purposes. HR 3404/3548, S. 1647: Worker, Homeownership, and Business Assistance Act of 2009; P.L. 111-92 HR 1274: Working Families Flexibility Act HR 5297: Small Business Jobs & Credit Act of 2010; P.L. 111-499 HR 5982: Small Business Tax Relief Act of 2010 HR 1586/S. 1451: FAA Air Transportation Modernization and Safety Improvement Act; Amendment 4567 (treatment of foreign tax); P.L. 111-226 HR 4853: Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 111-312

Client expense: $460,000 · Firm income: Not reported

Government targets: Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Natl Guard, SENATE

U.S. international tax including deferral, foreign tax credits: H.R. 4213 The American Jobs and Closing Tax loopholes Act 2010; H.R. 5893 Investing in American Jobs and Closing Tax loopholes Act of 2010; S. 3816 Creating Jobs and Ending Offshoring Act; H.R. 1586 FAA AIr Transport and Modernization Act with international offsets; Check the box entity classification Corporate tax reform: S. 3018 Bipartisan Tax Fairness and Simplification Act of 2010; H.R. 3970 Tax Reduction and Reform Act of 2007 (110th Congress) R&D tax credit (alternative simplified credit, ASC): H.R. 422 and S. 1203 to amend IRC to extend research credit through 2010 and increase and make permanent the ASC credit Other Treasury and IRS regulations: Economic substance codification; contract manufacturing; cost-sharing; Subpart F exemptions; S. 1934/H.R. 3933, Foreign Account Tax Compliance Act of 2009 Bilateral income tax treaties: Spain, Singapore, Korea, China, India and Brazil OECD guidelines and U.S. Treasury comments on taxation of intangibles, cross-border services taxation wit VAT/GST, and business restructuring Other bills and regulations: H.R. 2110 Mobile Workforce state income tax fairness; H.R. 5013 Implementing Management for Performance and Related reforms to obtain value in every acquisition Act of 2010; H.R. 5715 Lifelong Learning Accounts Act of 2010; H.R. 1083 BAT Simplifcation Act of 2009 and P.L. 86-272; Support centers excise tax; bonus depreciation

Client expense: $980,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense Advanced Research Projects Agency (DARPA), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Institute of Standards & Technology (NIST), Natl Security Agency (NSA), Natl Security Council (NSC), Office of Science & Technology Policy (OSTP), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Taxation of investment funds, investment fund managers, Foreign Acct. Tax Compliance Act provisions, included in H.R. 3933, S. 1934, and H.R. 4203, S. 3793.

Client expense: Not reported · Firm income: $70,000

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE

Proposals in FY2010 budget for changing tax rules for foreign income of US taxpayers and US beneficiaries of foreign trusts, and to address the offshore tax evasion accounts; HR 1265, Stop Tax Haven Abuse Act; S. 1934, Foreign Account Tax Compliance Act of 2009; HR 3933, Foreign Account Tax Compliance Act of 2009

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) Against Anti-Tax Haven Bills (S. 506, H.R. 1265, H.R. 3933 & S.1934).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of

1) Sharing interest income on bank deposits with foreign tax collectors -- no specific legislation. 2) Foreign Account Tax Compliance Act of 2009 (FATCA) as introduced on October 27, 2009 (H.R. 3933, S. 1934). 3) H.R.2847: HIRE Act (FATCA-Provision in the omnibus bill)

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of

1) Sharing interest income on bank deposits with foreign tax collectors -- no specific legislation. 2) Foreign Account Tax Compliance Act of 2009 (FATCA) as introduced on October 27, 2009 (H.R. 3933, S. 1934). 3) H.R.2847: HIRE Act (FATCA-Provision in the omnibus bill)

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) Against Anti-Tax Haven Bills (S. 506, H.R. 1265, H.R. 3933 & S.1934).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act H.R.4213 American Workers, State, and Business Relief Act H.R. 4213 American Jobs and Closing Tax Loopholes Act H.R. 2847 Hiring Incentives to Restore Employment Act H.R. 1586 FAA Air Transportation Modernization and Safety Improvement Act H.R. 5297 Small Business Jobs and Credit Act S. 3816 Creating American Jobs and Ending Offshoring Act

Client expense: $890,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Administration's FY2010 International Tax Proposals; Administration's FY2010 and Senate Finance Committee discussion draft offshore tax compliance proposals; H.R. 3408 (Taxpayer Responsibility, Accountability, and Consistency Act of 2009); H.R. 3933 (Foreign Account Tax Compliance Act); H.R. 4173 (Dodd-Frank Wall Street Reform and Consumer Protection Act); H.R. 4213 (American Jobs and Closing Tax Loopholes Act); H.R. 4849 (Small Business and Infrastructure Jobs Tax Act); H.R. 5297 (Small Business Jobs Act of 2010); H.R. 6128 (Fair Playing Field Act of 2010)(worker classification); S. 506 (Stop Tax Haven Abuse Act) (Administration's FY2010 dividend withholding proposals); S. 2882 (Taxpayer Responsibility, Accountability and Consistency Act of 2009); S. 2994 (Taxpayer Fairness Act); S. 3350 (Municipal Bond Market Support Act of 2010); S. 3786 (Fair Playing Field Act of 2010)(worker classification); Build America Bonds; Extension of Build America Bonds; Expansion of Build America Bond Rules to Tax Credit Bonds; Tax rules relating to regulation of over-the-counter derivative contracts; Extension of Federal Home Loan Bank Guarantee; Financial Transaction Tax Proposals; Tax issues related to standardization of credit default swaps; Extension of Active Financing Rules; Tax issues related to implementation of charge for failure to deliver Treasury securities; Administration's Financial Crisis Responsibility Fee; Tax issues related to interest expense allocation; Tax treatment of capital gains and dividends; Taxation of independent contractors; Taxation of cross-border equity swaps; Corporate tax reporting rules; Bonus tax proposals; Tax reporting requirements for foreign financial institutions on certain foreign accounts; Foreign Account Tax Compliance Act (FATCA), provisions enacted under the Hiring Incentives to Restore Employment Act (Notice 2010-60); Extension of the Alternative Minimum Tax, tax exemption for private activity bonds; Notice 2010-46 (Tax withholding on substitute dividend payments); Securities cost basis reporting regulations; Tax rules relating to Bearer Bonds.

Client expense: $1,270,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), 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)

Legislative and regulatory tax issues before Congress and the Administration regarding active financing and international and domestic tax issues: - H.R. 1944: A bill to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income - Administration's Fiscal Year 2011 Revenue Proposals; - H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010 - Proposals related to the Taxation of Banks - H.R. 3933, S. 1934, the Foreign Account Tax Compliance Act of 2009 - H.R. 4169, the Tax Technical Corrections Act of 2009 - S. 2826, the Clean Renewable Energy Advancement Tax Extension Jobs Act of 2009 - S. 1639, a bill to improve and extend certain energy-related tax provisions - H.R. 2454, the American Clean Energy and Security Act of 2009 - S. 3793, the Job Creation and Tax Cuts Act - S. 2899 & H.R. 5931, the Renewable Energy Incentive Act - S. 3738, the Clean Energy Technology Leadership Act of 2010

Client expense: Not reported · Firm income: $240,000

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

H.R. 4213, the Tax Extenders Act of 2009. H.R. 3933/S. 1934, the Foreign Account Tax Compliance Act of 2009. Issues related to financial crisis responsibility fee.

Client expense: Not reported · Firm income: $160,000

Government targets: Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE

HR 1984/1988/289/4146; S.401: 401(k) Fair Disclosure for Retirement Security Act of 2009 HR 4213/S 1934/S 3191/S 3333: Investing in American Jobs and Closing Tax Loopholes Act of 2010; Title II, subsections A, C, D (expiring tax provisions) HR 2897: Bank Accountability and Risk Assessment Act of 2009; PL 111-166 HR 1083: Simplification Act; PL 111-166 HR 989/S. 829: Eagle Employers Act HR 3933/S. 1934: Foreign Account Tax Compliance Act HR 2460/S. 1152: Healthy Families Act HR 1987/1508/S. 803: Healthy Workforce HR 5328: International Tax Cmpetitiveness Act of 2010 HR 1068: Let Wall Street Pay for Wall Street's Bailout Act of 2009 HR 5297: Small Business Jobs and Credit Act of 2010; P.L. 111-499 HR 2098: Corporations Bank Accountability and Risk Assessment Act of 2009; PL 111-166 HR 422: Extend R&D tax credit to through 2010, increase & make permanent alternative simplified credit (R&D Tax credit) HR 1542: TARP Bonus Tax HR 1944/HR 2089: Subpart F Extension HR 2158/HR 3530/S. 929: Nonroad Alternative Powered Equipment Tax Credits HR 3135: To amend the Internal Revenue Code of 1986 to provide additional incentives for facilities producing electricity from wind HR 3136/S. 2899: To extend the program to provide grants for specified energy property in lieu of tax credits HR 275/S. 392: Repeal of 3% witholding on certain payments to vendors by government entities S. 2927: A bill to amend the Internal Revenue Code of 1986 to impose a tax on certain securities transactions to fund job creation and deficit reduction, and for other purposes. HR 3404/3548, S. 1647: Worker, Homeownership, and Business Assistance Act of 2009; P.L. 111-92 HR 1274: Working Families Flexibility Act HR 5297: Small Business Jobs & Credit Act of 2010; P.L. 111-499 HR 5982: Small Business Tax Relief Act of 2010 HR 1586/S. 1451: FAA Air Transportation Modernization and Safety Improvement Act; Amendment 4567 (treatment of foreign tax); P.L. 111-226

Client expense: $350,000 · Firm income: Not reported

Government targets: Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Natl Guard, SENATE

S.1934/H.R.3933, Foreign Account Tax Compliance Act of 2009 - foreign income reporting S.3018, Bipartisan Tax Fairness and Simplification Act of 2010 - tax reform S.3217, Restoring American Financial Stability Act of 2010 - Executive Compensation/Proxy Rules S. 3816, Creating Jobs and Ending Offshoring Act - international tax provisions H.R.1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272 - federal preemption H.R.1586, The FAA Air Transportation Modernization and Safety Improvement Act - Senate amendment 4575 with international tax offsets H.R.2110, Mobile Workforce State Income Tax Fairness and Simplification Act - multistate taxation H.R.4213, The American Jobs and Closing Tax Loopholes Act of 2010 - tax extenders H.R.5013, Implementing Management for Performance and Related Reforms to Obtain Value in Every Acquisition Act of 2010, to repeal S.511 of the Tax Increase and Prevention Act and related IRS notice 2008-38 H.R. 5715, Lifelong Learning Accounts Act of 2010 - employee learning accounts H.R. 5893, Investing in American Jobs and Closing Tax Loopholes Act of 2010 - international tax provisions Deferral, foreign tax credit rules and H.R. 3970 (110th Cong.), "Tax Reduction and Reform act of 2007" Treasury "Check-the-Box" Entity Classification Regulations Treasury Reg. Section 338 on denial of foreign credits for covered asset acquisitions Treasury Reg. Section 956 on foreign tax credit planning Contract manufacturing in 954(d) and Treasury regs 1.954-3 Economic substance doctrine codification and modification Support Centers Excise Tax Treasury cost-sharing regulations under 1.482-7T (g) Bilateral tax treaties for Spain, Singapore, Korea, China, India and Brazil OECD Guidelines on taxation of cross-border services, business restructuring and permanent establishment Bonus depreciation

Client expense: $1,040,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Equal Employment Opportunity Commission (EEOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Security Agency (NSA), Office of Science & Technology Policy (OSTP), Office of Special Counsel, Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 436 - Certain Estate Tax Relief Act of 2009; entire bill H.R. 1083 - The Business Activity Tax Simplification Act of 2009; entire bill H.R. 1265 - Stop Tax Haven Abuse Act; provisions relating to management and control of foreign corporations H.R. 1586 FAA Air Transportation Modernization and Safety Improvement Act; provisions relating to taxation of foreign operations H.R. 1935 - To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services; entire bill H.R. 2920 Statutory Pay Go Act of 2009; provisions relating to estate tax and middle class tax benefits H.R. 3408 - Taxpayer Responsibility, Accountability, and Consistency Act of 2009; provisions relating to limitation of independent contractor status for independent broker dealers H.R. 3905 Estate Tax Relief Act; entire bill H.R. 3933 - Foreign Account Tax Compliance Act of 2009; to ensure workable reporting requirements for mutual funds H.R. 4154 - Permanent Estate Tax Relief for Families, Farmers, and Small Businesses Act of 2009; entire bill H.R. 4191 - Let Wall Street Pay for the Restoration of Main Street Act of 2009; entire bill H.R. 4213 - American Workers, State, and Business Relief Act of 2010; provisions relating to tax extenders, carried interest, and fee disclosures H.R. 4337 - Regulated Investment Company Modernization Act of 2009; provisions relating to mutual funds H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010; provisions relating to small business capital gains exclusion and Build America Bonds H.R. 4899 Supplemental Appropriations Act, 2010; provisions related to GRATS H.R. 5297 Small Business Lending Fund Act of 2010; provisions relating to taxes affecting small business, partial annuitization, and expansion of Roth conversions H.R. 5486 Small Business Jobs Tax Relief Act of 2010; provisions relating to small business investment incentives and grantor retained annuity trust H.R. 5982 Small Business Tax Relief Act of 2010; provisions relating to repeal of 1099 reporting obligations enacted in health care reform H.R. 6128 Fair Playing Field Act of 2010; provisions that would affect use of independent contractors within the securities industry S. 506 - Stop Tax Haven Abuse Act; provision relating to managed and controlled foreign entities S. 567 - A bill to repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gains rates; entire bill S. 651 - Compensation Fairness Act of 2009; entire bill S. 722 - Taxpayer Certainty and Relief Act of 2009; provisions relating to capital gains, dividends, and estate tax S. 1007 - Excessive Pay Capped Deduction Act of 2009; entire bill S. 2784 - A bill to amend the Internal Revenue Code of 1986 to permanently extend the estate tax as in effect in 2009; entire bill S. 2869 Small Business Job Creation and Access to Capital Act of 2009; entire bill S. 2882 - Taxpayer Responsibility, Accountability, and Consistency Act of 2009; provisions relating to independent contractors within the securities industry S. 2927 - Wall Street Fair Share Act; entire bill S. 3513 Bonus Depreciation Extension to Create Jobs Act; entire bill S. 3773 Tax Hike Prevention Act of 2010; provisions relating to capital gains dividends and estate tax S. 3786 Fair Playing Field Act; provisions that would affect use of independent contractors within the securities industry S. 3793 Job Creation and Tax Cuts Act of 2010; entire bill S. 3816 Creating American Jobs and Ending Offshoring Act; entire bill Administrations FY 2011 budget proposals relating to Auto IRA retirement savings initiatives, taxation of life insurance companies, international taxation, tax treatment of capital gains and dividends, independent contractor, estate tax, and Financial Crisis Responsibility Fee

Client expense: $580,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax issues affecting foreign-owned banks, including withholding tax issues and proposals for modifications to the Qualified Intermediary rules, and proposals for additional information reporting (H.R.3933, S.1934, H.R.4213, H.R.2847, and new IRC sections 1471-1474).

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

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

Taxation of investment funds, investment fund managers, Foreign Acct. Tax Compliance Act provisions, included in H.R. 3933, S. 1934, and H.R. 4203, S. 3793.

Client expense: Not reported · Firm income: $70,000

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, SENATE

S.292 - Withholding Tax Relief Act of 2009 H.R.275 - To repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities H.R.3933 - Foreign Account Tax Compliance Act of 2009 S.1934 - Foreign Account Tax Compliance Act of 2009

Client expense: $1,100,000 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE

Entire bill of the following: H.R.1880, National Insurance Consumer Protection Act H.R. 3596 / S.1681, the Health Insurance Industry Antitrust Enforcement Act of 2009 H.R.3059 / S.1368, the Access to Repair Parts Act Monitoring issues related to the insurance industry; H.R. 5114, Flood Insurance Reform Priorities Act of 2010 (National Flood Insurance Program) Extensions: HR 4851, Continuing Extension Act of 2010 (Related Bills: H.R.3404, H.R.3548, H.R.3756, H.R.4183, H.R.4691, H.R.4707, S.1647, S.1699, S.2831, S.3153, S.3173) H.R. 4213, American Jobs and Closing Tax Loopholes Act of 2010 (Related Bills: H.RES.955, H.RES.1403, H.R.1935, H.R.3931, H.R.3933, S.1934, S.3191, S.3333) H.R. 5569, National Flood Insurance Program Extension Act of 2010 (Related Bills: H.R.4778, H.R.5553, H.R.5650, S.3347) S. 3347, A bill to extend the National Flood Insurance Program through December 31, 2010 (Related Bills: H.R.4778, H.R.5553, H.R.5569) S.AMDT.4674 to H.R.3081, Continuing Appropriations Act, 2011 Monitored entire bills of the following: H.R. 1264, Multiple Peril Insurance Act of 2009 H.R. 2555, Homeowners' Defense Act of 2009

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

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Accounting and Tax issues related to Non US Insurers and Reinsurers, Natural Disaster Risk Financing HR 2555, HR 4213, HR 3424, HR 3933, S 505, and S 1934

Client expense: $150,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

Accounting and Tax issues related to Non US Insurers and Reinsurers, Natural Disaster Risk Financing HR 2555, HR 4213, HR 3424, HR 3933, S 505, and S 1934

Client expense: $150,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

Limit Executive Compensation Abuse Act - H.R. 857 The Savings for American Families Future Act of 2009 H.R. 1961 The 401 (k) Fair Disclosure for Retirement Security Act 0f 2009 H.R. 1984 Conflicted Investment Advice Prohibition Act of 2009 H.R. 1988 Savings Recovery Act H.R. 2021 Retirement Security Needs Lifetime Pay Act H.R. 2748 Retirement Savings Transparency Act of 2009 - H.R. 2792 The Defined Contribution Plan Fee Transparency Act H.R. 2779 401 (k) Fair Disclosure and Pension Security Act of 2009 H.R. 2989 Consumer Financial Protection Agency Act of 2009 H.R. 3126 Foreign Account Tax Compliance Act of 2009 H.R. 3933 Preserve Benefits and Jobs Act of 2009 H.R. 3936 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962/Public Law No: 111-192 Retirement Fairness Act H.R. 4126 Sensible Transparency for Retirement Plans Act H.R. 4146 Tax Technical Corrections Act of 2009 H.R. 4169 Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 American Workers, State, and Business Relief Act H.R. 4213/Unemployment Compensation Extension Act of 2010 (tax extenders) Public Law No: 111-205 Small Businesses Add Value for Employees Act of 2009 (SAVE Act) H.R. 4742 Employee Misclassification Prevention Act (EMPA) H.R. 5107 Small Business Jobs and Credit Act of 2010 H.R. 5297 tax extenders, defined benefit pension plan funding relief - technical corrections from H.R. 3962 Automatic IRA Act of 2010 H.R. 6099 Fair Playing Field Act of 2010 H.R. 6128 (worker classification) Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension Funding - additional funding relief for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, PBGC plan termination issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, conversions to Roth 401 (k) plans, automatic IRAs, investment advice, investment selection (target date funds), the Savers Credit, retirement savings plans for small businesses, lifetime income issues, nondiscrimination rules for retirement plans, alternative pension investments, accounting transparency for pensions, plan loans, tax expenditures for retirement plans Cap Executive Officer Pay Act of 2009 - S. 360 The Defined Contribution Fee Disclosure Act of 2009 - S. 401 Shareholder Bill of Rights Act S. 1074 Retirement Security for Life Act of 2009 S. 1297 Pension Benefit Guaranty Corporation (PBGC) Governance Improvement Act of 2009 S. 1544 Foreign Account Tax Compliance Act of 2009 S. 1934 Lifetime Income Disclosure Act S. 2832 Create Jobs and Save Benefits Act of 2010 S. 3157 Restoring American Financial Stability Act/Wall Street Transparency and Accountability Act S. 3217 Employee Misclassification Prevention Act (EMPA) S. 3254 Automatic IRA Act of 2010 S. 3760 Fair Playing Field Act of 2010 S. 3786 Job Creation and Tax Cuts Act of 2010 S. 3793 Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act H.R. 3962, Public Law No: 111-192 American Workers, State, and Business Relief Act /American Jobs and Closing Tax Loopholes Act (tax extenders) H.R. 4213, & Substitute amendments Dodd-Frank Wall Street Reform and Consumer Protection Act - Restoring American Financial Stability Act of 2010 H.R. 4173, Public Law No: 111-203 Small Business Jobs and Credit Act of 2010 H.R. 5297 (revised substitute) Health Care Reform regulatory implementation and compliance issues from the Patient Protection and Affordable Care Act (PPACA) Public Law No: 111-148 & the Health Care and Education Reconciliation Act of 2010 (HCERA) Public Law 111-152 new compensation deduction limits on entities receiving health insurance premiums (162 (m)(6)) Financial Services Reform regulation of swaps transactions, major swap participants (MSPs), swaps, business conduct standards, fiduciary duty and liability issues; effects on pension, retirement, and health plans that use swaps; 401 (k) stable value funds and contracts, retirement plan administration, compensation disclosure issues Pension funding additional funding relief for defined benefit pension plans, single and multiemployer plans, nonqualified deferred compensation conditions, PBGC premium funding target methods and premium submission issues, PBGC plan termination issues Retirement Security nonqualified deferred compensation, executive compensation, defined contribution plan issues, 401 (k) plans, automatic IRAs, conversions to Roth 401(k) plans, investment advice, investment selection (target date funds), the Savers Credit, lifetime income issues, nondiscrimination rules for retirement plans, plan loans, tax expenditures for retirement plans Regulatory communication with covered federal officials on legislative issues Pension funding relief, adequacy of defined benefit vehicles, hybrids, retirement plan designs, tax treatment of expatriates Investment advice, adequacy of defined contribution vehicles, investment selection (target date funds) and annuity issues, automatic/mandatory individual retirement accounts (IRAs) Disclosure for defined contribution (DC) and defined benefit (DB) plans and service providers ERISA Section 408 (b) (2) Defined Benefit (DB) plan year filing issues Form 5500 (EFAST) Cash balance and pension equity plans, market rate of return for hybrid plans Nonqualified deferred compensation (NQDC), new compensation deduction limits on entities receiving health insurance premiums 162 (m) (6) PBGC premium funding target methods (variable rate premiums), premium submission and plan termination issues Foreign bank account reporting, Report of Foreign Bank and Financial Accounts (FBAR) Financial services regulatory reform, compensation disclosure issues Domestic plan asset investment issues Proposed rule on application of ERISA to state/local health reform efforts, ERISA preemption

Client expense: $199,380 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Proposals in FY2010 budget for changing tax rules for foreign income of US taxpayers and US beneficiaries of foreign trusts, and to address the offshore tax evasion accounts; HR 1265, Stop Tax Haven Abuse Act; S. 1934, Foreign Account Tax Compliance Act of 2009; HR 3933, Foreign Account Tax Compliance Act of 2009

Client expense: Not reported · Firm income: $80,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) Against Anti-Tax Haven Bills (S. 506, H.R. 1265, H.R. 3933 & S.1934).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of

Legislative and regulatory tax issues before Congress and the Administration regarding active financing and international and domestic tax issues: - H.R. 1944: A bill to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income - Administration's Fiscal Year 2011 Revenue Proposals; - H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010 - Proposals related to the Taxation of Banks - H.R. 3933, S. 1934, the Foreign Account Tax Compliance Act of 2009 - H.R. 4169, the Tax Technical Corrections Act of 2009 - S. 2826, the Clean Renewable Energy Advancement Tax Extension Jobs Act of 2009 - S. 1639, a bill to improve and extend certain energy-related tax provisions - H.R. 2454, the American Clean Energy and Security Act of 2009

Client expense: Not reported · Firm income: $240,000

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

S. 506/H.R. 1265, Stop Tax Haven Abuse Act, provisions naming countries, including Switzerland, as tax haven jurisdictions. H.R.3933/S. 1934, Foreign Account Tax Compliance Act of 2009, specifically reporting and designation requirements for insurance. H.R. 3424, legislation to alter tax treatment of legitimate foreign affiliate reinsurance transactions undertaken by U.S. subsidiaries of foreign parent corporations, and related Senate Finance Committee draft legislation. TARP Responsibility Fee, specifically, initiatives to impose a TARP user tax on non-TARP recipients and property/casualty insurance firms.

Client expense: $1,540,000 · Firm income: Not reported

Government targets: Bureau of Land Management (BLM), Centers For Medicare and Medicaid Services (CMS), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 3933/S. 1934, Foreign Account Tax Compliance Act of 2009, (specifically reporting and designation requirements for insurance) as included and passed in the Hiring Incentive to Restore Employment (HIRE) Act. H.R. 3424, legislation to alter tax treatment of legitimate foreign affiliate reinsurance transactions undertaken by U.S. subsidiaries of foreign parent corporations, related Senate Finance Committee draft proposal, and FY 2011 Administration budget provisions. TARP Responsibility Fee, specifically, initiatives to impose a TARP user tax on non-TARP recipients and property/casualty insurance firms.

Client expense: $1,360,000 · Firm income: Not reported

Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act H.R.4213 American Workers, State, and Business Relief Act H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $980,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Administration's FY2010 International Tax Proposals; Administration's FY2010 and Senate Finance Committee discussion draft offshore tax compliance proposals; H.R. 3408 (Taxpayer Responsibility, Accountability, and Consistency Act of 2009); H.R. 3933 (Foreign Account Tax Compliance Act); H.R. 4173 (Restoring American Financial Stability Act of 2010); H.R. 4213 (Tax Extenders Act of 2009); H.R. 4849 (Small Business and Infrastructure Jobs Tax Act); S. 506 (Stop Tax Haven Abuse Act) (Administration's FY2010 dividend withholding proposals); S. 2882 (Taxpayer Responsibility, Accountability and Consistency Act of 2009); S. 2994 (Taxpayer Fairness Act); S. 3350 (Municipal Bond Market Support Act of 2010); Build America Bonds; Tax rules relating to regulation of over-the-counter derivative contracts; Tax rules relating to sourcing of guarantee fees; Extension of Federal Home Loan Bank Guarantee; Financial Transaction Tax Proposals; Tax issues related to standardization of credit default swaps; Extension of Active Financing Rules; Tax issues related to implementation of charge for failure to deliver Treasury securities; Administration's Financial Crisis Responsibility Fee; Tax issues related to interest expense allocation; Tax treatment of capital gains and dividends; Extension of Build America Bonds; Expansion of Build America Bond Rules to Tax Credit Bonds; Taxation of independent contractors; Taxation of cross-border equity swaps; Corporate tax reporting rules; Bonus tax proposals; Tax reporting requirements for foreign financial institutions on certain foreign accounts; Securities cost basis reporting regulations; Tax rules relating to Bearer Bonds.

Client expense: $1,480,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), 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)