Fighting Tax Fraud Act of 2012

IRC Section 67(e) Deductibility of trust administration expenses; Circular 230 - Preparer regulation including PTIN regulations, nonsigning preparers; ATM; S 845/HR 2382 - Tax Reform Due Dates. HR 674/S 89/S 1720/S 1726/S 1762/S 1885. Repeal full vesting on partial termination of qualified retirement plans; Harmonize and simplify education incentives; Revise the due date of the reporting requirement for foreign banks and financial accounts; Allow for abatement of a Section 6707A penalty of the taxpayer acts reasonable and in good faith; Repeal the Section 7122(c)(1) requirement to provide a 20% partial payment with lump sum offer in compromise; Amend Section 118 to apply to partnerships; Allow spouses (and divorced spouses) to transfer partnership suspended losses to one another; Allow S Corps to have nonresidential aliens as shareholders and potential current beneficiaries of electing small business trusts; modification of information reporting requirements under tax law; Employment tax treatment of S Corporations; Corrections on nonqualified referred compensation plan failures under Section 490(A) built in gains and losses relating to partnership mergers under Section 704(c) exempt status of hospitals; Office visits of tax return preparers by IRS; Foreign trusts aspects of FBAR; Carryover basis issues; HR 1864/S 3485 (Mobile workforce); IRS requests for accounting software; IRS uncertain tax return position programs (including Schedule M-3); Foreign bank account reporting (FinCen); Discussions with bank Security Act Advisory Group; Mandatory e-filing of FBARs; Form 990 Revisions; IRS suitability checks/fingerprinting and FOIA requests related to PTIN iProgram; GST legislative modications; Form 706/Form 8939 - carryover basis issues; taxation of large partnerships; HR 1697 - Community banking Relief; IRS Real Time Tax System; Form 8938 (requests for foreign financial information); Form 8949/Form 1099B (basis reporting) Form 8937 (Corporate organization changes); Preparer fraud penalty; Treasury/IRS regulatory business plan; Notice 2012-25 - Change in trust beneficial interests ("decanting"); TS 9522 and controlled groups that include S Corps for Section 179 purposes; Alternate valuation method under Section 2032; Enactment of permanent gift, estate and GST tax provisions; Make permanent GSTT technical modifications in EGTRRA; Administrative relief of late QTIP and QRT elections S 2271 - S Corporation "fast-tract" elections; carried interests. HR 4106; S Corp Modernization Act of 2011 - HR 1478. HR 5630 - Fraudulent under statement of a taxpayers' liability by a tax return preparer; IRS guidance related to tangible property capitalization; farm Service Agency/Agriculture Department - "Certifications" under Food, Conservation and Energy Act of 2008; Comments to IRS on penalties for certain late filings resulting from inadvertent partnership technical terminations; S 2271 - Support for "The Small Business Election Simplification Act"; Gift card regulatory guidance (IRS); Identity theft issues including ITIN Guidance (IRS); CPA definition for IRS PTIN database; Taxpayer's Hassle Reduction Act (Rep Tim Scott (SC)); IRS 2012 Offshore Voluntary Disclosure Program; Rev. Proc. 99-5 & 99-6 - conversations from a single member LLC to a partnership (and vice versa). House Small Business Subcommittee on Economic Growth, Tax and Capital Access Testimony (uncertainty impacting small business); Changes to IRS Circular 230. Basis reporting - Forms 1099-B and Form 8949; Income tax reporting for registered domestic partners; Section 1411; Individual Taxpayer Identification Numbers; Form 1099-K; Incorrect IRS notices on Form 3520; De minimis rule for partner's substantial economic effect (Section 704(b)); Proposed regulations on S corporation shareholder basis in indebtedness and back-to-back loans; Second class of stock issue for S corporations; Section 482; Retail inventory method; HR 6683 - Hurricane Sandy Tax Relief Act of 2012; Tax penalty reform; Comprehensive tax reform; Rationalization of phase-outs; Earned income tax credit; Different definitions of the same term within the Internal Revenue Code; Simplification of the Kiddie Tax; Simplification of retirement plan options; Inflation adjustments; Unused Tax Provisions (a.k.a. "deadwood")

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

Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

IC Section 67(e) Deductibility of trust administration expenses; Circular 230 - Preparer regulation including PTIN regulations, nonsigning preparers; AMT; S 845/HR 2382 - Tax Return Due Dates. HR 674/S 89/S 164/S 1720/S 1726/ S 1762/ S 1885. Repeal full vesting on partial termination of qualified retirement plans; Harmonize and simplify education incentives; Revise the due date of the reporting requirement for foreign banks and financial accounts; Allow for abatement of a Section 6707A penalty of the taxpayer acts reasonable and in good faith; Repeal the Section 7122(c)(I) requirement to provide a 20% partial payment with lump sum offer in compromise; Amend Section 118 to apply to partnerships; Allow spouses (and divorced spouses) to transfer partnership suspended losses to one another; Allow S Corps to have nonresidential aliens as shareholders and potential current beneficiaries of electing small business trusts; modification of information reporting requiremetns under tax law; Employment tax treatment of S Corporations; Corrections on nonqualified eferred comprensation plan failures under Section 490(A); built in gains and losses relating to partnership mergers under Section 704(c) exempt status of hospitals; Office visits of tax return preparers by IRS; Foreign trusts aspects of FBAR; Carryover basis issues; HR 1864/S 3485 (Mobile workforce); IRS requests for accounting software; IRS uncertain tax return position programs (including Schedule M-3); Foreign bank account reporting (FinCen); Discussions iwth bank Security Act Advisory Group; Mandatory e-filing of FBARs; Form 990 Rervisions; IRS suitability checks/fingerprinting and FOIA requests related to PTIN iProgram; GST legislative modifications; Form 706/Form 8939 - carryover basis issues; taxation of large partnerships; HR 1697 - Community banking Relief; IRS Real Time Tax System; Form 8938 (requests for foreign financial information); Form 8949/Form 1099B (basis reporting); Form 8937 (Corporate organization changes); Preparer fraud penalty; Treasury/IRS regulatory business plan; Notice 2012-25 - Change in trust beneficial interests ("decanting"); TS 9522 and controlled groups that include S Corps for Section 179 purposes; Alternate valuation method under Section 2032; Enactment of permanent gift, estate and GST tax provisions; Make permanent GSTT tehnical modifications in EGTRRA; Administrative relief of late QTIP and QRT elections; S 2271 - S Corporation "fast-track" elections; carried interests. HR 4106; S Corp Modernization Act of 2011 - HR 1478. HR 5630 - Fraudulent under statment of a taxpayers' liability by a tax return preparer; IRS guidance related to tangible property capitalization; Farm Service Agency/Agriculture Department - "Certifications" under Food, Conservation and Energy Act of 2008; Comments to IRS on penalties for certain late filings resulting from inadvertant partnership technical terminations; S 2271 - Support for "The Small business Election Simplification Act"; Gift card regulatory guidance (IRS); Identity theft issues including ITIN Guidance (IRS); CPA definition for IRS PTIN database; Taxpayer's Hassle Reduction Act (Rep Tim Scott (SC)); IRS 2012 Offshore Voluntary Disclosure Program; Rev. Proc. 99-5 & 99-6 - conversions from a single member LLC to a partnership (and vice versa). House Small Business Subcommittee on Economic Growth, Tax and Captital Access Testimony (uncertainty impacting small business); Changes to IRS Circular 230.

Client expense: $1,010,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

Consulting services related to various general corporate tax issues and more specifically compliance tax issues impacting tax payers and tax return preparers, and also tax issues impacting low and middle individual income taxpayers which were debated during the 112th session of Congress on the following bills: - H.R. 88, Bill to amend the Internal Revenue Code of 1986 to change the deadline for income tax returns for calendar year taxpayers from the 15th of April to the first Monday of November - H.R. 1069, A bill to amend the Internal Revenue Code of 186 to provide an election to nonitemizers to have their returns prepared by the Secretary of the Treasury and for other purposes - S. 18, Small Business Paperwork Mandate Elimination Act - S. 19, American Liberty Restoration Act - S. 139, Equal Access to Tax Planning Act - S. 336, Tax Relief Certainty Act of 2011 - S. 359, Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 - H.R.1583, Taxpayer Receipt Act of 2011 - H.R. 2528, Taxpayer Freedom to File Protection Act of 2011 - S.1796, Free File Program Act of 2011 - H.R.9, Small Business Tax Cut Act - H.R.3865, College Tax Cut Extension Act of 2012 - H.R. 3877 and S. 2083, 1099K Overreach Prevention Act - H.R. 4013, Temporary Payroll Tax Cut Continuation Act of 2012 - S. 2237, Small Business Jobs and Tax Relief Act - H.R. 5630, Fighting Tax Fraud Act of 2012 - H.R. 8, the Job Protection and Recession Prevention Act of 2012 - H.R. 6169, Pathway to Job Creation through a Simpler, Fairer Tax Code Act of 2012 - S. 3485, the Mobile Workforce State Income Tax Simplification Act of 2012 - S. 3521, the Family and Business Tax Cut Certainty Act of 2012

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE