Hurricane Sandy Tax Relief Act of 2012

Legislative and regulatory tax issues reg: energy and electricity including: - H.R.3123, American Job Creation and Investment Act of 2011 - S.1873, Bonus Depreciation and Small Business Expense Extension Act - H.R. 4196, to amend the Internal Revenue Code of 1986 to extend the allowance for bonus depreciation for certain business assets - S. 2240, A bill to amend the Internal Revenue Code of 1986 to extend the allowance for bonus depreciation for certain business asse - S. 3521, the Family and Business Tax Cut Certainty Act of 2012 - Fiscal cliff negotiations, culminating in the enactment of H.R. 8, the American Taxpayer Relief Act - H.R. 6683, the Hurricane Sandy Tax Relief Act

Client expense: Not reported · Firm income: $60,000

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

- Provisions related to utilities in the Hurricane Sandy Tax Relief Act of 2012 (H.R. 6683) and Senate draft not introduced. Extension of dividend tax rates in the following bills: HR 3091 (To make permanent the individual income tax rates for capital gains and dividends) S 1497 (To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates). HR 8 The American Taxpayer Relief Act

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax incentives for Wind Energy: - Fiscal cliff negotiations, culminating in the enactment of H.R. 8, the American Taxpayer Relief Act - H.R. 6683, the Hurricane Sandy Tax Relief Act - H.R.3307, American Renewable Energy Production Tax Credit Extension Act of 2011 - S. 2201, American Energy and Job Promotion Act - H.R. 6031, the Wind Powering American Jobs Act of 2012 - S.3275, Master Limited Partnerships Parity Act - S. 3521, the Family and Business Tax Cut Certainty Act of 2012 - H.R. 6437, Master Limited Partnerships Parity Act

Client expense: Not reported · Firm income: $50,000

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

Advocated for House and draft Senate bills for disaster tax relief with a focus on recovery from Superstorm Sandy: H.R. 6683 (Hurricane Sandy Tax Relief Act of 2012). Advocated for parity between dividend and capital gains taxes: bill list attached. HR 3091 (To make permanent the individual income tax rates for capital gains and dividends) S 1647 (To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates), HR 8 (The American Taxpayer Relief Act of 2012)

Client expense: $256,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 1346 - Stop Tax Haven Abuse Act S. 1647 - Tax hike Prevention and Business Certainty Act S. 1787 - Wall Street Trading and Speculators Tax Act S. 2033 - Closing the Derivatives Blended Rate Loophole Act S. 2075 - CUT Loopholes Act S. 3521 - Family and Business Tax Cut Certainty Act of 2012 H.R. 8 - American Taxpayer Relief Act of 2012 H.R. 2669 - Stop Tax Have Abuse Act H.R. 3091 - Tax Hike Prevention and Business Certainty Act H.R. 4623 - Make Permanent the Exemption for Certain Dividents Paid by RICs to Nonresident Aliens H.R. 6616 - To Protect Securities Transactions in the U.S. from Enforcement of Certain Excise Taxes Imposed by any Foreign Government H.R. 6683 - Hurricane Sandy Tax Relief Act of 2012 Capital Gains/Dividends Tax Rate Extension Comprehensive Tax Reform Flow-through/Tax Extenders Annual Contribution Limits for Retirement Plans Foreign Account Tax Compliance Act International Regulated Investment Company Tax-Exemption for Municipal Bonds Tax Treatment of Financial Products/ETNs RIC Modernization Act Technical Corrections

Client expense: $1,001,729 · Firm income: Not reported

- HR 8 Job Protection and Recession Prevention Act of 2012 - all provisions relating to cable. - HR 12 American Jobs Act of 2011 - all provisions relating to cable. - HR 16 Sensible Estate Tax Relief Act of 2012 - all provisions relating to cable. - HR 428 Telephone Excise Tax Repeal Act - all provisions relating to cable. - HR 468 To amend the Internal Revenue Code of 1986 to repeal the reduction in the deductible portion of expenses for business meals and entertainment - all provisions relating to cable. - HR 609 American Competitiveness Act of 2011 - all provisions relating to cable. - HR 660 Jumpstarting Our Business Sector Act of 2011 - all provisions relating to cable. - HR 629 To amend the Internal Revenue Code of 1986 to modify the private activity bond rules to except certain uses of intellectual property from the definition of private business use - all provisions relating to cable. - HR 696 Tax Relief Certainty Act all provisions relating to cable. - HR 705 Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 - all provisions relating to cable. - HR 710 Telework Tax Incentive Act - all provisions relating to cable. - HR 722 Say No to Drug Ads Act - all provisions relating to cable. - HR 934 Amend the Internal Revenue Code of 1986 to reduce the corporate tax rate to 18 percent - all provisions relating to cable. - HR 942 American Research and Competitiveness Act of 2011 - all provisions relating to cable. - HR 1002 Wireless Tax Fairness Act - all provisions relating to cable. - HR 1074 Amend the Internal Revenue Code of 1986 to reduce the corporate income tax rate to 10 percent and to lower the rate of tax on capital gains and dividends to 10 percent- all provisions relating to cable. - HR 1439 Business Activity Tax Simplification Act of 2011 - all provisions relating to cable. - HR 1732 Innovative Technologies Investment Act of 2011 - all provisions relating to cable. - HR 1773 Made in America Act of 2011 - all provisions relating to cable. - HR 1804 State Video Tax Fairness Act of 2011 all provisions relating to cable. - HR 1834 Freedom to Invest Act of 2011 - all provisions relating to cable. - HR 1860 Digital Goods and Services Tax Fairness Act of 2011 all provisions relating to cable. - HR 1864 Mobile Workforce State Income Tax Simplification Act of 2011 - all provisions relating to cable. - HR 2434 Financial Services and General Government Appropriations Act, 2012 - all provisions relating to cable. - HR 2596 Commerce, Justice, Science and Related Agencies Appropriations, 2012 - all provisions relating to cable. - HR 2701 Main Street Fairness Act all provisions relating to cable. - HR 2911 American Jobs Act of 2011 - all provisions relating to cable. - HR 3018 Corporate Assets Should Be Used to Hire Act - all provisions relating to cable. - HR 3105 Fairness in the American Tax Code Act of 2011 all provisions relating to cable. - HR 3179 Marketplace Equity Act of 2011 all provisions relating to cable. - HR 3366 Clarify that bonus depreciation is not a cost allocated to a contract under the percentage of completion method for long-term contracts all provisions relating to cable. - HR 3460 American Jobs First Act of 2011 all provisions relating to cable. - HR 3476 American Growth, Recovery, Empowerment and Entrepreneurship Act (AGREE) all provisions relating to cable. - HR 4196 To amend the Internal Revenue Code of 1986 to extend the allowance for bonus depreciation for certain business assets - all provisions relating to cable. - HR 5793 To amend the Internal Revenue Code of 1986 to extend the election to treat the cost of qualified film and television productions as an expense which is not chargeable to capital account all provisions relating to cable. - HR 5974 Invest in America Now Act of 2012 all provisions relating to cable. - HR 6152 Bring Jobs Home Act all provisions relating to cable. - HR 6169 Pathway to Job Creation through a Simpler, Fairer Tax Code Act of 2012 all provisions relating to cable. - HR 6205 Protect and Save Act of 2012 all provisions relating to cable. - HR 6206 Build America Bonds Act of 2012 all provisions relating to cable. - HR 6279 Death Tax Repeal Act all provisions relating to cable. - HR 6329 Build It in America Act of 2012 all provisions relating to cable. - HR 6448 Empowering Citizens Act all provisions relating to cable. - HR 6474 To adopt the seven immediate reforms recommended by the National Commission on Fiscal Responsibility and Reform to reduce spending and make the Federal government more efficient all provisions relating to cable. - HR 6544 Manufacturing Innovation in America Act of 2012 all provisions relating to cable. - HR 6549 Computers in Our Communities Act all provisions relating to cable. - HR 6559 To amend the Internal Revenue Code of 1986 to provide an exception from the passive loss rules for investments in high technology research small business pass-thru entities all provisions relating to cable. - HR 6683 Hurricane Sandy Tax Relief Act of 2012 all provisions relating to cable. - S 7 Comprehensive and Fair Tax Reform Act all provisions relating to cable. - S 12 Job Creation Act of 2011 - all provisions relating to cable. - S 85 Restoring America's Competitiveness in Enterprise (RACE) Act of 2011 - all provisions relating to cable. - S 106 Telephone Excise Tax Repeal Act of 2011 all provisions relating to cable. - S 135 Permanent Internet Tax Freedom Act of 2011 all provisions relating to cable. - S 155 Domestic Jobs Innovation Bonus Act - all provisions relating to cable. - S 256 American Opportunity Act of 2011 - all provisions relating to cable. - S. 336 Tax Relief Certainty Act of 2011 - all provisions relating to cable. - S 359 Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 - all provisions relating to cable. - S 543 Wireless Tax Fairness Act all provisions relating to cable. - S 727 Bipartisan Tax Fairness and Simplification Act of 2011 all provisions relating to cable. - S 770 Payroll Fraud Prevention Act all provisions relating to cable. - S 907 Amend the Internal Revenue Code of 1986 to repeal the reduction in the deductible portion of expenses for business meals and entertainment all provisions relating to cable. - S 971 Digital Goods and Services Tax Act of 2011 all provisions relating to cable. - S 1012 Telephone Excise Tax Repeal Act of 2011 all provisions relating to cable. - S 1452 Main Street Fairness Act of 2011 all provisions relating to cable. - S 1549 American Jobs Act of 2011 all provisions relating to cable - S 1572 Commerce and Justice, Science, and Related Agencies Appropriations Act, 2012 all provisions relating to cable. - S 1573 Financial Services and General Government Appropriations Act, 2012 all provisions relating to cable. - S 1660 American Jobs Act of 2011 all provisions relating to cable. - S 1671 Foreign Earnings Reinvestment Act - all provisions relating to cable. - S 1801 Small Business Jobs Tax Extenders Act of 2011 all provisions relating to cable. - S 1811 Telecommuter Tax Fairness Act of 2011 all provisions relating to cable. - S 1832 Marketplace Fairness Act all provisions relating to cable. - S 1837 Rebuilding America Act all provisions relating to cable. - S 1866 American Growth, Recovery, Empowerment and Entrepreneurship ("AGREE") Act - all provisions relating to cable. - S 1873 Bonus Depreciation and Small Business Expense Extension Act - all provisions relating to cable. - S 1917 Middle Class Tax Cut Act of 2011 - all provisions relating to cable. - S 1931 Temporary Tax Holiday and Government Reduction Act - all provisions relating to cable. - S 1934 To amend the Internal Revenue Code of 1986 to repeal certain communications taxes - all provisions relating to cable. - S 1944 Middle Class Tax Cut Act of 2011 - all provisions relating to cable. - S 1960 To provide incentives to create American jobs - all provisions relating to cable. - S 2240 To amend the Internal Revenue Code of 1986 to extend the allowance for bonus depreciation for certain business assets - all provisions relating to cable. - S 2242 Death Tax Repeal Permanency Act of 2012 - all provisions relating to cable. - S 2284 To amend the Internal Revenue Code of 1986 to provide expensing for small business - all provisions relating to cable. - S 3377 Philanthropic Enterprise Act of 2012 - all provisions relating to cable. - S 3364 Bring Jobs Home Act - all provisions relating to cable. - S 3432 Identity Theft and Tax Fraud Prevention Act - all provisions relating to cable. - S 3401 Tax Relief Act of 2012 - all provisions relating to cable. - S 3403 Death Tax Repeal Act - all provisions relating to cable. - S 3423 Tax Hike Prevention Act of 2012 - all provisions relating to cable. - S 3485 Mobile Workforce State Income Tax Simplification Act of 2012 - all provisions relating to cable. - S 3572 Restoring Tax and Regulatory Certainty to Small Business Act of 2012 - all provisions relating to cable. - S 3591 Commercial Building Modernization Act - all provisions relating to cable. - S 3595 To amend the Internal Revenue Code of 1986 to provide an exception from the passive loss rules for investments in high technology research small business pass-thru entities - all provisions relating to cable. - S 3714 Cliff Alleviation at Last Minute Act all provisions relating to cable.

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")

H. R. 6683, Hurricane Sandy Tax Relief Act of 2012, Issues pertaining to bonus depreciation.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE