Protect and Save Act of 2013

H.R. 295, Protect and Save Act of 2013, Issues relating to prepaid payments H.Res. 97, A simple resloution ensuring paper-based information, and where appropriate, offering electronic delivery opt-in

Client expense: $910,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

Tax Reform, Tax Reform Act of 2014, Senate Finance Committee Tax Reform Discussion Drafts, H.R. 1, S. 1090, H.R. 2253; (e.g., alternative minimum tax (AMT), education incentives (H.R. 3393), information reporting, Real Time Tax System, earned income tax credit, phase-outs, Kiddie Tax, depreciation, retirement plan options, inflation adjustments, unused provisions deadwood, the Tax Gap, Section 9100 relief, and terms with multiple definitions in the Internal Revenue Code); Tax penalties (e.g., the definitionof tax shelters; significant purpose; reasonable cause exception to penalties under sections 6707A and 6662A; reasonable cause exception to the section 6676 penalty for erroneous claim for refund or credit; and Form 3520 and 3520-A penalties); Identity theft (e.g., truncated taxpayer identification numbers (TTINs) and S. 149, Stop Identity Theft Act of 2013 and H.R. 295; Identity Theft and Tax Fraud Prevention Act of 2013, S. 676); IRS authority over tax preparers, H.R. 1570; preparer tax identification numbers (PTIN) registration process; Cash basis method of accounting; Due dates of tax returns (H.R. 901 and S. 420); (e.g., six-month automatic extension for entire Form 990 series and other information, excise and income tax returns of exempt organizations); Mobile Workforce State Income Tax Simplification Act (H.R. 1129, S. 1645); Permanent disaster relief; Hurricane Sandy Tax Relief, HR 2137; IRS weather-related impacts in filing due dates; Standardize the allowable mileage rates for business expense, medical expense and charitable contribution purposes; IRS Budget; Administrations fiscal year 2015 revenue proposals; Form 1099B and Form 8949; Form 1040 Questions on Schedule E relating to Form 1099 requirement; Guidance on tax issues for same-sex couples and registered domestic partners; Net investment income tax (Sec. 1411); Allow certain attorney fees and court costs as deductions for adjusted gross income (AGI); Clarify and simplify reporting of cancellation of debt income (Sec. 6050P); Provide parity for employees and self-employed individuals on the deduction of health insurance costs; Remove reference to section 332 from section 367(a)(i); Repeal the section 7122(c)(1) requirement to provide a 20 percent partial payment with a lump-sum offer in compromise; Allow transfer of partnership suspended losses to one another when spousal transfers under section 1041(a) tax place; Target allocations for partnerships; Clarify that husband and wife partnerships are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day post-termination transition period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Related party debt (proposed regulations on Sec. 752); Form 1120S; Repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S corporations under 1375(a)(2) from 25 percent to 60 percent; Qualified terminable interest property (QTIP) election relief; Treat consistently all federal tax payments of trusts and estates; 9100 relief; Mexican land trust (Fideicomisos); Amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; Exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; Reinstate and make permanent the fair market value exception under section 512(b)(13) and remove the binding contract requirement; Expand the exception from section 509(f)(2), which prohibits an organization from qualifying for section 509(a)(3) status if it accepted certain gifts, to be consistent with the technical change made to section 4958(c)(3)(C); Form 990 and instructions; Form 3115; Interactive Form 1023; e-filing for exempt organizations; Public disclosure of information on exempt organization forms; Top-heavy rules; Repeal full vesting on partial termination of qualified retirement plans; Speaking with Government Accountability Office (GAO) on retirement plan sponsor reporting and disclosure requirements, and issues pertaining to electronic disclosure of content to participants; Mid-year amenders on safe harbor plans; Use of forfeitures on making certain qualified contributions; Foreign Account Tax Compliance Act (FATCA); PFICs; Automatic penalties assessed on Form 5471; TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) and its e-filing requirements; The Retail Inventory Method; Rev. Proc. 97-27; Tangible personal property guidance repair regulations (Sec. 263A); Proposed Regulations to Amend the Definition of Research and Experimental Expenditures under Section 174; Estimated taxes for corporations and success based fees; Internal Revenue Services release in the delay of tax forms and abatement of penalties for late payment of tax; IRS preparer compliance visits; IRS e-signature standards; Uncertain tax positions (UTP); Sec. 7212; Individual taxpayer identification numbers (ITINs); Form 1099-K; Form 8937 (form used to report organizational actions affecting basis);Amended Forms 1099; IRS e-services; IRC section 1298 (f) filing requirements; Enrolled Agents, S. 1134, H.R. 2313; Affordable Care Act (e.g., Play or Pay rules; small business health care tax credit; information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans, and information reporting of minimum essential coverage); Interest Rate Determination Method (adjusted AFRs/Long-term tax-exempt rates); Estate Tax Expat Issues, S. 744; Rev. Proc. 99-6; Technical termination rules (Sec. 708, Sec. 197); State Sales Tax Collection/Marketplace Fairness Act (MFA), S. 336, S. 743, HR 684; Rev. Proc. 97-27 (non-automatic changes in method of accounting); Accounting method changes (Sec. 381); Extend expiring tax provisions; A de minimis threshold for small taxpayers (Sec. 382 NOL Limitation); Modifying the enhanced deduction rules for charitable contribution of inventory; Repeal of the anti-churning rules under sec. 197(f)(g); Modify the definition of W-2 wages for purposes of sec. 199; Modify the rules for capitalization and inclusion in inventory costs for certain expenses under section 263A; Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day Post-Termination Transition Period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Repeal section 1362(d)(3), whichterminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S-corporations under section 1375(a)(2) from 25% to 60%; Repeal section 1372; Sec. 174 research and experimental expenditures; Department of the Treasury Priority Guidance Plan.

H.R. 295, Protect and Save act of 2013, issues relating to prepaid payments H.Re. 97, A simple resolution ensuring paper-based information, and where appropriate, offering electronic delivery opt-in

Client expense: $1,510,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)

H.R. 295, Protect and Save Act of 2013, including provisions relating to section 7 H.J. Res. 59, Continuing Appropriations Resolution, 2014, including provisions relating to section 203

Client expense: $5,810,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE

Tax Reform, H.R. 1, S. 1090, H.R. 2253; (e.g., alternative minimum tax (AMT), education incentives, information reporting, Real Time Tax System, earned income tax credit, phase-outs, Kiddie Tax, depreciation, retirement plan options, inflation adjustments, unused provisions deadwood, the Tax Gap, Section 9100 relief, and terms with multiple definitions in the Internal Revenue Code); Tax penalties (e.g., the definition of tax shelters; significant purpose; reasonable cause exception to penalties to undersections 6707A and 6662A; reasonable cause exception to the section 6676 penalty for erroneous claim for refund or credit; and Form 3520 and 3520-A penalties); Identity theft (e.g., truncated taxpayer identification numbers (TTINs) and S. 149, Stop Identity Theft Act of 2013 and H.R. 295; Identity Theft and Tax Fraud Prevention Act of 2013, S. 676); IRS authority over tax preparers, HR 1570; preparer tax identification numbers (PTIN) registration process; Cash basis method of accounting; Due dates of tax returns (H.R. 901 and S. 420); (e.g., six-month automatic extension for entire Form 990 series and other information, excise and income tax returns of exempt organizations); Chairman Baucus tax reform discussion drafts on Tax Administration, Cost Recovery & Accounting and International tax reform; Mobile Workforce State Income Tax Simplification Act (H.R. 1129, S. 1645); Permanent disaster relief; Hurricane Sandy Tax Relief, HR 2137; IRS weather-related impacts in filing due dates; Standardize the allowable mileage rates for business expense, medical expense and charitable contribution purposes; IRS Budget; Form 1099B and From 8949; Form 1040 Questions on Schedule E relating to Form 1099 requirement; Guidance on tax issues for registered domestic partners; Net investment income tax (Sec. 1411); Allow certain attorney fees and court costs as deductions for adjusted gross income (AGI); Clarify and simplify reporting of cancellation of debt income (Sec. 6050P); Provide parity for employees and self-employed individuals on the deduction of health insurance costs; Simplified home office deduction; Remove reference to section 332 from section 367(a)(i); Repeal the section 7122(c)(1) requirement to provide a 20 percent partial payment with a lump-sum offer in compromise; Allow transfer of partnership suspended losses to one another when spousal transfers under section 1041(a) tax place; Related party debt (proposed regulations on Sec. 752); Targeted allocations for partnerships; Clarify that husband and wife partnerships are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day post-termination transition period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Form 1120S; Repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S corporations under 1375(a)(2) from 25 percent to 60 percent; Qualified terminable interest property (QTIP) election relief; Treat consistently all federal tax payments of trusts and estates; Mexican land trusts (Fideicomisos); Amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; Exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; Reinstate and make permanent the fair market value exception under section 512(b)(13) and remove the binding contract requirement; Expand the exception from section 509(f)(2), which prohibits an organization from qualifying for section 509(a)(3) status if it accepted certain gifts, to be consistent with the technical change made to section 4958(c)(3)(C); Form 990 and instructions; Form 3115; e-filing for exempt organizations; interactive Form 1023; Public disclosure of information on exempt organization forms; Top-heavy rules; Repeal full vesting on partial termination of qualified retirement plans; Speaking with Government Accountability Office (GAO) on retirement plan sponsor reporting and disclosure requirements, and issues pertaining to electronic disclosure of content to participants; Mid-year amenders on safe harbor plans; Use of forfeitures on making certain qualified contributions; Foreign Account Tax Compliance Act (FATCA); PFICs; Automatic penalties assessed on Form 5471; TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) and its e-filing requirements; The Retail Inventory Method; Rev. Proc. 97-27; Tangible personal property guidance repair regulations (Sec. 263A); Estimated taxes and success based fees; Proposed Regulations to Amend the Definition of Research and Experimental Expenditures under Section 174; Internal Revenue Services (IRSs) release in the delay of tax forms and abatement of penalties for late payment of tax; IRS preparer compliance visits; IRS e-signature standards; Uncertain tax positions (UTP); Sec. 7212; Individual taxpayer identification numbers (ITINs); Form 1099-K; Form 8937 (form used to report organizational actions affecting basis); Amended Forms 1099; IRS e-services; IRC section 1298 (f) filing requirements; Enrolled Agents, S 1134, H.R. 2313; Affordable Care Act (e.g., Play or Pay rules; small business health care tax credit; information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans, and information reporting of minimum essential coverage); Interest Rate Determination Method (adjusted AFRs/Long-term tax-exempt rates); Estate Tax Expat Issues, S 744; Rev. Proc. 99-6; Technical termination rules (Sec. 708, Sec. 197); State Sales Tax Collection/Marketplace Fairness Act (MFA), S. 336, S. 743, HR 684; Rev. Proc. 97-27 (non-automatic changes in method of accounting); Accounting method changes (Sec. 381)

H.R. 531, Tax Crimes and Identity Theft Prevention Act, issues relating to prepaid cards H.R. 295, Protect and Save Act of 2013, issues relating to prepaid paymentsH.Res. 97, Expressing the sense of the House of Representatives that the Federal Government should take all appropriate measures to ensure that citizens continue to be provided with paper-based information, products and services, and public notices while providing, where appropriate, the ability for all citizens to opt-in to electronic delivery if they so chose.

Client expense: $1,200,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)

H.R. 531, Tax Crimes and Identity Theft Prevention Act, issues relating to prepaid cards H.R. 295, Protect and Save Act of 2013 Proposals to reform the corporate tax code

Client expense: $1,200,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)

H.R. 531, Tax Crimes and Identity Theft Prevention Act, issues relating to prepaid cards H.R. 295, Protect and Save act of 2013, issues relating to prepaid payments H.Res. 97, a simple resolution ensuring paper-based information, products and services, and, where appropriate, offering electronic delivery opt-in

Client expense: $1,030,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)

Tax Reform, H.R. 1, S. 1090, H.R. 2253; (e.g., alternative minimum tax (AMT), education incentives, information reporting, Real Time Tax System, earned income tax credit, phase-outs, Kiddie Tax, depreciation, retirement plan options, inflation adjustments, unused provisions deadwood, the Tax Gap, Section 9100 relief, and terms with multiple definitions in the Internal Revenue Code); Tax penalties (e.g., the definition of tax shelters; significant purpose; reasonable cause exception to penalties undersections 6707A and 6662A; reasonable cause exception to the section 6676 penalty for erroneous claim for refund or credit; and Form 3520 and 3520-A penalties); Identity theft (e.g., truncated taxpayer identification numbers (TTINs) and S. 149, Stop Identity Theft Act of 2013 and H.R. 295; Identity Theft and Tax Fraud Prevention Act of 2013, S. 676); IRS authority over tax preparers, HR 1570; preparer tax identification numbers (PTIN) registration process; Cash basis method of accounting; Due dates of tax returns (H.R. 901 and S. 420); (e.g., six-month automatic extension for entire Form 990 series and other information, excise and income tax returns of exempt organizations); Mobile workforce (H.R. 1129); Permanent disaster relief; Hurricane Sandy Tax Relief, HR 2137; IRS weather-related impacts in filing due dates; Standardize the allowable mileage rates for business expense, medical expense and charitable contribution purposes; IRS Budget; Form 1099B and From 8949; Form 1040 Questions on Schedule E relating to Form 1099 requirement; Guidance on tax issues for registered domestic partners; Net investment income tax (Sec. 1411); Allow certain attorney fees and court costs as deductions for adjusted gross income (AGI); Clarify and simplify reporting of cancellation of debt income (Sec. 6050P); Provide parity for employees and self-employed individuals on the deduction of health insurance costs; Simplified home office deduction; Remove reference to section 332 from section 367(a)(i); Repeal the section 7122(c)(1) requirement to provide a 20 percent partial payment with a lump-sum offer in compromise; Allow transfer of partnership suspended losses to one another when spousal transfers under section 1041(a) tax place; Targeted allocations for partnerships; Clarify that husband and wife partnerships are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day post-termination transition period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Form 1120S; Repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S corporations under 1375(a)(2) from 25 percent to 60 percent; Qualified terminable interest property (QTIP) election relief; Treat consistently all federal tax payments of trusts and estates; Mexican land trusts (Fideicomisos); Amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; Exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; Reinstate and make permanent the fair market value exception under section 512(b)(13) and remove the binding contract requirement; Expand the exception from section 509(f)(2), which prohibits an organization from qualifying for section 509(a)(3) status if it accepted certain gifts, to be consistent with the technical change made to section 4958(c)(3)(C); Form 990 and instructions; Form 3115; e-filing for exempt organizations; Public disclosure of information on exempt organization forms; Top-heavy rules; Repeal full vesting on partial termination of qualified retirement plans; Speaking with Government Accountability Office (GAO) on retirement plan sponsor reporting and disclosure requirements, and issues pertaining to electronic disclosure of content to participants; Mid-year amenders on safe harbor plans; Use of forfeitures on making certain qualified contributions; Foreign Account Tax Compliance Act (FATCA); PFICs; Automatic penalties assessed on Form 5471; TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) and its e-filing requirements; The Retail Inventory Method; Rev. Proc. 97-27; Tangible personal property guidance repair regulations (Sec. 263a); Estimated taxes and success based fees; Internal Revenue Services (IRSs) release in the delay of tax forms and abatement of penalties for late payment of tax; IRS preparer compliance visits; IRS e-signature standards; Uncertain tax positions (UTP); Sec. 7212; Individual taxpayer identification numbers (ITINs); Form 1099-K; Form 8937 (form used to report organizational actions affecting basis); Amended Forms 1099; IRS e-services; IRC section 1298 (f) filing requirements; Enrolled Agents, S 1134, H.R. 2313; Affordable Care Act (e.g., Play or Pay rules; small business health care tax credit; information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans, and information reporting of minimum essential coverage); Interest Rate Determination Method (adjusted AFRs/Long-term tax-exempt rates); Estate Tax Expat Issues, S 744; Rev. Proc. 99-6; Technical termination rules (Sec. 708, Sec. 197); State Sales Tax Collection/Marketplace Fairness Act (MFA), S. 336, S. 743, HR 684; Rev. Proc. 97-27 (non-automatic changes in method of accounting); Accounting method changes (Sec. 381)

H.R. 531, Tax Crimes and Identity Theft Prevention Act, issues relating to prepaid cards H.R. 295, Protect and Save Act of 2013 Proposals to reform the corporate tax code

Client expense: $1,180,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)

H.R. 531, Tax Crimes and Identity Theft Prevention Act, issues relating to prepaid cards H.R. 295, Protect and Save Act of 2013, issues relating to prepaid paymentsH.Res. 97, Expressing the sense of the House of Representatives that the Federal Government should take all appropriate measures to ensure that citizens continue to be provided with paper-based information, products and services, and public notices while providing, where appropriate, the ability for all citizens to opt-in to electronic delivery if they so chose.

Client expense: $1,180,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE), U.S. Trade Representative (USTR)

Tax Reform, H.R. 1; Due dates of tax returns (H.R. 901 and S. 420); Mobile workforce (H.R. 1129); Hurricane Sandy Tax Relief, HR 2137; Preparer Tax Identification Numbers (PTIN) registration process; Tax penalties (including the definition of tax shelters; significant purpose; reasonable cause exception to penalties under sections 6707A and 6662A; reasonable cause exception to the section 6676 penalty for erroneous claim for refund or credit; Form 3520 and 3520-A penalties); Identity theft including truncatedtaxpayer identification numbers (TTINs) and S. 149, Stop Identity Theft Act of 2013, H.R. 295; S 676, Identify Theft & Tax Fraud Prevention Act of 2013; Qualified terminable interest property (QTIP) election relief; Tax Reform (including alternative minimum tax (AMT), education incentives, earned income tax credit, phase-outs, Kiddie Tax, retirement plan options, inflation adjustments, unused provisions deadwood, the Tax Gap, and terms with multiple definitions in the Internal Revenue Code); repeal full vesting on partial termination of qualified retirement plans, harmonize and simplify education-related tax provisions, standardize the allowable mileage rates for business expense, medical expense and charitable contribution purposes; allow certain attorney fees and court costs as deductions for adjusted gross income (AGI); clarify and simplify reporting of cancellation of debt income; provide parity for employees and self-employed individuals on the deduction of health insurance costs; remove reference to section 332 from section 367(a)(i); allow a reasonable cause exception to the section 6707A and 6662A penalties; repeal the section 7122(c)(1) requirement to provide a 20 percent partial payment with a lump-sum offer in compromise; allow transfer of partnership suspended losses to one another when spousal transfers under section 1041(a) tax place; clarify that husband and wife partnerships are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; add a new 120-day post-termination transition period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S corporations under 1375(a)(2) from 25 percent to 60 percent; allow administrative relief for certain late qualified terminable interest property (QTIP) and qualified revocable trust (QRT) elections; treat consistently all federal tax payments of trusts and estates; amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; allow a single six-month automatic extension for entire Form 990 series and other information, excise and income tax returns of exempt organizations; reinstate and make permanent the fair market value exception under section 512(b)(13) and remove the binding contract requirement; expand the exception from section 509(f)(2), which prohibits an organization from qualifying for section 509(a)(3) status if it accepted certain gifts, to be consistent with the technical change made to section 4958(c)(3)(C); Form 1099B and Form 8949; Form 1040 Questions on Schedule E relating to Form 1099 requirement; guidance on tax issues for registered domestic partners; Section 6050P, IR 2012-65 (Cancellation of debt); Section 1411; Form 990 and instructions; Form 3115; e-filing for exempt organizations; public disclosure of information on exempt organization forms; top-heavy rules; speaking with Government Accountability Office (GAO) on retirement plan sponsor reporting and disclosure requirements, and issues pertaining to electronic disclosure of content to participants; Play or Pay rules (employer-provided healthcare); mid-year amenders on safe harbor plans; use of forfeitures on making certain qualified contributions; the Foreign Account Tax Compliance Act (FATCA); automatic penalties assessed on Form 5471; TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) and its e-filing requirements; the Retail Inventory Method; Rev. Proc. 97-27; estimated taxes and success based fees; Internal Revenue Services (IRSs) release in the delay of tax forms and abatement of penalties for late payment of tax; IRS preparer compliance visits; Section 7216; uncertain tax positions (UTP); individual taxpayer identification numbers (ITINs); Form 1099-K; Form 8937 (form used to report organizational actions affecting basis); Mexican land trusts (Fideicomisos); Form 1120S; and repair regulations (Sec. 263a). Amended Forms 1099; IRS e-services, Regulatory and legislative changes to civil tax penalties; IRS weather-related impacts on filing due dates; IRS filing season; IRC section 1298(f) filing requirements; legislative proposals related to the cash basis of accounting; HR 1570 regarding preparer regulation; S 1134 and HR 2313 regarding enrolled agents

H.R.531, Tax Crimes and Identity Theft Prevention Act H.R.295, Protect and Save Act of 2013 Issues related to mobile paymentsH.Res.97, Expressing the sense of the House of Representatives that the Federal Government should take all appropriate measures to ensure that citizens continue to be provided with paper-based information, products and services, and public notices while providing, where appropriate, the ability for all citizens to opt-in to electronic delivery if they so choose

Client expense: $1,470,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE)

H.R.531, Tax Crimes and Identity Theft Prevention Act H.R.295, Protect and Save Act of 2013

Client expense: $1,470,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE)

H.R.531, Tax Crimes and Identity Theft Prevention Act H.R.295, Protect and Save Act of 2013 Issues related to Regulation II and prepaid products

Client expense: $1,470,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, U.S. Immigration & Customs Enforcement (ICE)

Tax Reform, H.R. 1; Due dates of tax returns (H.R. 901 and S. 420); Mobile workforce (H.R. 1129); Hurricane Sandy Tax Relief; Preparer Tax Identification Numbers (PTIN) registration process; Tax penalties (including the definition of tax shelters; significant purpose; reasonable cause exception to penalties under sections 6707A and 6662A; reasonable cause exception to the section 6676 penalty for erroneous claim for refund or credit; Form 3520 and 3520-A penalties); Identity theft (including truncated taxpayeridentification numbers (TTINs))and S. 149, Stop Identity Theft Act of 2013 and H.R. 295; Qualified terminable interest property (QTIP) election relief; Tax Reform (including alternative minimum tax (AMT), education incentives, earned income tax credit, phase-outs, Kiddie Tax, retirement plan options, inflation adjustments, unused provisions deadwood, the Tax Gap, and terms with multiple definitions in the Internal Revenue Code); repeal full vesting on partial termination of qualified retirement plans, harmonize and simplify education-related tax provisions, standardize the allowable mileage rates for business expense, medical expense and charitable contribution purposes; allow certain attorney fees and court costs as deductions for adjusted gross income (AGI); clarify and simplify reporting of cancellation of debt income; provide parity for employees and self-employed individuals on the deduction of health insurance costs; remove reference to section 332 from section 367(a)(i); allow a reasonable cause exception to the section 6707A and 6662A penalties; repeal the section 7122(c)(1) requirement to provide a 20 percent partial payment with a lump-sum offer in compromise; allow transfer of partnership suspended losses to one another when spousal transfers under section 1041(a) tax place; clarify that husband and wife partnerships are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; add a new 120-day post-termination transition period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S corporations under 1375(a)(2) from 25 percent to 60 percent; allow administrative relief for certain late qualified terminable interest property (QTIP) and qualified revocable trust (QRT) elections; treat consistently all federal tax payments of trusts and estates; amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; allow a single six-month automatic extension for entire Form 990 series and other information, excise and income tax returns of exempt organizations; reinstate and make permanent the fair market value exception under section 512(b)(13) and remove the binding contract requirement; expand the exception from section 509(f)(2), which prohibits an organization from qualifying for section 509(a)(3) status if it accepted certain gifts, to be consistent with the technical change made to section 4958(c)(3)(C); Form 1099B and Form 8949; Form 1040 Questions on Schedule E relating to Form 1099 requirement; guidance on tax issues for registered domestic partners; Section 6050P, IR 2012-65 (Cancellation of debt); Section 1411; Form 990 and instructions; Form 3115; e-filing for exempt organizations; public disclosure of information on exempt organization forms; top-heavy rules; speaking with Government Accountability Office (GAO) on retirement plan sponsor reporting and disclosure requirements, and issues pertaining to electronic disclosure of content to participants; Play or Pay rules (employer-provided healthcare); mid-year amenders on safe harbor plans; use of forfeitures on making certain qualified contributions; the Foreign Account Tax Compliance Act (FATCA); automatic penalties assessed on Form 5471; TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR); the Retail Inventory Method; Rev. Proc. 97-27; estimated taxes and success based fees; Internal Revenue Services (IRSs) release in the delay of tax forms and abatement of penalties for late payment of tax; IRS preparer compliance visits; Section 7216; uncertain tax positions (UTP); individual taxpayer identification numbers (ITINs); Form 1099-K; Form 8937 (form used to report organizational actions affecting basis); Mexican land trusts (Fideicomisos); Form 1120S; and repair regulations (Sec. 263a).