Partnership Audit Simplification Act of 2015

HR ___ American Business Competitiveness Tax Reform Draft Legislation; HR 1 Tax Reform Act; HR 2821 Partnership Audit Simplification Act; S 1656 Master Limited Partnerships Parity Act; S 1946 Tax Relief Extension Act; Legislative efforts concerning tax reform proposals relating to energy policy.

Client expense: $1,620,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Aviation Administration (FAA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), Pipeline & Hazardous Materials Safety Administration, SENATE, White House Office

H.R. 214: Tar Sands Tax Loophole Elimination Act H.R. 2821 : Partnership Audit Simplification Act of 2015 S. 187: Tar Sands Tax Loophole Elimination Act H.R. 4672: To amend the Internal Revenue Code of 1986 to make permanent the exception for marginal production from the taxable income limit on percentage depletion for oil and natural gas wells

Client expense: $381,275 · Firm income: Not reported

Government targets: Bureau of Land Management (BLM), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE, Small Business Administration (SBA), U.S. Fish & Wildlife Service (USFWS)

Reform relating to taxation of partnerships. Cash accrual. H.R. 2821 - Partnership Audit Simplification Act of 2015.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Alternative minimum tax; Cash basis method of accounting; Corporate integration; Deductions for adjusted gross income (certain attorney fees and court costs); Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Education-related provisions; Estates & Trusts; Estate valuation discounts under section 2704 (H.R. 6042, H.R. 6100, and S. 3436); Modify the deadline for estate basis reporting; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Foreign trust withholding credit to U.S. beneficiaries; Modify Form 3520-A due date from March 15th to April 15th; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Filing election/tax return 15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990 series; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation; definition of a patient); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Remove the binding contract requirement under section 512(b)(13)(E)(iii); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Mandate the electronic filing of the IRS except organization forms, as proposed in the FY 2017 Budget of the US Government and accompanying Treasury Explanations; Supporting organizations; SSNs on EO tax forms; Section 501(r); Form 1023; Group rulings and group filings; Section 1441 foreign equivalency determination; Foreign trusts; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Form 3520-A filing deadline; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Stolen Identity Refund Fraud Prevention Act of 2015 (H.R. 2991); Form W-2 due date acceleration; Identity Theft Mark-up Amendment Related to the Regulation of Tax Return Preparers; IRS Security Summit International Taxation; BEPS - country-by-country reporting; Information reporting for Disregarded Entities with foreign owners; Innovation Box; Inversion guidance under Section 7874; Pending Income Tax Treaties and Protocols; PFIC reporting requirements; Taxation of Foreign Income; Taxation of 529 Plans, ABLE accounts, ROTH IRAs and their foreign equivalents; Voluntary Disclosure and Streamlined Filing Programs for delinquent taxpayers with foreign assets and income; Notice 2016-48, Expiration & Renewal procedures for ITINs; Reporting requirements for foreign accounts held by U.S. taxpayers resident overseas; FinCEN Form 114 (FBAR) reporting requirements (RIN 1506-AB26); Tax treatment of retirement plans for taxpayers working overseas; IRS authority over tax return preparers and contingency fees; Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141); Tax Return Preparer Accountability Act of 2015 (H.R. 1609); IRS determination letter program; IRS budget, IRS customer service, IRS Future State; IRS proposed regulations guidance under Section 2801; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit; Tangible property regulations; Amortization of certain research and experimental expenditures.; Amortization of certain advertising expenditures;Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, de minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Section 170 charitable contribution of inventory; Notice 2015-40 Revenue Recognition; Revenue Procedure 2015-40; Section 199; Revenue Procedures 2015-13 and 2015-14 and 2016-29; Modify the enhanced deduction rules for charitable contributions of inventory; Modify the rules for capitalization and inclusion in inventory costs for certain expenses under 263A; Modify the rules for capitalization and inclusion in inventory costs for certain expenses under section 263A; Section 41(h) Treatment of Credit for Qualified Small Businesses; Section 471 cost definition under section 263A; Revenue Procedure 2004-34 advance payments; Accounting for loyalty points and the scope of Treas. Reg. 1.451-4; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Multi-State Worker (telecommuter) Tax Fairness Act; Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Shareholders; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities.; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Treatment under Section 721(c) of property transfers to partnerships with related foreign partners; Technical corrections to Partnership Audit procedures enacted as part of the Bipartisan Budget Act of 2016; Notice 2016-23, BBA Partnership Audit Regime regulations; Disguised sales rules under Section 707; Allocation of partnership liabilities under Section 752; Management fee waivers; Net Investment Income Tax on disposition of partnership interest; Treatment of partner as an employee for benefit purposes; User Fees Charged for S Corporation Private Letter Ruling Requests; Transfers of Property to Partnerships with Related Foreign Partners and of Certain Interests in Corporations as Stock or Indebtedness (Notice 2015-54); Additional Guidance for AAA Ordering Rules; S Corp Basis Ordering (Section 1367); S Corp guidance on inability to utilize certain suspended passive activity losses upon redemption (Section 469(g)); Update Treas. Reg. 1.1361-5 to reflect the addition of clause (ii) to section 1361(b) (3)(C) made by section 8234 of P.L. 110-28; Issue a revenue ruling incorporating the guidance from PLRs 200308035 and 201017019; Guidance regarding the application of section 302(b)(4) to distributions by an S corporation; Guidance as to when, for AMT purposes, S corporations will have attributes which are different for regular tax and AMT purposes; Provide additional guidance to whether a state tax refund attributable to the S portion of an electing small business trust (ESBT) is allocated to the S portion; Applicability of proposed section 385 regulations to partnerships; Reporting requirements for partnerships under section 6038; Treat the return of an S corporation as the return of any related qualified subchapter S subsidiary for purposes of any relevant period of limitations; Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs); The Small Business Healthcare Relief Act (H.R. 5447 / S. 1697); Small business health insurance tax credit; Employer information reporting requirements (Form 1095-C); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775 / S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the small business health insurance tax credit under IRC section 45R; Simplify the tax treatment of Roth individual retirement account contributions; SEPs; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Section 385 Proposed Regulations - Regarding the treatment of certain interests in corporations as stock or indebtedness (REG-108060-15); Small Business Tax Compliance Relief Act of 2015 (S. 1827); Standardize IRC definitions to avoid multiple meanings for the same term; The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burdens; International tax provisions related to the Tax Reform Act of 2014; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Private Debt Collection; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 3520 change technical correction; Taxpayer Bill of Rights; Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); Treasury/IRS Priority Guidance Plan (Notice 2016-26); United States Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) System; Virtual currency (Bitcoin)

Client expense: $1,320,000 · Firm income: Not reported

Government targets: Financial Crimes Enforcement Network (FinCEN), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

General Tax Issues; Comprehensive Tax Reform; Last In, First Out (LIFO) Method; Cost recovery; Master limited partnerships, Border Tax Adjustment; H.R.2821, Partnership Audit Simplification Act of 2015 - All Sections

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

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

-Oil and Gas Tax Issues: LIFO Repeal; Section 199 repeal; Retention of MACRS; MLP Structure (H.R. 2821); Comprehensive Tax Reform; House Republican Blueprint -International Financial Reporting Standards -Carbon Tax (H.Con.Res. 89, S. Res. 472)

Client expense: $730,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

FIRPTA: Modification of the Foreign Investment in Real Property Tax (FIRPTA) Sales Tax Fairness Proposals: H.R. 2775, S. 698 Tax Reform Section 1031 Like-Kind Exchanges IRC Section 179D: Commercial Building Modernization Act International Tax Reform Tax Treaties: US Model Income Tax Convention Technical Corrections Act HR 4891/S 2775 Treasury Section 385 Regulations Built-In Gains Tax Depreciation-Cost Recovery Partnership Audits: HR 2821

Client expense: $596,000 · Firm income: Not reported

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

H.R. 4141 Tax Return Preparer Competency Act of 2015, general issues regarding IRS licensing of tax preparers; H.R. 2821 Partnership Audit Simplification Act of 2015, general issues regarding the audit of partnerships by the IRS; S. 137 Taxpayer Protection and Preparer Proficiency Act of 2015, general issues regarding IRS licensing of tax preparers; Joint Committee on Taxation 108-15, The Chairman's Mark of a Bill to Prevent Identity Theft and Tax Refund Fraud, general issues regarding identity theft and fraud prevention; General issues regarding due dates for tax returns; General issues regarding tax reform and tax reform blueprint; and General issues regarding IRS management.

Client expense: $380,000 · Firm income: Not reported

Government targets: Bureau of Citizenship & Immigration Services (BCIS), HOUSE OF REPRESENTATIVES, SENATE, U.S. Immigration & Customs Enforcement (ICE), White House Office

Educate lawmakers on the value of section 7704 of the Internal Revenue Code Advocating against discriminatory taxes on interstate pipelines (H.R. 3663, S. 2117) Partnership Audit Simplification Act (H.R. 2821)

Client expense: Not reported · Firm income: $525,900

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

Reform relating to taxation of partnerships. Cash accrual. H.R. 2821 - Partnership Audit Simplification Act of 2015.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 214: Tar Sands Tax Loophole Elimination Act H.R. 2821 : Partnership Audit Simplification Act of 2015 S. 187: Tar Sands Tax Loophole Elimination Act H.R. 4672: To amend the Internal Revenue Code of 1986 to make permanent the exception for marginal production from the taxable income limit on percentage depletion for oil and natural gas wells

Client expense: $277,367 · Firm income: Not reported

Government targets: Bureau of Land Management (BLM), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE, Small Business Administration (SBA), U.S. Fish & Wildlife Service (USFWS)

Partnership and individual tax issues involving Publicly Traded Partnerships, including the auditing of large partnerships and proposed qualifying income regulations. HR2821 (Partnership Audit Simplification Act 2015); HR1314 (Bipartisan Budget Act of 2015), Section 1102; HR2029 (Consolidated Appropriations Act 2016), Section 411.

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

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

General Tax Issues; Comprehensive Tax Reform; Last In, First Out (LIFO) Method; Cost recovery; Master limited partnerships; H.R.2821, Partnership Audit Simplification Act of 2015 - All Sections

Client expense: $730,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Alternative minimum tax; Cash basis method of accounting; Corporate integration; Deductions for adjusted gross income (certain attorney fees and court costs); Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Education-related provisions; Estates & Trusts; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Foreign trust withholding credit to U.S. beneficiaries; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Filing election/tax return 15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990 series; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Supporting organizations; SSNs on EO tax forms; Section 501(r); Form 1023; Foreign trusts ; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Stolen Identity Refund Fraud Prevention Act of 2015 (H.R. 2991); Form W-2 due date acceleration; Identity Theft Mark-up Amendment Related to the Regulation of Tax Return Preparers; IRS Security Summit; International Taxation; BEPS - country-by-country reporting; Information reporting for Disregarded Entities with foreign owners; Innovation Box; Inversion guidance under Section 7874; Pending Income Tax Treaties and Protocols; PFIC reporting requirements; Taxation of Foreign Income; Taxation of 529 Plans, ABLE accounts, ROTH IRAs and their foreign equivalents; Voluntary Disclosure and Streamlined Filing Programs for delinquent taxpayers with foreign assets and income; Expiration & Renewal procedures for ITINs; Reporting requirements for foreign accounts held by U.S. taxpayers resident overseas; IRS authority over tax return preparers and contingency fees; Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141); Tax Return Preparer Accountability Act of 2015 (H.R. 1609); IRS determination letter program; IRS budget, IRS customer service, IRS Future State; IRS Implementation of Certified Professional Employer Organization Process; IRS proposed regulations guidance under Section 2801; IRS private debt collection; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit; Tangible property regulations; Amortization of certain research and experimental expenditures.; Amortization of certain advertising expenditures; Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, de minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Section 170 charitable contribution of inventory; Notice 2015-40 Revenue Recognition; Section 199 Online Software; Revenue Procedure 2015-40; Section 199; Revenue Procedures 2015-13 and 2015-14; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Multi-State Worker (telecommuter) Tax Fairness Act; Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Partners; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities.; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Treatment under Section 721(c) of property transfers to partnerships with related foreign partners; Partnership Audit procedures enacted as part of the Bipartisan Budget Act of 2016; Disguised sales rules under Section 707; Allocation of partnership liabilities under Section 752; Management fee waivers; Net Investment Income Tax on disposition of partnership interest; Treatment of partner as an employee for benefit purposes; User Fees Charged for S Corporation Private Letter Ruling Requests; Transfers of Property to Partnerships with Related Foreign Partners and of Certain Interests in Corporations as Stock or Indebtedness (Notice 2015-54); Additional Guidance for AAA Ordering Rules; S Corp Basis Ordering (Section 1367); S Corp guidance on inability to utilize certain suspended passive activity losses upon redemption (Section 469(g)); Update Treas. Reg. 1.1361-5 to reflect the addition of clause (ii) to section 1361(b) (3)(C) made by section 8234 of P.L. 110-28; Issue a revenue ruling incorporating the guidance from PLRs 200308035 and 201017019; Guidance regarding the application of section 302(b)(4) to distributions by an S corporation; Guidance as to when, for AMT purposes, S corporations will have attributes which are different for regular tax and AMT purposes; Provide additional guidance to whether a state tax refund attributable to the S portion of an electing small business trust (ESBT) is allocated to the S portion; Applicability of proposed section 385 regulations to partnerships; Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs); The Small Business Healthcare Relief Act (H.R. 5447 / S. 1697); Small business health insurance tax credit; Employer information reporting requirements (Form 1095-C); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775 / S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the tax treatment of Roth individual retirement account contributions; SEPs; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Section 385 Proposed Regulations - Regarding the treatment of certain interests in corporations as stock or indebtedness (REG-108060-15); Small Business Tax Compliance Relief Act of 2015 (S. 1827); The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burdens; International tax provisions related to the Tax Reform Act of 2014; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Private Debt Collection; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 3520 change technical correction; Taxpayer Bill of Rights; Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); Treasury/IRS Priority Guidance Plan (Notice 2016-26); United States Anti-Money; Laundering (AML) and Counter-Terrorism Financing (CTF) System; Virtual currency (Bitcoin)

Client expense: $1,230,000 · Firm income: Not reported

Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Supporting tax priorities of the oil and gas industry. H.R. 2821, Partnership Audit Simplification Act. Tax extenders; and Treasury 385 regulations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the tax treatment of MLPs Tax reform H.R.2821 - Partnership Audit Simplification Act of 2015 Finance Committee tax reform work groups Port of Wilmington Dredging / U.S. Corps of Engineers Reauthorization Appropriations S. 1656, Master Limited Partnerships Parity Act House Republican tax reform blueprint

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2821 Partnership Audit Simplification Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

-Oil and Gas Tax Issues: LIFO Repeal; Section 199 repeal; Retention of MACRS; MLP Structure (H.R. 2821); Comprehensive Tax Reform -International Financial Reporting Standards -Carbon Tax (H.Con.Res. 89, S. Res. 472)

Client expense: $720,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

HR ___ American Business Competitiveness Tax Reform Draft Legislation; HR 1 Tax Reform Act; HR 1665 Alternative Fuel Tax Parity Act; HR 2029 Protecting Americans From Tax Hikes Act; HR 2821 Partnership Audit Simplification Act; S __ Baucus Tax Reform Draft Legislation; S 1656 Master Limited Partnerships Parity Act; S 1946 Tax Relief Extension Act, provisions related to biodiesel tax credits; 70 Fed. Reg. 21332 Diesel Fuel and Kerosene Excise Tax, Dye Injection; Legislative efforts concerning tax reform proposals relating to energy policy.

Client expense: $1,440,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Railroad Administration, HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Minerals Management Service, Office of Management & Budget (OMB), Pipeline & Hazardous Materials Safety Administration, SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), U.S. Fish & Wildlife Service (USFWS), White House Office

Carried Interest/Enterprise Value Regulation of passive investment in U.S. securities and other assets by non-U.S. investors. Tax reform in non-U.S. jurisdictions. Pending legislation on international tax reform. Management and Control Unrelated Business Income Tax (UBIT) Legislative oversight of implementation of rules under 871(m) of the Tax Code. H.R. 2821 - To amend the Internal Revenue Code of 1986 to reform partnership audit rules. H.R. 2889 - To amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities. S.1686 - To amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities. H.R. 1314 - the Bipartisan Budget Act of 2015 - To amend the Internal Revenue Code of 1986 to provide for a right to an administrative appeal relating to adverse determinations of tax-exempt status of certain organizations. (partnership audit provisions) An Amendment to H.R. 2029 - the Consolidated Appropriations Act, 2016 (omnibus appropriations - partnership audit provisions) OECD BEPS Tax Treaty Project.

Client expense: $1,130,000 · Firm income: Not reported

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

H.R. 4141 Tax Return Preparer Competency Act of 2015, general issues regarding IRS licensing of tax preparers; H.R. 2821 Partnership Audit Simplification Act of 2015, general issues regarding the audit of partnerships by the IRS; S. 137 Taxpayer Protection and Preparer Proficiency Act of 2015, general issues regarding IRS licensing of tax preparers; Joint Committee on Taxation 108-15, The Chairman's Mark of a Bill to Prevent Identity Theft and Tax Refund Fraud, general issues regarding identity theft and fraud prevention; General issues regarding due dates for tax returns; General issues regarding tax reform and tax reform blueprint; and General issues regarding IRS management.

Client expense: $430,000 · Firm income: Not reported

Government targets: Bureau of Citizenship & Immigration Services (BCIS), HOUSE OF REPRESENTATIVES, SENATE, U.S. Immigration & Customs Enforcement (ICE), White House Office

-Oil and Gas Tax Issues: LIFO Repeal; Section 199 repeal; Retention of MACRS; MLP Structure (H.R. 2821); Comprehensive Tax Reform -International Financial Reporting Standards -Carbon Tax (H.Con.Res. 89)

Client expense: $720,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Comprehensive tax reform including partnership taxation and energy infrastructure incentives H.R. 2821 (Partnership Audit Simplification Act of 2015), all provisions Implementation of P.L. 114-113 (Consolidated Appropriations Act, 2016) Division Q, regarding bonus depreciation; and Division P, regarding solar investment tax credit S. 2658 (Federal Aviation Reauthorization Act of 2016), provisions regarding energy investment tax credit H.R. 4891 and S. 2775 (Technical Corrections Act of 2016), provisions regarding bonus depreciation H.R. 5167 (Technologies for Energy Security Act), all provisions

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Alternative minimum tax; Cash basis method of accounting; Corporate integration; Deductions for adjusted gross income (certain attorney fees and court costs); Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Education-related provisions; Estates & Trusts; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Foreign trust withholding credit to U.S. beneficiaries; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Filing election/tax return 15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990 series; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Supporting organizations; SSNs on EO tax forms; Section 501(r); Form 1023; Foreign trusts ; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Stolen Identity Refund Fraud Prevention Act of 2015 (H.R. 2991); Form W-2 due date acceleration; Identity Theft Mark-up Amendment Related to the Regulation of Tax Return Preparers; IRS Security Summit; International Taxation; BEPS - country-by-country reporting; Information reporting for Disregarded Entities with foreign owners; Innovation Box; Inversion guidance under Section 7874; Pending Income Tax Treaties and Protocols; PFIC reporting requirements; Taxation of Foreign Income; Taxation of 529 Plans, ABLE accounts, ROTH IRAs and their foreign equivalents; Voluntary Disclosure and Streamlined Filing Programs for delinquent taxpayers with foreign assets and income; IRS authority over tax return preparers and contingency fees; Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141);Tax Return Preparer Accountability Act of 2015 (H.R. 1609); IRS determination letter program; IRS budget, IRS customer service, IRS Future State; IRS proposed regulations guidance under Section 2801; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit ; Tangible property regulations; Amortization of certain research and experimental expenditures.; Amortization of certain advertising expenditures; Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, de minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Section 170 charitable contribution of inventory; Revenue Procedure 2015-40; Section 199; Revenue Procedures 2015-13 and 2015-14; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Multi-State Worker (telecommuter) Tax Fairness Act ; Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters ; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Partners; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities.; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Treatment under Section 721(c) of property transfers to partnerships with related foreign partners; Partnership Audit procedures enacted as part of the Bipartisan Budget Act of 2016; Disguised sales rules under Section 707; Allocation of partnership liabilities under Section 752; Management fee waivers; Net Investment Income Tax on disposition of partnership interest; Treatment of partner as an employee for benefit purposes; User Fees Charged for S Corporation Private Letter Ruling Requests; Transfers of Property to Partnerships with Related Foreign Partners and of Certain Interests in Corporations as Stock or Indebtedness (Notice 2015-54); Additional Guidance for AAA Ordering Rules; S Corp Basis Ordering (Section 1367); S Corp guidance on inability to utilize certain suspended passive activity losses upon redemption (Section 469(g)); Update Treas. Reg. 1.1361-5 to reflect the addition of clause (ii) to section 1361(b) (3)(C) made by section 8234 of P.L. 110-28; Issue a revenue ruling incorporating the guidance from PLRs 200308035 and 201017019; Guidance regarding the application of section 302(b)(4) to distributions by an S corporation; Guidance as to when, for AMT purposes, S corporations will have attributes which are different for regular tax and AMT purposes; Provide additional guidance to whether a state tax refund attributable to the S portion of an electing small business trust (ESBT) is allocated to the S portion; Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs); The Small Business Healthcare Relief Act (H.R. 5447 / S. 1697); Small business health insurance tax credit; Employer information reporting requirements (Form 1095-C); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775 / S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the tax treatment of Roth individual retirement account contributions; SEPs ; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Section 385 Proposed Regulations - Regarding the treatment of certain interests in corporations as stock or indebtedness (REG-108060-15); Small Business Tax Compliance Relief Act of 2015 (S. 1827); The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burdens; International tax provisions related to the Tax Reform Act of 2014; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Private Debt Collection; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 3520 change technical correction; Taxpayer Bill of Rights; Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); Treasury/IRS Priority Guidance Plan (Notice 2016-26); United States Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) System; Virtual currency (Bitcoin)

Client expense: $1,210,000 · Firm income: Not reported

Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

H.R. 214: Tar Sands Tax Loophole Elimination Act H.R. 2821 : Partnership Audit Simplification Act of 2015 S. 187: Tar Sands Tax Loophole Elimination Act H.R. 4672: To amend the Internal Revenue Code of 1986 to make permanent the exception for marginal production from the taxable income limit on percentage depletion for oil and natural gas wells

Client expense: $295,912 · Firm income: Not reported

Government targets: Bureau of Land Management (BLM), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE, Small Business Administration (SBA), U.S. Fish & Wildlife Service (USFWS)

Supporting tax priorities of the oil and gas industry. H.R. 2821, Partnership Audit Simplification Act. Tax extenders; and Treasury 385 regulations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Educate lawmakers on the value of section 7704 of the Internal Revenue Code Advocating against discriminatory taxes on interstate pipelines (H.R. 3663, S. 2117) Partnership Audit Simplification Act (H.R. 2821)

Client expense: Not reported · Firm income: $530,770

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

Reform relating to taxation of partnerships. Cash accrual. H.R. 2821 - Partnership Audit Simplification Act of 2015.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General Tax Issues; Comprehensive Tax Reform; Last In, First Out (LIFO) Method; Cost recovery; Master limited partnerships; H.R.2821, Partnership Audit Simplification Act of 2015 - All Sections; S.2848, Water Resources Development Act of 2016 - Sec. 2003; H.R.5303, Water Resources Development Act of 2016 - Sec. 108

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

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Issues related to the tax treatment of MLPs Tax reform H.R.2821 - Partnership Audit Simplification Act of 2015 Finance Committee tax reform work groups Port of Wilmington Dredging / U.S. Corps of Engineers Reauthorization Appropriations S. 1656, Master Limited Partnerships Parity Act House Republican tax reform blueprint

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Partnership and individual tax issues involving Publicly Traded Partnerships, including the auditing of large partnerships and proposed qualifying income regulations. HR2821 (Partnership Audit Simplification Act 2015); HR1314 (Bipartisan Budget Act of 2015), Section 1102; HR2029 (Consolidated Appropriations Act 2016), Section 411.

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

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

FIRPTA: Modification of the Foreign Investment in Real Property Tax (FIRPTA) HR 2128 Sales Tax Fairness Proposal: H.R. 2775, S. 698 Tax Reform Section 1031 Like-Kind Exchanges IRC Section 179D: Commercial Building Modernization Act International Tax Reform Tax Treaties: US Model Income Tax Convention Partnership Audits: HR 2821 Cost Recovery for Real Estate American Business Competitiveness Act: HR 4377 Mark to Market Rules Corporate Integration

Client expense: $620,000 · Firm income: Not reported

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

H.R.235/S.431 - Permanent Internet Tax Freedom Act/Internet Tax Freedom Forever Act (issues related to taxation of Internet Service Providers); H.R.879 - Axe the Tax on Middle Class Americans Health Plans Act; H.R.1087 - Wireless Telecommunications Tax and Fee Collection Fairness Act of 2015 (as related to restrictions on any state or local jurisdiction from imposing a new discriminatory tax on cell phone services, providers or property); H.R. 2050 - Middle Class Health Benefit Tax Repeal Act of 2015; H.R. 2775 - Remote Transactions Parity Act of 2015 ( to grant states the authority to enforce state and local sales and use tax laws on remote transactions); H.R. 2821 -- Partnership Audit Simplification Act of 2015; S.386 - Mobile Workforce State Income Tax Simplification act of 2015 (as related to changes to non-resident personal tax returns); S.698 - Marketplace Fairness Act (as related to sourcing issues for interstate sales and telecom tax simplification); S. 851/H.R. 1643 - Digital Goods and Services Tax Fairness Act of 2015 (provisions that promote neutrality, simplicity and fairness in the taxation of digital goods and services); and S.1660/H.R.2510 - To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation. General lobbying on the following issues: VOIP Sourcing tax legislation/Mobile Telecommunications Sourcing Act technical corrections; online sales tax simplification; excise taxation on high cost health insurance plans; wireless tax fairness; corporate tax reform and rates; corporate interest tax deductions; international tax reform; dividend taxation; and telecommunications equipment depreciation.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

-Oil and Gas Tax Issues: LIFO Repeal; Section 199 Repeal; Section 199 repeal; Retention of MACRS; MLP Structure (H.R. 2821); Comprehensive Tax Reform -International Financial Reporting Standards -Carbon Tax (H.Con.Res. 89)

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

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Comprehensive tax reform including partnership taxation and energy infrastructure incentives H.R. 2821 (Partnership Audit Simplification Act of 2015), entire bill Implementation of P.L. 114-113 (Consolidated Appropriations Act, 2016) Division Q, regarding bonus depreciation; and Division P, regarding solar investment tax credit

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

-Oil and Gas Tax Issues: LIFO Repeal; Section 199 Repeal; Section 199 repeal; Retention of MACRS; MLP Structure (H.R. 2821); Comprehensive Tax Reform -International Financial Reporting Standards -Carbon Tax (H.Con.Res. 89)

Client expense: $800,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

HR 2821: PARTNERSHIP AUDIT SIMPLIFICATION ACT OF 2015; ALL PROVISIONS OF THE BILL GENERAL DISCUSSIONS REGARDING BUSINESS TAX REFORM/PASS-THROUGHS GENERAL DISCUSSIONS REGARDING CASH METHOD OF ACCOUNTING GENERAL DISCUSSIONS REGARDING BASE EROSION AND PROFIT SHIFTING GENERAL DISCUSSIONS REGARDING MULTI-STATE WORKER TAX FAIRNESS DRAFT PROPOSAL DISCUSSION DRAFT: PROVISIONS RELATED TO PASS-THROUGH RATE REFORM

Client expense: $130,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Carried Interest/Enterprise Value Regulation of passive investment in U.S. securities and other assets by non-U.S. investors. Tax reform in non-U.S. jurisdictions. Pending legislation on international tax reform. Management and Control Unrelated Business Income Tax (UBIT) Legislative oversight of implementation of rules under 871(m) of the Tax Code. H.R. 2821 - To amend the Internal Revenue Code of 1986 to reform partnership audit rules. H.R. 2889 - To amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities. S.1686 - To amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities. H.R. 1314 - the Bipartisan Budget Act of 2015 - To amend the Internal Revenue Code of 1986 to provide for a right to an administrative appeal relating to adverse determinations of tax-exempt status of certain organizations. (partnership audit provisions) An Amendment to H.R. 2029 - the Protecting Americans from Tax Hikes (PATH) Act of 2015 (tax extenders) An Amendment to H.R. 2029 - the Consolidated Appropriations Act, 2016 (omnibus appropriations - partnership audit provisions) OECD BEPS Tax Treaty Project.

Client expense: $1,130,000 · Firm income: Not reported

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

FIRPTA: Modification of the Foreign Investment in Real Property Tax (FIRPTA) HR 2128 Sales Tax Fairness Proposal: H.R. 2775, S. 698 Tax Reform Section 1031 Like-Kind Exchanges IRC Section 179D: Commercial Building Modernization Act International Tax Reform Tax Treaties: US Model Income Tax Convention Partnership Audits: HR 2821

Client expense: $617,105 · Firm income: Not reported

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

Reform relating to taxation of partnerships. Cash accrual. H.R. 2821 - Partnership Audit Simplification Act of 2015.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General Tax Issues; Comprehensive Tax Reform; Tax Extender Legislation; Last In, First Out (LIFO) Method; Cost recovery; Master limited partnerships; H.R.2821, Partnership Audit Simplification Act of 2015 - All Sections; H.R.2821, Partnership Audit Simplification Act of 2015 - All Sections; Water Resources Development Act Reauthorization - Harbor Maintenance Trust Fund Structure and The Inland Waterways Trust Fund allocation

Client expense: $1,570,000 · Firm income: Not reported

Government targets: Army, Dept of (Corps of Engineers), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

H.R. 4141 Tax Return Preparer Competency Act of 2015, general issues regarding IRS licensing of tax preparers; H.R. 2821 Partnership Audit Simplification Act of 2015, general issues regarding the audit of partnerships by the IRS; S. 137 Taxpayer Protection and Preparer Proficiency Act of 2015, general issues regarding IRS licensing of tax preparers; Joint Committee on Taxation 108-15, The Chairman's Mark of a Bill to Prevent Identity Theft and Tax Refund Fraud, general issues regarding identity theft and fraud prevention; General issues regarding due dates for tax returns; General issues regarding tax reform, including cash accrual accounting; and General issues regarding IRS management.

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

Government targets: Bureau of Citizenship & Immigration Services (BCIS), HOUSE OF REPRESENTATIVES, SENATE, U.S. Immigration & Customs Enforcement (ICE), White House Office

HR __ American Business Competitiveness Tax Reform Draft Legislation; HR __ GROW AMERICA Act; HR 1 Tax Reform Act; HR 2029 Protecting Americans From Tax Hikes Act; HR 2821 Partnership Audit Simplification Act; S __ Baucus Tax Reform Draft Legislation; S 1656 Master Limited Partnerships Parity Act; S 1946 Tax Relief Extension Act; Legislative efforts concerning tax reform proposals relating to energy policy; Legislative efforts related to the Highway Trust Fund; The President's Framework for Business Tax Reform, A Joint Report by the White House and the Department of the Treasury, February 2012, provisions related to energy issues.

Client expense: $1,530,000 · Firm income: Not reported

Government targets: Bureau of Land Management (BLM), Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Energy Regulatory Commission (FERC), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Economic Council (NEC), Natl Transportation Safety Board (NTSB), Office of Management & Budget (OMB), Pipeline & Hazardous Materials Safety Administration, SENATE, Securities & Exchange Commission (SEC), Transportation, Dept of (DOT), U.S. Trade Representative (USTR), White House Office

Educate lawmakers on the value of section 7704 of the Internal Revenue Code Advocating against discriminatory taxes on interstate pipelines (H.R. 3663, S. 2117) Partnership Audit Simplification Act (H.R. 2821)

Client expense: Not reported · Firm income: $563,000

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

H.R. 879 - Ax the Tax on Middle Class Americans' Health Plans Act H.R. 1087 - Wireless Telecommunications Tax and Fee Collection Fairness Act of 2015 H.R. 2050 - Middle Class Health Benefits Tax Repeal Act of 2015 H.R. 2775 - Remote Transactions Parity Act of 2015 (to grant states the authority to enforce state and local sales and use tax laws on remote transactions) H.R. 2821 - Partnership Audit Simplification Act of 2015 H.R. 2510 & S. 1660 - To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation H.R. 235 & S. 431 - Permanent Internet Tax Freedom Act/Internet Tax Freedom Forever Act H.R. 1643 & S. 851 - Digital Goods and Services Tax Fairness Act of 2015 H.R. 2889 & S. 1686 - Carried Interest Fairness Act of 2015 S. 116 - Telephone Excise Tax Elimination Act of 2015 S. 386 - Mobile Workforce State Income Tax Simplification Act of 2015 S. 698 - Marketplace Fairness Act of 2015 (to restore states rights to enforce state and local sales and use tax laws) VoIP Sourcing tax legislation/Mobile Telecommunications Sourcing Act technical corrections Online Sales Simplification Act Excise tax on high cost health insurance plans Wireless tax fairness Corporate tax reform, rates Corporate interest tax deductions International tax reform Dividend taxation Telecommunications equipment depreciation

Client expense: $3,590,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office