Tax Administration Integrity Act

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

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

Alternative minimum tax; Cash basis method of accounting; CPA representation of state-legal marijuana businesses; 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; 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; 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; International Taxation; BEPS - country-by-country reporting; Pending Income Tax Treaties and Protocols; 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; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); 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; 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; 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); 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. 2911 / S. 1697); 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; 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; 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; 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); United States Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) System

Client expense: $1,130,000 · 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