A bill to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing.
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vs 4,105 other S bills in the 109th — cohort avg 35d
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Sources: Congress.gov
2006 · year_end · Taxation/Internal Revenue Code
Bills: HR 1500, Investment Tax Simplification Act; HR 1417, Extension of Subpart F Exemption for Active Financing Income; HR 819, Retirement Security for Life Act; HR 3, Transportation Equity Act; S. 732, Safe, Accountable, Flexible, and Efficient Transportation Equity Act; S. 7, Jobs and Growth Tax Relief Act; HR 809 (Permanence of individual income tax rates fro capital gains and dividends); HR 4297, Tax Relief Extension Reconciliation Act of 2005; S. 2020, Tax Relief Act of 2005; H.Con.Res.95, Budget FY2006 Appropriations Resolution; S.Con.Res.18, Budget FY2006 Appropriations Resolution; S. 1159.IS, A bill to amend the Internal Revenue Code of 1986 to permanently extend subpart F exemption for active financing; HR 2471, Economic Development Act of 2005; S 1524, To repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gain rates HR 4297, Tax Reconciliation; HR 5367, S 2414, Simplification Through Additional Reporting Tax Act HR 809, S. 1524, Dividend Permanence; S. 1159, HR 1417, permanently extend the subpart F exemption for active financing; S. 2766, Defense Authorization (revenue offset for contingent convertible debt); S. 2020, Tax Relief Act. Congressional Issues: Integration of the corporate and individual income taxes; Reduced taxation of corporate earnings and dividend income; Treatment of payments in lieu of dividends under reduced dividend rates; Treatment of foreign distributions under reduced dividend rates; Capital gains reductions; Permanent reforms of Subpart F with respect to the active financial services income of financial services firms; Proposals to change IRC Section 163(j) (limiting interest deductions of subsidiaries of foreign companies); International tax rules concerning foreign tax credits (interest allocation rules, financial services income basket as “base case” basket for credits relating to permanent tax base differences, 10/50 companies, overall domestic loss); Exclusion for individuals of an amount of capital gains distributions from mutual funds; Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; Reform of Subpart F more generally, territorial tax systems generally; Changes to IRC Section 956 (deemed repatriation); Changes to IRC Section 904(g) (resourcing rules); Relief of double taxation on global dealing operations; Valuation of securities for purposes of mark-to-market tax rules (IRC Section 475); Due date for providing information returns to payees; Electronic provision of information returns to payees; Changes to IRC Section 162(f) (deductibility of settlement payments); Changes to IRC Section 163(l) (disallowance of certain interest payments); Changes to IRC Section 1059 (extraordinary dividends); Changes to the tax treatment of contingent payment convertible debt; Corporate rate reductions; Corporate and individual capital gains issues (e.g., rate reductions, exclusions from income); Pending legislative proposals concerning tax shelters; Internal Revenue Code (“IRC”) Section 6111 (registration of confidential tax shelters); IRC Section 6112 (investor lists and regulations thereunder, as well as associated penalties); IRC Section 6011 (taxpayer disclosure of certain transactions); Joint Committee on Taxation and Treasury studies on corporate tax shelters; Proposals to codify economic substance doctrine; Extension of the R&E tax credit (IRC Section 41) and treatment of expenses of internal use software; Possible legislative proposals relating to hybrid arrangements; Straddle rules and need for “qualified covered calls” exception; Changes to IRC Section 911 (exclusion for individuals of earnings abroad); Tax treatment of income deposit securities; IRC Section 355(e); IRC Section 470 and investment funds; Mutual fund investment in commodity swaps; IRC Section 6701 (tax shelters); IRC Section 409A (deferred compensation); Tax-exempt interest reporting and backup withholding; Basis reporting by brokers; Health savings accounts. Executive Branch Actions: Reduced taxation of dividends (securities lending transactions, treatment of payments in lieu of dividends; qualifying foreign equities, reporting of payments on foreign securities, backup withholding, and treatment of financial intermediaries); Permanent reform of Subpart F, especially with respect to the active financial services income of financial services firms; Reform of Subpart F more generally; Valuation of securities under IRC Section 475 (mark-to-market tax rules); Proposed regulations under IRC Section 482 that would provide rules for allocating among affiliates and sourcing the income from a global dealing operation; OECD Model treaty provision on arbitration; OECD proposals for attribution of profits to permanent establishments; Treaty withholding tax relief for investments through collective investment vehicles; Proposed Section 482 Services Regulations; International reforms, including issues relating to territorial tax system and allocation of deductions to foreign-source income; International tax changes concerning foreign tax credits (e.g., interest allocation rules); Withholding tax treatment of earnings of regulated investment companies paid to foreign persons; IRC Section 956 (concerning making a market in a U.S. affiliate’s securities and other aspects to rationalize rules); IRC Section 904(g) (resourcing of foreign-source income); Pending legislative proposals concerning corporate tax shelters, including codification of economic substance doctrine; Regulations under IRC Sections 6011, 6111 and 6112 (addressing corporate tax shelters); Possible means of prevention of overtaxation of earnings from a global dealing operation (possible change to IRC Section 245(b)); Regulations under Section 1441 of the IRC (and related sections) and subsequent IRS notices concerning reporting and withholding obligations with respect to payments to foreign persons; IRC Section 263(g) (capitalization with respect to straddles); Issues relating to adjusted basis tracking by brokers; Withholding the treatment of Section 302 distributions; Katrina-related “B Notice” and backup withholding issues; Due date for providing information returns to payees generally (including proposal to move date to February 28 for nominees); Penalty relief in case of late, small corrections to 1099s; Electronic provision of information returns to customers; Corporate rate reductions; Corporate and individual capital gains issues generally (e.g., rate reductions, exclusions from income); IRC Section 41 (regulations concerning internal use software and other issues); Treasury Regulation Section 1.904-6 (concerning the allocation of foreign tax credits among various income “baskets”); Changes to IRC Section 162(f); Tax treatment of income deposit securities; Tax treatment of contingent convertible debt; Tax treatment of qualified covered calls; Tax treatment of variable prepaid forwards; Guidance under IRC Section 965 (one-time repatriation provision); ZIRC Section 470 and investment funds; U.S.-Japan income tax treaty (definition of “investment bank” for purposes of Article 11); Information return clearinghouse; IRS Schedule M-3 to Form 1120; Reporting of taxable stock transactions (under IRC Sec. 6043©, 6043A); Withholding with respect to Puerto Rico corporations; United Kingdom anti-arbitrage rules; Withholding on FIRPTA distributions of RICs and REITs; Reporting and backup withholding on tax-exempt interest; Tax consequences of JASDEC /Samurai bond market developments; Implementation of U.S.-Japan tax treaty MOU (definition of “investment bank”); Tax treatment of variable prepaid forwards; Revenue Ruling 2006-1 (commodities swaps and mutual funds); Withholding tax treatment of credit default swaps; Section 482 services regulations.
Client expense: Not reported · Firm income: $2,352,673
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State Justice Institute, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
2006 · year_end · Taxation/Internal Revenue Code
Negotiation and Ratification of Bilateral Income Tax Treaties U.S.-Canada Tax Treaty Revision of Tax Provisions in U.S. Model Treaty Taiwan-U.S. Tax Treaty U.S.-Brazil Tax Treaty U.S.-Germany Tax Treaty U.S.-Sweden Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Subpart F on Deferral of Taxation H.R. 1762/S. 750 on CFC Look-Through for Related Party Payments H.R. 1417/S. 1159 on Active Financing Under Section F H.R. 1736/S. 627 on the R&D Tax Credit Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings Internet Taxation and Business Activity Tax (BAT) European Union VAT on Outsourced Financial Services Active Financing Exception to Subpart F Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD IRS Notice 2005-14 on S. 199 Domestic Production Credit European Union Prospectus Directive Committee of European Securities Regulators (CESR) Report on GAAP Equivalence Treatment of Cross-Licensing Agreements under IRC (tax code) H.R. 4297 Tax Relief Extension Reconciliation Act of 2005 H.R. 2830 Pension Security and Transparency Act of 2005 Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code System Treasury Sections 1.954-3 Field Service Advisory (FSA) Economic Substance Doctrine Codification H.R. 5970 Estate Tax and Extension of Tax Relief Act of 2006 (ETETRA) H.R. 4297 Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954 "Contract Manufacturing" rule under Treasury Reg. S.1.954
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
| Republican |
| KY |
| Jon Kyl | Republican | AZ |
| Max Baucus | Democratic | MT |
| Mike Crapo | Republican | ID |
| Trent Lott | Republican | MS |
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
Client expense: $3,700,000 · Firm income: Not reported
Government targets: Agency for Healthcare Research & Quality (AHRQ), Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Council of Economic Advisers (CEA), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), Federal Communications Commission (FCC), Federal Trade Commission (FTC), Food & Drug Administration (FDA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Intl Trade Administration (ITA), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Vice President of the United States, Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Technology Administration, Treasury, Dept of, U.S. Agency for International Development (USAID), U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act Internal Revenue Service Proposed Regulations on Nonqualified Deferred Compensation under Internal Revenue Code Section 409A Internal Revenue Notice 2006-95 - Guidance Concerning Use of 2001 CSO Tables under Section 7702 Internal Revenue Notice 2003-51 - Treatment of Certain Partial Exchanges H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. See attachment.
Client expense: $2,200,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
Support H.R. 1417 & S1159 - bill to extend subpart F exemption. S2020, H.R. 4297 - tax reconciliation bills - extend subpart F active financing exception, R&E credit. Support H.R. 5970 - R&E Credit expansion. Support H.R. 5986/S.3496 Working American Competitiveness Act. H.R. 6111 - R&E Credit expansion. IRC Section 954 and related regulations.
Client expense: $1,160,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. International Trade Commission (ITC), U.S. Trade Representative (USTR), White House Office
2006 · year_end · Taxation/Internal Revenue Code
Consolidated Tax Returns Business Activity Tax (HR1956; S2721) Technical Corrections to HR4 (Pension Protection Act) Recognition of Gain under Section 355 (e) (HR 4187) Mutual Fund Capital Gain Relief Expiring provisions of Bush Administration Savings Proposal Tax Shelters and other revenue raising provisions Active Financing Legislation (HR1416; S1159)
Client expense: $1,260,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)
2006 · year_end · Taxation/Internal Revenue Code
(3) General legislative issues, including active financial services income (H.R. 4297), Qualified Zone Academy Bonds (HR 611, 5970) and FSC/ETI grandfather rules (H.R. 4297). (1) H.R. 1956: Business Activity Tax Simplification Act - Formalize physical nexus test for business taxation. (2) H.R. 1417, S. 1159: Permanently Extend Subpart F Exemption for Active Financing - General issues relating to exemption tax treatments.
Client expense: $1,020,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2006 · year_end · Taxation/Internal Revenue Code
General representation on legislative and regulatory issues, including active financial services income (S. 1159, H.R. 1417), State tax incentives (H.R. 2471, S. 1066)
Client expense: Not reported · Firm income: $780,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2006 · year_end · Taxation/Internal Revenue Code
H.R. 1417 To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for action financing income (Sought passage). H.R. 1956 Business Activity Tax Simplification Act of 2005 (Sought passage). H.R. 2911 To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for action financing income (Sought passage). H.R. 4247 "Tax Relief Extension Reconciliation Act of 2005" (Sought passage). H.R. 6134 The Health Opportunity Patient Empowerment Act of 2006 (Modification and passage of HSA provisions). H.R. 6264 The Tax Technical Corrections Act of 2006 (Modification to provisions relating to IRS 470). H.R. 6408 The Tax Relief and Health Care Act of 2006 (Sought passage). S. 750 A bill to amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between foreign corporations (Sought passage). S. 1159 A bill to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing (Sought passage). S. 1327 A bill to amend the Internal Revenue Code of 1986 to modify the active business definition under Section 355 (Sought passage). S. 2020 "Tax Relief Extension Reconciliation Act of 2005" (Sought passage). S. 2721 The Business Activity Tax Simplification Act of 2006 (Sought passage).
Client expense: Not reported · Firm income: $3,340,000
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Education, Dept of, Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Economic Council (NEC), Office of Management & Budget (OMB), Overseas Private Investment Corp (OPIC), Pension Benefit Guaranty Corporation (PBGC), SENATE, Social Security Administration (SSA), State, Dept of (DOS), Treasury, Dept of, U.S. Agency for International Development (USAID), U.S. Trade Representative (USTR)
2006 · year_end · Taxation/Internal Revenue Code
HR.1471 – “A bill to amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption to achieve financing income.” HR.1956 – Business Activity Tax Simplification Act of 2005 HR.1998 – FSA Rollovers HR.2682 – Long-Term Care and Retirement Security Act HR.2830 – Pension Protection Act of 2005 HR.2911 – “A bill to amend the Internal Revenue Code of 1986 to modify the active business definition under section 355.” HR.4440 – HSA Technical Correction HR.4511 – Flex Health Savings Accounts Act of 2005 HR. 6134 - Health Opportunity Patient Empowerment Act of 2006 HR. 6111 - Tax Relief and Health Care Act of 2006 S.114 – Kids Come First Act 2005 S.1159 – “A bill to amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption to achieve financing income.” S.1327 – “A bill to amend the Internal Revenue Code of 1986 to modify the active business definition under section 355.” S.1409 – Covering Kids Act of 2005 S.1783 – Pension Security and Transparency Act S.309 – “To amend the Internal Revenue Code of 1986 to provide for the disposition of unused health benefits in cafeteria plans flexible spending arrangements.” S.750 – “A bill to amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations.” S.978 – Healthcare Tax Relief for the Uninsured Act of 2005
Client expense: Not reported · Firm income: $80,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2006 · year_end · Taxation/Internal Revenue Code
H.R. 8- to make the repeal of the estate tax permanent H.R. 25- to promote freedom, fairness and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R.64 – to repeal the Federal death tax, including the estate and gift taxes and the tax on generation-skipping transfers. H.R.183 – to make the repeal of the estate tax permanent. H.R. 809 -- To make permanent the individual income tax rates for capital gains and dividends. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1150 – To Amend the Internal Revenue Code of 1986 to provide a credit to individuals for certain long-term care expenses H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.1560 – to amend the Internal Revenue Code of 1986 to increase the exclusion equivalent of the unified credit allowed against the estate tax to $7,500,000 and to establish a flat estate tax rate. H.R.1568 – to amend the Internal Revenue Code of 1986 to permanently reduce estate and gift tax rates to 30 percent, to increase the exclusion equivalent of the unified credit to $10,000,000, and to increase the annual gift tax exclusion to $50,000. H.R.1574 – to amend the Internal Revenue Code of 1986 and the Economic Growth and Tax Relief Reconciliation Act of 2001 to restore the estate tax and repeal the carryover basis rule and to increase the estate tax unified credit to an exclusion equivalent of $3,500,000. H.R.1577 – to amend the Internal Revenue Code of 1986 to retain the estate tax with an immediate increase in the exemption, to repeal the new carryover basis rules in order to prevent tax increases and the imposition of compliance burdens on many more estates than would benefit from repeal, and for other purposes H.R.1614 – to amend the Internal Revenue Code of 1986 to reduce estate tax rates by 20 percent, to increase the unified credit against estate and gift taxes to the equivalent of a $3,000,000 exclusion and to provide an inflation adjustment of such amount, and for other purposes. H.R.1624 – to amend the Internal Revenue Code of 1986 to provide for the immediate and permanent repeal of the estate tax on family-owned businesses and farms, and for other purposes. H.R.2180 - to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of variable contracts issued by life insurance companies subject to the laws of Puerto Rico. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005 H.R. 2830 – Pension Protection Act of 2005 H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3254 – CARE Act H.R. 3523 – Estate Tax Deferral for Working Farms and Land Conservation Act of 2005 H.R. 4104 – Qualified Long Term Care Fairness Act H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 H.R. 4707 – Simplified USA Tax Act of 2006 H.R. 5421 – To amend the Internal Revenue Code of 1986 to restore the estate tax and repeal the carryover basis rule, to increase the estate and gift tax unified credit to an exclusion equivalent of $5,000,000, and to reduce the rate of the estate and gifts taxes to the generally applicable capital gains income tax rate. H.R. 5638 – Permanent Estate Tax Relief Act of 2006 S.7 – to increase American jobs and economic growth by making permanent the individual income tax rate reductions, the reduction in the capital gains and dividend tax rates, and the repeal of the estate, gift, and generation-skipping transfer taxes. S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 381 -- Retirement Security for Life Act of 2005 S.420 – to make the repeal of the estate tax permanent. S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S. 812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S. 928 – to amend the Internal Revenue Code of 1986 to provide for the immediate and permanent repeal of the estate tax on family-owned businesses and farms, and for other purposes. S. 988 – to permanently repeal the estate and generation-skipping transfer taxes. S. 993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1783 – The Pension Security and Transparency Act of 2005 S. 1921 – Savings for Working Families Act of 2005 S. 2020 – Tax Relief Act of 2005 S. 2254 – Caregiver Assistance and Relief Effort Act S. 2281 – Aging with Respect and Dignity Act S. 2397 – Long Term Care Trust Account Act S. 2457 – Small Business Health Insurance Relief Act S. 3626 – Estate Tax Relief and Reform Act of 2006
Client expense: $4,392,150 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2006 · year_end · Taxation/Internal Revenue Code
HR.2911 – “A bill to amend the Internal Revenue Code of 1986 to modify the active business definition under section 355.” S.1159 – “A bill to amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption to achieve financing income.” S.1327 – “A bill to amend the Internal Revenue Code of 1986 to modify the active business definition under section 355.” S.750 – “A bill to amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations.” HR.6134 - Health Opportunity Patient Empowerment Act of 2006 HR.6111 - Tax Relief and Health Care Act of 2006 HR.1471 – “A bill to amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption to achieve financing income.” HR.1956 – Business Activity Tax Simplification Act of 2005
Client expense: Not reported · Firm income: $80,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2005 · year_end · Taxation/Internal Revenue Code
H.R.8 – to make the repeal of the estate tax permanent H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R.64 – to repeal the Federal death tax, including the estate and gift taxes and the tax on generation-skipping transfers. H.R.183 – to make the repeal of the estate tax permanent. H.R. 809 -- To make permanent the individual income tax rates for capital gains and dividends. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.1560 – to amend the Internal Revenue Code of 1986 to increase the exclusion equivalent of the unified credit allowed against the estate tax to $7,500,000 and to establish a flat estate tax rate. H.R.1568 – to amend the Internal Revenue Code of 1986 to permanently reduce estate and gift tax rates to 30 percent, to increase the exclusion equivalent of the unified credit to $10,000,000, and to increase the annual gift tax exclusion to $50,000. H.R.1574 – to amend the Internal Revenue Code of 1986 and the Economic Growth and Tax Relief Reconciliation Act of 2001 to restore the estate tax and repeal the carryover basis rule and to increase the estate tax unified credit to an exclusion equivalent of $3,500,000. H.R.1577 – to amend the Internal Revenue Code of 1986 to retain the estate tax with an immediate increase in the exemption, to repeal the new carryover basis rules in order to prevent tax increases and the imposition of compliance burdens on many more estates than would benefit from repeal, and for other purposes H.R.1614 – to amend the Internal Revenue Code of 1986 to reduce estate tax rates by 20 percent, to increase the unified credit against estate and gift taxes to the equivalent of a $3,000,000 exclusion and to provide an inflation adjustment of such amount, and for other purposes. H.R.1624 – to amend the Internal Revenue Code of 1986 to provide for the immediate and permanent repeal of the estate tax on family-owned businesses and farms, and for other purposes. H.R.2180 - to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of variable contracts issued by life insurance companies subject to the laws of Puerto Rico. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005. H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3304 – Growing Real Ownership for Workers Act of 2005. H.R. 4297 – Tax Relief Extension Reconciliation Act of 2005 S.7 – to increase American jobs and economic growth by making permanent the individual income tax rate reductions, the reduction in the capital gains and dividend tax rates, and the repeal of the estate, gift, and generation-skipping transfer taxes. S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 219 - National Employee Savings and Trust Equity Guarantee Act of 2005 S. 381 -- Retirement Security for Life Act of 2005 S.420 – to make the repeal of the estate tax permanent. S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S.812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S.928 – to amend the Internal Revenue Code of 1986 to provide for the immediate and permanent repeal of the estate tax on family-owned businesses and farms, and for other purposes. S.988 – to permanently repeal the estate and generation-skipping transfer taxes. S.993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1302 – Social Security Personal Savings Guarantee and Prosperity Act of 2005. S. 1783 – The Pension Security and Transparency Act of 2005 S. 2020 – Tax Relief Act of 2005
Client expense: $3,995,682 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2005 · year_end · Taxation/Internal Revenue Code
S. 1159, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing. H.R. 1417, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. H.R. 4297, Tax Relief Extension Reconciliation Act of 2005 Sec. 202(a), Subpart F Exemption for Active Financing
Client expense: $3,376,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
2005 · year_end · Taxation/Internal Revenue Code
Mutual Fund Capital Gain Relief Expiring Provisions of Bush Administration Savings Proposal Tax Shelters and other revenue raising provisions Active Financing Legislation (HR1417; S1159) Capital Gains & Dividend Tax Rate Extension Tax Reconciliation Legislation
Client expense: $1,240,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)
2005 · mid_year · Taxation/Internal Revenue Code
H.R.8 – to make the repeal of the estate tax permanent H.R.25 - to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. H.R.51 - to amend the Internal Revenue Code of 1986 to increase the dollar limitation on employer-provided group term life insurance that can be excluded from the gross income of the employee. H.R.64 – to repeal the Federal death tax, including the estate and gift taxes and the tax on generation-skipping transfers. H.R.183 – to make the repeal of the estate tax permanent. H.R. 809 -- To make permanent the individual income tax rates for capital gains and dividends. H.R. 819 – Retirement Security for Life Act of 2005. H.R.1040 – to amend the Internal Revenue Code of 1986 to provide taxpayers a flat tax alternative to the current income tax system. H.R. 1417 – To permanently extend the Subpart F exemption for active financing. H.R.1560 – to amend the Internal Revenue Code of 1986 to increase the exclusion equivalent of the unified credit allowed against the estate tax to $7,500,000 and to establish a flat estate tax rate. H.R.1568 – to amend the Internal Revenue Code of 1986 to permanently reduce estate and gift tax rates to 30 percent, to increase the exclusion equivalent of the unified credit to $10,000,000, and to increase the annual gift tax exclusion to $50,000. H.R.1574 – to amend the Internal Revenue Code of 1986 and the Economic Growth and Tax Relief Reconciliation Act of 2001 to restore the estate tax and repeal the carryover basis rule and to increase the estate tax unified credit to an exclusion equivalent of $3,500,000. H.R.1577 – to amend the Internal Revenue Code of 1986 to retain the estate tax with an immediate increase in the exemption, to repeal the new carryover basis rules in order to prevent tax increases and the imposition of compliance burdens on many more estates than would benefit from repeal, and for other purposes H.R.1614 – to amend the Internal Revenue Code of 1986 to reduce estate tax rates by 20 percent, to increase the unified credit against estate and gift taxes to the equivalent of a $3,000,000 exclusion and to provide an inflation adjustment of such amount, and for other purposes. H.R.1624 – to amend the Internal Revenue Code of 1986 to provide for the immediate and permanent repeal of the estate tax on family-owned businesses and farms, and for other purposes. H.R.2180 - to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of variable contracts issued by life insurance companies subject to the laws of Puerto Rico. H.R.2251 – COLI Best Practices Act of 2005 H.R. 2682 – Long-Term Care and Retirement Security Act of 2005. H.R. 3019 – To permit the consolidation of life insurance companies with other companies. H.R. 3304 – Growing Real Ownership for Workers Act of 2005. S.7 – to increase American jobs and economic growth by making permanent the individual income tax rate reductions, the reduction in the capital gains and dividend tax rates, and the repeal of the estate, gift, and generation-skipping transfer taxes. S.25 – to promote freedom, fairness, and economic opportunity by repealing the income tax and other taxes, abolishing the Internal Revenue Service, and enacting a national sales tax to be administered primarily by the States. S. 219 - National Employee Savings and Trust Equity Guarantee Act of 2005 S. 381 -- Retirement Security for Life Act of 2005 S.420 – to make the repeal of the estate tax permanent. S. 602 – Ronald Reagan Alzheimer’s Breakthrough Act of 2005. S. 723 – SIMPLE Cafeteria Plan Act of 2005. S.812 – to amend the Internal Revenue Code of 1986 to impose a flat tax only on individual taxable earned income and business taxable income, and for other purposes. S.928 – to amend the Internal Revenue Code of 1986 to provide for the immediate and permanent repeal of the estate tax on family-owned businesses and farms, and for other purposes. S.988 – to permanently repeal the estate and generation-skipping transfer taxes. S.993 - to amend the Internal Revenue Code of 1986 to impose an excise tax on amounts received under certain insurance policies in which certain exempt organizations hold an interest. S.1099 – to repeal the current Internal Revenue Code and replace it with a flat tax, thereby guaranteeing economic growth and greater fairness for all Americans. S. 1159 -- To permanently extend the Subpart F exemption for active financing. S. 1244 -- Long-Term Care and Retirement Security Act of 2005. S. 1293 -- To permit the consolidation of life insurance companies with other companies. S. 1302 – Social Security Personal Savings Guarantee and Prosperity Act of 2005.
Client expense: $4,200,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Labor, Dept of (DOL), SENATE, Treasury, Dept of
2005 · mid_year · Taxation/Internal Revenue Code
Active Financing Exception to Subpart F (H.R.1417, S.1159) Advanced Technology Tax Incentives (H.R.6, H.R.626, H.R.722, H.R.1397, H.R.1541, H.R.1744, H.R.2828, H.R.3152, H.R.3263, S.971) Corporate Alternative Minimum Tax Gas Guzzler Tax/Sport Utility Vehicles Group Legal Services Income Exclusion (H.R.897, H.R.1231, S.1160) Pension Reform (H.R.2830, S.219) Research & Dev. Tax Credit (H.R.1736, S.626) Section 280F/Sport Utility Vehicles Tax Reform Taxation of Manufacturer Incentives to Sales People Transportation/Motor Fuel Taxes Truck Excise Tax (H.R.1049)
Client expense: $4,060,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Council of Economic Advisers (CEA), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), Federal Highway Administration (FHA), Federal Maritime Commission, Federal Railroad Administration, Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Aeronautics & Space Administration (NASA), Natl Economic Council (NEC), Natl Highway Traffic Safety Administration (NHTSA), Natl Science Foundation (NSF), Natl Transportation Safety Board (NTSB), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Vice President of the United States, Pension Benefit Guaranty Corporation (PBGC), SENATE, State, Dept of (DOS), Surface Transportation Board (STB), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2005 · mid_year · Taxation/Internal Revenue Code
H.R. 1417, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income S. 1159, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exempton for active financing
Client expense: $1,683,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office