A bill 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.

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.