A bill to amend the Internal Revenue Code of 1986 to allow certain modifications to be made to qualified mortgages held by a REMIC or a grantor trust.

Real estate mortgage investment conduits (H.R. 1010, S. 580); Treasury regulations regarding WHFITs; tax reporting proposals; Treasury regulations regarding section 1221(a)(4) of the Internal Revenue Code

Client expense: Not reported · Firm income: $60,000

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

H.R. 8/ S. 420 - Death Tax Repeal Permanency Act of 2005 would make the provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001 concerning the repeal of the Federal estate tax and generation-skipping transfer tax (Death Tax/Estate Tax) permanent. H.R. 25/S. 1921 - Fair Tax Act of 2005 - Repeals the income tax, employment tax, and estate and gift tax. Redesignates the Internal Revenue Code of 1986 as the Internal Revenue Code of 2005. Imposes a national sales tax on the use or consumption in the United States of taxable property or services. H.R. 453 - Home Lead Safety Tax Credit Act of 2005 - Amends the Internal Revenue Code to provide owners of residential properties built in the United States before 1978 a tax credit for lead-based paint abatement costs performed by a certified lead abatement contractor. Limits the amount of such credit to 50 percent of the cost of the abatement, not to exceed $1,500 per dwelling unit. H.R. 1010/S. 580 - Amends the Internal Revenue Code to permit certain amendments, waivers, or other modifications to mortgages held by a Real Estate Mortgage Investment Conduit (REMIC) or a Grantor Trust without disqualifying such mortgages as REMIC or Grantor Trust mortgages. Permits amendments, waivers, or modifications that do not extend the final maturity date of a mortgage, increase the outstanding balance of the mortgage, result in the release of an interest in real property securing the mortgage, or result in an instrument or property right which is not debt for Federal income tax purposes. H.R. 1549/S. 859 - Renewing the Dream Tax Credit Act amends the Internal Revenue Code to allow homebuilders and investors a general business tax credit for building or substantially rehabilitating residences for low and moderate-income individuals in certain areas, including a rural area, an Indian reservation, or an area of chronic economic distress. H.R. 1663/S. 621 - would both amends the Internal Revenue Code to make permanent the 15-year recovery period for the depreciation of qualified leasehold improvement property (property held and improved by a lessor). H.R. 2668/ S. 3116 - Policyholder Disaster Protection Act of 2005 amends the Internal Revenue Code to allow insurance companies (other than life insurance companies) to make tax deductible contributions to a tax-exempt policyholder disaster protection fund established by this Act for the payment of policyholders' claims arising from certain catastrophic events, such as windstorms, earthquakes, fires, or floods. H.R. 2980/ H.R. 3268- Eminent Domain Relief Act amends the Internal Revenue Code to allow the non-recognition of gain from the involuntary conversion (by eminent domain) of taxpayer property. Exempts such taxpayer from certain tax rules for involuntary conversions, including the requirement that the condemned property be converted into similar property within a specified two-year period. H.R. 3098/S. 132 - Mortgage Insurance Fairness Act of 2005 amends the Internal Revenue Code to allow a tax deduction for mortgage insurance premiums. Reduces the amount of such deduction for taxpayers with adjusted gross incomes exceeding $100,000. H.R. 4128/S. 1895 - Private Property Rights Protection Act would make ineligible for federal funds any condemning authority or acquiring party that engages or participates in a taking or condemnation of any real property interest not for a public use or public purpose using the power of eminent domain, without the owner's consent. It would also allow a property owner who is notified that his or her property will be taken to file for and attach a Fifth Amendment property protection statement (PPS) indicating that the condemning entity is exceeding its authority. H.R. 4297/ S. 2020 - Tax Relief Act of 2005 were tax reconciliation bills. Included in these bills were real estate related tax provisions concerning: a one-year trial for specific mortgage insurance premium deductions, a one-year extension for brownfield tax deductions, a one-year extension for leasehold improvement property 15-year recovery period for depreciation, extensions and changes to qualified mortgage veteran bonds, and a one-year adjustment for the alternative minimum tax. H.R. 5638/ H.R. 5970 - Permanent Estate Tax Relief Act of 2006 would allow for estates under $5 million ($10 million for couples) to be exempt from the estate tax. Estates that are over $5 million but below $25 million would be taxed at the same rate as capital gains, currently 15%. Estates that are over $25 million would be taxed at double the capital gains rate, currently 30%. H.R. 3194/S. 1330 - Both bills would give employers a tax credit of up to 50 percent of $10,000 or 6% of the purchase price of the employee's principle residence (whichever is less). H.R. 6111 - The Tax Relief and Healthcare Act of 2006 included extensions to Internal Revenue Codes that included, leasehold improvements deductible and amortized over 15-years, Brownfield improvement deductions, and a mortgage insurance premium deduction. S. 1883 - Empowering More Property Owners With Enhanced Rights Act of 2005 would amend the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 to require a federal agency when acquiring real property to provide to a property owner with: (1) at the beginning of the negotiation process, the current contact information for the Office of the Property Rights Ombudsperson; (2) a description of available mediation and other dispute resolution alternatives; and (3) in specified cases, a copy of the appraisal. Downpayment Assistance Programs - Have contacted members of Congress and staff at Internal Revenue Service (IRS) concerning their May 4, 2006 ruling that organizations that provide seller-funded downpayment assistance to buyers cannot qualify as tax-exempt organizations. In order to qualify the programs must be properly structured and operated under the rules the IRS has set for not-for-profit organizations. Employee Housing Downpayment Assistance - Have contacted staff/members of Congress about the possibility of introducing legislation that would allow for employee housing downpayment assistance programs that would give employers an incentive to provide their employees with housing downpayment assistance and make the downpayment assistance tax-free to the employees. Tax Reform - Have contacted members of Congress concerning the President's Advisory Panel on Federal Tax Reform report, which was issued on November 1, 2005. Discussions were about the Real Estate related concerns, such as the mortgage interest deduction, home equity lines of credit, and state/local tax deductions. These issues have been addressed in conjunction with discussions concerning the Alternative Minimum Tax (AMT). House Concurrent Resolution 272 - Expresses support for the current standards of the mortgage interest tax deduction under the Internal Revenue Code and opposition to the initial recommendation of the President's Advisory Panel on Federal Tax Reform to limit such deduction. FIRPTA Changes - Have contacted members of Congress concerning changing the provisions in the Foreign Investment Real Property Tax Act (FIRPTA) to allow a seller of property to provide the information required by FIRPTA to escrow or another settlement provider as an alternative to providing that information to the buyer.

Client expense: $60,000 · Firm income: Not reported

Government targets: Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of, Veterans Affairs, Dept of (VA)

S 132 - MORTGAGE INSURANCE FAIRNESS ACT OF 2005 S 580 - AMERNDEMNT OF INTERNAL REVENUE CODE OF 1986 FOR QUALIFIED MORTGAGE MODIFICATIONS HR 12010 - AMENDMENT OF INTERNAL REVUNUE CODE OF 1986 FOR QUALIFIED MORTGAGE MODIFICATIONS HR 3098 - MORTGAGE INSURANCE FAIRNESS ACT OF 2005 S 1330/HR3194 - HOUSING AMERICAS WORKFORCE ACT HR 3975 - HURRICANE REGULATORY RELIEF ACT OF 2005 HR 4155 -- GULF OPPORTUNITY ZONE ACT OF 2005 HR 4334 HURRICANE WILMA TAXPAYER RELIEF ACT OF 2005

Client expense: $883,400 · Firm income: Not reported

Government targets: Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Patent & Trademark Office (PTO), SENATE