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A bill to amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations.
Legislative Progress
Momentum (last 30 days)
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0 actions · 0 new cosponsors · 0 votes
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vs 4,105 other S bills in the 109th — cohort avg 35d
No CRS summary is available for this bill yet. The source title, actions, sponsors, and text versions below come from Congress.gov.
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Filing registrants (7)
2006 · year_end · Taxation/Internal Revenue Code
Bills with similar content found using semantic analysis.
Sources: Congress.gov
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
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
2006 · year_end · Taxation/Internal Revenue Code
Permanent extension and expansion of research credit; energy tax benefits; tax on settlement payments; international taxation; superfund taxes; tax accounting S. 627; S. 750; S. 1321; S. 3523 H.R. 1762; H.R. 6111; H.R. 6142; H.R. 6408; H.R. 1212
Client expense: $740,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), Federal Railroad Administration, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Pension Benefit Guaranty Corporation (PBGC), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2006 · year_end · Taxation/Internal Revenue Code
H.R. 1186 - Alternative Minimum Tax Repeal Act of 2005 H.R. 1538 - To increase the exemption amounts for individuals under the AMT H.R. 1599 - To extend for two years the higher exemption amounts under the AMT for individuals and to adjust the exemption amounts and phaseout thresholds in the AMT for inflation H.R. 1762 - To amend the IRS Code of 1986 to allow look-through treatment of payments between related foreign corporations H.R. 2233 - Pension Fairness and Full Disclosure Act H.R. 2321 - Pension Security Disclosure Act H.R. 2830 - Pension Protection Act H.R. 2911 - To amend the IRS Code of 1986 to modify the active business definition under section 355 H.R. 4297 - Tax Relief Extension Reconciliation Act H.R. 4388 - To amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes. H.R. 5176 - The Fair Flat Tax Act of 2006 H.R. 5368 - A bill to amend the Internal Revenue Code of 1986 to provide for small business tax incentives, to amend the Fair Labor Standards Act of 1938 to increase the minimum wage and to increase the exemption for annual gross volume of sales made or business done H.R. 6408 - Tax Relief and Health Care Act of 2006 H.R. 6111 - Tax Relief and Health Care Act of 2006 H.R. 4 - Pension Protection Act of 2006 H.R. 809 - A Bill to Make Permanent the Individual Income Tax Rates for Capital Gains and Dividends S. 1020 - COMPETE Act of 2005 S. 1066 - Economic Development Act of 2005 S. 1103 - Individual Alternative Minimum Tax Repeal Act of 2005 S. 1327 - To amend the IRS Code of 1986 to modify the active business definition under section 355 S. 1783 - Pension Security and Transparency Act of 2005 S. 2020 - An original bill to provide for reconciliation pursuant to section 202(b) of the concurrent resolution on the budget for fiscal year 2006. S. 219 - National Employee Savings and Trust Equity Guarantee Act of 2005 S. 2558 - Keep America Competitive Tax Credit Act of 2006 S. 2720 - Research Competitiveness Act of 2006 S. 2856 - Financial Services Regulatory Relief Act of 2006 S. 2993 - A bill to amend the Internal Revenue Code of 1986 to impose a temporary oil profit fee and to use the proceeds of the fee collected to provide a Strategic Energy Fund and expand certain energy tax incentives, and for other purposes. S. 627 - Investment in America Act of 2005 S. 7 - Jobs and Growth Tax Relief Act of 2005 S. 750 - To amend the IRS Code of 1986 to allow look-through treatment of payments between related foreign corporations S. 991 - Pension Fairness and Full Disclosure Act of 2005
Client expense: $6,040,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE, White House Office
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 1736 Investment in America Act; HR 2830 Pension Security and Transparency Act; HR 1956 Business Activity Simplificaiton Act; S 750 To amend the IRS Code of 1986 to allow look through treatment for certain payments.
Client expense: $1,939,404 · Firm income: Not reported
Government targets: Bureau of the Census, Commerce, Dept of (DOC), Defense, Dept of (DOD), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Natl Archives & Records Administration (NARA), Navy, Dept of, SENATE, State, Dept of (DOS), Treasury, Dept of, Veterans Affairs, Dept of (VA)
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
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
2006 · mid_year · Taxation/Internal Revenue Code
H. R. 809 - To make permanents the individual income tax rates for capital gains H.R. 1186 - Alternative Minimum Tax Repeal Act of 2005 H.R. 1500 - Investment Tax Simplification Act of 2005 H.R. 1538 - To increase the exemption amounts for individuals under the AMT H.R. 1599 - To extend for two years the higher exemption amounts under the AMT for individuals and to adjust the exemption amounts and phaseout thresholds in the AMT for inflation H.R. 1736 - Investment in America Act 2005 H.R. 1762 - To amend the IRS Code of 1986 to allow look-through treatment of payments between related foreign corporations H.R. 2233 - Pension Fairness and Full Disclosure Act H.R. 2321 - Pension Security Disclosure Act H.R. 2471 - Economic Development Act of 2005 H.R. 2830 - Pension Protection Act H.R. 2911 - To amend the IRS Code of 1986 to modify the active business definition under section 355 H.R. 4297 - Tax Relief Extension Reconciliation Act H.R. 4388 - To amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes. H.R. 5176 - The Fair Flat Tax Act of 2006 H.R. 5368 - A bill to amend the Internal Revenue Code of 1986 to provide for small business tax incentives, to amend the Fair Labor Standards Act of 1938 to increase the minimum wage and to increase the exemption for annual gross volume of sales made or business done H.R. 6 - Energy Policy Act of 2005 H.R. 809 - A Bill to Make Permanent the Individual Income Tax Rates for Capital Gains and Dividends S. 1020 - COMPETE Act of 2005 S. 1066 - Economic Development Act of 2005 S. 1103 - Individual Alternative Minimum Tax Repeal Act of 2005 S. 1327 - To amend the IRS Code of 1986 to modify the active business definition under section 355 S. 1783 - Pension Security and Transparency Act of 2005 S. 2020 - An original bill to provide for reconciliation pursuant to section 202(b) of the concurrent resolution on the budget for fiscal year 2006. S. 219 - National Employee Savings and Trust Equity Guarantee Act of 2005 S. 2558 - Keep America Competitive Tax Credit Act of 2006 S. 2720 - Research Competitiveness Act of 2006 S. 2856 - Financial Services Regulatory Relief Act of 2006 S. 2993 - A bill to amend the Internal Revenue Code of 1986 to impose a temporary oil profit fee and to use the proceeds of the fee collected to provide a Strategic Energy Fund and expand certain energy tax incentives, and for other purposes. S. 627 - Investment in America Act of 2005 S. 7 - Jobs and Growth Tax Relief Act of 2005 S. 750 - To amend the IRS Code of 1986 to allow look-through treatment of payments between related foreign corporations S. 991 - Pension Fairness and Full Disclosure Act of 2005
2005 · year_end · Taxation/Internal Revenue Code
HR 627 Investment in America Act of 2005 (R&D credit) S 627 Invest,ment in America Act of 2005 (R&D credit) HR 2471 Economic Development Act of 2005 (Cuno) S 1066 Economic Development Act of 2005 (Cuno) HR 1956 Business Activity Tax Simplificacation Act HR 2830 Pension Protection Act of 2005 H.R. 1762 To amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations S. 750 To amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations
Client expense: $1,362,071 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Client expense: $6,800,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade Representative (USTR)
Government targets: Bureau of the Census, Defense, Dept of (DOD), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Natl Archives & Records Administration (NARA), Navy, Dept of, SENATE, State, Dept of (DOS), Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office