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A bill to amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions.
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0 actions · 0 new cosponsors · 0 votes
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vs 3,722 other S bills in the 110th — cohort avg 42d
No CRS summary is available for this bill yet. The source title, actions, sponsors, and text versions below come from Congress.gov.
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Filing registrants (6)
2009 · first_quarter · Taxation/Internal Revenue Code
Bills with similar content found using semantic analysis.
Sources: Congress.gov
Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] 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 OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment 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 Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC
Client expense: $2,030,000 · Firm income: Not reported
Government targets: Bureau of Economic Analysis, Bureau of Industry and Security (BIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Central Intelligence Agency (CIA), 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), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), 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), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Agency (NSA), 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, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office
2008 · first_quarter · Taxation/Internal Revenue Code
Legislation relating to subpart F - S. 2380, S. 540, H.R. 1505
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
Tax relief, general issues. S. 2380 Subpart F Relief Bill, entire bill. S. 41 Research Competititiveness Act, entire bill. H.R. 2138 Investment in America Act, entire bill. S. 2209 Research Credit Improvement Act, entire bill. H.R. 6049 Energy and Tax Extenders Act of 2008, Sec 221 R&D Tax credit and Sec. 240 Look Through rule. S. 3125 Energy Independence and Tax Relief Act of 2008, R&D Tax credit and look through provisions. H.R. 7060 Renewable Energy and Job Creation Tax Act, Sec. 221 R&D Tax credit and Sec. 240 Look Through rule. H.R. 1424 Emergency Economic Stablilization Act of 2008, Division C provisions relating to R&D Tax credit and Look Through rule extensions. S. 3335 Job, Energy, Families and Disaster Relief Act of 2008, Sec. 221 R&D Tax credit and Sec. 240 Look Through rule.
Client expense: $980,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Director of National Intelligence (ODNI), Executive Office of the President (EOP), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Natl Institutes of Health (NIH), Natl Security Agency (NSA), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)
2008 · fourth_quarter · Taxation/Internal Revenue Code
Negotiation and Ratification of Bilateral Income Tax Treaties Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] 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 OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment 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 Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification H.R. 4297, Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591, U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 1424, Paul Wellstone Mental Health and Addiction Equity Act of 2007
Client expense: $1,080,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Bureau of Economic Analysis, Bureau of Industry and Security (BIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Central Intelligence Agency (CIA), 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), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), 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), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Agency (NSA), 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, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 2138, Investment in America Act of 2007. S. 2209, Research Credit Improvement Act of 2007. S. 1726, Business Activity Tax Simplification Act of 2007. H.R. 5267, Business Activity Tax Simplification Act of 2008. S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 3970, The Tax Reduction and Reform Act of 2007. IRC Section 409A. IRC Section 954. IRC Sections 956 and 965. H.R. 3359, The Mobile Workforce State Income Tax Fairness and Simplification Act of 2007. Proposed Treas. Reg. 1.482-7. IRC Section 901(l). Transfer pricing, treaty, international tax, and tax reform issues. S. 2886, A bill to amend the Internal Revenue Code of 1986 to amend certain expiring provisions. S. 3125, Energy Independence and Tax Relief Act of 2008. H.R. 6049, To amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes. Proposed Protocol To The Income Tax Treaty Between The United States And Canada (services PE, hybrid issues). H.R. 1424, To provide authority for the Federal Government to purchase and insure certain types of troubled assets for the purposes of providing stability to and preventing disruption in the economy and financial system and protecting taxpayers, to amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes. S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008. H.R. 7060, Renewable Energy and Job Creation Tax Act of 2008.
Client expense: $2,020,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Science Foundation (NSF), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR)
2008 · fourth_quarter · Taxation/Internal Revenue Code
Legislation relating to subpart F - S.2380, S.540, H.R. 1505
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
Extension of R & D Tax Credit (S. 2886) Active Software Rents and Royalties Exception to Subpart F and Extension of Look Through Rule (S. 2380) Business Activity Tax Simplification Act (S. 1726, HR 5267) Streamlined Sales Tax (S. 34, HR 3396)
Client expense: $40,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · second_quarter · Taxation/Internal Revenue Code
Extension of R & D Tax Credit (S. 2886) Active Software Rents and Royalties Exception to Subpart F and Extension of Look Through Rule (S. 2380) Business Activity Tax Simplification Act (S. 1726, HR 5267) Streamlined Sales Tax (S. 34, HR 3396)
Client expense: $40,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
Legislation relating to subpart F - S.2380, S.540, H.R. 1505
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 2138, Investment in America Act of 2007. S. 2209, Research Credit Improvement Act of 2007. S. 1726, Business Activity Tax Simplification Act of 2007. H.R. 5267, Business Activity Tax Simplification Act of 2008. S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 3970, The Tax Reduction and Reform Act of 2007. IRC Section 409A. IRC Section 954. H.R. 3359, The Mobile Workforce State Income Tax Fairness and Simplification Act of 2007. Proposed Treas. Reg. 1.482-7. IRC Section 901(l). Transfer pricing, treaty, international tax, and tax reform issues. S. 2886, A bill to amend the Internal Revenue Code of 1986 to amend certain expiring provisions. S. 3125, Energy Independence and Tax Relief Act of 2008. H.R. 6049, To amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes. Proposed Protocol To The Income Tax Treaty Between The United States And Canada (services PE, hybrid issues). H.R. 1424, To provide authority for the Federal Government to purchase and insure certain types of troubled assets for the purposes of providing stability to and preventing disruption in the economy and financial system and protecting taxpayers, to amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes. S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008. H.R. 7060, Renewable Energy and Job Creation Tax Act of 2008.
Client expense: $1,980,000 · Firm income: Not reported
2008 · third_quarter · 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 U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India 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 Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section F; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] 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 OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment 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 Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification H.R. 4297, Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591, U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38
2008 · third_quarter · Taxation/Internal Revenue Code
Tax relief, general issues. S. 2380 Subpart F Relief Bill, entire bill. S. 41 Research Competititiveness Act, entire bill. H.R. 2138 Investment in America Act, entire bill. S. 2209 Research Credit Improvement Act, entire bill. H.R. 6049 Energy and Tax Extenders Act of 2008, Sec 221 R&D Tax credit and Sec. 240 Look Through rule. S. 3125 Energy Independence and Tax Relief Act of 2008, R&D Tax credit and look through provisions. H.R. 7060 Renewable Energy and Job Creation Tax Act, Sec. 221 R&D Tax credit and Sec. 240 Look Through rule. H.R. 1424 Emergency Economic Stablilization Act of 2008, Division C provisions relating to R&D Tax credit and Look Through rule extensions. S. 3335 Job, Energy, Families and Disaster Relief Act of 2008, Sec. 221 R&D Tax credit and Sec. 240 Look Through rule.
Client expense: $1,550,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Director of National Intelligence (ODNI), Executive Office of the President (EOP), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Natl Institutes of Health (NIH), Natl Security Agency (NSA), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)
2008 · second_quarter · Taxation/Internal Revenue Code
Tax relief, general issues; S 2380 Subpart F Relief Bill, whole bill. S. 41, Research Competitiveness Act, whole bill. H.R. 2138, Investment in America Act, whole bill. S 2209, Research Credit Improvement Act, whole bill. Specific Lobbying Issues Continued: H.R. 6049, Energy and Tax Extenders Act of 2008, R & D tax credit and look through provisions. S. 3125, Energy Independence and Tax Relief Act of 2008, R & D tax credit and look through provisions.
Client expense: $1,280,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Director of National Intelligence (ODNI), Executive Office of the President (EOP), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Labor, Dept of (DOL), Natl Institute of Standards & Technology (NIST), Natl Security Agency (NSA), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)
2008 · second_quarter · 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 U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India 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 Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section F; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] 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 OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment 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 Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification H.R. 4297, Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591, U.S. Troop Readiness, Veterans' Care, Katrina Recovery, and Iraq Accountability Appropriations Act, 2007 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38
2008 · first_quarter · Taxation/Internal Revenue Code
Extension of R & D Tax Credit (S. 2886) Active Software Rents and Royalties Exception to Subpart F and Extension of Look Through Rule (S. 2380) Business Activity Tax Simplification Act (S. 1726, HR 5267) Streamlined Sales Tax (S. 34, HR 3396)
Client expense: $40,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · second_quarter · Taxation/Internal Revenue Code
H.R. 2138, Investment in America Act of 2007. S. 2209, Research Credit Improvement Act of 2007. S. 1726, Business Activity Tax Simplification Act of 2007. H.R. 5267, Business Activity Tax Simplification Act of 2008. S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 3970, The Tax Reduction and Reform Act of 2007. IRC Section 409A. IRC Section 954. H.R. 3359, The Mobile Workforce State Income Tax Fairness and Simplification Act of 2007. Proposed Treas. Reg. 1.482-7. IRC Section 901(l). Transfer pricing, treaty, international tax, and tax reform issues. H.R. 3996, The Temporary Tax Relief Act of 2007. H.R. 5140, Economic Stimulus Act of 2008. S. 2886, A bill to amend the Internal Revenue Code of 1986 to amend certain expiring provisions. S. 3125, Energy Independence and Tax Relief Act of 2008. H.R. 6049, To amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes. Proposed Protocol To The Income Tax Treaty Between The United States And Canada (services PE, hybrid issues).
Client expense: $2,340,000 · Firm income: Not reported
2008 · second_quarter · Taxation/Internal Revenue Code
Legislation relating to subpart F - S.2380, S.540, H.R. 1505
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · second_quarter · Taxation/Internal Revenue Code
H.R. 2138, Investment in America Act of 2007. S. 2209, Research Credit Improvement Act of 2007. S. 1726, Business Activity Tax Simplification Act of 2007. H.R. 5267, Business Activity Tax Simplification Act of 2008. S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 3970, The Tax Reduction and Reform Act of 2007. IRC Section 409A. IRC Section 954. H.R. 3359, The Mobile Workforce State Income Tax Fairness and Simplification Act of 2007. Proposed Treas. Reg. 1.482-7. IRC Section 901(l). Transfer pricing, treaty, international tax, and tax reform issues. H.R. 3996, The Temporary Tax Relief Act of 2007. H.R. 5140, Economic Stimulus Act of 2008. S. 2886, A bill to amend the Internal Revenue Code of 1986 to amend certain expiring provisions. S. 3125, Energy Independence and Tax Relief Act of 2008. H.R. 6049, To amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes. Proposed Protocol To The Income Tax Treaty Between The United States And Canada (services PE, hybrid issues).
Client expense: $2,300,000 · Firm income: Not reported
2008 · first_quarter · Taxation/Internal Revenue Code
H.R. 2138, Investment in America Act of 2007. S. 2209, Research Credit Improvement Act of 2007. S. 1726, Business Activity Tax Simplification Act of 2007. H.R. 5267, Business Activity Tax Simplification Act of 2008. S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 3970, The Tax Reduction and Reform Act of 2007. IRC Section 409A. IRC Section 954. H.R. 3359, The Mobile Workforce State Income Tax Fairness and Simplification Act of 2007. Proposed Treas. Reg. 1.482-7. IRC Section 901(I). Transfer pricing, treaty, international tax, and tax reform issues. H.R. 3996, The Temporary Tax Relief Act of 2007. H.R. 5140, Economic Stimulus Act of 2008.
Client expense: $2,560,000 · Firm income: Not reported
2008 · first_quarter · Taxation/Internal Revenue Code
Tax relief, general issues; S 2380 Subpart F Relief Bill, whole bill. S 41 Research Competitiveness Act, whole bill. HR 2138 Investment in America Act, whole bill. S 2209 Research Credit Improvement Act, whole bill. Specific Lobbying Issues Continued: HR 5140 Economic Stimulus Act of 2008, whole bill
Client expense: $1,180,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Defense, Dept of (DOD), Executive Office of the President (EOP), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Natl Institute of Standards & Technology (NIST), Natl Security Agency (NSA), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)
2008 · first_quarter · 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 U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India 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 Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940 To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section F; and H.R. 1509 H.R. 2138 Investment in America Act of 2007 / S 41 Research Competitiveness Act of 2007 / S 2209 Research Credit Improvement Act of 2007 R&D Tax Credit S. 1726 Business Activity Tax Simplification Act of 2007 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 OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment 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 Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Economic Substance Doctrine Codification H.R. 4297 Tax Increase Prevention and Reconciliation Act of 2005 Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 H.R. 1591 Minimum Wage Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359 Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970 Tax Reduction and Reform Act of 2007 S. 2380 To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions.
2008 · first_quarter · Taxation/Internal Revenue Code
Extension of R & D Tax Credit (S. 2886) Active Software Rents and Royalties Exception to Subpart F and Extension of Look Through Rule (S. 2380) Business Activity Tax Simplification Act (S. 1726, HR 5267) Streamlined Sales Tax (S. 34, HR 3396)
Client expense: $40,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · first_quarter · Taxation/Internal Revenue Code
Extension of R & D Tax Credit (S. 2886) Active Software Rents and Royalties Exception to Subpart F and Extension of Look Through Rule (S. 2380) Business Activity Tax Simplification Act (S. 1726, HR 5267) Streamlined Sales Tax (S. 34, HR 3396)
Client expense: $40,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · first_quarter · Taxation/Internal Revenue Code
H.R. 2138, Investment in America Act of 2007. S. 2209, Research Credit Improvement Act of 2007. S. 1726, Business Activity Tax Simplification Act of 2007. H.R. 5267, Business Activity Tax Simplification Act of 2008. S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 3970, The Tax Reduction and Reform Act of 2007. IRC Section 409A. IRC Section 954. H.R. 3359, The Mobile Workforce State Income Tax Fairness and Simplification Act of 2007. Proposed Treas. Reg. 1.482-7. IRC Section 901(I). Transfer pricing, treaty, international tax, and tax reform issues. H.R. 3996, The Temporary Tax Relief Act of 2007. H.R. 5140, Economic Stimulus Act of 2008.
Client expense: $2,560,000 · Firm income: Not reported
2008 · first_quarter · Taxation/Internal Revenue Code
Legislation relating to subpart F - S. 2380, S. 540, H.R. 1505
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · first_quarter · Computer Industry
S. 1145 Patent reform: all provisions related to patents S. 2380: provisions related to active software royalties HR 4279: provisions related to copyright damages R&D tax credit: proposals related to extending the credit Intellectual property protection: policies related to software piracy, software license enforcement worldwide
Client expense: $90,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade Representative (USTR)
2007 · year_end · Taxation/Internal Revenue Code
Legislation relating to subpart F - S. 2380, S. 540, H.R. 1505
Client expense: Not reported · Firm income: $100,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2007 · year_end · Taxation/Internal Revenue Code
Legislation relating to subpart F - S. 2380, S. 540, H.R. 1505
Client expense: Not reported · Firm income: $100,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Science Foundation (NSF), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR)
Client expense: $1,240,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Bureau of Economic Analysis, Bureau of Industry and Security (BIS), Bureau of the Census, Centers For Disease Control & Prevention (CDC), Central Intelligence Agency (CIA), 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), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), 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), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Agency (NSA), 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, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office
Client expense: $2,030,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Bureau of Economic Analysis, Bureau of the Census, Centers For Disease Control & Prevention (CDC), Central Intelligence Agency (CIA), 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), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), 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), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Institutes of Health (NIH), Natl Science Foundation (NSF), Natl Security Agency (NSA), 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, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), Vice President of the U.S., White House Office
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Science Foundation (NSF), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR)
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Science Foundation (NSF), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR)
Client expense: $1,870,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Bureau of Economic Analysis, Bureau of the Census, Centers For Disease Control & Prevention (CDC), 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), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), 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), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), 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, SENATE, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR)
Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Science Foundation (NSF), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR)