Reduce Wasteful Tax Forms Act of 2007

S. 2242/HR 2419/HR 2881(Denial of deduction for certain settlement payments); HR 3970/HR 878/ S.601/HR 2419/HR 5720/ HR 3221 (adjusted basis reporting requirements for brokers); HR 1509/S. 902/HR 6049/S. 3125/S. 2886 (active financing exception under Subpart F); HR 5267 (Business Activity Tax Simplification Act of 2008); Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636/HR 3970/HR 2419/HR 5720/HR 3221 (relating to change in due date for providing payee statements to investors); Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries and banks; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediated structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 4351/HR 3970/HR 3920/HR 6049/HR 5720/3221 (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 4912 (Tax treatment of prepaid derivatives contracts); Extension of capital gains and dividend rates; HR 2091/S. 1963/HR 5720/3221 (Extend Federal Home Loan Bank letter of credit to tax-exempt bonds); HR 6049/HR 5720/HR 3221 (worldwide interest allocation); OECD request for comments on transactional profit methods; IRS Section 265 (b) safe harbor concerning interest expense deductibility; Revenue Procedure 2008-28 (effect of loan modifications on tax status of REMICs and other securitization vehicles); Tax reporting with respect to widely-held fixed investment trusts (Treas. Reg. section 1.671-5); HR 5720/HR 3221/S.2636 (Foreclosure Prevention Act of 2008) (tax exempt housing bonds).

Client expense: $1,050,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Education, Dept of, Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Security Council (NSC), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Taxation of Financial Products Active Financing Legislation (HR 1509; S940) Securities Cost Basis Reporting Energy Tax Legislation Consolidated Tax Returns Business Activity Tax Technical Corrections to Pension Protection Act Partnership Taxation Tax Information Reporting (S.636) Private Equity Taxation Issues Related to Tax-Exempt Bonds Issues Related to Pensions & Deferred Compensation Controlled Foreign Corporation Look Through Treatment (S. 1273, HR 3735) Issues Related to Net Operating Losses Issues Related to Housing Legislation

Client expense: $690,000 · 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, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), 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)

H.R. 878 Simplification Through Additional Reporting Tax Act of 2007; entire bill H.R. 1810 - To amend the Internal Revenue Code of 1986 to permit the consolidation of life insurance companies with other companies; entire bill H.R. 2419 Food and Energy Security Act of 2007; provisions relating to basis reporting H.R. 2796 Generate Retirement Ownership Through Long-Term Holding Act of 2007, entire bill H.R. 3221 - American Housing Rescue and Foreclosure Prevention Act of 2008; provisions relating to tax H.R. 3501 - To amend the Internal Revenue Code of 1986 relating to application of UBIT rules to U.S.-based investments; entire bill H.R. 3970 - Tax Reduction and Reform Act of 2007; provisions relating to individual and corporate rates and dividends received deduction H.R. 3997 - Heroes Earnings Assistance and Relief Tax Act of 2007; provisions relating to savings H.R. 4912 - To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts; provisions relating to exchange traded notes H.R. 5267 - Business Activity Tax Simplification Act of 2008; entire bill H.R. 5719 - Taxpayer Assistance and Simplification Act of 2008; provisions relating to HSA compliance requirements H.R. 5720 - Housing Assistance Tax Act of 2008; provisions relating to individual tax benefits and basis reporting H.R. 6049 - The Energy and Tax Extenders Act of 2008; provisions relating to R&D, small business, and IRA charitable rollovers . H.R. 6110 - Roadmap for America's Future Act; entire bill H.R. 6288 Retiree Health Account Act; entire bill S. 601 - Simplification Through Additional Reporting Tax Act of 2007; entire bill S. 636 Reduce Wasteful Tax Forms Act of 2007; entire bill S. 1593 - Defenders of Freedom Tax Relief Act; provisions relating to savings S. 1726 The Business Activity Tax Simplification Act; entire bill S. 2126 - Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007; entire bill S. 2242 - Heartland, Habitat, Harvest, and Horticulture Act of 2007; tax title S. 2886 - The Alternative Minimum Tax and Extenders Tax Relief Act; provisions relating to R&D, small business, and IRA charitable rollovers S.2933 - Incentives for Older Workers Act; provisions relating to employer-based programs P.L. 110-245 - The Heroes Earnings Assistance and Relief Tax (HEART) Act of 2008; provisions relating to savings

Private Equity Taxation Active Financing Legislation (HR 1509; S940) Consolidated Tax Returns Business Activity Tax Technical Corrections to Pension Protection Act Partnership Taxation Taxation of Financial Products Securities Cost Basis Reporting Tax Information Reporting (S.636) Energy Tax Legislation Issues Related to Tax-Exempt Bonds Issues Related to Pensions & Deferred Compensation Controlled Foreign Corporation Look Through Treatment (S. 1273, HR 3735) Issues Related to Net Operating Losses Issues Related to Housing Legislation

Client expense: $600,000 · 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, 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)

Private Equity Taxation Active Financing Legislation (HR 1509; S940) Consolidated Tax Returns Business Activity Tax Technical Corrections to Pension Protection Act Partnership Taxation Taxation of Financial Products Securities Cost Basis Reporting Tax Information Reporting (S.636) Energy Tax Legislation Issues Related to Tax-Exempt Bonds Issues Related to Pensions & Deferred Compensation Controlled Foreign Corporation Look Through Treatment (S. 1273, HR 3735) Issues Related to Net Operating Losses Issues Related to Housing Legislation

Client expense: $600,000 · 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, 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)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

H.R. 878 Simplification Through Additional Reporting Tax Act of 2007; entire bill H.R. 1810 - To amend the Internal Revenue Code of 1986 to permit the consolidation of life insurance companies with other companies; entire bill H.R. 1820 - Tax Equity for Health Plan Beneficiaries Act; entire bill H.R. 2419 Food and Energy Security Act of 2007; possible need for revenue offsets, including Senate tax provisions H.R. 2796 Generate Retirement Ownership Through Long-Term Holding Act of 2007, entire bill H.R. 3501 - To amend the Internal Revenue Code of 1986 relating to application of UBIT rules to U.S.-based investments H.R. 3970 - Tax Reduction and Reform Act of 2007; provisions relating to individual and corporate rates and dividends received deduction H.R. 3997 - Heroes Earnings Assistance and Relief Tax Act of 2007; provisions relating to retirement savings H.R. 4912 - To amend the Internal Revenue Code of 1986 with respect to the treatment of prepaid derivative contracts; provisions relating to exchange traded notes S. 601 - Simplification Through Additional Reporting Tax Act of 2007; entire bill S. 636 Reduce Wasteful Tax Forms Act of 2007; entire bill S. 1556 - Tax Equity for Domestic Partner and Health Plan Beneficiaries Act; entire bill S. 1593 - Defenders of Freedom Tax Relief Act; provisions relating to retirement savings S. 1726 The Business Activity Tax Simplification Act; entire bill S. 2126 - Generating Retirement Ownership Through Long-Term Holding (GROWTH) Act of 2007; entire bill S. 2242 - Heartland, Habitat, Harvest, and Horticulture Act of 2007; tax title P.L. 110-185 Recovery Rebates and Economic Stimulus for the American People Act of 2008

Client expense: $206,002 · Firm income: Not reported

Private Equity Taxation Active Financing Legislation (HR 1509; S940) Consolidated Tax Returns Business Activity Tax Technical Corrections to Pension Protection Act Partnership Taxation Taxation of Financial Products Securities Cost Basis Reporting Tax Information Reporting (S.636) Energy Tax Legislation Issues Related to Tax-Exempt Bonds Issues Related to Pensions & Deferred Compensation Controlled Foreign Corporation Look Through Treatment (S. 1273, HR 3735) Issues Related to Net Operating Losses Issues Related to Housing Legislation

Client expense: $600,000 · 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, 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)

S. 2242/HR 2419 (Settlement and deductibility) (Denial of deduction for certain settlement payments); HR 3996/HR3970/HR 6/HR 878/ S. 601 (Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); S. 2242/HR 2419/HR 3970/HR 4351 (Codification of economic substance doctrine); HR 1509; S. 902; permanence of active financing exception under Subpart F; Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043 A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Low rate on dividends of individuals; Business tax reform; Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools; Exchange traded notes/prepaid forwards (Notice 2008-2); Taxation of credit default swaps; taxation of notional principal contracts; Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration's project on tax intermediaries; OECD and EU projects on provision of treaty withholding tax relief when investment is made through collective investment vehicles or other intermediate structures; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rule; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Application of FIRPTA to debt exchangeable into REIT shares; Cross-border equity swaps; HR 3996/HR 4351/HR 3970/HR 3920 (Temporary Tax relief Act of 2007) (The AMT Relief Act of 2007) (delay in effective date of worldwide interest allocation election); HR 3996/S. 636/HR 3970/HR 6 (delay in filing deadline for 1099 statements; HR 4912 (Tax treatment of prepaid derivatives contracts) (prepaid derivative contracts and exchange traded notes); Basis Reporting; Active Financing Exception; Extension of capital gains and dividend rates; HR 2091/S. 1963 (Federal home loan bank bonds to tax exempt)

Private Equity Taxation Active Financing Legislation (HR 1509; S940) Consolidated Tax Returns Business Activity Tax (HR1956; S2721) Technical Corrections to HR4 (Pension Protection Act) Recognition of Gain under Section 355 (e) (HR 4187) Partnership Taxation Taxation of Financial Products Securities Cost Basis Reporting Tax Information Reporting (S.636) Energy Tax Legislation (HR. 6) Issues Related to Tax-Exempt Bonds Issues Related to Pensions & Deferred Compensation Controlled Foreign Corporation Look Through Treatment (S. 1273, HR 3735)

Client expense: $1,140,000 · Firm income: Not reported

H.R. 2014 Leasehold Improvement Depreciation Act of 2007 H.R. 2834, To amend the Internal Revenue Code of 1986 to treat income received by partners for performing investment management services as ordinary income received for the performance of services. S. 636, Reduce Wasteful Tax Forms Act of 2007, Basis Reporting US Tax Treaties H.R. 1147, REIT Investment Diversification and Empowerment Act S. 2002, REIT Investment Diversification and Empowerment Act

Client expense: $840,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

Consolidated Tax Returns Business Activity Tax (HR1956; S2721) Technical Corrections to HR4 (Pension Protection Act) Recognition of Gain under Section 355 (e) (HR 4187) Partnership Taxation Taxation of Financial Products Securities Cost Basis Reporting Tax Information Reporting (S.636) Mutual Fund Capital Gain Relief Expiring provisions of Bush Administration Savings Proposal Private Equity Taxation Active Financing Legislation (HR 1509; S940)

Client expense: $1,220,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Reserve System, 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)

Basis reporting by brokers; Issuer reporting of tax consequences of corporate actions under IRC sections 6043(c) and 6043A; S. 636 relating to change in due date for providing payee statements to investors; De minimis exception to requirement to provide 1099 to investors; Subpart F exemption for active financing income; Codification of economic substance doctrine and associated penalty proposals; Low rate on dividends of individuals; Foreign tax credit rules (including proposed “technical taxpayer” rule, noncompulsory payment rules, and treatment of UK manufactured overseas dividends tax); Allocation of income and deductions from global securities dealing operations; OECD project on attribution of profits to permanent establishments; Withholding tax consequences of self tenders and other distributions analyzed under IRC section 302; OECD Forum on Tax Administration’s project on tax intermediaries; OECD project on provision of treaty withholding tax relief when investment is made through collective investment vehicles ; Arbitration provisions in OECD Model Tax Convention, U.S. bilateral tax treaties, U.S. Model Treaty; International reform generally, including importance of interest expense allocation rules; IRS Form W-8 and instructions; Currency gains and losses of qualified business units under IRC section 987; Valuation safe harbor under IRC section 475 mark-to-market requirements; Application of FIRPTA to debt exchangeable into REIT shares; IRS Notice 2006-97 concerning excess inclusion income of REIT taxable mortgage pools HR 2; HR 1591; HR 2206, Tax treatment of contingent convertible debt; Denial of deduction for certain settlement payments; limitation on nonqualified deferred compensation plans; expansion of definition of covered employee under IRC section 162 (m); Discussion draft released by Senate Finance Committee (adjusted basis reporting requirements for brokers); Codification of economic substance doctrine; HR 1509; S 902; permanence of active financing exception under Subpart F;