Stop Tax Haven Abuse Act

Legislation involving the patenting of business method patents (in particular those covering tax strategies) including HR 2365, HR 1908, HR 2136, S 2365, S681 and S1145

Client expense: $645,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. 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. H.R. 2785 To amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services. H.R. 3501 To amend the Internal Revenue Code of 1986 to provide that indebtedness incurred by a partnership in acquiring securities and commodities is not treated as acquisition indebtedness by organizations which are limited partners for purposes of the unrelated business income tax. H.R. 3923 To amend the Internal Revenue Code of 1986 to provide for the treatment of certain foreign nonqualified deferred compensation. H.R. 3996 To amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes. H.R. 3970 To amend the Internal Revenue Code of 1986 to provide additional tax relief to low and moderate income individuals, to repeal the individual alternative minimum tax, to reform the corporate income tax, and for other purposes. S. 55 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax S. 681 Stop Tax Haven Abuse Act S. 1624 To amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services S. 2199 To amend the Internal Revenue Code of 1986 to provide for the treatment of certain foreign nonqualified deferred compensation. S. 2293 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax, and for other purposes. S. 2318 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax and to permanently extend the reductions in income tax rates, and for other purposes. Section 409A of the Internal Revenue Code H.R. 6049, the Renewable Energy and Job Creation Act of 2008 H.R.6275 Alternative Minimum Tax Relief Act of 2008

Client expense: $520,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 2776; Corporate Tax Reform H.R. 3970; S. 681 & Tax Shelters H.R. 2136 R&D Credits; S. 41/H.R. 2138 Railroads Investment Tax Credit H.R. 3117 Energy Efficiency Tax Credits, Biomaterials Tax Credits and Biofuels Tax Credits

Client expense: $1,059,886 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Bureau of Engraving & Printing, Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 5840 - Insurance Information Act of 2008 - All provisions; S 40/H.R. 3200 - National Insurance Act - All provisions HR 5792 - Increasing Insurance Coverage Options for Consumers Act - All provisions; S. 681/HR 1081 - Insurance Industry Competition Act of 2007 - All provisions; Treasury Blueprint for Financial Services Modernization

Client expense: Not reported · Firm income: $21,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

Stop Tax Haven Abuse Act (S 681/HR 2136) - legislation naming Switzerland (among other countries) as a secrecy jurisdiction for tax purposes for certain transactions; Proposals to alter tax treatment of legitimate business transactions undertaken by U.S. subsidiaries of foreign parent corporations, including, HR. 6969 proposals; MADE in the USA Tax Act (S. 3162) - (Title II, Subtitle C, Section 225) sense of the Senate regarding certain reinsurance transactions with foreign related persons; Oversight of the Performance and Effectiveness of National Contracting Act of 2008 (S. 3139) - (Title I, Section 102) prohibition on awarding of government contracts or grants to companies purposefully organized in an offshore secrecy jurisdiction to avoid federal tax obligation; HR 6969 - To amend the Internal Revenue Code of 1986 to alter tax treatment of legitimate business transactions undertaken by U.S. subsidiaries of foreign parent corporations; similar Senate "staff draft" of HR 6969.

Client expense: $790,000 · Firm income: Not reported

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

International taxation: S. 1006; HR 1672; S. 96; S. 681 Taxation on insurance companies; taxation of reinsurance transactions: HR 6969 Tax-deferred catastrophic reserves: Policyholder Disaster Protection Act of 2007 - S. 926, HR 164 Offshore Deferred Compensation Reform Act of 2007 - S. 2199

Client expense: $350,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

HR 1908 (Patent Reform), HR 2136 (Tax Strategy Patents), HR 2365 (Tax Strategy Patents), S 681 (Tax Strategy Patents), S 1145 (Patent Reform), S 2369 (Tax Patents)

Client expense: $1,105,858 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), SENATE

Permanent extension and expansion of research credit; energy & energy efficiency tax benefits, tax on settlement payments; domestic partner tax equity, international taxation; superfund taxes; tax accounting; aviation taxes; manufacturing deduction, economic substance doctrine; environmental tax benefits S 41, Research Competitiveness Act S 1179/HR 1887, Superfund Equity and Megasite Remediation Act S 1273, Look-through tax treatment S 681/HR 2136, Stop Tax Haven Abuse Act (settlement payments) S 1556/HR 1820, Tax Equity for Domestic Partner and Health Plan Beneficiaries Act HR 2138, Invest in America Act (R&D credit) HR 3056, Tax Collection Responsibility Act HR 5719, Taxpayer Assistance and Simplification Act HR 5720, Housing Assistance Tax Act S 2209, R&D credit HR 6049, extenders HR 6899, Comprehensive American Energy Security and Consumer Protection Act HR 7006, Disaster Tax Relief Act HR 6049, Energy Improvement and Extension Act HR 1424, Emergency Economic Stabilization Act S 3098, Expiring tax provisions HR 7060, Renewable Energy and Job Creation Act

Client expense: $1,370,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Environmental Protection Agency (EPA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Surface Transportation Board (STB), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R. 1908-Patent Reform Act of 2007; H.R. 2136-Stop Tax Haven Abuse Act; H.R. 2365-To amend title 35, United States Code, to limit damages and other remedies with respect to patents for tax planning methods; S. 681-Stop Tax Haven Abuse Act; S. 1145-Patent Reform Act of 2007; S. 2369-A bill to amend title 35, United States Code, to provide that certain tax planning inventions are not patentable, and for other purposes

Client expense: $280,000 · Firm income: Not reported

Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), U.S. Immigration & Customs Enforcement (ICE)

H.R. 6- Energy Independence Security Act of 2007; H.R. 878 & S. 601- broker reporting; H.R. 1509 & S. 940- Subpart F; H.R. 2136, H.R. 2345 & S. 681- tax shelters; H.R. 3970- tax reform/corporate tax; H.R. 3996- Temporary Tax Relief Act of 2007; H.R. 4912- prepaid derivatives; H.R. 5351 & S. 1508- energy tax credit extensions; S. 2- minimum wage; S. 349- small business tax issues; S. 2242- alternative energy tax incentives; (no bill #)- regulations re: foreign tax credit & non-compulsory payments; continued . . . H.R. 5160- Small Business Add Value for Employees Act of 2008; H.R. 2167- Automatic IRA Act of 2007; H.R. 3361- Pension Protection Technical Corrections Act of 2007; H.R. 6382- Pension Protection Technical Corrections Act

Client expense: $1,240,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Worked to get Latvia removed from an outdated list of off-shore secrecy jurisdictions which was included in S 681 and S 3139.

Client expense: Not reported · Firm income: $20,000

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of

HR 1712 - Research and Development Tax Credit Act of 2007; research and development tax credit provisions HR 2419 - Food and Energy Security Act of 2007; potential revenue raisers HR 5140 Recovery Rebates and Economic Stimulus for the American People Act of 2008; potential revenue raisers HR 6049 Energy and Tax Extenders Act of 2008; research and development credit H. Res. 1212 A bill providing for consideration of the bill (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; research and development credit S 681 - Stop Tax Haven Abuse Act; sale-in/lease-out tax provisions S 1799 - A bill to amend the Internal Revenue Code of 1986 to apply rate parity to the excise tax on small cigars and small cigarettes, and for other purposes; all provisions S 2547 Fair and Simple Tax Act of 2008 a bill to amend the Internal Revenue Code of 1986 to reduce taxes; capital gains and dividends provisions S 3125 - Energy Independence and Tax Relief Act of 2008; research and development credit

Client expense: $3,940,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 1712 - Research and Development Tax Credit Act of 2007; research and development tax credit provisions HR 2419 - Food and Energy Security Act of 2007; disaster assistance & agriculture tax provisions; sale-in/lease-out tax provisions, fines and penalties provisions, codification of economic substance doctrine provisions HR 2138 - Investment in America Act of 2007; research and development tax credit provisions S 681 - Stop Tax Haven Abuse Act; sale-in/lease-out tax provisions S 2419 - Working Families Flexibility Act; revenue raiser provisions HR 5140 Recovery Rebates and Economic Stimulus for the American People Act of 2008; potential revenue raisers S 2547 Fair and Simple Tax Act of 2008 a bill to amend the Internal Revenue Code of 1986 to reduce taxes; capital gain & dividends provisions S 1799 - A bill to amend the Internal Revenue Code of 1986 to apply rate parity to the excise tax on small cigars and small cigarettes, and for other purposes; federal excise tax provisions HR 5351 Renewable Energy & Energy Conservation Tax Act of 2008; potential revenue raisers

Client expense: $3,100,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS)

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) S. 396, S. 681 and H.R. 2136 (discriminate against low-tax jurisdictions)

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) S. 396, S. 681 and H.R. 2136 (discriminate against low-tax jurisdictions)

Client expense: $7,500 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of

1) For global tax competition and against global tax harmonization. 2) Against IRS regulation on reporting deposit interest paid to nonresident aliens (REG-133254-02). 3) Tax reform. Domestic and International. For a Territorial Tax System. No specific legislation. 4) S. 396, S. 681 and H.R. 2136 (discriminate against low-tax jurisdictions)

Client expense: $7,500 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of

Legislation involving the patenting of business method patents (in particular those covering tax strategies) including HR 2365, HR 1908, HR 2136, S 2365, S681 and S1145

Client expense: $630,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 1908-Patent Reform Act of 2007; H.R. 2136-Stop Tax Haven Abuse Act; H.R. 2365-To amend title 35, United States Code, to limit damages and other remedies with respect to patents for tax planning methods; S. 681-Stop Tax Haven Abuse Act; S. 1145-Patent Reform Act of 2007; S. 2369-A bill to amend title 35, United States Code, to provide that certain tax planning inventions are not patentable, and for other purposes

Client expense: $340,000 · Firm income: Not reported

Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), U.S. Immigration & Customs Enforcement (ICE)

Stop Tax Haven Abuse Act (S 681/HR 2136) - legislation naming Switzerland (among other countries) as a secrecy jurisdiction for tax purposes for certain transactions; Proposals to alter tax treatment of legitimate business transactions undertaken by U.S. subsidiaries of foreign parent corporations. MADE in the USA Tax Act (S. 3162) - (Title II, Subtitle C, Section 225) sense of the Senate regarding certain reinsurance transactions with foreign related persons; Oversight of the Performance and Effectiveness of National Contracting Act of 2008 (S. 3139) - (Title I, Section 102) prohibition on awarding of government contracts or grants to companies purposefully organized in an offshore secrecy jurisdiction to avoid federal tax obligation; HR 6969 - To amend the Internal Revenue Code of 1986 to disallow the deduction for excess non-taxed reinsurance premiums with respect to United States risks paid to affiliates.

Client expense: $270,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. 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. H.R. 2785 To amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services. H.R. 3501 To amend the Internal Revenue Code of 1986 to provide that indebtedness incurred by a partnership in acquiring securities and commodities is not treated as acquisition indebtedness by organizations which are limited partners for purposes of the unrelated business income tax. H.R. 3923 To amend the Internal Revenue Code of 1986 to provide for the treatment of certain foreign nonqualified deferred compensation. H.R. 3996 To amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes. H.R. 3970 To amend the Internal Revenue Code of 1986 to provide additional tax relief to low and moderate income individuals, to repeal the individual alternative minimum tax, to reform the corporate income tax, and for other purposes. S. 55 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax S. 681 Stop Tax Haven Abuse Act S. 1624 To amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services S. 2199 To amend the Internal Revenue Code of 1986 to provide for the treatment of certain foreign nonqualified deferred compensation. S. 2293 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax, and for other purposes. S. 2318 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax and to permanently extend the reductions in income tax rates, and for other purposes. Section 409A of the Internal Revenue Code H.R. 6049, the Renewable Energy and Job Creation Act of 2008 H.R.6275 Alternative Minimum Tax Relief Act of 2008

Client expense: $680,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

HR 1908 (Patent Reform), HR 2136 (Tax Strategy Patents), HR 2365 (Tax Strategy Patents), S 681 (Tax Strategy Patents), S 1145 (Patent Reform), S 2369 (Tax Patents)

Client expense: $1,288,791 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), SENATE

HR 1424 - Emergency Economic Stabilization Act; research and development tax credit provisions HR 1712 - Research and Development Tax Credit Act of 2007; research and development tax credit provisions HR 2419 - Food, Conservation and Energy Security Act of 2007; potential revenue raisers HR 5351 - Renewable Energy and Energy Conservation; potential revenue raisers HR 6049 - Energy and Tax Extenders Act of 2008; research and development credit HR 7060 - The Renewable Energy and Job Creation Act of 2008; research and development tax credit provisions H. Res. 1212 - A bill providing for consideration of the bill (HR 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; research and development credit S 681 - Stop Tax Haven Abuse Act; sale-in/lease-out tax provisions S 3125 - Energy Independence and Tax Relief Act of 2008; research and development credit

Client expense: $3,660,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

International taxation: S. 1006; HR 1672; S. 96; S. 681 Taxation on insurance companies; taxation of reinsurance transactions: HR 6969 Tax-deferred catastrophic reserves: Policyholder Disaster Protection Act of 2007 - S. 926, HR 164 Offshore Deferred Compensation Reform Act of 2007 - S. 2199

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

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R. 2776; Corporate Tax Reform H.R. 3970; S. 681 & Tax Shelters H.R. 2136 R&D Credits; S. 41/ H.R. 2138 Railroads Investment Tax Credit H.R. 3117 Energy Efficiency Tax Credits, Biomaterials Tax Credits and Biofuels Tax Credits

Client expense: $1,059,886 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Bureau of Engraving & Printing, Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)

Permanent extension and expansion of research credit; energy & energy efficiency tax benefits, tax on settlement payments; domestic partner tax equity, international taxation; superfund taxes; tax accounting; aviation taxes; manufacturing deduction, economic substance doctrine; environmental tax benefits S 41, Research Competitiveness Act S 1300, Aviation Investment and Modernization Act S 1179/HR 1887, Superfund Equity and Megasite Remediation Act S 1273, Look-through tax treatment S 681/HR 2136, Stop Tax Haven Abuse Act (settlement payments) S 1556/HR 1820, Tax Equity for Domestic Partner and Health Plan Beneficiaries Act HR 2138, Invest in America Act (R&D credit) HR 2776, Renewable Energy and Energy Conservation Tax Act HR 3056, Tax Collection Responsibility Act S 2242, Farm Bill (tax title) HR 5351, Renewable Energy and Energy Conservation Act HR 5719, Taxpayer Assistance and Simplification Act HR 5720 Housing Assistance Tax Act HR 3221, Foreclosure Prevent Act HR 2881, Aviation Investment and Modernization Act S 2209, R&D credit HR 6049, extenders HR 6081, Heroes Earnings Assistance and Relief Tax Act S 3335, Jobs, Energy, Families, and Disaster Relief Act HR 6899, Comprehensive American Energy Security and Consumer Protection Act HR 7006, Disaster Tax Relief Act HR 6049, Energy Improvement and Extension Act HR 1424, Emergency Economic Stabilization Act S 3098, expiring tax provisions HR 6124, Farm Bill tax title HR 7060, Renewable Energy and Job Creation Act

Client expense: $1,980,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Surface Transportation Board (STB), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

H.R. 5840 - Insurance Information Act of 2008 - All provisions; S 40/H.R. 3200 - National Insurance Act - All provisions HR 5792 - Increasing Insurance Coverage Options for Consumers Act - All provisions; S. 681/HR 1081 - Insurance Industry Competition Act of 2007 - All provisions; Treasury Blueprint for Financial Services Modernization

Client expense: Not reported · Firm income: $19,000

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

All issues relating to S. 681 - Stop Tax Haven Abuse Act

Client expense: Not reported · Firm income: Not reported

Government targets: Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

Tax Treatment of Trust Beneficiaries S. 681 Stop Tax Haven Abuse Act

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 6- Energy Independence Security Act of 2007; H.R. 878 & S. 601- broker reporting; H.R. 1509 & S. 940- Subpart F; H.R. 2136, H.R. 2345 & S. 681- tax shelters; H.R. 3970- tax reform/corporate tax; H.R. 3996- Temporary Tax Relief Act of 2007; H.R. 4912- prepaid derivatives; H.R. 5351 & S. 1508- energy tax credit extensions; S. 2- minimum wage; S. 349- small business tax issues; S. 2242- alternative energy tax incentives; (no bill #)- regulations re: foreign tax credit & non-compulsory payments; continued . . . H.R. 5160- Small Business Add Value for Employees Act of 2008; H.R. 2167- Automatic IRA Act of 2007; H.R. 3361- Pension Protection Technical Corrections Act of 2007; H.R. 6382- Pension Protection Technical Corrections Act

Client expense: $1,240,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Worked to get Latvia removed from an outdated list of off-shore secrecy jurisdictions which was included in S 681 and S 3139.

Client expense: Not reported · Firm income: $30,000

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of

Stop Tax Haven Abuse Act (S 681/HR 2136) - legislation naming Switzerland (among other countries) as a secrecy jurisdiction for tax purposes for certain transactions; Proposals to alter tax treatment of legitimate business transactions undertaken by U.S. subsidiaries of foreign parent corporations. MADE in the USA Tax Act (S. 3162) - (Title II, Subtitle C, Section 225) sense of the Senate regarding certain reinsurance transactions with foreign related persons; Oversight of the Performance and Effectiveness of National Contracting Act of 2008 (S. 3139) - (Title I, Section 102) prohibition on awarding of government contracts or grants to companies purposefully organized in an offshore secrecy jurisdiction to avoid federal tax obligation;

Client expense: $860,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of

Legislation involving the patenting of business method patents (in particular those covering tax strategies) including HR 2365, HR 1908, HR 2136, S 2365, S681 and S1145

Client expense: $625,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Meetings and calls with Members and staff of House and Senate Committees and agency officials concerning possible legislation and regulatory measures and Congressional studies affecting hedge funds and other alternative investments. 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. H.R. 2785 To amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services. H.R. 3501 To amend the Internal Revenue Code of 1986 to provide that indebtedness incurred by a partnership in acquiring securities and commodities is not treated as acquisition indebtedness by organizations which are limited partners for purposes of the unrelated business income tax. H.R. 3923 To amend the Internal Revenue Code of 1986 to provide for the treatment of certain foreign nonqualified deferred compensation. H.R. 3996 To amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes. H.R. 3970 To amend the Internal Revenue Code of 1986 to provide additional tax relief to low and moderate income individuals, to repeal the individual alternative minimum tax, to reform the corporate income tax, and for other purposes. S. 55 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax S. 681 Stop Tax Haven Abuse Act S. 1624 To amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services S. 2199 To amend the Internal Revenue Code of 1986 to provide for the treatment of certain foreign nonqualified deferred compensation. S. 2293 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax, and for other purposes. S. 2318 To amend the Internal Revenue Code of 1986 to repeal the individual alternative minimum tax and to permanently extend the reductions in income tax rates, and for other purposes. Section 409A of the Internal Revenue Code H.R. 6049, the Energy and Tax Extenders Act of 2008 H.R.6275 Alternative Minimum Tax Relief Act of 2008

Client expense: $600,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Legislation involving the patenting of business method patents (in particular those covering tax strategies) including HR 2365, HR 1908, HR 2136, S 2365, S681 and S1145

Client expense: $625,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

All issues relating to S. 681 - Stop Tax Haven Abuse Act

Client expense: Not reported · Firm income: Not reported

Government targets: Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

Legislation involving the patenting of business method patents (in particular those covering tax strategies) including HR 2365, HR 1908, HR 2136, S 2365, S681 and S1145

Client expense: $525,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

HR 1908 (Patent Reform), HR 2136 (Tax Strategy Patents), HR 2365 (Tax Strategy Patents), S 681 (Tax Strategy Patents), S 1145 (Patent Reform), S 2369 (Tax Patents)

Client expense: $1,085,550 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), SENATE

HR 878/S 601 - Simplification through additional Reporting Act; HR 2834 - To amend the IRS Code of 1986 to treat income received by partners for performing investment management services as ordinary income received for the performance of services; HR 2136/S 681 - Stop Tax Haven Abuse Act; Carried interest; Education and college savings tax issues HR 2419 - Farm, Nutrition, and Bioenergy Act of 2007 S 1624 - A bill to amend the Internal Revenue Code of 1986 to provide that the exception from the treatment of publicly traded partnerships as corporations for partnerships with passive-type income shall not apply to partnerships directly or indirectly deriving income from providing investment adviser and related asset management services. Tax treatmentof 529 college savings plans. HR 3970 - Tax Reduction and Reform Act HR 3996 - Tax Increase Prevention Act of 2007 HR 5140 - Recovery Rebates and Economic Stimulus for the American People Act of 2008 HR 3221 - New Direction for Energy Independence, National Security and Consumer Protection Act HR 1820/S 1556 - Tax Equity for Domestic Partner & Health Plan Beneficiaries Act S 2797 - Senior Protection Act of 2008 HR 5720 - Housing Assistance Tax Act S 2866 - Deferred Compensation bill HR 6081 - The Heroes Earnings Assistance and Relief Tax Act of 2008

Client expense: $230,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Education, Dept of, Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office

International taxation: Pay-for provision added to 2007 Farm Bill (HR 2419) that would deny certain tax treaty benefits to subsidiaries of foreign companies: HR 3160; S. 1006; HR 1672; S. 96; S. 681 Taxation on insurance companies; taxation of reinsurance transactions Tax-deferred catastrophic reserves: Policyholder Disaster Protection Act of 2007 - S. 926, HR 164

Client expense: $400,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Stop Tax Haven Abuse Act (S 681/HR 2136) - legislation naming Switzerland (among other countries) as a secrecy jurisdiction for tax purposes for certain transactions; Proposals to alter tax treatment of legitimate business transactions undertaken by U.S. subsidiaries of foreign parent corporations. MADE in the USA Tax Act (S. 3162) - (Title II, Subtitle C, Section 225) sense of the Senate regarding certain reinsurance transactions with foreign related persons; Oversight of the Performance and Effectiveness of National Contracting Act of 2008 (S. 3139) - (Title I, Section 102) prohibition on awarding of government contracts or grants to companies purposefully organized in an offshore secrecy jurisdiction to avoid federal tax obligation;

Client expense: $860,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of

Tax Treatment of Trust Beneficiaries S. 681 Stop Tax Haven Abuse Act

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2136/S.681 "Stop Tax Haven Abuse Act"; HR 4318 "To amend the IRS Code of 1986 to modify the penalty on the understatement of taxpayer's liability by tax return preparers"; S. 349 "Small Business & Work Opportunity Tax Act of 2007"; S. 2369 "To provide that certain tax planning inventions are not patentable, and for other purposes"; S. 2851 "To modify the penalty on the understatement of taxpayer's liability by tax preparers"

Client expense: $617,400 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Permanent extension and expansion of research credit; energy & energy efficiency tax benefits; tax on settlement payments; domestic partner tax equity, international taxation; superfund taxes; tax accounting; aviation taxes; manufacturing deduction, economic substance doctrine; environmental tax benefits S 41, Research Competitiveness Act S 1300, Avaiation Investment and Modernization Act S 1179/HR 1887, Superfund Equity and Megasite Remediation Act S 1273, Look-through tax treatment S 681/HR 2136, Stop Tax Haven Abuse Act (settlement payments) S 1556/HR 1820, Tax Equity for Domestic Partner and Health Plan Beneficiaries Act HR 2138, Invest in America Act (R&D credit) HR 2776, Renewable Energy and Energy Conservation Tax Act HR 3056, Tax Collection Responsibility Act S 2242, Farm Bill (tax title) HR 5351, Renewable Energy and Energy Conservation Act HR 5719, Taxpayer Assistance and Simplification Act HR 5720, Housing Assistance Tax Act HR 3221, Foreclosure Prevention Act HR 2419, Food and Energy Security Act HR 3996, Tax Increase Prevention Act HR 2881, Aviation Investment and Modernization Act S 2209, R&D credit HR 6049, extenders HR 6081, Heroes Earnings Assistance and Relief Tax Act

Client expense: $790,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Railroad Administration, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Surface Transportation Board (STB), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

HR 1712 - Research and Development Tax Credit Act of 2007; research and development tax credit provisions HR 2419 - Food and Energy Security Act of 2007; potential revenue raisers HR 5140 Recovery Rebates and Economic Stimulus for the American People Act of 2008; potential revenue raisers HR 6049 Energy and Tax Extenders Act of 2008; research and development credit H. Res. 1212 A bill providing for consideration of the bill (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; research and development credit S 681 - Stop Tax Haven Abuse Act; sale-in/lease-out tax provisions S 1799 - A bill to amend the Internal Revenue Code of 1986 to apply rate parity to the excise tax on small cigars and small cigarettes, and for other purposes; all provisions S 2547 Fair and Simple Tax Act of 2008 a bill to amend the Internal Revenue Code of 1986 to reduce taxes; capital gains and dividends provisions S 3125 - Energy Independence and Tax Relief Act of 2008; research and development credit

Client expense: $3,930,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE