A bill to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income.
Legislative Progress
Momentum (last 30 days)
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vs 3,722 other S bills in the 110th — cohort avg 42d
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2009 · first_quarter · Taxation/Internal Revenue Code
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
S. 940 - To amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption for active financing purposes; S. 2666 - Affordable Housing Investment Act of 2008; HR 3359 - Mobile Workforce State Income Tax Fairness and Simplification Act of 2007; HR 3996 - Temporary Tax Relief Act of 2007; HR 3970 - Tax Reduction and Reform Act of 2007; HR 1509 - Permanent Sub-part F Exemption for Active Financing Income; HR 5720 - Housing Assistance Tax Act; HR 5719 - The Taxpayer Assistance and Simplification Act of 2008;
Client expense: Not reported · Firm income: $45,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
S. 601, the Simplification Through Additional Reporting Tax Act of 2007 S. 777, to repeal the imposition of withholding on certain payments made to vendors by government entities. S. 819, the Public Good IRA Rollover Act of 2007 - Amends the Internal Revenue Code to exclude from gross income distributions from individual retirement accounts for certain charitable purposes. S. 940, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (all provisions) 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. (all provisions) S. 1726, the Business Activity Tax Simplification Act (all provisions) S. 2394, the Good Government Contractor Act of 2007 (provision to repeal withholding requirement) S. 3063, the S Corporation Modernization Act S. 3254, the Small Bank Tax Equity Act S. 3335, the Jobs, Energy, Families, and Disaster Relief Act of 2008 (provisions to extend business-related tax provisions) H.R. 6, the Renewable Fuels, Consumer Protection, and Energy Efficiency Act of 2007 (S.Amdt. 1704, tax title provisions) H.R. 976, the Small Business Tax Relief Act of 2007 (all provisions) H.R. 1419, the Public Good IRA Rollover Act or 2007 - Amends the Internal Revenue Code to exclude from gross income distributions from individual retirement accounts for certain charitable purposes. H.R. 1424, the Emergency Economic Stabilization Act H.R. 1509, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (all provisions) H.R. 1677, the Taxpayer Protection Act of 2007 (refund anticipation loan provisions) H.R. 1023, to repeal the impositions of withholding on certain payments made to vendors by government entities. H.R. 2370, to amend the Internal Revenue Code of 1986 to provide for the establishment of financial security accounts for the care of family members with disabilities. 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. 3056, the Tax Collection Responsibility Act of 2007 (all provisions) H.R. 3221, the American Housing Rescue and Foreclosure Prevention Act H.R. 3648, the Mortgage Forgiveness Debt Relief Act of 2007 (all provisions) H.R. 3678, the Internet Tax Freedom Act Amendments Act of 2007 (all provisions) H.R. 3970, the Tax Reduction and Reform Act of 2007 (revenue offset provisions, including economic substance doctrine, cost basis reporting, and deferred compensation taxation) H.R. 3996, the Tax Increase Prevention Act of 2007 (mortgage debt forgiveness, revenue offset tax provisions) H.R. 3997, the Emergency Economic Stabilization Act H.R. 4351, the AMT Relief Act of 2007 (revenue offsets provisions on the economic substance doctrine, deferred offshore compensation for hedge fund managers, and interest expense allocation rules for multinational firms) H.R. 4840, the S Corporation Modernization Act (all provisions) H.R. 5267, the Business Activity Tax Simplification Act of 2008 (all provisions) H.R. 5720, the Housing Assistance Tax Act of 2008 (all provisions, including bond authority, tax credits, cost-basis reporting requirements, and IRS withholding requirements) H.R. 6049, the Renewable Energy and Job Creation Act of 2008 (tax extension provisions, including research and development tax credit, Subpart F and Section 355 (controlled foreign corporation) rules, new markets tax credit; revenue offsets including effective date of new interest expense allocation, changes to deferred compensation rules for managers of offshore hedge funds) H.R. 6275, the Alternative Minimum Tax Relief Act of 2008 (revenue offset provisions) H.R. 6333, the Municipal Bonds Market Support Act (all provisions) H.R. 6601, the Small Business Tax Modernization Act of 2008 (all provisions) H.R. 7060, the Renewable Energy and Job Creation Tax Act of 2008 (business tax provisions, revenue offsets) Draft Legislation to require Cost-Basis Reporting for Securities Credit Card Information Reporting Codification of the Economic Substance Doctrine Proposals to apply unrelated business income tax (UBIT) to credit unions Proposals on Estate and Gift Tax Reform Proposed Middle Class Job Security Act (corporate tax rate, net operating loss carry-back provisions) Proposed amendment to Section 67(e) tax deductibility of trustee fees
2008 · second_quarter · Taxation/Internal Revenue Code
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 number) - regulations regarding foreign tax credit & continued ... non-compulsory payments; H.R. 5160 - Small Business Adds 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: $920,000 · Firm income: Not reported
2008 · fourth_quarter · Taxation/Internal Revenue Code
HR 1509, Permanent Extension of Subpart F Deferral for Financial Services S 940, Permanent Extension of Subpart F Deferral for Financial Services HR, 2776 The Renewable Energy and Energy Conservation Tax Act of 2007 S 1726 Business Activity Tax Simplification Act of 2007 S 34 Sales Tax Fairness and Simplification Act Class Life for Medical Equipment Codifications of Economic Substance Doctrine Deferred Compensation S 1525, Super Efficient Appliance Incentives and Market Transformation Act of 2007 HR 2137, Super Efficient Appliance Incentives and Market Transformation Act of 2007 HR 3970, Tax Reduction and Reform Act of 2007 HR 3396, Sales Tax Fairness and Simplification Act HR 3359, Mobile Workforce State Income Tax Fairness and Simplication Act of 2007 HR 6, (with regard to Wind, Appliance Tax Credit and Other Energy Tax Measures) IRC Section 45 Production Tax Credit (Wind) HR 5267, Business Activity Tax Simplification Act of 2008 S 2886, Alternative Mimimum Tax and Extenders Tax Relief of 2008 S 3098, Alternative Mimimum Tax and Extenders Tax Relief of 2008 S 3125, Energy Independence and Tax Relief Act of 2008 HR 3452 A bill to amend the Internal Revenue Code of 1986 to allow a credit with respect to clean renewable water supply bonds HR 6049, Energy Improvement and Extension Act of 2008 HR 1424, Emergency Stabilization Act of 2008 S 3162, Made in the USA Act HR 7060 The Renewable Energy and Job Creation Tax Act of 2008 HR 7201, The Energy Improvement and Extension Act of 2008 S 3478, Energy Independence and Investment Act of 2008 S 2821, Clean Energy Tax Stimulus Act of 2008 PTC Economic Viability Water Private Activity Bonds Treatment of loans from subsidiaries
| Republican |
| OR |
| Jim Bunning | Republican | KY |
| John D. Rockefeller, IV | Democratic | WV |
| Mike Crapo | Republican | ID |
| Orrin G. Hatch | Republican | UT |
| Pat Roberts | Republican | KS |
| Trent Lott | Republican | MS |
Client expense: $2,340,000 · Firm income: Not reported
Government targets: Defense, Dept of (DOD), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Social Security Administration (SSA), Treasury, Dept of, White House Office
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
Client expense: $4,260,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Consumer Product Safety Commission (CPSC), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Justice, Dept of (DOJ), Natl Aeronautics & Space Administration (NASA), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA)
2008 · second_quarter · Taxation/Internal Revenue Code
S 940, to permanently extend the subpart F exemption for active financing income HR 1509, to permanently extend the subpart F exemption for active financing income S 1726, Business Activity Tax Simplification Act, regulation of state taxation of interstate commerce Social Security Administration Consent Based Social Security Number Verification Process FY 2009 Budget Proposal, tax provisions, third-party reporting HR 578, Access to Capital for Entrepreneurs Act of 2007, tax credit for equity investments in small businesses S. 1273, Permanent Extension of CFC Look-thru Rule HR 3735, Five Year Extension of CFC Look-thru Rule HR 5267, Business Activity Tax Simplification Act, regulation of state taxation of interstate commerce HR 3221, the Foreclosure Prevention Act of 2008, proposal to require credit card companies to report to the IRS on reimbursement payments made to merchants HR 6275, the Alternative Minimum Tax Relief Act of 2008, proposal to require credit card companies to report to the IRS reimbursement payments made to merchants H.R. 6049, Renewable Energy and Job Creation Act of 2008, proposal to extend the active financing and look through exceptions from Subpart F S. 3125 Energy Independence and Tax Relief Act of 2008, proposal to extend the active financing and lookthrough exceptions from Subpart F H.R. 3359 Mobile Workforce State Income Tax Fairness and Simplification Act of 2007, issues involving non resident withholding S 3098 Alternative Minimum Tax and Extender Relief Act of 2008, proposal to extend the active financing and lookthrough exceptions from Subpart F
Client expense: $1,070,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Social Security Administration (SSA), Treasury, Dept of, U.S. Postal Service (USPS)
2008 · first_quarter · Taxation/Internal Revenue Code
HR 5267 "Business Activity Tax Simplification Act" - Legislation would create a physical presence standard under which a state may tax the income of business; S 940, HR 1509 - extend the active finance exception to Subpart F of the Internal Revenue Code, which requires current taxation of income earned overseas; HR 1677 "Taxpayer Protection Act" - educate Members and staff on the impact of restrictions on regulated, short-term loan products; Discuss deferred compensation.
Client expense: $1,430,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Federal Highway Administration (FHA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
S.940; HR.1509; S.349; HR.6; HR. 2776; renewable energy tax incentives for wind, solar and smart grid; IRC sections 45 and 48; S.6049; S.3098; S.3125; S.3335; HR.7060; HR.7202; HR.1424; S.1370 (sections 4 and 5); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; issues relating to inclusion of arbitration provisions in tax treaties; H.R.4912; tax treatment of exchange traded notes; Deferred compensation; HR. 6049; S.3098; S. 3125; economic stabilization provisions; H.R. 3997; H.R. 1424; tax treatment of REMICS and REITs.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
IRC Subpart F; HR.1509; S.940; HR.6049; S. 3098; S. 3125; S.3335; HR.7060; HR.7202; HR.1424; IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; IRS Notice 2007-58; sourcing rule under tax treaties; IRC section 956 (rules on investment in US property).
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
Extension and expansion of alternative simplified research and development tax credit; HR 2138; S. 41; HR.3996; S.2209; HR. 6049; S.3098; S.3125; S.3335; HR.7060; HR.7202; HR.1424; Subpart F issues, including look-through treatment for controlled foreign corporations and treatment of manufacturing under IRC section 954 and related regulations; IRS REG-124590-07; HR.1509; S.940; S.349 (section 206); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; international tax reform issues; IRS Notice 2007-58; HR.3735; S.1273; HR.6.
Client expense: Not reported · Firm income: $50,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
HR 1509, Permanent Extension of Subpart F Deferral for Financial Services S 940, Permanent Extension of Subpart F Deferral for Financial Services HR, 2776 The Renewable Energy and Energy Conservation Tax Act of 2007 S 1726 Business Activity Tax Simplification Act of 2007 S 34 Sales Tax Fairness and Simplification Act Class Life for Medical Equipment Codifications of Economic Substance Doctrine Deferred Compensation S 1525, Super Efficient Appliance Incentives and Market Transformation Act of 2007 HR 2137, Super Efficient Appliance Incentives and Market Transformation Act of 2007 HR 3970, Tax Reduction and Reform Act of 2007 HR 3396, Sales Tax Fairness and Simplification Act HR 3359, Mobile Workforce State Income Tax Fairness and Simplication Act of 2007 HR 6, (with regard to Wind, Appliance Tax Credit and Other Energy Tax Measures) IRC Section 45 Production Tax Credit (Wind) HR 5267, Business Activity Tax Simplification Act of 2008 S 2886, Alternative Mimimum Tax and Extenders Tax Relief of 2008 S 3098, Alternative Mimimum Tax and Extenders Tax Relief of 2008 S 3125, Energy Independence and Tax Relief Act of 2008 HR 3452 A bill to amend the Internal Revenue Code of 1986 to allow a credit with respect to clean renewable water supply bonds HR 6049, Energy Improvement and Extension Act of 2008 HR 1424, Emergency Stabilization Act of 2008 S 3162, Made in the USA Act HR 7060 The Renewable Energy and Job Creation Tax Act of 2008 HR 7201, The Energy Improvement and Extension Act of 2008 S 3478, Energy Independence and Investment Act of 2008 S 2821, Clean Energy Tax Stimulus Act of 2008 PTC Economic Viability Water Private Activity Bonds Treatment of loans from subsidiaries
Client expense: $4,260,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Consumer Product Safety Commission (CPSC), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Justice, Dept of (DOJ), Natl Aeronautics & Space Administration (NASA), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA)
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 1509, A bill to amend the Internal Revenue Code of 1986 to permanently extend the Sub-part F exemption for active financing income, All provisions H.R. 4195, Tax Technical Corrections Act of 2007, All provisions H.R. 5720, Housing Assistance Tax Act, All provisions H.R. 5719, The Taxpayer Assistance and Simplification Act of 2008, All provisions H.R. 6049, The Renewable Energy and Job Creation Act, Extender provisions H.R. 6110, Roadmap for Americas Future Act of 2008, Corporate and international provisions S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption for active financing purposes, All provisions H.R. 3963, Childrens Health Insurance Program Reauthorization, All provisions H.R. 3996, Temporary Tax Relief Act of 2007, All provisions S. 2666, Affordable Housing Investment Act of 2008, All provisions H.R. 5140 [No Senate Number Available], Economic Stimulus Act of 2008, All provisions S. 3125, Energy Independence and Tax Relief Act, All provisions H.R. 1424, Emergency Economic Stabilization Act of 2008 - Tax Extenders and Alternative Minimum Tax Relief Act of 2008, All Provisions H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007, All provisions H.R. 6275, Alternative Minimum Tax Relief Act of 2008, All provisions H.R. 3221, Foreclosure Prevention Act of 2008, All provisions S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008 , All provisions H.R. 7060, Renewable Energy and Job Creation Act of 2008, All provisions
Client expense: $1,710,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)
2008 · fourth_quarter · Taxation/Internal Revenue Code
Significant Tax Issues: Subpart f/BAT/SILO, S. 940, Subpart f Exemption H.R. 976, the Small Business Tax Relief Act of 2007 H.R. 2834, Carried Interest Income Bill H.R. 2776, the Renewable Energy and Energy Conservation Tax Act of 2007 Accountability Act of 2007, on tax changes on leasing, non-qualified deferred compensation, covered employees, deductibility of certain civil penalties and fines, the Energy Tax Bill (Senate Finance), and tax changes on leasing H.R. Tax Increase Prevention Act of 2007 H.R. 5267, Business Activity Tax Simplification Act H.R. 2365, tax practitioners for infringement of a patent for tax bill H.R. 2, the Fair Minimum Wage Act of 2007 Small Business and Work Opportunity Act of 2007 H.R. 1591, the US Troop Readiness, Veteran's Health, and Iraq;
Client expense: $1,600,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council of Economic Advisers (CEA), Environmental Protection Agency (EPA), Farm Credit Administration, Federal Accounting Standards Advisory Board (FASAB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Natl Economic Council (NEC), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR), White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
S. 601, the Simplification Through Additional Reporting Tax Act of 2007 S. 777, to repeal the imposition of withholding on certain payments made to vendors by government entities. S. 819, the Public Good IRA Rollover Act of 2007 - Amends the Internal Revenue Code to exclude from gross income distributions from individual retirement accounts for certain charitable purposes. S. 940, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (all provisions) 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. (all provisions) S. 1726, the Business Activity Tax Simplification Act (all provisions) S. 2394, the Good Government Contractor Act of 2007 (provision to repeal withholding requirement) S. 3063, the S Corporation Modernization Act S. 3254, the Small Bank Tax Equity Act S. 3335, the Jobs, Energy, Families, and Disaster Relief Act of 2008 (provisions to extend business-related tax provisions) H.R. 6, the Renewable Fuels, Consumer Protection, and Energy Efficiency Act of 2007 (S.Amdt. 1704, tax title provisions) H.R. 976, the Small Business Tax Relief Act of 2007 (all provisions) H.R. 1419, the Public Good IRA Rollover Act or 2007 - Amends the Internal Revenue Code to exclude from gross income distributions from individual retirement accounts for certain charitable purposes. H.R. 1424, the Emergency Economic Stabilization Act H.R. 1509, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (all provisions) H.R. 1677, the Taxpayer Protection Act of 2007 (refund anticipation loan provisions) H.R. 1023, to repeal the impositions of withholding on certain payments made to vendors by government entities. H.R. 2370, to amend the Internal Revenue Code of 1986 to provide for the establishment of financial security accounts for the care of family members with disabilities. 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. 3056, the Tax Collection Responsibility Act of 2007 (all provisions) H.R. 3221, the American Housing Rescue and Foreclosure Prevention Act H.R. 3648, the Mortgage Forgiveness Debt Relief Act of 2007 (all provisions) H.R. 3678, the Internet Tax Freedom Act Amendments Act of 2007 (all provisions) H.R. 3970, the Tax Reduction and Reform Act of 2007 (revenue offset provisions, including economic substance doctrine, cost basis reporting, and deferred compensation taxation) H.R. 3996, the Tax Increase Prevention Act of 2007 (mortgage debt forgiveness, revenue offset tax provisions) H.R. 3997, the Emergency Economic Stabilization Act H.R. 4351, the AMT Relief Act of 2007 (revenue offsets provisions on the economic substance doctrine, deferred offshore compensation for hedge fund managers, and interest expense allocation rules for multinational firms) H.R. 4840, the S Corporation Modernization Act (all provisions) H.R. 5267, the Business Activity Tax Simplification Act of 2008 (all provisions) H.R. 5720, the Housing Assistance Tax Act of 2008 (all provisions, including bond authority, tax credits, cost-basis reporting requirements, and IRS withholding requirements) H.R. 6049, the Renewable Energy and Job Creation Act of 2008 (tax extension provisions, including research and development tax credit, Subpart F and Section 355 (controlled foreign corporation) rules, new markets tax credit; revenue offsets including effective date of new interest expense allocation, changes to deferred compensation rules for managers of offshore hedge funds) H.R. 6275, the Alternative Minimum Tax Relief Act of 2008 (revenue offset provisions) H.R. 6333, the Municipal Bonds Market Support Act (all provisions) H.R. 6601, the Small Business Tax Modernization Act of 2008 (all provisions) H.R. 7060, the Renewable Energy and Job Creation Tax Act of 2008 (business tax provisions, revenue offsets) Draft Legislation to require Cost-Basis Reporting for Securities Credit Card Information Reporting Codification of the Economic Substance Doctrine Proposals to apply unrelated business income tax (UBIT) to credit unions Proposals on Estate and Gift Tax Reform Proposed Middle Class Job Security Act (corporate tax rate, net operating loss carry-back provisions) Proposed amendment to Section 67(e) tax deductibility of trustee fees Proposals to increase net operating loss carryback provisions Proposals to modify or eliminate Internal Revenue Service provisions (Notice 2008-83) affecting loss deductibility in bank mergers
Client expense: $1,930,000 · Firm income: Not reported
Government targets: Defense, Dept of (DOD), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Social Security Administration (SSA), Treasury, Dept of, White House Office
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. 4351, AMT Relief Act of 2007; H.R. 7060, the Renewable Energy & Job Creation Tax Act; S. 3335, Jobs, Energy, Families and Disaster Relief Act; H.R. 3997, Emergency Economic Stabilization Act of 2008; H.R. 1424, Tax Extenders & AMT Relief Act; S. 3098, AMT & Extenders Tax Relief Act of 2008; H.R. 6275, AMT Relief Act; H.R. 6049, the Renewable Energy & Job Creation Act, issues related to revenue offsets including deferred compensation; H.R. 3970, Tax Reduction and Reform Act of 2007; S. 1624, to amend the IRC to provide that the exception from the treatment of PTPs as corporations for partnerships with passive-type income....; H.R. 2834, to amend the IRC to treat income received by partners for performing services as ordinary income received for the performance of services; H.R. 6275, the Alternative Minimum Tax Relief Act; issues related to tax offsets and impact on insurance and financial services; S.940 / H.R. 1509, to make permanent the active financing exception; S. 2886, AMT & Extenders Tax Relief Act; S. 3125, Energy Independence & Tax Relief Act, issues related to extension of the active financing exception and revenue offsets.
Client expense: Not reported · Firm income: $20,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 5267 (Business Activity Tax Simplification Act of 2008); Valuation safe harbor under IRC section 475 mark-to-market requirements; Valuation of CDOs and related securities for purposes of section 475; Taxation of credit default swaps; taxation of national principal contracts; H.R. 3970 (Tax Reduction and Reform Act of 2007)/ H.R. 878 (Simplification Through Additional Reporting Tax Act)/ S. 601(Simplification Through Additional Reporting Tax Act)/ H.R. 5720 (Housing Assistance Tax Act)/ H.R. 3221(Housing and Economic Recovery Act)/ S. 3335 (Tax Relief Extension Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7201 (Energy Improvement and Extension Act)/ H.R.1424 (Emergency Economic Stabilization Act): (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act )/ S. 2886 (Alternative Minimum Tax and Extenders Tax Relief Act)/ S. 3335 (Tax Relief Extension Act)/ S. 940 (To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income)/ S. 3098 (Alternative Minimum Tax and Extenders Tax Relief Act)/ H.R. 7060 (Renewable Energy and Job Creation Tax Act)/ H.R. 7202 (Temporary Tax Relief Act)/ H.R. 1424 (Emergency Economic Stabilization Act): (active financing exception under Subpart F); Tax treatment of derivatives generally; Tax patent reporting; Foreign tax credit rules (including proposed "technical taxpayer" rule, noncompulsory payment rules); 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; Cross-border equity swaps; H.R. 4912 (Tax treatment of prepaid derivatives contracts); 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); H.R. 6333 (Municipal Bond Market Support Act)/ S. 3518 (Municipal Bond Market Support Act):(municipal bond tax provisions); H.R. 1424 (Emergency Economic Stabilization Act)/ H.R. 6049 (Energy and Tax Extenders Act)/ S. 3125 (Energy Independence and Tax Relief Act)/ S. 3335 (Tax Relief Extension Act): (executive compensation tax provisions); H.R. 1424 (Emergency Economic Stabilization Act) (tax-related regulatory issues relating to EESA programs); Economic Stimulus legislation (carryback of net operating losses; tax-exempt bond provisions; REMICs, modifications of energy tax credits).
Client expense: $1,320,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Education, Dept of, Executive Office of the President (EOP), 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
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 1509 and S. 940, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income; H.R. 6049, H.R. 1424
Client expense: Not reported · Firm income: $10,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
HR 6049 "Energy and Tax Extenders Act" HR 6275 "Alternative Minimum Tax Relief Act" S 3125 "Energy Independence and Tax Relief Act" S 3098, S 2886, S 940, HR 1509 - support legislation extending the active finance exception to Subpart F of the Internal Revenue Code, which requires current taxation on income earned overseas.
Client expense: $1,100,000 · Firm income: Not reported
Government targets: Federal Highway Administration (FHA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
HR 2138, Investment in America Act of 2007, Entire Bill S 2209, Research Credit Improvement Act, Entire Bill S 41, Research Competitiveness Act, Entire Bill S 940/ HR 1509, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (Official Title as Introduced), Entire Bill S 2359/ HR 5140, Economic Stimulus Act of 2008, Section 103 related to taxation HR 3221, The American Housing Rescue and Foreclosure Prevention Act of 2008 HR 1424, The Emergency Economic Stabilization Act of 2008, as amended by the Senate, the extenders tax package and plug-in Hybrid credit for consumers Canadian Tax Treaty Protocol, Entire Treaty (Treaty Doc 110-15) Tax incentives for Advanced Technology, Tax Reform, R&D Extension, Manufacturing Deduction
Client expense: $1,925,000 · Firm income: Not reported
Government targets: Energy, Dept of, Environmental Protection Agency (EPA), Export-Import Bank of the United States (EXIM Bank), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Transportation, Dept of (DOT), Treasury, Dept of, White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
Active financial services income (H.R. 1509, S. 940), nonqualified deferred compensation
Client expense: Not reported · Firm income: $380,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
R&D tax credit (H.R. 3996, H.R. 2138, S.41), active financial services income (H.R. 1509, S. 940), withholding on government payments to contractors (H.R. 1023, H.R. 3996)
Client expense: Not reported · Firm income: $70,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
S 940, to permanently extend the subpart F exemption for active financing income HR 1509, to permanently extend the subpart F exemption for active financing income S 1726, Business Activity Tax Simplification Act, regulation of state taxation of interstate commerce FY 2009 Budget Proposal, tax provisions, third-party reporting S. 1273, Permanent Extension of CFC Look-thru Rule HR 3735, Five Year Extension of CFC Look-thru Rule HR 5267, Business Activity Tax Simplification Act, regulation of state taxation of interstate commerce HR 3221, the Foreclosure Prevention Act of 2008, proposal to require credit card companies to report to the IRS on reimbursement payments made to merchants HR 6275, the Alternative Minimum Tax Relief Act of 2008, proposal to require credit card companies to report to the IRS reimbursement payments made to merchants H.R. 6049, Renewable Energy and Job Creation Act of 2008, proposal to extend the active financing and look through exceptions from Subpart F S. 3125 Energy Independence and Tax Relief Act of 2008, proposal to extend the active financing and lookthrough exceptions from Subpart F H.R. 3359 Mobile Workforce State Income Tax Fairness and Simplification Act of 2007, issues involving non resident withholding S 3098 Alternative Minimum Tax and Extender Relief Act of 2008, proposal to extend the active financing and lookthrough exceptions from Subpart F H.R. 1424, Emergency Economic Stabilization Act of 2008, proposal to extend active financing and lookthrough H.R. 6049, Energy Improvement and Extension Act of 2008, proposal to extend active financing and lookthrough
Client expense: $1,030,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Postal Service (USPS)
2008 · fourth_quarter · Taxation/Internal Revenue Code
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 Troubled Assets Relief Program
Client expense: $520,000 · 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)
2008 · fourth_quarter · Taxation/Internal Revenue Code
H.R. 197: To Extend the Production Tax Credit (PTC) H.R. 833/S. 286: Rural Communities Investment Act H.R. 976: Small Business Tax Relief Act H.R. 878/S. 601: Simplification Through Additional Reporting Tax Act H.R. 1509/S. 940: To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income H.R. 1591: U.S. Troop Readiness, Veterans' Health, and Iraq Accountability Act of 2007: Title II, Chapter 4: small business depreciation provisions S. 897: Alzheimer's Family Assistance Act S. 504: Long-Term Care Trust Account Act S. 46: Affordability in the Individual Market Act S. 400: Michelle's Law H.R. 2280/S. 1621: To amend the Internal Revenue Code of 1986 to treat certain farming business machinery and equipment as 5-year property for purposes of depreciation S. 1726 Business Activity Tax Simplification Act H.R. 3160: To amend the Internal Revenue Code of 1986 to prevent corporations from exploiting tax treaties to evade taxation of U.S. income S. 2209: Research Credit Improvement Act of 2007 S. 2242: Heartland, Habitat, Harvest, and Horticulture Act of 2007 H.R.3996: Temporary Tax Relief Act of 2007 H.R.4351: Alternative Minimum Tax Relief Act\ H.R.3735/S. 1273: To extend the look-through treatments of payments between related controlled foreign corporations H.R.3234: To improve access to health care through expanded health savings accounts H.R.2138: Investment in America Act of 2007 H.R.2776: Energy & Energy Conservation Tax Act of 2007 H.R.3056: Tax Collection Responsibility Act of 2007 H.R.4994: Middle Class Jobs Protection Act of 2008 H.R.5085: Small Business Expansion Act of 2008 H.R.5351: To amend the IRS Code of 1986 to provide tax incentives for the production of renewable energy and energy conservation H.R.5267: Business Activity Tax Simplification Act H.R.2419: Farm, Nutrition, and Bioenergy Act: Section 12407 of the Senate Amendment; Section 168 of Code H.R.5231: To amend the IRS Code of 1986 to extend the credit for electricity produced from certain renewable resources S.2821: The Clean Energy Tax Stimulus Act of 2008 H.R.3361: Pension Protection Technical Corrections Act S.1945: Patriot Employers Act H.R.5719: Taxpayer Assistance and Simplification Act of 2008 H.R.6049: Energy and Tax Extenders Act of 2008 H.R.5719: U.S.A. Substantiation Act H.R.6275: Alternative Minimum Tax Relief H.R. 1424: Economic Stabalization Act H.R. 3997: Emergency Economic Stabalization Act of 2008; P.L. 110-343 H.R. 7060: Tax Extenders: Subpart F, R&D credit; PTC credit H.R. 6049: Tax Extenders: Subpart F, R&D credit; PTC credit H.R. 6604: Commodity Markets Transparency and Accountability Act of 2008 H.R. 1424: TARP: Extending Expiring Tax Provisions; P.L. 110-343
Client expense: $280,000 · Firm income: Not reported
Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
S. 940/ H.R. 1509, To Amend the Internal Revenue Code of 2986 to Permanently Extend the Subpart F Exemption for Active Financing Income (Entire bill) H.R. 6049, Renewable Energy and Job Creation Act (Sec. 239) S. 2886, Alternative Minimum Tax and Extenders Tax Relief At (Sec. 203) S. 3098, AMT and Extenders Tax Relief Act (Sec. 303) S. 3125, Energy Independence and Tax Relief Act (Sec. 247) H.R. 1424, Emergency Economic Stabilization Act (Sec. 303)
Client expense: $390,000 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · fourth_quarter · Taxation/Internal Revenue Code
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
2008 · fourth_quarter · Taxation/Internal Revenue Code
S. 940 and H.R. 1509, to amend the IRC to permanently extend the subpart F exemption for active financing income; H.R. 3970, Tax Reduction and Reform Act of 2007; H.R. 6049, the Renewable Energy & Job Creation Act; S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act; S. 3125, Energy Independence and Tax Relief Act; H.R. 7060, the Renewable Energy & Job Creation Tax Act; S. 3335, Jobs, Energy, Families and Disaster Relief Act; H.R. 1424, Tax Extenders and AMT Relief Act; S. 3098, AMT & Extenders Act of 2008, issues related to revenue offsets and extension of expired tax incentives.
Client expense: Not reported · Firm income: $75,000
Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE
2008 · fourth_quarter · Taxation/Internal Revenue Code
HR2205 Retirement Security for Life Act of 2007 S1010 Retirement Security for Life Act of 2007 HR1810 To amend the Internal Revenue Code for 1986, to permit the consolidation of Life Insurance Companies with other companies S1366 To amend the Interal Revenue Code of 1986, to permit the consolidation of Life Insurance Companies with other compa nies HR1509 To amend the Interal Revenue Code of 1986, to permanently extend the subpart F exemption for active financing income S940 To amend the Interal Revenue Code of 1986, to permanently extend the subpart F exemption for active financing income
Client expense: $1,070,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Thrift Supervision (OTS), SENATE, Treasury, Dept of
2008 · fourth_quarter · Taxation/Internal Revenue Code
Emergency Economic Stabilization Act of 2008 - Tax Extenders and Alternative Minimum Tax Relief Act of 2008, H.R. 1424; A Bill to Amend the Internal Revenue Code of 1986 to Permanently Extend the Sub-part F Exemption for Active Financial Income, H.R. 1509; Tax Technical Corrections Act of 2007, H.R. 4195; The Taxpayer Assistance and Simplification Act of 2008, H.R. 5719; The Renewable Energy and Job Creation Act - extender provisions; H.R. 6049; Tax Extenders and Alternative Minimum Tax Act of 2008, H.R. 6049; To Amend the Interal Revenue Code of 1986 to Permanently Extend the Subpart F Exemption for Active Financing Purposes, S. 940.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · fourth_quarter · Insurance
HR 25 / S 1025--tax reform legislation; HR 2205 / S 1010--retirement security for life legislation; HR 1509 / S 940--subpart F legislation; HR 1810 / S 1366--life/non-life consolidated return legislation; HR 3200 / S 40--optional federal charter legislation; HR 3185 / HR 3765 / S 2473--401(k) fee disclosure legislation; HR 1098 / S 1145--patent reform legislation; PL 110-343--Emergency Economic Stabilization Act-market rescue and tax extenders legislation.
Client expense: $430,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
S 940, to permanently extend the subpart F exemption for active financing income HR 1509, to permanently extend the subpart F exemption for active financing income S 1726, Business Activity Tax Simplification Act, regulation of state taxation of interstate commerce FY 2009 Budget Proposal, tax provisions, third-party reporting S. 1273, Permanent Extension of CFC Look-thru Rule HR 3735, Five Year Extension of CFC Look-thru Rule HR 5267, Business Activity Tax Simplification Act, regulation of state taxation of interstate commerce HR 3221, the Foreclosure Prevention Act of 2008, proposal to require credit card companies to report to the IRS on reimbursement payments made to merchants HR 6275, the Alternative Minimum Tax Relief Act of 2008, proposal to require credit card companies to report to the IRS reimbursement payments made to merchants H.R. 6049, Renewable Energy and Job Creation Act of 2008, proposal to extend the active financing and look through exceptions from Subpart F S. 3125 Energy Independence and Tax Relief Act of 2008, proposal to extend the active financing and lookthrough exceptions from Subpart F H.R. 3359 Mobile Workforce State Income Tax Fairness and Simplification Act of 2007, issues involving non resident withholding S 3098 Alternative Minimum Tax and Extender Relief Act of 2008, proposal to extend the active financing and lookthrough exceptions from Subpart F H.R. 1424, Emergency Economic Stabilization Act of 2008, proposal to extend active financing and lookthrough H.R. 6049, Energy Improvement and Extension Act of 2008, proposal to extend active financing and lookthrough
Client expense: $920,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Postal Service (USPS)
2008 · third_quarter · Taxation/Internal Revenue Code
S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008, section 241. H.R. 1424, Emergency Economic Stabilization Act of 2008, section 303. H.R. 6049, the Renewable Energy and Job Creation Act of 2008, provisions relating to subpart F exemption for active financing income. H.R. 7060, Renewable Energy and Job Creation Tax Act of 2008, section 239. S. 940/H.R. 1509, to amend the Internal Revenue Code of 1986, to permanently extend the subpart F exemption for active financing income, all provisions.
Client expense: $1,840,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 3970/ H.R. 878/ S. 601/ H.R. 5720/ H.R. 3221/ S. 335/ H.R. 6049/ H.R. 7060/ H.R. 7201/ H.R.1424 (adjusted basis reporting requirements for brokers and delay in filing deadline for 1099 statement); H.R. 1509/ H.R. 6049/ S. 3125/ S. 2886/ S. 3335/ S. 940/ S. 3098/ H.R. 7060/ H.R. 7202/ H.R. 1424 (active financing exception under Subpart F); H.R. 5267 (Business Activity Tax Simplification Act of 2008); 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); 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; Cross-border equity swaps; IRS Notice 97-66 (foreign-to-foreign securities loans); H.R. 4912 (Tax treatment of prepaid derivatives contracts); 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); H.R. 6333/ S. 3518 (municipal bonds); H.R. 1424/ H.R. 6049/ S. 3125/ S. 3335 (executive compensation tax provisions).
Client expense: $1,430,000 · 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
2008 · third_quarter · Taxation/Internal Revenue Code
S.940; HR.1509; S.349; HR.6; HR. 2776; renewable energy tax incentives for wind, solar and smart grid; IRC sections 45 and 48; S.6049; S.3098; S.3125; S.3335; HR.7060; HR.7202; HR.1424; S.1370 (sections 4 and 5); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; issues relating to inclusion of arbitration provisions in tax treaties; H.R.4912; tax treatment of exchange traded notes; Deferred compensation; HR. 6049; S.3098; S. 3125; economic stabilization provisions; H.R. 3997; H.R. 1424; tax treatment of REMICS and REITs.
Client expense: Not reported · Firm income: $30,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
IRC Subpart F; HR.1509; S.940; HR.6049; S. 3098; S. 3125; S.3335; HR.7060; HR.7202; HR.1424; IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; IRS Notice 2007-58; sourcing rule under tax treaties.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
Extension and expansion of alternative simplified research and development tax credit; HR 2138; S. 41; HR.3996; S.2209; HR. 6049; S.3098; S.3125; S.3335; HR.7060; HR.7202; HR.1424; Subpart F issues, including look-through treatment for controlled foreign corporations and treatment of manufacturing under IRC section 954 and related regulations; IRS REG-124590-07; HR.1509; S.940; S.349 (section 206); IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR.4351; international tax reform issues; IRS Notice 2007-58; HR.3735; S.1273; HR.6.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
Issues relating to taxation of life insurance products; HR. 1509; S.940; IRC Subpart F and look-through treatment for controlled foreign corporations; HR. 6049; S.3098; S.3125; S.3335; HR.7060; HR. 7202; HR.1424; S.349 (section 206); international issues, including foreign tax credits; IRC section 7701(economic substance doctrine); S.2242; HR.3970; HR. 4351.
Client expense: Not reported · Firm income: $40,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2008 · third_quarter · Taxation/Internal Revenue Code
HR 6049 "Energy and Tax Extenders Act" HR 6275 "Alternative Minimum Tax Relief Act" S 3125 "Energy Independence and Tax Relief Act" S 3098, S 2886, S 940, HR 1509 - support legislation to extend the active finance exception to Subpart F of the Internal Revenue Code, which requires current taxation on income earned overseas; HR 5267 "Business Activity Tax Simplification Act" - support legislation creating a physical presence standard under which a state may tax the income of a business.
Client expense: $1,780,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Federal Highway Administration (FHA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)
2008 · third_quarter · Taxation/Internal Revenue Code
HR 2138, Investment in America Act of 2007, Entire Bill S 2209, Research Credit Improvement Act, Entire Bill S 41, Research Competitiveness Act, Entire Bill S 940/ HR 1509, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (Official Title as Introduced), Entire Bill S 2359/ HR 5140, Economic Stimulus Act of 2008, Section 103 related to taxation HR 3221, The American Housing Rescue and Foreclosure Prevention Act of 2008 HR 1424, The Emergency Economic Stabilization Act of 2008, as amended by the Senate, the extenders tax package and plug-in Hybrid credit for consumers Canadian Tax Treaty Protocol, Entire Treaty (Treaty Doc 110-15)
Client expense: $1,925,000 · Firm income: Not reported
Government targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
S. 940/ H.R. 1509, To Amend the Internal Revenue Code of 2986 to Permanently Extend the Subpart F Exemption for Active Financing Income (Entire bill) H.R. 6049, Renewable Energy and Job Creation Act (Sec. 239) S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act (Sec. 203) S. 3098, AMT and Extenders Tax Relief Act (Sec. 303) S. 3125, Energy Independence and Tax Relief Act (Sec. 247) H.R. 1424, Emergency Ecnomic Stabilization Act (Sec. 303)
Client expense: $480,000 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Council of Economic Advisers (CEA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
HR 1509, Permanent Extension of Subpart F Deferral for Financial Services S 940, Permanent Extension of Subpart F Deferral for Financial Services HR, 2776 The Renewable Energy and Energy Conservation Tax Act of 2007 S 1726 Business Activity Tax Simplification Act of 2007 S 34 Sales Tax Fairness and Simplification Act Class Life for Medical Equipment Codifications of Economic Substance Doctrine Deferred Compensation S 1525, Super Efficient Appliance Incentives and Market Transformation Act of 2007 HR 2137, Super Efficient Appliance Incentives and Market Transformation Act of 2007 HR 3970, Tax Reduction and Reform Act of 2007 HR 3396, Sales Tax Fairness and Simplification Act HR 3359, Mobile Workforce State Income Tax Fairness and Simplication Act of 2007 HR 6, (with regard to Wind, Appliance Tax Credit and Other Energy Tax Measures) IRC Section 45 Production Tax Credit (Wind) HR 5267, Business Activity Tax Simplification Act of 2008 S 2886, Alternative Mimimum Tax and Extenders Tax Relief of 2008 S 3098, Alternative Mimimum Tax and Extenders Tax Relief of 2008 S 3125, Energy Independence and Tax Relief Act of 2008 HR 3452 A bill to amend the Internal Revenue Code of 1986 to allow a credit with respect to clean renewable water supply bonds HR 6049, Energy Improvement and Extension Act of 2008 HR 1424, Emergency Stabilization Act of 2008 S 3162, Made in the USA Act HR 7060 The Renewable Energy and Job Creation Tax Act of 2008 HR 7201, The Energy Improvement and Extension Act of 2008 S 3478, Energy Independence and Investment Act of 2008 S 2821, Clean Energy Tax Stimulus Act of 2008
Client expense: $4,800,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Consumer Product Safety Commission (CPSC), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Justice, Dept of (DOJ), Natl Aeronautics & Space Administration (NASA), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA)
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
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
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 1509 and S. 940, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income; H.R. 6049, H.R.1424
Client expense: Not reported · Firm income: $20,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
Active financial services income (H.R. 1509, S. 940), nonqualified deferred compensation
Client expense: Not reported · Firm income: $390,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
R&D tax credit (H.R. 3996, H.R. 2138, S.41), active financial services income (H.R. 1509, S. 940), withholding on government payments to contractors (H.R. 1023, H.R. 3996)
Client expense: Not reported · Firm income: $80,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE
2008 · third_quarter · Taxation/Internal Revenue Code
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
2008 · third_quarter · Taxation/Internal Revenue Code
Significant Tax Issues: Subpart f/BAT/SILO, S. 940, Subpart f Exemption, H.R. 976, the Small Business Tax Relief Act of 2007, H.R. 2834, Carried Interest Income Bill, H.R. 2776, the Renewable Energy and Energy Conservation Tax Act of 2007, H.R. 2365, tax practitioners for infringement of a patent for tax bill, H.R. 2, the Fair Minimum Wage Act of 2007, Small Business and Work Opportunity Act of 2007, H.R. 1591, the US Troop Readiness, Veteran's Health, and Iraq; on tax changes on leasing, non-qualified deferred compensation, covered employees, deductibility of certain civil penalties and fines, the Energy Tax Bill (Senate Finance), and tax changes on leasing; H.R. Tax Increase Prevention Act of 2007; H.R. 5267, Business Activity Tax Simplification Act (BATSA) and S. 1726
Client expense: $1,800,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council of Economic Advisers (CEA), Environmental Protection Agency (EPA), Farm Credit Administration, Federal Accounting Standards Advisory Board (FASAB), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Office of Management & Budget (OMB), Office of Personnel Management (OPM), Office of Thrift Supervision (OTS), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR), White House Office
2008 · third_quarter · Taxation/Internal Revenue Code
H.R. 1509, A bill to amend the Internal Revenue Code of 1986 to permanently extend the Sub-part F exemption for active financing income, All provisions H.R. 4195, Tax Technical Corrections Act of 2007, All provisions H.R. 5720, Housing Assistance Tax Act, All provisions H.R. 5719, The Taxpayer Assistance and Simplification Act of 2008, All provisions H.R. 6049, The Renewable Energy and Job Creation Act, Extender provisions H.R. 6110, Roadmap for Americas Future Act of 2008, Corporate and international provisions S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption for active financing purposes, All provisions H.R. 3963, Childrens Health Insurance Program Reauthorization, All provisions H.R. 3996, Temporary Tax Relief Act of 2007, All provisions S. 2666, Affordable Housing Investment Act of 2008, All provisions H.R. 5140 [No Senate Number Available], Economic Stimulus Act of 2008, All provisions S. 3125, Energy Independence and Tax Relief Act, All provisions H.R. 1424, Emergency Economic Stabilization Act of 2008, Tax Extender Provisions H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007, All provisions H.R. 6275, Alternative Minimum Tax Relief Act of 2008, All provisions H.R. 3221, Foreclosure Prevention Act of 2008, All provisions S. 3335, Jobs, Energy, Families, and Disaster Relief Act of 2008 , All provisions
Client expense: $1,790,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)
2008 · third_quarter · Taxation/Internal Revenue Code
S. 601, the Simplification Through Additional Reporting Tax Act of 2007 S. 777, to repeal the imposition of withholding on certain payments made to vendors by government entities. S. 819, the Public Good IRA Rollover Act of 2007 - Amends the Internal Revenue Code to exclude from gross income distributions from individual retirement accounts for certain charitable purposes. S. 940, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (all provisions) 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. (all provisions) S. 1726, the Business Activity Tax Simplification Act (all provisions) S. 2394, the Good Government Contractor Act of 2007 (provision to repeal withholding requirement) S. 3063, the S Corporation Modernization Act S. 3254, the Small Bank Tax Equity Act S. 3335, the Jobs, Energy, Families, and Disaster Relief Act of 2008 (provisions to extend business-related tax provisions) H.R. 6, the Renewable Fuels, Consumer Protection, and Energy Efficiency Act of 2007 (S.Amdt. 1704, tax title provisions) H.R. 976, the Small Business Tax Relief Act of 2007 (all provisions) H.R. 1419, the Public Good IRA Rollover Act or 2007 - Amends the Internal Revenue Code to exclude from gross income distributions from individual retirement accounts for certain charitable purposes. H.R. 1424, the Emergency Economic Stabilization Act H.R. 1509, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income (all provisions) H.R. 1677, the Taxpayer Protection Act of 2007 (refund anticipation loan provisions) H.R. 1023, to repeal the impositions of withholding on certain payments made to vendors by government entities. H.R. 2370, to amend the Internal Revenue Code of 1986 to provide for the establishment of financial security accounts for the care of family members with disabilities. 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. 3056, the Tax Collection Responsibility Act of 2007 (all provisions) H.R. 3221, the American Housing Rescue and Foreclosure Prevention Act H.R. 3648, the Mortgage Forgiveness Debt Relief Act of 2007 (all provisions) H.R. 3678, the Internet Tax Freedom Act Amendments Act of 2007 (all provisions) H.R. 3970, the Tax Reduction and Reform Act of 2007 (revenue offset provisions, including economic substance doctrine, cost basis reporting, and deferred compensation taxation) H.R. 3996, the Tax Increase Prevention Act of 2007 (mortgage debt forgiveness, revenue offset tax provisions) H.R. 3997, the Emergency Economic Stabilization Act H.R. 4351, the AMT Relief Act of 2007 (revenue offsets provisions on the economic substance doctrine, deferred offshore compensation for hedge fund managers, and interest expense allocation rules for multinational firms) H.R. 4840, the S Corporation Modernization Act (all provisions) H.R. 5267, the Business Activity Tax Simplification Act of 2008 (all provisions) H.R. 5720, the Housing Assistance Tax Act of 2008 (all provisions, including bond authority, tax credits, cost-basis reporting requirements, and IRS withholding requirements) H.R. 6049, the Renewable Energy and Job Creation Act of 2008 (tax extension provisions, including research and development tax credit, Subpart F and Section 355 (controlled foreign corporation) rules, new markets tax credit; revenue offsets including effective date of new interest expense allocation, changes to deferred compensation rules for managers of offshore hedge funds) H.R. 6275, the Alternative Minimum Tax Relief Act of 2008 (revenue offset provisions) H.R. 6333, the Municipal Bonds Market Support Act (all provisions) H.R. 6601, the Small Business Tax Modernization Act of 2008 (all provisions) H.R. 7060, the Renewable Energy and Job Creation Tax Act of 2008 (business tax provisions, revenue offsets) Draft Legislation to require Cost-Basis Reporting for Securities Credit Card Information Reporting Codification of the Economic Substance Doctrine Proposals to apply unrelated business income tax (UBIT) to credit unions Proposals on Estate and Gift Tax Reform Proposed Middle Class Job Security Act (corporate tax rate, net operating loss carry-back provisions) Proposed amendment to Section 67(e) tax deductibility of trustee fees
Client expense: $2,340,000 · Firm income: Not reported
Government targets: Defense, Dept of (DOD), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Social Security Administration (SSA), Treasury, Dept of, White House Office