Stop Tax Haven Abuse Act

Trade issues impacting Hong Kong S. 506 Stop Tax Haven Abuse Act H.R. 1265 Stop Tax Haven Abuse Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Trade issues impacting Hong Kong S. 506 Stop Tax Haven Abuse Act H.R. 1265 Stop Tax Haven Abuse Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 11 (Build America Bonds to Create Jobs Now Act of 2011); H.R. 747 (Build America Bonds Extension Act of 2011); H.R. 847 (9/11 Health and Compensation Act)(worker classification rules); H.R. 992 (Building American Jobs Act of 2011)(infrastructure tax legislation); H.R. 3408 (Taxpayer Responsibility, Accountability, and Consistency Act of 2009); H.R. 3933 (Foreign Account Tax Compliance Act); H.R. 4173 (Dodd-Frank Wall Street Reform and Consumer Protection Act); H.R. 4213 (American Jobs and Closing Tax Loopholes Act); H.R. 4849 (Small Business and Infrastructure Jobs Tax Act); H.R. 4853 (Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010)(taxation of dividends and capital gains, extension of expiring business provisions); H.R. 5297 (Small Business Jobs Act of 2010); H.R. 6128 (Fair Playing Field Act of 2010)(worker classification); H.R. 6484 (Public Employee Pension Transparency Act); S. 506 (Stop Tax Haven Abuse Act) (Administration's FY2010 dividend withholding proposals); S. 727 (Bipartisan Tax Fairness and Simplification Act of 2011); S. 2882 (Taxpayer Responsibility, Accountability and Consistency Act of 2009); S. 2994 (Taxpayer Fairness Act); S. 3350 (Municipal Bond Market Support Act of 2010); S. 3786 (Fair Playing Field Act of 2010)(worker classification); S. 3793 (Job Creation and Tax Cuts Act of 2010); Expansion of Build America Bond Rules to Tax Credit Bonds; Tax rules relating to regulation of over-the-counter derivative contracts; Extension of Federal Home Loan Bank Guarantee; Financial Transaction Tax Proposals; Tax issues related to standardization of credit default swaps; Extension of Active Financing Rules; Tax issues related to implementation of charge for failure to deliver Treasury securities; Administration's Financial Crisis Responsibility Fee; Tax issues related to interest expense allocation; Tax treatment of capital gains and dividends; Taxation of independent contractors; Taxation of cross-border equity swaps; Corporate tax reporting rules; Bonus tax proposals; Tax reporting requirements for foreign financial institutions on certain foreign accounts; Foreign Account Tax Compliance Act (FATCA), provisions enacted under the Hiring Incentives to Restore Employment Act (Notice 2010-60); Extension of the Alternative Minimum Tax, tax exemption for private activity bonds; Notice 2010-46 (Tax withholding on substitute dividend payments); Securities cost basis reporting regulations; Tax rules relating to Bearer Bonds; Taxation of Transportation and Regional Infrastructure Project (TRIP) Bonds.

Client expense: $1,330,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Economic Council (NEC), 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)

H.R. 11 (Build America Bonds to Create Jobs Now Act of 2011); H.R. 747 (Build America Bonds Extension Act of 2011); H.R. 847 (9/11 Health and Compensation Act)(worker classification rules); H.R. 992 (Building American Jobs Act of 2011)(infrastructure tax legislation); H.R. 3408 (Taxpayer Responsibility, Accountability, and Consistency Act of 2009); H.R. 3933 (Foreign Account Tax Compliance Act); H.R. 4173 (Dodd-Frank Wall Street Reform and Consumer Protection Act); H.R. 4213 (American Jobs and Closing Tax Loopholes Act); H.R. 4849 (Small Business and Infrastructure Jobs Tax Act); H.R. 4853 (Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010)(taxation of dividends and capital gains, extension of expiring business provisions); H.R. 5297 (Small Business Jobs Act of 2010); H.R. 6128 (Fair Playing Field Act of 2010)(worker classification); H.R. 6484 (Public Employee Pension Transparency Act); S. 506 (Stop Tax Haven Abuse Act) (Administration's FY2010 dividend withholding proposals); S. 727 (Bipartisan Tax Fairness and Simplification Act of 2011); S. 2882 (Taxpayer Responsibility, Accountability and Consistency Act of 2009); S. 2994 (Taxpayer Fairness Act); S. 3350 (Municipal Bond Market Support Act of 2010); S. 3786 (Fair Playing Field Act of 2010)(worker classification); S. 3793 (Job Creation and Tax Cuts Act of 2010); Expansion of Build America Bond Rules to Tax Credit Bonds; Tax rules relating to regulation of over-the-counter derivative contracts; Extension of Federal Home Loan Bank Guarantee; Financial Transaction Tax Proposals; Tax issues related to standardization of credit default swaps; Extension of Active Financing Rules; Tax issues related to implementation of charge for failure to deliver Treasury securities; Administration's Financial Crisis Responsibility Fee; Tax issues related to interest expense allocation; Tax treatment of capital gains and dividends; Taxation of independent contractors; Taxation of cross-border equity swaps; Corporate tax reporting rules; Bonus tax proposals; Tax reporting requirements for foreign financial institutions on certain foreign accounts; Foreign Account Tax Compliance Act (FATCA), provisions enacted under the Hiring Incentives to Restore Employment Act (Notice 2010-60); Extension of the Alternative Minimum Tax, tax exemption for private activity bonds; Notice 2010-46 (Tax withholding on substitute dividend payments); Securities cost basis reporting regulations; Tax rules relating to Bearer Bonds; Taxation of Transportation and Regional Infrastructure Project (TRIP) Bonds.

Client expense: $1,290,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Economic Council (NEC), 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)

Trade issues impacting Hong Kong S. 506 Stop Tax Haven Abuse Act H.R. 1265 Stop Tax Haven Abuse Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2584 (tax strategy patents); S. 515 (Patent Reform); HR 1260 (Patent Reform); HR 1265 (Stop tax haven abuse act; sections regarding Tax strategy patents); S. 506 (Stop tax haven abuse act; sections regarding Tax strategy patents)

Client expense: $890,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

HR 2110 State income tax simplification mobile workforce; S 506/HR 1265 International Tax Provisions/Economic Substance/Patents; S 144/HR 690 Mobile Cell Phone Act, HR 436 Carry-over Basis Estate Tax Reform; HR 3200 Economic Substance, More Likely than Not Standard; S 437 - Allow certain attorney fees and court cost deductions for AGI IRC Section 67(3) deductibility of trust administration expenses); Prepare regulation including PTIN regulations; ATM; Tax return due dates Repeal full vesting on partial termination of qualified retirement plans; Harmonize and simplify education incentives; Pension Funding; Simplify the Kiddie Tax; Standardize the allowable mileage rates for business expense, medical expense, and charitable contribution purposes; Revise the due date of the reporting requirements for foreign banks and financial accounts; Allow for abatement of a Section 6707A penalty if the taxpayer acts reasonably and in good faith; Repeal the Section 7122 (c )(1) requirement to provide a 20 % partial payment with a lump sum offer in compromise; Amend Section 118 to apply to partnerships; Allow spouses (and divorced spouses) to transfer partnership suspended losses to one another; Allow S Corps to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Modification of information reporting requirements under tax law; HR 4213 (American Workers, State and Business Relief Act of 2010); Employment tax treatment of S Corporations; IRS Guidance Priority Test; Corrections on Nonqualified deferred compensation plan failures under Section 409(A); Built in gains and losses relating to partnership mergers under Section 704( c); Repeal of Section 9006 of PL 111-148 regarding forms 1099- miscellaneous information returns; HR 5141 -- Small Business Paperwork Mandate Elimination Act Mark

Client expense: $890,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

S.506 - Stop Tax Haven Abuse Act - provisions related to international tax on foreign direct investment; H.R. 1265 - Stop Tax Haven Abuse Act - provisions related to international tax on foreign direct investment; H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010 - international tax on foreign direct investment generally; International tax on foreign direct investment generally; S. 3793 - Job Creation Tax Cuts - issues relating to international tax; H.R. 847 - James Zadroga 9/11 Health and Compensation Act of 2010 - issues related to international tax.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.506 - Stop Tax Haven Abuse Act - provisions relating to international tax on foreign direct investment; H.R. 1265 - Stop Tax Haven Abuse Act - provisions relating to international tax on foreign direct investment; H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010 - international tax on foreign direct investment generally; International tax on foreign direct investment generally; H.R. 4213 - American Jobs and Closing Tax Loopholes Act of 2010 - provisions relating to international tax on foreign direct investment; H.R. 291 - Small business Jobs Act of 2010 (all provisions); S. 393 - Job Creation Tax Cuts Act - issues relating to international tax return.

Client expense: $450,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 506 - Stop Tax Haven Abuse Act - provisions related to international tax on foreign direct investment; H.R. 1265 - Stop Tax Haven Abuse Act - provisions related to international tax on foreign direct investment; H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010 - international tax on foreign direct investment; International tax on foreign direct investment generally; H.R. 4213 - American Jobs and Closing Tax Loopholes Act of 2010 - provisions relating to foreign direct investment.

Client expense: $480,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 506 - Stop Tax Haven Abuse Act (all provisions); H.R. 1265 - Stop Tax Haven Abuse Act (all provisions); H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010 (all provisions); International tax on foreign direct investment generally.

Client expense: $490,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Science & Technology Policy (OSTP), SENATE, White House Office

H.R. 275/S. 292, Withholding Tax Relief Act of 2009 H.R. 4213, Tax Extenders Act of 2009 H.R. 4849, Small Business and Infrastructure Jobs Tax Act of 2010 H.R. 2847, the Hiring Incentives to Restore Employment Act, provisions on Payroll Tax S. 996, S Corporation Modernization Act of 2009 S. 3014, the Stabenow-Hatch American Job Creation and Investment Act H.R. 3590, the Patient Protection and Affordable Care Act and the related budget reconciliation legislation H.R. 4872, the Student Aid and Fiscal Responsibility Act of 2009, tax provisions H.R. 4191, Let Wall Street Pay for the Restoration of Main Street Act S. 2927, Wall Street Fair Share Act H.R. 1322, Emergency Retiree Health Benefits Protection Act of 2009 H.R. 1265/S. 506, Stop Tax Haven Abuse Act S. 722, Taxpayer Certainty and Relief Act of 2009 H.R. 422, to amend the Internal Revenue Code of 1986 to extend the research credit through 2010 and to increase and make permanent the alternative simplified research credit S. 1203, Grow Research Opportunities With Taxcredits' Help Act H.R. 436, Certain Estate Tax Relief Act of 2009 S. 1678, a bill to amend the Internal Revenue Code of 1986 to extend the first-time homebuyer tax credit, and for other purposes H.R. 3463, Death Tax Repeal Permanency Act of 2009 H.R. 4154, Permanent Estate Tax Relief for Families, Farmers, and Small Businesses Act of 2009 H.R. 3590, Patient Protection and Affordable Care Act H.R. 4872, Health Care and Education Reconciliation Act of 2010 H.R. 2847, Hiring Incentives to Restore Employment S. 3014/H.R. 4850, American Job Creation and Investment Act (bill number does not include year) S. 3018, Bipartisan Tax Fairness and Simplification Act of 2010 Potential tax gap proposals for small business on 1099 Corporate Reporting and potential tax extenders legislation (no specific legislation introduced) FY 2011 Obama Budget proposal on potential bank tax (no specific legislation introduced) Reid Jobs Bill (Sub Amendment to H.R. 2847) Issues related to estate tax, deferral, net operating loss, executive compensation, LIFO, and research & development (specific legislation not yet introduced) Official Covered Positions for Jonthan Jachym: Intern, SEC Office of International Affairs Intern, FINRA Division of Market Regulation Intern, FINRA Office of the General Counsel

Client expense: $25,120,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Maritime Administration (MARAD), Natl Economic Council (NEC), Natl Security Council (NSC), Office of Management & Budget (OMB), Pipeline & Hazardous Materials Safety Administration, SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), St. Lawrence Seaway Development Corporation, State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Safe Schools Improvement Act (S. 506); Student Non-Discrimination Act of 2011 (H.R. 998/S. 555).

Client expense: $480,000 · Firm income: Not reported

Government targets: Centers For Disease Control & Prevention (CDC), Defense, Dept of (DOD), Education, Dept of, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Natl Institutes of Health (NIH), Office of Personnel Management (OPM), SENATE, State, Dept of (DOS), Treasury, Dept of, White House Office

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. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act H.R.4213 American Workers, State, and Business Relief Act H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $1,090,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), 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. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act H.R.4213 American Workers, State, and Business Relief Act H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $1,090,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), 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. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act of 2009 S. 1588 Stop Tax Breaks for Oil Profiteering Act of 2009 H.R. 3933 Foreign Account Tax Compliance Act of 2009 H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act of 2009 H.R.4213 American Workers, State, and Business Relief Act of 2010 H.R. 2847 Hiring Incentives to Restore Employment Act

Client expense: $1,070,000 · 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

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) Against Anti-Tax Haven Bills (S. 506, H.R. 1265, H.R. 3933 & S.1934).

Client expense: Not reported · Firm income: Not reported

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

Corporate Tax Insurance Rates Tax Issues Reinsurance HR 1265/ S 506 Stop Tax Haven Abuse Act

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 4213: American Jobs and Closing Tax Loopholes Act of 2010; provisions relating to revenue raisers and deductablilty of punitive damage awards. S 3793: Job Creation and Tax Cuts Act of 2010; all provisions of the bill. HR 4853: Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010; all provisions of the bill. HR 422: To amend the Internal Revenue Code of 1986 to extend the research credit through 2010 and to increase and make permanent the alternative simplified research credit; all provisions of the bill. S 506/HR 1265: Stop Tax Haven Abuse Act; provisions relating to revenue raisers. S 1341/HR 3439: A bill to amend the Internal Revenue Code of 1986 to impose an excise tax on certain proceeds received on SILO and LILO transactions; all provisions of the bill. HR 4994: Taxpayer Assistance Act of 2010; provisions relating to revenue raisers. Discussions concerning the extension of the 2010 Capital Gains and Dividends tax rates.

Client expense: $2,380,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), HOUSE OF REPRESENTATIVES, SENATE

Administration's FY2010 International Tax Proposals; Administration's FY2010 and Senate Finance Committee discussion draft offshore tax compliance proposals; H.R. 847 (9/11 Health and Compensation Act)(worker classification rules); H.R. 3408 (Taxpayer Responsibility, Accountability, and Consistency Act of 2009); H.R. 3933 (Foreign Account Tax Compliance Act); H.R. 4173 (Dodd-Frank Wall Street Reform and Consumer Protection Act); H.R. 4213 (American Jobs and Closing Tax Loopholes Act); H.R. 4849 (Small Business and Infrastructure Jobs Tax Act); H.R. 4853 (Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010)(taxation of dividends and capital gains, extension of expiring business provisions); H.R. 5297 (Small Business Jobs Act of 2010); H.R. 6128 (Fair Playing Field Act of 2010)(worker classification); S. 506 (Stop Tax Haven Abuse Act) (Administration's FY2010 dividend withholding proposals); S. 2882 (Taxpayer Responsibility, Accountability and Consistency Act of 2009); S. 2994 (Taxpayer Fairness Act); S. 3350 (Municipal Bond Market Support Act of 2010); S. 3786 (Fair Playing Field Act of 2010)(worker classification); S. 3793 (Job Creation and Tax Cuts Act of 2010); Build America Bonds; Extension of Build America Bonds; Expansion of Build America Bond Rules to Tax Credit Bonds; Tax rules relating to regulation of over-the-counter derivative contracts; Extension of Federal Home Loan Bank Guarantee; Financial Transaction Tax Proposals; Tax issues related to standardization of credit default swaps; Extension of Active Financing Rules; Tax issues related to implementation of charge for failure to deliver Treasury securities; Administration's Financial Crisis Responsibility Fee; Tax issues related to interest expense allocation; Tax treatment of capital gains and dividends; Taxation of independent contractors; Taxation of cross-border equity swaps; Corporate tax reporting rules; Bonus tax proposals; Tax reporting requirements for foreign financial institutions on certain foreign accounts; Foreign Account Tax Compliance Act (FATCA), provisions enacted under the Hiring Incentives to Restore Employment Act (Notice 2010-60); Extension of the Alternative Minimum Tax, tax exemption for private activity bonds; Notice 2010-46 (Tax withholding on substitute dividend payments); Securities cost basis reporting regulations; Tax rules relating to Bearer Bonds.

Client expense: $1,280,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), 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)

International taxation: Stop Tax Haven Abuse Act - HR 1265, S. 506 Proposal to alter tax treatment of affiliate reinsurance transactions - HR 3424 Proposal to disallow the deferral of overseas income

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)

Offshore Taxation HR 1265/ S 506 Stop Tax Haven Abuse Act HR 4213 American Workers, State and Business Relief Act of 2010

Client expense: Not reported · Firm income: $120,000

Government targets: Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

International tax on foreign direct investment. H.R. 1265, Stop Tax Haven Abuse Act S. 506, Stop Tax Haven Abuse Act H.R. 4213, American Jobs and Closing Tax Loopholes Act of 2010

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

Government targets: Centers For Medicare and Medicaid Services (CMS), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE

H.R. 1265 / S. 506 - To restrict the use of offshore tax havens and abusive tax shelters to inappropriately avoid Federal taxation. H.R. 1944 - To amend the Internal Revenue Code of 1986 to permanently extend the Subpart F exemption for active financing income. H.R. 3424 - 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. H.R. 4213 - Tax Extenders Act

Client expense: $1,202,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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. S. 506 Stop Tax Haven Abuse Act S. 31 To amend the Internal Revenue Code of 1986 with respect to the proper tax treatment of certain indebtedness discharged in 2009 or 2010, and for other purposes H.R.1935 To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services H.R. 1068 Let Wall Street Pay for Wall Street's Bailout Act S. 1588 Stop Tax Breaks for Oil Profiteering Act H.R. 3933 Foreign Account Tax Compliance Act H.R. 4191 Let Wall Street Pay for the Restoration of Main Street Act S. 3816 Creating American Jobs and Ending Offshoring Act H.R. 4853 Tax Relief, Unemployments Insurance Reauthorization, and Job Creation Act of 2010 H.R. 6467 Middle Class Tax Relief Act of 2010

Client expense: $670,000 · Firm income: Not reported

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

S. 515 - Patent Reform Act of 2009; H.R. 1260 - Patent Reform Act of 2009; H.R. 2110 - Mobile Workforce State Income Tax Fairness and Simplification Act; H.R. 1265 - Stop Tax Haven Abuse Act; S. 506 - Stop Tax Haven Abuse Act

Client expense: $380,000 · Firm income: Not reported

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

H.R. 436 - Certain Estate Tax Relief Act of 2009; entire bill H.R. 847 - James Zadroga 9/11 Health and Compensation Act of 2010; provisions relating to possible use of workforce classification reforms as the revenue offset (P.L. 111-347, 1/2/2011) H.R. 1083 - The Business Activity Tax Simplification Act of 2009; entire bill H.R. 1935 - To amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services; entire bill H.R. 2920 Statutory Pay Go Act of 2009; provisions relating to estate tax and middle class tax benefits H.R. 3408 - Taxpayer Responsibility, Accountability, and Consistency Act of 2009; provisions relating to limitation of independent contractor status for independent broker dealers H.R. 3905 Estate Tax Relief Act; entire bill H.R. 3933 - Foreign Account Tax Compliance Act of 2009; to ensure workable reporting requirements for mutual funds H.R. 4154 - Permanent Estate Tax Relief for Families, Farmers, and Small Businesses Act of 2009; entire bill H.R. 4191 - Let Wall Street Pay for the Restoration of Main Street Act of 2009; entire bill H.R. 4337 - Regulated Investment Company Modernization Act of 2009; entire bill (P.L. 111-325, 12/22/2010) H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010; provisions relating to small business capital gains exclusion and Build America Bonds H.R. 4853 - Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010; provisions relating to individual tax rates/estate tax and extenders, small business incentives relevant to the financial services sector H.R. 5982 Small Business Tax Relief Act of 2010; provisions relating to repeal of 1099 reporting obligations enacted in health care reform H.R. 6128 Fair Playing Field Act of 2010; provisions that would affect use of independent contractors within the securities industry S. 506 - Stop Tax Haven Abuse Act; provision relating to managed and controlled foreign entities S. 567 - A bill to repeal the sunset on the reduction of capital gains rates for individuals and on the taxation of dividends of individuals at capital gains rates; entire bill S. 651 - Compensation Fairness Act of 2009; entire bill S. 722 - Taxpayer Certainty and Relief Act of 2009; provisions relating to capital gains, dividends, and estate tax S. 1007 - Excessive Pay Capped Deduction Act of 2009; entire bill S. 2784 - A bill to amend the Internal Revenue Code of 1986 to permanently extend the estate tax as in effect in 2009; entire bill S. 2869 Small Business Job Creation and Access to Capital Act of 2009; entire bill S. 2882 - Taxpayer Responsibility, Accountability, and Consistency Act of 2009; provisions relating to independent contractors within the securities industry S. 2927 - Wall Street Fair Share Act; entire bill S. 3513 Bonus Depreciation Extension to Create Jobs Act; entire bill S. 3773 Tax Hike Prevention Act of 2010; provisions relating to capital gains dividends and estate tax S. 3786 Fair Playing Field Act; provisions that would affect use of independent contractors within the securities industry S. 3793 Job Creation and Tax Cuts Act of 2010; entire bill S. 3816 Creating American Jobs and Ending Offshoring Act; entire bill S. 3946 - Small Business Paperwork Relief Act; entire bill Administrations FY 2011 budget proposals relating to Auto IRA retirement savings initiatives, taxation of life insurance companies, international taxation, tax treatment of capital gains and dividends, independent contractor, estate tax, and Financial Crisis Responsibility Fee

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1265, revenue measure S. 506, revenue measure

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Trade issues impacting Hong Kong S. 506 Stop Tax Haven Abuse Act H.R. 1265 Stop Tax Haven Abuse Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Advice on anti-offshore finance legislation and international tax policy legislation, including S. 506, the Stop Tax Haven Abuse Act, and related Finance Committee tax legislation.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Monitoring proposals on U.S. tax treatment of foreign corporations; S. 506, Stop Tax Haven Abuse Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

International tax on foreign direct investment. H.R. 1265, Stop Tax Haven Abuse Act S. 506, Stop Tax Haven Abuse Act H.R. 1194/S. 2947 - Fire Sprinkler Incentive Act: all provisions

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Patent reform and liability issues including: H.R.1260 / S.515 - Patent Reform Act of 2009 - all provisions S.610 - Patent Reform Act of 2009 - all provisions S.506 - Stop Tax Haven Abuse Act - tax patent provision S.931/H.R.1020 Arbitration Fairness Act of 2009 all provisions H.R.1346 / S.540 Medical Device Safety Act of 2009 liability issues H.R.4094 Drywall Victim Insurance Protection Act - all provisions S.739 Drywall Safety Act of 2009 all provisions S. 3217- Restoring American Financial Stability Act of 2010 expansion of third party liability (Stoneridge) The Domestic Manufacturing and Energy Jobs Act of 2010 (Draft Text) tax and liability provisions H.R.847 / S.1334 - James Zadroga 9/11 Health and Compensation Act of 2010 liability provisions H.R.3534 Consolidated Land, Energy, and Aquatic Resources Act of 2009 (CLEAR Act) liability provisions

Client expense: $710,000 · Firm income: Not reported

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

S. 506/ H.R. 1265 Stop Tax Haven Abuse Act tax deferral issue taxation of offshore income excise tax of medical devices

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

Government targets: Centers For Medicare and Medicaid Services (CMS), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE

S.506 Stop Tax Haven Abuse Act-International tax on foreign direct investment generally; H.R. 1265 - Stop Tax Haven Abuse Act-International tax on foreign direct investment generally; H.R. 4849 - Small Business and Infrastructure Jobs Tax Act of 2010- International tax on foreign direct investment generally; International tax on foreign direct investment generally; S. 3793 Job creation Tax Cuts Act issues relating to international tax; H.R. 847 James Zadroga 9/11 Health and Compensation Act of 2010, issues related to international tax.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2110 State income tax simplification - "mobile workforce"; S 506/HR 1265 - Economic Substances/patents; S 144/HR 690 - Mobile Cell Phone Act; HR 436 - Carry-over Basis Estate Tax Reform; HR 3200 - Economic Substance, More Likely Than Not Standard; S 437 - Allow certain attorney fees and court cost deductions for AGI; IRC Section 67(e) (deductibility of trust administration expenses); Preparer regulation including PTIN, user fee, nonsigning preparers, and Circular 230 regulations; AMT; Tax return due dates; Repeal full vesting on partial termination of qualified retirement plans; Harmonize and simplify education incentives; Pension Funding; Simplify the Kiddie Tax; Standardize the allowable mileage rates for business expense, medical expense, and charitable contribution purposes; Revise the due date of the reporting requirements for foreign banks and financial accounts; Allow for abatement of a Section 6707A penalty if the taxpayer acts reasonably and in good faith; Repeal the Section 7122(c)(1) requiremnet to provide a 20% partial payment with a lump sum offer in compromise; Amend Section 118 to apply to partnerships; Allow spouses (and divorced spouses) to transfer partnership suspended losses to one another; Allow S Corps to have nonresident aliens as shareholders and potential current beneficiares of electing small business trusts; Modification of information reporting requirements under tax law; HR 4213 (American Workers, State and Business Relief Act of 2010); Employment tax treatment of S Corporations; Corrections on Nonqualified deferred compensation plan failures under Section 409(A); Built in gains and losses relating to partnership mergers under Section 704(c); Repeal of Section 9006 of PL 111-148 regarding forms 1099-miscellaneous information returns; HR 5141 - Small Business Paperwork Mandate Elimination Act; Mandatory E-filing; Section 704(c) built in gains and losses; Gift Tax Treatment for transfers to grantor trusts; International Provisions in HR 847/HR 5982/HR 5893/HR 5901/HR 4213; Self Employment Tax for S Corporations shareholder provisions of HR 4213; Uncertain Tax Provisions; Changes to tax return due dates; Extending the due date of employee plan returns (PTW, this was also pushed with PBGC & labor); Exempt status of hospitals; Office visits of tax returns preparers by IRS; Repeal of Section 2101 of PL 111-240 regarding forms 1099-miscellaneous returns; Foreign trust aspects of FBAR; Carryover basis issues;

Client expense: $1,140,680 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

HR 2584 (Tax Strategy Patents); S 515 (Patent Reform); HR 1260 (Patent Reform); HR 1265 (Stop Tax Haven Abuse Act - sections regarding tax strategy patents); S 506 (Stop Tax Haven Abuse Act - sections regarding tax strategy patents)

Client expense: $1,140,680 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

Provide legislative and other tax services related to corporate tax issues, international tax issues and pension issues during the 111th session of Congress on the following bills: - H.R. 1586: A bill to impose an additional tax on bonuses received from certain TARP recipients - H.R. 5328, the International Tax Competitiveness Act of 2010 - H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010 - S. 3793, the Job Creation and Tax Cuts Act - S. 3513, the Bonus Depreciation Extension to Create Jobs Act - H.R. 5297, the Small Business Lending Fund Act of 2010 - H.R. 4173, the Dodd-Frank Wall Street Reform and Consumer Protection Act - S.506, H.R. 1265: A bill to restrict the use of offshore tax havens and abusive tax shelters to inappropriately avoid Federal taxation, and for other purposes - H.R. 1935: A bill to amend the Internal Revenue Code of 1986 to provide for the treatment of partnership interests held by partners providing services - S. 3816, the Creating American Jobs and Ending Offshoring Act - H.R. 5982, the Small Business Tax Relief Act of 2010 - H.R. 6121. A bill to amend the Internal Revenue Code to extend the production tax credit and investment tax credit, to increase the investment tax credit with respect to equipment used to generate electricity by geothermal power, and to extend specified energy property grants under the American Recovery and Reinvestment Act - H.R. 5893, the Investing in American Jobs and Closing Tax Loopholes Act of 2010 - S. 3777 and S. 3783, Information Reporting Modernization Act of 2010 - S. 3513, the Bonus Depreciation Extension to Create Jobs Act - H.R. 4853, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Consulting services related to various domestic and int'l business tax issues with respect to the following bill: H.R. 5328, the International Tax Competitiveness Act of 2010; H.R. 4213, the American Jobs and Closing Tax Loopholes Act of 2010; S. 3793, the Job Creation and Tax Cuts Act; H.R. 5297, the Small Business Lending Fund Act of 2010; S.506, H.R. 1265: Stop Tax Haven Abuse Act; S. 3793, the Jobs Creation and Tax Cut Act; H.R. 5893, the Investing in American Jobs and Closing Tax Loopholes Act; S.3777 & S.3783 Info. Modernization Act; H.R. 4853, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010; S. 3816, the Creating American Jobs and Ending Offshoring Act.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 2927, Wall Street Fair Share Act S. 510, FDA Food Safety Modernization Act, including the Baucus amendment, the Johanns amendment, and provisions relating to 1099 reporting S. 3793, Job Creation and Tax Cuts Act of 2010, including provisions related to tax extenders and revenue offsets S. 3946, Small Business Paperwork Relief Act, including provisions related to 1099 reporting S. 722, Taxpayer Certainty and Relief Act of 2009 S. 3018, Bipartisan Tax Fairness and Simplification Act of 2010 S. 3816, Creating American Jobs and Ending Offshoring Act S. 1203, Grow Research Opportunities With Taxcredits' Help Act S. 996, S Corporation Modernization Act of 2009 S. 1678, A bill to amend the Internal Revenue Code of 1986 to extend the first-time homebuyer tax credit, and for other purposes S. 3773, Tax Hike Prevention Act of 2010 S. 3976, Emergency Senior Citizens Relief Act of 2010 H.R. 4191, Let Wall Street Pay for the Restoration of Main Street Act of 2009 H.R. 4853, Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010, including all provisions related to Titles I, II, III, IV, VI, and VII H.R. 5297, Small Business Jobs Act of 2010, including the Johanns amendment, the Nelson amendment, as well as issues related to 1099 information reporting H.R. 847, James Zadroga 9/11 Health and Compensation Act of 2010, including provisions related to Title III H.R. 1322, Emergency Retiree Health Benefits Protection Act of 2009 H.R. 422, To amend the Internal Revenue Code of 1986 to extend the research credit through 2010 and to increase and make permanent the alternative simplified research credit H.R. 5486, Small Business Jobs Tax Relief Act of 2010 H.R. 4849, Small Business and Infrastructure Jobs Tax Act of 2010 H.R. 436, Certain Estate Tax Relief Act of 2009 H.R. 3463, Death Tax Repeal Permanency Act of 2009 H.R. 4213, Unemployment Compensation Extension Act of 2010 H.R. 4154, Permanent Estate Tax Relief for Families, Farmers, and Small Businesses Act of 2009 H.R. 6415, Tax Relief Certainty Act H.R. 275 / S. 292, Withholding Tax Relief Act of 2009, including provisions related to repealing the 3% Tax Withholding Law H.R. 5141 / S. 3578, Small Business Paperwork Mandate Elimination Act, including provisions related to 1099 information reporting H.R. 1265 / S. 506, Stop Tax Haven Abuse Act Extension of Bush tax cuts (expiring 2001 and 2003) Issues related to estate tax, deferral, net operating loss, executive compensation, LIFO, research & development, limitation on the deductibilty of treaty benefits, transfer pricing, earnings stripping, dual capacity foreign tax credit, 2001 and 2003 tax extenders, unemployment, insurance, active finance, CFC look-through, AMT, a financial crisis responsibility fee, IRS 2010-0 reporting of uncertain tax positions, marginal income tax rates, estate tax reform, capital gains and dividend tax rates (specific legislation not yet introduced) Continued from pg # 17: Cholly Smith - Legislative Assistant, Rep. Mark Kirk; Legislative Correspondent, Rep. Mark Kirk

Client expense: $36,360,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Election Commission (FEC), Federal Reserve System, Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Justice, Dept of (DOJ), Labor, Dept of (DOL), Maritime Administration (MARAD), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), St. Lawrence Seaway Development Corporation, State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR), White House Office

S 253 - Fix Housing First Homebuyer Tax Credit; S 823 - Net Operating Loss Carryback Act; Obama Administration Budget, provisions relating to increasing taxes on US companies competing for business in international markets; HR 1265 - Stop Tax Haven Abuse Act; S 506 - Stop Tax Haven Abuse; Proposed increase of the Harbor Maintenance Tax; Proposed Research and Development Tax Credit. Separate return limitation year rules to net operating loss proposal HR 5297- The Small Business Jobs and Credit Act of 2010, HR 4849 - The Small Business and Infrastructure Jobs Tax Act of 2010, S 3513 - The Bonus Depreciation Extension to Create Jobs Act, HR 4213 - The American Jobs and Closing Tax Loopholes Act of 2010

Client expense: $110,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)

S. 506 - Stop Tax Haven Abuse Act (entire bill); international tax reform, repeal and deferral generally; and H.R. 4213 - Tax Extenders Act of 2009 and H.R. 4853Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act (extension of the R&D Tax Credit, Alcohol Excise Tax, and CFC look through rules).

Client expense: $879,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 506/HR 1265, Stop Tax Haven Abuse Act tax deferral issues taxation of offshore income excise tax of medical devices

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 1265, HR 2452, HR 3424, HR 4853, HR 4951, S 506, S 823

Client expense: $810,000 · Firm income: Not reported

Government targets: Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of