National Disaster Tax Relief Act of 2014

H.R. 1, Tax Reform Act of 2014 H.R. 3950, To amend the Internal Revenue Code of 1986 to extend for one year the credit for energy-efficient existing homes. H.R. 3995, To amend the Internal Revenue Code of 1986 to extend the deduction for mortgage insurance premiums. H.R. 4117, To amend the Internal Revenue Code of 1986 to expand the earned income tax credit. H.R. 4130, To amend the Internal Revenue Code of 1986 to encourage mixed-income housing development. H.R. 4326, To amend the Internal Revenue Code of 1986 to provide a refundable credit against income tax to assist individuals with high residential energy costs. H.R. 4329, To reauthorize the Native American Housing Assistance and Self-Determination Act of 1996, and for other purposes. H.R. 4365, To amend the Internal Revenue Code of 1986 to permanently extend the new markets tax credit, and for other purposes. H.R. 4717, To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program H.R. 4941, To amend the Internal Revenue Code of 1986 to provide for the establishment of Promise Zones. H.R. 5082, To provide tax relief for major disaster areas declared in 2012, 2013, and 2014, and for other purposes. H.R. 5198, To amend the Internal Revenue Code of 1986 to provide an appeal process for designation as qualified census tracts and difficult development areas under the low-income housing credit. H.R. 5222, Rental Assistance Housing Preservation and Rehabilitation Act of 2014 H.R. 5299, To amend the Internal Revenue Code of 1986 to allow an enhanced credit for the rehabilitation of buildings located in low-income communities. H.R. 5655, To amend the Internal Revenue Code of 1986 to expand the rehabilitation credit, and for other purposes. S. 1133, New Markets Tax Credit Extension Act of 2013 S. 1442, Improving the Low Income Housing Tax Credit Rate Act S. 2003, A bill to amend the Internal Revenue Code of 1986 to extend the energy credit for certain property under construction. S. 2059, A bill to amend the Internal Revenue Code of 1986 to allow a credit for the purchase of heating and cooling equipment which meets the Energy Star program requirements and is used in certain high-cost energy communities, and for other purposes. S. 2233, National Disaster Tax Relief Act of 2014 S. 2388, A bill to amend the Internal Revenue Code of 1986 to modify the depreciation recovery period for energy-efficient cool roof systems, and for other purposes. S. 2634, National Disaster Tax Relief Act of 2014

Client expense: $155,182 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.2645 - A bill to extend the temporary suspension of duty on certain catalytic converter mounting mats S.2644 - A bill to suspend temporarily the duty on certain catalytic converter mats of glass fibers S.2643 - A bill to extend the temporary suspension of duty on perfluorobutanesulfonyl fluoride S.2642 - A bill to suspend temporarily the duty on certain polycrystalline fibersS.2641 - A bill to extend the temporary suspension of duty on fluoropolymers containing 95 percent or more by weight of the monomer units tetrafluoroethylene, hexafluorpropylene, and vinylidene fluoride. S.2640 - A bill to suspend temporarily the duty on potassium persulfate encapsulated in cellulose acetate butyrate. S.2639 - A bill to suspend temporarily the duty on bisphenol A Bis (3-methacryloyloxypropyl) either substituted dimethacylate. S.2638 - A bill to suspend temporarily the duty on copoly (acrylic acid/itaconic acid). S.2637 - A bill to extend the temporary suspension of duty on C1-3 perfluoroalkyl perfluoromorpholine. S.2636 - A bill to extend the temporary suspension of duty on mixtures of C5-18 perfluorocarbon alkanes, perfluorocarbon armines, and/or perfluorocarbon ethers. S.2635 - A bill to extend the temporary suspension of duty on C5-8 perfluorocarbon alkanes. S.2634 - A bill to extend the temporary suspension of duty on perfluorocarbon amines.

Client expense: $1,500,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Highway Administration (FHA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. International Trade Commission (ITC), U.S. Trade Representative (USTR)

Tax Reform, Tax Reform Act of 2014, Senate Finance Committee Tax Reform Discussion Drafts, Comprehensive Tax Reform Act of 2014, H.R. 1, S. 1090, H.R. 2253; (e.g., alternative minimum tax (AMT), education incentives (H.R. 3393), information reporting, Real Time Tax System, earned income tax credit, phase-outs, Kiddie Tax, depreciation, retirement plan options, inflation adjustments, unused provisions deadwood, the Tax Gap, Section 9100 relief, and terms with multiple definitions in the Internal Revenue Code), House Ways and Means Committee draft Tax Reform Act of 2014, small business pass-through tax reform; Tax penalties (e.g., the definition of tax shelters; significant purpose; reasonable cause exception to penalties under sections 6707A and 6662A; reasonable cause exception to the section 6676 penalty for erroneous claim for refund or credit; and Form 3520 and 3520-A penalties); Identity theft (e.g., truncated taxpayer identification numbers (TTINs) and S. 149, Stop Identity Theft Act of 2013 and H.R. 295; Identity Theft and Tax Fraud Prevention Act of 2013, S. 676; Tax Refund Theft Prevention Act of 2014, S. 2736); IRS authority over tax preparers, H.R. 1570 and potential amendment to Senate The Preserving Americas Transit and Highways Act; preparer tax identification numbers (PTIN) registration process, voluntary certification program; Cash basis method of accounting; Due dates of tax returns (H.R. 901 and S. 420); (e.g., six-month automatic extension for entire Form 990 series and other information, excise and income tax returns of exempt organizations); Mobile Workforce State Income Tax Simplification Act (H.R. 1129, S. 1645); Permanent disaster relief; Hurricane Sandy Tax Relief, HR 2137; National Disaster Tax Relief Acto of 2014, S. 2634; IRS weather-related impacts in filing due dates; Standardize the allowable mileage rates for business expense, medical expense and charitable contribution purposes; IRS Budget; Administrations fiscal year 2015 revenue proposals; Form 1099B and Form 8949; Form 1040 Questions on Schedule E relating to Form 1099 requirement; Guidance on tax issues for same-sex couples and registered domestic partners; Net investment income tax (Sec. 1411), threshold/bracket for estates for net-investment income tax and regular income tax, applicability of net investment income tax to bona fide residents of U.S. mirror tax code territories; Allow certain attorney fees and court costs as deductions for adjusted gross income (AGI); Clarify and simplify reporting of cancellation of debt income (Sec. 6050P); Provide parity for employees and self-employed individuals on the deduction of health insurance costs; Remove reference to section 332 from section 367(a)(i); Repeal the section 7122(c)(1) requirement to provide a 20 percent partial payment with a lump-sum offer in compromise; Allow transfer of partnership suspended losses to one another when spousal transfers under section 1041(a) tax place; Target allocations for partnerships; Clarify that husband and wife partnerships are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day post-termination transition period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Related party debt (proposed regulations on Sec. 752); Form 1120S; Repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S corporations under 1375(a)(2) from 25 percent to 60 percent; Qualified terminable interest property (QTIP) election relief; Treat consistently all federal tax payments of trusts and estates; 9100 relief; Mexican land trust (Fideicomisos); Amend section 67(e) to simplify the law and allow estates and nongrantor trusts to fully deduct the cost of complying with fiduciary duties in administering estates and trusts; Exempt from the filing requirement of section 6034(a) trusts with charitable deductions only from flow-through entities; Reinstate and make permanent the fair market value exception under section 512(b)(13) and remove the binding contract requirement; Expand the exception from section 509(f)(2), which prohibits an organization from qualifying for section 509(a)(3) status if it accepted certain gifts, to be consistent with the technical change made to section 4958(c)(3)(C); Form 990 and instructions; Form 3115; Interactive Form 1023; e-filing for exempt organizations; Public disclosure of information on exempt organization forms; Top-heavy rules; Repeal full vesting on partial termination of qualified retirement plans; Speaking with Government Accountability Office (GAO) on retirement plan sponsor reporting and disclosure requirements, and issues pertaining to electronic disclosure of content to participants; Mid-year amenders on safe harbor plans; Use of forfeitures on making certain qualified contributions; Foreign Account Tax Compliance Act (FATCA); PFICs; Automatic penalties assessed on Form 5471; TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) and its e-filing requirements; The Retail Inventory Method; Rev. Proc. 97-27; Tangible personal property guidance repair regulations (Sec. 263A); Proposed Regulations to Amend the Definition of Research and Experimental Expenditures under Section 174; Estimated taxes for corporations and success based fees; Internal Revenue Services release in the delay of tax forms and abatement of penalties for late payment of tax; IRS preparer compliance visits; IRS e-signature standards; Uncertain tax positions (UTP); Sec. 7212; Individual taxpayer identification numbers (ITINs); Form 1099-K, credit card and receipts reconciliation; Form 8937 (form used to report organizational actions affecting basis);Amended Forms 1099; IRS e-services; IRC section 1298 (f) filing requirements; Enrolled Agents, S. 1134, H.R. 2313; Affordable Care Act (e.g., auto-enrollment issues; implementation issues; Play or Pay rules; small business health care tax credit; information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans, information reporting of minimum essential coverage, and related information and tax forms); Interest Rate Determination Method (adjusted AFRs/Long-term tax-exempt rates); Estate Tax Expat Issues, S. 744, immigration reform; Rev. Proc. 99-6; Technical termination rules (Sec. 708, Sec. 197); State Sales Tax Collection/Marketplace Fairness Act (MFA), S. 336, S. 743, HR 684; Rev. Proc. 97-27 (non-automatic changes in method of accounting); Accounting method changes (Sec. 381); Extend expiring tax provisions; Tax Increase Prevention Act of 2014, H.R. 5771; A de minimis threshold for small taxpayers (Sec. 382 NOL Limitation); Modifying the enhanced deduction rules for charitable contribution of inventory; Repeal of the anti-churning rules under sec. 197(f)(g); Modify the definition of W-2 wages for purposes of sec. 199; Modify the rules for capitalization and inclusion in inventory costs for certain expenses under section 263A; Allow an offset to the built-in gains tax for charitable contribution and foreign tax credit carryforwards from a C year; Add a new 120-day Post-Termination Transition Period (PTTP) beginning on the date that a taxpayer files an amended Form 1120S; Allow S corporations to have nonresident aliens as shareholders and potential current beneficiaries of electing small business trusts; Repeal section 1362(d)(3), which terminates an S election due to passive investment income that exceeds a certain threshold, or increase the passive investment income (PII) threshold of S-corporations under section 1375(a)(2) from 25% to 60%; Repeal section 1372; Sec. 174 research and experimental expenditures; Department of the Treasury Priority Guidance Plan; Expired tax provisions (extenders); Tax treaties; Multi-State Worker Tax Fairness Act (H.R. 4085).

Client expense: $1,130,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Financial Crimes Enforcement Network (FinCEN), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of