CUT Loopholes Act

Monitor developments related to the carried interest. Administration's Proposals on carried interest. Clarify enterprise value definition in carried interest legislation. S.268, CUT Loopholes Act. Monitor developments related to the Camp Tax Proposal. Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act, S.2260.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 1465 and H.R. 3331, Incorporation Transparency and Law Enforcement Assistance Actprovisions requiring states, certain businesses, and company formation agents to obtain and disclose beneficial ownership information regarding new companies and subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act.Department of the Treasury Financial Crimes Enforcement Network Advance Notice of Proposed Rulemaking on Customer Due Diligence Requirements for Financial Institutions, RIN 1506-AB25, Docket Number FINCEN-2014-0001, 77 Fed. Reg. 45151 (August 4, 2014)provisions requiring law firms that establish accounts at financial institutions on behalf of clients to disclose the identity and beneficial ownership information regarding those clients S.1533 and H.R.1554, Stop Tax Haven Abuse Actprovisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act S. 268, Cut Unjustified Tax Loopholes Actprovisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act H.R. 3666, the Sequester Delay and Stop Tax Haven Abuse Act - provisions subjecting lawyers that act as formation agents to anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act

Client expense: $190,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Congressional Budget Office (CBO), Defense, Dept of (DOD), Education, Dept of, Federal Bureau of Investigation (FBI), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Legal Services Corporation, Natl Security Agency (NSA), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), White House Office

Carried Interest Tax Treatment S268 - Cut Unjustified Tax Loopholes ActState and Local Use Tax Laws for Remote Sellers S336 - Marketplace Fairness Act S743 - Marketplace Fairness Act HR684 - Marketplace Fairness Act Tax Relief for Forgiven Mortgage Debt HR2788 - Mortgage Forgiveness Tax Relief Act HR2994 - Mortgage Forgiveness Tax Relief Act of 2013 S1187 - Mortgage Forgiveness Tax Relief Act of 2013 Tax Incentives for Safety Upgrades in Commercial Buildings S1163 - Fire Sprinkler Incentive Act Foreign Investment In Real Property Tax Relief Act Modifications HR2870 - Real Estate Investment and Jobs Act of 2013 S1181- Real Estate Investment and Jobs Act of 2013 Commercial Building Energy Deductions HR2189 - Energy Efficiency Tax Incentives Act S2260 - The EXPIRE Act of 2014 Internet Tax Freedom HR3086 - The Permanent Internet Tax Freedom Act Tax Relief for Small Businesses HR4457 - America's Small Business Tax Relief Act of 2014 Discussions with the Department of the Treasury on IRC Section 1031 Like-Kind Exchanges.

Client expense: $13,400,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Natl Economic Council (NEC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, Veterans Affairs, Dept of (VA)

H.R. 1, Tax Reform Act of 2014 H.R. 4, Jobs for America Act H.R. 30, Small Business Investment Enhancement and Tax Relief Act H.R. 83, Consolidated and Further Continuing Appropriations Act, 2015, including provisions relating to procurement policy, Buy America, inversion contracting matters, and contractor blacklisting H.R. 516, Middle Class Payroll Tax Relief Act H.R. 523, Protect Medical Innovation Act of 2013 H.R. 684 / S. 336 / S. 743, Marketplace Fairness Act of 2013 H.R. 694, Corporate Tax Fairness Act H.R. 763, To repeal the annual fee on health insurance providers enacted by the Patient Protection and Affordable Care Act H.R. 766 / S. 321, Paying a Fair Share Act of 2013 H.R. 851 / S. 337 / S. 2569 , Bring Jobs Home Act H.R. 886, America's Small Business Tax Relief Act of 2013 H.R. 3724 / S. 1364, Digital Goods and Services Tax Fairness Act of 2013 H.R. 4438, American Research and Competitiveness Act of 2014 H.R. 4453, S Corporation Permanent Tax Relief Act of 2014 H.R. 4457, America's Small Business Tax Relief Act of 2014 H.R. 4718, To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation H.R. 4923, Energy and Water Development and Related Agencies Appropriations Act, 2015, including provisions relating to procurement policy, inversion contracting matters, and contractor blacklisting H.R. 5016, Financial Services and General Government Appropriations Act, 2015, including provisions relating to procurement policy, inversion contracting matters, and contractor blacklisting H.R. 5278 / S. 2704, No Federal Contracts for Corporate Deserters Act of 2014 H.R. 5771, Tax Increase Prevention Act of 2014 S. 193, Startup Innovation Credit Act of 2013 S. 250, Corporate Tax Dodging Prevention Act S. 268, CUT Loopholes Act S. 277, Job Prevention and Economic Certainty Act of 2013 S. 278, Job Preservation and Sequester Replacement Act of 2013 S. 388, American Family Economic Protection Act of 2013 S. 410, Wall Street Trading and Speculators Tax Act S. 2260, EXPIRE Act of 2014 S. 2432, Bank on Students Emergency Loan Refinancing Act S. 2736, Tax Refund Theft Prevention Act of 2014, including provisions relating to section 11, lowering the threshold for electronic filings with the IRS and section 12, reducing the time in which small businesses have to file a return S. 2786, Corporate Inverters Earnings Stripping Reform Act of 2014 Draft legislation titled Remote Transaction Parity Act of 2014 Various issues relating to the implementation of Middle Class Tax Relief and Job Creation Act of 2012 (P.L. 112-96); implementation of the Housing and Economic Recovery Act of 2008 (P.L. 110-289), including Section 3091 - provisions relating to data collection and return requirements; Chairman Goodlattes principles governing sales tax collection legislation; Senator Levins Management and Control corporate residency proposal; comprehensive tax reform, including House Ways and Means Committee working drafts and Chairman Camps comprehensive draft bill; tax extenders including R&D tax credit, bonus depreciation, exemptions for active financing income, deferral tax provisions, S-Corp tax provisions, and Section 179 expensing limits; international competiveness of corporate tax rates; legislative proposals on corporate tax inversions; Alternative Minimum Tax (AMT); extension of unemployment insurance; House Judiciary Committee Principles on Internet Sales Tax; tax reform; entitlement reform; tax inversion; tax gap and small business paperwork and compliance burdens; sequestration; interpretation of IRS Rule 305(c); IRS efforts to evaluate the effectiveness of the 1099-K pilot matching program

Client expense: $21,250,000 · 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), Consumer Product Safety Commission (CPSC), Council on Environmental Quality (CEQ), 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 Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Food & Drug Administration (FDA), General Services Administration (GSA), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Fish & Wildlife Service (USFWS), U.S. Forest Service, U.S. Trade Representative (USTR), White House Office

Monitor developments related to the carried interest and publicly traded partnerships. Administration's Proposals on carried interest. Clarify enterprise value definition in carried interest legislation. S.268, Cut Loopholes Act. Monitor developments related to the Camp Tax Proposal.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

W&M international tax reform draft. White House and Treasury Department tax principles white paper. H.R. 8, the American Taxpayer Relief Act of 2012 specifically related to the R&D credit, the active financing exception under Subpart F, and the CFC look-through rule. Ways & Means tax reform working groups; proposals related to Subpart F; Tax Equity for Health Plan Beneficiaries. Comprehensive Tax Reform; S. 268, CUT Loopholes Act; White House and Treasury Department tax principles white paper and Administration FY2014 Budget; H.CON.RES.25/S.CON.RES.8, Establishing the budget for the United States Government for fiscal year 2014. H.J. Res. 59, Bipartisan Budget Act. H.R. 1129/S. 1645, Mobile Workforce; S. 1859, Tax Extenders Act of 2013; H.R. 1554/S. 1533, Stop Tax Haven Abuse Act; H.R. 3086/S. 1431, Internet Tax Freedom Forever Act; S. 728/H.R. 2499, Tax Parity for Health Plan Beneficiaries Act of 2013; S. 1364, Digital Goods and Services Tax Fairness Act of 2013; Business Tax Extenders; Ways and Means International Tax Draft Legislation. H.R. 4429, Permanent Active Financing Exception; H.R. 4438 Permanent R&D Tax Credit; H.R. 4464 Permanent Controlled-Foreign-Corporation Look Through Rule; S. 2260 Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act; H.R. 3086/S. 1431 permanently extend the Internet Tax Freedom Act. H.R. 5771, Tax Increase Prevention Act of 2014.

Client expense: $1,190,818 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council of Economic Advisers (CEA), Defense, Dept of (DOD), Education, Dept of, Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Economic Council (NEC), Natl Science Foundation (NSF), Office of Science & Technology Policy (OSTP), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

HR 6, HR 2772, HR 3094, HR 2262, HR 2653, HR 351, HR 4543, S 391, S 268, S 1696

Client expense: $57,351 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

Monitor matters related to publicly traded partnerships; S. 268 / H.R. 1554, the Cut Loopholes Act; S. 1533 on curtailing tax shelters; and comprehensive tax reform legislatives activities.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Effort to amend the Internal Revenue Code of 1986 to increase the alternative tax liability limitation for small property and casualty insurance companies - S. 1346/H.R. 4647, all provisions H.R.549: Homeowner Catastrophe Protection Act of 2013, all provisions H.R. 1129: Mobile Workforce State Income Tax Simplification Act Taxation of property/casualty insurance, all provisions S. 268 CUT Loopholes Act, all provisions S.2260 - EXPIRE Act of 2014, all provisions H.R. 694 Corporate Tax Fairness Act, all provisions Chairman Camp's Tax Reform Discussion Draft (Sec. 3124, 3508, 3510) and Efforts to amend and reform the current tax code with respect to general business and the business of insurance, all provisions H.R.4457 - America's Small Business Tax Relief Act of 2014, all provisions H.R.4438 - American Research and Competitiveness Act of 2014, all provisions

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

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

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities. Support maintaining current law regarding: (1) the tax treatment of carried interest; (2) the full deductibility of business interest; (3) the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds; (4) the permanent estate tax rules enacted in January 2013; (5) Section 1031 like-kind exchanges; (6) the 27.5-year depreciation period for multifamily buildings; (7) depreciation recapture; and (8) the deductibility of state and local real estate taxes. Finally, we favor: (1) loosening FIRPTA rules to incent foreign investment in U.S. real estate; and (2) expanding incentives for energy efficiency in commercial buildings (i.e., Internal Revenue Code Section 179D). H.R. 1, Tax Reform Act of 2014. Section 1001: Simplification of individual income tax rates. Section 1002: Deduction for adjusted net capital gain. Section 1405: Repeal of deduction for taxes not paid or accrued in a trade or business. Section 1502: Determination of net earnings from self employment. Section 3104: Reform of accelerated cost recovery system. Section 3113: Repeal of deduction for energy efficient commercial buildings. Section 3133: Repeal of like-kind exchanges. Section 3139: Depreciation recapture on gain from disposition of certain depreciable realty. Section 3204: Low-income housing tax credit. Section 3217: Repeal of new energy efficient home credit. Section 3431: Termination of private activity bonds. Section 3621: Ordinary income treatment in the case of partnership interest held in connection with performance of services. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions. Section 2: Repeal of Certain Specialized Expensing Provisions (i.e., Section 179D). Section 11: Pooled Asset Cost Recovery System and Depreciation of Real Property. Section 12: Rules Related to Treatment of Gains from Depreciable Property. Section 15: Repeal of Like-Kind Exchanges. Obama Administration's Fiscal Year 2015 Budget Revenue Proposal to Modify Like-Kind Exchange Rules for Real Property. Also, asked that the Obama Administration not include this proposal in its forthcoming FY 2016 Budget. Expiring Tax Provisions H.R. 5771, Tax Increase Prevention Act of 2014. Section 112: Extension of temporary minimum low-income housing tax credit rate for non-Federally subsidized buildings. Section 113: Extension of military housing allowance exclusion for determining whether a tenant in certain counties is low-income. Section 115: Extension of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension of increased expensing limitations and treatment of certain real property as section 179 property. Section 156: Extension of Credit for Energy Efficient New Homes. Section 158: Extension of Energy Efficient Commercial Buildings deduction. S. 2260, Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. Carried Interest S. 268, Cut Unjustified Tax Loopholes Act, Title VI, Ending the Carried Interest Loophole (Section 601: Short Title. Section 602: Partnership Interests Transferred in Connection with Performance of Services. Section 603: Special rules for Partners Providing Investment Management Services to Partnerships.) Low-Income Housing Tax Credit (LIHTC) H.R. 4717, to make permanent and expand the minimum rate for the LIHTC, all provisions. S. 1442, Improving the Low Income Housing Tax Credit Rate Act, to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings, all provisions. Obama Administration's Fiscal Year 2015 Budget Revenue Proposal to Encourage Mixed Income Occupancy by Allowing Low-Income Housing Tax Credit-Supported Projects to Elect a Criterion Employing a Restriction on Average Income We also considered proposals to expand the credit, such as ones to increase the program by 50% or convert private activity bonds into Low-Income Housing Tax Credits. Energy Tax Incentives S. 2189, the Energy Efficiency Tax Incentives Act. Section 101: Extension and modification of deduction for energy-efficient commercial buildings. Section 102. Deduction for retrofits of existing commercial and multifamily buildings. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2870, Real Estate Investment and Jobs Act of 2013, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. S. 1181, Real Estate Investment and Jobs Act of 2013, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. Amendment filed by Senators Menendez and Enzi to draft legislation before the Senate Finance Committee, Preserving Americas Transit and Highways Act, which would remove the tax penalty FIRPTA imposes on foreign pension funds investing in U.S. real estate and increase the ownership stake a foreign investor can take in a publicly traded company whose assets consist largely of U.S. real property without triggering FIRPTA. H.R. 5487, Real Estate Investment and Jobs Act of 2014, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property interests, all provisions. Treasury Regulations REG-119305-11: This document contains proposed regulations under section 707 of the Internal Revenue Code relating to disguised sales of property to, or by, a partnership and under section 752 relating to the treatment of partnership liabilities.

Client expense: $430,500 · Firm income: Not reported

Government targets: Army, Dept of (Corps of Engineers), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), President of the U.S., SENATE, Small Business Administration (SBA), Social Security Administration (SSA), Treasury, Dept of, U.S. Postal Service (USPS)

Tax reform issues HR 2084, S 1957 - Partnership to Build America Act of 2014 HR 2429, S 1183 - Death Tax Repeal Act HR 694, S 250, S 268, S 307 - Corporate Tax Reform, including various corporate tax loopholes HR 4679 - Stop Corporate Tax Inversions Act, reduced tax benefits for inverted firms Repatriation tax rate and rules Refundable low-income ARRA tax credits HR 5771 - Tax extenders Tax extenders, including the specific issues of Active Financing Exception; CFC Look-Through Rule; Research & Experimentation Tax Credit; Bonus Depreciation; Section 179 Expensing Limit on individual itemized deductions and selected exclusions Federal income tax deduction for state and local government taxes Commuter Parity Act of 2013 - Federal income tax exclusion for employer-sponsored mass transit commuter benefits Federal income tax exclusion for interest on state and local government public purpose bonds Federal tax reform impact on state and local government revenues Reduced tax rates on capital gains and dividends Corporate taxes, including rates, loopholes, repatriation, territorial S 1533 - Stop Tax Haven Abuse Act S 743, HR 684, S 2609 - Marketplace Fairness Act, (i.e. state and local taxes on internet and remote sales tax) HR 3086, S 1431, Internet Tax Freedom Act - state and local taxes on internet access HR 3724, S 1364 - Digital Goods and Services Tax Fairness Act HR 2992 - Business Activity Tax Simplification Act HR 1129 - Mobile Workforce State Income Tax Simplification Act HR 2309, S 1235 - Wireless Tax Fairness Act of 2013 S 410 and in general - Financial Transaction Tax Medical Device Tax

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

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), SENATE, U.S. Trade Representative (USTR), White House Office

Misc. tax issues including foreign reinsurance and other corporate tax matters; the Presidents Fiscal Year 2015 Budget Proposal; HR 2054 (Neal); S 991 (Menendez); S 268 (Levin); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); HR 1 (Camp). HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General corporate and international tax issues and issues related to international tax reform; the Presidents Fiscal Year 2015 Budget; S 268 (Levin); S 250 (Sanders); S 277 (Whitehouse); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett). HR 4985 (Van Hollen), HR 4679 (Levin), S 2260 (Wyden) and S 2360 (Levin).

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

Government targets: Natl Economic Council (NEC), Treasury, Dept of, White House Office

General corp. and intl tax issues; the Presidents Fiscal Year 2015 Budget Proposal; S 268 (Levin); S 250 (Sanders); S 277 (Whitehouse); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); HR 1 (Camp). HR 4438 (Brady) S 2260 (Wyden), and HR 5771 (Camp).

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

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

Misc. tax issues including foreign reinsurance, corporate information reporting, and other corporate tax matters; the Presidents Fiscal Year 2015 Budget Proposal; HR 2054 (Neal); S 991 (Menendez); S 268 (Levin); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); HR 1 (Camp). HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin).

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

Government targets: SENATE

General corporate and international tax issues; the Presidents Fiscal Year 2015 Budget Proposal; S 268 (Levin), S 250 (Sanders); S 707 (Reed); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); HR 1 (Camp); HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin); S. 2895 (Brown), H.R. 5549 (Doggett); S. 2786 (Schumer).

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

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of, White House Office

Misc. tax issues; tax issues related to foreign insurance and reinsurance; the Presidents Fiscal Year 2015 Budget Proposal; HR 2054 (Neal); HR 1554 (Doggett); HR 1555 (Doggett); S 991 (Menendez); S 268 (Levin); S 1533 (Levin); HR 1 (Camp). HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax reform, Senate Finance and House Ways and Means, specifically S. 268, S. 1533, S. 250, H.R. 1554, H.R. 2084, S. 1654, H.R. 3445, H.R. 4678, S. 2360, tax extenders

Client expense: $19,835 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Please see addendum.Issues related to the federal income tax exemption for credit unions Issues related to unrelated business income tax and the revised Form 990 Issues related to the tax treatment of mortgage interest Issues related to the Foreign Account Tax Compliance Act (FATCA) Issues related to the Camp Tax Reform proposal H.R. 243, Bowles-Simpson Plan of Lowering Americas Debt Act, all provisions H.R. 892, the S Corporation Modernization Act, all provisions S. 268, Cut Unjustified Tax (CUT) Loopholes Act, all provisions S. 887, a bill to repeal the violation of sovereign nations laws and privacy matters, all provisions

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

Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities. Support maintaining current law regarding: (1) the tax treatment of carried interest; (2) the full deductibility of business interest; (3) the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds; (4) the permanent estate tax rules enacted in January 2013; (5) Section 1031 like-kind exchanges; (6) the 27.5-year depreciation period for multifamily buildings; (7) depreciation recapture; and (8) the deductibility of state and local real estate taxes. Finally, we favor: (1) loosening FIRPTA rules to incent foreign investment in U.S. real estate; and (2) expanding incentives for energy efficiency in commercial buildings (i.e., Internal Revenue Code Section 179D). House Ways and Means and Committee Chairman's Discussion Draft on Tax Reform: Tax Reform Act of 2014. Section 1001: Simplification of individual income tax rates. Section 1002: Deduction for adjusted net capital gain. Section 1405: Repeal of deduction for taxes not paid or accrued in a trade or business. Section 1502: Determination of net earnings from self employment. Section 3104: Reform of accelerated cost recovery system. Section 3113: Repeal of deduction for energy efficient commercial buildings. Section 3133: Repeal of like-kind exchanges. Section 3139: Depreciation recapture on gain from disposition of certain depreciable realty. Section 3204: Low-income housing tax credit. Section 3217: Repeal of new energy efficient home credit. Section 3431: Termination of private activity bonds. Section 3621: Ordinary income treatment in the case of partnership interest held in connection with performance of services. Senate Committee on Finance Chairman's Staff Discussion Draft on Provisions to Reform International Business Taxation. Section 93: Modification to Tax on Foreign Investments in United States Real Property Interests. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions. Section 2: Repeal of Certain Specialized Expensing Provisions (i.e., Section 179D). Section 11: Pooled Asset Cost Recovery System and Depreciation of Real Property. Section 12: Rules Related to Treatment of Gains from Depreciable Property. Section 15: Repeal of Like-Kind Exchanges. Obama Administration's Fiscal Year 2015 Budget Revenue Proposal to Modify Like-Kind Exchange Rules for Real Property. Expiring Tax Provisions S. 2260, Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. H.R. 4457, America's Small Business Tax Relief Act of 2014. Section 2: Expensing certain depreciable assets for small business. H.R.4718, to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation, all provisions. Carried Interest S. 268, Cut Unjustified Tax Loopholes Act, Title VI, Ending the Carried Interest Loophole (Section 601: Short Title. Section 602: Partnership Interests Transferred in Connection with Performance of Services. Section 603: Special rules for Partners Providing Investment Management Services to Partnerships Low-Income Housing Tax Credit (LIHTC) H.R. 4717, to make permanent and expand the minimum rate for the LIHTC, all provisions. S. 1442, Improving the Low Income Housing Tax Credit Rate Act, to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings, all provisions. We also (1) support making the LIHTC more flexible by allowing developments to qualify if 40 percent of units go to families with incomes that average no more than 60 percent of area median income; and (2) considered proposals to expand the credit, such ones to increase the program by 50% or convert private activity bonds into Low-Income Housing Tax Credits. Energy Tax Incentives S. 2189, the Energy Efficiency Tax Incentives Act. Section 101: Extension and modification of deduction for energy-efficient commercial buildings. Section 102. Deduction for retrofits of existing commercial and multifamily buildings. S. 2388, Energy-Efficient Cool Roofs Act, to modify the depreciation period for energy-efficient cool roofs, all provisions. H.R. 4740, Roofing Efficiency Jobs Act of 2014, to modify the depreciation period for energy-efficient cool roof systems, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2870, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. S. 1181, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. Draft legislation before the Senate Finance Committee: Preserving America's Transit and Highways Act of 2014, provisions regarding mortgage reporting and FIRPTA. Treasury Regulations REG-119305-11: This document contains proposed regulations under section 707 of the Internal Revenue Code relating to disguised sales of property to, or by, a partnership and under section 752 relating to the treatment of partnership liabilities.

Client expense: $440,000 · Firm income: Not reported

Government targets: Army, Dept of (Corps of Engineers), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), Treasury, Dept of, U.S. Postal Service (USPS), White House Office

Monitor developments related to the carried interest. Administration's Proposals on carried interest. Clarify enterprise value definition in carried interest legislation. S.268, CUT Loopholes Act. Monitor developments related to the Camp Tax Proposal. Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act, S.2260.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 4, Jobs for America Act H.R. 30, Small Business Investment Enhancement and Tax Relief Act H.R. 516, Middle Class Payroll Tax Relief Act H.R. 523, Protect Medical Innovation Act of 2013 H.R. 684 / S. 336 / S. 743, Marketplace Fairness Act of 2013 H.R. 694, Corporate Tax Fairness Act H.R. 763, To repeal the annual fee on health insurance providers enacted by the Patient Protection and Affordable Care Act H.R. 766 / S. 321, Paying a Fair Share Act of 2013 H.R. 851 / S. 337 / S. 2569 , Bring Jobs Home Act H.R. 880 / S. 410, Wall Street Trading and Speculators Tax Act H.R. 886, Americas Small Business Tax Relief Act of 2013 H.R. 2546 / S. 1257, Protect American Investments Act of 2013 H.R. 3724 / S. 1364, Digital Goods and Services Tax Fairness Act of 2013 H.R. 4438, American Research and Competitiveness Act of 2014 H.R. 4453, S Corporation Permanent Tax Relief Act of 2014 H.R. 4457, America's Small Business Tax Relief Act of 2014 H.R. 4718, To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation, including provisions relating to modifying and making permanent 50% depreciation and the Alternative Minimum Tax (AMT) credit in lieu of 50% depreciation provisions H.R. 4923, Energy and Water Development and Related Agencies Appropriations Act, 2015, including provisions relating to procurement policy, inversion contracting matters, and contractor blacklisting H.R. 5016, Financial Services and General Government Appropriations Act, 2015, including provisions relating to procurement policy, inversion contracting matters, and contractor blacklisting H.R. 5278 / S. 2704, No Federal Contracts for Corporate Deserters Act of 2014 S. 193, Startup Innovation Credit Act of 2013 S. 250, Corporate Tax Dodging Prevention Act S. 268, CUT Loopholes Act S. 277, Job Prevention and Economic Certainty Act of 2013 S. 278, Job Preservation and Sequester Replacement Act of 2013 S. 388, American Family Economic Protection Act of 2013 S. 2260, EXPIRE Act of 2014 S. 2432, Bank on Students Emergency Loan Refinancing Act S. 2786, Corporate Inverters Earnings Stripping Reform Act of 2014 Draft Tax Reform Act of 2014 Various issues relating to the implementation of Middle Class Tax Relief and Job Creation Act of 2012 (P.L. 112-96); implementation of the Housing and Economic Recovery Act of 2008 (P.L. 110-289), including Section 3091 - provisions relating to data collection and return requirements; Chairman Goodlattes principles governing sales tax collection legislation; Senator Levins Management and Control corporate residency proposal; comprehensive tax reform, including House Ways and Means Committee working drafts and Chairman Camps comprehensive draft bill; tax extenders including R&D tax credit, bonus depreciation, exemptions for active financing income, deferral tax provisions, S-Corp tax provisions, and Section 179 expensing limits; international competitiveness of corporate tax rates; legislative proposals on corporate tax inversions; Alternative Minimum Tax (AMT); extension of unemployment insurance; House Judiciary Committee Principles on Internet Sales Tax; tax reform; entitlement reform; tax inversions; sequestration; online sales tax collection proposals

Client expense: $28,350,000 · 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), Consumer Product Safety Commission (CPSC), Council on Environmental Quality (CEQ), 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 Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Federal Trade Commission (FTC), Food & Drug Administration (FDA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Fish & Wildlife Service (USFWS), U.S. Forest Service, U.S. Trade Representative (USTR), White House Office

Carried Interest Tax Treatment S268 - Cut Unjustified Tax Loopholes ActState and Local Use Tax Laws for Remote Sellers S336 - Marketplace Fairness Act S743 - Marketplace Fairness Act HR684 - Marketplace Fairness Act Tax Relief for Forgiven Mortgage Debt HR2788 - Mortgage Forgiveness Tax Relief Act HR2994 - Mortgage Forgiveness Tax Relief Act of 2013 S1187 - Mortgage Forgiveness Tax Relief Act of 2013 Tax Incentives for Safety Upgrades in Commercial Buildings S1163 - Fire Sprinkler Incentive Act Foreign Investment In Real Property Tax Relief Act Modifications HR2870 - Real Estate Investment and Jobs Act of 2013 S1181- Real Estate Investment and Jobs Act of 2013 Commercial Building Energy Deductions HR2189 - Energy Efficiency Tax Incentives Act S2260 - The EXPIRE Act of 2014 Internet Tax Freedom HR3086 - The Permanent Internet Tax Freedom Act Tax Relief for Small Businesses HR4457 - America's Small Business Tax Relief Act of 2014 Discussions with the Department of the Treasury on cancellation of mortgage debt tax relief.

Client expense: $17,980,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Natl Economic Council (NEC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities. Support maintaining current law regarding: (1) the tax treatment of carried interest; (2) the full deductibility of business interest; (3) the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds; (4) the permanent estate tax rules enacted in January 2013; (5) Section 1031 like-kind exchanges; (7) the 27.5-year depreciation period for multifamily buildings; (7) depreciation recapture; and (8) the deductibility of state and local real estate taxes. Finally, we favor: (1) loosening FIRPTA rules to incent foreign investment in U.S. real estate and (2) expanding incentives for energy efficiency in commercial buildings (i.e., Internal Revenue Code Section 179D). House Ways and Means and Committee Chairman's Discussion Draft on Tax Reform: Tax Reform Act of 2014. Section 1001: Simplification of individual income tax rates. Section 1002: Deduction for adjusted net capital gain. Section 1405: Repeal of deduction for taxes not paid or accrued in a trade or business. Section 1502: Determination of net earnings from self employment. Section 3104: Reform of accelerated cost recovery system. Section 3113: Repeal of deduction for energy efficient commercial buildings. Section 3133: Repeal of like-kind exchanges. Section 3139: Depreciation recapture on gain from disposition of certain depreciable realty. Section 3204: Low-income housing tax credit. Section 3217: Repeal of new energy efficient home credit. Section 3431: Termination of private activity bonds. Section 3621: Ordinary income treatment in the case of partnership interest held in connection with performance of services. Senate Committee on Finance Chairman's Staff Discussion Draft on Provisions to Reform International Business Taxation. Section 93: Modification to Tax on Foreign Investments in United States Real Property Interests. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions. Section 2: Repeal of Certain Specialized Expensing Provisions (i.e., Section 179D). Section 11: Pooled Asset Cost Recovery System and Depreciation of Real Property. Section 12: Rules Related to Treatment of Gains from Depreciable Property. Section 15: Repeal of Like-Kind Exchanges. Expiring Tax Provisions S. 2260, Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. S. Amdt. 3060 to H.R. 3474, Expiring Provisions Improvement, Reform, and Efficiency (EXPIRE) Act of 2014. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. H.R. 4457, America's Small Business Tax Relief Act of 2014. Section 2: Expensing certain depreciable assets for small business. H.R.4718, to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation, all provisions. Carried Interest S. 268, Cut Unjustified Tax Loopholes Act, Title VI, Ending the Carried Interest Loophole (Section 601: Short Title. Section 602: Partnership Interests Transferred in Connection with Performance of Services. Section 603: Special rules for Partners Providing Investment Management Services to Partnerships Low-Income Housing Tax Credit & Renter Tax Credit H.R. 4479, to amend the Internal Revenue Code of 1986 to provide a renter's tax credit, all provisions. H.R. 4717, to make permanent and expand the minimum rate for the LIHTC, all provisions. S. 1442, Improving the Low Income Housing Tax Credit Rate Act, to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings, all provisions. We also (1) support making the LIHTC more flexible by allowing developments to qualify if 40 percent of units go to families with incomes that average no more than 60 percent of area median income; and (2) considered proposals to expand the credit, such ones to increase the program by 50% or convert private activity bonds into Low-Income Housing Tax Credits. Energy Tax Incentives S. 2189, the Energy Efficiency Tax Incentives Act. Section 101: Extension and modification of deduction for energy-efficient commercial buildings. Section 102. Deduction for retrofits of existing commercial and multifamily buildings. FIRPTA H.R. 2870, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. S. 1181, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. Draft legislation before the Senate Finance Committee: Preserving America's Transit and Highways Act of 2014, provisions regarding mortgage reporting and FIRPTA Treasury Regulations REG-119305-11: This document contains proposed regulations under section 707 of the Internal Revenue Code (Code) relating to disguised sales of property to, or by a partnership and under section 752 relating to the treatment of partnership liabilities.

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

Government targets: Army, Dept of (Corps of Engineers), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Social Security Administration (SSA), Treasury, Dept of, U.S. Postal Service (USPS)

H.R. 892, to amend the Internal Revenue Code of 1986 to provide for S corporation reform. H.R. 905, to amend the Internal Revenue Code of 1986 to make the research credit permanent and to increase the alternative simplified research credit. H.R. 1554, to restrict the use of offshore tax havens and abusive tax shelters to inappropriately avoid federal taxation, and for other purposes. H.R. 1555, to amend the Internal Revenue Code of 1986 to reduce international tax avoidance and restore a level playing field for American businesses. H.R. 1556, to prevent corporations from exploiting tax treaties to evade taxation of U.S. income. H.R. 2194, to improve access to health care through expanded health savings accounts. H.R. 2708, to amend the Harmonized Tariff Schedule of the United States to modify temporarily certain rates of duty. H.R. 2709, to extend the Generalized System of Preferences; to Ways & Means. H.R. 3331, to ensure that persons who form corporations or limited liability companies in the U.S. disclose the beneficial owners of those corporations or limited liability companies to prevent wrongdoers from exploiting U.S. corporations and limited liability companies for criminal gain, to assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, and other misconduct involving U.S. corporations and limited liability companies, and for other purposes. H.R. 4464, to amend the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. H.R.4503 -- Fair Playing Field Act of 2014, to permit the Secretary of the Treasury to issue prospective guidance clarifying the employment status of individuals for purposes of employment taxes and to prevent retroactive assessments with respect to such clarifications. S. 250, to amend the Internal Revenue Code of 1986 to modify the treatment of foreign corporations, and for other purposes. S. 268, to reduce the deficit and protect important programs by ending tax loopholes. S. 743, to restore states' sovereign rights to enforce state and local sales and use tax laws, and for other purposes. S. 1031, to amend the IRC of 1986 to improve access to health care through expanded health savings accounts. S. 1431, to permanently extend the Internet Tax Freedom Act. S. 1465, to ensure that persons who form corporations in the United States disclose the beneficial owners of those corporations, in order to prevent the formation of corporations with hidden owners, stop the misuse of U.S. corporations by wrongdoers, and assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, tax evasion, and other criminal and civil misconduct involving U.S. corporations, and for other purposes. S. 1489, to amend the Internal Revenue Code of 1986 to require the secretary of the treasury to notify the taxpayer each time the taxpayer's information is accessed by the Internal Revenue Service. S. 2600, the Marketplace and Internet Tax Fairness Act. S. 2609, the Marketplace and Internet Tax Fairness Act.

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

Government targets: Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, SENATE

Monitor matters related to publicly traded partnerships; S. 268 / H.R. 1554, the Cut Loopholes Act; S. 1533 on curtailing tax shelters; and comprehensive tax reform legislatives activities.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 1465 and H.R. 3331, Incorporation Transparency and Law Enforcement Assistance Actprovisions requiring states, certain businesses, and company formation agents to obtain and disclose beneficial ownership information regarding new companies and subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act.Department of the Treasury Financial Crimes Enforcement Network Advance Notice of Proposed Rulemaking on Customer Due Diligence Requirements for Financial Institutions, RIN 1506-AB25, Docket Number FINCEN-2014-0001, 77 Fed. Reg. 45151 (August 4, 2014)provisions requiring law firms that establish accounts at financial institutions on behalf of clients to disclose the identity and beneficial ownership information regarding those clients S.1533 and H.R.1554, Stop Tax Haven Abuse Actprovisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act S. 268, Cut Unjustified Tax Loopholes Actprovisions subjecting lawyers that act as formation agents to the anti-money laundering and suspicious activity reporting requirements of the Bank Secrecy Act

Client expense: $210,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Federal Bureau of Investigation (FBI), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Legal Services Corporation, Library of Congress (LOC), Natl Security Agency (NSA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Trade Representative (USTR), White House Office

Tax reform issues HR 4 - Jobs for America Act; Medical Device Tax HR 3086 - Permanent Internet Tax Freedom Act S 2360, S 2704, S 2786, S 2895 - Inversions- reduced tax benefits for inverted firms HR 4679 - Stop Corporate Tax Inversions Act Tax extenders- offsets, duration, active financing exception, CFC look-through rule HR 4453, HR 3474, S 2260 - tax extenders HR 4438 - Research and Experimentation Tax Credit bill HR 4718 - Bonus Depreciation HR 4457 - Section 179 Expensing Limit on individual itemized tax deductions and selected exclusions Federal income tax deduction for state and local government taxes Consumer Parity Act of 2013- Federal income tax exclusion for employer sponsored mass transit commuter benefits Federal income tax exclusion for interest on state and local government public purpose bonds Federal tax reform's impact on state and local government revenues Reduced tax rates on capital gains and dividends Corporate taxes, including rates, loopholes, repatriation, territorial S 1533 - Stop Tax Haven Abuse Act S 743, HR 684, S 2609 - Marketplace Fairness (i.e. state and local taxes on internet and remote sales tax) HR 3086, S 1431, HR 4, S 2735 - State and local taxes on internet access HR 3724, S 1364 - Business Activity Tax Simplification Act HR 1129 - Mobile Workforce State Income Tax Simplification Act HR 2309, S 1235 - Wireless Tax Fairness Act of 2013 S 410 - Financial Transaction Tax HR 5330 - Bringing Urgent Investment to Local Development Act HR 2084, S 1957 - Partnership to Build America Act of 2014 HR 2429, S 1183 - Death Tax Repeal Act HR 694, S 250, S 268, S 307 - Corporate Tax Reform, closing various corporate tax loopholes

Client expense: $550,000 · Firm income: Not reported

Government targets: Council of Economic Advisers (CEA), HOUSE OF REPRESENTATIVES, SENATE, U.S. Trade Representative (USTR), White House Office

Monitor developments related to the carried interest and publicly traded partnerships. Administration's Proposals on carried interest. Clarify enterprise value definition in carried interest legislation. S.268, Cut Loopholes Act. Monitor developments related to the Camp Tax Proposal.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 6, HR 2772, HR 3094, HR 2262, HR 2653, HR5351, HR 4543, S 391, S 268, S 1696

Client expense: $41,634 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

Effort to amend the Internal Revenue Code of 1986 to increase the alternative tax liability limitation for small property and casualty insurance companies S. 1346/H.R. 4647, all provisions Homeowner Catastrophe Protection Act of 2013 - H.R. 549, all provisions Mobile Workforce State Income Tax Simplification Act Taxation of property/casualty insurance - H.R. 1129, all provisionsCUT Loopholes Act - S. 268, all provisions EXPIRE Act of 2014 - S. 2260, all provisions Corporate Tax Fairness Act - H.R. 694, all provisions Chairman Camp's Tax Reform Discussion Draft (Sec. 3124, 3508, 3510) and Efforts to amend and reform the current tax code with respect to general business and the business of insurance. America's Small Business Tax Relief Act of 2014 - H.R. 4457, all provisions American Research and Competitiveness Act of 2014 - H.R. 4438, all provisions

Client expense: $390,000 · Firm income: Not reported

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

W&M international tax reform draft. White House and Treasury Department tax principles white paper. H.R. 8, the American Taxpayer Relief Act of 2012 specifically related to the R&D credit, the active financing exception under Subpart F, and the CFC look-through rule. Ways & Means tax reform working groups; proposals related to Subpart F; Tax Equity for Health Plan Beneficiaries. Comprehensive Tax Reform;S. 268, CUT Loopholes Act; White House and Treasury Department tax principles white paper and Administration FY2014 Budget; H.CON.RES.25/S.CON.RES.8, Establishing the budget for the United States Government for fiscal year 2014. H.J. Res. 59, Bipartisan Budget Act. H.R. 1129/S. 1645, Mobile Workforce; S. 1859, Tax Extenders Act of 2013; H.R. 1554/S. 1533, Stop Tax Haven Abuse Act; H.R. 3086/S. 1431, Internet Tax Freedom Forever Act; S. 728/H.R. 2499, Tax Parity for Health Plan Beneficiaries Act of 2013; S. 1364, Digital Goods and Services Tax Fairness Act of 2013; Business Tax Extenders; Ways and Means International Tax Draft Legislation. H.R. 4429, Permanent Active Financing Exception; H.R. 4438 Permanent R&D Tax Credit; H.R. 4464 Permanent Controlled-Foreign-Corporation Look Through Rule; S. 2260 Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act; H.R. 3086/S. 1431 permanently extend the Internet Tax Freedom Act.

Client expense: $1,119,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Council of Economic Advisers (CEA), Defense, Dept of (DOD), Education, Dept of, Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Economic Council (NEC), Natl Science Foundation (NSF), Office of Science & Technology Policy (OSTP), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Ways and Means Committee tax reform discussion drafts S. 268, Cut Unjustified Tax Loopholes Act, Title I S. 1533, Stop Tax Haven Abuse, Title III S. 2260, The Expiring Provisions Improvement Reform and Efficiency Act (EXPIRE Act), business tax provisionsSenate Finance Committee tax reform discussion drafts

Client expense: $70,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)

Misc. tax issues including foreign reinsurance, corporate information reporting, and other corporate tax matters; the Presidents Fiscal Year 2015 Budget Proposal; HR 2054 (Neal); S 991 (Menendez); S 268 (Levin); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); Camp Tax Reform Discussion Draft. HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General corp. and intl tax issues; the Presidents Fiscal Year 2015 Budget Proposal; S 268 (Levin); S 250 (Sanders); S 277 (Whitehouse); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); Camp Tax Reform Discussion Draft. HR 4438 (Brady) and S 2260 (Wyden).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Misc. tax issues including foreign reinsurance, corporate information reporting, and other corporate tax matters; the Presidents Fiscal Year 2015 Budget Proposal; HR 2054 (Neal); S 991 (Menendez); S 268 (Levin); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); Camp Tax Reform Discussion Draft. HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General corporate and international tax issues; the Presidents Fiscal Year 2015 Budget Proposal; S 268 (Levin), S 250 (Sanders); S 707 (Reed); S 1533 (Levin); HR 1554 (Doggett); HR 1555 (Doggett); Camp Tax Reform Discussion Draft. HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin); S. 2895 (Brown), H.R. 5549 (Doggett); S. 2786 (Schumer).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Misc. tax issues; tax issues related to foreign insurance and reinsurance; the Presidents Fiscal Year 2015 Budget Proposal; HR 2054 (Neal); HR 1554 (Doggett); HR 1555 (Doggett); S 991 (Menendez); S 268 (Levin); S 1533 (Levin); Camp Tax Reform Discussion Draft. HR 4985 (Van Hollen), HR 4679 (Levin) and S 2360 (Levin).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax Reform Carried Interest - S. 268, Cut Loopholes Act Real Estate Investment & Jobs Act - S. 1181, H.R. 2870, and H.R. 5487 Expiring Tax ProvisionsThe Marketplace Fairness Act - S. 336, S.743 and H.R. 684 Extension of 15-year Depreciation Schedule S. 749 179D Energy Efficient Building Tax Deduction, S. 2189 Foreign Accounting Tax Compliance Act Guidance IRS Notice 2007-55 Partnership Liability Allocation Regulations and Disguised Sale Regulations (Treas. Reg. 119305-11) Expire Act - tax extenders S. 2260 Tax Reform Act of 2014 (Ways and Means Committee discussion draft) "Fractions Rule" regulations (tax-exempt investors and debt-financed real estate) under I.R.C. Sec. 514(c)(9) Treasury/Budget proposal (Greenbook) on Like-Kind Exchanges (Sec. 1031) Corporate Investers Earnings Stripping Reform Act of 2014, S. 2786 and other earnings stripping tax proposals

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

Government targets: Army, Dept of (Corps of Engineers), Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Aviation Administration (FAA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office

The Expiring Provisions Improvement Reform and Efficiency Act (EXPIRE Act)- no bill number-business tax provisions Ways and Means Committee tax reform discussion drafts Senate Finance Committee tax reform discussion drafts S.268, Cut Unjustified Tax Loopholes Act, Title 1 S.1533, Stop Tax Haven Abuse Act, Title III

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

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE, State, Dept of (DOS), U.S. Trade Representative (USTR)

Please see addendum.Issues related to the federal income tax exemption for credit unions Issues related to unrelated business income tax and the revised Form 990 Issues related to the tax treatment of mortgage interest Issues related to the Foreign Account Tax Compliance Act (FATCA) Issues related to the Camp Tax Reform proposal H.R. 243, Bowles-Simpson Plan of Lowering Americas Debt Act, all provisions H.R. 892, the S Corporation Modernization Act, all provisions S. 268, Cut Unjustified Tax (CUT) Loopholes Act, all provisions S. 887, a bill to repeal the violation of sovereign nations laws and privacy matters, all provisions

Client expense: $1,060,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Credit Union Administration (NCUA), Office of Government Ethics (OGE), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Tax Reform Carried Interest - S. 268, Cut Loopholes Act Real Estate Investment & Jobs Act of 2013 - S. 1181 and H.R. 2870 Expiring Tax ProvisionsThe Marketplace Fairness Act - S. 336, S.743 and H.R. 684 Extension of 15-year Depreciation Schedule S. 749 179D Energy Efficient Building Tax Deduction, S. 2189 Foreign Accounting Tax Compliance Act Guidance IRS Notice 2007-55 Partnership Liability Allocation Regulations and Disguised Sale Regulations (Treas. Reg. 119305-11) Expire Act - tax extenders (Senate Finance Committee, not yet numbered) Tax Reform Act of 2014 (Ways and Means Committee discussion draft)

Client expense: $929,813 · Firm income: Not reported

Government targets: Army, Dept of (Corps of Engineers), Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office

H.R. 892, to amend the Internal Revenue Code of 1986 to provide for S corporation reform, and for other purposes. H.R. 905, to amend the Internal Revenue Code of 1986 to make the research credit permanent and to increase the alternative simplified research credit.H.R. 1554, to restrict the use of offshore tax havens and abusive tax shelters to inappropriately avoid federal taxation, and for other purposes. H.R. 1555, to amend the Internal Revenue Code of 1986 to reduce international tax avoidance and restore a level playing field for American businesses. H.R. 1556, to prevent corporations from exploiting tax treaties to evade taxation of U.S. income. H.R. 2194, to improve access to health care through expanded health savings accounts. H.R. 2708, to amend the Harmonized Tariff Schedule of the United States to modify temporarily certain rates of duty. H.R. 2709, to extend the Generalized System of Preferences; to Ways & Means. H.R. 3331, to ensure that persons who form corporations or limited liability companies in the U.S. disclose the beneficial owners of those corporations or limited liability companies to prevent wrongdoers from exploiting U.S. corporations and limited liability companies for criminal gain, to assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, and other misconduct involving U.S. corporations and limited liability companies, and for other purposes. H.R. 4464, to amend the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. H.R.4503 -- Fair Playing Field Act of 2014, to permit the Secretary of the Treasury to issue prospective guidance clarifying the employment status of individuals for purposes of employment taxes and to prevent retroactive assessments with respect to such clarifications. S. 250, to amend the Internal Revenue Code of 1986 to modify the treatment of foreign corporations, and for other purposes. S. 268, to reduce the deficit and protect important programs by ending tax loopholes. S. 743, to restore states' sovereign rights to enforce state and local sales and use tax laws, and for other purposes. S. 1031, to amend the IRC of 1986 to improve access to health care through expanded health savings accounts. S. 1431, to permanently extend the Internet Tax Freedom Act. S. 1465, to ensure that persons who form corporations in the United States disclose the beneficial owners of those corporations, in order to prevent the formation of corporations with hidden owners, stop the misuse of U.S. corporations by wrongdoers, and assist law enforcement in detecting, preventing, and punishing terrorism, money laundering, tax evasion, and other criminal and civil misconduct involving U.S. corporations, and for other purposes. S. 1489, to amend the Internal Revenue Code of 1986 to require the secretary of the treasury to notify the taxpayer each time the taxpayer's information is accessed by the Internal Revenue Service. S. 2600, the Marketplace and Internet Tax Fairness Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

Carried Interest Tax Treatment S268 - Cut Unjustified Tax Loopholes ActState and Local Use Tax Laws for Remote Sellers S336 - Marketplace Fairness Act S743 - Marketplace Fairness Act HR684 - Marketplace Fairness Act Tax Relief for Forgiven Mortgage Debt HR2788 - Mortgage Forgiveness Tax Relief Act HR2994 - Mortgage Forgiveness Tax Relief Act of 2013 S1187 - Mortgage Forgiveness Tax Relief Act of 2013 Tax Incentives for Safety Upgrades in Commercial Buildings S1163 - Fire Sprinkler Incentive Act Foreign Investment In Real Property Tax Relief Act Modifications HR2870 - Real Estate Investment and Jobs Act of 2013 S1181- Real Estate Investment and Jobs Act of 2013 Commercial Building Energy Deductions HR2189 - Energy Efficiency Tax Incentives Act Internet Tax Freedom HR3086 - The Permanent Internet Tax Freedom Act Tax Relief for Small Businesses HR4457 - America's Small Business Tax Relief Act of 2014

Client expense: $16,480,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Natl Economic Council (NEC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, Veterans Affairs, Dept of (VA)

HR 694, S 250, S 268, S 307 -Corporate tax reform, including tax rates, loopholes, profit repatriation, tax holiday, territorial system HR 4438, HR 4457, HR 4453, HR 3474, S 2260 -Tax extenders -offsets, active financing exception, CFC look-through rule HR 4438 -Research and Experimentation Tax Credit bill HR 4718 -Bonus DepreciationFederal income tax deduction for state and local government taxes; including state and local sales tax HR 2288 -Federal income tax exclusion for employer-sponsored mass transit commuter benefits; Commuter Parity Act of 2013 Limits on itemized deductions and selected exclusions Federal income tax exclusion for interest on state and local government public purpose bonds Federal tax reform impact on state and local government revenues Reduced tax rates on capital gains and dividends S 1533 -Stop Tax Haven Abuse Act S 743, HR 684 -Marketplace Fairness Act of 2013 S 743 -Internet Sales Tax HR 1129 -Mobile Workforce State Income Tax Simplification Act HR 3086, S 1431 -Permanent Internet Tax Freedom Act HR 3724, S 1364 -Digital Goods and Services Tax Fairness Act of 2013 HR 2992 -Business Activity Tax Simplification Act Financial Transaction Tax Tax Reform issues HR 2084, S 1957 -Partnership to Build America Act of 2014 HR 2429, S 1183 -Death Tax Repeal Act

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

Government targets: Council of Economic Advisers (CEA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Justice, Dept of (DOJ), SENATE, U.S. Trade Representative (USTR), White House Office