Taxpayer Bill of Rights Enhancement Act of 2015

Alternative minimum tax; Cash basis method of accounting; Corporate integration; Deductions for adjusted gross income (certain attorney fees and court costs); Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Education-related provisions; Estates & Trusts; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust elections; Treat consistently all federal tax payments of trusts and estates; 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Foreign trust withholding credit to U.S. beneficiaries; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Filing election/tax return 15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990 series; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Supporting organizations; SSNs on EO tax forms; Section 501(r); Form 1023; Foreign trusts ; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Stolen Identity Refund Fraud Prevention Act of 2015 (H.R. 2991); Form W-2 due date acceleration; Identity Theft Mark-up Amendment Related to the Regulation of Tax Return Preparers; IRS Security Summit; International Taxation; BEPS - country-by-country reporting; Information reporting for Disregarded Entities with foreign owners; Innovation Box; Inversion guidance under Section 7874; Pending Income Tax Treaties and Protocols; PFIC reporting requirements; Taxation of Foreign Income; Taxation of 529 Plans, ABLE accounts, ROTH IRAs and their foreign equivalents; Voluntary Disclosure and Streamlined Filing Programs for delinquent taxpayers with foreign assets and income; IRS authority over tax return preparers and contingency fees; Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141);Tax Return Preparer Accountability Act of 2015 (H.R. 1609); IRS determination letter program; IRS budget, IRS customer service, IRS Future State; IRS proposed regulations guidance under Section 2801; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit ; Tangible property regulations; Amortization of certain research and experimental expenditures.; Amortization of certain advertising expenditures; Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, de minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Section 170 charitable contribution of inventory; Revenue Procedure 2015-40; Section 199; Revenue Procedures 2015-13 and 2015-14; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Multi-State Worker (telecommuter) Tax Fairness Act ; Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters ; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Partners; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities.; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Treatment under Section 721(c) of property transfers to partnerships with related foreign partners; Partnership Audit procedures enacted as part of the Bipartisan Budget Act of 2016; Disguised sales rules under Section 707; Allocation of partnership liabilities under Section 752; Management fee waivers; Net Investment Income Tax on disposition of partnership interest; Treatment of partner as an employee for benefit purposes; User Fees Charged for S Corporation Private Letter Ruling Requests; Transfers of Property to Partnerships with Related Foreign Partners and of Certain Interests in Corporations as Stock or Indebtedness (Notice 2015-54); Additional Guidance for AAA Ordering Rules; S Corp Basis Ordering (Section 1367); S Corp guidance on inability to utilize certain suspended passive activity losses upon redemption (Section 469(g)); Update Treas. Reg. 1.1361-5 to reflect the addition of clause (ii) to section 1361(b) (3)(C) made by section 8234 of P.L. 110-28; Issue a revenue ruling incorporating the guidance from PLRs 200308035 and 201017019; Guidance regarding the application of section 302(b)(4) to distributions by an S corporation; Guidance as to when, for AMT purposes, S corporations will have attributes which are different for regular tax and AMT purposes; Provide additional guidance to whether a state tax refund attributable to the S portion of an electing small business trust (ESBT) is allocated to the S portion; Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs); The Small Business Healthcare Relief Act (H.R. 5447 / S. 1697); Small business health insurance tax credit; Employer information reporting requirements (Form 1095-C); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775 / S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the tax treatment of Roth individual retirement account contributions; SEPs ; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Section 385 Proposed Regulations - Regarding the treatment of certain interests in corporations as stock or indebtedness (REG-108060-15); Small Business Tax Compliance Relief Act of 2015 (S. 1827); The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burdens; International tax provisions related to the Tax Reform Act of 2014; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Private Debt Collection; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 3520 change technical correction; Taxpayer Bill of Rights; Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); Treasury/IRS Priority Guidance Plan (Notice 2016-26); United States Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) System; Virtual currency (Bitcoin)

Client expense: $1,210,000 · Firm income: Not reported

Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office

Probationary Period Issues (5 USC) Supervisory Training Issues (5 USC) CBP Customs User Fees CFTC Reauthorization Issues IRS Private Tax Collection Program S. 19, Federal Debt Management Act of 2015 S. 164, Federal Adjustment of Income Rates Act S. 278, Citizen Empowerment Act H.R. 280, to Recoup Bonuses and Awards Paid to VA Employees S. 303, Federal Employee Tax Accountability Act of 2015 H.R. 304, Federal Adjustment of Income Rates Act H.R. 399, Secure the Borders First Act, 2015 S. 208, Secure the Borders First Act, 2015 S. 362, Government Employee Accountability Act H.R. 417, Federal Workforce Reduction through Attrition Act S. 461, Cross Border Trade Enhancement Act of 2016 H.R. 532, Federal Employees Paid Parental Leave Act of 2015 H.R. 490, Security Clearance Reform Act of 2015 S. 579, IG Empowerment Act of 2015 H.R. 579, THRIFT Act of 2015 H.R. 586, Government Waste Reduction Act of 2015 H.R. 644, Trade Facilitation and Trade Enforcement Act of 2015 H.R. 653, FOIA Act S. 458, Emergency Port of Entry Personnel and Infrastructure Funding Act H.R. 883, Emergency Port of Entry Personnel and Infrastructure Funding Act S. 461, Cross Border Trade Enhancement Act H.R. 875, Cross Border Trade Enhancement Act H.R. 709, Prevent Targeting at the IRS Act H.R. 722, Government Employee Accountability Act S. 742, Stop Wasteful Federal Bonuses Act of 2015 H.R. 785, Federal Employee Pension Fairness Act H.R. 901, Eliminating Pornography from Agencies Act H.R. 998, Preclearance Authorization Act of 2015 H.R. 1026, the "Taxpayer Knowledge of IRS Investigations Act" H.R. 1054, TRUST Act H.R. 1058, Taxpayer Bill of Rights Act of 2015 H.R. 1137, PAID for Progress Act S. 1144, Federal Employees Sustainable Investment Act H.R. 2113, Federal Employee Sustainable Investment Act H.R. 1152, Prohibiting Employees of the IRS from Using Personal Email to Conduct Official Business H.R. 1206, No Hires for the Delinquent IRS Act H.R. 1230, Government Employee Pension Reform Act of 2015 S. 1378, Bonuses for Cost-Cutters Act of 2015 H.R. 1535, SACO Act H.R. 1553, FDIC Exams H.R. 1557, Federal Employee Antidiscrimination Act of 2015 H.R. 1562, Contracting and Tax Accountability Act of 2015 H.R. 1563, Federal Employee Tax Accountability Act of 2015 S. 1576, to prevent fraud by representative payees S. 1578, Taxpayer Bill of Rights Enhancement Act of 2015 S. 1616, Saving Federal Dollars through Better Use of Government Purchase and Travel Cards Act of 2015 H.R. 1633, DHS Paid Administrative Leave Act of 2015 H.R. 1702, LEO Fair Retirement Act of 2015 H.R. 1753, Executive Cyberspace Coordination Act of 2015 H.R. 1817, No Bonus for Tax Delinquent IRS Employees Act of 2015 S. 1888, the USA Act H.R. 1941, Financial Institution Exams S. 1946, Tax Relief Extension Act of 2015 H.R. 1950, Sunset Inefficient and Unaccountable Government Act H.R. 1994, VA Accountability Act of 2015 S. 1082, Department of Veterans Affairs Accountability Act S. 2007, Federal Cybersecurity Workforce Assessment Act S. 2033, Federal Employee Paid Parental Leave Act of 2015 S. 2035, Federal Employee Fair Treatment Act of 2015 S. 2051, Improving Postal Operations, Service and Transparency Act of 2015 S. 2113, To harness the expertise, ingenuity and creativity of all people to help the federal government S. 2127, Dr. Chris Kirkpatrick Whistleblower Protection Act of 2015 S. 2133, To improve Federal agency financial and administrative controls and procedures S. 2968, Office of Special Counsel Reauthorization Act of 2016 S. 2975, Federal Information Systems Safeguard Act of 2016 S. 3011, Bolster Accountability to Drive Government Efficiency H.R. 2146, Defending Public Safety Employees Retirement Act of 2015 H.R. 2254, the "Law Enforcement Officers Equity Act" H.R. 2385, CFPB Pay H.R. 2395, IG Empowerment Act of 2016 H.R. 2432, Federal Employee Gender Diversity Investment Act H.R. 2532, EASY Savings Act of 2015 H.R. 2741, Federal Employee Short-Term Disability Insurance Act of 2015 H.R. 2826, Government Transformation Act S. 1746, RECOVER Act H.R. 3029, RECOVER Act H.R. 3023, to modify probationary periods with respect to positions within the competitive service H.R. 3208, Retired Civil Servant Military Service Restoration Act of 2015 H.R. 3231, Federal Intern Protection Act of 2015 H.R. 3361, Amendment in the Nature of a Substitute - Department of Homeland Security Insider Threat and Mitigation Act of 2016 H.R. 3418, Federal Protective Service Improvement and Accountability Act of 2015 H.R. 3470, Fair Chance Act S. 2021, FAIR Chance Act H.R. 3572, DHS Headquarters Reform and Improvement Act of 2015 H.R. 3586, Border and Maritime Coordination Improvement Act H.R. 4144, the SAVE Benefits Act S. 2251, the SAVE Benefits Act H.R. 4585, Federal Adjustment of Income Rates Act of 2016 S. 2699, Federal Adjustment of Income Rates Act of 2016 S. 2430, Travel Facilitation and Safety Act S. 2450, Administrative Leave Act of 2016 S. 2612, Promoting Travel, Commerce, and National Security Act of 2016 H.R. 4657,Promoting Travel, Commerce, and National Security Act of 2016 H.R. 4359, Administrative Leave Reform Act H.R. 4360, Official Personnel File Enhancement Act H.R. 4361, Federal Information Systems Safeguards Act of 2016 H.R. 4482, Southwest Border Security Threat Assessment Act of 2016 H.R. 4639, Thoroughly Investigating Retaliation Against Whistleblowers Act H.R. 4680, National Park Service Centennial Act H.R. 3556, National Park Service Centennial Act S. 2257, National Park Service Centennial Act H.R. 4885, IRS Oversight While Eliminating Spending Act of 2016 H.R. 4890, to impose a ban on bonuses at the IRS H.R. 4906, to amend title 5 to clarify the eligibility of employees in a land management agency S. 2918, to amend title 5 to clarify the eligibility of employees in a land management agency H.R. 4909, FY 2017 National Defense Authorization Act H.R. 4912, the Taxpayer Protection Act of 2016 Senate Draft, the Taxpayer Protection Act of 2016 H.R. 5256, Expanding DHS Overseas Passenger Security Screening and Vetting Operations Act H.R. 5496, Family and Medical Leave Act protections for part-time workers act of 2016 H.R. 5518, Family and Medical Leave Enhancement Act of 2016 H.R. 5519, Family and Medical Leave Inclusion Act H.R. 5535, Family Leave for Parental Involvement in Education Act H.R. 5611, Homeland Safety and Security Act of 2016 Senate Draft, to Prevent Identity Theft and Refund Fraud S. 337, FOIA Improvement Act of 2016 S. 2715, National Security Whistleblower Protection Act of 2016 S. 2723, Congressional Whistleblower Protection Act S. 2814, FY 2017 National Defense Authorization Act S. 2921, Veterans First Act S. 2946, Law Enforcement Officers Equity Act of 2016 S. 2976, DHS Accountability Act of 2016

Alternative minimum tax; Cash basis method of accounting; CPA representation of state-legal marijuana businesses; Deductions for adjusted gross income (certain attorney fees and court costs); Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Education-related provisions; Estates & Trusts; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust elections; Treat consistently all federal tax payments of trusts and estates; 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Foreign trust withholding credit to U.S. beneficiaries; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Filing election/tax return 15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Supporting organizations; SSNs on EO tax forms; Foreign trusts; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Stolen Identity Refund Fraud Prevention Act of 2015 (H.R. 2991); Form W-2 due date acceleration; International Taxation; BEPS - country-by-country reporting; Pending Income Tax Treaties and Protocols; Taxation of Foreign Income; Taxation of 529 Plans, ABLE accounts, ROTH IRAs and their foreign equivalents; Voluntary Disclosure and Streamlined Filing Programs for delinquent taxpayers with foreign assets and income; IRS authority over tax return preparers and contingency fees; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141); Tax Return Preparer Accountability Act of 2015 (H.R. 1609); IRS determination letter program; IRS budget, IRS customer service, IRS Future State; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit; Tangible property regulations; Amortization of certain research and experimental expenditures; Amortization of certain advertising expenditures; Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, de minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Multi-State Worker (telecommuter) Tax Fairness Act; Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Partners; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs); The Small Business Healthcare Relief Act (H.R. 2911 / S. 1697); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775 / S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the tax treatment of Roth individual retirement account contributions; SEPs; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Small Business Tax Compliance Relief Act of 2015 (S. 1827); The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burdens; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 3520 change technical correction; Taxpayer Bill of Rights; Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); United States Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) System

Probationary Period Issues (5 USC) Supervisory Training Issues (5 USC) CBP Customs User Fees CFTC Reauthorization Issues IRS Private Tax Collection Program S. 19, Federal Debt Management Act of 2015 S. 164, Federal Adjustment of Income Rates Act S. 278, Citizen Empowerment Act H.R. 280, to Recoup Bonuses and Awards Paid to VA Employees S. 303, Federal Employee Tax Accountability Act of 2015 H.R. 304, Federal Adjustment of Income Rates Act H.R. 399, Secure the Borders First Act, 2015 S. 208, Secure the Borders First Act, 2015 S. 362, Government Employee Accountability Act H.R. 417, Federal Workforce Reduction through Attrition Act H.R. 532, Federal Employees Paid Parental Leave Act of 2015 H.R. 490, Security Clearance Reform Act of 2015 S. 579, IG Empowerment Act of 2015 H.R. 579, THRIFT Act of 2015 H.R. 586, Government Waste Reduction Act of 2015 H.R. 644, Trade Facilitation and Trade Enforcement Act of 2015 H.R. 653, FOIA Act S. 458, Emergency Port of Entry Personnel and Infrastructure Funding Act H.R. 883, Emergency Port of Entry Personnel and Infrastructure Funding Act S. 461, Cross Border Trade Enhancement Act H.R. 875, Cross Border Trade Enhancement Act H.R. 709, Prevent Targeting at the IRS Act H.R. 722, Government Employee Accountability Act S. 742, Stop Wasteful Federal Bonuses Act of 2015 H.R. 785, Federal Employee Pension Fairness Act H.R. 901, Eliminating Pornography from Agencies Act H.R. 998, Preclearance Authorization Act of 2015 H.R. 1026, the "Taxpayer Knowledge of IRS Investigations Act" H.R. 1054, TRUST Act H.R. 1058, Taxpayer Bill of Rights Act of 2015 H.R. 1137, PAID for Progress Act S. 1144, Federal Employees Sustainable Investment Act H.R. 2113, Federal Employee Sustainable Investment Act H.R. 1152, Prohibiting Employees of the IRS from Using Personal Email to Conduct Official Business H.R. 1206, No Hires for the Delinquent IRS Act H.R. 1230, Government Employee Pension Reform Act of 2015 S. 1378, Bonuses for Cost-Cutters Act of 2015 H.R. 1535, SACO Act H.R. 1553, FDIC Exams H.R. 1557, Federal Employee Antidiscrimination Act of 2015 H.R. 1562, Contracting and Tax Accountability Act of 2015 H.R. 1563, Federal Employee Tax Accountability Act of 2015 S. 1576, to prevent fraud by representative payees S. 1578, Taxpayer Bill of Rights Enhancement Act of 2015 S. 1616, Saving Federal Dollars through Better Use of Government Purchase and Travel Cards Act of 2015 H.R. 1633, DHS Paid Administrative Leave Act of 2015 H.R. 1702, LEO Fair Retirement Act of 2015 H.R. 1753, Executive Cyberspace Coordination Act of 2015 H.R. 1817, No Bonus for Tax Delinquent IRS Employees Act of 2015 S. 1888, the USA Act H.R. 1941, Financial Institution Exams S. 1946, Tax Relief Extension Act of 2015 H.R. 1950, Sunset Inefficient and Unaccountable Government Act H.R. 1994, VA Accountability Act of 2015 S. 1082, Department of Veterans Affairs Accountability Act S. 2007, Federal Cybersecurity Workforce Assessment Act S. 2033, Federal Employee Paid Parental Leave Act of 2015 S. 2035, Federal Employee Fair Treatment Act of 2015 S. 2051, Improving Postal Operations, Service and Transparency Act of 2015 S. 2113, To harness the expertise, ingenuity and creativity of all people to help the federal government S. 2127, Dr. Chris Kirkpatrick Whistleblower Protection Act of 2015 S. 2133, To improve Federal agency financial and administrative controls and procedures H.R. 2146, Defending Public Safety Employees Retirement Act of 2015 H.R. 2254, the "Law Enforcement Officers Equity Act" H.R. 2385, CFPB Pay H.R. 2432, Federal Employee Gender Diversity Investment Act H.R. 2532, EASY Savings Act of 2015 H.R. 2741, Federal Employee Short-Term Disability Insurance Act of 2015 H.R. 2826, Government Transformation Act H.R. 2827, Competitive Service Act of 2015 S. 1580, Competitive Service Act of 2015 S. 1746, RECOVER Act H.R. 3029, RECOVER Act H.R. 3023, to modify probationary periods with respect to positions within the competitive service H.R. 3208, Retired Civil Servant Military Service Restoration Act of 2015 H.R. 3231, Federal Intern Protection Act of 2015 H.R. 3361, Amendment in the Nature of a Substitute - Department of Homeland Security Insider Threat and Mitigation Act of 2016 H.R. 3418, Federal Protective Service Improvement and Accountability Act of 2015 H.R. 3470, Fair Chance Act S. 2021, FAIR Chance Act H.R. 3572, DHS Headquarters Reform and Improvement Act of 2015 H.R. 3586, Border and Maritime Coordination Improvement Act H.R. 4144, the SAVE Benefits Act S. 2251, the SAVE Benefits Act H.R. 4585, Federal Adjustment of Income Rates Act of 2016 S. 2699, Federal Adjustment of Income Rates Act of 2016 S. 2430, Travel Facilitation and Safety Act S. 2450, Administrative Leave Act of 2016 S. 2612, Promoting Travel, Commerce, and National Security Act of 2016 H.R. 4657,Promoting Travel, Commerce, and National Security Act of 2016 H.R. 4359, Administrative Leave Reform Act H.R. 4360, Official Personnel File Enhancement Act H.R. 4361, Federal Information Systems Safeguards Act of 2016 H.R. 4482, Southwest Border Security Threat Assessment Act of 2016 S. 337, FOIA Improvement Act of 2016

H.R. 2029, Amd 2Protecting Americans from Tax Hikes Act of 2015 H.R. 644Trade Facilitation and Trade Enforcement Act of 2015 - (PITFA) H.R. 3167Tax Administration Integrity Act H.R. 1104Fair Treatment for All Donations Act S. 2320Universal Savings Account Act H.R. 4094Universal Savings Account Act S. 1578, S. 949Taxpayer rights legislation (various through Coalition for Effective and Efficient Tax Administration) at introductionIRS Accountability Act H.R. 1206No Hires for the Delinquent IRS Act Reinsurance tax hike as "pay-for" H.R. 2775Internet sales tax H.R. 1087Wireless Telecommunications Tax and Fee Collection Fairness Act of 2015 H.R. 2510Bonus depreciation H.R. 880R&D tax credit H.R. 1901wind production tax credit phase out H.R. 235/ S.431internet access tax freedom H.R. 709Prevent IRS targeting H.R. 3167prevent IRS from hiring outside law firms H.R. 2698repeal tanning tax

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

Administrative Leave Issues (5 USC) Probationary Period Issues (5 USC) Supervisory Training Issues (5 USC) CBP Customs User Fees CFTC Reauthorization Issues IRS Private Tax Collection Program Tax Extenders Package S. 19, Federal Debt Management Act of 2015 H.R. 22, Fixing America's Surface Transportation (FAST) Act S. 136, Gold Star Fathers Act H.R. 1222, Gold Star Fathers Act S. 164, Federal Adjustment of Income Rates Act S. 242, Wounded Warriors Federal Leave Act of 2015 H.R. 313, Wounded Warriors Federal Leave Act of 2015 S. 278, Citizen Empowerment Act H.R. 280, to Recoup Bonuses and Awards Paid to VA Employees S. 303, Federal Employee Tax Accountability Act of 2015 H.R. 304, Federal Adjustment of Income Rates Act H.R. 399, Secure the Borders First Act, 2015 S. 208, Secure the Borders First Act, 2015 S. 362, Government Employee Accountability Act H.R. 417, Federal Workforce Reduction through Attrition Act H.R. 532, Federal Employees Paid Parental Leave Act of 2015 H.R. 490, Security Clearance Reform Act of 2015 S. 554, Federal Employee Retroactivity Pay Fairness Act of 2015 S. 579, IG Empowerment Act of 2015 H.R. 579, THRIFT Act of 2015 H.R. 586, Government Waste Reduction Act of 2015 H.R. 644, Trade Facilitation and Trade Enforcement Act of 2015 H.R. 653, FOIA Act S. 458, Emergency Port of Entry Personnel and Infrastructure Funding Act H.R. 883, Emergency Port of Entry Personnel and Infrastructure Funding Act S. 461, Cross Border Trade Enhancement Act H.R. 875, Cross Border Trade Enhancement Act H.R. 709, Prevent Targeting at the IRS Act H.R. 722, Government Employee Accountability Act S. 742, Stop Wasteful Federal Bonuses Act of 2015 H.R. 785, Federal Employee Pension Fairness Act H.R. 901, Eliminating Pornography from Agencies Act H.R. 998, Preclearance Authorization Act of 2015 H.R. 1026, the "Taxpayer Knowledge of IRS Investigations Act" H.R. 1046, Transit Tax Parity Act of 2015 H.R. 1054, TRUST Act H.R. 1058, Taxpayer Bill of Rights Act of 2015 H.R. 1137, PAID for Progress Act S. 1144, Federal Employees Sustainable Investment Act H.R. 2113, Federal Employee Sustainable Investment Act H.R. 1152, Prohibiting Employees of the IRS from Using Personal Email to Conduct Official Business H.R. 1206, No Hires for the Delinquent IRS Act H.R. 1230, Government Employee Pension Reform Act of 2015 S. 1378, Bonuses for Cost-Cutters Act of 2015 H.R. 1531, Land Management Workforce Flexibility Act H.R. 1535, SACO Act H.R. 1553, FDIC Exams H.R. 1557, Federal Employee Antidiscrimination Act of 2015 H.R. 1562, Contracting and Tax Accountability Act of 2015 H.R. 1563, Federal Employee Tax Accountability Act of 2015 S. 1576, to prevent fraud by representative payees S. 1578, Taxpayer Bill of Rights Enhancement Act of 2015 S. 1591, Land Management Flexibility Workforce Act S. 1603, Border Jobs for Veterans Act of 2015 H.R. 2835, Border Jobs for Veterans Act of 2015 S. 1616, Saving Federal Dollars through Better Use of Government Purchase and Travel Cards Act of 2015 H.R. 1633, DHS Paid Administrative Leave Act of 2015 H.R. 1702, LEO Fair Retirement Act of 2015 H.R. 1735, FY 2016 National Defense Authorization Act S. 1376, FY 2016 National Defense Authorization Act H.R. 1753, Executive Cyberspace Coordination Act of 2015 H.R. 1817, No Bonus for Tax Delinquent IRS Employees Act of 2015 S. 1869, A bill to improve Federal network security and authorize and enhance an existing intrusion detection and prevention system for civilian Federal networks S. 1888, the USA Act H.R. 1941, Financial Institution Exams S. 1946, Tax Relief Extension Act of 2015 H.R. 1950, Sunset Inefficient and Unaccountable Government Act S. 1990, Federal Computer Security Act H.R. 1994, VA Accountability Act of 2015 S. 1082, Department of Veterans Affairs Accountability Act S. 2007, Federal Cybersecurity Workforce Assessment Act S. 2033, Federal Employee Paid Parental Leave Act of 2015 S. 2035, Federal Employee Fair Treatment Act of 2015 S. 2051, Improving Postal Operations, Service and Transparency Act of 2015 S. 2113, To harness the expertise, ingenuity and creativity of all people to help the federal government S. 2127, Dr. Chris Kirkpatrick Whistleblower Protection Act of 2015 S. 2133, To improve Federal agency financial and administrative controls and procedures H.R. 2146, Defending Public Safety Employees Retirement Act of 2015 H.R. 2254, the "Law Enforcement Officers Equity Act" H.R. 2385, CFPB Pay H.R. 2432, Federal Employee Gender Diversity Investment Act H.R. 2532, EASY Savings Act of 2015 H.R. 2741, Federal Employee Short-Term Disability Insurance Act of 2015 H.R. 2826, Government Transformation Act H.R. 2827, Competitive Service Act of 2015 S. 1580, Competitive Service Act of 2015 S. 1746, RECOVER Act H.R. 3029, RECOVER Act H.R. 3208, Retired Civil Servant Military Service Restoration Act of 2015 H.R. 3231, Federal Intern Protection Act of 2015 H.R. 3313, Cyber Defense of Federal Networks Act of 2015 H.R. 3360, Defense Against Digital Theft Act H.R. 3402, Federal Information Security Management Reform Act of 2015 H.R. 3418, Federal Protective Service Improvement and Accountability Act of 2015 H.R. 3470, Fair Chance Act S. 2021, FAIR Chance Act H.R. 3572, DHS Headquarters Reform and Improvement Act of 2015 H.R. 3586, Border and Maritime Coordination Improvement Act H.R. 3635, Federal Employee Retroactive Pay Fairness Act H.R. 4144, the SAVE Benefits Act S. 2251, the SAVE Benefits Act S. 2430, Travel Facilitation and Safety Act

Alternative minimum tax; Cash basis method of accounting; CPA representation of state-legal marijuana businesses; Multi-State Worker (telecommuter) Tax Fairness Act; Tax Disaster Relief; National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Tax Extension Assurance Bill; Deductions for adjusted gross income (certain attorney fees and court costs); Education-related provisions; Estates & Trusts; Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust elections; Treat consistently all federal tax payments of trusts and estates; 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Provide portability relief; Filing election/tax return15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Foreign trust withholding credit to U.S. beneficiaries; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Executive Compensation; Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations; Form 990; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments; dual use facility expense allocation); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Supporting organizations; SSNs on EO tax forms; Foreign trusts; Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Health insurance deduction; Provide full deductibility of health insurance for small businesses; Identity theft; The Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Identity Theft and Tax Fraud Prevention Act of 2015 (H.R. 3981); Form W-2 due date acceleration; International Taxation; BEPs; Pending Income Tax Treaties and Protocols; Taxation of Foreign Income; IRS authority over tax return preparers; Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Tax Return Preparer Competency Act of 2015 (H.R. 4141); Taxpayer Bill of Rights: Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); IRS determination letter program; IRS budget, IRS customer service; Kiddie Tax rules; Listed property issues; Removing computer equipment from the definition of listed property; Internet sales and use tax collection; Marketplace Fairness Act of 2015, S. 698; Remote Transactions Parity Act of 2015, H.R. 2775; Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits; Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit; Tangible property regulations; Amortization of certain research and experimental expenditures; Amortization of certain advertising expenditures; Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, De minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Net operating loss deduction; Pass-through Entities; Allow Subchapters K and S to Remain as Separate Subchapters; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Partners; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership audits and adjustments; Partnership Audit Simplification Act of 2015 (H.R. 2821); Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements (HRAs): The Small Business Healthcare Relief Act) (H.R. 2911 / S. 1697); Remote Transactions Parity Act of 2015, Marketplace Fairness Act of 2015 (H.R. 2775, S. 6998); Savings & Investments; Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the tax treatment of Roth individual retirement account contributions; SEPs; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Small Business Tax Compliance Relief Act of 2015 (S. 1827); The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General); Principles of Good Tax Policy; Tax extenders (H.R. 2029, the Protecting Americans from Tax Hikes Act of 2015 and Consolidated Appropriations Act, 2016); Permanence of tax legislation; Small business compliance burden; Tax administration and compliance; Late and amended Forms 1099 - corrected information reporting safe harbor de minimis and reporting rollover to year of change; Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions; Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015); Form 5500 change technical correction; Form 3520 change technical correction

Alternative minimum tax; Cash basis method of accounting; CPA representation of state-legal marijuana businesses; Tax Disaster Relief - National Disaster Tax Relief Act of 2015 (H.R. 3110 / S. 1795); Deductions for adjusted gross income (certain attorney fees and court costs); Education-related provisions; Estates & Trusts - Allow administrative relief for late portability, inter vivos qualified terminal interest property, and qualified revocable trust elections; Treat consistently all federal tax payments of trusts and estates; 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; Subject estates, certain qualified revocable trusts, and qualified disability trusts to the income tax and net investment income tax in the same manner as married persons filing separate returns; Require Form 1099 reporting of interest and dividends paid to charitable remainder trusts; Provide portability relief - Filing election/tax return15 months after death; Simplified Form 706 EZ; Surviving spouse elections; Foreign trust withholding credit to U.S. beneficiaries; Section 2801 estate tax expatriation guidance; Estate tax closing letters; Estate tax basis consistency reporting; Executive Compensation - Section 409A; Excise tax on excess tax-exempt organization executive compensation; Exempt Organizations - Form 990; Jeopardizing investments; Unrelated Business Income Tax (name and logo royalties treated as unrelated business taxable income; parity of charitable contribution limitation between trusts and corporations; increased specific deduction; qualified sponsorship payments); Penalties (increase in information return penalties; manager-level accuracy-related penalty on underpayment of unrelated business income tax); Tax Exempt Entities/Excise Taxes (modification of intermediate sanctions; modification of taxes on self-dealing; excise tax on failure to distribute within five years contribution to donor advised fund; repeal of exception for private operating foundation failure to distribute income; excise tax based on investment income of private colleges and universities); Supporting organizations; SSNs on EO tax forms; Foreign trusts - Compliance issues continuing monitoring/discussing; Withholding issues with FATCA for foreign trusts and U.S. beneficiaries; Health insurance deduction - Provide full deductibility of health insurance for small businesses; International Taxation - BEPs; Pending Income Tax Treaties and Protocols; Taxation of Foreign Income; IRS authority over tax return preparers and identity theft - Chairman's Mark of A Bill To Prevent Identity Theft And Tax Refund Fraud (JCX-108-15); Taxpayer Protection and Preparer Proficiency Act of 2015 (S. 137); Taxpayer Bill of Rights - Taxpayer Bill of Rights Act of 2015 (H.R. 1058, S. 949, S. 951); Small Business Taxpayer Bill of Rights Act of 2015 (H.R. 1828, S. 949); Taxpayer Bill of Rights Enhancement Act of 2015 (S. 1578); IRS determination letter program; IRS budget, IRS customer service; Kiddie Tax rules; Listed property issues - Removing computer equipment from the definition of listed property; Internet sales and use tax collection: Marketplace Fairness Act of 2015 (S. 698), Remote Transactions Parity Act of 2015 (H.R. 2775); Medical lodging deduction limitation with the allowable business per diem rates; Methods/Periods/Credits - Cost recovery issues/UNICAP (including Sections 168, 179 and 263A); Mischaracterized section 174 expenditures; Modification of Rev. Proc. 2004-34 and Treas. Reg. 1.451-5 concerning the deferral of advance payments; Research credit; Tangible property regulations; Amortization of certain research and experimental expenditures.; Amortization of certain advertising expenditures; Tax treatment of deferred revenue in taxable asset acquisitions; Revenue Procedure 2015-20, De minimis safe harbor limit; Accounting method changes for mischaracterized section 174 expenditures needing a section 481(a) adjustment and audit protection; Mileage rates for business expense, medical expense, moving expense and charitable contribution purposes; Mobile Workforce State Income Tax Simplification Act of 2015 (H.R. 2315 and S. 386); Net operating loss deduction; Pass-through Entities - Allow Subchapters K and S to Remain as Separate Subchapters; Retain the Flexibility of the Subchapter K Model (Including Special Allocations and Outside Basis for Partnership Level Debt); Retain the Check-the-Box Rules; Obtain Tax Rate Parity Between Pass-Through Business Entities and C Corporations; Repeal Section 1372: Partnership Rules to Apply for Fringe Benefit Purposes for S Corporations; Make Permanent the Reduced Recognition Period for Built-In Gains for S Corporations; Allow Full Consideration of Net Realized Built-In Loss for S Corporations; Make Remedial Allocations Mandatory for Partnerships with Greater than 5% Nonresident Alien Individuals as Partners; Eliminate the Section 751(b) Calculation on Disproportionate Distributions; Oppose Any Proposal for Tax Treatment of "Large" Partnerships as Corporations; Require Mandatory Adjustments to Basis of Partnership Property in Case of Transfer of Partnership Interests and Mandatory Adjustments to Basis of Undistributed Partnership Property; Allow Accumulated Earnings and Profits Withdrawal from S Corporations with Certainty; Reduce Realized Built-In Gains of S Corporations by the Amount of Accrued State Income Tax; Allow Incentive Deductions Permitted by the Internal Revenue Code to Flow Through to Taxpayers Without Basis Limitations; Repeal the Prohibition of Section 179(d)(4) for Estates/Trusts; Alternatively, Allow Pass-Through Entity Allocation and Amortization at the Estate /Trust Level; Charitable Contribution Deduction for Electing Small Business Trusts; Permanent Rule Regarding Basis Adjustment to Stock of S Corporations Making Charitable Contribution of Property; 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 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 threshold of S corporations under section 1375(a)(2) from 25% to 60%; Extension of time for making S corporation elections; Partnership audits and adjustments; Allow the transfer of any partnership suspended losses to his/her spouse when spousal transfers under section 1041(a) take place; Clarify that husband and wife partnerships that are recognized under state law are eligible to elect Qualified Joint Venture status under section 761(f); Repeal section 708(b)(1)(B) relating to the technical terminations of partnerships; Retain existing safe harbors for allocation of shared partnership liabilities; Request for Guidance Regarding Worthless Stock Deductions Under Section 165(g) for S Corporations; Partnership Audit Simplification Act of 2015 (H.R. 2821); Patient Protection and Affordable Care Act (P.L. 111-148) implementation and related issues; Health reimbursement arrangements: The Small Business Healthcare Relief Act (H.R. 2911 / S. 1697); Savings & Investments - Consolidate and simplify the multiple types of tax-favored retirement plans and the rules governing them; Eliminate Certain Nondiscrimination Tests on Employee Pre-tax and Roth Deferrals for 401(k) Plans, Matching Contributions; Eliminate the Top-Heavy Rules; Create a Uniform Rule Regarding the Determination of Basis in Distributions; Create a Uniform Attribution Rule; Create a Uniform Definition of Owners; Change the Required Minimum Distribution Rules During Life and Remove Half-Year Age References; Create Uniform Rules for Early Withdrawal Penalties; Elimination of Income Limits on Contributions to Roth IRAs; Inflation Adjustments for Roth IRA Contributions; Simplify the tax treatment of Roth individual retirement account contributions; SEPs; SIMPLE 401(k)s; Rules Related to Designated Roth Contributions; Repeal the requirement that benefits become fully vested upon a partial termination of a qualified retirement plan; Small Business Tax Compliance Relief Act of 2015 (S. 1827); The Self-Employment Contributions Act (SECA); Determination of net earnings from self-employment; Equalize the tax treatment between employees and self-employed individuals with respect to the deduction for health insurance costs in determining income subject to OASDI and HI taxes; Tax Reform (General) - Principles of Good Tax Policy; Tax extenders; Permanence of tax legislation; Tax administration and compliance - Amend the section 6051 reporting requirement to permit truncation of employee social security numbers; Clarification of six-year statute of limitations in case of overstatement of basis; Penalties (definition of tax shelters; significant purpose; reasonable cause exceptions; penalty for failure to file; penalty for failure to file correct information returns and provide payee statements; Form 3520 and 3520-A penalties; late filing penalties under sections 6698 and 6699; Form 5471 penalty relief); Pre-populated returns; Repeal the section 7122(c)(1) requirement to provide a 20% partial payment with a lump-sum offer in compromise; Section 9100 relief (administrative relief for missed statutory elections); Tax Administration Integrity Act (H.R. 3167); Tax rates and definitions - Consistent definitions in the Internal Revenue Code; Deduction for adjusted net capital gain; Elimination of surtaxes; Inflation-adjusting thresholds and amounts; Repeal of phase-ins/phase-outs; Simplified Income Tax Rate Structure; Tax return due dates (Public Law 114-41, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015);

CFTC Reauthorization Issues IRS Private Tax Collection Program S. 19, Federal Debt Management Act of 2015 H.R. 22, DRIVE Act H.R. 53, Cybersecurity Education and Federal Workforce Enhancement Act S. 136, Gold Star Fathers Act H.R. 1222, Gold Star Fathers Act S. 164, Federal Adjustment of Income Rates Act S. 242, Wounded Warriors Federal Leave Act of 2015 H.R. 313, Wounded Warriors Federal Leave Act of 2015 S. 278, Citizen Empowerment Act H.R. 280, to Recoup Bonuses and Awards Paid to VA Employees S. 303, Federal Employee Tax Accountability Act of 2015 H.R. 304, Federal Adjustment of Income Rates Act H.R. 399, Secure the Borders First Act, 2015 S. 208, Secure the Borders First Act, 2015 S. 362, Government Employee Accountability Act H.R. 417, Federal Workforce Reduction through Attrition Act H.R. 532, Federal Employees Paid Parental Leave Act of 2015 H.R. 490, Security Clearance Reform Act of 2015 S. 554, Federal Employee Retroactivity Pay Fairness Act of 2015 S. 579, IG Empowerment Act of 2015 H.R. 579, THRIFT Act of 2015 H.R. 586, Government Waste Reduction Act of 2015 H.R. 644, Trade Facilitation and Trade Enforcement Act of 2015 S. 458, Emergency Port of Entry Personnel and Infrastructure Funding Act H.R. 883, Emergency Port of Entry Personnel and Infrastructure Funding Act S. 461, Cross Border Trade Enhancement Act H.R. 875, Cross Border Trade Enhancement Act H.R. 709, Prevent Targeting at the IRS Act H.R. 722, Government Employee Accountability Act S. 742, Stop Wasteful Federal Bonuses Act of 2015 H.R. 785, Federal Employee Pension Fairness Act H.R. 901, Eliminating Pornography from Agencies Act H.R. 998, Preclearance Authorization Act of 2015 H.R. 1026, the "Taxpayer Knowledge of IRS Investigations Act" H.R. 1046, Transit Tax Parity Act of 2015 H.R. 1054, TRUST Act H.R. 1058, Taxpayer Bill of Rights Act of 2015 H.R. 1137, PAID for Progress Act S. 1144, Federal Employees Sustainable Investment Act H.R. 2113, Federal Employee Sustainable Investment Act H.R. 1152, Prohibiting Employees of the IRS from Using Personal Email to Conduct Official Business H.R. 1206, No Hires for the Delinquent IRS Act H.R. 1230, Government Employee Pension Reform Act of 2015 S. 1378, Bonuses for Cost-Cutters Act of 2015 H.R. 1531, Land Management Workforce Flexibility Act H.R. 1535, SACO Act H.R. 1553, FDIC Exams H.R. 1557, Federal Employee Antidiscrimination Act of 2015 H.R. 1562, Contracting and Tax Accountability Act of 2015 H.R. 1563, Federal Employee Tax Accountability Act of 2015 S. 1576, to prevent fraud by representative payees S. 1578, Taxpayer Bill of Rights Enhancement Act of 2015 S. 1591, Land Management Flexibility Workforce Act S. 1603, Border Jobs for Veterans Act of 2015 H.R. 2835, Border Jobs for Veterans Act of 2015 S. 1616, Saving Federal Dollars through Better Use of Government Purchase and Travel Cards Act of 2015 H.R. 1633, DHS Paid Administrative Leave Act of 2015 H.R. 1702, LEO Fair Retirement Act of 2015 H.R. 1735, FY 2016 National Defense Authorization Act S. 1376, FY 2016 National Defense Authorization Act H.R. 1753, Executive Cyberspace Coordination Act of 2015 H.R. 1817, No Bonus for Tax Delinquent IRS Employees Act of 2015 S. 1869, A bill to improve Federal network security and authorize and enhance an existing intrusion detection and prevention system for civilian Federal networks S. 1888, the USA Act H.R. 1941, Financial Institution Exams S. 1946, Tax Relief Extension Act of 2015 H.R. 1950, Sunset Inefficient and Unaccountable Government Act S. 1990, Federal Computer Security Act H.R. 1994, VA Accountability Act of 2015 S. 1082, Department of Veterans Affairs Accountability Act S. 2007, Federal Cybersecurity Workforce Assessment Act S. 2033, Federal Employee Paid Parental Leave Act of 2015 S. 2035, Federal Employee Fair Treatment Act of 2015 S. 2051, Improving Postal Operations, Service and Transparency Act of 2015 S. 2113, To harness the expertise, ingenuity and creativity of all people to help the federal government S. 2127, Dr. Chris Kirkpatrick Whistleblower Protection Act of 2015 S. 2133, To improve Federal agency financial and administrative controls and procedures H.R. 2146, Defending Public Safety Employees Retirement Act of 2015 H.R. 2254, the "Law Enforcement Officers Equity Act" H.R. 2385, CFPB Pay H.R. 2432, Federal Employee Gender Diversity Investment Act H.R. 2532, EASY Savings Act of 2015 H.R. 2741, Federal Employee Short-Term Disability Insurance Act of 2015 H.R. 2826, Government Transformation Act H.R. 2827, Competitive Service Act of 2015 S. 1580, Competitive Service Act of 2015 S. 1746, RECOVER Act H.R. 3029, RECOVER Act H.R. 3208, Retired Civil Servant Military Service Restoration Act of 2015 H.R. 3231, Federal Intern Protection Act of 2015 H.R. 3313, Cyber Defense of Federal Networks Act of 2015 H.R. 3360, Defense Against Digital Theft Act H.R. 3402, Federal Information Security Management Reform Act of 2015 H.R. 3418, Federal Protective Service Improvement and Accountability Act of 2015 H.R. 3470, Fair Chance Act H.R. 3572, DHS Headquarters Reform and Improvement Act of 2015 H.R. 3586, Border and Maritime Coordination Improvement Act H.R. 3635, Federal Employee Retroactive Pay Fairness Act

H.R. 1104, the "Fair Treatment for All Donations Act," legislation to amend Section 2522(a) of the Internal Revenue Code to reflect in statute currently stated IRS policy concerning tax deductions for gifts to 501(c) organizations; entire bill. S.1578, the "Taxpayer Bill of Rights Enhancement Act of 2015," legislation to ensure that IRS employees are familiar with the Taxpayer Bill of Rights, enhance penalties for violations of taxpayer rights, and enhance safeguards intended to protect confidential taxpayer information; entire bill. General education concerning the protection of confidential taxpayer information and legislative proposals to ensure the protection of such information from abuse by IRS employees.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE