National Disaster Tax Relief Act of 2015

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits. S. 2962, Affordable Housing Credit Improvement Act. House Republican Tax Reform Task Force Blueprint. S. 3237, Affordable Housing Credit Improvement Act of 2016. S. 3384, the Middle-Income Housing Tax Credit Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 765, To amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property. H.R. 855, To amend the Internal Revenue Code of 1986 to permanently extend the new markets tax credit, and for other purposes H.R. 1001, To amend the Internal Revenue Code of 1986 to terminate certain energy tax subsidies and lower the corporate income tax rate H.R. 1142, To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program H.R. 3110, National Disaster Tax Relief Act of 2015 S. 394, A bill to amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property S. 591, New Markets Tax Credit Extension Act of 2015 S.1795, National Disaster Tax Relief Act of 2015 S. 2962, Affordable Housing Credit Improvement Act of 2016

Client expense: $137,712 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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; Expiration & Renewal procedures for ITINs; Reporting requirements for foreign accounts held by U.S. taxpayers resident overseas; 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 Implementation of Certified Professional Employer Organization Process; IRS proposed regulations guidance under Section 2801; IRS private debt collection; 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; Notice 2015-40 Revenue Recognition; Section 199 Online Software; 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; Applicability of proposed section 385 regulations to partnerships; 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)

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits. S. 2962, Affordable Housing Credit Improvement Act. House Republican Tax Reform Task Force Blueprint. S. 3237, Affordable Housing Credit Improvement Act of 2016. S. 3384, the Middle-Income Housing Tax Credit Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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)

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits. S. 2962, Affordable Housing Credit Improvement Act. House Republican Tax Reform Task Force Blueprint.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 765, To amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property H.R. 855, To amend the Internal Revenue Code of 1986 to permanently extend the new markets tax credit, and for other purposes H.R. 1001, To amend the Internal Revenue Code of 1986 to terminate certain energy tax subsidies and lower the corporate income tax rate H.R. 1142, To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program H.R. 3110, National Disaster Tax Relief Act of 2015 S. 394, A bill to amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property S. 591, New Markets Tax Credit Extension Act of 2015 S. 1193, A bill to amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program S. 1795, National Disaster Tax Relief Act

Client expense: $22,123 · Firm income: Not reported

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

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 765, To amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property. H.R. 855, To amend the Internal Revenue Code of 1986 to permanently extend the new markets tax credit, and for other purposes. H.R. 1001, To amend the Internal Revenue Code of 1986 to terminate certain energy tax subsidies and lower the corporate income tax rate. H.R. 1142, To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. H.R. 3110, National Disaster Tax Relief Act of 2015 S. 394, A bill to amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property. S. 591, New Markets Tax Credit Extension Act of 2015 S. 1193, A bill to amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program S. 1795, National Disaster Tax Relief Act

Client expense: $258,541 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

H.R. 765, To amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property. H.R. 855, To amend the Internal Revenue Code of 1986 to permanently extend the new markets tax credit, and for other purposes. H.R. 1001, To amend the Internal Revenue Code of 1986 to terminate certain energy tax subsidies and lower the corporate income tax rate. H.R. 1142, To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. H.R. 3110, National Disaster Tax Relief Act of 2015 S. 394, A bill to amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property. S. 591, New Markets Tax Credit Extension Act of 2015 S. 1193, A bill to amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program S. 1795, National Disaster Tax Relief Act

Client expense: $123,876 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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);