Ending the Carried Interest Loophole Act
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Ending the Carried Interest Loophole Act This bill revises the tax treatment of partnership interests received in connection with the performance of services. It eliminates the concept of carried interest, a form of compensation received by certain partners in private equity, real estate, or hedge funds for investment management services. Under current law, such compensation can be deferred from taxation until income is realized by the partnership. The bill requires partners to recognize deemed compensation received from a partnership annually, taxed at ordinary income tax rates and subject to self-employment taxation. The bill eliminates a partner's ability to defer tax on such compensation.
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Filing registrants (7)
2024 · second_quarter · Taxation/Internal Revenue Code
Read twice and referred to the Committee on Finance.
Introduced in Senate
Bills with similar content found using semantic analysis.
Sources: Congress.gov
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), AIM Act (S. 1232/H.R. 2788), Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $640,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2024 · first_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), AIM Act (S. 1232/H.R. 2788), Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $730,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2023 · fourth_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), AIM Act (S. 1232/H.R. 2788), Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $1,170,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2023 · third_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), AIM Act (S. 1232/H.R. 2788), Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $680,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2023 · second_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), AIM Act (S. 1232/H.R. 2788), Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $590,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2023 · first_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $660,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2023 · first_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $660,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · fourth_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, the Consolidated Appropriations Act (H.R.2617), Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $1,290,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · third_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, including Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $550,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · second_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, including Public Law 115-97, Tax Cuts and Jobs Act, the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $510,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2022 · first_quarter · Taxation/Internal Revenue Code
Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, including Public Law 115-97, Tax Cuts and Jobs Act, the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.
Client expense: $580,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2021 · fourth_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Build Back Better Act (H.R.5376), Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity in health care, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974.
Client expense: $900,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
2021 · third_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Build Back Better Act (H.R.5376), Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity in health care, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974.
Client expense: $540,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
2021 · second_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity in health care, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974.
Client expense: $540,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
2021 · first_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity in health care, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974.
Client expense: $531,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
2020 · fourth_quarter · Taxation/Internal Revenue Code
Tax treatment of investment capital and start-up companies; and tax policy that encourages new company formation, such as Section 382 reform and R&D tax credit. Issues related to the Implementation of PL 115-97 - Tax Cuts and Jobs Act H.R. 1735/S. 781 - Carried Interest Fairness Act. S.1639 - Ending the Carried Interest Loophole Act. CEO and Worker Pension Fairness Act. Families First Coronavirus Response Act (emergency leave, refundable tax credit). CARES Act (payroll tax deferral, employee retention credit). Families First Coronavirus Response Act, Public Law No: 116-127; CARES Act, Public Law No: 116-136 H.R. 7917, IGNITE American Innovation Act. H.R. 6800, The HEROES Act. Health, Economic Assistance, Liability Protection and Schools (HEALS) Act.
Client expense: Not reported · Firm income: $60,000
2020 · fourth_quarter · Taxation/Internal Revenue Code
Issues related to the Tax Cuts and Jobs Act; Section 1061 regulations; capital gains tax policy; Carried Interest Fairness Act, H.R. 1735/S. 781; Ending the Carried Interest Loophole Act, S. 1639; carried interest capital gains; partnership tax policy; tax policy that encourages new company formation including: R&D credit, Section 1202, Section 382, stock options, medical device tax, tax extenders, opportunity zones, energy innovation tax issues, including the Energy Sector Innovation Credit Act HR 7196; Research & Development Tax Credit Expansion Act, S. 2207; CEO and Worker Pension Fairness Act; Families First Coronavirus Response Act; Issues related to the Coronavirus Aid, Relief, and Economic Security Act; Issues related to the Phase IV economic relief package including monetization of tax assets for growth companies and the employee retention tax credit; IGNITE American Innovation Act HR 7917; HEROES Act HR 6800; Tax bills to encourage American innovation and medical independence, HRs 7766, 7505, 7556; American Innovation and Jobs Act S. 4822
Client expense: $847,156 · Firm income: Not reported
2020 · fourth_quarter · Taxation/Internal Revenue Code
Legislative oversight of implementation of The Tax Cuts and Jobs Act. Carried Interest/Enterprise Value S.1639 - Ending the Carried Interest Loophole Act H.R. 1735 - Carried Interest Fairness Act of 2019 International tax reform. Taxation of pass-through entities. Taxation of financial products. Limitations on deductions including interest expense. 864(b) of the Internal Revenue Code - safe harbor for investment in U.S. securities and other assets by non-U.S. investors. Unrelated Business Income Tax (UBIT) Section 451(b) of the Internal Revenue Code. Legislative oversight of implementation of rules under 871(m) of the Internal Revenue Code. Financial Transaction Tax S. 2589 - to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations. H.R. 748 - Coronavirus Aid, Relief, and Economic Security Act or the CARES Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. (Tax Titles) H.R. 6201 - Families First Coronavirus Response Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak by providing paid sick leave, tax credits, and free COVID-19 testing; expanding food assistance and unemployment benefits; and increasing Medicaid funding. (Tax Titles)
Client expense: $770,000 · Firm income: Not reported
2020 · fourth_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2019 (S. 781 / H.R. 1735), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals related to Net Operating Loss; Proposals downward attribution tax treatment; Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974. Provisions related to the tax treatment of private equity, Proposals to alter the tax treatment of carried interest capital gains, including (H.R. 1735, S.781), Carried Interest Fairness Act of 2019, Tax provisions, (H.R.133) - Consolidated Appropriations Act, 2021.
Client expense: $640,000 · Firm income: Not reported
2020 · third_quarter · Taxation/Internal Revenue Code
Legislative oversight of implementation of The Tax Cuts and Jobs Act. Carried Interest/Enterprise Value S.1639 - Ending the Carried Interest Loophole Act H.R. 1735 - Carried Interest Fairness Act of 2019 International tax reform. Taxation of pass-through entities. Taxation of financial products. Limitations on deductions including interest expense. 864(b) of the Internal Revenue Code - safe harbor for investment in U.S. securities and other assets by non-U.S. investors. Unrelated Business Income Tax (UBIT) Section 451(b) of the Internal Revenue Code. Legislative oversight of implementation of rules under 871(m) of the Internal Revenue Code. Financial Transaction Tax S. 2589 - to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations. H.R. 748 - Coronavirus Aid, Relief, and Economic Security Act or the CARES Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. (Tax Titles) H.R. 6201 - Families First Coronavirus Response Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak by providing paid sick leave, tax credits, and free COVID-19 testing; expanding food assistance and unemployment benefits; and increasing Medicaid funding. (Tax Titles)
Client expense: $470,000 · Firm income: Not reported
2020 · third_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2019 (S. 781 / H.R. 1735), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals related to Net Operating Loss; Proposals downward attribution tax treatment; Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974.
Client expense: $400,000 · Firm income: Not reported
2020 · third_quarter · Taxation/Internal Revenue Code
Tax treatment of investment capital and start-up companies; and tax policy that encourages new company formation, such as Section 382 reform and R&D tax credit. Issues related to the Implementation of PL 115-97 - Tax Cuts and Jobs Act H.R. 1735/S. 781 - Carried Interest Fairness Act. S.1639 - Ending the Carried Interest Loophole Act. CEO and Worker Pension Fairness Act. Families First Coronavirus Response Act (emergency leave, refundable tax credit). CARES Act (payroll tax deferral, employee retention credit). Families First Coronavirus Response Act, Public Law No: 116-127; CARES Act, Public Law No: 116-136 H.R. 7917, IGNITE American Innovation Act. H.R. 6800, The HEROES Act.
Client expense: Not reported · Firm income: $60,000
2020 · third_quarter · Taxation/Internal Revenue Code
Issues related to the Tax Cuts ands Jobs Act; Section 1061 regulations; capital gains tax policy; Carried Interest Fairness Act, H.R. 1735/S. 781; Ending the Carried Interest Loophole Act, S. 1639; carried interest capital gains; partnership tax policy; tax policy that encourages new company formation including: R&D credit, Section 1202, Section 382, stock options, medical device tax, tax extenders, opportunity zones, energy innovation tax issues, including the Energy Sector Innovation Credit Act HR 7196; Research & Development Tax Credit Expansion Act, S. 2207; CEO and Worker Pension Fairness Act; Families First Coronavirus Response Act; Issues related to the Coronavirus Aid, Relief, and Economic Security Act; Issues related to the Phase IV economic relief package including monetization of tax assets for growth companies and the employee retention tax credit; IGNITE American Innovation Act HR 7917; HEROES Act HR 6800; Tax bills to encourage American innovation and medical independence, HRs 7766, 7505, 7556
Client expense: $588,387 · Firm income: Not reported
2020 · second_quarter · Taxation/Internal Revenue Code
Issues related to the Tax Cuts ands Jobs Act; capital gains tax policy; Carried Interest Fairness Act, H.R. 1735/S. 781; Ending the Carried Interest Loophole Act, S. 1639; carried interest capital gains; partnership tax policy; tax policy that encourages new company formation including: R&D credit, Section 1202, Section 382, stock options, medical device tax, tax extenders, opportunity zones, energy innovation tax issues, including the Energy Sector Innovation Credit Act HR 7196; Research & Development Tax Credit Expansion Act, S. 2207; CEO and Worker Pension Fairness Act; Families First Coronavirus Response Act; Issues related to the Coronavirus Aid, Relief, and Economic Security Act; Issues related to the Phase IV economic relief package including monetization of tax assets for growth companies and the employee retention tax credit.
Client expense: $609,952 · Firm income: Not reported
2020 · second_quarter · Taxation/Internal Revenue Code
Legislative oversight of implementation of The Tax Cuts and Jobs Act. Carried Interest/Enterprise Value S.1639 - Ending the Carried Interest Loophole Act H.R. 1735 - Carried Interest Fairness Act of 2019 International tax reform. Taxation of pass-through entities. Taxation of financial products. Limitations on deductions including interest expense. 864(b) of the Internal Revenue Code - safe harbor for investment in U.S. securities and other assets by non-U.S. investors. Unrelated Business Income Tax (UBIT) Section 451(b) of the Internal Revenue Code. Legislative oversight of implementation of rules under 871(m) of the Internal Revenue Code. Financial Transaction Tax S. 2589 - to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations. H.R. 748 - Coronavirus Aid, Relief, and Economic Security Act or the CARES Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. (Tax Titles) H.R. 6201 - Families First Coronavirus Response Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak by providing paid sick leave, tax credits, and free COVID-19 testing; expanding food assistance and unemployment benefits; and increasing Medicaid funding. (Tax Titles)
Client expense: $1,050,000 · Firm income: Not reported
2020 · second_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Public Law 115-97, Tax Cuts and Jobs Act, Carried Interest Tax Fairness Act of 2019 (S. 781 / H.R. 1735), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848); Proposals related to equitable tax treatment of private equity, Transparency in Health Care Investments Act of 2020 (H.R. 5825); Proposals related to Net Operating Loss; Proposals downward attribution tax treatment; Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process. Department of Labor guidance on Employee Retirement Income Security Act of 1974.
Client expense: $500,000 · Firm income: Not reported
2020 · second_quarter · Taxation/Internal Revenue Code
Tax treatment of investment capital and start-up companies; and tax policy that encourages new company formation, such as Section 382 reform and R&D tax credit. Issues related to the Implementation of PL 115-97 - Tax Cuts and Jobs Act H.R. 1735/S. 781 - Carried Interest Fairness Act. S.1639 - Ending the Carried Interest Loophole Act. CEO and Worker Pension Fairness Act. Families First Coronavirus Response Act (emergency leave, refundable tax credit). CARES Act (payroll tax deferral, employee retention credit). Families First Coronavirus Response Act, Public Law No: 116-127; CARES Act, Public Law No: 116-136
Client expense: Not reported · Firm income: $60,000
2020 · second_quarter · Taxation/Internal Revenue Code
Like kind exchanges (Sec. 1031) - no bill H.R. 1680/S.750 The New Market Tax Credits Extension Act - ALL H.R. 6175 REHAB Act - ALL H.R. 1735/S. 781 Carried Interest Fairness Act - ALL S. 1639 Ending the Carried Interest Loophole Act - ALL S. 2942 to provide that certain contributions by government entities are treated as contributions to capital H.R. 748 CARES Act tax provisions [see Sec 2301 Employee Retention Tax Credit Sec 2303 Modifications of NOLs Modification of REIT ownership rule IRC sec. 856(d)] S. 3814 RESTART ACT - ALL H.R. 7079 Clean Start Back to Work Act - ALL H.R. 6799 Keeping the Lights On Act - ALL
Client expense: $560,000 · Firm income: Not reported
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
2020 · first_quarter · Taxation/Internal Revenue Code
Legislative oversight of implementation of The Tax Cuts and Jobs Act. Carried Interest/Enterprise Value S.1639 - Ending the Carried Interest Loophole Act H.R. 1735 - Carried Interest Fairness Act of 2019 International tax reform. Taxation of pass-through entities. Taxation of financial products. Limitations on deductions including interest expense. 864(b) of the Internal Revenue Code - safe harbor for investment in U.S. securities and other assets by non-U.S. investors. Unrelated Business Income Tax (UBIT) Section 451(b) of the Internal Revenue Code. Legislative oversight of implementation of rules under 871(m) of the Internal Revenue Code. Financial Transaction Tax S. 2589 - to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations. H.R. 748 - Coronavirus Aid, Relief, and Economic Security Act or the CARES Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. (Tax Titles) H.R. 6201 - Families First Coronavirus Response Act to respond to the COVID-19 (i.e., coronavirus disease 2019) outbreak by providing paid sick leave, tax credits, and free COVID-19 testing; expanding food assistance and unemployment benefits; and increasing Medicaid funding. (Tax Titles)
Client expense: $890,000 · Firm income: Not reported
2020 · first_quarter · Taxation/Internal Revenue Code
Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6175, Revitalizing Economies, Housing, and Businesses Act of 2020 or the REHAB Act of 2020, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Draft legislative proposal to amend the Internal Revenue Code of 1986 to provide a special allowance for certain real property placed in service during the COVID-19 pandemic. Support infrastructure bill including tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extending and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. Energy We support extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Fire Sprinklers H.R. 4685, High Rise Fire Sprinkler Incentive Act of 2019, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions. Tax Treatment of Capital Income Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Letter to Treasury and Internal Revenue Service requesting that the deadlines to identify replacement property and / or complete like-kind exchanges be extended per the relief described in Rev. Proc. 2018-58 and authorized under Internal Revenue Code 7508A. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.
2020 · first_quarter · Taxation/Internal Revenue Code
Tax treatment of investment capital and start-up companies; and tax policy that encourages new company formation, such as Section 382 reform and R&D tax credit. Issues related to the Implementation of PL 115-97 - Tax Cuts and Jobs Act H.R. 1735/S. 781 - Carried Interest Fairness Act. S.1639 - Ending the Carried Interest Loophole Act. CEO and Worker Pension Fairness Act. Families First Coronavirus Response Act (emergency leave, refundable tax credit). CARES Act (payroll tax deferral, employee retention credit).
Client expense: Not reported · Firm income: $60,000
2020 · first_quarter · Taxation/Internal Revenue Code
Implementation of tax reform, including pass-through deduction (Sec. 199A), interest limitation (Sec. 163(j)), contributions to capital (Sec. 118), like kind exchanges (Sec. 1031), Opportunity Zones (Sec. 1400 Z),venture capital and partnership issues. H.R. 2210 Foreign Investment in Real Property Act repeal - ALL H.R. 1680/S.750 The New Market Tax Credits Extension Act - ALL H.R. 6175 REHAB Act - ALL H.R. 1735/S. 781 Carried Interest Fairness Act - ALL S. 1639 Ending the Carried Interest Loophole Act - ALL H.R. 1869/S. 803 Restoring Investment in Improvements Act - ALL Tax Technical corrections S. 2942 to provide that certain contributions by government entities are treated as contributions to capital H.R. 748 CARES Act tax provisions [see Sec 2301 Employee Retention Tax Credit Sec 2303 Modifications of NOLs Sec 2307 Technical correction for QIP Modification of REIT ownership rule IRC sec. 856(d)]
Client expense: $320,000 · Firm income: Not reported
2020 · first_quarter · Taxation/Internal Revenue Code
Implementation of tax reform, including pass-through deduction (Sec. 199A), interest limitation (Sec. 163(j)), contributions to capital (Sec. 118), like kind exchanges (Sec. 1031), Opportunity Zones (Sec. 1400 Z),venture capital and partnership issues. H.R. 2210 Foreign Investment in Real Property Act repeal - ALL H.R. 1680/S.750 The New Market Tax Credits Extension Act - ALL H.R. 6175 REHAB Act - ALL H.R. 1735/S. 781 Carried Interest Fairness Act - ALL S. 1639 Ending the Carried Interest Loophole Act - ALL H.R. 1869/S. 803 Restoring Investment in Improvements Act - ALL Tax Technical corrections S. 2942 to provide that certain contributions by government entities are treated as contributions to capital H.R. 748 CARES Act tax provisions [see Sec 2301 Employee Retention Tax Credit Sec 2303 Modifications of NOLs Sec 2307 Technical correction for QIP Modification of REIT ownership rule IRC sec. 856(d)]
Client expense: $320,000 · Firm income: Not reported
2020 · first_quarter · Taxation/Internal Revenue Code
Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6175, Revitalizing Economies, Housing, and Businesses Act of 2020 or the REHAB Act of 2020, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Draft legislative proposal to amend the Internal Revenue Code of 1986 to provide a special allowance for certain real property placed in service during the COVID-19 pandemic. Support infrastructure bill including tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extending and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. Energy We support extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Fire Sprinklers H.R. 4685, High Rise Fire Sprinkler Incentive Act of 2019, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions. Tax Treatment of Capital Income Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Letter to Treasury and Internal Revenue Service requesting that the deadlines to identify replacement property and / or complete like-kind exchanges be extended per the relief described in Rev. Proc. 2018-58 and authorized under Internal Revenue Code 7508A. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.
2020 · first_quarter · Taxation/Internal Revenue Code
Issues related to the Tax Cuts ands Jobs Act; capital gains tax policy; Carried Interest Fairness Act, H.R. 1735/S. 781; Ending the Carried Interest Loophole Act, S. 1639; carried interest capital gains; partnership tax policy; tax policy that encourages new company formation including: R&D credit, Section 1202, Section 382, stock options, medical device tax, tax extenders, opportunity zones, energy innovation tax issues, including the Energy Sector Innovation Credit Act HR 7196; Research & Development Tax Credit Expansion Act, S. 2207; CEO and Worker Pension Fairness Act; Families First Coronavirus Response Act; Issues related to the Coronavirus Aid, Relief, and Economic Security Act; Request to allow electronic 83(b) filings;
Client expense: $569,176 · Firm income: Not reported
2020 · first_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including Tax Cuts and Jobs Act (Public Law No. 115-97), Carried Interest Tax Fairness Act of 2019 (S. 781/H.R. 1735), Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155/H.R. 3848); Proposals related to equitable tax treatment of private equity, Transparency in Health Care Investments Act of 2020 (H.R. 5825); CARES Act (Public Law No: 116-136, H.R. 748/S. 3548), legislation and regulations related to private equity; Proposals related to Net Operating Loss; Proposals regarding downward attribution tax treatment; Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process.
Client expense: $640,000 · Firm income: Not reported
2019 · fourth_quarter · Taxation/Internal Revenue Code
Depreciation Rules Requested Congress pass legislation to clarify that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Note: This proposed rule, as well as proposed rule: Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115420-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds, became a final regulation on December 19, 2019: Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9889, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. H.R. 5011, Opportunity Zone Accountability and Transparency Act, to amend the Internal Revenue Code of 1986 to require reporting by qualified opportunity funds, all provisions. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. S. 2994, Improving and Reinstating the Monitoring, Prevention, Accountability, Certification, and Transparency Provisions of Opportunity Zones or the IMPACT Act, to amend the Internal Revenue Code of 1986 to require information reporting with respect to the qualified opportunity zone tax incentives enacted by the 2017 tax reform legislation, to require public reports related to such tax incentives, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Energy H.R. 1865, Further Consolidated Appropriations Act, 2020 (became Public Law 116-94), Division Q -- Revenue Provisions, Taxpayer Certainty and Disaster Relief Act of 2019, Section 129: Energy efficient homes credit and Section 131: Energy efficient commercial buildings deduction. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Estate Tax Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017. Tax Administration Letter to Treasury Department and IRS requesting a delay of the implementation of the 2019 Draft Form 1065 and Schedule K-1 by at least one year (until 2020) to allow for a full public review and comment process. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.
2019 · fourth_quarter · Taxation/Internal Revenue Code
Legislative oversight of implementation of The Tax Cuts and Jobs Act. Carried Interest/Enterprise Value S.1639 - Ending the Carried Interest Loophole Act H.R. 1735 - Carried Interest Fairness Act of 2019 International tax reform. Taxation of pass-through entities. Taxation of financial products. Limitations on deductions including interest expense. 864(b) of the Internal Revenue Code - safe harbor for investment in U.S. securities and other assets by non-U.S. investors. Unrelated Business Income Tax (UBIT) Section 451(b) of the Internal Revenue Code. Legislative oversight of implementation of rules under 871(m) of the Internal Revenue Code. Financial Transaction Tax S. 2589 - to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations.
Client expense: $810,000 · Firm income: Not reported
2019 · fourth_quarter · Taxation/Internal Revenue Code
Issues related to Tax Cuts & Jobs Act, H.R.1735 & S.781 - Carried Interest Fairness Act, S.1639 - Ending the Carried Interest Loophole Act, and other tax issues affecting venture capital industry.
Client expense: Not reported · Firm income: $60,000
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
2019 · fourth_quarter · Taxation/Internal Revenue Code
Tax treatment of investment capital and start-up companies; and tax policy that encourages new company formation, such as Section 382 reform and R&D tax credit. Issues related to the Implementation of PL 115-97 - Tax Cuts and Jobs Act H.R. 1735/S. 781 - Carried Interest Fairness Act. S.1639 - Ending the Carried Interest Loophole Act.
Client expense: Not reported · Firm income: $60,000
2019 · fourth_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Tax Cuts and Jobs Act (Public Law 115-97), Carried Interest Tax Fairness Act of 2019 (H.R. 1735) and Carried Interest Fairness Act of 2019 (S. 781); Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process; Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848).
Client expense: $650,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2019 · fourth_quarter · Taxation/Internal Revenue Code
Depreciation Rules Requested Congress pass legislation to clarify that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Note: This proposed rule, as well as proposed rule: Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115420-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds, became a final regulation on December 19, 2019: Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9889, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. H.R. 5011, Opportunity Zone Accountability and Transparency Act, to amend the Internal Revenue Code of 1986 to require reporting by qualified opportunity funds, all provisions. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. S. 2994, Improving and Reinstating the Monitoring, Prevention, Accountability, Certification, and Transparency Provisions of Opportunity Zones or the IMPACT Act, to amend the Internal Revenue Code of 1986 to require information reporting with respect to the qualified opportunity zone tax incentives enacted by the 2017 tax reform legislation, to require public reports related to such tax incentives, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Energy H.R. 1865, Further Consolidated Appropriations Act, 2020 (became Public Law 116-94), Division Q -- Revenue Provisions, Taxpayer Certainty and Disaster Relief Act of 2019, Section 129: Energy efficient homes credit and Section 131: Energy efficient commercial buildings deduction. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Estate Tax Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017. Tax Administration Letter to Treasury Department and IRS requesting a delay of the implementation of the 2019 Draft Form 1065 and Schedule K-1 by at least one year (until 2020) to allow for a full public review and comment process. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.
2019 · fourth_quarter · Taxation/Internal Revenue Code
Implementation of tax reform, including pass-through deduction (Sec. 199A), interest limitation (Sec. 163(j)), contributions to capital (Sec. 118), like kind exchanges (Sec. 1031), Opportunity Zones (Sec. 1400 Z),venture capital and partnership issues. H.R. 1933, To prohibit States from retroactively imposing a sales tax collection duty on a remote seller, and for other purposes. ALL H.R. 2210 Foreign Investment in Real Property Act repeal - ALL H.R. 1680/S.750 The New Market Tax Credits Extension Act - ALL H.R. 3301 Taxpayer Certainty and Disaster Tax Relief Act, Sec. 141 New Markets Tax Credit H.R. 1735/S. 781 Carried Interest Fairness Act - ALL S. 1639 Ending the Carried Interest Loophole Act - ALL H.R. 1869/S. 803 Restoring Investment in Improvements Act - ALL Tax Technical corrections Energy Efficient Commercial Buildings deduction (Sec. 179D) S. 2942 to provide that certain contributions by government entities are treated as contributions to capital
Client expense: $290,000 · Firm income: Not reported
2019 · fourth_quarter · Taxation/Internal Revenue Code
Issues related to the Tax Cuts ands Jobs Act; capital gains tax policy; Carried Interest Fairness Act, H.R. 1735/S. 781; Ending the Carried Interest Loophole Act, S. 1639; carried interest capital gains; partnership tax policy; tax policy that encourages new company formation including: R&D credit, Section 1202, Section 382, stock options, medical device tax, tax extenders, opportunity zones, energy innovation tax issues, including the Energy Sector Innovation Credit Act HR 7196; Research & Development Tax Credit Expansion Act, S. 2207
Client expense: $775,933 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
2019 · third_quarter · Taxation/Internal Revenue Code
Legislative oversight of implementation of The Tax Cuts and Jobs Act. Carried Interest/Enterprise Value S.1639 - Ending the Carried Interest Loophole Act H.R. 1735 - Carried Interest Fairness Act of 2019 International tax reform. Taxation of pass-through entities. Taxation of financial products. Limitations on deductions including interest expense. 864(b) of the Internal Revenue Code - safe harbor for investment in U.S. securities and other assets by non-U.S. investors. Unrelated Business Income Tax (UBIT) Section 451(b) of the Internal Revenue Code. Legislative oversight of implementation of rules under 871(m) of the Internal Revenue Code. Financial Transaction Tax
Client expense: $720,000 · Firm income: Not reported
2019 · third_quarter · Taxation/Internal Revenue Code
Depreciation Rules Requested Congress pass legislation or, alternatively, that the Treasury Department revisit Rev. Proc. 2019-08 and clarify through the regulatory process that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3479, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 1956, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Legislative proposal, Renters Tax Credit Act of 2019, to amend the Internal Revenue Code of 1986 to provide a tax credit to taxpayers who provide reductions in rent to their tenants under State rental reduction programs, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Legislative proposal to spur housing development and infrastructure through: (1) tax-exempt bond financing in designated areas; and (2) increased community development block grant funding provided to States, local governments, and Indian tribes based on the extent to which those entities streamline development requirements for affordable housing, eliminate or reduce impact fees, and provide assurances they will supplement costs. Energy Support extending Energy efficient homes credit (IRC 45L) and Energy efficient commercial buildings deduction (IRC 179D). Also support modifying 179D to incentivize retrofits and allow REITs to benefit. H.R. 3301, The Taxpayer Certainty and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster relief, and for other purposes. Section 129: Energy efficient homes credit. Section 131: Energy efficient commercial buildings deduction. Section 201: Reduction of unified credit against estate tax. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 1288, Clean Energy for America Act, Title III -- Energy Efficiency Incentives: Section 301: Credit for new energy efficient residential buildings, Section 304: Deduction for new energy efficient commercial buildings, Section 305: Energy efficiency deduction for existing commercial buildings, and Section 306: Temporary extension of existing energy efficiency incentives. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. Legislative tax proposal (Energy Efficient Qualified Improvement Property (E-QUIP)) to establish a 10-year depreciation period for high-performance energy-efficient qualified improvement property (i.e., heating, cooling, ventilation and hot water; lighting; and envelope) installed in a covered building, including a multifamily building. Legislative proposal, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. H.R. 3848, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. S. 2155, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. Taxation of Capital Gains Monitored and analyzed proposal for Treasury Department to issue regulation that would index capital gains to inflation. Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security.
2019 · third_quarter · Taxation/Internal Revenue Code
Provisions related to the tax treatment of private equity in various budget proposals and tax reform proposals including, Public Law 115-97, Tax Cuts and Jobs Act, H.R. 2295 Carried Interest Tax Fairness Act of 2017 and S. 1020 Carried Interest Fairness Act of 2017; Proposals to alter the tax treatment of interest deductibility; Proposals to alter the tax treatment of pass-through businesses; Proposals to alter the tax treatment of carried interest capital gains; Proposals to alter the tax treatment of certain publicly traded partnerships; Laws and regulations relating to the partnership audit process; Ending the Carried Interest Loophole Act (S. 1639), Stop Wall Street Looting Act (S. 2155 / H.R. 3848).
Client expense: $480,000 · Firm income: Not reported
Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, White House Office
2019 · third_quarter · Taxation/Internal Revenue Code
Depreciation Rules Requested Congress pass legislation or, alternatively, that the Treasury Department revisit Rev. Proc. 2019-08 and clarify through the regulatory process that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3479, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 1956, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Legislative proposal, Renters Tax Credit Act of 2019, to amend the Internal Revenue Code of 1986 to provide a tax credit to taxpayers who provide reductions in rent to their tenants under State rental reduction programs, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Legislative proposal to spur housing development and infrastructure through: (1) tax-exempt bond financing in designated areas; and (2) increased community development block grant funding provided to States, local governments, and Indian tribes based on the extent to which those entities streamline development requirements for affordable housing, eliminate or reduce impact fees, and provide assurances they will supplement costs. Energy Support extending Energy efficient homes credit (IRC 45L) and Energy efficient commercial buildings deduction (IRC 179D). Also support modifying 179D to incentivize retrofits and allow REITs to benefit. H.R. 3301, The Taxpayer Certainty and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster relief, and for other purposes. Section 129: Energy efficient homes credit. Section 131: Energy efficient commercial buildings deduction. Section 201: Reduction of unified credit against estate tax. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 1288, Clean Energy for America Act, Title III -- Energy Efficiency Incentives: Section 301: Credit for new energy efficient residential buildings, Section 304: Deduction for new energy efficient commercial buildings, Section 305: Energy efficiency deduction for existing commercial buildings, and Section 306: Temporary extension of existing energy efficiency incentives. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. Legislative tax proposal (Energy Efficient Qualified Improvement Property (E-QUIP)) to establish a 10-year depreciation period for high-performance energy-efficient qualified improvement property (i.e., heating, cooling, ventilation and hot water; lighting; and envelope) installed in a covered building, including a multifamily building. Legislative proposal, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. H.R. 3848, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. S. 2155, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. Taxation of Capital Gains Monitored and analyzed proposal for Treasury Department to issue regulation that would index capital gains to inflation. Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security.
2019 · third_quarter · Taxation/Internal Revenue Code
Tax treatment of investment capital and start-up companies; and tax policy that encourages new company formation, such as Section 382 reform and R&D tax credit. Issues related to the Implementation of PL 115-97 - Tax Cuts and Jobs Act H.R. 1735/S. 781 - Carried Interest Fairness Act. S.1639 - Ending the Carried Interest Loophole Act.
Client expense: Not reported · Firm income: $60,000
2019 · third_quarter · Taxation/Internal Revenue Code
Issues related to the Tax Cuts ands Jobs Act; Carried Interest Fairness Act, H.R. 1735/S. 781; Ending the Carried Interest Loophole Act, S. 1639; carried interest capital gains; partnership tax policy; tax policy that encourages new company formation including: R&D credit, Section 1202, Section 382, stock options, medical device tax, tax extenders, opportunity zones, energy innovation tax issues; Research & Development Tax Credit Expansion Act, S. 2207
Client expense: $670,103 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of the Vice President of the United States, SENATE
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Reserve System, Financial Crimes Enforcement Network (FinCEN), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
Government targets: HOUSE OF REPRESENTATIVES, SENATE
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of the Vice President of the United States, SENATE
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, White House Office
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of the Vice President of the United States, SENATE
Government targets: Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Client expense: $1,440,000 · Firm income: Not reported
Government targets: Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Postal Service (USPS)
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of the Vice President of the United States, SENATE
Government targets: Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
Government targets: Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Reserve System, HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
Client expense: $1,440,000 · Firm income: Not reported
Government targets: Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Postal Service (USPS)
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Defense, Dept of (DOD), Federal Communications Commission (FCC), Federal Reserve System, Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), Treasury, Dept of, White House Office
Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Treasury, Dept of, White House Office
Client expense: $1,050,000 · Firm income: Not reported
Government targets: Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Postal Service (USPS)
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of the Vice President of the United States, SENATE
Client expense: $1,550,000 · Firm income: Not reported
Government targets: Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Postal Service (USPS)
Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Client expense: $1,080,000 · Firm income: Not reported
Government targets: Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, U.S. Postal Service (USPS)
Client expense: $1,080,000 · Firm income: Not reported
Government targets: Army, Dept of (Corps of Engineers), Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Natl Labor Relations Board (NLRB), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Treasury, Dept of, U.S. Postal Service (USPS)
Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of the Vice President of the United States, SENATE