Filing Relief for Natural Disasters Act

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

Client expense: $1,160,000 · Firm income: Not reported

Government targets: Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Small Business Administration (SBA), Treasury, Dept of

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (, unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3;

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

Government targets: Executive Office of the President (EOP), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

Client expense: $1,240,000 · Firm income: Not reported

Government targets: Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Small Business Administration (SBA), Treasury, Dept of