mr EDMUND PERRY

Dodd-Frank Wall Street Reform: H.R. 634/S.888 Business Risk Mitigation and Price Stabilization Act of 2013 (Exempt End-Users from Margin); H.R. 677 Inter-Affiliate Clarification Act (Exempt End-Users from Inter-Company Affiliate Swaps).

Dodd-Frank Wall Street Reform: H.R. 634 Business Risk Mitigation and Price Stabilization Act of 2013 (Exempt End-Users from Margin); H.R. 766 Paying a Fair Share Act of 2013 (Exempt End -Users from Inter-Company Affiliate Swaps).

Dodd-Frank Wall Street Reform: H.R. 634/S.888 Business Risk Mitigation and Price Stabilization Act of 2013 (Exempt End-Users from Margin); H.R. 677 Inter-Affiliate Clarification Act (Exempt End-Users from Inter-Company Affiliate Swaps).

Dodd-Frank Wall Street Reform: H.R. 634/S.888 Business Risk Mitigation and Price Stabilization Act of 2013 (Exempt End-Users from Margin); H.R. 677 Inter-Affiliate Clarification Act (Exempt End-Users from Inter-Company Affiliate Swaps).

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 Revise IRC of 1986 to make CFC look-through Section 954(c)6 permanent, H.R. 749 Amend IRC of 1986 to make active financing Section 954(h) permanent, S. 2075 "CUT" Unjustified Loopholes Act, S. 1346. Stop Tax Haven Abuse Act. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research & Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities with Tax Support Act 2011". Other Treasury and IRS Regulations: Foreign Account Tax Compliance Act "FATCA" regulations for Section 1471-1474, Notice 2012-15 on Sections 909 and 901(m) on Foreign Tax Credits. Bilateral Income Tax Treaties: Spain, Korea, Brazil, India, and China. OECD Guidelines and U.S. Treasury Comments on Taxation: IP and Intangibles and Cross-border Services, Business Restructuring and PE Issues. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", H.R. 1439 "The Business Activity Tax Simplification Act". Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 Revise IRC of 1986 to make CFC look-through Section 954(c)6 permanent, H.R. 749 Amend IRC of 1986 to make active financing Section 954(h) permanent, S. 2075 "CUT" Unjustified Loopholes Act, S. 1346. Stop Tax Haven Abuse Act. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research & Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities with Tax Support Act 2011". Other Treasury and IRS Regulations: Foreign Account Tax Compliance Act "FATCA" regulations for Section 1471-1474, Notice 2012-15 on Sections 909 and 901(m) on Foreign Tax Credits. Bilateral Income Tax Treaties: Spain, Korea, Brazil, India, and China. OECD Guidelines and U.S. Treasury Comments on Taxation: IP and Intangibles and Cross-border Services, Business Restructuring and PE Issues. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", H.R. 1439 "The Business Activity Tax Simplification Act". Taxation Issues for the "Cloud" and Services.

Dodd-Frank Wall Street Reform: H.R. 2779 (Exempt end-Users from Margin) and H.R. 2682 (Exempt End -Uses from Inter-Company Affiliate Swaps).

H.R. 2682 H.R. 2779 Dodd-Frank Wall Street Reform. Proposed Rulemaking: Proposed rules for Margin Requirements and Inter-Affiliate Swaps for Derivatives (Title VII of Dodd-Frank Act).

Dodd-Frank Wall Street Reform: H.R. 2779 Exempt Inter-Affiliate Swaps from the Regulatory Requirements of Title VII of the Dodd-Frank Act; H.R. 2682 Business Risk Mitigation and Price Stabilization Act. Proposed Rulemaking: CTFC rules regarding use of SWAPS by ERISA Pension Plans.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 Revise IRC of 1986 to make CFC look-through Section 954(c)6 permanent, H.R. 749 Amend IRC of 1986 to make active financing Section 954(h) permanent, S. 2075 "CUT" Unjustified Loopholes Act, S. 1346. Stop Tax Haven Abuse Act. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research & Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities with Tax Support Act 2011". Other Treasury and IRS Regulations: Foreign Account Tax Compliance Act "FATCA" regulations for Section 1471-1474, Notice 2012-15 on Sections 909 and 901(m) on Foreign Tax Credits. Bilateral Income Tax Treaties: Spain, Korea, Brazil, India, and China. OECD Guidelines and U.S. Treasury Comments on Taxation: IP and Intangibles and Cross-border Services, Business Restructuring and PE Issues. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", H.R. 1439 "The Business Activity Tax Simplification Act". Taxation Issues for the "Cloud" and Services.

Dodd-Frank Wall Street Reform: H.R. 2779 (Exempt end-Users from Margin) and H.R. 2682 (Exempt End -Uses from Inter-Company Affiliate Swaps).

Dodd-Frank Wall Street Reform: H.R. 2779 Exempt Inter-Affiliate Swaps from the Regulatory Requirements of Title VII of the Dodd-Frank Act; H.R. 2682 Business Risk Mitigation and Price Stabilization Act. Proposed Rulemaking: CTFC rules regarding use of SWAPS by ERISA Pension Plans.

H.R. 2682 H.R. 2779 Dodd-Frank Wall Street Reform. Proposed Rulemaking: Proposed rules for Margin Requirements and Inter-Affiliate Swaps for Derivatives (Title VII of Dodd-Frank Act).

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 Revise IRC of 1986 to make CFC look-through Section 954(c)6 permanent, H.R. 749 Amend IRC of 1986 to make active financing Section 954(h) permanent, S. 2075 "CUT" Unjustified Loopholes Act, S. 1346. Stop Tax Haven Abuse Act. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research & Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities with Tax Support Act 2011". Other Treasury and IRS Regulations: Foreign Account Tax Compliance Act "FATCA" regulations for Section 1471-1474, Notice 2012-15 on Sections 909 and 901(m) on Foreign Tax Credits. Bilateral Income Tax Treaties: Spain, Korea, Brazil, India, and China. OECD Guidelines and U.S. Treasury Comments on Taxation: IP and Intangibles and Cross-border Services, Business Restructuring and PE Issues. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", H.R. 1439 "The Business Activity Tax Simplification Act". Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 Revise IRC of 1986 to make CFC look-through Section 954(c)6 permanent, H.R. 749 Amend IRC of 1986 to make active financing Section 954(h) permanent, S. 2075 "CUT" Unjustified Loopholes Act, S. 1346. Stop Tax Haven Abuse Act. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research & Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities with Tax Support Act 2011". Other Treasury and IRS Regulations: Foreign Account Tax Compliance Act "FATCA" regulations for Section 1471-1474, Notice 2012-15 on Sections 909 and 901(m) on Foreign Tax Credits. Bilateral Income Tax Treaties: Spain, Korea, Brazil, India, and China. OECD Guidelines and U.S. Treasury Comments on Taxation: IP and Intangibles and Cross-border Services, Business Restructuring and PE Issues. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", H.R. 1439 "The Business Activity Tax Simplification Act". Taxation Issues for the "Cloud" and Services.

Dodd-Frank Wall Street Reform and Consumer Protection Act - derivative reform, captive finance, proxy access; pay ratio: H.R. 1062 Pay Ratio Repeal. Proposed Rulemaking: Facilitating Shareholder Director Nominations; Financial Stability Oversight Council; Derivatives.

Dodd-Frank Wall Street Reform: H.R. 1062 - Pay Ratio Repeal; H.R. 2779, A bill to exempt inter-affiliate swaps for certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform & Consumer Protection Act; S. 1650, Dodd-Frank Improvement Act of 2011. Proposed Rulemaking: Executive compensation reporting; CFTC Swaps for ERISA Plans; Pay Ratio.

Dodd-Frank Wall Street Reform: H.R. 1062 - Pay Ratio Repeal; H.R. 2779, A bill to exempt inter-affiliate swaps for certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform & Consumer Protection Act; S. 1650, Dodd-Frank Improvement Act of 2011. Proposed Rulemaking: Executive compensation reporting; CFTC Swaps for ERISA Plans; Pay Ratio.

Dodd-Frank Wall Street Reform: H.R. 1062 - Pay Ratio Repeal; H.R. 2779, A bill to exempt inter-affiliate swaps for certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform & Consumer Protection Act; S. 1650, Dodd-Frank Improvement Act of 2011. Proposed Rulemaking: Executive compensation reporting; CFTC Swaps for ERISA Plans; Pay Ratio.

Dodd-Frank Wall Street Reform: H.R. 1062 - Pay Ratio Repeal; H.R. 2779, A bill to exempt inter-affiliate swaps for certain regulatory requirements put in place by the Dodd-Frank Wall Street Reform & Consumer Protection Act; S. 1650, Dodd-Frank Improvement Act of 2011. Proposed Rulemaking: Executive compensation reporting; CFTC Swaps for ERISA Plans; Pay Ratio.

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation. HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access; pay ratio. Proposed Rule: Facilitating Shareholder Director Nominations. Proposed Rule Making Financial Stability Oversight Council. Proposed Rule Making for Derivatives.

Rare Earth Minerals, Domestic Supply, and China Export Restrictions. Trade Agreements: US-Korea FTA, US-Colombia FTA, and US-Panama FTA; Trans-Pacific Partnership negotiations (e-commerce, services, financial services, technical barriers to trade & government procurement chapters). APEC-Innovation: Policy Principles. WTO: Government Procurement Reform; E-commerce Work Program; Russia accession (Information Technology Agreement); China's Accession to the Government Procurement Agreement (GPA). Bi-lateral Trade Issues and Policy: China and India. Export/Import Regulation: Reform; Embargoes and Sanctions; China. Digital Economy Trade: Digital Goods/services legislation; Cross-border data flow. Disability Policy - UN Convention on the Rights of People with Disabilities. Currency Exchange Rate: H.R. 639 - Currency Reform for Fair Trade Act; S. 1619 - Currency Exchange Rate Oversight Reform Act.

Rare Earth Minerals, Domestic Supply, and China Export Restrictions. Trade Agreements: US-Korea FTA, US-Colombia FTA, and US-Panama FTA; Trans-Pacific Partnership negotiations (e-commerce, services, financial services, technical barriers to trade & government procurement chapters). APEC-Innovation: Policy Principles. WTO: Government Procurement Reform; E-commerce Work Program; Russia accession (Information Technology Agreement); China's Accession to the Government Procurement Agreement (GPA). Bi-lateral Trade Issues and Policy: China and India. Export/Import Regulation: Reform; Embargoes and Sanctions; China. Digital Economy Trade: Digital Goods/services legislation; Cross-border data flow. Disability Policy - UN Convention on the Rights of People with Disabilities. Currency Exchange Rate: H.R. 639 - Currency Reform for Fair Trade Act; S. 1619 - Currency Exchange Rate Oversight Reform Act.

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation. HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access; pay ratio. Proposed Rule: Facilitating Shareholder Director Nominations. Proposed Rule Making Financial Stability Oversight Council. Proposed Rule Making for Derivatives.

S. 1074, Shareholder Bill of Rights, proxy disclosures and rules S. 3217/H.R. 4173, Restoring American Financial Stability Act of 2010, scope of the systemic risk legislation

S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act, scope of the systemic risk legislation

S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act, scope of the systemic risk legislation

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access Proposed Rule: Facilitating Shareholder Director Nominations Proposed Rule Making Financial Stability Oversight Council Proposed Rule Making for Derivatives

S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act, scope of the systemic risk legislation

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access Proposed Rule: Facilitating Shareholder Director Nominations

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access Proposed Rule: Facilitating Shareholder Director Nominations Proposed Rule Making Financial Stability Oversight Council Proposed Rule Making for Derivatives

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access Proposed Rule: Facilitating Shareholder Director Nominations

S. 3217, Restoring American Financial Stability Act of 2010 - scope of the systemic risk legislation HR. 4173, Dodd-Frank Wall Street Reform and Consumer Protection Act (as S3217) - derivative reform, captive finance, proxy access Proposed Rule: Facilitating Shareholder Director Nominations Proposed Rule Making Financial Stability Oversight Council Proposed Rule Making for Derivatives

S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act, scope of the systemic risk legislation

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" Legislation to Regulate Derivatives; Legislation to Regulate Systemic Risk

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights"

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act "Restoring American Financial Stability Act of 2009" - Senate Legislation

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" Legislation to Regulate Derivatives; Legislation to Regulate Systemic Risk

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" Legislation to Regulate Derivatives; Legislation to Regulate Systemic Risk

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act "Restoring American Financial Stability Act of 2009" - Senate Legislation

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights"

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act "Restoring American Financial Stability Act of 2009" - Senate Legislation

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" Legislation to Regulate Derivatives; Legislation to Regulate Systemic Risk

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" H.R. 4173, The Wall Street Reform and Consumer Protection Act "Restoring American Financial Stability Act of 2009" - Senate Legislation

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" Legislation to Regulate Derivatives; Legislation to Regulate Systemic Risk

H.R. 1242, "TARP (Troubled Asset and Relief Program) Accountability and Disclosure Act" Internal modeling systems for financial data S. 1074, "Shareholders Bill of Rights" Legislation to Regulate Derivatives; Legislation to Regulate Systemic Risk

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment (PE) Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 2110, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 H.R. 4297 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, Singapore, China, India, Brazil, France and Argentina S. 1934, "Foreign Account Tax Compliance Act of 2009" and H.R. 3933

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Tax Provisions in U.S. Model Treaty and Organization for Economic Cooperation and Development (OECD) U.S.-Brazil Tax Treaty U.S.-China Tax Treaty U.S.-India Tax Treaty U.S.-Korea Tax Treaty U.S.-Italy Tax Treaty U.S.-Spain Tax Treaty Revision of Internal Revenue Code Section Subpart F on Deferral of Taxation Section 954 (c) 6 CFC Look-Through for Related Party Payments; and HR 1509/S. 940, To amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. Section 954 (h) Active Financing Under Section SubpartF; and H.R. 1509 H.R. 2138, Investment in America Act of 2007 / S 41, Research Competitiveness Act of 2007 / S 2209, Research Credit Improvement Act of 2007 R&D Tax Credit H.R. 5267 / S. 1726, Business Activity Tax Simplification Act of [HR: 2008] [S: 2007] Treasury "Check-the-Box" Regulations Taxation of Software (Section 18) Regulations Taxation of Internet Transactions and Software Fundamental Tax Reform - Tax Reform Advisory Panel and Various Congressional Hearings OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Research and Development Tax Credit Refinement - Alternative Simplified Credit Securities and Exchange Commission Implementation of P.L. 107-204 Sarbanes-Oxley Act of 2002 Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Revenue Ruling 97-48, Revenue Ruling 75-7, and Related Code Sections Treasury Sections 1.954-3 Field Service Advisory (FSA) 20020005 Proposed regulations relating to foreign-based company sales income under IRC sec. 954 (Reg. - 124590-07) Economic Substance Doctrine Codification Substantial Assistance rule under Treasury Reg. S.1.954-4 and IRS Notice 2007-13 "Contract Manufacturing" rule under Treasury Reg. S.1.954 Extension of Tax Relief Act of 2006 Internal Revenue Code sec. 401(k), sec. 529, and sec. 152(d)(2) for learning accounts legislation H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 S. 2380, To amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions. H.R. 6036, Lifelong Learning Accounts Act of 2008 H.R. 6049, Renewable Energy and Job Creation Act of 2008 tax extenders S. 2886, Alternative Minimum Tax and Extenders Tax Relief Act of 2008 tax extenders Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 Section 956 of Internal Revenue Code (Section Subpart F) and IRS Notice 2008-91 Section 965 of Internal Revenue Code (Section Subpart F) Energy Economic Stabilization Act of 2008, H.R. 1424 H.R. 422, Retain the Research credit and increase and make permanent the alternative simplified credit Superfund taxes, "Corporate Environmental Income Tax," CEIT S. 199, Production Deduction in IRC

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina

Revision of Internal Revenue Code Section Subpart F on Deferral H.R. 2098 on Extending Look-through treatment of payments between Controlled Foreign Corporation (CFCs) and Section 954(c)6 of Internal Revenue Code Treasury "Check-the-Box" Regulations OECD VAT/GST on cross border services and intangibles and taxation of short-term assignees OECD rules on business restructuring and permanent establishment Research and Development Tax Credit Regulations Permanent Establishment (PE) Rules for Profit Attribution and Business Restructuring in OECD Treasury Regulations on Contract Manufacturing Economic Substance Doctrine Codification H.R. 3359, Mobile Workforce State Income Tax Fairness and Simplification Act of 2007 Internal Revenue Code sec. 162(a) Away from Home rules H.R. 3970, Tax Reduction and Reform Act of 2007 H.R. 6036, Lifelong Learning Accounts Act of 2008 Government entities required to withhold 3% on payments for services and property under IRS Notice 2008-38 and S. 292 and H.R. 275 to repeal Section 511 of the Tax Increase Prevention and Reconciliation Act of 2005 H.R. 422, Increase and make permanent the alternative simplified credit S. 1203, Retain the Research Credit and increase and make permanent the Alternative Simplified Credit Superfund taxes, "Corporate Environmental Income Tax," CEIT H.R. 1083, Business Activity Tax Simplification Act of 2009 and P.L. 86-272, Prohibiting states from assessing net taxes without PE Temporary cost-sharing regulations and Treasury Regulation S.1.482-7T(g) Bilateral tax treaties including Korea, Italy, Spain, China, India, Brazil, France and Argentina