ALEX MANNING

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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax Act". Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 United States Job Creation and International Tax Reform Act of 2012, S. 3521 Family and Business Tax Cut Certainty Act of 2012, S. 2884 Bring Jobs Home Act, H.R. 5795 Rebuilding American Manufacturing Act of 2012, H.R. 1439 Business Activity Tax Simplification Act of 2011. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 American Research and Competitiveness Act of 2011, S. 1577 Greater Research Opportunities With Tax Help Act. Other Treasury and IRS Regulations: IRS Regulation Section 1.901-2 on foreign tax credits. Bilateral Income Tax Treaties: US-Spain Income tax treaty, U.S.- Korea Income tax treaty, U.S.- India Income tax treaty, U.S.-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD Discussion draft on Taxation of Intangibles. Employee-Related Tax Reform. 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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax Act". Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 To Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 To Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 "United States Job Creation and International Tax Reform Act of 2012", H.R. 1439 "Business Activity Tax Simplification Act of 2011", S. 3521 "Latest Title: Family and Business Tax Cut Certainty Act of 2012". R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research and Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities With Tax Help Act". Bilateral Income Tax Treaties: US- Korea Income tax treaty, US- India Income tax treaty, US-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", S. 3485 " Mobile Workforce 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.

S. 3333 Data Security and Breach Notification Act of 2012, H.R. 2577 SAFE Act; H.R. 3523 Cyber Intelligence Sharing and Protection Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 2151 SECURE IT Act; S. 3341 SECURE IT Act (reintroduced); S. 2105 Cybersecurity Act of 2012; S. 3254 FY13 National Defense Authorization Act (Sec. 925 and Sec. 928); H.R. 3523 Cyber Intelligence Sharing and Protection Act; H.R. 4257 Federal Information Security Amendments Act; H.R. 2096 Cybersecurity Enhancement Act; H.R. 3834 Advancing America's Networking and Information Technology R&D; H.R. 3674 PRECISE Act. Cybersecurity-Implications for International Trade: S. 2323 Sec 516 FY13 CJS Appropriations H.R. 5326 Sec 516 FY13 CJS Appropriations. Cloud Computing. Software Regulation - FDA. Internet Governance and ITU.

S. 3333 Data Security and Breach Notification Act of 2012, H.R. 2577 SAFE Act; H.R. 3523 Cyber Intelligence Sharing and Protection Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 2151 SECURE IT Act; S. 3341 SECURE IT Act (reintroduced); S. 2105 Cybersecurity Act of 2012; S. 3254 FY13 National Defense Authorization Act (Sec. 925 and Sec. 928); H.R. 3523 Cyber Intelligence Sharing and Protection Act; H.R. 4257 Federal Information Security Amendments Act; H.R. 2096 Cybersecurity Enhancement Act; H.R. 3834 Advancing America's Networking and Information Technology R&D; H.R. 3674 PRECISE Act. Cybersecurity-Implications for International Trade: S. 2323 Sec 516 FY13 CJS Appropriations H.R. 5326 Sec 516 FY13 CJS Appropriations. Cloud Computing. Software Regulation - FDA. Internet Governance and ITU.

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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax Act". Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 United States Job Creation and International Tax Reform Act of 2012, S. 3521 Family and Business Tax Cut Certainty Act of 2012, S. 2884 Bring Jobs Home Act, H.R. 5795 Rebuilding American Manufacturing Act of 2012, H.R. 1439 Business Activity Tax Simplification Act of 2011. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 American Research and Competitiveness Act of 2011, S. 1577 Greater Research Opportunities With Tax Help Act. Other Treasury and IRS Regulations: IRS Regulation Section 1.901-2 on foreign tax credits. Bilateral Income Tax Treaties: US-Spain Income tax treaty, U.S.- Korea Income tax treaty, U.S.- India Income tax treaty, U.S.-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD Discussion draft on Taxation of Intangibles. Employee-Related Tax Reform. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 To Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 To Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 "United States Job Creation and International Tax Reform Act of 2012", H.R. 1439 "Business Activity Tax Simplification Act of 2011", S. 3521 "Latest Title: Family and Business Tax Cut Certainty Act of 2012". R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research and Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities With Tax Help Act". Bilateral Income Tax Treaties: US- Korea Income tax treaty, US- India Income tax treaty, US-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", S. 3485 " Mobile Workforce 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.

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.

Fair Labor Standards Act: S. 1747 The Computer Professional Update Act. Immigration Reform: STEM Green Cards, STEM Visas, L1 Visa, H.R. 3012 Fairness for High-Skilled Immigrants Act, S. 1986 STEM Visa Act 2011 and S. 3217 Startup Act 2.0. Competition Policy. OFCCP Rulemaking on PwD Employment. Global Labor Policy.

S. 3333 Data Security and Breach Notification Act of 2012, H.R. 2577 SAFE Act; H.R. 3523 Cyber Intelligence Sharing and Protection Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 2151 SECURE IT Act; S. 3341 SECURE IT Act (reintroduced); S. 2105 Cybersecurity Act of 2012; S. 3254 FY13 National Defense Authorization Act (Sec. 925 and Sec. 928); H.R. 3523 Cyber Intelligence Sharing and Protection Act; H.R. 4257 Federal Information Security Amendments Act; H.R. 2096 Cybersecurity Enhancement Act; H.R. 3834 Advancing America's Networking and Information Technology R&D; H.R. 3674 PRECISE Act. Cybersecurity-Implications for International Trade: S. 2323 Sec 516 FY13 CJS Appropriations H.R. 5326 Sec 516 FY13 CJS Appropriations. Cloud Computing. Software Regulation - FDA. Internet Governance and ITU.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011, S. 1408 Data Breach Notification Act of 2011, S. 1207 Data Security and Breach Notification . Cybersecurity, Aquisition Reform and Supply Chain: H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011, H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011, S. 2105 Cybersecurity Act of 2012, S. 2151 SECURE IT Act, S. 2111 Cyber Crime Protection Act. Cybersecurity-Implications for International Trade. Cloud Computing.

S. 3333 Data Security and Breach Notification Act of 2012, H.R. 2577 SAFE Act; H.R. 3523 Cyber Intelligence Sharing and Protection Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 2151 SECURE IT Act; S. 3341 SECURE IT Act (reintroduced); S. 2105 Cybersecurity Act of 2012; S. 3254 FY13 National Defense Authorization Act (Sec. 925 and Sec. 928); H.R. 3523 Cyber Intelligence Sharing and Protection Act; H.R. 4257 Federal Information Security Amendments Act; H.R. 2096 Cybersecurity Enhancement Act; H.R. 3834 Advancing America's Networking and Information Technology R&D; H.R. 3674 PRECISE Act. Cybersecurity-Implications for International Trade: S. 2323 Sec 516 FY13 CJS Appropriations H.R. 5326 Sec 516 FY13 CJS Appropriations. Cloud Computing. Software Regulation - FDA. Internet Governance and ITU.

S. 3333 Data Security and Breach Notification Act of 2012, H.R. 2577 SAFE Act; H.R. 3523 Cyber Intelligence Sharing and Protection Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 2151 SECURE IT Act; S. 3341 SECURE IT Act (reintroduced); S. 2105 Cybersecurity Act of 2012; S. 3254 FY13 National Defense Authorization Act (Sec. 925 and Sec. 928); H.R. 3523 Cyber Intelligence Sharing and Protection Act; H.R. 4257 Federal Information Security Amendments Act; H.R. 2096 Cybersecurity Enhancement Act; H.R. 3834 Advancing America's Networking and Information Technology R&D; H.R. 3674 PRECISE Act. Cybersecurity-Implications for International Trade: S. 2323 Sec 516 FY13 CJS Appropriations H.R. 5326 Sec 516 FY13 CJS Appropriations. Cloud Computing. Software Regulation - FDA. Internet Governance and ITU.

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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax 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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax Act". Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 United States Job Creation and International Tax Reform Act of 2012, S. 3521 Family and Business Tax Cut Certainty Act of 2012, S. 2884 Bring Jobs Home Act, H.R. 5795 Rebuilding American Manufacturing Act of 2012, H.R. 1439 Business Activity Tax Simplification Act of 2011. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 American Research and Competitiveness Act of 2011, S. 1577 Greater Research Opportunities With Tax Help Act. Other Treasury and IRS Regulations: IRS Regulation Section 1.901-2 on foreign tax credits. Bilateral Income Tax Treaties: US-Spain Income tax treaty, U.S.- Korea Income tax treaty, U.S.- India Income tax treaty, U.S.-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD Discussion draft on Taxation of Intangibles. Employee-Related Tax Reform. Taxation Issues for the "Cloud" and Services.

Fair Labor Standards Act: S. 1747 Computer Professionals Update Act (CPU Act). Immigration Reform: Visas - H.R. 6429 STEM Jobs Act. OFCCP Rulemaking on PwD Employment.

Fair Labor Standards Act: FLSA CPU Act S. 1747. Immigration Reform: H.R. 6429 STEM Jobs Act of 2012. OFCCP Rulemaking on PwD Employment. NIOSH Health Study.

Cybersecurity, Aquisition Reform and Supply Chain: S. 3414 Cybersecurity Act of 2012; S. 3254 FY 13 National Defense Authorization Act - Sec 925, 929, SA3280; Federal IT Aquisition Reform Act (FITARA). Cybersecurity-Implications for International Trade. Cloud Computing. Internet Governance and ITU. Privacy -- E.g., reforming ECPA, CFAA, Privacy Act. Discussions of Re-authorization of the 2004 High Performance Computing Act. H.R. 6454 and S. 3459. Focus on exascale computing.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 United States Job Creation and International Tax Reform Act of 2012, S. 3521 Family and Business Tax Cut Certainty Act of 2012, S. 2884 Bring Jobs Home Act, H.R. 5795 Rebuilding American Manufacturing Act of 2012, H.R. 1439 Business Activity Tax Simplification Act of 2011. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 American Research and Competitiveness Act of 2011, S. 1577 Greater Research Opportunities With Tax Help Act. Other Treasury and IRS Regulations: IRS Regulation Section 1.901-2 on foreign tax credits. Bilateral Income Tax Treaties: US-Spain Income tax treaty, U.S.- Korea Income tax treaty, U.S.- India Income tax treaty, U.S.-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD Discussion draft on Taxation of Intangibles. Employee-Related Tax Reform. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 To Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 To Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 "United States Job Creation and International Tax Reform Act of 2012", H.R. 1439 "Business Activity Tax Simplification Act of 2011", S. 3521 "Latest Title: Family and Business Tax Cut Certainty Act of 2012". R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research and Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities With Tax Help Act". Bilateral Income Tax Treaties: US- Korea Income tax treaty, US- India Income tax treaty, US-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", S. 3485 " Mobile Workforce 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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax Act". Taxation Issues for the "Cloud" and Services.

Basic Research Funding for Dept. of Energy, Office of Science - High Performance Computing. Trusted Foundry. Department of Defense: HJ Res. 117 - funding for DCGS-A (Distributed Common Ground System - Army). Center for Medicare and Medicaid Services Program Integrity Funds; Social Security Administration - Program Integrity. H.R. 8, American Tax Payer Relief Act, issues relating to Sequestration.

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. 749 To Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 To Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 "United States Job Creation and International Tax Reform Act of 2012", H.R. 1439 "Business Activity Tax Simplification Act of 2011", S. 3521 "Latest Title: Family and Business Tax Cut Certainty Act of 2012". R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 "American Research and Competitiveness Act of 2011", S. 1577 "Greater Research Opportunities With Tax Help Act". Bilateral Income Tax Treaties: US- Korea Income tax treaty, US- India Income tax treaty, US-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation. Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act", S. 3485 " Mobile Workforce Act" .

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 749 Revise the Internal Revenue Code of 1986 on section 954h for active financing income, H.R. 2735 Revise the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. Corporate Tax Reform: S. 2091 United States Job Creation and International Tax Reform Act of 2012, S. 3521 Family and Business Tax Cut Certainty Act of 2012, S. 2884 Bring Jobs Home Act, H.R. 5795 Rebuilding American Manufacturing Act of 2012, H.R. 1439 Business Activity Tax Simplification Act of 2011. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 American Research and Competitiveness Act of 2011, S. 1577 Greater Research Opportunities With Tax Help Act. Other Treasury and IRS Regulations: IRS Regulation Section 1.901-2 on foreign tax credits. Bilateral Income Tax Treaties: US-Spain Income tax treaty, U.S.- Korea Income tax treaty, U.S.- India Income tax treaty, U.S.-China Income tax treaty. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD Discussion draft on Taxation of Intangibles. Employee-Related Tax Reform. 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; H.R. 5795 "Rebuilding American Manufacturing Act"; S. 2884" Bring Jobs Home Act" and House companion H.R. 5442. Corporate Tax Reform. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942, "American Research and Competitiveness Act of 2011", S. 1577 in Senate. Other Treasury and IRS Regulations: Foreign Account Transaction Control Act regs as affecting Section 1471 - 474 in IRC regs. Bilateral Income Tax Treaties: Brazil, Chile, India, China, Korea and Spain. OECD Guidelines and U.S. Treasury Comments on Taxation: Various position papers on taxation of "intangibles, PE rules, transfer pricing, and double non-taxation issues". Employee-Related Tax Reform: H.R. 1864 "Mobile Workforce Act"; H.R. 1439, "Business Activity Tax Act". Taxation Issues for the "Cloud" and Services.

Fair Labor Standards Act: S. 1747 The Computer Professional Update Act. Immigration Reform: STEM Green Cards, STEM Visas, L1 Visa, H.R. 3012 Fairness for High-Skilled Immigrants Act, S. 1986 STEM Visa Act 2011 and S. 3217 Startup Act 2.0. Competition Policy. OFCCP Rulemaking on PwD Employment. Global Labor Policy.

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.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011; S. 1408 Data Breach Notification Act of 2011; S. 1535 Personal Data Protection and Breach Accountability Act of 2011; S. 1207 Data Security and Breach Notification; H.R. 2577 SAFE Data Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 1867 National Defense Authorization Act for FY12 Sec 848; S. 1458 Intelligence Authorization Act for FY12 Sec 309; H.R. 1892 Intelligence Authorization Act for FY 12 Sec 308; H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011; H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011. Cybersecurity-Implications for International Trade. Cloud Computing: Privacy Issues.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011; S. 1408 Data Breach Notification Act of 2011; S. 1535 Personal Data Protection and Breach Accountability Act of 2011; S. 1207 Data Security and Breach Notification; H.R. 2577 SAFE Data Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 1867 National Defense Authorization Act for FY12 Sec 848; S. 1458 Intelligence Authorization Act for FY12 Sec 309; H.R. 1892 Intelligence Authorization Act for FY 12 Sec 308; H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011; H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011. Cybersecurity-Implications for International Trade. Cloud Computing: Privacy Issues.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011; S. 1408 Data Breach Notification Act of 2011; S. 1535 Personal Data Protection and Breach Accountability Act of 2011; S. 1207 Data Security and Breach Notification; H.R. 2577 SAFE Data Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 1867 National Defense Authorization Act for FY12 Sec 848; S. 1458 Intelligence Authorization Act for FY12 Sec 309; H.R. 1892 Intelligence Authorization Act for FY 12 Sec 308; H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011; H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011. Cybersecurity-Implications for International Trade. Cloud Computing: Privacy Issues.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011; S. 1408 Data Breach Notification Act of 2011; S. 1535 Personal Data Protection and Breach Accountability Act of 2011; S. 1207 Data Security and Breach Notification; H.R. 2577 SAFE Data Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 1867 National Defense Authorization Act for FY12 Sec 848; S. 1458 Intelligence Authorization Act for FY12 Sec 309; H.R. 1892 Intelligence Authorization Act for FY 12 Sec 308; H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011; H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011. Cybersecurity-Implications for International Trade. Cloud Computing: Privacy Issues.

Basic Research Funding for Dept. of Energy, Office of Science - High Performance Computing: DoE 2012 budget, exascale. Trusted Foundry. Department of Defense: H.R. 2219, Joint Land Elevated Netted Sensor System (JLENS) Funding; FY12 Appropriation (H.R. 2055) and FY13 Appropriation for the Distributed Common Ground System - Army; USSOCOM; H.R. 2219, H.R. 2055, H.R. 3671, Defense law enforcement records, records of armed conflict, DCGS-A Funding; Defense Data Center Consolidation. Debt-Ceiling Legislation: S. 365, S. 627, H. Res. 384, S. 635, Sequestration on Defense and other spending. Department of Commerce: H.R. 2596, S.R. 1572, Joint Polar Satellite System (JPSS) funding.

Basic Research Funding for Dept. of Energy, Office of Science - High Performance Computing: DoE 2012 budget, exascale. Trusted Foundry. Department of Defense: H.R. 2219, Joint Land Elevated Netted Sensor System (JLENS) Funding; FY12 Appropriation (H.R. 2055) and FY13 Appropriation for the Distributed Common Ground System - Army; USSOCOM; H.R. 2219, H.R. 2055, H.R. 3671, Defense law enforcement records, records of armed conflict, DCGS-A Funding; Defense Data Center Consolidation. Debt-Ceiling Legislation: S. 365, S. 627, H. Res. 384, S. 635, Sequestration on Defense and other spending. Department of Commerce: H.R. 2596, S.R. 1572, Joint Polar Satellite System (JPSS) funding.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

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.

Basic Research Funding for Dept. of Energy, Office of Science - High Performance Computing: DoE 2012 budget, exascale. Trusted Foundry. Department of Defense: H.R. 2219, Joint Land Elevated Netted Sensor System (JLENS) Funding; FY12 Appropriation (H.R. 2055) and FY13 Appropriation for the Distributed Common Ground System - Army; USSOCOM; H.R. 2219, H.R. 2055, H.R. 3671, Defense law enforcement records, records of armed conflict, DCGS-A Funding; Defense Data Center Consolidation. Debt-Ceiling Legislation: S. 365, S. 627, H. Res. 384, S. 635, Sequestration on Defense and other spending. Department of Commerce: H.R. 2596, S.R. 1572, Joint Polar Satellite System (JPSS) funding.

Basic Research Funding for Dept. of Energy, Office of Science - High Performance Computing: DoE 2012 budget, exascale. Trusted Foundry. Department of Defense: H.R. 2219, Joint Land Elevated Netted Sensor System (JLENS) Funding; FY12 Appropriation (H.R. 2055) and FY13 Appropriation for the Distributed Common Ground System - Army; USSOCOM; H.R. 2219, H.R. 2055, H.R. 3671, Defense law enforcement records, records of armed conflict, DCGS-A Funding; Defense Data Center Consolidation. Debt-Ceiling Legislation: S. 365, S. 627, H. Res. 384, S. 635, Sequestration on Defense and other spending. Department of Commerce: H.R. 2596, S.R. 1572, Joint Polar Satellite System (JPSS) funding.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011; S. 1408 Data Breach Notification Act of 2011; S. 1535 Personal Data Protection and Breach Accountability Act of 2011; S. 1207 Data Security and Breach Notification; H.R. 2577 SAFE Data Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 1867 National Defense Authorization Act for FY12 Sec 848; S. 1458 Intelligence Authorization Act for FY12 Sec 309; H.R. 1892 Intelligence Authorization Act for FY 12 Sec 308; H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011; H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011. Cybersecurity-Implications for International Trade. Cloud Computing: Privacy Issues.

Data Security and Breach Notification: S. 1151 Personal Data Privacy and Security Act of 2011; S. 1408 Data Breach Notification Act of 2011; S. 1535 Personal Data Protection and Breach Accountability Act of 2011; S. 1207 Data Security and Breach Notification; H.R. 2577 SAFE Data Act. Cybersecurity, Aquisition Reform and Supply Chain: S. 1867 National Defense Authorization Act for FY12 Sec 848; S. 1458 Intelligence Authorization Act for FY12 Sec 309; H.R. 1892 Intelligence Authorization Act for FY 12 Sec 308; H.R. 3674 Promoting and Enhancing Cybersecurity and Information Sharing Effectiveness Act of 2011; H.R. 3523 Cyber Intelligence Sharing and Protection Act of 2011. Cybersecurity-Implications for International Trade. Cloud Computing: Privacy Issues.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.

U.S. International Tax including Deferral, Foreign Tax Credits: H.R. 2735 to amend IRC 1986 to make permanent CFC lookthrough for payments of active income between related parties; H.R. 749 to Amend the IRC 1986 to make permanent active financing income between related foreign subsidiaries; H.R. 62 International Tax Competitiveness Act of 2011; H.R. 2495 Tax Equity and Middle Class Fairness Act of 2011. Corporate Tax Reform: S. 727 Bipartisan Tax Fairness and Simplification Act of 2011; W&M International Tax Reform discussion draft to amend the IRC of 1986 to provide for comprehensive income tax reform; H.R. 674 To amend the Internal Revenue Code of 1986 to repeal the imposition of 3 percent withholding on certain payments made to vendors by government entities; H.R. 1439 Business Activity Tax Simplification Act. R&D Tax Credit (Alternative Simplified Credit, ASC): H.R. 942 The American Research and Competitiveness Act of 2011; S. 1577 Greater Research Opportunities with Tax Help Act. Other Treasury and IRS Regulations: TD 9568 - Section 482 Methods to Determine Income in connection with a cost-sharing arrangement. Bilateral Income Tax Treaties: Spain, Korea, Singpapore, Brazil, India, China and Luxembourg, Hungary and Switzerland. OECD Guidelines and U.S. Treasury Comments on Taxation: OECD and BIAC guidelines on tax treatment of intangibles and services. Employee-Related Tax Reform: H.R. 1864, Mobile Workforce Act. Joint Select Committee on Deficit Reduction: Corporate tax rate: Territorial tax system: (95% dividend exemption) and IP/R&D incentives. Taxation Issues for the "Cloud" and Services.