id,filing_uuid,filing_type,registrant_name,registrant_id,client_name,filing_year,filing_period,issue_code,specific_issues,government_entities,income_amount,expense_amount,is_no_activity,is_termination,received_date
1165432,b6e8c19e-36dc-433e-a095-befdc73b1629,Q3,INTERNATIONAL BUSINESS MACHINES CORPORATION (IBM),19877,INTERNATIONAL BUSINESS MACHINES CORPORATION (IBM),2011,third_quarter,TAX,"U.S. international tax including deferral, foreign tax credits: H.R. 2735 ""Revise IRC to make permanent Section 954(c)6 CFC Look-through for related party payments; H.R. 749"" Revise IRC to make permanent active financing exemption Section 954 H.
Corporate tax reform: Support competitive corporate tax rate and competitive international tax system and competitive IP incentives. R&D tax credit (alternative simplified credit, ASC): S. 1577, ""Greater Research Opportunities with Tax Help Act;"" H.R. 942, ""The American Research and Competitiveness Act of 2011"".
Other Treasury and IRS regulations: Effects of proposal to tax excess returns on transfers of IP; pool foreign tax credits and restrictions on deferred interest deductions; H.R. 674, ""3% withholding tax on certain federal contracts"".
Bilateral income tax treaties: Treaties between US and Spain, Korea, Singapore, Brazil, India and China.
OECD guidelines and U.S. Treasury comments on taxation: Taxation of intangibles including services and software.
Employee-Related Tax Reform: H.R. 1864 ""Mobile Workforce Act"" 
Other: Tax issues as discussed in the Joint Select Committee on Deficit Reduction aka Supercommittee; H.R. 1439 ""Business Activity tax BATSA""","Commerce, Dept of (DOC),Commodity Futures Trading Commission (CFTC),Defense, Dept of (DOD),Energy, Dept of,Environmental Protection Agency (EPA),Federal Communications Commission (FCC),Health & Human Services, Dept of (HHS),Homeland Security, Dept of (DHS),HOUSE OF REPRESENTATIVES,Labor, Dept of (DOL),Natl Security Agency (NSA),Patent & Trademark Office (PTO),Pension Benefit Guaranty Corporation (PBGC),Securities & Exchange Commission (SEC),SENATE,State, Dept of (DOS),Treasury, Dept of,U.S. Trade Representative (USTR)",,1090000,0,0,2011-10-20T11:00:03.247000-04:00