Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties.

H.R. 1, One Big Beautiful Bill Act H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1639, American Innovation and Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act S. 1821, Tackling Predatory Litigation Funding Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation responding to the Supreme Court of the United States decision in Commissioner v. Zuch Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) (as corrected by 87 Fed. Reg. 45,018-45,021, July 27, 2022) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024) (as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions (90 Fed. Reg. 3,075-3,085, January 14, 2025) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act, (P.L. 117-169); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); U.S. legislative and administrative responses to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; federal income tax treatment of employer-provided health insurance coverage; challenging the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; realizing the proposed side-by-side solution described in the G7 Statement on Global Minimum Taxes of June 28, 2025; delay or withdrawal of Financial Accounting Standards Boards (FASB) ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; opposing the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; potential inclusion of Tackling Predatory Litigation Funding Act in Senate Finance Committees budget reconciliation (section 70605)

Client expense: $13,650,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 1, One Big Beautiful Bill Act H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 3512/S. 1821, Tackling Predatory Litigation Funding Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 847, Child Care Availability and Affordability Act S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1639, American Innovation and Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.Con.Res. 14, Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034 H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act Nomination of Billy Long to be Commissioner of the Internal Revenue Service (IRS) Nomination of Kenneth Kies to be Assistant Treasury Secretary for Tax Policy Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) as corrected by (87 Fed. Reg. 45,018-45,021, July 27, 2022) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024) (as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions (90 Fed. Reg. 3,075-3,085, January 14, 2025) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act, (P.L. 117-169); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); expiration of provisions from the 2017 Tax Cuts and Jobs Act; tax policy priorities for 2025; excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; inclusion of Section 45Q - Credit for Carbon Oxide Sequestration under the Inflation Reduction Act of 2022 (P.L. 117-169) in FY25 Budget; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; Federal income tax treatment of employer-provided health insurance coverage; challenging the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; child care related tax credits; dependent care assistance programs; proposals for third party litigation funders to pay tax on their income at the ordinary income tax rate plus a surcharge

Client expense: $19,340,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1827, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089, Generating Retirement Ownership through Long-Term Holding S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 847, Child Care Availability and Affordability Act S. 1559, Book Minimum Tax Repeal Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024)(as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Previously Taxed Earnings and Profits and Related Basis Adjustments, (89 Fed. Reg. 95,362-95,464, December 2, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions, (90 Fed. Reg. 3,075-3,085, January 14, 2025) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; Extraterritorial Application of Sec. 49 of the German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act, (P.L. 117-169); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; recommendations for Items to be Included on the 2024-2025 Priority Guidance Plan (Notice 2024-28), 2024-13 I, .R.B. 720; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; tax policy priorities for 2025; excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; inclusion of Section 45Q - Credit for Carbon Oxide Sequestration under the Inflation Reduction Act of 2022 (P.L. 117-169) in FY25 Budget; permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); Treasury regulations and other guidance related to the foreign tax credit; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; Federal income tax treatment of employer-provided health insurance coverage; challenging the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; child care related tax credits; dependent care assistance programs

Client expense: $19,340,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)