Real Corporate Profits Tax Act of 2021

General Tax Reform; H.R. 1381 and S. 480 Main Street Tax Certainty Act; S. 1077 Permanently Preserving Americas Investment in Manufacturing Act of 2021; H.R. 4549 and S. 749, American Innovation & Jobs Act; H.R. 2143 and S. 98, Neighborhood Homes Investment Act; S. 2680 and H.R. 4940 Real Corporate Profits Tax Act; H.R. 4759 and S. 2511, Revitalizing Americas Downtowns Act; S. Con.Res.14

Client expense: $530,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Workforce incentives, Earned Income Tax Credit Inflation Reduction Act (H.R. 5376) H.R. 4940 / S.2680 - Real Corporate Profits Tax Act of 2021 Global Tax Deal - OECD Agreement & Additional Global Support - Pillar 1 & 2 - administration agencies

Client expense: $300,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative and regulatory monitoring related to corporate and international tax issues, including issues relating to the Tax Cuts and Jobs Act. S. 147/H.R. 696, CARES Windfall for the Wealthiest Repeal Act MD/HD EV tax credit S. 975, EV Charging tax credit H.R. 698, EV CHARGE Act S. 1791, FAST Electricity Act H.R. 848, GREEN Act S.1608/H.R. 741, Sustainable Aviation Fuel Act S.2680/H.R. 4940, Real Corporate Profits Tax Act H.R. 5376, Inflation Reduction Act

Client expense: $2,990,000 · Firm income: Not reported

Billionaires Surtax- various proposals Individual taxes- Surtax, increase rates on high income, return top rate to 39.6%, close loopholes, Mark to Market Corporate tax rates, close loopholes Supporting Americans with Lower Taxes (SALT) Act Earned income tax credits, child tax credits HR 2549, S 1157- Tax Fairness for Workers Act, Individual tax deduction for union dues S 4192, HR 8448- No Tax Breaks for Union Busting Act HR 2337- Public Servants Protection and Fairness Act of 2021 Tax Filing Simplification Act HR 5376, HR 1785, S 714- International tax incentives for outsourcing and rates, No Tax Breaks for Outsourcing Act HR 5376, HR 2576, S 994- Estate Taxes, For the 99.5% Act HR 5376, S 510, HR 1459- Ultra-Millionaire Tax Act of 2021 HR 3805, S 2028- Millionaires Surtax Act HR 5376, S 2617, HR 1068, S 1598- Carried interest tax loophole HR 7502- Babies Over Billionaires Act HR 8558- Billionaire Minimum Income Tax Deemed realization (1 time) at death/transfer for large assets (e.g. >$1 B) HR 2286- Deemed Realization of capital gains HR 5376, HR 1116, HR 1200, S 1857, S 1788- Increase funds for IRS tax enforcement and services, IRS Enhancement and Tax Gap Reduction Act of 2021, Stop CHEATERS Act, Restoring the IRS Act S 1652- Paying a Fair Share Act Close NIIT and SECA tax loopholes- use revenue for Medicare HR 5376, S 2680, HR 4940- Corporate tax: minimum rate (e.g. 15%), Real Corporate Profits Tax Act of 2021 General Business Tax Credits refundability Tax extenders General, R&D Tax Credit, Refundable NOL Carryover Opportunity Zone Reform Act

Client expense: $470,000 · Firm income: Not reported

Legislative and regulatory monitoring related to corporate and international tax issues, including issues relating to the Tax Cuts and Jobs Act. S. 147/H.R. 696, CARES Windfall for the Wealthiest Repeal Act MD/HD EV tax credit S. 975, EV Charging tax credit H.R. 698, EV CHARGE Act S. 1791, FAST Electricity Act H.R. 848, GREEN Act S.1608/H.R. 741, Sustainable Aviation Fuel Act S.2680/H.R. 4940, Real Corporate Profits Tax Act H.R. 5376, Build Back Better Act

Client expense: $2,400,000 · Firm income: Not reported

Tax Provisions of Biden Administration FY2023 Budget Proposal Wyden-Portman Russia Foreign Tax Credit Discussion Draft Legislation H.R. 4940 / S.2680 - Real Corporate Profits Tax Act of 2021 Global Tax Deal - OECD Agreement & Additional Global Support - Pillar 1 & 2 - administration agencies

Client expense: $350,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General Tax Reform; H.R. 1381 and S. 480 Main Street Tax Certainty Act; S. 1077 Permanently Preserving Americas Investment in Manufacturing Act of 2021; H.R. 4549 and S. 749, American Innovation & Jobs Act; H.R. 2143 and S. 98, Neighborhood Homes Investment Act; S. 2680 and H.R. 4940 Real Corporate Profits Tax Act; H.R. 4759 and S. 2511, Revitalizing Americas Downtowns Act; S. Con.Res.14

Client expense: $460,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Biden Made in America Tax Plan Billionaires Surtax, various proposals Windfall Elimination Tax proposals HR 5376, HR 1785, S 714- international tax incentives for outsourcing and rates No Tax Breaks for Outsourcing Act HR 5376, HR 2576, S 994- Estate Tax Reform For the 99.5% Act HR 5376, S 510, HR 1459- Ultra-Millionaire Tax Act of 2021 HR 3805, S 2028- Millionaires Surtax Act HR 5376, S 2617, HR 1068, S 1598- Carried interest tax loophole various bills- Taxing Millionaires and Billionaires various bills- Corporate Tax Reform Earned income tax credits, child tax credits HR 2549, S 1157- Individual tax deduction for union dues S 4192- No Tax Breaks for Union Busting Act S 3701- Social Security 2100: A Sacred Trust, GPO/WEP HR 2337- Public Servants Protection and Fairness Act of 2021 HR 7502- Babies over Billionaires Act Billionaire Minimum Income Tax Deemed realization (1 time) at death/transfer for large assets (e.g. >$1B) HR 2286- Deemed Realization of capital gains HR 5376, HR 1116- Increase funds for IRS for tax enforcement and services HR 1200, S 1857, S 1788- IRS Enhancement and Tax Gap Reduction Act of 2021; Stop CHEATERS Act; Restoring the IRS Act S 1652- Paying a Fair Share Act Individual taxes- Surtax, increase rates on high income, return top rate to 39.6%, close loopholes, Mark to Market Close NIIT and SECA tax loopholes- use revenue for Medicare Corporate tax- higher rates, close loopholes, raise revenue, Minimum tax (e.g. 15%) S 2680, HR 4940- Real Corporate Profits Tax Act of 2021 HR 6847- Individual itemized tax deduction for SALT, Supporting Americans with Lower Taxes (SALT) Act Tax Fairness for Workers Act General Business Tax Credits refundability Tax extenders, R&D Tax Credit, Refundable NOL Carryover Opportunity Zone Reform Act Simplifying Federal Tax Filing Procedures, Tax Filing Simplification Act HR 3802, HR 7061- Big Oil Windfall Profits Tax Space Tax Act

HR 1459/S 510, Ultra-Millionaire Tax Act - impose a tax on the net value of assets of a taxpayer. HR 1984, Disaster Savings and Resilient Construction Act - provide a credit for owning certain disaster resilient property. S 617, Death Tax Repeal Act of 2021 - repeal the estate and generation-skipping transfer taxes. HR 1979/S 794, Tax Excessive CEO Pay Act - corporate tax rate increase on companies whose ratio of compensation of the CEO to median worker is more than 50 to 1. HR 328/S 817, Wall Street Tax Act - impose a 0.1% excise tax on certain purchases of stocks, bonds, and derivatives. HR 1565/S 856, Senior Security Act - establishes the Senior Investor Taskforce within the SEC. S 994, For the 99.5% Act - reinstate estate and generation-skipping taxes. PL 115-97, Tax Cuts and Jobs Act - amends corporate and individual tax provisions. TAX HR 2573/S 1136 Affordable Housing Credit Improvement Act of 2021 -- to reform the low-income housing credit S 1283Tax on Wall Street Speculation Act -- impose a tax on certain trading transactions S 1308American Infrastructure Bonds Act of 2021 -- allows the issuer of an American infrastructure bond a tax credit for 28% of the interest payable under such bond. S 2028Millionaires Surtax Act -- To impose a surtax on high income individuals. S 2621Modernization of Derivatives Tax Act - modifies the tax treatment of derivatives. HR 4940/S 2680 Real Corporate Profits Tax Act - imposes an additional 7% tax on the adjusted net book income of a corporation that exceeds $100 million HR 5376 Build Back Better Act - provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, childcare, health care, taxes, immigration, and the environment

Client expense: $940,000 · Firm income: Not reported

S.2680 Real Corporate Profits Act of 2021 H.R. 4940 Real Corporate Profits Tax Act 2021

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative and regulatory monitoring related to corporate and international tax issues, including issues relating to the Tax Cuts and Jobs Act. S. 147/H.R. 696, CARES Windfall for the Wealthiest Repeal Act MD/HD EV tax credit S. 975, EV Charging tax credit H.R.698, EV CHARGE ACT S. 1791, FAST Electricity Act H.R. 848, GREEN Act S. 1608/H.R. 741, Sustainable Aviation Fuel Act S. 2680/H.R. 4940, Real Corporate Profits Tax Act H.R. 5376, Build Back Better Act

Client expense: $2,224,000 · Firm income: Not reported

Tax Provisions of Biden Administration FY2023 Budget Proposal Wyden-Portman Russia Foreign Tax Credit Discussion Draft Legislation H.R. 5736 - Build Back Better Act - Subtitle I - (tax provisions; including discussion with Senate on funding alternatives) H.R. 4940 / S.2680 - Real Corporate Profits Tax Act of 2021 Global Tax Deal - OECD Agreement & Additional Global Support - Pillar 1 & 2 - administration agencies

Client expense: $280,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General Tax Reform; H.R. 1381 and S. 480 Main Street Tax Certainty Act; S. 1077 Permanently Preserving Americas Investment in Manufacturing Act of 2021; H.R. 4549 and S. 749, American Innovation & Jobs Act; H.R. 2143 and S. 98, Neighborhood Homes Investment Act; S. 2680 and H.R. 4940 Real Corporate Profits Tax Act; H.R. 4759 and S. 2511, Revitalizing Americas Downtowns Act; S. Con.Res.14

Client expense: $560,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Biden Made in America Tax Plan Paid Family Medical Leave Billionaires Surtax- various proposals HR 5376- Income tax on extremely high incomes; Billionaires Income Tax; Babies Over Billionaires Act (Deemed realization on individuals with sizable assets or large unrealized capital gains) S 3701- WEP/GPO; Windfall Elimination Tax; Social Security 2100: A Sacred Trust HR 5376, HR 1785, S 714- International tax incentives for outsourcing and rates; No Tax Breaks for Outsourcing Act HR 5376, HR 2576, S 994- Estate Taxes, For the 99.5% Act HR 5376, S 510, HR 1459- Ultra-Millionaire Tax Act of 2021 HR 3805, S 2028- Millionaires Surtax Act HR 5376, S 2617, HR 1068, S 1598- Carried interest tax loophole Deemed realization (one-time) at death or transfer for large assets (e.g. <$1,000,000,000) HR 2286- Deemed Realization of capital gains HR 5376, HR 1116, HR 1200, S 1857, S 1788- Increased federal funding of IRS to strengthen tax enforcement and services; IRS Enhancement and Tax Gap Reduction Act of 2021; Stop CHEATERS Act; Restoring the IRS Act 28% cap on value of individual itemized deductions 20% deduction for business owners' pass through income to individual taxes S 1652- Paying a Fair Share Act Individual taxes: Surtax; increase rates on high income; return top rate to 39.6%; close loopholes; Mark to Market Close NIIT and SECA tax loopholes and delicate revenue to fund Medicare Corporate tax- higher rates; close loopholes; raise revenue; minimum rate (e.g. 15%) S 2680, HR 4940- Real Corporate Profits Tax Act of 2021 HR 6847- Individual tax itemized deduction for state and local taxes (i.e. SALT) Supporting Americans with Lower Taxes Act (SALT Act) Earned income tax credits, child tax credits HR 2549, S 1157- Tax Fairness for Workers Act, Individual tax deduction for union dues General Business Tax Credits refundability Tax extenders generally, R&D Tax Credit, Refundable NOL Carryover Opportunity Zone Reform Act HR 2337- Public Servants Protection and Fairness Act of 2021 Simplifying Federal Tax Filing Procedures S 3802, HR 7061- Big Oil Windfall Profits Act Space Tax Act

HR 1459/S 510, Ultra-Millionaire Tax Act - impose a tax on the net value of assets of a taxpayer. HR 1984, Disaster Savings and Resilient Construction Act - provide a credit for owning certain disaster resilient property. S 617, Death Tax Repeal Act of 2021 - repeal the estate and generation-skipping transfer taxes. HR 1979/S 794, Tax Excessive CEO Pay Act - corporate tax rate increase on companies whose ratio of compensation of the CEO to median worker is more than 50 to 1. HR 328/S 817, Wall Street Tax Act - impose a 0.1% excise tax on certain purchases of stocks, bonds, and derivatives. HR 1565/S 856, Senior Security Act - establishes the Senior Investor Taskforce within the SEC. S 994, For the 99.5% Act - reinstate estate and generation-skipping taxes. PL 115-97, Tax Cuts and Jobs Act - amends corporate and individual tax provisions. TAX HR 2573/S 1136 Affordable Housing Credit Improvement Act of 2021 -- to reform the low-income housing credit S 1283Tax on Wall Street Speculation Act -- impose a tax on certain trading transactions S 1308American Infrastructure Bonds Act of 2021 -- allows the issuer of an American infrastructure bond a tax credit for 28% of the interest payable under such bond. S 2028Millionaires Surtax Act -- To impose a surtax on high income individuals. S 2621Modernization of Derivatives Tax Act - modifies the tax treatment of derivatives. HR 4940/S 2680 Real Corporate Profits Tax Act - imposes an additional 7% tax on the adjusted net book income of a corporation that exceeds $100 million HR 5376 Build Back Better Act - provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, childcare, health care, taxes, immigration, and the environment

Client expense: $560,000 · Firm income: Not reported

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

S.2680 Real Corporate Profits Act of 2021 H.R. 4940 Real Corporate Profits Tax Act 2021

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

H.R. 5736 - Build Back Better Act - Subtitle I - (tax provisions; including discussion with Senate on funding alternatives) H.R. 4940 / S.2680 - Real Corporate Profits Tax Act of 2021 Global Tax Deal - OECD Agreement & Additional Global Support - Pillar 1 & 2 - administration agencies

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

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Environmental Protection Agency (EPA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Reconciliation Legislation Senate Finance Committee, Draft Text of Build Back Better Act, Title XII -- Committee on Finance, Subtitle E -- Infrastructure Financing and Community Development, Part 1 -- Low-Income Housing Credit, Section 125101: Increases in State Allocations, Section 125102: Tax-Exempt Bond Financing Requirement; and Section 125103: Buildings Designated to Serve Extremely Low-Income Households; Subtitle F -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 126303: Energy Efficient Commercial Buildings Deduction and Section 126304: Extension, Increase, and Modifications of New Energy Efficient Home Credit; Subtitle H -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart A -- Corporate Tax Rate, Section 128101: Corporate Alternative Minimum Tax; Part 2: Tax Increases for High-Income Individuals, Section 128201: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 128202: Limitations on Excess Business Losses of Noncorporate Taxpayers, and Section 128203: Surcharge on High Income Individuals, Estates, and Trusts. H.R. 5376 (as amended by House Rules Committee Print 117-18, the version of the bill that passed the House of Representatives November 19, 2021), Build Back Better Act, Title XIII -- Committee on Ways and Means, Subtitle E -- Infrastructure Financing and Community Development, Part 1 -- Low Income Housing Credit, Section 135101: Increase in State Allocations, Section 135102: Tax-Exempt Bond Financing Requirement, and Section 135103 Buildings Designated to Serve Extremely Low-Income Households; Subtitle F -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle H -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart A -- Corporate Tax Rate, Section 138101: Corporate Alternative Minimum Tax; Part 2: Tax Increases for High-Income Individuals, Section 138201: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138202: Limitations on Excess Business Losses of Noncorporate Taxpayers, and Section 138203: Surcharge on High Income Individuals, Estates, and Trusts. House Rules Committee Print 117-17, Text of H.R. 5376, Build Back Better Act, Title XIII -- Committee on Ways and Means, Subtitle D -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle G -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart A -- Corporate Tax Rate, Section 138101: Corporate Alternative Minimum Tax; Part 2: Tax Increases for High-Income Individuals, Section 138201: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138202: Limitations on Excess Business Losses of Noncorporate Taxpayers, and Section 138203: Surcharge on High Income Individuals, Estates, and Trusts. H.R. 5376, to provide for reconciliation pursuant to title II of S. Con. Res. 14, TITLE IV-COMMITTEE ON FINANCIAL SERVICES, Subtitle A-Creating and Preserving Affordable, Equitable and Accessible Housing for the 21st Century, Title XIII -- Committee on Ways and Means, Subtitle F -- Infrastructure Financing and Community Development, Part 3 -- Rehabilitation Tax Credit, Section 135301: Determination of Credit Percentage, Section 135302: Increase in the Rehabilitation Credit for Certain Small Projects, Section 135303: Modification of Definition of Substantially Rehabilitated, and Section 135304: Elimination of Rehabilitation Credit Basis Adjustment; Part 5 -- Housing, Subpart A -- Low-Income Housing Tax Credit, Section 135501: Increase in State Allocations, Section 135502: Tax-Exempt Bond Financing Requirement, Section 135503: Buildings Designated to Serve Extremely Low-Income Households, Section 135504: Inclusion of Rural Areas as Difficult Development Areas, and Section 135507: Increase in Credit for Bond-Financed Projects Designated by Housing Credit Agency; Subtitle G -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle I -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart E -- Other Business Tax Provisions, Section 138149: Modification of Rules for Partnership Interests Held in Connection with the Performance of Services; Part 2: Tax Increases for High-Income Individuals, Section 138201: Increase in Top Marginal Individual Income Tax Rate, Section 138202: Increase in Capital Gains Rate for Certain High Income Individuals, Section 138203: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138204: Limitation on Deduction of Qualified Business Income for Certain High Income Individuals, Section 138205: Limitations on Excess Business Losses of Noncorporate Taxpayers, Section 138206: Surcharge on High Income Individuals, Estates, and Trusts, and Section 138207: Termination of Temporary Increase in Unified Credit; Part 3 -- Modifications of Rules Relating to Retirement Plans, Subpart B -- Other Provisions Relating to Individual Retirement Accounts, Section 138312: Prohibitions of IRA Investments Conditioned on Account Holder Status Taxation of Pass-Through Entities Senator Wyden Pass-Through Reform Discussion Draft, all provisions. Corporate Minimum Tax S. 2680, Real Corporate Profits Tax Act of 2021, to amend the Internal Revenue Code of 1986 to impose a tax on real profits of certain corporations, all provisions. Draft legislation, Senators, Elizabeth Warren, Angus King, and Ron Wyden, Corporate Profits Minimum Tax Proposal, all provisions. H.R. 4940, Real Corporate Profits Tax Act of 2021, to amend the Internal Revenue Code of 1986 to impose a tax on real profits of certain corporations, all provisions. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit Requested inclusion of provisions benefiting the Low-Income Housing Tax Credit as part of Build Back Better legislation. Support making permanent and augmenting by an additional 50 percent the increased Low-Income Housing Tax Credit credit authority enacted in March 2018 to enable the production of new units. S. 2820, Decent, Affordable, Safe Housing for All Act (DASH Act), to provide rental housing vouchers for the homeless, and for other purposes, Title I -- Housing Assistance, Subtitle A -- General Housing Assistance, Section 111: Rental Vouchers for the Homeless, portion of section pertaining to source of income rules; Title II -- Revenue Provisions: Sections 201-214 pertaining to the Low-Income Housing Tax Credit, Section 215 establishing a renter's tax credit, and Section 216 establishing a middle-income housing tax credit. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, REG-119890-18, RIN 1454 BO92, Section 42, Low-Income Housing Credit Average Income Test Regulations. Requested Treasury and IRS either finalize the proposed rule with modifications (impacting minimum set asides, unit designations, casualty losses, mitigating actions, and existing developments) or announce its intention to publish a new rule. Requested that Treasury modify its guidance to allow states and local governments to maximize the efficacy of Fiscal Recovery Funds used with the Low-Income Housing Tax Credit by recommending that Treasury publish guidance to: (1) clarify that Fiscal Recovery Funds structured as grants do not result in an eligible basis reduction in Housing Credit developments regardless of sponsor type, consistent with treatment of Tax Credit Exchange funds administered by the Treasury during the 2009 economic recovery; and (2) provide authority to use Fiscal Recovery Funds for principal amounts on loans with maturities beyond 2026-not just for the "cost of the loan" as currently outlined in the Interim Rule-and to allow repayments of funds to be used for similar affordable housing purposes, even after the 2026 deadline. Signed letter to Treasury. Energy Tax Incentives Support long-term extension of New energy efficient home credit (IRC 45L). Support expansion of Energy efficient commercial buildings deduction (IRC 179D) to establish a sliding scale of energy improvements, which would help spur investment in energy efficient improvements in older buildings. Biden Tax Proposals President Biden, Build Back Better Framework (released October 28, 2021), tax provisions imposing 15 percent corporate minimum tax on large corporations, establishing tax rate surcharges, applying the net investment income tax to a broader share of earnings, and limiting pass-through business losses. Like-kind exchanges: Support retaining current law. Capital Gains - Oppose doubling the long-term capital gains tax rate and support significant differential between ordinary income and capital gains tax rates. Carried interest: NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year. Stepped-Up Basis at Death and Taxation of Unrealized Capital Gains at Death: Support retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. Estate Tax: Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017. Opportunity Zones Requested Congress extend the recognition date for deferred capital gains invested into Opportunity Funds by two years, through the end of 2028. Also support enhanced information reporting, data collection, and transparency with regard to Opportunity Zones. Finally, support reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Fire Sprinklers H.R. 6192, High Rise Fire Sprinkler Incentive Act of 2021, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions.

General Tax Reform; H.R.1381 and S.480 Main Street Tax Certainty Act; S. 1077 Permanently Preserving Americas Investment in Manufacturing Act of 2021; H.R. 4549 and S. 749, American Innovation & Jobs Act; H.R. 2143 and S. 98, Neighborhood Homes Investment Act; S. 2680 and HR 4940 Real Corporate Profits Tax Act; H.R. 4759 and S. 2511, Revitalizing Americas Downtowns Act; S.Con.Res.14

Client expense: $490,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), SENATE, Treasury, Dept of, Veterans Affairs, Dept of (VA), White House Office

Legislative and regulatory monitoring related to corporate and international tax issues, including issues relating to the Tax Cuts and Jobs Act. S. 147/H.R. 696, CARES Windfall for the Wealthiest Repeal Act MD/HD EV tax credit S. 975, EV Charging tax credit H.R.698, EV CHARGE ACT S. 1791, FAST Electricity Act H.R. 848, GREEN Act S. 1608/H.R. 741, Sustainable Aviation Fuel Act S. 2680/H.R. 4940, Real Corporate Profits Tax Act H.R. 5376, Build Back Better Act

Client expense: $2,610,000 · Firm income: Not reported

Biden Made in America Tax Plan Paid Family Medical Leave Act HR 5376, HR 1785, HR 1459- Ultra-Millionaire Tax Act of 2021 HR 3805, S 2028 Millionaires Surtax Act HR 5376, S 2617, HR 1068, S 1598- Carried interest tax loophole HR 5376, discussion draft- Income tax on extremely high incomes, Billionaires Income tax Deemed realization (one-time) at death or transfer for large assets (e.g. >$1,000,000,000) Babies Over Billionaires Act (Deemed Realization on individuals with large unrealized capital gains during COVID timeframe) HR 5376, HR 1116, HR 1200, S 1857, S 1788- Increasing funding for IRS to strengthen tax enforcement 28% cap on value of individual itemized deductions 20% deduction for business owners' pass thru income to individual taxes HR 2286- Deemed Realization of capital gains S 1652- Paying a Fair Share Act Individual taxes: Surtax, higher rates on high income, close loopholes, Mark to Market Individual tax rate: raise top rate for 39.6% or higher Close NIIT and SECA tax loopholes and dedicate revenue to fund Medicare Corporate tax (e.g. higher rates, close loopholes, raise revenue) Generally, HR 5376, S 2680, HR 4940- Corporate tax- Minimum rate (e.g. 15%) Generally, SFC discussion draft, HR 5376- Corporate minimum tax: eligible income, pension plan income and appreciation Generally, HR 5376- Individual tax itemized deduction for state and local taxes (i.e. SALT) Generally, HR 5376- Earned income tax credits, child tax credits HR 2549, S 1157- Individual tax deduction for union dues General Business Tax Credits refundability Refundable NOL Carryover, Credit for R & D COVID-19 expenditures

Client expense: $600,000 · Firm income: Not reported

HR 1459/S 510, Ultra-Millionaire Tax Act - impose a tax on the net value of assets of a taxpayer. HR 1984, Disaster Savings and Resilient Construction Act - provide a credit for owning certain disaster resilient property. S 617, Death Tax Repeal Act of 2021 - repeal the estate and generation-skipping transfer taxes. HR 1979/S 794, Tax Excessive CEO Pay Act - corporate tax rate increase on companies whose ratio of compensation of the CEO to median worker is more than 50 to 1. HR 328/S 817, Wall Street Tax Act - impose a 0.1% excise tax on certain purchases of stocks, bonds, and derivatives. HR 1565/S 856, Senior Security Act - establishes the Senior Investor Taskforce within the SEC. S 994, For the 99.5% Act - reinstate estate and generation-skipping taxes. PL 115-97, Tax Cuts and Jobs Act - amends corporate and individual tax provisions. TAX HR 2573/S 1136 Affordable Housing Credit Improvement Act of 2021 -- to reform the low-income housing credit S 1283Tax on Wall Street Speculation Act -- impose a tax on certain trading transactions S 1308American Infrastructure Bonds Act of 2021 -- allows the issuer of an American infrastructure bond a tax credit for 28% of the interest payable under such bond. S 2028Millionaires Surtax Act -- To impose a surtax on high income individuals. S 2621Modernization of Derivatives Tax Act - modifies the tax treatment of derivatives. HR 4940/S 2680 Real Corporate Profits Tax Act - imposes an additional 7% tax on the adjusted net book income of a corporation that exceeds $100 million HR 5376 Build Back Better Act - provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, childcare, health care, taxes, immigration, and the environment

Client expense: $720,000 · Firm income: Not reported

S.2680 Real Corporate Profits Act of 2021 H.R. 4940 Real Corporate Profits Tax Act 2021

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 5736 - Build Back Better Act - Subtitle I - (tax provisions; including discussion with Senate on funding alternatives) H.R. 4940 / S.2680 - Real Corporate Profits Tax Act of 2021 Global Tax Deal - OECD Agreement & Additional Global Support - Pillar 1 & 2 - administration agencies S.617 - Death Tax Repeal Act H.R. 1712 - To amend the Internal Revenue Code of 1986 to repeal the estate and generation-skipping transfer taxes. S. 480 / H.R. 1321 - Main Street Tax Certainty Act America Jobs Plan - Corporate income tax (not introduced legislatively)

Client expense: $250,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Occupational Safety & Health Administration (OSHA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, White House Office

Legislative and regulatory monitoring related to corporate and international tax issues, including issues relating to the Tax Cuts and Jobs Act. S. 147/H.R. 696, CARES Windfall for the Wealthiest Repeal Act MD/HD EV tax credit S. 975, EV Charging tax credit H.R.698, EV CHARGE ACT S. 1791, FAST Electricity Act H.R. 848, GREEN Act S. 1608/H.R. 741, Sustainable Aviation Fuel Act S. 2680/H.R. 4940, Real Corporate Profits Tax Act

Client expense: $2,290,000 · Firm income: Not reported

Biden Made in America Tax Plan HR 564- Paid Family Medical Leave HR 1785, S 714- No Tax Breaks for Outsourcing Act HR 2576, S 994- For the 99.5% Act S 510, HR 1459- Ultra-Millionaire Tax Act of 2021 HR 3805, S 2028- Millionaires Surtax Act Sensible Taxation and Equity Promotion (STEP) Act, discussion draft HR 1068- Carried Interest Fairness Act HR 1116- IRS Enhancement and Tax Gap Reduction Act HR 1200, S 1857- Stop CHEATERS Act (Stop Corporations and High Earners from Avoiding Taxes and Enforce Rules Strictly) S 1788- Restoring the IRS Act of 2021 HR 328, S 817- Wall Street Tax Act HR 2735, S 1283- Tax on Wall Street Speculation Act 28% cap on value of individual itemized deductions 20% deduction for business owners' pass thru income to individual taxes HR 2286- Deemed Realization of capital gains at death or bequest Deemed Realization (one-time) at death or transfer for significant assets (e.g. >$1,000,000,000) Babies Over Billionaires Act (Deemed Realization on individuals with large unrealized capital gains during COVID timeframe) S 1652- Paying a Fair Share Act S 2680, HR 4940- Real Corporate Profits Tax S 794- Tax Excessive CEO Pay Act Individual taxes: Surtax, higher rates on high incomes, close loopholes, Mark to Market Individual tax rate: raise top rate to 39.6% or higher Close NIIT and SECA tax loopholes and dedicate revenue to fund Medicare Corporate taxes (e.g. higher rates, close loopholes, raise revenue) Corporate taxes: minimum 15% Individual tax itemized deduction for state and local taxes (i.e. SALT) Earned income tax credit and child tax credits HR 2549, S 1157- Tax Fairness for Workers Act HR 696, S 147- CARES Windfall for the Wealthiest Repeal Act General Business Tax Credits refundability Refundable NOL Carryover, Credit for R & D COVID-19 expenditures COVID Relief Package, Millionaires Giveaway Net Operating Loss tax break Ways and Means Draft, The Building an Economy for Families Act Payroll tax credit for child care providers (employer side refundable credit) HR 3007, S 1545- Disclosure of Tax Havens and Offshoring Act

H.R. 1068 -Carried Interest Fairness Act of 2021 H.R. 1321 -NMTC Extension Act of 2021 H.R. 1381 -Mainstreet Tax Certainty Act H.R. 1483 -REHAB Act of 2021 H.R. 1977 -Enhancing Credit Opportunities in Rural America Act H.R. 2143 -Neighborhood Homes Investment Act H.R. 2188 -Reopening America by Supporting Workers and Businesses Act H.R. 2189 -State Tax Freedom Act H.R. 2286 -taxes property transferred by gift or death as sold at market value H.R. 2288 -Investing in Our Communities Act H.R. 2294 -Historic Tax Credit Growth and Opportunity Act H.R. 2439 -SALT Fairness for Working Families Act H.R. 2558 -ALIGN Act H.R. 2573 -Affordable Housing Credit Improvement Act H.R. 2768 -American Housing and Economic Mobility Act of 2021 H.R. 2863 -First Time Homebuyer Act H.R. 3123 -Parity for Non-Traded REITS Act H.R. 3178 -Estate Tax Rate Reduction Act H.R. 3265 -Middle Class Savings Act H.R. 3324 -Incentivize Residential Energy Efficiency Act H.R. 3357 -Rural Jobs Act H.R. 3725 -Relief and Equity Through Small Business Tax Act H.R. 3805 -Millionaires Surtax Act H.R. 3903 -Tax Fairness Act H.R. 4165 -Uplifting First-Time Homebuyers Act of 2021 H.R. 4177 -Expanding Opportunity Zones Act H.R. 4940 -Real Corporate Profits Tax Act of 2021 H.R. 5376 -Build Back Better Act S. 98 -Neighborhood Homes Investment Act S. 456 -New Markets Tax Credit Extension Act of 2021 S. 480-Mainstreet Tax Certainty Act S. 1027-Tax Assistance for Crumbling Foundations Act S. 1136-Affordable Housing Credit Improvement Act S. 1166-Align Act S. 1368-American Housing and Economic Mobility Act S. 1403-Move America Act S. 1479-Home Lead Safety Credit Improvement Act S. 1499-REPAIR Act S. 1519-Save Hotel Jobs Act S. 1598-Carried Interest Fairness Act of 2021 S. 1627-Estate Tax Reduction Act S. 1652-Paying Fair Share Act S. 1653-SMART Act S. 1671-Rural Jobs Act S. 1753-Home Energy Savings Act S. 1768-Hope for HOMES Act S. 1805-SHELTER Act S. 2028-Millionaires Surtax Act S. 2234-Affordable Homes Act S. 2266-Historic Tax Credit Growth and Opportunity Act S. 2680-Real Corporate Profits Tax Act of 2021 S. 2820-DASH Act

HR 1459, S 510, Ultra-Millionare Tax Act of 2021; HR 3472, Biodiesel Tax Credit Extension Act of 2021; S.2617 - Ending the Carried Interest Loophole Act; S.2028 - Millionaires Surtax Act; S.2680 - Real Corporate Profits Tax Act of 2021; H.R.4940 - Real Corporate Profits Tax Act of 2021; H.R.2976 - Stop Corporate Inversions Act of 2021; S.2383 - Water and Agriculture Tax Reform Act of 2021; S.991 - Corporate Tax Dodging Prevention Act; H.R.3472 - Biodiesel Tax Credit Extension Act of 2021

Client expense: $10,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE

HR 1459/S 510, Ultra-Millionaire Tax Act - impose a tax on the net value of assets of a taxpayer. HR 1984, Disaster Savings and Resilient Construction Act - provide a credit for owning certain disaster resilient property. S 617, Death Tax Repeal Act of 2021 - repeal the estate and generation-skipping transfer taxes. HR 1979/S 794, Tax Excessive CEO Pay Act - corporate tax rate increase on companies whose ratio of compensation of the CEO to median worker is more than 50 to 1. HR 328/S 817, Wall Street Tax Act - impose a 0.1% excise tax on certain purchases of stocks, bonds, and derivatives. HR 1565/S 856, Senior Security Act - establishes the Senior Investor Taskforce within the SEC. S 994, For the 99.5% Act - reinstate estate and generation-skipping taxes. PL 115-97, Tax Cuts and Jobs Act - amends corporate and individual tax provisions. TAX HR 2573/S 1136 Affordable Housing Credit Improvement Act of 2021 -- to reform the low-income housing credit S 1283Tax on Wall Street Speculation Act -- impose a tax on certain trading transactions S 1308American Infrastructure Bonds Act of 2021 -- allows the issuer of an American infrastructure bond a tax credit for 28% of the interest payable under such bond. S 2028Millionaires Surtax Act -- To impose a surtax on high income individuals. S 2621Modernization of Derivatives Tax Act - modifies the tax treatment of derivatives. HR 4940/S 2680 Real Corporate Profits Tax Act - imposes an additional 7% tax on the adjusted net book income of a corporation that exceeds $100 million HR 5376 Build Back Better Act - provides funding, establishes programs, and otherwise modifies provisions relating to a broad array of areas, including education, labor, childcare, health care, taxes, immigration, and the environment

Client expense: $640,000 · Firm income: Not reported