Permanently Preserving America’s Investment in Manufacturing Act

- Issues related to residential energy efficiency tax credits in the Inflation Reduction Act of 2022 (H.R.5376). Issues related to the implementation of business-relief programs. - Issues related to business deductions for research and development (R&D) tax amortization. - Issues related to earnings before interest, taxes, depreciation, and amortization (EBITDA) and the Permanently Preserving Americas Investment in Manufacturing Act (H.R.5371/S.1077) - Issues related to bonus depreciation and the Accelerate Long-term Investment Growth Now (ALIGN) Act (H.R.2406/S.1117) - Issues related to the Low-Income Housing Tax Credit and the Affordable Housing Credit Improvement Act (H.R.3238/S.1557) - Issues related to housing tax credits and the Neighborhood Homes Investment Act (H.R.3940/S.657)

Client expense: Not reported · Firm income: $56,000

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

- Issues related to residential energy efficiency tax credits in the Inflation Reduction Act of 2022 (H.R.5376). Issues related to the implementation of business-relief programs. - Issues related to business deductions for research and development (R&D) tax amortization. - Issues related to earnings before interest, taxes, depreciation, and amortization (EBITDA) and the Permanently Preserving Americas Investment in Manufacturing Act (H.R.5371/S.1077) - Issues related to bonus depreciation and the Accelerate Long-term Investment Growth Now (ALIGN) Act (H.R.2406/S.1117) - Issues related to the Low-Income Housing Tax Credit and the Affordable Housing Credit Improvement Act (H.R.3238/S.1557) - Issues related to housing tax credits and the Neighborhood Homes Investment Act (H.R.3940/S.657)

Client expense: Not reported · Firm income: $56,000

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

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; H.R. 5371, S. 1077, Permanently Preserving America's Investment in Manufacturing Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent; and potential Senate companion bill. Bilateral Taiwan income tax agreement.

Client expense: $1,580,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

S.1077/H.R.5371: Permanently Preserving Americas Investment in Manufacturing Act - Extend provisions in the 2017 TCJA regarding the deductibility of interest expenses, the ability to expense depreciation, and the treatment of R&D expenses

Client expense: $360,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Concerns regarding final regulation on Foreign Tax Credit regulations, renewal of the previous EDITBA based limitation on the deductibility of interest expenses, and developments with OECD international tax projects S.1077/H.R.5371: Permanently Preserving Americas Investment in Manufacturing Act - Extend provisions in the 2017 TCJA regarding the deductibility of interest expenses, the ability to expense depreciation, and the treatment of R&D expenses

Client expense: $510,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; H.R. 5371, S. 1077, Permanently Preserving America's Investment in Manufacturing Act. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing). Final Foreign Tax Credit Regulations T.D. 9959, 87 Fed. Reg. 276. Advanced Manufacturing Investment Tax Credit, Reg-120653-22. Public Law no. 117-169, Inflation Reduction Act, implementation and regulations.

Client expense: $1,060,000 · Firm income: Not reported

Government targets: Council of Economic Advisers (CEA), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

ALIGN Act Business Interest Deduction Corporate Book Profits Minimum Tax Employee Stock Ownership Plan Estate Tax FASB Income Tax Disclosure Project Full Expensing H.R. 1304, American Innovation and R&D Competitiveness Act H.R. 2788, S. 1232, AIM Act H.R. 3665, Defending American Jobs and Investment Act H.R. 5371, S. 1077, Permanently Preserving Americas Investment in Manufacturing Act Individual Tax Rate Inflation Reduction Act Interest Deductibility (163(j) EBITDA Limitation) OECD Digital Tax Project Onshoring Tax Incentives Passthrough Deduction R&D Amortization R&D Tax Credit S. 866, American Innovation and Jobs Act S.1117, H.R. 2406, To make permanent 100% full expensing Stepped-up Basis Stock Buybacks Excise Tax US-Chile Tax Treaty

Client expense: $3,140,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

- Issues related to residential energy efficiency tax credits in the Inflation Reduction Act of 2022 (H.R.5376). Issues related to the implementation of business-relief programs. - Issues related to business deductions for research and development (R&D) tax amortization. - Issues related to earnings before interest, taxes, depreciation, and amortization (EBITDA) and the Permanently Preserving Americas Investment in Manufacturing Act (H.R.5371/S.1077) - Issues related to bonus depreciation and the Accelerate Long-term Investment Growth Now (ALIGN) Act (H.R.2406/S.1117) - Issues related to the Low-Income Housing Tax Credit and the Affordable Housing Credit Improvement Act (H.R.3238/S.1557) - Issues related to housing tax credits and the Neighborhood Homes Investment Act (H.R.3940/S.657)

Client expense: Not reported · Firm income: $56,000

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

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; Final Foreign Tax Credit Regulations T.D. 9959, 87 Fed. Reg. 276; H.R. 5371, S. 1077, Permanently Preserving America's Investment in Manufacturing Act. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0. Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing).

Client expense: $1,420,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), SENATE, Treasury, Dept of

Concerns regarding final regulation on Foreign Tax Credit regulations, renewal of the previous EDITBA based limitation on the deductibility of interest expenses, and developments with OECD international tax projects S.1077/H.R.5371: Permanently Preserving Americas Investment in Manufacturing Act - Extend provisions in the 2017 TCJA regarding the deductibility of interest expenses, the ability to expense depreciation, and the treatment of R&D expenses

Client expense: $590,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to residential energy efficiency tax credits in the Inflation Reduction Act of 2022 (H.R.5376). Issues related to the implementation of business-relief programs. Issues related to business deductions for research and development (R&D) tax amortization. Issues related to earnings before interest, taxes, depreciation, and amortization (EBITDA) and the Permanently Preserving Americas Investment in Manufacturing Act (H.R.5371/S.1077)

Client expense: Not reported · Firm income: $56,000

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

Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.

Client expense: $660,000 · Firm income: Not reported

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

Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.

Client expense: $660,000 · Firm income: Not reported

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

ALIGN Act Business Interest Deduction Corporate Book Profits Minimum Tax Corporate Tax Rate Employee Stock Ownership Plan Full Expensing H.R. 1304, American Innovation and R&D Competitiveness Act H.R. 5371, S. 1077, Permanently Preserving Americas Investment in Manufacturing Act H.R. 2406, S. 1117, To Make Permanent 100% Full Expensing Individual Tax Rate Inflation Reduction Act Interest Deductibility (163(j) EBITDA Limitation) OECD Digital Tax Project Onshoring Tax Incentives Partnership Taxes R&D Amortization R&D Tax Credit S. 866, American Innovation and Jobs Act Stock Buybacks Excise Tax US-Chile Tax Treaty Windfall Profits Tax Wyden International Tax Discussion Draft

Client expense: $2,170,000 · Firm income: Not reported

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

Consideration of H.R.5371/S.1077 the "PERMANENTLY PRESERVING AMERICA'S INVESTMENT IN MANUFACTURING ACT OF 2021" that "makes permanent the allowance for depreciation, amortization, or depletion for purposes of determining the income limitation on the tax deduction for business interest."

Client expense: $35,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

IRC Section 108 Cancellation of Indebtedness income- no bill S. 480/HR 1381 Main Street Tax Certainty Act - All H.R. 840 Retail Revitalization Act - All H.R. 2346 Energy Efficient Qualified Improvement Property Act of 2021 - All S. 1598/H.R. 1068 Carried Interest Fairness Act - All S. 2617 Ending the Carried Interest Loophole Act - All S 1997 To provide that certain contributions by government entities are treated as contributions to capital - All S. 2511 / H.R.4759 Revitalizing Downtowns Act - All Wyden Pass-Through Reform - no bill, discussion draft - All S. 4065/H.R. 7467 Opportunity Zones Improvement, Transparency and Extension Act - All S. 1077/H.R. 5371 Permanently Preserving America's Investment in Manufacturing Act - ALL

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Capital gains tax rate - no bill Like-Kind Exchanges - maintaining current tax treatment of IRC Section 1031 - no bill IRC Section 108 Cancellation of Indebtedness income- no bill IRC Section 1014 - maintaining stepped-up basis for inherited assets - no bill S. 480/HR 1381 Main Street Tax Certainty Act - All H.R. 840 Retail Revitalization Act - All H.R. 2346 Energy Efficient Qualified Improvement Property Act of 2021 - All S. 1598/H.R. 1068 Carried Interest Fairness Act - All S. 2617 Ending the Carried Interest Loophole Act - All S 1997 To provide that certain contributions by government entities are treated as contributions to capital - All S. 2511 / H.R.4759 Revitalizing Downtowns Act - All H.R. 6161/S.3625 The Employee Retention Tax Credit Reinstatement Act - All Wyden Pass-Through Reform - no bill, discussion draft - All Wyden capital gains mark to market proposals - no bill, discussion draft - All S. 4065/H.R. 7467 Opportunity Zones Improvement, Transparency and Extension Act - All Potential legislation on state sales tax collection and simplification post-Wayfair decision - no bill. S. 1077/H.R. 5371 Permanently Preserving America's Investment in Manufacturing Act - ALL H.R. 5376 Inflation Reduction Act of 2022. Proposals to modify the treatment of carried interest.

Client expense: $230,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on the following issues: corporate income tax rates; dividend taxation; expensing (bonus) depreciation; like-kind spectrum exchanges; book minimum tax treatment of pensions, depreciation, and spectrum; digital economy directives proposed by the OECD; state and local taxation of digital goods and services; state and local taxation of the Internet; mobile workforce state income taxation; remote worker state payroll withholding taxation; foreign taxation of digital services; international tax changes to GILTI; OECD tax proposals; interest tax deduction limitation under sec.163 of the I.R.C.; extending expiring tax benefits; and expensing and research, development and experimentation costs. Lobbying on the following specific legislation: Fair Access to Interstate Remedies (Draft)-A measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court; not yet introduced); H.R. 1304/S. 749 - American Innovation and R&D Competitiveness Act of 2021; H.R. 2558/S. 1166 - Accelerate Long-term Investment Now Act (Align Act); H.R. 4346 - Supreme Court Security Funding Act of 2022, AKA CHIPS Act of 2022; H.R. 5371/S.1077 - Permanently Preserving Americas Investment in Manufacturing Act, making permanent the allowance for depreciation, amortization or depletion for purposes of determining the income limitation on the tax deduction for business interest; H.R. 5376 - Build Back Better Act; H.R. 8913 - TCIA Permanency Act, making permanent the provisions affecting individual and business taxpayers enacted in 2017 by the Tax Cuts and Jobs Act, which are scheduled to expire at the end of 2025; H.R. 9449/S. 5021 - Broadband Grant Tax Treatment Act, to exclude certain broadband grants from gross income; and S. 1274 - Remote and Mobile Worker Relief Act of 2021.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Department of Labor policies and regulations on independent contractors, joint employer, and tip credit. DOL/OSHA safety regulations re: COVID-19. Wage/tip credit legislative proposals. Workforce development issues. Apprenticeships. Paid leave legislative proposals. Implementation of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub. L. No. 116-136. Implementation of the Families First Coronavirus Response Act, Pub. L. No. 116-127. Implementation of the Paycheck Protection Program Flexibility Act of 2020, Pub. L. No. 116-142. Implementation of the Paycheck Protection Program and Health Care Enhancement Act, Pub. L. No. 116-139. H.R. 842/S. 420, Protecting the Right to Organize Act of 2021. Implementation of the American Rescue Plan Act of 2021, Pub. L. No. 117-7. Implementing regulations and guidance re: restaurant recovery grant program. SBA Economic Injury Disaster Loans (EIDLs) and Advance Grants. H.R. 3449, HIRE Act of 2021. Pandemic risk insurance/business interruption insurance. Implementation of the Inflation Reduction Act of 2022, Pub. L. No. 117-169, fines and officer liability. PPP Second Draw Forgiveness. H.R. 5371/S. 1077, Permanently Preserving America's Investment in Manufacturing Act. OSHA National Emphasis Program on heat hazards.

Client expense: $780,000 · Firm income: Not reported

Government targets: Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Small Business Administration (SBA), Treasury, Dept of

Issues impacting corporate taxation and employer provided benefits; issues related to international taxation, issues related to capital gains and dividend taxation, issues related to the implementation of the COVID relief packages, the Infrastructure Investment and Jobs Act and the Inflation Reduction Act S 749American Innovation and Jobs Act, all provisions HR 1304American Innovation and R&D Competitiveness Act, all provisions S 1077/HR 5371Permanently Preserving Americas Investment in Manufacturing Act, all provisions S 1166/HR 2558ALIGN Act, all provisions S 5021/HR 9449 Broadband Grant Tax Treatment Act, all provisions H.R. 5371 Permanently Preserving Americas Investment in Manufacturing Act, all provisions H.R. 9030 To repeal the corporate alternative minimum tax, all provisions

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

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

Concerns regarding final regulation on Foreign Tax Credit regulations, renewal of the previous EDITBA based limitation on the deductibility of interest expenses, and developments with OECD international tax projects S.1077/H.R.5371: Permanently Preserving Americas Investment in Manufacturing Act - Amend Tax Cuts and Jobs Act Interest Expense

Client expense: $540,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

-S.1274 - Remote and Mobile Worker Relief Act of 2021 -HR 5376 - Build Back Better Act -HR 2558 & S.1166 - ALIGN Act -HR 4346 - Supreme Court Security Funding Act of 2022, AKA CHIPS Act of 2022 -HR 9449 & S 5021 - Broadband Grant Tax Treatment Act: A bill to exclude certain broadband grants from gross income -HR 5371 & S 1077 - Permanently Preserving America's Investment in Manufacturing Act: Makes permanent the allowance for depreciation, amortization, or depletion for purposes of determining the income limitation on the tax deduction for business interest. -HR 8913 - The TCJA Permanency Act: makes permanent provisions affecting individual and business taxpayers that were enacted in 2017 by the Tax Cuts and Jobs Act and are scheduled to expire at the end of 2025. -HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 -Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) -OECD Tax Proposals -Expensing of Research and Experimentation Costs -Corporate Income Tax Rates -Dividend Taxation -Expensing [Bonus] Depreciation -Like Kind Exchanges of Spectrum -Book Minimum Tax Treatment on Spectrum -Book Minimum Tax Treatment of Pensions -Book Minimum Tax Treatment of Depreciation -Digital Economy Directives proposed by the OECD -State and local Taxation of Digital Goods and Services -State and local Taxation of the Internet -Mobile Workforce State Income Legislation -Remote Worker State Payroll Withholding Tax Legislation - Foreign Taxation of Digital Service -International Tax changes to GILTI -Interest Tax Deduction Limitation under 163(j) of the I.R.C. -Extending Expiring Tax Benefits -Tax issues related to expensing and research and development expensing

Client expense: $3,040,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, White House Office

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals in H.R. 5376, Build Back Better Act; T.D. 9959, 87 Fed. Reg. 276, Final Foreign Tax Credit Regulations; S. 1077 and H.R. 5371, Permanently Preserving America's Investment in Manufacturing Act; Sec. 174 of the Internal Revenue Code, Amortization of Research and Experimental Expenditures. S. 1887, H.R. 4267, Multi-State Worker Tax Fairness Act of 2021. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and relevant treaties under negotiation.

Client expense: $1,260,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), SENATE, Treasury, Dept of, White House Office

H.R. 5371 - Permanently Preserving America's Investment in Manufacturing Act General Introductions

Client expense: Not reported · Firm income: $45,000

Government targets: HOUSE OF REPRESENTATIVES, White House Office

General lobbying on the following issues: corporate taxation and employer-provided benefits; international taxation; capital gains and dividend taxation; and implementation of the COVID relief packages and the Infrastructure Investment and Jobs Act. Lobbying on the following specific bills: S. 749 - American Innovation and Jobs Act, all provisions; S. 1077/H.R. 5371 - Permanently Preserving Americas Investment in Manufacturing Act, all provisions; S. 1166/H.R. 2558 - ALIGN Act, all provisions; S. 5021/H.R. 9449 - Broadband Grant Tax Treatment Act, all provisions; H.R. 1304 - American Innovation and R&D Competitiveness Act, all provisions; and H.R. 5371 - Permanently Preserving Americas Investment in Manufacturing Act, all provisions; and H.R. 9030 - To repeal the corporate alternative minimum tax, all provisions.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

The association monitors and reacts to policy concepts that may impact the ability of its members to function in an operationally sound manner as well as measures that may affect the ultimate transfer of such businesses. During the reporting period, the association focused on the following: S. 1077 - Permanently Preserving Americas Investment in Manufacturing Act - all sections. S. 1166 - Accelerate Long-Term Investment Growth Now Act - all sections. S. 4689 - ACCESS Rural America Act - all sections. S. 5021 - Broadband Grant Tax Treatment Act - all sections. H.R. 2558 - Accelerate Long-Term Investment Growth Now Act - all sections. H.R. 5371 - Permanently Preserving Americas Investment in Manufacturing Act- all sections. H.R. 9445 - ACCESS Rural America Act - all sections. H.R. 9449 - Broadband Grant Tax Treatment Act - all sections. Legislative and regulatory issues related to Sarbanes-Oxley Act.

Client expense: $50,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

The Tax Cuts and Jobs Act (Pub. Law 115-97); Implementing Regulations - GILTI, 163(j). Consolidated Appropriations Act 2023 (PL 117-328) Tax Extenders. Permanently Preserving America's Investment in Manufacturing Act (H.R.5371) and (S.1077). Implementation of the Inflation Reduction Act (PL 117-169) General Business Taxes. American Innovation and R&D Competitiveness Act of 2021 (H.R.1304). American Innovation and Jobs Act (S.749) Global tax activities and discussions on Pillar One and Pillar Two at OECD.

Client expense: $740,000 · Firm income: Not reported

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

S.1298 - Clean Energy for America Act; S.1608 - Sustainable Aviation Fuel Act; H.R.3440 - Sustainable Skies Act; S.1077 - Permanently Preserving Americas Investment in Manufacturing Act of 2021; H.R.5371 - Permanently Preserving Americas Investment in Manufacturing Act; H.R.3272 - Biodiesel, Renewable Diesel, and Alternative Fuels Extension Act of 2021; H.R.3472 - Biodiesel Tax Credit Extension Act of 2021; S. 1806 - Biodiesel Tax Credit Extension Act of 2021; H.R.3684 - Infrastructure Investment and Jobs Act, Sec. 80201 - Extension and Modification of Certain Superfund Excise Taxes; Last-in, First-out LIFO accounting method (no formal legislation); General Explanation of the Administrations Fiscal Year 2023 Revenue Proposals; H.R.5736 - The Inflation Reduction Act of 2022, Public Law No. 117-169, Title 1, Subtitles A and D; U.S. Treasury Department Notices for Implementing The Inflation Reduction Act; Discussion of Extension of 2017 Tax Reform Provisions - Full Expensing, 163(g), and Sec. 174 R&D Credit; Consolidated Appropriations Act, 2023 (P.L. 117 - 328)

Client expense: $880,000 · Firm income: Not reported

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

Proposed increases to the current corporate tax rate, repeal of QBAI and FDII (Build Back Better Act) Extension of EBITDA calculation for interest deductibility (H.R. 5371, S. 1077). Stock buyback excise tax and Alternative Minimum Tax (AMT) proposals in the Inflation Reduction Act (IRA) - H.R. 5376 (P.L. 117-169).

Client expense: $130,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

ALIGN Act Business interest deduction Corporate Book Profits Minimum Tax Corporate Tax Rate Employee Stock Ownership Plan Foreign Tax Credits Full Expensing H.R. 1304, American Innovation and R&D Competitiveness Act H.R. 5371, S. 1077, Permanently Preserving Americas Investment in Manufacturing Act Individual Tax Rate Inflation Reduction Act Interest Deductibility (163(j) EBITDA Limitation) Interest Deductibility (163(n) Leverage Test) OECD Digital Tax Project Onshoring tax incentives Partnership Taxes R&D Amortization R&D Tax Credit S. 749, American Innovation and Jobs Act Stock Buybacks Excise Tax US-Chile tax treaty Windfall Profits Tax Wyden International Tax Discussion Draft

Client expense: $2,640,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, White House Office

Issues related to residential energy efficiency tax credits in the Inflation Reduction Act of 2022 (H.R.5376). Issues related to the implementation of business-relief programs. Issues related to business deductions for research and development (R&D) tax amortization. Issues related to earnings before interest, taxes, depreciation, and amortization (EBITDA) and the Permanently Preserving Americas Investment in Manufacturing Act (H.R.5371/S.1077)

Client expense: Not reported · Firm income: $56,000

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

Legislation affecting the tax treatment of private equity, including proposed legislation on carried interest capital gains, the Consolidated Appropriations Act (H.R.2617), Inflation Reduction Act (Public Law No: 117-169), Build Back Better Act (H.R.5376), Carried Interest Tax Fairness Act of 2021 (H.R. 1068), Ending the Carried Interest Loophole Act (S. 1639), and the Stop Wall Street Looting Act (S. 2155 / H.R. 3848), proposals to alter the tax treatment of interest deductibility, Tax Cuts and Jobs Act (Public Law 115-97), the Permanently Preserving Americas Investment in Manufacturing Act of 2021 (S. 1077 / H.R. 5371); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.

Client expense: $1,290,000 · Firm income: Not reported

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

Tax issues related to Section 163(j). (HR 5371; H.R. 2617, the FY 2023 Consolidated Appropriations Act)

Client expense: Not reported · Firm income: $100,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction; Extend R&D; bonus depreciation. Provide comments on guidance on CAMT & green energy tax incentives to Treasury.

Client expense: $2,510,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), SENATE, Treasury, Dept of

Bipartisan Innovation Act H.R.2279 - Office of Manufacturing and Industrial Innovation Policy Act of 2021 S.997/H.R.2279 - A bill to establish the Office of Manufacturing and Industrial Innovation Policy and strategic national manufacturing policy for the United States. Legislation to provide for the establishment of a section of the website of the Department of Commerce that shall serve as the primary hub for information relating to Federal manufacturing programs, and for other purposes. Legislation to establish the National Manufacturing Advisory Council within the Department of Commerce, and for other purposes. Legislation to establish the National Institute of Manufacturing, and for other purposes. H.R.2900 (116th) - Chief Manufacturing Officer Act. H.R.4521 - America COMPETES Act of 2022. H.R.5371/S. 1077 - Permanently Preserving Americas Investment in Manufacturing Act. H.R.5505 - Supply Chain Security and Resilience Act. H.R.6290/S.1037 - Manufacturing.gov Act. H.R.1311 - China Technology Transfer Control Act of 2021. S.1044 - National Manufacturing Advisory Council for the 21st Century Act. S.1069 - National Institute of Manufacturing Act. S.1260 - United States Innovation and Competition Act of 2021. Issues related to export control, foreign investment, and antitrust measures to counter Chinas industrial policies.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Tax Code revisions (H.R.5376 - Inflation Reduction Act of 2022). BASF is concerned by proposals to increase corporate rates and otherwise revise the tax code and believes that there are alternative means available to fund infrastructure improvements and other important spending programs. H.R.5371/S.1077 - Permanently Preserving America's Investment in Manufacturing Act. BASF supports a permanent change to the tax code that allows full deduction of interest for capital investments.

Client expense: $70,000 · Firm income: Not reported

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

IRC Section 108 Cancellation of Indebtedness income- no bill S. 480/HR 1381 Main Street Tax Certainty Act - All H.R. 840 Retail Revitalization Act - All H.R. 2346 Energy Efficient Qualified Improvement Property Act of 2021 - All S. 1598/H.R. 1068 Carried Interest Fairness Act - All S. 2617 Ending the Carried Interest Loophole Act - All S 1997 To provide that certain contributions by government entities are treated as contributions to capital - All S. 2511 / H.R.4759 Revitalizing Downtowns Act - All Wyden Pass-Through Reform - no bill, discussion draft - All S. 4065/H.R. 7467 Opportunity Zones Improvement, Transparency and Extension Act - All S. 1077/H.R. 5371 Permanently Preserving America's Investment in Manufacturing Act - ALL

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Highway Trust Fund Solvency; Carbon Capture Utilization and Storage Tax Credit (S. 986); Coordinated Action to Capture Harmful (CATCH) Emissions Act (HR 3538); S. 2378, the FAIR Transition and Competition Act; The Permanently Preserving Americas Investment in Manufacturing Act (H.R. 5371/S. 1077); Gas Prices Relief Act (S. 3609/H.R. 6787); Inflation Reduction Act (H.R.5376), 45Q

Client expense: $125,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (PL 111-203); S. 4004/H.R. 6732 - The Small LENDER Act; H.R. 6739 - To require the Bureau of Consumer Financial Protection to issue a before deleting or modifying certain small business loan data, and for other purposes; The Bank Loan Privacy Act; H.R. 6802 - Preventing Racial Profiling in Lending Act; S. 1077/H.R. 5371 - Permanently Preserving Americas Investment in Manufacturing Act.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on the following issues: corporate taxation and employer-provided benefits; international taxation; capital gains and dividend taxation; and implementation of the COVID relief packages and the Infrastructure Investment and Jobs Act. Lobbying on the following specific bills: S. 749 - American Innovation and Jobs Act, all provisions; S. 1077/H.R. 5371 - Permanently Preserving Americas Investment in Manufacturing Act, all provisions; S. 1166/H.R. 2558 - ALIGN Act, all provisions; S. 5021 - Broadband Grant Tax Treatment Act, all provisions; H.R. 1304 - American Innovation and R&D Competitiveness Act, all provisions; and H.R. 5371 - Permanently Preserving Americas Investment in Manufacturing Act, all provisions; H.R. 5376 - Build Back Better Act, all tax provisions; and H.R. 9030 - To repeal the corporate alternative minimum tax, all provisions.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

The Tax Cuts and Jobs Act (Pub. Law 115-97); Implementing Regulations - GILTI, 163(j). Tax Extenders, General Business Taxes. Permanently Preserving America's Investment in Manufacturing Act (H.R.5371) and (S.1077). Build Back Better Act (H.R.5376); General business tax. Infrastructure Investment and Jobs Act (PL 117-58); Impletation and general tax issues. American Innovation and R&D Competitiveness Act of 2021 (H.R.1304) American Innovation and Jobs Act(S.749) The Permanently Preserving Americas Investment in Manufacturing Act (H.R.5371) and (S.1077) Accelerate Long Term Investment Growth Now Act (H.R.2558) and (S.1166) Global tax activities and discussions on Pillar One and Pillar Two at OECD.

Client expense: $1,230,000 · Firm income: Not reported

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

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction

Client expense: $3,000,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), SENATE, Treasury, Dept of

Department of Labor policies and regulations on independent contractors, joint employer, and tip credit. DOL/OSHA safety regulations re: COVID-19. Wage/tip credit legislative proposals. Workforce development issues. Apprenticeships. Paid leave legislative proposals. Implementation of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Pub. L. No. 116-136. Implementation of the Families First Coronavirus Response Act, Pub. L. No. 116-127. Implementation of the Paycheck Protection Program Flexibility Act of 2020, Pub. L. No. 116-142. Implementation of the Paycheck Protection Program and Health Care Enhancement Act, Pub. L. No. 116-139. H.R. 842/S. 420, Protecting the Right to Organize Act of 2021. H.R. 603/S. 53, Raise the Wage Act of 2021. H.R. 5, the Equality Act. H.R. 793/S. 255, RESTAURANTS Act of 2021. Implementation of the American Rescue Plan Act of 2021, Pub. L. No. 117-7. Implementing regulations and guidance re: restaurant recovery grant program. SBA Economic Injury Disaster Loans (EIDLs) and Advance Grants. H.R. 3449, HIRE Act of 2021. H.R. 4568, ENTREE Act. Pandemic risk insurance/business interruption insurance. S. 2675, Continuing Emergency Support for Restaurants Act. H.R. 5376, Inflation Reduction Act of 2022, fines and officer liability. S. 505, Forced Arbitration Injustice Repeal Act. PPP Second Draw Forgiveness. H.R. 5371/S. 1077, Permanently Preserving America's Investment in Manufacturing Act. S. 3889, Employee Rights Act. S. 4008, Small Business COVID Relief Act of 2022. OSHA National Emphasis Program on heat hazards.

Client expense: $700,000 · Firm income: Not reported

Government targets: Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Small Business Administration (SBA), Treasury, Dept of

Like Kind Exchanges Parity for Non-Traded REITs Act (H.R. 3123) Foreign Investment in Real Property Tax Act (FIRPTA) REIT Tax Modernization Energy Efficient Qualified Improvement Property (E-QIP)(H.R. 8930) Retail Revitalization Act (H.R. 840) REIT Constructive Ownership Proposals (S.2715) International Tax Proposals Infrastructure Tax Proposals GREEN Act of 2021 (H.R. 848) Inflation Reduction Act Clean Energy for America Act (S.2118) Renewable Energy Investment Act (H.R. 3180) Stock Buy Back Proposals (S. 2758) Renewing Investment in American Workers & Supply Chains Act (HR 7229, S. 4012) Revitalizing Downtowns Act (HR 4759, S.2511) Permanently Preserving America's Investment in Manufacturing Act (HR 5371, S. 1077) Monitor residential rental issues Monitor lodging issues Monitor skilled nursing facility issues

Client expense: $1,074,000 · Firm income: Not reported

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