Repealing the Ill-Conceived and Problematic (RIP) Book Minimum Tax Act

H.R. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 1381/S. 480, Main Street Tax Certainty Act of 2021 H.R. 1712/S. 617, Death Tax Repeal Act H.R. 2617, Consolidated Appropriations Act, 2023 H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 5376, Inflation Reduction Act of 2022 H.R. 8853, Protecting American Savers and Retirees Act H.R. 8913, TCJA Permanency Act H.R. 9030/S. 5015, Repealing the Ill-Conceived and Problematic (RIP) Book Minimum Tax Act S. 749, American Innovation and Jobs Act S. 948, A bill to protect American small businesses, gig workers, and freelancers by repealing the burdensome American Rescue Plan Act of 2021 transactions reporting threshold S. 1274, Remote and Mobile Worker Relief Act of 2021 S. 1298, Clean Energy for America Act S. 2621, Modernization of Derivatives Tax Act of 2021 Notice and Request for Comments, Internal Revenue Service; Proposed Extension of Information Collection Request Submitted for Public Comment, Concerning Source of Income from Certain Space and Ocean Activities, Source of Communications Income (87 Fed. Reg. 65,287, October 28, 2022) Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, 87 Fed. Reg. 276 (Jan. 4, 2022) (as corrected by 87 Fed. Reg. 45,018, 45,021, July 27, 2022) Various issues relating to The Tax Cuts and Jobs Act (P.L. 115-97), including implementation of, and follow up such as making individual rates and pass-through rates permanent; Internal Revenue Code Section 965/tax overpayments, and changes made to section 965 by the Tax Cuts and Jobs Act; foreign tax carryforwards transition; pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; 199A tax deduction; Internal Revenue Service controlled foreign corporation (CFC) look-thru rule; pending bilateral tax treaties before the U.S. Senate; potential for additional bilateral tax treaties; potential repeal of the State and Local Tax (SALT) cap; corporate tax filing deadline; digital services taxes; OECD Pillar Two rules, including global anti-base erosion proposal (GloBE); general business tax credits; taxation of mobile and remote workers during the coronavirus pandemic; tax free paycheck protection program loan forgiveness; Paycheck Protection Program (PPP) tax deductibility; work opportunity tax credit; implementation of the American Rescue Plan Act (P.L. 117-2) including Section 9674 relating to 1099-K form reporting; IRS priority guidance plan; continuation of the stepped-up basis; potential corporate tax rate increase; continuation of the percentage depletion tax deduction; Minding the Tax Gap; Improving Tax Administration for the 21st Century; Canadian proposal to enact a retroactive Digital Services Tax (DST); Global Intangible Low-Taxed Income (GILTI); proposals to institute a tax on financial statement incomes of corporations, known as a Book Tax; proposed Internal Revenue Code Section 163(n) limit on deductions for business interest expense; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; U.S. Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention Of Fiscal Evasion With Respect to Taxes on Income and Capital; legislation to address section 163(j) EBITDA standard for business interest deductions; section 174 (R & D amortization) and extension of 100 percent accelerated depreciation known as full expensing or bonus depreciation; Extraterritorial Application of Sec. 49 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 Inflation Reduction Act, (P.L. 117-169), including implementation of the Excise tax on repurchase of corporate stock, and corporate alternative minimum tax; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks

Client expense: $20,990,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

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

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 5376 Inflation Reduction Act of 2022 - imposes an alternative minimum tax of 15% of the average annual adjusted financial statement income HR 9030/S 5017, Repealing the Ill-Conceived and Problematic (RIP) Book Minimum Tax Act - This Bill repeals the 15% alternative minimum tax on corporations enacted by the Inflation Reduction Act of 2022 HR 4675/S 5176 Disaster Mitigation and Tax Parity Act of 2022 - excludes from gross income for income tax purposes, any qualified catastrophe mitigation payment made under a state-based catastrophe loss mitigation program

Client expense: $810,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE