AIM Act

Issues relating to the Tax Relief for American Families and Workers Act (H.R. 7204); issues relating to the American Innovation and R&D Competitiveness Act (H.R. 2673 and S. 866); issues relating to deduction of interest under Section 163(j), (American Investment in Manufacturing Act, H.R 2788); issues related to bonus depreciation (H.R. 1117, H.R. 2406); issues relating to OECD Pillar Two Model Rules and OECDs Pillar One and Pillar Two proposals; issues relating to OECD taxation of the digital economy project and potential tariff implications; issues relating to implementation of tax and energy provisions in the Inflation Reduction Act (H.R. 5376); issues related to the Defending American Jobs and Investment Act (H.R. 3665); issues relating to the US-Taiwan Expedited Double-Tax Relief Act; issues related to the expiration of tax provisions in 2025 including the corporate tax rate and international tax provisions including GILTI and FDII.

Client expense: $8,150,000 · Firm income: Not reported

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

Work Opportunity Tax Credit (WOTC). Extension/enhancement of the Employee Retention Tax Credit (ERTC) and ERTC refund improvements. Tax rates, including corporate, individual, small business, and proposed cap on 199A. Net Investment Income Tax (NIIT), estate tax, capital gains, and step-up basis. IRS tax enforcement, and ERTC refund improvements. FICA tax tip credit. Bonus depreciation. Business meals deduction. HIRE Act. H.R. 2788/S. 1232, AIM Act. Service Industry Tip Compliance Agreement program. S. 1706, Main Street Tax Certainty Act. H.R. 4756, Community News and Small Business Support Act. Estate tax repeal proposals. H.R. 7024, Tax Relief for American Families and Workers Act of 2024. H.R. 6833, Improve and Enhance the Work Opportunity Tax Credit Act. H.R. 5689, EITC Age Parity Act of 2023. Service Industry Tip Compliance Agreement (SITCA) program. H.R. 7577, Creating Hospitality Economic Enhancement for Restaurant and Servers. S. 3680, Paid Family and Medical Leave Tax Credit Extension and Enhancement Act. H.R. 8941/S. 4621, No Tax on Tips Act. H.R. 7035/S. 1108, Death Tax Repeal Act.

Client expense: $900,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 889: Broadband Grant Tax Treatment Act; all provisions H.R. 2406: Accelerate Long-term Investment Growth Now (ALIGN) Act; provisions related to full expensing H.R. 2673: American Innovation and R&D Competitiveness Act of 2023; provisions related to research and development expensing H.R. 2788: AIM Act; provisions related to corporate interest deductibility H.R. 3938: Build it in America Act; extension of tax provisions related to full expensing, research and development expensing, and corporate interest deductibility H.R. 7024: Tax Relief for American Families and Workers Act of 2024; provisions related to tax reform, full expensing, research and development expensing, and corporate interest deductibility S. 341: Broadband Grant Tax Treatment Act; all provisions S. 866: American Innovation and Jobs Act; provisions related to research and experimentation expensing S. 1117: ALIGN Act; provisions related to full expensing S. 1232: AIM Act; provisions related to corporate interest deductibility S. 1559: Book Minimum Tax Repeal Act; all provisions Discussions related to 100% expensing bonus depreciation, research and experimentation costs, dividend taxation Discussions related to corporate income tax credits and corporate income tax rate Discussions related to Book Minimum Tax treatment of spectrum Discussions related to corporate alternative minimum tax guidance Discussions related to interest tax deduction limitation under 163(j) of the I.R.C.

Client expense: $2,970,000 · Firm income: Not reported

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

American Family Act HR 3899; S.1992 - Child tax credits Social Security 2100 Act H.R. 4583; S. 2280 - Social Security Solvency No Tax Breaks for Outsourcing Act H.R. 774; S.357 - Making changes to various tax provisions that encourage offshoring of jobs No Tax Breaks for Union Busting Act H.R. 5456; S. 737 - Making changes to the tax code to disincentivize writing off expenses related to union busting taxes Billionaire Minimum Income Tax Act H.R. 6498 - Create new taxes billionaires Assuring Medicares Promise Act H.R. 34 - New taxes and changes to ensure Medicare solvency Social Security Expansion Act H.R. 1046; S. 393 - Expand social security benefits For the 99.5 Percent Act H.R. 2676; S. 1178 - Increase tax rates on decedent estates, gifts, and generation skipping transfers Ultra-Millionaire Tax Act H.R. 7749 - New taxes on ultrawealthy individuals Wall Street Tax Act H.R. 4870 - Create a 0.1% excise tax on certain financial transactions such as the purchase of stocks, bonds, and derivative Oligarch Act H.R. 4919 - Create a tax on the net value of all taxable assets of a taxpayer as of the last day of any calendar year Stop Subsidizing Multimillion Dollar Corporate Bonus Act H.R. 324; S. 3155 - Extend the $1 million limit on the deductibility of executive compensation to all employees of publicly traded corporations End Tax Breaks for Dark Money Act H.R. 7244; S. 3743 - Extends the capital gains tax on transfers of appreciated property to certain tax-exempt social organizations (e.g., civics leagues, agricultural organizations, or business leagues) End Polluter Welfare Act H.R. 9839 - Eliminates certain tax breaks and incentives for oil and gas companies Tax on Wall Street Speculation Act H.R. 4119; S. 1990 - Create an excise tax on the transfer of ownership in certain securities (covered transactions), including any share of stock in a corporation; any partnership or beneficial interest in a partnership or trust; any note, bond, debenture, or other evidence of indebtedness (excluding tax-exempt municipal bonds); and derivative financial instruments or digital assets End Oil & Gas Tax Subsidies Act H.R. 1483 - Limit or repeal certain fossil fuel oil and gas subsidies for oil companies. Tax Excessive CEO Pay Act H.R. 7041; S. 3620 - Increase the corporate income tax rate based on the ratio of compensation of principal executive officers or other highest compensated employees to median worker compensation Curtailing Executive Overcompensation Act H.R. 6191; S. 3176 - Create an excise tax on employers (i.e., business entities) that have at least a 50 to 1 disparity between the wages (including bonuses, stock awards and options) of chief executive officers and the wages paid to their workers. Applicable to employers that have not less than $100 million in annual gross receipts and $10 million in payroll over a 3 year period and limit such tax to 1% of an employer's gross receipts. Stop Corporate Inversions Act H.R. 8268 ; S. 4275 - Makes changes to corporate taxes to disincentivize offshoring CEO Accountability & Responsibility Act H.R. 1284 - Increases the corporate income tax rate for publicly traded corporations that pay their chief executive officers or highest paid employees more than 100 times the median compensation of all their U.S. employees or that increase the number of contracted or foreign employees. Ending Wall Street Tax Giveaway Act; H.R. 2686 - Modify the tax treatment of carried interest Medicare & Social Security Fair Share Act H.R. 4535 ; S. 1174 - Increase funding for the Social Security and Medicare trust funds by extending the payroll tax on wages, self-employment income, and investment income to taxpayers with earnings exceeding $400,000. Corporate Tax Dodging Prevention Act H.R. 7933; S. 4098 - Makes changes to prevent corporations dodging federal taxes American Innovation & Jobs Act H.R. 2673;S. 866 - Eliminate the five-year amortization requirement for research and experimental expenditures, thus allowing continued expensing of such expenditures in the taxable years in which they are incurred. Death Tax Repeal Act H.R. 7035; S. 1108 - Repeal of the estate and generation-skipping transfer taxes. It also sets forth conforming amendments related to the gift tax. Main Street Tax Certainty Act H.R. 4721; S. 1706 - Makes permanent the tax deduction for qualified business income TCJA Permanency Act H.R. 976 - Makes permanent the Tax Cuts and Jobs Act Saving Gig Economy Taxpayers Act H.R. 190 - This bill modifies requirements for third party settlement organizations to eliminate their reporting requirement with respect to the transactions of their participating payees unless they have earned more than $20,000 on more than 200 separate transactions in an applicable tax period. ALIGN Act H.R. 2406 - This bill makes permanent the expensing of certain new business equipment. Expensing allows the deduction of the full amount of an expense item in the same taxable year. FairTax Act H.R. 25 - This bill creates a national sales tax on the use or consumption in the United States of taxable property or services in lieu of the current income taxes, payroll taxes, and estate and gift taxes. Defending American Jobs & Investment Act H.R. 3665 - provides for the enforcement of remedies against foreign countries that have extraterritorial or discriminatory taxes. Small Business Growth Act H.R. 3661 - This bill increases from $1 million to $2 million to the limitation on expensing of depreciable business assets. It also increases the asset threshold amount used to reduce the expensing limitation. American Investment in Manufacturing Act H.R. 2788 - This bill makes permanent the allowance for depreciation, amortization, or depletion for purposes of determining the income limitation on the tax deduction for business interest. Permanently Repeal the Estate Tax Act H.R. 338 - Repeals the federal estate tax, effective for estates of decedents dying after December 31, 2022. Billionaires Income Tax Act - S. 3367 Imposes new taxes on taxpayers with high incomes Carried Interest Fairness Act - S. 4123 Eliminated Carried Interest loophole Paying a Fair Share Act S. 1173 - Requires an individual taxpayer whose adjusted gross income exceeds $1 million (high-income taxpayer) to pay a minimum tax rate of 30% of the excess of the taxpayer's adjusted gross income over the taxpayer's modified charitable contribution deduction for the taxable year (tentative fair share tax) Ending the Carried Interest Loophole Act S. 3317 - Ends the carried interest loophole Stock Buyback Accountability Act S. 413 - Increase stock buy back taxes Wall Street Tax Act S. 2491 - Create a 0.1% excise tax on certain purchases of stocks, bonds, and derivatives Stop Subsidizing Giant Mergers Act S.4011 - Eliminates the deferral of tax for shareholders who receive stock through corporate mergers, acquisitions, or transfers involving corporations with annual gross receipts exceeding $500 million over the three preceding taxable year period. Book Minimum Tax Repeal Act S. 1559 - Repeals the 15% alternative tax on the financial statement (i.e., book) income of certain corporations. The tax applies to companies that report over $1 billion in profits to their shareholders. Small Business Growth Act S. 2609 - This bill increases from $1 million to $2.5 million the limitation on expensing of depreciable business assets. It also increases the asset threshold amount used to reduce the expensing limitation. Carbon Aviation Tax Act S. 2378 - Imposes jet fuel taxes on private jets

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

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

American Innovation and R&D Competitiveness Act of 2023 (H.R.2673) make the immediate R&D expensing retroactive to 2022 and permanent. American Innovation and Jobs Act (S. 866) make the immediate R&D expensing retroactive to 2022 and permanent. American Investment in Manufacturing Act (H.R.2788) (S.1232) support reinstatement of the Earnings Before Interest, Tax, Depreciation and Amortization (EBITDA) measure. Accelerate Long-term Investment Growth Now (ALIGN) Act (H.R.2406) (S.1117), support making expensing for American investments in machinery and equipment permanent. The Tax Cuts and Jobs Act (TCJA) implementation, general business tax issues (P.L.117-169). Global tax activities and discussions on Pillar One and Pillar Two at OECD (No bill number). Tax Relief for American Families and Wokers Act of 2024 (H.R. 7024) Inflation Reduction Act of 2022, implementation of business tax provisions (P.L. 117-169).

Client expense: $1,150,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7360 Promoting Affordable Child Care for Everyone Act H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 H.R. 8540/S. 5254, Child Care for American Families Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Potential legislation similar to H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58 (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, October 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments (89 Fed. Reg. 64,750-64,778, 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) 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, Dec. 2, 2024) 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 of 2022 (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 Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. 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; proposal to repeal section 852(b)(6) of the Internal Revenue Code; instituting an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; extending the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, P.L. 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; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; federal income tax treatment of employer-provided health insurance coverage; proposed amendment (I-735) to Frances 2025 budget to raise the countrys digital services tax rate from 3% to 5%; legal challenge against 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: $22,410,000 · 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)

Tax Policy: American Innovation and R&D Competitiveness Act (H.R.2673/ S.866), which would permanently repeal the R&D amortization provision. The American Investment in Manufacturing (AIM) Act (H.R.2788/S.1232), which would permanently restore the pro-growth EBITDA interest limitation standard. Accelerate Long-Term Investment Growth Now (ALIGN) Act (H.R.2406/S.1117), which would permanently extend full expensing. Section 45X Advanced Manufacturing Production Tax Credit.

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

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, SENATE

HR 2406, S 1117: ALIGN Act HR 2788, S 1232: The American Investment in Manufacturing (AIM) Act S 1706; Main Street Tax Certainty Act

Client expense: $37,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the deductibility of interest expense, including IRC section 163(j). (H.R. 7024, H.R. 2788, S. 1232)

Client expense: Not reported · Firm income: $90,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

ALIGN Act Business Interest Deduction Corporate Book Profits Minimum Tax Corporate Income Tax Rate Employee Stock Ownership Plan Estate Tax Foreign Tax Credit Full Expensing H.R. 1304, American Innovation and R&D Competitiveness Act H.R. 2406, S. 1117, To Make Permanent 100% Full Expensing H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2788, S. 1232, AIM Act H.R. 3665, Defending American Jobs and Investment Act Individual Tax Rate Inflation Reduction Act Interest Deductibility (163(j) EBITDA Limitation) Onshoring Tax Incentives Partnership Basis-Shifting Passthrough Deduction R&D Amortization R&D Tax Credit S. 866, American Innovation and Jobs Act Stepped-up Basis Stock Buybacks Excise Tax Tax Cuts and Jobs Act Expiring Provisions Tax Relief for American Families and Workers Act

Client expense: $3,280,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Provision regarding the corporate tax rate; making permanent full expensing; S.1117/H.R.2406, the ALIGN Act; S.866, American Innovation and Jobs Act; H.R. 2673, American Innovation and R&D Competitiveness Act of 2023; Implementation of the Inflation Reduction Act (P.L. 117-169); Issues related to electric vehicle tax credits; Issues related to 45W; GILTI; International Tax Framework; H.R. 3938, Build It in America Act; H.R. 3665, Defending American Jobs and Investment Act; H.R. 2788 / S.1382, the American Investment in Manufacturing Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; S. 4237, Eliminating Lavish Incentives to Electric Act

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

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

Issues related to EBITDA, bonus depreciation, support HR 7024, the Tax Relief for Working Families Act, TCJA/international tax provisions and the OECD. American Investment in Manufacturing Act (S 1232 and HR 2788)

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

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

Implementation of the Tax Cuts and Jobs Act (P.L. No. 115-97); Implementation of the Coronavirus Aid, Relief, and Economic Security Act (P.L. No. 116-136); Implementation of the American Rescue Plan of 2021 (P.L. No 117-2), EBITDA reinstatement legislation; H.R. 3938 - Build It in America Act; S.1232/H.R. 2788 - American Investment in Manufacturing (AIM) Act; H.R. 7024 - Tax Relief for American Families and Workers Act of 2024.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Implementation of Tax Cuts & Jobs Act (Pub.L. 115-97) H.R. 7024 - Tax Relief for American Families and Workers Act of 2024 Implementation of the Inflation Reduction Act (Pub.L. 117-169) H.R. 2788 / S. 1232 - American Investment in Manufacturing Act Issues related to Interest Expense Limitation Issues related to Bonus Depreciation Issues related to R&D Expensing

Client expense: $110,000 · Firm income: Not reported

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

General lobbying on the following issues: 100% expensing of bonus depreciation, research and experimentation costs, and dividend taxation; book minimum tax treatment of spectrum; corporate income tax rates and credits; corporate income tax rate; corporate alternative minimum tax guidance; and interest tax deduction limitation under 163(j) of the I.R.C. Lobbying on the following specific legislation: S. 341/H.R. 889 - Broadband Grant Tax Treatment Act (all provisions); S. 866 - American Innovation and Jobs Act and H.R. 2673 - American Innovation and Jobs Act (Spectrum and BEAD Program issues); S. 1117/H.R. 2406 - Accelerate Long-Term Investment Growth Now Act (ALIGN Act); S. 1232/H.R. 2788 - American Investment in Manufacturing (AIM) Act (provisions related to corporate interest deductibility); H.R. 3938 - Build It In America Act (extension of full expensing, R&D expensing and corporate tax deductibility). H.R. 7024 -- Tax Relief for American Families and Workers Act (full expensing of R&E expenses; and EBITA, rather than EBIT, limits on interest deductions).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Work Opportunity Tax Credit (WOTC). Extension/enhancement of the Employee Retention Tax Credit (ERTC) and ERTC refund improvements. Tax rates, including corporate, individual, small business, and proposed cap on 199A. Net Investment Income Tax (NIIT), estate tax, capital gains, and step-up basis. IRS tax enforcement, and ERTC refund improvements. FICA tax tip credit. Bonus depreciation. Business meals deduction. H.R. 2788/S. 1232, AIM Act. Service Industry Tip Compliance Agreement program. S. 1706, Main Street Tax Certainty Act. H.R. 4756, Community News and Small Business Support Act. Estate tax repeal proposals. H.R. 7024, Tax Relief for American Families and Workers Act of 2024. H.R. 6833, Improve and Enhance the Work Opportunity Tax Credit Act. H.R. 5689, EITC Age Parity Act of 2023. Service Industry Tip Compliance Agreement (SITCA) program. H.R. 7577, Creating Hospitality Economic Enhancement for Restaurant and Servers. S. 3680, Paid Family and Medical Leave Tax Credit Extension and Enhancement Act. H.R. 8941/S. 4621, No Tax on Tips Act. H.R. 7035/S. 1108, Death Tax Repeal Act.

Client expense: $820,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of

Domestic and international tax legislative and regulatory issues relating to the Inflation Reduction Act, H.R. 2788/S. 1232 (the American Investment in Manufacturing Act), H.R. 7024 (the Tax Relief for American Families and Workers Act of 2024), and the Tax Cuts and Jobs Act.

Client expense: Not reported · Firm income: $60,000

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

Issues relating to the Tax Relief for American Families and Workers Act (H.R. 7024); issues relating to the American Innovation and Research & Development Competitiveness Act (H.R. 2673 and S. 866); issues relating to R&D Section 174 expensing; issues relating to deduction of interest deductibility under Section 163(j) of the American Investment in Manufacturing Act (H. R 2788); issues related to bonus depreciation (H.R. 1117 and H.R. 2406); issues relating to the Inflation Reduction Act (H.R. 5376, all provisions); issues relating to OECD Pillar Two Model Rules and OECDs Pillar One and Pillar Two proposals; issues relating to OECD taxation of the digital economy project and potential tariff implications; issues related to the Defending American Jobs and Investment Act (H.R. 3665), and issues related to the expiration of tax provisions in 2025, including the corporate tax rate and international tax provisions.

Client expense: $4,270,000 · Firm income: Not reported

Government targets: Council on Environmental Quality (CEQ), Energy, Dept of, Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

H.R. 889: Broadband Grant Tax Treatment Act; all provisions H.R. 2406: Accelerate Long-term Investment Growth Now (ALIGN) Act; provisions related to full expensing H.R. 2673: American Innovation and R&D Competitiveness Act of 2023; provisions related to research and development expensing H.R. 2788: AIM Act; provisions related to corporate interest deductibility H.R. 3938: Build it in America Act; extension of tax provisions related to full expensing, research and development expensing, and corporate interest deductibility H.R. 7024: Tax Relief for American Families and Workers Act of 2024; provisions related to tax reform, full expensing, research and development expensing, and corporate interest deductibility S. 341: Broadband Grant Tax Treatment Act; all provisions S. 866: American Innovation and Jobs Act; provisions related to research and experimentation expensing S. 1117: ALIGN Act; provisions related to full expensing S. 1232: AIM Act; provisions related to corporate interest deductibility S. 1559: Book Minimum Tax Repeal Act; all provisions Discussions related to 100% expensing bonus depreciation, research and experimentation costs, dividend taxation Discussions related to corporate income tax credits and corporate income tax rate Discussions related to Book Minimum Tax treatment of spectrum Discussions related to corporate alternative minimum tax guidance Discussions related to interest tax deduction limitation under 163(j) of the I.R.C.

Client expense: $2,600,000 · Firm income: Not reported

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

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), AIM Act (S. 1232/H.R. 2788) Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.

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

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

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 H.R.8540, Child Care for American Families Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58, (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, October 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property, (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750-64,778, 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) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); 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 Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); implementation of the Inflation Reduction Act, (P.L. 117-169), including tax and energy security provisions; 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); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; extending the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, Pub. 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; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720); Turkeys new tax reform legislation

Client expense: $14,750,000 · 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)

American Innovation and R&D Competitiveness Act of 2023 (H.R.2673) make the immediate R&D expensing retroactive to 2022 and permanent. American Innovation and Jobs Act (S. 866) make the immediate R&D expensing retroactive to 2022 and permanent. American Investment in Manufacturing Act (H.R.2788) (S.1232) support reinstatement of the Earnings Before Interest, Tax, Depreciation and Amortization (EBITDA) measure. Accelerate Long-term Investment Growth Now (ALIGN) Act (H.R.2406) (S.1117), support making expensing for American investments in machinery and equipment permanent. The Tax Cuts and Jobs Act (TCJA) implementation, general business tax issues (P.L.117-169). Global tax activities and discussions on Pillar One and Pillar Two at OECD (No bill number). Tax Relief for American Families and Wokers Act of 2024 (H.R. 7024) Inflation Reduction Act of 2022, implementation of business tax provisions (P.L. 117-169).

Client expense: $1,280,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 2406, S 1117: ALIGN Act HR 2788, S 1232: The American Investment in Manufacturing (AIM) Act S 1706; Main Street Tax Certainty Act

Client expense: $37,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

In support of the EITC Age Parity Act (H.R. 5689) to include those without children over the age of 65 and under the age of 25 who otherwise qualify for the benefit In support of the Improve and Enhance the Work Opportunity Tax Credit Act (H.R. 6833), which increases credit to reflect inflation and encourages worker retention. In support of the Main Street Certainty Act (S.1706, H.R. 4721) which makes the IRS Section 199A small-business deduction for certain qualified business income (QBI) permanent for partnerships LLC's and other non-corporate businesses. In support of the Death Tax Repeal Act (S. 1108, H.R. 7035) which permanently repeals a law which imposes a tax on the transfer of property, land and other assets from a deceased family member to heirs of family farms and small businesses. In support of the ALIGN Act (S.1117, H.R. 2406), which would make permanent full and immediate expensing for American investments in machinery and equipment. In support of the American Investment in Manufacturing (AIM) Act (S.1232, H.R. 2788), which re-instates the standard for business interest deductions.

Client expense: Not reported · Firm income: $15,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Provision regarding the corporate tax rate; making permanent full expensing; S.1117/H.R.2406, the ALIGN Act; S.866, American Innovation and Jobs Act; H.R. 2673, American Innovation and R&D Competitiveness Act of 2023; Implementation of the Inflation Reduction Act (P.L. 117-169); Issues related to electric vehicle tax credits; Issues related to 45W; GILTI; International Tax Framework; H.R. 3938, Build It in America Act; H.R. 3665, Defending American Jobs and Investment Act; H.R. 2788 / S.1382, the American Investment in Manufacturing Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; S. 4237, Eliminating Lavish Incentives to Electric Act

Client expense: $320,000 · Firm income: Not reported

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

Implementation of Tax Cuts & Jobs Act (Pub.L. 115-97) H.R. 7024 - Tax Relief for American Families and Workers Act of 2024 Implementation of the Inflation Reduction Act (Pub.L. 117-169) H.R. 2788 / S. 1232 - American Investment in Manufacturing Act Issues related to Interest Expense Limitation Issues related to Bonus Depreciation Issues related to R&D Expensing

Client expense: $110,000 · Firm income: Not reported

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

Tax Policy: The Tax Relief for American Families and Workers Act of 2024. American Innovation and R&D Competitiveness Act (H.R.2673, S.866), which would permanently repeal the R&D amortization provision. The American Investment in Manufacturing Act (H.R.2788, S.1232), which would permanently restore the pro-growth EBITDA interest limitation standard. Accelerate Long-Term Investment Growth Now Act (H.R.2406, S.1117), which would permanently extend full expensing.

Client expense: $220,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

ALIGN Act Business Interest Deduction Corporate Book Profits Minimum Tax Corporate Income Tax Rate Employee Stock Ownership Plan Estate Tax Foreign Tax Credit Full Expensing H.R. 1304, American Innovation and R&D Competitiveness Act H.R. 2406, S. 1117, To Make Permanent 100% Full Expensing H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2788, S. 1232, AIM Act H.R. 3665, Defending American Jobs and Investment Act Individual Tax Rate Inflation Reduction Act Interest Deductibility (163(j) EBITDA Limitation) Onshoring Tax Incentives Partnerships Passthrough Deduction R&D Amortization R&D Tax Credit S. 866, American Innovation and Jobs Act Stepped-up Basis Stock Buybacks Excise Tax Tax Cuts and Jobs Act Expiring Provisions Tax Relief for American Families and Workers Act

Client expense: $1,410,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to EBITDA, bonus depreciation, support HR 7024, the Tax Relief for Working Families Act, TCJA/international tax provisions and the OECD. American Investment in Manufacturing Act (S 1232 and HR 2788)

Client expense: $500,000 · Firm income: Not reported

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

Implementation of the Tax Cuts and Jobs Act (P.L. No. 115-97); Implementation of the Coronavirus Aid, Relief, and Economic Security Act (P.L. No. 116-136); Implementation of the American Rescue Plan of 2021 (P.L. No 117-2), EBITDA reinstatement legislation; H.R. 3938 - Build It in America Act; S.1232/H.R. 2788 - American Investment in Manufacturing (AIM) Act; H.R. 7024 - Tax Relief for American Families and Workers Act of 2024.

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the deductibility of interest expense, including IRC section 163(j). (H.R. 7024, H.R. 2788, S. 1232)

Client expense: Not reported · Firm income: $120,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on the following issues: 100% expensing of bonus depreciation, research and experimentation costs, and dividend taxation; book minimum tax treatment of spectrum; corporate income tax rates and credits; corporate alternative minimum tax guidance; dividend taxation; and interest tax deduction limitation under 163(j) of the I.R.C. Lobbying on the following specific legislation: S. 341/H.R. 889 - Broadband Grant Tax Treatment Act (all provisions); S. 866 - American Innovation and Jobs Act and H.R. 2673 - American Innovation and Jobs Act (Spectrum and BEAD Program issues); S. 1117/H.R. 2406 - Accelerate Long-Term Investment Growth Now Act (ALIGN Act); S. 1232/H.R. 2788 - American Investment in Manufacturing (AIM) Act (provisions related to corporate interest deductibility); H.R. 220 - Advanced Aviation Act (corporate tax rate provisions); H.R. 2673 - American Innovation and R&D Competitiveness Act of 2023 (provisions related to research and development expensing); H.R. 3938 - Build It In America Act (extension of full expensing, R&D expensing and corporate tax deductibility). H.R. 7024 -- Tax Relief for American Families and Workers Act (full expensing of R&E expenses; and EBITA, rather than EBIT, limits on interest deductions).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 220: Advanced Aviation Act; provisions related to the corporate tax rate H.R. 889: Broadband Grant Tax Treatment Act; all provisions H.R. 2406: Accelerate Long-term Investment Growth Now (ALIGN) Act; provisions related to full expensing H.R. 2673: American Innovation and R&D Competitiveness Act of 2023; provisions related to research and development expensing H.R. 2788: AIM Act; provisions related to corporate interest deductibility H.R. 3210: Book Minimum Tax Repeal Act; all provisions H.R. 3938: Build it in America Act; extension of tax provisions related to full expensing, research and development expensing, and corporate interest deductibility H.R. 7024: Tax Relief for American Families and Workers Act of 2024; provisions related to tax reform, full expensing, research and development expensing, and corporate interest deductibility S. 341: Broadband Grant Tax Treatment Act; all provisions S. 866: American Innovation and Jobs Act; provisions related to research and experimentation expensing S. 1117: ALIGN Act; provisions related to full expensing S. 1232: AIM Act; provisions related to corporate interest deductibility S. 1559: Book Minimum Tax Repeal Act; all provisions Discussions related to 100% expensing bonus depreciation, research and experimentation costs, dividend taxation Discussions related to corporate income tax credits and corporate income tax rate Discussions related to Book Minimum Tax treatment of spectrum Discussions related to corporate alternative minimum tax guidance Discussions related to interest tax deduction limitation under 163(j) of the I.R.C.

Client expense: $2,850,000 · Firm income: Not reported

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

Domestic and international tax legislative and regulatory issues relating to the Inflation Reduction Act, H.R. 2788/S. 1232 (the American Investment in Manufacturing Act), and H.R. 7024 (the Tax Relief for American Families and Workers Act of 2024).

Client expense: Not reported · Firm income: $60,000

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

Work Opportunity Tax Credit (WOTC). Extension/enhancement of the Employee Retention Tax Credit (ERTC) and ERTC refund improvements. Tax rates, including corporate, individual, small business, and proposed cap on 199A. Net Investment Income Tax (NIIT), estate tax, capital gains, and step-up basis. IRS tax enforcement, and ERTC refund improvements. FICA tax tip credit. Business meals deduction. H.R. 2788/S. 1232, AIM Act. Service Industry Tip Compliance Agreement program. S. 1706, Main Street Tax Certainty Act. H.R. 4756, Community News and Small Business Support Act. Estate tax repeal proposals. H.R. 7024, Tax Relief for American Families and Workers Act of 2024. H.R. 6833, Improve and Enhance the Work Opportunity Tax Credit Act. H.R. 5689, EITC Age Parity Act of 2023. Service Industry Tip Compliance Agreement (SITCA) program. H.R. 7577, Creating Hospitality Economic Enhancement for Restaurant and Servers. S. 3680, Paid Family and Medical Leave Tax Credit Extension and Enhancement Act. H.R. 8941/S. 4621, No Tax on Tips Act.

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

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), Treasury, Dept of

Issues relating to the Tax Relief for American Families and Workers Act (H.R. 7204); issues relating to the American Innovation and R&D Competitiveness Act (H.R. 2673, S. 866); issues relating to R&D Section 174 expensing; issues relating to deduction of interest deductibility under Section 163(j) (American Investment in Manufacturing Act, H.R 2788); issues relating to bonus depreciation (H.R. 1117, H.R. 2406); issues relating to the Inflation Reduction Act (H.R.5376, all provisions); issues relating to OECD Pillar Two Model Rules and OECDs Pillar One and Pillar Two proposals; issues relating to OECD taxation of the digital economy project and potential tariff implications; Issues relating to implementation of climate and energy tax provisions in the Inflation Reduction Act (H.R.5376); issues relating to the Defending American Jobs and Investment Act (H.R. 3665); issues relating to the expiration of tax provisions in 2025 and workforce tax incentives; Issues relating to preserving a competitive corporate tax rate and international tax system.

Client expense: $4,920,000 · Firm income: Not reported

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

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Internal Revenue Service (IRS), Treasury; Superfund Chemical Taxes (88 Fed. Reg. 18,446-18,471, March 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58 (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, Oct. 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); 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; the Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect (Bill C-59, Fall Economic Statement Implementation Act, 2023); 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 (AMT); 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); 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; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, Pub. L. No. 115-97; Treasury regulations and other guidance related to the foreign tax credit; 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; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720)

Client expense: $13,930,000 · 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)

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), AIM Act (S. 1232/H.R. 2788), Build It In America Act (H.R. 3938); and legislative proposals related to equitable tax treatment of private equity in health care; regulations affecting the tax treatment of private equity.

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

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

American Innovation and R&D Competitiveness Act of 2023 (H.R.2673) make the immediate R&D expensing retroactive to 2022 and permanent. American Innovation and Jobs Act (S. 866) make the immediate R&D expensing retroactive to 2022 and permanent. American Investment in Manufacturing Act (H.R.2788) (S.1232) support reinstatement of the Earnings Before Interest, Tax, Depreciation and Amortization (EBITDA) measure. Accelerate Long-term Investment Growth Now (ALIGN) Act (H.R.2406) (S.1117), support making expensing for American investments in machinery and equipment permanent. The Tax Cuts and Jobs Act (TCJA) implementation, general business tax issues (P.L.117-169). Global tax activities and discussions on Pillar One and Pillar Two at OECD (No bill number). Tax Relief for American Families and Wokers Act of 2024 (H.R. 7024) Inflation Reduction Act of 2022, implementation of business tax provisions (P.L. 117-169).

Client expense: $1,250,000 · Firm income: Not reported

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. 1117 - ALIGN Act - all sections. S. 1232 - Permanently Preserving Americas Investment in Manufacturing Act - all sections. S. 3242 - ACCESS Rural America Act - all sections. H.R. 2406 - ALIGN Act - all sections. H.R. 2788 - Permanently Preserving Americas Investment in Manufacturing Act - all sections. H.R. 4360 - ACCESS Rural America Act - all sections.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Implementation of Tax Cuts & Jobs Act (Pub.L. 115-97) H.R. 7024 - Tax Relief for American Families and Workers Act of 2024 Implementation of the Inflation Reduction Act (Pub.L. 117-169) H.R. 2788 / S. 1232 - American Investment in Manufacturing Act Issues related to Interest Expense Limitation Issues related to Bonus Depreciation Issues related to R&D Expensing

Client expense: $110,000 · Firm income: Not reported

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

ALIGN Act Business Interest Deduction Corporate Book Profits Minimum Tax Corporate Income Tax Rate Employee Stock Ownership Plan Estate Tax Foreign Tax Credit Full Expensing H.R. 1304, American Innovation and R&D Competitiveness Act H.R. 2406, S. 1117, To Make Permanent 100% Full Expensing H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2788, S. 1232, AIM Act H.R. 3665, Defending American Jobs and Investment Act Individual Tax Rate Inflation Reduction Act Interest Deductibility (163(j) EBITDA Limitation) Onshoring Tax Incentives Partnerships Passthrough Deduction R&D Amortization R&D Tax Credit S. 866, American Innovation and Jobs Act Stepped-up Basis Stock Buybacks Excise Tax Tax Cuts and Jobs Act Expiring Provisions Tax Relief for American Families and Workers Act

Client expense: $1,850,000 · Firm income: Not reported

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

Provision regarding the corporate tax rate; making permanent full expensing; S.1117/H.R.2406, the ALIGN Act; S.866, American Innovation and Jobs Act; H.R. 2673, American Innovation and R&D Competitiveness Act of 2023; Implementation of the Inflation Reduction Act (P.L. 117-169); Issues related to electric vehicle tax credits; Issues related to 45W; GILTI; International Tax Framework; H.R. 3938, Build It in America Act; H.R. 3665, Defending American Jobs and Investment Act; H.R. 2788 / S.1382, the American Investment in Manufacturing Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; S. 4237, Eliminating Lavish Incentives to Electric Act

Client expense: $330,000 · Firm income: Not reported

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

Issues related to EBITDA, bonus depreciation, support HR 7024, the Tax Relief for Working Families Act, TCJA/international tax provisions and the OECD. American Investment in Manufacturing Act (S 1232 and HR 2788)

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

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