Defending American Jobs and Investment Act

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. 1990, American Innovation and R&D Competitiveness Act H.R. 2406, S. 1117, To Make Permanent 100% Full Expensing 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: $1,680,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

Tax incentive issues as they relate to proposed global supply chain bills Discussions related to the repeal of the BEAT - provisions related to orphan drug tax credits S. 866/H.R. 2673, A bill to amend the Internal Revenue Code of 1986 to enhance tax benefits for research activities - issues related to R&D amortization H.R. 3665, To provide an enforcement of remedies against the extraterritorial taxes and discriminatory taxes of foreign countries. General issues around 2025 Reconciliation/Inbound Concerns

Client expense: $390,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES

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

H.R. 2688 - To amend the Internal Revenue Code of 1986 to permanently allow a tax deduction for the mining, reclaiming, or recycling of critical minerals and metals from the United States, and to support the development of domestic supply chains for rare earth elements and other critical materials essential to United States technology, manufacturing, energy, healthcare and advanced medical devices, broadband infrastructure, transportation, and national defense - Critical Minerals tax deduction credit for EV battery production H.R. 5376 - The Build Back Better Act - EV Tax incentives, new corporate tax rate, and other tax increases H.R. 4534 - FAIR Transition and Competition Act - Carbon Border Adjustment Tax Implementation of Pub. Law 117-169 - Inflation Reduction Act of 2022 - EV and clean energy incentives S. 5020 - Affordable Electric Vehicles for America Act of 2022 - Fix to IRA 30D implementation schedule H.R. 3665 - Defending American Jobs and Investment Act - A bill proposing penalties against companies headquartered in countries with a UTPR OECD Pillar 2 Implementation - Urging improved treatment of refundable and non-refundable tax credits in the United States that will conform to a global compliance regime H.R. 7024, the Tax Relief for American Families and Workers Act of 2024 - Includes a title that allows taxpayers to delay the date on which they must begin deducting their domestic R&D costs over a 5-year period; also, extends allowance for depreciation, amortization, or depletion in determining limitation of the business interest deduction, and extends 100% bonus depreciation and increases limitations on expensing depreciable business assets. S. 4873, the American Tax Dollars for American Solar Manufacturing Act, prohibiting the allowance of the advanced manufacturing production credit for components produced by foreign entities. W.H. Made in America Tax Plan - Corporation tax reform plan. W.H. The American Jobs Plan - Infrastructure plan that includes billions of dollars in tax credits and incentives. S. 3486 / H.R. 6762, Protecting American Advanced Manufacturing Act - The bill would prohibit companies associated with governments of foreign adversaries from receiving the advanced manufacturing production tax credit. S.4702, Critical Mineral Supply Chain Realignment Act of 2024 - The bill would impose duties on electromagnets, battery cells, electric storage batteries, and photovoltaic cells imported from certain countries. H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024 - This bill excludes from the new clean vehicle tax credit vehicles that contain components or material processed by a prohibited foreign entity (i.e., a terrorist organization) or an entity with ties to China, Iran, Russia, or North Korea.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

Monitored implementation of P.L.117-169, the Inflation Reduction Act, as it relates to corporate and international taxes. Issues related to the Orphan Drug Tax Credit. H.R. 7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D tax credit. Monitored H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665: DEFENDING AMERICAN JOBS AND INVESTMENT ACT; PROVISIONS RELATED TO INTERNATIONAL TAX REGULATION H.R. 7024: TAX RELIEF FOR AMERICAN FAMILIES AND WORKERS ACT OF 2024; PROVISIONS RELATED TO RESEARCH AND DEVELOPMENT TAX CREDIT AMORITIZATION GENERAL DISCUSSIONS RELATED TO CORPORATE AND INTERNATIONAL TAXATION AND INNOVATION

Client expense: $1,120,000 · Firm income: Not reported

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

H.R. 6833/S. 5370 - Improve and Enhance the Work Opportunity Tax Credit Act H.R. 3665 - Defending American Jobs & Investment Act S. 1706 - Main Street Tax Certainty Act Implementation of the Employee Retention Tax Credit S.1108 - Death Tax Repeal Act of 2023 Tax Extenders (including bonus depreciation) Earned income tax credit, workforce incentives H.R. 9263 - The Supporting Innovation in Agriculture Act Issues related to the expiration of the Tax Cuts and Jobs Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665, Defending American Jobs and Investment Act, OECD and Pillar II HR 3938, Build It in America Act, provisions related to R&D tax credits, full expensing, and EV incentives S.866, American Innovation and Jobs Act Implementation of H.R. 1, Tax Cuts and Jobs Act (P.L. 115-97) Issues related to corporate tax and international tax Implementation of H.R. 5376, Inflation Reduction Act (P.L. 117-169), electrification, clean energy provisions, and corporate and international tax provisions H.R.4695, Unfair Tax Prevention Act

Client expense: $520,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

Tax incentive issues as they relate to proposed global supply chain bills Discussions related to the repeal of the BEAT - provisions related to orphan drug tax credits S. 866/H.R. 2673, A bill to amend the Internal Revenue Code of 1986 to enhance tax benefits for research activities - issues related to R&D amortization H.R. 3665, To provide an enforcement of remedies against the extraterritorial taxes and discriminatory taxes of foreign countries. General issues around 2025 Reconciliation/Inbound Concerns

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES

International tax reform/OECD Digital services taxation On-shoring the semiconductor supply chain Tax Cuts and Jobs Act (TCJA)/foreign-derived intangible income (FDII) Permanency H.R. 3665 - Defending American Jobs and Investment Act R&D Amortization H.R. 8184 - Growing and Preserving Innovation in America Act

Client expense: $3,070,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Domestic and International Tax Policy Issues Research & Development Tax Credit Reforms Foreign Direct Investment Tax Cuts and Jobs Act Expensing of R&D Expenditures HR. 3665: Defending American Jobs and Investment Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D tax credit. Monitored H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to corporate international taxes, and the Orphan Drug Tax Credit. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665, Defending American Jobs and Investment Act H.R. 3938, Build It in America Act Discussions regarding the implementation of the Inflation Reduction Act (P.L. 117-169) Discussions related to tax credits for apprenticeships Monitor legislation and developments related to climate change Monitor development of international tax proposals Monitor proposal related to tax in COVID-19 legislation; monitor implementation of the Tax Cuts and Jobs Act of 2017 (P.L.115-97), provisions related to prevention of base erosion, treatment of P&C insurance, life insurance, and corporate rates Coronavirus Aid, Relief, and Economic Security Act (CARES Act), (P.L. 116-136); including issues relating to tax provisions and the treatment of net operating losses (NOLs) Inflation Reduction Act (P.L. 117-169) Discussions related to life insurance Monitor reports regarding US-Swiss tax treaty

Client expense: $450,000 · Firm income: Not reported

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

H.R. 3665, Defending American Jobs and Investment Act, OECD and Pillar II HR 3938, Build It in America Act, provisions related to R&D tax credits, full expensing, and EV incentives S.866, American Innovation and Jobs Act Tax Cuts and Jobs Act Implementation Issues related to corporate tax and international tax Implementation of H.R. 5376, Inflation Reduction Act (P.L. 117-169), electrification, clean energy provisions, and corporate and international tax provisions

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

International tax matters related to inbound and outbound investments and a global minimum tax; taxation matters related to the corporate tax rate. The Build It in America Act (H.R. 3938) The Defending American Jobs and Investment Act (H.R. 3665) The Unfair Tax Prevention Act (H.R. 4695)

Client expense: $1,225,684 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to corporate taxation; implementation of H.R.5376, Inflation Reduction Act of 2022 (P.L.117-169). Issues related to R&D expenses; H.R.7024, Tax Relief for American Families and Workers Act of 2024. Issues related to business interest expenses; S.1117/H.R.2406, A bill to amend the Internal Revenue Code of 1986 to permanently allow a tax deduction at the time an investment in qualified property is made. Issues related to R&D expenses and business interest expenses; H.R.7024, Tax Relief for American Families and Workers Act of 2024. Issues related to OECD International Tax Agreement; H.R.3665, Defending American Jobs and Investment Act; H.R.4695, Unfair Tax Prevention Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673), Build It in America Act (H.R. 3938), & American Innovation and Jobs Act (S.866): Research and Development (R&D) Expensing - advocacy for legislation to return to pre-2022 R&D expensing rules. OECD 2 Pillar Framework Implementation- International tax provisions specifically regarding the global minimum tax, including the Defending American Jobs and Investment Act (H.R. 3665) legislation regarding extraterritorial taxation. H.R.7024 - Tax Relief for American Families and Workers Act of 2024: Research and Development (R&D) Expensing - advocacy for legislation to return to pre-2022 R&D expensing rules

Client expense: $380,000 · 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 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

Monitor implementation of P.L. 117-169, the Inflation Reduction Act, as it relates to corporate and international taxes. H.R.7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D credit and interest expense deduction. Monitor H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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. 3665: DEFENDING AMERICAN JOBS AND INVESTMENT ACT; PROVISIONS RELATED TO INTERNATIONAL TAX REGULATION H.R. 7024: TAX RELIEF FOR AMERICAN FAMILIES AND WORKERS ACT OF 2024; PROVISIONS RELATED TO RESEARCH AND DEVELOPMENT TAX CREDIT AMORITIZATION GENERAL DISCUSSIONS RELATED TO CORPORATE AND INTERNATIONAL TAXATION AND INNOVATION

Client expense: $710,000 · Firm income: Not reported

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

H.R. 2688 - To amend the Internal Revenue Code of 1986 to permanently allow a tax deduction for the mining, reclaiming, or recycling of critical minerals and metals from the United States, and to support the development of domestic supply chains for rare earth elements and other critical materials essential to United States technology, manufacturing, energy, healthcare and advanced medical devices, broadband infrastructure, transportation, and national defense - Critical Minerals tax deduction credit for EV battery production H.R. 5376 - The Build Back Better Act - EV Tax incentives, new corporate tax rate, and other tax increases H.R. 4534 - FAIR Transition and Competition Act - Carbon Border Adjustment Tax Implementation of Pub. Law 117-169 - Inflation Reduction Act of 2022 - EV and clean energy incentives S. 5020 - Affordable Electric Vehicles for America Act of 2022 - Fix to IRA 30D implementation schedule H.R. 3665 - Defending American Jobs and Investment Act - A bill proposing penalties against companies headquartered in countries with a UTPR OECD Pillar 2 Implementation - Urging improved treatment of refundable and non-refundable tax credits in the United States that will conform to a global compliance regime H.R. 7024, the Tax Relief for American Families and Workers Act of 2024 - Includes a title that allows taxpayers to delay the date on which they must begin deducting their domestic R&D costs over a 5-year period; also, extends allowance for depreciation, amortization, or depletion in determining limitation of the business interest deduction, and extends 100% bonus depreciation and increases limitations on expensing depreciable business assets. S. 4873, the American Tax Dollars for American Solar Manufacturing Act, prohibiting the allowance of the advanced manufacturing production credit for components produced by foreign entities. W.H. Made in America Tax Plan - Corporation tax reform plan. W.H. The American Jobs Plan - Infrastructure plan that includes billions of dollars in tax credits and incentives. S. 3486 / H.R. 6762, Protecting American Advanced Manufacturing Act - The bill would prohibit companies associated with governments of foreign adversaries from receiving the advanced manufacturing production tax credit. S.4702, Critical Mineral Supply Chain Realignment Act of 2024 - The bill would impose duties on electromagnets, battery cells, electric storage batteries, and photovoltaic cells imported from certain countries. H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024 - This bill excludes from the new clean vehicle tax credit vehicles that contain components or material processed by a prohibited foreign entity (i.e., a terrorist organization) or an entity with ties to China, Iran, Russia, or North Korea.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

H.R. 3665, Defending American Jobs and Investment Act, OECD and Pillar II HR 3938, Build It in America Act, provisions related to R&D tax credits, full expensing, and EV incentives S.866, American Innovation and Jobs Act Implementation of H.R. 1, Tax Cuts and Jobs Act (P.L. 115-97) Issues related to corporate tax and international tax Implementation of H.R. 5376, Inflation Reduction Act (P.L. 117-169), electrification, clean energy provisions, and corporate and international tax provisions H.R.4695, Unfair Tax Prevention Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D tax credit. Monitored H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to corporate international taxes, and the Orphan Drug Tax Credit. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

International tax reform/OECD Digital services taxation On-shoring the semiconductor supply chain Tax Cuts and Jobs Act (TCJA)/foreign-derived intangible income (FDII) Permanency H.R. 3665 - Defending American Jobs and Investment Act R&D Amortization H.R. 8184 - Growing and Preserving Innovation in America Act

Client expense: $3,200,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 6833 - Improve and Enhance the Work Opportunity Tax Credit Act H.R. 3665 - Defending American Jobs & Investment Act S. 1706 - Main Street Tax Certainty Act Implementation of the Employee Retention Tax Credit S.1108 - Death Tax Repeal Act of 2023 Tax Extenders (including bonus depreciation) Earned income tax credit, workforce incentives H.R. 9263 - The Supporting Innovation in Agriculture Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665, Defending American Jobs and Investment Act H.R. 3938, Build It in America Act Discussions regarding the implementation of the Inflation Reduction Act (P.L. 117-169) Discussions related to tax credits for apprenticeships Monitor legislation and developments related to climate change Monitor development of international tax proposals Monitor proposal related to tax in COVID-19 legislation; monitor implementation of the Tax Cuts and Jobs Act of 2017 (P.L.115-97), provisions related to prevention of base erosion, treatment of P&C insurance, life insurance, and corporate rates Coronavirus Aid, Relief, and Economic Security Act (CARES Act), (P.L. 116-136); including issues relating to tax provisions and the treatment of net operating losses (NOLs) Inflation Reduction Act (P.L. 117-169) Discussions related to life insurance Monitor reports regarding US-Swiss tax treaty

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

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

Monitored implementation of P.L.117-169, the Inflation Reduction Act, as it relates to corporate and international taxes. Issues related to the Orphan Drug Tax Credit. H.R. 7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D tax credit. Monitored H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665, Defending American Jobs and Investment Act, OECD and Pillar II HR 3938, Build It in America Act, provisions related to R&D tax credits, full expensing, and EV incentives S.866, American Innovation and Jobs Act Tax Cuts and Jobs Act Implementation Issues related to corporate tax and international tax Implementation of H.R. 5376, Inflation Reduction Act (P.L. 117-169), electrification, clean energy provisions, and corporate and international tax provisions

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to corporate taxation; implementation of H.R.5376, Inflation Reduction Act of 2022 (P.L.117-169). Issues related to R&D expenses; H.R.7024, Tax Relief for American Families and Workers Act of 2024. Issues related to business interest expenses; S.1117/H.R.2406, A bill to amend the Internal Revenue Code of 1986 to permanently allow a tax deduction at the time an investment in qualified property is made. Issues related to R&D expenses and business interest expenses; H.R.7024, Tax Relief for American Families and Workers Act of 2024. Issues related OECD International Tax Agreement; H.R.3665, Defending American Jobs and Investment Act; H.R.4695, Unfair Tax Prevention Act.

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

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

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

Monitor implementation of P.L. 117-169, the Inflation Reduction Act, as it relates to corporate and international taxes. H.R.7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D credit and interest expense deduction. Monitor H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

International tax matters related to inbound and outbound investments and a global minimum tax; taxation matters related to the corporate tax rate. The Build It in America Act (H.R. 3938) The Defending American Jobs and Investment Act (H.R. 3665) The Unfair Tax Prevention Act (H.R. 4695)

Client expense: $1,521,648 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673), Build It in America Act (H.R. 3938), & American Innovation and Jobs Act (S.866): Research and Development (R&D) Expensing - advocacy for legislation to return to pre-2022 R&D expensing rules. OECD 2 Pillar Framework Implementation- International tax provisions specifically regarding the global minimum tax, including the Defending American Jobs and Investment Act (H.R. 3665) legislation regarding extraterritorial taxation. H.R.7024 - Tax Relief for American Families and Workers Act of 2024: Research and Development (R&D) Expensing - advocacy for legislation to return to pre-2022 R&D expensing rules

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665: DEFENDING AMERICAN JOBS AND INVESTMENT ACT; PROVISIONS RELATED TO INTERNATIONAL TAX REGULATION H.R. 7024: TAX RELIEF FOR AMERICAN FAMILIES AND WORKERS ACT OF 2024; PROVISIONS RELATED TO RESEARCH AND DEVELOPMENT TAX CREDIT AMORITIZATION

Client expense: $570,000 · Firm income: Not reported

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

H.R. 1319 - American Rescue Plan Act of 2021 - Provides additional relief to address the continued impact of COVID-19 on the economy, public health, state and local governments, individuals, and businesses H.R. 2688 - To amend the Internal Revenue Code of 1986 to permanently allow a tax deduction for the mining, reclaiming, or recycling of critical minerals and metals from the United States, and to support the development of domestic supply chains for rare earth elements and other critical materials essential to United States technology, manufacturing, energy, healthcare and advanced medical devices, broadband infrastructure, transportation, and national defense - Critical Minerals tax deduction credit for EV battery production W.H. Made in America Tax Plan - Corporation tax reform plan W.H. The American Jobs Plan - Infrastructure plan that includes billions of dollars in tax credits and incentives H.R. 5376 - The Build Back Better Act - EV Tax incentives, new corporate tax rate, and other tax increases H.R. 4534 - FAIR Transition and Competition Act - Carbon Border Adjustment Tax Implementation of Pub. Law 117-169 - Inflation Reduction Act of 2022 - EV and clean energy incentives S. 5020 - Affordable Electric Vehicles for America Act of 2022 - Fix to IRA 30D implementation schedule H.R. 3665 - Defending American Jobs and Investment Act - A bill proposing penalties against companies headquartered in countries with a UTPR OECD Pillar 2 Implementation - Urging improved treatment of refundable and non-refundable tax credits in the United States that will conform to a global compliance regime H.R. 7024, the Tax Relief for American Families and Workers Act of 2024 - Includes a title that allows taxpayers to delay the date on which they must begin deducting their domestic R&D costs over a 5-year period; also, extends allowance for depreciation, amortization, or depletion in determining limitation of the business interest deduction, and extends 100% bonus depreciation and increases limitations on expensing depreciable business assets.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office

H.R. 3665, Defending American Jobs and Investment Act, OECD and Pillar II HR 3938, Build It in America Act, provisions related to R&D tax credits, full expensing, and EV incentives S.866, American Innovation and Jobs Act Implementation of H.R. 1, Tax Cuts and Jobs Act (P.L. 115-97) Issues related to corporate tax and international tax Implementation of H.R. 5376, Inflation Reduction Act (P.L. 117-169), electrification, clean energy provisions, and corporate and international tax provisions H.R.4695, Unfair Tax Prevention Act

Client expense: $1,122,008 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 6833 - Improve and Enhance the Work Opportunity Tax Credit Act H.R. 3665 - Defending American Jobs & Investment Act H.R. 3937 - Small Business Jobs Act (Sec. 5 - Expensing for Depreciable Assets) S. 1706 - Main Street Tax Certainty Act Implementation of the Employee Retention Tax Credit S.1108 - Death Tax Repeal Act of 2023 Tax Extenders (including bonus depreciation) Earned income tax credit, workforce incentives

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

International tax reform/OECD Digital services taxation On-shoring the semiconductor supply chain Tax Cuts and Jobs Act (TCJA)/foreign-derived intangible income (FDII) Permanency H.R. 3665 - Defending American Jobs and Investment Act R&D Amortization H.R. 8184 - Growing and Preserving Innovation in America Act

Client expense: $2,960,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.7024, Tax Relief for American Families and Workers Act of 2024, as it relates to the R&D tax credit. Monitored H.R. 3665, Defending American Jobs & Investment Act, as it relates to taxation of foreign-based multinationals. Issues related to corporate international taxes, and the Orphan Drug Tax Credit. Issues related to the 2025 expiration of the Tax Cut and Jobs Act provisions impacting corporations.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3665, Defending American Jobs and Investment Act H.R. 3938, Build It in America Act Discussions regarding the implementation of the Inflation Reduction Act (P.L. 117-169) Discussions related to tax credits for apprenticeships Monitor legislation and developments related to climate change Monitor development of international tax proposals Monitor proposal related to tax in COVID-19 legislation; monitor implementation of the Tax Cuts and Jobs Act of 2017 (P.L.115-97), provisions related to prevention of base erosion, treatment of P&C insurance, life insurance, and corporate rates Coronavirus Aid, Relief, and Economic Security Act (CARES Act), (P.L. 116-136); including issues relating to tax provisions and the treatment of net operating losses (NOLs) Inflation Reduction Act (P.L. 117-169) Discussions related to life insurance Monitor reports regarding US-Swiss tax treaty

Client expense: $390,000 · Firm income: Not reported

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