To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules.

Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 11, 951A, 250, 55, 56A, 59, 174, and 958(b)(4).(H.R. 7024, H.R. 5751)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to OECD Pillar I and Pillar II negotiations and agreements on the taxation of global income. Issues related to Tax Cuts and Jobs Act. Issues related to corporate and international taxation. H.R. 7024 Tax Relief for American Families and Workers Act of 2024 and H.R. 5751 To amend the Internal Revenue Code of 1986 to restore limitation on downward attribution of stock ownership in applying constructive ownership rules; Issues related to tax code sections 11, 951A, 250, 55, 56A, 59, 174, and 958(b)(4).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the OECD Pillar 1 and Pillar 2 model rules. H.R.7024, Tax Relief for American Families and Workers Act of 2024. Issues related to tax code sections 951A, 250, 55, 56A, 59, 174, and 958(b)(4) H.R.5751, To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules. Issues related to tax code sections 951A, 250, 55, 56A, 59, 174, and 958(b)(4).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 951A, 250, 55, 56A, 59, 174, and 958(b)(4).(H.R. 7024, H.R. 5751)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to H.R. 5751 relating to restoring limitation on downward attribution of stock ownership Issues related to Amortization of Research and Experimental Expenditures (Section 174) in the Build it in America Act(H.R. 3938) Issues related to Limitations of Benefits in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 5988) Issues related to multiple tax provisions in the Tax Relief for American Families and Workers Act of 2024 (H.R. 7024)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to H.R. 5751 relating to restoring limitation on downward attribution of stock ownership Issues related to international taxes in the Defending American Jobs and Investment Act (H.R. 3665) Related to the OECD Pillar 2 Undertaxed Payment Rule Issues related to Amortization of Research and Experimental Expenditures (Section 174) in the Build it in America Act(H.R. 3938) Issues related to Limitations of Benefits in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 5988)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 951A, 250, 55, 56A, 59, 174, and 958(b)(4).(H.R. 3938, H.R. 5751)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to the OECD Pillar 1 and Pillar 2 model rules. H.R.5751; To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying constructive ownership rules; Issues regarding IRC 985(b)4

Client expense: $1,470,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to corporate and international taxation. Issues related to OECD Pillar 1 and Pillar 2 negotiations and agreements on the taxation of global income. Issues related to tax code sections 951A, 250, 163(j), 55, 56A, 59, 174, 41, and 958(b)(4). (H.R. 2673, H.R. 3938, H.R. 5751)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to H.R. 5751 relating to restoring limitation on downward attribution of stock ownership Issues related to international taxes in the Defending American Jobs and Investment Act (H.R. 3665) Related to the OECD Pillar 2 Undertaxed Payment Rule Issues related to Amortization of Research and Experimental Expenditures (Section 174) in the Build it in America Act(H.R. 3938) Issues related to Limitations of Benefits in the US-Taiwan Expedited Double Taxation Relief Act

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

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