Growing and Preserving Innovation in America Act of 2024

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 IRC sections 11, 951A, 250, and 163(j).(H.R. 7024, H.R. 8184).

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

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 and the potential impacts on the tax base of the U.S. and its Territories. Issues related to IRC sections 11, 951A, 250, 163(j), 168, 55, 56A, 59, 174 and 41. (H.R. 2673, H.R. 7024, H.R. 8184). Issues related to interest deductibility.

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

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 IRC sections 11, 951A, 250, 59A, 163(j), 168, 55, 56A, 59, 174 and 41. (H.R. 2673, H.R. 7024, H.R. 8184). Issues related to interest deductibility.

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

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. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 Inflation Reduction Act of 2022 (P.L. 117-169)

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

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office

H.J. Res. 148, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; H.R. 2673, American Innovation and R&D Competitiveness Act; H.R. 3210, Book Minimum Tax Repeal Act; H.R. 3938, Build It In America Act; H.R. 5564, REDUCE Act of 2023; H.R. 6454, Chemical Tax Repeal Act; H.R. 6532, Renewable Chemicals Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024; H.R. 8184, Growing and Preserving Innovation in America Act; H.R. 8773, Financial Services and General Government Appropriations Act, 2025; S.J. Res. 87, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; S. 866, American Innovation and Jobs Act; S. 1195, Chemical Tax Repeal Act; S. 1559, Book Minimum Tax Repeal Act; S. 2844, REDUCE Act of 2023; S. 3198, Foreign Pollution Fee Act; FY2025 Financial Services and General Government Appropriations Act; Implementation of the Superfund Tax on Chemicals; Tax Incentives and Rebates; Treaty Document 112-8, Tax Convention With Chile--Resolution of Advice and Consent;

Client expense: $5,830,000 · Firm income: Not reported

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

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 IRC sections 11, 951A, 250, and 163(j).(H.R. 7024, H.R. 8184).

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

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 IRC sections 11, 951A, 250, 59A, 163(j), 168, 55, 56A, 59, 174 and 41. (H.R. 2673, H.R. 7024, H.R. 8184).

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

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 and the potential impacts on the tax base of the U.S. and its Territories. Issues related to IRC sections 11, 951A, 250, 163(j), 168, 55, 56A, 59, 174 and 41. (H.R. 2673, H.R. 7024, H.R. 8184).

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

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 and the potential impacts on the tax base of the U.S. and its Territories. Issues related to IRC sections 11, 951A, 250, 163(j), 168, 55, 56A, 59, 174 and 41. (H.R. 2673, H.R. 7024, H.R. 8184).

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

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: $2,960,000 · 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. 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)

H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 Inflation Reduction Act of 2022 (P.L. 117-169)

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

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office