To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States.

Issues related to tax policy in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 33)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1340/S. 3332, More Homes on the Market Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2854/S. 1686, Neighborhood Homes Investment Act H.R. 2940/S. 4506, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) H.R. 8624/S. 4463, Workforce Apprenticeship Growth and Education Support (WAGES) Act of 2026 H.R. 8714, Skill Savings Account Act of 2026 H.R. 8780/S. 5330, Critical Mineral and Extraction Tax Parity Act H.R. 9012/S. 5366, the Affordable Housing Credit Carryback Act S. 796, Book Minimum Tax Repeal Act S. 5441, Taxpayer Assistance and Service (TAS) Act H.R. Res. 1383, Commemorating the one-year anniversary of the enactment of the Working Families Tax Cuts Potential legislation to extend and expand the advanced manufacturing investment credit in section 48D of the Internal Revenue Code Potential legislation to address the federal income tax treatment of cryptocurrency and other digital asset transactions 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) (as corrected by 89 Fed. Reg. 104,909-104,915, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, (91 Fed. Reg. 57,832-57,841, September 11, 2026) Interim Guidance on Special Depreciation Allowance for Qualified Production Property, I.R.S. Notice 2026-16, 2026-11 I.R.B. 685 Various issues relating to implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (Pub. L. 119-21); implementation of the employer-provided child care credit in section 45F of the Internal Revenue Code, as amended by the One Big Beautiful Bill Act (Pub. L. 119-21); Department of the Treasurys approach to tax deregulation; implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos Global Anti-Base Erosion (GLoBE) Rules; U.S. reengagement in a constructive dialogue on the taxation of the digital economy; Government of Belgiums consideration of a digital services tax; Polish Ministry of Digital Affairs draft legislation to introduce a 3% digital services tax; extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP); withdrawal or suspension of the Financial Accounting Standards Boards Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

Client expense: $16,480,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

S. 199/H.R. 33 - United States-Taiwan Expedited Double-Tax Relief Act;

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

Government targets: HOUSE OF REPRESENTATIVES

Advanced Manufacturing Investment Credit (IRC Section 48D) issues H.R.6055/S.1642, SEMI Investment Act, Entirety H.R.9438, Supporting Knowledge through Industry-Led Learning Act (SKILL Act), Entirety H.R.8780, Critical Mineral and Extraction Tax Parity Act, Entirety Critical mineral supply, Tax related issues Monitor the following: H.R.33/S.199, A bill to amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States, Entirety H.R.802, Semiconductor Technology Advancement and Research Act of 2025 (STAR Act of 2025), Entirety

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

Government targets: HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE, State, Dept of (DOS), Treasury, Dept of

Tax incentives for domestic investment in semiconductor manufacturing, research and development. CHIPS Implementation. H.R.33 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to international taxation; H.R.33/S.199, United States-Taiwan Expedited Double-Tax Relief Act; H.R.1, One Big Beautiful Bill Act (P.L.119-21) implementation; H.R.591, Defending American Jobs and Investment Act; H.R.2423, Unfair Tax Prevention Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to taxes, digital goods and services, renewable energy tax credits, and international and corporate taxation, including H.R. 1 - To provide for reconciliation pursuant to title II of H. Con. Res. 14. (P.L. 119-21), the United States-Taiwan Expedited Double Tax Relief Act (H.R. 33 / S. 199), and implementation of the Tax Cut and Jobs Act (P.L. 115-97).

Client expense: $4,360,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1340/S. 3332, More Homes on the Market Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2854/S. 1686, Neighborhood Homes Investment Act H.R. 2940/S. 4506, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) H.R. 8624/S. 4463, Workforce Apprenticeship Growth and Education Support (WAGES) Act of 2026 H.R. 8714, Skill Savings Account Act of 2026 H.R. 8780, Critical Mineral and Extraction Tax Parity Act S. 796, Book Minimum Tax Repeal Act S. 1605, International Competition for American Jobs Act S. 3931, Taxpayer Assistance and Service (TAS) Act Potential legislation to extend and expand the advanced manufacturing investment credit in section 48D of the Internal Revenue Code Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, Sept. 13, 2024) (as corrected by 89 Fed. Reg. 104,909-104,915, Dec. 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45Z Clean Fuel Production Credit, (91 Fed. Reg. 5,160-5,207, Feb. 4, 2026) Interim Guidance on Special Depreciation Allowance for Qualified Production Property, I.R.S. Notice 2026-16, 2026-11 I.R.B. 685 Recommendations for Items to be Included on the 2026-2027 Priority Guidance Plan, I.R.S. Notice 2026-23, 2026-15 I.R.B. 804 Various issues relating to implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (Pub. L. 119-21); Internal Revenue Code; clean fuel production credit section 45Z; implementation of the Inflation Reduction Act of 2022 (P. L. 117-169); Department of the Treasurys approach to tax deregulation; implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos global minimum tax rules; Government of Belgiums consideration of a digital services tax; extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; renewed multilateral dialogue on the taxation of the digital economy; withdrawal or suspension of the Financial Accounting Standards Boards Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP)

Client expense: $16,950,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R.33 and S. 199 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States. H.R. 1, One Big Beautiful Bill Act tax provisions. S. 3931, Taxpayer Assistance and Service Act ("TAS Act"). Corporate tax, transfer pricing, treaty, foreign tax credit, tax administration, mobile worker, international tax, and foreign tax issues.

Client expense: $2,690,000 · Firm income: Not reported

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

Issues related to tax policy in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 33).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to tax policy in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 33)

Client expense: $260,000 · Firm income: Not reported

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

S. 199/H.R. 33 - United States-Taiwan Expedited Double-Tax Relief Act;

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Advanced Manufacturing Investment Credit (IRC Section 48D) issues Pillar 2 global minimum tax issues H.R.33/S.199, A bill to amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States, Entirety H.R.802, Semiconductor Technology Advancement and Research Act of 2025 (STAR Act of 2025), Entirety H.R.6055/S.1642, SEMI Investment Act, Entirety H.R.9438, Supporting Knowledge through Industry-Led Learning Act (SKILL Act), Entirety H.R.8780, Critical Mineral and Extraction Tax Parity Act, Entirety Critical mineral supply, Tax related issues

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

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Security Council (NSC), Office of Science & Technology Policy (OSTP), SENATE, Treasury, Dept of

HR 4346 - CHIPS & Science Act HR 33 - United States-Taiwan Expedited Double-Tax Relief Act Discussions on the extension of the advanced manufacturing investment credit established under the CHIPS & Science Act

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

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Institute of Standards & Technology (NIST), SENATE, State, Dept of (DOS)

H.R.1990 - American Innovation and R&D Competitiveness Act of 2025. H.R.33 and S. 199 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States. H.R. 1, One Big Beautiful Bill Act tax provisions. Corporate tax, transfer pricing, treaty, foreign tax credit, tax administration, mobile worker, international tax, and foreign tax issues.

Client expense: Not reported · Firm income: Not reported

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

Issues related to international taxation; H.R.33/S.199, United States-Taiwan Expedited Double-Tax Relief Act; H.R.1, One Big Beautiful Bill Act (P.L.119-21) implementation; H.R.591, Defending American Jobs and Investment Act; H.R.2423, Unfair Tax Prevention Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Policy issues related to the extension of the advanced manufacturing investment credit (IRC section 48D) and direct payment of the credit; tax policy issues related to incentivizing semiconductor manufacturing, research and development, and design activities. All sections of the United States-Taiwan Expedited Double-Tax Relief Act (S. 199 and H.R. 33), Semiconductor Technology Advancement and Research (STAR) Act (H.R. 802), SEMI Investment Act (H.R. 6055 /S. 1642), and BASIC Act (H.R. 3204).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 2675, Protecting Our Courts from Foreign Manipulation Act H.R. 3941, To repeal the Caesar Syria Civilian Protection Act of 2019 H.R. 4215, International Traffic in Arms Regulations Licensing Reform Act H.R. 4233, AUKUS Reform for Military Optimization & Review ARMOR Act H.R. 6500, African Growth and Opportunity Act (AGOA) Reauthorization H.R. 6504, Haiti Economic Lift Program Extension Act S. 2934, Protecting Americans from Russian Litigation Act of 2025 H.J. Res. 72, Relating to a National Emergency by the President on February 1, 2025 Various issues related to reform of the World Trade Organization; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability for defective products and repealing Council Directive 85/374/EEC; development of the National Defense Authorization Act for Fiscal Year 2027, including provisions relating to foreign authorization legislation; compromise specific to right to repair for defense products intended for domestic and foreign use, foreign sales and industrial base cooperation reform; Congressional notification reform legislation

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Security Council (NSC), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2940, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6956/S. 452, BARCODE Efficiency Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) S. 796, Book Minimum Tax Repeal Act S. 1605, International Competition for American Jobs Act S. 4071, Child Care Tax Benefit Outreach and Assistance Act H.J. Res. 142/S.J. Res. 102, Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, Sept. 13, 2024) (as corrected by 89 Fed. Reg. 104,909-104,915, Dec. 26, 2024) Various issues relating to potential modifications to the gasoline tax, including waiving or temporary suspension; implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (P.L. 119-21); implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 (P.L. 119-78); implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos global minimum tax rules; Undertaxed Profit Rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; Polish Ministry of Digital Affairs proposal to adopt a discriminatory 3% digital services tax (DST) on select sectors of the digital economy; the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; renewed multilateral dialogue on the taxation of the digital economy; addressing the tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP); Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 2213/S. 998, Medical Supply Chain Resiliency Act H.R. 2548/S. 1241, Sanctioning Russia Act of 2025 H.R. 2665/S. 1272, Trade Review Act of 2025 H.R. 3193, United States-Republic of Korea Digital Trade Enforcement Act H.R. 5197/S. 3103, A bill to authorize the extension of nondiscriminatory treatment (normal trade relations treatment) to products of certain countries H.R. 5926, Mexican Energy Trade Enforcement Act H.R. 6194/S. 2934, Protecting Americans from Russian Litigation Act of 2025 H.R. 6500, AGOA Extension Act H.R. 6504, Haiti Economic Lift Program Extension Act S. 3399, Digital Trade Promotion Act S. 3841, Last Sale Valuation Act of 2026 H.J. Res. 72, Relating to the National Emergency by the President on February 1, 2025 S.J. Res. 77, A joint resolution terminating the national emergency declared to impose duties on articles imported from Canada S.J. Res. 88, A joint resolution terminating the national emergency declared to impose global tariffs Various issues relating to U.S.-Korea digital trade and services; Congressional tariff authority; Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process; reform of the World Trade Organization (WTO); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of the Trade Facilitation and Trade Enforcement Act of 2015 (P.L. 114-125); implementation of the Inflation Reduction Act, (P.L. 117-169); pharmaceutical price controls; patent-related issues, including patent linkage, patent term restoration, patent examination practices, and patent quality measures; regulatory data protection; efforts related to the U.S. International Development Finance Corporation (DFC); efforts related to ensuring a streamlined tariff refund process; efforts related to the advancement of tax treaties with Poland and Croatia; efforts related to identifying unfair foreign trade practices; efforts related to the extension of the African Growth and Opportunity Act (AGOA) (P.L. 106-200); efforts related to regulations issued by the Bank of Central African States (BEAC); efforts to preserve investment protections such as investor-state dispute settlement; efforts related to outlining critical mineral opportunities with key allies; efforts related to opposing international imposition of digital services taxes; efforts related to supporting strong digital trade rules; efforts to modify permanent normal trade relations treatment with China; U.S. economic and commercial relations with key trading partners across the globe; efforts to implement an outbound investment screening mechanism; efforts related to modernizing customs processes and updating tariff application procedures, including revisions to the de minimis statute; efforts related to the development of trade relations in the Indo-Pacific; efforts related to the development of trade relations in the Americas region; efforts related to the joint review of the U.S.-Mexico-Canada Agreement (USMCA); implementation and enforcement of U.S. free-trade agreements in force with 20 countries; implementation and enforcement of the agreements and ongoing negotiations of the WTO; trade policy concerns regarding customs duties on electronic transmissions; implementation of U.S. sanctions on Russia, including those related to Russias invasion of Ukraine; efforts related to sustaining momentum on providing aid to Ukraine; efforts related to reauthorization of the Export-Import Bank (Ex-Im Bank); reforms or changes to export controls; EU Digital Markets Act; EU Digital Services Act; EU Data Act; EU AI Act; IP issues relating to internet counterfeiting and digital piracy; IP issues relating to artificial intelligence; Global Internet Governance; policies and regulations restricting outbound data flows and data transfers; digital-related policies in the G20, G7, OECD, WTO, United Nations, and other international fora; digital trade policy considerations including cross-border data flows, digital service taxes, and issues of forced data localization, and forced disclosure of source code; international trade and regulatory practices impacting digital goods and services; international competition policy and related regulations; international artificial intelligence policy; international 5G policy and telecommunications infrastructure; international cybersecurity policy; international policies on standards development; international policies on data privacy; international digital health policies; international policies related to content moderation and intermediary liability; advancing international regulatory cooperation; consumer protection policy and related regulations; steel and aluminum tariffs; digital and tech sovereignty and sovereign cloud; IP issues at the WTO and the World Intellectual Property Organization; the EUs General Pharmaceutical Legislation; IP issues in Latin America, including enforcement of trade agreements and compulsory licenses and general IP standards and practices in Argentina, Mexico, Brazil, Colombia, and Chile; IP issues in India; USTRs Special 301 report and Review of Notorious Markets for Counterfeiting and Piracy; intersection of tariff-related policy and IP implications; U.S. Patent and Trademark Office IP Attache program; imposition of potential patent valuation fees; foreign pricing of pharmaceutical products; Most Favored Nation (MFN) reference pricing; ongoing practice of discretionary denials at the Patent Trial and Appeal Board; international competition policy, specifically FTC and DOJ involvement in the European Unions implementation of the EU Digital Markets Act; International Emergency Economic Powers Act (50 U.S.C. 1701(a)(b)) (IEEPA); IEEPA tariff refund implementation following the Supreme Courts decision in Learning Resources v. Trump; Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability for defective products and repealing Council Directive 85/374/EEC; Mexicos Tax Administration Service (SAT); recommended changes to the EUs Corporate Sustainability Due Diligence Directive (CS3D); supply chain and defense industrial base issues; development of the National Defense Authorization Act for Fiscal Year 2027

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Executive Office of the President (EOP), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Security Council (NSC), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR)

Tax incentives for domestic investment in semiconductor manufacturing, research and development. CHIPS Implementation. H.R.33 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 33 - United States-Taiwan Expedited Double-Tax Relief Act; S. 199 - United States-Taiwan Expedited Double-Tax Relief Act;

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

Government targets: SENATE

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 2675, Protecting Our Courts from Foreign Manipulation Act H.R. 3941, To repeal the Caesar Syria Civilian Protection Act of 2019 H.R. 4215, International Traffic in Arms Regulations Licensing Reform Act H.R. 4233, AUKUS Reform for Military Optimization & Review ARMOR Act H.R. 6500, African Growth and Opportunity Act (AGOA) Reauthorization H.R. 6504, Haiti Economic Lift Program Extension Act S. 2934, Protecting Americans from Russian Litigation Act of 2025 H.J. Res. 72, Relating to a National Emergency by the President on February 1, 2025 Various issues related to reform of the World Trade Organization; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability for defective products and repealing Council Directive 85/374/EEC; development of the National Defense Authorization Act for Fiscal Year 2027, including provisions relating to foreign authorization legislation; compromise specific to right to repair for defense products intended for domestic and foreign use, foreign sales and industrial base cooperation reform; Congressional notification reform legislation

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Security Council (NSC), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 2213/S. 998, Medical Supply Chain Resiliency Act H.R. 2548/S. 1241, Sanctioning Russia Act of 2025 H.R. 2665/S. 1272, Trade Review Act of 2025 H.R. 3193, United States-Republic of Korea Digital Trade Enforcement Act H.R. 5197/S. 3103, A bill to authorize the extension of nondiscriminatory treatment (normal trade relations treatment) to products of certain countries H.R. 5926, Mexican Energy Trade Enforcement Act H.R. 6194/S. 2934, Protecting Americans from Russian Litigation Act of 2025 H.R. 6500, AGOA Extension Act H.R. 6504, Haiti Economic Lift Program Extension Act S. 3399, Digital Trade Promotion Act S. 3841, Last Sale Valuation Act of 2026 H.J. Res. 72, Relating to the National Emergency by the President on February 1, 2025 S.J. Res. 77, A joint resolution terminating the national emergency declared to impose duties on articles imported from Canada S.J. Res. 88, A joint resolution terminating the national emergency declared to impose global tariffs Various issues relating to U.S.-Korea digital trade and services; Congressional tariff authority; Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process; reform of the World Trade Organization (WTO); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of the Trade Facilitation and Trade Enforcement Act of 2015 (P.L. 114-125); implementation of the Inflation Reduction Act, (P.L. 117-169); pharmaceutical price controls; patent-related issues, including patent linkage, patent term restoration, patent examination practices, and patent quality measures; regulatory data protection; efforts related to the U.S. International Development Finance Corporation (DFC); efforts related to ensuring a streamlined tariff refund process; efforts related to the advancement of tax treaties with Poland and Croatia; efforts related to identifying unfair foreign trade practices; efforts related to the extension of the African Growth and Opportunity Act (AGOA) (P.L. 106-200); efforts related to regulations issued by the Bank of Central African States (BEAC); efforts to preserve investment protections such as investor-state dispute settlement; efforts related to outlining critical mineral opportunities with key allies; efforts related to opposing international imposition of digital services taxes; efforts related to supporting strong digital trade rules; efforts to modify permanent normal trade relations treatment with China; U.S. economic and commercial relations with key trading partners across the globe; efforts to implement an outbound investment screening mechanism; efforts related to modernizing customs processes and updating tariff application procedures, including revisions to the de minimis statute; efforts related to the development of trade relations in the Indo-Pacific; efforts related to the development of trade relations in the Americas region; efforts related to the joint review of the U.S.-Mexico-Canada Agreement (USMCA); implementation and enforcement of U.S. free-trade agreements in force with 20 countries; implementation and enforcement of the agreements and ongoing negotiations of the WTO; trade policy concerns regarding customs duties on electronic transmissions; implementation of U.S. sanctions on Russia, including those related to Russias invasion of Ukraine; efforts related to sustaining momentum on providing aid to Ukraine; efforts related to reauthorization of the Export-Import Bank (Ex-Im Bank); reforms or changes to export controls; EU Digital Markets Act; EU Digital Services Act; EU Data Act; EU AI Act; IP issues relating to internet counterfeiting and digital piracy; IP issues relating to artificial intelligence; Global Internet Governance; policies and regulations restricting outbound data flows and data transfers; digital-related policies in the G20, G7, OECD, WTO, United Nations, and other international fora; digital trade policy considerations including cross-border data flows, digital service taxes, and issues of forced data localization, and forced disclosure of source code; international trade and regulatory practices impacting digital goods and services; international competition policy and related regulations; international artificial intelligence policy; international 5G policy and telecommunications infrastructure; international cybersecurity policy; international policies on standards development; international policies on data privacy; international digital health policies; international policies related to content moderation and intermediary liability; advancing international regulatory cooperation; consumer protection policy and related regulations; steel and aluminum tariffs; digital and tech sovereignty and sovereign cloud; IP issues at the WTO and the World Intellectual Property Organization; the EUs General Pharmaceutical Legislation; IP issues in Latin America, including enforcement of trade agreements and compulsory licenses and general IP standards and practices in Argentina, Mexico, Brazil, Colombia, and Chile; IP issues in India; USTRs Special 301 report and Review of Notorious Markets for Counterfeiting and Piracy; intersection of tariff-related policy and IP implications; U.S. Patent and Trademark Office IP Attache program; imposition of potential patent valuation fees; foreign pricing of pharmaceutical products; Most Favored Nation (MFN) reference pricing; ongoing practice of discretionary denials at the Patent Trial and Appeal Board; international competition policy, specifically FTC and DOJ involvement in the European Unions implementation of the EU Digital Markets Act; International Emergency Economic Powers Act (50 U.S.C. 1701(a)(b)) (IEEPA); IEEPA tariff refund implementation following the Supreme Courts decision in Learning Resources v. Trump; Directive (EU) 2024/2853 of the European Parliament and of the Council of 23 October 2024 on liability for defective products and repealing Council Directive 85/374/EEC; Mexicos Tax Administration Service (SAT); recommended changes to the EUs Corporate Sustainability Due Diligence Directive (CS3D); supply chain and defense industrial base issues; development of the National Defense Authorization Act for Fiscal Year 2027

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Executive Office of the President (EOP), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Security Council (NSC), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2940, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6956/S. 452, BARCODE Efficiency Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) S. 796, Book Minimum Tax Repeal Act S. 1605, International Competition for American Jobs Act S. 4071, Child Care Tax Benefit Outreach and Assistance Act H.J. Res. 142/S.J. Res. 102, Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, Sept. 13, 2024) (as corrected by 89 Fed. Reg. 104,909-104,915, Dec. 26, 2024) Various issues relating to potential modifications to the gasoline tax, including waiving or temporary suspension; implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (P.L. 119-21); implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 (P.L. 119-78); implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos global minimum tax rules; Undertaxed Profit Rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; Polish Ministry of Digital Affairs proposal to adopt a discriminatory 3% digital services tax (DST) on select sectors of the digital economy; the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; renewed multilateral dialogue on the taxation of the digital economy; addressing the tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP); Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

Issues related to taxes, digital goods and services, renewable energy tax credits, and international and corporate taxation, including H.R. 1 - To provide for reconciliation pursuant to title II of H. Con. Res. 14. (P.L. 119-21), the United States-Taiwan Expedited Double Tax Relief Act (H.R. 33 / S. 199), and implementation of the Tax Cut and Jobs Act (P.L. 115-97).

Client expense: $4,380,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

Advanced Manufacturing Investment Credit (IRC Section 48D) issues Pillar 2 global minimum tax issues H.R.33/S.199, A bill to amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States, Entirety H.R.802, Semiconductor Technology Advancement and Research Act of 2025 (STAR Act of 2025), Entirety H.R.6055/S.1642, SEMI Investment Act, Entirety

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.33 and S. 199 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States. H.R. 1, One Big Beautiful Bill Act tax provisions. Corporate tax, transfer pricing, treaty, foreign tax credit, tax administration, mobile worker, international tax, and foreign tax issues.

Client expense: $2,390,000 · Firm income: Not reported

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

Issues related to tax policy in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 33)

Client expense: $260,000 · Firm income: Not reported

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

HR 4346 - CHIPS & Science Act HR 33 - United States-Taiwan Expedited Double-Tax Relief Act Discussions on the extension of the advanced manufacturing investment credit established under the CHIPS & Science Act

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

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Natl Institute of Standards & Technology (NIST), SENATE, State, Dept of (DOS)

Issues related to international taxation; H.R.33/S.199, United States-Taiwan Expedited Double-Tax Relief Act; H.R.1, One Big Beautiful Bill Act (P.L.119-21) implementation; H.R.591, Defending American Jobs and Investment Act; H.R.2423, Unfair Tax Prevention Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to tax policy in the US-Taiwan Expedited Double Taxation Relief Act (H.R. 33).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Policy issues related to the extension of the advanced manufacturing investment credit (IRC section 48D) and direct payment of the credit; tax policy issues related to incentivizing semiconductor manufacturing, research and development, and design activities. All sections of the United States-Taiwan Expedited Double-Tax Relief Act (S. 199 and H.R. 33); Semiconductor Technology Advancement and Research (STAR) Act (H.R. 802); SEMI Investment Act (H.R. 6055 /S. 1642).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.1990 - American Innovation and R&D Competitiveness Act of 2025. H.R.33 and S. 199 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States. H.R. 1, One Big Beautiful Bill Act tax provisions. Corporate tax, transfer pricing, treaty, foreign tax credit, tax administration, mobile worker, international tax, and foreign tax issues.

Client expense: Not reported · Firm income: Not reported

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

Tax incentives for domestic investment in semiconductor manufacturing, research and development. CHIPS Implementation. H.R.33 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.1990 - American Innovation and R&D Competitiveness Act of 2025. H.R.33 and S. 199 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States. Corporate tax, transfer pricing, treaty, foreign tax credit, tax administration, mobile worker, international tax, and foreign tax issues.

Client expense: Not reported · Firm income: Not reported

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

Policy issues related to the implementation of the CHIPS and Science Act (P.L.117-167) advanced manufacturing investment credit (IRC section 48D); tax policy issues related to incentivizing semiconductor manufacturing, research and development, and design activities, United States-Taiwan Expedited Double-Tax Relief Act (S. 199 and H.R. 33). Semiconductor Technology Advancement and Research (STAR) Act (H.R. 802). SEMI Investment Act (H.R. 6055 /S. 1642). Implementation of the One Big Beautiful Bill Act (P.L. 119-21) pertaining to an increase in the rate of the advanced manufacturing investment credit and matters related to, IRC section 174 expensing.

Client expense: $424,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 33 - United States-Taiwan Expedited Double-Tax Relief Act; S. 199 - United States-Taiwan Expedited Double-Tax Relief Act;

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

Government targets: SENATE

Issues related to taxes, digital goods and services, renewable energy tax credits, and international and corporate taxation, including H.R. 1 - To provide for reconciliation pursuant to title II of H. Con. Res. 14. (P.L. 119-21), the United States-Taiwan Expedited Double Tax Relief Act (H.R. 33 / S. 199), and implementation of the Tax Cut and Jobs Act (P.L. 115-97).

Client expense: $4,590,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Natl Security Council (NSC), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R.1990 - American Innovation and R&D Competitiveness Act of 2025. H.R.33 and S. 199 - To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United States. H.R. 1, One Big Beautiful Bill Act tax provisions. Corporate tax, transfer pricing, treaty, foreign tax credit, tax administration, mobile worker, international tax, and foreign tax issues.

Client expense: $2,420,000 · Firm income: Not reported

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

Policy issues related to the implementation of the CHIPS and Science Act (P.L.117-167) advanced manufacturing investment credit (IRC section 48D); tax policy issues related to incentivizing semiconductor manufacturing, research and development, and design activities, United States-Taiwan Expedited Double-Tax Relief Act (S. 199 and H.R. 33). Semiconductor Technology Advancement and Research (STAR) Act (H.R. 802). SEMI Investment Act (H.R. 6055 /S. 1642). Implementation of the One Big Beautiful Bill Act (P.L. 119-21) pertaining to an increase in the rate of the advanced manufacturing investment credit and matters related to, IRC section 174 expensing.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 661, MIRACLE Medical Technology Act H.R. 953, United States Trade Leadership in the Indo-Pacific Act H.R. 1743/S. 776, UNITED Act H.R. 2213/S. 998, Medical Supply Chain Resiliency Act H.R. 2675, Protecting Our Courts from Foreign Manipulation Act H.R. 3838, Streamlining Procurement for Effective Execution and Delivery and National Defense Authorization Act for Fiscal Year 2026 H.R. 3941, To repeal the Caesar Syria Civilian Protection Act of 2019 H.R. 4215, International Traffic in Arms Regulations Licensing Reform Act H.R. 4216, Made-In-America Defense Act H.R. 4233, AUKUS Reform for Military Optimization & Review ARMOR Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3399, A bill to authorize the President to enter into digital trade agreements, and for other purposes S.J.Res. 37, A joint resolution terminating the national emergency declared to impose duties on articles imported from Canada Various issues related to implementation of the Trade-Related Aspects of Intellectual Property Rights (TRIPS) Agreement; reform of the World Trade Organization; Committee on Foreign Investment in the United States (CFIUS) concerns, specifically regarding the U.S. international exchange programs; negotiations with the International Monetary Fund; reauthorization of the U.S. International Development Finance Corporation; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); United States-Brazil Critical Minerals Cooperation; supply chain and the defense industrial base; Foreign Assistance Act for Fiscal Year 2026

Client expense: $17,960,000 · Firm income: Not reported

Government targets: Defense, Dept of (DOD), Energy, Dept of, HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Security Council (NSC), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2777/S. 1371, S-CAP Act of 2025 H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6231/S. 5370, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 6506, Taxpayer Due Process Enhancement Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Child Care Tax Benefit Outreach and Assistance Act Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) as corrected by (87 Fed. Reg. 45,018-45,021, July 27, 2022) 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)(as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Certain Disregarded Payments and Dual Consolidated Losses, T.D. 10026, (90 Fed. Reg. 3,003-3,021, January 14, 2025) Various issues relating to conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; 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, (P.L. 117-169); implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (Pub. L. No. 119-21); 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); IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); potential U.S. legislative and administrative responses 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; advancing the proposed side-by-side solution described in the G7 Statement on Global Minimum Taxes of June 28, 2025; withdrawal or suspension of the Financial Accounting Standards Boards Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; opposing the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; tax enforcement practices of Mexicos Tax Administration Service; Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

Client expense: $17,960,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 953, United States Trade Leadership in the Indo-Pacific Act H.R. 1625, the HELP Extension Act H.R. 1743/S. 776, Undertaking Negotiations on Investment and Trade for Economic Dynamism (UNITED) Act H.R. 2213/S. 998, Medical Supply Chain Resiliency Act H.R. 2548/S. 1241, Sanctioning Russia Act of 2025 H.R. 2665/S. 1272, Trade Review Act of 2025 H.R. 3193, United States-Republic of Korea Digital Trade Enforcement Act H.R. 5197/S. 3103, A bill to authorize the extension of nondiscriminatory treatment (normal trade relations treatment) to products of certain countries H.R. 5926, Mexican Energy Trade Enforcement Act H.R. 6194/S. 2934, Protecting Americans from Russian Litigation Act of 2025 H.R. 6500, AGOA Extension Act H.R. 6504, Haiti Economic Lift Program Extension Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3399, Digital Trade Promotion Act S.J.Res. 77, A joint resolution terminating the national emergency declared to impose duties on articles imported from Canada S.J.Res. 88, A joint resolution terminating the national emergency declared to impose global tariffs S.J.Res. 37, A joint resolution terminating the national emergency declared to impose duties on articles imported from Canada S.J.Res. 49, A joint resolution terminating the national emergency declared to impose global tariffs Draft legislation titled Haitian Hemispheric Opportunity through Partnership Encouragement Act Draft legislation titled AGOA Renewal and Improvement Act Draft legislation titled the Americas Act Proposed Rule, Federal Trade Commission; Business Opportunity Rule (16 CFR 437, January 13, 2025) Advanced Notice of Proposed Rulemaking, Federal Trade Commission; Earnings Claims Rule Regarding Multi-Level Marketing (Additional Provisions) (16 CFR Part 462, January 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients (90 Fed. Reg. 15,951-15,952, April 16, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices (90 Fed. Reg. 46,383, September 26, 2025) Various issues relating to U.S.-Korea digital trade and services; Generalized System of Preferences (GSP) reauthorization; Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process; fifty-percent (50%) tariff on imports from Brazil; ratification of the Assignment of Receivables in International Trade Convention; reform of the World Trade Organization (WTO); implementation of the American Manufacturing Competitiveness Act of 2016 (P.L.114-159); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of the Trade Facilitation and Trade Enforcement Act of 2015 (P.L. 114-125); implementation of the Uyghur Forced Labor Prevention Act (UFLPA) (P.L. 117-78); implementation of the African Growth and Opportunity Act (P.L. 106-200); implementation of the Inflation Reduction Act, (P.L. 117-169); reauthorization of the Customs-Trade Partnership Against Terrorism (CTPAT); pharmaceutical price controls; implementation of the Trade-Related Aspects of Intellectual Property Rights (TRIPS) Agreement; Office of the Intellectual Property Enforcement Coordinator and the National Intellectual Property Rights Coordination Center; patent-related issues, including patent linkage, patent term restoration, patent examination practices, and patent quality measures; regulatory data protection; efforts related to identifying unfair foreign trade practices; efforts related to the reauthorization of the African Growth and Opportunity Act (AGOA) (P.L. 106-200); efforts related to the reauthorization of the U.S. International Development Finance Corporation (DFC); efforts related to the advancement of tax treaties with Poland and Croatia; efforts related to regulations issued by the Bank of Central African States (BEAC); efforts related to the National Defense Authorization Act for Fiscal Year 2026; efforts to preserve investment protections such as investor-state dispute settlement; efforts related to outlining critical mineral opportunities with key allies; efforts related to opposing international imposition of digital services taxes; related efforts supporting strong digital trade rules; efforts to modify permanent normal trade relations treatment with China; U.S. economic and commercial relations with key trading partners across the globe; efforts to draft and implement an outbound investment screening mechanism; efforts related to establishing a domestic carbon border tax mechanism, foreign pollution fees; efforts related to modernizing customs processes and updating tariff application procedures, including revisions to the de minimis statute; efforts related to the development of trade relations in the Indo-Pacific; efforts related to the development and negotiation of the U.S.-Taiwan Initiative on 21st Century Trade; efforts related to the development of trade relations in the Americas region; efforts related to the development and negotiation of the U.S.-UK Dialogue on the Future of Atlantic Trade; efforts related to the development and negotiation of the U.S.-Kenya Strategic Trade and Investment Partnership; efforts related to the joint review of the U.S.-Mexico-Canada Agreement (USMCA); implementation and enforcement of U.S. free-trade agreements in force with Canada and Mexico (the United States-Mexico-Canada Agreement), the Dominican Republic-Central America Free Trade Agreement (CAFTA-DR FTA), Colombia and South Korea; implementation and enforcement of the agreements and ongoing negotiations of the World Trade Organization (WTO); efforts to significantly revise U.S. antidumping and countervailing duty law; Trade Promotion Authority (TPA) reauthorization and reform; U.S.-EU energy and sustainability cooperation; EU and international tax policy including digital tax proposals; U.S.-EU negotiations on a legal data transfer mechanism; U.S.-EU Trade & Technology Council; EU-U.S. Joint Technology Competition Policy Dialogue; EU Digital Markets Act; EU Digital Services Act; EU Data Act; EU AI Act; European Cybersecurity Certification Scheme for Cloud Services (EUCS); EU Carbon Border Adjustment Mechanism; China's intellectual property regime, industrial policies, and cyber security; implementation of the U.S.-China economic and trade agreement; United States-India Trade Policy Forum and associated bilateral trade negotiations; efforts related to sustaining momentum on providing aid to Ukraine; efforts to provide financial support, trade facilitation, and infrastructure support to the African Continental Free Trade Area (AfCFTA); IP issues relating to internet counterfeiting and digital piracy; IP issues relating to artificial intelligence; implementation of U.S. sanctions on Russia, including those related to Russias threats to and invasion of Ukraine; reforms to export controls; Global Internet Governance; network fees; Global Cross Border Privacy Rules Forum; policies and regulations restricting outbound data flows and data transfers; digital-related policies in the G20, G7, OECD, WTO, United Nations, and other international fora; Indias Information Communications Technology (ICT) Tariffs; Federal Trade Commission statutory authority under Section 19 of the Federal Trade Commission Act of 1914; efforts to modernize the Committee on Foreign Investment in the United States (CFIUS); efforts related to the Export-Import Bank (Ex-Im Bank); digital trade policy considerations including cross-border data flows, digital service taxes, and issues of forced data localization, and forced disclosure of source code; international trade and regulatory practices impacting digital goods and services; international competition policy and related regulations; international artificial intelligence policy; international 5G policy and telecommunications infrastructure; international cybersecurity policy; international policies on standards development; international policies on data privacy; international digital health policies; international policies related to content moderation and intermediary liability; advancing international regulatory cooperation; consumer protection policy and related regulations; steel and aluminum tariffs; trade policy concerns regarding customs duties on electronic transmissions; digital and tech sovereignty and sovereign cloud; tariff authority letter supporting Congress reclaiming its constitutional tariff authority; U.S.-Brazil trade; U.S.-Columbia Trade Promotion Agreement; Pacific Digital Trade Agreements; U.S.-Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital; U.S. Trade Representative section 301 investigation of Frances digital services tax; efforts to pass the Miscellaneous Tariff bill; Russian sovereign debt; Commercial Service Office in Bangladesh; Indo-Pacific Economic Framework and associated issues, digital trade de minimis level for duty free clearance of low value goods, competition provisions; recommendations for Export Controls Cooperation at the U.S.-EU Trade and Technology Council; adoption of digital clothing labels; IP issues at the World Trade Organization and the World Intellectual Property Organization; the EUs General Pharmaceutical Legislation; IP issues in Latin America, including enforcement of trade agreements and compulsory licenses and general IP standards and practices in Brazil and Chile; IP issues in India; USTRs Special 301 report and Review of Notorious Markets for Counterfeiting and Piracy; intersection of tariff-related policy and IP implications; U.S. Patent and Trademark Office IP Attache program; issues related to the imposition of potential patent valuation fees; issues related to the ongoing practice of discretionary denials at the Patent Trial and Appeal Board; international competition policy, specifically FTC and DOJ involvement in the European Unions implementation of the EU Digital Markets Act; proposal for General License Authorizing Private Commercial Arbitration Proceedings Involving Blocked Persons; The United States Trade Representatives decision to withdraw support for digital trade in the context of World Trade Organizations e-commerce negotiations; support for robust global framework for facilitation of digital trade through the ongoing joint statement initiative on e-commerce (JSI); Indonesia Ministry of Trade Import Licensing Regulations; International Emergency Economic Powers Act (50 U.S.C. 1701(a)(b)) (IEEPA); conduction of South Africas competition reviews; 2019 Agreement Suspending the Antidumping Investigation on Fresh Tomatoes from Mexico; continuation of the Moratorium on Customs Duties on Electronic Transmissions; recommended changes to the EUs Corporate Sustainability Due Diligence Directive (CS3D); Executive Order 14193, Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border; supply chain and defense industrial base issues; Foreign Assistance Act for Fiscal Year 2026

Client expense: $17,960,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Defense, Dept of (DOD), Energy, Dept of, Executive Office of the President (EOP), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Justice, Dept of (DOJ), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Security Council (NSC), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR)