Tax Fairness for Disaster Victims Act

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act S.3432 - A bill to amend the Internal Revenue Code of 1986 to allow disaster-affected taxpayers to use preceding taxable year earned income to determine eligibility for the earned income credit and the refundable portion of the child tax credit. S.3497 - A bill to amend the Internal Revenue Code of 1986 to provide a credit against tax for disaster mitigation expenditures. H.R.7825 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. S.4502 - Farm Disaster Tax Cut Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; Implementation of the One Big Beautiful Bill Act, P.L. 119-21, including the provisions related to no tax on tips, no tax on overtime, Trump accounts, section 68 itemized deduction limitation, section 4960 related to the excise tax on excess tax-exempt organization executive compensation, inventory donations under section 170, and the paid family and medical leave tax credit; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes and specified service trades or businesses; The taxation of digital assets; digital assets reporting, including the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, P.L. 119-27; Digital Asset Protection, Accountability, Regulation, Innovation, Taxation, and Yields (PARITY)Act (H.R. 8899); Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 and S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 346 and S.1773), and the Working Families Disaster Tax Relief Act (H.R. 6645 and S.3432); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 and S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, tax administrative relief related to a government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, CP53E notices, collection due process hearing period, and first time abatement relief; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, section 68 itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427 and S. 3027); Methods and periods issues, including section 174 research and experimentation expensing, accounting method changes, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, including basis-shifting transactions, the corporate alternative minimum tax (CAMT) application to partnerships and CAMT entity partners, partnership workload compression, and Form 1065 instructions; S Corporation issues, including private letter ruling user fees; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; section 162(m) related to limitations on executive compensation, section 274(o) related to meals provided for convenience of an employer, determination letter program, the Employee Plans Compliance Resolution System (EPCRS), the Voluntary Compliance Program (VCP), C-4 opinion letters, and the self-correction program. Exempt organization issues, including foreign related filings, processing of group rulings, Form 8050, and Donor Advised Funds; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, dual consolidated loss rules, and other expired and expiring provisions; Individual tax issues, including the Facilitating Useful Loss Limitations to Help Our Unique Service Economy (FULL HOUSE Act) (S. 2230), the Fair Accounting for Income Realized from Betting Earnings Taxation Act (Fair Bet Act) (H.R. 4304), Winnings and Gains Expense Restoration (WAGER Act) (H.R. 4630), penalty relief for qualified farmers and fishermen impacted by changes to instructions for IRS Form 8995, and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act S.3432 - A bill to amend the Internal Revenue Code of 1986 to allow disaster-affected taxpayers to use preceding taxable year earned income to determine eligibility for the earned income credit and the refundable portion of the child tax credit. S.3497 - A bill to amend the Internal Revenue Code of 1986 to provide a credit against tax for disaster mitigation expenditures. H.R.7825 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes.

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; Implementation of the One Big Beautiful Bill Act, P.L. 119-21, including the provisions related to no tax on tips, no tax on overtime, Trump accounts, section 68 itemized deduction limitation, section 4960 related to the excise tax on excess tax-exempt organization executive compensation, inventory donations under section 170, and the paid family and medical leave tax credit; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes and specified service trades or businesses; The taxation of digital assets; digital assets reporting, including the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, P.L. 119-27; Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 and S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 346 and S.1773), and the Working Families Disaster Tax Relief Act (H.R. 6645 and S.3432); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 and S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, tax administrative relief related to a government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, collection due process hearing period, and first time abatement relief; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, section 68 itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427 and S. 3027); Methods and periods issues, including section 174 research and experimentation expensing, accounting method changes, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, including basis-shifting transactions, the corporate alternative minimum tax (CAMT) application to partnerships and CAMT entity partners, partnership workload compression, and Form 1065 instructions; S Corporation issues, including private letter ruling user fees; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; section 162(m) related to limitations on executive compensation, section 274(o) related to meals provided for convenience of an employer, determination letter program, the Employee Plans Compliance Resolution System (EPCRS), the Voluntary Compliance Program (VCP), C-4 opinion letters, and the self-correction program. Exempt organization issues, including foreign related filings; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, dual consolidated loss rules, and other expired and expiring provisions; Individual tax issues, including the Facilitating Useful Loss Limitations to Help Our Unique Service Economy (FULL HOUSE Act) (S. 2230), the Fair Accounting for Income Realized from Betting Earnings Taxation Act (Fair Bet Act) (H.R. 4304), Winnings and Gains Expense Restoration (WAGER Act) (H.R. 4630), penalty relief for qualified farmers and fishermen impacted by changes to instructions for IRS Form 8995, and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; One Big Beautiful Bill Act, P.L. 119-21; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 / S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), and the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 3469/S.1773); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 / S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, collection due process hearing period; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, Pease itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427); Methods and periods issues, including section 174 research and experimentation expensing, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, basis-shifting transactions; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; Exempt organization issues, including foreign related filings; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, and other expired and expiring provisions; Individual tax issues, including qualified business income section 199A, the Survivors Assistance for Fear-free and Easy Tax Filing Act of 2025 (SAFE Act) (S. 2129), and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; One Big Beautiful Bill Act, P.L. 119-21; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 / S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), and the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 3469/S.1773); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 / S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, collection due process hearing period; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, Pease itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427); Methods and periods issues, including section 174 research and experimentation expensing, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, basis-shifting transactions; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; Exempt organization issues, including foreign related filings; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, and other expired and expiring provisions; Individual tax issues, including qualified business income section 199A, the Survivors Assistance for Fear-free and Easy Tax Filing Act of 2025 (SAFE Act) (S. 2129), and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; One Big Beautiful Bill Act, P.L. 119-21; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 / S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), and the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 3469/S.1773); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 / S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, collection due process hearing period; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, Pease itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427); Methods and periods issues, including section 174 research and experimentation expensing, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, basis-shifting transactions; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; Exempt organization issues, including foreign related filings; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, and other expired and expiring provisions; Individual tax issues, including qualified business income section 199A, the Survivors Assistance for Fear-free and Easy Tax Filing Act of 2025 (SAFE Act) (S. 2129), and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; One Big Beautiful Bill Act, P.L. 119-21; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 / S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), and the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 3469/S.1773); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 / S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, collection due process hearing period; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, Pease itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427); Methods and periods issues, including section 174 research and experimentation expensing, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, basis-shifting transactions; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; Exempt organization issues, including foreign related filings; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, and other expired and expiring provisions; Individual tax issues, including qualified business income section 199A, the Survivors Assistance for Fear-free and Easy Tax Filing Act of 2025 (SAFE Act) (S. 2129), and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act S.3432 - A bill to amend the Internal Revenue Code of 1986 to allow disaster-affected taxpayers to use preceding taxable year earned income to determine eligibility for the earned income credit and the refundable portion of the child tax credit. S.3497 - A bill to amend the Internal Revenue Code of 1986 to provide a credit against tax for disaster mitigation expenditures.

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act

Client expense: $442,147 · Firm income: Not reported

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; One Big Beautiful Bill Act, P.L. 119-21; Individual, S corporation, partnership, trust and estate implementation and extension issues regarding the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Federal Disaster Tax Relief Act, the Tax Fairness for Disaster Victims Act (H.R. 3975), Filing Relief for Natural Disasters Act (H.R. 517 / S. 132), the Casualty Loss Deduction Restoration Act, the Federal Disaster Responsibility Act, and the Disaster Related Extension of Deadlines Act (H.R. 1491), and the Tax Relief for Victims of Crimes, Scams, and Disasters Act (H.R. 3469/S.1773); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1151 / S. 756); IRS priority guidance plan; Tax administration issues, including IRS modernization, regulation of tax return preparers, Circular 230, credit and refund lookback period, mailbox rule for electronic submissions and payments, and the Electronic Filing and Payment Fairness Act (H.R. 1152), the Internal Revenue Service Math and Taxpayer Help Act (H.R. 998), the Taxpayer Assistance and Service (TAS) Act discussion draft, IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act (H.R. 990), filing flexibility, quarterly estimated payments, electronic payments and disbursements, collection due process hearing period; Trust and estate issues, including generation-skipping transfer taxes, basis reporting, Pease itemized deduction limitation impact on estates and trusts, income tax returns for estates and trusts, estate tax returns, and gift tax returns; Mobile workforce and state income tax simplification issues, including the Mobile Workforce State Income Tax Simplification Tax Act (S. 1443); State remote sales tax issues; State income tax issues concerning P.L. 86-272, including the Interstate Commerce Simplification Act of 2025 (H.R. 427); Methods and periods issues, including section 174 research and experimentation expensing, and other expired and expiring provisions; Corporate taxation issues, including the corporate alternative minimum tax (CAMT); Corporation taxation issues related to section 355, nonrecognition of gain or loss in corporate separations, incorporations, and reorganizations; Partnership taxation issues, basis-shifting transactions; Employee benefits tax issues, including implementation of SECURE 2.0, Federal income tax treatment of contributions and benefits, and paid benefits under state paid family and medical leave statute; Exempt organization issues, including foreign related filings; Guiding Principles of Good Tax Policy; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including transfer pricing, previously taxed earnings and profits, OECD Pillar One and Pillar Two issues, taxpayers abroad filing issues, and other expired and expiring provisions; Individual tax issues, including qualified business income section 199A, the Survivors Assistance for Fear-free and Easy Tax Filing Act of 2025 (SAFE Act) (S. 2129), and 2025 filing season issues; Accounting profession tax matters related to the 2025 budget reconciliation; Beneficial ownership information reporting issues.

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts.

Client expense: $435,663 · Firm income: Not reported