Taxpayer Due Process Enhancement Act
Legislative Progress
Momentum (last 30 days)
0
score
0 actions · 0 new cosponsors · 0 votes
Speed vs cohort
93pct
162d open
vs 10,940 other HR bills in the 119th — cohort avg 30d
Taxpayer Due Process Enhancement Act This bill suspends the period of time allowed for claiming a federal tax refund (limitations period) during collection due process (CDP) proceedings, prohibits the Internal Revenue Service (IRS) from applying tax overpayments to a tax liability that is disputed in such proceedings, and expands the Tax Court’s jurisdiction. As background, IRS collection actions and the underlying tax liability (in some circumstances) may be disputed in a CDP hearing. Collection actions are suspended during CDP proceedings, but the IRS may apply tax overpayments from other tax years to the disputed tax liability. The Tax Court may review an appeal of a CDP hearing determination. However, the Supreme Court held in Commissioner v. Zuch that the Tax Court loses jurisdiction over a CDP appeal if the CDP hearing determination is revoked because tax overpayments are applied to and fully satisfy the tax liability. In such circumstances, the taxpayer may claim a refund and seek redress in federal district court. Currently, the limitations period to file a refund claim is not suspended during CDP proceedings. The bill suspends the limitations period for claiming a tax refund during CDP proceedings (with exceptions), prohibits the IRS from applying tax overpayments to a properly disputed tax liability during CDP proceedings (unless waived or an exception applies), expands the Tax Court's jurisdiction in CDP cases to include jurisdiction over the underlying tax liability amount (if properly disputed), and provides that the Tax Court retains its jurisdiction if the IRS abandons collection actions.
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Filing registrants (2)
2026 · third_quarter · Small Business
Good Government White House Conference on Small Business Act, H.R. 6855: Support action by U.S. House to advance the legislation. DME Scammer Prevention Act of 2026, H.R. 8871: Support the legislation and advancement through House Ways and Means Committee. Preventing Waste, Fraud and Abuse in TANF Act, H.R. 8872: Support the legislation and advancement through House Ways and Means Committee. Protecting Seniors and Stopping Fraudsters Act, H.R. 8883: Support the legislation and advancement through House Ways and Means Committee. Recover COVID Unemployment Fraud in Banks Act, H.R. 8873: Support the legislation and advancement through House Ways and Means Committee. Workforce Issues Valuing Employee Stock Today Act, H.R.8660: Support the legislation. Workforce Apprenticeship Growth and Education Support (WAGES) Act, H.R. 8624 and S. 4463: Support the legislation. Empowering Employer Child and Elder Care Solutions Act, H.R. 2270: Continue to support U.S. House passage of the bill. Working Families Flexibility Act, H.R. 2870: Continue to support full U.S. House passage of the bill. Tipped Employee Protection Act, H.R. 2312: Continue to support U.S. House passage of the bill. Access to Capital: INVEST Act, H.R. 3383: Continue to support U.S. Senate passage of this Housed-passed bill. Comments to Securities and Exchange Commission: Submitted comments in in support of a petition to raise the Regulation Crowdfunding offering limit to $20 million. Tax Policy Small Business Tax Cut Act, H.R. 8415: Support the legislation. Indexing Capital Gains Tax Liability to Inflation: Support legislative or administrative action to make this reform. More Homes on the Market Act, H.R. 1340, S.3332: Support the legislation. American Innovation Act, H.R. 1778, S. 4207: Support the legislation. Business Startup & Growth SAVE Local Businesses Act, H.R. 4366: Support U.S. House passage of the bill. New Opportunities for Business Ownership and Self-Sufficiency Act (NO BOSS Act), H.R. 6431: Supported U.S. House passage of the legislation and U.S. Senate introduction of the legislation. American Innovation Act, H.R. 1778, S. 4207: Support the legislation. AI and Technology Continue to voice restraint on excessive regulatory frameworks or actions that would undermine what is a critical new technology for small businesses. Comments to Federal Trade Commission: Submitted comments on the Proposed Enforcement Policy Statement Regarding Personalized Pricing, expressing concerns about the scope of the proposal the proposed frameworks misunderstanding of how dynamic and data-driven pricing tools are utilized by small businesses, and therefore how it would negatively impact their competitiveness and growth. AI Education: Continue to brief congressional staff on the benefits of AI to small businesses and startups as conveyed through SBE Council research and surveys. American Innovation and Choice Online Act (AICOA). S. 4746: Continue to oppose the legislation. Regulatory Modernization and Reform Guidance Out of Darkness (GOOD) Act (H.R. 1515): Urged Senate to advance House-passed bill. Bipartisan American Affordability and Jobs Act: Support the Senate introduced legislation. Latest Action on CTAs BOI Rule: Expressed support for the U.S. Department of the Treasury and Financial Crimes Enforcement Network (FinCEN) step in finalizing its rule ending the Beneficial Ownership Information (BOI) reporting mandate for U.S. businesses and individuals under the Corporate Transparency Act (CTA), and for taking the important additional step of deleting previously submitted information pertaining to U.S. persons. Comments to Small Business Administration: Submitted comments on the SBAs Proposed Small Business Size Standards, expressing support for modernization but a reconsideration of aspects of the methodology that could unintentionally disadvantage the very firms SBA exists to serve. Comments to Securities and Exchange Commission: Submitted comments in support of the Proposed Rule on Semiannual Reporting. NEPA Modernization: Expressed support for the Federal Communications Commissions vote to modernize its National Environmental Policy Act (NEPA) rules and streamline permitting for communications infrastructure. Packaging and Claims Knowledge Act (PACK Act), H.R. 6832: Support the legislation. Information Quality Assurance Act (H.R. 6329): Urged Senate to advance House-passed bill. ESA Amendments Act, H.R. 1897: Continue to support U.S. House passage of the bill. Prove It Act of 2025, H.R. 1163: Continue to support full U.S. House action and passage of the bill. Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act, H.R. 6398: Supported House passage of the legislation and Senate action. Standardizing Permitting and Expediting Economic Development Act (SPEED Act), H.R. 4776: Continue to support Senate action on House-passed bill. Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, H.R. 3898: Continue to support Senate action on House-passed bill. Repealing Big Brother Overreach Act, H.R. 425: Continue to support the legislation. Nominations Supported the nomination and confirmation of Keith Sonderling as U.S. Labor Department Secretary. Government Reform and Operations Tax Relief for Fraud Victims Act, H.R. 9500: Supported U.S. House passage of the legislation. AI Tax Integrity Act of 2026, H.R. 9501: Support full U.S. House passage of the legislation. Taxpayer Advocate Participation Act, H.R. 9498: Supported U.S. House passage of the legislation. Taxpayer Assistance and Service Act. S. 3931: Support full U.S. Senate passage of the legislation. Taxpayer Due Process Enhancement Act, H.R. 6506: Support U.S. Senate action on the House-passed bill. Taxpayer Notification and Privacy Act, H.R. 6495: Continue to support U.S. Senate action on the House-passed bill. Healthcare and Affordable Health Coverage HSAs For All Act, H.R. 7681: Continue to support the legislation. Lower Health Care Premiums for All Americans Act, H.R. 6703: Support Senate action of House-passed bill. Comments to the Centers for Medicare & Medicaid Services: Submitted comments on the proposed Medicare Program: Medicare Drug Price Negotiation Program and Medicare Prescription Drug Benefit Program rule, opposing CMSs proposed modification for initial price applicability year (IPAY) 2029 that would change how the agency identifies a qualifying single source drug under the Medicare Drug Price Negotiation Program created by the Inflation Reduction Act (IRA). Request for Information on Common Sense Policy Options to Lower Drug Prices for Patients: Submitted comments to Senate Finance Committees (via Ranking Member Wyden) Request for Information on policy options to lower prescription drug costs. 340B Drug Program: Continue to voice concerns about this program to Congress (in terms of effects on high drug and health premium costs) and the need for reforms. Abolish the Center for Medicare and Medicaid Innovation (CMMI) Act, H.R. 8293: Support the legislation. Intellectual Property Patent Eligibility Restoration Act (PERA), S. 1546: Reiterated support for the Senate introduced bill. Trade and Global Market Access Comments to the Office of the United States Trade Representative: Submitted comments on the 301 Investigation into Germanys persistent underpayment for innovative drugs, expressing encouragement about the investigation into the countrys unfair pharmaceutical pricing and the use of available USTR tools to press Americas trading partners to lift their price controls and contribute fairly to the innovation ecosystem from which they benefit American Global Competitiveness at 250: Legislative Proposals to Secure U.S. Technology Leadership: Submitted written testimony for the record before U.S. House Committee on Energy and Commerce expressing concerns about the European Unions Corporate Sustainability Due Diligence Directive (commonly referred to as CSDDD or CS3D) and the significant implications it poses for American businesses, small businesses and entrepreneurs. USMCA Review: Expressed overall support for the USMCA as it undergoes a review process. Urged the Administration to focus on strengthening and building upon the success of USMCA, make changes where warranted - such in the area of enforcement - so as not to destabilize supply chains and markets have become increasingly important to Americas entrepreneurs and small businesses.
Received in the Senate and Read twice and referred to the Committee on Finance.
Motion to reconsider laid on the table Agreed to without objection.
On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
Considered under suspension of the rules. (consideration: CR H3564-3567)
Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
Placed on the Union Calendar, Calendar No. 373.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
Congress.gov source codes: 5000, H12200
Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
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Sources: Congress.gov
Client expense: $35,000 · Firm income: Not reported
Government targets: Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Federal Communications Commission (FCC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, SENATE, Small Business Administration (SBA), U.S. Trade Representative (USTR)
2026 · second_quarter · Small Business
GOOD GOVERNMENT: White House Conference on Small Business Act, H.R. 6855: Support action by U.S. House to advance the legislation. DME Scammer Prevention Act of 2026, H.R. 8871: Support the legislation. Preventing Waste, Fraud and Abuse in TANF Act, H.R. 8872: Support the legislation. Protecting Seniors and Stopping Fraudsters Act, H.R. 8883: Support the legislation. Recover COVID Unemployment Fraud in Banks Act, H.R. 8873: Support the legislation. Supporting Rural Communities, H. Res. 1182: Supported House passage of the resolution. WORKFORCE ISSUES: Workforce Apprenticeship Growth and Education Support (WAGES) Act, H.R. 8624 and S. 4463: Support the legislation. Faster Labor Contracts Act, H.R. 5408: Opposed House passage of the legislation. Flexibility for Workers Education Act, H.R. 2262: Continue to support U.S. House passage of the bill. Empowering Employer Child and Elder Care Solutions Act, H.R. 2270: Continue to support U.S. House passage of the bill. Working Families Flexibility Act, H.R. 2870: Continue to support U.S. House passage of the bill. Tipped Employee Protection Act, H.R. 2312: Support U.S. House passage of the bill. DOLs Proposal to Expand Investment Opportunities in 401(k) Plans (Fiduciary Duties in Selecting Designated Investment Alternatives): Expressed support for a proposed rulemaking to provide American workers, small business owners and their employees with access to the same diversified opportunities long available to large pension funds. Submitted Comments to Department of Labor (DOL) on Employee or Independent Contractor Status Under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act: Expressed support for the proposed rule changes on independent contractors. President Trumps Executive Order on PROMOTING RETIREMENT-SAVINGS ACCESS FOR AMERICAN WORKERS BY ESTABLISHING TRUMPIRA.GOV: Expressed support for the initiative. ACCESS TO CAPITAL: INVEST Act, H.R. 3383: Support U.S. Senate passage of this Housed-passed bill. Submitted Comments to the Federal Reserve on Regulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations [R-1887]: SBE Council welcomed the re-proposal as a substantive improvement over the 2023 version and made slight recommendations. Submitted Comments to the Office of the Comptroller (OCC) on National Bank Non-Interest Charges and Fees, and interim final order, Order Preempting the Illinois Interchange Fee Prohibition Act. SBE Council expressed support for these actions. TAX POLICY: Small Business Tax Cut Act, H.R. 8415: Support the legislation. Indexing Capital Gains Tax Liability to Inflation: Support legislative or administrative action to make this change. H. Res. 1156 which Expresses Support for Tax Policies that Support Working Families: Supported the House resolution. More Homes on the Market Act, H.R. 1340, S.3332: Support the legislation. American Innovation Act, H.R. 1778, S. 4207: Support the legislation. BUSINESS STARTUP AND GROWTH: SAVE Local Businesses Act, H.R. 4366: Support U.S. House passage of the bill. New Opportunities for Business Ownership and Self-Sufficiency Act (NO BOSS Act), H.R. 6431: Supported U.S. House passage of the legislation. American Innovation Act, H.R. 1778, S. 4207: Support the legislation. Submitted Comments to Federal Trade Commission and Department of Justice on Making Improvements to the Premerger Notification and Report Form: Urged the agencies to consider maintaining the current HSR form and system, as potential changes have not been substantiated with failures, problems or flaws. AI AND TECHNOLOGY Continue to voice restraint on excessive regulatory frameworks or actions that would undermine what is a critical new technology for small businesses. SECURE Data Act (Securing and Establishing Consumer Uniform Rights and Enforcement over Data Act), H.R. 8413: Welcomed the introduction of comprehensive data privacy legislation. AI Education: Continue to brief congressional staff on the benefits of AI to small businesses and startups as conveyed through SBE Council research and surveys. American Innovation and Choice Online Act (AICOA). S. 4746: Oppose the legislation. REGULATORY REFORM AND MODERNIZATION Guidance Out of Darkness (GOOD) Act (H.R. 1515): Urged Senate to advance House-passed bill. Information Quality Assurance Act (H.R. 6329): Urged Senate to advance House-passed bill. ESA Amendments Act, H.R. 1897: Supported House passage of the bill. Prove It Act of 2025, H.R. 1163: Support House action and passage of the bill. 21st Century ROAD to Housing Act, H.R. 6644: Supported House amendment to the Senate-passed bill and final bill that went into law. Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act, H.R. 6398: Supported House passage of the legislation. Earnings Claims Rulemaking and Business Opportunity Rule: Continue to express concerns about these Biden-Era regulatory efforts that remain on the Federal Trade Commissions regulatory agenda Standardizing Permitting and Expediting Economic Development Act (SPEED Act), H.R. 4776: Supporting Senate action on House-passed bill. Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, H.R. 3898: Support Senate action on House-passed bill. Repealing Big Brother Overreach Act, H.R. 425: Support the legislation. GOVERNMENT REFORM AND OPERATIONS: Tax Relief for Fraud Victims Act, H.R. 9500: Support the legislation. AI Tax Integrity Act of 2026, H.R. 9501: Support the legislation. Taxpayer Advocate Participation Act, H.R. 9498: Support the legislation. Taxpayer Assistance and Service Act. S. 3931: Support the legislation. Taxpayer Due Process Enhancement Act, H.R. 6506: Support U.S. Senate action on the House-passed bill. Taxpayer Notification and Privacy Act, H.R. 6495: Support U.S. Senate action on the House-passed bill. HEALTHCARE AND AFFORDABLE HEALTH COVERAGE: HSAs For All Act, H.R. 7681: Support the legislation. Lower Health Care Premiums for All Americans Act, H.R. 6703: Support Senate action of House-passed bill. 340B Drug Program: Continue to voice concerns about this program to Congress (in terms of effects on high drug and health premium costs) and the need for reforms. Medication Affordability and Patent Integrity Act, S. 2658: Expressed concern about the legislation. Biosimilar Red Tape Elimination Act, S. 1954: Expressed concern about the legislation. Ensuring Timely Access to Generics Act, S. 3014: Expressed concern about the legislation. Abolish the Center for Medicare and Medicaid Innovation (CMMI) Act, H.R. 8293: Support the legislation. TRADE AND GLOBAL MARKET ACCESS: Submitted coalition comments to U.S. Department of Commerce on Section 232 Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment (91 FR 2443): Urged the Administration to refrain from imposing tariffs on semiconductors and downstream consumer and commercial technology products.
Client expense: $45,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), Labor, Dept of (DOL), Office of the Comptroller of the Currency (OCC), SENATE, White House Office
2026 · first_quarter · Small Business
Good Government White House Conference on Small Business Act, H.R. 6855: Support action by U.S. House to advance the legislation. Workforce Issues Flexibility for Workers Education Act, H.R. 2262: Continue to support U.S. House passage of the bill. Empowering Employer Child and Elder Care Solutions Act, H.R. 2270: Continue to support U.S. House passage of the bill. Working Families Flexibility Act, H.R. 2870: Continue to support U.S. House passage of the bill. Tipped Employee Protection Act, H.R. 2312: Support U.S. House passage of the bill. DOLs Proposal to Expand Investment Opportunities in 401(k) Plans: Supportive of a framework to provide American workers, small business owners and their employees with access to the same diversified opportunities long available to large pension funds. Access to Capital: INVEST Act, H.R. 3383: Support U.S. Senate passage of this Housed-passed bill. Small Entrepreneurs Empowerment and Development Act (SEED Act), H.R. 4171: Support U.S. House passage of the bill. Main Street Parity Act, H.R. 5763: Supported U.S. House passage of the bill. Tax Policy Indexing Capital Gains Tax Liability to Inflation: Support legislative or administrative action to make this change. More Homes on the Market Act, H.R. 1340, S.3332: Support the legislation. American Innovation Act, H.R. 1778, S. 4207: Support the legislation. H.J.Res. 142 - Disapproving the action of the D.C. Councils D.C. Income Franchise Conformity and Revision Temporary Amendment Act of 2025: Supported the resolution. Business Startup & Growth SAVE Local Businesses Act, H.R. 4366: Support U.S. House passage of the bill. New Opportunities for Business Ownership and Self-Sufficiency Act (NO BOSS Act), H.R. 6431: Continue to support action by the U.S. House on the legislation. American Innovation Act, H.R. 1778, S. 4207: Support the legislation. AI and Technology H.Res. 1007, Expressing the sense of the House of Representatives with respect to the use of artificial intelligence (AI) in the financial services and housing industries: SBE Council supports the resolution. AI for Main Street Act, H.R. 5764: Supported U.S. House passage of the bill. Continue to voice restraint on excessive regulatory frameworks or actions that would undermine what is a critical new technology for small businesses. White House National AI Legislative Framework: Voiced support for general vision of the framework and support efforts in the Congress to act on the framework. White House Ratepayer Protection Pledge: Voiced general support for the principles outlined by the executive action. AI Education: Continue to brief congressional staff on the benefits of AI to small businesses and startups as conveyed through SBE Council research and surveys. Regulatory Modernization and Reform Prove It Act of 2025, H.R. 1163: Support House action and passage of the bill. SHOWER Act, H.R. 4593: Supported U.S. House passage of the bill. Housing for the 2st Century Act, H.R. 6644: Supported U.S. House passage of the bill. Affordable Homes Act, H.R. 5184: Supported U.S. House passage of the bill. Critical Mineral Dominance Act, H.R. 4090: Supported U.S. House passage of the bill. Standardizing Permitting and Expediting Economic Development Act (SPEED Act), H.R. 4776: Supporting Senate action on House-passed bill. Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, H.R. 3898: Support Senate action on House-passed bill. Corporate Transparency Act (CTA) Database: Support eliminating the database by U.S. Treasury. Department of Labors Proposed Independent Contractor Rule: Voiced general support for the direction of the newly proposed rule (formal comments forthcoming.) Government Reform and Operations President Trumps Executive Action to Ensure Pay for TSA Workers, Secure and Stable Travel: Voiced support for the Action. Taxpayer Due Process Enhancement Act, H.R. 6506: Support U.S. Senate action on the House-passed bill. Taxpayer Notification and Privacy Act, H.R. 6495: Support U.S. Senate action on the House-passed bill. Health in American and Affordable Health Coverage HSAs For All Act, H.R. 7681: Support the legislation. Lower Health Care Premiums for All Americans Act, H.R. 6703: Support Senate action of House-passed bill. President Trumps Great Healthcare Plan: Voiced general support for elements of the plan that focus on improving accountability, competition, and transparency in order to create a market-based system for healthcare and insurance coverage. Trump Administrations New Dietary Guidelines for Americans: Voiced general support for the new guidelines. Reforming the Center for Medicare and Medicaid Innovation (CMMI): Support reforms to CMMI. Trade and Global Market Access Maintaining American Innovation and Technology Leadership - Ways and Means Committee, Subcommittee on Trade. Submitted a statement for the congressional record on how unfair trade practices and protectionist measures used by international competitors undermines U.S. technological leadership and the startups and small businesses that are the fonts of innovation in the U.S. Permanent WTO Moratorium on Customs Duties on Electronic Transmissions and WTO Work Programme on Electronic Commerce: Continue to support a permanent moratorium.
Client expense: $35,000 · Firm income: Not reported
Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of, White House Office
2025 · fourth_quarter · Taxation/Internal Revenue Code
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)
2025 · fourth_quarter · Small Business
Government Funding Legislation to Open the Federal Government: Supported ongoing efforts in the Senate to advance the minibus package, pass a clean CR - extending the CR to January 2026 - to keep the doors of the federal government open, and ongoing advocacy urging the Senate to open the federal government once shut down. Tax Related Issues: Relief, Compliance, Reform The Family Business Legacy Act, H.R. 2918: Continue to support U.S. House passage of the legislation. Taxpayer Due Process Enhancement Act, H.R. 6506: Supported U.S. House passage of the legislation. Taxpayer Notification and Privacy Act, H.R. 6495: Supported U.S. House passage of the legislation. Access to Capital: Accredited Investor Definition: Continue to express support for efforts in the Congress to modernize the standard. INVEST Act, H.R. 3383: Supported U.S. House Passage of the legislation. Main Street Parity Act, H.R. 5763: Support U.S. House action of the legislation. Made in America Manufacturing Finance Act (H.R. 3174): Support U.S. House action of the legislation. Business Startup & Growth AI for Main Street Act, H.R. 5764: Support action by the U.S. House on the legislation. New Opportunities for Business Ownership and Self-Sufficiency Act (NO BOSS Act), H.R. 6431: Continue to support action by the U.S. House on the legislation. Workforce and Workplace Enhancement Issues Flexibility for Workers Education Act, H.R. 2262: Continue to support U.S. House passage of the bill. Empowering Employer Child and Elder Care Solutions Act, H.R. 2270: Continue to support U.S. House passage of the bill. Working Families Flexibility Act, H.R. 2870: Continue to support U.S. House passage of the bill. Ensuring Workers Get PAID Act, H.R. 2299/S. 2267: Support action by the U.S. House and U.S. Senate on the legislation. Improve and Enhance the Work Opportunity Tax Credit (WOTC) Act, S.3265/H.R. 6231: Support action on the legislation. EITC for Older Workers Act, H.R. 2972: Support U.S. House action on the legislation. Credit for Caring Act, S. 925, H.R. 2036: Support action by U.S. House and U.S. Senate on the legislation. Regulation, Regulatory Modernization, and Compliance Reform: Small Business Regulatory Reduction Act (H.R. 2965): Supported U.S. House passage of the legislation. Small Business Regulatory Flexibility Improvements Act (H.R. 421): Continue to support the legislation and U.S. House passage. Destroying Unnecessary, Misaligned, and Prohibitive Red Tape (DUMP Red Tape) Act, H.R. 4305: Supported U.S. House passage of the legislation. Standardizing Permitting and Expediting Economic Development Act (SPEED Act), H.R. 4776: Support U.S. House passage of the legislation. Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, H.R. 3898: Support U.S. House passage of the legislation. PROVE It Act S.2074: Support the U.S. House and U.S. Senate legislation to strengthen regulatory accountability and transparency for small businesses. Fair and Accountable IRS Reviews Act, H.R. 5346: Continue to support the legislation. Taxpayer Due Process Enhancement Act, H.R. 6506: Supported U.S. House passage of the legislation. Taxpayer Notification and Privacy Act, H.R. 6495: Supported U.S. House passage of the legislation. Tax Court Improvement Act, H.R. 5349: Supported U.S. House passage of the legislation. IRS Basis-Shifting Rule and Fair Tax Enforcement: Continue to urge U.S. Treasury to take additional steps to protect small business partnerships from the implementation of policies and procedures that carry out the rules intent even though it as been rescinded. Warehouse Worker Protection Act (S.2613/H.R.4896): Oppose the legislation. Privacy Framework: Continue to support a federal framework governing privacy rules for the United States. DOL Independent Contractor Rule: Continue to support rescission of the independent contractor rule finalized by the Biden Administration, Employee or Independent Contractor Classification Under the Fair Labor Standards Act. FTCs 2023 Merger Guidelines and New Pre-Merger Filing Requirements: Continue to urge reform and clawing back the actions. Modern Worker Empowerment Act, H.R. 1319: Support action by the U.S. House. Modern Worker Security Act, H.R. 1320: Support action by the U.S. House. Faster Labor Contracts Act, S. 844: Oppose this U.S. Senate legislation. The Worker Enfranchisement Act, H.R. 2572: Support action by the U.S. House. Affordable Health Coverage: Lower Health Care Premiums for All Americans Act, H.R. 6703: Supported U.S. House passage of the legislation. Health Savings Accounts (HSAs): Support efforts in the House and Senate to expand and improve the accounts. Centers for Medicare and Medicaid Services (CMS) Rural Health Transformation Program: Supported implementation of the plan to support and strengthen the healthcare ecosystem in rural America that was advanced in the One Big Beautiful Bill Act. Price Controls: Continue to express concerns about drug price controls via most favored nation (MFN) and impact of importing price controls on innovation, investment, patient health. IP Rights and Protections: The RESTORE Patent Rights Act, S.708/H.R. 1574: Support action by the U.S. House and U.S. Senate on the legislation. Presidential Executive Orders and Memorandums SBE Council issued a supportive statement on "Ensuring a National Policy Framework for Artificial Intelligence." Trade and Global Markets: USTR Comments: 2026 Joint Review of the United States-Mexico-Canada Agreement (USMCA): Submitted comments to USTR in support of the general framework, urging more compliance efforts focused on protecting intellectual property (IP). U.S. Commerce Department Comments: Filed comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices, and asked for an exemption of Medtech from Sec. 232 tariffs. Continue to Support House and Senate Review of European-based digital laws and regulation such as the EUs Digital Services Act, the UKs Digital Markets, Competition and Consumers Act (DMCC), the EUs Digital Markets Act (DMA), and digital taxes and how these impose discriminatory barriers for American companies. Submitted Testimony for the Record for the Hearing Anti-American Antitrust: How Foreign Governments Target U.S. Businesses to House Judiciary Committee Subcommittee on the Administrative State, Regulatory Reform, and Antitrust and the impact of protectionist policies on U.S. based businesses.
Client expense: $30,000 · Firm income: Not reported
Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
Committee Consideration and Mark-up Session Held
Referred to the House Committee on Ways and Means.
Introduced in House
Congress.gov source codes: 1000, Intro-H
| Referred To |
| December 9, 2025 |
| December 9, 2025 |