Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies.

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 H.R.8540, Child Care for American Families Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58, (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, October 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property, (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750-64,778, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; Extraterritorial Application of Sec. 49 of the German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); implementation of the Inflation Reduction Act, (P.L. 117-169), including tax and energy security provisions; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; extending the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, Pub. L. No. 115-97; Treasury regulations and other guidance related to the foreign tax credit; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720); Turkeys new tax reform legislation

Client expense: $14,750,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Internal Revenue Service (IRS), Treasury; Superfund Chemical Taxes (88 Fed. Reg. 18,446-18,471, March 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58 (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, Oct. 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; Extraterritorial Application of Sec. 49 of the German Income Tax Act; the Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect (Bill C-59, Fall Economic Statement Implementation Act, 2023); potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement recommendations for Items to be Included on the 2024-2025 Priority Guidance Plan (Notice 2024-28); implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, Pub. L. No. 115-97; Treasury regulations and other guidance related to the foreign tax credit; U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720)

Client expense: $13,930,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406 / S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767 / S. 1243, Small Business Investment Act of 2023 H.R. 2788 / S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210 / S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R.5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H. Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Internal Revenue Service, Treasury Department; Advanced Manufacturing Investment Credit (88 Fed. Reg. 17,451-17,466, March 23, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, (88 Fed. Reg. 59,576-59,659, Aug. 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, Aug. 30, 2023) (as corrected by 88 Fed. Reg. 73,807, Oct. 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property, REG-117631-23, (88 Fed. Reg. 89,220-89,255, Dec. 26, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; U.S. Chile Income Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital; Extraterritorial Application of Sec. 49 of the German Income Tax Act; the Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect (Bill C-59, Fall Economic Statement Implementation Act, 2023); potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; recommendations for Items to be Included on the 2023-2024 Priority Guidance Plan (Notice 2023-36); 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); proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; Treasury regulations and other guidance related to the foreign tax credit; U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One

Client expense: $23,370,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of