Taxpayer Protection and Preparer Proficiency Act of 2019

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

Client expense: $1,310,000 · Firm income: Not reported

Government targets: Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), SENATE, Treasury, Dept of

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT Cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25, organization of the IRS, practitioner services division; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214; and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; Trust and estate tax issues, including foreign trusts, filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, valuation discounts, grantor trusts, estates and surcharge on trust and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

Educate Members of Congress on tax preparation services and related legislation, including H.R. 3466, to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; and H.R. 3330 / S. 1192, the Taxpayer Protection and Preparer Proficiency Act of 2019. Monitor H.R. 6800, the Heroes Act; H.R. 925, the Heroes Act (revised); S. 1624, HEALS Act; and implementation of the CARES Act (P.L. 116-136). Educate Members of Congress on reforming the PTIN issuance process, extending the tax filing deadline, and the Government Populated Return; monitor and educate on issues pertaining to the administration of Economic Impact Payments; support S. 3995 / H.R. 8056, the Remote and Mobile Worker Relief Act of 2020.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Monitor the following: H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Public Law 116-127, H.R.6201, Families First Coronavirus Response Act, Individual and business tax provisions Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Individual and business tax provisions

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Educate Members of Congress on tax preparation services and related legislation, including H.R. 3466, to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; and H.R. 3330 / S. 1192, the Taxpayer Protection and Preparer Proficiency Act of 2019. Monitor H.R. 6800, the Heroes Act; H.R. 925, the Heroes Act (revised); S. 1624, HEALS Act; and implementation of the CARES Act (P.L. 116-136). Educate Members of Congress on reforming the PTIN issuance process, extending the tax filing deadline, and the Government Populated Return; monitor and educate on issues pertaining to the administration of Economic Impact Payments.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Monitor the following: H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Public Law 116-127, H.R.6201, Families First Coronavirus Response Act, Individual and business tax provisions Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Individual and business tax provisions

Client expense: Not reported · Firm income: $10,000

Government targets: SENATE

Enrolled agent issues generally Public Law 116-25, Taxpayer First Act, Implementation issues H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Tax Return Preparers Public Law 116-127, Families First Coronavirus Response Act, Taxpayer related issues and initiatives and implementation Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Taxpayer related issues and initiatives and implementation H.R.6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act , Taxpayer related issues and initiatives

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

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

Educate Members of Congress on tax preparation services and related legislation, including H.R. 3466, to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; and H.R. 3330 / S. 1192, the Taxpayer Protection and Preparer Proficiency Act of 2019; monitor H.R. 6800, the HEROES Act, and implementation of the CARES Act (P.L. 116-136); educate Members of Congress on reforming the PTIN issuance process, the IRS Free File program, extending the tax filing deadline, and the Government Populated Return.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Public Law 116-127, H.R.6201, Families First Coronavirus Response Act, Individual and business tax provisions Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Individual and business tax provisions

Client expense: Not reported · Firm income: $10,000

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

H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Public Law 116-127, H.R.6201, Families First Coronavirus Response Act, Individual and business tax provisions Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Individual and business tax provisions

Client expense: Not reported · Firm income: $20,000

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

Enrolled agent issues generally Public Law 116-25, Taxpayer First Act, Implementation issues H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Tax Return Preparers Public Law 116-127, Families First Coronavirus Response Act, Taxpayer related issues and initiatives and implementation Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Taxpayer related issues and initiatives and implementation H.R.6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act , Taxpayer related issues and initiatives

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

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

Educate Members of Congress on tax preparation services and related legislation, including H.R. 3466, to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; H.R. 3330 / S. 1192, the Taxpayer Protection and Preparer Proficiency Act of 2019; and H.R. 1865, the Further Consolidated Appropriations Act, 2020 regarding IRS funding; oppose S. 1194, the Tax Simplification Act of 2019; advocate for clarification on tax filing deadlines.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Public Law 116-127, H.R.6201, Families First Coronavirus Response Act, Individual and business tax provisions Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Individual and business tax provisions

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Enrolled agent issues generally Public Law 116-25, Taxpayer First Act, Implementation issues H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Tax Return Preparers Public Law 116-127, Families First Coronavirus Response Act, Taxpayer related issues and initiatives Public Law 116-136, Coronavirus Aid, Relief, and Economic Security Act or the CARES Act, Taxpayer related issues and initiatives

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

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

Educate Members of Congress on tax preparation services and related legislation, including H.R. 3466, to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; H.R. 3330 / S. 1192, the Taxpayer Protection and Preparer Proficiency Act of 2019; and H.R. 1865, the Further Consolidated Appropriations Act, 2020 regarding IRS funding; oppose S. 1194, the Tax Simplification Act of 2019.

Client expense: Not reported · Firm income: $60,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax administration and tax fraud prevention; Taxpayer Service Standards; H.R. 3466, To amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; Preparer Tax Identification Number (PTIN) issuance reform; S. 1192, Taxpayer Protection and Preparer Proficiency Act of 2019; H.R. 3330, Taxpayer Protection and Preparer Proficiency Act of 2019; H.R. 1957, Taxpayer First Act of 2019; S. 928, Taxpayer First Act of 2019; S. 1194, Tax Simplification Act of 2019; IRC 7216, Disclosure or use of information by preparers of returns;

Client expense: $900,000 · Firm income: Not reported

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

Consulting services related to various general corporate tax issues and more specifically compliance tax issues impacting taxpayers and tax return preparers, and also tax issues impacting low and middle individual income taxpayers including: - Improve tax administration and tax fraud prevention; Promote minimum competency standards for tax return preparers; Regulatory reform; IRS reform - H.R. 3466, Bill to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers - S. 1192, Taxpayer Protection and Preparer Proficiency Act of 2019 - H.R. 4571, Tax Return Preparer Accountability Act of 2019

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Enrolled agent issues generally Public Law 116-25, Taxpayer First Act, Implementation issues H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Tax Return Preparers

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

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

Tax administration and tax fraud prevention; Taxpayer Service Standards; H.R. 3466, To amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; Preparer Tax Identification Number (PTIN) issuance reform; S. 1192, Taxpayer Protection and Preparer Proficiency Act of 2019; H.R. 3330, Taxpayer Protection and Preparer Proficiency Act of 2019; H.R. 1957, Taxpayer First Act of 2019; S. 928, Taxpayer First Act of 2019; S. 1194, Tax Simplification Act of 2019; IRC 7216, Disclosure or use of information by preparers of returns;

Client expense: $1,130,000 · Firm income: Not reported

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

H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Proposed New W-4 Form related issues

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Enrolled agent issues generally Public Law 116-25, Taxpayer First Act, Implementation issues H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Tax Return Preparers Public Law 115-97, Tax Cuts and Jobs Act, Implementation issues

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

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

Educate Members of Congress on tax preparation services and related legislation, including H.R. 3466, to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers; and H.R. 3330 / S. 1192, the Taxpayer Protection and Preparer Proficiency Act of 2019.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Consulting services related to various general corporate tax issues and more specifically compliance tax issues impacting taxpayers and tax return preparers, and also tax issues impacting low and middle individual income taxpayers including: - Improve tax administration and tax fraud prevention; Promote minimum competency standards for tax return preparers; Regulatory reform; IRS reform - H.R. 3466, Bill to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers - S. 1192, Taxpayer Protection and Preparer Proficiency Act of 2019

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Improve tax administration and tax fraud prevention; Promote minimum competency for tax return preparers; Regulatory reform; IRS reform H.R. 1957, Taxpayer First Act of 2019 S. 928, Taxpayer First Act of 2019 Education on administration of the Government Populated Return. Education on administration of the Free File program. Taxpayer Service Standards Issuance and revocation of the Preparer Tax Identification Number S. 1192, Taxpayer Protection and Preparer Proficiency Act of 2019 H.R. 3330, Taxpayer Protection and Preparer Proficiency Act of 2019 H.R. 3466, To amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers. IRC 7216, Disclosure or use of information by preparers of returns; Safeguarding and appropriate handling of taxpayer data

Client expense: $880,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Consulting services related to various general corporate tax issues and more specifically compliance tax issues impacting taxpayers and tax return preparers, and also tax issues impacting low and middle individual income taxpayers including: - Improve tax administration and tax fraud prevention; Promote minimum competency standards for tax return preparers; Regulatory reform; IRS reform - H.R. 1957, S. 928, Taxpayer First Act of 2019 - H.R. 3466, Bill to amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to rescind identifying numbers of tax return preparers - S. 1192, Taxpayer Protection and Preparer Proficiency Act of 2019

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Enrolled agent issues generally Public Law 116-25, Taxpayer First Act, generally H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Tax Return Preparers Public Law 115-97, Tax Cuts and Jobs Act, Implementation

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

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

Small business tax reform, generally Public Law 116-25, Taxpayer First Act, generally H.R.3330/S.1192, Taxpayer Protection and Preparer Proficiency Act of 2019, Regulation of Return Preparers issues Proposed New W-4 Form related issues

Client expense: Not reported · Firm income: $20,000

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

Advocating in support of improvements to the IRS and changes to tax administration policy, supporting HR 3151, S 1192.

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE