ALIGN Act

Business interest deduction CFC look-through Deductibility of expenses paid with PPP funds Employee Retention Tax Credit Estate Tax General Business Tax Credits H.R. 4549, American Innovation and Competitiveness Act H.R. 748, CARES Act OECD Digital Tax Project Onshoring tax incentives Payroll tax deferral R&D Amortization R&D Tax Credit Rev. Proc. 94-69 S. 3296, ALIGN Act S. 3612, Small Business Expense Protection Act of 2020 S. 3995, To limit the authority of States or other taxing jurisdictions to tax certain income of employees for employment duties performed in other States or taxing jurisdictions S. 4822, American Innovation and Jobs Act Tax Reform Implementation

Client expense: $1,350,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Citizenship & Immigration Services (BCIS), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Consumer Product Safety Commission (CPSC), Council on Environmental Quality (CEQ), Defense Information Systems Agency, Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Export-Import Bank of the United States (EXIM Bank), Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), Food & Drug Administration (FDA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Security Council (NSC), Office of Management & Budget (OMB), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), Postal Regulatory Commission, SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

General lobbying on the following issues: issues impacting corporate taxation and employer provided benefits; and issues related to international data taxation. Lobbying on the following bills: H.R.957 - Tax Cuts and Jobs Middle Class Enhancement Act (all provisions related to Implementation of the Tax Cuts and Jobs Act including provisions related to GILTI); H.R. 1725, Digital Goods and Services Fairness Act of 2019 (all provisions); H.R. 1869/S. 803, Restoring Investment in Improvements Act, restores the fifteen year depreciation recovery period for Qualified Improvement Property (all provisions); S. 604, Mobile Workforce State Income Tax Simplification Act of 2019 (all provisions); S. 684/H.R. 748, Middle Class Health Benefits Tax Repeal Act of 2019 (all provisions); S.3296/H.R.6802 - Align Act (all provisions); and S. 3995 - Remote and Mobile Worker Relief Act of 2020 (all provisions).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on the following issues: Digital Economy Directives proposed by OECD; State and local Taxation of Digital Good and Services; Corporate Interest Tax Deduction Regulations; Corporate Tax Rates; Dividend Taxation; Pension Smoothing; Foreign Taxation of Digital Services; State and Local Taxation of the Internet; Expensing (Bonus) Depreciation; Like Kind Exchanges; International Tax Regulations; and Term Asset Backed Security Loan Facility (TALF) Program. Lobbying on the following specific legislation: H.R. 748/S. 3548 - Employee Retention Credit; H.R. 1725/S. 765 - Digital Goods and Services Tax Fairness Act of 2019; H.R. 1869/S. 803 - Restoring Investment in Improvement Act; H.R. 4796 - Mobile Workforce State Income Tax Simplification Act of 2019; H.R. 5674 - Mobile Workforce State Income Tax Simplification Act of 2020; H.R. 6802/S.3296 - Accelerate Long-Term Investment Growth Now (ALIGN) Act; H.R. 8056 - Remote Worker Relief Act of 2020; S. 604 - Mobile Workforce State Income Tax Simplification Act of 2019; S.3995 - Remote and Mobile Worker Relief Act of 2020; and S. 4318 - American Workers, Families, and Employers Assistance Act.

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

H.R. 1434/S.634, the Education Freedom Scholarships and Opportunity Act H.R. 2210, the Invest in America Act H.R. 748, the CARES Act Issues related to FIRPTA reform Issues related to GILTI implementation Issues related to indexing capital gains taxes to inflation Issues related to SALT deduction Issues related to tax extenders Mobile Workforce State Income Tax Simplification Act of 2020, H.R. 5674 S. 3280, the Blocking New Corporate Tax Giveaways Act S. 3296, the Accelerate Long-Term Investment Growth Now Act The PLAN Act, H.R. 4232 "H.R. 6800, The Heroes Act " Issues related to implementation of the Paycheck Protection Program "S. 3612, the Small Business Expense Protection Act " Issues related to Schedule B Issues related to alcohol excise taxes Issues related to tax filing and tax preparation deadlines Issues related to DoL information letter on Private Equity investments H.R. 6800, The Heroes Act Issues related to federal royalty rate payments Issues related to federal royalty rate payments Issues related to C-Band Helping Gig Economy Workers Act H. R. 7749, To amend the Internal Revenue Code of 1986 to encourage the transfer of intangible property from controlled foreign corporations to United States shareholders H. R. 7767, To amend the Internal Revenue Code of 1986 to provide for credits against tax for domestic medical and drug manufacturing and advanced medical manufacturing equipment H.R 8201, the Support for Workers, Families, and Social Security Act H.R. 7556, To amend the Internal Revenue Code of 1986 to make a portion of research credit refundable for certain small businesses engaging in specified medical research H.R. 7615, To provide a payrolltaxcreditfor certain expenses associated with protecting employees from COVID-19. H.R. 7787, the Invest Now Act H.R.7505, the AmericanInnovationAct H.R.7537, the Infectious Disease Therapies Research and Innovation Act H.R.7555, To amend the Internal Revenue Code of 1986 to add a new medical research component to the credit for increasing research activities H.Res.1097 - Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Issues related to digital services taxes Issues related to payroll tax EO S. 1703/H.R.3077, the Affordable Housing Credit Improvement Act S. 4537, The Reinvigorating the Economy, Creating Opportunity for Every Vocation, Employer, Retiree, and Youth (RECOVERY) Act S. 4708/H.R.8038, the Pandemic Preparedness, Response, and Recovery Act (PPRRA) S.3733 and H.R. 6988, the Helping Gig Economy Workers Act of 2020

Issues impacting corporate taxation and employer provided benefits, issues related to international data taxation S 604, Mobile Workforce State Income Tax Simplification Act of 2019, all provisions HR 1725, Digital Goods and Services Fairness Act of 2019, all provisions Implementation of the Tax Cuts and Jobs Act including provisions related to GILTI HR 1869/S 803, Restoring Investment in Improvements Act, restores the fifteen year depreciation recovery period for Qualified Improvement Property, all provisions S 684/HR 748, Middle Class Health Benefits Tax Repeal Act of 2019 S 3995, Remote and Mobile Worker Relief Act of 2020, all provisions S 3296/HR 6802, Align Act, all provisions

Client expense: $2,530,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Science & Technology Policy (OSTP), Office of the Vice President of the United States, SENATE, Treasury, Dept of, White House Office

H.R. 748/S. 3548 - Employee Retention Credit H.R. 1725/S. 765 - Digital Goods and Services Tax Fairness Act of 2019 H.R. 1869/S. 803 - Restoring Investment in Improvement Act H.R. 4796 - Mobile Workforce State Income Tax Simplification Act of 2019 H.R. 5674 - Mobile Workforce State Income Tax Simplification Act of 2020 H.R. 6802/S. 3296 - Accelerate long-term Investment Growth Now Act (ALIGN Act) H.R. 8056 - Remote Worker Relief Act of 2020 S. 604 - Mobile Workforce State Income Tax Simplification Act of 2019 S. 3995 - Remote and Mobile Worker Relief Act of 2020 S. 4318 - American Workers, Families, and Employers Assistance Act Digital Economy Directives proposed by OECD State and local Taxation of Digital Good and Services Corporate Interest Tax Deduction Regulations Corporate Tax Rates Dividend Taxation Pension Smoothing Foreign Taxation of Digital Services State and Local Taxation of the Internet Expensing (Bonus) Depreciation Like Kind Exchanges of Spectrum International Tax Regulations Term Asset Backed Security Loan Facility (TALF) Program

Client expense: $2,240,000 · Firm income: Not reported

HR 748 Responding to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. S 3548 Coronavirus Aid, Relief, and Economic Security (CARES) Act. S 3296 Makes permanent the expensing of certain new business equipment. Expensing allows the deduction of the full amount of an expense item in the same taxable year. Other issues: Aircraft deduction disallowance rules under IRC section 274 Tax depreciation schedules for general aviation aircraft IRS air transportation excise taxes Air transportation excise tax suspension implemented under the CARES Act Proposed rules implementing Section 13822 of Public Law 115-97, 131 Stat. 2054, 2182 (2017) (i.e. Tax Cuts and Jobs Act), which amended the code by adding a provision that no tax shall be imposed by sections 4261 or 4271 for amounts paid by an aircraft owner for management services related to, or flights on, the owner's aircraft Aircraft equipage and funding Internal Revenue Service-I.R.C.280F(d)(6)(c); Treas. Reg. 1.280F-6(d) qualified business use test Request for IRS to provide guidance regarding the tax consequences of the use of a business aircraft in charitable and humanitarian activities Request for IRS to review the treatment of TAM200945037 of leasing aircraft to 5-percent owners and related parties under the depreciation limitation in I.R.C.280F(9)(B) and provide administrative guidance Depreciation systems for business use property Temporary expensing rules under IRC 168(k) Request for IRS to provide guidance on limitation of deductions for entertainment and commuting expenses

Client expense: $440,000 · Firm income: Not reported

General lobbying on the following issues: Digital Economy Directives proposed by OECD; State and local Taxation of Digital Good and Services; Corporate Interest Tax Deduction Regulations; Corporate Tax Rates; Dividend Taxation; Pension Smoothing; Foreign Taxation of Digital Services; State and Local Taxation of the Internet Expensing (Bonus) Depreciation; State Payroll Tax Withholding; Like Kind Exchanges; and TALF ABS Program. Lobbying on the following specific legislation: H.R. 748/S. 3548 - Employee Retention Credit; H.R. 1725/S. 765 - Digital Goods and Services Tax Fairness Act of 2019; H.R. 1869/S. 803 - Restoring Investment in Improvement Act; H.R. 4796 - Mobile Workforce State Income Tax Simplification Act of 2019; H.R. 5674 - Mobile Workforce State Income Tax Simplification Act of 2020; H.R. 6802/S.3296 - Accelerate Long-Term Investment Growth Now (ALIGN) Act; S. 604 - Mobile Workforce State Income Tax Simplification Act of 2019; and S.3995 - Remote and Mobile Worker Relief Act of 2020.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 748/S. 3548 - Employee Retention Credit H.R. 1725/S. 765 - Digital Goods and Services Tax Fairness Act of 2019 H.R. 1869/S. 803 - Restoring Investment in Improvement Act H.R. 4796 - Mobile Workforce State Income Tax Simplification Act of 2019 H.R. 5674 - Mobile Workforce State Income Tax Simplification Act of 2020 H.R. 6802/S. 3296 - Accelerate long-term Investment Growth Now Act (ALIGN Act) S. 604 - Mobile Workforce State Income Tax Simplification Act of 2019 S. 3995 - Remote and Mobile Worker Relief Act of 2020 Digital Economy Directives proposed by OECD State and local Taxation of Digital Good and Services Corporate Interest Tax Deduction Regulations Corporate Tax Rates Dividend Taxation Pension Smoothing Foreign Taxation of Digital Services State and Local Taxation of the Internet Expensing (Bonus) Depreciation State Payroll Tax Withholding Like Kind Exchanges TALF ABS program

Client expense: $2,534,000 · Firm income: Not reported

HR 748 Responding to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. S 3296 Makes permanent the expensing of certain new business equipment. Expensing allows the deduction of the full amount of an expense item in the same taxable year. Other issues: Aircraft deduction disallowance rules under IRC section 274 Tax depreciation schedules for general aviation aircraft IRS air transportation excise taxes Aircraft equipage and funding Internal Revenue Service-I.R.C.280F(d)(6)(c); Treas. Reg. 1.280F-6(d) qualified business use test Request for IRS to provide guidance regarding the tax consequences of the use of a business aircraft in charitable and humanitarian activities Request for IRS to review the treatment of TAM200945037 of leasing aircraft to 5-percent owners and related parties under the depreciation limitation in I.R.C.280F(9)(B) and provide administrative guidance Depreciation systems for business use property Temporary expensing rules under IRC 168(k) Request for IRS to provide guidance on limitation of deductions for entertainment and commuting expenses

Client expense: $330,000 · Firm income: Not reported

H.R. 1434/S.634, the Education Freedom Scholarships and Opportunity Act H.R. 2210, the Invest in America Act H.R. 748, the CARES Act Issues related to FIRPTA reform Issues related to GILTI implementation Issues related to indexing capital gains taxes to inflation Issues related to SALT deduction Issues related to tax extenders Mobile Workforce State Income Tax Simplification Act of 2020, H.R. 5674 S. 3280, the Blocking New Corporate Tax Giveaways Act S. 3296, the Accelerate Long-Term Investment Growth Now Act The PLAN Act, H.R. 4232 "H.R. 6800, The Heroes Act " Issues related to implementation of the Paycheck Protection Program "S. 3612, the Small Business Expense Protection Act " Issues related to Schedule B Issues related to alcohol excise taxes Issues related to tax filing and tax preparation deadlines Issues related to DoL information letter on Private Equity investments H.R. 6800, The Heroes Act Issues related to federal royalty rate payments Issues related to federal royalty rate payments Issues related to C-Band Helping Gig Economy Workers Act

Client expense: $80,000 · Firm income: Not reported

H.R. 1434/S.634, the Education Freedom Scholarships and Opportunity Act H.R. 2210, the Invest in America Act H.R. 748, the CARES Act Issues related to FIRPTA reform Issues related to GILTI implementation Issues related to indexing capital gains taxes to inflation Issues related to SALT deduction Issues related to tax extenders Mobile Workforce State Income Tax Simplification Act of 2020, H.R. 5674 S. 3280, the Blocking New Corporate Tax Giveaways Act S. 3296, the Accelerate Long-Term Investment Growth Now Act The PLAN Act, H.R. 4232

Client expense: $90,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Justice, Dept of (DOJ), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

H.R. 1869 / S. 803 - Restoring Investment in Improvements Act H.R. 218 / S. 215 - Death Tax Repeal Act of 2019 H.R. 1717 / S. 786 - Healthy Food Access for All Americans Act S.3296 - Accelerate Long-Term Investment Growth Now Act (ALIGN) H.R. 748 - Coronavirus Aid, Relief, and Economic Security Act (CARES) Act - Qualified Improved Property (QIP) fix

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

Government targets: Federal Motor Carrier Safety Administration, HOUSE OF REPRESENTATIVES, SENATE

HR 748 Responding to the COVID-19 (i.e., coronavirus disease 2019) outbreak and its impact on the economy, public health, state and local governments, individuals, and businesses. S 3296 Makes permanent the expensing of certain new business equipment. Expensing allows the deduction of the full amount of an expense item in the same taxable year. Other issues: Aircraft deduction disallowance rules under IRC section 274 Tax depreciation schedules for general aviation aircraft IRS air transportation excise taxes Aircraft equipage and funding Internal Revenue Service-I.R.C.280F(d)(6)(c); Treas. Reg. 1.280F-6(d) qualified business use test Request for IRS to provide guidance regarding the tax consequences of the use of a business aircraft in charitable and humanitarian activities Request for IRS to review the treatment of TAM200945037 of leasing aircraft to 5-percent owners and related parties under the depreciation limitation in I.R.C.280F(9)(B) and provide administrative guidance Depreciation systems for business use property Temporary expensing rules under IRC 168(k) Request for IRS to provide guidance on limitation of deductions for entertainment and commuting expenses

Client expense: $580,000 · Firm income: Not reported

H.R. 6396: To provide tax and regulatory relief and health care flexibility to individuals and businesses affected by the 2020 coronavirus pandemic. Full Bill Issues related to a tax credit for U.S. territories. Issues related to the internet sales tax. S. 3296: ALIGN Act. Full Bill S. 2553: ED ACCESS Act. Full Bill

Client expense: $550,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, White House Office