Remote and Mobile Worker Relief Act of 2020

H.R. 1516/S.647 (116th Cong.) - Wall Street Tax Act of 2019; United States individual and business taxation; Proposals to modify tax incentives for retirement savings and investment; Taxation of contract modifications associated with transition from LIBOR to alternative reference rates, including SOFR; Tax Incentives to preserve interest deduction related to municipal bonds; Tax Incentives to reinstate advance refunding bonds; Tax Incentives to provide for direct pay municipal bonds; Issues related to taxation of ownership of securities and securities transactions; H.R. 3967 (116th Cong.) - Municipal Bond Market Support Act of 2019; Proposals to expand Private Activity Bonds; S. 3995 (116th Cong.) - the Remote and Mobile Worker Relief Act of 2020; H.R. 2 (116th Cong.) - Moving Forward Act (municipal finance provisions); Public Law 116-136 - CARES Act (retirement and savings provisions); S. 479, the LOCAL Infrastructure Act; H.R. 2288 - To amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. 2954 - Securing a Strong Retirement Act of 2021; S. 817/H.R. 328 - Wall Street Tax Act of 2021; H.R. 3684 - INVEST in America Act; S. 1308 - American Infrastructure Bonds Act of 2021; S. 1676 - Rural Broadband Financing Flexibility Act; H.R. 2977 - Connect America Now (CAN) Act; S. 1770 - Retirement Security and Savings Act of 2021; S. 1443/H.R. 2917 - Retirement Parity for Student Loans Act of 2021.

Client expense: $1,870,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Ginnie Mae, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Natl Security Council (NSC), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 1319, American Rescue Plan Act of 2021, issues pertaining to the administration of Economic Impact Payments (EIPs), SBA's Paycheck Protection Program (PPP) loan for small businesses, and unemployment insurance. H.R. 2297/S. 1194 (116th CONGRESS), Tax Filing Simplification Act of 2019, issues pertaining to education on the Government Populated Return. S. 3995 (116th CONGRESS), Remote and Mobile Worker Relief Act of 2020, issues pertaining to remote and mobile workers and the emergency, temporary COVID provision in this legislation to maintain the pre-COVID status quo for state income tax. Health, Economic Assistance, Liability Protection and Schools (HEALS) Act (116th CONGRESS) Implementation of the Coronavirus Aid, Relief, and Economic Security Act or the CARES Act (P.L. 116-136), including provisions pertaining to the administration of Economic Impact Payments (EIPs) and SBA's Paycheck Protection Program (PPP) loan for small businesses. Issues pertaining to moving the tax filing season beyond April 15.

Client expense: $670,000 · Firm income: Not reported

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

H.R. 1516/S.647 (116th Cong.) - Wall Street Tax Act of 2019; United States individual and business taxation; Proposals to modify tax incentives for retirement savings and investment; Taxation of contract modifications associated with transition from LIBOR to alternative reference rates, including SOFR; Tax Incentives to preserve interest deduction related to municipal bonds; Tax Incentives to reinstate advance refunding bonds; Tax Incentives to provide for direct pay municipal bonds; Issues related to taxation of ownership of securities and securities transactions; H.R. 3967 (116th Cong.) - Municipal Bond Market Support Act of 2019; Proposals to expand Private Activity Bonds; S. 3995 (116th Cong.) - the Remote and Mobile Worker Relief Act of 2020; H.R. 2 (116th Cong.) - Moving Forward Act (municipal finance provisions); S. 4203 (116th Cong.) - American Infrastructure Bond Act; Public Law 116-136 - CARES Act (retirement and savings provisions); S. 2866 (116th Cong.) - Rural Broadband Financing Flexibility Act; H.R. 7857 (116th Cong.) - Connect America Now (CAN) Act; S. 479, the LOCAL Infrastructure Act; H.R. 2288, a bill to amend the Internal Revenue Code of 1986 to reinstate advance refunding bonds; H.R. ______ - Investing in Our Communities Act; S. ______ - Retirement Security and Savings Act; H.R. ___/S.___ - Retirement Parity for Student Loans Act; H.R. ______ - Securing a Strong Retirement Act.

Client expense: $1,750,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Ginnie Mae, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Natl Security Council (NSC), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

The Mobile Workforce State Income Tax Simplification Act, and the Remote and Mobile Worker Relief Act (Pending introduction in 117th). H.R. 5674, S. 604 (116th) Mobile Workforce State Income Tax Simplification Act, S. 3995, S. 4318 (Sec. 403) (116th). The legislation sets a uniform national 30-day threshold for personal income tax filing obligation for traveling employees crossing state borders to work in a non-resident state for short durations, and corresponding withholding obligations for their employers. The Remote and Mobile Worker Relief Act additionally clarifies nexus and safeguards against sourcing and apportionment issues due to remote workers working out-of-state due to the pandemic, and provides employers with the option to either continue withholding at the employees usual place of work or switch withholding to where the employee is working remotely because of the pandemic.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S 4822/HR 4549 - American Innovation and Jobs Act including issues related to the immediate expensing of qualified research and development expenditure and to reverse a change in the 2017 tax law to ensure that companies can continue to fully deduct R&D investments each year; S 604/HR 5674 - Mobile Workforce State Income Tax Simplification Act of 2020 to limit the authority of states to tax employees for employment duties performed in other states; S 3995 - Remote and Mobile Worker Relief Act of 2020 to ensure that remote workers and medical professionals who supported hard hit areas during COVID-19 do not face unexpected state income tax bills; HR 748 - CARES Act including issues related to tax and R&D credit; HR 6800 - HEROES Act including issues related to tax and R&D credit; HR 4035 - Pension and Budget Integrity Act of 2019 including issues related to pension funding relief and Pension Benefit Guaranty Corporation (PBGC) premium eduction; S 684 - Middle Class Health Benefits Tax Repeal Act of 2019 including issues related to healthcare, paid leave, prescription drug costs, surprise billing, Health Savings Account (HSA) modernization; Discussions on corporate tax rate

Client expense: $2,880,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax reform (Tax Cuts and Jobs Act of the 115th Congress): issues related to net operating loss (NOL) carryback provision impact on financial services industry; S. 3995 Remote and Mobile Worker Relief Act; S.604/H.R. 5674 Mobile Workforce State Income Tax Simplification Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax Cuts and Jobs Act (entire bill) - P.L. 115-97 - Re: implementation; S.3995 - Remote and Mobile Worker Relief Act of 2020 (entire bill); General discussions related to global efforts regarding digital services tax and minimum corporate tax (no bill number); HR 5240 - To amend the Internal Revenue Code of 1986 to make the look-thru rule for related controlled foreign corporations permanent. (entire bill); HR 133 Consolidated Appropriations Act, 2021, Division EE, Sec.111 - look-thru rule for related foreign corporations.

Client expense: $570,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), HOUSE OF REPRESENTATIVES, Office of the Vice President of the United States, SENATE, U.S. Trade Representative (USTR)

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 of Spectrum; 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.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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 5377- Restoring Tax Fairness Act HR 4857, S 309- For the 99.8% Act Repeal certain tax breaks in TCJA Act Oppose payroll tax cut or capital gains tax cut S 3640, HR 6579- Repeal corporate tax cuts in CARES Act HR 1711, S 780- No Tax Breaks for Outsourcing Act HR 1516, S 647- Wall Street Tax Act S 2809, HR 5043- Millionaires Surtax Act Fairness in Taxation Act Individual taxes, including surtax, higher rates, Mark to Market Individuals' itemized tax deductions for certain state and local taxes (e.g. SALT)(end/raise cap) S 1138, HR 3157- Earned income tax credit and child tax credits (expand/increase) Corporate taxes, including higher rates, close loopholes, raise revenue HR 2103, S 1026- Tax Fairness for Workers Act HR 6579- CARES Windfall for the Wealthiest Repeal Act HR 7734- Building Businesses Back Act of 2020 General Business Tax Credits refundability Businesses' PPP Double Dip Refundable business tax credits, including refundable NOL Carryover; Advance Refundable credit for R&D COVID-19 related expenditures S 604- Mobile Workforce State Income Tax Simplification Act of 2019 S 3995- Remove and Mobile Worker Relief Act of 2020 COVID Relief Package- State and Local Income Taxes of Remote Workers FY 2021-2022 appropriations for IRS tax enforcement and staffing

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Health savings accounts; student debt repayment tax incentives; tax treatment of financial products; retirement savings tax incentives; S.3995-Remote and Mobile Worker Relief Act of 2020 (remote worker state payroll tax withholding); S.2999-Primary Care Enhancement Act (HSA eligibility)

Client expense: $410,000 · Firm income: Not reported

Government targets: Commodity Futures Trading Commission (CFTC), Federal Reserve System, HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Economic Council (NEC), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Tax Cuts and Jobs Act (entire bill) - P.L. 115-97 - Re: implementation; S.3995 - Remote and Mobile Worker Relief Act of 2020 (entire bill); General discussions related to global efforts regarding digital services tax and minimum corporate tax (no bill number); HR 5240 - To amend the Internal Revenue Code of 1986 to make the look-thru rule for related controlled foreign corporations permanent. (entire bill); HR 133 Consolidated Appropriations Act, 2021, Division EE, Sec.111 - look-thru rule for related foreign corporations.

Client expense: $450,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), HOUSE OF REPRESENTATIVES, Office of the Vice President of the United States, SENATE, U.S. Trade Representative (USTR)

H.R. 748/S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act, including Issues pertaining to the administration of Economic Impact Payments (EIPs) and SBA's Paycheck Protection Program (PPP) loan for small businesses H.R. 3330, Taxpayer Protection and Preparer Proficiency Act of 2019, including provisions regarding 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, including provisions regarding the PTIN revocation process H.R. 7010, Paycheck Protection Program Flexibility Act of 2020, including issues pertaining to the modified Paycheck Protection Program loan for small businesses S. 1194, Tax Filing Simplification Act of 2019, including issues relating to education on the government populated return S. 3995, Remote and Mobile Worker Relief Act of 2020, including issues pertaining to remote and mobile workers and the emergency, temporary COVID provision in this legislation to maintain the pre-COVID status quo for state income tax. Draft legislation To amend the Internal Revenue Code of 1986 to clarify the authority of the Secretary of the Treasury to issue identifying numbers of tax return preparers including issues relating to reforming the PTIN issuance process

Client expense: $780,000 · Firm income: Not reported

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

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/S. 604 - 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. 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: $2,410,000 · Firm income: Not reported

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

Taxation of digital goods, generally; S. 765/H.R. 1725, Digital Goods and Services Tax Fairness Act of 2019; Corporate taxation, generally; S. 3548, the Coronavirus Aid, Relief, and Economic Security (CARES) Act - provisions related to corporate tax; S.3995, Remote and Mobile Worker Relief Act

Client expense: $830,000 · Firm income: Not reported

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; 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

Section 7216 Regulations, S.3995 - Remote and Mobile Worker Relief Act of 2020, Administration of Economic Impact Payments

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (, unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3;

Client expense: Not reported · Firm income: $40,000

Government targets: Executive Office of the President (EOP), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Small Business Administration (SBA), Treasury, Dept of

H.R. 216/S. 1149, Main Street Tax Certainty Act H.R. 218/S. 215, Death Tax Repeal Act H.R. 748 Coronavirus Aid, Relief, and Economic Security (CARES) Act H.R. 1516/S. 647, Wall Street Tax Act of 2019 H.R. 1725/S. 765, Digital Goods and Services Tax Fairness Act of 2019 H.R. 2213/S. 978, Work Opportunity Tax Credit and Jobs Act H.R. 2923/S. 1587, Inclusive Prosperity Act of 2019 H.R. 5674/S. 604, Mobile Workforce State Income Tax Simplification Act of 2019 H.R. 6201, Families First Coronavirus Response Act H.R. 6379, Take Responsibility for Workers and Families Act, including provisions relating to country-by-country tax reporting H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act S. 3612, Small Business Expense Protection Act of 2020 S. 3995, Remote and Mobile Worker Relief Act of 2020, including provisions relating to state tax certainty for employers and employees S. 4318, American Workers, Families, and Employers Assistance Act, including provisions relating to state tax certainty for employers and employees Proposed rule regarding guidance under Section 958 (rules for determining stock ownership) and section 951A (global intangible low taxed income) (84 Fed. Reg. 29,114-29,133, June 21, 2019) Regulations on guidance related to section 951A (global intangible low-taxed income) and certain guidance related to foreign tax credits (84 Fed. Reg. 29,288-29,370, June 21, 2019) Proposed rule and guidance related to the allocation and apportionment of deductions and foreign taxes, financial services income, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), and consolidated groups (84 Fed. Reg. 69,124-69,180, December 17, 2019) Proposed additional rules regarding base erosion and anti-abuse tax (84 Fed. Reg. 67,046-67,058, December 6, 2019) Proposed rule regarding certain employee remuneration in excess of $1,000,000 under Internal Revenue Code Section 162(m) (84 Fed. Reg. 70,356-70,391, December 20, 2019) Proposed rule regarding guidance involving hybrid arrangements and the allocation of deductions attributable to certain disqualified payments under section 951A (Global Intangible Low-Taxed Income) (85 Fed. Reg. 19,858-19,873, April 8, 2020) Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (PL 115-97), including implementation of, and follow up such as making individual rates and pass-through rates permanent; Internal Revenue Code section 965/tax overpayments, and changes made to section 965 by the Tax Cuts and Jobs Act; Foreign tax carryforwards transition; pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; 199A tax deduction; Internal Revenue Service controlled foreign corporation (CFC) look thru rule; pending bilateral tax treaties before the U.S. Senate; potential for additional bilateral tax treaties; potential repeal of the State and Local Tax (SALT) cap; corporate tax filing deadline; Canadian digital services tax; global anti-base erosion proposal (GloBE) under pillar two; comments on Employee Retention Tax Credit (ERTC) Frequently Asked Questions (FAQs); FAQ65; comments on Employee Retention Tax Credit (ERTC) Frequently Asked Questions (FAQs): Additional Modifications; comments on the CARES Act (P.L. 116-136) implementation letter to IRS and Treasury; general business tax credits; digital services taxes, GILTI high tax exception, Cornyn loan expense deductibility bill; tax extenders; Comments on Implementation of the Executive Order Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster; Comments on N-2020-47: Public Recommendations Invited on Items to be Included on the 2020-2021 Priority Guidance Plan; Comments on REG-104591-18: Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Information with Respect to Certain Fines, Penalties, and Other Amounts; Comments on REG-112339-19 Credit for carbon oxide sequestration under section 45Q; Comments on REG-119307-19: Qualified Transportation Fringe, Transportation and Commuting Expenses under Section 274; Comments on REG-127732-19 Guidance under Section 954(b)(4) Regarding Income Subject to a High Rate of Foreign Tax; Comments on Section 461(l) - Limitations on Excess Business Losses of Noncorporate Taxpayers; Issues related to Tax Free Paycheck Protection Program Loan Forgiveness; Comments on Section 301 Investigation of Digital Service Taxes; Comments on Revenue Procedure 94-69; Paycheck Protection Program (PPP) Deductibility; Comments on REG-107911-18: Rules Concerning the Limitation on the Deduction for Business Interest Expense; Comments on REG-110059-20: Ownership Attribution Under Section 958 for Purposes of Sections 367(a) and 954(c)(6); Revenue Procedure 94-69, disclose changes in tax positions after the opening of an examination, legislative technical corrections and regulatory comments; REG-107911-18, Various Business Interest Expense Deduction Limitation Issues, legislative technical corrections and regulatory comments; REG-110059-20: Ownership Attribution Under Section 958 for Purposes of Sections 367(a) and 954(c)(6), legislative technical corrections and regulatory comments; OECD Public Consultation Document on the Reports on the Pillar One and Pillar Two Blueprints, comments and responses to questions presented by the OECD Public Consultation document; Extension of Expiring Tax Provisions and tax comments for general tax relief; general COVID relief legislation: tax comments for general COVID-19 relief

Client expense: $22,290,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Citizenship & Immigration Services (BCIS), Bureau of Industry and Security (BIS), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Reserve System, Federal Trade Commission (FTC), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

H.R. 4549, American Innovation and Competitiveness Act of 2019. S. 4822, American Innovation and Jobs Act. S. 3995, The Remote and Mobile Worker Relief Act of 2020. S. 4318, American Workers, Families, and Employers Assistance Act 2020. H.R. 133, Consolidated Appropriations Act 2021. Transfer pricing, treaty, foreign tax credit, stranded worker, international tax, and foreign tax issues.

Client expense: $2,190,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Institute of Standards & Technology (NIST), Natl Science Foundation (NSF), Natl Security Council (NSC), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Patent & Trademark Office (PTO), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Postal Service (USPS), U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), White House Office

Insurance Coverage Issues, S.3995 - Remote and Mobile Worker Relief Act of 2020

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

Government targets: SENATE

H.R. 284 Mortgage Insurance Premiums Deduction H.R. 1120 Marijuana Products Taxation and Regulation H.R. 4598 Foreign Insurance Companies Interests Exemption S. 604 State Income Tax Limitation H.R. 5494 Catastrophe Loss Gross Income Exclusion S. 3995 Tax Authority Limitation

Client expense: $1,200,000 · Firm income: Not reported

Government targets: Centers For Disease Control & Prevention (CDC), Centers For Medicare and Medicaid Services (CMS), Commerce, Dept of (DOC), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Natl Economic Council (NEC), Natl Labor Relations Board (NLRB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

Support NOL carryback; Employee Retention Credit (HR 6776); Healthy Workplace Tax Credit (HR 7615, S 4214); Safe Reopening Tax Credit (HR 7222); Remote and Mobile Workforce Relief Act (S 3995); Support Work Opportunity Tax Credit (WOTC) S 978, HR 2213, S 4318; Efairness legislation - oppose HR5515, S 128; ; oppose imposition of Value Added Tax, National Retail Sales Tax (H.R. 25); Oppose corporate tax rate increases.

Client expense: $1,660,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Consumer Financial Protection Bureau (CFPB), Consumer Product Safety Commission (CPSC), Equal Employment Opportunity Commission (EEOC), Federal Maritime Commission, Federal Motor Carrier Safety Administration, Federal Reserve System, Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Maritime Administration (MARAD), Natl Economic Council (NEC), Natl Labor Relations Board (NLRB), Patent & Trademark Office (PTO), SENATE, Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Customs & Border Protection, U.S. Postal Service (USPS), U.S. Trade Representative (USTR), White House Office

Implementation and rulemaking processes related to provisions of the Tax Cuts and Jobs Act - business interest and international taxation aspects, including foreign earnings taxation and repatriation, deductibility of interest expenses General discussions regarding excepting income earned in highly-taxed foreign countries from the taxation of global intangible low-taxed income House Ways & Means Committee energy tax package General discussions regarding tax credits for electric vehicles, energy storage, natural gas vehicles, natural gas fueling infrastructure, and natural gas used as a vehicle fuel General discussions regarding the tax treatment of renewable natural gas, hydrogen, and other alternative fuels General discussions regarding carryover period for charitable expense deductions General discussions regarding proposals to extend or make permanent the Subpart F look-through rule for controlled foreign corporations S. 604 - Mobile Workforce State Income Tax Simplification Act - provisions related to taxation of out-of-state workers S. 3995 - Remote and Mobile Workforce Relief Act - provisions related to taxation of out-of-state workers General discussions regarding provisions of draft legislation related to taxation of out-of-state workers

Client expense: $500,000 · Firm income: Not reported

Government targets: Bureau of Indian Affairs (BIA), Commerce, Dept of (DOC), Energy, Dept of, Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Internal Revenue Service (IRS), Natl Economic Council (NEC), Office of Management & Budget (OMB), Pipeline & Hazardous Materials Safety Administration, SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Implementing U.S. Treasury regulations and follow on issues from H.R. 1, Tax Cuts and Jobs Act, TCJA, Public Law No. 115-97; Proposed regulations on "Classification of Cloud Transactions and Transactions Involving Digital Content" new section 1.861-19 and amendment of -18 regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD "Addressing Tax Challenges of Digitalization" and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. S. 604 "Mobile Workforce State Income Tax Simplification Act", and companion bill H.R. 4796; S. 3995 "The Remote and Mobile Workers Relief Act." Bilateral income tax treaties pending before the Senate, especially Chile; support treaties under negotiation. H.R. 5240 "To amend the Internal Revenue Code of 1986 to make the look-thru for related controlled foreign corporations permanent"; work on Senate companion bill.

Client expense: $1,050,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Education, Dept of, Energy, Dept of, HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

S 4822/HR 4549 - American Innovation and Jobs Act including issues related to the immediate expensing of qualified research and development expenditure and to reverse a change in the 2017 tax law to ensure that companies can continue to fully deduct R&D investments each year; S 604/HR 5674 - Mobile Workforce State Income Tax Simplification Act of 2020 to limit the authority of states to tax employees for employment duties performed in other states; S 3995 - Remote and Mobile Worker Relief Act of 2020 to ensure that remote workers and medical professionals who supported hard hit areas during COVID-19 do not face unexpected state income tax bills; HR 748 - CARES Act including issues related to tax and R&D credit; HR 6800 - HEROES Act including issues related to tax and R&D credit; HR 4035 - Pension and Budget Integrity Act of 2019 including issues related to pension funding relief and Pension Benefit Guaranty Corporation (PBGC) premium eduction; S 684 - Middle Class Health Benefits Tax Repeal Act of 2019 including issues related to healthcare, paid leave, prescription drug costs, surprise billing, Health Savings Account (HSA) modernization; Discussions on corporate tax rate

Client expense: $2,860,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Air Force, Dept of, Army, Dept of (Other), Commerce, Dept of (DOC), Defense, Dept of (DOD), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Navy, Dept of, SENATE, State, Dept of (DOS)

Tax reform (Tax Cuts and Jobs Act of the 115th Congress): issues related to net operating loss (NOL) carryback provision impact on financial services industry; S. 3995 Remote and Mobile Worker Relief Act; S.604/H.R. 5674 Mobile Workforce State Income Tax Simplification Act.

Client expense: $210,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General tax issues; S. 3995, The Remote and Mobile Worker Relief Act of 2020; H.R. 1725/S. 765, Digital Goods and Services Tax Fairness Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1516 (Wall Street Tax Act of 2019); H.R. 2772 (Investing in Our Communities Act); S. 647 (Wall Street Tax Act of 2019); United States individual and business taxation; Proposals to modify tax incentives for retirement savings and investment; Taxation of contract modifications associated with transition from LIBOR to alternative reference rates, including SOFR; Tax Incentives to preserve interest deduction related to municipal bonds; Tax Incentives to reinstate advance refunding bonds; Tax Incentives to provide for direct pay municipal bonds; Issues related to taxation of ownership of securities and securities transactions; H.R. 3967 - Municipal Bond Market Support Act of 2019; Proposals to expand Private Activity Bonds; S. 3995, the Remote and Mobile Worker Relief Act of 2020; H.R. 2, Moving Forward Act (municipal finance provisions); S. 4203, American Infrastructure Bond Act; Public Law 116-136, CARES Act (retirement and savings provisions); S. 1431, Retirement Security and Savings Act of 2019 (various retirement and savings provisions); S. 1428/H.R. 6276, Retirement Parity for Student Loans Act; S. 2866 - Rural Broadband Financing Flexibility Act; H.R. 7857 - Connect America Now (CAN) Act; S. 4129 - LOCAL Infrastructure Act; H.R. 8696 - Securing a Strong Retirement Act of 2020.

Client expense: $2,250,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Executive Office of the President (EOP), Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency (FHFA), Federal Reserve System, Ginnie Mae, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Credit Union Administration (NCUA), Natl Economic Council (NEC), Natl Security Council (NSC), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR)

Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995.

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

Government targets: SENATE

General discussions related to infrastructure and energy policies affecting electric and natural gas services. S.3995, Remote and Mobile Worker Relief Act of 2020. Issues related to disconnection and debt collection; H.R.6800, The Heroes Act, S.178, Delivering Immediate Relief to America's Families, Schools and Small Businesses Act, and H.R.133, Making consolidated appropriations for the fiscal year ending September 30, 2021, providing coronavirus emergency response and relief, and for other purposes (P.L.116-260).

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

H.R. 216/S. 1149, Main Street Tax Certainty Act H.R. 218/S. 215, Death Tax Repeal Act H.R. 748/S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act H.R. 1516/S. 647, Wall Street Tax Act of 2019 H.R. 1725/S. 765, Digital Goods and Services Tax Fairness Act of 2019 H.R. 2213/S. 978, Work Opportunity Tax Credit and Jobs Act H.R. 2923/S. 1587, Inclusive Prosperity Act of 2019 H.R. 4805, Access Business Credit Act of 2019 H.R. 5674/S. 604, Mobile Workforce State Income Tax Simplification Act of 2019 H.R. 6201, Families First Coronavirus Response Act H.R. 6379, Take Responsibility for Workers and Families Act, including provisions relating to country-by-country tax reporting H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act S. 3612, Small Business Expense Protection Act of 2020 S. 3995, Remote and Mobile Worker Relief Act of 2020, including provisions relating to state tax certainty for employers and employees S. 4318, American Workers, Families, and Employers Assistance Act, including provisions relating to state tax certainty for employers and employees Proposed rule regarding guidance under Section 958 (rules for determining stock ownership) and section 951A (global intangible low taxed income) (84 Fed. Reg. 29,114-29,133, June 21, 2019) Regulations on guidance related to section 951A (global intangible low-taxed income) and certain guidance related to foreign tax credits (84 Fed. Reg. 29,288-29,370, June 21, 2019) Proposed rule and guidance related to the allocation and apportionment of deductions and foreign taxes, financial services income, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), and consolidated groups (84 Fed. Reg. 69,124-69,180, December 17, 2019) Proposed additional rules regarding base erosion and anti-abuse tax (84 Fed. Reg. 67,046-67,058, December 6, 2019) Proposed rule regarding certain employee remuneration in excess of $1,000,000 under Internal Revenue Code Section 162(m) (84 Fed. Reg. 70,356-70,391, December 20, 2019 Proposed rule regarding guidance involving hybrid arrangements and the allocation of deductions attributable to certain disqualified payments under section 951A (Global Intangible Low-Taxed Income) (85 Fed. Reg. 19,858-19,873, April 8, 2020) Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (PL 115-97), including implementation of, and follow up such as making individual rates and pass-through rates permanent; Internal Revenue Code section 965/tax overpayments, and changes made to section 965 by the Tax Cuts and Jobs Act; Foreign tax carryforwards transition; pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; 199A tax deduction; Internal Revenue Service controlled foreign corporation (CFC) look thru rule; pending bilateral tax treaties before the U.S. Senate; potential for additional bilateral tax treaties; potential repeal of the State and Local Tax (SALT) cap; corporate tax filing deadline; Canadian digital services tax; global anti-base erosion proposal (GloBE) under pillar two; comments on Employee Retention Tax Credit (ERTC) Frequently Asked Questions (FAQs): FAQ65; comments on Employee Retention Tax Credit (ERTC) Frequently Asked Questions (FAQs): Additional Modifications; comments on the CARES Act (P.L. 116-136) implementation letter to IRS and Treasury; general business tax credits; digital services taxes, GILTI high tax exception, Cornyn loan expense deductibility bill; tax extenders; Comments on Implementation of the Executive Order Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster; Comments on REG-104591-18: Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Information with Respect to Certain Fines, Penalties, and Other Amounts; Comments on Section 461(l) - Limitations on Excess Business Losses of Noncorporate Taxpayers Issues related to Tax Free Paycheck Protection Program Loan Forgiveness; Comments on Section 301 Investigation of Digital Service Taxes; Public Comment to IRS on Notice 2020-42, Remote Notarization; REG-104591-18: Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Information with Respect to Certain Fines, Penalties, and Other Amounts, legislative technical corrections and regulatory comments; N-2020-47: Public Recommendations Invited on Items to be Included on the 2020-2021 Priority Guidance Plan, legislative technical corrections and regulatory comments; REG-112339-19: Credit for Carbon Oxide Sequestration Under Section 45Q, legislative technical corrections and regulatory comments; REG-119307-19: Qualified Transportation Fringe, Transportation and Commuting Expenses under Section 274, legislative technical corrections and regulatory comments; REG-127732-19: Guidance under Section 954(b)(4) Regarding Income Subject to a High Rate of Foreign Tax, legislative technical corrections and regulatory comments; Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, comments and request for additional guidance from the Department of Treasury; general COVID relief legislation: tax comments for general COVID-19 relief

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

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Citizenship & Immigration Services (BCIS), Bureau of Industry and Security (BIS), Bureau of Reclamation, Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Motor Carrier Safety Administration, Federal Reserve System, Federal Trade Commission (FTC), General Services Administration (GSA), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

Client expense: $1,160,000 · Firm income: Not reported

Government targets: Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Labor, Dept of (DOL), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), SENATE, Small Business Administration (SBA), Treasury, Dept of

Mobile Workforce State Income Tax Simplification Act, S. 604 / H.R. 4796: This bill proposes a uniform minimum 30-day threshold before wages or other remuneration earned by an employee who performs employment duties in more than one state can be subject to income tax in any state other than the state of the employee's residence. The bill exempts employers from state income tax withholding and information reporting requirements for employees not subject to income tax in the state under this bill. Remote and Mobile Worker Relief Act of 2020, S. 3995: This bill includes provisions of the Mobile Workforce State Income Tax Simplification Act and also has provisions to provide relief to workers working remotely in states that are not their usual place of business due to COVID-19 pandemic, and to their employers, clarifying nexus rules, and withholding and filing obligations. Sec. 403 of S. 4318, the American Workers, Families and Employers Assistance Act, which contains the provisions of S. 3995.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 604 Mobile Workforce State Tax Simplification Act of 2019. S. 3995 The Remote and Mobile Worker Act of 2020. H.R. 4796 Mobile Workforce State Tax Simplification Act of 2019. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 604 Mobile Workforce State Tax Simplification Act of 2019. S. 3995 The Remote and Mobile Worker Act of 2020. H.R. 4796 Mobile Workforce State Tax Simplification Act of 2019. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 604 Mobile Workforce State Tax Simplification Act of 2019. S. 3995 The Remote and Mobile Worker Act of 2020. H.R. 4796 Mobile Workforce State Tax Simplification Act of 2019. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 604 Mobile Workforce State Tax Simplification Act of 2019. S. 3995 The Remote and Mobile Worker Act of 2020. H.R. 4796 Mobile Workforce State Tax Simplification Act of 2019. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 604 Mobile Workforce State Tax Simplification Act of 2019. S. 3995 The Remote and Mobile Worker Act of 2020. H.R. 4796 Mobile Workforce State Tax Simplification Act of 2019. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 604 Mobile Workforce State Tax Simplification Act of 2019. S. 3995 The Remote and Mobile Worker Act of 2020. H.R. 4796 Mobile Workforce State Tax Simplification Act of 2019. H.R. 5674 Mobile Workforce State Income Tax Simplification Act of 2020.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 216/S. 1149, Main Street Tax Certainty Act H.R. 218/S. 215, Death Tax Repeal Act H.R. 748/S. 3548, Coronavirus Aid, Relief, and Economic Security (CARES) Act H.R. 1516/S. 647, Wall Street Tax Act of 2019 H.R. 1725/S. 765, Digital Goods and Services Tax Fairness Act of 2019 H.R. 2213/S. 978, Work Opportunity Tax Credit and Jobs Act H.R. 2923/S. 1587, Inclusive Prosperity Act of 2019 H.R. 4805, Access Business Credit Act of 2019 H.R. 5674/S. 604, Mobile Workforce State Income Tax Simplification Act of 2019 H.R. 6201, Families First Coronavirus Response Act H.R. 6379, Take Responsibility for Workers and Families Act, including provisions relating to country-by-country tax reporting H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act S. 3612, Small Business Expense Protection Act of 2020 S. 3995, Remote and Mobile Worker Relief Act of 2020, including provisions relating to state tax certainty for employers and employees S. 4318, American Workers, Families, and Employers Assistance Act, including provisions relating to state tax certainty for employers and employees Proposed rule regarding guidance under Section 958 (rules for determining stock ownership) and section 951A (global intangible low taxed income) (84 Fed. Reg. 29,114-29,133, June 21, 2019) Regulations on guidance related to section 951A (global intangible low-taxed income) and certain guidance related to foreign tax credits (84 Fed. Reg. 29,288-29,370, June 21, 2019) Proposed rule and guidance related to the allocation and apportionment of deductions and foreign taxes, financial services income, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), and consolidated groups (84 Fed. Reg. 69,124-69,180, December 17, 2019) Proposed additional rules regarding base erosion and anti-abuse tax (84 Fed. Reg. 67,046-67,058, December 6, 2019) Proposed rule regarding certain employee remuneration in excess of $1,000,000 under Internal Revenue Code Section 162(m) (84 Fed. Reg. 70,356-70,391, December 20, 2019 Proposed rule regarding guidance involving hybrid arrangements and the allocation of deductions attributable to certain disqualified payments under section 951A (Global Intangible Low-Taxed Income) (85 Fed. Reg. 19,858-19,873, April 8, 2020) Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (PL 115-97), including implementation of, and follow up such as making individual rates and pass-through rates permanent; Internal Revenue Code section 965/tax overpayments, and changes made to section 965 by the Tax Cuts and Jobs Act; Foreign tax carryforwards transition; pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; 199A tax deduction; Internal Revenue Service controlled foreign corporation (CFC) look thru rule; pending bilateral tax treaties before the U.S. Senate; potential for additional bilateral tax treaties; potential repeal of the State and Local Tax (SALT) cap; corporate tax filing deadline; Canadian digital services tax; global anti-base erosion proposal (GloBE) under pillar two; comments on Employee Retention Tax Credit (ERTC) Frequently Asked Questions (FAQs): FAQ65; comments on Employee Retention Tax Credit (ERTC) Frequently Asked Questions (FAQs): Additional Modifications; comments on the CARES Act (P.L. 116-136) implementation letter to IRS and Treasury; general business tax credits; digital services taxes, GILTI high tax exception, Cornyn loan expense deductibility bill; tax extenders; Comments on Implementation of the Executive Order Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster; Comments on REG-104591-18: Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Information with Respect to Certain Fines, Penalties, and Other Amounts; Comments on Section 461(l) - Limitations on Excess Business Losses of Noncorporate Taxpayers Issues related to Tax Free Paycheck Protection Program Loan Forgiveness; Comments on Section 301 Investigation of Digital Service Taxes; Public Comment to IRS on Notice 2020-42, Remote Notarization; REG-104591-18: Denial of Deduction for Certain Fines, Penalties, and Other Amounts; Information with Respect to Certain Fines, Penalties, and Other Amounts, legislative technical corrections and regulatory comments; N-2020-47: Public Recommendations Invited on Items to be Included on the 2020-2021 Priority Guidance Plan, legislative technical corrections and regulatory comments; REG-112339-19: Credit for Carbon Oxide Sequestration Under Section 45Q, legislative technical corrections and regulatory comments; REG-119307-19: Qualified Transportation Fringe, Transportation and Commuting Expenses under Section 274, legislative technical corrections and regulatory comments; REG-127732-19: Guidance under Section 954(b)(4) Regarding Income Subject to a High Rate of Foreign Tax, legislative technical corrections and regulatory comments; Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, comments and request for additional guidance from the Department of Treasury; general COVID relief legislation: tax comments for general COVID-19 relief

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

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Citizenship & Immigration Services (BCIS), Bureau of Industry and Security (BIS), Bureau of Reclamation, Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Consumer Financial Protection Bureau (CFPB), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Executive Office of the President (EOP), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Motor Carrier Safety Administration, Federal Reserve System, Federal Trade Commission (FTC), General Services Administration (GSA), Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Interior, Dept of (DOI), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), Office of the Comptroller of the Currency (OCC), Patent & Trademark Office (PTO), Pension Benefit Guaranty Corporation (PBGC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation Security Administration (TSA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Copyright Office, U.S. Customs & Border Protection, U.S. Trade Representative (USTR), White House Office

Implementation and rulemaking processes related to provisions of the Tax Cuts and Jobs Act - business interest and international taxation aspects, including foreign earnings taxation and repatriation, deductibility of interest expenses General discussions regarding excepting income earned in highly-taxed foreign countries from the taxation of global intangible low-taxed income House Ways & Means Committee energy tax package General discussions regarding tax credits for electric vehicles, energy storage, natural gas vehicles, natural gas fueling infrastructure, and natural gas used as a vehicle fuel General discussions regarding the tax treatment of renewable natural gas, hydrogen, and other alternative fuels General discussions regarding carryover period for charitable expense deductions General discussions regarding proposals to extend or make permanent the Subpart F look-through rule for controlled foreign corporations S. 604 - Mobile Workforce State Income Tax Simplification Act - provisions related to taxation of out-of-state workers S. 3995 - Remote and Mobile Workforce Relief Act - provisions related to taxation of out-of-state workers General discussions regarding provisions of draft legislation related to taxation of out-of-state workers

Client expense: $660,000 · Firm income: Not reported

Government targets: Bureau of Indian Affairs (BIA), Commerce, Dept of (DOC), Energy, Dept of, Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Internal Revenue Service (IRS), Natl Economic Council (NEC), Office of Management & Budget (OMB), Pipeline & Hazardous Materials Safety Administration, SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)

Tax Cuts and Jobs Act (entire bill) - P.L. 115-97 - Re: implementation. S.3995 - Remote and Mobile Worker Relief Act of 2020 (entire bill). General discussions related to global efforts regarding digital services tax and minimum corporate tax (no bill number).

Client expense: $470,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Executive Office of the President (EOP), Export-Import Bank of the United States (EXIM Bank), HOUSE OF REPRESENTATIVES, Office of the Vice President of the United States, SENATE, U.S. Trade Representative (USTR), White House Office