Remote and Mobile Worker Relief Act of 2021

H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,540,000 · Firm income: Not reported

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

H.R. 5376, Inflation Reduction Act of 2022. H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,300,000 · Firm income: Not reported

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

H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. H.R. 5376, Build Back Better Act, to provide reconciliation pursuant to title II of S. Con. Res. 14. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,410,000 · Firm income: Not reported

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

S.1274 - Remote and Mobile Worker Relief Act of 2021 HR 5376 - Build Back Better Act HR 2558 & S.1166 - ALIGN Act Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) OECD Tax Proposals Expensing of Research and Experimentation Costs HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 Corporate Tax Rate Dividend Taxation Expensing [Bonus] Depreciation Like Kind Exchanges of Spectrum Book Minimum Tax Treatment on Spectrum Book Minimum Tax Treatment of Pensions Digital Economy Directives proposed by the OECD State and local Taxation of Digital Goods and Services State and local Taxation of the Internet Mobile Workforce State Income Legislation Remote Worker State Payroll Withholding Tax Legislation Foreign Taxation of Digital Service

Client expense: $2,997,000 · Firm income: Not reported

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

S.1274 - Remote and Mobile Worker Relief Act of 2021 HR 5376 - Build Back Better Act HR 2558 & S.1166 - ALIGN Act Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) OECD Tax Proposals Expensing of Research and Experimentation Costs HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 Corporate Tax Rate Dividend Taxation Expensing [Bonus] Depreciation Like Kind Exchanges of Spectrum Book Minimum Tax Treatment on Spectrum Book Minimum Tax Treatment of Pensions Digital Economy Directives proposed by the OECD State and local Taxation of Digital Goods and Services State and local Taxation of the Internet Mobile Workforce State Income Legislation Remote Worker State Payroll Withholding Tax Legislation Foreign Taxation of Digital Service

Client expense: $2,970,000 · Firm income: Not reported

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

General lobbying on the following issues: corporate income tax rates; dividend taxation; expensing (bonus) depreciation; like-kind spectrum exchanges; book minimum tax treatment of pensions, depreciation, and spectrum; digital economy directives proposed by the OECD; state and local taxation of digital goods and services; state and local taxation of the Internet; mobile workforce state income taxation; remote worker state payroll withholding taxation; foreign taxation of digital services; international tax changes to GILTI; OECD tax proposals; interest tax deduction limitation under sec.163 of the I.R.C.; extending expiring tax benefits; and expensing and research, development and experimentation costs. Lobbying on the following specific legislation: Fair Access to Interstate Remedies (Draft)-A measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court; not yet introduced); H.R. 1304/S. 749 - American Innovation and R&D Competitiveness Act of 2021; H.R. 2558/S. 1166 - Accelerate Long-term Investment Now Act (Align Act); H.R. 4346 - Supreme Court Security Funding Act of 2022, AKA CHIPS Act of 2022; H.R. 5371/S.1077 - Permanently Preserving Americas Investment in Manufacturing Act, making permanent the allowance for depreciation, amortization or depletion for purposes of determining the income limitation on the tax deduction for business interest; H.R. 5376 - Build Back Better Act; H.R. 8913 - TCIA Permanency Act, making permanent the provisions affecting individual and business taxpayers enacted in 2017 by the Tax Cuts and Jobs Act, which are scheduled to expire at the end of 2025; H.R. 9449/S. 5021 - Broadband Grant Tax Treatment Act, to exclude certain broadband grants from gross income; and S. 1274 - Remote and Mobile Worker Relief Act of 2021.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

-S.1274 - Remote and Mobile Worker Relief Act of 2021 -HR 5376 - Build Back Better Act -HR 2558 & S.1166 - ALIGN Act -HR 4346 - Supreme Court Security Funding Act of 2022, AKA CHIPS Act of 2022 -HR 9449 & S 5021 - Broadband Grant Tax Treatment Act: A bill to exclude certain broadband grants from gross income -HR 5371 & S 1077 - Permanently Preserving America's Investment in Manufacturing Act: Makes permanent the allowance for depreciation, amortization, or depletion for purposes of determining the income limitation on the tax deduction for business interest. -HR 8913 - The TCJA Permanency Act: makes permanent provisions affecting individual and business taxpayers that were enacted in 2017 by the Tax Cuts and Jobs Act and are scheduled to expire at the end of 2025. -HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 -Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) -OECD Tax Proposals -Expensing of Research and Experimentation Costs -Corporate Income Tax Rates -Dividend Taxation -Expensing [Bonus] Depreciation -Like Kind Exchanges of Spectrum -Book Minimum Tax Treatment on Spectrum -Book Minimum Tax Treatment of Pensions -Book Minimum Tax Treatment of Depreciation -Digital Economy Directives proposed by the OECD -State and local Taxation of Digital Goods and Services -State and local Taxation of the Internet -Mobile Workforce State Income Legislation -Remote Worker State Payroll Withholding Tax Legislation - Foreign Taxation of Digital Service -International Tax changes to GILTI -Interest Tax Deduction Limitation under 163(j) of the I.R.C. -Extending Expiring Tax Benefits -Tax issues related to expensing and research and development expensing

Client expense: $3,040,000 · Firm income: Not reported

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

H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,540,000 · Firm income: Not reported

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

H.R. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 1381/S. 480, Main Street Tax Certainty Act of 2021 H.R. 1712/S. 617, Death Tax Repeal Act H.R. 2617, Consolidated Appropriations Act, 2023 H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 5376, Inflation Reduction Act of 2022 H.R. 8853, Protecting American Savers and Retirees Act H.R. 8913, TCJA Permanency Act H.R. 9030/S. 5015, Repealing the Ill-Conceived and Problematic (RIP) Book Minimum Tax Act S. 749, American Innovation and Jobs Act S. 948, A bill to protect American small businesses, gig workers, and freelancers by repealing the burdensome American Rescue Plan Act of 2021 transactions reporting threshold S. 1274, Remote and Mobile Worker Relief Act of 2021 S. 1298, Clean Energy for America Act S. 2621, Modernization of Derivatives Tax Act of 2021 Notice and Request for Comments, Internal Revenue Service; Proposed Extension of Information Collection Request Submitted for Public Comment, Concerning Source of Income from Certain Space and Ocean Activities, Source of Communications Income (87 Fed. Reg. 65,287, October 28, 2022) Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, 87 Fed. Reg. 276 (Jan. 4, 2022) (as corrected by 87 Fed. Reg. 45,018, 45,021, July 27, 2022) Various issues relating to The Tax Cuts and Jobs Act (P.L. 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; digital services taxes; OECD Pillar Two rules, including global anti-base erosion proposal (GloBE); general business tax credits; taxation of mobile and remote workers during the coronavirus pandemic; tax free paycheck protection program loan forgiveness; Paycheck Protection Program (PPP) tax deductibility; work opportunity tax credit; implementation of the American Rescue Plan Act (P.L. 117-2) including Section 9674 relating to 1099-K form reporting; IRS priority guidance plan; continuation of the stepped-up basis; potential corporate tax rate increase; continuation of the percentage depletion tax deduction; Minding the Tax Gap; Improving Tax Administration for the 21st Century; Canadian proposal to enact a retroactive Digital Services Tax (DST); Global Intangible Low-Taxed Income (GILTI); proposals to institute a tax on financial statement incomes of corporations, known as a Book Tax; proposed Internal Revenue Code Section 163(n) limit on deductions for business interest expense; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; U.S. Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention Of Fiscal Evasion With Respect to Taxes on Income and Capital; legislation to address section 163(j) EBITDA standard for business interest deductions; section 174 (R & D amortization) and extension of 100 percent accelerated depreciation known as full expensing or bonus depreciation; Extraterritorial Application of Sec. 49 German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the Excise tax on repurchase of corporate stock, and corporate alternative minimum tax; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks

Client expense: $20,990,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction; Extend R&D; bonus depreciation. Provide comments on guidance on CAMT & green energy tax incentives to Treasury.

Client expense: $2,510,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), 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; IRS Form 1099-K reporting; 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, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, 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, updated Schedule UTP on uncertain tax positions; 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, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; 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.

Client expense: $1,340,000 · 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 Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce Sate Income Tax Simplification Act of 2021 (H.R. 429, Multi-state Worker Tax Fairness Act of 2021 (S. 1887). 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; Virtual Currency

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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.

Client expense: $1,300,000 · 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 lobbying on the following issues: corporate income tax rates; dividend taxation; expensing (bonus) depreciation; like-kind spectrum exchanges; book minimum tax treatment of pensions and spectrum; digital economy directives proposed by the OECD; state and local taxation of digital goods and services; state and local taxation of the Internet; mobile workforce state income taxation; remote worker state payroll withholding taxation; foreign taxation of digital services; international tax changes to GILTI; tax extenders; and spectrum tax. Lobbying on the following specific legislation: Fair Access to Interstate Remedies (Draft)-A measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court; not yet introduced); H.R. 1304/S. 749 - American Innovation and R&D Competitiveness Act of 2021; H.R. 2558/S. 1166 - Accelerate Long-term Investment Now Act (Align Act); H.R. 5376 - Build Back Better Act; and S. 1274 - Remote and Mobile Worker Relief Act of 2021.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction

Client expense: $3,000,000 · Firm income: Not reported

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

-S.1274 - Remote and Mobile Worker Relief Act of 2021 -HR 5376 - Build Back Better Act -HR 2558 & S.1166 - ALIGN Act -HR 4346 - Supreme Court Security Funding Act of 2022, AKA CHIPS Act of 2022 -S 5021 - A bill to exclude certain broadband grants from gross income -Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) -OECD Tax Proposals -Expensing of Research and Experimentation Costs -HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 -Corporate Income Tax Rates -Dividend Taxation -Expensing [Bonus] Depreciation -Like Kind Exchanges of Spectrum -Book Minimum Tax Treatment on Spectrum -Book Minimum Tax Treatment of Pensions -Digital Economy Directives proposed by the OECD -State and local Taxation of Digital Goods and Services -State and local Taxation of the Internet -Mobile Workforce State Income Legislation -Remote Worker State Payroll Withholding Tax Legislation - Foreign Taxation of Digital Service -International Tax changes to GILTI -Tax Extenders -Spectrum Tax

Client expense: $2,830,000 · Firm income: Not reported

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

H.R. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 1381/S. 480, Main Street Tax Certainty Act of 2021 H.R. 1712/S. 617, Death Tax Repeal Act H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 5376, Build Back Better Act H.R. 8853, Protecting American Savers and Retirees Act S. 749, American Innovation and Jobs Act S. 948, A bill to protect American small businesses, gig workers, and freelancers by repealing the burdensome American Rescue Plan Act of 2021 transactions reporting threshold S. 1274, Remote and Mobile Worker Relief Act of 2021 S. 1298, Clean Energy for America Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 2758, Stock Buyback Accountability Act of 2021 Draft legislation titled Repealing the Ill-Conceived and Problematic (RIP) Book Minimum Tax Act Draft legislation titled Protecting American Savers and Retirees Act Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (P.L. 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; digital services taxes; OECD Pillar Two rules, including global anti-base erosion proposal (GloBE); general business tax credits; taxation of mobile and remote workers during the coronavirus pandemic; tax free paycheck protection program loan forgiveness; Paycheck Protection Program (PPP) tax deductibility; work opportunity tax credit; implementation of the American Rescue Plan Act (P.L. 117-2) including Section 9674 relating to 1099-K form reporting; IRS priority guidance plan; continuation of the stepped-up basis; potential corporate tax rate increase; continuation of the percentage depletion tax deduction; Minding the Tax Gap; Improving Tax Administration for the 21st Century; Canadian proposal to enact a retroactive Digital Services Tax (DST); Global Intangible Low-Taxed Income (GILTI); proposals to institute a tax on financial statement incomes of corporations, known as a Book Tax; proposed Internal Revenue Code Section 163(n) limit on deductions for business interest expense; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; U.S. Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention Of Fiscal Evasion With Respect to Taxes on Income and Capital; section 163(j) EBITDA standard for business interest deductions; Extraterritorial Application of Sec. 49 German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169); proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to increase the capital gains rate, including the treatment of carried interest; proposal to institute an excise tax on stock buybacks

Client expense: $23,940,000 · Firm income: Not reported

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

H.R. 5376, Inflation Reduction Act of 2022. H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,300,000 · Firm income: Not reported

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

Client expense: $1,300,000 · 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 Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce Sate Income Tax Simplification Act of 2021 (H.R. 429, Multi-state Worker Tax Fairness Act of 2021 (S. 1887). 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; Virtual currency

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on the following issues: corporate income tax rates; dividend taxation; expensing (bonus) depreciation; like kind exchanges of spectrum; book minimum tax treatment of pensions and spectrum; digital economy directives proposed by the OECD; state and local taxation of digital goods and services; state and local taxation of the Internet; mobile workforce state income taxation; remote worker state payroll withholding taxation; foreign taxation of digital services; international tax changes to GILTI; expensing of research and experimentation costs; and remote sales tax. Lobbying on the following specific legislation: Fair Access to Interstate Remedies (Draft)-A measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court; not yet introduced); H.R. 1304/S. 749 - American Innovation and R&D Competitiveness Act of 2021; H.R. 2558/S. 1166 - Accelerate Long-term Investment Now Act (Align Act); H.R. 5376 - Build Back Better Act; and S. 1274 - Remote and Mobile Worker Relief Act of 2021.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction

Client expense: $2,910,000 · Firm income: Not reported

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

-S.1274 - Remote and Mobile Worker Relief Act of 2021 -HR 5376 - Build Back Better Act -HR 2558 & S.1166 - ALIGN Act -Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) -Issues re Remote Sales Tax -OECD Tax Proposals -Expensing of Research and Experimentation Costs -HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 -Corporate Income Tax Rates -Dividend Taxation -Expensing [Bonus] Depreciation -Like Kind Exchanges of Spectrum -Book Minimum Tax Treatment on Spectrum -Book Minimum Tax Treatment of Pensions -Digital Economy Directives proposed by the OECD -State and local Taxation of Digital Goods and Services -State and local Taxation of the Internet -Mobile Workforce State Income Legislation -Remote Worker State Payroll Withholding Tax Legislation - Foreign Taxation of Digital Service -International Tax changes to GILTI

Client expense: $2,920,000 · Firm income: Not reported

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

H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. H.R. 5376, Build Back Better Act, to provide reconciliation pursuant to title II of S. Con. Res. 14. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,410,000 · Firm income: Not reported

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

H.R. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 1381/S. 480, Main Street Tax Certainty Act of 2021 H.R. 1712/S. 617, Death Tax Repeal Act H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 3684, Infrastructure Investment and Jobs Act H.R. 5376, Build Back Better Act S. 749, American Innovation and Jobs Act S. 948, A bill to protect American small businesses, gig workers, and freelancers by repealing the burdensome American Rescue Plan Act of 2021 transactions reporting threshold S. 1274, Remote and Mobile Worker Relief Act of 2021 S. 1298, Clean Energy for America Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 2758, Stock Buyback Accountability Act of 2021 Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (P.L. 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; digital services taxes; OECD Pillar Two rules, including global anti-base erosion proposal (GloBE) under Pillar Two; general business tax credits; taxation of mobile and remote workers during the coronavirus pandemic; tax free paycheck protection program loan forgiveness; Paycheck Protection Program (PPP) tax deductibility; work opportunity tax credit; implementation of the American Rescue Plan Act (P.L. 117-2) including Section 9674 relating to 1099-K form reporting; IRS priority guidance plan; continuation of the stepped-up basis; potential corporate tax rate increase; continuation of the percentage depletion tax deduction; Minding the Tax Gap; Improving Tax Administration for the 21st Century; Canadian proposal to enact a retroactive Digital Services Tax (DST); Global Intangible Low-Taxed Income (GILTI); proposals to institute a tax on financial statement incomes of corporations, known as a Book Tax; proposed Internal Revenue Code Section 163(n) limit on deductions for business interest expense; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; U.S. Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention Of Fiscal Evasion With Respect to Taxes on Income and Capital; section 163(j) EBITDA standard for business interest deductions; Extraterritorial Application of Sec. 49 German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension: proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to increase the capital gains rate, including the treatment of carried interest; proposal to impose a tax on certain financial transactions

Client expense: $15,800,000 · Firm income: Not reported

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

Client expense: $1,300,000 · 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 Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce Sate Income Tax Simplification Act of 2021 (H.R. 429, Multi-state Worker Tax Fairness Act of 2021 (S. 1887). 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; Virtual currency

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General lobbying on the following issues: expensing of research and experimentation costs; digital economy directives proposed by OECD; state and local taxation of digital goods and services; state and local taxation of the Internet; mobile workforce state income taxation; remote worker state payroll withholding tax; expensing (bonus) depreciation; corporate tax rate; dividend taxation; foreign taxation of digital services; like-kind exchanges of spectrum; and book minimum tax treatment of pensions and spectrum. Lobbying on the following specific legislation: Fair Access to Interstate Remedies (Draft)-A measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court; not yet introduced); H.R. 1304/S. 749 - American Innovation and R&D Competitiveness Act of 2021; H.R. 2558/S. 1166 - Accelerate Long-term Investment Now Act (Align Act); H.R. 5376 - Build Back Better Act; and S. 1274 - Remote and Mobile Worker Relief Act of 2021.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1274 - Remote and Mobile Worker Relief Act of 2021 HR 5376 - Build Back Better Act HR 2558 & S.1166 - ALIGN Act Fair Access to Interstate Remedies (a measure to prevent the imposition of discriminatory taxation and undue burdens on interstate commerce by providing taxpayers access to judicial remedies in federal court: not yet introduced) OECD Tax Proposals Expensing of Research and Experimentation Costs HR 1304 & S 749 - American Innovation and R&D Competitiveness Act of 2021 Corporate Tax Rate Dividend Taxation Expensing [Bonus] Depreciation Like Kind Exchanges of Spectrum Book Minimum Tax Treatment on Spectrum Book Minimum Tax Treatment of Pensions Digital Economy Directives proposed by the OECD State and local Taxation of Digital Goods and Services State and local Taxation of the Internet Mobile Workforce State Income Legislation Remote Worker State Payroll Withholding Tax Legislation Foreign Taxation of Digital Service

Client expense: $2,870,000 · Firm income: Not reported

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

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction

Client expense: $1,800,000 · Firm income: Not reported

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

H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. H.R. 5376, Build Back Better Act, to provide reconciliation pursuant to title II of S. Con. Res. 14. Administrations Fiscal Year 2022 and 2023 Revenue Proposals relating to corporate and international taxation. H. R. 1304, S. 748, R&D/ Internal Revenue Section 174. HR. 4521, United States Innovation and Competition Act/America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength of 2022.

Client expense: $2,540,000 · Firm income: Not reported

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

H.R. 1381/S. 480, Main Street Tax Certainty Act of 2021 H.R. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 1712/S. 617, Death Tax Repeal Act H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 3684, Infrastructure Investment and Jobs Act H.R. 5376, Build Back Better Act S. 749, American Innovation and Jobs Act S. 948, A bill to protect American small businesses, gig workers, and freelancers by repealing the burdensome American Rescue Plan Act of 2021 transactions reporting threshold S. 1274, Remote and Mobile Worker Relief Act of 2021 S. 1298, Clean Energy for America Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 2758, Stock Buyback Accountability Act of 2021 Final regulation, Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, (87 Fed. Reg. 276-376, January 4, 2022) Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (P.L. 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; digital services taxes; OECD Pillar Two rules, including global anti-base erosion proposal (GloBE) under Pillar Two; general business tax credits; taxation of mobile and remote workers during the coronavirus pandemic; tax free paycheck protection program loan forgiveness; Paycheck Protection Program (PPP) tax deductibility; work opportunity tax credit; implementation of the American Rescue Plan Act (P.L. 117-2) including Section 9674 relating to 1099-K form reporting; IRS priority guidance plan; continuation of the stepped-up basis; potential corporate tax rate increase; continuation of the percentage depletion tax deduction; Minding the Tax Gap; Improving Tax Administration for the 21st Century; Canadian proposal to enact a retroactive Digital Services Tax (DST); Global Intangible Low-Taxed Income (GILTI); proposals to institute a tax on financial statement incomes of corporations, known as a Book Tax; proposed Internal Revenue Code Section 163(n) limit on deductions for business interest expense; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; U.S. Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention Of Fiscal Evasion With Respect to Taxes on Income and Capital; section 163(j) EBITDA standard for business interest deductions; Extraterritorial Application of Sec. 49 German Income Tax Act; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to increase the capital gains rate, including the treatment of carried interest

Client expense: $18,660,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), 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 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 Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce Sate Income Tax Simplification Act of 2021 (H.R. 429, Multi-state Worker Tax Fairness Act of 2021 (S. 1887). 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;

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 5376 - Build Back Better Act including issues related to funding and modifying provisions related to child care, education, health care, climate change and tax provisions, specifically focused on a four-year deferral of the research and development amortization provision, Foreign-Derived Intangible Income Tax (FDII) deduction, and corporate tax rate; S 749/HR 1304 - American Innovation and Jobs Act to repeal the Research and Development amortization provision in the tax code, sec. 174 and issues related to the corporate tax rate and FDII; S 1274 - Remote and Mobile Worker Relief Act of 2021 to ensure uniformity in state and local income tax assessment for employees that may travel on behalf of their employers to work in a different state where they reside; HR 4830 - Pension and Budget Integrity Act of 2021 including issues related to Pension Benefit Guaranty Corporation premium education; HR 3 - Elijah E. Cummings Lower Drug Costs Now Act including issues related to prescription drug costs, paid leave, Health Savings Account modernization, telemedicine expansion

Client expense: $3,410,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of

HR 5376 - Build Back Better Act including issues related to funding and modifying provisions related to child care, education, health care, climate change and tax provisions, specifically focused on a four-year deferral of the research and development amortization provision, Foreign-Derived Intangible Income Tax (FDII) deduction, and corporate tax rate; S 749/HR 1304 - American Innovation and Jobs Act to repeal the Research and Development amortization provision in the tax code, sec. 174 and issues related to the corporate tax rate and FDII; S 1274 - Remote and Mobile Worker Relief Act of 2021 to ensure uniformity in state and local income tax assessment for employees that may travel on behalf of their employers to work in a different state where they reside; HR 4830 - Pension and Budget Integrity Act of 2021 including issues related to Pension Benefit Guaranty Corporation premium education; HR 3 - Elijah E. Cummings Lower Drug Costs Now Act including issues related to prescription drug costs, paid leave, Health Savings Account modernization, telemedicine expansion

Client expense: $3,630,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), SENATE, Treasury, Dept of

H.R 1319 - American Rescue Plan Act of 2021 H.R. 3684 - Infrastructure Investment and Jobs Act S.1274 - Remote and Mobile Worker Relief Act of 2021 HR 5376 - Build Back Better Act - To provide for reconciliation pursuant to title II of S. Con. Res. 14. HR 2558 & S 1166 - ALIGN Act Digital Economy Directives proposed by the OECD State and local Taxation of Digital Goods and Services State and local Taxation of the Internet Expensing [Bonus] Depreciation Corporate Income Tax Rates Dividend Taxation Reconciliation Foreign Taxation of Digital Services Like Kind Exchanges of Spectrum

Client expense: $2,550,000 · Firm income: Not reported

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

Oppose corporate tax rate increases (Build Back Better Act); Oppose repeal of QBAI and FDII; Extend EBITDA calculation for interest deductibility (H.R. 5371, S. 1077); oppose National Retail Sales Tax/VAT; Support Remote and Mobile Worker Relief Act (S. 1274); Oppose repeal of Sec. 199A deduction

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

Government targets: Agriculture, Dept of (USDA), Centers For Disease Control & Prevention (CDC), Commerce, Dept of (DOC), Consumer Financial Protection Bureau (CFPB), Consumer Product Safety Commission (CPSC), Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Energy Regulatory Commission (FERC), Federal Maritime Commission, Federal Motor Carrier Safety Administration, Federal Reserve System, Federal Trade Commission (FTC), Food & Drug Administration (FDA), 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), Office of Management & Budget (OMB), Patent & Trademark Office (PTO), President of the U.S., 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

General lobbying on the following issues: retirement; digital economy directives proposed by OECD; state and local taxation of digital goods and services; state and local taxation of the Internet; mobile workforce state income; remote worker state payroll withholding tax; expensing (bonus) depreciation; corporate income tax rates; dividend taxation; reconciliation; foreign taxation of digital services; like kind exchanges of spectrum; and book minimum tax treatment of pensions and spectrum. Lobbying on the following specific legislation: H.R. 2558/S. 1166 - Accelerate Long-term Investment Now Act (Align Act); H.R. 5376 - Build Back Better Act - to provide reconciliation pursuant to Title II of S. Con. Res. 14; and S. 1274 - Remote and Mobile Worker Relief Act of 2021.

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

Government targets: Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, SENATE

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. S. 1274, Remote and Mobile Worker Relief Act of 2021, 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. H.R. 2297/S. 1194 (116th CONGRESS), Tax Filing Simplification Act of 2019, issues pertaining to education on the Government Populated Return. H.R. 4184, Taxpayer Protection and Preparer Proficiency Act of 2021, issues pertaining to taxpayer service standards. H.R. 3684, Infrastructure Investment and Jobs Act, issues pertaining to cryptocurrency reporting provisions and the employee retention credit. Issues pertaining to the administration of financial information reporting requirements, tax preparer regulations, small business deduction, feasibility study of government populated return, increasing tax credits, and the broadening and extension of the family credits enacted in the American Rescue Plan.

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

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

H.R. 1381/S. 480, Main Street Tax Certainty Act of 2021 H.R. 1712/S. 617, Death Tax Repeal Act H.R. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 3684, Infrastructure Investment and Jobs Act H.R. 5376, Build Back Better Act S. 749, American Innovation and Jobs Act S. 948, A bill to protect American small businesses, gig workers, and freelancers by repealing the burdensome American Rescue Plan Act of 2021 transactions reporting threshold S. 1274, Remote and Mobile Worker Relief Act of 2021 S. 1298, Clean Energy for America Act S. 2621, Modernization of Derivatives Tax Act of 2021 S. 2758, Stock Buyback Accountability Act of 2021 Various issues relating to tax extenders, including bonus depreciation, deferral tax provisions, S-Corp tax provisions, and flow-throughs; Tax Cuts and Jobs Act (P.L. 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; digital services taxes; global anti-base erosion proposal (GloBE) under Pillar Two; general business tax credits; taxation of mobile and remote workers during the coronavirus pandemic; tax free paycheck protection program loan forgiveness; Paycheck Protection Program (PPP) tax deductibility; work opportunity tax credit; implementation of the American Rescue Plan Act (P.L. 117-2) including Section 9674 relating to 1099-K form reporting; IRS priority guidance plan; continuation of the stepped-up basis; potential corporate tax rate increase; continuation of the percentage depletion tax deduction; Minding the Tax Gap; Improving Tax Administration for the 21st Century; Canadian proposal to enact a retroactive Digital Services Tax (DST); Global Intangible Low-Taxed Income (GILTI); proposals to institute a tax on financial statement incomes of corporations, known as a Book Tax; Proposed Internal Revenue Code Section 163(n) limit on deductions for business interest expense; Tax Reporting Proposal by the Department of the Treasury related to a $600 or more annual account threshold; U.S. Chile Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention Of Fiscal Evasion With Respect to Taxes on Income and Capital; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to increase the capital gains rate, including the treatment of carried interest

Client expense: $19,560,000 · 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 Bureau of Investigation (FBI), 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), 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), Intl Trade Administration (ITA), Justice, Dept of (DOJ), Labor, Dept of (DOL), Natl Aeronautics & Space Administration (NASA), Natl Economic Council (NEC), Natl Highway Traffic Safety Administration (NHTSA), Natl Institute of Standards & Technology (NIST), Natl Labor Relations Board (NLRB), Natl Science Foundation (NSF), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Occupational Safety & Health Administration (OSHA), 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. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR), White House Office

S. 1274 - Remote & Mobile Worker Relief Act of 2021 H.R. 5376 - Build Back Better Act HR 2558 & S 1166 - ALIGN Act Retirement Corporate Tax Rate Digital Economy Directives proposed by the OECD State and local Taxation of Digital Goods and Services State and local Taxation of the Internet Mobile Workforce State Income Legislation Remote Worker State Payroll Withholding Tax Legislation Expensing [Bonus] Depreciation Corporate Income Tax Rates Dividend Taxation Foreign Taxation of Digital Services Like Kind Exchanges of Spectrum Book Minimum Tax Treatment on Spectrum Book Minimum Tax Treatment on Pensions

Client expense: $2,990,000 · Firm income: Not reported

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

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.

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

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

H.R. 1304, the American Innovation and R&D Competitiveness Act of 2021. S. 749, the American Innovation and Jobs Act. S. 1274, Remote and Mobile Workers Relief Act of 2021. S. 1545 & H.R. 3007, Disclosure of Tax Havens and Offshoring Act. Corporate tax, transfer pricing, treaty, foreign tax credit, mobile worker, international tax, and foreign tax issues. H.R. 5376, Build Back Better Act, to provide reconciliation pursuant to title II of S. Con. Res. 14. Administrations Fiscal Year 2022 Revenue Proposals relating to corporate and international taxation.

Client expense: $2,470,000 · 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