Multi-State Worker Tax Fairness Act of 2021

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.

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.

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Implementation of U.S. Treasury regulations and follow on issues from H.R. 1, Tax Cuts and Jobs Act, TCJA, Public Law No. 115-97; Tax proposals in H.R. 5376, Build Back Better Act; T.D. 9959, 87 Fed. Reg. 276, Final Foreign Tax Credit Regulations; S. 1077 and H.R. 5371, Permanently Preserving America's Investment in Manufacturing Act. S. 1887, H.R. 4267, Multi-State Worker Tax Fairness Act of 2021. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and relevant treaties under negotiation.

Client expense: $1,610,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), 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. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code 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

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Implementation of U.S. Treasury regulations and follow on issues from H.R. 1, Tax Cuts and Jobs Act, TCJA, Public Law No. 115-97; Tax proposals in H.R. 5376, Build Back Better Act; T.D. 9959, 87 Fed. Reg. 276, Final Foreign Tax Credit Regulations; S. 1077 and H.R. 5371, Permanently Preserving America's Investment in Manufacturing Act. S. 1887, H.R. 4267, Multi-State Worker Tax Fairness Act of 2021. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and relevant treaties under negotiation.

Client expense: $1,680,000 · Firm income: Not reported

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

General issues related to multiple areas of the tax law and code 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

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Implementation of U.S. Treasury regulations and follow on issues from H.R.1, Tax Cuts and Jobs Act, TCJA, Public Law No. 115-97; Tax proposals in H.R. 5376, Build Back Better Act; T.D. 9959, 87 Fed. Reg. 276, Final Foreign Tax Credit Regulations; S. 1077 and H.R. 5371, Permanently Preserving America's Investment in Manufacturing Act. S. 1887, H.R. 4267, Multi-State Worker Tax Fairness Act of 2021. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and relevant treaties under negotiation.

Client expense: $1,040,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Economic Council (NEC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), 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, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code 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

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.

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Overhauling International Tax framework of Senate Finance Committee; Implementation of U.S. Treasury regulations and follow on issues from H.R. 1, Tax Cuts and Jobs Act, TCJA, Public Law No. 115-97; Proposed regulations on Classification of Cloud Transactions and Transactions Involving Digital Content, new regulatory section 1.861-19 and amendment of -18 regulations; tax proposals in H.R. 5376, Build Back Better Act. S. 1887, H.R. 4267, Multi-State Worker Tax Fairness Act of 2021. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and GloBE anti-base erosion proposals, model rules and commentary; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and selected treaties under negotiation.

Client expense: $1,060,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Economic Council (NEC), Natl Institute of Standards & Technology (NIST), Natl Security Council (NSC), Natl Telecommunications & Information Administration (NTIA), Office of Science & Technology Policy (OSTP), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), Veterans Affairs, Dept of (VA), 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.

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

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: H.R. 1319, P.L. 117-2, "The American Rescue Plan"; "Made in America Tax Plan"; "Overhauling International Tax framework"; Implementation of U.S. Treasury regulations and follow on issues from H.R. 1, "Tax Cuts and Jobs Act," TCJA, Public Law No. 115-97; Proposed regulations on "Classification of Cloud Transactions and Transactions Involving Digital Content" new section 1.861-19 and amendment of -18 regulations. W&M Committee amendment in nature of substitute to The Build Back Better Budget Reconciliation bill. Multi-State Worker Tax Fairness Act of 2021, S. 1887. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD "Addressing Tax Challenges of Digitalization" and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and relevant treaties under negotiation.

Client expense: $1,250,000 · Firm income: Not reported

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

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

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: H.R. 1319, P.L. 117-2, "The American Rescue Plan"; "Made in America Tax Plan"; "Overhauling International Tax framework"; Implementation of U.S. Treasury regulations and follow on issues from H.R. 1, "Tax Cuts and Jobs Act," TCJA, Public Law No. 115-97; Proposed regulations on "Classification of Cloud Transactions and Transactions Involving Digital Content" new section 1.861-19 and amendment of -18 regulations. Multi-State Worker Tax Fairness Act of 2021, S. 1887. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD "Addressing Tax Challenges of Digitalization" and BEPS 2.0; implementation of OECD Base Erosion Profit-Shifting (BEPS) recommendations. Bilateral income tax treaties pending before the Senate, e.g., Chile and relevant treaties under negotiation.

Client expense: $980,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Education, Dept of, Energy, Dept of, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Intl Trade Administration (ITA), Labor, Dept of (DOL), Natl Economic Council (NEC), Natl Science Foundation (NSF), Natl Security Council (NSC), Office of Science & Technology Policy (OSTP), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Trade Representative (USTR), White House Office

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

General issues related to multiple areas of the tax law and code 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).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE