Stock Buyback Accountability Act of 2021

S 2621 Modernization of Derivatives Act of 2021: This bill modifies the tax treatment of derivatives. A derivative is any contract (including any option, forward contract, futures contract, short position, swap, or similar contract) the value of which, or any payment or other transfer with respect to which, is (directly or indirectly) determined by reference to another specified item. The bill modifies the tax treatment of derivatives to (1) require mark to market treatment (treating the contracts as if they had been terminated or transferred at fair market value at the end of the year) for derivatives not terminated or transferred during the year, (2) require gains and losses to be taxed at ordinary tax rates and sourced to the taxpayer's country of residence, and (3) revise the reporting requirements and tax rules that apply to taxpayers that use derivatives to hedge capital assets. The bill includes several exceptions for certain real property; hedging transactions; securities lending, sale-repurchase, and similar financing transactions; options received in connection with the performance of services; insurance contracts, annuities, and endowments; derivatives with respect to stock of members of the same worldwide affiliated group; and commodities used in the normal course or trade of business. S 2758 Stock Buyback Accountability Act of 2021: A summary is in progress H.R. 5161 Expanding Small Employer Pooling Options for Paid Family Leave Act of 2021 Summary in Progress Executive Report 117-1 Tax Convention with Chile Proposed treaty to promote and facilitate trade and investment between the United States and Chile.

Client expense: $538,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Like Kind Exchanges Parity for Non-Traded REITs Act (H.R. 3123) Foreign Investment in Real Property Tax Act (FIRPTA) REIT Tax Modernization Energy Efficient Qualified Improvement Property (E-QIP)(H.R. 8930) Retail Revitalization Act (H.R. 840) REIT Constructive Ownership Proposals (S.2715) International Tax Proposals Infrastructure Tax Proposals GREEN Act of 2021 (H.R. 848) Build Back Better Plan Clean Energy for America Act (S.2118) Renewable Energy Investment Act (H.R. 3180) Stock Buy Back Proposals (S. 2758) Renewing Investment in American Workers & Supply Chains Act (HR 7229, S. 4012) Monitor residential rental issues Monitor skilled nursing facility issues

Client expense: $953,000 · Firm income: Not reported

Like Kind Exchanges Parity for Non-Traded REITs Act (H.R. 3123) Foreign Investment in Real Property Tax Act (FIRPTA) REIT Tax Modernization Energy Efficient Qualified Improvement Property (E-QIP)(H.R. 8930) Retail Revitalization Act (H.R. 840) International Tax Proposals Infrastructure Tax Proposals GREEN Act of 2021 (H.R. 848) Build Back Better Plan Clean Energy for America Act (S.2118) Renewable Energy Investment Act (H.R. 3180) Stock Buy Back Proposals (S. 2758) Renewing Investment in American Workers & Supply Chains Act (HR 7229, S. 4012) Monitor residential rental issues Monitor skilled nursing facility issues

Client expense: $953,000 · Firm income: Not reported

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

S 2621 Modernization of Derivatives Act of 2021: This bill modifies the tax treatment of derivatives. A derivative is any contract (including any option, forward contract, futures contract, short position, swap, or similar contract) the value of which, or any payment or other transfer with respect to which, is (directly or indirectly) determined by reference to another specified item. The bill modifies the tax treatment of derivatives to (1) require mark to market treatment (treating the contracts as if they had been terminated or transferred at fair market value at the end of the year) for derivatives not terminated or transferred during the year, (2) require gains and losses to be taxed at ordinary tax rates and sourced to the taxpayer's country of residence, and (3) revise the reporting requirements and tax rules that apply to taxpayers that use derivatives to hedge capital assets. The bill includes several exceptions for certain real property; hedging transactions; securities lending, sale-repurchase, and similar financing transactions; options received in connection with the performance of services; insurance contracts, annuities, and endowments; derivatives with respect to stock of members of the same worldwide affiliated group; and commodities used in the normal course or trade of business. S 2758 Stock Buyback Accountability Act of 2021: A summary is in progress H.R. 5161 Expanding Small Employer Pooling Options for Paid Family Leave Act of 2021 Summary in Progress Executive Report 117-1 Tax Convention with Chile Proposed treaty to promote and facilitate trade and investment between the United States and Chile.

Client expense: $518,000 · Firm income: Not reported

Like Kind Exchanges Parity for Non-Traded REITs Act (H.R. 3123) REIT Tax Modernization Built-In Gains Energy Efficient Qualified Improvement Property (E-QIP)(H.R. 8930) Retail Revitalization Act (H.R. 840) REIT Constructive Ownership Proposals (S.2715) International Tax Proposals Infrastructure Tax Proposals Mark to Market Proposals Main Street Tax Certainty Act of 2021 (H.R. 1381, S. 480) GREEN Act of 2021 (H.R. 848) Build Back Better Plan Clean Energy for America Act (S.2118) Renewable Energy Investment Act (H.R. 3180) Stock Buy Back Proposals (S. 2758) Modernization of Derivatives Act (S.2621)

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

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

S 2621 Modernization of Derivatives Act of 2021: This bill modifies the tax treatment of derivatives. A derivative is any contract (including any option, forward contract, futures contract, short position, swap, or similar contract) the value of which, or any payment or other transfer with respect to which, is (directly or indirectly) determined by reference to another specified item. The bill modifies the tax treatment of derivatives to (1) require mark to market treatment (treating the contracts as if they had been terminated or transferred at fair market value at the end of the year) for derivatives not terminated or transferred during the year, (2) require gains and losses to be taxed at ordinary tax rates and sourced to the taxpayer's country of residence, and (3) revise the reporting requirements and tax rules that apply to taxpayers that use derivatives to hedge capital assets. The bill includes several exceptions for certain real property; hedging transactions; securities lending, sale-repurchase, and similar financing transactions; options received in connection with the performance of services; insurance contracts, annuities, and endowments; derivatives with respect to stock of members of the same worldwide affiliated group; and commodities used in the normal course or trade of business. S 2758 Stock Buyback Accountability Act of 2021: A summary is in progress H.R. 5161 Expanding Small Employer Pooling Options for Paid Family Leave Act of 2021 Summary in Progress Executive Report 117-1 Tax Convention with Chile Proposed treaty to promote and facilitate trade and investment between the United States and Chile.

Client expense: $1,277,000 · Firm income: Not reported

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

Like Kind Exchanges FIRPTA: Modification of the Foreign Investment in Real Property Tax Act REIT Tax Modernization Built-In Gains Energy Efficient Qualified Improvement Property (E-QIP)(H.R. 8930) Retail Revitalization Act (H.R. 840) REIT Constructive Ownership Proposals (S.2715) International Tax Proposals Infrastructure Tax Proposals Mark to Market Proposals Wealth Tax Proposals Main Street Tax Certainty Act of 2021 (H.R. 1381, S. 480) GREEN Act of 2021 (H.R. 848) Build Back Better Plan Clean Energy for America Act (S.2118) Renewable Energy Investment Act (H.R. 3180) Stock Buy Back Proposals (S. 2758) Modernization of Derivatives Act (S.2621)

Client expense: $848,000 · Firm income: Not reported

HR 1799 PPP Extension Act of 2021 This bill extends the Paycheck Protection Program, established to support small businesses in response to COVID-19 (i.e., coronavirus disease 2019), through June 30, 2021. Currently, the program is set to expire on March 31, 2021. For the final 30 days of the program (i.e., from June 1 until June 30), the Small Business Administration may only process applications submitted prior to June 1, and it may not accept any new loan applications. The bill excludes the budgetary effects of this bill from PAYGO scorecards under the Statutory Pay-As-You-Go Act of 2010 and from Senate PAYGO scorecards. S 2621 Modernization of Derivatives Act of 2021: This bill modifies the tax treatment of derivatives. A derivative is any contract (including any option, forward contract, futures contract, short position, swap, or similar contract) the value of which, or any payment or other transfer with respect to which, is (directly or indirectly) determined by reference to another specified item. The bill modifies the tax treatment of derivatives to (1) require mark to market treatment (treating the contracts as if they had been terminated or transferred at fair market value at the end of the year) for derivatives not terminated or transferred during the year, (2) require gains and losses to be taxed at ordinary tax rates and sourced to the taxpayer's country of residence, and (3) revise the reporting requirements and tax rules that apply to taxpayers that use derivatives to hedge capital assets. The bill includes several exceptions for certain real property; hedging transactions; securities lending, sale-repurchase, and similar financing transactions; options received in connection with the performance of services; insurance contracts, annuities, and endowments; derivatives with respect to stock of members of the same worldwide affiliated group; and commodities used in the normal course or trade of business. S 2758 Stock Buyback Accountability Act of 2021: A summary is in progress

H.R. 1068, Carried Interest Fairness Act: legislation to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities. H.R. 1785/S. 714, No Tax Breaks for Outsourcing Act: a bill to amend the Internal Revenue Code of 1986 to provide for current year inclusion of net CFC tested income, and for other purposes. S. 2758, Stock Buyback Accountability Act of 2021: a bill to amend the Internal Revenue Code of 1986 to impose an excise tax on stock buybacks of publicly traded corporations.

Client expense: $400,000 · Firm income: Not reported

Government targets: Centers For Disease Control & Prevention (CDC), Federal Aviation Administration (FAA), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Natl Mediation Board, SENATE, Transportation, Dept of (DOT), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 328/S. 817, Wall Street Tax 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. 1304, American Innovation and R&D Competitiveness Act of 2021 H.R. 2735/S. 1283, Tax on Wall Street Speculation Act H.R. 3007, Disclosure of Tax Havens and Offshoring Act H.R. 3425, Saving Gig Economy Taxpayers Act H.R. 3684, Infrastructure Investment and Jobs 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; Memorandum for the Secretary of the Treasury deferring payroll tax obligations in light of the ongoing COVID-19 disaster; 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; potential U.S. - Chile income tax treaty; remote notarization; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to increase the capital gains rate

H.R. 328- Wall Street Tax Act of 2021 (DeFazio) H.R. 2954- Securing a Strong Retirement Act of 2021 (Neal) H.R. 3142- Tax Parity for US Mutual Funds Act (Davis) H.R. 5334- PRIA Act of 2021 (Himes) S. 817- Wall Street Tax Act of 2021 (Schatz) S. 1703- Improving Access to Retirement Savings Act (Grassley) S. 1730- Retirement Savings Lost and Found Act of 2021 (Warren) S. 1770- Retirement Security and Savings Act of 2021 (Cardin) S. 1870- Enhancing Emergency and Retirement Savings Act of 2021 (Lankford) S. 2387- Small Business Tax Fairness Act (Wyden) S. 2452- Encouraging Americans to Save Act (Wyden) S. 2621- Modernization of Derivatives Tax Act (Wyden) S. 2758- Stock Buyback Accountability Act of 2021 (Brown) S. 2870- PRIA Act of 2021 (Warner) Build Back Better Act IRC section 852(b)(6) Auto-IRA/Plan Requirement Limits on large IRA balances Capital gains and dividends taxation Financial account reporting Remote notarization for retirement plans Tax deferral of retirement contributions Tax exemption for municipal bond interest Reinstate advance refunding bonds Certifications of US Tax Residency

Client expense: $1,720,000 · Firm income: Not reported

Like Kind Exchanges FIRPTA: Modification of the Foreign Investment in Real Property Tax Act REIT Tax Modernization Built-In Gains Energy Efficient Qualified Improvement Property (E-QIP)(H.R. 8930) Retail Revitalization Act (H.R. 840) International Tax Proposals Infrastructure Tax Proposals Mark to Market Proposals Wealth Tax Proposals Main Street Tax Certainty Act of 2021 (H.R. 1381, S. 480) GREEN Act of 2021 (H.R. 848) Build Back Better Plan Clean Energy for America Act (S.2118) Renewable Energy Investment Act (H.R. 3180) Stock Buy Back Proposals (S. 2758) Modernization of Derivatives Act (S.2621)

Client expense: $1,288,000 · Firm income: Not reported

HR 1799 PPP Extension Act of 2021 This bill extends the Paycheck Protection Program, established to support small businesses in response to COVID-19 (i.e., coronavirus disease 2019), through June 30, 2021. Currently, the program is set to expire on March 31, 2021. For the final 30 days of the program (i.e., from June 1 until June 30), the Small Business Administration may only process applications submitted prior to June 1, and it may not accept any new loan applications. The bill excludes the budgetary effects of this bill from PAYGO scorecards under the Statutory Pay-As-You-Go Act of 2010 and from Senate PAYGO scorecards. S 2621 Modernization of Derivatives Act of 2021: This bill modifies the tax treatment of derivatives. A derivative is any contract (including any option, forward contract, futures contract, short position, swap, or similar contract) the value of which, or any payment or other transfer with respect to which, is (directly or indirectly) determined by reference to another specified item. The bill modifies the tax treatment of derivatives to (1) require mark to market treatment (treating the contracts as if they had been terminated or transferred at fair market value at the end of the year) for derivatives not terminated or transferred during the year, (2) require gains and losses to be taxed at ordinary tax rates and sourced to the taxpayer's country of residence, and (3) revise the reporting requirements and tax rules that apply to taxpayers that use derivatives to hedge capital assets. The bill includes several exceptions for certain real property; hedging transactions; securities lending, sale-repurchase, and similar financing transactions; options received in connection with the performance of services; insurance contracts, annuities, and endowments; derivatives with respect to stock of members of the same worldwide affiliated group; and commodities used in the normal course or trade of business. S 2758 Stock Buyback Accountability Act of 2021: A summary is in progress