Supply Chain Disruptions Relief Act

Issues related to dealer inventory and supply chain shortages H.R. 7382/ S. 4105, LIFO: Last in First Out Tax Policy H.R. 2617, Consolidated Appropriations Act, 2023

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

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 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.

S. 4105 and H.R. 7382, the Supply Chain Disruptions Relief Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax reforms; small business protection; LIFO recapture: S.4105/H.R.7382

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

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.

1.Americas Outdoor Recreation Act of 2022 (S.3266); 2.Assault Weapons Ban (S.736 / H.R.1808); 3.Assault Weapons Excise Act (H.R.8051); 4.Background Check Completion Act of 2021 (S.591); 5.Background Check Expansion Act (S.529); 6.Bipartisan Background Checks Act (H.R.8); 7.Bipartisan Safer Communities Act (S.2938); 8.Chronic Wasting Disease Research and Management Act (S.4111/H.R.5608); 9.Closing the Loophole on Interstate Firearm Sales Act (H.R.647); 10.Commercial sales of M855/SS109 green tip ammunition; 11.Concealed Carry Reciprocity Act (S.1522/H.R.38/S.4105); 12.Department of Justice zero tolerance policy; 13.Disarm Hate Act (S.2090/ H.R.3929); 14.Empowering Law Enforcement for Safer Firearm Transfers Act of 2021 (H.R.1782); 15.Enhanced Background Checks Act of 2021 (H.R.1446); 16.Extreme Risk Protection Order Act of 2021 (S.1819); 17.Fair Access to Banking Act (S.563/H.R.1729) / Discrimination in lending; 18.FDIC Act (S.229); 19.Federal Extreme Risk Protection Order Act of 2021 (H.R.2377); 20.Federal Firearm Licensee Act (H.R.6225); 21.Federal Firearms Licensee Protection Act (S.2449/H.R.3252); 22.Federal Trade Commission (FTC) on advertising by firearm manufacturers; 23.Firearm Industry Nondiscrimination Act (S.4435/H.R.6970); 24.Firearm Safety Act of 2021 (H.R.880); 25.Firearm Tracing / Tiahrt Amendment; 26.Foreign National Firearms Background Check Enhancement Act (H.R.2971); 27.Firearms Safety Act (S.788); 28.FY23 Appropriations-Agriculture, Rural Development, Food and Drug Administration, and Related Agencies; 29.FY23 Appropriations-Commerce, Justice, Science and Related Agencies; 30.FY23 Appropriations-Homeland Security; 31.FY23 Appropriations-Interior, Environment, and Related Agencies; 32.Gun Records Restoration and Preservation Act (S.974/H.R.2282); 33.Gun Violence Prevention Through Financial Intelligence Act (S.3117/ H.R.5764); 34.HEAR Act (S.1131); 35.Hearing Protection Act (S.2050/H.R.95); 36.Home Defense and Competitive Shooting Act of 2021 (S.803/ H.R.1758); 37.Illegal Alien NICS Alert Act (S.1261/H.R.355) 38.INDEX Act (S.4241/ H.R.8521); 39.Keep Americans Safe Act (S.1108/ H.R.2510); 40.Keeping Gun Dealers Honest Act of 2021 (S.2320/ H.R.4271); 41.Lawful Interstate Transportation of Firearms Act (S.525/H.R.225/H.R.1680); 42.Limiting Section 230 Immunity to Good Samaritans Act (H.R.277); 43.Local Public Health And Safety Protection Act (H.R.4888); 44.Merchant Category Code for Firearms, Ammunition; 45.Minnesota Senate Lead Ammo Ban Question; 46.Modernizing Access to Our Public Land Act (S.904/H.R.3113); 47.Multiple Firearm Sales Reporting Modernization Act of 2022 (H.R.7904); 48.National Defense Authorization Act for FY23 (H.R.7900); 49.No ESG at TSP Act (H.R.7896); 50.No User Fees for Gun Owners Act (H.R.7366); 51.Nomination of Rachel Bloomekatz (United States Circuit Judge for the Sixth Circuit); 52.Nomination of Steve Dettelbach (ATF Director); 53.Pistol Brace Protection Act (S.4069); 54.Pittman-Robertson Wildlife Conservation Funding; 55.Preventing Unjust Red Flag Laws Act of 2021 (H.R.5417); 56.Protect Our Military Families 2nd Amendment Rights Act (H.R.1013); 57.Protecting Access for Hunters and Anglers Act of 2022 (S.4940/H.R.9088); 58.Protecting Our Kids Act (H.R.7910); 59.Protecting the Right To Keep and Bear Arms Act of 2021 (S.1916/H.R.1534); 60.PROTECT the Second Amendment Act (H.R.6247); 61.Protection of Lawful Commerce in Arms Act / Equal Access to Justice for Victims of Gun Violence Act of 2022 (S.1338 / H.R.2814) 62.Raise the Age Act (H.R.3015); 63.Recreational Lands Self Defense Act (S.2948); 64.Responsible Ownership of Firearms Act (H.R.4136) / Firearm Safety and Education; 65.RETURN our Constitutional Rights Act of 2022 (H.R.8167); 66.RIFLE Act (H.R.3101); 67.SAFER Voter Act (H.R.2890); 68.SAME Act (S.1373); 69.Second Amendment is Essential Act of 2021 (H.R.4060); 70.SECURE Firearm Storage Act (S.2908/ H.R.5465); 71.SOAR Act (S.1229); 72.Stop Online Ammunition Sales Act of 2021 (H.R.1207); 73.STOP Straw Purchases Act (H.R.1604); 74.To amend the Internal Revenue Code of 1986 to exempt certain silencers from regulation under the National Firearms Act (Draft Legislation); 75.Trafficking Reduction And Criminal Enforcement (TRACE) Act (H.R.6646); 76.Traveler's Gun Rights Act (S.4029/ H.R.7466); 77.Untraceable Firearms Act of 2021 (S.1558/ H.R.3088); 78.U.S. Fish and Wildlife Service (USFWS) settlement negotiations with Center for Biological Diversity; 79.U.S. Fish and Wildlife Service (USFWS) Proposed Rule to ban the use of traditional lead ammunition on National Wildlife Refuges (NWRs); 80.USML to CCL Transition (Export Control Reform); 81.U.S. Treasurys Sanctions on Russia; and 82.Veterans 2nd Amendment Protection Act (H.R.1217)

Repeal of the estate tax - S. 617, the Death Tax Repeal Act of 2021; Repeal of the estate tax - H.R. 1712, the Death Tax Repeal Act. Tax incentives as they relate to the auto industry and specifically the purchase of electric vehicles/clean vehicles: S. 1298 - The Clean Energy for America Act; S. 2118 - Clean Energy for America Act; H.R. 5376 - Build Back Better Act; H.R. 5376 - Inflation Reduction Act. Supply chain issues as it relates to LIFO recapture: Supply Chain Disruptions Relief Act - H.R. 7382; Supply Chain Disruptions Relief Act - S. 4105.

Client expense: $320,000 · Firm income: Not reported

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

Legislation to repeal the federal excise tax on heavy-duty trucks and trailers (H.R. 8116/S. 2435, "The Modern, Clean, and Safe Trucks Act") Legislation to provide relief under Section 473 of the Internal Revenue Code for interruptions in LIFO inventories (H.R. 7382/S. 4105 "The Supply Chain Disruptions Relief Act") Legislative proposals affecting the estate tax and modifications to stepped up basis Legislative proposals that modify the corporate tax rate, Section 199A deductions for pass through entities, expansion of the net investment income tax (NIIT) and other business taxes Legislative proposals which would reform electric vehicle tax credits and establish new tax credits for electric commercial vehicles (H.R. 5376, "The Inflation Reduction Act") Legislative proposals affecting electric vehicle charging programs (H.R. 3684, "The Infrastructure Investment and Jobs Act")

Client expense: $1,736,000 · Firm income: Not reported

Issues related to dealer inventory and supply chain shortages H.R. 7382/ S. 4105 LIFO: Last in First Out Tax Policy

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

Government targets: HOUSE OF REPRESENTATIVES, 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.

S. 4105 and H.R. 7382, the Supply Chain Disruptions Relief Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to electric vehicle tax credits; H.R. 7382 and S. 4105 - the Supply Chain Disruptions Relief Act; H.R.5376 - Inflation Reduction Act of 2022 (Public Law No: 117-169).

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Repeal of the estate tax - S. 617, the Death Tax Repeal Act of 2021; Repeal of the estate tax - H.R. 1712, the Death Tax Repeal Act. Tax incentives as they relate to the auto industry and specifically the purchase of theChain Disruptions Relief Act (H.R. 7382)electric vehicles: S. 1298 - The Clean Energy for America Act; S. 2118 - Clean Energy for America Act; H.R. 5376 - Build Back Better Act; Supply Chain Disruptions Relief Act - H.R. 7382; Supply Chain Disruptions Relief Act - S. 4105.

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

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

Legislation to repeal the federal excise tax on heavy-duty trucks and trailers (H.R. 8116/S. 2435, "The Modern, Clean, and Safe Trucks Act") Legislation to provide relief under Section 473 of the Internal Revenue Code for interruptions in LIFO inventories (H.R. 7382/S. 4105 "The Supply Chain Disruptions Relief Act") Legislative proposals affecting the estate tax and modifications to stepped up basis Legislative proposals that modify the corporate tax rate, Section 199A deductions for pass through entities, expansion of the net investment income tax (NIIT) and other business taxes Legislative proposals which would reform electric vehicle tax credits and establish new tax credits for electric commercial vehicles (H.R. 5376, "The Build Back Better Act" and Title XII of the Senate Finance Committees December 2021 Build Back Better Act text)

Client expense: $1,215,000 · Firm income: Not reported

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.

Issues related to electric vehicle tax credits; H.R. 7382 and S. 4105 - the Supply Chain Disruptions Relief Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 4105 and H.R. 7382, the Supply Chain Disruptions Relief Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE