Book Minimum Tax Repeal Act

"Inflation Reduction Act Implementation S. 1559. Book Minimum Tax Repeal Act (Barrasso) HR 3210 Book Minimum Tax Repeal Act (Arrington)"

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Inflation Reduction Act Implementation S. 1559. Book Minimum Tax Repeal Act (Barrasso) HR 3210 Book Minimum Tax Repeal Act (Arrington)"

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 2872, the RESILIENCE Act of 2025; S. 448, the CIRCUIT Act; S.1559, Book Minimum Tax Repeal Act; H.R. 3210 Book Minimum Tax Repeal; H.R.5376, Inflation Reduction Act of 2022; H.R. 7024, the Tax Relief for American Families and Workers Act; H.R. 3938, Build It in America Act; Resiliency issues generally; Distribution transformer issues generally; Transmission and distribution issues generally; Inflation Reduction Act Implementation; Tax Cuts and Jobs Act issues generally; Inflation Reduction Act Implementation.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Inflation Reduction Act Implementation S. 1559. Book Minimum Tax Repeal Act (Barrasso) HR 3210 Book Minimum Tax Repeal Act (Arrington)"

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 889: Broadband Grant Tax Treatment Act; all provisions H.R. 2406: Accelerate Long-term Investment Growth Now (ALIGN) Act; provisions related to full expensing H.R. 2673: American Innovation and R&D Competitiveness Act of 2023; provisions related to research and development expensing H.R. 2788: AIM Act; provisions related to corporate interest deductibility H.R. 3938: Build it in America Act; extension of tax provisions related to full expensing, research and development expensing, and corporate interest deductibility H.R. 7024: Tax Relief for American Families and Workers Act of 2024; provisions related to tax reform, full expensing, research and development expensing, and corporate interest deductibility S. 341: Broadband Grant Tax Treatment Act; all provisions S. 866: American Innovation and Jobs Act; provisions related to research and experimentation expensing S. 1117: ALIGN Act; provisions related to full expensing S. 1232: AIM Act; provisions related to corporate interest deductibility S. 1559: Book Minimum Tax Repeal Act; all provisions Discussions related to 100% expensing bonus depreciation, research and experimentation costs, dividend taxation Discussions related to corporate income tax credits and corporate income tax rate Discussions related to Book Minimum Tax treatment of spectrum Discussions related to corporate alternative minimum tax guidance Discussions related to interest tax deduction limitation under 163(j) of the I.R.C.

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

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) Senate Version: S.3349 - A bill to prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. (Katie Britt, R-AL) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.5992 - To amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Josh Harder, D-CA-9) H.R.6082 - To amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (Andrew Garbarino, R-NY-2) Senate Version: S.3153 - A bill to amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.6186 - To amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. (Scott Franklin, R-FL-18) H.R.6304 - To increase coverage under the National Flood Insurance Program for costs of compliance, and for other purposes. (Nick LaLota, R-NY-1) S.3253 - A bill to amend the Federal Crop Insurance Act to require research and development on frost or cold weather insurance, and for other purposes. (Marco Rubio, R-FL) S.3270 - A bill to amend the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of 1994 to establish a budgetary Tribal Government consultation process at the Department of Agriculture, and for other purposes. (Mike Rounds, R-SD) H.R.6944 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. (Adam Schiff, D-CA-30) H.R.7000 - To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Bryan Steil, R-WI-1) Senate Version: S.3592 - A bill to amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Tim Scott, R-SC) S.3650 - A bill to amend the Biggert-Waters Flood Insurance Reform Act of 2012 to improve mapping under the National Flood Insurance Program, and for other purposes. (Marco Rubio, R-FL) H.R.7462 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Maxine Waters, D-CA-43) H.R.7537 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. (Madeleine Dean, D-PA-4) S.4081 - A bill to amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (John Hoeven, R-ND) House Version: H.R.8350 - To amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (Brad Finstad, R-MN-1) S.4143 - A bill to amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Rick Scott, R-FL) House Version: H.R.8102 - To amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Byron Donalds, R-FL-19) H.R.8637 - To make protection against damage and loss resulting from the erosion and undermining of shorelines available under the National Flood Insurance Program, and for other purposes. (Greg Murphy, R-NC-3) S.4740 - A bill to amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets. (Thom Tillis, R-NC) S.4772 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) S.4934 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. (Rick Scott, R-FL) House Version: H.R.9411 - To amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. (Gus Bilirakis, R-FL-12) S.4969 - A bill to require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Martin Heinrich, D-NM) H.R.9414 - To require the Administrator of the Federal Emergency Management Agency to establish a community-based flood insurance pilot program, and for other purposes. (Andrew Garbarino, R-NY-12) H.R.9726 - To require the Administrator of the Federal Emergency Management Agency to develop a flood insurance information tool, and for other purposes. (Matt Cartwright, D-PA-8) S.5104 - A bill to amend the Federal Crop Insurance Act to reduce Federal spending on crop insurance, and for other purposes. (Jeanne Shaheen, D-NH) H.R.10543 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2)

American Family Act HR 3899; S.1992 - Child tax credits Social Security 2100 Act H.R. 4583; S. 2280 - Social Security Solvency No Tax Breaks for Outsourcing Act H.R. 774; S.357 - Making changes to various tax provisions that encourage offshoring of jobs No Tax Breaks for Union Busting Act H.R. 5456; S. 737 - Making changes to the tax code to disincentivize writing off expenses related to union busting taxes Billionaire Minimum Income Tax Act H.R. 6498 - Create new taxes billionaires Assuring Medicares Promise Act H.R. 34 - New taxes and changes to ensure Medicare solvency Social Security Expansion Act H.R. 1046; S. 393 - Expand social security benefits For the 99.5 Percent Act H.R. 2676; S. 1178 - Increase tax rates on decedent estates, gifts, and generation skipping transfers Ultra-Millionaire Tax Act H.R. 7749 - New taxes on ultrawealthy individuals Wall Street Tax Act H.R. 4870 - Create a 0.1% excise tax on certain financial transactions such as the purchase of stocks, bonds, and derivative Oligarch Act H.R. 4919 - Create a tax on the net value of all taxable assets of a taxpayer as of the last day of any calendar year Stop Subsidizing Multimillion Dollar Corporate Bonus Act H.R. 324; S. 3155 - Extend the $1 million limit on the deductibility of executive compensation to all employees of publicly traded corporations End Tax Breaks for Dark Money Act H.R. 7244; S. 3743 - Extends the capital gains tax on transfers of appreciated property to certain tax-exempt social organizations (e.g., civics leagues, agricultural organizations, or business leagues) End Polluter Welfare Act H.R. 9839 - Eliminates certain tax breaks and incentives for oil and gas companies Tax on Wall Street Speculation Act H.R. 4119; S. 1990 - Create an excise tax on the transfer of ownership in certain securities (covered transactions), including any share of stock in a corporation; any partnership or beneficial interest in a partnership or trust; any note, bond, debenture, or other evidence of indebtedness (excluding tax-exempt municipal bonds); and derivative financial instruments or digital assets End Oil & Gas Tax Subsidies Act H.R. 1483 - Limit or repeal certain fossil fuel oil and gas subsidies for oil companies. Tax Excessive CEO Pay Act H.R. 7041; S. 3620 - Increase the corporate income tax rate based on the ratio of compensation of principal executive officers or other highest compensated employees to median worker compensation Curtailing Executive Overcompensation Act H.R. 6191; S. 3176 - Create an excise tax on employers (i.e., business entities) that have at least a 50 to 1 disparity between the wages (including bonuses, stock awards and options) of chief executive officers and the wages paid to their workers. Applicable to employers that have not less than $100 million in annual gross receipts and $10 million in payroll over a 3 year period and limit such tax to 1% of an employer's gross receipts. Stop Corporate Inversions Act H.R. 8268 ; S. 4275 - Makes changes to corporate taxes to disincentivize offshoring CEO Accountability & Responsibility Act H.R. 1284 - Increases the corporate income tax rate for publicly traded corporations that pay their chief executive officers or highest paid employees more than 100 times the median compensation of all their U.S. employees or that increase the number of contracted or foreign employees. Ending Wall Street Tax Giveaway Act; H.R. 2686 - Modify the tax treatment of carried interest Medicare & Social Security Fair Share Act H.R. 4535 ; S. 1174 - Increase funding for the Social Security and Medicare trust funds by extending the payroll tax on wages, self-employment income, and investment income to taxpayers with earnings exceeding $400,000. Corporate Tax Dodging Prevention Act H.R. 7933; S. 4098 - Makes changes to prevent corporations dodging federal taxes American Innovation & Jobs Act H.R. 2673;S. 866 - Eliminate the five-year amortization requirement for research and experimental expenditures, thus allowing continued expensing of such expenditures in the taxable years in which they are incurred. Death Tax Repeal Act H.R. 7035; S. 1108 - Repeal of the estate and generation-skipping transfer taxes. It also sets forth conforming amendments related to the gift tax. Main Street Tax Certainty Act H.R. 4721; S. 1706 - Makes permanent the tax deduction for qualified business income TCJA Permanency Act H.R. 976 - Makes permanent the Tax Cuts and Jobs Act Saving Gig Economy Taxpayers Act H.R. 190 - This bill modifies requirements for third party settlement organizations to eliminate their reporting requirement with respect to the transactions of their participating payees unless they have earned more than $20,000 on more than 200 separate transactions in an applicable tax period. ALIGN Act H.R. 2406 - This bill makes permanent the expensing of certain new business equipment. Expensing allows the deduction of the full amount of an expense item in the same taxable year. FairTax Act H.R. 25 - This bill creates a national sales tax on the use or consumption in the United States of taxable property or services in lieu of the current income taxes, payroll taxes, and estate and gift taxes. Defending American Jobs & Investment Act H.R. 3665 - provides for the enforcement of remedies against foreign countries that have extraterritorial or discriminatory taxes. Small Business Growth Act H.R. 3661 - This bill increases from $1 million to $2 million to the limitation on expensing of depreciable business assets. It also increases the asset threshold amount used to reduce the expensing limitation. American Investment in Manufacturing Act H.R. 2788 - This bill makes permanent the allowance for depreciation, amortization, or depletion for purposes of determining the income limitation on the tax deduction for business interest. Permanently Repeal the Estate Tax Act H.R. 338 - Repeals the federal estate tax, effective for estates of decedents dying after December 31, 2022. Billionaires Income Tax Act - S. 3367 Imposes new taxes on taxpayers with high incomes Carried Interest Fairness Act - S. 4123 Eliminated Carried Interest loophole Paying a Fair Share Act S. 1173 - Requires an individual taxpayer whose adjusted gross income exceeds $1 million (high-income taxpayer) to pay a minimum tax rate of 30% of the excess of the taxpayer's adjusted gross income over the taxpayer's modified charitable contribution deduction for the taxable year (tentative fair share tax) Ending the Carried Interest Loophole Act S. 3317 - Ends the carried interest loophole Stock Buyback Accountability Act S. 413 - Increase stock buy back taxes Wall Street Tax Act S. 2491 - Create a 0.1% excise tax on certain purchases of stocks, bonds, and derivatives Stop Subsidizing Giant Mergers Act S.4011 - Eliminates the deferral of tax for shareholders who receive stock through corporate mergers, acquisitions, or transfers involving corporations with annual gross receipts exceeding $500 million over the three preceding taxable year period. Book Minimum Tax Repeal Act S. 1559 - Repeals the 15% alternative tax on the financial statement (i.e., book) income of certain corporations. The tax applies to companies that report over $1 billion in profits to their shareholders. Small Business Growth Act S. 2609 - This bill increases from $1 million to $2.5 million the limitation on expensing of depreciable business assets. It also increases the asset threshold amount used to reduce the expensing limitation. Carbon Aviation Tax Act S. 2378 - Imposes jet fuel taxes on private jets

H.J. Res. 148, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; H.R. 2673, American Innovation and R&D Competitiveness Act; H.R. 3210, Book Minimum Tax Repeal Act; H.R. 3938, Build It In America Act; H.R. 5564, REDUCE Act of 2023; H.R. 6454, Chemical Tax Repeal Act; H.R. 6532, Renewable Chemicals Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024; H.R. 8184, Growing and Preserving Innovation in America Act; H.R. 8773, Financial Services and General Government Appropriations Act, 2025; S.J. Res. 87, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; S. 866, American Innovation and Jobs Act; S. 1195, Chemical Tax Repeal Act; S. 1559, Book Minimum Tax Repeal Act; S. 2844, REDUCE Act of 2023; S. 3198, Foreign Pollution Fee Act; FY2025 Financial Services and General Government Appropriations Act; Implementation of the Superfund Tax on Chemicals; Tax Incentives and Rebates; Treaty Document 112-8, Tax Convention With Chile--Resolution of Advice and Consent;

Client expense: $6,530,000 · Firm income: Not reported

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting, including section 6045 broker basis reporting and digital asset basis tracking; Disaster relief, including the Federal Disaster Tax Relief Act of 2023 (H.R. 5863), Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815), the Casualty Loss Deduction Restoration Act (H.R. 4539), the Federal Disaster Responsibility Act (H.R. 5343 / S. 2721), and the Disaster Tax Lookback Parity Act of 2024 (H.R. 8007); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22), legislative proposals related to the farmers and fishers tax deadline, and additional administrative relief under section 7508A; Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, electronic filing, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), electronic transmission of Schedules K-1 to beneficiaries (Form 1041) and shareholders (Form 1120-S), IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708), the Tax Administration Simplification Act (H.R. 8864), and Improving IRS Customer Service Act (S. 5280); Trust and estate issues, including foreign trust reporting, domestic grantor trust reporting, generation-skipping transfer taxes, purpose trusts, gift tax returns, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700 / S. 443), credit for increasing research activities, and automatic changes in methods of accounting, including change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax (CAMT) and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559) and legislative proposals related to CAMT simplification, and section 1202 partial exclusion for gain from certain small business stock; Partnership taxation issues, including the centralized partnership audit regime, basis-shifting transactions; S corporation taxation issues, including inadvertent terminations, F reorganizations; Employee benefits tax issues, including implementation of and technical corrections to SECURE 2.0, remote work environment, the employee retention credit and the Employee Retention Tax Credit Repeal Act (S. 5079), and executive compensation, determination letter program, employee plans compliance resolution system; Exempt organization issues, including donor-advised funds, Form 990 series; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting, income and currency gain or loss, report of foreign bank and financial accounts reporting extensions for disasters, Form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund, and OECD Pillar One and Pillar Two issues; Individual tax issues, including section 461(l) excess business losses of noncorporate taxpayers, the Tax-Free Pell Grant Act (S. 2920), and section 280E; Taxpayer digital privacy issues; Beneficial ownership information reporting issues, including the Protecting Small Business Information Act of 2023 (H.R. 4035 / S. 2623); Emergency Capital Investment Program, Quarterly Supplemental Reporting; Taxpayer privacy.

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7360 Promoting Affordable Child Care for Everyone Act H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 H.R. 8540/S. 5254, Child Care for American Families Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Potential legislation similar to H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58 (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, October 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments (89 Fed. Reg. 64,750-64,778, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022 (89 Fed. Reg. 75,062-75,243, September 13, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Previously Taxed Earnings and Profits and Related Basis Adjustments (89 Fed. Reg. 95,362-95,464, Dec. 2, 2024) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; extraterritorial application of Sec. 49 of the German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act of 2022 (P.L. 117-169); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; Recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720); implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; tax policy priorities for 2025; proposal to repeal section 852(b)(6) of the Internal Revenue Code; instituting an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; extending the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, P.L. 115-97; Treasury regulations and other guidance related to the foreign tax credit; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; federal income tax treatment of employer-provided health insurance coverage; proposed amendment (I-735) to Frances 2025 budget to raise the countrys digital services tax rate from 3% to 5%; legal challenge against the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; child care related tax credits; dependent care assistance programs

Inflation Reduction Act Implementation S. 1559. Book Minimum Tax Repeal Act (Barrasso) HR 3210 Book Minimum Tax Repeal Act (Arrington)

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.7024 - the "Tax Relief for American Families and Workers Act of 2024"; H.R. 3210 and S 1559 - the "Book Minimum Tax Repeal Act," and legislative and regulatory matters affecting master limited partnerships and energy infrastructure companies, including H.R. 3690 and S.2641, the "Financing Our Energy Future Act".

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) Senate Version: S.3349 - A bill to prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. (Katie Britt, R-AL) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.5992 - To amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Josh Harder, D-CA-9) H.R.6082 - To amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (Andrew Garbarino, R-NY-2) Senate Version: S.3153 - A bill to amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.6186 - To amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. (Scott Franklin, R-FL-18) H.R.6304 - To increase coverage under the National Flood Insurance Program for costs of compliance, and for other purposes. (Nick LaLota, R-NY-1) S.3253 - A bill to amend the Federal Crop Insurance Act to require research and development on frost or cold weather insurance, and for other purposes. (Marco Rubio, R-FL) S.3270 - A bill to amend the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of 1994 to establish a budgetary Tribal Government consultation process at the Department of Agriculture, and for other purposes. (Mike Rounds, R-SD) H.R.6944 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. (Adam Schiff, D-CA-30) H.R.7000 - To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Bryan Steil, R-WI-1) Senate Version: S.3592 - A bill to amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Tim Scott, R-SC) S.3650 - A bill to amend the Biggert-Waters Flood Insurance Reform Act of 2012 to improve mapping under the National Flood Insurance Program, and for other purposes. (Marco Rubio, R-FL) H.R.7462 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Maxine Waters, D-CA-43) H.R.7537 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. (Madeleine Dean, D-PA-4) S.4081 - A bill to amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (John Hoeven, R-ND) House Version: H.R.8350 - To amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (Brad Finstad, R-MN-1) S.4143 - A bill to amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Rick Scott, R-FL) House Version: H.R.8102 - To amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Byron Donalds, R-FL-19) H.R.8637 - To make protection against damage and loss resulting from the erosion and undermining of shorelines available under the National Flood Insurance Program, and for other purposes. (Greg Murphy, R-NC-3) S.4740 - A bill to amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets. (Thom Tillis, R-NC) S.4772 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) S.4934 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. (Rick Scott, R-FL) House Version: H.R.9411 - To amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. (Gus Bilirakis, R-FL-12) S.4969 - A bill to require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Martin Heinrich, D-NM) H.R.9414 - To require the Administrator of the Federal Emergency Management Agency to establish a community-based flood insurance pilot program, and for other purposes. (Andrew Garbarino, R-NY-12) H.R.9726 - To require the Administrator of the Federal Emergency Management Agency to develop a flood insurance information tool, and for other purposes. (Matt Cartwright, D-PA-8) S.5104 - A bill to amend the Federal Crop Insurance Act to reduce Federal spending on crop insurance, and for other purposes. (Jeanne Shaheen, D-NH)

H.R. 889: Broadband Grant Tax Treatment Act; all provisions H.R. 2406: Accelerate Long-term Investment Growth Now (ALIGN) Act; provisions related to full expensing H.R. 2673: American Innovation and R&D Competitiveness Act of 2023; provisions related to research and development expensing H.R. 2788: AIM Act; provisions related to corporate interest deductibility H.R. 3938: Build it in America Act; extension of tax provisions related to full expensing, research and development expensing, and corporate interest deductibility H.R. 7024: Tax Relief for American Families and Workers Act of 2024; provisions related to tax reform, full expensing, research and development expensing, and corporate interest deductibility S. 341: Broadband Grant Tax Treatment Act; all provisions S. 866: American Innovation and Jobs Act; provisions related to research and experimentation expensing S. 1117: ALIGN Act; provisions related to full expensing S. 1232: AIM Act; provisions related to corporate interest deductibility S. 1559: Book Minimum Tax Repeal Act; all provisions Discussions related to 100% expensing bonus depreciation, research and experimentation costs, dividend taxation Discussions related to corporate income tax credits and corporate income tax rate Discussions related to Book Minimum Tax treatment of spectrum Discussions related to corporate alternative minimum tax guidance Discussions related to interest tax deduction limitation under 163(j) of the I.R.C.

Client expense: $2,600,000 · Firm income: Not reported

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) Senate Version: S.3349 - A bill to prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. (Katie Britt, R-AL) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.5992 - To amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Josh Harder, D-CA-9) H.R.6082 - To amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (Andrew Garbarino, R-NY-2) Senate Version: S.3153 - A bill to amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.6186 - To amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. (Scott Franklin, R-FL-18) H.R.6304 - To increase coverage under the National Flood Insurance Program for costs of compliance, and for other purposes. (Nick LaLota, R-NY-1) S.3253 - A bill to amend the Federal Crop Insurance Act to require research and development on frost or cold weather insurance, and for other purposes. (Marco Rubio, R-FL) S.3270 - A bill to amend the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of 1994 to establish a budgetary Tribal Government consultation process at the Department of Agriculture, and for other purposes. (Mike Rounds, R-SD) H.R.6944 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. (Adam Schiff, D-CA-30) H.R.7000 - To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Bryan Steil, R-WI-1) Senate Version: S.3592 - A bill to amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Tim Scott, R-SC) S.3650 - A bill to amend the Biggert-Waters Flood Insurance Reform Act of 2012 to improve mapping under the National Flood Insurance Program, and for other purposes. (Marco Rubio, R-FL) H.R.7462 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Maxine Waters, D-CA-43) H.R.7537 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. (Madeleine Dean, D-PA-4) S.4081 - A bill to amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (John Hoeven, R-ND) House Version: H.R.8350 - To amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (Brad Finstad, R-MN-1) S.4143 - A bill to amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Rick Scott, R-FL) House Version: H.R.8102 - To amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Byron Donalds, R-FL-19) H.R.8637 - To make protection against damage and loss resulting from the erosion and undermining of shorelines available under the National Flood Insurance Program, and for other purposes. (Greg Murphy, R-NC-3) S.4740 - A bill to amend the Internal Revenue Code of 1986 to exclude debt held by certain insurance companies from capital assets. (Thom Tillis, R-NC) S.4772 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) S.4934 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. (Rick Scott, R-FL) House Version: H.R.9411 - To amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. (Gus Bilirakis, R-FL-12) S.4969 - A bill to require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Martin Heinrich, D-NM) H.R.9414 - To require the Administrator of the Federal Emergency Management Agency to establish a community-based flood insurance pilot program, and for other purposes. (Andrew Garbarino, R-NY-12) H.R.9726 - To require the Administrator of the Federal Emergency Management Agency to develop a flood insurance information tool, and for other purposes. (Matt Cartwright, D-PA-8) S.5104 - A bill to amend the Federal Crop Insurance Act to reduce Federal spending on crop insurance, and for other purposes. (Jeanne Shaheen, D-NH)

H.J. Res. 148, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; H.R. 2673, American Innovation and R&D Competitiveness Act; H.R. 3210, Book Minimum Tax Repeal Act; H.R. 3938, Build It In America Act; H.R. 5564, REDUCE Act of 2023; H.R. 6454, Chemical Tax Repeal Act; H.R. 6532, Renewable Chemicals Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024; H.R. 8184, Growing and Preserving Innovation in America Act; H.R. 8773, Financial Services and General Government Appropriations Act, 2025; S.J. Res. 87, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; S. 866, American Innovation and Jobs Act; S. 1195, Chemical Tax Repeal Act; S. 1559, Book Minimum Tax Repeal Act; S. 2844, REDUCE Act of 2023; S. 3198, Foreign Pollution Fee Act; FY2025 Financial Services and General Government Appropriations Act; Implementation of the Superfund Tax on Chemicals; Tax Incentives and Rebates; Treaty Document 112-8, Tax Convention With Chile--Resolution of Advice and Consent;

Client expense: $5,830,000 · Firm income: Not reported

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 H.R.8540, Child Care for American Families Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58, (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, October 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property, (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750-64,778, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; Extraterritorial Application of Sec. 49 of the German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); implementation of the Inflation Reduction Act, (P.L. 117-169), including tax and energy security provisions; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; extending the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, Pub. L. No. 115-97; Treasury regulations and other guidance related to the foreign tax credit; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720); Turkeys new tax reform legislation

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting, including section 6045 broker basis reporting; Disaster relief, including the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815), the Casualty Loss Deduction Restoration Act (H.R. 4539), the Federal Disaster Responsibility Act (H.R. 5343 / S. 2721), and the Disaster Tax Lookback Parity Act of 2024 (H.R. 8007); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22), legislative proposals related to the farmers and fishers tax deadline; Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, electronic filing, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708), the Tax Administration Simplification Act (H.R. 8864), and Improving IRS Customer Service Act (S. 5280); Trust and estate issues, including foreign trust reporting, domestic grantor trust reporting, generation-skipping transfer taxes, purpose trusts, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700 / S. 443), credit for increasing research activities, and automatic changes in methods of accounting, including change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax (CAMT) and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559) and legislative proposals related to CAMT simplification; Partnership taxation issues, including the centralized partnership audit regime, basis-shifting transactions; S corporation taxation issues, including inadvertent terminations, F reorganizations; Employee benefits tax issues, including implementation of and technical corrections to SECURE 2.0, remote work environment, the employee retention credit and the Employee Retention Tax Credit Repeal Act (S. 5079), and executive compensation; Exempt organization issues, including donor-advised funds, Form 990 series; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting, income and currency gain or loss, report of foreign bank and financial accounts reporting extensions for disasters, and OECD Pillar One and Pillar Two issues; Individual tax issues, including section 461(l) excess business losses of noncorporate taxpayers; Taxpayer digital privacy issues; Beneficial ownership information reporting issues, including the Protecting Small Business Information Act of 2023 (H.R. 4035 / S. 2623); Emergency Capital Investment Program, Quarterly Supplemental Reporting; Taxpayer privacy.

H.R.7024 - the "Tax Relief for American Families and Workers Act of 2024"; H.R. 3210 and S 1559 - the "Book Minimum Tax Repeal Act," and legislative and regulatory matters affecting master limited partnerships and energy infrastructure companies, including H.R. 3690 and S.2641, the "Financing Our Energy Future Act".

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 220: Advanced Aviation Act; provisions related to the corporate tax rate H.R. 889: Broadband Grant Tax Treatment Act; all provisions H.R. 2406: Accelerate Long-term Investment Growth Now (ALIGN) Act; provisions related to full expensing H.R. 2673: American Innovation and R&D Competitiveness Act of 2023; provisions related to research and development expensing H.R. 2788: AIM Act; provisions related to corporate interest deductibility H.R. 3210: Book Minimum Tax Repeal Act; all provisions H.R. 3938: Build it in America Act; extension of tax provisions related to full expensing, research and development expensing, and corporate interest deductibility H.R. 7024: Tax Relief for American Families and Workers Act of 2024; provisions related to tax reform, full expensing, research and development expensing, and corporate interest deductibility S. 341: Broadband Grant Tax Treatment Act; all provisions S. 866: American Innovation and Jobs Act; provisions related to research and experimentation expensing S. 1117: ALIGN Act; provisions related to full expensing S. 1232: AIM Act; provisions related to corporate interest deductibility S. 1559: Book Minimum Tax Repeal Act; all provisions Discussions related to 100% expensing bonus depreciation, research and experimentation costs, dividend taxation Discussions related to corporate income tax credits and corporate income tax rate Discussions related to Book Minimum Tax treatment of spectrum Discussions related to corporate alternative minimum tax guidance Discussions related to interest tax deduction limitation under 163(j) of the I.R.C.

Client expense: $2,850,000 · Firm income: Not reported

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) Senate Version: S.3349 - A bill to prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. (Katie Britt, R-AL) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.5992 - To amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Josh Harder, D-CA-9) H.R.6082 - To amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (Andrew Garbarino, R-NY-2) Senate Version: S.3153 - A bill to amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.6186 - To amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. (Scott Franklin, R-FL-18) H.R.6304 - To increase coverage under the National Flood Insurance Program for costs of compliance, and for other purposes. (Nick LaLota, R-NY-1) S.3253 - A bill to amend the Federal Crop Insurance Act to require research and development on frost or cold weather insurance, and for other purposes. (Marco Rubio, R-FL) S.3270 - A bill to amend the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of 1994 to establish a budgetary Tribal Government consultation process at the Department of Agriculture, and for other purposes. (Mike Rounds, R-SD) H.R.6944 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. (Adam Schiff, D-CA-30) H.R.7000 - To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Bryan Steil, R-WI-1) Senate Version: S.3592 - A bill to amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Tim Scott, R-SC) S.3650 - A bill to amend the Biggert-Waters Flood Insurance Reform Act of 2012 to improve mapping under the National Flood Insurance Program, and for other purposes. (Marco Rubio, R-FL) H.R.7462 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Maxine Waters, D-CA-43) H.R.7537 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. (Madeleine Dean, D-PA-4) S.4081 - A bill to amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (John Hoeven, R-ND) House Version: H.R.8350 - To amend the Federal Crop Insurance Act to provide premium support for certain plans of insurance, and for other purposes. (Brad Finstad, R-MN-1) S.4143 - A bill to amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Rick Scott, R-FL) House Version: H.R.8102 - To amend the Internal Revenue Code of 1986 to provide an above-the-line deduction for flood insurance premiums. (Byron Donalds, R-FL-19) H.R.8637 - To make protection against damage and loss resulting from the erosion and undermining of shorelines available under the National Flood Insurance Program, and for other purposes. (Greg Murphy, R-NC-3)

H.J. Res. 148, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; H.R. 2673, American Innovation and R&D Competitiveness Act; H.R. 3210, Book Minimum Tax Repeal Act; H.R. 3938, Build It In America Act; H.R. 5564, REDUCE Act of 2023; H.R. 6454, Chemical Tax Repeal Act; H.R. 6532, Renewable Chemicals Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024; H.R. 8773, Financial Services and General Government Appropriations Act, 2025; S.J. Res. 87, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Treasury relating to "Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern"; S. 866, American Innovation and Jobs Act; S. 1195, Chemical Tax Repeal Act; S. 1559, Book Minimum Tax Repeal Act; S. 2844, REDUCE Act of 2023; Implementation of the Superfund Tax on Chemicals; Tax Incentives and Rebates; Treaty Document 112-8, Tax Convention With Chile--Resolution of Advice and Consent;

Client expense: $4,840,000 · Firm income: Not reported

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406/S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767/S. 1243, Small Business Investment Act of 2023 H.R. 2788/S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210/S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R. 5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 H.R. 7470, Secure U.S. Leadership in Space Act of 2024 H.R. 8184, Growing and Preserving Innovation in America Act of 2024 S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H.Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Internal Revenue Service (IRS), Treasury; Superfund Chemical Taxes (88 Fed. Reg. 18,446-18,471, March 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock; 26 CFR Parts 1 and 58 (89 Fed. Reg. 25,980-26,067, April 12, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions (88 Fed. Reg. 59,576-59,659, August 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, August 30, 2023) (as corrected by 88 Fed. Reg. 73,807, Oct. 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; Extraterritorial Application of Sec. 49 of the German Income Tax Act; the Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect (Bill C-59, Fall Economic Statement Implementation Act, 2023); potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement recommendations for Items to be Included on the 2024-2025 Priority Guidance Plan (Notice 2024-28); implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); UK Carbon Border Adjustment Mechanism (CBAM) Consultation; expiration of provisions from the 2017 Tax Cuts and Jobs Act; proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, Pub. L. No. 115-97; Treasury regulations and other guidance related to the foreign tax credit; U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One; proposed Article xx to U.N. Model Tax Convention on Dealing with Cross-Border Business Services; recommendations for Items to be Included on the Department of the Treasury and Internal Revenue Services 2024-2025 Priority Guidance Plan (I.R.S. Notice 2024-28, 2024-13 I.R.B. 720)

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification, tax reform, and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting, including section 6045 broker basis reporting; Disaster relief, including the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815), the Casualty Loss Deduction Restoration Act (H.R. 4539), the Federal Disaster Responsibility Act (H.R. 5343 / S. 2721), and the Disaster Tax Lookback Parity Act of 2024 (H.R. 8007); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22); Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, electronic filing, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708); Trust and estate issues, including foreign trust reporting, domestic grantor trust reporting, generation-skipping transfer taxes, purpose trusts, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700 / S. 443), credit for increasing research activities, and automatic changes in methods of accounting, including change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559); Partnership taxation issues, including the centralized partnership audit regime; S corporation taxation issues, including inadvertent terminations, F reorganizations; Employee benefits tax issues, including implementation of and technical corrections to SECURE 2.0, remote work environment, the employee retention credit, and executive compensation; Exempt organization issues, including donor-advised funds, Form 990 series; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting, income and currency gain or loss, report of foreign bank and financial accounts reporting extensions for disasters, and OECD Pillar One and Pillar Two issues; Individual tax issues, including section 461(l) excess business losses of noncorporate taxpayers; Taxpayer digital privacy issues; Beneficial ownership information reporting issues, including the Protecting Small Business Information Act of 2023 (H.R. 4035 / S. 2623); Emergency Capital Investment Program, Quarterly Supplemental Reporting; Taxpayer privacy.

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) Senate Version: S.3349 - A bill to prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. (Katie Britt, R-AL) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.5992 - To amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Josh Harder, D-CA-9) H.R.6082 - To amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (Andrew Garbarino, R-NY-2) Senate Version: S.3153 - A bill to amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.6186 - To amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. (Scott Franklin, R-FL-18) H.R.6304 - To increase coverage under the National Flood Insurance Program for costs of compliance, and for other purposes. (Nick LaLota, R-NY-1) S.3253 - A bill to amend the Federal Crop Insurance Act to require research and development on frost or cold weather insurance, and for other purposes. (Marco Rubio, R-FL) S.3270 - A bill to amend the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of 1994 to establish a budgetary Tribal Government consultation process at the Department of Agriculture, and for other purposes. (Mike Rounds, R-SD) H.R.6944 - To require the Secretary of the Treasury to establish a catastrophic property loss reinsurance program, and for other purposes. (Adam Schiff, D-CA-30) H.R.7000 - To amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Bryan Steil, R-WI-1) Senate Version: S.3592 - A bill to amend the Consumer Financial Protection Act of 2010 to clarify the authority of the Bureau of Consumer Financial Protection with respect to persons regulated by a State insurance regulator, and for other purposes. (Tim Scott, R-SC) S.3650 - A bill to amend the Biggert-Waters Flood Insurance Reform Act of 2012 to improve mapping under the National Flood Insurance Program, and for other purposes. (Marco Rubio, R-FL) H.R.7462 - To require the Government Accountability Office to conduct a study regarding insurance coverage for damages from wildfires, and for other purposes. (Maxine Waters, D-CA-43) H.R.7537 - To provide for the disclosure and sharing of certain policy and claims information under the National Flood Insurance Program, and for other purposes. (Madeleine Dean, D-PA-4)

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406 / S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767 / S. 1243, Small Business Investment Act of 2023 H.R. 2788 / S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210 / S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R. 5779, Fiscal Commission Act of 2023 H.R.5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act H.R. 7024, Tax Relief for American Families and Workers Act of 2024 S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H. Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service; Section 45X Advanced Manufacturing Production Credit (88 Fed. Reg. 86,844-86,868, December 15, 2023) Proposed Rule, Internal Revenue Service, Treasury Department; Advanced Manufacturing Investment Credit (88 Fed. Reg. 17,451-17,466, March 23, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, (88 Fed. Reg. 59,576-59,659, Aug. 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, Aug. 30, 2023) (as corrected by 88 Fed. Reg. 73,807, Oct. 27, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election To Treat Clean Hydrogen Production Facilities as Energy Property, REG-117631-23, (88 Fed. Reg. 89,220-89,255, Dec. 26, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; U.S. Chile Income Tax Treaty, Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital; Extraterritorial Application of Sec. 49 of the German Income Tax Act; the Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect (Bill C-59, Fall Economic Statement Implementation Act, 2023); potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax (AMT); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; recommendations for Items to be Included on the 2023-2024 Priority Guidance Plan (Notice 2023-36); implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; SECURE 2.0 Act Student Loan and Emergency Savings Guidance; Treasury regulations and other guidance related to the foreign tax credit; U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One

H.R. 2673, American Innovation and R&D Competitiveness Act; H.R. 3210, Book Minimum Tax Repeal Act; H.R. 3938, Build It In America Act; H.R. 5564, REDUCE Act of 2023; H.R. 6454, Chemical Tax Repeal Act; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; S. 866, American Innovation and Jobs Act; S. 1195, Chemical Tax Repeal Act; S. 1559, Book Minimum Tax Repeal Act; S. 2844, REDUCE Act of 2023; Implementation of the Superfund Tax on Chemicals; Tax Incentives and Rebates; Treaty Document 112-8, Tax Convention With Chile--Resolution of Advice and Consent;

Client expense: $4,930,000 · Firm income: Not reported

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting, including section 6045 broker basis reporting; Disaster relief, including the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815), the Casualty Loss Deduction Restoration Act (H.R. 4539), the Federal Disaster Responsibility Act (H.R. 5343 / S. 2721), and the Disaster Tax Lookback Parity Act of 2024; 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22); Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, electronic filing, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708); Trust and estate issues, including foreign trust reporting, domestic grantor trust reporting, generation-skipping transfer taxes, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700 / S. 443), credit for increasing research activities, and automatic changes in methods of accounting, including change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559); Partnership taxation issues; S corporation taxation issues, including inadvertent terminations, F reorganizations; Employee benefits tax issues, including implementation of and technical corrections to SECURE 2.0, remote work environment, the employee retention credit, and executive compensation; Exempt organization issues, including donor-advised funds; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting, income and currency gain or loss, report of foreign bank and financial accounts reporting extensions for disasters, and OECD Pillar One and Pillar Two issues; Individual tax issues, including section 461(l) excess business losses of noncorporate taxpayers; Taxpayer digital privacy issues; Beneficial ownership information reporting issues, including the Protecting Small Business Information Act of 2023 (H.R. 4035 / S. 2623); Emergency Capital Investment Program, Quarterly Supplemental Reporting; Taxpayer privacy.

-100% Expensing Tax Credit -State and Local Broadband Tax Litigation Legislation (Pre Introduction) -Taxes -100% Expensing [Bonus] Depreciation Tax Extenders (Expensing and R&D) -Corporate Income Tax Rates -Corporate Alternative Minimum Tax Guidance -Dividend Taxation -Book Minimum Tax Treatment on Spectrum -Expensing of Research and Experimentation Costs -Book Minimum Tax Repeal Act (H.R. 3210 & S. 1559) -Interest Tax Deduction Limitation under 163(j) of the I.R.C. -American Innovation and Jobs Act (Spectrum Issues and BEAD Program) (S. 866) -American Innovation and R&D Competitiveness Act of 2023 (House title); and American Innovation and Jobs Act (Senate Title) (H.R. 2673 & S.866) -Broadband Grant Tax Treatment Act (H.R.889 & S. 341) -Accelerate Long-term Investment Growth Now Act or the ALIGN Act" (HR 2406 & S. 1117) -AIM Act: American Investment in Manufacturing Act (H.R. 2788 & S. 1232) -Build It In America Act (H.R. 3938) (full expensing/bonus depreciation and R&E tax credit) -Book Minimum Tax Treatment of Employee Benefits -Fair Access to Interstate Remedies (discriminatory taxation and undue burdens on interstate commerce)

Client expense: $3,480,000 · Firm income: Not reported

General lobbying on the following issues: 100% expensing tax credit; state and local broadband tax litigation legislation (pre-introduction); extension of 100% expensing [bonus] depreciation; tax extenders (expensing and R&D); corporate income tax rates; corporate alternative minimum tax guidance; dividend taxation; book minimum tax treatment of spectrum; expensing/bonus depreciation of research and experimentation costs; book minimum tax treatment of employee benefits; fair access to interstate remedies (discriminatory taxation and undue burdens on interstate commerce); and interest tax deduction limitation under 163(j) of the I.R.C. Lobbying on the following specific legislation: S. 341/H.R. 889 - Broadband Grant Tax Treatment Act; S. 866 - American Innovation and Jobs Act and H.R. 2673 - American Innovation and Jobs Act (Spectrum and BEAD Program issues); S. 1117/H.R. 2406 - Accelerate Long-Term Investment Growth Now Act (ALIGN Act); H.R. 2788/S. 1232 - American Investment in Manufacturing (AIM) Act; H.R. 3210/S. 1559 - Book Minimum Tax Repeal Act; and H.R. 3938 - Build It In America Act (full expensing/bonus depreciation; and R&E tax credit).

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

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406 / S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767 / S. 1243, Small Business Investment Act of 2023 H.R. 2788 / S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210 / S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act H.R.5988/S. 3084, United States-Taiwan Expedited Double-Tax Relief Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H. Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Internal Revenue Service, Treasury Department; Advanced Manufacturing Investment Credit (88 Fed. Reg. 17,451-17,466, March 23, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Gross Proceeds and Basis Reporting by Brokers and Determination of Amount Realized and Basis for Digital Asset Transactions, (88 Fed. Reg. 59,576-59,659, Aug. 29, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018-60,054, Aug. 30, 2023)(as corrected by 88 Fed. Reg. 73,807, Oct. 27, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); 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; Extraterritorial Application of Sec. 49 German Income Tax Act; the Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect (Bill C-59, Fall Economic Statement Implementation Act, 2023); potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the excise tax on repurchase of corporate stock and corporate alternative minimum tax; repurchase of corporate stock and corporate alternative minimum tax; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; recommendations for Items to be Included on the 2023-2024 Priority Guidance Plan (Notice 2023-36); implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; Financial Accounting Standards Board (FASB) proposal to require greater income tax disclosures; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; IRS. Notice 2023-36, 2023-21 I.R.B. 855 (Public Recommendations Invited on Items to be Included on the 2023-2024 Priority Guidance Plan); Treasury regulations and other guidance related to the foreign tax credit; undue compliance burden (filing requirements) facing certain claimants of the employee retention credit; Financial Accounting Standards Board (FASB) Exposure Draft of Proposed Accounting Standards Update, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; improvements to the Child and Dependent Care Tax Credit, Dependent Care Assistance Program, and Employer Provided Child Care Tax Credit; Additional Interim Guidance Regarding the Application of the Corporate Alternative Minimum Tax under Sections 55, 56A, and 59 of the Internal Revenue Code, I.R.S. Notice 2023-64, 2023-40 I.R.B. 974 (Oct. 2, 2023); OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings draft Multilateral Convention to Implement Amount A of Pillar One

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) Senate Version: S.3349 - A bill to prohibit the Federal Insurance Office of the Department of the Treasury and other financial regulators from collecting data directly from an insurance company. (Katie Britt, R-AL) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.5992 - To amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Josh Harder, D-CA-9) H.R.6082 - To amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (Andrew Garbarino, R-NY-2) Senate Version: S.3153 - A bill to amend the National Flood Insurance Act of 1968 to establish a pilot program to increase the allowable amounts of advance payments under the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.6186 - To amend the Federal Crop Insurance Act to direct the Federal Crop Insurance Corporation to conduct research and development on frost or cold weather insurance, and for other purposes. (Scott Franklin, R-FL-18) H.R.6304 - To increase coverage under the National Flood Insurance Program for costs of compliance, and for other purposes. (Nick LaLota, R-NY-1) S.3253 - A bill to amend the Federal Crop Insurance Act to require research and development on frost or cold weather insurance, and for other purposes. (Marco Rubio, R-FL) S.3270 - A bill to amend the Federal Crop Insurance Reform and Department of Agriculture Reorganization Act of 1994 to establish a budgetary Tribal Government consultation process at the Department of Agriculture, and for other purposes. (Mike Rounds, R-SD)

H.R. 2673, American Innovation and R&D Competitiveness Act; H.R. 3210, Book Minimum Tax Repeal Act; H.R. 3938, Build It In America Act; H.R. 5564, REDUCE Act of 2023; S. 866, American Innovation and Jobs Act; S. 1195, Chemical Tax Repeal Act; S. 1559, Book Minimum Tax Repeal Act; S. 2844, REDUCE Act of 2023; Implementation of the Superfund Tax on Chemicals; Tax Incentives and Rebates; Treaty Document 112-8, Tax Convention With Chile--Resolution of Advice and Consent;

Client expense: $6,270,000 · Firm income: Not reported

-100% Expensing Tax Credit -State and Local Broadband Tax Litigation Legislation (Pre Introduction) -Taxes -100% Expensing [Bonus] Depreciation Tax Extenders (Expensing and R&D) -Corporate Income Tax Rates -Corporate Alternative Minimum Tax Guidance -Dividend Taxation -Book Minimum Tax Treatment on Spectrum -Expensing of Research and Experimentation Costs -Book Minimum Tax Repeal Act (H.R. 3210 & S. 1559) -Interest Tax Deduction Limitation under 163(j) of the I.R.C. -American Innovation and Jobs Act (Spectrum Issues and BEAD Program) (S. 866) -American Innovation and R&D Competitiveness Act of 2023 (House title); and American Innovation and Jobs Act (Senate Title) (H.R. 2673 & S.866) -Broadband Grant Tax Treatment Act (H.R.889 & S. 341) -Accelerate Long-term Investment Growth Now Act or the ALIGN Act" (HR 2406 & S. 1117) -AIM Act: American Investment in Manufacturing Act (H.R. 2788 & S. 1232) -Build It In America Act (H.R. 3938) (full expensing/bonus depreciation and R&E tax credit) -Book Minimum Tax Treatment of Employee Benefits -Fair Access to Interstate Remedies (discriminatory taxation and undue burdens on interstate commerce)

Client expense: $3,187,000 · Firm income: Not reported

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815), and the Casualty Loss Deduction Restoration Act (H.R. 4539), and the Federal Disaster Responsibility Act (H.R. 5343 / S. 2721); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22); Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708); Trust and estate issues, including foreign trust reporting, generation-skipping transfer taxes, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700 / S. 443), credit for increasing research activities, and automatic changes in methods of accounting, including change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559); Partnership taxation issues; S corporation taxation issues, including inadvertent terminations, F reorganizations; Employee benefits tax issues, including implementation of and technical corrections to SECURE 2.0, remote work environment, and the employee retention credit; Exempt organization issues; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting, and OECD Pillar One issues; Taxpayer digital privacy issues; Beneficial ownership information reporting issues, including the Protecting Small Business Information Act of 2023 (H.R. 4035 / S. 2623); Emergency Capital Investment Program, Quarterly Supplemental Reporting; Taxpayer privacy.

General lobbying on the following issues: 100% expensing tax credit; state and local broadband tax litigation legislation (pre-introduction); extension of 100% expensing [bonus] depreciation; corporate income tax rates; corporate alternative minimum tax guidance; dividend taxation; OECD tax proposals; book minimum tax treatment of spectrum; tax expensing; expensing/bonus depreciation of research and experimentation costs; and interest tax deduction limitation under section 163(j) of the I.R.C. Lobbying on the following specific legislation: S. 341/H.R. 889 - Broadband Grant Tax Treatment Act; S. 866/H.R. 2673 - American Innovation and Jobs Act (Spectrum and BEAD Program issues); S. 1117/H.R. 2406 - Accelerate Long-Term Investment Growth Now Act (ALIGN Act); H.R. 1123 - Understanding Cybersecurity of Mobile Networks Act; H.R. 2788/S. 1232 - American Investment in Manufacturing (AIM) Act; H.R. 3210/S. 1559 - Book Minimum Tax Repeal Act; and H.R. 3938 - Build It In America Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

-100% Expensing Tax Credit -State and Local Broadband Tax Litigation Legislation (Pre Introduction) -Taxes -100% Expensing [Bonus] Depreciation -Corporate Income Tax Rates -Corporate Alternative Minimum Tax Guidance -Dividend Taxation -OECD International Tax Proposals -Book Minimum Tax Treatment on Spectrum -Expensing of Research and Experimentation Costs -Book Minimum Tax Repeal Act (HR 3210 & S. 1559) -Interest Tax Deduction Limitation under 163(j) of the I.R.C. -American Innovation and Jobs Act (Spectrum Issues and BEAD Program) (S. 866) -American Innovation and R&D Competitiveness Act of 2023; and American Innovation and Jobs Act (HR 2673 & S.866) -Broadband Grant Tax Treatment Act (HR 889 & S. 341) -Accelerate Long-term Investment Growth Now Act or the ALIGN Act" (S. 1117 & HR 2406) -Full expensing, R&E expensing/bonus depreciation -AIM Act: American Investment in Manufacturing Act (HR 2788 & S. 1232) -Build It In America Act (HR 3938) -Tax expensing

Client expense: $2,972,060 · Firm income: Not reported

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA) H.R.4686 - To establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Anna Paulina Luna, R-FL-13) Senate Version: S.2852 - A bill to establish a grace period for nonpayment of premiums for flood insurance coverage under the national flood insurance program until the Administrator of the Federal Emergency Management Agency implements the option for monthly payment of such premiums, and for other purposes. (Rick Scott, R-FL) H.R.4762 - To amend title 49, United States Code, to extend the non-premium war risk insurance program. (Rudy Yakym, R-IN-2) S.2391 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA) H.R.4888 - To require certain insurance companies to disclose investments and underwriting that relate to coal mining and oil and gas extraction and fossil fuel extraction, and for other purposes. (Adam Schiff, D-CA-30) S.2458 - A bill to amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Amy Klobuchar, D-MN) S.2523 - A bill to amend the Federal Crop Insurance Act to require certain membership on the Board of Directors of the Federal Crop Insurance Corporation. (Tommy Tuberville, R-AL) S.2541 - A bill to amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to conduct research and development on the inclusion of certain oilseed crops in double cropping policies, and for other purposes. (Tommy Tuberville, R-AL) S.2643 - A bill to amend the Federal Crop Insurance Act to modify eligibility for prevented planting insurance under certain drought conditions, and for other purposes. (Ben Ray Lujan, D-NM) H.R.5535 - Insurance Data Protection Act (Scott Fitzgerald, R-WI-5) H.R.5828 - To reauthorize the National Flood Insurance Program. (Andrew Garbarino, R-NY-2) H.R.5843 - To temporarily extend the National Flood Insurance Program. (Clay Higgins, R-LA-3) S.2968 - A bill to reauthorize the National Flood Insurance Program. (John Kennedy, R-LA)

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406 / S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767 / S. 1243, Small Business Investment Act of 2023 H.R. 2788 / S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210 / S. 1559, Book Minimum Tax Repeal Act H.R. 4571, Child Care Investment Act of 2023 H.R. 4721/S. 1706, Main Street Tax Certainty Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 H. Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Draft legislation titled United States-Taiwan Expedited Double-Tax Relief Act Proposed Rule, Internal Revenue Service, Treasury Department; Advanced Manufacturing Investment Credit (88 Fed. Reg. 17,451-17,466, March 23, 2023) Proposed Rule, Department of the Treasury, Internal Revenue Service: Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements (88 Fed. Reg. 60,018, Aug. 30, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; The Government of Canadas revised legislative proposal for a unilateral, discriminatory digital services tax (DST) with retroactive effect; Canadian proposal to enact a retroactive Digital Services Tax (DST); 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; Extraterritorial Application of Sec. 49 German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the Excise tax on repurchase of corporate stock and corporate alternative minimum tax; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; recommendations for Items to be Included on the 2023-2024 Priority Guidance Plan (Notice 2023-36); implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; Financial Accounting Standards Board (FASB) proposal to require greater income tax disclosures; proposed Accounting Standards Update, Income Taxes (Topic 740); I.R.S. Notice 2023-36, 2023-21 I.R.B. 855 (Public Recommendations Invited on Items to be Included on the 2023-2024 Priority Guidance Plan); Treasury regulations and other guidance related to the foreign tax credit; undue compliance burden (filing requirements) facing certain claimants of the employee retention credit; Financial Accounting Standards Board (FASB) Exposure Draft of Proposed Accounting Standards Update, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; Additional Interim Guidance Regarding the Application of the Corporate Alternative Minimum Tax under Sections 55, 56A, and 59 of the Internal Revenue Code, I.R.S. Notice 2023-64, 2023-40 I.R.B.; improvements to the Child and Dependent Care Tax Credit, Dependent Care Assistance Program, and Employer Provided Child Care Tax Credit

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cuts and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief, including the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815), and the Casualty Loss Deduction Restoration Act (H.R. 4539); 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22); Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS strategic operating plan, contingency plan for possible government shutdown, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708); Trust and estate issues, including foreign trust reporting, generation-skipping transfer taxes, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700 / S. 443), and automatic changes in methods of accounting, including change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559); Partnership taxation issues; S corporation taxation issues, including inadvertent terminations, F reorganizations; Employee benefits tax issues, including implementation of and technical corrections to SECURE 2.0, remote work environment, and the employee retention credit; Exempt organization issues; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting; Taxpayer digital privacy issues; Beneficial ownership information reporting issues, including the Protecting Small Business Information Act of 2023 (H.R. 4035 / S. 2623); Emergency Capital Investment Program, Quarterly Supplemental Reporting; Taxpayer privacy.

H.R.274 - To require a report by the Comptroller General of the United States on a national all-hazards disaster insurance program. (Sheila Jackson Lee, D-TX-18) H.R.385 - To ban the imposition of any State or local liability insurance, tax, or user fee requirement for firearm or ammunition ownership or commerce. (Ronny Jackson, R-TX-13) H.R.900 - To amend the National Flood Insurance Act of 1968 to allow for the consideration of private flood insurance for the purposes of applying continuous coverage requirements, and for other purposes. (Kathy Castor, D-FL-14) H.R.1306 - To provide for greater transfer of risk under the National Flood Insurance Program to private capital and reinsurance markets, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1307 - To repeal the mandatory flood insurance coverage requirement for commercial properties located in flood hazard areas, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1308 - To allow communities to develop alternative flood insurance rate maps, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1309 - To require the use of replacement cost value in determining the premium rates for flood insurance coverage under the National Flood Insurance Act, and for other purposes. (Blaine Luetkemeyer, R-MO-3) H.R.1392 - To reauthorize the National Flood Insurance Program through December 31, 2024. (Warren Davidson, R-OH-8) H.R.1540 - To establish a means-tested assistance program for national flood insurance program policyholders, and for other purposes. (Matt Cartwright, D-PA-8) H.R.1545 - To amend the Internal Revenue Code of 1986 to exclude from gross income certain income from providing real propoerty insurance following certain federally declared disasters. (Clay Higgins, R-LA-3) S.601 - A bill to amend the National Flood Insurance Act of 1968 to modify the amount by which the chargeable risk premium rate for flood insurance under that Act may be increased in any year. (John Kennedy, R-LA) S.602 - A bill to require the Administrator of the Federal Emergency Management Agency to take certain actions relating to the National Flood Insurance Program. and for other purposes. (John Kennedy, R-LA) S.795 - A bill to amend the Federal Crop Insurance Act to improve education and risk management assistance, and for other purposes. (Chris Murphy, D-CT) S.721 - A bill to permit policyholders under the National Flood Insurance Program to elect to have previous premium rates remain in effect until the Administrator of the Federal Emergency Management Agency satisfies certain conditions, and for other purposes. (Cindy Hyde-Smith, R-MS) S.1039 - A bill to authorize the Administrator of the Federal Emergency Management Agency to terminate certain contracts on the basis of detrimental conduct to the National Flood Insurance Program, and for other purposes. (John Kennedy, R-LA) H.R.2458 - To amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to establish an emergency preparedness grant program for higher education institutions, and for other purposes. (Troy Carter, D-LA-2) H.R.2538 - To prohibit the sale of a firearm to, and the purchase of a firearm by, a person who is not covered by appropriate liability insurance coverage. (Mark Takano, D-CA-39) H.R.2542 - To preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. (Brandon Williams, R-NY-22) H.R.2568 - To provide for improvements to National Flood Insurance Program rate maps, and for other purposes. (Alex Mooney, R-WV-2) H.R.2933 - To eliminate the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ben Cline, R-VA-6) Senate Version: S.1694 - A bill to abolish the Federal Insurance Office of the Department of the Treasury, and for other purposes. (Ted Cruz, R-TX) H.R.2984 - To create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Nydia Velazquez, D-NY-7) Senate Version: S.1359 - A bill to create a safe harbor for insurers engaging in the business of insurance in connection with a cannabis-related legitimate business, and for other purposes. (Bob Menendez, D-NJ) H.R.3014 - To amend the Internal Revenue Code of 1986 to establish a system for the taxation of catastrophic risk transfer companies to ensure sufficient capital to cover catastrophic insurance losses, and for other purposes. (Darin LaHood, R-IL-16) S.1417 - A bill to amend the National Flood Insurance Act of 1968 to ensure community accountability for areas repeatedly damaged by floods, and for other purposes. (Tim Scott, R-SC) S.1427 - A bill to exempt certain entities from liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 with respect to releases of perfluoroalkyl and polyfluoroalkyl substances, and for other purposes. (Cynthia Lummis, R-WY) S.1539 - A bill to amend the Federal Crop Insurance Act and the Federal Agriculture Improvement and Reform Act of 1996 to make the native sod provisions applicable to the United States and to modify those provisions, and for other purposes. (John Thune, R-SD) H.R.3210 - To amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (Jodey Arrington, R-TX-19) Senate Version: S.1559 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. (John Barrasso, R-WY) S.1690 - A bill to amend the Federal Crop Insurance Act to establish a Good Steward Cover Crop program, and for other purposes. (Sherrod Brown, D-OH) H.R.3815 - To amend the Federal Crop Insurance Act to require the research and development of a policy to insure the production of mushrooms. (Chrissy Houlahan, D-PA-6) H.R.3880 - To prohibit private passenger automobile insurers from using certain income proxies to determine insurance rates and eligibility. (Bonnie Watson Coleman, D-NJ-12) H.R.3904 - To amend the Federal Crop Insurance Act to promote crop insurance support for beginning farmers and ranchers, and for other purposes. (Randy Feenstra, R-IA-4) S.1787 - A bill to amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. (Bob Menendez, D-NJ) H.R.3997 - To ensure the availability and affordability of homeowners' insurance coverage for catastrophic events. (Federica Wilson, D-FL-24) S.2035 - A bill to amend the Federal Agriculture Improvement and Reform Act of 1996 to make additional coverage under the Noninsured Crop Disaster Assistance Program available for crops and grasses used for grazing, and for other purposes. (Mike Rounds, R-SD) H.R.4308 - To amend the Federal Crop Insurance Act to require the Federal Crop Insurance Corporation to carry out research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Mike Thompson, D-CA-4) H.R.4349 - To reauthorize the National Flood Insurance Program, and for other purposes. (Frank Pallone, D-NJ-6) Senate Version: S.2142 - A bill to reauthorize the National Flood Insurance Program, and for other purposes. (Bob Menendez, D-NJ) S.2104 - A bill to amend the Federal Crop Insurance Act to allow for the separation of enterprise units by continuous and fallow cropping systems. (Roger Marshall, R-KS) S.2108 - A bill to amend the National Flood Insurance Act of 1968 to require that certain information is made publicly available, and for other purposes. (Rick Scott, R-FL) S.2109 - A bill to ensure that Write Your Own companies can sell private flood insurance products that compete with National Flood Insurance Program products. (Rick Scott, R-FL) S.2110 - A bill to allow National Flood Insurance Program policyholders who leave the program to purchase a private insurance flood policy to return to the National Flood Insurance Program without penalty, and for other purposes. (Rick Scott, R-FL) S.2134 - A bill to amend the Federal Crop Insurance Act to require research and development regarding a policy to insure wine grapes against losses due to smoke exposure, and for other purposes. (Alex Padilla, D-CA)

H.R. 515, Protecting American Savers and Retirees Act H.R. 976, TCJA Permanency Act H.R. 1010/S. 453, Prohibiting IRS Financial Surveillance Act H.R. 2406 / S. 1117, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 2673, American Innovation and R&D Competitiveness Act H.R. 2767 / S. 1243, Small Business Investment Act of 2023 H.R. 2788 / S. 1232, American Investment in Manufacturing (AIM) Act H.R. 3210 / S. 1559, Book Minimum Tax Repeal Act S. 866, American Innovation and Jobs Act S. 1457, Taiwan Tax Agreement Act of 2023 S. 1706, Main Street Tax Certainty Act of 2023 H. Res. 268, Expressing strong opposition to the imposition of digital services taxes by other countries that discriminate against United States companies Proposed Rule, Alcohol and Tobacco Tax and Trade Bureau; Consideration of Updates to Trade Practice Regulations (88 Fed. Reg. 1,171, January 9, 2023) Proposed Rule, Internal Revenue Service, Treasury Department; Advanced Manufacturing Investment Credit (88 Fed. Reg. 17,451-17,466, March 23, 2023) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canadian proposal to enact a retroactive Digital Services Tax (DST); 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; Extraterritorial Application of Sec. 49 German Income Tax Act; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the Inflation Reduction Act, (P.L. 117-169), including implementation of the Excise tax on repurchase of corporate stock and corporate alternative minimum tax; IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; recommendations for Items to be Included on the 2023-2024 Priority Guidance Plan (Notice 2023-36); proposal to repeal section 852(b)(6) of the Internal Revenue Code; proposal to institute an excise tax on stock buybacks; Financial Accounting Standards Board (FASB) proposal to require greater income tax disclosures; Treaty Document No. 112-8, Tax Convention with Chile; I.R.S. Notice 2023-36, 2023-21 I.R.B. 855 (Public Recommendations Invited on Items to be Included on the 2023-2024 Priority Guidance Plan); Treasury regulations and other guidance related to the foreign tax credit; undue compliance burden (filing requirements) facing certain claimants of the employee retention credit; Financial Accounting Standards Board (FASB) Exposure Draft of Proposed Accounting Standards Update, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cut and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815) and the Casualty Loss Deduction Restoration Act; 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22); Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS operational plan, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708); Trust and estate issues, including foreign trust reporting, generation-skipping transfer taxes, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700, S. 443), and automatic change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559); Partnership taxation issues; S corporation taxation issues, including inadvertent terminations; Employee benefits tax issues, including implementation of SECURE 2.0, remote work environment, and the employee retention credit; Exempt organization issues; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting; Taxpayer digital privacy issues; Taxpayer privacy.

General issues related to multiple areas of the tax law and code including: Legislative proposals on tax simplification and technical tax changes; Individual, S corporation, partnership, trust and estate implementation issues in the Tax Cut and Jobs Act, P.L.115-97, including SALT cap passthrough entity-level taxes; Virtual currency and digital assets reporting; Disaster relief the Filing Relief for Natural Disasters Act (H.R. 3861 / S. 1815) and the Casualty Loss Deduction Restoration Act; 529 plan expansion legislation, the Freedom to Invest in Tomorrows Workforce Act (H.R. 1477 / S. 7.22); Energy tax credits; Excise tax on repurchases of corporate stock; IRS priority guidance plan; E-signature; Tax administration issues, including appeals, first-time abatement penalty relief, regulation of tax return preparers, credit and refund lookback period, mailbox rule for electronic submissions and payments and the Electronic Communications Uniformity Act (S. 1338), IRS user fees, IRS Form 1099-K reporting and the Saving Gig Economy Taxpayers Act (H.R. 190) and the Red Tape Reduction Act (S. 1761), IRS operational plan, extension simplification and the Simplify Automatic Filing Extensions (SAFE) Act of 2023 (H.R. 3566), filing flexibility, quarterly estimated payments and the Tax Deadline Simplification Act (H.R. 3708); Trust and estate issues, including foreign trust reporting, generation-skipping transfer taxes, and section 645; Mobile workforce and state income tax simplification issues; State remote sales tax issues; Methods and periods issues, including section 174 research and experimentation expensing and the American Innovation and Jobs Act (S. 866) and the American Innovation and R&D Competitiveness Act of 2023 (H.R. 2673) and other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700, S. 443), and automatic change to required section 174 method; Corporate taxation issues, including the corporate alternative minimum tax and the Book Minimum Tax Repeal Act (H.R. 3210 / S. 1559); Partnership taxation issues; S corporation taxation issues, including inadvertent terminations; Employee benefits tax issues, including implementation of SECURE 2.0, remote work environment, and the employee retention credit; Exempt organization issues; International Code of Ethics for Professional Accountants (IESBA) rules on tax planning and related services; International tax issues, including dual residents reporting; Taxpayer digital privacy issues; Taxpayer privacy.