Book Minimum Tax Repeal Act

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act S.3432 - A bill to amend the Internal Revenue Code of 1986 to allow disaster-affected taxpayers to use preceding taxable year earned income to determine eligibility for the earned income credit and the refundable portion of the child tax credit. S.3497 - A bill to amend the Internal Revenue Code of 1986 to provide a credit against tax for disaster mitigation expenditures. H.R.7825 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. S.4502 - Farm Disaster Tax Cut Act

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1340/S. 3332, More Homes on the Market Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2854/S. 1686, Neighborhood Homes Investment Act H.R. 2940/S. 4506, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) H.R. 8624/S. 4463, Workforce Apprenticeship Growth and Education Support (WAGES) Act of 2026 H.R. 8714, Skill Savings Account Act of 2026 H.R. 8780, Critical Mineral and Extraction Tax Parity Act S. 796, Book Minimum Tax Repeal Act S. 1605, International Competition for American Jobs Act S. 3931, Taxpayer Assistance and Service (TAS) Act Potential legislation to extend and expand the advanced manufacturing investment credit in section 48D of the Internal Revenue Code Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, Sept. 13, 2024) (as corrected by 89 Fed. Reg. 104,909-104,915, Dec. 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Section 45Z Clean Fuel Production Credit, (91 Fed. Reg. 5,160-5,207, Feb. 4, 2026) Interim Guidance on Special Depreciation Allowance for Qualified Production Property, I.R.S. Notice 2026-16, 2026-11 I.R.B. 685 Recommendations for Items to be Included on the 2026-2027 Priority Guidance Plan, I.R.S. Notice 2026-23, 2026-15 I.R.B. 804 Various issues relating to implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (Pub. L. 119-21); Internal Revenue Code; clean fuel production credit section 45Z; implementation of the Inflation Reduction Act of 2022 (P. L. 117-169); Department of the Treasurys approach to tax deregulation; implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos global minimum tax rules; Government of Belgiums consideration of a digital services tax; extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; renewed multilateral dialogue on the taxation of the digital economy; withdrawal or suspension of the Financial Accounting Standards Boards Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP)

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2940, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6956/S. 452, BARCODE Efficiency Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) S. 796, Book Minimum Tax Repeal Act S. 1605, International Competition for American Jobs Act S. 4071, Child Care Tax Benefit Outreach and Assistance Act H.J. Res. 142/S.J. Res. 102, Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, Sept. 13, 2024) (as corrected by 89 Fed. Reg. 104,909-104,915, Dec. 26, 2024) Various issues relating to potential modifications to the gasoline tax, including waiving or temporary suspension; implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (P.L. 119-21); implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 (P.L. 119-78); implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos global minimum tax rules; Undertaxed Profit Rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; Polish Ministry of Digital Affairs proposal to adopt a discriminatory 3% digital services tax (DST) on select sectors of the digital economy; the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; renewed multilateral dialogue on the taxation of the digital economy; addressing the tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP); Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2940, Advancing Water Reuse Act H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6956/S. 452, BARCODE Efficiency Act H.R. 7450/S. 3605, Disaster Zone Energy Affordability and Investment Act H.R. 8101/S. 4221, Ensuring Better Interest Treatment and Deductibility Act (EBITDA) S. 796, Book Minimum Tax Repeal Act S. 1605, International Competition for American Jobs Act S. 4071, Child Care Tax Benefit Outreach and Assistance Act H.J. Res. 142/S.J. Res. 102, Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, Sept. 13, 2024) (as corrected by 89 Fed. Reg. 104,909-104,915, Dec. 26, 2024) Various issues relating to potential modifications to the gasoline tax, including waiving or temporary suspension; implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (P.L. 119-21); implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of Disapproving the action of the District of Columbia Council in approving the D.C. Income and Franchise Tax Conformity and Revision Temporary Amendment Act of 2025 (P.L. 119-78); implementation of the OECD-brokered side-by-side arrangement to exempt U.S.-headquartered companies from Pillar Twos global minimum tax rules; Undertaxed Profit Rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; Polish Ministry of Digital Affairs proposal to adopt a discriminatory 3% digital services tax (DST) on select sectors of the digital economy; the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; renewed multilateral dialogue on the taxation of the digital economy; addressing the tax audit and enforcement practices of Mexicos Tax Administration Service (SAT) and Italys Milan Public Prosecutor (MPP); Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

**Issues lobbied without specific bill number: Corporate Alternative Minimum Tax **Issues lobbied without specific bill number: Implementation of Inflation Reduction Act **Issues lobbied without specific bill number: TCJA **Issues lobbied without specific bill number: Third Party Litigation Financing Tax on Any Income Derived from that Kind of Litigation Funding S. 35 An Above the Line Deduction for Certain Homeowner Insurance Premiums S. 336 To Exclude from Gross Income Amount Received from State-based Catastrophe Loss Mitigation Programs H.R. 1070 To Exclude from Gross Income Certain Income from Providing Real Property Insurance Following Certain Federally Declared Disasters H.R. 948 To Provide a Refundable Credit Against Tax for Wildfire Mitigation Expenditures S. 586 A Refundable Credit to Offset Flood Insurance Premiums H.R. 1481 To Ensure Sufficient Capital to Cover Catastrophic Insurance Losses S. 796 To Repeal the Corporate Alternative Minimum Tax H.R. 1849 To Provide for the Exclusion from Gros Income of Amounts Received from State-based Catastrophe Loss Mitigation Programs S. 1323 Tax Treatment for Disaster Mitigation

Client expense: $1,440,000 · Firm income: Not reported

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act S.3432 - A bill to amend the Internal Revenue Code of 1986 to allow disaster-affected taxpayers to use preceding taxable year earned income to determine eligibility for the earned income credit and the refundable portion of the child tax credit. S.3497 - A bill to amend the Internal Revenue Code of 1986 to provide a credit against tax for disaster mitigation expenditures. H.R.7825 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes.

**Issues lobbied without specific bill number: Corporate Alternative Minimum Tax **Issues lobbied without specific bill number: Implementation of Inflation Reduction Act **Issues lobbied without specific bill number: TCJA **Issues lobbied without specific bill number: Third Party Litigation Financing Tax on Any Income Derived from that Kind of Litigation Funding S. 35 An Above the Line Deduction for Certain Homeowner Insurance Premiums S. 336 To Exclude from Gross Income Amount Received from State-based Catastrophe Loss Mitigation Programs H.R. 1070 To Exclude from Gross Income Certain Income from Providing Real Property Insurance Following Certain Federally Declared Disasters H.R. 948 To Provide a Refundable Credit Against Tax for Wildfire Mitigation Expenditures S. 586 A Refundable Credit to Offset Flood Insurance Premiums H.R. 1481 To Ensure Sufficient Capital to Cover Catastrophic Insurance Losses S. 796 To Repeal the Corporate Alternative Minimum Tax H.R. 1849 To Provide for the Exclusion from Gros Income of Amounts Received from State-based Catastrophe Loss Mitigation Programs S. 1323 Tax Treatment for Disaster Mitigation

Client expense: $1,400,000 · Firm income: Not reported

**Issues lobbied without specific bill number: Corporate Alternative Minimum Tax **Issues lobbied without specific bill number: Implementation of Inflation Reduction Act **Issues lobbied without specific bill number: TCJA **Issues lobbied without specific bill number: Third Party Litigation Financing Tax on Any Income Derived from that Kind of Litigation Funding S. 35 An Above the Line Deduction for Certain Homeowner Insurance Premiums S. 336 To Exclude from Gross Income Amount Received from State-based Catastrophe Loss Mitigation Programs H.R. 1070 To Exclude from Gross Income Certain Income from Providing Real Property Insurance Following Certain Federally Declared Disasters H.R. 948 To Provide a Refundable Credit Against Tax for Wildfire Mitigation Expenditures S. 586 A Refundable Credit to Offset Flood Insurance Premiums H.R. 1481 To Ensure Sufficient Capital to Cover Catastrophic Insurance Losses S. 796 To Repeal the Corporate Alternative Minimum Tax H.R. 1849 To Provide for the Exclusion from Gros Income of Amounts Received from State-based Catastrophe Loss Mitigation Programs S. 1323 Tax Treatment for Disaster Mitigation

Client expense: $1,410,000 · Firm income: Not reported

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2777/S. 1371, S-CAP Act of 2025 H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6231/S. 5370, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 6506, Taxpayer Due Process Enhancement Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Child Care Tax Benefit Outreach and Assistance Act Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) as corrected by (87 Fed. Reg. 45,018-45,021, July 27, 2022) 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)(as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Certain Disregarded Payments and Dual Consolidated Losses, T.D. 10026, (90 Fed. Reg. 3,003-3,021, January 14, 2025) Various issues relating to conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; 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, (P.L. 117-169); implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (Pub. L. No. 119-21); 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); IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); potential U.S. legislative and administrative responses 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; advancing the proposed side-by-side solution described in the G7 Statement on Global Minimum Taxes of June 28, 2025; withdrawal or suspension of the Financial Accounting Standards Boards Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; opposing the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; tax enforcement practices of Mexicos Tax Administration Service; Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

S 796 Book Minimum Tax Repeal Act; draft legislation in Senate as finance companion to HR 1; Fed. Reg. Notice 2026-1: Safe Harbor for the Credit for Carbon Oxide Sequestration under Section 45Q for Qualified Carbon Oxide Disposed of in Secure Geological Storage in Calendar Year 2025; 84 Fed. Reg. 29288 Guidance Related to Section 951A (Global Intangible Low-Taxed Income) and Certain Guidance Related to Foreign Tax Credits; 89 Fed. Reg. 75062 Corporate Alternative Minimum Tax Applicable After 2022.

Client expense: $1,920,000 · Firm income: Not reported

Government targets: SENATE, Treasury, Dept of

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act S.3432 - A bill to amend the Internal Revenue Code of 1986 to allow disaster-affected taxpayers to use preceding taxable year earned income to determine eligibility for the earned income credit and the refundable portion of the child tax credit. S.3497 - A bill to amend the Internal Revenue Code of 1986 to provide a credit against tax for disaster mitigation expenditures.

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.5225 - To amend the Internal Revenue Code of 1986 to exclude qualified wildfire relief payments from gross income, and for other purposes. H.R.4861 - Working Waterfront Disaster Mitigation Tax Credit Act

Client expense: $442,147 · Firm income: Not reported

H.R. 1, One Big Beautiful Bill Act H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1639, American Innovation and Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act S. 1821, Tackling Predatory Litigation Funding Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation responding to the Supreme Court of the United States decision in Commissioner v. Zuch Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) (as corrected by 87 Fed. Reg. 45,018-45,021, July 27, 2022) 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, 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) (as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions (90 Fed. Reg. 3,075-3,085, January 14, 2025) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; 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, (P.L. 117-169); 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); IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); 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 and administrative responses 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; federal income tax treatment of employer-provided health insurance coverage; challenging the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; realizing the proposed side-by-side solution described in the G7 Statement on Global Minimum Taxes of June 28, 2025; delay or withdrawal of Financial Accounting Standards Boards (FASB) ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; opposing the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; potential inclusion of Tackling Predatory Litigation Funding Act in Senate Finance Committees budget reconciliation (section 70605)

**Issues lobbied without specific bill number: Corporate Alternative Minimum Tax **Issues lobbied without specific bill number: Implementation of Inflation Reduction Act **Issues lobbied without specific bill number: TCJA **Issues lobbied without specific bill number: Third Party Litigation Financing Tax on Any Income Derived from that Kind of Litigation Funding S. 35 An Above the Line Deduction for Certain Homeowner Insurance Premiums S. 336 To Exclude from Gross Income Amount Received from State-based Catastrophe Loss Mitigation Programs H.R. 1070 To Exclude from Gross Income Certain Income from Providing Real Property Insurance Following Certain Federally Declared Disasters H.R. 948 To Provide a Refundable Credit Against Tax for Wildfire Mitigation Expenditures S. 586 A Refundable Credit to Offset Flood Insurance Premiums H.R. 1481 To Ensure Sufficient Capital to Cover Catastrophic Insurance Losses S. 796 To Repeal the Corporate Alternative Minimum Tax H.R. 1849 To Provide for the Exclusion from Gros Income of Amounts Received from State-based Catastrophe Loss Mitigation Programs S. 1323 Tax Treatment for Disaster Mitigation

Client expense: $1,410,000 · Firm income: Not reported

HR 5376 Inflation Reduction Act of 2022 (tax provisions related to the oil and gas industry; Part 1- Corporate Tax Reform); S 796 Book Minimum Tax Repeal Act; draft legislation that would allow for the expensing of the intangible drilling costs under the corporate alternative minimum tax; draft legislation in Senate as finance companion to HR 1 (provisions related to tax section of HR 1). Proposed IRS provisions for implementation of HR 1 related to self-created property and Sec. 168.

Client expense: $1,920,000 · Firm income: Not reported

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

S. 796 - the "Book Minimum Tax Repeal Act," and legislative and regulatory matters affecting master limited partnerships and energy infrastructure companies.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

**Issues lobbied without specific bill number: Corporate Alternative Minimum Tax **Issues lobbied without specific bill number: Implementation of Inflation Reduction Act **Issues lobbied without specific bill number: TCJA **Issues lobbied without specific bill number: Third Party Litigation Financing Tax on Any Income Derived from that Kind of Litigation Funding S. 35 An Above the Line Deduction for Certain Homeowner Insurance Premiums S. 336 To Exclude from Gross Income Amount Received from State-based Catastrophe Loss Mitigation Programs H.R. 1070 To Exclude from Gross Income Certain Income from Providing Real Property Insurance Following Certain Federally Declared Disasters H.R. 948 To Provide a Refundable Credit Against Tax for Wildfire Mitigation Expenditures S. 586 A Refundable Credit to Offset Flood Insurance Premiums H.R. 1481 To Ensure Sufficient Capital to Cover Catastrophic Insurance Losses S. 796 To Repeal the Corporate Alternative Minimum Tax H.R. 1849 To Provide for the Exclusion from Gros Income of Amounts Received from State-based Catastrophe Loss Mitigation Programs S. 1323 Tax Treatment for Disaster Mitigation

Client expense: $1,740,000 · Firm income: Not reported

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures. H.R.3512 - To amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. S.1821 - A bill to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation. H.R.3975 - To amend the Internal Revenue Code of 1986 to provide a lookback rule in the case of certain federally declared disasters for amounts related to earned income for purposes of determining certain tax credits. S.1940 - A bill to amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts. H.R.1 - One Big Beautiful Bill Act -To provide for reconciliation pursuant to title II of H. Con. Res. 14. under tax. S.35 - A bill to amend the Internal Revenue Code of 1986 to create an above the line deduction for certain homeowners insurance premiums. H.R.440 - To amend the Internal Revenue Code of 1986 to provide for Residential Emergency Asset-accumulation Deferred Taxation Yield (READY) accounts.

Client expense: $435,663 · Firm income: Not reported

H.R. 1, One Big Beautiful Bill Act H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 3512/S. 1821, Tackling Predatory Litigation Funding Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 847, Child Care Availability and Affordability Act S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1639, American Innovation and Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.Con.Res. 14, Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034 H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act Nomination of Billy Long to be Commissioner of the Internal Revenue Service (IRS) Nomination of Kenneth Kies to be Assistant Treasury Secretary for Tax Policy Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) as corrected by (87 Fed. Reg. 45,018-45,021, July 27, 2022) 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, 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) (as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions (90 Fed. Reg. 3,075-3,085, January 14, 2025) 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; 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, (P.L. 117-169); 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); expiration of provisions from the 2017 Tax Cuts and Jobs Act; tax policy priorities for 2025; excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; inclusion of Section 45Q - Credit for Carbon Oxide Sequestration under the Inflation Reduction Act of 2022 (P.L. 117-169) in FY25 Budget; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); 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; Federal income tax treatment of employer-provided health insurance coverage; challenging 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; proposals for third party litigation funders to pay tax on their income at the ordinary income tax rate plus a surcharge

HR 1 One Big Beautiful Bill Act (provisions related to Titles IV, VIII, XI, and the energy industry); HR 5376 Inflation Reduction Act of 2022 (tax provisions related to the oil and gas industry); S 1605 International Competition for American Jobs Act; S 187 ALIGN Act; S 224 Promoting Domestic Energy Production Act; S 796 Book Minimum Tax Repeal Act; draft legislation that would allow for the expensing of intangible drilling costs under the corporate alternative minimum tax; efforts related to Internal Revenue Code Sections 45Q, 45V and 45Z.

Client expense: $2,070,000 · Firm income: Not reported

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

H.R. 1 - the "One Big Beautiful Bill Act," S. 796 - the "Book Minimum Tax Repeal Act," H.R. 703 and S.213 - the "Main Street Tax Certainty Act," and legislative and regulatory matters affecting master limited partnerships and energy infrastructure companies, including H.R. 2545 and S. 510 - the "Financing Our Energy Future Act."

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

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

S.336 - A bill to amend the Internal Revenue Code of 1986 to exclude from gross income amounts received from State-based catastrophe loss mitigation programs. S.796 - A bill to amend the Internal Revenue Code of 1986 to repeal the corporate alternative minimum tax. H.R.948 - To amend the Internal Revenue Code of 1986 to provide a refundable credit against tax for wildfire mitigation expenditures.

Client expense: $424,512 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

**Issues lobbied without specific bill number: Corporate Alternative Minimum Tax **Issues lobbied without specific bill number: Implementation of Inflation Reduction Act **Issues lobbied without specific bill number: TCJA **Issues lobbied without specific bill number: Third Party Litigation Financing Tax on Any Income Derived from that Kind of Litigation Funding S. 35 An Above the Line Deduction for Certain Homeowner Insurance Premiums S. 336 To Exclude from Gross Income Amount Received from State-based Catastrophe Loss Mitigation Programs H.R. 1070 To Exclude from Gross Income Certain Income from Providing Real Property Insurance Following Certain Federally Declared Disasters H.R. 948 To Provide a Refundable Credit Against Tax for Wildfire Mitigation Expenditures S. 586 A Refundable Credit to Offset Flood Insurance Premiums H.R. 1481 To Ensure Sufficient Capital to Cover Catastrophic Insurance Losses S. 796 To Repeal the Corporate Alternative Minimum Tax H.R. 1849 To Provide for the Exclusion from Gros Income of Amounts Received from State-based Catastrophe Loss Mitigation Programs

Client expense: $1,290,000 · Firm income: Not reported

H.Con.Res.14, Establishing the congressional budget for the United States Government for the fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034; H.R.137, TCJA Permanency Act; H.R.591, Defending American Jobs and Investment Act; H.R.640, Chemical Tax Repeal Act; H.R.1778, American Innovation Act of 2025; H.R.1990, American Innovation and R&D competitiveness act of 2025; House Concurrent Res. 14 - budget resolution; Senate Concurrent Res. 7 - budget resolution; S.615, Chemical Tax Repeal Act; S.796, Book Minimum Tax Repeal Act; Business State and local tax exemption; IRA Energy Efficiency Tax Credits 25C, 45L, 179D; IRA energy tax credits 45V, 45Q, and 48C IRA domestic manufacturing tax credits 48D and 45X Preserve 501 (c) entities tax exemption

Client expense: $4,190,000 · Firm income: Not reported

HR 1141 Natural Gas Tax Repeal Act; HR 5073 Promoting Domestic Energy Production Act; HR 5376 Inflation Reduction Act of 2022 (tax provisions related to the oil and gas industry); S 187 ALIGN Act; S 224 Promoting Domestic Energy Production Act; S 796 Book Minimum Tax Repeal Act; draft Fiscal Year 2025 Budget Resolution (provisions relating to tax); efforts related to Internal Revenue Code Sections 45Q, 45V and 45Z; efforts related to international tax reform; efforts related to retention of corporate tax provisions in 2025 legislation.

Client expense: $1,920,000 · Firm income: Not reported

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

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1827, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089, Generating Retirement Ownership through Long-Term Holding S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 847, Child Care Availability and Affordability Act S. 1559, Book Minimum Tax Repeal Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act 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)(as corrected by 89 Fed. Reg. 104,909, December 26, 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, December 2, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions, (90 Fed. Reg. 3,075-3,085, January 14, 2025) 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, (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 2024-2025 Priority Guidance Plan (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; excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; inclusion of Section 45Q - Credit for Carbon Oxide Sequestration under the Inflation Reduction Act of 2022 (P.L. 117-169) in FY25 Budget; permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.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; Federal income tax treatment of employer-provided health insurance coverage; challenging 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

S. 796 - the "Book Minimum Tax Repeal Act," H.R. 703 and S.213 - the "Main Street Tax Certainty Act," and legislative and regulatory matters affecting master limited partnerships and energy infrastructure companies, including H.R. 2545 and S. 510 - the "Financing Our Energy Future Act."

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

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