EDWARD KARL

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.

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.

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 and draft legislation of the Filing Relief for Natural Disasters Act; 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, IRS user fees, IRS Form 1099-K reporting, IRS operational plan, extension simplification, filing flexibility; Trust and estate issues, including foreign trust reporting, 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 other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700, S. 443); Corporate taxation issues, including the corporate alternative minimum tax; 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 tax issues, including dual residents reporting.

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.

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.

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 and draft legislation of the Filing Relief for Natural Disasters Act; 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, IRS user fees, IRS Form 1099-K reporting, IRS operational plan, extension simplification, filing flexibility; Trust and estate issues, including foreign trust reporting, 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 other expired and expiring provisions, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 700, S. 443); Corporate taxation issues, including the corporate alternative minimum tax; 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 tax issues, including dual residents reporting.

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.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties; IRS Form 1099-K reporting; Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, trust and estate income tax form e-filing, generation-skipping transfer tax and gift tax forms and instructions improvements, section 2053, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax, updated Schedule UTP on uncertain tax positions; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, Form 990-PF required disclosures, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Individual tax issues, including virtual currency reporting; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate reconciliation language released July 27, 2022, Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, nonqualified deferred compensation, rules on partnership interests held in connection with the performance of services, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); and Enhancing American Retirement Now (EARN) Act (S. 4808); Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including IRS Priority Practitioner Service line; Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS; third-party relationships office; federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R. 2437; penalty relief, H.R. 5155; IRS services; e-filing issues; quarterly payment deadlines; tax filing season and recommendations to reduce the backlog, including continued use of surge teams, suspending and keeping suspended automated notices, and offering, extending and expanding scope of broad penalty relief; Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including portability election simplified method timing extension, foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, generation-skipping transfer tax and gift tax forms and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates, electronic filing of estate and gift tax returns, reporting of estimated total value of trust assets; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss, and the corporate alternative minimum tax; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International tax issues, including form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 245A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); Guidance under section 1202 regarding Qualified Small Business Stock; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief, timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers; Exempt organization issues, including group rulings; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, and section 254A.

General issues related to multiple areas of the tax law and code including: Compendium of tax legislative proposals, including employee benefits, individual income tax, tax administration, partnerships, trust, estate and gift tax, corporations and shareholders, tax methods and periods, and international tax related issues. Tax provisions in Senate Finance Committee reconciliation legislation released on December 11, 2021, tax provisions in House Managers amendment to Rules Committee reconciliation legislation, and tax provisions in House reconciliation legislation (H.R.5376, the Build Back Better Act) including: individual tax provisions, employer-provided dependent care assistance exclusion, temporary rule to allow certain S corporations to reorganize as partnerships tax free, section 174 amortization deferral, international tax provisions, section 199A, section 461(l), section 162(m), employee benefits tax provisions, trust and estate tax provisions, certain losses under section 165(g), limitation on certain special rules for section 1202 gains, modification of procedural requirements relating to assessment of penalties, IRS regulation of paid tax return preparers, financial account reporting to improve tax compliance, IRS funding, structural changes to subchapter K (partnership taxation), corporation alternative minimum tax, and nonqualified deferred compensation, and effective dates. Coronavirus Pandemic (COVID-19), including the American Rescue Plan Act of 2021, P.L. 117-2; Consolidated Appropriations Act, 2021, P.L. 116- 260; The Coronavirus Aid, Relief and Economic Security Act, P. L. 116-136, and the Infrastructure Investment and Jobs Act, P.L. 117-58, specifically the employee retention credit, impact of paycheck protection program (PPP) expense deductibility loan forgiveness on basis of passthrough entities, section 501(c)(6) and PPP loans, COBRA premium tax credit, paid sick and family leave credits, self-employment tax deferral; Individual, corporate and S corporation tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, electing small business trusts, qualified business income deduction, SALT cap passthrough entity-level taxes, global intangible low-taxed income, excess business losses, losses on worthless stock, corporate book minimum tax, trust and estate tax issues; Disaster relief, Filing Relief for Natural Disasters Act (H.R. 3574, S. 2748); Claiming Losses After Disasters Act (S. 3173); Disaster Retirement Savings Act (S. 2583); ); and Enhancing American Retirement Now (EARN) Act; Guidance under section 1202 regarding Qualified Small Business Stock; IRS priority guidance plan; E-signature; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25; organization of the IRS, third-party relationships office, federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief H.R. 5155, IRS services, e-filing issues, quarterly payment deadlines, tax filing season and recommendations to reduce backlog, including suspending automated notices and offering broad penalty relief: Tax Deadline Simplification Act of 2021, H.R.4214; regulation of tax return preparers, Taxpayer Protection and Preparer Proficiency Act, H.R. 4184 (117th) / S. 1192 (116th); financial account reporting requirements; modification of procedural requirements to assess penalties. Trust and estate issues, including foreign trusts filing penalties and withholding credit for U.S. beneficiaries of a foreign trust, estate closing letters, gift tax form and instructions improvements, grantor letters, valuation discounts, grantor trusts, estates, and surcharge on trusts and estates; Mobile workforce and state income tax simplification issues, Remote and Mobile Worker Relief Act of 2021 (S. 1274), Mobile Workforce State Income Tax Simplification Act of 2021 (H.R. 429), Multi-state Worker Tax Fairness Act of 2021 (S. 1887); State remote sales tax (Wayfair) issues; Methods and periods issues, including UNICAP, method changes, revenue recognition, deferral of live event advance payments, section 473 relief including the Supply Chain Disruptions Relief Act (H.R. 7382, S. 4105), timing of income, section 174 amortization, research credit refund claims, and small business issues; Corporate taxation issues, inclusive of section 382(h) related to built-in gain and loss; Partnership taxation issues; S corporation taxation issues; Employee benefits tax issues, including the Securing a Strong Retirement Act of 2021 (H.R. 2954) and the Retirement Security and Savings Act (S. 1770), fringe benefits, remote workers, section 414(m) controlled and affiliated groups, required minimum distributions; Exempt organization issues, including group rulings, the Form 990 series, the Business Master File (BMF) and e-filing initiatives; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes (Schedules K-2 and K-3); transition tax installments, net operating loss carryback relief under the CARES Act (P. L. 116-136), OECD/digital economy, foreign tax credits, previously taxed earnings and profits, Passive Foreign Investment Companies (PFICs), foreign information reporting and section 254A.