CARI WESTON

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 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 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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, trust and estate tax issues; Disaster relief; Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division, IRS regulation of tax return preparers), federal tax return deadline extensions: To extend to May 17 the first scheduled estimated tax payment for 2021, H.R.2437, penalty relief, IRS services, e-filing issues, quarterly payment deadlines: Tax Deadline Simplification Act of 2021, H.R.4214, and regulation of tax return preparers Taxpayer Protection and Preparer Proficiency Act, H.R. 4184; Foreign trusts, including filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Estate closing letters; Gift tax form and instructions improvements; 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, section 473 relief, timing of income, alternative tax net operating losses, and small business issues; 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; Executive compensation tax issues; Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: 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, 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; Disaster relief; , Filing Relief for Natural Disasters Act (H.R. 3574); 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, practitioner services division; 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 Deadline Simplification Act of 2021, H.R.4214; and 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 tax 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, valuation discounts, grantor trusts, estates and surcharge on trust 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, section 473 relief, timing of income, alternative tax net operating losses, section 174 amortization, and small business issues; 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; Executive compensation tax issues, including nonqualified deferred compensation; Virtual currency; International issues, including proposed international form changes; 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. 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 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, 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, 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; Executive compensation tax issues, including nonqualified deferred compensation Virtual currency; International issues, including proposed international form changes; 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: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief; Partnership issues, including centralized partnership audit regime, tax capital reporting, Form 1065 changes, and state-level pass-through entity taxes; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing issues, including outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans, FICA and federal income tax withholding for stock-settled awards; Virtual Currency; International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3; section 965(h) transition tax installments, and net operating loss carryback relief under the CARES Act (P. L. 116-136); Corporate tax issues; including holding period following certain section 351 transactions; Consolidated Appropriations Act, 2021 (P.L. 116-260), including section 501(c)(6), PPP loans, PPP loan forgiveness expense deductibility.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations; trusts; partnerships; S corporations; and virtual currency.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; Families First Coronavirus Response Act, Pub. L. No. 116-127, specifically the medical and sick leave tax credits; The Coronavirus Aid, Relief and Economic Security Act, Pub. L. 116-136, specifically, the employee retention credit and employer payroll tax deferral; the Presidential Memorandum on Deferring Social Security Payroll Taxes; and related tax filing and payment relief. Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters (conservation easements), qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, carried interests, issues impacting exempt organizations (unrelated business income tax, forms, international filings, excise tax and group rulings), qualified transportation fringe benefits, executive compensation, excess business losses, education reform, trust and estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; E-signature - permanent and temporary relief Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; e-filing outage on 9/15 filing deadline; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604 and the Remote and Mobile Worker Relief Act, S. 3995; American Workers, Families, and Employers Assistance Act, S. 4318; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic and non-automatic method changes, revenue recognition, timing of income, fines and penalties, small business and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; Virtual Currency International issues, including proposed international changes to Form 1065, Schedule K-2, and Schedule K-3.

General issues related to multiple areas of the tax law and code including: Coronavirus Pandemic (COVID-19), including the Tax Filing Relief for America Act, S. 3535; CARES Act, Pub. L. 116-136; Families First Coronavirus Response Act, Pub. L. No. 116-127; and related tax filing and payment relief; Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief, Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; The Freedom to Invest in Tomorrows Workforce Act, H.R. 5339; Tax administration issues, including Taxpayer First Act, Pub. L. No. 116-25 (organization of the IRS, practitioner services division, IRS regulation of tax return preparers) federal tax return deadline extensions, penalty relief, and impact of the Federal Government shutdown on the IRS, and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604, and the Remote and Mobile Worker Relief Act, S. 3995; Implementation of Setting Every Community Up for Retirement Enhancement Act (SECURE Act) contained in the Further Consolidated Appropriations Act, 2020 (P.L. 116-94); South Dakota v. Wayfair, Inc., and related issues; Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections program, employee plans compliance resolution system, hardship withdrawals, multiple employer plans; International issues; Other issues related to multiple areas of the tax law including: exempt organizations, trusts and estates, partnerships, S corporations, and virtual currency.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, tax shelters, qualified opportunity zones, global intangible low-taxed income, interest expense limitations, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and Mobile Workforce State Income Tax Simplification Act, S. 604.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, issues impacting exempt organizations (qualified transportation fringe benefits, UBIT, forms, and international filings), executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief, built-in gains and losses; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Foreign trusts, including Form 3520 and Form 3520-A filing penalties and withholding credit for U.S. beneficiaries of a foreign trust; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties; Methods and periods issues, including bonus depreciation, UNICAP, inventoriable digital goods, automatic method changes, revenue recognition, timing of income, and international issues; Employee benefits issues, including IRS determination letter program, voluntary compliance program, self-corrections, hardship withdrawals, multiple employer plans; International issues.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, tax shelters, qualified opportunity zones, global intangible low-taxed income, interest expense limitations, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and Mobile Workforce State Income Tax Simplification Act, S. 604.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.

General issues related to multiple areas of the tax law and code including: Individual and corporate tax reform implementation and technical correction issues in the Tax Cut and Jobs Act, P.L.115-97, including foreign tax credits, bonus depreciation, tax shelters, qualified opportunity zones, qualified business income deduction, global intangible low-taxed income, business interest expense limitations, qualified transportation fringe benefits, executive compensation, excess business losses, education reform, estate tax issues; S Corp transition relief; Tax extenders; Disaster relief; Filing Relief for Natural Disasters Act, S. 1677, H.R. 2976, and Disaster Relief Act of 2019, H.R. 2145; Centralized partnership audit regime; S Corporation modernization; Education reform/savings plans, Lifelong Learning and Training Account Act of 2019, S.539; Tax administration issues, including penalty relief, organization of the IRS, practitioner services division, IRS regulation of tax return preparers, and impact of the Federal Government shutdown on the IRS; and IRS and Treasurys Priority Guidance Plan; Mobile Workforce State Income Tax Simplification Act, S. 604; Virtual Currency; and Tax Treaties.