Holland & Knight's Legislative Tax Practice by Holland & Knight

Legislative Tax Practice  The Holland & Knight Legislative Tax Team helps clients shape federal tax legislation and rulemaking by working with the leadership of Congress, the Trump Administration, the U.S. Treasury Department and the Internal Revenue Service (IRS).  Members of our team have strong relationships with Washington decision-makers. Our team includes a former member of the Trump transition team, a former GOP congressman who served on the House Ways and Means Committee, and others with high-level public policy experience in our nation's capital.  All industries are affected by tax policy, and we represent a diverse range of clients whose interests are at stake in tax reform. President Donald Trump and the U.S. Congress have made a commitment to comprehensive tax reform. The president articulated the principles of his tax plan during his campaign, and Republican lawmakers in the U.S. House of Representatives – where tax legislation must begin – released their "Better Way" plan in 2016. The "Big Six" – a group of top tax policymakers that includes the Treasury Secretary, National Economic Council Director, Senate Majority Leader, Senate Finance Committee Chairman, Speaker of the House, and the House Ways and Means Committee Chairman – came together in summer 2017 to begin work on a comprehensive tax reform plan that focuses on simplifying the tax code, reducing tax rates, increasing global competitiveness and growing the economy. In late September, the Big Six released a framework entitled "Unified Framework for Fixing Our Broken Tax Code." Although the framework lacks significant details, the process now begins for the committees of jurisdiction to get to work on number-crunching, pay-fors, and providing details on how the reforms and cuts will be achieved. With a goal of a fiscal year (FY) 2018 budget going to a vote by mid-October 2017, tax reform legislation could go to the House and Senate floors for consideration by the end of the year based on the statements of congressional leadership. The result would be a significantly reformed tax code in 2018. The attorneys and government affairs advisors on Holland & Knight's Legislative Tax Team provide clients a seat at the table as deliberations on tax reform continue in Washington. Tax reform inevitably will have winners and losers, and our team has the knowledge and relationships to forcefully advocate for and represent our clients' interests as tax legislation is written and moved in Congress, interpreted at the U.S. Treasury Department and Internal Revenue Service (IRS), and enforced by the IRS and other federal agencies. We have a deep bench of team members who held policymaking positions under both Republican and Democratic leadership in Washington, giving us bipartisan insight into the legislative and rulemaking processes. As the details of tax reform are being developed in Washington, we are positioned to monitor and respond quickly to assert our clients' interests to the key participants.

COMPREHENSIVE LEGISLATIVE TAX SERVICES Our Legislative Tax Team represents a range of businesses and industries, including national nonprofit organizations, trade associations, cooperatives, Native American tribal governments, multinational enterprises and businesses in almost every industry. Our services include advocating proposed tax law changes; assisting with the development of legislative proposals; monitoring legislative activities; assisting with technical submissions, such as statutory drafts and congressional hearing testimony; providing technical

analysis of existing tax statutes; and advocating for and analyzing the impact of guidance by the Treasury Department and the IRS. Chambers USA praises our government relations practice as "bipartisan" and "thriving," with experience in "the full range of legislative and federal appropriation processes."

BIPARTISAN EXPERIENCE IN CONGRESS AND THE WHITE HOUSE Key members of our Legislative Tax Team include:

 four former members of Congress, including a former Republican congressman who was a senior member of the House Ways and Means Committee, was elected to House leadership and also served for four years as chair of the National Republican Congressional Committee

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a former member of President Trump's transition team and his campaign director of congressional relations a former senior White House adviser and many congressional staff members a former chief of staff for the House Republican Conference who was named a "Top Lobbyist" by The Hill a former tax counsel to the House Ways and Means Committee a former Treasury executive and senior adviser to the IRS Commissioner

REPRESENTATIVE ENGAGEMENTS We are committed to achieving positive outcomes for our clients. Some highlights of our accomplishments in the legislative tax arena include the following:

 obtained federal excise tax relief for medical inhalers  resolved a cooperative tax issue for a national hospital group purchasing organization  secured a special exemption from the federal unemployment tax for Indian tribal governments and tribal enterprises

 created a coalition advocating for tax law changes that would encourage donations of conservation easements and ensure that audits by the IRS are conducted fairly and efficiency

 advocated for tax incentives for alternative energy technologies  analyzed and advocated against various proposals to stiffen the tax filing, disclosure, corporate governance and community benefit requirements imposed on tax-exempt organizations

 advocated for technical and policy changes to an excise tax simplification provision, defeating an attempt to apply the unrelated business income tax to tribal government enterprise revenue

 helped enact favorable tax treatment of the income and expenses of Alaska Native subsistence whaling

CONTACTS Nicole M. Elliott Partner | Washington, D.C. 202.469.5144 nicole.elliott@hklaw.com

Hon. Thomas M. Reynolds Senior Policy Advisor | Washington, D.C. 202.469.5107 thomas.reynolds@hklaw.com

Rich Gold Partner | Washington, D.C. 202.457.7143 rich.gold@hklaw.com