KELSEA MORSHUK-ALLEN

Issues related to the Section 301 tariffs Issues related to the Section 232 tariffs Issues related to the Section 122 tariffs Issues related to the 2026 United States-Mexico-Canada Agreement (USMCA) Joint Review Issues related to reciprocal tariffs under International Economic Emergency Powers Act

Issues relating to corporate tax reform's impact on the competitiveness of the U.S. as a location for FDI Issues related to guidance and implementation of certain provisions in the Inflation Reduction Act including the new stock buyback excise tax and corporate AMT provisions. Issues related to alignment with the OECD relating to a 15% global rate and other OECD developments, including on the side-by-side agreement with the U.S. tax system. Issues relating to Section 174 the Research & Development expensing. Issues related to Internal Revenue Code Sec. 385, the 2016 final regulations and 2019 updates. Issues related to tax treaties including updates to the U.S.-Switzerland Tax Treaty Issues related to the One Big Beautiful Bill Act (H.R. 1) Issues related to the Base Erosion Anti-Abuse Tax Issues related to H.R.1911 - To amend the Internal Revenue Code of 1986 to provide that certain payments to foreign related parties subject to sufficient foreign tax are not treated as base erosion payments.

Issues relating to promoting and the ability of the U.S. to compete for FDI. Activities related to promoting the benefits of foreign direct investment directly to the Executive Branch. Activities related to promoting the Global Investment in American Jobs Caucus in the U.S. House of Representatives and U.S. Senate.

Issues relating to the ability of U.S. subsidiaries to compete for government contracts. Issues relating to CFIUS and potential changes to CFIUS authority to review certain transactions and its impact on the ability of the U.S. to attract foreign investment. Issues relating to FARA including the Lobbying Disclosure Improvement Act (S. 264).