LINDA EVANS

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act, notably Global Intangible Low-Taxed Income, or GILTI Minimum Tax; H.R. 7024, Tax Relief for American Families and Workers Act of 2024; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; United Nations tax convention and Terms of Reference. T.D. 9959, Final Regulations on foreign tax credits; REG-120653-22, CHIPS Act advanced manufacturing tax credit; Notice 2023-63 and Notice 2024-12 on application of Section 174 on R&D expenses.

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations; H.R. 7024, Tax Relief for American Families and Workers Act of 2024. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; United Nations tax convention. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues; T.D. 9959, Final Regulations on foreign tax credits; REG-120653-22, CHIPS Act advanced manufacturing tax credit; Notice 2023-63 and Notice 2024-12. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent, and potential Senate companion bill. H.R. 5988, United States-Taiwan Expedited Double-Tax Relief Act.

Legislative & Regulatory Issues Related to Technology Policy, including R&D, Cybersecurity, Privacy, Health IT & Technology Procurement: Artificial Intelligence (AI), general purpose AI and foundation models, open source AI, AI regulatory guidance, AI bias, AI and the workforce, AI use and implementation by federal agencies; cloud computing, secure cloud policy; quantum computing; federal agency IT modernization; privacy legislation; S. 3312, Artificial Intelligence Research, Innovation, and Accountability Act of 2023; H.R. 5077, S. 2714, CREATE AI Act of 2023; S. 2770, Protect Elections from Deceptive AI Act; H.R. 3106, Preventing Deepfakes of Intimate Images Act; S. 4569, Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks (TAKE IT DOWN) Act; H.R. 6936, S. 3205, Federal Artificial Intelligence Risk Management Act of 2023; S. 4178, Future of Artificial Intelligence Innovation Act of 2024; H.R. 8818, American Privacy Rights Act of 2024; H.R. 7891, S. 1409, Kids Online Safety Act; H.R. 7890, S. 1418, Children and Teens' Online Privacy Protection Act; H.R. 6213, National Quantum Initiative Reauthorization Act; implementation of Public Law no. 115-368, the National Quantum Initiative Act; implementation and issues related to Public Law no. 117-167, CHIPS and Science Act; National AI Research Resource Task Force; NIST AI Risk Management Framework; Executive Order 14110, Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. National Cybersecurity Strategy implementation plan efforts on harmonization, secure by design, secure software liability proposals, migration to memory safety programming languages, and open-source software security; encryption policy; post quantum cryptography; cyber incident reporting policy; cybersecurity workforce development strategy; reasonable data security practices language and liability protections; international cybersecurity coordination; critical infrastructure designation and cybersecurity obligations; AI security; S. 4230, Secure A.I. Act of 2024; Executive Order 14028, Improving the Nation's Cybersecurity provisions on software bill of materials, zero trust and cloud security architecture, and standards to improve software supply chain security; Executive Order 13984, Taking Additional Steps to Address the National Emergency with Respect to Significant Malicious Cyber-Enabled Activities; Cybersecurity Framework 2.0.

Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; United Nations tax convention. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues; T.D. 9959, Final Regulations on foreign tax credits; REG-120653-22, CHIPS Act advanced manufacturing tax credit. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent, and potential Senate companion bill. H.R. 5988, United States-Taiwan Expedited Double-Tax Relief Act.

INTERNATIONAL BUSINESS MACHINES CORPORATION (IBM)

INTERNATIONAL BUSINESS MACHINES CORPORATION (IBM)

INTERNATIONAL BUSINESS MACHINES CORPORATION (IBM)