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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 3930 University Dr. |
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| City | Fairfax |
State | VA |
Zip Code | 22030 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 401102073-12
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6. House ID# 431740001
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| TYPE OF REPORT | 8. Year | 2023 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: William Brett Richardson |
Date | 11/14/2023 2:41:44 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
RVDA supports H.R. 3624 - the Travel Trailer and Camper Tax Parity Act.
Current disparity: Under the current law, the tax exemption for interest paid on dealer inventory applies only to RV motorhomes, leaving RV travel trailers at a disadvantage. While motorhome interest remains fully deductible, travel trailers are now limited to a 30 percent deduction for dealers with $25 million in annual sales. This exclusion affects approximately 85% of RVs sold, which are non-motorized travel trailers, creating an unfair and complicated accounting situation for RV dealers.
Impact on dealers: According the U.S. Census Bureau, an estimated 550 U.S. RV dealers with more than 25,000 employees are impacted by this disparity. In 2023, its estimated that these dealers will pay an additional $100 million in taxes due to the inventory interest deduction limitation. This puts these dealers at a competitive disadvantage compared to other recreation equipment dealers, such as powersports and marine dealers, who can fully deduct interest on their inventory floor plans.
Impact on consumers: Retail RV prices have increased by 15% to 30% or more depending on the type of unit since 2020. While not all the increase can be attributed to higher taxes paid by impacted dealers, a higher, disparate tax burden on these businesses contributes to the inflation and the increase in RV prices as indicated in the Feds RV Dealer Producer Price Index.
Bipartisan support: There is bipartisan support in both the House and Senate for legislation to address this issue. Representatives Rudy Yakym and Dina Titus, Co-Chairs of the House RV Caucus, have introduced H.R. 3624 to ensure that towable RVs are included in the floor plan interest financing deductibility provisions. Last Congress, Senator Joni Ernst and Senator Angus King introduced a companion measure, and we expect reintroduction of the legislation in the Senate in the coming weeks.
Equity in financing: RV trailers are considered motor vehicles under state and federal motor vehicle laws. They are designed to provide temporary living quarters for short-term camping and comply with applicable Federal Motor Vehicle Safety Standards for motor vehicle regulations. Therefore, it is essential to create equity in the financing of RV inventory by including RV trailers in the deductibility provisions.
Initial Intent of legislation: Both House and Senate tax legislation in 2017 intended to include RV trailers as motor vehicles in the floor plan interest exclusion. The consolidation of language aimed to simplify the provision but unintentionally excluded RV trailers due to confusion about the different types of RVs. Reinstating the original intent will rectify this unintended consequence.
Requested Action:
Support the Travel Trailer and Camper Tax Parity Act (HR 3624), legislation that ensures towable RVs are included in the floor plan interest financing deductibility provisions under IRS Code 163(j). By correcting this discrepancy, we can promote fairness, strengthen the competitiveness of RV trailer dealers, and support the growth of the RV industry.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
William |
Richardson |
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Philip |
Ingrassia |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code NAT
16. Specific lobbying issues
Senate Bill 873 - America's Outdoor Recreation Act of 2023 Federal Lands Recreation Enhancement Act.
A bill to improve recreation opportunities on, and facilitate greater access to, Federal public land, and for other purposes.
RV consumers rely on federal infrastructure for safe and enjoyable experiences, but deteriorating and inadequate campgrounds, roads, bridges, water systems, and other utilities reduce enjoyment and add safety concerns. Campgrounds are experiencing record demand across the country, and visitors expect our federal campgrounds to be safe, accessible and have adequate modern amenities. We ask Congress to continue to fully fund vital outdoor recreation programs and encourage federal land agencies to utilize the Great American Outdoors Act and the Bipartisan Infrastructure Law to implement infrastructure improvements on public lands, including campground modernization and expansion.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
William |
Richardson |
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Philip |
Ingrassia |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code ACC
16. Specific lobbying issues
RVDA supports H.R. 3624 - the Travel Trailer and Camper Tax Parity Act.
Current disparity: Under the current law, the tax exemption for interest paid on dealer inventory applies only to RV motorhomes, leaving RV travel trailers at a disadvantage. While motorhome interest remains fully deductible, travel trailers are now limited to a 30 percent deduction for dealers with $25 million in annual sales. This exclusion affects approximately 85% of RVs sold, which are non-motorized travel trailers, creating an unfair and complicated accounting situation for RV dealers.
Impact on dealers: According the U.S. Census Bureau, an estimated 550 U.S. RV dealers with more than 25,000 employees are impacted by this disparity. In 2023, its estimated that these dealers will pay an additional $100 million in taxes due to the inventory interest deduction limitation. This puts these dealers at a competitive disadvantage compared to other recreation equipment dealers, such as powersports and marine dealers, who can fully deduct interest on their inventory floor plans.
Impact on consumers: Retail RV prices have increased by 15% to 30% or more depending on the type of unit since 2020. While not all the increase can be attributed to higher taxes paid by impacted dealers, a higher, disparate tax burden on these businesses contributes to the inflation and the increase in RV prices as indicated in the Feds RV Dealer Producer Price Index.
Bipartisan support: There is bipartisan support in both the House and Senate for legislation to address this issue. Representatives Rudy Yakym and Dina Titus, Co-Chairs of the House RV Caucus, have introduced H.R. 3624 to ensure that towable RVs are included in the floor plan interest financing deductibility provisions. Last Congress, Senator Joni Ernst and Senator Angus King introduced a companion measure, and we expect reintroduction of the legislation in the Senate in the coming weeks.
Equity in financing: RV trailers are considered motor vehicles under state and federal motor vehicle laws. They are designed to provide temporary living quarters for short-term camping and comply with applicable Federal Motor Vehicle Safety Standards for motor vehicle regulations. Therefore, it is essential to create equity in the financing of RV inventory by including RV trailers in the deductibility provisions.
Initial Intent of legislation: Both House and Senate tax legislation in 2017 intended to include RV trailers as motor vehicles in the floor plan interest exclusion. The consolidation of language aimed to simplify the provision but unintentionally excluded RV trailers due to confusion about the different types of RVs. Reinstating the original intent will rectify this unintended consequence.
Requested Action:
Support the Travel Trailer and Camper Tax Parity Act (HR 3624), legislation that ensures towable RVs are included in the floor plan interest financing deductibility provisions under IRS Code 163(j). By correcting this discrepancy, we can promote fairness, strengthen the competitiveness of RV trailer dealers, and support the growth of the RV industry.
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
William |
Richardson |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code AUT
16. Specific lobbying issues
(H.R. 621/S. 154) Preventing Auto Recycling Theft, or PART, Act - aims to reduce catalytic converter thefts by requiring new vehicles to have the VIN stamped onto the converter, allowing law enforcement officers to link stolen parts to the originating vehicles.
It also would create a grant program to allow dealerships, repair shops and other eligible parties to stamp VINs onto converters of existing vehicles, and it would establish federal criminal penalties for theft, sale, trafficking or known purchases of stolen catalytic converters.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
William |
Richardson |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |