Recent Legislation

DEG’s work is unique in not only informing our clients’ goals, strategies and decisions, but also in providing analyses and insights to ultimately improve the quality and effectiveness of public policies.

DEG’s analyses have informed the development of these specific pieces of recently-enacted tax legislation:

(Federal Internal Revenue Code sections in parentheses after provision name; all in Title 26 unless otherwise stated)

Credit for carbon oxide sequestration (45Q), in the Inflation Reduction Act of 2022, P.L. 117-169, enacted 8/16/2022:

• DEG estimated the budgetary effect of increasing the tax credit for direct air capture facilities.

Expanding access to capital for business development companies (15 U.S.C. 80a-60), in Consolidated Appropriations Act, 2018, P.L. 115-66, enacted 3/23/2018:

• DEG estimated the budgetary effect of allowing increased leverage for investment capital in business development companies, a type of mutual fund, under the Investment Act of 1940.

Repeal of corporate alternative minimum tax (55), in Tax Cuts and Jobs Act, P.L. 115-97, enacted 12/22/2017:

• DEG identified the counter-cyclic nature of corporate AMT revenues over the history of the tax.

Computation of life insurance reserves (807), in Tax Cuts and Jobs Act, P.L. 115-97, enacted 12/22/2017:

• DEG modeled the time profile of major life insurance industry product reserves by year of purchase.

Definition of company’s share and shareholder’s share (812), in Tax Cuts and Jobs Act, P.L. 115-97, enacted 12/22/2017:

• DEG developed a mapping to tax returns of company and shareholder shares of dividends for life insurance companies.

Capitalization of certain policy acquisition expenses (848), in Tax Cuts and Jobs Act, P.L. 115-97, enacted 12/22/2017:

• DEG modeled the time profile for the deferral of deductions for allowable expenses for life insurance industry products from 1987 through the current budget period.

Reform of rule related to qualified tax collection contracts, and special compliance personnel program (6306), in Fixing America’s Surface Transportation act (FAST ACT), P.L. 114-94, enacted 12/04/2015:

• DEG modeled the time profile of uncollected tax debt that could be serviced by private debt collection companies with IRS oversight.

Provide special rules concerning charitable contributions to, and public charity status of, agricultural research organizations (170(b) and 501(h)), in Consolidated Appropriations Act, 2016, P.L. 114-113, enacted 12/18/2015:

• DEG modeled the extent to which tax-exempt organization assets might be used in an Agriculture Research Organization, a new form of non-profit that can take the lead on agricultural research projects.

Treatment of certain persons as employers with respect to motion picture projects (3512), in Consolidated Appropriations Act, 2016, P.L. 114-113, enacted 12/18/2015:

• DEG modeled the impact on tax compliance of motion picture film productions reclassifying certain workers from employees to independent contractors.

Gift tax not to apply to gifts made to certain exempt organizations (2501(a)), in Consolidated Appropriations Act, 2016, P.L. 114-113, enacted 12/18/2015:

• DEG modeled alternatives for gift tax applicability to contributions to certain tax-exempt organizations.

Exclusion of dividends from controlled foreign corporations (CFCs) from the definition of personal holding company income for purposes of the personal holding company rules (543), in Tax Increase Prevention Act of 2014 and the Stephen Beck Jr., Achieving A Better Life Experience Act of 2014 (TIPRA and ABLE Act), P.L. 113-295, enacted 12/19/2014:

• DEG identified and measured amounts of foreign dividends indefinitely deferred from CFCs of certain closely held domestic corporations and other entities subject to the personal holding company rules.