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DC Tax Flash: JCT Scores Senate-Passed CARES Act

Tax Alert

The Joint Committee on Taxation (JCT) today issued a revenue estimate for the tax-related provisions in the Coronavirus Aid, Relief, and Economic Security (CARES) Act (H.R. 748). The bill cleared the Senate last night on a 96-0 vote and is expected to pass the House tomorrow.

According to JCT, the bill's revenue provisions taken together would reduce federal taxes by $591 billion, or more than a quarter of the cost of the bill, which is estimated to total roughly $2 trillion.

Almost $300 billion of that cost comes from the bill's direct transfer payments to individuals. These "recovery rebates" would deliver $1,200 to individuals (twice that for joint filers) and $500 per child. These payments would phase-out for those with incomes above $75,000, and for couples above $150,000.

The JCT revenue estimate includes the following scores for the bill's business tax provisions:

  • Employee Retention Credit for Employers Subject to Closure or Experiencing Economic Hardship Due to COVID-19: $54.5 billion;
  • Delay of Payment of Employer Payroll Taxes: $12.3 billion;
  • Modification of Net Operating Losses (NOLs): $25.5 billion;
  • Modification of Limitation on Losses for Taxpayers Other than Corporations: $169 billion;
  • Modification of Credit for Prior Year Minimum Tax Liability of Corporations: No revenue effect after 2021;
  • Modification of Limitation on Business Interest: $13.3 billion;
  • Qualified Improvement Property Technical Correction: No revenue effect;
  • Temporary Exception from Excise Tax on Alcohol for Producing Hand Sanitizer: Less than $500,000;
  • Suspension of Certain Aviation Excise Taxes: $4.3 billion; and
  • Single-Employer Plan Delay in Pension Contributions: $19 million.

The JCT revenue score released today is posted here.

The text of the CARES Act, as approved last night by the Senate, is posted here.


Miller & Chevalier has formed an interdisciplinary task force, comprised of attorneys in seven main practice areas, to help businesses navigate the complex legal issues created by this global event. More information is posted here.



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