Prospects for pre-election stimulus deal dim as 'Problem Solvers' proposal falls flat with congressional leaders - Deloitte

Tax News & Views
                                                                                                          Capitol Hill briefing.
                                                                                                          September 18, 2020

In this issue:

Prospects for pre-election stimulus deal dim as ‘Problem Solvers’ proposal falls flat with congressional leaders .......... 1
GAO: President Trump’s employee-side payroll tax deferral policy subject to Congressional Review Act ..................... 5
New TCJA regs issued ..................................................................................................................................... 6
Richmond tapped for Ways and Means vacancy .................................................................................................. 7
Deloitte Tax releases updated Biden-Trump tax policy comparison ........................................................................ 8

Prospects for pre-election stimulus deal dim as ‘Problem Solvers’ proposal falls
flat with congressional leaders
Congressional leaders in both parties this week dismissed a bipartisan proposal to address the on-going economic and
health impact of the coronavirus pandemic – despite a surprise push by President Trump for a bill with “much higher
numbers” than the GOP has previously discussed and calls from some House Democrats for their leadership to reach a
deal on a narrower package than they had originally envisioned – making further action to aid the economy ahead of
November’s elections continue to appear unlikely.

Staking out a middle ground

The House Problem Solvers Caucus – which comprises 25 Democrats and 25 Republicans and is co-chaired by Rep.
Josh Gottheimer, D-N.J., and Ways and Means Committee member Tom Reed, R-N.Y. – released on September 15
what they dubbed a “March to Common Ground” framework designed to “help break the gridlock” on a so-called Phase
4 coronavirus relief package. The outline draws on some of the areas of agreement between the two parties and
includes $1.5 trillion in new spending, reallocation of $130 billion included in the Coronavirus Aid, Relief, and Economic

Tax News & Views                                                            Page 1 of 8                Copyright © 2020 Deloitte Development LLC
September 18, 2020                                                                                                             All rights reserved.

Security (CARES) Act (P.L. 116-136) enacted in March, and automatic boosters and reducers that could kick in next
year depending on relevant metrics.
URL: https://oversight.house.gov/news/press-releases/house-chairs-joint-statement-on-problem-solvers-caucus-coronavirus-relief

Among the spending proposals in the caucus’ plan are a second round of Payroll Protection Program (PPP) loans with
both new and reappropriated money; additional funding for a targeted Employee Retention Tax Credit (ERTC); another
round of direct stimulus checks to individuals and families; enhanced unemployment benefits through January 2021;
enhanced liability protections for entities that follow new OSHA guidelines; and money for housing assistance, COVID-
19 testing and contact tracing, state and local governments, election administration, and schools and daycare
providers. An additional three months of enhanced unemployment benefits and a third round of stimulus checks,
adding $400 billion to the costs, could be triggered in 2021 depending on economic conditions, while funding for PPP,
state and local governments, and rental assistance could be reduced by up to $200 billion.

“Americans deserve a functioning Congress that can rise to the challenge and deliver the relief they need,” said Reed
in a press release introducing the plan. “Our framework reflects months of bipartisan consensus-building on the
actions the federal government can take to help working families and local communities across the country as they
navigate the impacts of COVID-19.”

At $1.5 trillion, the proposal comes in short of the $3.2 trillion in tax and spending provisions proposed in the Heroes
Act, which cleared the House on May 15. (For details on the Heroes Act, see Tax News & Views, Vol. 21, No. 27, May
15, 2020.) But it is significantly more expensive than the two proposals that Senate Republicans have put forward to
date – the roughly $1 trillion HEALS Act, which was unveiled in July but never taken up in the chamber, and the
smaller (estimated $500 billion) Delivering Immediate Relief to America’s Families, Schools, and Small Businesses Act,
which failed to advance in the Senate following an unsuccessful procedural vote on September 10. (For details on the
HEALS Act, see Tax News & Views, Vol. 21, No. 37, July 31, 2020; for details on the Delivering Immediate Relief to
America’s Families, Schools, and Small Businesses Act, see Tax News & Views, Vol. 21, No. 41, Sep. 11, 2020.)
URL: https://newsletters.usdbriefs.com/2020/Tax/TNV/200515_1.html
URL: https://newsletters.usdbriefs.com/2020/Tax/TNV/200731_1.html
URL: https://newsletters.usdbriefs.com/2020/Tax/TNV/200911_1.html

Pressure to act, but Democratic and GOP leaders unmoved

The release of the Problem Solvers’ proposal came as Democratic and Republican leaders in Congress have faced
pressures from within their respective parties to reach a deal; but those leaders so far have appeared unwilling to
abandon their stated positions.

Following the release of the Problem Solvers’ proposal, President Trump urged Republicans in a September 16
statement on Twitter to “[g]o for the much higher numbers, … it all comes back to the USA anyway (one way or
another!).” At a White House press conference later that day, he referred to the Problem Solver Caucus’ plan and said
that he agreed with “a lot of it.”

‘Too many needs unmet’: Some House Democrats viewed as most vulnerable to losing their re-election bids in
November have reportedly urged Speaker Nancy Pelosi, D-Calif., to bring some more narrow bills to the floor and pass
legislation in a more piecemeal way, but Pelosi has stuck to her goal of a single large package, and the president’s
comments likely validated her position.

“A skinny deal is not a deal. It’s a Republican bill,” she told Democratic members on a September 16 conference call.

Eight House Democratic committee chairs, including Ways and Means Committee Chairman Richard Neal of
Massachusetts, quickly opposed the Problem Solvers’ proposal, saying in a joint statement that although they
appreciated every attempt to provide relief, this particular one “falls short of what is needed” and “leaves too many
needs unmet.”
URL: https://oversight.house.gov/news/press-releases/house-chairs-joint-statement-on-problem-solvers-caucus-coronavirus-relief

Asked September 17 at a press conference whether $2.2 trillion – her most recent public compromise offer to
Republicans – was her floor in negotiations with the Senate and the White House, Pelosi said “it’s hard to see how we
can go any lower when you see the great needs,” specifically citing small businesses, restaurants, and transportation

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providers. Pelosi reportedly spoke with Treasury Secretary Steven Mnuchin on September 16 and similarly told him
that recovery requirements have only increased since the House passed its $3.4 trillion Heroes Act in mid-May.

White House Chief of Staff Mark Meadows, the other key negotiator for the administration, said on CNBC September
16 that the Problem Solvers’ $1.5 trillion proposal is not a “show-stopper,” and he told Politico that “while there are
some priorities outlined that are inconsistent with the White House’s initial proposal, it could provide a basis for further
conversations with the Speaker and Leader in the Senate.”

Pelosi and Senate Democratic Leader Charles Schumer of New York released a statement September 16 saying, “We
look forward to hearing from the president’s negotiators that they will finally meet us halfway.”

‘You’d lose a bunch of fiscal conservatives’: The administration has previously floated support for a $1.3 trillion
package, and the president’s tweet this week seems to indicate he might accept a bill with a higher price tag.
However, Senate Republicans are in a starkly different position: Majority Leader Mitch McConnell, R-Ky., tried without
success during August to garner support from his members for his $1 trillion HEALS Act and last week failed to move
the smaller Delivering Immediate Relief to America’s Families, Schools, and Small Businesses Act. (A motion to
consider the bill got 52 votes and lost only one Republican but fell short of the 60 votes required to clear that
procedural hurdle.)

Following President Trump’s suggestion this week that the GOP consider a larger package, Senate Republican Whip
John Thune of South Dakota indicated that is unlikely to happen, telling reporters, “I think if the number gets too high,
anything that got passed in the Senate will be passed mostly with Democratic votes and a handful of Republicans, so
it’s [going to] have to stay in a sort of a realistic range.”

Thune specifically called out the Problem Solvers’ proposal of $500 billion for state and local funding as a non-starter
with Senate Republicans. In his CNBC appearance, Meadows said the administration could accept a figure in the range
of $250 billion-$300 billion.

Sen. Mike Braun, R-Ind., echoed Thune’s comments, telling Politico, “I think politically the president still benefits from
maybe asking for more, but I think it was pretty clear that was voted upon by 52 senators. …You’d lose a bunch of
fiscal conservatives if you did anything other than what we voted [for] last week.”

Similarly, in the House, Republican Conference Chair Liz Cheney of Wyoming said, “I would be hesitant to make a
commitment about a level that is that high [$1.5 trillion]. I’m really concerned about funds that have been
appropriated [in the CARES Act] and haven’t been spent yet.”

An outlier of optimism among Republicans, Sen. Roy Blunt of Missouri told reporters at the Capitol September 16, “I
think there’s a deal to be had here. My concern is that the window probably closes at the end of this month, and we
need to get busy finding out what we can all agree on. And I think the number is going to be higher than our trillion
dollars.”

That rapidly closing window

The “window” Blunt mentioned refers to plans in the House and Senate to approve a short-term continuing resolution
(CR) that generally would extend current funding levels for federal agencies and departments and prevent a
government shutdown after fiscal year 2020 comes to a close at midnight on September 30. (Congress has not yet
completed work on the 12 appropriations measures needed to fund the government for fiscal year 2021 and will need
to rely on a CR to keep the government open until a more complete spending package is in place.)

The House is expected to vote on a CR the week of September 21 and then adjourn until mid-November, when they
are scheduled to return for a so-called “lame duck” legislative session between the elections and year-end. While the
House is out of session, however, members will be subject to a call to return to Washington – with 24 hours’ notice – if
negotiators manage to agree on a compromise recovery package on which both chambers would need to vote.

Senate Republicans, for their part, also reportedly plan to adjourn after completing work on the CR in order to give
those members up for re-election some additional time on the campaign trail.

Tax News & Views                                            Page 3 of 8           Copyright © 2020 Deloitte Development LLC
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Democrats and Republicans have generally agreed to pass a “clean” CR without any extraneous legislation attached or
partisan measures, but they have not yet agreed on how long the measure should run. Republicans are pushing for a
mid-December date, while Democrats have advocated a CR that goes into February 2021 and the new session of
Congress.

Limited glimmers of consensus at Select Revenue Measures hearing

In other stimulus-related developments, the discussion at a recent House Ways and Means Select Revenue Measures
Subcommittee hearing on “the consequences of inaction on COVID tax legislation” was emblematic of the larger
debate that has been unfolding between Democratic and Republican congressional leaders.

Democrats on the subcommittee touted the House-approved Heroes Act, accused Senate Republican leaders of
delaying their offer of a counterproposal, and dismissed the two Senate GOP packages that have been put forward
thus far as insufficient to address the damage the coronavirus has done to the economy.

Subcommittee Republicans countered that Democrats drafted the Heroes Act and advanced it through the House
without making an effort to gain GOP support and were not committed to pursuing a bipartisan deal. They also argued
that a number of the provisions in the Heroes Act – particularly on the spending side – are poorly targeted and in
some cases even superfluous.

There was, however, some bipartisan agreement among subcommittee members on a limited number of provisions
that they thought should be included in a subsequent coronavirus recovery package, even if some differences remain
as to how those provisions should operate:

   •   Expanded employee retention tax credit: Taxwriters and witnesses agreed that the ERTC, which was
       enacted in the CARES Act, has been effective in helping businesses keep employees on their payrolls and that
       it should be expanded. (Variations of an expanded ERTC have been proposed in both the Heroes Act and the
       HEALS Act.) Subcommittee Democrat Suzan DelBene of Washington commented that the next iteration of the
       ERTC should include a provision in the Senate’s HEALS Act – but not in the House-passed Heroes Act – that
       would make the credit available to businesses participating in the Paycheck Protection Program. Under the
       CARES Act, taxpayers are not permitted to claim the ERTC if they have received a forgivable loan under the
       PPP.
   •   Business credit for COVID mitigation expenses: Subcommittee member Tom Rice, R-S.C., spoke in favor
       of legislation (H.R. 7615) he sponsored that would provide a temporary refundable 50 percent credit against
       employer-side Social Security payroll taxes for certain expenses a business incurs to protect its employees
       from the coronavirus – for example, costs for testing, personal protective equipment, cleaning products or
       services, and reconfiguring workplaces and technology to prevent the spread of the virus. Rice’s proposal is
       not included in the Heroes Act but a similar proposal is in the Senate’s HEALS Act. Ways and Means Committee
       Democrat Stephanie Murphy of Florida (who is not on the subcommittee but was allowed to speak at the
       hearing) told the panel that such a provision should be part of the next recovery package.

Rollback of SALT deduction cap still a significant sticking point: The hearing also revealed that Democratic and
Republican taxwriters remain as divided as ever over a proposal in the House-passed Heroes Act that would suspend
the current-law $10,000 limitation on the deduction for state and local taxes (SALT) for 2020 and 2021. (The cap on
the SALT deduction was enacted in the 2017 tax code rewrite informally known as the Tax Cuts and Jobs Act, P.L.
115-97.)

South Carolina Republican Tom Rice argued that suspending the deduction would chiefly benefit upper-income
taxpayers as well as state and local governments that, in his view, “mismanaged” their finances.

But subcommittee member Tom Suozzi, D-N.Y., contended that the House proposal is a subsidy not for the wealthy,
but, rather, for “progressive states that offer a high level of services” to their residents.

Upcoming hearing to focus on restaurant industry: Subcommittee Chairman Mike Thompson, D-Calif., announced
late this week that the panel will hold a hearing on September 25 focusing on “restaurants in America during the
COVID-19 pandemic.” A witness list for the hearing was not available at press time.

Tax News & Views                                        Page 4 of 8          Copyright © 2020 Deloitte Development LLC
September 18, 2020                                                                                   All rights reserved.

House Republicans outline broad recovery goals

Also this week, the House GOP leadership unveiled a “Commitment to America” platform highlighting Republican’s fall
goals for US recovery from the pandemic and the resulting economic downturn.
URL: https://www.republicanleader.gov/commitment/

Under the goal of “Get America working and provide 10 million new good-paying jobs,” Republicans are advocating
$200 billion in forgivable loans through the PPP; an extension of the $2,000 child tax credit, which was enacted in the
2017 GOP tax code overhaul and is due to revert to $1,000 after 2025; making permanent the temporary Opportunity
Zone tax incentives also created in 2017; and continuing “proven pro-growth tax policies that increase take-home pay
and encourage innovation.”

At the press conference House leaders hosted to unveil their agenda, Rep. Kevin Brady of Texas, the ranking
Republican on the House Ways and Means Committee, said, “We’ll make the [2017] GOP tax cuts permanent, because
the proven way to rebuild local economies is to let families and businesses keep more of what they work so hard to
earn.”

 —     Storme Sixeas and Michael DeHoff
       Tax Policy Group
       Deloitte Tax LLP

GAO: President Trump’s employee-side payroll tax deferral policy subject to
Congressional Review Act
The Government Accountability Office (GAO) confirmed this week that IRS Notice 2020-65 – guidance issued on
August 28 implementing President Trump’s August 8 executive memorandum allowing for the deferral of certain
employee-side payroll tax obligations – is, in fact, a “rule” subject to scrutiny under the Congressional Review Act
(CRA). Still, the likelihood of the guidance being rescinded under that process this year appears very low.
URL: https://www.irs.gov/pub/irs-drop/n-20-65.pdf
URL: https://www.whitehouse.gov/presidential-actions/memorandum-deferring-payroll-tax-obligations-light-ongoing-covid-19-
disaster/

The president’s memorandum and the implementing guidance generally allow employers to defer withholding and
paying the employee portion of the Social Security payroll tax if the employee’s wages or compensation during any bi-
weekly pay period generally are less than $4,000, calculated on a pre-tax basis, or the equivalent amount with respect
to other pay cycles. The deferral applies to wages or compensation paid from September 1, 2020, through December
31, 2020.

Response to Schumer, Wyden

The GAO’s determination – which was communicated in a letter dated September 15 to Senate Minority Leader Charles
Schumer, D-N.Y., and Senate Finance Committee ranking Democrat Ron Wyden of Oregon, who in a September 2
letter of their own had asked the agency to render its views on the matter – notes that because the IRS submitted
Notice 2020-65 to the GAO as a non-major rule under the CRA, the question was essentially moot. (For more detail on
Notice 2020-65 and the request made by Sens. Schumer and Wyden, see Tax News & Views, Vol. 21, No. 41, Sep. 11,
2020.)
URL: https://www.gao.gov/assets/710/709404.pdf
URL: https://www.democrats.senate.gov/imo/media/doc/Schumer-
Wyden%20letter%20to%20GAO%20on%20Treasury%20and%20IRS%20Payroll%20Tax%20Deferral%20Guidance%20-
%20CRA%20Determination%20FINAL.pdf
URL: https://newsletters.usdbriefs.com/2020/Tax/TNV/200911_1.html

“That submission obviates the need for us to make that determination here,” the letter states.

The GAO goes on to clarify that “[w]hen an agency submits a document to our office under CRA, we consider that to
be the agency’s determination that the document is a rule under CRA.”

Tax News & Views                                              Page 5 of 8           Copyright © 2020 Deloitte Development LLC
September 18, 2020                                                                                          All rights reserved.

Under the CRA, certain rules promulgated by federal agencies can be rescinded by Congress through an expedited
process that requires just a simple majority in both chambers (as opposed to the usual case in the Senate where it
generally takes a three-fifths supermajority – typically, 60 votes – to advance legislation). To qualify for the expedited
treatment, Congress has 60 days (calculated as “session days” in the Senate and “legislative days” in the House) from
the day of submission to pass a joint resolution disapproving a particular rule.

According to the 1996 law, if a rule is rescinded it cannot be promulgated later in “substantially the same” form.

Democrats to consider ‘next steps’

Sen. Wyden – who, along with most congressional Democrats, has been staunchly opposed to the administration’s
actions on payroll tax deferral – praised the GAO’s confirmation that the Notice 2020-65 is subject to the CRA, but
otherwise did not elaborate on Democrats’ game plan other than to say that he and Sen. Schumer “will look at next
steps.”

Among other concerns, many Democrats argue that employees may be surprised by – or perhaps unable to absorb –
the doubled withholding rate that would apply between January 1 and April 30, 2021 under Notice 2020-65 to allow
the government to recoup any deferred payroll taxes. (Although the president has indicated that he would like the
deferred taxes to be forgiven, doing so would seem to require action by Congress.)

Part of the Democrats’ calculation with respect to the CRA process surely takes into account the likelihood that any
effort to rescind the IRS guidance would have trouble clearing the Senate, where Democrats currently control only 47
seats, and surely would be subject to a veto by President Trump. And even if a disapproval resolution were to clear
Congress and reach the president’s desk, overcoming a presidential veto requires a two-thirds vote in both chambers,
a feat that would appear close to impossible given the current balance of power in the House and Senate. (Democrats
control 232 seats in the House – a comfortable majority over Republicans, who control 198 seats, but far short of a
two-thirds supermajority.)

Still, Democrats may attempt to draw attention to the issue and are laying the groundwork for potential action, with
House Ways and Means Committee member John Larson, D-Conn., having introduced on September 4 a resolution of
disapproval (H.J.Res. 94) with respect to the notice. At press time, no action had been scheduled on the measure.
URL: https://www.congress.gov/bill/116th-congress/house-joint-resolution/94/text

GOP on different page

Democratic efforts to nix Notice 2020-65 run directly counter to legislation introduced on September 10 by the House’s
top GOP taxwriter, Kevin Brady of Texas, that would cement – and expand – the president’s policy by reducing the
employee-side Social Security tax to zero for all workers on wages paid between September 1 and December 31,
2020. According to an estimate from the Joint Committee on Taxation staff, the measure would reduce revenues by
$137 billion.
URL: https://newsletters.usdbriefs.com/2020/Tax/TNV/200911_1_suppC.pdf

However, House Ways and Means Committee Chairman Richard Neal, D-Mass., is not expected to take up Brady’s
proposal in committee and Speaker Nancy Pelosi, D-Calif., is unlikely to bring it to the floor – thus leaving both parties’
efforts in limbo.

 —     Alex Brosseau
       Tax Policy Group
       Deloitte Tax LLP

New TCJA regs issued
The Treasury Department and Internal Revenue Service issued several sets of regulations this week implementing
various provisions enacted in the 2017 tax code overhaul known informally as the Tax Cuts and Jobs Act (TCJA, P.L.
115-97).

Tax News & Views                                              Page 6 of 8          Copyright © 2020 Deloitte Development LLC
September 18, 2020                                                                                         All rights reserved.

Recently released guidance includes:

     •    Final regulations that address TCJA provisions that (1) permit section 481(a) adjustments by certain S
          corporations that convert to C corporations to be taken into account ratably over six years and (2) provide
          special rules regarding distributions of money after the post-termination transition period;
          URL: https://www.irs.gov/pub/irs-drop/td-9914.pdf
     •    Final regulations that coordinate a TCJA provision allowing the historic rehabilitation tax credit to be claimed
          over five years with other special rules for investment credit property;
          URL: https://www.irs.gov/pub/irs-drop/td-9915.pdf
     •    Final regulations that address TCJA changes to the computation of life insurance company reserves;
          URL: https://www.irs.gov/pub/irs-drop/td-9911.pdf
     •    Final regulations for determining the TCJA’s 1.4 percent excise tax on net investment income of certain private
          colleges and universities; and
          URL: https://www.irs.gov/pub/irs-drop/td-9917.pdf
     •    Final regulations that clarify the definition of “qualifying relative” for purposes of TCJA changes to the
          dependent exemption, the tax treatment of alimony and support payments, and the credit for dependents
          other than a qualifying child. (As enacted, TCJA provisions in these areas are in effect from 2018 through
          2025.)
          URL: https://www.irs.gov/pub/irs-drop/td-9913.pdf

Bonus depreciation regs clear OIRA: Also this week, the Office of Information and Regulatory Affairs (OIRA),
indicated that it has completed its review of final regulations implementing TCJA provisions related to bonus
depreciation, including the treatment of qualified improvement property. Completion of the OIRA review suggests that
the release of these regulations could be imminent.

Coronavirus guidance update

On the COVID-19 front, the IRS this week released Announcement 2020-17, which extends until January 15, 2021
(from September 15, 2020) the due date for reporting and paying excise taxes under sections 4971(a)(1) and
4871(f)(1) with respect to certain delayed minimum required contributions to a single-employer defined benefit plan.
The extension applies with respect to minimum required contributions to a single-employer defined benefit plan that
were delayed under section 3608(a) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-
136).
URL: https://www.irs.gov/pub/irs-drop/a-20-17.pdf

The Service’s announcement coordinates the due date for reporting and paying the section 4971(a)(1) and 4971(f)(1)
excise taxes with the extended due date under the CARES Act for paying the minimum required contributions.

A running list of guidance and other resources that address significant tax issues stemming from the pandemic is
available from Deloitte Tax LLP.
URL: https://newsletters.usdbriefs.com/2020/Tax/TNV/Stimulus-Resource-Table.pdf

 —       Michael DeHoff
         Tax Policy Group
         Deloitte Tax LLP

Richmond tapped for Ways and Means vacancy
The House Democratic Steering and Policy Committee on September 16 nominated Rep. Cedric Richmond, D-La., to
serve on the Ways and Means Committee. The appointment fills the vacancy created by the death of Rep. John Lewis,
D-Ga., on July 17.

Richmond, who was first elected to Congress in 2010, currently serves on the House Homeland Security Committee
and the Judiciary Committee and is the House Democratic assistant to the majority whip. He is also national co-chair
of former Vice President Joe Biden’s 2020 presidential election campaign.

Tax News & Views                                              Page 7 of 8          Copyright © 2020 Deloitte Development LLC
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In a September 16 news release, Ways and Means Chairman Richard Neal, D-Mass., called Richmond “a proven fighter
for families and workers” who will bring terrific energy and character to the table as we advance policies to provide
Americans with better health care, stronger financial security, and greater opportunity. Richmond’s “years of service
on the Judiciary and Homeland Security committees and track record of conducting thorough oversight will certainly
enhance our work, as will his experience serving as chair of the Congressional Black Caucus,” Neal said.

Richmond’s nomination still needs to be approved by the full Democratic caucus, although that vote, which is expected
to take place the week of September 21, is seen as a formality at this point.

 —      Michael DeHoff
        Tax Policy Group
        Deloitte Tax LLP

Deloitte Tax releases updated Biden-Trump tax policy comparison
Deloitte Tax LLP has released an updated edition of its recent publication, Tax policy decisions ahead: Implications of
the 2020 presidential elections, which compares the tax policy platforms of former Vice President Joe Biden and
President Donald Trump.
URL: https://www2.deloitte.com/us/en/pages/tax/articles/biden-trump-tax-
policy.html?id=us:2em:3na:tnv:awa:tax:091820&sfid=7011O0000038l7NQAQ

The updated edition incorporates newly announced proposals from Biden regarding the tax treatment of US companies
that he claims have sent jobs offshore and companies that bring jobs back to the US, as well as changes to the rules
governing global intangible low-taxed income. (Biden announced his proposals shortly after the original version of our
publication went to press.)

 —      Jon Traub
        Managing Principal, Tax Policy
        Deloitte Tax LLP

This document contains general information only and Deloitte is not, by means of this
document, rendering accounting, business, financial, investment, legal, tax, or other
professional advice or services. This document is not a substitute for such professional
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responsible for any loss sustained by any person who relies on this document.

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Tax News & Views                                                           Page 8 of 8          Copyright © 2020 Deloitte Development LLC
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