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Home Source documents The American Rescue Plan Act of 2021 (ARPA; H.R. 1319) Title IX Subtitle G—Tax Provisions Related to Promoting Economic Security (R46680, Version 9, Updated March 8, 2021)

The American Rescue Plan Act of 2021 (ARPA; H.R. 1319) Title IX Subtitle G—Tax Provisions Related to Promoting Economic Security (R46680, Version 9, Updated March 8, 2021)

Full text

The American Rescue Plan Act of 2021 (ARPA;
H.R. 1319) Title IX Subtitle G—Tax Provisions
Related to Promoting Economic Security

Updated March 8, 2021




                                 Congressional Research Service
                                  https://crsreports.congress.gov
                                                         R46680


Congressional Research Service
                                 Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




Contents
Tables
Table 1. American Rescue Plan Act of 2021 (ARPA; H.R. 1319); Title IX Subtitle G—
  Tax Provisions Related to “Promoting Economic Security” as amended by S.Amdt. 891 ......... 4
Table 2. American Rescue Plan Act of 2021 (ARPA; H.R. 1319); Title IX Subtitle G—
  Tax Provisions Related to “Promoting Economic Security” as passed the House of
  Representatives February 27, 2021................................................................................ 15
Table 3. Estimated Cost of Title IX Subtitle G of the American Rescue Plan Act of 2021
  (ARPA; H.R. 1319) as amended by S.Amdt. 891 ............................................................. 26
Table 4. Estimated Cost of Title IX Subtitle G of the American Rescue Plan Act of 2021
  (ARPA; H.R. 1319) as passed the House of Representatives February 27, 2021 ................... 29


Contacts
Author Information ....................................................................................................... 32




Congressional Research Service
                                Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




       he 117th Congress is considering Coronavirus Disease 2019 (COVID-19)-related relief and

T      economic stimulus legislation. On February 8, 2021, House Ways and Means Committee
       Chairman Richard E. Neal released nine legislative proposals to be considered under the
budget reconciliation instructions. 1 On February 27, 2021, the House passed these proposals as
part of the American Rescue Plan Act of 2021 (ARPA; H.R. 1319). On March 4, 2021, the Senate
version of the American Rescue Plan Act of 2021, S.Amdt. 891 to H.R. 1319, was proposed. 2 On
Saturday March 6, 2021, the Senate passed H.R. 1319, as amended by S.Amdt. 891. This report
summarizes the tax provisions in Title IX Subtitle G of the House and Senate versions of the
American Rescue Plan Act. 3
The current proposed COVID-19 tax relief (Title IX Subtitle G of H.R. 1319) would
        provide a one-time direct payment of $1,400 per person to eligible households;
        temporarily expand the child tax credit for low- and moderate-income families,
         with a portion of the credit issued in 2021 before income taxes are filed;
        temporarily expand the earned income tax credit (EITC) for workers without
         qualifying children;
        temporarily expand the child and dependent care credit for most taxpayers and
         temporarily expand the exclusion for child and dependent care expenses;
        modify and extend the payroll tax credits for employer-provided paid sick and
         paid family leave;
        further extend the employee retention tax credit;
        temporarily enhance benefits and/or expand eligibility for the health insurance
         premium tax credit (PTC);
        repeal a provision that allows worldwide allocation of interest for the foreign tax
         credit limit, decreasing foreign tax credits in some cases;
        provide that advances against Economic Injury Disaster Loans that are not repaid
         and grants under the Restaurant Revitalization Fund will be excluded from
         income, and deductions for associated expenses will be allowed;
        modify reporting thresholds for third-party settlement organizations; and
        temporarily exclude most forgiven student loan debt from taxation.


1 For information on budget reconciliation, see CRS Report R44058, The Budget Reconciliation Process: Stages of

Consideration, by Megan S. Lynch and James V. Saturno. For information on the budget resolution for 2021, which
contains reconciliation directives, see CRS Report R46675, S.Con.Res. 5: The Budget Resolution for FY2021 , by
Megan S. Lynch and James V. Saturno.
2
  For the text of S.Amdt. 891 as introduced on March 4, 2021, see https://www.budget.senate.gov/imo/media/doc/
American%20Rescue%20Plan%20Act%20SENAT E.pdf.
3 Revenue provisions in Subtitle H, Pensions, are described in CRS In Focus IF11766, Pension Provisions in Budget

Reconciliation, by Elizabeth A. Myers and John J. T opoleski; and CRS In Focus IF11765, Special Financial Assistance
to Multiemployer Plans, by John J. T opoleski and Elizabeth A. Myers. T itle IX Subtitle H of the Senate version of the
American Rescue Plan Act of 2021 also includes an expansion of the Internal Revenue Code (IRC) §162(m) limit on
excessive employee compensation, effective after December 31, 2026. T he provision would deny deduction of
compensation in excess of $1 million to certain highly paid employees, plus the CEO or CFO, at publicly traded
companies. T he Joint Committee on Taxation (JCT ) estimates that the provision would generate $7.8 billion in revenue
between FY2016 and FY2031. T itle IX Subtitle A of the Senate version of the American Rescue Plan Act of 2021
includes a provision to exclude up to $10,200 in unemployment compensation benefits from tax in 2020 for taxpayers
with modified AGI of less than $150,000.




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                               Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




Current consideration of COVID-19-related tax relief follows the enactment of other laws
addressing the COVID-19 crisis: (1) the Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020 (P.L. 116-123); (2) the Families First Coronavirus Response Act
(FFCRA; P.L. 116-127); (3) the Coronavirus Aid, Relief, and Economic Security (CARES) Act
(P.L. 116-136);4 (4) the Paycheck Protection Program and Health Care Enhancement Act (P.L.
116-139); and (5) the Consolidated Appropriations Act, 2021 (P.L. 116-260). 5
Other pandemic-related tax policy proposals were considered in the 116 th Congress, but not
enacted. In the House, tax relief was also considered in the Heroes Act (H.R. 8406, adopted as
H.R. 925; H.R. 6800). 6 Legislation introduced in the Senate (the American Workers, Families,
and Employers Assistance Act [S. 4318]; the Supporting America’s Restaurant Workers Act [S.
4319]; and the Restoring Critical Supply Chains and Intellectual Property Act [S. 4324]) would
have provided tax relief intended to alleviate the economic effects of the COVID-19 pandemic. 7
Table 1 of this report summarizes the tax provisions in Title IX Subtitle G of the American
Rescue Plan Act (ARPA; H.R. 1319) as amended by S.Amdt. 891 (as passed by the Senate on
March 6, 2021) and provides links to CRS resources containing additional information. Table 2
of this report summarizes the tax provisions in Title IX Subtitle G of the American Rescue Plan
Act (ARPA; H.R. 1319) as passed by the House of Representatives on February 27, 2021. Joint
Committee on Taxation (JCT) revenue estimates for these provisions in both the Senate substitute
and the House-passed bill are included in Table 3 and Table 4, respectively.

Additional Resources
        Joint Committee on Taxation, Estimated Revenue Effects Of An Amendment in
         the Nature of a Substitute to H.R. 1319, The “American Rescue Plan Act Of
         2021,” As Passed by the House of Representatives And Scheduled for
         Consideration by the Senate, JCX-13-21, March 4, 2021, at https://www.jct.gov/
         publications/2021/jcx-13-21/.
        Joint Committee on Taxation, Estimated Revenue Effects Of H.R. 1319, The
         “American Rescue Plan Act Of 2021,” Scheduled For Consideration By The
         House Of Representatives On February 26, 2021, JCX-12-21, February 26, 2021,
         at https://www.jct.gov/publications/2021/jcx-12-21/. 8
        U.S. Congress, House Committee on the Budget, American Rescue Plan Act of
         2021, Report of the Committee on the Budget House of Representatives to
         Accompany H.R. 1319, 117th Cong., 1st sess., February 24, 2021, Report 117-7.


4
 For more on tax provisions in the CARES Act, see CRS Report R46279, The Coronavirus Aid, Relief, and Economic
Security (CARES) Act—Tax Relief for Individuals and Businesses, coordinated by Molly F. Sherlock.
5 For more information on the tax provisions in this legislation, see CRS Report R46649, The COVID-Related Tax

Relief Act of 2020 and Other COVID-Related Tax Provisions in P.L. 116-260, by Molly F. Sherlock et al.
6
  For more information on tax provisions in the Heroes Act, see CRS Report R46358, Heroes Act: Revenue Provisions,
coordinated by Molly F. Sherlock.
7 For more information on the Senate proposals, see CRS Report R46470, The American Workers, Families, and

Employers Assistance Act (S. 4318): Title II—Revenue Provisions and Other “HEALS Act” Tax Provisions,
coordinated by Molly F. Sherlock.
8 Earlier estimates were prepared in advance of consideration by the House Committee on Ways and Means. See Joint
Committee on T axation, Estimated Budgetary Effects Of The Revenue Provisions Of The Chairman’s Amendment In
The Nature Of A Substitute To The Budget Reconciliation Legislative Recommendations, Scheduled For Markup By
The House Committee On Ways And Means On February 10, 2021, JCX-9-21, February 9, 2021, at
https://www.jct.gov/publications/2021/jcx-9-21/.



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                             Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




        Joint Committee on Taxation, Description Of The Budget Reconciliation
         Legislative Recommendations Relating To Prompting Economic Security, JCX-3-
         21, February 8, 2021, at https://www.jct.gov/publications/2021/jcx-3-21/.
        Joint Committee on Taxation, Technical Explanation of the Modification of
         Exceptions of Reporting Third Party Network Transactions in New Section 9674
         of Subtitle IX of the American Rescue Plan Act of 2021, as Amended, by the
         Proposed Manager’s Amendment, February 26, 2021, at https://www.jct.gov/
         publications/2021/technical-explanation-of-section-9674-of-hr-1319/.




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                             Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




Table 1. American Rescue Plan Act of 2021 (ARPA; H.R. 1319); Title IX Subtitle G—
Tax Provisions Related to “Promoting Economic Security” as amended by S.Amdt.
                                       891
 Section Title                              Description                                  CRS Resources

 Subtitle G—Promoting Economic Security
 Part 1—2021 Recovery Rebates to Individuals
 Recovery Rebates to     Would enact a third round of direct payments            For more information, see
 Individuals             for individuals and households (“stimulus                  CRS Insight IN11624, COVID-
                         checks”). These payments would be structured as             19 and Direct Payments: How
                         refundable tax credits against 2021 income taxes,           Do the “Stimulus Check”
                         but would be issued (and hence received) in                 Phaseouts Differ Between the
                         2021, as opposed to 2022 (when 2021 income                  House-Passed American Rescue
                         tax returns will be filed). Amount and eligibility          Plan and Senate Amendment
                         for the advanced credit would generally be based            891?, by Margot L. Crandall-
                         on information from 2020 income tax returns (or             Hollick.
                         2019 returns, if 2020 returns have not been filed
                         when the advanced credit is initially issued). For         CRS Insight IN11628, Estimated
                         households whose payment was based on 2019                  “Direct Payments” by State
                         income data, and who would be eligible to                   Under the House and Senate
                         receive a larger payment based on 2020 data, the            Versions of the American Rescue
                         IRS would be directed to issue a supplementary              Plan Act of 2021 (H.R. 1319), by
                         payment (a “top up”) within 90 days of the tax              Conor F. Boyle and Jameson
                         filing deadline or September 1, 2021, whichever             A. Carter.
                         date is earlier.                                           CRS Insight IN11604, COVID-
                         Payments would generally be issued per                      19 and Direct Payments:
                         household and equal the sum of $1,400 per                   Frequently Asked Questions
                         eligible individual ($2,800 for married joint filers)       (FAQs) About the Proposed Third
                         and $1,400 for each eligible dependent (including           Round of “Stimulus Checks” in
                         older children and adult dependents). For each              the American Rescue Plan Act of
                         individual who died before January 1, 2021, the             2021 (ARPA; H.R. 1319), by
                         payment amount would be reduced from $1,400                 Margot L. Crandall-Hollick.
                         to $0.                                                     CRS Insight IN11605, COVID-
                         The payment would phase out ratably (i.e.,                  19 and Direct Payments:
                         proportionally) between $75,000 and $80,000 for             Comparison of First and Second
                         single filers, $112,500 and $120,000 for head of            Round of “Stimulus Checks” to a
                         household filers, and $150,000 and $160,000 for             Proposed Third Round in the
                         married joint filers. The larger the total credit           American Rescue Plan Act of
                         amount, the faster the payment would phase out              2021 (ARPA; H.R. 1319), by
                         using this method.                                          Margot L. Crandall-Hollick.
                         Eligible individuals and dependents would               For background, see
                         generally need to have a social security number            CRS Report R46415, CARES
                         (SSN) to receive the payment. (Adoption                     Act (P.L. 116-136) Direct
                         taxpayer ID numbers would also be valid for                 Payments: Resources and
                         dependents.) The maximum payment amount                     Experts, coordinated by Margot
                         ($1,400) would be reduced to $0 for each                    L. Crandall-Hollick.
                         otherwise eligible individual or qualifying
                                                                                    CRS Insight IN11576, COVID-
                         dependent who does not have an SSN (i.e., they
                                                                                     19 and Direct Payments to
                         have an individual taxpayer identification number,
                                                                                     Individuals: Comparison of the
                         or ITIN, instead). This provision would not apply
                                                                                     Second Round of “Stimulus
                         to married members of the Armed Forces if at
                                                                                     Checks” in P.L. 116-260 to the
                         least one spouse had an SSN. In such cases, they
                                                                                     First Round in the CARES Act
                         would be eligible for up to $2,800. If no eligible
                                                                                     (P.L. 116-136), by Margot L.
                         individual had an SSN (i.e., an unmarried taxpayer
                                                                                     Crandall-Hollick.
                         does not have an SSN or neither spouse of a
                         married joint filing couple has an SSN), they              CRS Insight IN11575, COVID-
                                                                                     19 and Direct Payments to




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 Section Title                              Description                                  CRS Resources
                         would still receive a payment for a qualifying              Individuals: Frequently Asked
                         dependent with an SSN.                                      Questions (FAQs) About the
                         The advanced payment of the credit would                    Second Round of “Stimulus
                         generally be exempt from offset by Treasury                 Checks” in P.L. 116-260, by
                         prior to when the payment is issued for certain             Margot L. Crandall-Hollick.
                         past-due debts owed by the recipient (including            CRS Insight IN11580, COVID-
                         past-due child support). However, the amount                19 and Direct Payments:
                         the taxpayer would claim as a credit on their               Summary of the CASH Act (H.R.
                         2021 tax returns would generally be subject to              9051, 116th Congress)
                         offset.                                                     Modifications to “Stimulus
                         For eligible individuals who did not file a 2020 or         Checks,” by Margot L. Crandall-
                         2019 income tax return, the IRS would be given              Hollick.
                         broad authority to make payments based on
                         information available to the Treasury, in a similar
                         manner as was done with the second round of
                         payments enacted under P.L. 116-260.
                         Treasury would be directed to make payments to
                         the U.S. territories (mirror code and non-mirror
                         code) equal to the aggregate amount issued to
                         their residents as a result of this provision. (Many
                         territorial residents will receive this benefit under
                         a version of the provision administered via the
                         territorial government, rather than the IRS.)
                         These payments would not be taxable. In
                         addition, like other tax credits, these payments
                         would not count as income or resources for a
                         12-month period in determining eligibility for, or
                         the amount of assistance provided by, any
                         federally funded public benefit program.
                         If a taxpayer received a larger advanced credit in
                         2021 than they were eligible for on their 2021
                         income tax return, they generally would not be
                         required to pay it back. If an individual received
                         an advanced payment less than what they were
                         eligible for on their 2021 income tax return, they
                         could claim the difference on that return (filed in
                         2021).
 Part 2—Child Tax Credit
 Child Tax Credit        For 2021, would temporarily increase the                For more information, see
 Improvements for        amount of the child tax credit for low- and                CRS Insight IN11613, The Child
 2021                    moderate-income taxpayers to up to $3,600 per               Tax Credit: Proposed Expansion
                         child for a young child and up to $3,000 for older          in the American Rescue Plan Act
                         children by modifying several provisions of the             of 2021 (ARPA; H.R. 1319), by
                         existing credit. First, the bill would eliminate the        Margot L. Crandall-Hollick.
                         earned-income-based phase-in of the refundable
                         portion of the child credit (often referred to as       For background, see
                         the “additional child credit” or ACTC) and                 CRS Report R41873, The Child
                         eliminate the maximum amount of the ACTC                    Tax Credit: How It Works and
                         ($1,400). Hence, the child credit would be “fully           Who Receives It, by Margot L.
                         refundable” and available to otherwise eligible             Crandall-Hollick.
                         taxpayers with no earned income. Second, the               CRS Report R46502, The Child
                         bill would increase the maximum age for an                  Tax Credit: Selected Legislative
                         eligible child to 17. Third, the bill would increase        Proposals in the 116th Congress,
                         the maximum amount of the credit from $2,000                by Margot L. Crandall-Hollick.
                         per child to $3,600 per child for a young child (0-
                         5 years old) and $3,000 per child for an older



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                             Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                              Description                         CRS Resources
                         child (6-17 years old). This increase in the
                         maximum child credit of $1,600 per child for
                         young children and $1,000 per child for older
                         children would gradually phase out at a rate of
                         5% as income exceeded specified thresholds until
                         the credit amount equaled the current-law
                         maximum of $2,000 per child. These thresholds
                         would be $75,000 for single filers, $112,500 for
                         head of household filers, and $150,000 for
                         married joint filers. (The actual income level at
                         which the credit phased down to $2,000 per
                         child would depend on the number and age of
                         qualifying children.) For most families, the credit
                         would then remain at its current-law level and
                         phase out when income exceeded the current-
                         law thresholds of $200,000 ($400,000 for
                         married joint filers).a
                         Would direct the Treasury to issue half of the
                         expected 2021 credit in periodic payments
                         beginning July 1, 2021. These periodic payments
                         would generally be of equal size. The remaining
                         half of the total 2021 credit would be claimed on
                         a 2021 income tax return filed in early 2022. The
                         amount of the payments advanced in 2021 would
                         be estimated based on 2020 income tax data, or
                         if unavailable, 2019 income tax data. The
                         advanced child credit payments would reduce the
                         child credit received with a 2021 return. In cases
                         where a taxpayer receives more in advanced
                         payments than they are eligible for (whether due
                         to changes in income, changes in filing status, or
                         changes in the number of eligible children who
                         live with the taxpayer between 2021 and the year
                         that provides data on which the advanced credit
                         is based [2020 or 2019]), taxpayers would
                         generally need to repay total aggregate advanced
                         payments. In cases where a taxpayer received
                         excess advanced payments due to net changes in
                         the number of qualifying children between 2020
                         (or 2019) and 2021, repayment obligations would
                         be reduced for low- and moderate-income
                         taxpayers. Specifically, taxpayers with income
                         below $40,000 for single filers, $50,000 for head
                         of household filers, and $60,000 for joint filers in
                         2021 would not need to repay up to $2,000 per
                         qualifying child in advanced credit overpayments
                         (the $2,000 amount is referred to as the “safe
                         harbor amount”). Taxpayers with income above
                         these thresholds but below $80,000 for single
                         filers, $100,000 for head of household filers, and
                         $120,000 for married joint filers would gradually
                         have the safe harbor amount reduced to $0 per
                         qualifying child. Hence, taxpayers with income
                         over $80,000 for single filers, $100,000 for head
                         of household filers, and $120,000 for married
                         joint filers in 2021 would need to repay the
                         entire amount of the overpayment.




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                               Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                                Description                                CRS Resources
                          The bill would create an online portal to allow
                          taxpayers the options to opt out of receiving
                          advanced payments and to provide information
                          regarding changes in income, marital status, and
                          number of qualifying children in order to modify
                          the advanced credit amounts.
                          Advanced payments would not be subject to
                          offset prior to when the payment is issued for
                          certain past-due debts owed by the recipient.
                          However, the amount the taxpayer claims as a
                          credit on their 2021 tax returns would generally
                          be subject to offset.
                          The bill would allow the Treasury to adjust
                          income tax withholding to accommodate these
                          advance payments.
                          Advanced payments would generally not be
                          available to eligible residents of U.S. territories.
 Application of the       Would effectively expand child credit eligibility to   For background, see
 Child Tax Credit in      residents of U.S. territories permanently. For            CRS Report R44651, Tax Policy
 Possessions              “mirror code” territories, the Treasury would              and U.S. Territories: Overview
                          make payments equal to the territory’s costs of            and Issues for Congress, by Sean
                          the child tax credit. For American Samoa (a non-           Lowry.
                          mirror code territory), the Treasury would make
                          payments equal to the territory’s costs of the
                          child tax credit as if it were a mirror code
                          territory. In contrast, eligible residents of Puerto
                          Rico (also a non-mirror code territory) would file
                          for the credit directly with the IRS.
 Part 3—Earned Income Tax Credit
 Strengthening the        For 2021, would temporarily expand both                For more information, see
 Earned Income Tax        eligibility for and the amount of the earned              CRS Insight IN11610, The
 Credit for Individuals   income tax credit (EITC) for taxpayers without             “Childless” EITC: Summary of
 with no Qualifying       qualifying children by modifying the eligibility age       Current Law and Proposed
 Children                 and credit formula.                                        Expansion in the American
                          Regarding eligibility age, would expand eligibility        Rescue Plan Act of 2021 (ARPA;
                          for the EITC for individuals with no qualifying            H.R. 1319), by Margot L.
                          children—sometimes referred to as the “childless           Crandall-Hollick.
                          EITC”—by reducing the minimum eligibility age          For background, see
                          from 25 to 19 for most workers. In other words,
                          this change would allow most eligible workers             CRS Report R43805, The
                          ages 19 to 24 to claim the childless EITC. For             Earned Income Tax Credit
                          students who are attending school at least part-           (EITC): How It Works and Who
                          time, the age limit would be temporarily reduced           Receives It, by Margot L.
                          from 25 to 24.b For former foster children and             Crandall-Hollick, Gene Falk,
                          youth who are homeless, the minimum age would              and Conor F. Boyle.
                          temporarily be reduced from 25 to 18. The bill
                          would also temporarily eliminate the upper age
                          limit, so workers aged 65 and older would be
                          eligible.
                          Regarding the credit amount, would temporarily
                          increase the childless EITC by increasing the
                          earned income amount (the minimum income
                          necessary to receive the maximum credit
                          amount) and phaseout threshold amount (the
                          maximum income level at which taxpayers
                          receive the maximum credit amount before it



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                              Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                               Description                                 CRS Resources
                          begins to phase out) to $9,820 and $11,610,
                          respectively, while also doubling the phase-in and
                          phaseout rates from 7.65% to 15.3%. The
                          maximum childless EITC would increase from
                          $543 to $1,502 in 2021.
 Taxpayer Eligible for    Would permanently allow taxpayers who
 Childless Earned         currently cannot claim the childless EITC because
 Income Credit in Case    all of their qualifying children do not have SSNs
 of Qualifying Children   to be eligible to claim the childless EITC.
 Who Fail to Meet
 Certain Identification
 Requirements
 Credit Allowed in        Would permanently allow married taxpayers
 Case of Certain          who file their tax returns as married filing
 Separated Spouses        separately to claim the EITC if they live with a
                          child for whom they can claim the EITC for more
                          than half the year and either (1) do not have the
                          same principal place of abode as their spouse for
                          the last six months of the year, or (2) have a
                          decree, instrument, or agreement (i.e., other
                          than a divorce decree) and do not live with their
                          spouse at the end of the year.
 Modification of          Would permanently modify the disqualified
 Disqualified             investment income test. Under current law,
 Investment Income        taxpayers with investment income over a certain
 Test                     threshold—$3,650 in 2020 and 2021—are
                          ineligible for the EITC. Disqualified investment
                          income is defined as interest income (including
                          tax-exempt interest), dividends, net rent, net
                          capital gains, and net passive income. It also
                          includes royalties from sources other than the
                          filer’s ordinary business activities. This provision
                          would permanently raise this amount to $10,000
                          and annually adjust it for inflation beginning in
                          2022.
 Application of Earned    Would permanently provide authority to make
 Income Tax Credit in     payments to Puerto Rico, American Samoa, and
 Possession of the        mirror-code territories for amounts they pay out
 United States            in the EITC. For Puerto Rico and American
                          Samoa, such payments would be contingent upon
                          increasing the amount of their EITC or enacting
                          an EITC, respectively.
 Temporary Special        For the purposes of calculating their EITC on
 Rule for Determining     their 2021 income tax return, would allow
 Earned Income for        taxpayers to substitute their 2019 earned income
 Purposes of Earned       for their 2021 earned income if their earned
 Income Tax Credit        income at the end of 2021 was less than their
                          2019 earned income.
 Part 4—Dependent Care Assistance
 Refundability and        For 2021, would temporarily expand the child           For background, see
 Enhancement of Child     and dependent care credit by making the credit            CRS Report R44993, Child and
 and Dependent Care       refundable and making it larger for most workers.          Dependent Care Tax Benefits:
 Tax Credit               The CDCTC credit amount is a product of the                How They Work and Who
                          amount of qualifying expenses (which is subject
                          to a cap) and the credit rate. The bill would



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 Section Title                              Description                              CRS Resources
                         increase the cap on qualifying expenses from            Receives Them, by Margot L.
                         $3,000 for one child and $6,000 for two or more         Crandall-Hollick.
                         children to $8,000 and $16,000, respectively. The
                         bill would also increase the credit rate for
                         workers with $185,000 or less of income (the
                         credit rate would remain the same as under
                         current law for those with income over $185,000
                         up to $400,000 [i.e., 20%], and be reduced from
                         current law for those with over $400,000 of
                         income). Specifically, for those with less than
                         $125,000 of income, the credit rate would
                         increase to 50% (from 35%) of expenses. This
                         50% credit rate would gradually phase down to
                         20% until taxpayers had $185,000 of income. For
                         those with more than $185,000 of income up to
                         $400,000, the credit rate would then remain at
                         20%, gradually falling to zero when income
                         exceeds $440,000. As a result, those with income
                         over $440,000 would not be eligible for the
                         credit.
                         By making the credit refundable, the bill would
                         effectively expand eligibility to lower-income
                         taxpayers. Under current law, the CDCTC is a
                         nonrefundable credit, meaning the value of the
                         credit cannot exceed a taxpayer’s income tax
                         liability. As a result, those with little or no
                         income tax liability, including many low-income
                         taxpayers, receive little or no benefit from the
                         current credit.
                         In combination, these changes would increase the
                         maximum amount of the CDCTC from $2,100 to
                         $8,000, based on expenses and income.
                         The bill would allow the Treasury to make
                         payments to Puerto Rico, American Samoa, and
                         mirror-code territories for the cost of providing
                         the refundable CDCTC in 2021 to their
                         territorial residents. (Non-mirror code
                         territories [i.e., Puerto Rico and American
                         Samoa] would need to develop a plan, approved
                         by the Treasury Secretary, to distribute the
                         amounts of the refundable CDCTC to their
                         residents.)
 Increase in Exclusion   For 2021, would temporarily increase the
 for Employer-           maximum amount of qualifying child care
 Provided Dependent      expenses that eligible taxpayers could exclude
 Care Assistance         from their income from $5,000 to $10,500.
 Part 5—Credits for Paid Sick and Family Leave
 Payroll Credits         Would extend the Families First Coronavirus         For background, see
                         Response Act (FFCRA; P.L. 116-127) employer            CRS In Focus IF11739, Payroll
                         payroll tax credits for paid sick and paid family       Tax Credit for COVID-19 Sick
                         leave from March 31, 2021, through September            and Family Leave, by Molly F.
                         30, 2021.                                               Sherlock.
                         FFCRA paid sick leave was limited to 10 days per
                         employee. This provision would reset the 10-day
                         limit, starting April 1, 2021, for employers




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 Section Title                              Description                          CRS Resources
                         claiming the credit for paid sick leave provided to
                         their employees.
                         Would expand the paid sick and paid family leave
                         credits to allow credits for leave taken to obtain
                         immunization related to COVID-19 or recover
                         from any injury, disability, illness, or condition
                         related to COVID-19 immunization.
                         Would expand the definition of qualifying paid
                         family leave to allow family leave payroll tax
                         credits to be claimed for all qualifying uses of paid
                         sick time, including for leave provided if the
                         employee is subject to a quarantine or isolation
                         order due to COVID-19 or is caring for
                         someone in a similar situation.
                         The tax credit for family leave wages is limited to
                         $200 per day, and $10,000 total per employee.
                         This provision would increase this limit on the
                         tax credit for paid family leave wages, allowing
                         the credit on up to $12,000 in paid family leave
                         wages.
                         Would add a nondiscrimination rule to the paid
                         leave payroll tax credits, providing employers
                         could not claim the credits if paid leave provided
                         to employees discriminates in favor of highly
                         compensated employees or full-time employees,
                         or discriminates on the basis of employment
                         tenure with the employer.
                         The paid sick and paid family leave tax credits are
                         currently claimed against the Old-Age, Survivors
                         and Disability Insurance (OASDI) tax, or the
                         equivalent amount of the Railroad Retirement
                         Tax Act (RRTA) tax. This provision would
                         restructure the paid sick and family leave payroll
                         tax credits to be claimed against the employer’s
                         share of the hospital insurance (HI) payroll tax,
                         after March 31, 2021. The employer’s share is
                         1.45% of wages paid to employees. This credit
                         would not affect amounts transferred to the
                         Federal Hospital Insurance Trust Fund.
                         Government employers, including state and local
                         government employers, are not allowed to claim
                         paid leave payroll tax credits. This provision
                         would provide that 501(c)(1) organizations and
                         501(a) organizations could claim the tax credits,
                         making certain state and local governments, as
                         well as 501(c)(1) federal government
                         instrumentalities, tax-credit eligible.
                         Provision provides that paid sick and paid family
                         leave payroll tax credits can be increased by the
                         employer’s share of OASDI and HI payroll taxes
                         (and equivalent RRTA tax) for the paid leave
                         wages. Denial of double benefit applies, and gross
                         income of the employer is increased by the
                         amount of the credit provided by this section.




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 Section Title                               Description                                 CRS Resources

 Credit for Sick Leave     Under FFCRA, self-employed individuals are            For background, see
 for Certain Self-         allowed a refundable income tax credit for paid          CRS In Focus IF11739, Payroll
 Employed Individuals      sick leave. This provision would extend and               Tax Credit for COVID-19 Sick
                           expand the paid sick leave tax credits for self-          and Family Leave, by Molly F.
                           employed individuals, similar to the modifications        Sherlock.
                           made for employers (described above).
 Credit for Family         Under FFCRA, self-employed individuals are            For background, see
 Leave for Certain Self-   allowed a refundable income tax credit for paid          CRS In Focus IF11739, Payroll
 Employed Individuals      family leave. This provision would extend and             Tax Credit for COVID-19 Sick
                           expand the paid family leave tax credits for self-        and Family Leave, by Molly F.
                           employed individuals, similar to the modifications        Sherlock.
                           made for employers (described above). Tax
                           credits could be claimed for up to 60 days of
                           family leave for self-employed individuals.
 Part 6—Employee Retention Credit
 Extension of              Through June 30, 2021, the employee retention         For background, see
 Employee Retention        and rehiring tax credit is 70% of qualified wages.       CRS In Focus IF11721, The
 Credit                    The refundable payroll credit can be computed             Employee Retention and
                           on up to $10,000 in qualified wages paid to an            Employee Retention and Rehiring
                           eligible employee per calendar quarter. Thus, the         Tax Credits, by Molly F.
                           maximum credit amount for 2021 is $14,000                 Sherlock.
                           (70% of up to $20,000 in qualified wages paid
                           over the first two quarters). Qualified wages
                           depend on the number of employees the
                           employer had in 2019. For employers with more
                           than 500 full-time employees, qualified wages are
                           wages paid when employee services are not
                           provided. For employers with 500 or fewer full-
                           time employees, all wages paid by eligible
                           employers are credit-eligible.
                           This provision would extend the employee
                           retention credit through December 31, 2021. A
                           credit of up to $50,000 per calendar quarter
                           would also be provided to recovery startup
                           businesses, defined as businesses established after
                           February 15, 2020, with average annual gross
                           receipts that do not exceed $1 million. Severely
                           financially distressed employers, those with gross
                           receipts that are less than 10% of what they were
                           in the same calendar quarter in 2019, would be
                           able to treat all wages as qualified wages. The
                           credit would be restructured to be claimed
                           against the employer’s share of the hospital
                           insurance (HI) payroll tax (as opposed to the
                           OSADI and equivalent amount of RRTA tax).




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 Section Title                              Description                                CRS Resources

 Part 7—Premium Tax Credit
 Improving               For 2021 and 2022, would temporarily expand           For background, see
 Affordability by        eligibility for and the amount of the premium tax        CRS Report R44425, Health
 Expanding Premium       credit (PTC) by modifying the income eligibility          Insurance Premium Tax Credits
 Assistance for          criteria and credit formula.                              and Cost-Sharing Subsidies, by
 Consumers               Regarding income, would temporarily expand                Bernadette Fernandez.
                         eligibility by eliminating the current-law phaseout
                         for households with annual incomes above 400%
                         of the federal poverty level (FPL).
                         Regarding the formula, would temporarily
                         increase the credit amount by reducing the
                         percentage of annual income that eligible
                         households would be required to contribute
                         toward the premium. The temporary percentages
                         would range from 0.0% to 8.5% of household
                         income, with higher-income groups subject to
                         the larger percentages, as specified.
 Temporary               For 2020, would temporarily provide tax relief to
 Modification of         individuals who would be subject to the current-
 Limitations on          law requirement to pay back PTC amounts that
 Reconciliation of Tax   were provided in excess. Would temporarily
 Credits for Coverage    suspend the recapture of excess credit amounts
 Under a Qualified       under the current tax reconciliation process.
 Health Plan with
 Advance Payments of
 Such Credit




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 Section Title                               Description                                  CRS Resources

 Application of           For 2021, would temporarily expand eligibility for      For background, see
 Premium Tax Credit       and the amount of the PTC for certain individuals          CRS Report R45478,
 in Case of Individuals   who receive unemployment compensation (UC).                 Unemployment Insurance:
 Receiving                Would temporarily deem individuals who receive              Legislative Issues in the 116th
 Unemployment             UC for any week in calendar year 2021 to have               Congress, by Julie M. Whittaker
 Compensation During      met the PTC income eligibility criteria. Would              and Katelin P. Isaacs.
 2021                     temporarily disregard any household income
                          above 133% FPL.
 Part 8—Miscellaneous Provisions
 Repeal of Election to    U.S. firms are eligible for foreign tax credits up to   For background, see
 Allocation Interest,     the amount of U.S. tax paid on foreign-source              CRS Report RL34494, The
 Etc. on Worldwide        income. To impose this limit, U.S. and foreign-             Foreign Tax Credit’s Interest
 Basis                    source income must be determined. Certain                   Allocation Rules, by Jane G.
                          deductions are allocated between U.S. and                   Gravelle and Donald J.
                          foreign sources, including interest. Until 2021,            Marples.
                          firms allocated interest excluding that paid by
                          foreign firms (called “waters edge” allocation).
                          Under current law, beginning in 2021, firms can
                          elect to include interest paid by related foreign
                          firms. This treatment is called worldwide
                          allocation. It is beneficial for some firms because
                          some of the interest paid for foreign firms is
                          allocated to U.S. sources, increasing foreign-
                          source income, increasing the limit on the foreign
                          tax credit and, thus, increasing foreign tax credits
                          that reduce tax liability. A provision was adopted
                          in 2004 to move to worldwide allocation, but it
                          has been delayed by other legislation and is
                          scheduled to begin in 2021. This provision would
                          repeal the election to move to worldwide
                          allocation.
 Tax Treatment of         Under normal tax rules, a forgiven debt is              For background, see
 Targeted Economic        generally treated as taxable income to the                 CRS Insight IN11378, IRS
 Injury Disaster Loan     borrower. Prior legislation has allowed forgiven            Guidance Says No Deduction Is
 Advances                 loans for certain programs (such as those                   Allowed for Business Expenses
                          provided by the Paycheck Protection Program, or             Paid with Forgiven PPP Loans, by
                          PPP, and certain other small business loans) to be          Sean Lowry and Jane G.
                          excluded from income. Following an IRS ruling               Gravelle.
                          that associated expenses would not be
                          deductible, legislation specified that associated          CRS Report R46284, COVID-19
                          expenses would be deductible. This provision                Relief Assistance to Small
                          would extend this treatment (exclusion from                 Businesses: Issues and Policy
                          income and deduction of expenses) to additional             Options, by Robert Jay Dilger,
                          Economic Injury Disaster Loan (EIDL) advances               Bruce R. Lindsay, and Sean
                          on loans that are not required to be repaid.                Lowry.
                                                                                     CRS Insight IN11370, SBA EIDL
                                                                                      and Emergency EIDL Grants for
                                                                                      COVID-19, by Bruce R. Lindsay.
 Tax Treatment of         Under normal tax rules, a forgiven debt is treated      For background, see
 Restaurant               as taxable income to the borrower. Prior                   CRS Insight IN11378, IRS
 Revitalization Grants    legislation has allowed forgiven loans for certain          Guidance Says No Deduction Is
                          programs (such as those provided by the                     Allowed for Business Expenses
                          Paycheck Protection Program, or PPP, and                    Paid with Forgiven PPP Loans, by
                          certain other small business loans) to be                   Sean Lowry and Jane G.
                          excluded from income. Following an IRS ruling               Gravelle.
                          that associated expenses would not be



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                               Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                               Description                                  CRS Resources
                          deductible, legislation specified that associated         CRS Report R46284, COVID-19
                          expenses would be deductible. This provision               Relief Assistance to Small
                          would extend this treatment (exclusion from                Businesses: Issues and Policy
                          income and deduction of expenses) to additional            Options, by Robert Jay Dilger,
                          grants made from the new Restaurant                        Bruce R. Lindsay, and Sean
                          Revitalization Fund.                                       Lowry.
 Modification of          Credit card companies and electronic payment
 Exceptions for           processors are required to annually file aggregate
 Reporting of Third       transaction reports with the IRS listing total
 Party Network            annual payments to merchants (Internal Revenue
 Transactions             Code §6050W). A de minimus reporting
                          exception provides that third-party settlement
                          organizations are only required to report
                          transactions of payees who receive more than
                          $20,000 and conduct more than 200 transactions
                          per year. This provision would modify the
                          threshold for reporting, setting it at $600 per
                          year.
 Modification of          Would exclude from gross income qualifying            For background, see
 Treatment of Student     student loans for postsecondary education                 CRS Report R43571, Federal
 Loan Forgiveness         discharged, for almost any reason, between                 Student Loan Forgiveness and
                          December 31, 2020, and January 1, 2026.                    Loan Repayment Programs,
                          Qualifying student loans would include all federal         coordinated by Alexandra
                          student loans, and certain private education and           Hegji.
                          institutional loans. Hence, these amounts of
                          discharged student loan debt would not be                 CRS Report R45931, Federal
                          subject to taxation.                                       Student Loans Made Through the
                                                                                     William D. Ford Federal Direct
                                                                                     Loan Program: Terms and
                                                                                     Conditions for Borrowers, by
                                                                                     David P. Smole.

    Source: H.R. 1319 Title IX Subtitle G, as amended by S.Amdt. 891.
    a.   For example, if a married couple had three children under 6 years old, the maximum credit they would be
         eligible for would be $10,800 ($3,600 x 3) if they had income under $150,000. For taxpayers with income
         over $150,000, the additional $4,800 of the credit ($1,600 x 3) would be reduced at a rate of 5%. At
         $246,000 of income, the credit would be $6,000 ($2,000 x 3), the current-law amount. The credit would
         remain at this amount until the taxpayer’s income reached the current-law thresholds of $400,000. At that
         point, the credit would phase out under the provisions of current law (5% phaseout rate).
    b.   The legislation includes as part of the definition of a student someone carrying half or more of the normal
         full-time workload for their program of study, as defined under Internal Revenue Code (IRC) §25A(b)(3).




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Table 2. American Rescue Plan Act of 2021 (ARPA; H.R. 1319); Title IX Subtitle G—
 Tax Provisions Related to “Promoting Economic Security” as passed the House of
                        Representatives February 27, 2021
 Section Title                              Description                                  CRS Resources

 Subtitle G—Promoting Economic Security
 Part 1—2021 Recovery Rebates to Individuals
 Recovery Rebates to     Would enact a third round of direct payments            For more information, see
 Individuals             for individuals and households (“stimulus                  CRS Insight IN11604, COVID-
                         checks”). These payments would be structured as             19 and Direct Payments:
                         refundable tax credits against 2021 income taxes,           Frequently Asked Questions
                         but would be issued (and hence received) in                 (FAQs) About the Proposed Third
                         2021, as opposed to 2022 (when 2021 income                  Round of “Stimulus Checks” in
                         tax returns will be filed). Amount and eligibility          the American Rescue Plan Act of
                         for the advanced credit would generally be based            2021 (ARPA; H.R. 1319), by
                         on information from 2020 income tax returns (or             Margot L. Crandall-Hollick.
                         2019 returns, if 2020 returns have not been filed
                         when the advanced credit is initially issued). For         CRS Insight IN11605, COVID-
                         households whose payment was based on 2019                  19 and Direct Payments:
                         income data, and who would be eligible to                   Comparison of First and Second
                         receive a larger payment based on 2020 data, the            Round of “Stimulus Checks” to a
                         IRS would be directed to issue a supplementary              Proposed Third Round in the
                         payment (a “top up”) within 90 days of the tax              American Rescue Plan Act of
                         filing deadline or September 1, 2021, whichever             2021 (ARPA; H.R. 1319), by
                         date is earlier.                                            Margot L. Crandall-Hollick.
                         Payments would generally be issued per                  For background, see
                         household and equal the sum of $1,400 per                  CRS Report R46415, CARES
                         eligible individual ($2,800 for married joint filers)       Act (P.L. 116-136) Direct
                         and $1,400 for each eligible dependent (including           Payments: Resources and
                         older children and adult dependents). For each              Experts, coordinated by Margot
                         individual who died before January 1, 2021, the             L. Crandall-Hollick.
                         payment amount would be reduced from $1,400                CRS Insight IN11576, COVID-
                         to $0.                                                      19 and Direct Payments to
                         The payment would phase out ratably (i.e.,                  Individuals: Comparison of the
                         proportionally) between $75,000 and $100,000                Second Round of “Stimulus
                         for single filers, $112,500 and $150,000 for head           Checks” in P.L. 116-260 to the
                         of household filers, and $150,000 and $200,000              First Round in the CARES Act
                         for married joint filers. The larger the total credit       (P.L. 116-136), by Margot L.
                         amount, the faster the payment would phase out              Crandall-Hollick.
                         using this method.
                                                                                    CRS Insight IN11575, COVID-
                         Eligible individuals and dependents would                   19 and Direct Payments to
                         generally need to have a social security number             Individuals: Frequently Asked
                         (SSN) to receive the payment. (Adoption                     Questions (FAQs) About the
                         taxpayer ID numbers would also be valid for                 Second Round of “Stimulus
                         dependents.) The maximum payment amount                     Checks” in P.L. 116-260, by
                         ($1,400) would be reduced to $0 for each                    Margot L. Crandall-Hollick.
                         otherwise eligible individual or qualifying
                                                                                    CRS Insight IN11580, COVID-
                         dependent who does not have an SSN (i.e., they
                                                                                     19 and Direct Payments:
                         have an individual taxpayer identification number,
                                                                                     Summary of the CASH Act (H.R.
                         or ITIN, instead). This provision would not apply
                                                                                     9051, 116th Congress)
                         to married members of the Armed Forces if at
                                                                                     Modifications to “Stimulus
                         least one spouse had an SSN. In such cases, they
                                                                                     Checks”, by Margot L. Crandall-
                         would be eligible for up to $2,800. If no eligible
                                                                                     Hollick.
                         individual had an SSN (i.e., an unmarried taxpayer
                         does not have an SSN or neither spouse of a
                         married joint filing couple has an SSN), they




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 Section Title                              Description                                  CRS Resources
                         would still receive a payment for a qualifying
                         dependent with an SSN.
                         The advanced payment of the credit would
                         generally be exempt from offset by Treasury
                         prior to when the payment is issued for certain
                         past-due debts owed by the recipient (including
                         past-due child support). However, the amount
                         the taxpayer would claim as a credit on their
                         2021 tax returns would generally be subject to
                         offset.
                         For eligible individuals who did not file a 2020 or
                         2019 income tax return, the IRS would be given
                         broad authority to make payments based on
                         information available to the Treasury, in a similar
                         manner as was done with the second round of
                         payments enacted under P.L. 116-260.
                         Treasury would be directed to make payments to
                         the U.S. territories (mirror code and non-mirror
                         code) equal to the aggregate amount issued to
                         their residents as a result of this provision. (Many
                         territorial residents will receive this benefit under
                         a version of the provision administered via the
                         territorial government, rather than the IRS.)
                         These payments would not be taxable. In
                         addition, like other tax credits, these payments
                         would not count as income or resources for a
                         12-month period in determining eligibility for, or
                         the amount of assistance provided by, any
                         federally funded public benefit program.
                         If a taxpayer received a larger advanced credit in
                         2021 than they were eligible for on their 2021
                         income tax return, they generally would not be
                         required to pay it back. If an individual received
                         an advanced payment less than what they were
                         eligible for on their 2021 income tax return, they
                         could claim the difference on that return (filed in
                         2021).
 Part 2—Child Tax Credit
 Child Tax Credit        For 2021, would temporarily increase the                For more information, see
 Improvements for        amount of the child tax credit for low- and                CRS Insight IN11613, The Child
 2021                    moderate-income taxpayers to up to $3,600 per               Tax Credit: Proposed Expansion
                         child for a young child and up to $3,000 for older          in the American Rescue Plan Act
                         children by modifying several provisions of the             of 2021 (ARPA; H.R. 1319), by
                         existing credit. First, the bill would eliminate the        Margot L. Crandall-Hollick.
                         earned-income-based phase-in of the refundable
                         portion of the child credit (often referred to as       For background, see
                         the “additional child credit” or ACTC) and                 CRS Report R41873, The Child
                         eliminate the maximum amount of the ACTC                    Tax Credit: How It Works and
                         ($1,400). Hence, the child credit would be “fully           Who Receives It, by Margot L.
                         refundable” and available to otherwise eligible             Crandall-Hollick.
                         taxpayers with no earned income. Second, the               CRS Report R46502, The Child
                         bill would increase the maximum age for an                  Tax Credit: Selected Legislative
                         eligible child to 17. Third, the bill would increase        Proposals in the 116th Congress,
                         the maximum amount of the credit from $2,000                by Margot L. Crandall-Hollick.
                         per child to $3,600 per child for a young child (0-
                         5 years old) and $3,000 per child for an older



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 Section Title                              Description                         CRS Resources
                         child (6-17 years old). This increase in the
                         maximum child credit of $1,600 per child for
                         young children and $1,000 per child for older
                         children would gradually phase out at a rate of
                         5% as income exceeded specified thresholds until
                         the credit amount equaled the current-law
                         maximum of $2,000 per child. These thresholds
                         would be $75,000 for single filers, $112,500 for
                         head of household filers, and $150,000 for
                         married joint filers. (The actual income level at
                         which the credit phased down to $2,000 per
                         child would depend on the number and age of
                         qualifying children.) For most families, the credit
                         would then remain at its current-law level and
                         phase out when income exceeded the current-
                         law thresholds of $200,000 ($400,000 for
                         married joint filers).a
                         Would direct the Treasury to issue half of the
                         expected 2021 credit in periodic payments
                         beginning July 1, 2021. These periodic payments
                         would generally be of equal size. The remaining
                         half of the total 2021 credit would be claimed on
                         a 2021 income tax return filed in early 2022. The
                         amount of the payments advanced in 2021 would
                         be estimated based on 2020 income tax data, or
                         if unavailable, 2019 income tax data. The
                         advanced child credit payments would reduce the
                         child credit received with a 2021 return. In cases
                         where a taxpayer receives more in advanced
                         payments than they are eligible for (whether due
                         to changes in income, changes in filing status, or
                         changes in the number of eligible children who
                         live with the taxpayer between 2021 and the year
                         that provides data on which the advanced credit
                         is based [2020 or 2019]), taxpayers would
                         generally need to repay total aggregate advanced
                         payments. In cases where a taxpayer received
                         excess advanced payments due to net changes in
                         the number of qualifying children between 2020
                         (or 2019) and 2021, repayment obligations would
                         be reduced for low- and moderate-income
                         taxpayers. Specifically, taxpayers with income
                         below $40,000 for single filers, $50,000 for head
                         of household filers, and $60,000 for joint filers in
                         2021 would not need to repay up to $2,000 per
                         qualifying child in advanced credit overpayments
                         (the $2,000 amount is referred to as the “safe
                         harbor amount”). Taxpayers with income above
                         these thresholds but below $80,000 for single
                         filers, $100,000 for head of household filers, and
                         $120,000 for married joint filers would gradually
                         have the safe harbor amount reduced to $0 per
                         qualifying child. Hence, taxpayers with income
                         over $80,000 for single filers, $100,000 for head
                         of household filers, and $120,000 for married
                         joint filers in 2021 would need to repay the
                         entire amount of the overpayment.




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 Section Title                                Description                                CRS Resources
                          The bill would create an online portal to allow
                          taxpayers the options to opt out of receiving
                          advanced payments and to provide information
                          regarding changes in income, marital status, and
                          number of qualifying children in order to modify
                          the advanced credit amounts.
                          Advanced payments would not be subject to
                          offset prior to when the payment is issued for
                          certain past-due debts owed by the recipient.
                          However, the amount the taxpayer claims as a
                          credit on their 2021 tax returns would generally
                          be subject to offset.
                          The bill would allow the Treasury to adjust
                          income tax withholding to accommodate these
                          advance payments.
                          Advanced payments would generally not be
                          available to eligible residents of U.S. territories.
 Application of the       Would effectively expand child credit eligibility to   For background, see
 Child Tax Credit in      residents of U.S. territories permanently. For            CRS Report R44651, Tax Policy
 Possessions              “mirror code” territories, the Treasury would              and U.S. Territories: Overview
                          make payments equal to the territory’s costs of            and Issues for Congress, by Sean
                          the child tax credit. For American Samoa (a non-           Lowry.
                          mirror code territory), the Treasury would make
                          payments equal to the territory’s costs of the
                          child tax credit as if it were a mirror code
                          territory. In contrast, eligible residents of Puerto
                          Rico (also a non-mirror code territory) would file
                          for the credit directly with the IRS.
 Part 3—Earned Income Tax Credit
 Strengthening the        For 2021, would temporarily expand both                For more information, see
 Earned Income Tax        eligibility for and the amount of the earned              CRS Insight IN11610, The
 Credit for Individuals   income tax credit (EITC) for taxpayers without             “Childless” EITC: Summary of
 with no Qualifying       qualifying children by modifying the eligibility age       Current Law and Proposed
 Children                 and credit formula.                                        Expansion in the American
                          Regarding eligibility age, would expand eligibility        Rescue Plan Act of 2021 (ARPA;
                          for the EITC for individuals with no qualifying            H.R. 1319), by Margot L.
                          children—sometimes referred to as the “childless           Crandall-Hollick.
                          EITC”—by reducing the minimum eligibility age          For background, see
                          from 25 to 19 for most workers. In other words,
                          this change would allow most eligible workers             CRS Report R43805, The
                          ages 19 to 24 to claim the childless EITC. For             Earned Income Tax Credit
                          students who are attending school at least part-           (EITC): How It Works and Who
                          time, the age limit would be temporarily reduced           Receives It, by Margot L.
                          from 25 to 24.b For former foster children and             Crandall-Hollick, Gene Falk,
                          youth who are homeless, the minimum age would              and Conor F. Boyle.
                          temporarily be reduced from 25 to 18. The bill
                          would also temporarily eliminate the upper age
                          limit, so workers aged 65 and older would be
                          eligible.
                          Regarding the credit amount, would temporarily
                          increase the childless EITC by increasing the
                          earned income amount (the minimum income
                          necessary to receive the maximum credit
                          amount) and phaseout threshold amount (the
                          maximum income level at which taxpayers
                          receive the maximum credit amount before it



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 Section Title                               Description                                 CRS Resources
                          begins to phase out) to $9,820 and $11,610,
                          respectively, while also doubling the phase-in and
                          phaseout rates from 7.65% to 15.3%. The
                          maximum childless EITC would increase from
                          $543 to $1,502 in 2021.
 Taxpayer Eligible for    Would permanently allow taxpayers who
 Childless Earned         currently cannot claim the childless EITC because
 Income Credit in Case    all of their qualifying children do not have SSNs
 of Qualifying Children   to be eligible to claim the childless EITC.
 Who Fail to Meet
 Certain Identification
 Requirements
 Credit Allowed in        Would permanently allow married taxpayers
 Case of Certain          who file their tax returns as married filing
 Separated Spouses        separately to claim the EITC if they live with a
                          child for whom they can claim the EITC for more
                          than half the year and either (1) do not have the
                          same principal place of abode as their spouse for
                          the last six months of the year, or (2) have a
                          decree, instrument, or agreement (i.e., other
                          than a divorce decree) and do not live with their
                          spouse at the end of the year.
 Modification of          Would permanently modify the disqualified
 Disqualified             investment income test. Under current law,
 Investment Income        taxpayers with investment income over a certain
 Test                     threshold—$3,650 in 2020 and 2021—are
                          ineligible for the EITC. Disqualified investment
                          income is defined as interest income (including
                          tax-exempt interest), dividends, net rent, net
                          capital gains, and net passive income. It also
                          includes royalties from sources other than the
                          filer’s ordinary business activities. This provision
                          would permanently raise this amount to $10,000
                          and annually adjust it for inflation beginning in
                          2022.
 Application of Earned    Would permanently provide authority to make
 Income Tax Credit in     payments to Puerto Rico, American Samoa, and
 Possession of the        mirror-code territories for amounts they pay out
 United States            in the EITC. For Puerto Rico and American
                          Samoa, such payments would be contingent upon
                          increasing the amount of their EITC or enacting
                          an EITC, respectively.
 Temporary Special        For the purposes of calculating their EITC on
 Rule for Determining     their 2021 income tax return, would allow
 Earned Income for        taxpayers to substitute their 2019 earned income
 Purposes of Earned       for their 2021 earned income if their earned
 Income Tax Credit        income at the end of 2021 was less than their
                          2019 earned income.
 Part 4—Dependent Care Assistance
 Refundability and        For 2021, would temporarily expand the child           For background, see
 Enhancement of Child     and dependent care credit by making the credit            CRS Report R44993, Child and
 and Dependent Care       refundable and making it larger for most workers.          Dependent Care Tax Benefits:
 Tax Credit               The CDCTC credit amount is a product of the                How They Work and Who
                          amount of qualifying expenses (which is subject            Receives Them, by Margot L.
                          to a cap) and the credit rate. The bill would



Congressional Research Service                                                                                  19
                             Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                              Description                              CRS Resources
                         increase the cap on qualifying expenses from            Crandall-Hollick and Conor F.
                         $3,000 for one child and $6,000 for two or more         Boyle.
                         children to $8,000 and $16,000, respectively. The
                         bill would also increase the credit rate for
                         workers with $185,000 or less of income (the
                         credit rate would remain the same as under
                         current law for those with income over $185,000
                         up to $400,000 [i.e., 20%], and be reduced from
                         current law for those with over $400,000 of
                         income). Specifically, for those with less than
                         $125,000 of income, the credit rate would
                         increase to 50% (from 35%) of expenses. This
                         50% credit rate would gradually phase down to
                         20% until taxpayers had $185,000 of income. For
                         those with more than $185,000 of income up to
                         $400,000, the credit rate would then remain at
                         20%, gradually falling to zero when income
                         exceeds $440,000. As a result, those with income
                         over $440,000 would not be eligible for the
                         credit.
                         By making the credit refundable, the bill would
                         effectively expand eligibility to lower-income
                         taxpayers. Under current law, the CDCTC is a
                         nonrefundable credit, meaning the value of the
                         credit cannot exceed a taxpayer’s income tax
                         liability. As a result, those with little or no
                         income tax liability, including many low-income
                         taxpayers, receive little or no benefit from the
                         current credit.
                         In combination, these changes would increase the
                         maximum amount of the CDCTC from $2,100 to
                         $8,000, based on expenses and income.
                         The bill would allow the Treasury to make
                         payments to Puerto Rico, American Samoa, and
                         mirror-code territories for the cost of providing
                         the refundable CDCTC in 2021 to their
                         territorial residents. (Non-mirror code
                         territories [i.e., Puerto Rico and American
                         Samoa] would need to develop a plan, approved
                         by the Treasury Secretary, to distribute the
                         amounts of the refundable CDCTC to their
                         residents.)
 Increase in Exclusion   For 2021, would temporarily increase the
 for Employer-           maximum amount of qualifying child care
 Provided Dependent      expenses that eligible taxpayers could exclude
 Care Assistance         from their income from $5,000 to $10,500.
 Part 5—Credits for Paid Sick and Family Leave
 Payroll Credits         Would extend the Families First Coronavirus         For background, see
                         Response Act (FFCRA; P.L. 116-127) employer            CRS In Focus IF11739, Payroll
                         payroll tax credits for paid sick and paid family       Tax Credit for COVID-19 Sick
                         leave from March 31, 2021, through September            and Family Leave, by Molly F.
                         30, 2021.                                               Sherlock.
                         FFCRA paid sick leave was limited to 10 days per
                         employee. This provision would reset the 10-day
                         limit, starting April 1, 2021, for employers




Congressional Research Service                                                                                   20
                             Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                              Description                          CRS Resources
                         claiming the credit for paid sick leave provided to
                         their employees.
                         Would expand the paid sick and paid family leave
                         credits to allow credits for leave taken to obtain
                         immunization related to COVID-19 or recover
                         from any injury, disability, illness, or condition
                         related to COVID-19 immunization.
                         Would expand the definition of qualifying paid
                         family leave to allow family leave payroll tax
                         credits to be claimed for all qualifying uses of paid
                         sick time, including for leave provided if the
                         employee is subject to a quarantine or isolation
                         order due to COVID-19 or is caring for
                         someone in a similar situation.
                         The tax credit for family leave wages is limited to
                         $200 per day, and $10,000 total per employee.
                         This provision would increase this limit on the
                         tax credit for paid family leave wages, allowing
                         the credit on up to $12,000 in paid family leave
                         wages.
                         Would add a nondiscrimination rule to the paid
                         leave payroll tax credits, providing employers
                         could not claim the credits if paid leave provided
                         to employees discriminates in favor of highly
                         compensated employees or full-time employees,
                         or discriminates on the basis of employment
                         tenure with the employer.
                         The paid sick and paid family leave tax credits are
                         currently claimed against the Old-Age, Survivors
                         and Disability Insurance (OASDI) tax, or the
                         equivalent amount of the Railroad Retirement
                         Tax Act (RRTA) tax. This provision would
                         restructure the paid sick and family leave payroll
                         tax credits to be claimed against the employer’s
                         share of the hospital insurance (HI) payroll tax,
                         after March 31, 2021. The employer’s share is
                         1.45% of wages paid to employees. This credit
                         would not affect amounts transferred to the
                         Federal Hospital Insurance Trust Fund.
                         Government employers, including state and local
                         government employers, are not allowed to claim
                         paid leave payroll tax credits. This provision
                         would provide that 501(c)(1) organizations and
                         501(a) organizations could claim the tax credits,
                         making certain state and local governments, as
                         well as 501(c)(1) federal government
                         instrumentalities, tax-credit eligible.
                         Provision provides that paid sick and paid family
                         leave payroll tax credits can be increased by the
                         employer’s share of OASDI and HI payroll taxes
                         (and equivalent RRTA tax) for the paid leave
                         wages. Denial of double benefit applies, and gross
                         income of the employer is increased by the
                         amount of the credit provided by this section.




Congressional Research Service                                                                        21
                               Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                               Description                                CRS Resources

 Credit for Sick Leave     Under FFCRA, self-employed individuals are           For background, see
 for Certain Self-         allowed a refundable income tax credit for paid         CRS In Focus IF11739, Payroll
 Employed Individuals      sick leave. This provision would extend and              Tax Credit for COVID-19 Sick
                           expand the paid sick leave tax credits for self-         and Family Leave, by Molly F.
                           employed individuals, similar to the modifications       Sherlock.
                           made for employers (described above).
 Credit for Family         Under FFCRA, self-employed individuals are           For background, see
 Leave for Certain Self-   allowed a refundable income tax credit for paid         CRS In Focus IF11739, Payroll
 Employed Individuals      family leave. This provision would extend and            Tax Credit for COVID-19 Sick
                           expand the paid family leave tax credits for self-       and Family Leave, by Molly F.
                           employed individuals, similar to the modifications       Sherlock
                           made for employers (described above). Tax
                           credits could be claimed for up to 60 days of
                           family leave for self-employed individuals.
 Part 6—Employee Retention Credit
 Extension of              Through June 30, 2021, the employee retention        For background, see
 Employee Retention        and rehiring tax credit is 70% of qualified wages.      CRS In Focus IF11721, The
 Credit                    The refundable payroll credit can be computed            Employee Retention and
                           on up to $10,000 in qualified wages paid to an           Employee Retention and Rehiring
                           eligible employee per calendar quarter. Thus, the        Tax Credits, by Molly F.
                           maximum credit amount for 2021 is $14,000                Sherlock.
                           (70% of up to $20,000 in qualified wages paid
                           over the first two quarters). Qualified wages
                           depend on the number of employees the
                           employer had in 2019. For employers with more
                           than 500 full-time employees, qualified wages are
                           wages paid when employee services are not
                           provided. For employers with 500 or fewer full-
                           time employees, all wages paid by eligible
                           employers are credit-eligible.
                           This provision would extend the employee
                           retention credit through December 31, 2021.
                           The credit would be restructured to be claimed
                           against the employer’s share of the hospital
                           insurance (HI) payroll tax (as opposed to the
                           OSADI and equivalent amount of RRTA tax).




Congressional Research Service                                                                                      22
                             Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                              Description                                CRS Resources

 Part 7—Premium Tax Credit
 Improving               For 2021 and 2022, would temporarily expand           For background, see
 Affordability by        eligibility for and the amount of the premium tax        CRS Report R44425, Health
 Expanding Premium       credit (PTC) by modifying the income eligibility          Insurance Premium Tax Credits
 Assistance for          criteria and credit formula.                              and Cost-Sharing Subsidies, by
 Consumers               Regarding income, would temporarily expand                Bernadette Fernandez.
                         eligibility by eliminating the current-law phaseout
                         for households with annual incomes above 400%
                         of the federal poverty level (FPL).
                         Regarding the formula, would temporarily
                         increase the credit amount by reducing the
                         percentage of annual income that eligible
                         households would be required to contribute
                         toward the premium. The temporary percentages
                         would range from 0.0% to 8.5% of household
                         income, with higher-income groups subject to
                         the larger percentages, as specified.
 Temporary               For 2020, would temporarily provide tax relief to
 Modification of         individuals who would be subject to the current-
 Limitations on          law requirement to pay back PTC amounts that
 Reconciliation of Tax   were provided in excess. Would temporarily
 Credits for Coverage    suspend the recapture of excess credit amounts
 Under a Qualified       under the current tax reconciliation process.
 Health Plan with
 Advance Payments of
 Such Credit




Congressional Research Service                                                                                      23
                              Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                               Description                                  CRS Resources

 Application of           For 2021, would temporarily expand eligibility for      For background, see
 Premium Tax Credit       and the amount of the PTC for certain individuals          CRS Report R45478,
 in Case of Individuals   who receive unemployment compensation (UC).                 Unemployment Insurance:
 Receiving                Would temporarily deem individuals who receive              Legislative Issues in the 116th
 Unemployment             UC for any week in calendar year 2021 to have               Congress, by Julie M. Whittaker
 Compensation During      met the PTC income eligibility criteria. Would              and Katelin P. Isaacs.
 2021                     temporarily disregard any household income
                          above 133% FPL.
 Part 8—Miscellaneous Provisions
 Repeal of Election to    U.S. firms are eligible for foreign tax credits up to   For background, see
 Allocation Interest,     the amount of U.S. tax paid on foreign-source              CRS Report RL34494, The
 Etc. on Worldwide        income. To impose this limit, U.S. and foreign-             Foreign Tax Credit’s Interest
 Basis                    source income must be determined. Certain                   Allocation Rules, by Jane G.
                          deductions are allocated between U.S. and                   Gravelle and Donald J.
                          foreign sources, including interest. Until 2021,            Marples.
                          firms allocated interest excluding that paid by
                          foreign firms (called “waters edge” allocation).
                          Under current law, beginning in 2021, firms can
                          elect to include interest paid by related foreign
                          firms. This treatment is called worldwide
                          allocation. It is beneficial for some firms because
                          some of the interest paid for foreign firms is
                          allocated to U.S. sources, increasing foreign-
                          source income, increasing the limit on the foreign
                          tax credit and, thus, increasing foreign tax credits
                          that reduce tax liability. A provision was adopted
                          in 2004 to move to worldwide allocation, but it
                          has been delayed by other legislation and is
                          scheduled to begin in 2021. This provision would
                          repeal the election to move to worldwide
                          allocation.
 Tax Treatment of         Under normal tax rules, a forgiven debt is              For background, see
 Targeted Economic        generally treated as taxable income to the                 CRS Insight IN11378, IRS
 Injury Disaster Loan     borrower. Prior legislation has allowed forgiven            Guidance Says No Deduction Is
 Advances                 loans for certain programs (such as those                   Allowed for Business Expenses
                          provided by the Paycheck Protection Program, or             Paid with Forgiven PPP Loans, by
                          PPP, and certain other small business loans) to be          Sean Lowry and Jane G.
                          excluded from income. Following an IRS ruling               Gravelle.
                          that associated expenses would not be
                          deductible, legislation specified that associated          CRS Report R46284, COVID-19
                          expenses would be deductible. This provision                Relief Assistance to Small
                          would extend this treatment (exclusion from                 Businesses: Issues and Policy
                          income and deduction of expenses) to additional             Options, by Robert Jay Dilger,
                          Economic Injury Disaster Loan (EIDL) advances               Bruce R. Lindsay, and Sean
                          on loans that are not required to be repaid.                Lowry.
                                                                                     CRS Insight IN11370, SBA EIDL
                                                                                      and Emergency EIDL Grants for
                                                                                      COVID-19, by Bruce R. Lindsay.
 Tax Treatment of         Under normal tax rules, a forgiven debt is treated      For background, see
 Restaurant               as taxable income to the borrower. Prior                   CRS Insight IN11378, IRS
 Revitalization Grants    legislation has allowed forgiven loans for certain          Guidance Says No Deduction Is
                          programs (such as those provided by the                     Allowed for Business Expenses
                          Paycheck Protection Program, or PPP, and                    Paid with Forgiven PPP Loans, by
                          certain other small business loans) to be                   Sean Lowry and Jane G.
                          excluded from income. Following an IRS ruling               Gravelle.
                          that associated expenses would not be



Congressional Research Service                                                                                           24
                               Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




 Section Title                               Description                                 CRS Resources
                          deductible, legislation specified that associated         CRS Report R46284, COVID-19
                          expenses would be deductible. This provision               Relief Assistance to Small
                          would extend this treatment (exclusion from                Businesses: Issues and Policy
                          income and deduction of expenses) to additional            Options, by Robert Jay Dilger,
                          grants made from the new Restaurant                        Bruce R. Lindsay, and Sean
                          Revitalization Fund.                                       Lowry.
 Modification of          Credit card companies and electronic payment
 Exceptions for           processors are required to annually file aggregate
 Reporting of Third       transaction reports with the IRS listing total
 Party Network            annual payments to merchants (Internal Revenue
 Transactions             Code §6050W). A de minimus reporting
                          exception provides that third-party settlement
                          organizations are only required to report
                          transactions of payees who receive more than
                          $20,000 and conduct more than 200 transactions
                          per year. This provision would modify the
                          threshold for reporting, setting it at $600 per
                          year.

    Source: H.R. 1319 Title IX Subtitle G, as passed the House on February 27, 2021.
    a.   For example, if a married couple had three children under 6 years old, the maximum credit they would be
         eligible for would be $10,800 ($3,600 x 3) if they had income under $150,000. For taxpa yers with income
         over $150,000, the additional $4,800 of the credit ($1,600 x 3) would be reduced at a rate of 5%. At
         $246,000 of income, the credit would be $6,000 ($2,000 x 3), the current -law amount. The credit would
         remain at this amount until the taxpayer’s income reached the current-law thresholds of $400,000. At that
         point, the credit would phase out under the provisions of current law (5% phaseout rate).
    b.   The legislation includes as part of the definition of a student someone carrying half or more of the normal
         full-time workload for their program of study, as defined under Internal Revenue Code (IRC) §25A(b)(3).




Congressional Research Service                                                                                         25
  Table 3. Estimated Cost of Title IX Subtitle G of the American Rescue Plan Act of 2021 (ARPA; H.R. 1319) as amended by
                                                         S.Amdt. 891
                                                            Fiscal Years; Millions of Dollars
 Provision                            2021       2022     2023       2024   2025       2026     2027    2028       2029    2030       2031       2021-2031

 Part 1—2021 Recovery Rebates to Individuals
 Recovery Rebates to Individuals      393,714    16,918          -      -          -       -        -          -       -          -       -         410,632
 Part 2—Child Tax Credit
 Child Tax Credit: Improvements for    25,826    79,249    710        721     725       721      307     311        316      320       323          109,529
 2021 and Application of the Child
 Tax Credit in Possessions
 Part 3—Earned Income Tax Credit
 Strengthening the Earned Income         521     11,361          -      -          -       -        -          -       -          -          -        11,882
 Tax Credit for Individuals with no
 Qualifying Children
 Taxpayer Eligible for Childless           (i)      12       2          1       1         1        2       2          2           2      2               26
 Earned Income Credit in Case of
 Qualifying Children Who Fail to
 Meet Certain Identification
 Requirements
 Credit Allowed in Case of Certain           1      20      21         22      23        25       25      27         28       30        31              252
 Separated Spouses
 Modification of Disqualified             24       330     198        200     225       229      238     233        231      240       251             2,399
 Investment Income Test
 Application of Earned Income Tax            -     738     746        764     781       798      814     831        849      867       885             8,074
 Credit in Possession of the United
 States
 Temporary Special Rule for                  -    3,185          -      -          -       -        -          -       -          -       -            3,185
 Determining Earned Income for
 Purposes of Earned Income Tax
 Credit
 Total of Earned Income Tax Credit       546     15,646    967        987   1,030      1,053    1,079   1,093      1,110   1,139      1,169           25,818




CRS-26
 Provision                              2021     2022     2023       2024     2025       2026       2027     2028       2029       2030       2031       2021-2031

 Part 4—Dependent Care Assistance
 Refundability and Enhancement of        2,127    5,837          -       -           -       -          -           -      -              -      -             7,964
 Child and Dependent Care Tax
 Credit
 Increase in Exclusion for Employer-       78       39           -       -           -       -          -           -      -              -      -              117
 Provided Dependent Care
 Assistance
 Total of Dependent Care Assistance      2,205    5,876          -       -           -       -          -           -      -              -      -             8,081
 Part 5—Credits for Paid Sick and Family Leave
 Extension and Modification of           4,506    1,747     (ii)       (ii)     (ii)       (ii)       (ii)          -      -              -      -             6,253
 Credits for Paid Sick and Family
 Leave
 Part 6—Employee Retention Credit
 Extension and Modification of the       3,076    7,146     (ii)       (ii)     (ii)       (ii)       (ii)          -      -              -      -            10,222
 Employee Retention Credit
 Part 7—Premium Tax Credit
 Improving Affordability by Expanding    4,137   22,234   7,964       536       -23          -          -           -      -              -      -            34,847
 Premium Assistance for Consumers
 Temporary Modification of               4,696    1,565          -       -           -       -          -           -      -              -      -             6,261
 Limitations on Reconciliation of Tax
 Credits for Coverage Under a
 Qualified Health Plan with Advance
 Payments of Such Credit
 Application of Premium Tax Credit       2,624    1,660    232           -           -       -          -           -      -              -      -             4,516
 in Case of Individuals Receiving
 Unemployment Compensation
 During 2021
 Total of the Premium Tax Credit        11,457   25,459   8,196       536       -23             -        -          -          -          -          -        45,624




CRS-27
 Provision                                  2021       2022        2023      2024       2025      2026       2027      2028       2029       2030       2031        2021-2031

 Part 8—Miscellaneous Provisions
 Repeal of Election to Allocation             -335     -1,277     -2,023     -2,284     -2,383    -2,334    -2,358     -2,385     -2,343     -2,283     -2,327           -22,331
 Interest, Etc. on Worldwide Basis
 Tax Treatment of Targeted EIDL                                                                                                                                      Estimate Not
 Advances                                                                                                                                                                Availablea
 Tax Treatment of Restaurant                                                                                                                                         Estimate Not
 Revitalization Grants                                                                                                                                                   Availablea
 Modification of Exceptions for                    -     -146     -1,081      -751        -789      -829      -870       -913       -959     -1,007     -1,057             -8,403
 Reporting of Third Party Network
 Transactions
 Modification of Treatment of                      1         8          8         9          9         9         (i)        (i)         -           -        -                 44
 Student Loan Forgiveness
 Total of Miscellaneous Provisions            -334      -1,415     -3,096    -3,026     -3,163    -3,154    -3,228      -3,298    -3,302      -3,290    -3,384            -30,690

    Source: Joint Committee on Taxation, Estimated Revenue Effects Of An Amendment in the Nature of a Substitute to H.R. 1319, The “American Rescue Plan Act Of
    2021,”As Passed by the House of Representatives And Scheduled for Consideration by the Senate, JCX-13-21, March 4, 2021, at
    https://www.jct.gov/publications/2021/jcx-13-21/.
    Notes: A negative number indicates the provision is estimated to result in a revenue gain. An (i) indicates a cost of less than $500,000. An (ii) indicates a gain of less than
    $500,000.
    a.    The Joint Committee on Taxation (JCT) revenue estimate indicates that the cost estimate for this provision will be provided b y the Congressional Budget Office.
          The estimate is not included in JCT’s estimate of the revenue effects.




CRS-28
   Table 4. Estimated Cost of Title IX Subtitle G of the American Rescue Plan Act of 2021 (ARPA; H.R. 1319) as passed the
                                         House of Representatives February 27, 2021
                                                              Fiscal Years; Millions of Dollars
 Provision                            2021         2022     2023       2024   2025       2026     2027    2028       2029    2030       2031       2021-2031

 Part 1—2021 Recovery Rebates to Individuals
 Recovery Rebates to Individuals      404,937      17,400          -      -          -       -        -          -       -          -       -         422,337
 Part 2—Child Tax Credit
 Child Tax Credit: Improvements for    25,826      79,249    710        721     725       721      307     311        316      320       323          109,529
 2021 and Application of the Child
 Tax Credit in Possessions
 Part 3—Earned Income Tax Credit
 Strengthening the Earned Income         521       11,361          -      -          -       -        -          -       -          -          -        11,882
 Tax Credit for Individuals with no
 Qualifying Children
 Taxpayer Eligible for Childless             (i)      12       2          1       1         1        2       2          2           2      2               26
 Earned Income Credit in Case of
 Qualifying Children Who Fail to
 Meet Certain Identification
 Requirements
 Credit Allowed in Case of Certain           1        20      21         22      23        25       25      27         28       30        31              252
 Separated Spouses
 Modification of Disqualified             24         330     198        200     225       229      238     233        231      240       251             2,399
 Investment Income Test
 Application of Earned Income Tax             -      738     746        764     781       798      814     831        849      867       885             8,074
 Credit in Possession of the United
 States
 Temporary Special Rule for                   -     3,185          -      -          -       -        -          -       -          -       -            3,185
 Determining Earned Income for
 Purposes of Earned Income Tax
 Credit
 Total of Earned Income Tax Credit       546       15,646    967        987   1,030      1,053    1,079   1,093      1,110   1,139      1,169           25,818




CRS-29
 Provision                              2021     2022     2023       2024     2025       2026       2027     2028       2029       2030       2031       2021-2031

 Part 4—Dependent Care Assistance
 Refundability and Enhancement of        2,127    5,837          -       -           -       -          -           -      -              -      -             7,964
 Child and Dependent Care Tax
 Credit
 Increase in Exclusion for Employer-       78       39           -       -           -       -          -           -      -              -      -              117
 Provided Dependent Care
 Assistance
 Total of Dependent Care Assistance      2,205    5,876          -       -           -       -          -           -      -              -      -             8,081
 Part 5—Credits for Paid Sick and Family Leave
 Extension and Modification of           4,409    1,742     (ii)       (ii)     (ii)       (ii)       (ii)          -      -              -      -             6,151
 Credits for Paid Sick and Family
 Leave
 Part 6—Employee Retention Credit
 Extension and Modification of the       2,791    5,993     (ii)       (ii)     (ii)       (ii)       (ii)          -      -              -      -             8,784
 Employee Retention Credit
 Part 7—Premium Tax Credit
 Improving Affordability by Expanding    4,137   22,234   7,964       536       -23          -          -           -      -              -      -            34,847
 Premium Assistance for Consumers
 Temporary Modification of               4,696    1,565          -       -           -       -          -           -      -              -      -             6,261
 Limitations on Reconciliation of Tax
 Credits for Coverage Under a
 Qualified Health Plan with Advance
 Payments of Such Credit
 Application of Premium Tax Credit       2,624    1,660    232           -           -       -          -           -      -              -      -             4,516
 in Case of Individuals Receiving
 Unemployment Compensation
 During 2021
 Total of the Premium Tax Credit        11,457   25,459   8,196       536       -23             -        -          -          -          -          -        45,624




CRS-30
 Provision                                  2021        2022       2023      2024       2025       2026      2027       2028       2029       2030       2031       2021-2031

 Part 8—Miscellaneous Provisions
 Repeal of Election to Allocation             -335      -1,277     -2,023    -2,284     -2,383     -2,334    -2,358     -2,385     -2,343     -2,283    -2,327            -22,331
 Interest, Etc. on Worldwide Basis
 Tax Treatment of Targeted EIDL                                                                                                                                       Estimate Not
 Advances                                                                                                                                                                 Availablea
 Tax Treatment of Restaurant                                                                                                                                          Estimate Not
 Revitalization Grants                                                                                                                                                    Availablea
 Modification of Exceptions for                    -      -146     -1,081      -751       -789      -829       -870       -913      -959      -1,007    -1,057              -8,403
 Reporting of Third Party Network
 Transactions
 Total of Miscellaneous Provisions            -335      -1,423     -3,104    -3,035      -3,172    -3,163    -3,228     -3,298     -3,302     -3,290     -3,384            -30,734

    Source: Joint Committee on Taxation, Estimated Revenue Effects Of H.R. 1319, The “American Rescue Plan Act Of 2021,” Scheduled For Consideration By The House Of
    Representatives On February 26, 2021, JCX-12-21, February 26, 2021, at https://www.jct.gov/publications/2021/jcx-12-21/.
    Notes: A negative number indicates the provision is estimated to result in a revenue gain. An (i) indicates a cost of less than $500 ,000. An (ii) indicates a gain of less than
    $500,000.
    a.    The Joint Committee on Taxation (JCT) revenue estimate indicates that the cost estimate for this provision will be provided by the Cong ressional Budget Office.
          The estimate is not included in JCT’s estimate of the revenue effects.




CRS-31
                               Tax Provisions for COVID-19 Relief: Subtitle G – Promoting Economic Security




Author Information

Molly F. Sherlock                                        Jane G. Gravelle
Specialist in Public Finance                             Senior Specialist in Economic Policy

Margot L. Crandall-Hollick
Acting Section Research Manager




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Congressional Research Service            R46680 · VERSION 9 · UPDATED                                  32


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