Experience Estimating the Revenue Impact of TCJA a Microsimulation Modeling Approach

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Revenue Estimation & Tax Research Conference Experience Estimating the Revenue Impact of TCJA a Microsimulation Modeling Approach Chainbridge Software, LLC October 9, 2018

Background -- Chainbridge Has been developing and delivering tax policy analysis tools for state government clients for nearly two decades Eric Cook, PhD, revenue estimator at the US Congressional Joint Committee on Taxation during federal tax reform efforts leading to the Tax Reform Act of 1986 Directed development of tax modeling projects for state government clients (Price Waterhouse and KPMG), left KPMG to form Chainbridge in 2000 2

Background -- recent events Early in 2018, two states contracted with Chainbridge to assist in their analysis of the TCJA Two microsimulation models developed (individual income tax and corporate income tax) for and delivered to the two states Impacts of the (1) individual, (2) business, and (3) international provisions of the TCJA on the these two states were estimated and reports developed 3

The Chainbridge team Eric Cook, PhD, CEO Nancy Cook, President Kirk Copen, VP Software Development James Copenhaver, VP Software Development Stephen Woerner, Software Engineer 4

Overall approach Construct two microsimulation models (individual income tax and corporate income tax) For each provision within each provision type (individual, business or international): Determine what the likely impact that the provision has on the state Determine whether an on-model (using the microsimulation models) or off-model approach would be employed Generate the revenue estimates and prepare a report presenting the results 5

Why microsimulation modeling? The Gold Standard for modeling tax policy changes Accurate method for assessing the impact by simulating a policy change for each taxpayer and aggregating results Forecasting and data extrapolation allows policy analysis to be conducted at future year levels 6

Estimating the impact of the TCJA using microsimulation models International provisions Individual provisions Business provisions 7

Significant international provisions Deduction for dividends received by domestic corporations from certain foreign corporations (DRD provision) Treatment of deferred foreign income upon transition to participation exemption system of taxation (Repatriation provision) Taxation of global intangible low-taxed income (GILTI provision) Deduction for foreign-derived intangible income derived from trade or business within the US (FDII provision) 8

Estimating approach international provisions Corporate income tax model Augmented with data from Standard and Poor s Compustat database Review of Forms 10-K filed with the SEC Individual income tax portion of Repatriation provision off-model approach 9

Significant individual provisions Standard deduction modification Loss limitation for noncorporate taxpayers Changes in itemized deductions: Repeal of certain itemized deductions (state and local taxes, non-disaster casualty losses, some miscellaneous) Limitation on mortgage interest deduction 10

Estimating approach individual income tax provisions Individual Income Tax Model employed for the majority of the provisions as a percentage of the net revenue impact Database includes State returns matched with federal returns for residents Allows for tax to be recalculated using federal data and federal law (indexing provisions) Extrapolation of microdatabase to future years 11

Estimating issues individual income tax provisions Stacking order Impact of the standard deduction modification switching issue Extrapolation issue federal Earned Income Tax Credit (EITC) 12

Significant business provisions Limitation on the net interest deduction Amortization of research and experimental expenses Repeal of the domestic production activities deduction Modification of the net operating loss (NOL) deduction Increase in IRC section 179 expensing Simplified accounting for small business 13

Estimating approach business provisions Corporate Income Tax Model employed for the majority of the provisions as a percentage of the net revenue impact Population of state corporate income tax returns Matched with pro-forma federal Forms 1120 Extrapolation of microdatabase to future years 14

Estimating issues business provisions Affect both corporations and pass-through entities split between corporate and individual Corporate Individual Share Share Provision (percent) (percent) Bonus Depreciation 70 30 Section 179 Expensing 10 90 Net Interest Deduction 95 5 Small Business Accounting Changes 30 70 Modifications to NOLs 90 10 Amortization of R&D 75 25 Repeal Domestic Production Activities Deduction 75 25 Source: US Congress, Joint Committee on Taxation 15

Thank you and please feel free to contact us: Eric Cook ecook@chainbridge.com Jaime Copenhaver jcopenha@chainbridge.com Kirk Copen kcopen@chainbridge.com 703.359.8211 703.359.5934 (fax) 16

Appendix: PolicyLinks Screenshots and Output Tables

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