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                                                                                                  April 21, 2021

Advancing Refundable Tax Credits: Policy Considerations


Many  policymakers have expressed interest in having the
Treasury advance refundable taxcredits in installments
(potentially monthly or quarterly). This approach is an
alternative to providing the credits as an annuallump sum
(i.e., as a taxrefund), which may help households better
meet their ongoing needs. In the American Rescue Plan Act
of 2021 (ARPA;  P.L. 117-2), Treasury is directed to
advance half of the temporarily expanded child credit
during the last sixmonths of2021.

There are four general considerations that policymakers
may  face when designing advance payments ofrefundable
tax credits for families:
*  the lackof data on alleligible households;
*  the lagged nature of available annual data;
*  changes in households' circumstances; and
*  whether and how households would be required to
   reconcile (and perhaps repay any excess) advance
   payments  when taxes are filed.

   The term household as used in this In Focus refers to
   the individuals who are or would be listed on a federal
   income tax return (if it were filed); it is used
   interchangeably with taxpayer and tax filer. Other
   analyser m t22 huo l tax uniL

This In Focus discusses these considerations in the context
of the advance child credit (ARPA child credit').
Policymakers may choose different approaches when
considering advancing taxcredits for families in the future.

Lack  of Data on  Eligible Households
The federaltax systemdoes not include data on all
households potentially eligible for an adv ance credit.
Hence, unless eligible non-filer families manually
provide that information to the IRS, they will generally not
receive a payment. A 2017 CBO analysis estimated that of
292.6 million individuals who could be included on a
federal income tax return (as the taxpayer, spouse, or
dependent), 251.9 million were actually included-
representing about 86% of all individuals. The study
es timated that the greatest share of non-filers were lower-
income households who  are generally not required to file a
federal income tax return.

The IRS could provide a means for families to pro vide this
information (like the non-filer portalused for the stimulus
checks). Ifa tool were made available, some eligible
households might not use it. For example, this was the case
in October 2020, when five months after the stimulus check
non-filer portal was created, an estimated 9 million to 12
million eligible non-filing households had not received a
check.
                                          https://crs repo


In SeptemberandOctober2020,   the IRS, onbehalfof
Treasury, sent notices to approximately 9 million taxpayers
that were potentially eligible for the firs t round of s timulus
checks. According to data provided to CRS by the IRS,
between  September 19, 2020 (the date notices were first
released) and November 21, 2020 (the date the non-filer
portal closed), approximately 1.2 million returns were
accepted. It is unclear exactly how many of the 9 million
notice recipients were ultimately eligible, nor is it clear the
extent to which the notices increased use of the non-filer
portal. Nonetheless, this may be indicative of the number of
households who  were eligible for the first payment, but did
not receive it in 2020.

ARPA   Child Credit: ARPA  directs the Treasury to create
a portal to allowhouseholds to modify information related
to potential advance payments of the child taxcredit. It is
unclear if otherwise eligible non-filers willbe able to use
this portalto provide new information, or whether the portal
will only allow taxfilers to updateexisting taxreturn
information. If new information cannotbe provided onthe
portal, the application for the advanced credit will be a
2020 income taxreturn.

Lagged   Nature  of Available Annual  Data
Federal tax law as sesses taxes on annual taxable income.
Thus, the federalincome taxsystemcollects data via tax
returns on annual income and annual family structure (i.e.,
marital s tatus and number of children). For example, a 2020
income taxreturn will include a household's total incone in
2020, as well as their marital status (e.g., filing a joint tax
return indicates two adults are married) and the number of
children they claimfor various child-related taxbenefits in
2020.

Tax filing status for a given year depends on whether a
taxpayer is married or unmarried and whether or not the
taxpayer has dependents. Marital status is determined as of
the last day of the calendar year. For example, if a couple is
married on December31,  2020, they are considered married
for all of 2020 for taxpurposes. (There are exceptions to
this generalrule.) Most married taxpayers file their returns
jointly. Taxpayers with dependents may file using the head
of household filing status. Formost taxbenefits, children
must live with the taxpayer for more than sixmonths outof
the year to be considered a qualifying child (something
that may only be clear at the end ofthe year for some
households.) In addition to annualincome and family
structure data, households often provide a street address and
bank account information on their tax return.

Tax data generally do not include information about within-
year fluctuations in income and family structure. This may
limit the ability to structure a taxbenefit to respond to

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