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public health emergency, any reduction in revenue relative to the counterfactual estimate was <br />presumed in the interim final rule to be considered revenue lost due to the pandemic. <br />Treasury stated in the Supplementary Information to the interim final rule that it was <br />considering when, if ever, during the period of performance it would be appropriate to reevaluate <br />the presumption that all losses are attributable to the public health emergency. Treasury also <br />sought comment on whether to take into account other factors, including actions taken by the <br />recipient as well as the expiration of the COVID-19 public health emergency, in determining <br />whether to presume that revenue losses are "due to" the COVID-19 public health emergency. <br />Public Comment: Treasury received many comments in support of the presumption, as <br />well as some opposed. Some commenters argued that the presumption eases the administrative <br />burden on recipients because, without it, it would be difficult to identify which losses are <br />attributable to the COVID-19 public health emergency. Many commenters also argued that <br />Treasury should maintain the presumption because recipients are likely to experience losses due <br />to the public health emergency even after the end of the public health emergency. Treasury also <br />received comments asking that it adjust any revenue loss calculation to account for tax changes <br />enacted by the recipient. In particular, some commenters noted that some recipients had <br />increased taxes in order to meet additional demands for government services or to address <br />declines in revenue due to the pandemic. These tax increases have in some cases offset some or <br />all of the actual revenue loss attributable to the public health emergency. Because the interim <br />final rule calculates revenue loss by reference to actual revenue collected, commenters argued <br />that the calculation of revenue loss "due to" the public health emergency needs to take into <br />consideration the effects of tax increases by deducting the effect of these tax increases from <br />actual revenue collected. <br />250 <br />