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revenue must similarly base their calculations on reasonable estimates that do not use dynamic <br />methodologies. Recipients should apply this adjustment in determining their actual revenue totals <br />at Step 3 in the revenue loss calculation described above. <br />Revisions to Presumption to Address Tax Increases <br />As noted above, the calculation methodology in the interim final rule implicitly assumed <br />that recipients did not experience a reduction in revenue due to the public health emergency if <br />they did not experience a reduction in aggregate revenue relative to the counterfactual estimate. <br />Treasury recognizes that some recipients may have experienced a reduction in revenue due to the <br />public health emergency that was offset by other revenue, particularly in the case of increases to <br />tax revenue resulting from a tax increase. The final rule requires recipients that increased taxes to <br />deduct the amount of increases to revenue attributable to such tax increase. This change is also <br />consistent with the incorporation in the interim final rule and final rule of a counterfactual <br />growth rate, which effectively permits recipients to count revenue losses due to the public health <br />emergency that are offset by increased tax revenue resulting from organic growth. <br />For these reasons, Treasury is providing in the final rule that recipients must subtract <br />from their calculation of actual revenue the effect of tax increases adopted after the date of <br />adoption of this final rule (January 6, 2022) for purposes of calculation dates that occur on or <br />after April 1, 2022. This change and the change to the final rule described above treat tax <br />changes in a consistent manner: in the case of reduction in revenue resulting from a tax cut, a <br />recipient must add the amount of that reduction to its calculation of actual revenue, and in the <br />case of an increase in revenue resulting from a tax increase, a recipient must subtract the amount <br />255 <br />