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Timing of the impact of covered changes. <br />Public Comment: Several commenters expressed concern that recipient governments, to <br />evade the offset provision, may backload the costs of certain covered changes outside of the <br />covered period, and advocated that covered changes be instead evaluated as the net present value <br />in the year that the covered change is enacted. These commenters argued that some tax cuts <br />could have effects on tax revenue for many decades or could be structured to take effect after the <br />end of the covered period. <br />Treasury Response: As discussed in section Timeline for Use of SLFRF Funds, SLFRF <br />funds must be used to cover costs incurred prior to December 31, 2024. Accordingly, SLFRF <br />funds generally would not be able to offset a reduction in net tax revenue occurring after <br />December 31, 2024. <br />For these reasons, Treasury is maintaining this element of the interim final rule without <br />change. <br />(2) In excess of the de minimis. Under the framework established in the interim final rule, <br />after establishing that a covered change occurred, the recipient government next calculates the <br />total value of all covered changes in the reporting year resulting in revenue reductions, identified <br />in Step 1. If the total value of the revenue reductions resulting from these changes is below the <br />de minimis level, the recipient government is deemed not to have any revenue -reducing changes <br />for the purpose of determining the recognized net reduction. If the total is above the de minimis <br />level, the recipient government must identify sources of in -year revenue to cover the full costs of <br />changes that reduce tax revenue. Under the interim final rule, the de minimis level is calculated <br />as 1 percent of the reporting year's baseline. <br />330 <br />