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This potentially has huge tax implications
Today, @RichardRubinDC reported on the new sec. 7508A(d), which suspends tax filing & payment obligations in a disaster area for the length of the disaster + 60 days wsj.com/articles/irs-r… 1/
I noted 4 reasons why Trump’s 3/13 declaration migh not trigger sec. 7508A(d):
1) No incident date in declaration
2) No geographic area in declaration
3) A convoluted argument I came up w/ involving the definition of the word “manner”
4) Difference b/ “emergency” & “disaster” 2/
You can read all about that here: medium.com/whatever-sourc…

Trump’s “major disaster” declaration for NY State obliterated points 1, 2 & 4, leaving only #3

3/
Which means it now is reasonably likely that no individual who resides in NY State & no corp HQ’d in NY State owes any federal income, employment, estate, gift, or excise tax (or needs to file any return w/r/t those taxes) until the covid-19 disaster is over 4/
That potentially goes way, way beyond @stevenmnuchin1’s action today to delay the individual income tax return deadline from 4/15 until 7/15.

5/
There’s still the “manner” argument I outline in the Medium post. But I wouldn’t want to bet billions of dollars on that. & Trump could call off the NY disaster at any moment. But that would involve eating a lot of crow.

6/
In other words, this disaster declaration could amount to a very big interest-free loan from the fed gov’t to NY residents, Wall Street banks, & all the other firms—large & small—HQ’d in NY State

7/7
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