Skip to content

Keep claimable-filer rules in the repeal of state dependent exemptions - #10134

Draft
MaxGhenis wants to merge 18 commits into
mainfrom
repeal-state-dep-exemptions-claimable-filer
Draft

MaxGhenis wants to merge 18 commits into
mainfrom
repeal-state-dep-exemptions-claimable-filer

Conversation

@MaxGhenis

Copy link
Copy Markdown
Contributor

WIP draft. This is stacked on #10087 and depends on the rest of the claimable-filer stack (see "Depends on"). I will rebase it onto main and mark it ready after those PRs merge.

Summary

The contributed reform repeal_state_dependent_exemptions overrides state formulas so each keeps the state's personal exemptions and drops dependent exemptions. Several overrides counted personal exemptions with head_spouse_count or is_tax_unit_head_or_spouse, which ignore whether a filer can be claimed as a dependent on another return. Once #10024 and the claimable-filer PRs land, the baseline denies that filer a personal exemption in most of these states (IRC 151(d)(2) and the state rules that follow it). Under the reform, that filer got an exemption the baseline does not allow.

After this PR and the stack, each override matches its baseline's rule for a claimable filer:

State Override Baseline for a claimable head or spouse (after the stack) Reform
DE de_personal_credit no credit (de_personal_credit_potential reads exemptions_count) this PR: head_spouse_count_not_dependent_elsewhere
HI hi_regular_exemptions no exemption and no aged extra this PR: head_spouse_count_not_dependent_elsewhere; the aged extra skips a claimable filer
NE ne_exemptions no credit (exemptions_count, in claimable-filer-ma-mi-mn-ms-mo-mt-ne) this PR: head_spouse_count_not_dependent_elsewhere
RI ri_exemptions no exemption (exemptions_count) this PR: head_spouse_count_not_dependent_elsewhere
VA va_personal_exemption_person no exemption (filer & ~claimable) this PR: head_or_spouse & ~claimable
VT vt_personal_exemptions no exemption (reads head_is_dependent_elsewhere and spouse_is_dependent_elsewhere) this PR: label-free head_spouse_count_not_dependent_elsewhere
WI wi_base_exemption no exemption (exemptions_count) this PR: head_spouse_count_not_dependent_elsewhere
WV wv_personal_exemption no $2,000 exemption; $500 once per return when the count is zero (#10044) this PR: the same on head_spouse_count_not_dependent_elsewhere
MI mi_personal_exemptions, mi_exemptions mi_exemptions computes such a return outside mi_personal_exemptions: $1,500 for the claimable filer, and that return's dependents when the would-be claimant meets the filing exception this PR: also overrides mi_exemptions, without the dependents
CA ca_exemptions no personal, blind or senior credit #10053
MD md_total_personal_exemptions no exemption #10045
KS ks_exemptions before 2024: zero exemptions if a filer is claimed. From 2024: the filing-status amount stays #10045
OK ok_count_exemptions no regular exemption; the 65+ and blind exemptions stay #10043
OH oh_personal_exemptions_eligible_person not eligible #10087 (reads claimable_as_dependent_on_another_return)
GA, IN, IA, MA ga_exemptions, in_base_exemptions, ia_exemption_credit, ma_income_tax_exemption_threshold the filer keeps the exemption unchanged
KY ky_family_size_tax_credit_threshold family size is tax_unit_size unchanged
OK ok_child_care_child_tax_credit not an exemption unchanged

Invariants

For every return and every overridden output, under the reform:

  1. The output does not depend on which spouse is labelled head.
  2. Marking another filer as claimable never raises an exemption.
  3. The reform never exceeds the baseline. For Delaware the comparison is with de_personal_credit_potential: the reform overrides the applied credit with its amount before the tax-liability limit, and the ordered cap applies afterwards.
  4. On a return without dependents, the reform equals the baseline.
  5. On a return with a claimable filer whose would-be claimant does not meet the filing exception, the baseline has no dependents (IRC 152(b)(1)), so the reform equals the baseline. Two outputs are exempt: Kentucky's family size, which still counts that return's dependents, and mi_personal_exemptions, which Michigan's baseline does not read on such a return.

Tests

  • tests/policy/contrib/state_dependent_exemptions/repeal_state_dependent_exemptions_claimable_filer.yaml: 47 cases.
    • For each of DE, HI, NE, RI, VA, VT, WI and WV: a single claimable filer, a joint return with a child and one claimable spouse under both head/spouse labellings, and a control where neither spouse can be claimed.
    • HI aged couples; MI and OH cases; an OK single filer; WV with both spouses claimable.
    • RI and MI cases where the filing exception restores the child in the baseline and the reform still drops it.
    • IN and IA pins, where a claimable filer keeps the exemption.
    • Expected values are hand-computed from 2025 parameters and noted on each case.
  • tests/core/test_repeal_state_dependent_exemptions_claimable_invariants.py: properties 1-5 over Hypothesis-drawn and seeded couples and single filers in the 19 states, in 2023 and 2026. Each filer may be claimable, claimed or not, with or without the filing exception. Each property runs one baseline and one reform simulation over a vectorized batch, comparing the two systems. A YAML case runs one system, so it cannot express these comparisons.

Local results (macOS, on a local merge of this branch with every stack branch): pending. I will add the pass counts, elapsed time and peak memory here.

Plan

  • Align each override with the stack's baseline, with YAML and property tests.
  • Local test results and measurements (running).
  • After the stack merges: rebase onto main, re-check every override against the merged baselines, and rerun the tests.
  • Independent review, then mark ready.

Not in scope (noted)

  • Delaware's combined-separate path (Filing Status 4) reads de_personal_credit_indv, which the reform does not override. On that path, own credits already follow the claimable-filer rule, but dependent credits survive the repeal. de_dependent_credit_reform records the same limitation.

Depends on

#10024, #10087 (base), #10089 (HI), #10091 (VA), #10044 (RI, VT, WV, WI), #10043 (OK), #10045 (KS, MD), #10053 (CA), #10049 (IN), #10050 (GA) and the branch claimable-filer-ma-mi-mn-ms-mo-mt-ne (NE, MA, MI; no PR yet). On #10087 alone, two things fail: the Oklahoma YAML case, which needs #10043's override copy, and the property test's comparisons with the baseline, which need the baselines in the PRs above.

axiom: n/a: contributed reform (hypothetical repeal of state dependent exemptions), not a statutory provision

🤖 Generated with Claude Code

MaxGhenis and others added 18 commits October 8, 2026 11:03
The federal standard deduction and 17 state formulas read only whether the
tax-unit head is claimed elsewhere, so a joint return where one spouse can be
claimed was taxed differently depending on which spouse was labelled head.
Each formula now applies its jurisdiction's rule for that case (either spouse,
single filers only, per spouse, or only when every filer is claimed), using
two new label-independent helpers. Adds swap-pair YAML cases and a Hypothesis
property test.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
… barred

The New Mexico, Maine and Hawaii renters gates counted filers who are not
claimed elsewhere, so a tax unit with neither a head nor a spouse (252 in
the default dataset) looked like one whose every filer was claimed. A new
helper, every_filer_is_dependent_elsewhere, requires a claimed filer and no
unclaimed one.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
…ss EITC

- Hawaii's dependent standard deduction uses earned income net of the
  deductible part of self-employment tax, as the N-11 worksheet does.
- New Mexico's medical care credit needs a filer who is both 65 or older
  and not a dependent when a filer is a dependent elsewhere (NMSA 7-2-18.13).
- The federal EITC without a qualifying child requires that no filer can be
  claimed as a dependent (IRC 32(c)(1)(A)(ii)(III), Publication 596), so
  Missouri's working family credit no longer reaches such a couple.
- Hawaii's food/excise credit keeps minor children receiving public support
  (HRS 235-55.85(c)) on a joint return where one spouse can be claimed.
- Comments label the readings the law does not settle, and the property
  test covers the EITC and the food/excise exemption amount.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
… meaning

- The federal and Oregon dependent worksheets use earned income net of the
  deductible part of self-employment tax, as Hawaii's now does.
- Hawaii's food/excise minor-child count excludes children who can be
  claimed by another taxpayer and the filers themselves (Form N-311 line 3).
- claimed_as_dependent_on_another_return documents what it stands for: a
  §151 deduction for the person is allowable to another taxpayer, so a
  person whose would-be claimer files only for a refund is not one
  (Publications 501 and 596); rules on actually being claimed read it too.
- Hawaii's renters comment labels the mixed joint reading as an inference;
  the Hawaii dependent threshold cites HRS 235-2.4(a)(3) on its page.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
A filer who can be claimed on another return is treated as having no
dependents (IRC 152(b)(1); on a joint return either spouse counts) and has no
personal exemption (IRC 151(d)(2)); one who is claimed gets no education
credits (25A(g)(3)), student loan interest deduction (221(c)) or recovery
rebate (6428(d)(2), 6428A(d)(2), 6428B(c)(2)). The model read none of these.
Now the child tax credit and credit for other dependents, the under-13 child
and dependent care qualifying person, exemptions_count and its RI, DE, OH, OR,
WI, HI and NM readers, the recovery rebates, the education credits and the
student loan interest deduction apply them symmetrically for joint returns.
Georgia keeps its own counts; the HI, WI and Treasury exemption reforms
follow the corrected count.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- Child and dependent care: childcare expenses do not count on a return with a
  claimable filer unless a child under 13 still qualifies (IRC 21(b)(2)(A)(ii)).
- Tuition and fees deduction: not allowed to a filer who can be claimed (IRC
  222(c)(3)), so the education credit bar no longer makes such a filer eligible.
- Recovery rebates: the Armed Forces exception waives the identification rule
  only, not the exclusion of a spouse who is another taxpayer's dependent.
- Georgia: the contributed refundable credit and SB 520 reforms count the same
  children as ga_ctc_potential through a new ga_ctc_eligible_child.
- Education credits and student loan interest read the claimed input directly,
  since IRC 25A(g)(3) and 221(c) turn on an actual claim.
- One reference per source document; quote IRC 24(h)(4)(A) exactly.
- Tests: mixed-recipient care, tuition deduction, military rebates, Georgia
  refund cap, and the swapped New Mexico rebate case; the property test now
  covers the state readers of the exemption count.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
# Conflicts:
#	policyengine_us/tests/policy/baseline/gov/states/oh/tax/income/exemptions/personal/oh_personal_exemptions_eligible.yaml
#10024 now separates three facts: is claimed, can be claimed, and the would-be
claimant's filing exception.

- IRC 152(b)(1) gates (child tax credit, credit for other dependents, under-13
  care child and its expenses, dependents in exemptions_count, ARPA dependents,
  Ohio dependents, the Hawaii and Wisconsin reforms) read
  head_or_spouse_is_dependent_elsewhere_without_filing_exception, so a filer
  within the Publication 501 exception keeps their dependents.
- Own exemptions, recovery rebates and the tuition deduction read claimability.
- Education credits and student loan interest keep reading the claimed input.
- Tests: the filing exception and a filer who can be claimed but is not.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
#10024's food/excise credit, Act 115 rebate and renters credit took claimable
filers off exemptions_count themselves. exemptions_count now leaves them out
(and, outside the filing exception, the return's dependents), so those credits
read it as it is; the filing-exception cases were one exemption short.

The renters credit also leaves out a dependent who can be claimed by another
taxpayer (Schedule X counts only people who cannot be), as the food/excise
credit already did.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- Education credits: a dependent student is not eligible on a return whose
  filer can be claimed outside the filing exception (IRC 25A(f)(1)(A)(iii),
  152(b)(1)); the filer's own eligibility still turns on an actual claim.
- Recovery rebates: no credit when every filer is a dependent of another
  taxpayer (IRC 6428B(a)); the CARES and CAA child prerequisite is a spouse
  with a valid SSN, whether or not that spouse is an eligible individual.
- Child and dependent care: cdcc_qualifying_childcare_expenses holds the
  expense rule, and the single-parent work requirement reform and California's
  expenses read it.
- References: Georgia HB 136 page 3; one entry per recovery rebate statute;
  quote IRC 24(h)(4)(A) exactly in the test comment.
- Tests: dependent students, the two rebate cases, the reform and California
  expenses, and the Hawaii, Wisconsin and Treasury reforms with a claimable
  filer under both labellings.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- Education credits: is_barred_from_education_credits_by_dependency holds the
  claimed-filer and dependent-student rules; both eligibility formulas and the
  reconciliation SSN reform's Lifetime Learning Credit read it, so the reform
  no longer turns a barred student's tuition into that credit.
- Child and dependent care: childcare counts when any child under 18 is still a
  qualifying individual, so an incapacitated child aged 13 to 17 keeps it.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Setting meets_eitc_identification_requirements on one person made it an input
for every person, so the other spouse lost their SSN too.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
The repeal reform's personal-exemption overrides counted every head and
spouse, so a filer whom another taxpayer can claim kept a personal
exemption under the reform that the baseline denies once #10024 and the
claimable-filer PRs apply IRC 151(d)(2). Delaware, Hawaii, Nebraska,
Rhode Island, West Virginia and Wisconsin now count
head_spouse_count_not_dependent_elsewhere (West Virginia keeps its $500
exemption for a return on which no filer has one), Virginia's per-person
exemption and Hawaii's aged exemption skip a claimable filer, and
Vermont's count no longer depends on which spouse is labelled head.

Michigan's baseline computes a claimable filer's return outside
mi_personal_exemptions and, when the would-be claimant meets the filing
exception, allows that return's dependents. The reform now overrides
mi_exemptions as well, so those dependent exemptions are repealed too.

California, Kansas, Maryland, Ohio and Oklahoma follow their baselines
in the claimable-filer PRs that changed them. Georgia, Indiana, Iowa,
Kansas from 2024, Kentucky and Massachusetts let a claimable filer keep
the exemption, so their overrides are unchanged.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Base automatically changed from claimable-filer-federal to main October 16, 2026 06:10

This branch has not been deployed

No deployments
Sign up for free to join this conversation on GitHub. Already have an account? Sign in to comment

Labels

None yet

Projects

None yet

Development

Successfully merging this pull request may close these issues.

1 participant