I thank the Senator for his inquiry and can clarify that the Senator is correct that the current-law limitations that generally apply to tax credits under section 38 would not reduce the amount of credits eligible for transfer by the transferor of transferable tax credits under the bill and that the Treasury Department should issue technical guidance that reflects this intent.
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The only way for Republicans to pass this horribly destructive bill, which is based on budget math as fake as Donald Trump's tan, was to go nuclear and hide it behind a bunch of procedural jargon.
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