Tax Policy in the 114th Congress (and Beyond)€¦ · Source: Congressional Budget Office, An...
Transcript of Tax Policy in the 114th Congress (and Beyond)€¦ · Source: Congressional Budget Office, An...
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
We’ve made progress on the deficit…
1,227
438
0
200
400
600
800
1000
1200
1400
2010 Projected* Actual
FY 2015 Budget Deficit
Billions of $
*CBO’s projected FY2015 baseline deficit in August 2010 increased by CBO’s estimated cost in 2015 of extending all of the 2001 and 2003 tax cuts, patching the Alternative Minimum Tax, and extending other expiring tax provisions.
Sources: Congressional Budget Office, The Budget and Economic Outlook: An Update (Aug. 2010), and An Update to the Budget and Economic Outlook: 2016 to 2026 (Aug. 2016)
11th Hour Deals
• Budget Control Act of 2011
• American Taxpayer Relief Act of 2012
Just Got Lucky
• Persistently low interest rates
• Slower than expected healthcare cost growth
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
17%
18%
19%
20%
21%
22%
23%
24%
Current Law Revenues Current Law Spending
…but the deficit reprieve is over
Note: Assumes current law remains unchanged (e.g., remaining tax extenders expire as scheduled, sequester cuts are allowed to transpire as scheduled, etc.).
Source: Congressional Budget Office, An Update to the Budget and Economic Outlook: 2016 to 2026 (Aug. 2016); light shaded lines reflect comparable CBO data from August 2015.
% of GDP
Comparable projections from last year:
$7.0 trillion deficit
$8.6 trillion deficit
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Changing demographics will push up mandatory spending
16.5
2.8
0
2
4
6
8
10
12
14
16
18
1950 2015
Covered Workers per SS/DI Beneficiary Projected Cut in Scheduled Benefits Upon
Trust Fund Exhaustion
Social Security (combined OASDI) Medicare (HI)
14% in 2030
21% in 2034
Sources: The 2015 annual reports of the Boards of Trustees of the OASDI and Medicare trust funds
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
What’s not driving the long-run budget problem?
0
2
4
6
8
10
12
14
Discretionary Spending – Past and Projected
% of GDP
Source: Congressional Budget Office, An Update to the Budget and Economic Outlook: 2016 to 2026 (Aug. 2016)
Yr. Average (8.7% of GDP)-50
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
IRS caught in the crossfire
13.6
11.2
10.9
12.3
10
11
12
13
14
2010 Enacted 2016 Enacted 2017 Proposed (House GOP,White House)
Billio
ns o
f $
Inflation-adjusted IRS funding (2016 dollars)
Sources: Center on Budget and Policy Priorities
Down 17%
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Different Speaker, same challenges?
Under Speaker Boehner
247 Size of House GOP Conference
218 Votes to pass bills in the House
~40 Approximate size of House Freedom Caucus
54 Size of Senate GOP Conference
60 Votes to overcome a Senate filibuster
290/67 Votes to override a President’s veto in the House/Senate
Under Speaker Ryan
247
218
~40
54
60
290/67
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
A tough House to flip
Current Balance of
Power Solid D Likely D Lean D Toss-Up Lean R Likely R Solid R
188 Democrats
177 3 4 3 0 1 0
247 Republicans
0 2 4 14 12 13 202
Net Pick-Up if Dems Run the Table: 19 Seats
Source: Cook Political Report, House Race Ratings (as of Oct. 4, 2016)
Race Ratings - November 2016 House Elections
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Senate up for grabs – 2016 map unfavorable to Republicans...
Source: University of Virginia Center for Politics, Sabato’s Crystal Ball
…but Senate Democrats back on defense in 2018
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
The race for 270 – one Electoral College scenario
Source: Washington Post, May 2, 2016 post in “The Fix” by Chris Cilizza
Presentation title [To edit, click View > Slide Master > Slide master1]
Copyright © 2016 Deloitte Development LLC. All rights reserved. 13
Can history help predict future tax changes?
Tax Policy in the 114th Congress (and Beyond)
Signed Economic Recovery Tax Act on August 13, 1981
Signed Omnibus Budget Reconciliation Act on November 5, 1990
Signed Omnibus Budget Reconciliation Act on August 10, 1993
Signed Economic Growth and Tax Relief Reconciliation Act on June 7, 2001
Signed American Recovery and Reinvestment Act on February 17, 2009
Act Fast Tailwinds Help
Economic recession
Projected budget deficits
Projected budget deficits
Projected budget surpluses
Financial crisis
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Tax reform in 2015 – missed opportunities and lessons learned
The parties can’t agree on how much revenue is enough and whether to use tax reform to make the system more (or less) progressive than it is today
Pass-through supporters indicated to Congress that if C Corps get a rate reduction that there is no other benefit, short of a rate cut, that will work for them
First idea Second idea Last idea
Comprehensive tax reform
How about business only tax reform?
Can we pair international tax reform with more money to help pay for highways?
Political toxicity of raising the gas tax, along with inversions, foreign acquisitions, BEPS, and European Commission cases created a perfect storm for this approach, but talks ostensibly fell apart due to disagreement over highway spending levels
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
“Corporate-only” tax reform – tough optics
0%
2%
4%
6%
8%
10%
12%
14%
16%
18%
20%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Share of Net Income by Entity Type
C Corporations
Source: Deloitte analysis of IRS Statistics of Income data (Integrated Business Data, Table 1)
S Corporations
Partnerships
Sole Proprietorships
C Corp returns as a share of all business returns
(right axis)
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Populist tax sentiment hard for policymakers to ignore
0%
10%
20%
30%
40%
50%
60%
70%
80%
2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
Percentage of Americans Who Feel these Groups Pay “Too Little” in Taxes
Middle-Income Individuals
Lower-Income Individuals
Source: Gallup, More Americans Say Low-Income Earners Pay Too Much in Taxes, Justin McCarthy (April 15, 2015)
Corporations
Upper-Income Individuals
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
The year-end 2015 tax extenders deal – a recap
Made Permanent Medium-Term Extension Two-Year Extension (‘15-16)
R&D Credit Active
Financing
Exception from
Subpart F
Enhanced Sec.
179 Expensing 15-year straight-line
recovery for qualified
leasehold
improvements
Tax-free IRA
distributions for
charitable
purposes Itemized deduction for
state/local sales tax
Stimulus-era enhancements
to EITC, CTC, and AOTC
Bonus depreciation
(phased-out thru 2019) CFC “Look-
Through” Rule
(thru 2019)
Work
Opportunity
Tax Credit
(thru 2019) New Markets
Tax Credit
(thru 2019)
PTC for Wind
Energy
(phased-out
thru 2019)
Enhanced ITC
for Solar Energy
(phased-out
thru 2021)
Most other alternative
energy & energy
efficiency provisions Itemized deduction for
mortgage insurance
premiums
Exclusion for certain
forgiven mortgage
debt Other, often
parochial,
provisions
Non-Extender Policies
2-year suspension of
medical device tax
(‘16-’17) 2-year delay of
“Cadillac” tax
(‘18-’19)
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Statutory corporate rates among OECD countries (including subnational) – 2015
12.5% 17%
19% 19% 19%
20% 20% 20% 20% 20%
21.1% 22% 22%
22.5% 23.5%
24.2% 24.6% 25% 25%
26% 26.3% 26.5%
27% 27.5%
28% 28%
29.2% 29.5%
30% 30% 30.2%
32.1% 34%
34.4% 39%
0 5 10 15 20 25 30 35 40
IrelandSlovenia
Czech RepublicHungary
PolandFinlandIcelandTurkeyEstonia
United KingdomSwitzerland
Slovak RepublicSweden
ChileDenmark
KoreaAverage (Ex-U.S.)
AustriaNetherlands
GreeceCanada
IsraelNorway
ItalyNew Zealand
SpainLuxembourg
PortugalAustralia
MexicoGermany
JapanBelgium
FranceUnited States
Source: OECD Tax Database, Table II.1
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
“You can observe a lot just by watching” – Yogi Berra
20%
25%
30%
35%
40%
45%
50%
Corporate Tax Rates Over Time – Including Subnational
U.S. OECD Weighted Avg. (by GDP) OECD Simple Average
Source: OECD, Tax Foundation
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Developed nations trending away from worldwide taxation
8
26
28
6
Source: Tax Foundation
International Tax Systems Among Current OECD Members
Territorial Worldwide
1972 Today
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
The revenue/spending split viewed differently – the balanced budget years
16
17
18
19
20
21
22
23
1969 1998 1999 2000 2001
Revenues Spending
% of GDP
Source: Congressional Budget Office, An Update to the Budget and Economic Outlook: 2016 to 2026 (Aug. 2016)
Projected Avg. Spending over Next Decade (22.0%)
Projected Avg. Revenues over Next Decade (18.3%)
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Is the tax code too progressive, or not progressive enough?
0%
5%
10%
15%
20%
25%
30%
Share of Pre-Tax Income, Total Federal Tax by Income Group
Source: Congressional Budget Office, The Distribution of Household Income and Federal Taxes, 2011 (Nov. 2014), supplemental data
Top 1%
Bottom 20%
Share of Pre-Tax Income Share of Total Federal Tax
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Broadening the base – easier said than done
Largest Corporate Tax Expenditures - 2014 Billions
of $
Deferral of active CFC income 83.4
Accelerated depreciation (w/o bonus) 24.0
§199 deduction 12.2
Deferral on like-kind exchanges 11.7
Exclusion for muni bond interest 9.3
Deferral of gain on installment sales 6.9
Low-income housing tax credit 6.8
Expensing of R&E expenditures 4.6
Reduced rates on corporate TI below $10M 3.8
Inventory property sales source rule exception 3.0
Top 10 as a % of total corporate ~80%
Largest Individual Tax Expenditures - 2014 Billions
of $
Exclusion of employer-provided health benefits 143.0
Reduced rates on LT cap gains/dividends 96.5
Tax-preferred retirement plans 88.8
Earned Income Tax Credit 69.2
Mortgage interest deduction 67.8
Child tax credit 57.3
State and local tax deduction 56.5
Exclusion of Social Security benefits 37.4
Charitable contribution deduction 34.8
Exclusion for cafeteria plan benefits 34.5
Top 10 as a % of total individual ~66%
Source: Senate Budget Committee Print 113-32, Tax Expenditures: Compendium of Background Material on Individual Provisions (Dec. 2014)
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
U.S. is unique in not taxing consumption
0% 9.2%
12.1% 13%
13.7% 13.8%
15.5% 15.7%
16.6% 17.2%
17.9% 18.2% 18.2%
18.6% 19%
19.4% 20.1%
20.6% 20.8% 20.8% 20.9% 21.1% 21.1% 21.2% 21.3%
21.7% 22% 22.1%
22.8% 23.7%
24.7% 26.4% 26.6%
30% 37.7%
0 5 10 15 20 25 30 35 40
United StatesJapan
AustraliaSwitzerland
CanadaItaly
FranceBelgium
SpainKorea
NetherlandsLuxembourg
NorwayAustriaMexico
GermanyAverage (Ex-U.S.)
DenmarkTurkey
United KingdomCzech Republic
SwedenFinlandGreece
Slovak RepublicIreland
SloveniaPoland
IcelandHungary
IsraelPortugalEstonia
New ZealandChile
Sources: OECD, Consumption Tax Trends 2014 (Table 1.A1.7); VAT increase information from Edward Lazear data, Hoover Institution
How many of the 33 other OECD countries have raised their VAT
rates since original implementation?
26
Value Added Taxes as a % of total taxation – OECD countries – 2012
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
2016 presidential contenders moving goalposts further apart Business provisions
Donald Trump Secretary Clinton
Corporate Rate 15% No change
Pass-through Rate May elect to be taxed as a C corp to benefit from 15% rate;
however, all but “small” pass-throughs (undefined) would face second-layer tax on distributions to owners
No change to rate; new small business “standard deduction,” enhanced §179 depreciation, expanded cash accounting
Full Expensing? Yes, electable for US manufacturers No
Interest Deduction Eliminated for firms that elect full expensing No change
Carried Interest ---------- Tax as ordinary income ----------
Energy No changes specified, but see “Other” below Repeal various fossil fuel preferences, including percentage
depletion and expensing of IDCs
Financial Products and Institutions
Phase-out deferral of inside build-up on life insurance contracts for “high-income earners”
(per original plan released in September 2015)
• Impose “high-frequency trading tax” with focus on discouraging excessive order cancellations
• Impose annual fee on covered liabilities of certain large financial firms
• Require certain derivatives to be marked to market annually
International Repeal deferral
• Tighten §7874 by lowering 80% test to 50%
• Impose “exit tax” on the unrepatriated foreign-source income of inverters and foreign-acquired US firms
• “Claw back” tax benefits from US firms that outsource jobs
• Address earnings stripping
Deemed Repatriation Yes (10% rate, payable over 10 years) No
Business Tax Reform Related to Enhanced
Infrastructure Spending?
Trump has discussed increasing such spending (by an amount “at least double” Clinton’s proposal), but has not connected the policy
with business tax reform
Yes. Clinton has proposed to increase such spending by $275 billion over 5 years, paid for by unspecified business tax reforms
Other Reduce or repeal “special interest“ provisions and deductions
made “unnecessary or redundant” by the 15% rate
New tax credits to encourage profit-sharing and apprenticeships; make permanent the New Markets Tax Credit; reauthorize and
expand the Build America Bonds program
.Source: Unless otherwise noted, parameters taken from campaign websites and Tax Policy Center
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
2016 presidential contenders moving goalposts further apart Individual provisions
Donald Trump Secretary Clinton
Top Individual Rate 33% (begins at $225k for joint filers) 43.6% (after new 4 percent surcharge on income over $5 million)
“Buffett Rule” No Yes. Minimum 30% rate on income over $1 million.
Capital Gains and Dividends 20% top rate (repeal 3.8% net investment income tax) Raise top capital gains rate to 43.4% (holding period ≤ 2 years),
gradually reduced to 23.8% (holding period > 6 years); no specified changes to dividend rates
Alternative Minimum Tax Repeal (both individual and corporate) No change
Itemized Deductions Dollar cap on total itemized deductions
($200k for joint filers, $100k for single filers)
Except for charitable contributions, limit tax benefit to 28 cents on the dollar (28% limit would also apply to excluded employer-
provided health benefits, tax exempt interest, etc.)
Standard Deduction $15,000 (single) / $30,000 (joint), indexed No change
Retirement No changes specified Limit additional contributions for taxpayers with high-balance,
tax-deferred retirement accounts
Estate and Gift Tax Repeal, but tax capital gains at death in excess of $10 million
• Increase rate to 45% on estate value > $3.5m; 50% on estates > $10m; 55% on estates > $50m;
65% on estates > $500m • Keep exemption portability, but no inflation adjustment
• Eliminate “step-up basis” at death • Unindexed $1m lifetime gift tax exemption
• Tighten grantor trust rules
Personal Exemptions Repeal No change
New Tax Benefits New above-the-line deduction for child care costs + new
Dependent Care Savings Accounts New tax credits for family caregivers and high out-of-pocket
health costs, expanded Child Tax Credit
10-Year Revenue Effect (Individual AND Business)
Loses $6.2 trillion
Raises $1.4 trillion
.Source: Unless otherwise noted, parameters and revenue impact taken from campaign websites and Tax Policy Center
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
President Obama’s “Framework” for business tax reform Relevant beyond 2016?
Obama “Framework”
Corporate Rate 28% (enhanced §199 deduction reduces effective rate on manufacturers to 25%)
Pass-through Rate No change to rate; enhanced §179 depreciation and expanded cash accounting intended to compensate
Depreciation Slow depreciation schedules by moving toward “economic” depreciation
Interest Deduction Reduce incentive for debt-financing, such as by “haircutting” business interest deduction
Research Credit Repeal traditional calculation method; increase ASC rate to 18%
Energy Repeal various fossil fuel preferences, including percentage depletion and expensing of IDCs; make permanent the PTC
and ITC for renewable electricity / renewable energy technologies
International
• 19% per-country minimum tax on foreign earnings imposed currently (i.e., no deferral); per-country foreign tax credit based on 85% of average effective rate
• Foreign earnings could be repatriated without residual US tax
• Tighten §7874 by lowering 80% test to 50%
Other
• Repeal LIFO
• Limit deferral under §1031 to $1 million per taxpayer per year
• Require certain derivatives to be marked to market annually
Deemed Repatriation Yes (14%, payable ratably over 5 years, with a proportional foreign tax credit, i.e., 14%:35%)
Business Tax Reform Related to Enhanced Infrastructure Spending?
Yes. Obama proposes to direct most of the “one-time” revenue raised through deemed repatriation to new infrastructure spending (remainder would go toward deficit reduction)
Budget Impact Revenue-neutral over the “long-run” (meaning beyond just the 10-year budget window); and raise sufficient revenue to
pay for deficit-financed 2015 extenders deal
Source: The President’s Framework for Business Tax Reform: An Update (April 2016)
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Another approach – the House GOP tax reform blueprint “Destination-based cash-flow tax”
House GOP Tax Reform Blueprint
Bu
sin
ess
Corporate Rate 20%
Pass-through Rate 25%
Full Expensing Yes
Interest Deduction No current deduction for net interest expense (disallowed deductions may be carried forward indefinitely)
Alternative Minimum Tax Repeal (both corporate and individual)
§199 Deduction Repeal
Net Operating Losses Eliminate NOL carryback; permit indefinite carryforward with amount “increased by an interest factor”; limit current deduction to
90% of taxable income
International
• Territorial (via 100% dividend exemption)
• One-time deemed repatriation with differential rates for cash (8.75%) and noncash assets (3.5%), payable over 8 years at the taxpayer’s election
• Eliminate most subpart F rules; retain foreign personal holding company rules
Border Adjusted Tax Base Tax imposed on imports, but not exports (similar in concept to border adjustment of other countries’ credit-invoice VATs)
In
div
idu
al
Top Individual Rate 33%
Capital Gains and Dividends Tax at ordinary rates with 50% exclusion (i.e., effective top rate of 16.5%); repeal 3.8% net investment income tax*
Itemized Deductions Repeal state and local tax deduction; review mortgage interest and charitable deductions to make more “effective and efficient”
Standard Deduction Consolidate standard deduction & personal exemption into a larger standard deduction of $12,000 (single) / $24,000 (joint)
Health Care Cap exclusion for employer provided health benefits at an unspecified threshold; new refundable credit for individuals without
access to workplace plans; repeal all other ACA taxes* (e.g., med device tax, “Cadillac” tax, additional 0.9% Medicare tax)
Estate Tax Repeal
Budget Impact Goal of revenue neutrality against a “current policy” baseline and after including “dynamic” revenue effects
.Items marked with an asterisk were included in the House GOP health care reform blueprint, which was released separately from the tax reform blueprint *
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Across the Capitol – senators have even more tax reform ideas
The yet unreleased corporate integration plan from Senate Finance Committee Chairman Orrin Hatch, R-Utah, is expected to call for a dividends paid deduction in order to reduce effective corporate tax rates, equalize the tax treatment of C corporations and pass-throughs, and reduce incentives for debt financing. In order keep the budget impact in check, all dividend recipients would be subject to full tax (i.e., not at preferred rates) by way of a withholding regime. To avoid favoring debt over equity, withholding is also expected to apply to interest payments on corporate debt.
Senate Finance Committee Ranking Democrat Ron Wyden of Oregon has been laying the groundwork for a possible return to the chairmanship in 2017 by releasing legislative discussion drafts: so far, (1) replacing asset-by-asset depreciation under MACRS with “pooling” approach (2) mark-to-market for speculative derivatives, and (3) changes affecting high-balance Roth accounts and inherited retirement accounts. Wyden historically has supported the policy of repealing deferral of active foreign source income as a means to help finance a reduction in the corporate rate.
Senate Finance Committee member Ben Cardin, D-Md., released legislation in 2014 that would impose a 10% credit-invoice Value Added Tax on most purchases of goods and services as part of a broader plan that would reduce the corporate rate to 17% and the top individual rate to 28%, while retaining most current law tax benefits. Cardin is expected to reintroduce an updated bill this fall.
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
What to expect from the remainder of the 114th Congress
“Lame Duck” Possibilities
FY2017 appropriations beyond December 9 (MUST DO)
Trans-Pacific Partnership
Nominations – SCOTUS, Export-Import Bank
Defense funding authorization
Coal miners’ pension rescue
Criminal justice reform
Lingering Tax Issues
Orphaned tax extenders from 2015 PATH Act – i.e., §48 ITC technologies
Other tax extenders expiring after 12/31/2016
Tax technical corrections
Federal legislation affecting state/local taxes (e.g., remote sales tax, “Mobile Workforce”, etc.)
Pending tax treaties
Legislative response to 385 regs / European Commission rulings
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
Questions?
Alex Brosseau
202.661.4532
Tax Policy in the 114th Congress (and Beyond) Copyright © 2016 Deloitte Development LLC. All rights reserved.
This presentation contains general information only and Deloitte is not, by means of this presentation, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This presentation is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Deloitte shall not be responsible for any loss sustained by any person who relies on this presentation.
About this presentation
About Deloitte
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee (“DTTL”), its network of member firms, and their related entities. DTTL
and each of its member firms are legally separate and independent entities. DTTL (also referred to as “Deloitte Global”) does not provide services to clients. Please see
www.deloitte.com/about for a detailed description of DTTL and its member firms. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP
and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.
Copyright © 2016 Deloitte Development LLC. All rights reserved.
36 USC 220506