Skip to content

Improve federal CDCC conformance with IRC § 21 (deemed income, qualifying-individual count, filing status)#8704

Draft
hua7450 wants to merge 2 commits into
PolicyEngine:mainfrom
hua7450:cdcc-disabled-dependent-expenses
Draft

Improve federal CDCC conformance with IRC § 21 (deemed income, qualifying-individual count, filing status)#8704
hua7450 wants to merge 2 commits into
PolicyEngine:mainfrom
hua7450:cdcc-disabled-dependent-expenses

Conversation

@hua7450

@hua7450 hua7450 commented Jun 21, 2026

Copy link
Copy Markdown
Collaborator

Summary

Improves federal CDCC conformance with IRC § 21, building on the expense fix in #8746 (which lets a disabled adult's care expenses reach the credit base via the new care_expenses input). This PR adds the eligibility, count, earned-income, and filing-status rules — most importantly, the rule that makes the credit actually pay out for a disabled non-earning spouse.

Includes #8746. This branch contains #8746's commit so it's testable on its own; once #8746 merges, this PR's diff collapses to just the § 21 edge cases below.

Changes

1. Qualifying individual — is_cdcc_eligible / count_cdcc_eligible (§ 21(b)(1)). The disability prong now covers a disabled spouse, including one the model assigns as the tax-unit head; the age prong requires dependency. A couple's two incapacitated spouses count as one qualifying individual (§ 21(b)(1)(C): the taxpayer is never their own), so the $3,000/$6,000 cap and the deemed floor aren't double-counted.

2. Deemed earned income — § 21(d)(2). A spouse who is a full-time student or incapable of self-care is deemed to earn $250/mo (one qualifying individual) or $500/mo (two or more), applied to only one spouse (Treas. Reg. § 1.21-2(b)(4), Example 3). Without it, a non-earning disabled spouse fails the earned-income test and the credit is $0. New deemed_earned_income parameter, cdcc_income_floor_eligible variable, and rewritten min_head_spouse_earned.

3. Married filing separately — § 21(e)(2). The credit now returns $0 for SEPARATE filers. A separated taxpayer who qualifies under § 21(e)(4) is treated as not married and files as head of household, so they are not excluded.

Reproductions (TY 2024)

Scenario Before After
Married, both spouses incapable of self-care, one earns $50k $1,200 (2×) $600
Married filing separately, one child, $3k expenses $660 $0

How it composes with #8746

The "two incapacitated spouses" integration case is the proof the two PRs fit together: the care expense reaches the base via care_expenses (#8746), and the count cap + § 21(d)(2) deemed income (this PR) let it survive the caps → $600.

Tests

Edge-case unit tests (is_cdcc_eligible, count_cdcc_eligible, cdcc_income_floor_eligible, min_head_spouse_earned, MFS in cdcc.yaml) and the federal integration case. 29 pass locally; CI runs the full suite.

🤖 Generated with Claude Code

@codecov

codecov Bot commented Jun 21, 2026

Copy link
Copy Markdown

Codecov Report

✅ All modified and coverable lines are covered by tests.
✅ Project coverage is 100.00%. Comparing base (cf06458) to head (294902b).
⚠️ Report is 14 commits behind head on main.

Additional details and impacted files
@@            Coverage Diff            @@
##              main     #8704   +/-   ##
=========================================
  Coverage   100.00%   100.00%           
=========================================
  Files            5         8    +3     
  Lines           73       120   +47     
  Branches         0         1    +1     
=========================================
+ Hits            73       120   +47     
Flag Coverage Δ
unittests 100.00% <100.00%> (ø)

Flags with carried forward coverage won't be shown. Click here to find out more.

☔ View full report in Codecov by Harness.
📢 Have feedback on the report? Share it here.

🚀 New features to boost your workflow:
  • ❄️ Test Analytics: Detect flaky tests, report on failures, and find test suite problems.

@hua7450 hua7450 changed the title Fix CDCC returning $0 for disabled adult dependents Fix CDCC returning $0 for disabled adult dependents (with section 21(d)(2) deemed income) Jun 22, 2026
@hua7450 hua7450 changed the title Fix CDCC returning $0 for disabled adult dependents (with section 21(d)(2) deemed income) Improve federal CDCC conformance with IRC § 21 (disabled dependents, deemed income, filing status) Jun 23, 2026
@hua7450 hua7450 marked this pull request as ready for review June 24, 2026 03:46
@hua7450 hua7450 force-pushed the cdcc-disabled-dependent-expenses branch from 9607204 to cf3acf8 Compare June 24, 2026 04:10
hua7450 and others added 2 commits June 24, 2026 16:31
The Child and Dependent Care Credit drew care expenses only from
tax_unit_childcare_expenses, which is child-scoped (children under 18). A
disabled adult qualifying individual under IRC section 21 — a dependent or
spouse age 18 or older — was therefore attributed $0 of care expenses and
received a $0 credit (and $0 in state mirrors such as Kansas, where
ks_cdcc is a share of the federal credit).

Route adult dependent care through the existing care_expenses input (now
year-defined) and add it to cdcc_relevant_expenses alongside childcare. The
childcare and childcare-subsidy pipeline is left unchanged, so CCDF/state
CCAP programs and the DC KCCATC are unaffected.

Co-Authored-By: Claude Opus 4.8 (1M context) <noreply@anthropic.com>
Builds on the care_expenses expense fix:
- Count a disabled spouse modeled as the tax-unit head, and treat a couple's
  two incapacitated spouses as one qualifying individual (IRC 21(b)(1)(C)),
  so cdcc_limit and the deemed floor are not double-counted.
- Apply IRC section 21(d)(2) deemed earned income for a student or
  incapacitated spouse, so the earned-income test no longer zeroes the credit
  for a non-earning disabled spouse.
- Disallow the credit for married taxpayers filing separately (IRC 21(e)(2)).

Co-Authored-By: Claude Opus 4.8 (1M context) <noreply@anthropic.com>
@hua7450 hua7450 force-pushed the cdcc-disabled-dependent-expenses branch from 8208419 to 294902b Compare June 24, 2026 20:47
@hua7450 hua7450 changed the title Improve federal CDCC conformance with IRC § 21 (disabled dependents, deemed income, filing status) Improve federal CDCC conformance with IRC § 21 (deemed income, qualifying-individual count, filing status) Jun 24, 2026
@hua7450 hua7450 marked this pull request as draft June 24, 2026 20:49
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