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comments submitted on proposed clawback regs

2/21/2019

 
In the end, despite what a couple of Joint Committee staffers told me about who understood what when the statutory language was being hammered out and what the revenue estimates did or did not assume about clawback, I decided to go ahead and submit comments opposing the proposed regs.  Full text appended, and this will get a brief mention in the next issue of Jack Straw.
greystocke_project_comment.pdf
File Size: 63 kb
File Type: pdf
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    the very occasional blogger

    The text here used to say,

    "In my 'day job,'  I do not often have an opportunity to articulate some of my more contrarian views."

    With the launch of the Jack Straw Fortnightly back in January 2018 that is no longer the case. This blog remains "very occasional," however, and functions primarily as a place to post news releases.

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