I. Overview
This blog does not serve as a critique of the Coronavirus Aid, Relief and Economic Security (“CARES”) Act or the U.S. bailout packages from 2008 through 2009. Instead, this blog seeks to highlight and explain key economic provisions of the emergency funding in response to the 2008 financial crisis and the ongoing financial crisis resulting from COVID-19. Setting aside the debate of which institution was responsible for the 2008 financial crisis, the bank bailouts served the essential purpose of providing credit to the mainstream economy.[1] The mainstream economy then was no different from the economy today. It included massive corporations, mid-size businesses, and local “mom and pop” stores. [2] When all was said and done, the 2008 bailouts cost taxpayers around $1.64 trillion.[3]
The present bailouts are aimed at mitigating the economic impact of the Coronavirus, otherwise referred to as COVID-19. Based on initial estimates, the CARES Act bailouts will likely cost taxpayers around $2.00 trillion.[4] Unlike the 2008 bailout, the recent stimulus package aims to provide economic relief for individuals and small businesses, which have been economically decimated after being forced to close their doors in an effort to mitigate the spread of Coronavirus.[5] While certain parallels can be drawn between the current crisis and the 2008 financial crisis, the ongoing public health crisis creates another dimension of complex problems for fiscal relief to address.
II. CARES Act
On March 27, 2020, the Coronavirus Aid, Relief and Economic Security Act passed the House of Representatives, by a voice vote, and was signed into law later that day by President Trump.[6] The CARES Act builds on the two former pieces of legislation, the $8.3 billion emergency funding deal and the House Families First Coronavirus Response (“HFFCR”) Act, by providing a broader range of support to individuals and businesses, including changes to tax policy.[7]
Tranche 1: $8 billion emergency funding deal
Earlier this past March, President Trump signed into law the first Coronavirus Aid tranche.[8] The tranche included an approximately $8 billion emergency funding deal.[9] The deal included over $3 billion for the research and development of Coronavirus vaccines and diagnostics, roughly $2.2 billion to fund public health programs, and $1 billion for medical supplies and other Coronavirus preparedness measures.[10] The initial legislation also introduced and new set of low-interest Small Business Administration (“SBA”) loans for businesses.[11]
Tranche 2: House Families First Coronavirus Response Act
President Trump signed the HFFCR Act into law only a few weeks later.[12] HFFCR provided two weeks of paid sick leave to workers required to quarantine, take care of a sick family member, or care for their children whose school or daycare closed because of the Coronavirus.[13] In addition, HFFCR requires that workers forced to quarantine or that have Coronavirus symptoms will receive their regular pay, while workers who are taking care of a family member or their child would receive two-thirds of their regular pay.[14] The paid sick leave is limited to $511 per day and a $5,110 aggregate pay limit for workers that have Coronavirus symptoms or were forced to quarantine.[15] A $200 per day and $2,000 aggregate limit applies for workers caring for a sick family member or child.[16]
Tranche 3: Coronavirus Aid, Relief and Economic Security Act
Shortly after passing the HFFCR, the United States sadly exceeded over 10,000 confirmed Coronavirus cases, later becoming the country with the most confirmed cases worldwide.[17] Despite unfortunate delays, the bipartisan CARES Act came to the aid of U.S. individuals and businesses on March 27, 2020.[18] The bulk of this blog focuses on the CARES Act, since it is the most significant piece of U.S. Coronavirus aid as of today.
Tranche 4: Small Business Relief Replenishment and Additional Assistance
Less than a month after passing the CARES Act, the federal government was forced to assess the need for additional funding in light of the ongoing stay at home guidelines. The House sent a $484 billion bill to President Trump on April 23, 2020, which he signed into law the next afternoon.[19] The most recent bill replenishes the Paycheck Protection Program (discussed below), sets aside additional funds for medium, small and community lenders, and funds for expanded testing capacity nationwide.[20]
A. CARES Act Key Highlights
1. Expansion of Unemployment Insurance and Benefits: Relief for Workers Affected by Coronavirus Act:
The “Relief for Workers Affected by Coronavirus Act” (“Title II, Section A”) drastically expands unemployment insurance benefits for workers sidelined for reasons associated with the Coronavirus.[21] Title II, Section A creates the temporary Pandemic Unemployment Assistance program (“PUA”), effective January 27, 2020 through December 31, 2020, which covers individuals not otherwise eligible for unemployment insurance and benefits. [22] Covered individuals now include the self-employed, independent contractors, those with limited work history, or those who have exhausted previous unemployment benefits.[23] The individual must self-certify they are unemployed, partially unemployed or unable to work because: i) they have been diagnosed with or have Coronavirus symptoms; ii) a member of their household has Coronavirus; iii) they are caring for a family member or member of their household who has Coronavirus; iv) a member of their household for which the individual is a primary caregiver is unable to attend school as a direct result of the Coronavirus public health emergency; v) they have quit their job as a direct result of Coronavirus, and other factors.[24] Individuals who are able to telework with pay or who already have received paid sick leave are ineligible to receive Pandemic Unemployment Assistance.[25]
Covered individuals may receive assistance for a maximum of 39 weeks, in addition to any weeks the covered individual received regular unemployment benefits provided under pre-Coronavirus federal or state law.[26] A covered individual would receive regular unemployment they are entitled to under federal or state law plus an additional amount referred to as Federal Pandemic Unemployment Compensation of $600 per week.[27] The program also claims to remove any waiting periods established by state unemployment laws.[28]
2. Payment Protection Program:
The Paycheck Protection Program (“PPP”) is a loan program designed to provide a direct incentive for small businesses (classified as fewer than 500 employees) to keep their workers on the company payroll.[29] Under the PPP, eligible small businesses may qualify for a loan up to $10 million determined by eight weeks of prior average payroll plus an additional 25% of that amount.[30] The SBA indicated loan payment will be deferred for six months, and the SBA will forgive loans (including interest) if all employees are kept on the payroll for eight weeks and the loan money is used for business payroll, rent, mortgage interest, or utilities.[31] In other words, the PPP loan can be converted to a grant for many small businesses.
The federal government initially allocated $349 billion for the PPP that can cover employees making up to $100,000 per year.[32] Based on initial reports, the PPP loan was set to be available from February 15, 2020 through June 30, 2020.[33] On April 16, 2020, the SBA announced it would not accept any more applications for the initial $349 billion program since funds quickly ran out.[34]
Following rumors that U.S. lawmakers would advance legislation to provide more money under the PPP before the end of April, House lawmakers reached a deal on April 23, 2020.[35] The $484 billion program, round two for the PPP, replenishes two small business-relief programs and offers additional assistance to hospitals while funding an expansion of testing capacity nationwide.[36] It is important to monitor how the PPP funds will be allocated over the next few weeks since there were distinct abuses in the first round of aid.[37] In the event funds from the second round of PPP are depleted before businesses are back on their feet, lawmakers will likely have to draw up a third round of grants.
3. Recovery Rebate:
The recovery rebate gives individuals a cash payment of $1,200 ($2,400 for married couples) plus an additional $500 for qualifying dependent children.[38] The payments begin to phase out at $75,000 in adjusted gross income ($150,000 for married couples and $112,500 for heads of household), completely phasing out at $99,000 for single taxpayers with no children and $198,000 for joint taxpayers with no children.[39] The recovery rebate will be calculated based on a taxpayer’s 2018 or 2019 income tax return (whichever is filed most recently), but taxpayers eligible for a larger rebate based on 2020 income will receive it in the 2020 tax season.[40] The idea is if a taxpayer’s income were adversely affected by the Coronavirus during the 2020 tax year, they should be given the larger, more beneficial credit in 2020.
The Penn Wharton Budget Model projects that the rebates would decrease federal revenue by around $285 billion in 2020.[41] In addition, the recovery rebate does not generally constitute taxable income at the federal or state level.[42] However, the tax code in a small handful of states does not specifically exempt the federal credit from state taxable income.[43] Therefore, Alabama, Iowa, Louisiana, Missouri, Montana, and Oregon would likely have to amend their tax code to exempt the recovery rebate from state income taxation.[44] For an overview of the comparable Economic Stimulus Act of 2008, please see the below discussion.
4. $454 Billion Emergency Fund:
CARES provides $454 billion for the Secretary of the Treasury to make direct loans or to guarantee loans made by the Federal Reserve to assist business, states, and municipalities dealing with the pandemic.[45] The Federal Reserve would do this through (i) purchasing obligations or other interests directly from issuers or other interests; (ii) purchasing obligations or other interests in secondary markets or otherwise; or (iii) making loans, including loans or other advances secured by collateral.[46] Companies taking loans must not engage in stock buybacks for the duration of the loan plus one year, and must retain at least 90 percent of its employment level as of March 24, 2020.[47] There are also terms in the loan limiting compensation and severance pay for individuals employed by the firms taking loans.[48]
5. $150 billion in a Coronavirus Relief Fund:
CARES offers state aid through a $150 billion Coronavirus Relief Fund that state and local governments can use this year to meet costs connected to Coronavirus.[49] It is estimated each state will receive at least $1.25 billion, with the District of Columbia receiving $500 million, and the most populous states (California and Texas) receiving over $10 billion each.[50] For reference, it is estimated Florida and New York will receive $8.33 billion and $7.54 billion, respectively, while 20 of the least populated states will receive $1.25 billion each.[51]
6. Health Provision:
Perhaps the most important non-economic provision of the CARES Act is the health provision. The provision addresses the alarming health crisis while also having an indirect impact on the economy. The quicker people get healthy, the quicker our economy gets back on its feet.[52] The health provision addresses supply shortages, diagnostic testing, encouragement for the creation of drugs to treat the virus, and support for health-care providers.[53] The provision also addresses improving telehealth services access, strengthening related Medicare and Medicaid provisions, and providing support for educational institutions.[54]
7. 10 Percent Early Withdrawal Penalty Waiver:
Taxpayers can take up to $100,000 in Coronavirus-related distributions from retirement plans without being subject to the Internal Revenue Code Sec. 72(t) 10% tax for early distributions, repayable within three years.[55] An eligible taxpayer is one who has been diagnosed or whose spouse or dependent has been diagnosed with Coronavirus.[56] An eligible taxpayer is also an individual who experiences adverse financial consequences from being quarantined, furloughed, or laid off, or who has had his or her work hours reduced, or who is unable to work due to lack of child care.[57] The bill also allows loans up to $100,000 from qualified plans with deferred repayment.[58]
8. Charitable deductions:
Taxpayers will be able to claim up to $300 in cash contributions made to a nonprofit charity this year as a deduction from their gross income, even if they take the standard deduction on their 2020 income tax return.[59] Recently, taxpayers were only able to claim charitable deductions if they itemized their deductions, which has changed substantially since the standard deduction increased as a result of the Tax Cuts and Jobs Act of 2017.[60]
9. Other provisions:
Employer payment of student loans: Under CARES, employers may contribute up to $5,250 annually toward student loans and the payments would be excluded from an employee’s income.[61]
Payroll tax delay: The bill delays payment of 50% of 2020 employment taxes until Dec. 31, 2021; the other 50% will be due Dec. 31, 2022.[62]
Net operating losses: The bill temporary repeals the 80% income limitation for net operating loss deductions for years beginning before 2021.[63] For losses arising in 2018, 2019, and 2020, a five-year carryback is allowed.[64]
Interest limitation: For tax years beginning in 2019 and 2020, Sec. 163(j) is amended to increase the adjusted taxable income percentage from 30% to 50%.[65]
B. CARES Act Summary:
The CARES package includes approximately $350 billion in forgivable loans (or grants) to small business, around $250 billion in increased unemployment insurance and $300 billion in direct payments to households.[66] Reminiscent of the 2008 deal, CARES also includes $500 billion in loans to airlines and other businesses, as well as billions in direct grants to companies in exchange for a stake in the companies receiving the grant.[67] In total, the initial package is estimated to cost taxpayers over $2 trillion.[68] However, the April 24th fund replenishment is a reminder that the ongoing health crisis will dictate the extend of federal aid funding.
III. Economic Stimulus Act of 2008 and the New Deal
A. Recovery Rebate of 2008
In contrast to the recovery rebate under CARES, most taxpayers in 2007 or 2008 received a basic refundable credit of $600 ($1,200 for joint filers).[69] Taxpayers who qualified for less than $300 of the full basic credit ($600 for joint filers) could get $300 ($600 for joint) under provisions of the Economic Stimulus Act.[70] People who qualified for the basic refundable credit could receive an extra $300 credit for each eligible child.[71] Total aid under the Economic Stimulus Act of 2008 amounted to $152 billion.[72]
B. Emergency Economic Stabilization Act of 2008: Troubled Asset Relief Program
On October 3, 2008, President George W. Bush signed a $700 billion bank bailout bill; the Emergency Economic Stabilization Act of 2008.[73] The purpose of the bailout was to alleviate the financial crisis of the late 2000s by taking mortgage-backed securities that were in danger of default off the books of banks, hedge funds, and pension funds.[74]
The key highlight of the bill was the Troubled Assets Relief Program (“TARP”) where troubled banks were expected to submit a bid price to sell their assets (in different auctions based on asset class) to TARP.[75] However, because it took too long to develop the auction program and financial institutions needed immediate help, the Treasury Department had to pivot its efforts and used $105 billion in TARP funds to launch the Capital Purchase Program.[76] Under the Capital Purchase Program, the Treasury Department purchased preferred stock in the eight leading banks.[77]
TARP expired on October 3, 2010, and during that time, the Treasury had used the funds in four general areas: i) it contributed $67.8 billion to the $182 billion bailout of American International Group (AIG); ii) it used $80.7 billion to bail out General Motors Company, Chrysler LLC and Ford Motor Company; iii) it loaned $20 billion to the Federal Reserve who in turn lent the money to its member banks so they could continue offering credit to homeowners and business; and, iv) it set aside $75 billion to help homeowners refinance or restructure their mortgages with the Homeowner Affordability and Stability Plan.[78]
C. American Recovery and Reinvestment Act of 2009
As a follow-up to President George W. Bush’s TARP, President Barack Obama signed the American Recovery Reinvestment Act (“ARRA”) of 2009 into law early that year, ultimately ending the Great Recession in July 2009.[79] ARRA was a plan to put $787 billion into the pockets of American families and small businesses to boost demand and instill confidence in our economy.[80]
In short, the ARRA helped: i) stimulate economic demand by sending $260 billion to families through tax cuts, credits and unemployment benefits; ii) create jobs by funding public works projects to modernize federal infrastructure; iii) jump start the alternative energy industry in America through renewable energy tax cuts; iv) expand health care; v) fund and improve public and private education; vi) invest in science research and technology; and, vii) help small businesses through tax deductions, credits and loan guarantees.[81]
When all was said and done, the Economic Stimulus Act of 2008, TARP, and ARRA cost taxpayers around $1.64 trillion.[82] However, it helped turn around the U.S. economy from the stock market crash of 2008 and the Great Recession of late 2008 in a relatively short period of time. In addition, estimates indicate the U.S. government recorded a $15.3 billion profit when it closed its books on TARP in late 2014.[83]
D. The New Deal
It is worth mentioning the New Deal, a set of policies that President Franklin D. Roosevelt implemented to counteract the economic effects of the Great Depression.[84] The stock market crashed on October 29, 1929, triggering the Great Depression (1929 through 1940s) which spread from the U.S. to the rest of the world.[85] In response to waves of bank failures and 25% unemployment, the government adopted a wide range of programs that sought to stimulate the economy – collectively referred to as the “New Deal.”[86] According to economists Price Fishback and Valentina Kachanovskaya, New Deal federal spending was $41.7 billion at the time, which translates to roughly $653 billion today.[87]
IV. Conclusion
The New Deal, TARP, and ARRA were implemented in the midst of an economic crisis. The bills were passed to stabilize an economy, decades apart, clobbered by unemployment, stock market crashes, and bank failure. The rebound post 1930s and late 2000s were gradual, but promising, for the U.S. and world economy. CARES Act was implemented in anticipation of an economic downturn, “The Great Lockdown,” which was recently cited as the worst economic downturn since the Great Depression.[88] Therefore, though we have the New Deal, TARP, and ARRA as a benchmark of a federal lifejacket, we have not really seen a bailout of this magnitude, timing, and with these health implications. In all likelihood, the early success of the CARES Act, and its progeny, will be tested as the crisis continues into the future.
The Great Depression and the New Deal opened the door to government involvement in the economy and established new norms.[89] Similarly, TARP and ARRA ran contrary to certain assumptions about the government’s relationship with private markets. After the bailouts of the late 2000s, policy makers swore they would never do it again.[90] Unfortunately, it took around 10 years for the next bailout, and one might question whether “bailouts” are the new normal. However, before going that far, it is paramount that the ongoing crisis, at its core, is one of public health and is therefore distinguishable from the crises in the 1930s and late 2000s. Simply put, it is too early to say what this will mean for the government’s relationship with private markets in the future.[91]
With respect to the efficacy of the CARES Act – although the New Deal and 2008 bailout provide an instructive framework for how to stimulate the economy – the ongoing public health crisis makes it hard to say with certainty which tools from the past will prove useful today. If these policy measures are successful, we will be able to revive the economy more quickly when the underlying public health crisis eventually subsides, and businesses are clear to open their doors.
Endnotes:
[1] Greg Ip and Jacob M. Schlesinger, Spend Generously, Take Care of Workers: Coronavirus Stimulus Takes Lessons From Tarp, Wall Street Journal (Mar. 26, 2020), https://www.wsj.com/articles/spend-generously-take-care-of-workers-coronavirus-stimulus-takes-lessons-from-tarp-11585246787
[2] Id.
[3] Id.
[4] Kelsey Snell, What’s Inside the Senate’s $2 Trillion Coronavirus Aid Package (Mar. 25, 2020), https://www.npr.org/2020/03/26/821457551/whats-inside-the-senate-s-2-trillion-coronavirus-aid-package
[5] Greg Ip and Jacob M. Schlesinger, Spend Generously, Take Care of Workers: Coronavirus Stimulus Takes Lessons From Tarp, Wall Street Journal (Mar. 26, 2020), https://www.wsj.com/articles/spend-generously-take-care-of-workers-coronavirus-stimulus-takes-lessons-from-tarp-11585246787
[6] Garret Watson, Taylor LaJoie, Huaqun Li & Daniel Bunn, Congress Approves Economic Relief Plan for Individuals and Business, Tax Foundation (Mar. 30, 2020), https://taxfoundation.org/cares-act-senate-coronavirus-bill-economic-relief-plan/
[7] Id.
[8] Gina Heeb, House passes $8 billion emergency package in scramble to fight coronavirus outbreak in US, Markets Insider (Mar. 4, 2020), https://markets.businessinsider.com/news/stocks/congress-lawmakers-8-billion-funding-deal-fight-coronavirus-outbreak-2020-3-1028965749
[9] Id.
[10] Id.
[11] Coronavirus (COVID-19): Small Business Guidance & Loan Resources, https://www.sba.gov/page/coronavirus-covid-19-small-business-guidance-loan-resources
[12] Erica York, Senate Receives Final Versions of House Coronavirus Bill Offering Paid Leave, Tax Foundation (Mar. 17, 2020), https://taxfoundation.org/senate-coronavirus-bill-paid-leave/
[13] Id.
[14] Id.
[15] Id.
[16] Id.
[17] Marisa Iati, et al U.S. becomes first country to report 100,000 confirmed coronavirus cases; Trump invokes Defense Production Act., Washington Post (Mar. 27, 2020), https://www.washingtonpost.com/world/2020/03/27/coronavirus-latest-news/
[18] Leon LaBrecque, The CARES Act Has Passed: Here Are The Highlights, Forbes (Mar. 29, 2020), https://www.forbes.com/sites/leonlabrecque/2020/03/29/the-cares-act-has-passed-here-are-the-highlights/#58218acd68cd
[19] Andrew Duehren and Siobhan Hughes, House Approves $484 Billion Bill to Aid Small Businesses, Hospitals, The Wall Street Journal (Apr. 23, 2020), https://www.wsj.com/articles/house-set-to-approve-484-billion-bill-to-aid-small-businesses-hospitals-11587641659?mod=hp_lead_pos1
[20] Id.
[21] Michael P. Wissa, CARES Act: Expansion of Unemployment Insurance and Benefit, The National Law Review (Mar. 27, 2020), https://www.natlawreview.com/article/cares-act-expansion-unemployment-insurance-and-benefits
[22] Id.
[23] Id.
[24] Id.
[25] Id.
[26] Id.
[27] Id.
[28] Id.
[29] Paycheck Protection Program (PPP), https://www.sba.gov/funding-programs/loans/paycheck-protection-program-ppp
[30] Rosalind Z. Wiggins, CARES Act $454 billion Emergency Fund Could add up to Much More for Businesses, States and Municipalities
[31] Paycheck Protection Program (PPP), https://www.sba.gov/funding-programs/loans/paycheck-protection-program-ppp
[32] Garret Watson, Taylor LaJoie, Huaqun Li & Daniel Bunn, Congress Approves Economic Relief Plan for Individuals and Business, Tax Foundation (Mar. 30, 2020), https://taxfoundation.org/cares-act-senate-coronavirus-bill-economic-relief-plan/
[33] Paycheck Protection Program (PPP), https://www.sba.gov/funding-programs/loans/paycheck-protection-program-ppp
[34] Stephen Gandel, Paycheck Protection Program out of money: Thousands of small businesses shut out (Apr. 16, 2020), https://www.cbsnews.com/news/paycheck-protection-program-out-of-money-small-businesses-shut-out/
[35] Andrew Duehren and Siobhan Hughes, House Approves $484 Billion Bill to Aid Small Businesses, Hospitals, The Wall Street Journal (Apr. 23, 2020), https://www.wsj.com/articles/house-set-to-approve-484-billion-bill-to-aid-small-businesses-hospitals-11587641659?mod=hp_lead_pos1
[36] Id.
[37] Sarah Hansen, Large Public Companies May Be Shut Out of New PPP Funds After Shake Shack Fallout, Forbes (Apr. 23, 2020), https://www.forbes.com/sites/sarahhansen/2020/04/23/large-public-companies-may-be-shut-out-of-new-ppp-funds-after-shake-shack-fallout/#67c1c154658b
[38] Recovery Rebates in the CARES Act: Update, Penn Wharton University of Pennsylvania (Mar. 27, 2020), https://budgetmodel.wharton.upenn.edu/estimates/2020/3/27/the-cares-act-update
[39] Supra at note iii.
[40] Id.
[41] Recovery Rebates in the CARES Act: Update, Penn Wharton University of Pennsylvania (Mar. 27, 2020), https://budgetmodel.wharton.upenn.edu/estimates/2020/3/27/the-cares-act-update
[42] Jared Walczak, These States Could Tax Your Recovery Rebates, Tax Foundation (Apr. 8, 2020), https://taxfoundation.org/cares-act-rebate-state-tax-rebate/
[43] Id.
[44] Id.
[45] Rosalind Z. Wiggins, CARES Act $454 billion Emergency Fund Could add up to Much More for Businesses, States and Municipalities
[46] Id.
[47] Supra at note iii
[48] Id.
[49] How Much Each State Will Receive From the Coronavirus Relief Fund in the CARES Act, (Mar. 26, 2020), https://www.cbpp.org/research/how-much-each-state-will-receive-from-the-coronavirus-relief-fund-in-the-cares-act
[50] Id.
[51] Id.
[52] Healthy population equals healthy economy, American Medical Association (Jan. 13, 2015), https://www.ama-assn.org/practice-management/economics/healthy-population-equals-healthy-economy
[53] Garret Watson, Taylor LaJoie, Huaqun Li & Daniel Bunn, Congress Approves Economic Relief Plan for Individuals and Business, Tax Foundation (Mar. 30, 2020), https://taxfoundation.org/cares-act-senate-coronavirus-bill-economic-relief-plan/
[54] Id.
[55] Alistair M. Nevius, CARES Act tax provisions aim to stabilize pandemic-ravaged economy, Journal of Accountancy (Mar. 25, 2020 updated Mar. 27, 2020), https://www.journalofaccountancy.com/news/2020/mar/cares-act-economic-relief-coronavirus-tax-provisions.html
[56] Id.
[57] Id.
[58] Id.
[59] Tanza Loudenback, As coronavirus spreads, the $2 trillion economic relief bill makes donating to charity more convenient than ever, Business Insider (Mar. 27, 2020), https://www.businessinsider.com/personal-finance/coronavirus-stimulus-bill-new-charitable-deduction-2020-3
[60] Id.
[61] Garret Watson, Taylor LaJoie, Huaqun Li & Daniel Bunn, Congress Approves Economic Relief Plan for Individuals and Business, Tax Foundation (Mar. 30, 2020), https://taxfoundation.org/cares-act-senate-coronavirus-bill-economic-relief-plan/
[62] Tucker Higgins, Senate’s $2 trillion coronavirus package includes payroll tax delay for employers, CNBC (Mar. 26, 2020), https://www.cnbc.com/2020/03/26/coronavirus-stimulus-bill-includes-payroll-tax-delay-for-employers.html
[63] Alistair M. Nevius, CARES Act tax provisions aim to stabilize pandemic-ravaged economy, Journal of Accountancy (Mar. 25, 2020 updated Mar. 27, 2020), https://www.journalofaccountancy.com/news/2020/mar/cares-act-economic-relief-coronavirus-tax-provisions.html
[64] Id.
[65] Id.
[66] Greg Ip and Jacob M. Schlesinger, Spend Generously, Take Care of Workers: Coronavirus Stimulus Takes Lessons From Tarp, Wall Street Journal (Mar. 26, 2020), https://www.wsj.com/articles/spend-generously-take-care-of-workers-coronavirus-stimulus-takes-lessons-from-tarp-11585246787
[67] Id.
[68] Id.
[69] What did the 2008-10 tax stimulus acts do?, Tax Policy Center (Dec. 7, 2020), https://www.taxpolicycenter.org/briefing-book/what-did-2008-10-tax-stimulus-acts-do
[70] Id.
[71] Id.
[72] Greg Ip and Jacob M. Schlesinger, Spend Generously, Take Care of Workers: Coronavirus Stimulus Takes Lessons From Tarp, Wall Street Journal (Mar. 26, 2020), https://www.wsj.com/articles/spend-generously-take-care-of-workers-coronavirus-stimulus-takes-lessons-from-tarp-11585246787
[73] Kimberly Amadeo, What Was the Bank Bailout Bill?, The Balance (Aug. 22, 2019), https://www.thebalance.com/what-was-the-bank-bailout-bill-3305675
[74] Id.
[75] Andrew Ackerman and Jeffrey Sparshott, A TARP Auction Loss for Treasury, The Wall Street Journal (Mar. 29, 2012), https://www.wsj.com/articles/SB10001424052702303404704577311323366221962
[76] Supra at note Iii.
[77] Id.
[78] Id.
[79] Id.
[80] Id.
[81] Id.
[82] Greg Ip and Jacob M. Schlesinger, Spend Generously, Take Care of Workers: Coronavirus Stimulus Takes Lessons From Tarp, Wall Street Journal (Mar. 26, 2020), https://www.wsj.com/articles/spend-generously-take-care-of-workers-coronavirus-stimulus-takes-lessons-from-tarp-11585246787
[83] Chris Isidore, U.S. ends TARP with $15.3 billion profit, CNN (Dec. 19, 2014), https://money.cnn.com/2014/12/19/news/companies/government-bailouts-end/
[84] Kimberly Amadeo, New Deal Summary, Programs, Policies, and Its Success, The Balance (Mar. 3, 2020), https://www.thebalance.com/fdr-and-the-new-deal-programs-timeline-did-it-work-3305598
[85] Surviving the Dust Bowl, PBS (accessed April 16, 2020), https://www.pbs.org/wgbh/americanexperience/features/dustbowl-great-depression/
[86] Kimberly Amadeo, New Deal Summary, Programs, Policies, and Its Success, The Balance (Mar. 3, 2020), https://www.thebalance.com/fdr-and-the-new-deal-programs-timeline-did-it-work-3305598
[87] Bill Dupor, The Recovery Act of 2009 vs. FDR’s New Deal: Which Was Bigger, Federal Reserve Bank of St. Louis (Feb. 10, 2017), https://www.stlouisfed.org/publications/regional-economist/first_quarter_2017/the-recovery-act-of-2009-vs-fdrs-new-deal-which-was-bigger
[88] Gita Gopinath, The Great Lockdown: Worst Economic Downturn Since the Great Depression, IMFBlog (Apr. 14, 2020), https://blogs.imf.org/2020/04/14/the-great-lockdown-worst-economic-downturn-since-the-great-depression/
[89] Surviving the Dust Bowl, PBS (accessed April 16, 2020), https://www.pbs.org/wgbh/americanexperience/features/dustbowl-great-depression/
[90] Obama: Financial Bill Means ‘No More… Bailouts, Period’, NPR (July 15, 2010), https://www.npr.org/sections/thetwo-way/2010/07/15/128549117/obama-financial-bill-means-no-more-bailouts-period
[91] Li Zhou and Ella Nilsen, “This one is scarier”: Obama-era officials say current economic crisis is fundamentally different from 2008, Vox (Mar. 30, 2020), https://www.vox.com/2020/3/30/21191352/coronavirus-economic-crisis-2008-obama-administration
