<table><tr><th>From:</th><th>Erika Kellerhals</th></tr><tr><td>Sent:</td><td>Saturday, December 16, 2017 12:48 AM</td></tr><tr><td>To:</td><td>jeffrey E.</td></tr><tr><td>Cc:</td><td>Richard Kahn</td></tr><tr><td>Subject:</td><td>Re:</td></tr></table>

Here's the explanation we go from C=apo's tax guy

The conference report language is now posted o= the House Rules Committee website. Tony may have already told you gu=s, since he was in the conference, but we found out from Team Hatch as the c=nference wrapped up that our USVI provisions had to be dropped out. T=ny may more insight but apparently JCT ultimately determined that the langu=ge as written would also apply to Puerto Rico, leading to a revised score o= $3.9 billion, which was more than they could accommodate in the bill. = When they tried to find a way to adjust the language to only apply to the V=, they found it couldn't be done without it being considered an ine=igible tax earmark. I'm still waiting for more details about h=w and why JCT ended up with this new interpretation. But sadly it app=ars after all our efforts we are now back to the drawing board.

<=>r>

Erika A. Kellerhals

Member

=div>Kellerhals Ferguson Kroblin PLLC

## 9053 Es=ate Thomas, Suite 101

St. Thomas VI 00802

Office
Cell:

On Dec 15, 2017, at 8:26 PM, jeffrey E. <1eevacation@gmail.com> wrote:

=blockquote type="cite">

sourcing rules taken o=t in conference.

= please note

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