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Apply New York's rules for a filer who can be claimed as a dependent - #10090

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@MaxGhenis MaxGhenis commented Oct 11, 2026 •

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Summary

New York Tax Law 606, 616 and 1310 bar an individual whom another taxpayer can claim from several credits and from dependent exemptions; the model did not apply them consistently (the 2026 child and dependent care credit barred only a claimable filer labelled head; the rest were not applied). Form IT-201 asks once per return, at item C, "Can you be claimed as a dependent on another taxpayer's federal return?", and the household credit instructions say "If you marked the Yes box at item C ... you do not qualify". Some provisions instead work per spouse.

Stacked on the federal claimable-filer PR (whose CTC, child care and EITC changes flow into New York's 2021-2024 Empire State child credit, child care credit and EITC) and on #10024.

Formula Rule now Source
ny_household_credit_potential $0 when either filer can be claimed Tax Law 606(b); IT-201 line 40
nyc_household_credit Same Tax Law 1310(d); IT-201 line 48
nyc_school_tax_credit_fixed_amount(_eligible) Needs a filer who cannot be claimed; a joint return on which one spouse can be claimed gets the individual $63 Tax Law 606(ggg)(4-a); Form NYC-210 instructions: "credit amount of the eligible spouse"
nyc_school_tax_credit_rate_reduction_amount_eligible Needs a filer who cannot be claimed 606(ggg)(4-b); IT-201 line 69a
ny_real_property_tax_credit Needs a filer who cannot be claimed. On a return that cannot claim dependents, a dependent's age no longer reaches the elderly table 606(e)(7)(E); 606(e)(6)(C) covers "a qualified taxpayer and their spouse"; IT-214: "You could not be claimed as a dependent"
ny_exemptions (and its copies in the dependent exemption and working families tax credit reforms) No dependent exemptions when either filer can be claimed and the filing exception does not apply Tax Law 616(a) (a dependent for whom the taxpayer is entitled to an IRC 151(c) deduction); IRC 152(b)(1)
ny_allowable_college_tuition_expenses Leaves out a student who is claimed on another return (an actual-claim rule), and a return's dependents when a filer can be claimed and the filing exception does not apply 606(t)(2)(D); IT-272: "only the person who claims the student as a dependent"; 616(a) with IRC 152(b)(1) for the dependents
nyc_cdcc_age_restricted_expenses No under-4 dependents when either filer can be claimed and the filing exception does not apply NYC Admin Code 11-1706(e)(1): children "who are dependents of the taxpayer"
ny_inflation_refund_credit (2023 base year) $0 when either filer was claimed (an actual-claim rule) 606(qqq): recipients, including "taxpayers filing joint returns", "must not have been claimed as a dependent"
ny_cdcc (2026 credit under 606(c-2)) $0 when either filer can be claimed; before, only a claimable filer labelled head barred it 606(c-2), added by L.2026 ch. 59, Part A: the taxpayer "is not a dependent of another taxpayer"; a joint return's under-13 children also fail IRC 21(b)(1)(A) with 152(b)(1)
nyc_income_tax_elimination_credit_eligible (2025+) Not eligible when either filer can be claimed and the filing exception does not apply Tax Law 1310(h)(1)(A): a dependent for whom the taxpayer is allowed an IRC 151(c) deduction; 152(b)(1); IT-270-I p.1: "you claimed one or more dependents"

Readings for Max (queue via the US + core hub)

  1. Household credits on a joint return with one claimable spouse. This PR treats item C as marked when either spouse can be claimed ($0). Tax Law 606(b) lists married couples separately from the unmarried-individual exclusion, so an exemption-count reading ($60 state / $30 NYC in the test household) or a whole-household reading ($75 / $60) is also defensible.

  2. School tax rate reduction, one claimable spouse. Kept with the joint schedule; an either-spouse bar or halving are the alternatives. The fixed amount follows Form NYC-210's per-spouse rule.

  3. Real property tax credit, one claimable spouse. Kept (606(e)(6)(C)); an either-spouse bar from IT-214's single question is the alternative.

  4. 2026 child and dependent care credit, one claimable spouse. This PR bars the joint return (a joint return is one taxpayer). 606(c-2)(2)(B) defines its own qualifying individuals and includes an incapacitated spouse, so a per-spouse reading could let the spouse who cannot be claimed keep the credit for an incapacitated spouse. No 2026 IT-216 instructions exist yet to settle it.

  5. New York City child care credit, incapacitated child under 4 of a claimable filer. This PR reads NYC Admin Code 11-1706(e)(1)'s "dependents of the taxpayer" literally, so the child's expenses do not count ($0). Reading dependency through the incorporated IRC 21 definition, which keeps an incapacitated dependent, would count them ($288.75 in a household with $1,000 of expenses and a $385 state credit).

  6. College tuition on a joint return with one claimed spouse. This PR keeps the other spouse's own tuition ($6,000 of allowable expenses and a $240 credit in the test household), reading 606(t)(2)(D) per individual. Form IT-272 asks one dependency question for the return and stops there, which would give $0.

Which fact each rule reads

#10024 separates three facts. Own college tuition and the inflation refund read whether a filer is claimed. The household credits, school tax credits, real property tax credit and 2026 child and dependent care credit read whether a filer can be claimed. The rules that need dependents (dependent exemptions and both reforms, dependents' tuition, under-4 care expenses, the elimination credit's dependent test) read whether a filer can be claimed and the filing exception does not apply (Pub. 501).

Known limits of the inputs

  • Which return claims the student. IT-272 bars a student "claimed as a dependent on another person's New York State tax return". The model has no input for which return claims a person, so a claimed student is taken to be claimed on a New York return. A New York student claimed only on an out-of-state parent's federal return would keep the tuition credit or deduction ($6,000 of allowable expenses in the test household) and gets $0 here.

Invariants

  1. Swap invariance of every changed output under either head/spouse labelling.
  2. Monotonicity. Marking another filer as claimed never raises any changed output.
  3. Unchanged when no filer can be claimed or is claimed (a filer who can be claimed but is not claimed triggers the "can be claimed" rules).

Tests

  • YAML: variable-named cases for every changed formula. Each joint case with a claimable spouse appears under both head/spouse labellings, except the one filing-exception control for the real property tax credit. Run locally at edd12b8407: the changed YAML files and the test folders next to every changed variable (58 files): 542 passed, 0 failed.
  • Property test policyengine_us/tests/core/test_claimable_filer_ny_invariants.py for 2023, 2025 and 2026 (state-level outputs). Hypothesis batches check invariant 1; a seeded population and crafted couples with tuition (their own and a dependent student's) check 1 and 2. The New York City credits need a New York City household and, like the reforms, are covered by YAML only. Invariant 3 is checked by the microsimulation below, where no filer is claimed. 4 tests passed, 0 failed, in 36 s with a peak memory footprint of 1.8 GB (/usr/bin/time -l).

Hub microsimulation impact (current head)

A real microsimulation on the default dataset, main at the merge base 6989afda46 against this PR's head 38fb674e85, for 2025 and 2026. The runs went one at a time under the shared heavy-job lock. Sums are weighted.

Output 2025 change 2026 change 2025 records changed (weighted) 2026 records changed (weighted)
ny_income_tax +0 +0 0 (0) 0 (0)
ny_cdcc +0 +0 0 (0) 0 (0)
ny_real_property_tax_credit +0 +0 0 (0) 0 (0)
ny_eitc +0 +0 0 (0) 0 (0)
ny_household_credit +0 +0 0 (0) 0 (0)
state_income_tax +0 +0 0 (0) 0 (0)
income_tax +0 +0 0 (0) 0 (0)
household_net_income +0 +0 0 (0) 0 (0)
household_benefits +0 +0 0 (0) 0 (0)

Zero is expected on the default dataset. The PR's New York and New York City rules read the claimability variables (head_or_spouse_is_dependent_elsewhere and its relatives), which all trace to the input claimed_as_dependent_on_another_return. The default dataset (populace_us_2024.h5 at tag populace-us-2024-spm-20260909) doesn't carry that input, so it is false for every record. The 2025 PR-side run was paused and resumed by the host's load governor, and its runner logged exit 145 (a stop status). It had saved every measured variable before then, so the 2025 comparison is complete.

Comparison files are in fixes/10090-impact/ on the hub host.

Microsimulation impact

Real microsimulations on the default dataset (hf://datasets/policyengine/populace-us/populace_us_2024.h5@populace-us-2024-spm-20260909) for 2025 and 2026, compared record by record. In that dataset no person can be claimed as a dependent on another return (claimable_as_dependent_on_another_return is true for 0 of 166,321 people), so every rule gated on it is inactive there; the runs check that nothing else moves.

This stack's federal branch (35a2cbcbb9) against a local merge of the four state branches onto it (13d24ac157). Each state branch changes only its own state's variables, so the comparison is split by state.

  • 2025: no record changes in this PR's states.
  • 2026: no record changes in this PR's states.

Axiom parity

axiom: us-ny/statutes/TAX/606(b) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/1310(d) + us-ny/statutes/NYC/11-1706(b) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/606(ggg)(4-a) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/606(ggg)(4-b) + us-ny/policies/tax/it-201-instructions/nyc-school-tax-credit-rate-reduction queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/606(e) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/616 queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/606(t)(2)(D) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/606(qqq) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/NYC/11-1706(e)(1) + us-ny/policies/tax/it-216-instructions/nyc-child-dependent-care-credit queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/606(c-2) queued (NY1: TheAxiomFoundation/rulespec-us#1688) | us-ny/statutes/TAX/1310(h) queued (NY1: TheAxiomFoundation/rulespec-us#1688)

Every queued item is a pe-parity issue filed in TheAxiomFoundation/rulespec-us on 2026-10-12 (verbatim law, required outputs, review finding, companion tests).

🤖 Generated with Claude Code

Merge with main after #10087

Merged main at 03f4434e51918d38845733f4ef2925025dd57ad9. Conflicts in nm_medical_expense_credit.py, nm_medical_expense_credit.yaml, and ca_cdcc_relevant_expenses.yaml take main's reviewed versions because this PR left all three unchanged from its federal base. Removed the obsolete federal changelog fragments claimable-filer-federal.fixed.md and head-dependent-elsewhere-swap.fixed.md. The automatic merge keeps main's pre-2026 NY CDCC calculation alongside this PR's 2026 spouse claimability rule. The exact replay diff check passes: the diff against that main preserves this PR's original state changes.

A second merge brought in main at 6989afda4698d6c643f5dd0ef7ad19aff9f769b8; the head 38fb674e85 includes it. Its changes add Wyoming supplementation and update package version/changelog metadata; the dependency audit found no NY policy, helper, test, or tested-output dependency changes.

Validation: all 14 changed test files passed (182 YAML cases and 4 Python tests); the Python property file was rerun after the newer-main merge. make format and Ruff 0.15.5 format --check / check passed.

MaxGhenis and others added 26 commits October 8, 2026 11:03
The federal standard deduction and 17 state formulas read only whether the
tax-unit head is claimed elsewhere, so a joint return where one spouse can be
claimed was taxed differently depending on which spouse was labelled head.
Each formula now applies its jurisdiction's rule for that case (either spouse,
single filers only, per spouse, or only when every filer is claimed), using
two new label-independent helpers. Adds swap-pair YAML cases and a Hypothesis
property test.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
… barred

The New Mexico, Maine and Hawaii renters gates counted filers who are not
claimed elsewhere, so a tax unit with neither a head nor a spouse (252 in
the default dataset) looked like one whose every filer was claimed. A new
helper, every_filer_is_dependent_elsewhere, requires a claimed filer and no
unclaimed one.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
…ss EITC

- Hawaii's dependent standard deduction uses earned income net of the
  deductible part of self-employment tax, as the N-11 worksheet does.
- New Mexico's medical care credit needs a filer who is both 65 or older
  and not a dependent when a filer is a dependent elsewhere (NMSA 7-2-18.13).
- The federal EITC without a qualifying child requires that no filer can be
  claimed as a dependent (IRC 32(c)(1)(A)(ii)(III), Publication 596), so
  Missouri's working family credit no longer reaches such a couple.
- Hawaii's food/excise credit keeps minor children receiving public support
  (HRS 235-55.85(c)) on a joint return where one spouse can be claimed.
- Comments label the readings the law does not settle, and the property
  test covers the EITC and the food/excise exemption amount.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
… meaning

- The federal and Oregon dependent worksheets use earned income net of the
  deductible part of self-employment tax, as Hawaii's now does.
- Hawaii's food/excise minor-child count excludes children who can be
  claimed by another taxpayer and the filers themselves (Form N-311 line 3).
- claimed_as_dependent_on_another_return documents what it stands for: a
  §151 deduction for the person is allowable to another taxpayer, so a
  person whose would-be claimer files only for a refund is not one
  (Publications 501 and 596); rules on actually being claimed read it too.
- Hawaii's renters comment labels the mixed joint reading as an inference;
  the Hawaii dependent threshold cites HRS 235-2.4(a)(3) on its page.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
A filer who can be claimed on another return is treated as having no
dependents (IRC 152(b)(1); on a joint return either spouse counts) and has no
personal exemption (IRC 151(d)(2)); one who is claimed gets no education
credits (25A(g)(3)), student loan interest deduction (221(c)) or recovery
rebate (6428(d)(2), 6428A(d)(2), 6428B(c)(2)). The model read none of these.
Now the child tax credit and credit for other dependents, the under-13 child
and dependent care qualifying person, exemptions_count and its RI, DE, OH, OR,
WI, HI and NM readers, the recovery rebates, the education credits and the
student loan interest deduction apply them symmetrically for joint returns.
Georgia keeps its own counts; the HI, WI and Treasury exemption reforms
follow the corrected count.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Tax Law 606 and 1310 bar an individual whom another taxpayer can claim from
several credits the model gave anyway. Now:
- the NY and NYC household credits are zero when item C is marked, which a
  joint return does when either spouse can be claimed (IT-201 lines 40, 48);
- the NYC school tax credit fixed amount keeps the eligible spouse's
  individual amount on a joint return (Form NYC-210), and the rate reduction
  amount and the real property tax credit (606(e)(6)(C)) keep a spouse who
  cannot be claimed;
- NY dependent exemptions (616(a)), the NYC child care credit's dependents
  under 4, and the college tuition of a claimed student or of a return's
  dependents follow IRC 152(b)(1) and 606(t)(2)(D);
- the 2023-based inflation refund excludes a return with a claimed filer
  (606(qqq)).

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- Child and dependent care: childcare expenses do not count on a return with a
  claimable filer unless a child under 13 still qualifies (IRC 21(b)(2)(A)(ii)).
- Tuition and fees deduction: not allowed to a filer who can be claimed (IRC
  222(c)(3)), so the education credit bar no longer makes such a filer eligible.
- Recovery rebates: the Armed Forces exception waives the identification rule
  only, not the exclusion of a spouse who is another taxpayer's dependent.
- Georgia: the contributed refundable credit and SB 520 reforms count the same
  children as ga_ctc_potential through a new ga_ctc_eligible_child.
- Education credits and student loan interest read the claimed input directly,
  since IRC 25A(g)(3) and 221(c) turn on an actual claim.
- One reference per source document; quote IRC 24(h)(4)(A) exactly.
- Tests: mixed-recipient care, tuition deduction, military rebates, Georgia
  refund cap, and the swapped New Mexico rebate case; the property test now
  covers the state readers of the exemption count.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- NYC school tax fixed amount: reduce a joint return to the individual amount
  only when a spouse can be claimed (an abstract joint fixture with one person
  was reduced).
- Dependent exemption and working families tax credit reforms: keep the
  baseline's rule that a return with a claimable filer has no dependents.
- Inflation refund: reads the claimed input directly, since Tax Law 606(qqq)
  turns on an actual claim; college tuition documents that the claim is taken
  to be on a New York return.
- Quote Tax Law 606(b)(3)(B) accurately.
- Tests: tuition of a dependent on a return with a claimable filer, both
  reforms, and tuition cases in the property test.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
# Conflicts:
#	policyengine_us/tests/policy/baseline/gov/states/oh/tax/income/exemptions/personal/oh_personal_exemptions_eligible.yaml
#10024 now separates three facts: is claimed, can be claimed, and the would-be
claimant's filing exception.

- IRC 152(b)(1) gates (child tax credit, credit for other dependents, under-13
  care child and its expenses, dependents in exemptions_count, ARPA dependents,
  Ohio dependents, the Hawaii and Wisconsin reforms) read
  head_or_spouse_is_dependent_elsewhere_without_filing_exception, so a filer
  within the Publication 501 exception keeps their dependents.
- Own exemptions, recovery rebates and the tuition deduction read claimability.
- Education credits and student loan interest keep reading the claimed input.
- Tests: the filing exception and a filer who can be claimed but is not.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Dependent rules (exemptions and both reforms, dependents' tuition, under-4 care
expenses, the NYC elimination credit's dependent test) read the
claimable-and-not-within-the-filing-exception helper; the credits barred for an
individual who can be claimed read claimability; own tuition and the inflation
refund keep reading the claimed input.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
#10024's food/excise credit, Act 115 rebate and renters credit took claimable
filers off exemptions_count themselves. exemptions_count now leaves them out
(and, outside the filing exception, the return's dependents), so those credits
read it as it is; the filing-exception cases were one exemption short.

The renters credit also leaves out a dependent who can be claimed by another
taxpayer (Schedule X counts only people who cannot be), as the food/excise
credit already did.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- Education credits: a dependent student is not eligible on a return whose
  filer can be claimed outside the filing exception (IRC 25A(f)(1)(A)(iii),
  152(b)(1)); the filer's own eligibility still turns on an actual claim.
- Recovery rebates: no credit when every filer is a dependent of another
  taxpayer (IRC 6428B(a)); the CARES and CAA child prerequisite is a spouse
  with a valid SSN, whether or not that spouse is an eligible individual.
- Child and dependent care: cdcc_qualifying_childcare_expenses holds the
  expense rule, and the single-parent work requirement reform and California's
  expenses read it.
- References: Georgia HB 136 page 3; one entry per recovery rebate statute;
  quote IRC 24(h)(4)(A) exactly in the test comment.
- Tests: dependent students, the two rebate cases, the reform and California
  expenses, and the Hawaii, Wisconsin and Treasury reforms with a claimable
  filer under both labellings.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
…tier on a return without dependents

A return on which a filer can be claimed as a dependent (outside the claimant
filing exception) has no dependents, so an aged dependent no longer moves it to
the elderly table.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
- Education credits: is_barred_from_education_credits_by_dependency holds the
  claimed-filer and dependent-student rules; both eligibility formulas and the
  reconciliation SSN reform's Lifetime Learning Credit read it, so the reform
  no longer turns a barred student's tuition into that credit.
- Child and dependent care: childcare counts when any child under 18 is still a
  qualifying individual, so an incapacitated child aged 13 to 17 keeps it.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
Setting meets_eitc_identification_requirements on one person made it an input
for every person, so the other spouse lost their SSN too.

Co-Authored-By: Claude Opus 5.5 <noreply@anthropic.com>
@MaxGhenis

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Hand-off to the US + core hub

Pending (not mine to do):

Follow-ups: listed in #10087 under "Follow-ups"; the hub holds the regional state PRs stacked on the federal branch.

Session local_0143a3e8-4ab1-4492-8aab-9140b74e67e5 is closing; the hub owns this PR from here.

@MaxGhenis MaxGhenis closed this Oct 16, 2026
@MaxGhenis MaxGhenis reopened this Oct 16, 2026
@MaxGhenis
MaxGhenis marked this pull request as ready for review October 16, 2026 15:59
@MaxGhenis
MaxGhenis merged commit b3eb975 into main Oct 16, 2026
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US + core hub merge audit, us#10090 at 38fb674e85ce710c14f1474ebcc355de6dd27c79 (squash): Apply New York's rules for a filer who can be claimed as a dependent.

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