As was discussed at ACA’s webinar "Congress Can Pass Residence-Based Taxation and Here’s How", tax reform legislation may be passed under Senate Budget Reconciliation rules. If Budget Reconciliation rules are applied, Residence-Based Taxation (RBT) provisions would have to be revenue neutral, or RBT would be subject to a point of order by any Senator on the Senate Floor and therefore stripped from the bill. Ignoring numbers and thinking that they aren’t needed for adoption of RBT is foolhardy if you understand the legislative process. Marie Sapirie outlines how the Senate Reconciliation and the Byrd Rule function in the legislative process in an in-depth Tax Notes article, “How Senate Rules and Precedents Shape Tax Law”. Ms. Sapirie highlights how Senate Reconciliation can kill provisions of tax bills, a provision like RBT, if you don’t have good revenue numbers and support for the tax change.