The law must also permit the alleged exemption or exclusion. Windsor sought to claim the federal estate tax exemption for surviving spouses. Jurisdictions may enter into agreements with other jurisdictions that provide for reciprocal tax exemption. Prior to 2018, individuals were allowed a special deduction called a personal exemption for dependents. Multi-jurisdictional agreements for tax exemption also exist. The plan is to increase taxation on large organizations by reducing tax evasion/exemption. Increases in the age exemption and dependant relative's income limits benefited the low-income elderly. There are several different approaches used in granting exemption to organizations. The law disallowed religious and philosophical reasons for exemption from vaccination. The Constitution provides considerable potential for cutting down the range of permissible exemption clauses, however. A9 relate to community employment schemes and employer's PRSI exemption schemes. On February 17, 2017, Cyborg was granted a retroactive therapeutic use exemption (TUE). There are two exceptions to this exemption, however. In Australia there is no specific constitutional exemption. Most beneficiaries of this exemption are Haredi Jews.