ATF Tax Reform Plan Matrix

	A	B	C	D	E	F	G	H	I	J
1	TAX ITEMS	Repeal/ Amend TCJA	BIDEN SCORE $ Billions	SOURCE	BREATHE ACT SCORE $ Billions	SOURCE	OTHER $ Billions	SOURCE	ATF POSITION

2
3	Individual Taxes
4	Wealth Tax: An annual tax on the net assets of the wealthiest households. Would apply to fortunes over $32 million, with a scale of rates beginning at 1% and topping out at 8% for wealth over $10 billion. (Sanders plan)				2,300	TPC
5	Equalize ordinary and capital gains rates at 39.6% for the top 1%. Tax unrealized capital gains via MTM, get rid of stepped-up basis and tax capital gains at death (Warren proposal)				2,000	Johnson, Stevenson and Zandi
6	Equalize ordinary and capital gains rates above the $1 million level. End stepped up basis and tax capital gains at death.		448	TPC
7	Reverse TCJA cuts, restoring the top rate on ordinary income to 39.6% above the $400,000 level OR have no minimum income level (set to expire for 2026)	Yes	143	TPC	128	JCT from Dem Infrastructure plan				BREATHE would not apply at 400k level
8	Estate Tax -- Restore 2015 parameters of $5.5 million at 40% (already set to return in 2026) OR enact Sanders-Gomez For the 99.8% Act	Yes	82	JCT	383	TPC		JCT score is old
9	Replace estate tax with inheritance tax, which would require people who inherit wealth to pay similar tax rates as people who work. Tax exemptions range from $1.25 to $2.1 million and tax surcharges range from 10% to 15%.						670	Batchelder/Kamin
10	Establish a 10% surtax on all AGI above $2 million for a married couple and $1 million for a single. (VanHollen-Beyer legislation, S. 2809 and H.R. 5043)				635	TPC
11	Cap the value of itemized deductions at 28%		306	TPC	306	TPC
12	Further limit the value of itemized deductions above the $400,000 level		70	TPC	70	TPC
13	Curb deferral of taxes on income from annuities and life insurance policies. Taxes investment income from these products like other investment income.				210	CBO		Current est. from 2013; CRFB est. $240B in 2017
14	Reduce limits on annual contributions to retirement plans. Applies to 401(k) and IRA limits affecting higherincome workers.				103	CBO		This is a 2018 estimate
15	Limit tax-favored retirement account balances of the wealthy. (CBO, Treasury Dept.)				30	Treasury		Can't find an update for this 2016 Treasury est. (p. 269)
16	Subtotal		1,049		6,165		670
17
18	BUSINESS TAXES
19	Phase out the 20% deduction for pass-through business income above the $400,000 level OR for all income levels (set to expire for 2026)	Yes	219	TPC	255	TPC
20	Eliminate tax breaks for the real estate industry, including "like-kind exchange," which would require capital gains taxes to be paid when an asset is sold for a profit, rather than exchanged with a similar asset to indefinitely delay paying taxes.		294	TPC	294	TPC		See what ATF report said about like kind exchange loophole -- put it under cap gains section
21	Close loopholes allowing some wealthy business owners to avoid taxes that fund healthcare programs. To support Medicare and the Affordable Care Act, apply a 3.8% Medicare tax to all business profits of high-income taxpayers and ensure owners of professional services businesses pay self-employment taxes.				236	CBO/JCT	This replaces Gingrich-Edwards -- Our Fair Taxes Now report says it will raise 163 (CBO) or 236 (Treasury/JCT JCX-15-16)
22	Tax carried interest as regular income.				14	CBO
23	Subtotal		513		799		0
24
25	CORPORATE TAXES
26	Increase rate to 28% (with an offshore tax penalty of 30.8% -- not part of TPC score) OR increase rate to 35%	Yes	1,300	TPC	2,100	TPC
27	Increase the GILTI rate on offshore profits to 21% (apply tax on a per country basis -- not part of TPC score) OR go to 35%	Yes	309	TPC	822	TPC
28	Increase BEAT rate on offshore profits to 17.5% and end Foreign Derived Intangible Income (FDII)	Yes			335	TPC
29	Impose a minimum 15% tax on corporate book income		166	TPC	NA
30	Reform how businesses account for advertising expenses. Requires businesses to write off half their advertising expenses over time, rather than deduct them all in the year incurred.				132	CBO		This is from Dec. 2018
31	Place a fee on liabilities of large financial institutions. Applies a 0.15% tax on uninsured liabilities of banks with at least $50 billion in assets.				103	CBO		From Dec. '18
32	End manipulation of inventory accounting. LIFO & LCM. End "Last-In, First-Out" (LIFO) & "Lower of Cost or Market" (LCM).				58	CBO		Dec. '18
33	Repeal tax breaks for fossil fuels.				10	CBO; JCT; Treasury Department		This is ATF mixture from 2018 &'16 sources; this 2019 CRS update only has single year estimates
34	Fully close bonus pay loophole not completely closed by TCJA. Prevents corporations from deducting cost of executive pay over $1 million.				20	JCT		This is our own estimate, based on 2017 figures; can't find newer est.
35	Close stock option loophole. Prevents corporations from lowering taxes by claiming higher costs for paying executives with stock options.				25	JCT		From 2012. ITEP found that Fortune 500 saved $10B in 2018 alone
36	Sunset of expensing provision earlier than 2022	Yes
37	Change in interest expense limitation from EBITDA to EBIT	Yes
38	Termination of the research and experimentation deduction provision expiring in DATE
39	Further limit deductibility of interest on business debt
40	Miscelaneous tax breaks and credits		14	TPC
41	Subtotal		1,789		3,605
42
43	OTHER
44	Financial Transactions Tax -- Schatz-DeFazio Wall Street Tax Act				777	JCT
45	Apply Social Security taxes to income above $400,000 OR above $250,000		962	TPC	1,400	TPC
46	Tax Gap / IRS Funding				35	CBO		Most recent IRS estimate (made in 2019 for tax years 2011-13) is an average annual tax gap of $381B
47	Charitable Conservation Easement Program Integrity Act S. 170/H.R. 1992) to limit abuses of the incentive for conservation easement donations. IRS found $9.2 billion in deductions in 2018 alone. (Daines-Thompson legislation)							Land Trust Alliance
48	Subtotal		962		1,435
49	TOTAL		4,313		12,004	0	670
50
51	CREDITS & DEDUCTIONS
52	Tax credits and deductions -- tax credits to facilitate caregiving, promote electric vehicles and energy-efficient residences, make the tax value of retirement-savings contributions more equal, encourage automatic IRAs for small businesses		-238	TPC
53	CTC
54	EITC -- CBPP to fill in
55	SUBTOTAL		-238
56
57	Source Documents
58	ATF fact sheet -- Biden’s tax plan
59	ATF list of TCJA items and other Fair Taxes Now report items
60	ATF Presidential candidates’ chart
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100