Broadening the Tax Base

Proposed legislation: Tax Fairness and Base Broadening Act of 2025.pdf (PDF)

Broadening the Tax Base: Cost-Benefit Analysis of Proposed Reforms

The proposal seeks to broaden the U.S. federal tax base through a suite of measures: a new carbon dividend (carbon tax with rebate), a financial transaction tax (FTT), and closing loopholes for carried interest, offshore income, and unrealized capital gains. Additionally, it calls for narrowing the $540+ billion annual tax gap via enhanced enforcement and technology. This analysis examines the fiscal impacts over a 5–15 year horizon, including projected net revenue gains, administrative costs, and enforcement efficiency. It also compares these measures to maintaining the status quo or using non-tax alternatives (like borrowing or spending cuts), and draws on international case studies (e.g. EU’s FTT, Canada’s carbon dividend, OECD transparency efforts) for context. The goal is to provide policymakers a detailed cost-benefit perspective, using real-dollar estimates and structured comparisons to baseline scenarios.

Projected Revenue Gains from Proposed Measures

Carbon Dividend (Carbon Tax) – Implementing a federal carbon tax with proceeds rebated to citizens (“carbon dividend”) could significantly broaden the tax base and raise substantial gross revenue. For example, the Congressional Budget Office (CBO) analyzed a $25 per ton CO₂ tax (rising 5% above inflation annually): it would generate about $865 billion over 10 years (2023–2032), net of interactions with other taxes. Even a smaller or slower-ramping carbon tax yields hundreds of billions (e.g. ~$770 billion over 10 years if rising 2% plus inflation).These figures represent gross revenue that would be collected; under a carbon dividend design, most of this money is returned to households as rebates. Canada’s federal carbon pricing regime, for instance, rebates ~90% of carbon tax revenues to households to offset higher energy costs. In Canada’s case, the policy has been nearly revenue-neutral for the government (funds flow back to citizens), yet it still contributes to emissions reductions and most households (around 80%) come out net-positive after the rebate.For the U.S., a similar approach could return money to taxpayers while still leveraging the behavioral benefits of a carbon tax (pricing carbon externalities). Net fiscal impact: If 100% of revenues are rebated, the direct deficit reduction is zero; however, policymakers could opt to retain a portion of the revenue for deficit reduction or other programs. Even with full dividends, there are indirect fiscal benefits: lower climate-related damages long-term (which can affect the budget) and potentially avoiding costlier regulation. In sum, a carbon tax/dividend would broaden the tax base (new revenue stream from emissions) and could gross tens of billions per year, but its net contribution to the treasury depends on the rebate structure. Administrative costs for a carbon tax are moderate – it can piggyback on existing fuel excise tax collection systems – and Canada’s experience shows it’s feasible to implement nationally. The cost-benefit tradeoff also includes environmental gains: by 2032, U.S. energy-related emissions might be ~11% lower than under current policy with a moderate carbon tax, reducing future economic damage from climate change, an important ancillary benefit beyond fiscal metrics.

Financial Transaction Tax (FTT) – A small tax on trades of stocks, bonds, or derivatives would tap into a very broad base of financial activity. According to Joint Committee on Taxation (JCT) and CBO estimates, a 0.1% FTT on all securities could raise roughly $777 billion over 10 years. That equates to about $75–80 billion per year in federal revenue – a sizable new source.The revenue yield, however, is sensitive to market reactions: if trading volumes significantly decline or migrate to untaxed venues, actual revenues could be lower. Experiences abroad show mixed results. For instance, the United Kingdom’s stamp duty on stock trades (0.5%) has existed for decades and reliably raised on the order of £3–5 billion annually (around 0.3–0.4% of GDP in strong market years). France and Italy implemented narrower FTTs (on stock purchases of large companies) which raise more modest amounts (e.g. France’s 0.3% FTT brings in on the order of a few billion euros per year). The EU as a whole has debated an FTT to avoid intra-Europe trading shifts, with an agreement among some countries to implement a harmonized FTT, though full EU-wide adoption has faced hurdles. Cost-benefit considerations: An FTT would directly raise revenue primarily from financial market participants – effectively a very progressive source (since wealthy investors and institutions conduct the most trading). It could also dampen excessively high-frequency trading, potentially reducing volatility. On the cost side, critics argue it may widen bid-ask spreads and raise the cost of capital marginally, and if set too high, could push trading offshore. However, by setting the rate low (e.g. 0.1% or less) and designing it broadly (to minimize easy avoidance), these downsides can be mitigated. The administrative cost of collecting an FTT is relatively low because it can be integrated into clearing and settlement systems (modern technology makes automatic collection feasible.). In sum, an FTT offers a large fiscal upside (~$700+ billion/decade) with a mostly manageable impact on markets if coordinated and kept at a low rate, as evidenced by the UK and other countries’ long-running transaction taxes.

Carried Interest Loophole – Currently, private equity and hedge fund managers often treat their performance fees (“carried interest”) as long-term capital gains, taxed at about 20%, rather than as ordinary income taxed up to 37%. Closing this loophole (i.e. taxing carried interest as regular income) would raise only a small amount of revenue relative to other proposals – roughly $13–14 billion over 10 years per CBO estimates. That’s on the order of $1–2 billion per year, because the universe of affected taxpayers is small (albeit very wealthy) and the volume of carried interest income is limited. While modest in fiscal terms (just a few hundredths of a percent of federal revenue), closing this loophole is often justified on grounds of fairness: it would equalize tax rates between fund managers’ income and wages/salaries earned by other workers The administrative cost and complexity of this reform are minimal – it’s a simple change in tax treatment. Benefit-cost summary: Net revenue gain of ~$1.3B/year, virtually no implementation cost, and an improvement in tax equity (eliminating a tax preference that primarily benefits ultra-high-income individuals). The effect on investment levels or the economy would likely be negligible (as the capital backing private equity funds already seeks high returns and the fee tax change is a second-order consideration). Most advanced economies do not give such generous treatment to fund managers; ending it would align the U.S. more with international norms on capital income taxation. Overall, this is a low-hanging fruit policy: politically symbolic and equitable, albeit fiscally minor.

Offshore Corporate Income and Tax Havens – Multinational companies often shift profits to low-tax jurisdictions, eroding the U.S. tax base. The proposal to end loopholes for offshore income includes measures like raising the global minimum tax on U.S. multinationals’ foreign earnings, eliminating the tax exemption for the first 10% return on tangible assets abroad, and tightening rules so profits are taxed per country rather than blended, among others. The potential revenue impact is very large. Senate legislation scored by JCT indicates that stopping the use of offshore tax havens by corporations could raise over $1 trillion in revenue over 10 years.. This figure likely assumes a combination of reforms – for example, increasing the tax rate on global intangible low-tax income (GILTI) to 21% (from the current ~10.5%), aligning with the new OECD-led 15% global minimum tax, and closing gaps that allow profit shifting. President Biden’s recent budget proposals in this area illustrate the magnitude: strengthening global minimum tax rules was projected to raise about $374 billion/decade, adopting a worldwide “undertaxed profits” rule another $136 billion and repealing the 10% tangible asset exemption (part of the 2017 law) would add more. Cumulatively, international reform efforts could easily top half a trillion over 10 years, and aggressive crackdowns approach $1T when combined with a higher corporate rate. International context: The OECD’s Base Erosion and Profit Shifting (BEPS) initiative and the 2021 global agreement on a 15% minimum corporate tax indicate broad support for curbing profit shifting. Many U.S. allies (UK, EU members, etc.) are implementing the global minimum tax in 2024–2025, which means U.S. multinationals will face those taxes even if the U.S. doesn’t act – so it makes sense for the U.S. to collect that revenue instead of foreign governments. The benefit of closing offshore loopholes is not only the direct revenue gained, but also improved competitiveness and fairness for purely domestic companies (who currently may be at a tax disadvantage). Costs/implementation: Corporations may argue higher taxes reduce investment, but by coordinating globally, the playing field is leveled and the impact on investment locations is minimized. The administrative effort involves complex international tax rules, but the IRS already administers GILTI; reforms would build on existing mechanisms. Moreover, tax transparency improvements globally make enforcement easier: under the OECD’s Common Reporting Standard, tax authorities now automatically exchange information on millions of accounts – in 2022, information on 123 million financial accounts (worth €12 trillion) was shared among countries. This data trove helps identify offshore earnings and assets. Already, over €114 billion in additional tax revenue worldwide has been recovered through voluntary disclosures and audits spurred by these transparency initiatives. In summary, cracking down on offshore tax avoidance offers one of the highest fiscal upsides of any proposal (hundreds of billions to ~$1T over a decade), with growing international momentum to back it and modern data tools to enforce it. The trade-off is tighter rules for multinationals – effectively asking them to pay closer to the full 21% U.S. rate on their global profits, which many major companies can clearly afford given record profits and the modest effective rates many paid under prior law (often under 10–15%).

Unrealized Capital Gains (“Billionaires’ Tax” and Step-Up Basis) – Perhaps the most novel (and challenging) piece is taxing unrealized capital gains, which addresses the fact that the ultra-wealthy can accrue vast wealth growth without ever “realizing” income for tax purposes. Two approaches are often discussed: (1) End stepped-up basis at death, so that unrealized gains are taxed when assets transfer to heirs; (2) Annual wealth tax or minimum income tax on unrealized gains for extremely rich households. The proposal generally aims to end the “loophole” that currently allows untaxed gains to escape taxation entirely if held until death. The revenue potential is significant. CBO analysis shows that simply taxing capital gains at death (rather than forgiving the tax via step-up) could raise on the order of $500+ billion over 10 years (if applied broadly). Even a more limited reform – carryover basis (heirs pay gain when they sell) – was estimated at about $110 billion/decade, while taxing gains at death immediately could be around $200 billion/decade by some estimates assuming exemptions for small estates. President Biden’s “Billionaire Minimum Income Tax” proposal is instructive: it would require households worth over $100 million to pay at least 25% tax on their total income, including unrealized gains. This was projected to raise about $503 billion over 10 years, targeting only the top 0.01% of wealth holders. In effect, that policy is a periodic tax on unrealized gains (with deferral and smoothing mechanisms) for the richest Americans. These numbers indicate that taxing unrealized gains (whether at death or periodically for the ultra-rich) could yield hundreds of billions in the medium term – roughly $30–50 billion per year once fully implemented. Qualitative benefits: This would close a major tax avoidance strategy used by billionaires – “buy, borrow, die” – wherein they never sell assets but borrow against them, then pass them to heirs tax-free. It would also enhance fairness, ensuring the very wealthy pay tax on income that currently goes untaxed, thereby reducing inequality. Administrative and economic challenges: Implementing a tax on unrealized gains is the most complex of the proposals. It requires annual or at-death valuation of assets, which can be hard for illiquid assets like private businesses or real estate. However, mechanisms exist (e.g. allowing payment of tax over several years for illiquid assets, or deferring tax until actual sale with an interest charge, etc.). Countries like Canada tax capital gains at death (with some exceptions), and many OECD countries have inheritance or wealth taxes, indicating it’s feasible to tax large accumulations of wealth. The U.S. already has an estate tax (though with a high exemption); taxing unrealized gains at death could piggyback on estate tax administration. Care would be needed to prevent double taxation by crediting any estate tax paid. Economically, a moderate tax on unrealized gains for the super-rich is unlikely to deter productive investment – those individuals would remain enormously wealthy post-tax. It may, however, discourage locking wealth in low-basis assets purely for tax reasons and could unlock more economic activity (the current step-up rule encourages holding assets until death rather than selling or reinvesting). In summary, ending the unrealized gains loophole could raise on the order of $300–500 billion/decade depending on design, improving tax justice at the cost of added complexity in the tax code. Policymakers would need to invest in valuation expertise and perhaps phasing rules, but the payoff is substantial revenue from those most able to contribute.

Closing the Tax Gap (Enforcement) – The “tax gap” – the difference between taxes owed under the law and taxes actually paid – is estimated at around $540 billion per year gross (2017–2019 average), or about $470 billion/year net after late payments and enforcement. Closing this gap (even partially) represents a major fiscal opportunity. The proposal envisions using advanced enforcement and technology to recoup unpaid taxes. Recent U.S. policy moves provide insight: The Inflation Reduction Act of 2022 invested roughly $80 billion in the IRS over 10 years to bolster enforcement, technology, and taxpayer services. The CBO estimated this would yield about $200 billion in additional revenue over a decade– a net deficit reduction around $120 billion after the cost of investment. That implies an average ROI of 2.5:1 for the marginal enforcement dollars. Treasury and the White House anticipated even higher returns (up to $400 billion net over a decade), but CBO was more conservative Importantly, those estimates account for diminishing returns – initial audits yield high ROI (the IRS historically brings in about $7-$9 per $1 on enforcement on average), but scaling up requires hiring and training agents, upgrading IT, and may be less efficient at the margins. The proposal’s aspiration to close the $540B annual gap entirely is ambitious; in practice, no country collects 100% of taxes owed. However, even shrinking the gap by 10-20% would yield huge revenue – on the order of $50–100 billion per year in sustained collections. With advanced data analytics, AI, and better information reporting, these gains are plausible. For example, a Stanford study finds that auditing complex partnerships (a known tax avoidance vehicle) can return $20 for every $1 spent – far higher than typical enforcement ROI Targeting such high-noncompliance areas (like pass-through businesses, offshore evasion, cryptocurrency transactions, etc.) using modern technology could significantly boost effective collections. The cost side of enforcement is the budget for the IRS (hiring skilled auditors, improving IT systems for cross-checking data, etc.) and potential increased compliance burden on taxpayers. The proposal’s focus on technology suggests using data matching, machine learning, and better information flows to spot evasion with less need for brute-force audits. Expanded third-party reporting (for instance, banks reporting aggregate account flows, or cryptocurrency exchanges reporting transactions) can automate compliance. Internationally, OECD tax transparency efforts (like automatic bank account info exchange) have made it much harder to hide income – as noted, tax authorities exchanged info on accounts worth €12 trillion in 2022, leading to voluntary disclosures that brought in over €100 billion in back taxes and penalties globally. The U.S. benefits from some of these efforts (via FATCA and bilateral agreements) and could benefit more by joining broader data-sharing. In sum, closing the tax gap is one of the most cost-effective fiscal measures: it raises revenue without raising tax rates, simply by enforcing existing laws. A well-resourced, modernized IRS would improve collection and also enhance fairness (honest taxpayers won’t feel like evaders are getting a free ride). The main caveat is that enforcement must respect privacy and avoid overly harsh tactics on small taxpayers; the emphasis should be on big-dollar evasion and high-tech solutions. With tens of billions at stake annually, the net benefit is clearly positive. For perspective, the CBO projects that over 2025–2035, net interest on the national debt will total $13.8 trillion; recouping even a quarter of the annual tax gap over the next decade (say $1.3 trillion total) would cover a tenth of that interest burden – a meaningful dent achieved just by improving efficiency.

Administrative and Implementation Considerations

Implementing this comprehensive tax-base-broadening agenda would entail upfront administrative efforts, but each component is grounded in precedent either domestically or internationally:

International Case Studies and Comparisons

Each element of this proposal has analogues or lessons from abroad:

In aggregate, international comparisons confirm that broadening the tax base through these kinds of measures is not radical – many peer nations already tax carbon, financial trades, carried interest (often just as ordinary income), global corporate profits, and large fortunes in ways the U.S. does not. The U.S. has room to expand its base while still keeping rates competitive and following best practices demonstrated elsewhere.

Fiscal Impact vs. Status Quo and Alternatives

Relative to the status quo baseline, this package of tax base broadening would markedly improve the U.S. fiscal outlook over the next decade and beyond. Under current law, the CBO projects deficits from 2025–2034 to total $21.1 trillion, with annual deficits rising toward 7% of GDP – a trajectory that pushes debt and interest costs to unprecedented highs. Simply put, maintaining the status quo means continued heavy borrowing, which comes at increasing cost: net interest on the national debt is on pace to reach about $1.8 trillion per year by 2035 (over 4% of GDP), crowding out other priorities. The proposed tax measures would generate substantial new revenues to offset these deficits:

In summary, compared to the baseline of rising deficits, high debt, and minimal changes, this broadening-the-base agenda offers a fiscally responsible path that raises significant revenue, improves tax system efficiency and fairness, and produces co-benefits (climate mitigation, financial stability, reduced inequality). The costs – whether administrative investments or potential economic side effects – appear manageable and are far outweighed by the benefits in revenue and public good.

Conclusion

Over a 5–15 year horizon, implementing a carbon dividend, financial transaction tax, closing major tax loopholes, and enhancing IRS enforcement could together yield multi-trillion-dollar deficit reduction while modernizing the tax code for fairness and efficiency. The net revenue gains are substantial: roughly $300+ billion per year within a decade when fully phased in, according to various independent estimates. These funds could be used to lower federal debt growth or finance critical investments, reducing reliance on borrowing. Administrative costs – such as IRS upgrades (~$80B) or new systems for carbon dividends – are relatively small in context and themselves have high returns (e.g. enforcement paying for itself several times over). Enforcement efficiency would be dramatically improved, as demonstrated by international tax transparency efforts that have made hiding income increasingly difficult.

From a cost-benefit standpoint, the proposed tax base broadening offers a compelling value proposition. It taps into activities that either have negative externalities (pollution, speculative trading) or where the equity case for taxation is strong (large inheritances, billionaire wealth accrual, multinational profits), thus improving the overall efficiency of the tax system. It also brings U.S. policy more in line with other advanced nations’ practices, leveraging lessons learned abroad to minimize downsides. While no revenue measure is without economic impact, these largely avoid burdening working- and middle-class Americans – in fact, the carbon dividend and the curbing of tax evasion would directly or indirectly benefit typical households (through dividend checks and a fairer tax burden distribution).

Compared to the status quo baseline – persistent deficits addressed by more debt – this approach is far more sustainable. And compared to non-tax alternatives like sweeping spending cuts, it is more equitable and likely more politically palatable, since it asks those who can most afford it (wealthy individuals, large corporations) and those whose activities impose costs on society (polluters, high-frequency traders) to contribute more. In a time when interest costs are consuming a growing share of the budget, broadening the tax base is a prudent strategy to raise needed revenue with minimal sacrifice of economic growth or essential services. Indeed, by reducing deficits, it can alleviate pressure on interest rates and inflation, yielding macroeconomic benefits.

For policymakers, the key will be in the design and implementation: calibrating the carbon tax rate and rebates, setting the FTT low enough to preserve market liquidity, coordinating internationally on corporate tax rules, and giving the IRS the support to enforce laws justly. If done well, the U.S. could see, over the next 5–15 years, a significant fiscal turnaround – a lower debt-to-GDP path than baseline, more resources for public investments, and a tax system that better reflects our economic realities and values. The cost-benefit calculus strongly favors this suite of reforms: the costs are manageable and largely one-time, while the benefits (both fiscal and societal) compound over time, helping ensure long-term economic prosperity and stability.

Sources: The analysis draws on estimates from the Congressional Budget Office, Joint Committee on Taxation, and Treasury (for revenue projections), as well as case studies from OECD and various countries illustrating the impacts of similar tax measures. These sources provide a quantitative foundation for the revenue and cost figures cited throughout. The comparisons to baseline fiscal projections reference CBO’s Budget Outlook and related analyses. Each component of the proposal is grounded in real-world data, underlining the credibility of the projected net gains.

← Back to The Great Reinvention