Summary: At 9AM this morning, the White House released a set of revenue options for budget reconciliation that the White House estimated to total $1,995 billion over 10 years (available here). PWBM's estimate of the same package is $1,527 billion, a difference of $468 billion.
| Provision | White House Revenue Estimate | PWBM Revenue Estimate | PWBM Notes |
|---|---|---|---|
| 15% percent minimum tax on book income | 325 | 195 | $1 billion threshold. NOLs, FTCs, GBCs allowed. |
| 1% excise tax on share repurchases | 125 | 50 | Mergers and acquisitions are excluded similar to recent legislative language. |
| Modifications to GILTI | 350 | 252* | Country-by-country GILTI at rate of 15% to 18.8%, effective 2024. BEAT on undertaxed payments. |
| New surcharge on AGI | 230 | 265 | 5% bracket above $10M, 8% bracket above $25M. |
| NIIT tax base harmonization above $400K | 250 | 225 | |
| Extension of excess noncorporate losses limitation | 170 | 175 | |
| Increase IRS funding by $80B over the next ten years | 400 | 190 | Adding $600 threshold bank reporting requirement, as described in the FY2022 budget, would increase estimate by roughly $300B. |
| "Rebate rule" repeal | 145 | 175 | Estimate will be lower if the rule is delayed separately in the BIF bill. |
| Total | 1,995 | 1,527 | Refinement of interactions will change total |
Source: Penn Wharton Budget Model
Note: estimates are preliminary and are subject to revision upon further policy details and legislative language.
* Updated 10/28/2021 at 2pm to include modifications to the Base Erosion and Anti-Abuse Tax (BEAT).