UNIFIED FRAMEWORK

FOR FIXING
OUR BROKEN TAX CODE

SEPTEMBER 27, 2017

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 OVERVIEW

It is now time for all members of Congress Democrat, Republican

and Independent to support pro-American tax reform. Its time
for Congress to provide a level playing field for our workers, to bring
American companies back home, to attract new companies and businesses
to our country, and to put more money into the pockets of everyday
hardworking people.

President Donald J. Trump | Milwaukee Journal Sentinel | September 3, 2017

President Trump has laid out four principles for tax reform: First, make the tax code simple, fair
and easy to understand. Second, give American workers a pay raise by allowing them to keep more
of their hard-earned paychecks. Third, make America the jobs magnet of the world by leveling the
playing field for American businesses and workers. Finally, bring back trillions of dollars that are
currently kept offshore to reinvest in the American economy.

The Presidents four principles are consistent with the goals of both congressional tax-writing
committees, and are at the core of this framework for fixing Americas broken tax code.

Too many in our country are shut out of the dynamism of the U.S. economy, which has led to
the justifiable feeling that the system is rigged against hardworking Americans. With significant
and meaningful tax reform and relief, we will create a fairer system that levels the playing field
and extends economic opportunities to American workers, small businesses, and middle-income
families.

The Trump Administration and Congress will work together to produce tax reform that will put
America first.

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 GOALS

The Trump Administration, the House Committee on Ways and Means, and the Senate Committee
on Finance have developed a unified framework to achieve pro-American, fiscally-responsible
tax reform. This framework will deliver a 21st century tax code that is built for growth, supports
middle-class families, defends our workers, protects our jobs, and puts America first. It will deliver
fiscally responsible tax reform by broadening the tax base, closing loopholes and growing the
economy. It includes:

Tax relief for middle-class families.

The simplicity of postcard tax filing for the vast majority of Americans.

Tax relief for businesses, especially small businesses.

Ending incentives to ship jobs, capital, and tax revenue overseas.

Broadening the tax base and providing greater fairness for all Americans by closing
special interest tax breaks and loopholes.

This unified framework serves as a template for the tax-writing committees that will develop
legislation through a transparent and inclusive committee process. The committees will also
develop additional reforms to improve the efficiency and effectiveness of tax laws and to effectuate
the goals of the framework. The Chairmen welcome and encourage bipartisan support and
participation in the process.

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TAX RELIEF AND SIMPLIFICATION FOR AMERICAN FAMILIES
Over the last decade too many hard-working Americans have struggled to find good-paying jobs, make
ends meet, provide for their families and plan for their retirement. They are the focus of this framework.
Strengthening and growing the middle class, and keeping more money in their pockets, is how we build
a stronger America. By lowering the tax burden on the middle class, and creating a healthier economy,
we can give American families greater confidence and help them get ahead. At the same time, taxpayers
deserve a system that is simpler and fairer. Americas tax code should be working for, not against, middle-
class families.

ZERO TAX BRACKET

Under the framework, typical middle-class families will see less of their income subject to federal
income tax.

The framework simplifies the tax code and provides tax relief by roughly doubling the standard
deduction to:

$24,000 for married taxpayers filing jointly, and

$12,000 for single filers.

To simplify the tax rules, the additional standard deduction and personal exemptions for the taxpayer
and spouse are consolidated into this larger standard deduction. This change is fundamental to a
simpler, fairer system.

In combination, these changes simplify tax filing and effectively create a larger zero tax bracket by
eliminating taxes on the first $24,000 of income earned by a married couple and $12,000 earned by a
single individual.

INDIVIDUAL TAX RATE STRUCTURE

Under current law, taxable income is subject to seven tax brackets. The framework aims to consolidate
the current seven tax brackets into three brackets of 12%, 25% and 35%.

Typical families in the existing 10% bracket are expected to be better off under the framework due
to the larger standard deduction, larger child tax credit and additional tax relief that will be included
during the committee process.

An additional top rate may apply to the highest-income taxpayers to ensure that the reformed tax code
is at least as progressive as the existing tax code and does not shift the tax burden from high-income to
lower- and middle-income taxpayers.

The framework also envisions the use of a more accurate measure of inflation for purposes of indexing
the tax brackets and other tax parameters.

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 ENHANCED CHILD TAX CREDIT AND MIDDLE CLASS TAX RELIEF
To further simplify tax filing and provide tax relief for middle-income families, the framework
repeals the personal exemptions for dependents and significantly increases the Child Tax Credit.
The first $1,000 of the credit will be refundable as under current law.

In addition, the framework will increase the income levels at which the Child Tax Credit begins
to phase out. The modified income limits will make the credit available to more middle-income
families and eliminate the marriage penalty in the existing credit.

The framework also provides a non-refundable credit of $500 for non-child dependents to help
defray the cost of caring for other dependents.

Finally, the committees will work on additional measures to meaningfully reduce the tax burden on
the middle-class.

INDIVIDUAL ALTERNATIVE MINIMUM TAX (AMT)

The nonpartisan Joint Committee on Taxation (JCT) and the Internal Revenue Service (IRS)
Taxpayer Advocate have both recommended repealing the AMT because it no longer serves its
intended purpose and creates significant complexity. This framework substantially simplifies the
tax code by repealing the existing individual AMT, which requires taxpayers to do their taxes twice.

ITEMIZED DEDUCTIONS
In order to simplify the tax code, the framework eliminates most itemized deductions, but retains
tax incentives for home mortgage interest and charitable contributions. These tax benefits help
accomplish important goals that strengthen civil society, as opposed to dependence on government:
homeownership and charitable giving.

WORK, EDUCATION AND RETIREMENT

The framework retains tax benefits that encourage work, higher education and retirement
security. The committees are encouraged to simplify these benefits to improve their efficiency and
effectiveness. Tax reform will aim to maintain or raise retirement plan participation of workers and
the resources available for retirement.

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 OTHER PROVISIONS AFFECTING INDIVIDUALS
Numerous other exemptions, deductions and credits for individuals riddle the tax code. The
framework envisions the repeal of many of these provisions to make the system simpler and fairer
for all families and individuals, and allow for lower tax rates.

DEATH AND GENERATION-SKIPPING TRANSFER TAXES

The framework repeals the death tax and the generation-skipping transfer tax.

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COMPETITIVENESS AND GROWTH FOR ALL JOB CREATORS
Small businesses drive our economy and our communities, and they deserve a significant tax cut. This
framework creates a new tax structure for small businesses so they can better compete. Furthermore,
Americas outdated tax code has fallen behind the rest of the world costing U.S. workers both jobs
and higher wages. In response, the framework puts Americas corporate tax rate below the average of
other industrialized countries and promotes greater investment in American manufacturing.

TAX RATE STRUCTURE FOR SMALL BUSINESSES

The framework limits the maximum tax rate applied to the business income of small and family-
owned businesses conducted as sole proprietorships, partnerships and S corporations to
25%. The framework contemplates that the committees will adopt measures to prevent the
recharacterization of personal income into business income to prevent wealthy individuals from
avoiding the top personal tax rate.

TAX RATE STRUCTURE FOR CORPORATIONS

The framework reduces the corporate tax rate to 20% which is below the 22.5% average of the
industrialized world. In addition, it aims to eliminate the corporate AMT, as recommended by the
non-partisan JCT. The committees also may consider methods to reduce the double taxation of
corporate earnings.

EXPENSING OF CAPITAL INVESTMENTS

The framework allows businesses to immediately write off (or expense) the cost of new
investments in depreciable assets other than structures made after September 27, 2017, for at least
five years. This policy represents an unprecedented level of expensing with respect to the duration
and scope of eligible assets. The committees may continue to work to enhance unprecedented
expensing for business investments, especially to provide relief for small businesses.

INTEREST EXPENSE
The deduction for net interest expense incurred by C corporations will be partially limited. The
committees will consider the appropriate treatment of interest paid by non-corporate taxpayers.

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 OTHER BUSINESS DEDUCTIONS AND CREDITS
Because of the frameworks substantial rate reduction for all businesses, the current-law domestic
production (section 199) deduction will no longer be necessary. Domestic manufacturers will see
the lowest marginal rates in almost 80 years. In addition, numerous other special exclusions and
deductions will be repealed or restricted.

The framework explicitly preserves business credits in two areas where tax incentives have proven
to be effective in promoting policy goals important in the American economy: research and
development (R&D) and low-income housing. While the framework envisions repeal of other
business credits, the committees may decide to retain some other business credits to the extent
budgetary limitations allow.

TAX RULES AFFECTING SPECIFIC INDUSTRIES
Special tax regimes exist to govern the tax treatment of certain industries and sectors. The
framework will modernize these rules to ensure that the tax code better reflects economic reality
and that such rules provide little opportunity for tax avoidance.

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THE AMERICAN MODEL FOR GLOBAL COMPETITIVENESS
The framework puts America on a level international playing field and puts an end to the
incentives for shipping jobs overseas.

TERRITORIAL TAXATION OF GLOBAL AMERICAN COMPANIES

The framework transforms our existing offshoring model to an American model. It ends the
perverse incentive to keep foreign profits offshore by exempting them when they are repatriated
to the United States. It will replace the existing, outdated worldwide tax system with a 100%
exemption for dividends from foreign subsidiaries (in which the U.S. parent owns at least a 10%
stake).

To transition to this new system, the framework treats foreign earnings that have accumulated
overseas under the old system as repatriated. Accumulated foreign earnings held in illiquid assets
will be subject to a lower tax rate than foreign earnings held in cash or cash equivalents. Payment
of the tax liability will be spread out over several years.

STOPPING CORPORATIONS FROM SHIPPING JOBS AND CAPITAL OVERSEAS

To prevent companies from shifting profits to tax havens, the framework includes rules to protect
the U.S. tax base by taxing at a reduced rate and on a global basis the foreign profits of U.S.
multinational corporations. The committees will incorporate rules to level the playing field between
U.S.-headquartered parent companies and foreign-headquartered parent companies.