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November 15, 2016
2016-1955

EY compares Trump tax positions with House Republican Blueprint

Given the post-election focus on the potential for tax reform, EY has prepared a side-by-side comparison of the tax positions taken by President Donald Trump and the House Republican Blueprint for Tax Reform, which was released in June 2016 by House Speaker Paul Ryan (R-WI) and House Ways and Means Committee Chair Kevin Brady (R-TX). For details, see the chart below.

Side-by-side, Trump tax positions and House Republican Blueprint

 

Trump

House GOP

Top corporate tax rate (now 35%)

15%, corporate AMT eliminated

20%, corporate AMT eliminated

Top pass-through rate (now 39.6%)

15% rate within the personal income tax system for pass-through entities that want to retain profits within the business

25%

Taxation of future foreign earnings

In September 2015, proposed immediate worldwide taxation, repeal of deferral; unclear if he still supports

- Territorial, 100% exemption for dividends paid from foreign subsidiaries

- Border tax adjustment mechanism

Mandatory tax, untaxed accumulated foreign earnings

10%

8.75% for cash/cash equivalents, 3.5% otherwise, payable over 8 years

Cost recovery

Expensing for manufacturers

100% expensing of tangible, intangible assets

Interest

Manufacturers electing to expense capital investment lose the deductibility of corporate interest expense

No current deduction will be allowed for net interest expense

Other business provisions

Calls for them to generally be eliminated, except for research credit

Calls for them to generally be eliminated, except for research credit and LIFO

Individual rates (now 10%, 15%, 25%, 28%, 33%, 35%, 39.6%)

12%, 25%, 33%

12%, 25%, 33%

Capital gains

-Existing capital gains rate structure (maximum rate of 20%)

-3.8% Net Investment Income Tax (NIIT) repealed

50% deduction for capital gains, dividends, and interest, leading to basic rates of 6%, 12.5%, and 16.5%

Dividends

Existing rates but NIIT repealed

Carried interest

Ordinary income

(Not addressed)

Estate tax (now 40% rate, $5.45 million exemption)

Repealed, but capital gains held until death will be subject to tax, with the first $10 million tax-free

Repealed

State tax deduction

Cap itemized deductions at $100,000 for single filers and $200,000 for couples

Eliminated

Charitable contribution deduction

Retained, but could be modified

Mortgage Interest deduction

Retained, but could be modified

Dependent care expenses

- Deduction for care expenses, up to 4 children, elderly dependents, capped at the average cost of care for state of residence

- Available to those earning $250,000 per year or less for individuals, $500,000 couples

- Child credit and personal exemptions for dependents consolidated into an increased child credit of $1,500

- First $1,000 will be refundable as under current law

- Non-refundable credit of $500 also will be allowed for non-child dependents

Personal Exemption Phase-out (PEP), and Pease limitation on itemized deductions (now apply for families with income over $311,300, individuals over $259,400)

Unspecified "steepening the curve" of PEP and Pease

(Not addressed)

Personal AMT

Eliminated

Eliminated

Life insurance build-up

Included in income for high earners

(Not addressed)

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ATTACHMENT

Tax Reform Proposals