The American Tax Plan: Public Companion

Public companion v0.1 — Working edition

Public-Facing Toolkit

Document version: v0.1

Document type: Companion to American Tax Plan v1.1 — public-facing toolkit

Purpose: Give readers an entry point at any level of engagement, a tool they can apply to provisions outside this plan, a demonstration of the tool in operation, a fast triage form for everyday use, and visibility into the framework's epistemic structure.

How to Use This Packet

• Use the one-page public brief to introduce the framework to a general reader.
• Use the glossary to clarify the framework's working vocabulary.
• Use the public evaluation tool to apply the framework's standards to any tax provision — including provisions outside this plan.
• Use the worked example to learn the public tool by watching it work end-to-end.
• Use the scenario card template for fast structured response when a full evaluation is more apparatus than the situation requires.
• Use the claim-source matrix to verify what the framework claims, what is sourced, and what is not yet supported.
• Use the Claims Not Carried Forward section to see what earlier versions claimed and the current framework will not stand behind.

Packet Contents

1. One-Page Public Brief
2. Glossary
3. How to Evaluate a Tax Provision (the public tool)
4. Worked Example: State-Level Annual Wealth Taxes
5. Scenario Card Template
6. Claim-Source Matrix v0.1
7. Claims Not Carried Forward

1. One-Page Public Brief

The American Tax Plan: A Public-Return Framework

A tax system should not be judged only by what it declares about fairness. It should be judged by whether it actually distributes responsibility according to real economic power — and whether the revenue it raises is visibly returned to the conditions that make ordinary life possible.

By that test, the current system is failing.

Work is taxed reliably. Wages are reported, withheld, and matched against the law. Workers meet the tax system every paycheck. But concentrated wealth is taxed differently. Gains can be deferred until sale. Assets can be borrowed against without triggering tax. Inheritance often passes without paying income tax on lifetime appreciation. Large corporations report profits to shareholders while reducing actual federal tax through deductions, credits, and international structuring. The result is a system that taxes work more honestly than it taxes wealth.

This plan is built on a different premise: tax responsibility should follow real economic power, and public revenue should visibly return to the conditions that hold ordinary life together.

It rests on four commitments.

Protect work. Ordinary workers should not face new direct tax increases under this plan. The first layer of income needed for basic life should be protected. The EITC and worker credits should be simplified and strengthened. Filing should be free and accessible. Audit pressure should fall on high-dollar avoidance, not low-income filers.

Tax wealth honestly. At high income levels, the tax code should not privilege ownership income over labor income. Capital gains and dividends above $1 million in annual income should be taxed at ordinary rates. Extreme unrealized wealth above $100 million should face a minimum income tax that includes appreciation, with valuation rules and hardship protections. Inherited gains should not escape income taxation entirely through the step-up basis. Family farms, ranches, small businesses, primary homes, and tribal assets must be protected from forced sale.

Make corporations return value to the public systems they use. Corporate profit depends on public infrastructure, contract enforcement, monetary stability, and public research. The corporate rate should be adjusted upward. The minimum tax floor should be defended. Stock buybacks should be taxed at higher rates. Public effective tax rates should be disclosed. Offshore profit shifting should be addressed through international coordination.

Show the public where the money goes — and correct the plan when evidence shows harm. Revenue should be tracked and reported annually. Public investments — infrastructure, housing, health, disaster readiness, tribal and rural infrastructure — should be visible and auditable. If any provision shifts burden onto ordinary workers, harms protected groups, or fails its own standards, it must be revised.

This is not a generic tax increase. It is a public-return framework: an alternative to both the implemented system, which often serves neither work nor public conditions, and the speculative proposals that never engage with how taxes actually function. It is designed to be used, debated, adapted, and corrected.

2. Glossary

Anti-abuse rule. A provision designed to prevent taxpayers from using technical maneuvers — entity structures, timing, valuation games, jurisdictional shifts — to defeat the purpose of a tax rule while complying with its letter.

Billionaire Minimum Income Tax (BMIT). The preferred but contested lead instrument of the framework's extreme-wealth pillar — not the pillar itself. The pillar leads at the top of the wealth distribution; BMIT is the instrument within it that most directly reaches the buy-borrow-die pattern, supported by a standing portfolio of parallel and fallback mechanisms (strengthened step-up reform, tightened capital-gains parity, restored enforcement, Pillar Two alignment) that carry the pillar's goal whether or not BMIT survives review. BMIT is a proposed minimum tax that would apply to households above $100 million in net worth, calculated against a base that includes both realized income and the year's increase in asset value. Designed so that ultra-high-net-worth households cannot reduce their effective tax rate to near zero simply by choosing not to sell assets. Structured as a minimum income tax with accelerated payment rather than a tax on unrealized appreciation: amounts collected on the unrealized-appreciation component are characterized as prepayments of the income tax owed when the gain is realized, creditable against the realized tax liability and refundable if the eventual realized tax liability is smaller. BMIT is paired with the step-up basis reform (the deemed-realization-at-death provision is BMIT's terminal realization event). BMIT is legally exposed and carries explicit conditional status: the Supreme Court's 2024 decision in Moore v. United States declined to resolve whether realization is constitutionally required for income taxation, and BMIT leads the pillar conditional on counsel review converging on a defensible post-Moore litigation path; if that condition is not met, BMIT moves to reserve status (not rejected, promotable later) and strengthened step-up reform leads the pillar. Substantive legal review by qualified counsel is required before the framework's BMIT design is presented for external implementation. The framework's commitment is to the work-wealth-parity goal the pillar serves, not to BMIT as the only instrument.

Capital-gains parity. The principle that, at high income levels, income from selling appreciated assets should be taxed at the same rate as income from work. Currently, long-term capital gains receive preferential rates. Under this plan, ordinary rates apply to capital gains and qualified dividends for households above $1 million in annual income. Preferential rates remain for low- and middle-income investors.

Corrigibility. The capacity of a system to be corrected when evidence shows it is failing its own purposes. In this plan, corrigibility means that every major provision must identify who measures performance, what data they use, how often review occurs, and who has authority to revise, narrow, pause, or remove the provision if it harms protected groups or loses connection to public return.

Lead mechanism. A provision the plan is willing to defend as central to its purpose, even if it carries legal, administrative, or political risk. Lead mechanisms include worker protection, capital-gains parity, step-up reform, BMIT (with caveat), corporate public-return tax, and enforcement restoration.

Protected continuity. Groups, institutions, and assets the plan is designed not to harm: ordinary workers, low- and middle-income households, family homes, small businesses, family farms and ranches, modest inheritances, retirement accounts, tribal governments, tribal enterprises, trust lands, treaty-protected rights, culturally significant property, and genuine community assets. Protection is treated as a design constraint, not a carve-out added after the fact.

Public return. The principle that public revenue is legitimate only when it is visibly returned to the conditions that make ordinary life possible — infrastructure, housing stability, health, education, public safety, disaster readiness, tribal and rural infrastructure, and stabilization of public capacity. Connects the tax plan to the broader civic-resilience framework's three duties: anti-violence governance, foundational economic security, and infrastructure resiliency.

Real economic power. The practical capacity to command resources, shape markets, defer or avoid public obligations, influence public systems, preserve wealth across time, or shift costs onto others — whether or not that power appears as ordinary taxable income in a given year. The phrase is disciplined by thresholds, measurable indicators, public-return justification, protected-continuity guardrails, and correction triggers. It does not authorize unlimited taxation; it identifies the actual location of economic capacity that the tax system should follow.

Reserve mechanism. A provision that may be morally aligned with the plan's purpose but is too legally exposed, administratively unproven, or distributionally uncertain to lead the framework. Reserve mechanisms include the direct net wealth tax, broad financial transaction tax, +10% surtax above $100 million income, megacorporation 28% tier, and broad taxation of asset-backed borrowing. Reserve does not mean rejected; it means not ready to carry the framework.

Step-up basis. A feature of current tax law that resets the cost basis of inherited assets to their market value at the time of the original owner's death. This means lifetime appreciation can pass to heirs without ever being subject to income tax. Step-up reform in this plan would tax large unrealized gains above high exemption thresholds at death or transfer, with active-business and active-farm deferrals, hardship rules, and protections against forced sale.

Values-to-conditions test. The standard against which the plan judges itself and against which readers can judge the tax system: not what fairness, opportunity, or responsibility are declared to be, but whether those values become actual lived conditions for ordinary people. A tax system passes the test when it distributes responsibility according to real economic power and produces public conditions people can live under. It fails when declared fairness coexists with structural advantage for concentrated wealth.

Work-wealth parity. The principle that, at comparable economic capacity, income from labor and income from ownership should be taxed at comparable rates. The current system violates this principle through preferential capital-gains rates, step-up basis, deferral, and asset-backed borrowing without realization. Work-wealth parity is the plan's primary alignment claim: not that wealth should be punished, but that it should not be structurally advantaged over work.

3. How to Evaluate a Tax Provision

A Public Tool from the American Tax Plan Framework

Any tax provision — proposed, enacted, or hypothetical — can be evaluated against five dimensions. This tool gives readers a way to apply the framework's standards to provisions outside this plan, including provisions this plan does not address and provisions this plan itself contains. The tool is not a scoring system. It is a structured way to surface what a provision is doing, what it is risking, and what would need to be true for it to belong in a serious public-return framework.

A provision evaluation produces five judgments, each with an explicit confidence level. The judgments are independent — a provision can score strongly on one dimension and weakly on another. The honest verdict is the full picture, not a composite.

Dimension 1: Mission Fit

The first question is whether the provision serves one of the three duties: anti-violence governance, foundational economic security, or infrastructure resiliency. If the provision serves a duty, name which one and how. If the provision serves none — if its justification is purely revenue, purely symbolic, or purely political — that is itself a finding.

Confidence levels: - Strong fit. The provision directly serves at least one duty, and the connection is structural rather than incidental. - Partial fit. The provision serves a duty but also carries elements that do not, or its service to the duty is indirect. - Weak fit. The provision's primary justification is revenue, optics, or political signaling rather than service to a duty. - No fit. The provision serves none of the duties or actively undermines one.

Dimension 2: Burden Alignment

The second question is whether the burden of the provision falls on those who hold real economic power. This dimension has two parts: who is the intended payer, and who is the likely economic bearer after behavioral and market adjustment. These are often different. A corporate tax is legally paid by a corporation but economically borne in some combination by shareholders, workers, consumers, and suppliers. A wealth tax is legally aimed at ultra-high-net-worth households but can produce forced-sale pressure on illiquid asset holders if drafted poorly.

Confidence levels: - Aligned. The intended payer and likely bearer are both within the population the provision claims to target, and the protected continuity groups remain protected. - Misaligned. Either the intended payer is not the actual bearer, or the provision creates burden on protected groups (workers, small businesses, family farms, retirement savers, tribal governments, primary residences). - Uncertain. The burden depends heavily on behavioral response, incidence assumptions, or design specifics that have not been resolved.

Dimension 3: Avoidance Exposure

The third question is how concentrated wealth, sophisticated entities, and high-capacity advisors will respond to the provision. A provision that is morally aligned but easily avoided produces less of its intended effect and more of its unintended distortion. The evaluation should name the specific avoidance mechanisms the provision is exposed to — not general categories like "structuring" but specific strategies: deferral, valuation discounts, jurisdictional shifts, entity classification, charitable substitution, timing changes, income recharacterization, and so on.

Confidence levels: - Low exposure. The provision is structurally difficult to avoid, or the anti-abuse rules attached to it are credible. - Moderate exposure. The provision is avoidable through identifiable strategies, but the avoidance is itself costly or visible. - High exposure. The provision is avoidable through routine planning that sophisticated taxpayers will use as standard practice. - Unresolved. The avoidance landscape has not been mapped and the provision should not be evaluated as final until it has.

Dimension 4: Administrative Feasibility

The fourth question is whether the provision can actually be administered — measured, collected, audited, and corrected — by the institutions responsible for it. A provision that requires data that does not exist, valuations that cannot be performed reliably, or enforcement capacity that has not been built is not yet a real provision.

Confidence levels: - Feasible. The administering institution has the data, capacity, and legal authority required. - Buildable. The provision requires new capacity, but the capacity can be built within a reasonable timeframe. - Uncertain. The administrative requirements are unproven, contested, or depend on capacity that has been weakened and not restored. - Infeasible. The provision cannot be administered honestly with current or near-term capacity.

Dimension 5: Legal Durability

The fifth question is whether the provision can survive constitutional challenge, statutory interpretation, and administrative-law review. Some provisions are clearly within congressional taxing authority. Others test the boundaries — particularly provisions touching realization doctrine, retroactivity, takings, equal protection, or international treaty obligations. The evaluation should name the specific legal questions, not assert legal validity in the abstract.

Confidence levels: - Settled. The provision falls within well-established congressional authority and survives existing doctrine. - Defensible. The provision raises identifiable legal questions but has plausible arguments for survival. - Exposed. The provision faces serious legal challenge under current doctrine, and survival depends on judicial interpretation that is not yet resolved. - Unresolved. The legal question has not been engaged seriously enough to support any judgment.

Using the Tool

A complete evaluation produces five confidence levels, one per dimension. The honest verdict is the full picture: a provision might be strong fit, aligned, moderate exposure, buildable, defensible — which is a serious provision worth defending despite its uncertainties. Or it might be weak fit, uncertain, high exposure, infeasible, exposed — which is a provision that should not be in a serious framework regardless of how attractive its headline sounds.

A few patterns are worth naming.

A provision that scores strongly on Mission Fit but poorly on Avoidance Exposure or Administrative Feasibility is not ready to lead a framework. It may belong in reserve until the gaps are closed. The Billionaire Minimum Income Tax in this plan is an example: strong mission fit, but exposed on legal durability and uncertain on administrative feasibility. The plan leads with it under caveat rather than treating its inclusion as settled.

A provision that scores strongly on revenue but weakly on Mission Fit should be treated with suspicion. The financial transaction tax in this plan is an example: it raises revenue, but its primary justification is revenue rather than service to a duty. It belongs in reserve.

A provision that scores strongly across the first four dimensions but is Exposed on legal durability is not necessarily disqualified. It requires fallback architecture — design choices that preserve the provision's purpose if litigation narrows or eliminates the lead mechanism. Step-up basis reform in this plan is an example: legally complex, but with substantial design space for protected fallbacks.

A provision that scores well across all dimensions but produces Misaligned burden — particularly burden on protected continuity groups — fails its own purpose. The evaluation should treat misalignment as a correction trigger, not a tolerable cost.

The tool's value is not in the labels themselves. The labels are scaffolding. The value is in the discipline of asking the five questions honestly about each provision, naming what is known and what is not, and refusing to collapse uncertainty into false confidence.

What the Tool Does Not Do

The tool does not produce a single recommended verdict. It does not score provisions against one another. It does not tell readers whether a provision is good or bad in the abstract — only what it is doing, what it is risking, and what would need to be true for it to belong in a serious public-return framework.

It also does not replace specialized expertise. A serious evaluation of administrative feasibility benefits from tax-administration experts. A serious evaluation of legal durability benefits from constitutional and administrative-law expertise. A serious evaluation of avoidance exposure benefits from tax-practitioner experience. The tool gives non-specialist readers a structured way to think about these dimensions and to know which questions require expert input. It does not pretend that the structured thinking is itself the expertise.

4. Worked Example: State-Level Annual Wealth Taxes

This example demonstrates the public tool in operation. It evaluates state-level annual wealth tax proposals (typically annual taxes of 1–4% on net worth above thresholds ranging from $30 million to $1 billion, applied to state residents) as a category. A specific proposal would require its own evaluation; the category-level evaluation surfaces what state-level wealth taxes generally face.

Dimension 1: Mission Fit — Partial fit

State-level wealth taxes claim to serve foundational economic security by funding state public services through revenue raised from concentrated wealth that currently faces little state-level tax exposure beyond property tax and capital-gains realization. They also gesture at anti-violence governance — addressing structural inequality and the institutional advantages of concentrated wealth — and at infrastructure resiliency through revenue allocated to state infrastructure, housing, education, and health systems.

The mission fit is real but partial. State wealth taxes serve foundational economic security through the revenue they raise, but the connection is mediated by state spending allocation, which varies dramatically by state and by year. The mission fit is therefore not inherent to the tax — it depends on what the state does with the revenue. State wealth taxes also serve anti-violence governance to the extent that they reduce the structural asymmetry between work and wealth at the state level. But that anti-violence service is weakened if the wealth tax produces relocation rather than payment.

Dimension 2: Burden Alignment — Misaligned to uncertain

The intended payer of a state wealth tax is residents above the wealth threshold. The likely economic bearer is more complicated. Residents who remain pay the tax directly. Residents who relocate to non-taxing states avoid the tax entirely and shift their contribution to public conditions out of the state. Residents who restructure assets may reduce but not eliminate exposure. Residents whose wealth is concentrated in illiquid assets face valuation pressure and possible forced-sale incentives.

The most significant misalignment risk is that state wealth taxes concentrate burden on residents whose wealth is least mobile — typically holders of physical assets, in-state business interests, and family wealth tied to local presence — while allowing the most mobile wealth to exit. This produces a paradoxical pattern: the tax reaches the wealth most tied to the state's actual economic conditions while exempting the wealth most disconnected from them.

A second misalignment risk concerns illiquid asset holders — particularly family businesses, working farms and ranches, and closely-held interests. A 1-4% annual tax on net worth requires liquidity that illiquid holders do not have. Without hardship provisions, valuation deferrals, and active-business protections, state wealth taxes create forced-sale pressure on exactly the kind of protected-continuity groups a public-return framework is designed to protect.

Dimension 3: Avoidance Exposure — High exposure at the very top; modest below it; stratified by wealth level

State wealth taxes face the simplest available avoidance mechanism: leave the state. The U.S. constitutional structure permits free movement between states, and state residency is a question of fact that taxpayers can change. But the empirical literature shows that the migration response is sharply stratified by wealth level, and an honest evaluation must reflect that stratification rather than asserting uniform high exposure.

At the very top of the wealth distribution, exposure is severe. Moretti and Wilson (2023, American Economic Journal: Economic Policy), studying the Forbes 400, found that approximately 35% of resident billionaires left states after estate-tax liability became location-dependent in 2001, with sensitivity increasing significantly with age. For the population a state wealth tax most depends on for revenue — a small number of very large fortunes — relocation risk is real and large.

For the broader population of merely high-income or high-net-worth households below the Forbes 400 level, exposure is modest. Young, Varner, Lurie, and Prisinzano (2016, American Sociological Review), using IRS administrative data covering 45 million records, found that millionaire tax flight occurs "only at the margins of statistical and socioeconomic significance." Young and Varner's natural-experiment study of New Jersey's 2004 millionaire tax found a statistically significant migration response only for the top 0.1%, not for millionaires generally. State wealth tax proposals typically set thresholds ($30M to $1B) that span both populations, so the avoidance exposure is genuinely mixed: high for the largest fortunes that drive most of the revenue, modest for the larger number of households nearer the threshold.

Specific avoidance mechanisms available to the most mobile wealth include: change of state residency, often to Florida, Texas, Nevada, Wyoming, South Dakota, or Tennessee; relocation of trusts to favorable trust jurisdictions (Delaware, Nevada, South Dakota, Alaska) regardless of grantor residency; restructuring of business operations to reduce state nexus; transfer of assets to family members or trusts in non-taxing jurisdictions before residency moves are completed; conversion of in-state assets to portable forms; use of holding company structures that can themselves be relocated; pre-emptive estate planning that distributes wealth across jurisdictions before the tax applies.

Anti-abuse responses available at the state level are limited. Exit taxes face constitutional questions under the dormant Commerce Clause, the Privileges and Immunities Clause, and the right to travel. Look-back provisions face similar challenges. Trust situs rules can be tightened but not made airtight. The federal government does not face this exposure to the same degree, because leaving the country is far costlier than crossing a state line and the U.S. maintains an exit-tax regime; states cannot replicate that structure.

One critical caveat the literature requires. High avoidance exposure does not automatically mean net revenue loss. Moretti and Wilson found that even with 35% billionaire relocation, the revenue collected from those who remain exceeds the revenue lost from those who relocate in the vast majority of states — of states without estate taxes, all but California would gain revenue by adopting one. A high-exposure verdict on Dimension 3 is therefore a warning about base erosion and the importance of design, not a prediction that the tax loses money.

Dimension 4: Administrative Feasibility — Uncertain to buildable

State revenue agencies do not currently have the capacity to value and audit comprehensive net worth annually. Property valuations are familiar; business equity, private partnership interests, art, intellectual property, complex trust interests, and closely-held assets are not. Annual valuation of net worth for hundreds or thousands of high-wealth state residents requires capacity that no state currently has.

States can build that capacity, but building it requires hiring valuation specialists, developing audit protocols, establishing legal frameworks for disputed valuations, creating appeal mechanisms, and integrating new reporting requirements with existing state revenue systems. This is buildable within several years of dedicated effort and funding, but no state has yet done it.

Dimension 5: Legal Durability — Exposed to unresolved

State wealth taxes face multiple legal questions, several of which are unresolved.

State constitutional questions vary by state. Federal constitutional questions include the dormant Commerce Clause, the Due Process Clause, the Privileges and Immunities Clause, and the Equal Protection Clause. Exit-tax provisions and look-back provisions face additional scrutiny under the constitutional right to travel established in Saenz v. Roe (1999).

State wealth taxes also face statutory federal questions under ERISA preemption, federal banking law, and federal trust law principles.

These are real legal questions, not theoretical objections. None has been resolved by litigation because no state has implemented a wealth tax to be challenged.

Composite View

What This Evaluation Means

The evaluation does not say state-level wealth taxes are wrong, illegitimate, or undesirable. It says that as currently designed in most state proposals, they face structural problems that would prevent them from functioning as serious public-return mechanisms. The federal BMIT in this plan faces some of the same problems (legal durability, administrative feasibility) but not others — residency-based avoidance is dramatically less available at the federal level, because the migration evidence shows the largest fortunes relocate readily across state lines but face far higher cost and an existing exit-tax regime when leaving the country entirely.

Two findings from the migration literature should temper any reading of this evaluation as simple opposition to state wealth taxes. First, avoidance exposure is stratified: it is severe for the Forbes 400-level fortunes that drive most of the potential revenue, but modest for the broader high-income population nearer the threshold. Second, high exposure does not mean net revenue loss — Moretti and Wilson found that even with substantial billionaire relocation, the revenue from those who remain exceeds the revenue lost from those who leave in the vast majority of states. The honest verdict is that state wealth taxes face serious base-erosion risk at the top that demands careful design, not that they are doomed to lose money.

A state considering a wealth tax could use this evaluation to identify which dimensions require design response before implementation: visible revenue allocation to public-return priorities, illiquid-asset protections, anti-abuse design beyond what residency mobility allows, multi-year capacity building before implementation, and constitutional defenses that engage rather than dismiss the legal questions.

A reader who concludes from this evaluation that the federal BMIT in this plan should also be evaluated against the same five dimensions and judged honestly is using the tool exactly as it is designed to be used.

5. Scenario Card Template

A short structured response tool from the American Tax Plan Framework

Use this card when a tax provision needs a structured initial response and a full worked evaluation is more apparatus than the situation requires.

Provision name: ___

One-sentence description: ___

Intended payer: ___

1. Mission Fit

Which of the three duties does this provision serve, and how? - Anti-violence governance: ___ - Foundational economic security: ___ - Infrastructure resiliency: ___

Strongest fit: [Strong / Partial / Weak / None]

2. Burden Alignment

Likely economic bearer (not necessarily the intended payer): ___

Protected continuity groups at risk: - Ordinary workers: [Risk / No risk / Unknown] - Small businesses: [Risk / No risk / Unknown] - Family farms, ranches, or active operations: [Risk / No risk / Unknown] - Primary residences: [Risk / No risk / Unknown] - Retirement savers: [Risk / No risk / Unknown] - Tribal governments or community assets: [Risk / No risk / Unknown]

Alignment judgment: [Aligned / Misaligned / Uncertain]

3. Avoidance Exposure

Specific avoidance mechanisms this provision is exposed to: 1. ___ 2. ___ 3. ___

Anti-abuse design currently attached: [Credible / Partial / Absent / Unknown]

Exposure judgment: [Low / Moderate / High / Unresolved]

4. Administrative Feasibility

Administering institution: ___

Required capacity: [Existing / Buildable / Uncertain / Infeasible]

Specific capacity gaps if any: ___

5. Legal Durability

Specific legal questions the provision faces: 1. ___ 2. ___ 3. ___

Durability judgment: [Settled / Defensible / Exposed / Unresolved]

Composite Reading

Required Next Step

• [ ] Develop design response to address [specific dimension weakness]
• [ ] Request expert input on [specific dimension]
• [ ] Refer for full worked evaluation
• [ ] Proceed as designed
• [ ] Recommend reserve status until [specific condition]
• [ ] Recommend against inclusion

Filled by: ___ Date: ___ Review date: ___

6. Claim-Source Matrix v0.1

This matrix tracks the substantive claims in the American Tax Plan framework. Each claim is identified, classified, and either sourced, marked for sourcing, or explicitly withdrawn.

Claim statuses: - Framework claim. Original moral or analytical architecture from the corpus. - Sourced empirical claim. Empirical claim with a verifiable external source. - Empirical claim, sourcing pending. Empirical claim that appears in the framework but does not yet have a verifiable source. - Method claim. A tool, procedure, or evaluative structure proposed by the framework. - Not carried forward. Claim that appeared in earlier versions but is not used in the current framework.

Framework Claims (Original Architecture)

Sourced Empirical Claims

Empirical Claims, Project B Sourcing Status

Project B (empirical sourcing) converts pending claims into findings-level entries. P1 through P8 are all complete; Project B is closed. Full findings are in the Project B Sourcing Document v0.7.

Sourced (Project B complete):

All Project B claims are now sourced. The Sourcing Pending table is closed.

Method Claims

Not Carried Forward

7. Claims Not Carried Forward

This section records claims that appeared in earlier versions of the American Tax Plan or in adjacent debates that the current framework will not stand behind without further work. Including this section is part of the framework's corrigibility discipline. A serious public-return framework should be willing to name what it has corrected, what it has restricted, and what it has withdrawn, rather than allowing earlier overclaim to circulate alongside corrected language.

The corrections fall into four categories.

Revenue Claims

The most consequential withdrawal concerns the framework's revenue estimates. Earlier versions, particularly the v0.2 revenue annex, presented a range of $2.0 to $2.4 trillion net over ten years as the lead package's revenue potential. That figure should be understood as a working estimate produced from internal assumptions about rate changes, behavioral response, base broadening, and interaction effects. It is not a JCT score, a CBO estimate, or a microsimulation result. The framework does not claim it is. The current framework presents revenue ranges with explicit acknowledgment that they reflect working assumptions rather than formal scoring, and that any serious legislative use would require independent revenue estimation by the appropriate scorekeeping institutions.

A related restriction concerns generalized claims about public-spending returns. The framework cites the National Institute of Building Sciences finding that federal hazard mitigation grants save approximately $6 per $1 invested. That citation is specific to hazard mitigation and to federal grants of that category. The framework does not generalize this finding to other public spending categories.

Distributional Claims

Earlier versions, particularly the v0.3 distributional annex, performed substantial work on incidence questions. That work included a "mixed incidence scenario" assumption that corporate tax burden would fall in a 60/25/15 split between capital, labor, and consumers. The 60/25/15 split is not carried forward. It was a working assumption identified as a central case for analytical purposes, not a finding grounded in a specific empirical model. The actual incidence literature contains substantial disagreement.

The broader distributional claim — that the framework proves its distributional effects across the population — is also restricted. The framework's distributional discipline is to identify who is intended to pay, who is protected, and where burden could unintentionally shift. It does not claim to have proven distribution in the sense that JCT or Tax Policy Center distributional tables prove distribution. That work remains outstanding.

Mechanism Claims

Several mechanisms that earlier versions considered as lead provisions have been moved to reserve status in v1.0. Reserve does not mean withdrawn. It means the mechanism is not currently positioned to lead the framework. The +10% surtax above $100 million income, the megacorporation 28% tier, the direct annual net wealth tax, the broad financial transaction tax, and the broad anti-borrowing rule against asset-backed loans are all reserved pending resolution of specific issues.

The most consequential mechanism claim that has been corrected concerns BMIT. Earlier versions sometimes presented BMIT as if its legal foundations were more settled than they are. The Supreme Court's 2024 decision in Moore v. United States upheld the Mandatory Repatriation Tax on narrow attribution grounds while explicitly declining to resolve the broader question of whether realization is constitutionally required for income taxation. Four justices wrote separately to affirm a realization requirement; one wrote separately to reject it; the remaining majority did not decide. The controlling doctrine on a future challenge to a mark-to-market mechanism is not settled. The current framework therefore presents BMIT as a framework / legal-risk claim, not a settled legal claim: BMIT is the preferred but contested lead instrument of the framework's extreme-wealth pillar — the pillar leads, and BMIT is the instrument within it carrying explicit conditional status. BMIT is designed with the prepayment-and-portfolio architecture detailed in Section V of the Integrated Framework, and substantive legal review by qualified tax counsel and constitutional litigators is required before BMIT is presented for external implementation. BMIT leads the pillar conditional on that review converging on a defensible post-Moore litigation path; if the condition is not met, BMIT moves to reserve status (not rejected, promotable later) and strengthened step-up reform leads the pillar. The framework's commitment is to the work-wealth-parity goal that the pillar serves, not to BMIT's specific survival; the standing portfolio of parallel and fallback mechanisms preserves the goal whether or not BMIT survives. Claims that BMIT is legally settled are not carried forward.

A specific administrative claim should also be corrected. Earlier framing of the framework's enforcement pillar treated "Corporate Transparency Act restoration" as if it referred to restoring pre-2025 beneficial-ownership reporting rules. The March 21, 2025 FinCEN interim final rule narrowed BOI reporting to foreign reporting companies. Restoration is therefore a substantial undertaking — requiring either Congressional action, new rulemaking by a future administration's FinCEN, or judicial review of the interim final rule.

Framing Claims

The most persistent pattern across earlier versions has been framing that ran ahead of the work the framing claimed to describe. The v0.3 distributional annex was sometimes described as having "answered who pays" when it had identified intended payers and surfaced the questions a distributional analysis must answer. The v0.4 governance memo was sometimes described as having "made correction operational" when it had designed the institutions, data sources, cadences, and authorities through which correction should occur. Whether correction actually occurs depends on sustained political will, funded enforcement, and institutional persistence that no statute can fully guarantee.

These framings have been corrected. The current framework does not describe itself as legislatively ready, distributionally proven, legally settled, or finally scored. It describes itself as an integrated working framework — a guide and rallying point intended to fill the gap between implemented tax systems and idealistic-speculative proposals, designed to be used, debated, adapted, and corrected.

Why This Matters

A framework that records its corrections is not a weaker framework. It is a more honest one. Readers can verify what the current claims are by checking the matrix and source list. They can see what earlier versions claimed and what was corrected. They can argue with the corrections themselves, which is part of the corrigibility discipline the framework is built on.

A framework that does not record its corrections produces several specific problems. Earlier overclaim continues to circulate alongside corrected language, and readers cannot tell which represents the current position. Critics can cite the overclaim version against the framework as if it were the current position, and the framework has no clean response. The discipline of correction becomes private — visible to the authors but invisible to readers — which means the corrigibility claim is rhetorical rather than operational.

This section is the public commitment that the framework's corrigibility is operational, not rhetorical.

Companion Packet v0.1 — produced May 27, 2026; revised to integrate Project B findings P2 (high-wealth migration stratification) into the worked example and to update the claim-source matrix for all Project B findings (P1–P8). All eight claims are sourced and integrated; Project B is closed. Glossary entry for BMIT and the "Claims Not Carried Forward" N4 entry further revised on May 30, 2026, to implement the BMIT lead-versus-reserve decision: BMIT is presented as the preferred but contested lead instrument of the extreme-wealth pillar (the pillar leads, not the instrument), carrying explicit conditional status, with a standing portfolio of parallel and fallback mechanisms that carries the pillar's goal whether or not BMIT survives review, and with substantive legal review by qualified counsel required before external implementation. To be read alongside American Tax Plan v1.1 (the main framework), the Project B Sourcing Document v0.7 (empirical findings), the Development Record v0.3 (the project's institutional memory), the BMIT post-Moore legal memo v0.1 (the analytic record behind Section V's current language), and the BMIT Lead-versus-Reserve Decision Memo (the reasoning behind the pillar/instrument framing).

Related reading

The American Tax Plan contains the main framework and its public dashboard. This companion supplies the brief, glossary, evaluation tools, and worked examples.

Political Economy & Public Return: project and status · All work · Corrections and updates