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 Kozi Checks & Balances TaxTactics News 
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July 25.2025
2 Minutes Read

Understanding the Future of BEAT Tax and Its Global Impact

Colorful vintage globe image showcasing North America, symbolizing global tax ideas.

The Evolution and Future of the BEAT Tax

As corporations navigate the complex US tax landscape, the base erosion and anti-abuse tax (BEAT) emerges as a focal point in discussions surrounding international corporate taxation. First introduced under the Tax Cuts and Jobs Act of 2017, BEAT serves as a mechanism specifically targeting multinational entities that deduct significant expenses linked to profit shifting—a practice that allows companies to sidestep US corporate tax obligations. However, recent legislative developments under the One Big Beautiful Bill Act (OBBBA) have driven a renewed dialogue about the alignment and effectiveness of BEAT in curbing tax avoidance.

Understanding BEAT: The Basics

BEAT applies to large corporations with average annual receipts exceeding $500 million, particularly those whose base erosion payments reach 3% of their total deductions. This tax was initially set at a rate of 10%, slated to increase to 12.5% in 2026. However, the OBBBA has modified this trajectory by establishing a slightly higher BEAT rate of 10.5%, which, while seeming like an increase, does little to address the systemic issues it aims to solve. This creates a challenging environment for both domestic and foreign companies planning investments in the U.S.

Challenges of Implementation and Hidden Flaws

The intent behind BEAT is to identify and tax payments likely related to profit shifting, such as royalties and interest. Yet, the current framework neglects crucial considerations about the tax jurisdictions receiving these payments. By not accurately assessing whether these transactions are made to high-tax areas, BEAT risks punishing legitimate business operations and discouraging foreign direct investment more than it deters tax evasion.

Future Implications of BEAT under OBBBA

Despite initial proposals to revamp BEAT more thoroughly, the OBBBA leaves much unaltered, revealing a legislative struggle between protecting domestic tax revenue and fostering a competitive investment climate. The discarding of substantial changes, such as the punitive enforcement through Section 899, suggests an ongoing debate about how best to balance these two opposing aims.

Why Understanding BEAT Matters Now

The complexities surrounding BEAT will have lasting implications not only for multinational corporations but also for global economic relations. As investors scrutinize U.S. tax policy, clear communication and responsive modifications to legislation will be crucial in maintaining the nation’s attractiveness as a business destination. Engaging in informed discussions about BEAT and its role in international taxation is essential for business owners navigating this landscape.

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10.30.2025

Illinois Lawmakers Push Rush Tax on Unrealized Gains — What It Means

Update Illinois Moves to Tax Unrealized Gains: A Controversial Proposal In an accelerated legislative effort, Illinois lawmakers are pushing a radical tax plan aimed at billionaires that targets "unrealized gains." A new proposal, aptly named the Extremely High Wealth Mark-to-Market Tax Act, aims to levy a 4.95% tax on the unrealized gains from various assets. This includes stocks, bonds, business interests, art, and other owned properties—whether they are physically located in Illinois or not. The shock factor of this initiative rests not only in its ambitious scope but also in the rapid timeline set for its passing, with only 48 hours designated for legislative review. The Mechanics of the Tax: Understanding Unrealized Gains Under this ambitious plan, taxpayers would be taxed not on the income they earn, but on the increased value of their assets, which cannot be realized until they are sold. This means that a billionaire’s assets could face taxation based solely on an appreciated value that has yet to become liquid cash. While proponents argue that taxing these unrealized gains could close significant tax loopholes, critics cite potential economic repercussions, suggesting that such a system may discourage investment and lead to capital flight out of Illinois. Legal and Economic Implications of the Proposal Adding to the complexity, Illinois’s current constitution prohibits personal property taxes, framing this legislation as an income tax instead. This raises questions about its constitutional viability and economic equity. While some may deem taxing billionaires as a reasonable measure, the bill could inadvertently exert pressure on small businesses and startup investments, as asset-rich entrepreneurs might find themselves cash-poor due to these unrealized tax obligations. Historical Context: A Precedent or a New Frontier? No nation has successfully implemented a mark-to-market capital gains tax system akin to what is being proposed in Illinois. This gives rise to significant questions about the practical implementation of such a tax. With complexities regarding valuation—especially for non-liquid assets—experts predict that measuring the value of privately held companies, art, and collectibles will be fraught with difficulties. As financial experts note, this is tantamount to expecting meticulous assessments in a paradigm that has historically avoided direct taxation on unrealized wealth. Final Thoughts: What This Means for Illinois The initiatives led by Illinois lawmakers reflect a mounting tension between the state's need for revenue and the potential ramifications for its wealthiest residents. The question remains: will targeting unrealized gains through such an aggressive tax method solve budgetary concerns, or will it drive wealthy individuals and their investments out of state? Illinois residents, businesses, and stakeholders must stay informed on this crucial issue as it unfolds. Understanding the potential impact of this tax proposal could be vital in guiding discussions about fairness in taxation and economic sustainability in the region.

10.23.2025

How OBBBA Upheld the Progressive Tax System Amid Complexities

Update The Impact of OBBBA on the Progressive Tax System The One Big Beautiful Bill Act (OBBBA), enacted in 2025, has been a significant point of discussion regarding its influence on the federal tax system. Operating at a scale not seen since the Tax Cuts and Jobs Act (TCJA) of 2017, the OBBBA is said to maintain the progressiveness of the federal income tax, bringing both benefits and drawbacks to various income groups. Understanding Tax Progressivity Tax progressivity means that tax rates increase as income rises, with the wealthy contributing a larger share of their income compared to lower-income individuals. The recent changes have reportedly upheld this structure, ensuring that taxation corresponds fairly to citizens’ ability to pay. However, some taxpayers in the top quintile of earners may not feel these benefits equally due to the introduction of new gross tax hikes affecting high-income earners. The Arithmetic of Redistribution: Examining After-Tax Income Figures The OBBBA proposes an average increase in after-tax incomes, with projections indicating an average rise of 2.9% in 2025 and 5.4% in 2026. The bottom quintile might see an increase of about 1.5% in 2025, possibly due to new limits on popular credits like the child tax credit and the earned income tax credit. Complexity vs. Simplicity: A Double-Edged Sword While the OBBBA aims to simplify tax implications by making temporary TCJA provisions permanent, it paradoxically introduces complexities. New deductions for overtime income, tipped income, and senior citizens further entangle an already complicated tax system. Critics argue that these additions detract from the primary goal of a streamlined fiscal policy. Public Sentiment and Legislative Disconnect Public opinion surrounding the OBBBA remains divided; a significant proportion of respondents express concern that the tax cuts favor wealthy individuals over lower-income groups. Polls indicated that while financial repercussions could be significant, many citizens felt ill-equipped to assess the real implications of such expansive legislation. Future Considerations for Tax Policy Reform Looking forward, it is essential to scrutinize how each provision of the OBBBA will affect social welfare programs and the federal deficit. While the Act promises sleepless nights for policymakers seeking to confront long-term challenges in the tax code, it opens avenues for reevaluation as provisions begin to expire after 2028. Historical patterns suggest that bridging the gap between public opinion and legislative action will require increased transparency and public engagement. The continued progression of tax reform demands balancing effective policy incurred by societal needs and the pressing nature of public sentiment. The OBBBA may provide the necessary foundation for a more responsive fiscal approach that truly represents the diverse needs of all citizens.

10.07.2025

The Hidden Costs of Property Tax Repeal: Why Revenue Replacement Matters

Update Understanding the Complex Landscape of Property Tax RepealProperty taxes are the largest revenue source for local governments in the U.S., generating over 70 percent of local tax revenue, by some estimates. They primarily fund essential services like education, public safety, and infrastructure. However, dissatisfaction with property taxes prompts discussions about their elimination, leading to important questions: if property taxes are repealed, how will that lost revenue be replaced, and what are the implications for local communities?The Challenge of Revenue ReplacementReplacing property tax revenue is fraught with challenges. In various jurisdictions, local sales and income tax bases differ significantly, complicating any attempt to equalize funding. For example, an agricultural area may find itself with no viable sales tax base to harness, while urban regions might not have sufficient income tax revenue potential. As a result, any alternative tax replacements could exacerbate existing inequalities, pressing communities to grapple with deeper economic divides.Moreover, the push for local taxing authority can lead to diverse tax rates across regions. For example, Florida’s mixed local and state sales tax rates can reach as high as 15.34 percent in some counties, placing an enormous stress on local consumers. The variations don’t just threaten local economies; they also risk alienating residents from essential services that rely on tax funding.A Look at Previous Attempts and their Economic ConsequencesVarious proposals for property tax alternatives have arisen, including local income taxes and increased sales taxes. However, evidence suggests that income taxes tend to drive wealthier citizens to relocate to lower-tax regions, ultimately leading to decreased funding for local services in higher-tax areas. A study explored in the AIER highlights how recent reforms have failed to successfully replace property tax revenue without creating economic distortions. This trend can ripple out to affect businesses and residents alike, discouraging investment in crucial local services.What Lies Ahead: Future Predictions and ConsequencesDismissing property taxes can appear appealing, particularly due to their unpopularity among taxpayers. However, experts argue that any repeal must be approached with a detailed plan to replace the lost revenue. Without a systematic replacement strategy, communities risk losing funding essential for their operations.The Path Forward: Informed Decisions and Voter EngagementProponents of property tax repeal must engage in open discussions on replacement taxes, shedding light on the true cost of cancellation. Residents should have the opportunity to evaluate any new proposals thoroughly and take accountability for how funding will be structured in the future. Understanding these dynamics will empower voters to make more informed decisions that ensure sustainable community funding.The path to tax reform is challenging and riddled with complexities. But ignoring the consequences of property tax repeal could have lingering effects on community viability and growth. Engaging in this dialogue not only informs voters but also holds government accountable for the services and taxes they prioritize.

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