On 28 March 2022, U.S. President Joe Biden released the Fiscal Year 2023 Budget. Alongside the Budget, the U.S. Department of the Treasury published the so-called Greenbook, providing further detail on the Budget revenue proposals. The proposed revenue measures as summarized by the Treasury Department include:

• Reform Business and International Taxation
  • Raise the Corporate Income Tax Rate to 28%
  • Adopt the Undertaxed Profits Rule
  • Provide Tax Incentives for Locating Jobs and Business Activity in the United States and Remove Tax Deductions for Shipping Jobs Overseas
  • Prevent Basis Shifting by Related Parties through Partnerships
  • Conform Definition of "Control" with Corporate Affiliation Test
  • Expand Access to Retroactive Qualified Electing Fund Elections
  • Expand the Definition of Foreign Business Entity to Include Taxable Units
• Support Housing and Urban Development
  • Make Permanent the New Markets Tax Credit
  • Allow Selective Basis Boosts for Bond-Financed Low-Income Housing Credit Projects
• Modify Fossil Fuel Taxation
  • Eliminate Fossil Fuel Tax Preferences
  • Modify Oil Spill Liability Trust Fund Financing and Superfund Excise Taxes
• Strengthen Taxation of High-Income Taxpayers
  • Increase the Top Marginal Income Tax Rate for High Earners
  • Reform the Taxation of Capital Income
  • Impose a Minimum Income Tax on the Wealthiest Taxpayers
• Support Families and Students
  • Make Adoption Tax Credit Refundable and Allow Certain Guardianship Arrangements to Qualify
  • Provide Income Exclusion for Student Debt Relief
• Modify Estate and Gift Taxation
  • Modify Income, Estate and Gift Tax Rules for Certain Grantor Trusts
  • Require Consistent Valuation of Promissory Notes
  • Improve Tax Administration for Trusts and Decedents' Estates
  • Limit Duration of Generation-Skipping Transfer Tax Exemption
• Close Loopholes
  • Tax Carried (Profits) Interests as Ordinary Income
  • Repeal Deferral of Gain from Like-Kind Exchanges
  • Require 100 Percent Recapture of Depreciation Deductions as Ordinary Income for Certain Depreciable Real Property
  • Limit a Partner's Deduction in Certain Syndicated Conservation Easement Transactions
  • Limit Use of Donor Advised Funds to Avoid Private Foundation Payout Requirement
  • Extend the Period for Assessment of Tax for Certain Qualified Opportunity Fund Investors
  • Establish an Untaxed Income Account Regime for Certain Small Insurance Companies
  • Expand Pro Rata Interest Expense Disallowance for Business-Owned Life Insurance
  • Correct Drafting Errors in the Taxation of Insurance Companies Under the Tax Cuts and Jobs Act of 2017
  • Define the Term "Ultimate Purchaser" for Purposes of Diesel Fuel Exportation
• Improve Tax Administration and Compliance
  • Enhance Accuracy of Tax Information
  • Address Taxpayer Noncompliance with Listed Transactions
  • Amend the Centralized Partnership Audit Regime to Permit the Carryover of a Reduction in Tax that Exceeds a Partner's Tax Liability
  • Incorporate Chapters 2/2A in Centralized Partnership Audit Regime Proceedings
  • Authorize Limited Sharing of Business Tax Return Information to Measure the Economy More Accurately
  • Impose an Affirmative Requirement to Disclose a Position Contrary to a Regulation
  • Require Employers to Withhold Tax on Failed Nonqualified Deferred Compensation Plans
  • Extend to Six Years the Statute of Limitations for Certain Tax Assessments
  • Expand and Increase Penalties for Noncompliant Return Preparation and E-Filing and Authorize IRS Oversight of Paid Preparers
  • Address Compliance in Connection with Tax Responsibilities of Expatriates
  • Simplify Foreign Exchange Gain or Loss Rules and Exchange Rate Rules for Individuals
  • Increase Threshold for Simplified Foreign Tax Credit Rules and Reporting
• Modernize Rules, Including those for Digital Assets
  • Modernize Rules Treating Loans of Securities as Tax-Free to Include Other Asset Classes and Address Income Inclusion
  • Provide for Information Reporting by Certain Financial Institutions and Digital Asset Brokers for Purposes of Exchange of Information
  • Require Reporting by Certain Taxpayers of Foreign Digital Asset Accounts
  • Amend the Mark-to-Market Rules for Dealers and Traders to Include Digital Assets
• Improve Benefits Tax Administration
  • Clarify Tax Treatment of Fixed Indemnity Health Policies
  • Clarify Tax Treatment of On-Demand Pay Arrangements
  • Rationalize Funding for Post-Retirement Medical and Life Insurance Benefits

Click the following links for remarks on the 2023 Budget by President Biden and Treasury Secretary Yellen.