Individual layer
⟳ Engine 1 · Revenue Capture · Individual layer · Flat Payroll Tax (uncapped, on all compensation)

Flat Payroll Tax (uncapped, on all compensation)

A single 28% rate applied to all compensation at source — wages, bonuses, equity, options, perks, platform income, service income — uncapped and substance-tested, replacing FICA.

Revenue CaptureIndividual layerStructural layerReal-world cases
Individual layerFlat Payroll TaxCapital-gains convergenceProgressive rate ladderEstate Tax Prepayment PlanBuy-borrow-dieWage-to-capitalLifetime giftsFoundation transfersTax-exempt accumulationLike-kind exchangesOpportunity-zonePass-through gamesTransfer-rate arbitrageGenerational repatriation
Individual layer overview

The current code taxes labor reliably while allowing capital, wealth, perks, and inherited appreciation to escape or defer tax. The Accord taxes progressively by broadening the base, applying higher rates at the top, and pairing broad consumption taxation with monthly rebates and luxury surcharges.

Revenue at maturity
Not separately scored
Comprehensive withholding does not have a standalone revenue line. Its load is realized in the payroll tax and income-tax aggregates because withholding the full base is what makes those rates collectable. The measure of the stream's value is what would otherwise leak — the gap between today's statutory top rates and the effective rates the top of the income distribution actually pays after compensation-form games.
1 · What it fixes

Today's payroll tax (FICA) catches paycheck wages reliably and almost nothing else, and it caps at $168,600 — wages above that cap escape the payroll tax entirely. Bonuses partially in the base. Equity vesting, exercised options, perks, deferred compensation, partnership distributions, platform income, and service income flow around it via timing, classification, and entity games.

The reliable contributors are wage earners. The unreliable contributors are everyone with discretion over how their compensation is delivered. The result is a tax system whose published rates only apply to the people who can't choose the form of their pay.

2 · What the Accord does

The Flat Payroll Tax — a single 28% rate applied to every compensation form on the same source-collection footing, uncapped. Substance governs treatment: the form of the payment does not determine whether tax is collected. The base supports the payroll tax and the progressive income-tax rate ladder, plus Social Security accrual on the full comprehensive base rather than the FICA-capped wage base. Same effective rate on a school teacher and a hedge-fund partner.

Scope
Wages, bonuses, equity vesting, exercised options, fringe benefits, deferred comp, active-participant partnership distributions, platform income, contractor service income
Collection point
Source — employer or platform operator remits
Substance test
Binary: working in the entity = compensation. No dollar threshold, no active/passive split with carve-outs.
Reconciliation
Through the existing income-tax filing infrastructure (employee payroll tax share = above-the-line deduction)
Foreign-source
Citizens-resident-abroad with no US-source income are outside the base
3 · Who pays

Anyone receiving compensation in any form. The instrument is structurally invisible to W-2 wage earners — their experience does not change. It bites high earners with discretion over their compensation form, who can no longer choose the lowest-tax channel.

4 · Who is protected

Ordinary wage earners and small businesses paying ordinary wages — already in the base, no change. The protection is structural, not threshold-based: the rule applies uniformly so that no high-income taxpayer can reroute around it.

5 · Revenue role

Not separately scored.

Comprehensive withholding does not have a standalone revenue line. Its load is realized in the payroll tax and income-tax aggregates because withholding the full base is what makes those rates collectable. The measure of the stream's value is what would otherwise leak — the gap between today's statutory top rates and the effective rates the top of the income distribution actually pays after compensation-form games.

See tax ladder · fiscal scoring

6 · Avoidance paths closed
Wage-to-equity recharacterization
Vested equity and exercised options enter the base; carried-interest and founder-equity conversions close through the wage-to-capital subpage.
Deferred-comp timing
Source collection at the substance-of-payment moment; deferral of withholding to a later year does not delay the tax.
Partnership special allocations
Allocations lacking economic substance fail the substance test; the allocated amount enters the active participant's compensation base.
Contractor classification arbitrage
An economic-substance test governs misclassification; misclassified relationships flow through withholding as W-2 employment.
Perk and fringe-benefit non-reporting
Fringe benefits enter the base at fair value; a published de minimis threshold continues for genuinely incidental items.

Detail rules for each closure live in the linked loophole subpages.

7 · Interactions with other Accord systems
payroll tax
payroll tax applies to the same comprehensive base. The base is what makes the levy hard to evade.
Progressive rate ladder
The ladder rates apply to the comprehensive base. The top statutory rate is what the top of the distribution actually pays.
Capital-gains convergence
The convergence rule governs the gain rate above the lifetime cap. The base it applies to is established here through the substance-over-form rule.
Social Security 2.0
Benefit accrual on the full comprehensive base, not the FICA-capped wage base. SS 2.0 stretched bend-points calibrate from this broader base.

The comprehensive base is the layered-enforcement entry point. The corporation's compensation declaration funds its own deduction; the same disclosure becomes the audit basis for the recipient's withholding, the recipient's income-tax return, and the recipient's estate-tax-prepayment filing if applicable. False statement at any layer is independently tax fraud — and the disclosed records are evidence for every other instrument that touches the same base.

9 · Red-team
Strongest objection

Compliance burden on smaller employers issuing irregular compensation forms — equity, contractor payments, irregular bonuses.

Mitigation

IRS-published source-collection schedules per compensation type. Existing W-2 infrastructure already handles wages, bonuses, and most equity. The genuine new lift is non-cash perks and platform-income reporting; that's substantively similar to existing 1099-K and 1099-MISC infrastructure with broader applicability. Cutover is uniform on the scheduled date — no carve-outs.

10 · Open questions and v10.2 work

Honesty about gaps. The Accord's credibility comes partly from explicit acknowledgment of what is not yet specified. The items below are flagged for v10.2 specification or for outside expert review.

  • Equity-grant withholding timing: collect on grant vs. vest vs. exercise. The substance principle is to collect when the worker has unrestricted access to the value, but the implementation rule across restricted stock, ISOs, NQSOs, and RSUs needs explicit specification.
Canon and references: DNA Chapter 5 — Revenue Capture · DNA Chapter 6 — payroll tax · DNA Chapter 7 — Income Tax · Tax ladder · Fiscal scoring · Canonical parameters· Blueprint reference: Chapter 5
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Same category
Progressive ordinary-income rate ladder
13-bracket progressive structure topping at 55% on extraordinary income, applied to the comprehensive base. Brackets 1–7 unchanged from current law; new brackets 8–13 fill the previously-flat upper range.
Same category
Lifetime cap on capital-gains preference
Favored long-term-gain rate continues for ordinary savers up to a $10M lifetime cap. Above the cap, gains pay the ordinary marginal rate. The retiree, the home-seller, and the small-business exiter keep the preference; the serial high-end realizer crosses the cap and converges to ordinary.
Same category
Capital-gains tax at death
Death is a realization event. Stepped-up basis is eliminated. Decades of unrealized appreciation that today escape income tax forever — basis resetting to fair market value at the decedent's death — are taxed at the decedent's marginal rate before transfer to heirs.
Same category
Estate Tax Prepayment Plan
Annual installment on net worth above $10M individual (or $20M jointly held with filing testament), structured as estate-tax prepayment with liquidity protection for illiquid assets.
Close escape valves
Wage-to-capital conversion
Carried interest, founder equity beyond a sweat-equity safe harbor, and partnership special allocations lacking economic substance flow back to ordinary income. Substance governs treatment.
Close escape valves
Pass-through and platform classification
Labor income that escapes through entity form or contractor classification is brought back to the substance of work.