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Definitions, assumptions, exclusions, and the public sources behind the proposal

Unburden America is built around a measurable settlement base, but not every published infrastructure total belongs in the taxable base.

Our current conservative working estimate identifies about $4.5 quadrillion per year in taxable U.S. dollar settlement flows. That figure is a rounded, deduped policy estimate built from included cash-settlement categories, not a simple sum of all reported infrastructure totals.

The purpose of this page is to show what is reported, what is estimated, what is excluded, and where the current framework still needs refinement.

Core methodological principles

Cash settlement only

The proposal is built around actual U.S. dollar cash settlement. It does not tax notionals, market capitalization, gross trade prints, or order flow.

Tax it once

The same dollar should not be taxed multiple times as it moves through the financial system.

Venue priority matters

Higher-level settlement venues take precedence over downstream payment rails. If the cash is already captured at the settlement venue, it should not be taxed again farther down the chain.

Main Street stays out

Ordinary consumer payments, payroll, household transfers, and routine government disbursements are excluded from the current core public base.

Financial settlement tax base map

A. DTCC securities settlement

Representative venues: DTC, NSCC, FICC, MBSD
Reported infrastructure scale: $3.79 quadrillion in 2024 total value of securities processed, up from $2.99 quadrillion in 2023
Included in core base: Yes
Included taxable component: Primary core base
Deduplication / boundary rule: Tax the cash leg once at the DTCC-level settlement point. Do not tax the same dollars again if they later move through Fedwire or CHIPS.
Confidence / note: High. Best-reported and most defensible core category.

B. CLS FX settlement

Representative venue: CLSSettlement
Reported infrastructure scale: $7.2 trillion average daily settled value in 2024, or roughly $1.8 quadrillion annualized using a standard business-day count
Included in core base: Yes
Included taxable component: USD-leg-only subset, not the full published CLS total
Deduplication / boundary rule: Include only the U.S.-dollar leg of covered FX settlement. Exclude non-USD legs and avoid double counting second legs of swaps or rolls.
Confidence / note: Moderate. CLS publishes total settled value, not a separate USD-leg subtotal. The included amount must be a conservative policy estimate, not the raw total.

C. Cleared derivatives cash flows

Representative venues: OCC, CME Clearing, ICE Clear, LCH
Reported infrastructure scale: Public reporting often emphasizes contracts or notional amounts, which are not the taxable base
Included in core base: Yes
Included taxable component: Actual U.S.-dollar cash movements only, including option premia, variation margin, final cash settlement, and related cash flows that actually settle
Deduplication / boundary rule: Exclude notionals, internal offsets, and any cash already captured at DTCC or another higher-priority settlement venue.
Confidence / note: Moderate. Conceptually sound, but less cleanly reported than DTCC.

D. Fedwire / CHIPS

Representative venues: Fedwire Funds, CHIPS
Reported infrastructure scale: Very large gross payment volumes, but not used as primary taxable nodes in the current framework
Included in core base: No
Included taxable component: Excluded
Deduplication / boundary rule: Exclude as downstream transmission rails when cash is already captured at DTCC, CLS, or covered CCP settlement.
Confidence / note: High on exclusion logic. These are important rails, but taxing them directly creates obvious double-counting risk.

E. Retail / cards / P2P / household payments

Representative channels: Card networks, peer-to-peer apps, routine consumer payment channels
Reported infrastructure scale: Large in consumer terms, but not central to the proposal’s target base
Included in core base: No
Included taxable component: Excluded
Deduplication / boundary rule: No routine card purchases, household ACH, P2P apps, or similar everyday consumer activity.
Confidence / note: High. Clean policy choice and important for Main Street protection.

F. Routine government disbursements

Representative flows: Benefits, payroll, grants, reimbursements, ordinary contractor/vendor payments
Reported infrastructure scale: Large in aggregate, but not part of the targeted settlement base
Included in core base: No
Included taxable component: Excluded
Deduplication / boundary rule: Exclude ordinary government spending, transfer payments, payroll, grants, reimbursements, and routine public disbursements.
Confidence / note: High. Clear boundary rule.

G. ACH (large-value institutional only)

Representative venues: ACH Network, FedACH, EPN
Reported infrastructure scale: $86.2 trillion ACH Network value in 2024 across 33.6 billion payments
Included in core base: No, not in phase one
Included taxable component: Not in core public base for now
Deduplication / boundary rule: Public data do not directly report the subset above a policy threshold such as $1 million per day per counterparty. A final rule would need a cleaner implementation design.
Confidence / note: Low for precise taxable sizing from public data. Best treated as a future anti-avoidance or expansion category rather than a core pillar today.

What is reported vs. what is estimated

Boundary rules

The current framework draws clear lines around what belongs in the core taxable base.

Included

  • DTCC securities settlement

  • CLS USD-leg-only settlement component

  • cleared derivatives cash-settlement flows through covered CCP structures

Excluded

  • ordinary consumer payments

  • payroll and household ACH

  • retail card and peer-to-peer activity

  • routine government disbursements

  • Fedwire and CHIPS when they function as downstream rails for cash already captured upstream

  • notionals, gross trade prints, internal offsets, and non-cash reference values

Under further refinement

  • large-value institutional ACH as a possible future anti-avoidance or expansion category

What is reported vs. what is estimated

One of the most important distinctions in this proposal is the difference between published infrastructure values and the included taxable base.

Reported

These are figures directly published by infrastructure operators or official sources.

  • DTCC annual total value of securities processed

  • CLS average daily total settled value

  • ACH network total annual value

Estimated / policy-adjusted

These are the figures that require deductions, exclusions, or policy filtering.

  • the USD-leg-only portion of CLS

  • the included CCP cash-settlement component

  • any future thresholded ACH category

  • the final deduped taxable-base estimate

This is why the base is described as a working estimate rather than a fixed constant.

Illustrative phased implementation model

Unburden America has also developed an illustrative phased implementation model showing one possible sequence for the proposal.

In that model, the settlement tax begins at 0.10%, rises gradually to 0.30%, targets debt retirement in about 8 years, phases in tax relief over time, and leaves room for possible future program expansions only after core fiscal goals are addressed.

The model is meant to clarify sequencing and tradeoffs. It is illustrative, not final.

Why the public anchor remains about $4.5 quadrillion

The public-facing anchor remains about $4.5 quadrillion per year because the proposal is built on a conservative, rounded, deduped estimate — not a raw addition of every large reported infrastructure number.

 

That conservative framing still makes sense because:

  • DTCC’s reported number is very large,

  • CLS must be adjusted downward to reflect the USD-leg-only rule,

  • and ACH is no longer being counted as part of the phase-one core public base.

So the number remains large, but the methodology remains intentionally cautious.

Limitations and open questions

This proposal is meant to be examined, challenged, and refined. A serious methodology page should say that clearly.

Current limitations

  • some categories are reported more cleanly than others

  • some included components are policy estimates rather than directly published subtotals

  • behavioral response and substitution risk require further study

  • ACH remains under further refinement and is not part of the current core public base

  • the final legislative design would need precise anti-avoidance and administrative rules

What that means

These figures should be treated as conservative working estimates, not untouchable constants.

What that means

A proposal of this scale would require:

  • phased implementation

  • transparent reporting

  • revenue-smoothing tools

  • temporary oversight during the transition

Concepts under consideration include a stabilization reserve to smooth receipts and protect core commitments during downturns, and a temporary fiscal transition and solvency commission to monitor implementation, liquidity, calibration, and reporting over time.

Source categories

Federal revenue and tax rates

  • Congressional Budget Office

  • Internal Revenue Service

  • U.S. Treasury

Settlement infrastructure

  • DTCC annual reporting and public statistics

  • CLS annual reporting and settlement data

  • OCC, CME Clearing, ICE Clear, and LCH public materials and institutional cash-settlement framing

  • Nacha and ACH network statistics for context only, not as a direct taxable subtotal

Social Security and Medicare

  • Congressional Budget Office

  • Internal Revenue Service

  • U.S. Treasury

Comparative and market-structure materials

  • BIS FX and market-structure data used as context for USD-leg estimation and cross-border settlement structure

  • historical transaction-tax and settlement-literature comparisons

Why this page exists

Unburden America is not asking people to trust a slogan.

 

The proposal is being built around:

  • measurable categories

  • explicit exclusions

  • transparent assumptions

  • and serious public scrutiny

That is why this page exists. And that is why the proposal deserves to be debated on the evidence, not just on instinct.

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