Health Care Reform to be Funded with Evergreen Proposals

According to a briefing service I get at work, the $1 trillion health care overhaul bill just released in the House would be paid for mostly by the surtaxes on the "rich", but also with a few other offsets that keep finding their way into various legislation from time to time.

The offsets are as follows:

--$540 billion from a surtax on households earning more than $350,000 (starting at 1% for couples earning >350K, 1.5% for couples earning b/w 500K and 1M and 5.4%!!!! for couples earning more than 1M.  This would bring the top marginal rate post-expiration of Bush's tax cuts to 45%;

--$8.1 billion from the codification of the economic substance doctrine;

--$22.3 billion from a delay of the implementation date of the worldwide interest allocation provision put into law in 2004; and

-- unclear amounts from provisions relating to sale-in, lease-out transactions.

Now, I'm no mathematician, but those numbers aren't going to add up to $1 trillion, which makes me think that included in the offsets must be the limitation on itemized deductions for high-earners.  We'll see once the bill comes out.  That 45% top marginal rate will be the headline in tomorrow's news though.

Update: More here at the taxprof blog.