Abstract: This report analyzes a proposal, recently published by the Hamilton Project of the Brookings Institution, for a new division of the tax base between businesses and individuals. The discussion proceeds in three steps: a review of certain equivalences that underlie the logic of the proposal, a brief examination of 10 related divisions of the tax base, and an analysis of the major components of the proposal. The principal conclusions of the report are that the objectives of the tax proposed for businesses could be more simply accomplished with expensing; that the tax proposed for individuals is impractical; that the tax subsidy proposed for foreign investment by U.S. companies is undesirable; and that the rationale for applying graduated rates to some, but not all, components of capital income is not apparent.