Tax Expenditure

A tax expenditure is a revenue loss from a special tax provision. See the statutory definition, why the estimates cannot be added, and what repeal would raise.

Written by AccountablyReviewed by Jugal Thacker, CPA6 minute readUpdated

A tax expenditure is a revenue loss the federal government takes on by writing a preference into the tax law rather than by spending money directly. The term is defined by statute: tax expenditures means those revenue losses attributable to provisions of the Federal tax laws which allow a special exclusion, exemption, or deduction from gross income or which provide a special credit, a preferential rate of tax, or a deferral of tax liability (2 U.S.C. 622(3)). The same section defines the tax expenditures budget as an enumeration of such tax expenditures (2 U.S.C. 622(3)).

The word expenditure is doing deliberate work. These exceptions are often viewed as alternatives to other policy instruments, such as spending or regulatory programs (US Department of the Treasury, Tax Expenditures), so the concept treats a tax break as a form of spending that happens to be delivered through the return rather than through an appropriation.

The Five Forms a Preference Can Take

The definition is a closed list, and it is worth reading as one, because it settles what does and does not get counted. A provision is a tax expenditure if it allows a special exclusion from gross income, a special exemption, a special deduction, a special credit, a preferential rate of tax, or a deferral of tax liability (2 U.S.C. 622(3)).

Every one of those is a mechanism a return preparer already handles from the other direction. The taxpayer-side entries for the ones a firm meets most are above-the-line deductions, the standard deduction, the SALT deduction, the QBI deduction and tax credit. What makes any of them a tax expenditure is not the return, it is the budget-side accounting of what the provision costs the Treasury.

What the Estimates Do Not Mean

This is where the term is most often misused, and the publisher of the estimates is unusually direct about it.

Repeal would not raise the money. Tax expenditure estimates do not include the effects of changes in economic behavior, they are for fully phased in tax changes so the revenue from repeal over a typical ten-year budget window can differ, and they account only for changes in income taxes, so changing a provision may affect payroll or estate taxes the estimate never looked at (US Department of the Treasury, Tax Expenditures).

The estimates also assume taxpayers do not change what they do. Generally the estimates assume that taxpayers do not alter their choices about what activities to undertake, although they do allow tax form behavior as taxpayers attempt to minimize tax liability, so the mortgage interest estimate lets a taxpayer switch to the standard deduction if that is better for them (US Department of the Treasury, Tax Expenditures).

They Cannot Be Added Together

A total is not published, and that is a methodological position rather than an oversight. An important assumption underlying each estimate is that other parts of the Tax Code remain unchanged, and because of interactions between provisions it is generally not correct to add separate tax expenditures for each provision to obtain a total for repealing all at once (US Department of the Treasury, Tax Expenditures).

The interactions run both ways. Taken individually, the itemized deductions for charitable contributions, mortgage interest and state and local taxes sum to more than they do jointly, because repealing all of them at once makes the standard deduction the better answer for more taxpayers. Taken jointly, income exclusions can sum to more than their individual estimates, because removing them together pushes taxpayers into higher brackets (US Department of the Treasury, Tax Expenditures).

So any figure presented as the total cost of tax expenditures is an addition the publisher says should not be performed.

Why Some of Them Raise Revenue

An estimate can come out negative, which reads as a tax break that collects money. Timing explains it. A provision properly thought of as a tax subsidy can take a negative value in some years because provisions that accelerate deductions or defer the recognition of income have offsetting revenue impacts over time, and for those the present value estimate is a more meaningful measure of the cost (US Department of the Treasury, Tax Expenditures).

That is a different thing from a negative tax expenditure, which is the name sometimes given to a revenue increasing provision, since the Budget Act defines a tax expenditure as a revenue losing provision of tax law (US Department of the Treasury, Tax Expenditures). Two different meanings, one adjective, and they are worth keeping apart in any sentence that uses it.

The two measures behind that also differ. Current revenue effects report the annual cash flow value, incorporating the effects of withholding, estimated payments and the timing of filing, while the present value is a summary measure of the revenue effects over a number of years discounted to the present, which is especially helpful where the provision involves deferral (US Department of the Treasury, Tax Expenditures).

What the Largest Ones Are

The list is dominated by exclusions rather than by the deductions that get the attention. On the fiscal year 2026 estimates the largest are the exclusion of employer contributions for medical insurance premiums and medical care at $296 billion, the exclusion of net imputed rental income at $157 billion, defined contribution employer plans at $156 billion, and capital gains other than agriculture, timber, iron ore and coal at $135 billion (US Department of the Treasury, Tax Expenditures).

Estimates are made relative to current law as of July 1 of the calendar year the latest estimates are released (US Department of the Treasury, Tax Expenditures), so a figure quoted without its vintage has already lost part of its meaning.

Where a Firm Meets the Term

Not on a return. No taxpayer ever has a tax expenditure, claims one or reports one, and no line on any form is captioned with the phrase. It is a budget term for the cost of a provision, and the provision itself reaches the client as an ordinary exclusion, deduction, credit, rate or deferral.

Where it does turn up is in the policy conversation around a client’s planning, usually when a provision a client relies on is described in the press as costing the government a stated amount. Two things are worth saying when that happens. The figure is an estimate built on an assumption that behavior does not change, and it is not what repeal would collect.

Common Questions

The exclusion of employer contributions for medical insurance premiums and medical care, which is the largest single one on the fiscal year 2026 estimates at $296 billion (US Department of the Treasury, Tax Expenditures). It qualifies because it is a special exclusion from gross income, which is the first of the forms the statute names (2 U.S.C. 622(3)).

Only where it is a special one. The statute reaches a special exclusion, exemption or deduction from gross income rather than every deduction in the Code (2 U.S.C. 622(3)), so a deduction that is part of the normal measurement of income is not a preference and is not counted as one.

Accountably places trained offshore accountants and tax preparers inside US CPA and EA firms, and a firm can put a block of its own return preparation and research work through a trial task so its reviewers stay on the judgment calls.

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