We Can End Property Taxes
This article is being updated with new data after the release of 2025 actual tax revenues and expenditures, and new Federal data pertaining to the Texas economy. Sections of the plan are in draft form and this article will be updated as the plan is finalized.
The current article has the updated numbers, and the overall plan, but is still in draft form.
About 75% complete as of May 13, 2026.
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This article is designed to be updated periodically as new data becomes available and as new challenges to the plan are put forward. Please check back periodically for updates - Don’t hesitate to contact us if you see anything that requires correction by emailing us at: communication@willcampbellfortexas.com
By Will Campbell · May 26, 2026 · Texas Property Tax Replacement Plan
The Texas Property Tax Replacement Plan: A Complete Guide to Ending Property Taxes in Texas
A data-driven, primary-source-grounded blueprint for replacing every property tax in Texas — state, county, city, ISD, and special district — with a unified 5-tier sales-and-use tax. No exemptions for special interests. No carve-outs for the powerful. Every Texan pays less.
Where Texas Tax Dollars Come From Today
The current tax system — who collects it, how much, and why property taxes are the core problem.
Texas is one of the few large states with no personal income tax. The Texas Constitution prohibits a state income tax on individuals — a prohibition reinforced by voter referendum. That structural choice shapes everything else: without income tax revenue, Texas depends on a layered combination of property taxes, sales taxes, and a set of narrowly targeted excise and business taxes to fund everything from schools to roads to emergency services at every level of government.
The Core Problem with Property Taxes
"Local governments are hiking your property taxes incessantly. It's time to drive a stake through the heart of local property tax hikes for good."— Governor Greg Abbott, reelection announcement, Houston, November 2025 ATPE, Nov. 2025
Property taxes are not merely a policy inconvenience — they are structurally defective in ways that no amount of rate-capping or appraisal reform can fix. Ad valorem property taxes are assessed on the value of an asset you already own, regardless of whether you have the income to pay them. A retired couple on a fixed income whose home has appreciated dramatically faces a rising tax bill with no corresponding increase in their ability to pay. They did not earn more money. They did not sell their home. They simply own something worth more — and the bill arrives anyway, every year, with no regard for their circumstances.
Property taxes are also a tax you can never fully escape. Even debt-free homeowners cannot actually own their property free and clear — every year the government requires payment to keep what they have already bought. Miss enough payments and the government can ultimately seize the home. Texas tax law places property tax liens ahead of virtually every other claim on a property. For the 4.05 million Texas renter households, the situation is equally burdensome — landlords pass property taxes through in higher rents, making renters effective property taxpayers who never see the bill and cannot contest their assessment. TCPA 96-463, Jan 2025
Every legislative session, Texas debates property tax relief — appraisal caps, homestead exemptions, rate rollback elections, circuit breakers. None of these reforms address the underlying problem: a tax on the assessed value of an asset you already own, billed annually regardless of income, is structurally incompatible with financial security and true property ownership. The Texas Property Tax Replacement Plan does not propose to reform property taxes. It proposes to end them permanently — by constitutional amendment — and replace them with a tax on economic activity, not on the privilege of owning what you have already paid for.
There are three distinct layers to the Texas tax system. The state layer — taxes collected directly by the State of Texas, led by the state sales and use tax. The local property tax layer — ad valorem taxes levied independently by counties, cities, independent school districts (ISDs), and special districts on the assessed value of real and personal property. And the local sales tax layer — add-on sales taxes collected by cities, counties, and special districts on top of the state's base rate. The data explorer below details each layer and entity type.
Texas government collects $185.0B per year across state taxes, local property taxes, and local sales taxes. Property taxes alone account for nearly half of all government revenue — and are collected by 7,144 separate local entities, none of which is the State of Texas.
| Layer / Entity Type | Property Tax | Sales / Other Tax | FY2025 Total | Share |
|---|---|---|---|---|
| State of Texas | — | $84,198M | $84,198M | 45.5% |
| 254 Counties | $16,791M | $878M | $17,669M | 9.5% |
| 1,225 Cities | $16,734M | $9,067M | $25,801M | 13.9% |
| 1,016 ISDs | $41,655M | — | $41,655M | 22.5% |
| 3,648 Special Districts | $14,267M | $1,451M | $15,718M | 8.5% |
| Total — All Entities | $89,446M | $95,594M | $185,040M | 100.0% |
Source. TX Comptroller PTAD TY2025 levy files A-1 through A-4; TX Annual Cash Report FY2025 B-1; TX Comptroller Local Sales Tax Allocations CY2025; BRB Annual Report 2025 K-1.
Texas collects state revenue across 12+ tax categories. The state sales and use tax dominates at 58.3% of all state revenue — but it applies to a narrow slice of economic activity taxed at 6.25%. The state levies no property tax. State bond debt service is funded from appropriated general revenue, not a dedicated rate.
| # | Tax Category | Rate / Basis | FY2025 Revenue | % of State |
|---|---|---|---|---|
| 1 | State Sales & Use Tax | 6.25% on taxable retail goods & services | $49,060,000,000 | 58.3% |
| 2 | Franchise (Margin) Tax | On gross margin of Texas businesses | $7,056,000,000 | 8.4% |
| 3 | Motor Vehicle Sales & Use Tax | 6.25% on vehicle purchases; 10% rentals | $6,844,000,000 | 8.1% |
| 4 | Oil Production Tax | 4.6% of market value of oil produced | $4,977,000,000 | 5.9% |
| 5 | Natural Gas Production Tax | 7.5% of market value of gas produced | $3,348,000,000 | 4.0% |
| 6 | Motor Fuels Tax | $0.20/gal gasoline & diesel | $3,958,000,000 | 4.7% |
| 7 | Alcoholic Beverage Tax | Excise on beer, wine, and liquor | $1,697,000,000 | 2.0% |
| 8 | Insurance Premiums Tax | On premiums written by TX-licensed insurers | $1,589,000,000 | 1.9% |
| 9 | Cigarette & Tobacco Tax | $1.41/pack cigarettes; additional on other tobacco | $1,004,000,000 | 1.2% |
| 10 | Hotel Occupancy Tax | 6% of hotel room charge | $692,000,000 | 0.8% |
| 11 | Utility Tax | Electric, gas, telecom utility receipts | $596,000,000 | 0.7% |
| 12 | Other State Taxes & Fees | Racing, bingo, inheritance, misc. excise | $376,809,115 | 0.4% |
| Total State Tax Revenue — FY2025 | $84,197,809,115 | 100.0% | ||
Note. State GO bond debt service (~$714M/yr) is funded from general revenue appropriations — no dedicated I&S rate. Source: TX Comptroller Annual Cash Report FY2025, Table 3. Annual Cash Report
Each of Texas's 254 counties sets its own property tax rate through its commissioners court — an M&O rate for operations and an I&S rate for bond debt service. Counties may also levy a local option sales tax up to 0.50%. The bond I&S levy directly funds annual principal and interest payments on voter-approved general obligation bonds.
| Revenue Component | Basis | TY/FY2025 Amount | Notes |
|---|---|---|---|
| M&O Property Tax Levy | Ad valorem — M&O rate, assessed property value | $14,943,035,519 | Day-to-day county operations |
| I&S Property Tax Levy | Ad valorem — bond debt service rate | $1,847,790,862 | Annual payment on voter-approved GO bonds |
| Total Property Tax Levy | M&O + I&S | $16,790,826,381 | Certified PTAD levy — 18.8% of statewide total |
| Annual Bond Debt Service | Principal + interest on outstanding bonds | $3,847,912,041 | Funded via I&S levy; ~22.9% of county levy |
| Local Option Sales Tax | Up to 0.50%; Texas Tax Code §323 | $878,000,000 | ~77% of counties levy a local sales tax |
| Total County Revenue | $17,668,826,381 | Property tax + local sales tax | |
Source. TX Comptroller PTAD 2025 County Rates & Levies; TX Bond Review Board Annual Report 2025 BRB 2025; TX Comptroller Local Sales Tax Allocations CY2025.
Cities are the only entity type with substantial revenue from both property taxes and local sales taxes. The local sales tax (up to the 2.0% combined local cap) is cities' second-largest revenue source, and cities collect the largest share of all local sales taxes in Texas by a wide margin.
| Revenue Component | Basis | TY/FY2025 Amount | Notes |
|---|---|---|---|
| M&O Property Tax Levy | Ad valorem — M&O rate | $13,773,434,200 | Police, fire, public works, general operations |
| I&S Property Tax Levy | Ad valorem — bond debt service rate | $2,960,435,688 | Voter-approved GO bonds for capital improvements |
| Total Property Tax Levy | M&O + I&S | $16,733,869,888 | Certified PTAD levy — 18.7% of statewide total |
| Annual Bond Debt Service | Principal + interest on outstanding bonds | $5,276,789,434 | ~31.5% of total city property tax levy |
| Local Sales Tax | Up to 2.0% combined local cap; Tax Code §321 | $9,067,000,000 | Largest local sales tax collector in Texas |
| Total City Revenue | $25,800,869,888 | Property tax + local sales tax | |
Source. TX Comptroller PTAD 2025 City Rates & Levies; TX Bond Review Board Annual Report 2025; TX Comptroller Local Sales Tax Allocations CY2025.
ISDs are the single largest category of property tax collector in Texas — more than counties and cities combined. ISD property taxes fund day-to-day school operations (M&O) and school construction bonds (I&S). ISDs do not levy a local sales tax. The state supplements ISD funding through the Foundation School Program (FSP), sourced from state general revenue.
| Revenue Component | Basis | TY2025 Amount | Notes |
|---|---|---|---|
| M&O Property Tax Levy | Ad valorem — M&O rate (recapture applies) | $29,223,209,072 | Salaries, operations; subject to Robin Hood recapture |
| I&S Property Tax Levy | Ad valorem — voter-approved bond rate | $12,431,375,477 | School construction, renovation, equipment bonds |
| Total ISD Property Tax Levy | M&O + I&S | $41,654,584,549 | 46.6% of total statewide property tax levy |
| Annual Bond Debt Service (I&S) | Principal + interest on outstanding school bonds | $12,431,224,477 | Largest bond service category in Texas |
| State Foundation School Program | State general revenue transfer; not a local tax | $23,622,909,091 | Context only — state appropriation, not ISD levy |
| Total ISD Revenue (Local Levy Only) | $41,654,584,549 | Property tax levy; FSP is separate state funding | |
Source. TX Comptroller PTAD 2025 ISD Rates & Levies; TX Bond Review Board Annual Report 2025; LBB Fiscal Size-Up FY2024-25.
Texas has more special-purpose districts than any other state — MUDs, hospital districts, emergency services districts, navigation districts, transit authorities, port authorities, and dozens of other types. Most Texans are paying property taxes to multiple special districts they cannot name and have never voted in. Most special districts levy both M&O and I&S rates; transit authorities and port authorities additionally levy a local sales tax.
| Revenue Component | Basis | TY/FY2025 Amount | Notes |
|---|---|---|---|
| M&O Property Tax Levy | Ad valorem — M&O rate (varies by district type) | $12,234,974,299 | Operations across all district types |
| I&S Property Tax Levy | Ad valorem — bond service rate | $2,031,829,731 | Particularly heavy in MUDs funding new infrastructure bonds |
| Total Special District Property Tax | M&O + I&S | $14,266,804,030 | Certified PTAD levy — 15.9% of statewide total |
| Annual Bond Debt Service | Principal + interest on outstanding bonds | ~$2,031,829,731 | Primarily MUD infrastructure; I&S levy closely tracks actual debt service |
| Local Sales Tax (select districts) | Transit authorities, port authorities — enabling acts | $1,451,000,000 | METRO (Houston), VIA (San Antonio), RTA, port authorities |
| Total Special District Revenue | $15,717,804,030 | Property tax + local sales tax | |
Source. TX Comptroller PTAD 2025 Special District Rates & Levies; TX Bond Review Board Annual Report 2025 BRB 2025; TX Comptroller Local Sales Tax Allocations CY2025.
The Household Burden
What every Texan actually pays — the visible bill and the hidden cost.
The true tax burden on Texas households is substantially heavier than most families realize, for a simple reason: most Texans only see part of the bill. The visible portion — the property tax statement mailed once a year to homeowners, plus the sales tax line on retail receipts — is Level 1 (L1). But there is a second layer, Level 2 (L2), that includes commercial property tax pass-throughs: the embedded property taxes paid by landlords, retailers, manufacturers, and service providers that are silently built into every rent payment and every price tag.
The Level 1 burden for homeowners is their direct annual property tax bill plus their current state and local sales tax cost. For renters, Texas Comptroller economic incidence research documents that approximately 18.5% of the landlord's property tax is passed through to the renter via higher rents. [TCPA 96-463, Jan 2025] This means renters are paying property taxes — they just don't know it. The bill arrives as a line item labeled “rent,” not “property tax.”
The Level 2 burden adds 50% of commercial property tax pass-throughs — the fraction of retail prices, service fees, and consumer goods costs attributable to property taxes paid by the businesses that sell those goods. Retailers pay property tax on their stores. Manufacturers pay property tax on their factories. Restaurants pay property tax on their buildings. Every dollar of property tax paid by a business is ultimately embedded in the prices of the products and services consumers buy. The TPTRP methodology uses the 50% commercial pass-through rate documented in the TCPA incidence research as the Level 2 adjustment. [TCPA 96-463]
The current combined state and local sales tax stands at 8.25% (6.25% state rate plus up to 2.0% local rate) for consumers in localities at the cap. This places Texas among the highest combined sales tax rate jurisdictions in the United States. For households in the lower income quintiles, who spend a higher fraction of their income on taxable consumption, the effective sales tax burden as a share of income is disproportionately large — a structural regressivity problem built into the current system.
The regressivity of the current combined tax burden is stark. Bureau of Labor Statistics Consumer Expenditure Survey data for Texas, 2022–23 — escalated to 2025 dollars using the Bureau of Economic Analysis Texas GDP growth factor of 1.13183 — shows that the bottom income quintile (Q1) pays approximately 27.9% of pre-tax income in combined L1 property tax and state+local sales tax burden, while the top quintile (Q5) pays approximately 7.6%. [BLS CE TX 2022-23] [BEA SAGDP2 TX] The property-tax-only regressivity ratio — comparing each quintile's direct property tax burden as a share of income — is 5.2×: Q1 households pay 14.5% of income in property taxes (direct or renter pass-through) while Q5 households pay only 2.8%. This is one of the most regressive state and local tax structures in the country.
The property-tax regressivity ratio under the current Texas system is 5.2×: the bottom quintile of Texas earners pays 14.5% of income in property taxes — directly or through rent — while the top quintile pays only 2.8%. When current sales taxes are added, Q1's combined L1 burden rises to 27.9% of income versus Q5's 7.6% — about a 3.7-to-1 gap on the combined measure. This is among the most regressive state tax structures in the United States. The TPTRP's 12-category Texas Living Essentials Standard (TLES) is specifically designed to invert this regressivity by permanently exempting the spending categories that consume the greatest share of lower-income household budgets.
The hidden weight of the property tax is only half of the picture. Once the current 8.25% sales tax is layered on top, the combined burden on the lowest-income Texans becomes severe — and the gap between what the poorest and wealthiest households surrender to the state widens dramatically.
Texas has approximately 4.05 million renter households — about 37.6% of the state's 10.75 million occupied households — per the U.S. Census Bureau's American Community Survey 2019–2023 five-year estimates. [ACS 2019-2023 DP04] Not one of these households ever receives a property tax bill. But every one of them is paying a property tax — embedded in their rent, invisible on the statement, and impossible to contest. The Texas property tax protest system, which allows property owners to challenge their assessed values, is structurally unavailable to renters. They pay the tax without recourse.
Property tax is also a regressive wealth tax in a deeper sense: it is assessed on the value of real property regardless of the owner's income or ability to pay. A household earning $40,000 per year and a household earning $400,000 per year occupying identically valued homes pay exactly the same property tax bill. The tax is indifferent to income. For low- and moderate-income homeowners, particularly elderly Texans on fixed incomes, the annual property tax bill represents a much larger share of disposable income than it does for wealthier households — and when appraisals rise, as they have dramatically across Texas over the past decade, that burden rises with them regardless of whether income has kept pace.
The current combined property-tax and sales-tax burden on Texas households, in 2025 dollars. L1 = direct PT bill (owner) or 18.5% renter pass-through, plus the current 8.25% combined sales tax. L2 adds the 50% commercial property-tax pass-through embedded in everyday prices.
| Quintile | Avg Income (2025$) | L1 PT Burden | Current ST | L1+ST Total | L1+ST % Income | L2+ST Total | L2+ST % Income |
|---|---|---|---|---|---|---|---|
| Q1 Lowest 20% | $15,044 | $2,182 | $2,021 | $4,203 | 27.9% | $5,107 | 33.9% |
| Q2 Second 20% | $39,679 | $3,016 | $3,084 | $6,100 | 15.4% | $7,391 | 18.6% |
| Q3 Middle 20% | $68,731 | $3,469 | $3,735 | $7,204 | 10.5% | $8,772 | 12.8% |
| Q4 Fourth 20% | $117,243 | $4,569 | $5,490 | $10,059 | 8.6% | $12,134 | 10.3% |
| Q5 Highest 20% | $230,158 | $7,216 | $10,226 | $17,442 | 7.6% | $19,758 | 8.6% |
| All HH avg | $103,108 | $4,150 | $4,997 | $9,147 | 8.9% | $10,955 | 10.6% |
Source. BLS Consumer Expenditure Survey TX 2022–23 quintile tables [G-8]; BEA SAGDP2 TX escalator 1.13183 [G-9]; TCPA 96-463 pass-through rates [B-10]. Note. L1 PT = direct property tax (BLS owner PT line) or 18.5% renter pass-through per TCPA 96-463 midpoint, applied to BLS rent expenditure by quintile. Current ST = 8.25% combined state+local rate applied to taxable spending after current-law exemptions (groceries, Rx, residential rent, utilities, medical). L2 adds the 50% commercial PT pass-through on the non-residential property-tax levy distributed proportionally across quintiles by TPTRP-taxable consumption proxy. All dollar figures in 2025$; BLS raw 2022–23 figures escalated via BEA SAGDP2 TX × 1.13183.
What Texas households across each income quintile actually spend their money on, in 2025 dollars. The spending structure — particularly the high share of non-discretionary spending in Q1 and Q2 — drives the structural progressivity of the TPTRP's TLES exemptions.
| Spending Category | Q1 $15,044 | Q2 $39,679 | Q3 $68,731 | Q4 $117,243 | Q5 $230,158 | All HH Avg |
|---|---|---|---|---|---|---|
| Total Expenditures (2025$) | ||||||
| Total Expenditures | $38,852 | $53,927 | $62,536 | $86,923 | $147,199 | $79,004 |
| Housing | ||||||
| Owned dwellings (mortgage, taxes, ins., maint.) | $1,317 | $3,051 | $7,098 | $13,774 | $28,173 | $10,271 |
| Rented dwellings | $6,297 | $6,975 | $5,709 | $6,381 | $4,482 | $5,947 |
| Utilities, fuels, public services | $4,830 | $5,127 | $5,015 | $5,469 | $6,382 | $5,319 |
| Food | ||||||
| Food at home (groceries) | $4,759 | $5,736 | $6,214 | $7,575 | $10,978 | $6,991 |
| Food away from home | $2,534 | $3,300 | $4,074 | $5,070 | $8,567 | $4,642 |
| Transportation | ||||||
| Vehicle purchases (net outlay) | $1,904 | $3,520 | $4,149 | $5,495 | $8,437 | $4,610 |
| Gasoline, other fuels | $1,998 | $2,874 | $3,165 | $3,867 | $5,511 | $3,467 |
| Other vehicle expenses | $2,840 | $3,580 | $4,597 | $6,083 | $9,499 | $5,218 |
| Healthcare | ||||||
| Health insurance | $3,170 | $3,955 | $4,338 | $5,195 | $7,603 | $4,788 |
| Medical services & drugs | $1,103 | $1,422 | $1,657 | $1,883 | $2,819 | $1,773 |
| Other Spending | ||||||
| Apparel & services | $961 | $1,549 | $1,994 | $2,619 | $5,113 | $2,410 |
| Entertainment | $1,306 | $2,086 | $2,971 | $3,883 | $7,712 | $3,617 |
| Education | $474 | $715 | $1,051 | $1,513 | $4,038 | $1,556 |
| Personal insurance & pensions | $694 | $3,342 | $6,753 | $13,541 | $24,760 | $9,025 |
| All other | $2,862 | $4,195 | $5,747 | $8,576 | $13,118 | $6,899 |
| Current PT + ST Tax Burden (L1) | $4,203 | $6,100 | $7,204 | $10,059 | $17,442 | $9,147 |
| Tax Burden as % of Income | 27.9% | 15.4% | 10.5% | 8.6% | 7.6% | 8.9% |
Source. BLS CE TX 2022–23 [G-8]. All figures escalated to 2025$ via BEA SAGDP2 TX ×1.13183 [G-9]. Tax burden from TCPA 96-463 [B-10].
Household spending organized into five policy-relevant categories showing what share of each quintile's budget falls into TLES-protected (essential) vs. taxable categories under the TPTRP. Lower-income households have a far higher share of TLES-protected spending — which is why the TPTRP's flat rate is structurally progressive.
| Policy Category | Q1 | Q2 | Q3 | Q4 | Q5 | All HH |
|---|---|---|---|---|---|---|
| TLES-Protected Spending (total) | $19,340 | $23,192 | $26,272 | $31,071 | $37,752 | — |
| as % of total spending | 43.4% | 37.2% | 35.1% | 29.0% | 21.4% | — |
| Cat 1 — Mortgage & Rent (housing cost) | $7,614 | $10,026 | $12,807 | $20,155 | $32,655 | $16,218 |
| % of total spending | 19.6% | 18.6% | 20.5% | 23.2% | 22.2% | 20.5% |
| Cat 2 — Gas & Groceries | $6,757 | $8,610 | $9,379 | $11,442 | $16,489 | $10,458 |
| % of total spending | 17.4% | 16.0% | 15.0% | 13.2% | 11.2% | 13.2% |
| Cat 3 — Direct Property Taxes (owner BLS line) | $1,017 | $1,726 | $2,413 | $3,388 | $7,216 | $3,049 |
| Cat 4 — Discretionary & Durable Goods | $9,289 | $8,938 | $14,124 | $19,984 | $38,694 | $18,491 |
| Cat 5 — Services, Insurance, Healthcare & Transfers | $12,524 | $18,683 | $23,961 | $36,932 | $72,185 | $32,795 |
| Q_TAXABLE (TPTRP base, post 12-TLES) | $19,512 | $30,935 | $36,264 | $55,852 | $109,742 | $51,392 |
| Q_TAXABLE as % of total spending | 50.2% | 57.4% | 58.0% | 64.3% | 74.5% | 65.1% |
Source. BLS CE TX 2022–23 [G-8], escalated to 2025$. TLES-protected spending = groceries, residential rent, utilities, gas at pump, prescription drugs, medical care, education, childcare, primary-residence home purchase, residential property insurance, auto insurance, life insurance (TLES-1 through TLES-12). Q_TAXABLE = total expenditures minus TLES-protected spending per TPTRP Master Plan v11 methodology.
The MIT Living Wage Calculator establishes the minimum annual income needed to cover basic living expenses in Dallas County without public assistance. Three of the five Texas income quintiles — and the median HD109 household — fall below the MIT survival floor for a family of four, and those same groups carry the highest property tax burden as a share of income.
| Household / Quintile | Annual Income (2025$) | MIT Benchmark | Income as % of Floor | L1 PT Burden | PT as % of Income | Below MIT Floor? |
|---|---|---|---|---|---|---|
| Q1 — Lowest 20% | $15,044 | $48,489 | 31.0% | $2,182 | 14.5% | Yes — $33,445 short |
| Q2 — Second 20% | $39,679 | $48,489 | 81.8% | $3,016 | 7.6% | Yes — $8,810 short |
| Q3 — Middle 20% | $68,731 | $80,866 | 85.0% | $3,469 | 5.0% | Yes — $12,135 short |
| Q4 — Fourth 20% | $117,243 | $80,866 | 145.0% | $4,569 | 3.9% | No |
| Q5 — Highest 20% | $230,158 | $80,866 | 284.6% | $7,216 | 3.1% | No |
| HD109 Median HH (ACS $57,836) | $57,836 | $80,866 | 71.5% | $5,225 | 9.0% | Yes — $23,030 short |
| MIT 2A 1Wkg 2Ch (canonical TPTRP family) | $80,866 | $80,866 | 100.0% | $5,225 | 6.5% | At floor |
Sources. MIT Living Wage Calculator, Dallas County, TX, Feb 15 2026 [G-15]. BLS CE TX 2022–23 quintile income, escalated to 2025$ via BEA SAGDP2 TX ×1.13183 [G-8]. HD109 median HH income: ACS 2019–23 via TX Legislative Council PLANH2316 [H-2]. HD109 PT: TX Comptroller PTAD TY2025 rate 2.0265% × avg home $257,838 [A-1]. Q1 MIT benchmark = 1A 0Ch; Q2–Q5 = 2A 1Wkg 2Ch per canonical TPTRP family archetype.
Renters pay a hidden property tax embedded in their monthly rent — with no bill, no protest right, and no equity in return. The gap between what Q1 renters and Q1 owners pay in effective property tax burden is the structural inequity that the TPTRP's TLES-2 residential rent exemption directly eliminates.
| Quintile | Owner Avg PT (direct) | Owner % Income | Renter Pass-Through (18.5%) | Renter % Income | Gap (Renter − Owner) |
|---|---|---|---|---|---|
| Q1 Lowest 20% | $1,017 | 6.8% | $1,165 | 7.7% | +$148 / +0.9 pp |
| Q2 Second 20% | $1,726 | 4.4% | $1,290 | 3.3% | −$436 / −1.1 pp |
| Q3 Middle 20% | $2,413 | 3.5% | $1,056 | 1.5% | −$1,357 / −2.0 pp |
| Q4 Fourth 20% | $3,388 | 2.9% | $1,181 | 1.0% | −$2,207 / −1.9 pp |
| Q5 Highest 20% | $7,216 | 3.1% | $830 | 0.4% | −$6,386 / −2.7 pp |
| All HH avg | $3,049 | 3.0% | $1,101 | 1.1% | −$1,948 / −1.9 pp |
HD109 has a 28.5% renter population (ACS 2019–23). A Q1 renter in HD109 pays approximately $1,165/yr in hidden property tax through rent — with no bill, no protest right, and no deduction. Under TPTRP, residential rent is TLES-2 exempt. The landlord's property tax disappears, and the tenant's hidden tax disappears with it. [TCPA 96-463] [H-2]
Sources. BLS CE TX 2022–23 owner PT and renter expenditure by quintile, escalated to 2025$ [G-8]. Renter pass-through = 18.5% of annual rent per TCPA 96-463 midpoint [B-10]. HD109 renter rate: ACS 2019–23 via TLC PLANH2316 [H-2].
The Plan
Abolish property taxes in Texas. Replace them with a fair, transparent, and broad-based sales-and-use tax.
The Texas Property Tax Replacement Plan proposes to do something that has never been done at scale in American government: eliminate the entire ad valorem property tax system — at every level — by amending the Texas Constitution to make ad valorem property taxes unconstitutional. Not reduced. Not capped. Ended. Article VIII of the Texas Constitution would be amended to add a new §1-e prohibiting all ad valorem taxes on real or personal property in the state of Texas, in perpetuity, by any governmental entity at any level.
In its place, the TPTRP establishes a unified 5-tier sales-and-use tax applied to all economic transactions in Texas. The critical distinction from the current sales tax is scope: the TPTRP applies to all transactions — business-to-business, manufacturing chain, wholesale, service, and retail — not just retail consumer purchases. The current Texas state sales tax exempts enormous categories of economic activity for reasons ranging from administrative convenience to decades of special-interest lobbying. The TPTRP ends all of those exemptions, with one deliberately limited set of exceptions: the 12-category Texas Living Exemption Set (TLES), described below.
The TPTRP is structured around a simple, unassailable principle: equal treatment under the tax law. Every transaction, every sector, every industry pays the same rate. No industry earns a carve-out by hiring a lobbyist. No sector receives a special exemption because it is politically connected. The oil and gas industry pays. The financial services industry pays. Agricultural wholesale transactions pay. Technology sector B2B transactions pay. The manufacturing supply chain pays at each stage. The rate is the same for all. The only exception is the TLES — and the TLES is built to protect what every family needs to survive, not what any industry wants to protect.
The 12 TLES categories are the product of careful analysis of Texas household spending by income quintile, cross-referenced against the categories most likely to create hardship if taxed. They are: TLES-1 Groceries ($97.19B annually — food security); TLES-2 Residential Rent ($71.02B — housing stability); TLES-3 Home Utilities ($40.60B — basic necessities: electricity, gas, water); TLES-4 Prescription Drugs ($41.56B — health necessity); TLES-5 Medical Care ($340.0B — all out-of-pocket costs plus insurance); TLES-6 Education ($32.98B — K-12 private tuition and public higher education tuition); TLES-7 Gas at the Pump ($63.50B — working family transportation); TLES-8 Childcare ($19.15B — working family necessity); TLES-9 Primary Residence Home Purchase ($93.26B — homeownership access); TLES-10 Residential Property Insurance ($20.19B — homeowners and renters insurance premiums, preventing double-taxation on insured assets); TLES-11 Personal Auto Insurance ($32.12B — mandatory liability coverage required by Texas law under TX Transp. Code §601.072); and TLES-12 Individual Life Insurance ($15.45B — individual life and annuity premiums). Total TLES protection: $867,012,967,203 per year — $867.0 billion in annual spending that is completely off the tax table.
The 5-tier rate structure mirrors the existing governance architecture of Texas. Tier 1 is the State. Tier 2 encompasses the 254 counties plus 1,284 county-absorbed special districts. Tier 3 is the 1,225 cities plus 2,864 city-absorbed special districts. Tier 4 covers the 1,016 ISDs plus the education funding reallocation from Tier 1. Tier 5 administers the 500 statewide special districts through a TPTRP-governed pool. Each tier has its own rate component, set by the TPTRP Implementation Act and the Constitutional Cap. The five rates stack to produce the total per-transaction rate that any given consumer or business sees on a transaction in that jurisdiction.
The constitutional amendment is the keystone of the plan. Without it, property taxes could simply return — whether through legislative action, judicial interpretation, or regulatory expansion. The amendment makes property taxation permanently unconstitutional in Texas and simultaneously establishes the Constitutional Cap Rate (CCR) of 6.00% as the maximum combined TPTRP rate any government at any level may impose. Today's 8.25% combined sales tax cap is replaced by a 6.00% ceiling — and the locked Starting Cap Rate of 3.25% is far below that ceiling.
The implementing legislation — a five-bill package filed in the Texas Legislature — establishes the rate structure, defines the TLES, creates the Texas Property Tax Replacement Transition Board, and protects bondholders whose existing bond covenants pledge property tax revenues. The transition is orderly, legally sound, and fully funded from Day 1. No government entity goes a single day without its full revenue equivalent.
This is not a speculative or untested concept. Broad-based transaction taxes fund governments across the developed world — Australia's 10% GST, Canada's 5% GST, New Zealand's 15% GST all demonstrate that unified broad-base transaction taxes are fiscally stable, administratively efficient, and economically sustainable. The TPTRP's 3.25% Starting Cap Rate is lower than every one of those international comparators, applied to a transaction base that is exceptionally large relative to Texas's government obligations. The math works. The data is public. The plan is open for scrutiny.
Your property tax bill goes to zero. Your combined sales tax rate drops from 8.25% to 3.25% at the locked starting rate. You never pay a property tax assessor again. You never file a protest. You never worry about your assessed value rising faster than your income. The annual anxiety of the property tax cycle — for 11 million Texas households — ends permanently.
TLES-1 Groceries — $97.19B/yr. Food at home. No family should pay a transaction tax on feeding itself.
TLES-2 Residential Rent — $71.02B/yr. Housing stability for 4.05M renter households. Today's 18.5% PT pass-through ends.
TLES-3 Home Utilities — $40.60B/yr. Electricity, gas, and water. Basic necessities for every Texas home.
TLES-4 Prescription Drugs — $41.56B/yr. Medically necessary drugs should never be taxed.
TLES-5 Medical Care — $340.0B/yr. All out-of-pocket and insured healthcare costs. Texans should not pay a consumption tax on staying alive.
TLES-6 Education — $32.98B/yr. Private K-12 tuition and public higher education tuition. Investment in human capital.
TLES-7 Gas at the Pump — $63.50B/yr. Transportation for working families who have no alternative.
TLES-8 Childcare — $19.15B/yr. Working family necessity. Taxing childcare taxes employment itself.
TLES-9 Primary Residence Home Purchase — $93.26B/yr. Homeownership access. First-home purchase should not carry a new transaction tax burden.
TLES-10 Residential Property Insurance — $20.19B/yr. Homeowners and renters insurance premiums. Texans should not pay a transaction tax on protecting their homes. [NAIC 2024 TX]
TLES-11 Personal Auto Insurance — $32.12B/yr. Mandatory liability coverage required by Texas Transportation Code §601.072. Taxing legally required insurance taxes compliance with the law itself. [NAIC 2024 TX]
TLES-12 Individual Life Insurance — $15.45B/yr. Individual life and annuity premiums. Long-term financial protection for Texas families. [ACLI 2024]
Inspect the Data
All source data underlying this article, organized by topic. Each tab includes the primary data table and a methodology note.
Tax Base Derivation — 3-Stage Summary
How the $8.776T full transaction base is filtered and reduced to the $7.126T Stage 3 Final Taxable Base on which replacement rates are applied.
| Stage | Description | Amount ($) |
|---|---|---|
| Stage 1 | Full Tax Base (5-Component Hybrid Gross) | $8,776,294,863,705 |
| − | Definition Filter (federal/nonprofit exclusions) | −$783,038,000,000 |
| Stage 2 | Relevant Tax Base | $7,993,256,863,705 |
| − | TLES Deductions (12 categories) | −$867,012,967,203 |
| Stage 3 | Final Taxable Base (FTB) — Rate Applied Here | $7,126,243,896,502 |
| # | Category | Annual Value | Primary Source |
|---|---|---|---|
| TLES-1 | Groceries (food at home) | $97,185,000,000 | USDA ERS FAH 2025 |
| TLES-2 | Residential Rent | $71,024,000,000 | ACS 2019-2023 |
| TLES-3 | Home Utilities (elec, gas, water) | $40,598,000,000 | EIA EIA-861 2024 |
| TLES-4 | Prescription Drugs | $41,563,000,000 | CMS NHEA 2024 |
| TLES-5 | Medical Care (out-of-pocket + insurance) | $340,000,000,000 | CMS NHEA 2024 |
| TLES-6 | Education (K-12 private + public HE tuition) | $32,976,000,000 | SHEEO SHEF FY2024 |
| TLES-7 | Gas at the Pump | $63,500,000,000 | EIA TX Energy Profile 2025 |
| TLES-8 | Childcare | $19,150,000,000 | Child Care Aware 2025 |
| TLES-9 | Primary Residence Home Purchase | $93,255,194,072 | TX REALTORS 2025 + NAR 2024 |
| TLES-10 | Residential Property Insurance | $20,193,000,000 | NAIC 2024 TX Market Scorecard |
| TLES-11 | Personal Auto Insurance | $32,118,773,131 | NAIC 2024 TX Market Scorecard |
| TLES-12 | Individual Life Insurance | $15,450,000,000 | ACLI 2024 Fact Book |
| Total TLES Protection | $867,012,967,203 | ||
5-Tier TPTRP Rate Stack — AFR, SCR, and CCR
The three rate benchmarks for each tier: Aggregate Floor Rate (minimum), Starting Cap Rate (locked policy), and Constitutional Cap Rate (hard ceiling).
| Tier | Entities | TRO ($M) | AFR (%) | SCR (%) | CCR (%) |
|---|---|---|---|---|---|
| T1 State | 1 sovereign | $66,632M | 0.9350% | 1.0000% | 2.0000% |
| T2 Counties+SDs | 254 + 1,284 absorbed | $24,548M | 0.3444% | 0.4000% | 1.0000% |
| T3 Cities+SDs | 1,225 + 2,864 absorbed | $38,270M | 0.5370% | 0.6000% | 1.0000% |
| T4 ISDs+ed realloc | 1,016 ISDs | $71,805M | 1.0076% | 1.2000% | 1.5000% |
| T5 Statewide SDs | 500 SDs | $2,299M | 0.0323% | 0.0500% | 0.5000% |
| SUM | 7,144 governed entities | $203,554M | 2.8563% | 3.25% | 6.00% |
TPTRP Entity Registry — 7,144 Governed Entities
All Texas taxing entities by tier: sovereign entities and absorbed entities. Total governed entity universe under the TPTRP rate stack.
| Tier | Entity Type | Sovereign | Absorbed | Total | PT Revenue ($M) |
|---|---|---|---|---|---|
| T1 | State of Texas | 1 | — | 1 | — |
| T2 | Counties + absorbed county SDs | 254 | 1,284 | 1,538 | $16,791M |
| T3 | Cities + absorbed city SDs | 1,225 | 2,864 | 4,089 | $16,734M |
| T4 | ISDs (independent school districts) | 1,016 | — | 1,016 | $41,655M |
| T5 | Statewide special districts (TPTRP-administered) | 500 | — | 500 | $14,267M |
| TOTAL | 2,996 | 4,148 | 7,144 | $89,447M | |
Texas Local Government Bond Debt — TPTRP Transition Overview
Total outstanding bonded indebtedness, the absorbed share, and the annual debt service obligation that TPTRP absorbs and guarantees.
| Category | Total Outstanding | TPTRP Absorbed | Annual DS (FY2026) |
|---|---|---|---|
| State of Texas (T1) | $75,200M | — | — |
| Counties (T2) | $32,100M | $18,900M | $1,890M |
| Cities (T3) | $98,400M | $57,300M | $5,730M |
| ISDs (T4) | $157,600M | $141,200M | $11,280M |
| Special Districts (T5) | $79,250M | $45,830M | $3,369M |
| TOTAL | $442,550M | $263,230M | $22,269M |
Complete Source Registry — All Primary Data Sources
Every primary data source used in this article, with URLs, data category, and section usage. No advocacy organization commentary, no internal workbooks.
The Full Tax Base
How $7.128 trillion in annual Texas economic transactions become the replacement tax base.
The central technical achievement of the TPTRP is the construction of a credible, defensible, primary-source-grounded tax base. The Final Taxable Base (FTB) of $7,126,243,896,502 is not an estimate, a model projection, or an advocacy number — it is derived from official Texas and federal government data sources through a documented three-stage process.
Stage 1 — Full Tax Base: $8,776,294,863,705
Texas nominal GDP in 2025 is estimated at approximately $2.6 trillion. However, the transaction base — the sum of all observable economic transactions in the state, including business-to-business, manufacturing chain, wholesale, and intermediate transactions — is far larger than GDP. GDP measures final value added and nets out intermediate transactions to avoid double-counting. A gross transaction tax, by contrast, applies at every stage of the production chain. The appropriate base for a TPTRP-style tax is the Hybrid Gross Base: the observable total of all taxable transactions before any deductions. [BEA SAGDP2 TX]
The Stage 1 Full Tax Base of $8,776,294,863,705 is constructed from five components: C1 — In-state taxable sales (Texas Comptroller quarterly taxable sales data, Q3 2025 annualized) [B-4]; C2 — Oil and gas wellhead value (Texas Railroad Commission monthly production data × EIA wellhead price series) [D-1] [G-10]; C3 — Insurance premiums (Texas Department of Insurance Market Conduct Annual Report 2024, $83.07B) [F-1]; C4 — Real estate transaction value (Texas REALTORS 2025 annual market statistics) [I-1]; C5 — Banking and financial services value added (FDIC Texas bank statistics profile 2025) [G-14].
Stage 2 — Definition Filter: −$783,038,000,000 → Relevant Tax Base: $7,993,256,863,705
The Definition Filter removes transactions that are legally or practically outside the TPTRP's scope. These fall into three categories: federal government transactions (federal agencies operating in Texas are constitutionally exempt from state taxation under the Supremacy Clause); nonprofit organizational transfers (where no commercial exchange of value occurs); and intra-company accounting transfers that represent ledger movements rather than actual economic exchanges between independent parties. These are not productive economic transactions that represent real commercial activity — they do not belong in a commercial transaction tax base. After applying the Definition Filter, the Relevant Tax Base is $7,993,256,863,705.
Stage 3 — TLES Deductions: −$867,012,967,203 → Final Taxable Base: $7,126,243,896,502
The 12 TLES categories are deducted from the Relevant Tax Base to produce the Stage 3 Final Taxable Base (FTB) of $7,126,243,896,502. Each TLES category deduction is sourced to a specific primary data source. Medical Care at $340.0B is the largest, sourced from Centers for Medicare & Medicaid Services National Health Expenditure Accounts 2024. [G-12] Groceries at $97.19B are sourced from USDA Economic Research Service Food Expenditure Series. [G-13] Residential Rent at $71.02B is derived from ACS 2019-2023 median gross rent × renter household count. [G-6]
The combined TLES deduction of $867,012,967,203 is not an arbitrary round number — each line item is individually sourced and cross-referenced. The Stage 3 FTB of $7.126T is the base upon which all TPTRP rates are calculated. It is the foundation of the entire plan.
| Stage | Description | Amount |
|---|---|---|
| Stage 1 | Full Tax Base (5-component Hybrid Gross) | $8,776,294,863,705 |
| − | Definition Filter (federal, nonprofit, intra-company) | −$783,038,000,000 |
| Stage 2 | Relevant Tax Base | $7,993,256,863,705 |
| − | TLES Deductions (12 categories) | −$867,012,967,203 |
| Stage 3 | Final Taxable Base (FTB) | $7,126,243,896,502 |
| # | Category | Annual Value | Primary Source |
|---|---|---|---|
| TLES-1 | Groceries (food at home) | $97,185,000,000 | USDA ERS FAH 2025 |
| TLES-2 | Residential Rent | $71,024,000,000 | ACS 2019-2023 |
| TLES-3 | Home Utilities (elec, gas, water) | $40,598,000,000 | EIA EIA-861 2024 |
| TLES-4 | Prescription Drugs | $41,563,000,000 | CMS NHEA 2024 |
| TLES-5 | Medical Care (all out-of-pocket + insurance) | $340,000,000,000 | CMS NHEA 2024 |
| TLES-6 | Education (K-12 private + public HE tuition) | $32,976,000,000 | SHEEO SHEF FY2024 |
| TLES-7 | Gas at the Pump | $63,500,000,000 | EIA TX Energy Profile 2025 |
| TLES-8 | Childcare | $19,150,000,000 | Child Care Aware 2025 |
| TLES-9 | Primary Residence Home Purchase | $93,255,194,072 | TX REALTORS 2025 + NAR 2024 |
| TLES-10 | Residential Property Insurance (homeowners + renters) | $20,193,000,000 | NAIC 2024 TX Market Scorecard [L-1]; TDI 2025 Annual Report [F-2] |
| TLES-11 | Personal Auto Insurance (mandatory TX liability + all coverages) | $32,118,773,131 | NAIC 2024 TX Market Scorecard [L-1]; Insurify 2026 [L-4] |
| TLES-12 | Individual Life Insurance (individual life + annuity premiums) | $15,450,000,000 | ACLI 2024 Fact Book [L-6] |
| Total | TLES Protection | $867,012,967,203 |
Cross-Validation: Two Methods, One Answer
Independent verification that the $7.126T Final Taxable Base is sound.
Any tax base of the magnitude proposed in the TPTRP warrants rigorous independent validation. A single methodology, no matter how carefully constructed, can contain systematic biases, data gaps, or definitional errors that produce a plausible-looking but incorrect result. The TPTRP addresses this through a formal two-method cross-validation: a top-down Hybrid Gross Base approach and a bottom-up Input-Output reconstruction, applied independently and compared for convergence.
Method 1 — Hybrid Gross Base (top-down): Starting from all observable Texas economic transactions as reported by the Comptroller, the Railroad Commission, the Texas Department of Insurance, the Texas REALTORS association, and the FDIC, the full Stage 1 base is constructed by aggregating the five C-components described in Section 4. The Definition Filter is applied to remove out-of-scope transaction categories. The 12 TLES categories are deducted. The result is the Stage 3 FTB of $7,126,243,896,502. This is the primary derivation. [B-4]
Method 2 — Input-Output / Bottom-Up Reconstruction: The Bureau of Economic Analysis publishes State Annual GDP data (SAGDP) and associated input-output tables. [BEA SAGDP2 TX] Using the BEA Gross Output-to-GDP ratio for the Texas economy — which the BEA measures at approximately 2.5 to 3.0× GDP for a large manufacturing-and-energy state like Texas — and cross-referencing against the Texas Comptroller's quarterly taxable sales data broken out by NAICS sector, the bottom-up reconstruction of the transaction base converges on the same order-of-magnitude result as Method 1. The Input-Output approach yields a range centered on approximately $7.1T to $7.3T in post-TLES taxable transactions — directly consistent with the Stage 3 FTB of $7.126T.
The two approaches — top-down and bottom-up — independently converge on the $7.126T figure. This is not an advocacy estimate; it is a cross-validated data product. The convergence of two methodologically distinct approaches provides strong evidence that the Stage 3 FTB is within the correct order of magnitude and is not the product of a systematic methodological error in either direction.
As a final sanity check: $7.126T ÷ Texas population of approximately 30.5 million = roughly $233,700 per Texan in annual taxable economic activity. Texas GDP per capita (2025 estimate) is approximately $85,000. The ratio — approximately 2.77× — is the transaction multiplier effect of including B2B and intermediate-stage transactions that GDP, which nets out double-counting at each production stage, does not include. This ratio is consistent with the academic and BEA literature on the relationship between Gross Output and GDP. For a highly interconnected energy, manufacturing, and services economy like Texas, a 2.7-3.0× transaction-to-GDP ratio is entirely expected and well-documented. [BEA SAGDP2 TX]
The $7.126T figure is the result of two independent methodologies — a top-down Hybrid Gross Base construction and a bottom-up BEA Input-Output reconstruction — that independently converge on the same order-of-magnitude result. If either one had produced a significantly different answer, the TPTRP methodology would require revision. They don't. The convergence is the validation.
The Replacement Rate
A 5-tier rate stack that funds every dollar of Texas government — at 3.25% to start.
With both the Total Replacement Obligation ($203,554,603,387) and the Final Taxable Base ($7,126,243,896,502) established and cross-validated, calculating the minimum required rate is a matter of arithmetic: TRO ÷ FTB = $203,554,603,387 ÷ $7,126,243,896,502 = 2.8563%. This is the Aggregate Floor Rate (AFR) — the mathematically minimum rate at which the TPTRP can fund every dollar of its obligations. At the AFR, not a penny of government revenue is left unfunded, and there is no surplus.
The Starting Cap Rate (SCR) of 3.25% is the locked policy rate — not the AFR, but the rate set by the TPTRP Implementation Act (HB 100) as the starting rate for Year 1. At the SCR, annual revenue is approximately $231,602,926,636 ($7.126T × 3.25%), generating a buffer of $28,048,323,250 above the TRO. This buffer is not available for general appropriation — it flows through the 8-level Citizen Surplus Waterfall described in Section 12.
Beyond the SCR surplus, the TPTRP's Total Replacement Obligation is set at 110% of current revenue — every entity's replacement obligation includes a 10% buffer above what it currently collects. That 10% buffer totals $18,504,963,944 system-wide. Together, the buffer and the SCR surplus form the Year-1 Transition Fund: $18,504,963,944 + $28,048,323,250 = $46,553,287,194. This $46.6 billion fund — generated automatically by the rate structure on Day 1 — is managed by the Transition Board to support the small number of entities that require individualized assistance during the transition period. The fund is not borrowed, appropriated, or contingent. It is a mathematical consequence of the 3.25% starting rate applied to a $7.128 trillion tax base. [TX Comptroller BRE]
The SCR of 3.25% is locked in statute. It can only be changed by the Legislature with a two-thirds supermajority vote, and it can never exceed the Constitutional Cap Rate.The Constitutional Cap Rate (CCR) of 6.00% is embedded in the Texas Constitution by the same HJR 1 that abolishes property taxes. It is the absolute ceiling on the combined TPTRP rate that any government at any level may impose. Today's combined property-plus-sales tax effective burden on a typical Texas family runs between 7% and 10% of income. The TPTRP CCR of 6.00% is lower than the current statutory cap of 8.25% — and the SCR of 3.25% is far below the CCR. This means that even if the Legislature someday raises the rate to the maximum allowed, Texas households would still face a lower combined rate than they do today under the current system.
The 5-tier breakdown at the SCR is: T1 State 1.00%; T2 Counties+SDs 0.40%; T3 Cities+SDs 0.60%; T4 ISDs+ed 1.20%; T5 Statewide SDs 0.05%. These five rates sum to exactly 3.25%. Each tier's rate component is apportioned in proportion to that tier's share of the Total Replacement Obligation, with modest rounding adjustments to produce clean rate digits. The T4 rate of 1.20% is the largest single component, reflecting that K-12 public education — funded through ISDs plus the State education reallocation — represents the largest single category of government spending in Texas.
The rate corridor — from AFR at 2.8563% to SCR at 3.25% to CCR at 6.00% — gives the TPTRP structural resilience. The SCR buffer funds the Surplus Waterfall, providing financial reserves, capital infrastructure investment, and direct citizen dividends. The CCR ceiling prevents government from gradually eroding the tax relief that the plan delivers. Future legislatures can lower the rate, permanently reducing the tax burden on Texans. They can never raise it above 6.00% without a constitutional amendment — which requires a supermajority of the Legislature and a statewide vote of the people.
For comparison: under the current system, a typical Texas family with median household income of approximately $67,000 pays an effective combined property tax and sales tax burden of roughly 8-10% of income depending on whether they own or rent, their location, and their spending patterns. Under TPTRP at the 3.25% SCR applied to the post-TLES taxable fraction of their spending (roughly 55-70% of total expenditures), the effective rate on total income is approximately 2.0-2.5%. Even accounting for the broader base of the TPTRP compared to the current retail-only sales tax, the net effective burden drops dramatically for every income level.
Texas currently has a combined sales tax cap of 8.25% (6.25% state + up to 2.0% local) — one of the highest in the nation. Under TPTRP, the Constitutional Cap drops to 6.00% — and the locked Starting Cap Rate is 3.25%. The rate Texas pays on every transaction drops by more than 60% from the current cap. Property taxes, which average about $5,225 per household in HD109 (ACS-area home value × effective rate), go to zero. Every Texan pays less on Day 1.
| Tier | Entities | AFR | SCR | CCR | Notes |
|---|---|---|---|---|---|
| T1 State | 1 | 0.9350% | 1.0000% | 2.0000% | Post-ed-reallocation; includes $23.62B T4 transfer |
| T2 Counties+SDs | 254 sovereign + 1,284 absorbed | 0.3444% | 0.4000% | 1.0000% | |
| T3 Cities+SDs | 1,225 sovereign + 2,864 absorbed | 0.5370% | 0.6000% | 1.0000% | |
| T4 ISDs+ed | 1,016 ISDs | 1.0076% | 1.2000% | 1.5000% | Receives $23.62B ed realloc from T1 |
| T5 Statewide SDs | 500 SDs | 0.0323% | 0.0500% | 0.5000% | TPTRP-administered pool |
| SUM | 7,144 governed | 2.8563% | 3.25% | 6.00% |
Addressing Pyramiding
The most common technical objection — answered with data and first principles.
Tax pyramiding is the phenomenon by which a tax is applied multiple times to the same underlying economic value as a product or service moves through successive stages of a production and distribution chain. In a narrow retail sales tax regime — such as the current Texas state sales tax — pyramiding is avoided by limiting the tax to the final consumer sale. But in a broad-based transaction tax regime — such as the TPTRP, which applies to B2B and intermediate transactions — pyramiding becomes a central technical concern. Critics of broad-based transaction taxes frequently invoke pyramiding as an argument that the effective tax burden on the final consumer will compound to far exceed the nominal rate.
The TPTRP does apply a uniform rate to all transactions, including B2B and manufacturing-chain transactions. This is by design — it is the source of the plan's extraordinary tax base breadth. A 3.25% rate applied to $7.126T in transactions raises $231.6B. The same rate applied only to retail consumer sales (currently the Texas taxable sales base of approximately $1.7-2.0T) would raise only $55-65B — nowhere near enough to replace property taxes. Breadth of base is the mechanism that allows the rate to be low. You cannot have a 3.25% rate and a narrow base.
The response to the pyramiding concern is threefold. First, the AFR is calculated from the actual Hybrid Gross Base — a base that already includes all B2B and intermediate transactions. The 2.8563% AFR is the rate at which the TPTRP exactly funds its obligations given this broader base. The pyramiding effect is already baked into the rate calculation. If B2B transactions effectively compound the burden, that compounding is captured in the gross transaction volume — and the rate required to cover the TRO from that volume is still only 2.8563%. The rate is calibrated to the base, not to a retail-only approximation.
Second, the current property tax system already pyramids — silently and invisibly. Every product manufactured in a Texas factory includes the property tax on that factory. Every product transported through a Texas distribution center includes the property tax on that facility. Every product sold at a Texas retail store includes the property tax on that building. These embedded property taxes compound through the supply chain at every stage, just as a transaction tax would. The difference is that property tax pyramiding is invisible and non-transparent, while TPTRP pyramiding is explicit, uniform, and at a dramatically lower rate per stage. Replacing a 2.0265% effective property tax rate at each stage with a 3.25% transaction tax applied once at each stage produces a lower effective burden in many supply chains. [TCPA 96-463]
Third, international comparators demonstrate that broad-base transaction taxes at rates in the 3-15% range do not produce compounding distortions that make domestic industry uncompetitive. Canada's Goods and Services Tax (GST) is 5% applied broadly to goods and services including many B2B transactions. Australia's GST is 10%. New Zealand's GST is 15%. All three are applied to economies that are internationally competitive, export-oriented, and economically healthy. If a 15% GST does not make New Zealand uncompetitive, a 3.25% TPTRP rate — less than one-fifth of New Zealand's rate — will not make Texas industry uncompetitive. The economic argument for pyramiding distortions simply does not hold at the rate level the TPTRP proposes.
The arithmetic closes precisely: $7.126T × 3.25% = $231.6B, which is $28.05B above the $203.55B TRO. This buffer — generated by the SCR being above the AFR — is proof that the rate is not over-calibrated. If pyramiding effects were causing the effective tax burden to compound to unsustainable levels, we would expect to see consumption base shrinkage, economic distortion, or fiscal shortfall. The 14.9% SCR margin above the AFR provides the fiscal cushion that absorbs any such effects without jeopardizing government revenue adequacy.
The current property tax system pyramids silently at every stage of the Texas economy. Every product you buy contains embedded property taxes from the manufacturer's facility, the distribution warehouse, the trucking depot, and the retail store — all passed through in prices. Under TPTRP, the tax is explicit, uniform, and at a dramatically lower rate. Replacing invisible high-rate pyramiding with transparent low-rate pyramiding is not an economic problem — it is an economic improvement.
Plausibility Checks
Does 3.25% actually work? Three independent tests.
Beyond cross-validation of the tax base (Section 5), the TPTRP undergoes three independent plausibility tests that confirm the plan is fiscally sound, historically grounded, and economically coherent.
Check 1 — Revenue Adequacy at AFR
The most direct test: does the math close? $7,126,243,896,502 × 2.8563% = $203,554,603,387 — exactly equal to the Total Replacement Obligation of $203,554,603,386.71. The calculation is not approximate; it is a mathematical identity. The AFR is defined as TRO ÷ FTB, so by construction, AFR × FTB = TRO. The real test is whether the FTB and TRO are correctly measured — and that is what Section 4 and the cross-validation of Section 5 establish.
At the SCR of 3.25%, annual revenue is $231,602,926,636, generating a $28,048,323,250 buffer above the TRO. This buffer represents a 14.87% coverage margin. Even if actual transaction volume in Year 1 comes in 10% below projection — a conservative economic stress scenario — the SCR still generates enough revenue to cover 104.4% of the TRO. The plan survives a 10% revenue shortfall without requiring rate adjustment or government-service disruption.
Check 2 — Historical Comparator
Canada implemented a federal Goods and Services Tax (GST) at 7% in 1991, later reduced to 5%, covering a broad base of goods and services transactions including many B2B categories. New Zealand implemented a GST at 10% in 1986, later raised to 15% — applied across virtually all transactions with minimal exemptions, and widely regarded as one of the cleanest, most economically neutral consumption taxes in the world. Australia's GST at 10% (2000) covers most goods and services. All three countries demonstrate that broad-base transaction taxes are fiscally durable, economically tolerable, and administratively workable. The TPTRP's SCR of 3.25% is lower than all three — 35% below Canada's lowest-ever rate, 78% below Australia's rate, and 78% below New Zealand's current rate. If those countries fund major proportions of their central government expenditure at 5-15%, Texas can fund all of its local and state government obligations at 3.25%.
Check 3 — Texas Economy Scale Sanity
Texas nominal GDP in 2025 is approximately $2.6 trillion. The Stage 3 FTB of $7.126T is 2.77× GDP — a transaction-to-GDP ratio consistent with the Bureau of Economic Analysis's Gross Output measure for a large, complex economy. [BEA SAGDP2 TX] The BEA's Gross Output measure for the US economy as a whole has historically run at approximately 2.0-2.5× GDP. Texas, as a major oil-and-gas and manufacturing state with extensive supply-chain activity, would be expected to have a higher gross-output-to-GDP ratio than the national average — 2.77× is entirely plausible and consistent with the BEA literature. The FTB figure passes the macroeconomic scale test: it is neither impossibly large nor suspiciously small relative to the observable size of the Texas economy.
At the Aggregate Floor Rate of 2.8563%, $7.126T × 2.8563% = $203.55B = the exact Total Replacement Obligation. This is not a coincidence — it is a mathematical identity. The AFR is defined as TRO ÷ FTB. The real question is whether the TRO and FTB are correctly measured. Section 4 sources each figure to primary government data. Section 5 validates through two independent methods. The checks confirm the plan is fiscally sound from every angle.
Household Impact
What TPTRP means for every Texan — by income, by renter/owner status, and for HD109 specifically.
The TPTRP is not an abstraction. For every Texas household, the plan produces a specific, calculable change in annual tax burden. The calculation is straightforward: current combined property tax plus sales tax burden (the L1 or L2 figure) minus the new TPTRP liability at the SCR on the post-TLES taxable fraction of that household's spending. The difference is the net annual savings. For the average Texas household, that savings is $7,477 per year on the L1 basis and $9,285 per year on the full L2 basis — money that stays in family budgets rather than flowing to governments whose tax instruments are being replaced, dollar-for-dollar, by the new unified system.
Every quintile saves under the TPTRP. This is not a plan that helps the wealthy while burdening the poor. Q1 (lowest 20%, average income $15,044) saves $3,569 per year on the L1 basis — equivalent to 23.7% of Q1 average income. Q5 (highest 20%, average income $230,158) saves $13,875 per year on L1 — 6.0% of income. The absolute dollar savings is larger for higher-income households; the proportional income relief is larger for lower-income households. This embedded structural progressivity is the direct result of the TLES exemptions, which shield the spending categories that constitute the largest fraction of lower-income household budgets. [BLS CE TX 2022-23]
The TLES effect is the engine of progressivity in the TPTRP. Q1 households spend approximately 40-50% of their income on TLES-protected categories: groceries, rent, utilities, prescription drugs, medical care, and gas. Under the TPTRP, none of that spending is taxed. The taxable fraction of Q1 spending is low — which means the TPTRP cost to a Q1 household is low. Under the current system, that same Q1 household pays a property tax pass-through embedded in their rent (18.5% of the landlord's property tax) and faces an 8.25% combined sales tax on every taxable retail purchase. The TPTRP eliminates the rent pass-through entirely (TLES-2) and drops the sales tax rate from 8.25% to 3.25% on a narrower taxable base. [TCPA 96-463]
For Texas's 4.05 million renter households, the TPTRP delivers a specific, structural relief mechanism that no property tax homestead exemption or appraisal cap reform can replicate: the full exemption of residential rent from the TPTRP rate under TLES-2. Today, every renter in Texas pays a hidden property tax — 18.5% of the landlord's property tax, embedded in their monthly rent, with no bill, no disclosure, and no way to contest it. The TPTRP eliminates this entirely. On Day 1, the effective property tax embedded in rent goes to zero. Renters do not need to wait for landlords to lower rents to capture this benefit — the tax cost disappears from the landlord's cost structure, creating direct competitive pressure to pass through the savings in rent pricing. [ACS 2019-2023]
The MIT Living Wage Calculator for Dallas County — as of February 15, 2026 — establishes that a canonical working family of four (2 adults, 1 working, 2 children) requires $80,866 per year to meet basic living costs in the Dallas metropolitan area. [MIT Living Wage Dallas County] This is the bare-minimum threshold for human dignity — it covers housing, food, transportation, childcare, healthcare, and essential clothing. No savings, no retirement contribution, no vacation, no margin. Three of Texas's five income quintiles — Q1, Q2, and Q3 — fall below this floor. Three quintiles of Texans are currently paying property and sales taxes out of money that they need, by the MIT calculation, for food, childcare, and basic healthcare. The TPTRP returns an average of $5,000-$7,000 per year to those households — money that should never have been taken.
House District 109 encompasses Cedar Hill, DeSoto, Lancaster, Glenn Heights, Hutchins, Seagoville, and Wilmer — seven communities wholly within Dallas County. HD109 is home to 185,049 residents in 62,106 households. The median household income is $57,836 — 71.5% of the MIT family survival floor of $80,866, meaning the median HD109 household cannot meet the MIT basic needs threshold. The combined effective property tax rate across HD109 jurisdictions is 2.0265%. The average HD109 household pays $5,225 per year in property taxes alone (ACS-area average home value $257,838 × the 2.0265% combined effective rate). [TLC ACS 405 HD109]
Under the TPTRP at the SCR, the canonical HD109 working family of four (MIT 2 adults, 1 working, 2 children, earning at the living wage) saves $8,775 per year — 10.9% of their total survival budget returned to them directly. That is not an economic projection — it is the difference between their current total PT+ST burden of $10,360 and their new TPTRP liability of $1,585. In concrete terms, $8,775 per year is: one full year of childcare for one child in Dallas County; or three months of housing costs; or six months of grocery costs for a family of four; or seven months of transportation costs. This is the real, kitchen-table impact of the TPTRP for the families Rep. Campbell represents.
TPTRP's $8,775/year in net savings is not an abstraction. It is a year of childcare for one child. It is three months of rent. It is six months of family groceries. At 10.9% of the MIT survival-floor budget, this is the difference between staying above water and falling below it for the median HD109 family. This money belongs to those families — and the TPTRP returns it to them.
| Quintile | Avg Income | Q Taxable | TPTR @ SCR | L1+ST Savings | L2+ST Savings | L2 Savings % Inc |
|---|---|---|---|---|---|---|
| Q1 Lowest 20% | $15,044 | $19,512 | $634 | $3,569 | $4,473 | 29.7% |
| Q2 Second 20% | $39,679 | $30,935 | $1,005 | $5,095 | $6,386 | 16.1% |
| Q3 Middle 20% | $68,731 | $36,264 | $1,179 | $6,025 | $7,593 | 11.0% |
| Q4 Fourth 20% | $117,243 | $55,852 | $1,815 | $8,244 | $10,319 | 8.8% |
| Q5 Highest 20% | $230,158 | $109,742 | $3,567 | $13,875 | $16,191 | 7.0% |
| All HH avg | $103,108 | $51,392 | $1,670 | $7,477 | $9,285 | 9.0% |
| Household Type | Current PT+ST | TPTR @ SCR | Net Savings | % of MIT Floor |
|---|---|---|---|---|
| Median owner HH ($57,836) | $9,426 | $1,056 | $8,370 | — |
| Median renter HH ($57,836) | $7,948 | $1,056 | $6,892 | — |
| MIT 2A 1Wkg 2Ch (canonical) | $10,360 | $1,585 | $8,775 | 10.9% |
| MIT 1A 0Ch | $8,032 | $875 | $7,157 | 14.8% |
| MIT 2A BothW 2Ch | $12,044 | $2,033 | $10,011 | 9.3% |
The Action Plan
How Texas ends property taxes — five legislative and constitutional steps.
The TPTRP requires both a constitutional amendment and a suite of implementing legislation filed in the Texas Legislature. The constitutional amendment is the keystone — without it, property taxes could return through legislative action at any future session. The implementing legislation establishes the rate structure, the TLES, the Transition Board, and the bondholder protections that make the plan legally durable and financially complete. The five-bill package is designed to be introduced as a unified legislative initiative in the 89th Texas Legislature.
Step 1 — HJR 1: The Constitutional Amendment
The first and most critical step is filing a House Joint Resolution proposing to amend Article VIII of the Texas Constitution to add a new §1-e prohibiting all ad valorem taxes on property at every level of Texas government. The amendment also establishes the Constitutional Cap Rate of 6.00% as the maximum combined TPTRP rate. A constitutional amendment requires a two-thirds majority vote in both chambers of the Texas Legislature, followed by ratification by a majority of Texas voters in a statewide election. The target timeline: introduced in the 89th Legislature (2025 session), passed by the Legislature with a two-thirds supermajority, placed on the November 2025 ballot, ratified by Texas voters, and effective January 1, 2026. [TX Constitution Art. XVII]
Step 2 — HB 100: The TPTRP Implementation Act
The core implementing legislation. HB 100 establishes the 5-tier sales-and-use tax rate structure as specified in Section 6 of this article — T1 through T5, with AFR components, the locked SCR of 3.25%, and individual tier CCR ceilings. It defines the 12 TLES exemption categories with precise statutory language cross-referencing the appropriate NAICS and product classification codes for each category. It creates the Texas Property Tax Replacement Transition Board (described in Section 11) and defines its composition, authority, and sunset. It defines the Citizen Surplus Waterfall priority structure (described in Section 12). HB 100 is effective upon ratification of HJR 1 by Texas voters. [TLC Drafting Manual, 89th Legislature]
Step 3 — HB 101: The Transition Fund Establishment Act
HB 101 creates the Texas Property Tax Replacement Transition Fund — the Year-1 fiscal buffer pool funded from the SCR margin above the AFR (approximately $28.09 billion per year at current transaction volumes). The Act defines the fund's legal structure, its permitted uses (Year-1 bond debt service absorbing during entity transition, operational reserves for the Transition Board, seed funding for the Rate Reduction Reserve), its governance structure (administered by the Transition Board under the Comptroller's custodial oversight), and its sunset (Years 1-7, transitioning to the permanent Citizen Surplus Waterfall structure beginning in Year 3 and completing in Year 8). The fund is not an appropriation vehicle — surplus funds flow through the Waterfall, not into general revenue.
Step 4 — HB 102: The Bondholder Protection Act
Texas local governments have $442.55 billion in total outstanding bonded indebtedness, of which $263.23 billion is absorbed into the TPTRP TRO structure. Annual debt service on absorbed bonds is $22,269,813,952 for FY2026. HB 102 provides statutory bondholder protections guaranteeing that all outstanding Texas local-government general obligation bonds whose covenants pledge ad valorem property tax revenues will continue to be honored on their original principal and interest schedules. The mechanism: the ad valorem property tax pledge in each bond covenant is substituted by an equivalent TPTRP sales-and-use tax revenue pledge, with the annual debt service amount flowing directly from the T2, T3, T4, and T5 tier allocations through the Level 1b Debt Service Reserve of the Surplus Waterfall. No bondholder experiences any change in receivable amount, payment date, or security priority. The bond market receives legal clarity and contractual certainty that the TPTRP transition does not impair existing debt obligations.
Step 5 — HB 103: The Property Appraisal Dissolution Act
With property taxes abolished, the central appraisal district (CAD) system — 254 county CADs, their associated appraisal review boards (ARBs), and the entire property tax protest industry — has no function. HB 103 phases out CAD operations over a 3-year transition period. During the transition, CAD offices perform a single remaining function: maintaining property value records needed for bond defeasance calculations on pre-TPTRP general obligation bonds that used assessed value as a covenant benchmark. After the transition period, CAD offices are dissolved and their records transferred to county clerk offices for archival purposes. The approximately 10,000 full-time-equivalent jobs in the CAD and tax-protest industry transition through a workforce adjustment program funded from the Level 2b Transition Subsidy Fund of the Citizen Surplus Waterfall. The annual savings from CAD dissolution — estimated at $350-500 million statewide in administrative costs — are automatically redirected to the Surplus Waterfall.
The Texas Property Tax Replacement Transition Board
The independent body that manages the 7-year transition from property tax to sales tax.
The Flagged Entity Register: $6.8 Billion Against a $46.6 Billion Fund
This plan's analysis covers more than 6,000 Texas taxing entities. For the vast majority, the math closes cleanly at each tier's starting rate — their allocated share of the $7.128 trillion Final Tax Base generates enough revenue at the 3.25% starting rate to cover their replacement obligation. But 585 entities fall into one of three flag categories, each representing a different challenge with a different resolution path.
| Confidence Tier | Counties | Cities | ISDs | Total | SCR Shortfall ($) | Board Resolution Path |
|---|---|---|---|---|---|---|
| BOTH_SHORT — both methods agree on structural shortfall | 17 | 96 | 20 | 133 | $6,812,041,804 | Definitive Day-1 workload — transition fund support, adjusted timeline, or SD rerouting |
| PRIMARY_SHORT — primary allocation method flags shortfall | 40 | 187 | 17 | 244 | $2,220,135,867 | Board reviews allocation methodology — many resolve without structural intervention |
| ABSORPTION_TRIGGER — entity OK alone; absorbed SDs drive shortfall | 82 | 123 | 3 | 208 | ~$0 (rerouting resolves) | Reroute absorbed special districts to adjacent tier — entity itself clears the starting rate |
| Tier 5 Statewide SDs | — | — | — | 0 | $0 | All 500 statewide special districts clear the starting rate — strongest result in the analysis |
| All flagged entities | 139 | 406 | 40 | 585 | ~$9,032,177,671 | Year-1 Transition Fund: $46,553,287,194 — covers all shortfalls 5.2× over |
Year-1 Transition Fund: $46,553,287,194. Total SCR shortfall across all 585 flagged entities: approximately $9.0 billion. Coverage ratio: 5.2×. For the 133 highest-confidence entities (both methods agree): shortfall $6,812,041,804, coverage 6.8×. The fund is not borrowed, contingent, or speculative. It is generated automatically by the 3.25% starting rate operating above the 2.8563% mathematical floor on a $7.128 trillion base. Every flagged entity can be made whole. The question for the Transition Board is how, not whether. [TX 2025 Annual Cash Report]; [BRB AR2025]
For the 208 ABSORPTION_TRIGGER entities — the largest single category — the most efficient resolution is to reroute the absorbed special districts to an adjacent tier rather than adjusting the entity's own rate. A city that is financially sound on its own operations but carries excess obligation from absorbed municipal utility districts simply needs those districts reassigned. No rate change. No transition fund allocation. A structural adjustment the Board can make administratively.
For flagged counties and ISDs — particularly small rural communities — the Transition Board's most powerful long-term tool is economic development facilitation. The same analysis that identifies these communities as flagged also reveals why: their local economic base is small relative to their government service costs. The Transition Fund provides the runway. Economic development — business attraction, infrastructure investment, regulatory streamlining — provides the path to permanent self-sufficiency within the TPTRP framework. Texas has done this before: communities that once depended on federal commodity payments or state aid have grown into self-sustaining economic centers. The Transition Board connects flagged communities with the tools to do it again.
A plan of the TPTRP's scale — replacing the entire property tax infrastructure of the seventh-largest economy in the world, restructuring 7,144 taxing entities, absorbing 4,148 special districts, and managing a $30 billion annual surplus waterfall — cannot be safely administered through existing governmental structures. The Texas Comptroller is a political office with a full agenda. The Legislature is a biennial body that cannot respond quickly to revenue anomalies. The Governor's office has no fiscal administration expertise of this depth. The TPTRP requires a purpose-built, independent fiscal institution: the Texas Property Tax Replacement Transition Board.
The Transition Board is created by HB 100 and HB 101 as a new state entity with an explicit independence mandate. It is not a division of the Comptroller's office, not a legislative committee, and not a gubernatorial advisory panel. It has statutory powers, a dedicated administrative budget funded from the Level 2b Transition Subsidy Fund, and a governance structure designed to insulate it from short-term political pressure. The Board's members serve staggered 6-year terms — not aligned with gubernatorial or legislative election cycles — and can be removed only for cause, as defined by statute, not at the pleasure of the appointing official.
The Board is composed of 7 members: 2 appointed by the Governor, 2 by the Lieutenant Governor, 2 by the Speaker of the House, and 1 independent at-large public member elected statewide in a nonpartisan election. The at-large member serves as a direct accountability mechanism to the public — a citizen representative on the body that manages the most consequential fiscal transition in Texas history. The Board elects its own Chair from among its members. No more than 4 of the 7 members may be from the same political party.
The Board's core functions are defined by statute and include five principal responsibilities: (1) Rate monitoring — monthly review of TPTRP revenue collections versus TRO, with mandatory public reporting within 15 days of each month-end; (2) Transition Fund management — investment and disbursement oversight of the SCR buffer pool through the Surplus Waterfall, with a fiduciary duty to maximize taxpayer benefit; (3) Bond coordination — interface with the Texas Bond Review Board to ensure that all IS&F (Interest and Sinking Fund) obligations for absorbed bonds are met on schedule, with immediate escalation authority if a shortfall is projected; (4) Entity absorption oversight — managing the structured absorption of 4,148 special districts into the T2, T3, and T5 tiers, including governance transitions, administrative wind-downs, and cost-basis settlements; and (5) Rate adjustment authority — the Board may propose a permanent rate reduction to the Legislature if three-year trailing revenue exceeds the TRO by more than 15%. The Board cannot propose or approve rate increases — that authority belongs exclusively to the Legislature, subject to the CCR ceiling.
The Transition Board sunsets at the end of Year 10 post-implementation. At sunset, its functions transfer to existing institutions: rate monitoring to the Comptroller, fund management to the Legislative Budget Board, and bond coordination to the Texas Bond Review Board. These are the natural institutional homes for each function once the extraordinary transition challenges of Years 1-10 have been resolved. The Board exists precisely because the transition period is extraordinary — and dissolves precisely because the permanent TPTRP structure does not require a dedicated oversight institution once it is fully operational.
Without an independent, empowered transition body, a plan of this scale would be vulnerable to legislative interference, political budget raids, and interest-group capture. Every fiscal transition of this magnitude in modern history — whether in government restructuring, pension reform, or major tax overhaul — has succeeded when administered by an independent institution with a clear mandate and structural protection from political pressure. The Transition Board's independence is a structural feature of the TPTRP, not a political compromise. It is what converts a legislative proposal into a durable fiscal institution.
The Citizen Surplus Waterfall
When TPTRP generates more revenue than it needs, the surplus flows to taxpayers — through 8 defined levels.
The Starting Cap Rate of 3.25% generates approximately $28,048,323,250 per year above the Aggregate Floor Rate. This surplus is not available for general government appropriation. It is not a slush fund. It is not at the discretion of any legislature, governor, or comptroller to redirect as political conditions dictate. Instead, the TPTRP's Citizen Surplus Waterfall defines a strict, priority-ordered cascade structure through which every dollar of surplus above the TRO must flow — starting with structural protections and ending with direct benefits to Texans.
The Waterfall has eight levels. No level is accessed until the one above it is fully funded. This priority structure is not advisory — it is statutory, defined in HB 100 and HB 101, enforceable in court. The Transition Board's mandate includes ensuring that surplus distributions follow the Waterfall sequence. Any deviation from the sequence is a statutory violation subject to judicial review.
Level 0 — TRO Coverage (Non-Negotiable Floor)
The first priority, always, is full funding of the Total Replacement Obligation: $203,554,603,387 per year, distributed to all 7,144 governed entities at their full FY2025 revenue equivalent. No government is funded below its current revenue level. No service is cut. No entity is shorted. Level 0 is the floor beneath which the TPTRP never falls. Only after Level 0 is fully funded does any other level receive a single dollar.
Level 1a — Operational Reserve (6-Month / 10% Cap)
Each of the five tiers builds a dedicated 6-month operational reserve equal to 50% of its annual TRO allocation. This reserve is capped at 10% of the tier's share of the Stage 3 FTB apportionment. Its purpose is insurance against revenue fluctuations, economic recessions, or seasonal collection patterns. The Texas economy is not uniform through the year — retail sales spike in Q4, oil and gas revenues fluctuate with commodity prices, and real estate transactions cluster in certain months. The Operational Reserve smooths these fluctuations so that government services are never interrupted by a revenue timing gap.
Level 1b — Debt Service Reserve (100% Annual DS)
One hundred percent of each tier's annual debt service obligation on absorbed general obligation bonds is held in a dedicated Debt Service Reserve, separate from the Operational Reserve. The total absorbed annual debt service is $22,269,813,952 for FY2026 per the Texas Bond Review Board's Local Annual Report. [BRB AR2025] This reserve guarantees that bond payments are never at risk, even if a revenue shortfall materializes. Bondholders effectively have structural first-claim on this reserve — it is funded before any Waterfall level below Level 1b. This is the legal foundation of the bondholder protection guarantee in HB 102.
Level 2a — Rate Reduction Reserve (3% FTB Cap)
Once Levels 0, 1a, and 1b are fully funded, surplus flows to the Rate Reduction Reserve. This reserve accumulates until it reaches 3% of the Stage 3 FTB — approximately $215.8 billion at current FTB levels. The Rate Reduction Reserve is the mechanism for permanent rate decreases. When the reserve reaches its cap, the Transition Board must transmit a rate reduction proposal to the Legislature. The Legislature may adopt, modify, or reject the proposal — but if it rejects it, the Board must transmit a new proposal in the next legislative session. The Rate Reduction Reserve creates a structural fiscal gravity toward lower rates over time, as long as the Texas economy continues to grow.
Level 2b — Transition Subsidy Fund (Sunsets Year 7)
A time-limited fund that subsidizes the administrative costs of the CAD dissolution transition (HB 103), the entity absorption process, the workforce transition program for displaced CAD and appraisal-industry employees, and the Transition Board's own operational expenses. Funded only from surplus above Levels 0, 1a, 1b, and 2a. Sunsets at the end of Year 7 post-implementation — by which point all transition costs have been fully resolved. After Year 7, surplus that would have gone to Level 2b flows directly to Level 3a.
Level 3a — Capital Infrastructure Fund
After all structural reserve levels are funded, additional surplus flows to a Capital Infrastructure Fund available for Texas infrastructure projects — roads and highways, water supply and treatment systems, broadband connectivity, seaports, airports, and other capital investments with documented statewide economic benefits. The fund is administered by the Transition Board in coordination with the Texas Department of Transportation, the Texas Water Development Board, and the Texas Broadband Development Office. Projects are selected through a transparent, merit-based competitive process with public comment requirements. The Capital Infrastructure Fund is a mechanism for the TPTRP surplus to generate compound economic returns — infrastructure investment that expands the transaction base and thereby sustainably increases future TPTRP revenue.
Level 3b — Citizen Dividend / Tax Rebate
After capital infrastructure, the next priority is the most direct form of taxpayer benefit: an equal per-household cash rebate distributed to every Texas household on record. Not per-capita — per household. Every household, regardless of income level, size, or location, receives the same check. The amount varies each year depending on how much surplus reaches Level 3b, but the distribution method is deliberately egalitarian. A family of four and a single-person household receive the same dollar amount — which means the per-capita benefit is larger for smaller households, providing additional structural support for the working families who are most often single-parent or small-household units. The Citizen Dividend is the most visible, politically durable feature of the TPTRP — every Texan sees the check and knows exactly who sent it.
Level 3c — Education Excellence Endowment
Any surplus remaining after Level 3b flows to the Texas Education Excellence Endowment — a permanent investment fund modeled on the Texas Permanent School Fund. The Endowment is invested in low-cost diversified index funds through the State Comptroller's office investment management infrastructure. Annual distributions are capped at 5% of corpus per year, consistent with endowment best practices, and are used to supplement the per-pupil funding allocation for every student in every Texas school district. The Endowment is perpetual — it does not sunset, does not appropriate into general revenue, and cannot be raided by any future Legislature without a two-thirds supermajority vote and a 2-year advance notice period. It is Texas's investment in the education of every future generation of Texans.
The Waterfall is a taxpayer protection mechanism as much as a revenue allocation structure. It ensures that when TPTRP generates more revenue than government needs — as it is designed to do, by setting the SCR above the AFR — the money flows back to the public through a defined, priority-ordered, statutorily enforceable process. First through structural buffers that protect the plan's integrity. Then through capital investment that grows the economy. Then directly into Texans' pockets through the Citizen Dividend. And finally into the educational foundation of every Texas child, in perpetuity.
| Level | Name | Trigger | Cap | Purpose |
|---|---|---|---|---|
| 0 | TRO Coverage | Always | None | Fund all 7,144 entities at full TRO |
| 1a | Operational Reserve | Post-L0 | 10% FTB apportionment | 6-month revenue buffer per tier |
| 1b | DS Reserve | Post-L0 | 100% annual DS ($22.27B) | Bond payment guarantee fund |
| 2a | Rate Reduction Reserve | Post-L1 | 3% FTB (~$215.8B) | Accumulate for permanent rate reduction |
| 2b | Transition Subsidy Fund | Post-L2a | Sunsets Year 7 | CAD dissolution + entity absorption costs |
| 3a | Capital Infrastructure Fund | Post-L2 | LBB-approved cap | TX infrastructure (roads, water, broadband) |
| 3b | Citizen Dividend / Tax Rebate | Post-L3a | Revenue-dependent | Equal per-household cash rebate |
| 3c | Education Excellence Endowment | Post-L3b | Permanent | Per-pupil supplement + investment corpus |
Texas Property Tax Replacement Plan — Legislative Package
Rep. Will Campbell · House District 109 · Review each bill in the tabs below
References
Sources organized by section grouping. APA 7th Edition format. All sources are primary government data, peer-reviewed research, or nationally recognized reference data sets. No internal workbooks or advocacy organization commentary cited.
Section A — TX Comptroller / PTAD Property Tax Data (Sections 1 & 6)
Texas Comptroller of Public Accounts, Property Tax Assistance Division. (2025). 2025 County Property Tax Rates and Levies. https://comptroller.texas.gov/taxes/property-tax/docs/2025-county-rates-levies.xlsx
A-1. Certified county-tier property tax levy total: $16,790,826,380.72. Used in Section 1 T2 row and TRO calculation. Primary source for all county-tier PT revenue figures in this article.
Texas Comptroller of Public Accounts, Property Tax Assistance Division. (2025). 2025 City Property Tax Rates and Levies. https://comptroller.texas.gov/taxes/property-tax/docs/2025-city-rates-levies.xlsx
A-2. Certified city-tier property tax levy total: $16,733,869,888.00. Used in Section 1 T3 row and TRO calculation. Primary source for all city-tier PT revenue.
Texas Comptroller of Public Accounts, Property Tax Assistance Division. (2025). 2025 School District Property Tax Rates and Levies. https://comptroller.texas.gov/taxes/property-tax/docs/2025-school-district-rates-levies.xlsx
A-3. Certified ISD-tier property tax levy total: $41,654,584,549.00. Used in Section 1 T4 row. Largest single PT revenue tier.
Texas Comptroller of Public Accounts, Property Tax Assistance Division. (2025). 2025 Special District Property Tax Rates and Levies. https://comptroller.texas.gov/taxes/property-tax/docs/2025-special-district-rates-levies.xlsx
A-4. Certified special-district-tier property tax levy total: $14,266,804,030.00. Used in Section 1 T5 row.
Texas Comptroller of Public Accounts, Property Tax Assistance Division. (2025). 2025 All-Tier Property Tax Rates and Levies Roll-Up. https://comptroller.texas.gov/taxes/property-tax/docs/2025-total-rates-levies.xlsx
A-5. Statewide total across all four tiers: $89,446,084,847. Used as the canonical statewide PT levy figure throughout the article.
Section B — TX Comptroller Sales Tax and State Revenue (Sections 1, 4, 6)
Texas Comptroller of Public Accounts. (2025). Annual Cash Report — Fiscal Year 2025. https://comptroller.texas.gov/transparency/reports/annual-cash-report/2025
B-1. Primary source for FY2025 state revenue: state sales tax $49.06B, other state taxes $35.14B, total $84.20B. Foundation of T1 TRO row and total TRO calculation of $203,554,603,387.
Texas Comptroller of Public Accounts. (2025). Quarterly Taxable Sales Data. https://comptroller.texas.gov/taxes/sales/index.php
B-4. Quarterly taxable sales by NAICS sector. Used in Section 4 Stage 1 C1 component of Hybrid Gross Base. Cross-reference for Method 2 bottom-up validation in Section 5.
Texas Comptroller of Public Accounts. (2025). Active Sales Tax Permits Dataset. https://comptroller.texas.gov/transparency/open-data/search-datasets
B-7. Active sales tax permit universe for counting taxable business entities in Texas. Supporting data for Stage 1 base construction.
Texas Comptroller of Public Accounts. (2025). Local Sales Tax Authority Collections. https://comptroller.texas.gov/taxes/sales/index.php
B-9. Local sales tax collections by entity: cities $9.067B, counties $0.878B, special districts $1.451B. Used in Section 1 local ST column of TRO table.
Texas Comptroller of Public Accounts. (2025). Tax Exemptions and Tax Incidence: A Report to the Governor and the Legislative Budget Board (Publication 96-463). https://comptroller.texas.gov/transparency/reports/tax-exemptions-and-incidence/2025/96-463.pdf
B-10 / TCPA 96-463. Primary source for tax incidence methodology: 18.5% residential rent PT pass-through rate, 50% commercial PT pass-through rate. Used throughout Sections 2, 7, and 9 for burden and savings calculations.
Section C — TX Bond Review Board and Legislative Sources (Sections 10 & 12)
Texas Bond Review Board. (2025). Local Government Annual Report 2025. https://www.brb.state.tx.us/publications/annual-report.aspx
K-1. Primary source for total outstanding Texas local government bonded indebtedness ($442.55B total), absorbed bonds ($263.23B), and annual debt service ($22,269,813,952 FY2026). Used in Sections 10 (HB 102) and 12 (Level 1b Debt Service Reserve).
Texas Bond Review Board. (2025). Bond Finance Data Center. https://www.brb.state.tx.us/bond/data.aspx
K-2. Bond Finance Data Center — granular bond issuance, outstanding balance, and maturity data by issuer and tier. Used in Section 12 waterfall Level 1b Debt Service Reserve and Section 10 HB 102 bondholder protection calculations.
Texas Legislative Council. (2025). ISD Attendance Zone Boundaries. https://data.capitol.texas.gov/dataset/school-districts
H-1. GIS boundary data for ISD attendance zones. Used to confirm HD109 overlapping ISDs (Cedar Hill, DeSoto, Lancaster, Ferris, Wilmer-Hutchins) for Section 9 HD109 constituent analysis.
Texas Legislative Council. (2025). ACS-Based District Population Report No. 405 — House District 109. https://data.capitol.texas.gov
H-2. TLC district data for HD109: population 185,049; household count 62,106; median household income $57,836. Primary source for all HD109 demographic anchors used throughout Section 9.
Section D — Federal Statistical Sources (Sections 2, 4, 5, 8, 9)
U.S. Census Bureau. (2023). American Community Survey 5-Year Estimates, 2019–2023: Texas State Profile. https://data.census.gov/profile/Texas?g=040XX00US48
G-6. ACS 5-year estimates for Texas: total households, renter/owner split, income distribution, housing costs. Primary source for 4.05 million renter household figure and TLES-2 residential rent base used in Sections 2 and 9.
U.S. Census Bureau. (2023). American Community Survey 1-Year Estimates — House District 109 Area. https://data.census.gov
G-7. HD109-level ACS data supporting TLC Report 405 figures. Cross-reference for household counts, income quintile distribution, and tenure status in HD109 for Section 9 constituent impact tables.
U.S. Bureau of Labor Statistics. (2023). Consumer Expenditure Survey — State Tables: Texas Income Quintiles, 2022–2023 Two-Year Average. https://www.bls.gov/cex/tables/geographic/mean/2023/cu-state-tx-income-quintiles-before-taxes-2-year-average-2023.htm
G-8. BLS CE state-level quintile income and spending data for Texas. Primary source for the quintile burden analysis in Section 2 (Table 2) and the household savings table in Section 9 (Table 9a). Foundation of the 2.8× regressivity ratio finding.
U.S. Bureau of Economic Analysis. (2025). Regional Economic Accounts — State Annual GDP by Industry (SAGDP2), Texas. https://apps.bea.gov/regional/downloadzip.cfm
G-9. BEA SAGDP2 Texas GDP data. Primary source for the BEA escalator factor (1.13183) used in Section 4 Stage 1 base construction, and the GDP cross-check used in Section 8 Plausibility Check 3. Confirms $2.6T Texas nominal GDP for 2025.
U.S. Energy Information Administration. (2025). Texas State Energy Profile. https://www.eia.gov/state/analysis.php?sid=TX
G-10. EIA Texas energy profile. Primary source for TLES-7 gas-at-the-pump base ($63.50B), motor fuel price data used with RRC production in Stage 1 C2 component, and home utility expenditures cross-check for TLES-3.
U.S. Energy Information Administration. (2024). Electric Power Annual — Form EIA-861 State Data: Texas. https://www.eia.gov/electricity/data/eia861/
G-11. EIA-861 residential electricity sales data for Texas. Primary source for the residential electricity component of TLES-3 Home Utilities ($40.598B combined elec/gas/water). Used in Section 4 TLES table.
Centers for Medicare & Medicaid Services. (2024). National Health Expenditure Accounts (NHEA) — State-Level Data 2024. https://www.cms.gov/research-statistics-data-and-systems/statistics-trends-and-reports/nationalhealthexpenddata
G-12. CMS NHEA 2024. Primary source for TLES-4 Prescription Drugs ($41.563B) and TLES-5 Medical Care ($340.0B) — both Texas-apportioned from national NHEA data using Texas share of national personal health expenditures. Used in Section 4 TLES table and Section 3 plan description.
U.S. Department of Agriculture, Economic Research Service. (2025). Food Expenditure Series — Food at Home, 2025. https://www.ers.usda.gov/data-products/food-expenditure-series/
G-13. USDA ERS food expenditure data. Primary source for TLES-1 Groceries (food at home, $97.185B, Texas-apportioned). Used in Section 4 TLES table and Section 3 TLES category description.
Federal Deposit Insurance Corporation. (2025). BankStats — Texas Banking Profile. https://www.fdic.gov/bank/statistical/bankstats/
G-14. FDIC Texas banking statistics. Primary source for C5 (banking and finance value-added) component of the Stage 1 Hybrid Gross Base in Section 4. Used in Section 4 Stage 1 methodology description.
MIT Living Wage Project. (2026, February 15). Living Wage Calculator — Dallas County, Texas. https://livingwage.mit.edu/counties/48113
G-15. MIT Living Wage Calculator, Dallas County, February 15, 2026 snapshot. Primary source for the canonical family survival-floor figures used throughout Section 9: 2 adults 1 working 2 children = $80,866/yr minimum living wage. Anchor for all HD109 savings-as-percent-of-survival-floor calculations.
Section E — Trade, Research, and Specialized Sources (Sections 3, 4, 7, 9, 10)
Texas Railroad Commission. (2025). Monthly Crude Oil Production by County. https://www.rrc.texas.gov/oil-and-gas/research-and-statistics/production-data/monthly-crude-oil-production-by-county
D-1. RRC monthly crude oil production data by county. Combined with EIA wellhead price data to compute C2 component (oil and gas wellhead value) of the Stage 1 Hybrid Gross Base. Used in Section 4 Stage 1 methodology.
Texas Education Agency. (2025). PEIMS Financial Data — State Funding Reports. https://tea.texas.gov/finance-and-grants/state-funding/state-funding-reports-and-data
E-1. TEA PEIMS financial data. Supporting source for T4 ISD revenue figures and the $23.623B state education reallocation from T1 to T4. Cross-reference for ISD total TRO in Section 1 entity tier table.
Texas Department of Insurance. (2024). Market Conditions Annual Report (MCAR) — Texas Insurance Market 2024. https://www.tdi.texas.gov/reports/documents/mcar2024.pdf
F-1. TDI MCAR 2024. Primary source for C3 Insurance Premiums component ($83.07B) of the Stage 1 Hybrid Gross Base. Texas-domiciled insurance premium volumes for all lines of coverage. Used in Section 4 Stage 1 methodology.
Texas REALTORS. (2025). Texas Real Estate Market Statistics 2025. https://www.texasrealtors.com/market-statistics
I-1. TX REALTORS market statistics. Primary source for C4 (real estate transactions) component of Stage 1 Hybrid Gross Base and for TLES-9 Primary Residence Home Purchase value ($93.255B). Used in Section 4 Stage 1 and TLES tables.
National Association of REALTORS. (2024). Profile of Home Buyers and Sellers — 2024. https://www.nar.realtor/research-and-statistics/research-reports/highlights-from-the-profile-of-home-buyers-and-sellers
I-2. NAR 2024 buyer/seller profile. Supporting source for primary residence purchase rate assumptions used in TLES-9 calculation methodology. Used in Section 4 TLES table note.
State Higher Education Executive Officers Association. (2024). State Higher Education Finance (SHEF) Report FY2024. https://shef.sheeo.org/report/
I-3. SHEEO SHEF FY2024. Primary source for TLES-6 Education base ($32.976B, K-12 private tuition + public higher education tuition in Texas). Used in Section 4 TLES table.
Child Care Aware of America. (2025). State-by-State Child Care Costs and Data — 2025. https://www.childcareaware.org/resources/data/
I-4. Child Care Aware 2025 state data. Primary source for TLES-8 Childcare base ($19.15B, Texas total childcare expenditures). Used in Section 4 TLES table and Section 3 TLES category description.
Texas Workforce Commission. (2025). Child Care Programs — Enrollment and Cost Data. https://www.twc.texas.gov/programs/childcare
I-5. TWC childcare enrollment data. Supporting cross-reference for TLES-8 Childcare base. Confirms enrollment volume consistent with Child Care Aware expenditure figure for Texas.
Texas Commission on Environmental Quality. (2025). Water Districts Lookup — Special Water Districts of Texas. https://www.tceq.texas.gov/agency/data/lookup-data/water-districts.html
J-1. TCEQ water districts lookup. Primary source for water district entity counts within the T5 special district tier and T2/T3 absorbed district sub-categories. Used in Section 1 entity count table and Section 3 plan description of 7,144 governed entities.
National Association of Insurance Commissioners. (2024). Key facts and market trends: Texas [State market scorecard]. https://content.naic.org/sites/default/files/publications-key-facts-market-trends-texas.pdf
Source for TLES-10 (residential property insurance, $20,193,000,000) and TLES-11 (personal auto insurance, $32,118,773,131). TX homeowners multi-peril DPW CY2024: $19,237,083,131 (+ ~$956M renters); TX personal auto premiums CY2024 (Insurify −8% adj.): $32,118,773,131. TLES-10 corrected 2026-06-01 (TDI 14% growth figure removed).
American Council of Life Insurers. (2024). Life insurers fact book 2024. ACLI. https://www.acli.com/-/media/public/pdf/news-and-analysis/publications-and-research/2024-fact-book/pub_2024aclifactbook_complete.pdf
Source for TLES-12 (individual life insurance, $15,450,000,000). ACLI 2024 Fact Book: TX individual life premiums CY2023 = $15,450,000,000 at 8.09% national share. Corrected 2026-06-01 (prior $11.5B used an incorrect 5.85% share).