Beneficiary-Resolved Tax Expenditure Governance

Beneficiary-Resolved Tax Expenditure Governance (BRTEG) is a governance framework for tracing tax-preferred expenditures to their ultimate beneficiaries. Rather than treating deductions, exclusions, depreciation schedules, credits, and similar provisions solely as tax mechanics, BRTEG models them as public subsidy flows whose economic benefit must ultimately terminate in either enterprise utility, taxable personal utility, escrow, refusal, or appealable conversion. The framework combines tax expenditure theory, economic substance doctrine, beneficiary-resolution concepts derived from FATCA and CRS, and transaction-governance principles inspired by VAT input-credit systems into a unified attribution architecture. BRTEG represents subsidized transactions and asset events as benefit graphs composed of typed relationships, evidence weights, provenance bindings, and beneficiary allocations. Utility attribution is performed through evidence-based graph analysis rather than declarative labeling alone, allowing enterprise and personal benefit to be distinguished within mixed-use assets, expenses, and subsidy pathways. The framework introduces conditional Minimum Adequate Cost (MAC) baselines, beneficiary attribution functions, conservation constraints, safe-harbor thresholds, appeal mechanisms, and conversion pathways that route unresolved or personalized subsidy value into taxable treatment. The paper formalizes a Bounded Reduction Theorem showing that, under explicit assumptions regarding evidence completeness, attribution accuracy, conservation, and enforceable conversion, the framework weakly reduces subsidized luxury substitution relative to conventional tax-preferred treatment and strictly reduces it whenever conversion exceeds aggregate attribution error. The model is designed as a governance substrate rather than a tax-code redesign, operating within existing statutory structures while providing a systematic mechanism for beneficiary resolution, subsidy accountability, and public-benefit tracing. BRTEG proposes a graph-governed approach to tax expenditure administration in which every subsidized path lands somewhere, transforming subsidy governance from category-based classification into evidence-based beneficiary attribution.