In effect, the BNRT as proposed was a type of subtraction-method value-added tax in that it sought to tax each firm on the market value of the goods/services it produced, less amounts paid to other firms.
Had the Commission's recommendations been accepted, the remaining state tax structure would have consisted primarily of a reformed and reduced income tax and the BNRT.
Unlike the corporate income tax, the BNRT would come with its own legal and administrative complexities that could not be avoided through reliance on an existing federal structure.
Second, adoption of the BNRT or similar reforms would likely trigger constitutional and statutory challenges based on the Quill holding and Pub.
By shifting the tax burden away from the income tax toward the BNRT, the overall federal subsidy for the state's taxes would necessarily decline.