What a Real Tax Reform Could Look Like – III: A Carbon Tax to Address Climate Change

Source:  James Hansen, Global Temperatures, update of December 18, 2017


A.  Introduction

The final element of a comprehensive tax reform would be a tax to address climate change.  Previous posts have looked at what a true reform of corporate and individual income taxes could look like, plus what could be done to ensure Social Security benefits can continue to be paid in accord with current formulae, and indeed enhanced.  This post will look at a tax on greenhouse gas emissions (commonly called a carbon tax, as carbon dioxide is the primary contributor) to address global warming.

There is no doubt the planet is warming –  the chart above shows the most recent estimates.  And this is primarily due to our economies pouring into the air carbon dioxide and certain other gases (such as methane) that lead to heat being retained by the atmosphere.  These greenhouse gases have warmed the planet, leading to an increased frequency of extreme weather events such as the series of remarkably intense hurricanes that hit the US this August and September.  The cost, already being incurred, has been staggering.  Early estimates of the cost of just Hurricanes Harvey (which hit Texas) and Irma (which hit Florida) reach $290 billion.  Hurricane Maria (which hit Puerto Rico) may have cost Puerto Rico as much as $95 billion according to an early estimate (and this excludes the cost to other Caribbean nations it hit).

As I am writing this (January 3, 2018), record-breaking cold has swept over much of the eastern half of the US.  And it is forecast to get worse over the next few days.  Trump has, not surprisingly, tweeted that this cold shows that global warming is not true.  But this illustrates well his ignorance.  First, there is more to the world than the eastern US.  There is also today unseasonably warm weather in the western US (especially Alaska, relative to what is normal there), as well as in Europe, Russia, and especially Siberia.  Overall, the average global surface temperature today is 0.5 degrees Celsius above the 1979 to 2000 average for this time of year, and 0.9 degrees Celsius above that average in the Northern Hemisphere.  But second, that blast of cold hitting the eastern US should not be taken as a surprising outcome of global warming.  Warming leads to greater volatility in atmospheric currents, including in the jet streams that allow (or block) cold air to come down from the Arctic.

One cannot, of course, attribute with certainty any particular severe weather event (whether hurricanes, extreme hot or cold temperatures, drought or floods, and more) to climate change.  We had severe weather events before global warming became significant.  But the same is true of lung cancer and smoking:  One cannot attribute any individual’s death from lung cancer to his or her smoking.  People died of lung cancer before smoking became common.  The issue, rather, is that smoking increases the likelihood of getting lung cancer.  Similarly, global warming increases the likelihood and hence frequency of severe weather events.

And that is precisely what we have seen.  Severe weather events have increased in number in recent years as the planet has warmed and as climate change models have predicted.  A database maintained by the National Oceanic and Atmospheric Administration (NOAA, the home of the National Weather Service) has kept track since 1980 of the number of weather and climate disasters in the US which each cost $1 billion or more (in 2017 prices).  Over that close to 37 year period the 7 worst years (in terms of the number of such disasters) have all come in the last 10 years (including 2017, which as of end September already had tied the worst full year so far, and will exceed it once fourth quarter data is included).

Global warming, arising from man-made emissions of carbon dioxide (CO2), methane (natural gas), and certain other gases (together, greenhouse gases or GHGs, for the greenhouse effect they cause), is thus imposing a huge cost already on society, and one which will get worse as the planet warms further.  It is thus a mark of confusion to say, as Trump and many Republican politicians have, that we cannot “afford” to address the causes of the warming planet.  We are already bearing the costs, and those costs will get far worse if nothing is done.  The question is whether steps will be taken to reduce those costs by addressing the underlying causes.

The issue is that the costs such GHG emissions cause are not being borne by those who emit those gases.  The emitters of GHGs are in effect being subsidized, and encouraged to burn fossil fuels rather than make use of a cleaner alternative.  And when a producer is not bearing the full cost of what he is producing, it will be badly done.  The key is to charge a tax or fee on such production equal to the cost being imposed on others, so that the producer faces the full cost of what he is making.  The producer will then have a reason to make suitable choices on how the product can be made at the least cost to all.  And consumers, facing the full costs of what they are buying, can then make suitable choices on whether to buy one product or another.

A suitable tax on greenhouse gas emissions would bring prices in line with the total costs being incurred.  A comprehensive tax reform should include this.  And it would be straightforward to implement.  There is indeed a well worked out plan being promoted by a group of traditional Republican conservatives, the Climate Leadership Council, with the active involvement and endorsements of several Treasury Secretaries in past Republican administrations (Hank Paulson, James Baker, and George Schultz); as well as of individuals such as Michael Bloomberg and liberal and conservative economists such as Larry Summers, Martin Feldstein, and Gregory Mankiw; companies such as ExxonMobil, General Motors, and Shell; and environmental organizations such as The Nature Conservancy and Conservation International.

It is a good plan, and I would suggest basically just copying it.  The proposal will be explained below.  A one-page summary of the Climate Leadership Council’s specific proposal is available here, while a more complete description is available here.  A very similar proposal has also been assessed by the US Treasury, with a brief summary of the Treasury analysis available on the Climate Leadership Council website here, while the complete Treasury analysis is available here on the Treasury website (assuming the Trump administration has not taken it down).  The Treasury assessment is excellent, as it reviews precisely how one could implement such a tax, including the practicalities, and arrives at specific quantitative estimates of the impact on different income groups.  The analysis below will basically follow the variant of the plan as assessed by the Treasury.

This post will first provide a description of that plan, how it could be implemented, and what the impact on prices might be.  Importantly, clean alternatives exist for many of the processes which emit GHGs, particularly from the burning of fossil fuels, which thus can be substituted for processes emitting those gases.  This would limit the price impact and smooth the way to sharp reductions in GHG emissions.  Furthermore, a key feature of this plan is that the revenues that would be collected by the carbon tax would all be rebated to the American population.  The final section will discuss this and the distributional implications.  The plan would be revenue neutral – the aim is to change prices so that they fully reflect the costs being incurred, not to raise revenues.  And the rebates would be distributionally positive, with the bottom seven deciles of the population (the bottom 70%) coming out ahead after the rebates.  Only the top three deciles (top 30%) would see a net loss, as a direct consequence of their disproportionate share in consumption of goods that cause the GHG emissions in the first place.

B.  A Carbon Tax to Address Climate Change

In brief, under this proposal a tax would be charged for each unit of GHG pollution emitted.  The Climate Leadership Council would set the tax to start at $40 per ton of CO2, with the taxes on other GHGs set in proportion based on their global warming impact per ton relative to that of CO2.  This is often called simply a carbon tax, although it is in fact a tax on CO2 (carbon dioxide) emissions and on other GHGs in proportion to their global warming impact.  The tax would then rise in real terms over time.  The start date would presumably have been 2018, although this was not explicit (the proposal came out in early 2017).  The Treasury variant examined a price of $49 per ton of CO2-equivalent starting in 2019 (with some phasing in of the goods to which it would apply until 2021), and then increasing at a rate of 2% a year in real terms from 2019.

Importantly, all revenues collected would be returned directly to the American population.  The impact on the federal budget thus would be revenue neutral.  There would also be border adjustments for imports and exports (discussed below).  The Treasury estimates that at $49 per ton, the carbon tax would lead to a rebate in the first year (2019) of $583 per person, or $2,332 for a family of four.  Scaling this in proportion, a $40 per ton carbon tax would lead to a rebate of $476 per person, or $1,904 for a family of four.  And the tax would be highly progressive.  The Treasury estimated that there would on average be net income gains for the bottom 70% of the population.  That is, their rebates would be greater than the higher amounts they would need to spend on goods and services to reflect the cost of the carbon tax.

In more detail, under this plan a price (whether $40 or $49 to start) would be charged which reflects the cost to society of the GHGs being emitted as part of the production process for the good or service being produced.  This is called the “social cost of carbon”, and while the concept is clear, it is difficult in practice to estimate precisely.  Its value will depend on factors which are difficult to know at this point in time, including the full cost to our economies (starting now and extending many decades into the future) as a consequence of climate change, the cost of technologies to limit GHG emissions (again starting now, and then for decades into the future), and the appropriate values for parameters such as the proper discount rate to use to put the costs and benefits over this range of time all into the prices of today.  A fundamental difficulty of GHG emissions is that their impact is not just in the near term, but can extend for centuries.  They remain in the atmosphere for a very long time.

Thus while starting at a reasonable cost of carbon (whether $40 or $49) is important, probably more important is how this price should be adjusted over time to reflect actual experience.  Some predictability in the path is also valuable, so firms can make their investment decisions accordingly.  Thus the Climate Leadership Council plan would have the price rise in real terms over time at some unspecified pace, while the Treasury assessment assumed concretely a rise of 2% a year in real terms.  Such a 2% real increase is reasonable.

One should, however, also recognize the inherent uncertainty, as the proper price on carbon is difficult to know before we have any experience with such a plan.  Thus one should allow for reassessment and adjustment, perhaps every five years or so, with the pace of price adjustment increased or decreased depending on the observed response.  The pace would be raised if we find that GHG emissions are not falling at the pace needed, or reduced if we find GHGs are falling at a more rapid pace than anticipated and needed.  Past experience with market mechanisms to reduce pollution (in particular the use of trading schemes to reduce sulfur dioxide and nitrogen oxides pollution) worked surprisingly well, with costs well below what had been anticipated and what would have been incurred through traditional regulatory regimes.  The same would be likely, in my view, if we would start to price GHG emissions.

Pricing GHG emissions is also relatively straightforward administratively for the bulk of GHG sources.  Fully 76% of GHG emissions in the US come from the burning of fossil fuels.  This rises to 83% if one adds in the emission of GHGs in the production of the fossil fuels themselves (at the mine or well-head) plus from the non-energy use of fossil fuels.  The carbon tax thus could be applied at the level of the limited number of power plants that still burn coal; at the level of petroleum refineries where substantially all crude oil must be processed; and at the level of gas pipelines as substantially all natural gas is transported via pipelines.  A limited number of industrial plants then account for a significant share of the remainder.  These include from the use of coking coals in the production of iron and steel; from the production of petrochemicals such as plastics; and GHGs resulting from the production of cement, glass, limestone, and similar products.  For these, it would be straightforward to apply a carbon tax at the factory or plant level.  There would remain GHG emissions from a range of resources, including in particular in agriculture (accounting for about 8% of GHG emissions in the US), and the Treasury analysis assumes the carbon tax would not apply to those sources.  But they are a small share of the total, and an issue one could address in the future.

A key part of the plan is that there would also be a border tax adjustment, where exports would receive a rebate for the carbon taxes paid on their production, while imports would be charged a carbon tax based on the GHGs emitted in their production.  The rebate for exports means that US production would not be disadvantaged by being located here, and there would be no incentive from this source to move such plants abroad.  This addresses the Trump criticism (and confusion) that such carbon taxes will make US industry uncompetitive.  And imports would be charged a carbon tax based on their GHG emissions to the extent such imports do not already reflect such charges (which would likely be the case, as they too would likely be given rebates in their home countries on carbon taxes paid, just as US exports would be).

A feature of this border tax adjustment is that revenues for the US would be generated (and rebated to the US population) in the case where other countries are not themselves charging a carbon tax (or the equivalent, such as in a cap and trade system), but also (given the US trade structure) even when they are.  In the first case, where other countries are not at first themselves charging such a tax, imposing the carbon tax on such imports will generate revenues which would be distributed to the US population.  This would provide a strong incentive for those other countries to join the US and start to charge a similar carbon tax.  And such a border adjustment for the carbon tax would be compliant with WTO rules on trade, as the tax would simply be ensuring that imported goods are being taxed the same as their domestic equivalents are (just as is true for a value-added tax).  This is not discrimination against imports, but rather equal treatment.

In the second case, where trading partners are themselves all charging a similar carbon tax (let’s assume), the US would still come out ahead in carbon tax revenues due to our trade structure.  US imports of goods are about 50% higher than its exports of goods, and it is primarily in the production of goods that GHGs are emitted.  Partially offsetting this in the overall trade balance, US exports of services are about 50% higher than its imports of services.  But services are a smaller share of trade, plus services are not as intensive as goods in the GHGs emitted.  Overall, the US has a current account deficit (more imports of goods and services than exports), matched by capital inflows being invested in the US.  With such a trade structure, the carbon taxes charged on imports will substantially exceed whatever is rebated on exports.  The US population would come out ahead.  Put another way, producers of goods being sold in the US are currently being provided a subsidy by not charging them for the cost we are incurring due to the greenhouse gases being emitted in their production.  Given the US trade structure, a substantial share of this subsidy is going to foreign producers.  A tax on such GHG emissions is simply the removal of this subsidy.

C.  Price Impacts, and the Viability of Clean Alternatives

Applying the carbon tax will lead producers to raise their prices if they do not otherwise adjust their processes.  For transportation fuels, for example, the Treasury analysis estimated that at $49 per ton of CO2 (and its equivalent for other GHGs), the tax would equal 44 cents per gallon for gasoline, or 50 cents per gallon for diesel fuel.  While significant, such increases are not huge.  There have been far greater fluctuations in such fuel prices in recent years in response to the price of crude oil rising or falling, and consumers and the economy have been able to accommodate such changes.

More broadly, and expressed in terms of percentage increases, the Treasury analysts estimated that if the cost increases from the carbon tax were all fully passed along, the price of gasoline would rise by 11.8%, home heating oil by 12.4%, and air transportation by 7.5%.  The price of natural gas would go up by 27.0% and the price of electricity by 16.9%, but note these are the prices of just the energy alone.  The delivered price to our homes also includes distribution and other charges.  For natural gas, for example, the energy component of my bill (in Washington, DC) was just 44% of my total bill over the last 12 months, so a 27% increase in the wholesale cost of natural gas would mean a 15% increase in my overall bill for gas.  There would be no reason for distribution and other such charges to go up by any significant amount, as their costs depend on the volume delivered and not on the wholesale cost of the gas being delivered (and similarly for electricity).  Overall, the Treasury analysis forecasts that prices in general would go up by 2.6% if the new carbon tax (at $49 per ton of CO2) were fully passed forward.

But the higher costs would provide incentives both to producers to change how they make things, and to consumers to take into account the total costs in their decisions on what to buy.  One would see this most importantly (given its share as a source of GHG emissions) in how electricity is produced.  Generating electricity by the burning of fossil fuels is now heavily subsidized, in effect, as nothing is charged for the cost of the damage done (hurricanes and other severe weather events, and more) by the resulting GHG emissions.  But even with such subsidies going to those who burn fossil fuels, solar and wind produced power is now competitive (even without the subsidies going to solar and wind – see below) for newly built power plants, and indeed has been for some years.  See the careful analysis of the relative costs that is undertaken annually by Lazard (see here for their November 2017 report).  Indeed, Lazard found in its 2017 analysis that at current costs, utility-scale solar and wind generation is now often cheaper than just the operating costs of coal or nuclear plants, thus encouraging such substitution even when the capital costs of coal and nuclear plants are treated as a sunk cost.

Furthermore, solar and wind technology is still developing, with costs falling rapidly, while at this point the further reduction in costs in traditional power generation is slow.  Lazard estimates the levelized cost of energy production at a new installation (in terms of dollars of overall costs, including capital costs, per megawatt hour of electricity generated, and excluding explicit subsidies on renewables) fell by 72% between 2009 and 2017 for utility-scale solar installations and by 47% for wind generation (to prices of $50 and $45 per megawatt hour, for solar and wind respectively; this is equivalent to 5 cents and 4.5 cents per kilowatt hour).  In contrast, the cost for power generated by coal fell by just 8% over this period (to $102 per megawatt hour) and by 28% for natural gas (to $60).  And the full levelized cost for nuclear power generation actually rose by 20% over the period (to $148).

There is, of course, wide variability in the cost of solar and wind across the country, depending on local conditions.  Existing coal and nuclear plants are also of various ages and efficiencies, and hence also of varying costs.  Thus overall averages tell only part of the story.  The cost competitiveness (on average) of new installations does not mean that all new installations will be solar or wind, much less that all generation would or could shift immediately.  But the now competitive costs have led to a bit over 50% of all new generation capacity built in the US over the last 10 years (2007 to 2016) to come from installations of solar, wind, or other renewables (with most of the solar coming only in the second half of that period).

No transition will be instantaneous, but should a significant carbon tax be imposed (of $40 or $49, for example), one should see an acceleration in the pace of such substitution of renewables for fossil fuels.  And with such substitution, the impact on higher power prices will be limited in time, and should soon decline.

The other major user of fossil fuels is transportation, and here one sees a similar dynamic.  Electric battery powered cars are now either competitive in cost or close to it (depending on how one values other attributes, such as better performance and inherently easier maintenance), and a carbon tax will accelerate the transition to such vehicles.  And battery-powered vehicles are not just limited to cars.  Tesla has announced plans to produce heavy trucks powered by batteries, with a range of up to 500 miles on a charge.  Costs would be more than competitive with traditional fueled heavy trucks, and a substantial number of pre-orders have indeed already come in from owners of large trucking fleets.  There is an interest at least in trying this.  And with battery-powered heavy trucks possible, the same is true for full-size buses.

Again, starting to charge for the costs borne by society from the CO2 and other GHGs emitted in transportation would accelerate the shift to less polluting vehicles.  It won’t happen overnight.  But that shift will limit the extent and duration of higher costs stemming from charging a carbon tax.

And while such a tax alone will not lead to zero GHG emissions with current technologies available, it would be a giant step in that direction.  It would also provide a strong incentive to develop the technologies that would carry this further and at a lower cost.

D.  Distributional Implications

Finally and importantly, the funds collected by the carbon tax would be fully rebated to all Americans, with the same amount rebated per person.  The Treasury analysis estimated that at $49 per ton of CO2 in 2019, the carbon tax would collect funds sufficient to provide a rebate of $583 per person (for the year), or $2,332 for a family of four.  The rebate could be provided annually or quarterly, or even monthly, and through the IRS or Social Security.

The rebates would also be distributionally positive.  The poor would indeed benefit on a net basis.  Being poor, they do not consume that much, and thus do not account for a high share of GHG emissions.  The rich, in contrast, not only consume more (they are rich, and can afford more), but the products they buy are also more polluting in greenhouse gases (big gas-guzzling cars rather than small fuel-efficient ones; jet travel for vacations but not public transit; large homes kept heated and air-conditioned rather than smaller homes and apartments; etc.).  Thus the rich will receive back less than what is paid in carbon taxes on the goods they consume, while the poor will receive back more.  Furthermore, because the poor are poor, a given dollar amount rebated to them will be a higher percentage of their (low) incomes, than the same dollar amount would be (in percentage terms) for the rich.

The impacts are significant.  The Treasury analysis (based on data they use for their tax simulation models) concluded that the impacts by family income decile would be:

Net Impact on Income from $49 per ton Carbon Tax, with $583 per Person Rebate, by Family Decile


% of Income

0 to 10


10 to 20


20 to 30


30 to 40


40 to 50


50 to 60


60 to 70


70 to 80


80 to 90


90 to 100


Families are ranked here by income decile, so the first decile (0 to 10%) is made up of the 10% of families (in number) who have the lowest incomes, the second decile (10 to 20%) is made up of the 10% of families with the next lowest incomes, and so on, up to the richest 10% of families (90 to 100%).

The results indicate that on a net basis (i.e. after taking account of the higher prices that would be paid on goods purchased, reflecting the carbon tax at $49 per ton), the lowest income decile families would see an increase in their real incomes of 8.9% following the $583 per person rebate.  This is quite substantial.  And the analysis found there would be a similar, positive, gain for all families up through the 7th decile, although at diminishing shares of their income.  The top 3 deciles would end up paying more on a net basis, due to their greater purchases of goods where greenhouse gases are emitted (both in total amount and in the mix of their goods).  But the net cost reaches just 1% of incomes for the richest decile.  It is only a small share in part because their incomes are of course the highest.  This tax is not unaffordable.

E.  Conclusion

To conclude, imposing a carbon tax is administratively practical, would bring prices and costs in line with the costs being borne by society when greenhouse gases are emitted, and even with current technologies would lead to a significant shift away from processes that are warming our planet.  It is a fundamental confusion to assert, as Trump and others have done, that “we cannot afford it”.  That is nonsense:  We are paying the costs already (in an increased frequency of severe weather events, in droughts in some areas and floods in others, and other such impacts), and they will get far worse if nothing is done.  Furthermore, such a carbon tax would not reduce our competitiveness when applied equally to imported items (and rebated for exports).  Indeed, with our current trade structure, the US would come out ahead financially by starting to charge for GHG emissions.

Such a tax also would be distributionally highly progressive, as the poor would come well ahead on a net basis with the revenues collected being rebated back to the population.  Indeed, it is estimated that the bottom 70% of the population would come out ahead on a net basis.  And while the rich would end up paying more, reflecting their greater consumption and the GHG intensity of the goods they buy, this would come just to 1% of the incomes of the richest 10% of the population.

Such a tax on GHG emissions would be the final component of what a comprehensive tax reform really should have looked like.  As discussed in the preceding posts on this blog, there should have been a reform to simplify corporate and individual income taxes (with all sources of income taxed similarly), plus action taken on Social Security taxes to ensure the system will be sustained for the foreseeable future.  None of this was done.  Nor was any action taken to address climate change, where the subsidy we are implicitly providing fossil fuels and other sources of greenhouse gas emissions (by not charging for the damage being done as a result of those emissions) could have been addressed by a tax on such emissions.

This is not surprising, unfortunately.  There are important vested interests in the fossil fuel industries (coal, oil, and gas) that benefit from not being charged for the damage their fuels are causing.  As a rationalization of this, Trump and much of the Republican Party continue to deny that climate change even exists.  But the result will be that the damage being done, already large, will grow over time.  Plus, once the doubters do finally recognize it, the actions that will then need to be taken will be more costly and disruptive than if action were taken now.

As discussed above, there is no practical or special administrative difficulty to addressing the climate change problem now.  It would be straightforward to implement a tax on GHG emissions.  And the sooner this is done, the better.

What a Real Tax Reform Could Look Like – II: Social Security

A.  Introduction

The previous post on this blog looked at what a true tax reform could look like, addressing issues pertaining to corporate and individual income taxes.  This post will look at what should be done for Social Security and the taxes that support it.  Our federal tax system involves more than just income taxes.  Social Security taxes are important, and indeed many individuals pay more in Social Security taxes than they do in individual income taxes.  Overall, Social Security taxes account for just over a quarter of total federal revenues collected in FY2017, and are especially important for the poor and middle classes.  With a total tax of 12.4% for Social Security (formally half paid by the employee and half by the employer, but in reality all ultimately paid by the employee), someone in the 10% income tax bracket is in fact paying tax at a 22.4% rate on their wages, someone in a 15% bracket is actually paying 27.4%, and so on up to the ceiling on wages subject to this tax of $128,400 in 2018.  They also pay a further 2.9% tax on wages for Medicare (with no ceiling), but this post will focus just on the Social Security side.

And as is well known, the Social Security Trust Fund is forecast to be depleted by around 2034 if Congress does nothing.  Social Security benefits would then be automatically scaled back by about 22%, to a level where the then current flows going into the Trust Fund would match the (cut-back) outflows.  This would be a disaster for many.  Congress needs to act.

A comprehensive tax reform thus should include measures to ensure the Social Security Trust Fund remains solvent, and is at a minimum able, for the foreseeable future, to continue to pay its obligations in full.  Also, and as will be discussed below, Social Security benefit payments are embarrassingly small.  Cutting them further is not a “solution”.  And despite their small size, many now depend on Social Security in their old age, especially as a consequence of the end of most private company defined benefit pension schemes in recent decades.  We really need to look at what can be done to strengthen and indeed expand the Social Security safety net.  The final section below will discuss a way to do that.

B.  Remove the Ceiling on Wages Subject to Social Security Tax

As was discussed in an earlier post on this blog, the Social Security Trust Fund is forecast to run out by around 2034 not because, as many presume, baby boomers will now be retiring, nor because life expectancies are turning out to be longer.  Both of these factors were taken into account in 1983, when following recommendations made by a commission chaired by Alan Greenspan, Social Security tax rates were adjusted and other measures taken to ensure the Trust Fund would remain solvent for the foreseeable future.  Those changes were made in full awareness of when the baby boomers would be retiring – they had already been born.  And while life expectancy has been lengthening, what matters is not whether life expectancy has been growing longer or not, but rather whether it has been growing to be longer than what had earlier been forecast when the changes were made in 1983.  And it hasn’t:  Life expectancy has turned out to be growing more slowly than earlier forecast, and for some groups has actually been declining.  In itself, this would have lengthened the life of the Social Security Trust Fund over what had been forecast.  But instead it was shortened.

Why is it, then, that the Trust Fund is now forecast to run out by around 2034 and not much later?  As discussed in that earlier post, the Greenspan Commission assumed that wage income inequality would not change going forward.  At the time (1983) this was a reasonable assumption to make, as income inequality had not changed much in the post World War II decades leading up to the 1980s.  But from around 1980, income distribution worsened markedly following the Reagan presidency.  This matters.  Wages above a ceiling (adjusted annually according to changes in average nominal wages) are exempted from Social Security taxes.  But with the distribution of wages becoming increasingly skewed (in favor of the rich) since 1980, adjusting the ceiling according to changes in average wages will lead to an increasing share of wages being exempted from tax.  An increasing share of wage income has been pulled into the earnings of those at the very top of the income distribution, so an increasing share of wages has become exempt from Social Security taxes.  As a direct consequence, the Social Security Trust Fund did not receive the inflows that had been forecast.  Thus it is now forecast to run out by 2034.

Unfortunately, we cannot now go back in time to fix the rates and what they covered to reflect the consequences of the increase in inequality.  Thus what needs to be done now has to be stronger than what would have been necessary then.  Given where we are now, one needs to remove the ceiling on wages subject to the Social Security tax altogether to ensure system solvency.  If that were done, the depletion of the Social Security Trust Fund (with all else unchanged, including the benefit formulae) would be postponed to about 2090.  Given the uncertainties over such a time span (more than 70 years from now), one can say this is for the foreseeable future.

The chart at the top of this post (taken from the earlier blog post on this issue) shows the paths that the Social Security Trust Fund to GDP ratio would take.  If nothing is done, the Trust Fund would be depleted by around 2034 and then turn negative (not allowed under current law) if all benefits were continued to be paid (the falling curve in black).  But if the ceiling on wages subject to tax were removed, the Trust Fund would remain positive (the upper curves in blue, where the one in light blue incorporates the impact of the resulting benefit changes under the current formulae, as benefits are tied to contributions).

As discussed in that earlier blog post, the calculations indicate the Social Security Trust Fund then would remain solvent to a forecast year of about 2090.  That is over 70 years from now, and the depletion at that time is largely driven by the assumption (by the Social Security demographers) on how fast life expectancy is forecast to rise in the future.  This could again be over-estimated.

Lifting the ceiling on wages subject to Social Security tax would also be equitable:  The poor and middle classes are subject to the 12.4% Social Security tax on all of their wages; a rich person should be similarly liable for the tax on all of his or her earnings.  And I cannot see the basis for any argument that a rich person making a million dollars a year cannot afford the tax, while a poor person can.

C.  Apply the Social Security Tax to All Forms of Income, Not Just Wages, and Then Raise Benefits

But I would go further.  In the modern era, there is no reason why the Social Security tax should be applied solely to wage earnings, while earnings from wealth are not taxed at all.  As one of the basic principles of taxation noted in the previous post on tax reform, all forms of income should be taxed similarly, and not with differing rates applied to one form (e.g. 12.4% on wages) as compared to another (e.g. 0% on income from wealth).

Broadening the base would allow, if nothing else is changed, for a reduction in the rate to produce the same in revenues.  We can calculate roughly what that lower rate would be.  Making use of IRS data for incomes reported on the Form 1040s in 2015 (the most recent year available), one can calculate that if Adjusted Gross Income (line 37 of Form 1040) was used as the base for the Social Security tax rather than just wages, the Social Security tax rate could be cut from 12.4% to 8.6% to generate the same in revenues.  That is, taxing all reported income (including income from wealth) at an 8.6% rate (instead of taxing just wages at 12.4%) would generate sufficient revenues for the Social Security Trust Fund to remain solvent for the foreseeable future.  This would be a more than 30% fall in the taxes on wages, but also, of course, a shift to those who also earn a substantial share of their income from wealth.

[Note:  There would also be second-order effects as Social Security benefits paid are tied to the taxes paid over the highest 40 years of an individual’s earnings, there is some progressivity in the formulae used, and taxes on all earnings rather than just on wages will shift the share of the taxes paid towards the rich.  But the impact of these second-order effects would be relatively small.  Also, the direction of the impact would be that the break-even tax rate could be cut a bit further to allow for the same to be paid out in benefits, or a bit more in benefits could be paid for the same tax rate.  But given that the impact would be small, we will leave them out of the calculations here.]

The 8.6% tax on all forms of income would generate the revenues needed to keep the Social Security Trust Fund solvent at the benefit levels as defined under current law.  But Social Security benefit payments are embarrassingly small.  Using figures for September 2017 from the Social Security Administration, the average benefit paid (in annualized terms) for all beneficiaries is just $15,109, for retired workers it is $16,469, and for those on disability it is $12,456.  These are not far above (and for disability indeed a bit below) the federal poverty guideline level of $13,860 in 2017 for a single individual.  And the average benefit levels, being averages, mean approximately half of the beneficiaries are receiving less.

Yet even at such low levels, Social Security benefits account for 100% of the income of 20% of beneficiaries aged 65 or higher; for 90% or more of the incomes of 33% of those aged beneficiaries, and 50% or more of the incomes of 61% of those aged beneficiaries (data for 2014; see Table 9.A1).  And for those aged 65 or older whose income is below the federal poverty line, Social Security accounts for 100% of the income of 50% of them, for 90% or more of the income of 74% of them, and for 50% or more of the income for 93% of them (see Table 9.B8).  The poor are incredibly dependent on Social Security.

Thus we really should be looking at a reform which would allow such benefit payments to rise.  The existing levels are too low to serve as an effective safety net in a country where defined benefit pension plans have largely disappeared, and the alternative approach of IRAs and 401(k)s has failed to provide adequate pensions for many if not most workers.

Higher benefits would require higher revenues.  To illustrate what might be done, suppose that instead of cutting the Social Security tax rate from the current 12.4% to a rate of 8.6% (which would just suffice to ensure the Trust Fund would remain solvent at benefit levels as defined under current law), one would instead cut the tax rate just to 10.0%.  This would allow average Social Security benefits to rise by 15.8% (= 10.0%/8.6%, but based on calculations before rounding).  One can work out that based on the distribution of Social Security benefit payments in 2015 (see table 5.B6 of the 2016 Annual Statistical Supplement), that if benefits were raised by 5% for the top third of retirees receiving Social Security and by 10% for the middle third, then the extra revenues would allow us to raise the average benefit levels by 45% for the bottom (poorest) third:

Annual Social Security Benefits

Avg in 2015

% increase



   Bottom Third of Retirees





   Middle Third of Retirees





   Top Third of Retirees





Overall for Retirees





This would make a significant difference to those most dependent in their old age on Social Security.  The poorest third of retirees receiving Social Security received (in December 2015 and then annualized) a payment of just $8,761 per year.  Increasing this by 45% would raise it to $12,733.  While still not much, it would be an increase of almost $4,000 annually.  And for a married couple where both had worked and are now receiving Social Security, the benefits would be double this.  It would make a difference.

D.  Conclusion

Conservatives have long been opposed to the Social Security system (indeed since its origin under Roosevelt), arguing that it is a Ponzi scheme, that it is unsustainable, and that the only thing we can do is to scale back benefits.  None of this is true.  Rather, Social Security has proven to be a critically important support for the incomes of the aged.  An astonishingly high share of Americans depend on it, and its importance has only increased with the end of defined benefit pension schemes for most American workers.

But there are, indeed, problems.  Due to the ceiling on wages subject to Social Security tax, and the sharp increase in inequality starting in the 1980s under Reagan and continuing since, an increasing share of wages in the nation have become exempt from this tax.  As a consequence, and if nothing is done, the Trust Fund is now forecast to run out in 2034.  This would trigger a scaling back of the already low benefits by 22%.  This would be a disaster for many.

Lifting the ceiling on wages, so that all wages are taxed equally, would resolve the Trust Fund solvency issue for the foreseeable future (to a forecast year of about 2090).  Benefits as set under the current formulae could then be maintained.  Furthermore, if the base for the tax were extended to all forms of income (including income from wealth), and not limited just to wages, benefits as set under current formulae could be sustained with the tax rate cut from the current 12.4% to a new rate of just 8.6%.

But as noted above, current benefits are low.  One should go further.  Cutting the rate to just 10%, say, would allow for a significant increase in benefits.  Focussing the increase on the poorest, who are most dependant on Social Security in their old age, a rate of 10% applied to all forms of income would allow benefits to rise by 5% for the top third of retirees, by 15% for the middle third, and by a substantial 45% for the bottom third.  This would make a real difference.

What a Real Tax Reform Could Look Like – I: Corporate and Individual Income Taxes

A.  Introduction

After many months in development, although behind closed doors until near the end, Republicans in Congress approved on December 20 a sweeping change in the nation’s tax laws.  Trump signed the measure on December 22, and it will go into effect in 2018.

However, this is not, in fact, a tax reform.  Rather, the measures are primarily a series of tax cuts for certain favored groups.  The greed on display was breathtaking, as special interest lobbyists were able to get many of their provisions included, with the legislation then rammed through on largely party-line votes.  The specific legislative language was kept secret to as late as possible, no public hearings with expert testimony were held, and tax lawyers are already finding numerous newly created loopholes in the drafting.  Instead of simplifying the tax system, the new law has created numerous opportunities for various special interests to game the system and avoid taxes that others must pay.

And it truly is a Republican tax plan, not just Trump’s.  On the key votes, 100% of Republicans in the Senate voted for it, while 95% of Republicans in the House did so.  No attempt was made to develop a bipartisan plan, and Democrats were never consulted on it.  Thus, not surprisingly, no Democrats voted for it.  For these reasons, I will refer to it below as the Republican tax plan.

A true tax reform would be quite different.  The reforms themselves would be revenue neutral, with the focus on measures to simplify and rationalize the tax system.  Tax rates would then be adjusted up or down, as necessary, to restore the revenues that would be lost or gained by the reform measures.  But the measure passed is instead forecast to produce a net loss in revenues of $1.5 trillion over the next ten years (and many believe the cost will in fact be higher as the cost from the new loopholes created, as well as from rushed, and consequently poor, drafting language, will be greater than congressional staff forecast).  But even at $1.5 trillion, the loss in tax revenues is not small.

But tax reform is possible, provided there is a modicum of political will, and reform is indeed certainly needed.  This post will look at what a true tax reform could look like.

To start, any true tax reform would reflect three key principles:

a)  Taxes due should not depend on the source of a person’s income (whether from wages or from wealth), but rather on that person’s total income from all sources.

b)  Tax rates should be progressive.  Those with a higher income should pay taxes at a higher rate than those with a lower income.  As Warren Buffett has noted, he pays taxes (perfectly legally under the current system) at a lower rate than what his far less rich secretary pays.  That is not fair.

c)  And the system should be as simple as possible.  Taxing income from all sources similarly would be a huge step to a simpler system, as much of the complexity arises from taxing different sources of income differently.  But there is more that could be done beyond this to simplify the system.  Indeed, one suspects that Congress has often added needless complexity to the tax code for purely political reasons.

The discussion below will be on reforms to taxes on income, whether corporate or individual.  Much of the focus of the recently passed tax legislation has been on the corporate income tax, which would be permanently slashed.  It is a complex topic, especially due to the international aspects of it (how to treat income earned abroad by US corporations, and income generated in the US by foreign-owned corporations).  It is also inextricably linked to individual income taxes, as individuals ultimately own corporations and receive the incomes corporations generate.  Thus income taxes on corporations and on individuals should be considered together.

The first section below thus will consider what a reform of corporate income taxes could look like, with the next section then looking at reforms to the individual income system.  We will then look at rough estimates of the tax revenue implications of such reforms.  Under the simplified system of taxes proposed, where all forms of income are taxed similarly, it is estimated that total tax revenues generated would rise, by close to $2.5 trillion over the next ten years.  One could then adjust rates downward to yield the same tax revenues as is being generated by the fragmented system we have had up to now current.

A comprehensive tax reform would cover more, however, than just income taxes.  This blog post will therefore be followed by two more:  One on reforms to Social Security taxes in order to ensure the Social Security trust fund remains solvent (it will run out around 2034 if Congress does nothing), and one which proposes a tax on emissions of greenhouse gases (commonly referred to as a carbon tax, as it would apply to carbon dioxide emissions primarily) in order to address climate change.  Both of these reforms would be designed to be revenue neutral, in the sense that Social Security taxes would be directed to what is required to fund Social Security benefits, while the revenues collected by a tax on greenhouse gas emissions would all be rebated to American households.  Thus they can be treated separately from reforms to the corporate and individual income tax systems.

Note finally that in the discussion below, reforms will be discussed in terms of changes relative to the tax system that has been in place up to now.  It will change as of January 1, 2018, under the recently passed Republican legislation, with many changes including new rates.  But the aim here is to discuss what a true tax reform could have looked like.  In addition, data we have on tax revenues (current and projected) are all in terms of the current tax system, not the new one, and we need such data to estimate what the revenue impacts would be of a true reform.  Thus references to tax rates and other aspects of the tax system will all be in reference to what we have had up to now.

B.  Corporate Income Taxes

Corporate income taxes (or corporate profit taxes – the terms will be used interchangeably) were a focus in the recent debate on taxes, with a good deal of hyperbole and confusion.  It is also a complex and peculiar tax, which exists today in its current form probably more for historical reasons than as something one would create now if one were to start anew.

The reason is that a corporation is purely a legally constructed entity, which defines an organizational structure that can borrow money, hire workers, produce something, sell it, and then distribute the gains from this production in accordance with decisions made in a precisely defined decision-making structure.  Whatever is gained is distributed to someone, or it is retained on the books of the corporation for use in the future.

But in taxing these corporate profits, including what is then distributed to individuals as their share of the profits, one is taxing the same gains twice – at the level of the company and then at the level of the individual.  This is double taxation, and creates problems.  The special, low, rate of tax paid on capital gains (on earnings from the sale of corporate shares, as well as from the sale of other assets) has been justified for this reason.  But that low rate is then of special benefit to those who are well-off compared to others.  This is not what one should want in a system of progressive taxation.

There are other problems as well, starting importantly with how one defines taxable corporate profits.  Profits are revenues obtained from selling a product minus the cost of producing it, but how one defines “revenues” and “costs” is not a simple matter.  Revenues, for example, may be paid in cash in the current period, but might also accrue now but only be paid at some future time (as credit is extended).  How should one count the latter?

There are similar timing issues with costs, but also issues of what one counts in costs.  Should one include the cost of interest on loans taken out to finance the company?  How about the cost of dividends paid on the capital obtained from shareholders?  Most definitions of costs include the former (interest) but not the latter (dividends), but the justification for this distinction is not clear.  Investment is also clearly a cost, but for an asset which will last for more than one period (by definition – otherwise it would simply be treated as a current input).  One should then include depreciation as a current year cost, but determining what that depreciation should be is not straightforward.  And there are more complicated issues as well, such as how to include the cost of stock options provided to management.  Finally and importantly, the law provides for a large range of various tax credits and tax deductions which are designed to provide special subsidies to various favored industries or owner categories.  Different countries do this differently, and they of course change over time in any individual country as well.

Such difficulties have created a profitable industry of lawyers and tax accountants with expertise on how, legally, to minimize recorded taxable corporate profits.  Together with changes in the underlying law, this has led to the steady decline in corporate profit taxes paid as a share of corporate profits (as defined in the GDP accounts), to where the actual rate paid now is in fact only around 20% (with this including what is paid at the state and local level, as well as to foreign governments).

Such factors also show why it is meaningless to compare the 35% rate in the US to that in other countries.  Each country defines the portion of corporate profits that are treated as taxable in its own way, so the base to which the tax rate is being applied will differ across countries.  Thus, while Trump has repeatedly asserted that US corporate taxes are the highest in the world, this is simply not true.  One cannot look solely at the headline rate (35% in the US, which will be slashed to 21% in the new Republican tax plan).  Indeed, based on what is actually paid, US corporate profit taxes at the headline rate of 35% are already lower on average than what is paid in most other OECD members.  As a share of GDP, and using OECD data (where 2014 is the most recent year with comparable data for all members), corporate profit taxes were just 2.18% of GDP in the US.  This was more than a quarter below the average of 3.00% of GDP across all OECD members.  One cannot just focus on the 35% headline rate, but rather one must look at the system as a whole.

a)  “Follow the money”:  Tax dividends at the level of the individual, and treat it as a cost at the level of the corporation

How then to approach the taxation of incomes deriving from corporate activities?  My primary recommendation is to “follow the money”, and tax such incomes at the level of the individuals receiving them.  That is, the focus would be on a fair and progressive system of taxes on individuals receiving such income, with income to individuals from corporate sources taxed in the same way and at the same rate as income from any other source.  How this would be done will be discussed in detail in the next section below, when we look at individual income taxes.  But at the level of corporations, one would not separately tax the payments made by corporations (nor indeed any other business entity) to individuals liable for US income taxes.  Rather, a Form 1099 would be filed by the company on what dividend payments they made and who they went to, as is in fact now done.  And if the individual or entity is not subject to US income taxes (or has not told the corporation whether they are), the company would withhold taxes at the 35% rate, which the individual or other entity could later claim when they file their tax forms on US-source incomes.  This is also as now.

Thus, one would not tax at the level of corporations what they pay lenders for interest on loans (as is the case now, as interest payments are treated as a cost to the company), but nor also for what they pay as dividends to their shareholders (who, like lenders, have also supplied capital to the corporations).

What would remain would then be profits that the corporation has retained rather than distributed (although with a provision for the cost of investment, to be discussed immediately below).  These earnings, retained on the balance sheet and not invested in productive assets, would be subject to tax, and a 35% rate (as we have had prior to the new Republican tax legislation) would be reasonable.  The income generated as a result of corporate activities would thus all be subject to tax, either at the level of the individual (if paid out) or at the level of the corporation (if, and only if, retained on the books).  This would also ensure one is not leaving a loophole where incomes could be accumulated forever on the corporate balance sheet, and never be subject to the taxes that others are bearing.

b)  Allow 100% expensing of investment costs

How then to treat investment?  Investment is low in the US, and likely is a significant factor in why productivity growth has slowed in recent decades.  As discussed in an earlier post on this blog, net private investment has declined in the US from over 7% of GDP between 1951 and 1980, to just half that now.  Stagnant real wages have likely been a factor in this (why invest in new equipment if you can hire workers at low wages instead?).  And while one will certainly want to take direct actions in the labor market to address this (most importantly by keeping the economy at close to full employment, thus strengthening the bargaining power of labor), tax policy can also contribute.

As discussed above, profits are defined as revenues minus costs, but the costs will in principle include only the extent to which invested assets have depreciated.  The problem in practice is that it is impossible to know what that depreciation really is, so our accounting systems use various simplified rules.  An example is the frequently used method of straight-line depreciation, where the investment is depreciated at a fixed percentage of its original cost for each year of some assumed lifetime.  But commonly, as part of tax policy, depreciation at some accelerated pace is allowed, thus reducing what is considered to be taxable corporate profits in the current period.  Costs are treated as if they were higher, by the extent of the higher depreciation allowed under the tax law.  This then reduces the share of actual corporate profits that are treated as taxable.

One could extend this to the maximum limit and allow 100% of investment to be depreciated (or “expensed”) in the current year.  Investment expenditures would be treated, in the period in which they are made, the same as any other input cost.  This would greatly simplify the system, and also would provide a strong incentive to invest.

One would then have that only those corporate profits which are retained on the balance sheet, and not invested in productive assets nor distributed either as interest or as dividends, would be subject to the corporate profits tax (at the 35% rate).  This would be close to a cash flow definition of profits (treating interest and similarly dividends as a cost for the capital used by the company), and would be straightforward to measure.  Corporate income taxes would only apply to those profits which are neither invested nor paid out as interest or dividends, but rather simply allowed to build up in bank accounts.

c)  Tax foreign operations of US corporations the same as their domestic operations, and tax foreign corporations operating in the US the same as a US corporation would be taxed on US operations

Corporations operate across borders, both US firms with operations overseas and foreign-owned corporations with operations in the US.  This raises special issues.  We will first look at the former (operations of US firms overseas), and then the latter (foreign-owned firms operating in the US).

The recently passed Republican tax legislation would partially exempt from US tax those profits earned by US companies on operations they undertake abroad.  But there is no logic in this – why should their operations overseas be taxed at a lower rate than the same operations would be had they been located in the US?  And it would also create a tremendous incentive for US companies to shift their operations to overseas locations, preferably to some tax haven.  Why this would be considered as something good for American workers is not at all clear.  Rather, and to create a level playing field, the earnings on such overseas operations should be subject to tax in the same way as corporate operations on American soil are.  And they should be subject to tax at the time such profits are generated, rather than deferred.

One should recognize, again in the name of a level playing field, that corporate taxes paid abroad should count as a credit against their US taxes.  This is to avoid what would otherwise be double-taxation (by both the country where the operations are being undertaken, and by the US), and is the standard practice in most of the countries where such operations exist (covered by double-taxation treaties).  This is the same as now.  But while the payment of such taxes to foreign governments should be recognized and treated as a cost of doing business there, what remains as income should be treated the same as if it were generated by operations in the US.

There is also the issue of what to do about the existing stock of accumulated, untaxed, corporate profits now held abroad.  Under US tax law (prior to the recent legislation), profits earned by US companies on overseas operations have not been treated as taxable in the US until such profits are repatriated to the US.  This has created the incentive to keep those profits in overseas accounts and investments, with this summing to at least an estimated $2.6 trillion (for 322 of the Fortune 500 top US companies that disclosed such figures, as of end 2016).  There is no rational economic reason why such accumulated earnings should benefit from a tax amnesty (whether in full or partial, as the new Republican tax legislation grants).  Rather, the taxes due on those funds should be paid and no longer deferred, in accord with the tax reform plan being presented here (distributions to shareholders would be taxed at the level of the individual, investments expensed, and remaining funds not invested in productive assets would be taxed at the 35% rate).  One could, however, provide for a multi-year period (of perhaps five years or so) to spread the impact.  And keep in mind that the corporations cannot argue that they cannot afford to make such payments.  Those assets (of over $2.6 trillion for a sub-set of the larger companies) are sitting in accounts abroad right now.

Finally, there is the issue of how to treat profits from operations in the US of companies owned (wholly or partially) by overseas entities.  The basic principle to follow, and to ensure a level playing field as well, is that they should be taxed the same as US owned companies would be.  Note that any company operating in the US has to be incorporated in the US under US law (as is the case for companies operating in any country), and thus in principle are US companies.  That is, Toyota or BMW car plants in the US are operated by US incorporated subsidiaries owned by (or primarily owned by) Toyota of Japan and BMW of Germany.  But their foreign ownership raises special issues.

Such subsidiaries will generally transfer as “dividends” the profits they generate to their foreign parents.  But there are other ways (perhaps not always so obvious) to pass along their profits.  These include paying interest on loans provided by the corporate parent (possibly at especially high interest rates), or by paying royalties or licensing fees for patents, trademarks, or proprietary designs coming from the parent companies.  All such transfers to corporate parents should be treated similarly as dividends.

Taxation of such entities should again follow the “follow the money” principle.  To the extent any such payments (whether dividends, interest, or royalties or licensing fees) paid to corporate parents (or to other entities where there is an ownership interest) are made by the foreign-owned subsidiary in the US to US entities who themselves are subject to US taxes (whether individuals, or banks, or other corporate entities), the payments would be treated as a cost.  The company would file (as US companies do) the Form 1099s that go to the IRS to inform them that such payments had been made.  Tax would then be paid by those individuals or other US entities receiving such payments, on their regular tax forms and in accordance with what they individually owe.

If the entity receiving the payment is not otherwise subject to US taxes (or has not told the company whether they are or not), the foreign-owned US subsidiary would withhold taxes that might be due, at the 35% rate.  The individuals or other entities could later file US income tax forms to cover the US taxes they might owe (on these distributions together with that owed on any other activities that generated taxable income in the US), and claim as a credit the taxes withheld on their behalf.  If they choose not to file US tax forms, the taxes withheld (at the 35% rate) would constitute the equivalent of corporate profit taxes being paid at such a rate on these US operations.  Again, the point is a level playing field between US and foreign-owned companies operating on US soil.

d)  Subsidies provided through the tax system to specific industries, sectors, or owners, should end

Finally, the tax code is riddled with special provisions that favor particular industries, sectors, or types of owners.  They are provided through a variety of means, including accelerated depreciation provisions in certain industries or for certain types of investments, various tax credits and deductions, and exemption from profit taxation (fully or partially) for those in certain industries.

Subsidies for certain of these activities might well be warranted.  But if so, it would be less costly and more transparent to provide such subsidies directly, through the budget, rather than hiding them in the tax code.

It should also be noted that with full expensing of investments allowed under the proposed new system, there will be built-in, and non-discriminatory, advantages provided to all investments.  The favored treatment of certain industries and not others, through granting of accelerated depreciation provisions for certain investments and not others, will no longer matter as all industries would be able to deduct 100% of the cost of investment in the year the investment was made.  This would include investments made in research and development, where 100% expensing has generally been allowed in recent years.  Such R&D costs would still enjoy this, but so would other investments.

As part of an overall reform of the corporate income tax, however, the many special, often industry specific, tax subsidies should end.  We will examine below, in Section D, what the resulting savings from this might be.

e)  Summary of corporate income tax reforms

In summary, the following is recommended to reform the system of corporate income taxes:

a)  Corporate investment expenditures should be allowed to be fully expensed in the year they are incurred.

b)  Dividend distributions should be treated as an expense, as interest on loans is now.  Together with full expensing of investment expenditures, this would imply that taxable corporate profits will equal what was retained that year and neither distributed (as dividends or interest) nor invested.  Those retained earnings, accumulating in bank accounts on the corporate balance sheet, would be taxed at 35% in the year they are so retained.

c)  Companies would report the dividend distributions to individuals or other entities on Form 1099s, just like interest payments are now reported.  If the individual or other entity has not provided their tax ID number to the company, then the company would withhold taxes on such distributions at the 35% rate.  Foreign individuals or entities would be treated similarly, with the taxes withheld, which they could then claim credit for if they file US tax forms covering all their US source incomes.

d)  Taxable corporate profits (as defined here) would apply not just to US-based operations, but also to the operations of US companies abroad.  That is, the taxation will be the same on a worldwide basis, and there would be no tax incentive to relocate operations to some foreign jurisdiction.  Like now, corporate income taxes paid in countries where double-taxation treaties have been negotiated would count as a credit.

e)  Profits of US corporations that have accumulated abroad (of an estimated $2.6 trillion for a sub-set of the larger companies) would be subject to a one-time tax on the same basis as retained earnings would now be.  One could allow a multi-year period, of perhaps five years, to spread this out.

f)  The US subsidiaries of foreign corporations would report (on Form 1099s or their equivalent) any distributions they make.  These would include payments of dividends or interest, but also royalties and licensing fees paid to corporate parents (or other entities with an ownership interest).  For foreign entities receiving such distributions that are not otherwise subject to US taxes, or in cases where the entity has not provided notice of their US tax status, the companies would withhold taxes at a 35% rate.

g)  Special tax subsidies for particular industries or purposes granted through the tax code should end.  To the extent any such subsidies are warranted as a matter of public interest, it would be less costly to provide them directly and transparently through the budget.

These reforms would have a major impact on what is collected as corporate income taxes.  As we will see below, income taxes paid directly by the corporations themselves would indeed be reduced.  But this would in large part be a consequence of the shift of the locus at which such incomes are taxed, from the corporate level to the individuals receiving those incomes.  One therefore needs to look at the revenue impact of these together, which we will do in Section D below after first discussing proposed reforms to individual income taxes.

C.  Individual Income Taxes

There are six major areas where reforms to the individual income tax system should be enacted:

a)  All forms of income should be taxed the same, and not at differing rates and brackets that vary depending on the source of that income;

b)  Equal benefit from deductions and personal exemptions should be provided to all, rather than (as now) higher benefits to those in the higher tax brackets;

c)  The cost basis of assets passed via inheritance should be retained at what they were, and not stepped-up;

d)  Exemption levels on estates subject to tax should be restored to $1.0 million for individuals and $2.0 million for married couples, which is roughly where they were from the mid-1980s through the 1990s (in terms of today’s prices);

e)  The use of life insurance to evade taxes on especially large estates should no longer be allowed;

f)  Tax subsidies for special, favored, private business activities should end.  Any such subsidies which are warranted can be provided at lower cost through the budget.

I have discussed the first three reforms on the list above in an earlier post on this blog.  Those interested in further detail on those measures may refer to that earlier post.  However, I will try to ensure the discussion here is sufficient to keep this post self-contained.

a)  Tax all forms of income the same

Taxing all forms of income the same is a matter not only of basic fairness, but also for reasons of tax efficiency and simplification.  To be clear, this does not mean one tax rate for all, but rather that income of one type (say wages) should be taxed the same as income from another source (such as capital gains).  Under the current US system a person will pay tax at different rates depending on the source of that income:  of up to 39.6% (37% in the recently passed legislation) on what is deemed “ordinary income” (such as wages), of up to 20% on income from capital gains on assets that have been held for more than a year, of also up to 20% on dividends paid on equity shares held for more than 60 days (but not on interest paid by those same companies), of up to 28% from capital gains on “collectibles” and certain small business stock, and of up to 25% from “unrecaptured Section 1250 gain” (whatever that is; I believe it is something primarily to do with real estate).

But this is not all.  In addition to such basic rates, there are various add-ons that raise the actual or effective rates for certain households.  For example, there has been a net investment income tax (applying to all forms of investment income, including capital gains as well as interest, dividends, rent, and so on) of 3.8% for households with incomes above $250,000 (when married filing jointly).  There is also an additional tax for Medicare of 0.9% for wage and self-employment income for households with income above $250,000 (when married filing jointly).  This is on top of the regular Medicare tax of 2.9% on all wage income (half technically “paid” by the employer and half by the individual, with the full 2.9% applying for the self-employed).

And then to add even further complexity, personal exemptions and itemized deductions are phased out for higher-income households (of more than $313,800 if married filing jointly in 2017).  These are called the PEP and Pease phase-outs, respectively, and act in effect as a higher tax rate on such households up to a certain amount that varies by household (depending on the number of personal exemptions and the value of their declared deductions).  Households who are extremely rich, with incomes above these phase-out amounts, then effectively pay a lower income tax rate than these more moderately well-off households pay.  The phase-outs raise the effective income tax rate paid by such households by about 1% point for the itemized deductions phaseout (or a bit more if one accounts for interaction effects), and by about 1% point for each personal exemption (thus 2% for a household of two, or 5% for a household of five, and again a bit more with interaction effects).

Finally, on top of all this is the Alternative Minimum Tax, which applies to moderately well-off households, excludes certain exemptions and deductions (in whole or in part), and then taxes the resulting taxable income (as then defined) at a rate of 26% or 28%.

This is incredibly complex, and for no justifiable purpose other than possibly an intention to obfuscate what rate is actually being paid.  And the complication does not come from the number of income tax brackets, but rather from taxing different forms of income differently, each with its own set of tax rates and tax brackets.  This is not only complex to figure out, but also provides an incentive to try to shift one’s income to a category that is taxed at a lower rate.  Thus, for example, suitably structured payments of stock options to high-level managers and other insiders allow them to switch what would otherwise be wage income (taxed at rates of up to 39.6% up to now) to long-term capital gains (taxed at 15% or 20%).  Similarly, managers of investment funds are able to structure the payments they receive from successful deals (which they call “carried interest”) at the low capital gains rate, even though they have no money of their own invested and are being compensated for their work in putting together the deals.

The recently passed Republican tax plan does not address this fundamental cause of complexity in the individual income tax system.  While some aspects would change (e.g. there would no longer be any personal exemptions, and hence no issue of personal exemptions being phased out), it would also create a new, highly favorable, treatment of what is termed “pass-through” income, that individuals obtain from businesses organized as partnerships, sole proprietorships, sub-chapter S corporations, and similar entities.  Currently, such income is treated the same as other ordinary income (such as wages) and is taxed as ordinary income is.  But under the new legislation, those in certain professions (but not others, where the rationale for including certain professions and not others is not clear), will be able to reduce their tax rate by 20%.  That is, those in the favored professions (and meeting certain other conditions), would be able to reduce the tax due on such income from the 37% others pay to just 29.6%.  This would create a strong incentive for such well-off individuals to structure the payments they receive for their work in such a way as to benefit from this lower rate (as the University of Kansas men’s basketball coach did when Kansas started to exempt such pass-through income from the state income tax).  Trump himself would be a prime beneficiary of such a “reform”.

The differing tax rates for different forms of income also has major distributional consequences.  For example, the special, low, rates on long-term capital gains and on dividends (on shares held for more than 60 days), primarily benefits those who enjoy a high income:

The Congressional Budget Office, in a May 2013 report, estimated that fully 93% of the benefit of the preferential tax rates on capital gains and dividends accrued to the richest 20% of households (those with a minimum income of $162,800 for a family of four), and over two-thirds (68%) accrued to the richest 1% (those with a minimum income of $654,000 for a family of four).  This is a special tax benefit that overwhelmingly favors the rich.

Taxing all forms of individual income the same thus would not only greatly simplify the system, but would also be distributionally positive.  And it would be fair, as individuals would pay the same tax on the same total income, regardless of whether they received that income in one form (e.g. wages) or another (e.g. capital gains or dividends).

One issue that would need to be addressed would be to ensure all the income and gains are taxed in terms of today’s prices. This is not a problem for income received in the last year.  One just adds up the various sources of income.  But for capital gains on assets held for a number of years, accumulated general inflation can be a significant factor.  However, it would not be difficult to take account of this.  Each year, the IRS would publish a table for accumulated general inflation from any given prior year to today, and these tables would be used to adjust the cost basis of the assets to reflect today’s price level.

A simple example will illustrate what would be done.  Suppose you sold shares in some company for $300,000 now, which you had bought for $100,000 ten years ago.  The nominal gain would be $200,000.  However, a significant share of this reflects inflation.  Suppose, in this example, that inflation had averaged 2.0% per year over the ten years.  Compounded, cumulative inflation over this period would then be 21.9%, and the $100,000 spent for the asset ten years ago would be equal to $121,900 in today’s prices.  The taxable gain in today’s dollars would then be $178,100.  One would add that amount to your other earnings this year to determine what your total taxable earnings are this year, in terms of today’s prices.

This would not add any real complication.  One already must know the cost basis as well as the date the asset was acquired, and indeed, these are entered on our tax forms.  One would just then need to multiply the cost basis by the inflation factor provided by the IRS to reflect the cost in today’s prices.

Another category of income that is taxed differently than other categories of income is interest income from bonds issued by state and local governments (commonly called municipal or “Muni” bonds), as well as Private Activity Bonds (PABs) that are treated similarly.  Interest on such bonds is taxed at a special rate of zero (i.e. they are not taxed) at the federal level, and similarly not taxed at the level of most states and localities (for citizens of those jurisdictions).

With the interest income on such bonds not taxed federally (nor locally), the bonds can be issued at a lower interest rate.  The market will be able to issue such bonds at a rate of, for example, say 4%, when similar bonds (with similar risks) can only be sold with an interest rate of say 6%.  If one is in a 40% tax bracket, taxable interest earnings at 6% will equal 3.6% after taxes, so a similar risk bond paying 4% with no taxes due will be attractive.

This is done as a means to provide federal subsidy support to states and localities as they fund their investments and programs, but it is a terrible way to do it.  The federal subsidy comes from the federal tax revenue that is given up by allowing such bonds to be issued tax-free.  But it would cost less to the federal treasury if such subsidies were provided directly to the states and localities, rather than indirectly through this tax avoidance mechanism.  The reason is that such bonds will be sold in the market at that price where the interest paid by them will match what the marginal individual buying such bonds would receive, after taxes, from a regular, taxable, bond of similar risk and maturity.  At that price, the marginal individual buying such bonds would be indifferent between the two types of bonds.  They would receive the same, after tax, interest on each.

This would normally be for someone in one of the middle tax brackets.  Someone who is richer than that, in one of the higher tax brackets, will then receive a windfall gain equal to the difference between what they will earn from the tax-free bond, and what they would earn (after taxes) had the bond not been tax-free.  In the example above, the windfall to someone in the 40% bracket would equal the difference between the 3.6% and 4.0% interest rates, times the value of such bonds that they hold.  This is a direct windfall to the rich, and only the rich.  It would be cheaper for the federal government to provide the subsidies directly to the states and localities, if such subsidies are warranted.

Private Activity Bonds have the same problem, as the interest on them is also tax-free.  The original logic appears to be that such bonds would be used to finance infrastructure and other expenditures that states and localities have traditionally funded, but the allowable purposes for which such PABs can now be used is much broader.  They are used for many real estate development projects, for some housing, for investments in “qualified enterprise zones”, for certain mortgages, and even for certain manufacturing and farm investments.  They can be used for pro sports stadiums and arenas (although not for luxury skyboxes built in them).  But while there are guidelines for the allowable purposes, there appears to be a good deal of discretion at the local level on what qualifies as eligible, and politically well-connected actors undoubtedly have an advantage in receiving such local approvals.

But even aside from whether PABs may be used for questionable purposes, they suffer from the same inherent excessive cost as Muni bonds do.  If it made sense for the federal government to subsidize such activities, it would be cheaper to subsidize them directly through the federal budget.  Providing the subsidy by granting such bonds tax-free treatment leads to a windfall going directly to the rich in the higher tax brackets.

To sum up, in replacement of the current complex system where different forms of income are often taxed differently, requiring different taxes to be computed on each and with resulting interactions among them, one should simply add up incomes earned each year from all sources (in current year prices), and pay a progressive tax on the total.

b)  Provide equal tax benefits to all from deductions and exemptions

Under the current system, the cost to someone in, say, a 40% tax bracket for a $100 contribution to some charity is only $60.  The charitable contribution is tax deductible, and hence the federal government is compensating someone in the 40% bracket $40 for the contribution to that charity.  But someone in the middle class in, say, a 20% tax bracket, would only receive a $20 compensation from the federal government for a $100 contribution to that exact same charity.  It would cost them a net $80.  And someone even poorer, in a 10% tax bracket would receive only $10 back, so it would cost them $90 for a contribution to that exact same charity again (assuming they itemize deductions; if not, it would cost them the full $100).

This is not fair.  The richer are receiving a bigger gift from the federal government for a $100 contribution to the same charity that the others have also contributed to.  There is also no reason of practicality why the system needs to be structured in this way.  Instead, one would simply add up all deductions (as now on Schedule A of the Form 1040), plus whatever amounts are set for personal exemptions ($4,050 per person in the household in 2017).  Then, instead of deducting this total from gross income, with the tax then determined based on the various tax rates, one would deduct some share (perhaps 25%, but the same for everyone) as a credit from taxes due.  That is, one would first determine taxes due on gross income, and then treat as a tax credit some fixed percentage of the total of what is now treated as deductions and exemptions.

As part of this, one would also eliminate the PEP and Pease phase-outs which in effect make those who are moderately well-off pay a higher tax rate than what they are nominally obliged to pay (and a higher rate than what those who are even wealthier have to pay).  This just complicates the system.  It is better to set the rates openly and clearly, and keep the rates progressive.

Under the proposed system, a $100 contribution to some charity would in effect then cost the taxpayer $75 (if a 25% rate is used) whether or not the person is rich, middle class, or poor.  The rate to be used, 25% in the examples here, could be set at that level which would be neutral in terms of the overall impact on tax collections.  It would in effect be a weighted average of what applies now to everyone in all tax brackets.  One would also apply the same rate of 25% (or whatever) to the amount used for the standard deduction ($12,700 in 2017 for couples filing jointly), as well as to personal exemptions ($4,050 per person in 2017), and then treat them all similarly as a tax credit.

One would do this primarily to be fair to all.  But it would also simplify the system.

c)  Maintain the prior cost basis on inherited assets

Taxes are paid on the income obtained from capital gains when assets are sold.  The gain is equal to the difference between the price received for the asset, and the price paid for it at some time before (the cost basis).  As discussed above, as part of a general tax reform the cost basis should be adjusted for general inflation between when the asset was purchased and when it was sold (and then taxed at the same rate as any other source of income), but the principle remains that taxes are paid on the income received from buying and selling assets.

There is, however, an exception to this in the current tax system (and would remain an exception in the new Republican plan).  When an asset is received via inheritance, the cost basis is reset to what the value of the asset is at the time it is inherited.  That can be a major favor to those inheriting assets, and there is no justifiable reason for it.

Some have argued that the person inheriting the asset would not necessarily know the cost basis, but that could be easily remedied.  First, the cost basis for financial assets traded through some broker such as Fidelity or Merrill Lynch will be recorded by that broker (and is reported to the IRS when the asset is sold).  And the value at which real estate is bought and sold will be recorded by the local government and kept in its land records forever.  Thus one will normally have the cost basis independently, from third-party sources.  But should there be any other asset where there might not be an independent record of the cost basis, or should the cost basis change for some valid reason (such as for a major capital improvement in some real estate asset), one could always make sure the correct cost basis is recorded in an annex or something similar in any wills or trusts that convey the assets to the beneficiaries.  Or that annex could indicate where to go to find the papers with the cost basis.  Indeed, it would be good practice anyway to record those values (or where to go to find the values) in such documents for all assets being passed to heirs.

Another argument that might be made is that those inheriting the assets might not be able to afford to pay the tax if the income received is calculated based on the original cost basis of the asset, rather than a stepped-up value.  But this would be a confused argument.  First, the tax due would not arise until the asset is sold, which could be many years later.  And second, when the asset is sold those inheriting the asset will receive a payment for the full amount of the sale.  One will have the funds to pay any tax that is then due.

The current treatment of these assets, with a step-up in the cost basis to the value at the time of inheritance, is also of greatest benefit to the rich.  This is not surprising:  the wealthy will leave a larger estate to be inherited than the not so wealthy.  The Congressional Budget Office has provided an estimate:

While not so extremely skewed distributionally as the benefit gained from the low rate of tax on long-term capital gains (discussed above), two-thirds of the benefits of this tax provision still go to the richest 20% of households, and over 20% of the benefit goes to the richest 1%.

As part of a general tax reform, this provision should be eliminated.  The cost basis of assets should remain at whatever it had been, and not stepped-up at the time the asset is inherited to whatever the value is then.

d)  Restore the exemption levels for the estate tax to $1.0 million for individuals and $2.0 million for married couples

The estate tax is now paid by only a tiny percentage of high net worth estates, because the exemption level has been raised over time to extremely high levels.  In 2017, estates with a net taxable value (after contributions to charity) of $5.49 million (or $10.98 million for married couples, if some standard arrangements have been made) are subject to this tax.  Because this exemption level is now so high, and with other ways as well to avoid estate taxes (such as use of life insurance, to be discussed below), only a small percentage of estates, less than 0.2%, end up paying any estate tax at all.  And under the recently passed Republican tax legislation, these floors on what is taxed would double, to $22 million for a married couple.  Only an exceedingly small share of estates will need to be concerned with this tax.

Until the tax cuts passed in 2001 under George W. Bush, the exemption level of estates had been far less.  It was raised as part of those tax cuts from $675,000 in 2001 to $1.0 million in 2002-03, and then by phases to the current $5.49 million (for 2017).  Indeed, in one year (2010) it was removed altogether.  Its complete removal has long been a goal of Republican leaders.

Returning the floor of what is subject to tax to $1.0 million for individuals and $2.0 million for married couples (with this inflation indexed going forward) would restore it to where it roughly was (in terms of today’s prices) from the mid-1980s through the 1990s.  Based on what was observed in the late 1990s, it would apply only to the richest 2% of households, approximately.  And this 2% share is indeed less than what the share was for most of the post-World War II period.  On average, a bit over 3% of estates were subject to the tax between 1946 and 2001.  There is no evidence that this tax at those levels did any harm to the economy.

e)  Ensure life insurance proceeds on especially large estates are subject to normal taxation, and not used as a way to evade taxation

A common “tax planning” tool used by the very wealthy to evade estate (and any other) taxes on assets passed to their heirs has been the use of life insurance.  Life insurance proceeds are not subject to tax.  For those who use life insurance for its intended purpose (to provide for family members and other dependants in case of an unexpected death), this is reasonable.  It should not then be subject to tax.  But its use to evade estate taxes should not be allowed.

One would then need to distinguish between these two purposes, and the question is how.  That could be done in various ways.  One could establish certain criteria, such as that both the age of death at which it would apply would be the normal retirement age or greater (say at age 66), plus that those receiving the insurance proceeds would be individuals other than the spouse or non-adult dependants of the deceased, plus that the amount in total to be paid out would (together with other estate assets) exceed the exemption level for estates subject to tax (which would be, as proposed above, $1.0 million for individuals and $2.0 million for married couples).

Using life insurance proceeds as a tax planning tool to allow extremely large estates to pass tax-free to heirs is a loophole which evades the intent of the estate tax.  It should be closed.

f)   Stop providing tax subsidies for special private activities

Finally, like the corporate income tax, the individual income tax provides special tax subsidies for various private business activities.  These include special deductions for certain “domestic production activities” (defined somehow in the tax code), favorable treatment of income earned abroad, and special advantages from the sale of certain categories of business stock.  While various subsidies to clean energy sources and energy efficiency are also included here, they are only a small share of the total – less than 10%.

To the extent such subsidies serve a valid public purpose, it would be less costly and more transparent to provide them directly and explicitly through the budget.  But many of these subsidies would not survive such public scrutiny.  They should be ended.

D.  An Estimate of the Impact of These Reforms on Tax Revenues

What would be the net impact on tax revenues from the reforms discussed above?  Estimates for the totals over the ten-year period of FY2018 to FY2027 are:

Impact of Tax Reform on Revenues, in $ billions


Corporate Income Taxes:

  End deferral of tax on overseas income


  End subsidies for special industries & activities


  Expense investment at 100%


  Exclude dividends paid to domestic persons




Individual Income Taxes:

  Tax capital gains and dividends at ordinary rates


  Tax interest from Muni bonds and PABs at ordinary rates


  End step-up of cost basis of inheritance


  Return estate tax exemption to $1.0 / $2.0 million


  Tax large life insurance proceeds from estates at ordinary rates


  End special tax subsidies for favored private business activities


  End surtax on investment income 


  End PEP and Pease phase-outs




     Overall Net Impact on Tax Revenues


     % change in Tax Revenues as share of Individual Income Tax


(Estimates rounded to nearest $50 billion, and totals are based on figures before rounding.)

I should emphasize that these are very rough estimates.  I will discuss below the various sources and assumptions made to arrive at these figures, but would stress that the information available to make such estimates is limited, and also does not take into account interaction effects nor how agents would react should such reforms be enacted.  Because they are rough, I have rounded each of the estimates to the nearest $50 billion (for the ten-year totals).  Nevertheless, the figures should suffice to give a sense of the magnitudes, and how the individual impacts would add up.

I have also excluded here what would be a significant, but one time, source of tax revenues under the proposed reforms.  Specifically, I have left out from the estimates here the taxes that would be paid on the accumulation of profits held overseas, on which taxes otherwise would have been due in the past had those profits been repatriated to the US.  As noted above, those untaxed profits are estimated to total $2.6 trillion for a subset of the larger US companies (the subset where data could be obtained for an estimate).  Those up-to-now untaxed profits would be subject to a 35% tax to the extent they are not either distributed to shareholders (in which case they would then be taxed at the individual level, at that individual’s rate) nor invested in productive assets (as investments could be fully expensed).  It is impossible to say how companies would then respond, but if they did nothing, a 35% tax on $2.6 trillion would total $910 billion.  This would be a significant addition to the ten-year totals.  But it is one time (perhaps spread, as discussed above, over a five year period), plus companies would be expected to respond in some way.  Thus I have left this figure, significant though it might be, out of the totals here.  Rather, the focus is on what the on-going, long-term, impacts might be of the tax reforms.

On the sources:  Most of the figures are derived from the most recent (January 2017) estimates of tax expenditures published by the Joint Committee on Taxation (JCT) of Congress.  The JCT publishes such estimates annually, and cover around 250 individual items.  Most are quite small, but they add up.  The report shows them separately for corporations and for individuals, and by year although only for the five years of FY2016 through FY2020 in their most recent report.  To scale them to the fiscal years of FY2018-27 (to make them comparable to the years discussed in the Republican tax legislation), I rescaled the totals for each category to FY2018-27 by multiplying them by the ratio of the Congressional Budget Office June 2017 forecasts of corporate or individual income tax revenues for FY2018-27 to what CBO is forecasting for FY2016-20 (separately for the corporate income tax and for the individual income tax).

Adjustments were needed for two of the proposed reform items.  The JCT estimates of the impact of the special, low, capital gains tax rate applied to long-term capital gains and qualified dividends, is based on figures which do not reflect inflation indexing of the cost basis for long-term capital gains.  Such inflation indexing would reduce the revenues collected significantly, but we do not have the data needed to provide a good estimate of how much.  To arrive at the figure shown here, I first took out the qualified dividends share of the total taxed at the capital gains rate (where published IRS data shows that in 2015 the share was 31%), as such dividends are paid in the current year.  The remainder reflects actual long-term capital gains.  Arbitrarily but generously, I assumed such capital gains would be reduced by 50% due to inflation indexing of the cost basis.  I suspect this is on the high side – the true reduction is likely to be less.  But based on this assumption, I arrived at the figure shown in the table.

The second item in the JCT estimates that needed to be adjusted was the impact of no longer treating as tax-free the payments made under life insurance.  As discussed above, some life insurance is used as a genuine tool to manage the financial risk of losing a provider for the family.  But life insurance is also used as an estate planning tool by wealthy estates to convey, tax-free, the assets from an estate to heirs, and thus avoid the estate tax.  In terms of dollar volumes, this latter use likely dominates.  One would want to design the tax only to apply to the latter, which could be done through various ways (using age, who the heirs would be, and a large minimum size).  For the purposes of the calculation of the tax revenue impact of such a reform, I assumed that the revenues generated would be reduced to 80% of the JCT estimates, as life insurance for the management of the financial risk of losing a family provider would remain tax exempt.

The January 2017 JCT report on tax expenditures did not have estimates for three of the tax items.  One was what the impact would be from allowing 100% expensing of all corporate investment.  However, a recent (November 14) JCT analysis of the tax revenue impacts of the House Republican tax plan did include, as a separate item, the cost of a proposed 100% expensing of corporate investment.  While this expensing (under the then House Republican plan) would formally end in 2022, one can use the estimates shown for a separate 100% expensing item (for small business) to calculate what it would roughly be in the second half of the decade (the relative proportions would be similar).  Note that the net tax revenue impact of 100% expensing diminishes over time.  Full expensing essentially brings forward allowed depreciation, so instead of spreading depreciation over time, the asset is treated as if the full cost was borne in the initial period.  This reduces taxable profits in the initial year, but then will raise it later (as the full depreciation has already been taken).

The second was the cost of returning exemption levels for estates to $1.0 million for individuals and $2.0 million for married couples.  This was estimated based on figures from the Tax Policy Center on the revenues collected by this tax in the late 1990s (but converted into revenues in today’s prices), when the exemption levels then (in terms of today’s prices) were close to the proposed new levels.  They were then forecast going forward to grow at the same rate as what the Congressional Budget Office forecast for the estate tax under current law.  The net increase in revenues would then equal the difference between this stream of tax revenues (with the exemption levels at $1.0 / $2.0 million) and what the CBO is forecasting the revenues would be under current law.

Finally, the impact of shifting the taxation of dividends from the corporate level to the individual level (where it would be taxed at the same rate as other income) was estimated based on current figures from the GDP accounts on corporate dividends, less Tax Policy Center estimates on the share going to foreigners, with this then forecast to grow at the same rate as what the JCT is forecasting for dividends and capital gains.

The resulting figures are shown in the table, with each rounded to the nearest $50 billion.  The net impact of the reforms on what would be collected directly through the corporate income tax would be a decline of $250 billion over the next ten years.  There would be a reduction in taxes collected at the corporate level of $2.5 trillion from excluding dividends from taxable corporate profits, and a reduction of $200 billion from allowing investment to be 100% expensed.  But this would mostly be offset by ending the deferral of taxes on income earned abroad by US corporate subsidiaries (generating $1.5 trillion in revenues), and by ending corporate subsidies for various special industries and activities (generating $950 billion).

Income tax collected at the individual level would, however, grow by an estimated $2.7 trillion over the ten year period.  The largest component of this ($1.15 trillion) would be generated by taxing capital gains and dividends at ordinary income tax rates, rather than the special low rate (20% generally) they are granted now.  Taxing interest on state and local government bonds (Munis) as well as private activity bonds (PABs), rather than not taxing them at all, would generate $700 billion over the ten years.  Ending the step-up of cost basis on assets received via inheritance would generate $450 billion, while returning the exemption level for the estate tax to $1.0 million for individuals and $2.0 million for married couples would generate $500 billion.  Taxing large life insurance proceeds from estates, used to evade estate taxes, would generate an estimated $250 billion.  And ending special tax subsidies to individuals for favored private business activities would generate $250 billion.

Partially offsetting this, ending the surtax on certain rich households on investment income (so that it would be taxed the same as other income) would mean a reduction of $400 billion in tax revenues over the decade.  And ending the complication of the PEP (personal exemption) and Pease (itemized deductions) phase-outs would reduce revenues by an estimated $250 billion.

Adding the impacts on both the corporate income tax and the individual income tax, the net effect would be to raise tax revenues collected by an estimated $2.45 trillion over the ten years.  This is large, and can be contrasted with the loss of $1.5 trillion in tax revenues that would follow from the recently passed Republican tax plan.  Even if several of my revenue estimates turn out to be too optimistic, the $2.45 trillion increase in revenues leaves a generous margin for uncertainties.  The net impact of these tax reforms would almost certainly be budget positive.

But assuming the $2.45 trillion surplus is a reasonable estimate, what could be done with such an amount?  First, I would note that some of the savings would come from ending various subsidies through the tax system.  As discussed above, providing such subsidies through the tax system is both costly (it would cost less to provide the subsidies directly through the budget, as the current system provides a windfall to those in the higher tax brackets) and lacks transparency.  Many of these subsidies should cease altogether, but some might well serve a valid public purpose.  When this is the case, regular budget expenditures would rise, and one should use a portion of the $2.45 trillion for such expenditures.

One might also wish to use a portion of the $2.45 trillion for other urgently needed budget expenditures the nation requires, such as for infrastructure.  As discussed in prior posts on this blog, government expenditures have been squeezed for many years, leaving a backlog of high priority needs.  One might also use a portion of the $2.45 trillion to pay down part of the national debt, although the priority of this is not clear.  Even the supposedly fiscally conservative Republicans see no problem with voting for a tax plan that would reduce tax revenues by $1.5 trillion over the next decade.

Finally, one could use the $2.45 trillion to adjust income tax rates downward.  If the full $2.45 trillion were used for this, and if one were to apply the reduction in proportion to current rates (as of 2017), one can calculate (using the CBO forecasts of tax revenues under current law), that the top tax rate could be cut from the current 39.6% to a rate of 35.6%.  The other tax rates would be similarly reduced (proportionally).  This would even be close to the top rate of 35% that the Republican plans have been aiming for (at various times), but would have been achieved as a consequence of true reforms.  That is, rather than setting a rate target (of 35% or whatever) and then trying to find sufficient measures to allow this to be met (including allowing for a net revenue loss of $1.5 trillion), the approach of a true reform is to start with several basic principles (uniform tax rates on all forms of income, progressivity, and simplification), work out what reforms would follow from this, and then set the rates accordingly for revenue neutrality.

E.  Conclusion

The recent debate on tax policy was an opportunity to enact a true reform.  We certainly need it.  The current tax system is inequitable, overly complicated, has provisions which induce perverse behavior, and is costly to administer.  Sadly, the recently passed Republican tax plan will make it worse, as just the example of the special treatment of pass-through income makes clear.  The new law introduces new inequities (pass-through tax provisions that favor a narrow few), new complications (distinctions that cannot be logically explained as to whom will be able to cut their taxes on pass-through income, such as professionals in real estate but not certain others), provisions that will induce perverse behavior (such as newly-created business structures for doctors to sell and lease back their offices, in order to obtain some of the pass-through benefits that real estate companies will enjoy), and will be costly to administer (as the IRS tries to ensure the law is applied as intended despite the numerous complications, as for example again with regard to who will and will not be allowed to benefit from the tax cuts for pass-through income).

And the complications and inequities in the new Republican tax legislation extend far beyond what was done on pass-through income.  Many new loopholes have been created, and the tax cuts provided have gone disproportionately to the rich.  Along with differing treatments of different sources of income, the new system will be more complex than the old, and less progressive.  Finally, it will not be revenue neutral.  Rather, it will lead to $1.5 trillion more being borrowed in our budget over the next ten years.  Our budget is in deficit and will remain so if nothing is done, even though now is the time, with the economy at full employment, that one should be moving to a budget surplus.  In effect, we are borrowing a further $1.5 trillion over the next decade to hand out primarily to the rich.

In a simple and fair system of taxation, one would be paying the same in taxes whether one’s income came from working for wages, from business income, from dividends from corporations or interest from loans, from stock options, or from capital gains.  Under our current tax system, each of these sources of income may be taxed at different rates.  The result is undue complication, as one has to determine not only what total income is but also how it should be categorized.  But in addition there are interaction effects, where the tax applied in some category depends not only on the income earned in that category, but also often on the income earned in other categories.  And most importantly, there is then the incentive to try to arrange income payments so that they will come under a category where lower taxes are due (e.g. shifting wage income to stock options, or for hedge fund managers to shift what would be wage income to “carried interest”).

The new Republican tax plan will make this worse.  Now there is a new general category treated preferentially, of pass-through income.  Pass-through income had been taxed before the same as wage and other ordinary income.  Now it will be taxed 20% less.  This is a strong incentive, for those who are able, to try to arrange the payments they receive to qualify as pass-through income rather than wages.  This is just a gift to the wealthy who are able to obtain such special treatment.

But there is no disagreement that a true tax reform is certainly needed in the US.  The proposals outlined above show what could have been done.  And such a reform now is more important than ever, as the Republican tax plan has moved us in the opposite direction of what we needed.

An Analysis of the Trump Tax Plan: Not a Tax Reform, But Rather a Massive Tax Cut for the Rich

A.  Introduction

The Trump administration released on September 27 its proposed tax plan.  It was exceedingly skimpy (only nine pages long, including the title page, and with all the white space could have been presented on half that number of pages).  Importantly, it was explicitly vague on many of the measures, such as what tax loopholes would be closed to partially pay for the tax cuts (simply saying they would do this somehow).  One can, however, examine measures that were explicitly presented, and from these it is clear that this is primarily a plan for massive tax cuts for the rich.

It is also clear that this is not a tax reform.  A tax reform would be revenue neutral.  The measures proposed would not be.  And a reform would focus on changes in the structure of the tax system.  There is little of that here, but rather proposals to cut various tax rates (including in several cases to zero), primarily for the benefit of those who are well off.

One can see this in the way the tax plan was approached.  In a true tax reform, one would start by examining the system, and whether certain deductions and tax exemptions are not warranted by good policy (but rather serve only certain vested interests).  Closing such loopholes would lead to higher revenues being collected.  One would then determine what the new tax rates could be (i.e. by how much they could be cut) to leave the overall level of tax collection the same.

But that was not done here.  Rather, they start with specific proposals on what the new tax rates “should” be (12%, 25%, and 35% for individuals, and 20% for corporations), and then make only vague references to certain, unspecified, deductions and tax exemptions being eliminated or reduced, in order not to lose too much in revenues (they assert).  They have the process backward.

And it is clear that these tax cuts, should they be enacted by Congress, would massively increase the fiscal deficit.  While it is impossible to come up with a precise estimate of how much the tax plan would cost in lost revenues, due to the vagueness on the parameters and on a number of the proposals, Republicans have already factored into the long-term budget a reduction in tax revenues of $1.5 trillion over ten years.  And estimates of the net cost of the Trump plan range from a low of $2.2 trillion over ten years ($2.7 trillion when additional interest is counted, as it should be), to as high as $5 trillion over ten years.  No one can really say as yet, given the deliberate lack of detail.

But any of these figures on the cost are not small.  The total federal debt held by the public as of the end of September, 2017, was $14.7 trillion.  The cost in lost revenue could equal more than a third of this.  Yet Republicans in Congress blocked the fiscal expenditures we desperately needed in the years from 2010 onwards during the Obama years, when unemployment was still high, there was excess capacity in our underutilized factories, and the country needed to rebuild its infrastructure (as we still do).  The argument then was that we could not add to our national debt.  But now the same politicians see no problem with adding massively to that debt to cover tax cuts that will primarily benefit the rich.  The sheer hypocrisy is breath-taking.

Not surprisingly, Trump officials are saying that there will be no such cost due to a resulting spur to our economic growth.  Trump himself asserted that his tax plan would lead the economy to grow at a 6% pace.  No economist sees this as remotely plausible.  Even Trump’s economic aides, such as Gary Cohn who was principally responsible for the plan, are far more cautious and say only that the plan will lead to growth of “substantially over 3 percent”.  But even this has no basis in what has been observed historically after the Reagan and Bush tax cuts, nor what one would expect from elementary economic analysis.

The lack of specificity in many of the proposals in the tax plan issued on September 27 makes it impossible to assess it in full, as major elements are simply only alluded to.  For example, it says that a number of tax deductions (both personal and corporate) will be eliminated or reduced, but does not say which (other than that they propose to keep the deductions for home mortgage interest and for charity).  As another example, the plan says the number of personal income tax brackets would be reduced from seven currently to just three broad ones (at 12%, 25%, and 35%), but does not say at what income levels each would apply.  Specifics were simply left out.

For a tax plan where work has been intensively underway for already the eight months of this administration (and indeed from before, as campaign proposals were developed), such vagueness must be deliberate.  The possible reasons include:  1) That the specifics would be embarrassing, as they would make clear the political interests that would gain or lose under the plan; 2) That revealing the specifics would spark immediate opposition from those who would lose (or not gain as others would); 3) That revealing the specifics would make clear that they would not in fact suffice to achieve what the Trump administration is asserting (e.g. that ending certain tax deductions will make the plan progressive, or generate revenues sufficient to offset the tax rate cuts); and/or 4) That they really do not know what to do or what could be done to fix the issue.

One can, however, look at what is there, even if the overall plan is incomplete.  This blog post will do that.

B.  Personal Income Taxes

The proposals are (starting with those which are most clear):

a)  Elimination of the Estate Tax:  Only the rich pay this.  It only applies to estates given to heirs of $10.98 million or more (for a married couple).  This only affects the top 0.2%, most wealthy, households in the US.

b)  Elimination of the Alternative Minimum Tax:  This also only applies to those who are rich enough for it to apply and who benefit from a range of tax deductions and other benefits, who would otherwise pay little in tax.  It would be better to end such tax deductions and other special tax benefits that primarily help this group, thus making the Alternative Minimum Tax irrelevant, than to end it even though it had remained relevant.

c)  A reduction in the top income tax rate from 39.6% to 35%:  This is a clear gain to those whose income is so high that they would, under the current tax brackets, owe tax at a marginal rate of 39.6%.  But this bracket only kicks in for households with an adjusted gross income of $470,700 or more (in 2017).  This is very close to the minimum income of those in the top 1% of the income distribution ($465,626 in 2014), and the average household income of those in that very well-off group was $1,260,508 in 2014.  Thus this would be a benefit only to the top 1%, who on average earn over $1 million a year.

The Trump plan document does include a rather odd statement that the congressional tax-writing committees could consider adding an additional, higher, tax bracket, for the very rich, but it is not at all clear what this might be.  They do not say.  And since the tax legislation will be written by the congressional committees, who are free to include whatever they choose, this gratuitous comment is meaningless, and was presumably added purely for political reasons.

d)  A consolidation in the number of tax brackets from seven currently to just three, of 12%, 25%, and 35%:  Aside from the clear benefit to those now in the 39.6% bracket, noted above, one cannot say precisely what the impact the new tax brackets would have for the other groups since the income levels at which each would kick in was left unspecified.  It might have been embarrassing, or contentious, to do so.  But one can say that any such consolidation would lead to less progressivity in the tax system, as each of the new brackets would apply to a broader range of incomes.  Instead of the rates rising as incomes move up from one bracket to the next, there would now be a broader range at which they would be kept flat.  For example, suppose the Trump plan would be for the new 25% rate to span what is now taxed at 25% or 28%.  That range would then apply to household incomes (for married couples filing jointly, and in 2017) from $75,900 on the low end to $233,350 at the high end.  The low-end figure is just above the household income figure of $74,869 (in 2016) for those reaching the 60th percentile of the income distribution (see Table A-2 of this Census Bureau report), while the top-end is just above the $225,251 income figure for those reaching the 95th percentile.  A system is not terribly progressive when those in the middle class (at the 60th percentile) pay at the same rate as those who are quite well off (in the 95th percentile).

e)  A ceiling on the tax rate paid on personal income received through “pass-through” business entities of just 25%:  This would be one of the more regressive of the measures proposed in the Trump tax plan (as well as one especially beneficial to Trump himself).  Under current tax law, most US businesses (95% of them) are incorporated as business entities that do not pay taxes at the corporate level, but rather pass through their incomes to their owners or partners, who then pay tax on that income at their normal, personal, rates.  These so-called “pass-through” business entities include sole proprietorships, partnerships, Limited Liability Companies (LLCs), and sub-chapter S corporations (from the section in the tax code).  And they are important, not only in number but also in incomes generated:  In the aggregate, such pass-through business entities generate more in income than the traditional large corporations (formally C corporations) that most people refer to when saying corporation.  C corporations must pay a corporate income tax (to be discussed below), while pass-through entities avoid such taxes at the company level.

The Trump tax plan would cap the tax rate on such pass-through income at 25%.  This would not only create a new level of complexity (a new category of income on which a different tax is due), but would also only be of benefit to those who would otherwise owe taxes at a higher rate (the 35% bracket in the Trump plan).  If one were already in the 25% bracket, or a lower one, that ceiling would make no difference at all and would be of no benefit.  But for those rich enough to be in the higher bracket, the benefit would be huge.

Who would gain from this?  Anyone who could organize themselves as a pass-through entity (or could do so in agreement with their employer).  This would include independent consultants; other professionals such as lawyers, lobbyists, accountants, and financial advisors; financial entities and the partners investing in private-equity, venture-capital, and hedge funds; and real estate developers.  Trump would personally benefit as he owns or controls over 500 LLCs, according to Federal Election Commission filings.  And others could reorganize into such an entity when they have a tax incentive to do so.  For example, the basketball coach at the University of Kansas did this when Kansas created such a loophole for what would otherwise be due under its state income taxes.

f)  The tax cuts for middle-income groups would be small or non-existent:  While the Trump tax proposal, as published, repeatedly asserts that they would reduce taxes due by the middle class, there is little to suggest in the plan that that would be the case.  The primary benefit, they tout (and lead off with) is a proposal to almost double the standard deduction to $24,000 (for a married couple filing jointly).  That standard deduction is currently $12,700.  But the Trump plan would also eliminate the personal exemption, which is $4,050 per person in 2017.  Combining the standard deduction and personal exemptions, a family of four would have $28,900 of exempt income in 2017 under current law ($12,700 for the standard deduction, and personal exemptions of four times $4,050), but only $24,000 under the Trump plan.  They would not be better off, and indeed could be worse off.  The Trump plan is also proposing that the child tax credit (currently a maximum of $1,000 per child, and phased out at higher incomes) should be raised (both in amount, and at the incomes at which it is phased out), but no specifics are given so one cannot say whether this would be significant.

g)  Deduction for state and local taxes paid:  While not stated explicitly, the plan does imply that the deduction for state and local taxes paid would be eliminated.  It also has been much discussed publicly, so leaving out explicit mention was not an oversight.  What the Trump plan does say is the “most itemized deductions” would be eliminated, other than the deductions for home mortgage interest and for charity.

Eliminating the deduction for state and local taxes appears to be purely political.  It would adversely affect mostly those who live in states that vote for Democrats.  And it is odd to consider this tax deduction as a loophole.  One has to pay your taxes (including state and local taxes), or you go to jail.  It is not something you do voluntarily, in part to benefit from a tax deduction.  In contrast, a deduction such as for home mortgage interest is voluntary, one benefits directly from buying and owning a nice house, and such a deduction benefits more those who are able to buy a big and expensive home and who qualify for taking out a large mortgage.

h)  Importantly, there was much that was not mentioned:  One must also keep in mind what was not mentioned and hence would not be changed under the Trump proposals.  For example, no mention was made of the highly favorable tax rates on long-term capital gains (for assets held one year or more) of just 20%.  Those with a high level of wealth, i.e. the wealthy, gain greatly from this.  Nor was there any mention of such widely discussed loopholes as the “carried interest” exception (where certain investment fund managers are able to count their gains from the investment deals they work on as if it were capital gains, rather than a return on their work, as it would be for the lawyers and accountants on such deals), or the ability to be paid in stock options at the favorable capital gains rates.

C.  Corporate Income Taxes

More than the tax cuts enacted under Presidents Reagan and Bush, the Trump tax plan focuses on cuts to corporate income (profit) taxes.  Proposals include:

a)  A cut in the corporate income tax rate from the current 35% to just 20%:  This is a massive cut.  But it should also be recognized that the actual corporate income tax paid is far lower than the headline rate.  As noted in an earlier post on this blog, the actual average rate paid has been coming down for decades, and is now around 20%.  There are many, perfectly legal, ways to circumvent this tax.  But setting the rate now at 20% will not mean that taxes equal to 20% of corporate profits will be collected.  Rather, unless the mechanisms used to reduce corporate tax liability from the headline rate of 35% are addressed, those mechanisms will be used to reduce the new collections from the new 20% headline rate to something far less again.

b)  Allow 100% of investment expenses to be deducted from profits in the first year, while limiting “partially” interest expense on borrowing:  This provision, commonly referred to as full “expensing” of investment expenditures, would reduce taxable profits by whatever is spent on investment.  Investments are expected to last for a number of years, and under normal accounting the expense counted is not the full investment expenditure but rather only the estimated depreciation of that investment in the current year.  However, in recent decades an acceleration in what is allowed for depreciation has been allowed in the tax code in order to provide an additional incentive to invest.  The new proposal would bring that acceleration all the way to 100%, which as far as it can go.

This would provide an incentive to invest more, which is not a bad thing, although it still would also have the effect of reducing what would be collected in corporate income taxes.  It would have to be paid for somehow.  The Trump proposal would partially offset the cost of full expensing of investments by limiting “partially” the interest costs on borrowing that can be deducted as a cost when calculating taxable profits.  The interest cost of borrowing (on loans, or bonds, or whatever) is currently counted in full as an expense, just like any other expense of running the business.  How partial that limitation on interest expenses would be is not said.

But even if interest expenses were excluded in full from allowable business expenses, it is unlikely that this would come close to offsetting the reduction in tax revenues from allowing investment expenditures to be fully expensed.  As a simple example, suppose a firm would make an investment of $100, in an asset that would last 10 years (and with depreciation of 10% of the original cost each year).  For this investment, the firm would borrow $100, on which it pays interest at 5%.  Under the current tax system, the firm in the first year would deduct from its profits the depreciation expense of $10 (10% of $100) plus the interest cost of $5, for a total of $15.  Under the Trump plan, the firm would be able to count as an expense in the first year the full $100, but not the $5 of interest.  That is far better for the firm.  Of course, the situation would then be different in the second and subsequent years, as depreciation would no longer be counted (the investment was fully expensed in the first year), but it is always better to bring expenses forward.  And there likely will be further investments in subsequent years as well, keeping what counts as taxable profits low.

c)  Tax amnesty for profits held abroad:  US corporations hold an estimated $2.6 trillion in assets overseas, in part because overseas earnings are not subject to the corporate income tax until they are repatriated to the US.  Such a provision might have made sense decades ago, when information systems were more primitive, but does not anymore.  This provision in the US tax code creates the incentive to avoid current taxes by keeping such earnings overseas.  These earnings could come from regular operations such as to sell and service equipment for foreign customers, or from overseas production operations.  Or such earnings could be generated through aggressive tax schemes, such as from transferring patent and trademark rights to overseas jurisdictions in low-tax or no-tax jurisdictions such as the Cayman Islands.  But whichever way such profits are generated, the US tax system creates the incentive to hold them abroad by not taxing them until they are repatriated to the US.

This is an issue, and could be addressed directly by changing the law to make overseas earnings subject to tax in the year the earnings are generated.  The tax on what has been accumulated in the past could perhaps be spread out equally over some time period, to reduce the shock, such as say over five years.  The Trump plan would in fact start to do this, but only partially as the tax on such accumulated earnings would be set at some special (and unannounced) low rates.  All it says is that while both rates would be low, there would be a lower rate applied if the foreign earnings are held in “illiquid” assets than in liquid ones.  Precisely how this distinction would be defined and enforced is not stated.

This would in essence be a partial amnesty for capital earnings held abroad.  Companies that have held their profits abroad (to avoid US taxes) would be rewarded with a huge windfall from that special low tax rate (or rates), totalling in the hundreds of billions of dollars, with the precise gain on that $2.6 trillion held overseas dependant on how low the Trump plan would set the tax rates on those earnings.

It is not surprising that US corporations have acted this way.  There was an earlier partial amnesty, and it was reasonable for them to assume there would be future ones (as the Trump tax plan is indeed now proposing).  In one of the worst pieces of tax policy implemented in the George W. Bush administration, an amnesty approved in 2004 allowed US corporations with accumulated earnings abroad to repatriate that capital at a special, low, tax rate of just 5.25%.  It was not surprising that the corporations would assume this would happen again, and hence they had every incentive to keep earnings abroad whenever possible, leading directly to the $2.6 trillion now held abroad.

Furthermore, the argument was made that the 2004 amnesty would lead the firms to undertake additional investment in the US, with additional employment, using the repatriated funds.  But analyses undertaken later found no evidence that that happened.  Indeed, subsequent employment fell at the firms that repatriated accumulated overseas earnings.  Rather, the funds repatriated largely went to share repurchases and increased dividends.  This should not, however, have been surprising.  Firms will invest if they have what they see to be a profitable opportunity.  If they need funds, they can borrow, and such multinational corporations generally have no problem in doing so.  Indeed, they can use their accumulated overseas earnings as collateral on such loans (as Apple has done) to get especially low rates on such loans.  Yet the Trump administration asserts, with no evidence and indeed in contradiction to the earlier experience, that their proposed amnesty on earnings held abroad will this time lead to more investment and jobs by these firms in the US.

d)  Cut to zero corporate taxes on future overseas earnings:  The amnesty discussed above would apply to the current stock of accumulated earnings held by US corporations abroad.  Going forward, the Trump administration proposes that earnings of overseas subsidiaries (with ownership of as little as 10% in those firms) would be fully exempt from US taxes.  While it is true that there then would be no incentive to accumulate earnings abroad, the same would be the case if those earnings would simply be made subject to the same current year corporate income taxes as the US parent is liable for, and not taxable only when those earnings are repatriated.

It is also not at all clear to me how exempting these overseas earnings from any US taxes would lead to more investment and more jobs in the US.  Indeed, the incentive would appear to me to be the opposite.  If a plant is sited in the US and used to sell product in the US market or to export it to Europe or Asia, say, earnings from those operations would be subject to the regular US corporate income taxes (at a 20% rate in the Trump proposals).  However, if the plant is sited in Mexico, with the production then sold in the US market or exported from there to Europe or Asia, earnings from those operations would not be subject to any US tax.  Mexico might charge some tax, but if the firm can negotiate a good deal (much as firms from overseas have negotiated such deals with various states in the US to site their plants in those states), the Trump proposal would create an incentive to move investment and jobs to foreign locations.

D.  Conclusion

The Trump administration’s tax plan is extremely skimpy on the specifics.  As one commentator (Allan Sloan) noted, it looks like it was “written in a bar one evening over a batch of beers for a Tax 101 class rather than by serious people who spent weeks working with tax issues”.

It is, of course, still just a proposal.  The congressional committees will be the ones who will draft the specific law, and who will then of necessity fill in the details.  The final product could look quite different from what has been presented here.  But the Trump administration proposal has been worked out during many months of discussions with the key Republican leaders in the House and the Senate who will be involved.  Indeed, the plan has been presented in the media not always as the Trump administration plan, but rather the plan of the “Big Six”, where the Big Six is made up of House Speaker Paul Ryan, Senate Majority Leader Mitch McConnell, House Ways and Means Committee Chairman Kevin Brady, Senate Finance Committee Chairman Orrin Hatch, plus National Economic Council Director Gary Cohn and Treasury Secretary Steven Mnuchin of the Trump administration.  If this group is indeed fully behind it, then one can expect the final version to be voted on will be very similar to what was outlined here.

But skimpy as it is, one can say with some certainty that the tax plan:

a)  Will be expensive, with a ten-year cost in the trillions of dollars;

b)  Is not in fact a tax reform, but rather a set of very large tax cuts;

and c)  Overwhelmingly benefits the rich.

Productivity: Do Low Real Wages Explain the Slowdown?

GDP per Worker, 1947Q1 to 2016Q2,rev

A.  Introduction, and the Record on Productivity Growth

There is nothing more important to long term economic growth than the growth in productivity.  And as shown in the chart above, productivity (measured here by real GDP in 2009 dollars per worker employed) is now over $115,000.  This is 2.6 times what it was in 1947 (when it was $44,400 per worker), and largely explains why living standards are higher now than then.  But productivity growth in recent decades has not matched what was achieved between 1947 and the mid-1960s, and there has been an especially sharp slowdown since late 2010.  The question is why?

Productivity is not the whole story; distribution also matters.  And as this blog has discussed before, while all income groups enjoyed similar improvements in their incomes between 1947 and 1980 (with those improvements also similar to the growth in productivity over that period), since then the fruits of economic growth have gone only to the higher income groups, while the real incomes of the bottom 90% have stagnated.  The importance of this will be discussed further below.  But for the moment, we will concentrate on overall productivity, and what has happened to it especially in recent years.

As noted, the overall growth in productivity since 1947 has been huge.  The chart above is calculated from data reported by the BEA (for GDP) and the BLS (for employment).  It is productivity at its most basic:  Output per person employed.  Note that there are other, more elaborate, measures of productivity one might often see, which seek to control, for example, for the level of capital or for the education structure of the labor force.  But for this post, we will focus simply on output per person employed.

(Technical Note on the Data: The most reliable data on employment comes from the CES survey of employers of the BLS, but this survey excludes farm employment.  However, this exclusion is small and will not have a significant impact on the growth rates.  Total employment in agriculture, forestry, fishing, and hunting, which is broader than farm employment only, accounts for only 1.4% of total employment, and this sector is 1.2% of GDP.)

While the overall rise in productivity since 1947 has been huge, the pace of productivity growth was not always the same.  There have been year-to-year fluctuations, not surprisingly, but these even out over time and are not significant. There are also somewhat longer term fluctuations tied to the business cycle, and these can be significant on time scales of a decade or so.  Productivity growth slows in the later phases of a business expansion, and may well fall as an economic downturn starts to develop.  But once well into a downturn, with businesses laying off workers rapidly (with the least productive workers the most likely to be laid off first), one will often see productivity (of those still employed) rise.  And it will then rise further in the early stages of an expansion as output grows while new hiring lags.

Setting aside these shorter-term patterns, one can break down productivity growth over the close to 70 year period here into three major sub-periods.  Between the first quarter of 1947 and the first quarter of 1966, productivity rose at a 2.2% annual pace.  There was then a slowdown, for reasons that are not fully clear and which economists still debate, to just a 0.4% pace between the first quarter of 1966 and the first quarter of 1982.  The pace of productivity growth then rose again, to 1.4% a year between the first quarter of 1982 and the second quarter of 2016.  But this was well less than the 2.2% pace the US enjoyed before.

An important question is why did productivity growth slow from a 2.2% pace between the late 1940s and mid-1960s, to a 1.4% pace since 1982.  Such a slowdown, if sustained, might not appear like much, but the impact would in fact be significant.  Over a 50 year period, for example, real output per worker would be 50% higher with growth at a 2.2% than it would be with growth at a 1.4% pace.

There is also an important question of whether productivity growth has slowed even further in recent years.  This might well still be a business cycle effect, as the economy has recovered from the 2008/09 downturn but only slowly (due to the fiscal drag from cuts in government spending).  The pace of productivity growth has been especially slow since late 2010, as is clear by blowing up the chart from above to focus on the period since 2000:

GDP per Worker, 2000Q1 to 2016Q2,rev

Productivity has increased at a rate of just 0.13% a year since late 2010.  This is slow, and a real problem if it continues.  I would hasten to add that the period here (5 1/2 years) is still too short to say with any certainty whether this will remain an issue.  There have been similar multi-year periods since 1947 when the pace of productivity growth appeared to slow, and then bounced back.  Indeed, as seen in the chart above, one would have found a similar pattern had one looked back in early 2009, with a slow pace of productivity growth observed from about 2005.

There has been a good deal of work done by excellent economists on why productivity growth has been what it was, and what it might be in the future.  But there is no consensus.  Robert J. Gordon of Northwestern University, considered by many to be the “dean in the field”, takes a pessimistic view on the prospects in his recently published magnum opus “The Rise and Fall of American Growth”.  Erik Brynjolfsson and Andrew McAfee of MIT, in contrast, argue for a more optimistic view in their recent work “The Second Machine Age” (although “optimistic” might not be the right word because of their concern for the implication of this for jobs).  They see productivity growth progressing rapidly, if not accelerating.

But such explanations are focused on possible productivity growth as dictated by what is possible technologically.  A separate factor, I would argue, is whether investment in fact takes place that makes use of the technology that is available.  And this may well be a dominant consideration when examining the change in productivity over the short and medium terms.  A technology is irrelevant if it is not incorporated into the actual production process.  And it is only incorporated into the production process via investment.

To understand productivity growth, and why it has fallen in recent decades and perhaps especially so in recent years, one must therefore also look at the investment taking place, and why it is what it is.  The rest of this blog post will do that.

B.  The Slowdown in the Pace of Investment

The first point to note is that net investment (i.e. after depreciation) has been falling in recent decades when expressed as a share of GDP, with this true for both private and public investment:

Domestic Fixed Investment, Total, Public, and Private, Net, percentage of GDP, 1951 to 2015, updated Aug 16, 2016

Total net investment has been on a clear downward trend since the mid-1960s.  Private net investment has been volatile, falling sharply with the onset of an economic downturn and then recovering.  But since the late 1970s its trend has also clearly been downward. Net private investment has been less than 3 1/2% of GDP in recent years, or less than half what it averaged between 1951 and 1980 (of over 7% of GDP).  And net public investment, while less volatile, has plummeted over time.  It averaged 3.1% of GDP between 1951 and 1968, but is only 0.5% of GDP now (as of 2015), or less than one-sixth of what it was before.

With falling net investment, the rates of growth of public and private capital stocks (fixed assets) have fallen (where 2014 is the most recent year for which the BEA has released such data):

Rate of Growth In Per Capita Net Stock of Private and Government Fixed Assets, edited, 1951 to 2014

Indeed, expressed in per capita terms, the stock of public capital is now falling.  The decrepit state of our highways, bridges, and other public infrastructure should not be a surprise.  And the stock of private capital fell each year between 2009 and 2011, with some recovery since but still at almost record low growth.

Even setting aside the recent low (or even negative) figures, the trend in the pace of growth for both public and private capital has declined since the mid-1960s.  Why might this be?

C.  Why Has Investment Slowed?

The answer is simple and clear for pubic capital.  Conservative politicians, in both the US Congress and in many states, have forced cuts in public investment over the years to the current low levels.  For whatever reasons, whether ideological or something else, conservative politicians have insisted on cutting or even blocking much of what the United States used to invest in publicly.

Yet public, like private, investment is important to productivity.  It is not only commuters trying to get to work who spend time in traffic jams from inadequate roads, and hence face work days of not 8 1/2 hours, but rather 10 or 11 or even 12 hours (with consequent adverse impacts on their productivity).  It affects also truck drivers and repairmen, who can accomplish less on their jobs due to time spent in jams.  Or, as a consequence of inadequate public investment in computer technology, a greater number of public sector workers are required than otherwise, in jobs ranging from issuing driver’s licenses to enrolling people in Medicare.  Inadequate public investment can hold back economic productivity in many ways.

The reasons behind the fall in private investment are less obvious, but more interesting. An obvious possible cause to check is whether private profitability has fallen.  If it has, then a reduction in private investment relative to output would not be a surprise.  But this has in fact not been the case:

Rate of Return on Produced Assets, 1951 to 2015, updated

The nominal rate of return on private investment has not only been high, but also surprisingly steady over the years.  Profits are defined here as the net operating surplus of all private entities, and is taken from the national account figures of the BEA.  They are then taken as a ratio to the stock of private produced assets (fixed assets plus inventories) as of the beginning of the year.  This rate of return has varied only between 8 and 13% over the period since at least 1951, and over the last several years has been around 11%.

Many might be surprised by both this high level of profitability and its lack of volatility.  I was.  But it should be noted that the measure of profitability here, net operating surplus, is a broad measure of all the returns to capital.  It includes not only corporate profitability, but also profits of unincorporated businesses, payments of interest (on borrowed capital), and payments of rents (as on buildings). That is, this is the return on all forms of private productive capital in the economy.

The real rates of return have been more volatile, and were especially low between 1974 and 1983, when inflation was high.  They are measured here by adjusting the nominal returns for inflation, using the GDP deflator as the measure for inflation.  But this real rate of return was a good 9.6% in 2015.  That is high for a real rate of return.  It was higher than that only for one year late in the Clinton administration, and for several years between the early 1950s and the mid-1960s.  But it was never higher than 11%.  The current real rate of return on private capital is far from low.

Why then has private investment slowed, in relation to output, if profitability is as high now as it has ever been since the 1950s?  One could conceive of several possible reasons. They include:

a)  Along the lines of what Robert Gordon has argued, perhaps the underlying pace of technological progress has slowed, and thus there is less of an incentive to undertake new investments (since the returns to replacing old capital with new capital will be less).  The rate of growth of capital then slows, and this keeps up profitability (as the capital becomes more scarce relative to output) even as the attractiveness of new investment diminishes.

b)  Conservatives might argue that the reduced pace of investment could be due to increased governmental regulations, which makes investment more difficult and raises its cost.  This might be difficult to reconcile with the rate of return on capital nonetheless remaining high, but in principle could be if one argues that the slower pace of new investment keeps up profitability as capital then becomes more scarce relative to output. But note that this argument would require that the increased burden of regulation began during the Reagan years in the early 1980s (when the share of private investment in GDP first started to slow – see the chart above), and built up steadily since then through both Republican and Democratic administrations.  It would not be something that started only recently under Obama.

c)  One could also argue that the reduced investment might be a consequence of “Baumol’s Cost Disease”.  This was discussed in earlier posts on this blog, both for overall government spending and for government investment in infrastructure specifically.  As discussed in those posts, Baumol’s Cost Disease explains why activities where productivity growth may be relatively more difficult to achieve than in other activities, will see their relative costs increase over time.  Construction is an example, where productivity growth has been historically more difficult to achieve than has been the case in manufacturing.  Thus the cost of investing, both public and private, relative to the cost of other items will increase over time.  This can then also be a possible explanation of slowing new investment, with that slower investment then keeping profitability up due to increasing scarcity of capital.

One problem with each of the possible explanations described above is that they all depend on capital investments becoming less attractive than before, either due to higher costs or due to reduced prospective return.  If such factors were indeed critical, one would need to take into account also the effect of taxes on investment returns.  And such taxes have been cut sharply over this same period.  As discussed in an earlier blog post, taxes on corporate profits, for example, are taxed now at an effective rate of less than 20%, based on what is actually paid after all the legal deductions and credits are included.  And this tax rate has fallen steadily over time.  The current 20% rate is less than half the effective rate that applied in the 1950s and 1960s, when the effective rate averaged almost 45%.  And the tax rate on long-term capital gains, as would apply to returns on capital to individuals, fell from a peak of just below 40% in the mid-1970s to just 15% following the Bush II tax cuts and to 20% since 2013.

Such sharp cuts in taxes on profits implies that the after-tax rate of return on assets has risen sharply (the before-tax rate of return, shown on the chart above, has been flat).  Yet despite this, private investment has fallen steadily since the early 1980s as a share of GDP.

Such explanations for the reason behind the fall in private investment since the early 1980s are therefore questionable.  However, the purpose of this blog post is not to debate this. Economists are good at coming up with models, possibly convoluted, which can explain things ex post.  Several could apply here.

Rather, I would suggest that there might be an alternative explanation for why private investment has been declining.  While consistent with basic economics, I have not seen it before.  This explanation focuses on the stagnant real wages seen since the early 1980s, and the impact this would have on whether or not to invest.

D.  The Impact of Low Real Wages

Real wages have stagnated in the US since the early 1980s, as has been discussed in earlier posts on this blog (see in particular this post).  The chart below, updated to the most recent figures available, compares the real median wage since 1979 (the earliest year available for this data series) to real GDP per worker employed:

Real GDP per Worker versus Real Median Wage, 1979Q1 to 2016Q2, rev

Real median wages have been flat overall:  Just 3% higher in 2016 than what they were 37 years before.  But real GDP per worker is almost 60% higher over this same period.  This has critically important implications for both private investment and for productivity growth. To sum up in one line the discussion that will follow below, there is less and less reason to invest in new, productivity enhancing, capital, if labor is available at a stagnant real wage that has changed little in 37 years.

Traditional economics, as commonly taught, would find it difficult to explain the observed stagnation in real wages while productivity has risen (even if at a slower pace than before). A core result taught in microeconomics is that in “perfectly competitive” markets, labor will be paid the value of its marginal product.  One would not then see a divergence such as that seen in this chart between growth in productivity and a lack of growth in the real wage.

(The more careful observers among the readers of this post might note that the productivity curve shown here is for average productivity, and not the marginal productivity of an extra worker.  This is true.  Marginal productivity for the economy as a whole cannot be easily observed, nor indeed even be well defined.  However, one should note that the average productivity curve, as shown here, is rising over time.  This can only happen if marginal productivity on new investments are above average productivity at any point in time.  For other reasons, the real average wage would not rise permanently above average productivity (there would be an “adding-up” problem otherwise), but the theory would still predict a rise in the real wage with the increase in observed productivity.)

There are, however, clear reasons why workers might not be paid the value of their marginal product in the real world.  As noted, the theory applies in markets that are assumed to be perfectly competitive, and there are many reasons why this is not the case in the world we live in.  Perfect competition assumes that both parties to the transaction (the workers and employers) have complete information on not only the opportunities available in the market and on the abilities of the individual worker, but also that there are no costs to switching to an alternative worker or employer.  If there is a job on the other side of the country that would pay the individual worker a bit more, then the theory assumes the worker will switch to it.  But there are, of course, significant costs to moving to the other side of the country.  Furthermore, there will be uncertainty on what the abilities of any individual worker will be, so employers will normally seek to keep the workers they already have to fill their needs (as they know what these workers can do), than take a risk on a largely unknown new worker who might be willing to work for a lower wage.

For these and other reasons, labor markets are not perfectly competitive, and one should not then be surprised to find workers are not being paid the value of their marginal product.  But there is also an important factor coming from the macroeconomy. Microeconomics assumes that all resources, including labor resources, are being fully employed.  But unemployment exists and is often substantial.  Additional workers can then be hired at the current wage, without a need for the firm to raise that wage.  And that will hold whether or not the productivity of those workers has risen.

In such an environment, when unemployment is substantial one should not be surprised to find a divergence between growth in productivity and growth in the real wage.  And while there have of course been sharp fluctuations arising from the business cycle in the rate of unemployment from year to year, the simple average in the rate since 1979 has been 6.4%.  This is well in excess of what is normally considered the full employment rate of unemployment (of 5% or less).  Macro policy (both fiscal and monetary) has not done a very good job in most of the years since 1979 in ensuring there is sufficient demand in the aggregate in the economy to allow all workers who want to be employed in fact to be employed.

In such an environment, of workers being available for hire at a stagnant real wage which over time diverges more and more from their productivity, consider the investment decision a private firm faces.  Suppose they see a market opportunity and can sell more. To produce more, they have two options.  They can hire more labor to work with their existing plant and equipment to produce more, or they can invest in new plant and equipment.  If they choose the latter, they can produce more with fewer workers than they would otherwise need at the new level of production.  There will be more output per unit of labor input, or put another way, productivity will rise if the latter option is chosen.

But in an economy where labor is available at a flat real wage that has not changed in decades, the best choice will often simply be to hire more labor.  The labor is cheap.  New investment has a cost, and if the cost of the alternative (hire more labor) is low enough, then it is more profitable for the firm simply to hire more labor.  Productivity in such a case will then not go up, and may indeed even go down.  But this could be the economically wise choice, if labor is cheap enough.

Viewed in this way, one can see that the interpretation of many conservatives on the relationship between productivity growth and the real wage has it backwards.  Real wages have not been stagnant because productivity growth has been slow.  Labor productivity since 1979 has grown by a cumulative 60%, while real median wages have been basically flat.

Rather, the causation may well be going the other way.  Stagnant and low real wages have led to less and less of an incentive for private firms to invest.  And such a cut-back is precisely what we saw in the chart above on private (as well as public) investment as a share of GDP.  With less investment, the pace of productivity growth has then slowed.

As a reflection of this confusion, conservatives have denounced any effort to raise wages, asserting that if this is done, jobs will be lost as firms choose instead to invest and automate.  They assert that raising the minimum wage, which is currently lower in real terms than what it was when Harry Truman was president, would lead to minimum wage workers losing their jobs.  As a former CEO of McDonalds put it in a widely cited news report from last May, a $15 minimum wage would lead to “a job loss like you can’t believe.”   Fast food outlets like McDonalds would then find it better to invest in robotic arms to bag the french fries, he said, rather than hire workers to do this.

This is true.  The confusion comes from the widespread presumption that this is necessarily bad.  Outlets like McDonalds would then require fewer workers, but they would still need workers (including to operate the robotic arms), and those workers would be more productive.  They could be paid more, and would be if the minimum wage is raised.

The error in the argument comes from the presumption that the workers being employed at the current minimum wage of $7.25 an hour do not and can not possess the skills needed to be employed in some other job.  There is no reason to believe this to be the case.  There was no problem with ensuring workers could be fully employed at a minimum wage which in real terms was higher in 1950, when Harry Truman was president, than what it is now.  And average worker productivity is 2.4 times higher now than what it was then.

Ensuring full employment in the economy as a whole is not a responsibility of private business.  Rather, it is a government responsibility.  Fiscal and monetary policy need to be managed so that labor markets are tight enough to ensure all workers who want a job can get a job, while not so tight at to lead to inflation.

Following the economic collapse at the end of the Bush administration in 2008, monetary policy did all it could to try to ensure sufficient aggregate demand in the economy (interest rates were held at or close to zero).  But monetary policy alone will not be enough when the economy collapsed as far as it did in 2008.  It needs to be complemented by supportive fiscal policy.  While there was the initial stimulus package of Obama which was critical to stabilizing the economy, it did not go far enough and was allowed to run out. And government spending from 2010 was then cut, acting as a drag which kept the pace of recovery slow.  The economy has only in the past year returned to close to full employment.  It is not a coincidence that real wages are finally starting to rise (as seen in the chart above).

E.  Conclusion

Productivity growth is key in any economy.  Over the long run, living standards can only improve if productivity does.  Hence there is reason to be concerned with the slower pace of productivity growth seen since the early 1980s, and especially in recent years.

Investment, both public and private, is what leads to productivity growth, but the pace of investment has slowed since the levels seen in the 1950s and 60s.  The cause of the decline in public investment is clear:  Conservative politicians have slowed or even blocked public investment.  The result is obvious in our public infrastructure:  It is overused, under-maintained, and often an embarrassment.

The cause of the slowdown in private investment is less obvious, but equally important. First, one cannot blame a decline in private investment on a fall in profitability:  Profitability is higher now than it has been in all but one year since the mid-1960s.

Rather, one needs to recognize that the incentive to invest in productivity enhancing tools will not be there (or not there to the same extent) if labor can be hired at a wage that has stagnated for decades, and which over time became lower and lower relative to existing productivity.  It then makes more sense for firms to hire more workers with their existing stock of capital and other equipment, rather than invest in new, productivity enhancing, capital.  And this is what we have observed:  Workers are being hired, but productivity is not growing.

An argument is often made that if firms did indeed invest in capital and equipment that would raise productivity, that workers would then lose their jobs.  This is actually true by definition:  If productivity is higher, then the firm needs fewer workers per unit of output than they would otherwise.  But whether more workers would be employed in the economy as a whole does not depend on the actions of any individual firm, but rather on whether fiscal and monetary policy is managed to ensure full employment.

That is, it is the investment decisions of private firms which determine whether productivity will grow or not.  It is the macro management decisions of government which determine whether workers will be fully employed or not.

To put this bluntly, and in simplistic “bumper sticker” type terms, one could say that private businesses are not job creators, but rather job destroyers.  And that is fine.  Higher productivity means that a firm needs fewer workers to produce what they make than would otherwise have been needed, and this is important for ensuring efficiency.  As a necessary complement to this, however, it is the actions of government, through its fiscal and monetary policies, which “creates” jobs by managing aggregate demand to ensure all workers who want to be employed, are employed.