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Integration of Business and Individual Taxes
Simplicity, Administration and Compliance
The following issues briefs analyze tough questions such as: How fair would a flat-tax system be, and what does "fairness" mean? Would a consumption tax system actually increase savings and investment? How difficult would the transition be from our current income tax to a radically new and untested system?
More concrete matters, such as trade issues, the integration of business
and individual taxes under a new system, collection of value-added tax, simplicity,
administration, compliance, the effect of a new system on state and local governments, and
the potential for revenue cuts as a result of fundamental tax reform, have also been
considered.
Issue: Can the Tax System Be Made More Fair?
In the debate over fundamental tax restructuring, proponents of different plans will argue that their plans promote greater fairness. Although most analysts who describe "fairness" rely on the notion of "ability to pay" or the taxpayer's capacity to bear taxes, they do not agree on how to assess a taxpayer's ability to pay. Several possible measures of fairness are outlined below.
Historically, the federal government has relied on income as the principal measure of
ability to pay. As a result, 55 percent of federal revenues are derived from income taxes.
State and local governments have tended to rely more heavily on consumption (sales) and
wealth (property and estate) taxes. In recent years, as state and local budgets have
grown, income taxes have become more important to the states.
The result is that taxes collected at all levels of government are comprised of a
combination of income, consumption, and wealth taxes.
Income. Many analysts suggest using a comprehensive measure of income as the
measure of ability to pay. Income during a particular period represents the additional
resources the taxpayer could devote to consumption during a period. Although an annual
measure of income is commonly used, it may be misleading. An individual's income can vary
greatly from year to year, and any one year's result may not necessarily reflect general
ability to pay. Income may be low during school years, peak toward the end of one's
working years, and decline in retirement. The annual income of college students or
retirees may not reflect their ability to pay. Many economists have argued that lifetime
income (or some average of income over several years) is a better indicator of ability to
pay. On the other hand, for individuals who have little wealth and for whom borrowing on
future income is very costly, the fact that their income may have been higher in the past
(or will be higher in the future) may have little to do with their ability to pay taxes in
the current year.
Consumption. Annual consumption is much less variable than annual income. Over an
individual's life, consumption is roughly equal to income plus gifts and bequests. In
addition, annual consumption is more likely to be a function of lifetime income than
annual income. This leads some to advocate annual consumption as the best measure of
ability to pay. Others have advocated a consumption tax base, not as a proxy for income,
but because it may be a better measure of economic well-being. Advocates of this view tend
to believe that the ability of individuals to borrow when they want to spend and to lend
when they have excess resources implies that the timing of the receipt of income is not
relevant in measuring the ability to pay taxes.
Equal Treatment of Equals. Present law may impose different tax liabilities on
taxpayers with the same economic income if the taxpayers have different sources of income
or different types of expenses. Some view this outcome as unfair and advocate a broad tax
base that minimizes the number of exclusions and deductions. The principle of a
comprehensive tax is to apply the same rate of tax to all similarly-situated individuals.
However, whether two individuals are similarly situated is not an easy question. For
example, people disagree over whether two taxpayers are similarly situated if they have
the same income but make different housing choices or have different medical, state and
local tax, or work-related expenses.
Progressivity. A tax is progressive if the average tax rate rises as the tax base
rises. An average income tax rate is the total tax imposed divided by the
taxpayer's total income. A marginal income tax rate is the rate of tax imposed on an
additional, or marginal, dollar of income earned by the taxpayer. The present federal
individual income tax is a progressive tax because as income rises, the average tax rate
rises.
A flat tax, such as that proposed by Mr. Armey, is
progressive because it exempts some initial level of wage income from taxation. Similarly,
a single-rate personal consumption tax could be progressive if an initial level of
consumption is exempt. However, tax systems that contain only one rate are likely to be
less progressive than the present-law system and therefore will reduce tax burdens for
high-income taxpayers and increase burdens for middle-income taxpayers. With a multi-rate
schedule, a personal consumption tax, such as that in the Nunn-Domenici proposal, could be
designed to be as progressive as the present-law system.
If the tax base is changed at the same time the rate structure is altered, general
statements about the effects of progressivity are not possible. For example, a flat tax
might lower the marginal tax rate and total tax liability for higher-income taxpayers. If,
however, the tax base were broadened to include interest from existing state and local
bonds and if higher-income taxpayers held substantial amounts of those bonds, the tax
liabilities for higher-income taxpayers might increase even as their marginal tax rate
fell.
Conclusion. The struggle to achieve fairness frequently creates
complexity. Under present law, the alternative minimum tax, the anti-deferral rules, the
limits on passive losses, and the premature accrual rules all arose, at least in part,
from arguments couched in terms of fairness. Additionally, the competition of views over
how best to define ability to pay suggests that the current system, which combines income,
wage, consumption, and wealth taxes, may be a good political compromise. Concerns over
fairness may drive Congress to create a less simple tax than the one that would emerge if
simplicity were the chief concern.
Issue: Can and Should the Tax System Be Used to Encourage Savings, Investment, and Growth?
By their very nature, taxes are not neutral and distort taxpayer behavior. They influence a taxpayer's decisions about consumption, savings, and work. A tax system that taxes different individuals based on decisions to earn or consume income is not neutral among individuals, sources of income, or types of consumption, and it affects those decisions. A tax system may lead taxpayers to make decisions that result in an inefficient use of their own and the economy's resources, reduce the taxpayers' welfare, and diminish the performance of the economy. In addition, taxpayers may be encouraged to engage in activities that offer a positive private return but no net return to the economy. These effects may occur within the current year or across different years.
Economists observe that income taxes are nonneutral, or biased, over
multiple years. By taxing both wage income and any return on after-tax wages saved, income
taxes increase the cost of future consumption compared to present consumption. This may
create a bias against saving. Besides distorting consumer behavior, if aggregate savings
are significantly reduced, economic output may be reduced, because savings may be
necessary to finance investment in productivity-enhancing training, equipment, and
research.
On the other hand, consumption taxes reduce the return from work effort.
Other things being equal, the rate of income tax that raises the same revenue as a
consumption tax is lower because the former taxes capital income. Thus, the income tax may
cause less distortion on work decisions. Further, many economists are skeptical that
effect on savings of switching from the current income tax (which already has many
consumption tax elements, such as pensions) to a consumption tax would be large.
Current-Year Biases. The present federal income tax imposes different tax rates on
different individuals. Taxing different individuals at different marginal tax rates
creates opportunities for various taxpayers to manipulate their positions to take
advantage of the different rates. For example, a taxpayer who has discretion over timing
of receipts and expenses will plan to recognize income when marginal tax rates otherwise
would be low and to pay expenses when marginal tax rates otherwise would be high. Although
such strategies are profitable for the taxpayer, the economy as a whole may receive no
benefit. Also, the delay or acceleration of economic activity merely to affect a
taxpayer's tax liability may create inefficiencies in the market.
A single marginal tax rate, as in a flat tax, generally reduces the potential for private
profit from various tax strategies and may free the taxpayer's time and resources for
other activity. Similarly, a VAT or retail sales tax would eliminate tax strategies because of
the single rate structure and because they are not being levied directly on individuals.
Under a tax system with increasing marginal tax rates on consumption, such as the Nunn-Domenici proposal, taxpayers would benefit by trying to
avoid bunching large purchases in one year.
Another bias is reflected in the benefits different taxpayers get from holding different
types of assets. One group of taxpayers may have an advantage by holding one type of
asset, and another group of taxpayers may have an advantage in holding another type of
asset. For example, because certain interest is deductible, high-tax bracket taxpayers
might be more likely to borrow, and to borrow from low- or zero-bracket taxpayers. This
could distort credit markets because a factor that has nothing to do with the taxpayer's
credit worthiness would cause taxpayers to experience different interest rates.
Such a bias also may lead to the collection of less tax. Under the present income tax,
interest income is taxable and corporations may deduct interest expense. If all taxpayers
faced the same tax rate, the aggregate tax collected from interest income recognized from
corporate interest payments would be offset by corporate interest deductions. If taxpayers
in tax-rate brackets lower than those of corporations hold the debt, the government on net
collects less in tax from interest income than it forgoes in interest deductions.
The present federal income tax also imposes different effective tax rates on different sources of income. For example, income from investments in corporate equity generally is subject to a corporate-level tax when earned and to individual-level tax when the income is distributed to individuals. Interest from certain state and local securities is exempt from tax. These distinctions may distort investor decisions and reduce the efficiency of the capital market in allocating capital to its most highly valued uses. Consumption-based taxes seek to avoid this distortion by effectively exempting all investment income from direct taxation, although reforms in the income tax could also address this issue.
Similarly, certain forms of employee compensation, such as employer-provided health
benefits, are not taxed. Some economists suggest that the exclusion of certain health
benefits from taxable compensation leads employees to consume more health care and fewer
other goods than they otherwise would. Similar biases could arise under consumption-based
taxes if certain consumption goods were exempt from tax or taxed at lower rates. For
example, exclusion of health care services and health insurance from a consumption tax
base also may lead individuals to consume more of these services than they otherwise
would.
Taxpayers could also arrange their affairs to increase tax-preferred sources of income or
consumption, leading to an erosion of the tax base. For example, employees might negotiate
for a larger proportion of their income to be paid in the form of nontaxed fringe
benefits. Erosion of the tax base could lead to higher rates of tax, which, in turn, would
create greater economic distortions. The consumption tax base may also shrink if taxpayers
could arrange their affairs to take advantage of general exemption amounts or lower rates
of tax.
Multi-Year Biases. Any income tax can be criticized as nonneutral between present
and future consumption. If a taxpayer earns wage income today and consumes today, the tax
on that consumption is equal to the tax on the wages. If the taxpayer earns wage income
today and saves it to consume tomorrow, the tax on that future consumption will equal the
tax on the wage income plus the tax owed on any interest earned. The total tax is greater
if the consumption is deferred.
The potential distortion in favor of present, rather than future, consumption may create a
disincentive to saving; and as discussed above, saving is necessary for economic growth.
Proponents of consumption taxes believe a flat tax or a VAT will encourage investment and saving, which will
strengthen the U.S. economy.
When an economy's rate of net investment (gross investment less depreciation) increases,
the economy's stock of capital increases. A larger capital stock permits greater
production of goods and services using a fixed amount of labor. The larger a country's
capital stock, the more productive its workers and, generally, the higher its real wages
and salaries. Increases in investment tend to lead to future increases in a nation's
standard of living.
Investment can be financed either by national savings or by foreign borrowing (which is
actually savings by foreigners). When demand for investment funds in the United States
outstrips the supply of national savings, interest rates rise. Increases in interest rates
attract foreign capital to the United States, and the excess of domestic investment over
national savings is financed by foreigners' savings. If capital is not perfectly mobile
between nations, the level of national savings can affect the level of investment. When
the domestic savings rate is low, the domestic investment rate is also low. Historically,
there has been a strong positive correlation between a country's rate of investment and
its rate of savings.
Effect of Tax Policy on Savings. Economists disagree whether, in fact, an
income tax does discourage saving. At issue is the extent to which taxpayers change their
saving in response to the net after-tax return to their savings. Some studies have argued
substantial increases in savings should result from increases in the net return. Other
studies argue that large behavioral responses would not result from changes in the
after-tax rate of return. Empirical investigation of the responsiveness of personal saving
to the taxation of investment earnings provides no conclusive results.
Trends in National Saving. Net business saving, personal saving, and public saving
all were lower during the past several years than in any of the three previous decades.
Although private saving remained positive, public saving (that is, the excess of
governmental spending over governmental revenues) consistently was negative during the
1980s as the result of federal deficits. The magnitude of public negative saving during
the past 15 years generally was larger relative to GDP than in earlier years. Net national
savings declined steadily through most of the 1980s. The U.S. national savings rate is low
when compared to that of other nations. The U.S. net savings rate for 1993 was 2.7 percent
compared to the OECD average of 7.3 percent. The relative effect on savings of differences
among or changes in countries' tax systems, as compared to other economic, demographic,
and cultural factors, is a continuing source of controversy.
Conclusion. Concern that the current income tax system may inappropriately favor
consumption over savings and investment is a major motivator for most consumption-tax
advocates. They believe that the current U.S. savings rate is too low and that Americans
are falling behind internationally because of the barriers to investment inherent in the
income tax. Others are skeptical that the tax system either is the source of poor savings
habits in the United States or that a new tax system could cure our economic challenges.
Some argue that too rapid a shift to a tax system that in fact created greater savings
could be disastrous at a time when the federal government is withdrawing massive amounts
of economic stimulus by moving to a balanced budget. Further, consumption tax critics
argue that some of the beneficial features of a broad-based consumption tax, such as lower
rates and equal treatment of various sources of income, also could be achieved by reforms
in the income tax.
Ultimately, whether a consumption tax is adopted as a complete or partial
replacement of the income tax may be determined by the response of financial markets and
others to the central issue of what role taxes can or should play in encouraging a healthy
mix of consumption and savings.
Issue: If a New System Is Adopted, How Are Taxpayers Protected During the Transition?
Many advocates of consumption taxes have suggested that the transition from the current system to a new one is a major consideration. Concern over transition centers on the likely effects of adopting a consumption tax on asset values, prices, and savings, as well as concerns over potential double taxation. A consumption tax is equal to a tax on wages plus a tax on capital existing at the time of the introduction of the tax. This one-time capital tax may change the value of existing assets. In the absence of specific transition rules, the introduction of a consumption tax will result in increased tax liability on the returns to existing assets. Because a broad-based VAT may increase prices by the amount of tax (if the Federal Reserve Board's monetary policy accommodates such an outcome), the replacement of the present income tax with a VAT could affect the level of interest rates and, therefore, the value of various financial assets. The ultimate effect would depend on the nature of the demand for and supply of savings. For individuals, introduction of a consumption tax creates transition issues regarding the carryover of assets (such as pension savings) and liabilities (such as home mortgages) from the preconsumption tax regime.
Whether by design or otherwise, most of the consumption tax proposals
introduced to date do not provide transition rules. Only the Nunn-Domenici proposal
contains comprehensive and explicit transition rules. Some commentators argue that
transition may not be desirable or necessary for a variety of reasons. They reason that
(1) all policy changes create "winners" and "losers," (2) not
providing transition rules appropriately rewards those persons who have diversified their
investments as insurance against legislative change, (3) transition rules that benefit
"old" wealth would negate efficiency gains brought about by the new
consumption-based tax, (4) transition rules are not important because the current tax
system is a hybrid of consumption and income bases, and (5) transition rules are likely to
create complexity and reduce revenue.
Despite these arguments, many commentators believe that, as a practical and political
matter, transition rules probably will be part of any tax-restructuring legislation.
Certain transition rules may be necessary to prevent the significant economic disruption
that could occur if taxpayers were to delay transactions in anticipation of, for example,
elimination of tax on capital gains and expensing treatment for new capital investments.
Although the details of any transition rules depend on the type of tax system that is
being adopted, discussions of transition rules generally involve the treatment of savings
accumulated before the enactment of the new system. Some believe it would be unfair to tax
the spending from the old savings under the new consumption-based system. This issue is
particularly important to the elderly, who are no longer earning wage income, hold a
disproportionate share of old savings, and withdraw from old savings to meet their
consumption needs. Similarly, the adjusted bases of capital assets held by a business on
the date of enactment of a new system might require special treatment.
It should be noted that transition relief probably would not be needed if a consumption
tax is adopted in addition to, rather than in place of, the current tax system. The
following discusses various forms of transition relief relating to accumulated wealth and
invested business capital.
No Transition Rules. As described above, some commentators advocate a delayed
effective date, with no transition rules, for the switch from the current tax system to a
consumption tax. Some argue that a substantial amount of time from the date of enactment
to the effective date of the consumption tax would be needed to properly implement the new
system. With a delayed effective date, transition rules become less of a concern as
taxpayers would have opportunities to arrange their investments to correspond to the new
tax system. Some suggest that financial markets already are beginning to make such
adjustments.
Even a delayed effective date would not adequately address the concerns of elderly
individuals who, because of the stage of their life cycles, naturally are depleting, not
increasing, their savings. One possible approach would be to provide relief outside the
tax system, such as by increasing transfer payments (that is, social security) to the
affected class of individuals.
In addition, reliance upon the current tax system for a period of time allows any
transition relief to be provided within the system. For example, depreciation for the
adjusted income tax basis of property in existence on the date of enactment could be
accelerated to fit this window, and investments with accrued but unrecognized capital
gains could be marked to market and subject to tax to prevent any windfall gains from
occurring.
Even if Congress were not to provide transition relief for old savings on the
implementation of a consumption-based tax, transition rules still would be required for
certain items. These would include rules for the treatment of long-term contracts and
other works-in-process that span the effective date and rules for used goods in the hands
of consumers on the effective date that are sold in commercial settings after the
effective date. Further, providing a relatively long lead-in period may have adverse
consequences as taxpayers may be reluctant to make current investments or engage in other
transactions that may have significantly better tax treatment if made after the effective
date.
Phased-in Transition. Others have suggested that the current tax system could be
phased out as the new system is being phased in. This could be structured in a number of
ways. Taxpayers could be subject to both systems for a period of years, with the income
tax rate declining as the consumption tax rate increases. At the end of a specified
period, the income tax would no longer exist. Alternatively, taxpayers could be required
to pay the higher of their liability as computed under the new system or the old system
during the transition period (similar to the operation of the regular income tax and the
alternative minimum tax under present law).
Providing a phased-in transition lessens the effect of shifting between two different
systems and provides the government with a more stable revenue pattern during the
transition period. On the other hand, phased-in transition (1) creates complexity and
uncertainty (that is, taxpayers will wonder whether future legislators will modify the
transition), (2) is a second-best solution in some respects because it retains traces of
the income tax system and may discourage certain investment, and (3) does not adequately
address the goals of those who want immediate, fundamental tax reform. In addition, a
phased-in transition could raise the anxiety of taxpayers who do not trust the government
and believe that the result would be the permanent existence of two tax systems.
Use of Income Tax Attributes. Another form of transition would allow all or a
portion of the income tax attributes in existence on the effective date of a consumption
tax (for example, loss and credit carryovers and adjusted basis in assets) to be used
under the new tax system. These attributes could be amortized over a specified period or
taken into account with respect to an identifiable event (such as the sale of a
preeffective date asset). Providing transition would likely involve increased
recordkeeping, may not be compatible with or easily structured for certain forms of
consumption taxes (such as a retail sales tax), may result in significant revenue
shortfalls, and probably would not address the windfall gains realized by the winners
under tax restructuring.
Conclusion. As individuals and businesses contemplate the adoption
of a totally new system, they may be unable to confidently measure the benefits and
burdens of the new system on an ongoing basis. Nonetheless, they will be acutely aware of
the potential loss of tax benefits they have planned to realize in the future. For
example, threats to continued depreciation, mortgage interest deductions, and the value of
existing assets will not go unnoticed. For this reason, the question of transition may be
the most important to resolve in trying to build consensus for any particular approach to
tax reform.
Issue: Would a Consumption Tax System Improve the U.S. Position in International Trade?
Some argue that the U.S. corporate income tax places U.S.-based corporations at a disadvantage when selling overseas and creates an advantage for foreign-based corporations that sell in the United States. Proponents of a VAT suggest that replacement of the corporate income tax would encourage exports and discourage the purchase of imports. Because border tax adjustments provide rebates on exported goods and impose taxes on imported goods, destination-based VATs (such as that in the Nunn-Domenici proposal) appear to subsidize exports and penalize imports. Armey's flat tax, however, would impose tax on all business activities that occur in the United States, regardless of where goods or services are sold. Thus, the flat tax appears to penalize exports relative to imports. In fact, economists believe border tax adjustments provide neither incentives nor penalties for international trade.
A consumption tax based on the destination principle imposes tax on imports and provides
tax rebates on exports. These border tax adjustments are a fixture of most VAT systems
currently in place. Such adjustments also would apply under a retail sales tax. They are
fully consistent with General Agreement on Tariffs and Trade (GATT) rules as long as they
do not discriminate against imports or provide over-rebates on exports. Proponents believe
that a consumption tax (based on the destination principle) would help the U.S. balance of
trade. Economists long have held that there is no direct effect of a consumption tax on
the volume of exports or imports. The imposition of a tax on imports-equal to that imposed
on goods produced domestically-and a similar tax rebate on exports is intended to maintain
a level playing field between domestic and foreign producers in their competition for
business in both domestic and foreign markets.
Suppose a certain commodity produced both overseas and domestically, such as wheat, sells
at $4.00 per bushel. With the enactment of a broad-based U.S. VAT at a rate of 10 percent,
the price of wheat in the United States would increase by 10 percent to $4.40 (under the
assumption that the tax is passed along to consumers) for wheat produced domestically as
well overseas since both are subject to the tax-the domestically produced wheat being
subject to the normal VAT and the wheat produced overseas subject to the import tax at the
same rate as the VAT. Thus, even though imports are subject to tax, U.S. buyers' choice
between imported and domestically produced wheat is not altered.
Similarly, foreign consumers' choice between goods produced in the United States and goods
produced in their own country is not altered even though U.S.-produced goods are given VAT
rebates when exported. Wheat produced outside of the United States and sold to foreign
consumers remains at its world price of $4.00 and wheat produced inside the United States
remains at $4.00 since no U.S. VAT is imposed on the exported wheat.
A consumption tax without border tax adjustments (an origin-principle consumption tax)
such as Armey's flat tax at first appears to create a disadvantage for domestic producers
relative to foreign producers in overseas markets. Border tax adjustments, though, may not
be the only mechanism operating to maintain neutrality. Other self-executing adjustments
by the markets, such as reductions in wage rates or in the value of the domestic currency,
could offset wholly any potentially detrimental trade effects of origin-based taxation on
exported goods.
It is often assumed that consumption taxes are passed along to consumers in the form of
higher prices, and it is assumed that corporate income taxes are borne by owners of
capital. Under these assumptions, although domestic and foreign producers may be subject
to different corporate tax burdens, none of these corporate burdens are reflected in
higher prices, and the relative attractiveness of goods produced by U.S.- and
foreign-owned firms is not affected. On the other hand, consumption taxes would raise
prices uniformly for the goods of both domestic- and foreign-owned firms, but the relative
attractiveness of their goods would not be affected. Under these assumptions, a
consumption tax, as compared to a corporate income tax, does not directly improve the U.S.
balance of trade by raising the price of goods of foreign-owned firms. Many economists do
not share the view of consumption tax proponents that such a tax would enhance the U.S.
trade position.
Conclusion. Proponents of a VAT seek a tax system that will
strengthen the position of the United States in international trade. Proposals that are
perceived as being more supportive of domestic producers will have an advantage in the
contest for political support. The arguments of many economists that, generally speaking,
the trade balance will be largely unaffected by any tax system the United States enacts
may not persuade businesses that see themselves on the winning or losing side of the
political debate over fundamental tax reform.
Integration of Business and Individual Taxes
Issue: If Individual Income Taxes Are Replaced with a Consumption Tax, Should Business Income Taxes Also Be Replaced?
An individual consumption tax could be imposed without changing the taxation of businesses, but the current consumption tax proposals that leave individuals as taxpayers do more than just change the individual income tax to be consistent with consumption tax principles. They also integrate business and individual taxation by using consumption tax principles in taxing business activity. Under present law, partnerships, subchapter S corporations, and sole proprietorships already are directly integrated into the individual income tax because of the pass-through treatment of these entities. For businesses organized under subchapter C, however, a separate, generally income-based, tax applies in addition to taxation at the individual level of the returns from the business.
How Are Businesses Integrated into a Consumption Tax? A business
consumption tax is achieved by defining the tax base according to "cash-flow
accounting" principles. This concept implements the notion that any expenditure
leading to the ownership of a nonfinancial asset is a form of savings, so that a full
deduction should be allowed, regardless of the period during which the asset is used to
generate income. Thus, under cash-flow accounting, businesses do not capitalize any
expenditures. Rather, they treat as expense items and fully deduct all business purchases,
including capital assets and additions to inventory. By contrast, an income tax relies on
capitalization principles to measure the base, so that deductions are taken for the cost
of depreciable property over its useful life and for inventory when it is used to produce
income.
Cash-flow accounting principles treat business activity in essentially the
same way individual savings are treated in a consumption-based tax: savings are deducted
from the base and returns to savings are included upon withdrawal. In the business
context, expenses in the current period that yield revenues in future periods are savings;
those future revenues are the return to savings.
Inventories and Durable Goods. The differences between the income
tax and a consumption tax may be most stark in the treatment of inventories and durable
goods purchases. For example, assume a manufacturer produces goods in a particular year,
but it does not sell the goods in that year. Under an income tax, the cost of producing
the unsold goods is capitalized and a deduction for the capitalized cost is not allowed
until the goods are sold. Under a consumption tax the production costs of unsold goods are
deducted as the costs are incurred, not in the year in which the goods are sold. The
addition to inventory is a form of savings and a full deduction is allowed.
Another example: Assume the manufacturer purchases a new machine that has a
useful life longer than one year. Under an income tax, only the value of the machine that
is used up during that year is deducted. The remainder of the value of the machine is
deducted in future years. Under a consumption tax, the taxpayer deducts the entire
purchase price of the machine from the annual output of the business in the year the
machine is purchased. The purchase of a durable good is a form of savings and a full
deduction is allowed.
Cash Flows. A cash-flow or consumption-type business tax may take
into account only transactions involving real (nonfinancial) activity or transactions
involving both real activity and financial activity (except for transactions with the
equity holders). Under either alternative, sales of goods and services are included in the
base, purchases of inputs are subtracted from the base, and stock sale proceeds and
dividends are ignored. Under the first approach, proceeds from a bank loan or a sale of
stock are not included in the base, and outflows such as loan repayments and payments of
interest and dividends are not subtracted from the base. Under the second approach, loan
proceeds are included in the base, and loan repayments and payments of interest as well as
purchases of inputs are subtracted from the base.
Under either base, a consumption-based tax on businesses results in an
expected tax collection of zero on the returns to additional units of capital; this is
consistent with the exclusion of investment income from a consumption tax on individuals.
In a competitive market, the price of each additional capital good would be
the expected present value of the output produced over the lifetime of the capital good.
Under most consumption-based taxes, the business deducts that price in the year of
purchase. 0 If future returns from the capital good are equal to those expected by the
taxpayer at the time of purchase, the returns the business receives from using each
additional capital good increase its tax base in the future, but only by as much in
present value as the amount expensed at the time of purchase. Thus, the expensing of the
cost of a capital good is equivalent to exempting from tax the expected returns generated
by the good. Any net collections (in present value terms) of the cash-flow tax arise from
returns in excess of those expected by the market at the time of the purchase.
Conclusion. The case for individual tax reform may rest most clearly
in concerns about fairness and complexity. The case for reform of the taxation of business income may also address the
fundamental question of whether returns on capital investment should be taxed. While
arguments about the effect of the tax system on capital formation might support expensing
of capital investments, the resulting reduction in business taxes and the ability of
businesses to manage their tax liability through investment choices might create a system
that is difficult to defend politically. Some citizens will see corporations or other
businesses as separate entities that should pay a "fair share" of taxes.
Issue: What Is the Best Way to Collect a Value Added Tax?
A value-added tax (VAT) generally is a tax imposed and collected on the value added at every stage in the production and distribution process of a good or service. Although a VAT may be computed in any of several ways, the amount of value added generally can be thought of as the difference between the value of sales and purchases of a business.
Several administrative systems could be used for a VAT: the credit-invoice
method, the subtraction method, and the addition method. The credit-invoice method has
been the system of choice in nearly all countries that have adopted a VAT. A
subtraction-method VAT is also known as a business-transfer tax. The addition method is a
mirror image of the subtraction method and will not be discussed here.
Credit-Invoice Method VAT. Under the credit-invoice method, a tax is
imposed on the seller for all of its sales. The tax is calculated by applying the tax rate
to the sales price of the good or service, and the amount of tax generally is disclosed on
the sales invoice. A business credit is provided for all VAT taxpayers on all purchases of
taxable goods and services (that is, on inputs) used in the seller's business. The
ultimate nonbusiness consumer does not receive a credit for his or her purchases. The VAT
credit for inputs prevents the imposition of multiple layers of tax on the total final
purchase price. As a result, the net tax paid at a particular stage of production or
distribution is based on the value added by that taxpayer at that stage of production or
distribution. In theory, the total amount of tax paid with respect to a good or service
from all levels of production and distribution should equal the sales price of the good or
service to the ultimate consumer multiplied by the VAT rate.
To receive an input credit, a business purchaser generally is required to
have an invoice from a seller containing the name of the purchaser and the amount of tax
collected. At the end of a reporting period, a taxpayer may calculate its tax liability by
subtracting the cumulative amount of tax stated on its purchase invoices from the
cumulative amount of tax stated on its sales invoices.
Subtraction-Method VAT. Under the subtraction method, value added is
measured as the difference between a business's taxable sales and its purchases of taxable
goods and services from other businesses. At the end of the reporting period, a rate of
tax is applied to this difference in order to determine the tax liability. The subtraction
method is similar to the credit-invoice method in that both methods measure value added by
comparing sales to purchases that have borne the tax.
The subtraction method differs from the credit-invoice method principally
in that the tax rate is applied to a net amount of value added (sales less purchases)
rather than to gross sales with credits for tax on gross purchases. A business's tax
liability under the credit-invoice method relies on the business's sales records and
purchase invoices, while the tax liability under the subtraction method may rely on
records that the taxpayer maintains for income tax or financial accounting purposes.
Exclusions under a VAT. Most VATs provide special treatment for
imported and exported goods and services as well as exclusions for various goods and
services or for classes of taxpayers for economic, social, or political reasons. Certain
other goods and services are excluded from the VAT because the amount of the value added
or the element of consumption is difficult to measure.
Goods, services, or classes of taxpayers may be excluded from a VAT by
providing either a zero rating or an exemption. If a sale is zero-rated, the sale
is considered a taxable transaction, but the rate of tax is zero percent. Sellers of
zero-rated goods or services do not collect or remit any VAT on their sales of those
items, but are required to register as taxpayers under the credit-invoice method. In this
way, sellers of zero-rated items are able to claim credits (and perhaps a refund to the
extent the taxpayer does not have taxable sales) for the VAT they paid with respect to
purchased goods and services.
The seller of goods or services that are exempt also is not required to
collect any VAT on its sales, although, in contrast, it may not claim any refunds of the
VAT paid on its purchases. A VAT exemption, as opposed to a zero rating, in a
credit-invoice system breaks the chain between inputs and outputs along the various stages
of production and distribution and may result in a situation in which the total tax
collected from all stages of production would be greater than the retail sales price of
the goods times the VAT rate. For example, the exempt purchaser pays a price for goods
that includes the seller's VAT. The exempt purchaser resells at presumably an equal or
greater price that includes the earlier VAT but not its own. This breaks the reporting
chain because the second purchaser does not have evidence of the VAT. For this reason,
most VAT commentators, while recognizing that exemptions may be useful in easing the
administrative and recordkeeping burdens of certain targeted taxpayers or transactions
(such as small businesses or casual sales), prefer zero rating for providing VAT relief
under the credit-invoice method.
It is difficult to assess how exclusions would operate under a
subtraction-method VAT because of a lack of practical experience with these methods.
Theoretically, however, it should be possible to design exclusions that would replicate
the results of zero ratings or exemptions under the credit-invoice method. For a
subtraction-method VAT to replicate the results of zero ratings under the credit-invoice
method, a seller designated for relief would not be taxed on sales but would be allowed
deductions for purchases that bore the tax, potentially creating a net deficit upon which
a refund could be based. Businesses that acquire goods from zero-rated sellers may or may
not be allowed to deduct the cost of the purchases under a subtraction-method VAT.
Most VAT commentators agree that the most efficient VAT would be one that
has a minimum number of exclusions. Under such a broad-based VAT, the credit-invoice and
subtraction methods would operate in much the same manner. The commentators also agree
that, to the extent exclusions are provided, zero rating is preferable to exemption and
the credit-invoice method is a more amenable to zero or multiple rating because the
credit-invoice method allows the character of the good or service, and the appropriate tax
treatment, to be determined at the time of sale. The invoice documents the determination
of the tax treatment contemporaneously. To the extent exemptions are preferable to zero
rating (for example, if one wanted to provide administrative relief for small businesses
that provide goods and services at an intermediate stage of production or distribution),
the "naive" subtraction method may be preferable to the credit-invoice method to
avoid the imposition of multiple layers of tax with respect to the total final purchase
price.
Simplicity, Administration, and Compliance
Issue: Would a New Tax System Be Less Complex, Easier to Administer, and Harder to Avoid?
A common complaint about the current income tax system is that it is extremely complex. This complexity requires the use of resources to learn tax rules, plan tax-effective transactions, and comply with reporting requirements. Consumption tax advocates want a simpler system that uses fewer resources in the collection of the same amount of revenue.
Can a simpler system collect the same amount of revenue? Will a simpler
system create problems of complexity and administration, at least in the short run?
Present Law. Individuals, businesses, and the government all use resources in the
process of tax collection. Expenditures by individuals and businesses have been estimated
by researchers. Expenditures by the government show up in staffing and budget
requirements. For fiscal year 1994, the Internal Revenue Service had a budget of over $7.3
billion dollars, with more than 104,000 full-time equivalent employees. During fiscal
1994, the IRS processed 193.1 million primary returns and 8.7 million supplemental
documents. The IRS also processed slightly over one billion information returns in the
course of its document-matching program. There were nearly 123 million income, estate,
gift, and partnership returns filed in 1993. The IRS examined 1.3 million returns that
year, for an audit rate of 1.08 percent.
Components of Complexity. Complexity has many parents. Taxpayers probably consider
a tax system complex if one or more of the following exists: (1) substantial recordkeeping
or reporting requirements, (2) numerous legal or factual distinctions, (3) alternative
treatments of similar item, (4) uncertainty in the law, (5) frequent changes in the law or
reporting requirements, and (6) mechanically complex calculations. Present law essentially
maximizes the complexity of the system for many taxpayers. These aspects of complexity as
they relate to a consumption tax are discussed below.
Recordkeeping and Reporting Requirements. For businesses, a consumption tax may
offer a substantial reduction in recordkeeping burdens. To the extent business outputs and
inputs can be measured using financial accounts, the need for an alternate set of tax
records is reduced. Elimination of basis calculations, inventories, and taxes on
investment income would greatly reduce recordkeeping needs. For individuals, recordkeeping
burdens would be reduced by elimination of itemized deductions and distinctions among
types of savings transactions. Some of the more annoying individual recordkeeping burdens
could remain. For example, under the Nunn-Domenici proposal, all taxpayers would have to
keep track of their savings and investment transactions, because net contributions to
savings would be deductible and net withdrawals from savings would be taxable. In
addition, under any system, taxpayers with potential mixed-use business property, such as
automobiles or home offices, would have to keep records of personal use.
Numerous Distinctions. The current system attempts to relate tax liability to the
ability to pay of the taxpayer by using income to define the tax base. Defining income,
particularly certain items of capital income, can be difficult. For example, present law
has sophisticated rules relating to the measurement of interest income, the definition of
capital and ordinary income, the classification of payments as interest or dividends, and
the categorization of qualified and nonqualified compensation or excludable and
nonexcludable fringe benefits. A consumption tax could eliminate many of the more
difficult distinctions drawn under present law.
Alternative Treatments of Similar Items. The current system provides many special
incentives or treatments that involve exceptions from the general rules to encourage or
reward specific behavior. For example, interest paid on mortgage secured by residential
property is treated differently depending on its qualification as qualified residence
interest, home equity interest, investment interest, or business interest and potentially
on the application of passive loss and vacation home rules. These rules require taxpayers
to learn more about taxes and keep a greater array of records. To the extent that a
consumption tax could be instituted on a comprehensive base, this kind of complexity could
be reduced. If many exceptions are provided, whether for efficiency or equity reasons, the
consumption tax would be made more complex.
Uncertainty. Uncertainty about the law can add significantly to cost of the system.
For example, much of the tax-shelter activity of the 1970s was driven by the failure of
the courts or Congress to address clearly the tax consequences of incurring nonrecourse
debt in excess of the market value of property. Because the IRS and taxpayers were left to
take differing views, there was considerable litigation and uncertainty. If the current
income tax is replaced with a new tax structure, complexity associated with the uncertain
meaning of the law could increase over the short term. Over the long term, the presence of
fewer special rules would increase certainty.
Frequent Change Requirements. A common complaint is that tax laws change too
frequently. As soon as taxpayers learn one set of rules and adopt procedures to deal with
them, Congress changes those rules. This year's tax legislation will be the eleventh major
tax bill in the last 20 years. Today, a single business could well be maintaining
depreciation information under seven or more distinct depreciation schedules for regular
or alternative minimum tax as a result of legislation since 1980.
Radical restructuring of any kind will, at least in the short term, increase this sort of
complexity. Many businesses have spent enormous amounts of time and effort structuring
their international operations to reflect U.S. tax law. A major change in U.S. tax law
would require a complete reexamination of current strategy. Over time, it is likely that
Congress will continue to tinker with taxes and complicate business and individual taxes
as a result.
Mechanically Complex Calculations. A final form of complexity is mechanical
complexity. For example, the current rules for taxing a portion of social security
benefits require recipients to make an 18-step calculation. The mechanics of a consumption
tax could be more straightforward than those of a comprehensive income tax.
Underground Economy. Under the current income tax, some activity that is legally
subject to tax may escape taxation. A forecast made by the IRS in 1990 projected that in
tax year 1992, the amount of income taxes due but not paid by individuals and corporations
would be as great as $127 billion.
Part of this shortfall arises from the existence of a subset of the economy (perhaps 4.5
to 6 percent of GDP), known as the underground economy, which largely carries on
transactions in cash and avoids detection.
Consumption tax proponents argue that their taxes would fall more efficiently on
activities of the underground economy, since even individuals who engage in criminal
enterprises purchase goods and services from the legitimate sector of the economy. In
theory, criminals and recipients of cash compensation who underreport income would have to
pay tax built in to the cost of items they consume. To the extent retail product prices
reflect income and wage tax burdens of the producers, this already is true under present
law. Further, if individual providers of services take cash payments and do not report the
receipts, nothing in a VAT will compel reporting of that income. When they sell,
deductions or credits might be taken against any reported income from other sources.
IRS Administration of Consumption Taxes. A 1984 report by the Treasury
Department under the Reagan administration estimated that it would require approximately
20,000 additional IRS employees to administer a credit-invoice method VAT in the United
States. Since these employees would be in addition to the existing IRS staff, it is not
clear from the report what the total staffing requirements would be if the VAT were used
to replace the current income tax. Although the report assumed there would be only limited
integration of the VAT with the income tax, some of the existing IRS employees perhaps
would be required to deal with VAT-related functions (such as re-turns processing), so
that the 20,000 additional staff would not represent the entire IRS work force involved
with VAT administration.
The design features of a VAT have the largest influence on the number of staff required to
administer a VAT. The most significant of these design features is the choice of a
credit-invoice method VAT or a subtraction-method VAT. A subtraction-method VAT with no
significant exemptions could require fewer employees than a credit-invoice method VAT.
Extensive exemption or zero rating of particular sectors also could increase required IRS
administrative resources. Another important design feature is the general size of the
businesses subject to the VAT. With respect to the U.S. income tax, IRS data generally
indicate that large firms make fewer errors in basic computations than small firms. This
also is likely to be true with respect to a VAT.
Conclusion. Complexity in taxation may be the natural consequence of
a highly complex economy and a desire for fairness in the sense of assuring that everyone
pays the tax imposed on him or her. Although the current system undoubtedly could be made
less complicated for many individuals, whether they could ultimately be satisfied with the
results of such a simpler system is less clear.
Issue: How Would a New Tax System Respect the Roles and Responsibilities of State and Local Governments?
State and local governments have at least three concerns with the potential adoption of a federal consumption tax. First, does the new tax invade a tax base they believe belongs to them? To the extent a federal VAT creates hostility toward consumption or sales taxes, state and local governments may find themselves confronted by more angry taxpayers demanding lower taxes.
Second, elimination of the federal income tax effectively could require the
states to abandon income taxes as part of their revenue base. Smaller states cannot afford
the costs of a full-fledged income tax system without the assistance of a federal scheme
that they currently only need to modify to suit their needs. State income tax compliance
depends heavily on definitions and reporting requirements prescribed at the federal level.
If most states follow the federal government in abandoning the income tax, the few states
that might be able to run a system independently could not do so practically.
Finally, if all savings and investment income is exempt from federal tax so
that the interest rate on state and local debt is not reduced by a federal tax advantage,
state and local governments may be concerned with their ability to borrow
cost-effectively.
Issue: Can the Move to a New System Be Made Without Increasing the Federal Deficit?
President Clinton's fiscal year 1996 budget projects annual revenues by the turn of the century to total $1.7 trillion. Individual and corporate income taxes will account for $946 billion or 55 percent of total receipts. Another $614 billion (36 percent of receipts) is social security taxes. Replacing the income taxes would put in play a revenue stream that constitutes nearly 11 percent of the gross domestic product and nearly all of the income of the government that is not dedicated to a specific program.
Under the balanced budget promises of the new Republican majority, any
fundamental tax restructuring must be revenue neutral. As Congress struggles to achieve a
balanced budget, no room will exist for a tax restructuring that cuts everyone's taxes.
What little room may have existed will be taken away with the FY1996 budget bill, which
could cut up to $245 billion in taxes over the next seven years.
In addition, the unprecedented breadth of change that would occur if one of
these proposals were adopted could create a large amount of uncertainty in the revenue
estimates. For example, if significant unanticipated behavioral response led to a revenue
shortfall, an increase in rates and other changes in a newly-enacted tax code could be
necessary to meet the balanced budget objective.
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