Monday, March 09, 2009

Rightside-Up Benefits, part 2

This past Friday, I posted some thoughts on the "upside-down benefit problem," which arises from the fact that tax deductions are more valuable to people as their incomes rise. Focusing on the deduction for charitable contributions, I created a hypothetical taxpayer named Zoe, with taxable income of $25,000, who would have only 15% of her contributions subsidized by the tax code. Anwar, on the other hand, declared $425,000 in taxable income and would thus receive a 35% subsidy. Some of the comments on my post offered interesting questions and suggestions about the issues raised by a plan from the Obama administration to partially fix this problem, and I thought I would offer some further thoughts inspired by those comments.

First, some clarifications. The current system provides two ways (other than rate cuts) for Congress to reduce people's taxes. Tax credits are straight-up reductions in a person's tax due. If I receive a $500 tax credit for, say, child care, then my taxes go down by $500. By contrast, tax deductions reduce taxable income, which is then multiplied by a person's marginal tax rate (their current tax bracket) to determine their tax saving. A person who receives a $500 deduction will reduce her taxes by $50 if she is in the 10% bracket but by $140 if she is in the 28% bracket and $175 if she is in the top 35% bracket.

A credit system with a flat rate would set a uniform percentage of total deductions to be credited against total tax liability, severing the link between the benefits from deductions and one's tax bracket. For example, a 25% credit would simply mean that every $4 of deductions would result in $1 of reduced tax liability, no matter the taxpayer's current bracket. (I also described a progressive crediting system, but I'll leave that aside here.)

The Obama plan would go only part of the way toward a pure credit system with a flat rate. Under his plan, someone like Anwar would reduce his taxes by $28 for a $100 charitable donation, because that is the maximum amount that can be credited. In other words, at income levels starting with the 28% bracket, there will be no connection between one's tax bracket and the tax savings that result from deductions. At lower income levels, the connection (and thus the upside-down benefit) would still exist. Therefore, Zoe's taxes would still go down by only $15 if she gave a $100 donation (and if she itemizes).

Some people on the comments board discussed various possibilities such as setting a uniform credit rate at the top bracket rate, which would not reduce the tax benefit from deductions for the highest incomes from current levels but would increase them for everyone else. (Again, even this only works for people who itemize, which leaves out a lot of middle- and almost all lower-income taxpayers.) I am relatively agnostic about this, though I note that setting the credit rate at the top income level is the most expensive option. I also see no reason to tie the credit rate to tax rates at all.

The broadest point that I wanted to make is that reducing people's taxes for any of the things for which we currently allow taxes or credits is the equivalent of a direct subsidy from the government. We could partially reimburse people for making charitable contributions, for example, simply by having them apply to an agency other than the IRS and then sending them a check. Running this through the tax code is, as I noted, an accident of history. While this accident has the advantage of being administratively quite inexpensive, it has the disadvantage of making people think of these things as "tax benefits" rather than just "government benefits" or "public subsidies." This connection to taxes thus muddles the debate by bringing in all of the white-hot rhetoric about the supposed evils of taxes. It need not be so.

Second, Mike -- proving that he remembers a lot more tax law than I remember con law -- pointed out that the Obama plan creates an interesting non-neutrality. People who are in the highest income tax brackets would have an incentive to provide services directly to charity rather than to earn income in their jobs and then give the money to a charity, because cash deductions will only save 28% while in-kind donations avoid 35% for the highest income taxpayers. Very true, as a theoretical matter. Mike makes no suggestion that this is empirically significant, but I will simply offer my hunch that this will not be a big deal. We are only talking about people whose taxable income in 2008 is roughly $165,000, which means that their gross income would typically be above $200,000. I find it hard to believe that this would be the type of taxpayer who would be likely to change from cash donations to labor donations on the basis of a few percentage points of difference. I could be wrong, but as my GW tax colleague Sarah Lawsky put it: "How many people are we talking about here? Ten?"

More to the point, this example applies to charitable contributions but not to the other major items for which we allow tax deductions. According to 2007 data, "charitable contributions other than education and health" (such as soup kitchens, but also including symphonies and opera companies) cost the Treasury just over $34 billion. The mortgage interest deduction cost almost $88 billion, and that cannot be gamed in the way that Mike describes. More broadly, we should not be focused only on charitable contributions, though this is mostly my fault for using that to motivate my examples.

Third, some commenters pointed out that there are some deductions that are available because they are necessary to allow us to measure income correctly. Miscellaneous employee expenses, for example, are properly taken out of income because they are part of the cost of producing income. We could, therefore, use this as an opportunity to think carefully about which deductions are part of computing income accurately and which are genuine subsidies that happen to be run through the income tax system, subjecting only the latter to the Obama rule or its extension. Apparently, the Obama plan would apply to all deductions as currently defined.

Even though I like theoretical purity as much as the next tax nerd, I am not especially concerned about this distinction, for two reasons. For one thing, the equivalence between phasing out or limiting deductions for higher-income earners and raising effective rates is easy to demonstrate arithmetically. If the Obama plan amounts to raising or lowering effective rates indirectly by limiting the deduction of certain expenses, that will hardly be the first time that we have deviated from a pure system. Raising the top rates after sorting out the deductions that should not be limited is an option, but the bottom line would be the same.

Moreover, we also violate the income-measurement aspect of the tax code for other reasons, such as ease of administation. We limit deductions for miscellaneous employee expenses to amounts exceeding 2% of adjusted gross income, meaning that we currently miscalculate income for literally everyone. We do so because of the saving in time and effort for people who are freed from keeping receipts for everything. More generally, I tend to be worried when we make tax changes that create a new type of exception to general tax principles or that significantly increase the size of an existing exception. Based on currently available information, neither of those concerns appears to be raised by the Obama plan or even by the two more thorough-going alternatives that I endorsed on Friday. The big changes are the de-coupling of benefits from tax rates and the mild increase in progressivity, which is why I am excited about this plan.

These thoughts are not meant to be definitive but only to suggest that I view the admitted impurities of switching from a deduction system to a credit system as not worrisome enough to make this a bad idea. Far from it. As always, however, further evidence and analysis could change my mind.

-- Posted by Neil H. Buchanan


Michael C. Dorf said...

(To the extent that I remember from or have learned anything about tax law since law school) I agree with nearly all of this. I'd point out that there's another reason to think that in my example the donor would not shift to in-kind donations. Consider the lawyer who can earn $500/hour working for a corporate client who, under the current system gets a tax savings of $175 on his $500 donation to the soup kitchen. The Obama change reduces the tax savings to $140. In other words, whereas under the current system it costs him $325 to give the soup kitchen $500, under the new plan it costs him $360. Assuming he only wants to be out of pocket $325, he'll simply give a smaller amount--$451.39 by my calculation--to the soup kitchen. That will reduce the effective benefit to the soup kitchen--as we see, by $48.61--but he would reduce the effective benefit to the soup kitchen to a much greater degree if he just started volunteering in the soup kitchen for an hour. That's because the value of his time as a soup-maker is MUCH less (probably not much over minimum wage) than the value of his time as a lawyer.

SBL said...

I agree with both Neil and Mike, but just want to clarify one thing: The only way the initial comparison works is if the lawyer is volunteering as a lawyer. If he's volunteering as a soup-maker, he's not giving something of equal value to his cash donation, so the equality falls apart anyway.

Paul Scott said...

I agree with much of what was said, but will point out the following logical fallacy:

"Again, even this only works for people who itemize, which leaves out a lot of middle- and almost all lower-income taxpayers."

This is just not true, or if it is then the solution is to eliminate the standard deduction. I agree that the incentives to give are removed middle- and lower-income tax payers. The complaint, which was made in a far more pernicious manner the last time it was posted on this blog, that somehow these people are being cheated out of the benefit of itemized deductions is, however, complete fabrication. A more true way to phrase it is that middle- and lower-income taxpayers are given the benefit (and given it at a higher rate) without regard to whether they made the sacrifice required of other to receive the benefit.

I don't object to the progressive nature of the standard deduction, nor do I object to it as a means of simplifying the tax code. But I do object to its use by others as a means of suggesting that persons that take the standard deduction are being deprived of the benefits of itemization. They are all free to itemize, but the standard deduction simply provides a greater benefit.

George Lowrey said...

Part I:

Let us return to first principles. A flat tax is a highly progressive tax. At 10%, if one person earns $100,000 that person pays $10,000 in taxes. If another person earns $1,000,000 that person pays $100,000 in taxes or 10x as much as the first person. Yet there may well be no difference in the demands that both persons place on legitimate governmental services.

The second person earning $1,000,000 may live very modestly, drive little, take care to protect his home and belongings through private insurance, assume the entire responsibility to save for his own retirement and health care without Social Security and Medicare, and yet he pays 10x more income tax than the first person.

The first person may have many children attending public schools, drive an 18 wheeler and so use the interstate highways, and fritter away all his earnings, saving nothing for his old age and relying entirely on the Ponzi schemes known as Social Security and Medicare which already have created unbearable burdens upon future generations of Americans as the demographic ratio of retirees to workers approaches 1 to 1. Yet he pays 10% of the income tax paid by the second person.

From a moral standpoint, who should pay more taxes?

It is a fallacy to suggest that the person earning $1,000,000 is somehow depriving the other person of earnings or opportunities. The pie of wealth in the USA is not fixed but should grow at a rapid rate if taxes are lowered and incentives to work, innovate, save and invest are increased. The European model to which the new "Progressive" are so committed - high rates of unemployment, taxation and regulation and a low rate of productivity growth - is proof positive of this phenomenon by way of opposite example.

Yet those who promote higher and higher tax rates as income increases fall prey to the fallacy that income and wealth are a zero sum game (e.g. Thomas Malthus, Karl Marx and Lester Thurow) to be "equalized" in the name of "fairness" as determined by the members of Congress who are subject to perverse incentives to redistribute money at the behest of the best lobbyists and/or those who have themselves grown wealthy by making an industry out of yelling "discrimination" over 100 years after the Civil War - in which more Americans lost their lives than in all other American wars combined - was won, and almost 30 years after the triumph of the civil rights movement.

This zero sum game fallacy is the stock in trade of demagogues like President Obama. It encourages people to spend more time envying their fellow citizens and rent seeking from the Congress to redistribute wealth and less time sticking to their own knitting and working hard to get ahead and innovate so that overall productivity in the United States will increase more rapidly. It is the latter, and only the latter, that will increase the wealth of all Americans in the long run.

Ironically it is many of the most wealthy Americans who, through hard work, risk taking, innovation and finding more and better ways to do things who have made enormous contributions to this country not only by "building a better widget" to increase the productivity of their fellow Americans (think the personal computer) but also through charitable giving. Andrew Carnegie, the Rockefellers, Bill Gates, Sam Walton, and Warren Buffett all come to mind.

It is far better for the nation to allow these extraordinary entrepreneurs to distribute their wealth through giving to worthy private charities than to allow Congress to expropriate more and more of that wealth to distribute through a thoroughly corrupt political system in Washington.

Part II:

I don't agree that the benefit received by the rich from national defense is more than the benefit received by the poor. Property is very important to all people for all kinds of reasons, whether they be rich or poor, as in the example I gave that a man's home is his castle, be it ever so humble. It is protected by the Decalogue in Commandment 7. Voluntary exchanges of property under the common law benefit both parties to a transaction. This is the beauty and enormous social benefit of private contracts which war would threaten.

As to life, all people are mortal. No matter how wealthy they might be they eventually will die. The prohibition against taking innocent life is even more important to God and consists of Commandment 5.

Interestingly the prohibition against adultery falls in the middle at Commandment 7. Keep that in mind when people blather about how a man-man relationship should receive the same legal standing as marriage. But I digress........

Most of our tax law is motivated by envy by groups of citizens and their representatives (primarily Democrats) of what other citizens have accumulated and earn regardless of whether their income and wealth comes from very hard work or genius or any other means. This is condemned in Commandment 10, which the writers of the 16th Amendment (and Bismark, their inspiration) seem to have conveniently forgotten.

I also would remind you that the federal budget is quite different from what was envisioned by the Founders. According to the OMB, for the year 2007, only 22% of the federal budget was spent on defense and security, and this is at a time of war in Iraq and threats of terrorism at home and abroad. Social Security, Medicare, Medicaid, SCHIP and other Safety Net Programs accounted for 51% of the entire federal budget.

In other words, 51% of the federal budget now consists of forcibly taking dollars from one set of citizens who earned them under the rule of law and putting those dollars in the hands of citizens who didn't earn them, something that would be called theft if done in the private sphere by one citizen to another.

Social Security and Medicare are not exempt from this criticism because they never have been actuarially sound in that today's recipients receive far more than they would have had they invested in a private annuity and the ratio of people who pay into these Ponzi schemes to the ratio of recipients approaches 1 to 1 - which is unsustainable.

This is a recipe for European socialism, and the trend lines do not look good. Had the Founders' original intention remained intact, the federal budget would be about 25% of its present size and most social programs would originate in and be operated by the states or, even better, through private charity, much more efficiently and fairly than can be done by the government through huge, inefficient bureaucracies.

The rich can buy security systems and other means of protecting their lives and property that the poor cannot possibly afford. The existence of police and firemen and the elimination of anarchy shows that our society provides for the protection of the property and lives of the poor at the expense, primarily, of the rich who, again, even under a flat tax would pay much more income tax than the poor ever would.

What is so unfair or immoral about that?

Finally, let me pass along George's axiom for your consideration:

"The value of any law is inversely related to its length and complexity."

The best example is to compare the Decalogue with the Internal Revenue Code. The first is easy to understand and can be followed. The second is impossible for one single person to understand, creates an enormous drag on the economy and its morality is subject to genuine question.

Tam Ho said...

I'd respond, but George's points speak for themselves. Well done.

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