Friday, March 06, 2009

Turning the Upside-Down Benefit Rightside-Up

President Obama's budget plan includes a dramatic change in the tax code that -- because it would change the way tax deductions are handled -- seems anything but dramatic. Even so, it is a partial version of an extremely good idea that should be extended still further. The idea is to make the tax benefit that one receives from deductions completely independent of the person's tax bracket. Asleep yet? Stay with me. This could be really big.

Two people each give $100 to their favorite charities. Anwar has taxable income of $425,000, putting him in the 35% tax bracket, while Zoe has taxable income of $25,000, putting her in the 15% tax bracket. This means that the $100 deduction for charitable contributions reduces Anwar's taxes by $35, allowing him to give his favored charity $100 at a personal cost of only $65. Zoe only saves $15 and pays $85 to give $100 to her favored charity. (Actually, the chances are pretty good that Zoe does not even itemize her deductions, in which case she saves nothing on taxes and pays the full freight for her charitable donation.)

This unappealing result has long been known in the tax world as the "upside-down benefit" problem, because it gives the largest tax savings to the highest-income taxpayers. It might seem to be impossible to fix this problem, however, because it appears to be the inevitable result of having a progressive rate structure. If you want to have higher tax rates on higher incomes (and I do), then you have to accept the upside-down benefit, right? Actually, it is well known that the answer is no.

The Obama budget takes an approach that is only a partial fix to the upside-down benefit problem, but it is still a huge step forward. The plan would limit the tax benefit for deductions to 28% of the amount deducted. Even though a single person with more than $164,550 in income (in 2008) pays tax at a 33% rate on income up to $357,700 and 35% on amounts above that, the Obama plan would limit the tax benefit to 28% of the deducted amount. The benefit is still upside-down for lower brackets (and for non-itemizers), but it is no longer upside-down for the highest brackets.

This approach might seem to hit higher earners coming and going. They pay a 33% or 35% rate when they earn income, yet they only get a 28% benefit when they offset income. True enough, but why should there be any connection between the rate that one pays on income and the benefit that one receives from deductions? To stay with charitable deductions as our example, why should my tax bracket have anything to do with how much it costs me to give to charity? The charitable deduction is a method by which the rest of society agrees to share in the cost of a decision that an individual taxpayer makes. You pay (1-x)% of something, and we pay x% of it. There is no coherent reason that Anwar's and Zoe's tax brackets should have anything to do with how much of their deductible activities are subsidized by other taxpayers, with taxpayers currently contributing $35 to Anwar's charity but $15 to Zoe's. It is simply an accident of history that we have used the tax code to provide this subsidy, and it is another accident of history that we have tied the amount of the subsidy to the structure of the tax brackets by making this a deduction. The Obama plan partially fixes those historical accidents.

There is no good reason why we should continue to provide these benefits through tax deductions. In fact, we have perfectly good examples of how we can provide tax advantages to certain activities without creating an upside-down benefit. For example, when I lived in Wisconsin in 1998-99, I discovered that the state completely de-couples tax deductions from tax brackets. At that time, the state's income tax brackets ran from 3-7%, but all deductions were multiplied by 5% to determine the tax savings from the favored activities. Instead of deducting dollars from taxable income, taxpayers would simply reduce their taxes by 5% of their total deductions. This turns a tax deduction (which interacts with tax brackets) into a tax credit (which does not). This could be done at the federal level by making deductions worth 28% in tax savings for all taxpayers, not just for the upper-middle and upper classes.

To take it a step further, there is no reason why there has to be a single rate to determine the tax credit, nor do the credit rates have to be tied to the tax brackets at all. We could set up credit brackets that decrease with the amount of deductions. For example, the credit rate could be 25% for the first $20,000 of deductions, 15% for the next $20,000, and 5% for anything more than that. This would be no more complicated than having a table for tax credits that would work much like the table for tax brackets.

Even stopping short of my preference for progressive credit rates, though, Congress should embrace Obama's idea and extend it to all income levels. This would not only increase the overall progressivity of the tax code, but it would do so by separating two things that never should have been linked in the first place. It would, in other words, be a good idea even without the increase in progressivity. This is hardly the sexiest policy idea on the table, but its effects could profoundly affect the way people think about taxes, charity, and all of the other things in our lives that we currently subsidize through deductions.

[As a side note, it is obviously true that any change in the tax code changes people's incentives and thus might change their behavior. Decreasing the tax benefits of charitable donations for higher income earners might cause them to reduce the size of their gifts; but will it? And if so, by how much? The best evidence indicates that the effect on charitable giving will be minimal to non-existent. See various sources linked here.]

-- Posted by Neil H. Buchanan

24 comments:

Paul Scott said...

But what you are suggesting - the decoupling of benefit from tax, does not seem to be the case for Obama's plan. At least not how you have described it.

"The plan would limit the tax benefit for deductions to 28% of the amount deducted."

This sentence to me reads that it will work as it always did except that if a tax deduction otherwise gained you more than 28%, it's benefit would be reduced to 28%.

I am all for the decoupling (though not in favor of the progression) you suggest, but this doesn't look like that is the case. Do I have it wrong?

GEORGE said...
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GEORGE said...
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GEORGE said...

If we want a more vibrant economy then we should allow people to keep more of the fruits of their labor. If we want a less vibrant economy then we should take away more and more of the the fruits of their labor through taxation. As Chief Justice Marshall noted: "The power to tax is the power to destroy." I see no reason why the same principles would not apply to charitable donations. This is axiomatic. Anyone who denies it knows nothing about basic human nature and should not be writing tax laws.

Michael C. Dorf said...

Here's an argument for the current regime (albeit one that may be overcome by other arguments of the sort Neil makes): Suppose Bob is a chef. He wants to donate an hour of his time making soup at a kitchen, so he goes to the soup kitchen for an hour. Bob receives no money for this service and so pays no tax. Suppose, instead, that Bob simply donates the wages he earns in an hour working at a restaurant, say $25, to the soup kitchen, which then uses the money to defray the cost of paying its soup chef. Under current law, Bob gets a deduction for the full $25, so the hour spent at his job followed by money donated to the soup kitchen is equivalent to the hour worked on a volunteer basis at the soup kitchen. That's true under the Obama plan too, because Bob doesn't earn enough to be at the upper income levels. But if we extend Neil's principle more broadly, as he wants us to do, or if we substitute a lawyer who can earn $500/hour for Bob, then the change introduces an asymmetry between volunteer work and money donated after performing the work that people are normally doing. There is, however, at least a prima facie argument that the tax consequences of donating an hour of time should be the same as the tax consequences of donating the money earned from an hour of paid work.

andy said...
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Paul Scott said...

At the moment the economy does not need "vibrancy." It needs to avoid becoming a depression. We can concern ourselves with "vibrancy" (or other equally meaningless descriptive terms) when the threat of a depression is no longer serious. It is my understanding in any event that it is now fairly well settled that tax policy is dwarfed by monetary policy in any event.

Paul Scott said...

Mike,
as I see it there are two questions being asked (though neither are really related to Obama's plan as I understand it).

1. Should tax benefits be independent from tax obligations?

2. If so, at what rate should tax benefits be set?

One way to answer #2 is that tax benefits should be fixed at the highest possible tax rate. That would maintain your 1:1 for the highest tax payers and actually make anyone not being taxed at the highest rate encouraged to give money rather than time.

A fixed tax benefit rate - if sufficiently high (as I think the Obama proposed 28% would be under our current tax structure) AND if a true fix, not merely a CAP (as Obama's plan appears to be), would be a net win for all but the most wealthy individuals. A "typical" high income family that itemizes can find their marginal rate after many deductions (Mortgage interest and business loss being the big ones) below 28%.

GEORGE said...

A vibrant economy is the opposite of a depression. Tax rates should be cut and as many taxes eliminated as possible. The threat of the opposite policy is one important cause contributing to the current collapse of the stock market.

George Lowrey said...

The long term consequence of limiting the current deduction is the growth of government at the expense of civil society and an erosion of the present generosity of the rich who give to the poor in favor of more and more socialist encroachment into areas that could be dealt with far better through private charitable giving. No lover of freedom in civil society should welcome that result.

leaf said...

The intellectual foundation of the income tax is that income = revenues - expenses. Some things have been lumped in with expenses (and therefore excluded from income) even when perhaps they shouldn't be (e.g. charitable contributions or home mortgage interest). Other things, however, like unreimbursed business expenses are genuine expenses, and really should be excluded from income for individuals. One significant weakness of Obama's plan is that it treats all deductions the same way I think it would be fairer to simply raise marginal income tax rates (and, if we want to eliminate the home mortgage interest deduction at the same time as we increase the overall progressivity of the tax tables, I think that would be quite a good plan also).

Brian Thomas said...

I think it depends on what you set as your baseline. If you frame the question as "how much benefit should each individual receive from a charitable deduction" President Obama's proposal seems like a step toward a fairer system. If instead you frame the question as whether a person should be taxed on income that he or she gives to charity Obama's proposal may appear less "fair." Michael Dorf's comment is basically making this point. At the extreme one might ask whether it is fair that the government charge a taxpayer if he or she decides to give his or her entire income to charity (I should note that under the current rules there is an annual limit on the deductibility of charitable contributions )

Moving away from charitable contributions -- think about the proposal applied to investment interest. Imagine an investor borrows at 5% to invest in a bond paying 5.5%. how fair does it seem to tax the investor at 39.6% on their income while limiting the deduction for the interest expense to 28%?

Ultimately it comes down to what we consider "income." In the charitable deduction case you might see the person as having income that he chose to give away and conclude that it would be fair for the government to allow no deduction for these transfers so allowing a greater deduction for some is unfair. Its harder to sustain this argument with respect to investment interest where it is being used to fund an investment yielding currently taxable income.

As an aside -- glad I found this blog Michael -- we went to law school together though you probably don't remember me. You are posting some great stuff on here -- keep up the excellent work.

George Lowrey said...

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 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.

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.

Yet those who promote higher and higher tax rates as income increases fall prey to the fallacy that wealth is a zero sum game (e.g. 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 wealth to those who have the best lobbyists and/or have made an industry out of yelling "discrimination" over 100 years after the Civil War was won.

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" 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.

Paul Scott said...

The one "service" you are failing to attribute anything to is the benefit of a society. The guy making $1,000,000 is getting a huge benefit from the government in that it protects him from the guy making $10,000 (or nothing) from taking part or all of his $1,000,000 by force.

This is, frankly, the most important function of government - the establishment and enforcement of the rule of law. And this benefit is far more advantageous to the wealthy than it is to the poor.

George Lowrey said...

I agree that the protection of the lives and property of Americans is a benefit to all citizens. I do not believe, as you do, that the per capita cost of providing that protection rises or falls in lock step with a citizen's income or wealth, and neither did the Founders. A home, no matter how humble, is sacred to its owner. It does not matter how much income or wealth the owner may have. Without that protection economic activity of all kinds is impaired to the detriment of all, and we no longer have anything worthy of the name "government."

Paul Scott said...

The cost doesn't increase much at all. But we (or at least I) am not referring to costs. The benefit received by the wealthy is of far greater value than the benefit received by the poor. Sure, you can toss around unquantifiable and romanticized terms such as "sacredness," but that does not change the fact that the wealth have a lot more to be gained from police protection than the poor.

Paul Scott said...

"...Without that protection economic activity of all kinds is impaired to the detriment of all."

This is clearly wrong. It is not to the detriment of all. Persons with the ability and willingness to use force to obtain wealth from others but with little to no skills valued by today's society would greatly benefit from the lack of a police state.

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