Entrepreneur: Start & Grow Your Business

How federal policymakers account for the concerns of state and local governments in the formulation of federal tax policy.


by Gravelle, Jane G.^Gravelle, Jennifer
National Tax Journal • Sept, 2007 •

INTRODUCTION

In Showdown at Gucci Gulch (Birnbaum and Murray, 1987), chronicling the passage of the Tax Reform Act of 1986, the issues of state and local tax preferences are front and center. The lobbying effort to remove from the Administration's proposal the repeal of state and local tax deductions was "one of the most persistent and pervasive lobbying campaigns of the tax reform story" (p. 113). That effort succeeded in preserving, in this watershed tax reform, the full deduction in the House, and all but the sales tax deduction in the Senate. The final proposal eliminated the sales tax deduction, but in 2004 the deduction was restored as an option to the income tax deduction.

In addition, tax exemption for state and local bonds "was one of the most intensely lobbied parts of the tax bill" (p. 137). The debate, however, was not about the general exemption, but the alarming growth in private activity bonds, which, despite previously enacted restrictions, had surged to two-thirds of the bond market. And even in this case, numerous carve-outs for many types of activities, as well as capped small issue bonds, remained. Although private activity bonds were included in the minimum tax, the general tax exempt preference was not. As the tax reform drama played out, we saw the federal government as protective of the states' tax benefits and slow to react even when these benefits were being abused--an indulgent approach. At the same time, as we show in the following discussion, in many cases federal tax revisions have taken place with consequences for the states, but with little attention to states' concerns.

In order to review both the ways in which federal tax policy affecting the states is made and how important those effects are, it is useful to sort the interaction between federal tax policy and state and local government activity into four broad categories. The first is the explicit preferences granted state and local governments in the federal tax law. The second is indirect effects on the costs of financing state and local activities from apparently unrelated tax provisions. The third is how tax changes interact with the states' desires to conform their tax systems to the federal system to simplify administration and compliance of their own tax systems. Finally, there are federal restrictions on state tax policy; recent provisions are tracked by the Congressional Budget Office under the Unfunded Mandates Reform Act of 1995. Following the discussion of these interactions, the concluding section discusses implications for the attitudes of federal policymakers towards state and local governments in formulating tax policy and the outlook for future changes.

EXPLICIT PREFERENCES IN TAX LAW

The deduction for state and local taxes and exemption of interest on tax exempt bonds have been in the income tax since its beginning and together constitute the main tax expenditures for state and local activity in the federal income tax. As shown in Table 1, out of the $80 billion of official tax expenditures associated with state and local governments, slightly over half (55 percent) are itemized deductions for state and local taxes, and virtually all of the remainder are with tax exempt bond interest. (Note that it is not strictly correct to add the preferences, particularly for itemized deductions, because of interactions.) The tax expenditure list allocates these expenditures by functional category and does not classify the property tax or the exemptions for interest on private activity bonds as supporting state and local government activity.

Two additional items, not in the official tax expenditure list, could be considered subsidies. One is the deduction from the federal income tax base for state and local corporate income taxes, estimated at approximately $20 billion. If corporate income tax deductions were considered a preference, and a case can be made for doing so, the cost would rise by $20 billion, to $100 billion, with tax deductions accounting for almost two-thirds of the total.

The second item that could be considered an income tax expenditure is the exemption from income tax of the profits of state and local business enterprise. These activities are also activities undertaken by the for-profit sector. The Congressional Budget Office (CBO) has estimated, for FY 2002, sales of $287 billion associated with these enterprises (CBO, 2005). The largest share of these sales is for hospitals (23 percent), higher education (21 percent), electric power (19 percent), and water (12 percent). Other activities include gas utilities, lotteries, air transport, solid waste management, parks and recreation, toll highways, liquor stores, special assessments, water transport, and parking. The benefit of excluding this income from the federal corporate tax is uncertain; CBO (2007) has estimated a revenue gain of $0.8 billion from taxing electric utilities; if this same amount relative to revenue occurred for other business enterprises, the total benefit would be $4.2 billion. This number may be too large given the capital intensity of electric power production, but may be understated because of direct funding for activities such as higher education. Given the lack of precedent in taxing these activities, the small size of the effect, and the conferring of similar benefits on the tax-exempt sector, this area seems one unlikely to be subject to legislation. Nevertheless, CBO (2007) included a provision for taxing state electric utilities, where no non-profit counterparts exist, in their budget options study.

Prior estate tax law allowed a credit against the federal estate tax, up to a limit, for state death taxes. If the estate tax repeal enacted in 2001 is allowed to expire, the state death tax credit, which was repealed by the end of 2004, would be restored. In 2001, this death tax credit was $6.3 billion. The credit was actually a free ride for the states, since each dollar of the death credit up to the limit in the tax law (and states generally constructed their taxes to conform to those limits) reduced the federal tax dollar for dollar. The current smaller estate tax now has a deduction, which is less valuable because it reduces the tax by taxes paid times the estate tax rate, and many states no longer have a death tax credit.

The repeal of the estate tax and the elimination of the state death tax credit are examples entirely different from the treatment of preferences in the 1986 reform act. In this case, virtually no attention was paid to the implications for the states. Indeed, the state death tax credit was phased out more rapidly than the estate tax itself. On the other hand, a dollar-for-dollar state death tax credit is an extraordinarily generous federal tax provision that involves a direct transfer of federal revenues to the states, limited only by the size of the federal estate tax.

For a variety of reasons, many believe that the complete repeal of the estate tax may not be feasible. In 2006, a number of proposals were made to substitute a much smaller permanent estate tax for the elimination of the estate tax. Interestingly, elimination of the deduction of state death taxes in computing the federal estate tax was also proposed to limit the revenue impact, a case where tax policy makers were pursuing their own interests without retaining any benefit for the states.

The remainder of this subsection discusses the two major tax preferences--deductibility of state and local taxes and tax exempt interest--in more detail.

Deductibility of State and Local Taxes

Tax subsidies for state and local itemized deductions amounted to $44 billion in FY 2007, or about six percent of state and local tax receipts, based on receipts reported in the Economic Report of the President, 2006. The subsidies vary substantially both by tax and by state (and locality). The largest relative subsidy is for individual income taxes, where the tax expenditure is 11 percent of state and local individual income tax collections. For property taxes, the subsidy is much less, four percent, because property taxes also apply to businesses and owners of rental property (where the tax would be deducted as a business expense in any case) as well as owner-occupied homes. The additional benefit due to the sales tax deduction is less than one percent of sales and gross receipt taxes. This small effect occurs because the current sales tax deduction is allowed as a substitute for income tax deductions and the benefit is measured as the additional deduction allowed because of this option, which tends to be small. (Because disaggregated state and local tax data are only available for 2004, and aggregate data, only for 2006, these estimates assume each revenue source grew at the same rate from 2004 to 2006, and by aggregate GDP growth from 2006 to 2007.)

A curious issue is why deductions for state and local income taxes by corporations are not considered a tax subsidy. The general rule for determining whether a tax deduction constitutes an income tax expenditure is whether it reduces the taxable base for purposes of the federal income tax, or more broadly, whether it results in a mismeasurement of income. The exceptions to this rule are provisions such as personal exemptions and standard deductions that constitute part of the progressive structure of the federal income tax and items whose inclusion is not practical (such as imputed net rent on owner-occupied housing). Deducting state and local corporate profit taxes reduces corporate income in the same way that state and local individual income tax deductions reduce individual income. The notion that state and local corporate taxes are part of the firm's cost structure is not persuasive. There seems no more reason that state and local taxes on the profits of corporations should be considered a necessary cost of earning income than is the case of unincorporated businesses or, for that matter, wage earners or investors. Indeed, many of the firms that have become unincorporated in recent years, due to the rapid growth of Subchapter S firms, now have their tax deduction treated as a preference when the same view is not applied to incorporated business. Mere legal form should not alter the view of a subsidy. And the revenue loss from state and local corporate tax deductions is considerable. According to Census data, state and local corporate taxes were $57.5 billion in 2006. At a 35 percent tax rate (and one presumes that firms with state and local corporate profit taxes were taxable for federal purposes), the value of the subsidy is $20 billion.

This view of the corporate state and local income tax deduction as a subsidy, although compelling on economic grounds, has not been included in proposals, such as those by the administration in 1986 or the recent President's Advisory Panel (2005) proposals.

Note that the this argument for counting tax deductions as tax expenditures cannot be as made for property taxes or sales taxes. In measuring income, sales taxes are appropriately deducted as a cost by firms, whether corporate or unincorporated, in determining profit; the subsidy occurs at the individual level when the sales tax is deducted a second time as an itemized deduction by consumers. Property tax deductions by firms and landlords are similarly an appropriate deduction because they are a cost that arises before income is determined, and these deductions are not considered subsidies. The property tax deduction for owner-occupied housing is a subsidy, not because of the property tax per se, but because imputed rent is not included in income. Were imputed gross rent to be included in income, the costs would be appropriately deductible. Whether property tax deductions on owner-occupied homes are treated as a subsidy to state and local activities or a subsidy to home ownership is, however, a legitimate question.

Many economists and tax reformers are critical of deductions for state and local taxes. State taxes provide untaxed benefits, and an income tax that excludes these payments from the base fails to tax comprehensive income. There is an alternative view, however: that they are mandatory payments and should be deducted on those grounds and that costs and benefits do not match closely. The deduction also distorts the level of state and local services and the mix of taxes and fees. Thus, there are two very different types of issues surrounding the deductibility of state and local taxes: those of fairness in the distribution, and those of incentives.

These tax deductions reduce both revenue and the progressivity of the income tax, but, assuming the rate structure could be adjusted to offset these effects as was the case in 1986, to many the important equity issue is the disparate treatment of taxpayers in different states. Although itemized deductions are taken by 35 percent of taxpayers overall, the share itemizing varies substantially across the states (Maguire, 2006). In 2004, the shares itemizing varied from almost 50 percent in Maryland to 17 percent in West Virginia. Only Maryland had a share above 45 percent, but eight states and the District of Columbia had shares of 40 percent to 45 percent. Of the nine states without a broad income tax, only three (Nevada, New Hampshire, and Washington) were among the states with a share above the average, and all of those fell into the 35 percent to 40 percent itemizing. Reuben (2005), studying the issue using data from 2002 before the sales tax option was added, concludes that itemization occurs at higher rates with states with high income and wealth and progressive income taxes. These characteristics persist with the sales tax deduction. According to data in Maguire (2006), only a third of states without an income tax had an itemization rate above the average, while over one-half of those with an income tax did. Thus, even with the optional sales tax deduction in place, having an income tax made itemization more likely.

The addition of the sales tax deduction, which was extended but remains temporary, primarily benefited taxpayers in the states without an income tax (Alaska, Florida, Nevada, New Hampshire, South Dakota, Tennessee, Texas, Washington, and Wyoming). These states only accounted for half of the sales tax deductions claimed, but many are small states, and in the case of other states with an income tax, the net benefit (in excess of the income tax option) is likely small.

One policy concern is that the deduction increases the size of the state and local sector by reducing the state and local tax burden for itemizers. At the same time, some applaud the preferences for income taxes and property taxes, which tend to be more progressive than sales taxes, and even with the sales tax option, the deduction of income taxes dominates the deduction for sales taxes ($202 billion in income taxes compared to $19 billion in sales taxes in 2004). Arguments are also made that federal deductibility mutes distortions in interstate location decisions as a result of differential taxes. While there are concerns that the deduction influences the magnitude of the state and local sector and the mix of taxes, most studies find mixed effects. The two most recent studies, Stotsky (1990) and Courant and Gramlich (1990), like most of the previous ones (which they reviewed), tend to find modest effects. Reuben (2005) points out that no state lowered its sales tax rates after the 1986 revision eliminating deductibility and 15 states had a higher sales tax rate in 1989 than in 1985. No state without an income tax introduced one to substitute for sales tax revenues. However, an argument has been made that the lowering of marginal tax rates was a more serious reduction in the value of income tax deductions than of state and local tax deductions because income taxes were more important for the high-income taxpayers with the largest rate reductions (Stark, 2004). Chirinko and Wilson (2005) review the evidence on interstate substitution, which suggests limited effects of state and local tax differentials on location decisions. These results may suggest to federal tax policy makers that the deduction has no significant distorting effects on states' mix or level of taxes, and should not be an important issue in the consideration of these policies. Concern may instead be directed at equity issues and, if so, the likelihood of retaining the sales tax deduction appears high.

Equity issues may also factor in a number of legislative proposals. Arguments have been made that the elimination of state and local tax deductibility is a good offset for eliminating the Alternative Minimum Tax (AMT), where the major preference is the state and local tax deduction, and the reach of the AMT will increase dramatically without legislative change that is costly in revenue loss. Such proposals were explored by Reuben (2005) and in recent simulations by Burman, Gale, Leiserson, and Rohaly (2007). The President's Advisory Panel's (2005) tax reform proposals proposed to eliminate the deduction along with the AMT. A different approach to addressing inequities across the states was taken by Senator Ron Wyden and Congressman Rahm Emmanuel, who proposed replacing the itemized deduction with a credit for state and local taxes available to all taxpayers in their comprehensive tax reform proposal, introduced in the Senate as S. 1111.

Tax Exempt Bonds

State and local issuance of debt has been going on virtually throughout the existence of the republic. (The history discussed in this section is based on Zimmerman (1991).) Throughout the early to mid 1800s, state public debt began increasing. States turned more and more to aiding private developers. With the industrial revolution, railroad development was actively sought by state and local governments, to the point of serious fiscal problems by 1837. Indeed, the sharp increases in debt issued to aid private developers along with the depression sparked a multitude of restrictions, generally restrictions against lending to private individuals and corporations, and debt limits on general obligation bonds that continue to this day. However, with the limitations came numerous methods for avoidance such as special districts, special funds, and public authorities.

These concerns all seemed to stem from fears over state fiscal collapse, not from the overlap of state and federal government tax authorities. In fact, prior to the civil war there was no federal income tax, making the question of tax-exempt bonds a moot point. Although many advocates of exemption status may note, and use, a first instance of the concept of intergovernmental tax immunity with Justice Marshall's 1819 decision and statement "the power to tax involves the power to destroy," this famous claim actually referred to the states ability to tax an instrument of the federal government.

While there were repeated attempts after ratification of the 16th amendment in 1913 to remove tax-exempt bonds in their entirety, it was not until after World War II that there was ever a discussion of limiting the particular use of tax exempt bonds. Nineteen hundred and sixty-eight marked the first attempt to restrict state uses of tax exempt bonds. The 1968 Congress began by limiting industrial development bonds (IDBs) and arbitrage bonds in response to a growth of bonds issued for private purposes. In fact, the limits on IDBs began the first qualified private activity bonds. Congress set the future trend not by defining public purpose but rather by defining what was not. The 1968 restrictions outlined the still-current two-part use and security test of a private activity bond, although at the time the use and security tests required 25 percent or more of the use or securities to be private. This test is a test for "bad" bonds, that is, if the share is greater than 25 percent the bond passes the test for a taxable bond. This and later restrictions were met with an onslaught from the states to exempt specific activities. For example, transition rules were added, in part to acquiesce to congressional pressures on behalf of their states, which included "exceptions to tax-exempt-bond-limits for a new stadium for the Miami Dolphins football team, a convention center in Miami Beach, a midtown Miami redevelopment project, and two new heating and cooling systems for the Florida Region" (Birnbaum and Murray, 1987, p. 147).

The states' pleas that were met as private activities qualifying for tax exempt status continued to include residential property; sports facilities; facilities for convention or trade show; airports; docks, wharves, parking facilities, and mass commuting facilities; and other waste, pollution, and utility facilities were allowed to qualify for tax exempt status.

The Tax Reform Act of 1986 made substantial changes to the exempted facilities and narrowed the use and security tests to ten percent (i.e., ten percent or more of the use or the securities were private). Gold (1990) points out the dramatic fall in state and local bond financing in response to changes in TRA 1986. Municipal financing fell from $204.3 billion in 1985 and $151.0 billion in 1986 to $105.5 billion in 1987 and $117.0 billion in 1989.

Despite the federal government's historical relaxation and subsequent constriction of tax exempt municipal bonds, states and local governments have a wide variety of activities that can be financed with tax exempt bonds, particularly government obligation bonds that have few limits. For example, according to the Government Accountability Office (2006), 15 percent of golf courses were owned by state and local governments. Of these, four percent were associated with resort or real estate facilities. In addition, 39 hotels associated with convention centers, airports or golf courses were identified by finance experts as being financed with tax--exempt bonds. The report also mentions over 300 government-owned convention centers and cites instances of state and local government support of gaming facilities.

Table 2 shows the distribution of bond issuance across broad categories of activities that can be considered private in nature. Of states' bond issues, at least half are for these activities. (Total bond issuances exclude general purpose since there is no reliable way to allocate those bonds to private or public purpose. Bonds issued for general purpose account for roughly a quarter of total bond issuances.) This table also includes tax-exempt, taxable, and qualified private activity bond issues, which account, respectively, for 85.1 percent, 7.4 percent, and 7.5 percent of total (including general purpose) issuances over the six-year period.

According to Table 1, above, explicitly private activity bonds account for 23 percent of the tax expenditure for bonds. This number is larger because of the existing stock. As with the property tax deduction, the tax expenditure list classifies these bonds in functional categories outside state and local activities. Nevertheless, the states and localities play an important role in allocating these resources. While some of the uses in Table 2 could be argued to be traditional functions of state and local governments, convention centers, stadiums and arenas, and other private-entertainment-related activities are questionable.

ECONOMIC EFFECTS OF OTHER FEDERAL TAX POLICIES

State and local governments are also affected indirectly by other tax policies of the federal government. The most obvious are the marginal tax rates themselves. As important, in terms of incentives, as proposals to disallow state and local tax deductions was the fall in the top marginal tax rate from 70 percent in 1980 to 28 percent in 1986. Although part of this rate reduction was reversed in 1993, with rates then reduced again in 2001, there has been little attention to this effect. Of course, states were hardly in a position to protest the lower rates because these rates benefited their taxpayers. Moreover, there may have been little in incentive effects for state and local taxes. These changes affect the benefits of interest exclusion for state and local bonds because the value of the exclusion is higher for higher marginal tax rates.

There are several other important tax policy decisions affecting tax burdens on capital income that affect tax exempt borrowing, including the tax rates on corporate source income (the corporate tax rate, capital gains tax rates, and tax rates on dividends), business subsidies, and tax preferred savings provisions. These effects depend on which assets are closer substitutes for municipal bonds.

Consider the corporate tax rate. If interest-bearing assets are much closer substitutes for state and local bonds than equities, the corporate income tax, which might normally be expected to burden competing business investment, could make state and local bond finance more costly by driving up the interest rate. Interest is deductible at the corporate level, leading corporations to favor debt finance, and their increased d