INTRODUCTION
I am pleased to be part of this National Tax Journal forum
celebrating the 100th anniversary of the National Tax Association and
grateful for the invitation to discuss the effects of taxes on economic
behavior, a subject that has been central in my research since my paper
some forty years ago on the effects of tax rules on corporate dividends
(Feldstein, 1967). Over the years, my tax research has focused primarily
on the ways that taxes affect household behavior and on the welfare
implications of those changes, and that will be the focus of this paper.
The effect of taxes on economic behavior is important for three
distinct reasons. First, the behavioral response of taxpayers affects
the revenue consequences of changes in tax rates and tax rules. Second,
the effects on economic efficiency or deadweight loss depend on
taxpayers' compensated behavioral responses, i.e., on the
behavioral effects excluding pure income effects. And, third, behavior
is important for understanding the short-run macroeconomic consequences
of tax changes on aggregate demand and employment.
I have long been an advocate of reforming the revenue estimation
process to reflect explicitly the impact of taxes on behavior and the
implications of that behavior for tax revenue (e.g., Feldstein, 1997). I
am pleased, therefore, that in recent years the revenue estimators of
the Treasury and the Congress have been taking behavior into account
more fully in their revenue estimates, going beyond the traditional
so-called "static estimates" that assume that taxes have no
effect on taxpayer behavior. But the very limited nature of the behavior
that is taken into account means that official analyses of tax rate
increases still overstate the resulting revenue gain while official
analyses of tax rate reductions overstate the resulting revenue losses.
Therefore these revenue estimates bias the political decision process to
favor tax rate increases over tax cuts. Although much can be done to
improve these calculations, I am encouraged by the willingness of the
revenue estimators to improve their earlier methods and by their
participation in the annual meeting of the National Bureau of Economic
Research (NBER) group that focuses on these revenue estimation issues. I
will return later in this paper to the issue of improving revenue
estimates.
Unfortunately, there is no reason to be pleased about the analysis
in policy discussions of the efficiency effects of tax changes. Explicit
estimates of the welfare consequences of proposed tax changes are
completely absent in the Congressional and White House discussions of
tax policy. Although policymakers understand that higher taxes hurt the
economy by distorting behavior--reducing work effort, saving, and
risk-taking--there is no attempt to quantify these adverse effects or
translate them into reductions in economic efficiency. My own experience
is that the concept of the deadweight loss of a tax increase, i.e., the
amount that individuals would have to be paid to make them as well off
as they would be without the proposed tax change, is much easier to
teach in a classroom than to convey in a Congressional hearing. And yet
any sensible policy analysis of alternative tax structures should
involve comparing the revenue, deadweight loss, and distributional
consequences of the alternative tax options. Later in this paper I will
illustrate this with an example from the current debate about raising
payroll tax revenue to fund future Social Security benefits. I will also
comment on two common conceptual errors that economists make in
assessing the deadweight losses of tax changes.
The short-run macroeconomic consequences of tax changes depend on
how the Federal Reserve (Fed) changes monetary policy in response to the
tax change. If a tax change produces a fiscal stimulus that exceeds what
the Fed believes to be prudent, it will neutralize it by raising
interest rates. Alternatively, a fiscal stimulus may simply substitute
for an easier monetary policy that the Fed would otherwise implement. As
a general rule, it would seem best to assume that a change in fiscal
stimulus would be offset by the induced change in monetary policy. One
exception would occur when interest rates are so low that the Fed cannot
lower rates any further. In such a liquidity trap, a fiscal stimulus
would raise aggregate demand. A second exception would occur when
financial market conditions or the availability of bank capital make it
difficult for the Fed to stimulate economic activity. In this case, the
Fed would welcome a fiscal stimulus and would not seek to offset it.
Because of these exceptions to the general rule, the possible fiscal
stimulus effect of a tax change must be considered on a case-by-case
basis to assess the likely reaction of the Federal Reserve to the
proposed change in tax rates or tax rules. Note that this discussion of
the cyclical effects of tax policies is very different from the
longer-term supply side effects of tax changes on the gross domestic
product (GDP) which could not be offset by monetary policy.
REVENUE ESTIMATION
I turn now to the issue of revenue estimation, focusing on the
effect of changes in tax rates on labor income. It would, of course, be
desirable to have a fully specified dynamic microeconomic model that
could trace out the revenue consequences through time of any proposed
tax change, including the full general equilibrium effects. A variety of
such models have been studied by academic researchers (e.g., Golosov and
Tsyvinski, 2005) and by the staffs of the Joint Tax Committee and the
Treasury Department (e.g., Carroll, Diamond, Johnson, and Mackie, 2006).
In my judgement, they are helpful in shaping our understanding of the
complex economic interactions caused by tax changes, but are not a
suitable base for policy analysis now and will not be at any time in the
foreseeable future. Therefore I will concentrate my comments on the more
practical estimates that focus on the direct first-order behavioral
responses to tax changes.
When studying a proposed tax change it would also be desirable to
know what current or future change in taxes or spending will be made to
maintain an unchanged level of the national debt. This would be easy if
the purpose of the tax increase is to finance some particular program,
e.g., a revenue increase to fund increased Social Security benefits or
to allow the elimination of another tax like the alternative minimum
tax. In general, however, major tax changes are not earmarked in this
way. In such cases, I think we should follow the same analytic approach
that was done by Richard Musgrave and others in their studies of tax
incidence, i.e., to assume a concurrent budget balance achieved by a
lump sum change in taxes or spending (Musgrave, 1959).
In what follows I will focus first on the revenue and efficiency
effects of changes in the general tax rates on labor income. I will then
comment briefly on the efficiency effects of taxing the return to
saving. I will not discuss the substantial amount of work that has been
done on the impact of capital gains taxes, on the realization of capital
gains, and the resulting changes in revenue (e.g., Feldstein and
Yitzhaki, 1978). There has also been substantial work on the effect of
dividend tax rules on corporate payout rates. The results of this
research on capital gains and dividends has been adopted by the official
revenue estimators because it does not violate their self-imposed rule
that their estimates assume no change in GDP, a subject to which I
return below. There has, however, been no work on quantifying the
efficiency effects of these taxes. There is also relatively little work
on the impact of taxes on the composition of individuals'
portfolios (Feldstein, 1976).
TAXES ON LABOR INCOME
Labor economists have produced a large body of research estimating
the effects of wages on labor force participation and total working
hours. Public finance economists have contributed to this literature by
focusing on net-of-tax wages and showing that individuals respond to the
tax component of the net-of-tax wage. But what matters for revenue
estimation is not the change in working hours but the change in labor
supply more broadly defined--including effort, occupation, human capital
accumulation, etc.--and in the mix between taxable cash wages and
untaxed fringe benefits and nice working conditions. Although it is not
possible to estimate each of these two components separately, the public
use files of individual tax returns that the Treasury makes available to
researchers does permit estimating their combined effect, i.e., how
changes in tax rates affect tax revenue through the combination of
changes in labor supply and in the form of compensation.
Changes in tax rates also affect taxpayers' behavior as
consumers, altering the quantities of tax-favored consumption (including
owner-occupied housing, charitable contributions, and local property
taxes). The overall revenue effect of a change in tax rates depends,
therefore, on the extent to which the tax base is reduced, including the
effects on labor supply broadly defined, on the form of compensation,
and on the magnitudes of tax deductions.
Several studies have now used the Treasury's public use files
of individual tax returns to estimate the elasticity of taxable income
with respect to the net-of-tax rate (i.e., one minus the marginal tax
rate). In an early paper, I used panel data that followed the same
individuals before and after the major tax rate reductions of the 1987
Tax Reform Act in which the top tax rate fell from 50 percent to 28
percent (Feldstein, 1995). The difference in difference estimates based
on comparing incomes in 1985 and in 1988 implied a compensated
elasticity of about one. Subsequent work by others (e.g., Auten and
Carroll, 1998 and Gruber and Saez, 2002) using different data sets and
different estimating methods, found a range of estimates from about 0.4
to 1.0 for middle- and upper-income taxpayers.
There are of course disputes about the interpretation of this
behavioral response. Gordon and Slemrod (2000) have suggested that some
of this reaction may reflect a shift between corporate and personal
income. In the opposite direction, it should be noted that this
relatively short-run response does not allow for the effect of the tax
rate reduction on decisions about the choice of occupation and the
accumulation of human capital.
A more fundamental issue in the estimation of behavioral response
is that it assumes that the taxpaying unit is the decision-making unit
even when there are two working adults in the unit. This is of practical
importance when the husband and wife face different marginal tax rates
as they do in the United States when one, but not both of them, is
earning below the ceiling on Social Security taxable income. Because of
the ceiling on the payroll tax base, some couples will have different
marginal tax rates for the husband and wife. In a study of data on
Swedish households Gelber (2007) has shown that there are important
differences between husbands and wives in their income and substitution
elasticities and in cross-elasticities.
My judgement, based on the existing studies, is that an elasticity
of 0.5 for middle- and upper-income taxpayers (who pay the overwhelming
bulk of income taxes) is a reasonable estimate and probably a
conservative one. It is substantially higher than the response implicit
in the revenue estimates of the Treasury and the Joint Tax Committee. In
presenting illustrative calculations of tax proposals, such as the ones
discussed below, I have generally been cautious and assumed elasticities
of 0.4 and 0.5.
The official estimates used by the Treasury and the Joint Tax
Committee are generally depressed by the quite remarkable self-imposed
restriction that the changes of behavior implied by changes in tax rates
do not result in any change in GDP. In their analysis, a change in tax
rates can change the form of compensation, can change the realization of
capital gains, and can shift portfolios between taxable and tax exempt
securities, but it cannot alter the supply of labor or the level of real
compensation. To the extent that any change is admitted that alters GDP,
some offsetting assumption is made to keep GDP unchanged.
This "constant GDP" assumption eliminates the important
effect of changes in labor supply broadly defined, i.e., changes in
labor force participation rates, in hours worked, in the choice of jobs,
in the degree of effort, etc. Although the revenue estimators wish to
allow for changes in the form of compensation, the restriction that
there be no change in GDP makes it impossible to use the tax return data
to estimate the change in the form of compensation since the observed
changes in taxable incomes reflect both the change in total labor supply
(i.e., in potential labor income) and in the extent to which the
resulting change in potential income is taken in the form of taxable
cash. Since the changes in the form of compensation cannot be observed
or estimated separately, the revenue estimators are forced to make a
judgement based on their intuition, something very difficult for a civil
servant whose working conditions and degree of discretion in the form of
compensation are quite different from those in many private sector jobs.
The rationale for the "constant GDP" assumption is that
the projected level of GDP is established by the administration or the
Congressional Budget Office and, therefore, must be taken as a fixed
parameter by the revenue estimators. In my judgement, this makes no
sense at all. The GDP forecast could be taken as a baseline number on
which the effects of proposed tax changes can be superimposed. I wonder
how many members of Congress realize that the "revenue
estimates" given by the Joint Tax Committee staff have made this
arbitrary assumption of constant GDP.
Fortunately, the restricted nature of the estimated behavioral
effects is beginning to change and the official estimates of some
proposed tax changes do attempt to use the accumulating evidence on
behavioral responses. It would be good to have more transparent
descriptions of these changes so that the economics profession could
comment on the assumptions and the resulting estimates.
TWO EXAMPLES
Before turning to other aspects of taxpayer behavior, I will
illustrate the importance of behavioral responses by looking at two
examples. First consider an across the board tax increase in which every
tax rate is raised by one percent: the ten percent marginal tax rate
goes to 10.1 percent, the 25 percent to 25.25 percent, etc. My NBER
colleague, Dan Feenberg, used the NBER's TAXSIM model to estimate
how taxpayer behavior alters the estimated revenue effect of this tax
change. The analysis, based on 100,000 random tax returns for 2001
adjusted to income levels of 2004, calculates that with no behavioral
response (i.e., the so-called "static" estimate) tax revenue
would rise by seven and one-half billion dollars.
Using a very conservative compensated elasticity of tax revenue
with respect to the net of tax rate of 0.4 and an income elasticity of
0.15 (implying an uncompensated behavioral response elasticity of less
than 0.4) implied that the additional personal income tax revenue would
be only five billion dollars or two-thirds of the "static"
revenue estimate. The reduced taxable income would also lower payroll
tax revenue by some $400 million, bringing the total additional revenue
to just $4.6 billion or 57 percent of the "static" revenue
estimate (Feldstein, 2004).
The effect of taxpayer behavior on revenue can be even more
dramatic when the proposed tax change is not simply proportional. A few
years ago, I analyzed the proposal to raise the maximum taxable income
for the Social Security payroll tax by 25 percent, from $87,900 to
$110,000 (Feldstein, 2004). For someone with initial income at the top
of the new range, i.e., of $110,000, the tax base would rise by $22,100
if there were no behavioral response. In that case, the tax revenue
would rise by 12.4 percent (the payroll tax rate) of this increased tax
base or $2,740. But with a behavioral elasticity of 0.5 with respect to
the net of tax rate--a reasonable assumption for these high-income
individuals--the taxpayer would reduce taxable earnings (by working less
and taking more income as fringe benefits) to $102,000. This lowers the
extra payroll tax and, more importantly, also lowers the personal income
tax revenue and the Medicare payroll tax revenue. Calculations show that
the reductions in the personal tax revenue and in the Medicare payroll
revenue would actually exceed the extra Social Security payroll tax
revenue. The total taxes paid by this high-income individual would
actually decline if the payroll tax base were increased in this way.
Extending this type of calculation to the entire population of
taxpayers with incomes of more than $87,900, Feenberg and I found that
the rise in the payroll tax revenue would be $19 billion a year with no
behavioral response, but only $16 billion with a taxable income
elasticity of 0.5. The lower tax base shrinks the Medicare and Personal
Income tax revenue by a total of $11 billion, bringing the total revenue
gain down to just five billion dollars instead of the $19 billion
"static" estimate, implying that some two-thirds of the extra
Social Security funds would come as the result of a back door transfer
from personal income taxes and Medicare taxes.
Although these examples show the importance of taking behavioral
responses into account when calculating the revenue effects of major
changes in tax rates, there are strong advocates of continuing to use
the current "static" revenue estimates. They make two
arguments. First, since the behavioral elasticity is only a rough
estimate, it is inappropriate for use in revenue estimation. Second,
there are a very large number of detailed and complex tax proposals for
which revenue estimates must be produced. There would never be enough
time to do the research on the needed behavioral elasticities for these
many proposals. These arguments carry particular force because of the
legislative requirement that any projected increase in the budget
deficit (through a tax cut or spending increase) must be financed by a
decrease in the projected deficit (by a tax increase or spending cut).
In this context, revenue "scoring" must be "precise"
and must apply to all proposals.
Although there is much to recommend the marginal self-financing
rule that Congress has imposed on itself, it should not be an excuse for
using grossly incorrect revenue estimates. At a minimum, for proposals
with large revenue implications (e.g., static revenue effects of more
than ten billion dollars a year), the members of Congress should see the
revenue estimates based on plausible behavioral assumptions as well as
the traditional static analysis. The budget committees should then have
the option to replace the traditional static revenue estimate with the
more accurate (although imprecise) behavioral estimate.
CALCULATING DEAD WEIGHT LOSSES
Efficiency calculations are central to the analysis that public
finance economists bring to tax policy. But introducing these ideas into
the actual Congressional evaluation of tax policies involves three
separate challenges. First, the politically responsible officials and
their staffs must come to understand the basic idea of deadweight loss.
Second, the nature of the distortion that gives rise to the deadweight
loss must be correctly identified. And, third, the relevant parameters
must be estimated.
In my experience, the concept of deadweight loss is difficult to
explain because it does not correspond to any observable number. Perhaps
that is why the staff of the Joint Tax Committee, even in its
theoretical infinite horizon dynamic simulations, summarizes the
economic effects of alternative tax systems by the change in GDP rather
than by an estimated deadweight loss or gain. But a tax change could
create deadweight losses even though it caused GDP to rise (e.g.,
because of income effects or even because of incentives that lead to
more labor input than individuals would otherwise choose to supply). So
economists have still not gotten across the notion that taxes distort
choices and that the revenue that the government collects understates
how much worse off an individual is because of a tax.
Perhaps an example would help non-economists to grasp the idea.
Consider a law that prevented people from buying apples. That law would
not transfer money to the government, but individuals would consider
themselves worse off than in the absence of such a law. The amount that
the government would have to give people to make them feel as well off
as they would have been without the law is its deadweight loss, i.e.,
the loss to the individuals in excess of the revenue to the government.
Now consider a less draconian law that merely reduces the number of
apples that anyone can buy. That implies a smaller deadweight loss. But
what if, instead of a law limiting the purchase of apples, the
government levies a tax on apples that reduces the number of apples that
the individual chooses to buy? The individual would then be worse off
relative to no law for two reasons: he consumes fewer apples and he must
pay a higher price per apple (which goes to the government as tax
revenue). The extent to which the individual is worse off because of the
tax can be divided into two parts--the revenue transferred to the
government and the deadweight loss due to the reduced consumption of
apples. Similarly, a tax that induces someone to work less not only
transfers revenue to the government, but also causes a distortion in the
individual's behavior (reduces the extent to which the individual
supplies labor and obtains money with which to buy goods and services)
and, therefore, a deadweight loss.
More generally, the income tax causes a much broader set of
distortions, reducing all aspects of labor supply, causing a shift in
the form of compensation, and inducing individuals to substitute tax
favored consumption (i.e., deductible expenditures) for other types of
consumption. Fortunately, despite the multiple sources of deadweight
loss, the total deadweight loss can be easily calculated by focusing on
the elasticity of taxable income with respect to the net-of-tax rate.
This simplification is appropriate because each of the three sources of
distortion is based on the same marginal tax rate: the individual buys
"leisure" at one-minus the marginal tax rate, he buys fringe
benefits at this rate, and he buys tax deductible consumption at this
rate. The marginal deadweight loss is, thus, the same for any behavior
that reduces taxable income. More technically, the three forms of
behavior that reduce taxable income constitute a Hicksian composite good
and, therefore, can be treated as if they are one good for the purpose
of welfare analysis (Feldstein, 1999).
Using an estimated compensated elasticity of 0.4 and the usual
formula based on the square of the marginal tax rate for approximating
the incremental deadweight loss implies that the one percent across the
board increase in all tax rates that yielded incremental revenue of $4.6
billion would result in a deadweight loss of three and one-half billion
dollars. The deadweight loss is, thus, 76 percent of the incremental
revenue. This means that the total cost of an additional billion dollars
of government spending financed by an across the board increase in tax
rates is $1.76 billion. Similarly, cutting government spending by a
billion dollars and passing the funds back in the form of an across the
board proportional tax cut would raise taxpayers real incomes--including
the reduced deadweight losses--by $1.76 billion. Wouldn't the
Congressional process of setting tax rates and authorizing government
spending be improved if this were better understood?
The implications of this analysis are even more striking when
applied to a possible non-proportional change in the payroll tax. Recall
that the proposal to raise the maximum income subject to the Social
Security payroll tax from $87,900 to $110,000 would result in net
revenue of five billion dollars when the behavioral response is taken
into account. The deadweight loss calculation in this case implies an
increased deadweight loss of nine billion dollars. The total cost of the
five billion dollars of additional revenue is, thus, $14 billion, nearly
three times as much as the revenue itself. It is useful to contrast this
with the implications of the static revenue analysis that implies
additional revenue of $19 billion and that ignores the deadweight loss.
An alternative way to raise payroll tax revenue by five billion
dollars would be to raise the payroll tax rate instead of increasing the
ceiling on the taxable payroll. With a payroll tax base of approximately
five trillion dollars, the required increase in the tax rate is only 0.1
percent. The overall marginal tax rate--including personal income tax,
state income tax and payroll taxes--would rise from about 45 percent to
45.1 percent, depending on the individual's particular situation.
The resulting deadweight loss would be only about $1.6 billion, less
than one-fifth of the deadweight loss that would result from increasing
the ceiling on taxable payroll. I believe the political process should
consider these two ways of raising the five billion dollars, noting the
difference in the distribution of the increased tax burden and the
difference in the deadweight losses.
TAXES ON INVESTMENT INCOME
I turn briefly now to the taxation of investment income. Tax rules
affect many types of behavior that influence investment income: the
volume of saving, the allocation of that saving among alternative
investments, the realization of capital gains, etc. I will focus on just
one of these: the effect of taxes on household saving.
I want to make a single important point about the deadweight loss
associated with taxing the return to saving. For a discussion of how
taxes on the return to saving interacts with taxes on labor income, see
Feldstein (2006).
A common fallacy in discussing taxes on the return to saving is to
note that the elasticity of saving with respect to the net-of-tax
interest rate is very low and to conclude from that observation that
taxing the return to saving has very little adverse efficiency effect
(Feldstein, 1978). Even if one accepts the premise that the elasticity
of saving with respect to the net-of-tax interest rate is very low, the
conclusion about the deadweight loss does not follow.
Why? Because the deadweight loss in this case depends not on the
change in the level of saving but on the distortion in the timing of
consumption. It is consumption that matters for this because it is
consumption that enters the individual's utility function. Even if
saving is not changed at all in response to a higher rate of tax on
investment income, the level of future consumption can fall
substantially. It is that fall in future consumption that is the source
of the deadweight loss.
An analogy may help to clarify this point. Consider a simple excise
tax on the consumption of apples. If the pretax price of apples remains
constant, an individual with a unit elasticity of demand for apples will
consume fewer apples, but spend the same total amount on the purchase of
apples. It is clear in this case that the deadweight loss depends on the
change in the number of apples consumed and not on the unchanged
spending on apples. By analogy, saving is the "expenditure"
today to purchase future consumption. The welfare loss depends on the
change in that future consumption and not on the spending today to
purchase that future consumption.
FUTURE RESEARCH
I will conclude by pointing to some fruitful directions for future
research in the study of taxpayer behavior.
First, it would be good to reduce the uncertainty about the effect
of the net-of-tax rate on taxable labor income. New research should
distinguish the response by different income levels, marital status, and
age/sex groups. More panel data from the Treasury would be enormously
helpful in this research. The separate payroll and income taxes should
be used to distinguish the own and cross elasticities of husbands and
wives.
Second, we need better estimates of the income effect of changes in
tax rates. These are needed to calculate the revenue effect of tax
changes.
Third, we need to develop a better analysis of the welfare effects
of different aspects of capital taxation, particularly the effect of
changes in dividends and in capital gains, and in outright tax evasion.
And finally we need to develop better ways of incorporating this
research into the analysis done by the staffs of the Treasury and the
Joint Tax Committee, and into the thinking of political decisionmakers.
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Martin Feldstein
National Bureau of Economic Research, Cambridge, MA 02138
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