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fh'ilurO Uiu^cu, DISTRIBUTION OF TAX PAYMENTS BY INCOME GROUPS: A CASE STUDY FOR 1948 by R. A. MUSGRAVE, J. J. CARROLL, L. D. COOK, AND L. FRANE Reprinted from NATIONAL TAX JOURNAL March, 1951, Volume IV, Number 1 National Tax Journal V o l u m e IV, N o . 1 March 1951 DISTRIBUTION OF TAX PAYMENTS BY INCOME GROUPS: A CASE STUDY FOR 1948 * R. A. MUSGRAVE, J . J . CARROLL, L . D. COOK, A N D L . F R A N E absence of information. There is some empirical evidence to work with, and some conclusions may be reached deductively. Moreover, the economist can be useful in making explicit the assumptions underlying a particular conclusion. His informed judgment, to say the least, should prove a better basis of policy than random guesses or political slogans. Thus there is no need to apologize for the tentative nature of our results. In section I the conceptual difficulties and limitations underlying a study of I. T H E M E A N I N G O F I N C I D E N C E T HE SEARCH for quantitative estimates of tax incidence leads the explorer through a wasteland of muddled concepts, inadequate theory, and lack of data. Nevertheless, the question who pays the taxes must be answered if taxes are to be raised in accordance with the public's ideas of distributional justice and the maintenance of sound economic conditions. Although available evidence is discouragingly scarce, the economist cannot plead complete * This study is a product of a seminar in public finance at the University of Michigan, conducted during the fall term of 1949 under the direction of Professors R. S. Ford and R. A. Musgrave. Members of the seminar who contributed to the study were J. J. Carroll, L. D. Cook, L. Frane, H . Frisinger, H . S. Gordman, C. T. Hardwick, J. Hurwitz, H. Jaroche, and J. W. Reher. The revision, expansion, and assembling of the work was undertaken by the present authors, who alone should be blamed for its shortcomings. More than on any other source, this study draws upon the findings of the Survey of Consumer Finances, prepared by the Survey Research Center of the University of Michigan in conjunction with the Board of Governors of the Federal Reserve System. Our thanks are due to members of the staff of the Survey Research Center, especially George Katona and Kent Winter, for their help in supplying and interpreting much of the underlying data. Also, we are indebted to the Executive Board of the Horace H. Rackham School of Graduate Studies of the University of Michigan for a grant from the Faculty Research Fund. EDITOR'S NOTE: Because of the importance of this subject and the convenience to users of having the whole study published in a single issue, we have departed from customary restrictions on length of articles. A limited number of reprints are available from Secretary of National Tax Association, P. O. Box 1799, Sacramento 8, California, at a price of 50 cents each {45 cents each for 20 or more). 1 2 NATIONAL TAX tax incidence are given brief consideration. In section II sources of data, assumptions, and our procedures with regard to particular taxes are reviewed. In section III we examine the results for the "standard case," based upon what appears to us the most likely set of assumptions. In section IV the significance of alternative assumptions is explored, and our results are compared with those of earlier studies. Some of the underlying data are explained further in the appendix. This study, like other attempts at quantitative estimation of tax incidence, inevitably involves the use of grossly simplifying assumptipns. Nevertheless, it is important to consider first how the measurement of incidence should be formulated if all empirical difficulties could be overcome. Unless we are clear as to what it is we wish to measure, we are in no position to appraise the merits or shortcomings of our statistical results. The impatient reader may want to skip the somewhat theoretical discussion presented in the initial section; but if he does he should be warned that "incidence" is an ambiguous and far from self-explanatory term. 1. Taxation and Surrender of Resources Let us start out from an economy in which there is no public budget. Certain public services are now to be introduced. For this purpose, resources previously employed to meet private demand must be transferred to public use. The government may resort to two methods of doing this: It may conscript or, as done usually, it may go into the market and purchase. If the resources or products are to be purchased, various means of finance are available. Finance by fees or special assessments is feasible for only a small part of public JOURNAL [VOL. I V services. The bulk of public services must be tax- or loan-financed. Consider the case of tax finance. The government must raise a tax yield equal to the purchase price of the required resources or products. 1 To simplify, let us suppose that the economy is limited to two factors of production, a and b, and to two taxpayers, X and Y. Also, let us assume that X is primarily a consumer of a and Y primarily a consumer of b. Suppose now that the government is in need of a. It is evident that this resource must be surrendered largely by X, but it does not follow that X rather than Y must bear the major burden. Let us suppose that the government wishes to impose the major burden upon Y. The revenue may then be obtained from an income tax on Y, whose demand for b will decline as a result. X will find that the price of a has risen because of additional public demand for it, while that of b has fallen because of the shrinkage of Y's demand. Accordingly, he will substitute b for a in his consumption pattern. Thus he will recoup from Y in the form of b most of what he has surrendered to the government in the form of a. As is apparent from this illustration, the party surrendering the resources required for public use need not be the party bearing the major part of the cost of the public service. It follows that the formulation of tax policy involves an inevitable decision as to whose income should be cut. Considerations of income distribution are the heart of tax policy. 2. Nature of Tax Burden Suppose now that it has been decided ^•We are here concerned with exhaustive or real expenditures only. Transfer payments, throughout this discussion, should be thought of as negative taxes. No. 1] TAX PAYMENTS BY INCOME GROUPS how much various members of the community should contribute to the given yield total. There remains the question how this desired distribution can be implemented or how the cost of public services will in fact be distributed under any given revenue structure. This, broadly speaking, is the problem of incidence. But before considering how the distribution of this cost or burden can be determined, let us examine more closely how the burden concept is to be defined. It is evident that the term " burden of taxation " applies to only one side of the revenue-expenditure process. Whether a particular revenue-expenditure combination results in an ultimate net gain or loss to the community depends upon the balance between the gains incident to the public use of resources and the losses incident to their withdrawal from private use. The concept of burden, as here used, refers only to the losses incident to the withdrawal of resources. Therefore, it does not imply the existence of a social burden, which results only where additions to the revenue-expenditure total result in a net loss on balance. Let us begin with the concept of money burden. Given the level of income before tax, every tax dollar collected by the government will reduce someone's income after tax by a similar amount. This is evident as regards personal taxes because they are simply deducted from income before tax to obtain income after tax. The case is a little more difficult for taxes paid by consumers in the form of higher prices. To simplify matters, we shall translate such taxes into personal taxes and define a person's income net of tax to equal his money income received, minus his 3 3 personal taxes I>aid, and minus indirect taxes imputed to him. We may then say that the money burden of prevailing taxes upon any particular taxpayer equals the difference between his actual money income net of tax and the money income which he would receive in the absence of taxes. And if we assume money income before tax to be the same with and without taxes, it follows that the aggregate money burden carried by taxpayers as a group is equal to the tax yield.2 But if income before tax differs in the two cases, the total money burden will exceed or fall short of the tax yield. Money burden thus defined is the basic concept of this study, but it has serious shortcomings. It may, for various reasons, be a poor measure of the welfare loss involved, and the measurement of welfare loss, after all, is the raison d'etre for the development of any burden concept. Discrepancies between money burden " and " true burden " may arise for several reasons. Two situations may involve the same total money burden; yet the true burden may differ, depending on the distribution of the money burden among members of the community. Or, as between two situations involving similar distributions of an equal money burden, the total true burden may differ depending upon what taxes (e.g. personal taxes or excises) are used. For similar reasons, the distribution of the true burden among members of the community may differ from the distribution of the money burden. Some individuals may, in fact, be subject to no money 2 The reader will note that it is absurd to assume income to be unchanged by tax repeal, if, at the same time, public expenditures are held constant. See below. 4 NATIONAL TAX JOURNAL burden, yet carry a share of the true burden. Consider, for instance, taxpayer X in the above illustration. Suppose that the price increase in commodity a is matched by a proportionate decrease in the price of b. In this case X will suffer no money burden; but if he prefers a over b> his economic position will be worsened nevertheless. For purposes of this study, we shall disregard these rather elusive issues and consider only changes in welfare as reflected in corresponding changes in money income. This omits interesting issues but reduces the problem to measurable form. The burden of taxation applicable to any particular taxpayer, accordingly, is defined as the difference between his actual money income net of tax and what this income would be in the absence of the tax. This difference, we repeat, is defined to include differences in money income before tax, differences in personal taxes paid, and differences in excise tax payments imputable to the particular taxpayer. 3. Impact and Adjustment Tax Changes to In determining the distribution of this money burden, two extreme approximations suggest themselves. One is that each tax dollar rests with whoever carries the statutory liability for its payment; the other is that, no matter where the initial payment is made, the tax liability will eventually be shared alike by all members of the community. Both propositions are untenable. The statutory taxpayer will attempt to recover part of his payments by adjusting the terms on which he trades in the market. Depending upon the type of tax and the market setting, he will be more or less successful in [VOL. I V doing so. The truth, it appears, lies somewhere between the extremes of the impact and diffusion theories. We must try, as best we can, to determine where the burden of particular taxes lies. As will be shown presently, it is impossible to determine the burden distribution for any particular tax system without reference to the burden distribution under an alternative system or without including the effects of the expenditure side of the public budget. But let us avoid this difficulty for the time being and consider the consequences of substituting a new tax structure for a prevailing structure of equal yield. This change will disturb the prevailing equilibrium (or alter the prevailing disequilibrium) and call forth an extensive chain of adjustments throughout the economy. The chain of adjustments will extend much beyond the points of impact, where old taxes are removed and new taxes are imposed. The manufacturer who pays a new tax will raise his price to the wholesaler and the wholesaler to the retailer who, in turn, will raise the price charged to the consumer; consumers will shift to products the prices of which have risen less or have fallen; wages and profits will rise in industries facing increased demand and decline in industries facing reduced demand. These changes will bring about further adjustments in the budgets of wage and profit recipients and so forth. This succession of induced adjustments, radiating out and branching off in all directions, will continue until the economy has reached a new position of equilibrium. 3 3 The distinction between new and old taxes is clear-cut in a setting in which tax changes provide No. 1] TAX PAYMENTS BY INCOME GROUPS 3 In the course of this process the in- income before tax is changed in the come positions of individuals will be af- process. But even if income before tax fected in various ways. Changes in is assumed constant, the sum of losses Mr. Jones' income due to direct changes will typically exceed T, since taxpayers in his tax payments are only one among will incur losses while avoiding tax paymany factors. This is frequently over- ment. Thus the producer, who is sadlooked, as the shifting process, which is dled with an excise, will raise his price but a different term for the process of to curtail the burden; but even though adjustment just described, is thought of the tax, as reflected in the price rise, is in terms of a spreading network of in- imputed to the consumer, the producer come losses, coming to an end wherever is still likely to suffer a decline in any particular part of the tax burden profits. At the same time, the very stays put. Thus, a seller who is con- shift in demand which leads to a decline fronted with an additional excise yield- of profits and wages in the taxed indusing a total amount T raises his price but try, also leads to a corresponding insells less.4 Accordingly, he finds his crease in profits and wages somewhere profits reduced (suffers a loss) by an else. The tax adjustment produces a 5 amount L s . The consumer, in turn, series of gains as well as losses. Denotfinds the price increased. He reduces ing all such gains with G, we have his purchase but suffers a remaining T = L, + L0 + LW — G. loss Lc equal to the increment in price If income before tax is unchanged, the times the new quantity bought. The excess of income losses over tax yield workers in the taxed industry may find will be offset by gains in another part their wage receipts cut and suffer a loss of the system. Lw, and so forth. If we interpret the conventional concept correctly, the 4. Incidence and Effects The difference in the distribution of total money burden T is thought of as the sum of these losses, while its distri- the money burden under the new and bution is taken to be split according to the old revenue structures may now be the amounts L8, Lc, and Lw. But this is determined by comparing the initial equilibrium with that which prevails not correct. The sum of L8 -f- Lc + Lw will equal after adjustment to the new tax system T only under quite exceptional condi- is completed. Unless total income betions. Obviously, there will be no such fore tax has changed, total income net equality in the general case, where the of tax will be the same in both cases. The distribution of income, however, the only disequilibrating factor. In a dynamic econwill differ. This change in distribution, omy, which is continuously in a process of change, as determined by comparing the two the distinction between old and new taxes is blurred; even old taxes remain part of the economic map and hence a factor in the continuous process of adjustment. 4 To facilitate presentation, the argument in this and the following paragraph is in terms of a particular tax, and hence absolute incidence, rather than in terms of a comparison between two taxes. However, the same line of reasoning applies with regard to differential incidence. 5 Other gains might result as well. Thus X might benefit from a decline in the price of b, brought about by the decline in Y's demand due to an increase in Y's income tax. In order to allow for this type of gain or loss, the above definition of change in income net of tax must be amended to allow for all changes in the prices of consumer goods bought, not only for price changes of commodities which have been directly subject to an excise change. 5 NATIONAL TAX JOURNAL 6 equilibria, will reflect all the previously mentioned gains and losses brought about in the course of the adjustment process. A comparison of the two equilibria does not permit us to single out any particular chain or link in the adjustment process and to determine its result separate from that of the remaining adjustments. Yet, this is precisely what most authors, employing the timehonored distinction between " incidence " and " effects " attempt to do.6 This separation, usually appears to aim at a distinction between changes in income brought about " directly" by tax payments (i.e., changes in personal and excise taxes imputed to the particular individual) and changes in income brought about by other phases of the adjustment process (e.g., changes in income before tax or changes in the prices of products bought, which do not directly reflect indirect tax payments). As far as we can see, such a separation serves no analytical purpose. For the taxpayer as well as the government, what counts is how income positions are changed on balance by the entire tax adjustment. A decline in a taxpayer's wages, brought about by reduced demand for his services is no less painful than a decline in his wages brought about by an increase in his personal tax. Both changes are part of the same equilibrating process and can be determined only simultaneously. If there is any meaningful way in which the end result of the tax adjustment may be divided, it appears to be 6 Compare, for instance, E. R. A. Seligman, The Shifting and Incidence of Taxation, p. 14, and Otto y. Mering, The Shifting and Incidence of Taxation, p. 3. For a healthy skepticism regarding the difference between incidence and effects, see, however, Cannan, Edgeworth, and Black, as noted in D. Black, The Incidence of Income Taxes, p. 123. [VOL. I V between changes in the level of income before tax and changes in the distribution of income net of tax. Both are important outcomes of the same tax adjustment, but they may be usefully distinguished and be measured separately. This distinction, perhaps, contains the kernel of usefulness in the dichotomy between " incidence" and " effects." Resulting changes in the level of income may be referred to as "effects," while resulting changes in distribution may be referred to as ff incidence " of taxation. But if such a distinction is made, it must not be forgotten that both parts are the result of the same adjustment process and that both encompass all links and chains in this process; the distinction merely applies to different features of the end result. 7 5. Absolute vs. Differential Incidence The reader may wonder why, after having defined the concept of burden in section 2 in terms of absolute money burden, we conducted the discussion in section 3 in terms of changes in the distribution of the money burden which results when one tax system is substituted for another. Would it not have been simpler to compare income net of tax under the given tax structure with income net of tax in the absence of taxes and thus determine the absolute burden distribution of the given tax structure? Unfortunately, this cannot be done, for the simple reason that taxes are the counterpart of public expenditures. 8 7 In addition to effects on distribution of income and level of employment, one might distinguish f u r ther effects, such as effects on capital formation or the rate of growth, which are also separately measurable. 8 Note that we start with a situation in which government expenditures are tax financed. Suppose now that we start with a situation in which in order No. 1] TAX PAYMENTS BY INCOME GROUPS In a situation where, to begin with, we have public expenditures as well as taxes, we cannot <c think the existing taxes away"—to borrow Wicksell's terms—without either (a) thinking public expenditures away as well, or (b) substituting some alternative means of finance.9 (a) If we choose the first approach, we aim at determining the combined incidence of taxation and public expendituresh That is, we compare the situation under the prevailing budget with a hypothetical situation in which there are neither taxes nor public expenditures. If the problem is formulated in this way, two aspects of expenditure incidence need to be distinguished. First, we must account for changes in the income position of individuals which are brought about by the expenditure side of the budget; second, we must account for the benefits derived frohi public services which are enjoyed free of charge. to maintain full employment expenditures are credit financed. We have two lines of reasoning. One is to argue that, in the absence of public expenditures, there would be unemployment of resources; hence the public employment of resources involves no opportunity cost in alternative private use. While there is some validity to this line of thinking, it is rather unsatisfactory: in a rationally conducted economic system, the allocation of resources for any use, public or private, should always be on the assumption of full employment; policies aimed at maintaining full employment should (and can) be handled as such and so as to be neutral with regard to allocation. The other line of reasoning is to argue that in the absence of the given expenditure program, the maintenance of full employment would have been secured by alternative expenditures, say transfer payments, proportional to income. In this case the burden of public services might be obtained by comparing the actual situation with one of proportional transfer payments. • See Knut Wicksell, Finanztbeoretische XJnterzuchungen und das Steuerwesen Scbwedens (Jena, 1896), p. 6 if. 3 The first problem offers no conceptual difficulty. Changes in money income due to public expenditures may be in the form of direct income subsidies through transfer expenditures; or they may take the form of changes in factor income due to changes in the over-all pattern of demand. By comparing the distribution of income in the pre- and post-budget economies, such gains and losses are determined together with those stemming from the tax side of the budget. If money income before tax is the same in both situations, the gains and losses thus determined for the combined tax-expenditure process will show a burden (decline in income net of tax) equal to the amount of tax yield or expenditure. 10 The component changes in individual income positions will show how the total money burden, incident to the withdrawal of resources from private use, is distributed. But note that the result thus obtained is one of budget incidence, not of tax incidence. We cannot obtain two separate and additive results relating to the tax and expenditure sides respectively. The second aspect of the expenditure problem is more difficult to handle. Unless one is willing to follow Adam Smith's rule of thumb that " benefits received are proportional to income received under the protection of the state," there is no simple way in which the benefits from general public services may be imputed to particular members of the community. And without this, we do not have a complete picture of the distributional effects of the public budget. But even though this comThis refers to goods and service expenditures. In the case of transfer payments there will be an offset of gains and losses and a zero burden. 7 8 NATIONAL TAX plete picture may be impossible to obtain, we may at least derive an absolute measure of the distribution of money burden by combining the income changes which result from both the tax and expenditure side of the budget. (b) While it is evident that a complete analysis of incidence must include both sides of the budget, it nonetheless remains of interest to consider the tax side as such. Except for certain minor cases of clear-cut benefit taxation, the two sides of the budget are the result of separate legislation and involve quite distinct issues. In expenditure determination, the objective is to render certain services and to do so efficiently; the distributive effects of public demand for resources are secondary. In tax determination, the distribution of the money burden is of primary importance. But, if we wish to study the incidence of taxation as such, it must be recognized that this incidence cannot be thought of in absolute terms; an alternative means of finance must be substituted when the prevailing taxes are " thought away," and this means that the result will necessarily be in differential terms. The concept of differential incidence is not necessarily one of differential tax incidence. Suppose, for instance, that bank credit is substituted for tax finance. If full employment would have prevailed in the case of tax finance, inflation is bound to result. The comparison, then, will be between the burden distributions for inflation and for tax finance. This, to be sure, is not a particularly useful comparison. A more useful approach to differential incidence is to follow the procedure applied in section 3 above and to compare the incidence of the prevailing tax JOURNAL [VOL. I V structure with that of an alternative tax structure. In this case, the comparison is between the prevailing equilibrium and that which would result if the new tax structure were substituted. While this permits a comparison of incidence under any two tax structures, a more general measure permitting comparison between more than two tax structures might be desirable. For this purpose, each of the given tax structures might be compared with some easily definable reference case, say a tax structure in which tax payments are proportional to income before tax. Whatever is done, it appears that a meaningful concept of incidence must either be formulated in differential terms (in which case public expenditures and their incidence may be held constant) or it must be a combined measure of tax and expenditure incidence. 6. Empirical Difficulties We now proceed to a quite different level of argument and consider the empirical difficulties which prevent statistical implementation of a conceptually proper estimate of tax incidence. The limitations are appalling. Economists can rarely experiment. They cannot switch tax systems or repeal the budget; and even if they could, they would be unable to " hold other things constant " while equilibrating adjustments took place. Thus our reasoning is largely deductive. Occasionally a major deductive conclusion may be buttressed by empirical observation of the adjustments that result from a minor change in the tax structure. Beyond this, empirical studies of tax shifting are nonexistent. In view of these limitations, let us now consider how the issues No. 1] TAX PAYMENTS BY INCOME GROUPS raised in the preceding pages are handled in this study. (a) We do not attempt to trace incidence by individual taxpayers but limit ourselves to a study of incidence by spending unit income groups. (b) We do not adopt a general impact or diffusion theory, but attempt —in light of accepted theories of market behavior—to make reasonable assumptions regarding the point in the income-expenditure stream from which the tax is drawn. By applying these assumptions to our data, we attempt to estimate the final money burden for each tax by spending unit income brackets. The deductive reasoning underlying certain important assumptions, especially those relating to the shifting of the corporation tax, is by no means conclusive; in such cases alternative assumptions are formulated and the results compared. (c) In considering the equilibrating adjustment to any given tax change, it is not feasible to trace out the entire pattern of gains and losses. We must be content to record only items of loss associated directly with the sale (or purchase) of the taxed commodity or service. Items of loss incurred in adjustment to the tax, such as reduced profits due to reduced output, are not accounted for, and gains and losses occurring elsewhere in the system are wholly neglected. For example, the rule of thumb is used that an excise tax should be imputed to consumers in the same proportion in which they consume the taxed commodity. Changes in business profits or in returns to factors before tax are disregarded, as are consumer gains and losses that result from changes in the relative prices of taxed and nontaxed commodities. 3 9 From the preceding discussion, it is evident that such simplifications can be defended only because they are essential in order to reduce the problem to empirically manageable terms. They cannot be defended by arguing that the resulting concept of money burden is endowed with analytical significance which it does not possess. There is a question of how seriously these oversimplifications affect the quantitative results. Undoubtedly the resulting distortions would be serious if we were to measure the incidence of the tax system with respect to each individual taxpayer; the factors here omitted may well be decisive for changes in the income position of any one person. Since we are concerned with the distribution of the money burden by income brackets only, the distortion will be less serious. We may presume that a transfer of profits from one seller to another or an inter-industry change in wages will be distributed more or less in line with the existing income distribution; and the same may be expected to hold for consumer gains and losses from a change in the prices of commodities not taxed. Restated in these terms, the diffusion principle has some merit. (d) This study does not take into account the expenditure side of the budget but deals only with the distribution of the tax burden; and, as shown in the preceding discussion, this concept can be formulated meaningfully only in terms of differential incidence. Yet, the results of this study, as presented in subsections 1-4 of section III, trace the absolute tax yield under the given revenue structure to its resting place by income brackets. This provides us with the type of data presented in earlier incidence studies; but it ap- 10 NATIONAL TAX pears to record incidence in absolute terms, which, according to our preceding discussion, is not meaningful. Rather, the incidence of the given tax structure must be measured in terms of its difference from an alternative structure. For a reference case we may consider a hypothetical structure which provides for a proportional distribution of the money burden. In subsection 5 of section III an attempt is made to provide such a measure of differential incidence. Admittedly this is little more than a gesture of respect to our conceptual discussion. The distribution of tax payments for the proportional system case is arrived at by proportionately allocating the given yield total on the basis of the same distribution of income before tax existing under the impact of the given 1948 tax structure. That is to say, we disregard the fact that the basic distribution of income before tax would have differed had a proportional tax system been applied. Again, this is a procedure which can be defended only on grounds of empirical limitations. (e) The study, finally, makes no allowance for possible changes in the level of money (and real) income which may result from the tax adjustment. In the terminology of incidence and effects suggested above, the implicit assumption is that the entire result of the tax adjustment is measurable in terms of incidence, effects being zero. If we consider our results in terms of differential incidence, this involves the additional assumption that the level of income before tax (as well as its distribution) would be the same under both tax structures. ( / ) To this list of shortcomings others must be added which arise from JOURNAL [VOL. I V faulty assumptions or deficient data. These will be considered in detail in the following section. At this point, the reader may despair of the usefulness of undertaking a quantitative study of this kind. Certainly, a healthy skepticism is in order. It should not, however, be carried too far. We must remember that distributional considerations are of major importance in the determination of tax policy. Legislators must choose between alternative taxes, and it is better that they be provided with part of the answers than with none. And, where empirical evidence cannot be obtained, it is important at least that assumptions be made explicit and be acceptable on deductive grounds. II. SOURCES, M E T H O D S , A N D ASSUMPTIONS In this section we present a brief summary of the methods by which our distribution of tax payments has been derived. No detailed calculations are presented, but we lay our cards on the table and give the reader an opportunity to familiarize himself with the underlying data, procedures, and assumptions. Only thus will he be in a position properly to appraise the reliability of our results. 1. Basic Data: Distribution of Income Calendar year 1948 was chosen for this study as the latest period for which data were available. The first step was to obtain a distribution of income by income brackets to which tax payments might be allocated. The distribution of income by spending units, appearing in the " 1949 Survey of Consumer Finances," was most appropriate for our purpose. Prepared by the Survey Research Center of the University of TAX PAYMENTS BY INCOME GROUPS No. 1] Michigan for the Board of Governors of the Federal Reserve System, this distribution accounts for 50.4 million spending units and a total money income of $176 billion. This income is distributed among seven income brackets, ranging from "under $1,000 " to 3 11 tive tax rates are higher than they would be had we used the larger income base. We decided to use the S.R.C. income total because the entire study is based upon the S.R.C. distribution of income, the distribution of the difference between the two income TABLE 1 BASIC DISTRIBUTIONS FOB TAX ALLOCATION (In per cent) Spending Unit Income Brackets (Thousands of dollars) Item (1) Money income Consumer expenditures: (2) Total (3) Durables House expenditures: (4) Owners (5) Renters (6) Liquid asset holdings Consumer expenditures: (7) Tobacco (8) Auto transport (9) Other transport (10) Recreation (11) Food (12) Alcoholic beverages (13) Housing (14) All other (15) Dividends (16) Wage and salary income . . . . (17) Wages covered by p.r. tax .. (18) Rental income Under 1 1-2 2-3 3-4 4-5 5-7.5 Total 2.0 7.6 16.1 19.5 14.5 17.3 23.0 100.0 3.9 2.2 9.3 5.6 18.1 18.2 20.7 20.0 14.4 15.8 16.1 17.0 17.5 212 100.0 100.0 2.7 3.2 4.0 8.8 13.6 7.0 16.9 24.0 14.0 21.2 22.2 14.0 13.9 13.7 11.0 15.0 14.5 18.0 21.5 8.7 32.0 100.0 100.0 100.0 3.9 3.4 1.0 1.8 4.1 9 4.1 4.2 1.1 2.5 1.1 4.7 11.4 6.0 10.1 5.0 11.4 8.9 9.6 8.7 2.3 9.2 8.7 8.0 21.1 12.1 20.5 13.4 20.5 17.2 18.4 17.6 3.4 19.5 23.7 9.9 22.9 20.1 23.3 20.0 21.8 22.5 22.1 19.2 4.3 23.6 30.6 11.5 14.3 16.5 13.3 15.1 14.2 12.7 14.7 14.2 3.7 17.5 20.2 8.5 14.1 18.8 16.5 20.5 14.6 16.4 14.5 16.8 7.3 16.0 12.8 12.2 12.2 23.1 15.3 24.1 13.3 21.4 16.6 19.4 77.9 11.7 2.9 45.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 Note: Details do not necessarily add to totals because of rounding. Source: Items (1) to (6) were obtained from data of Survey Research Center, University of Michigan. Items (7) to (14) were estimated on basis of B.L.S. data. Items (15) to (18) were estimated on basis of various other sources. For details see appendix. "over $7,500." The basic distribution is shown in line (1) of Table 1 . . | £ t '11* r 11 The income total ot $176 billion tails short of the Department of Commerce estimate of personal income for 1948 bye 1 . , , , / 1 .11' -xr 1 i i r nearly $36 billion. More than half of this amount may be accounted for by conceptual differences, the remainder being due to statistical discrepancies.1 « 1 1 . 1 . Since the level ofe income here usedj is lower, the tax to income ratios or effec- inc ° r m e d a t a ^ not include an estimated $13.0 billion of income in kind and imputed income or a n estimated $7.0 billion of income to institutional and transient population. This leaves an unexplained of * T o have used t h e sonal income figure of the Department of Commerce, and t o have d i s t r i b u t e d it b y income groups accord _ ing to the S.R.C. income distribution, would have meant making the unwarranted assumption that the $36 billion difference was distributed in the same manner as the S.R.C. income. In view of the nature , . . , , of the major items that account for the difference, there is no reason to assume this. 12 NATIONAL TAX totals being unknown. Moreover, the underlying income total is relatively unimportant for our purpose, which is primarily to estimate the distribution of tax payments. Whereas the general level of " effective tax rates" (i.e., taxes contributed as a percentage of income received) shown in section III depends upon the income total used, the distribution of the tax bill does not. However, in comparing our results with those of other studies, an adjustment to the Department of Commerce level of income will be made. The S.R.C. distribution provides no breakdown of income above $7,500. Nor is it possible to obtain consumption data for income brackets above this level. Hence no attempt is made to determine the allocation of tax payments among income groups above $7,500. While a further allocation of tax payments among the higher income groups would be of considerable interest, there are no adequate data on which to base such estimates. Also, it is evident that tax policy in a high-taxation economy, such as lies ahead, will be concerned increasingly with the middle and lower level income range here studied. 2. Basic Data: Distribution of Expenditures In order to allocate the yield from excise taxes and such fraction of other taxes as is assumed to be shifted forward to consumers, it was necessary to obtain a distribution of consumer expenditures by income brackets. This information was obtained from two sources. A distribution of total consumer expenditures was derived as a residual from S.R.C. data providing distribu- JOURNAL [VOL. I V tions of income, income tax liability, and savings. The resulting distribution for total consumer expenditures is shown in line (2) of Table 1. Most excise taxes and the forward-shifted parts of some other taxes, however, do not apply to consumer expenditures in general but to specific expenditure items. Expenditures on specific items, in many instances, are distributed in a quite different way than are total expenditures. In order to allocate excises as much as possible in accordance with the distribution of specific types of consumption expenditures, a more detailed pattern of consumer expenditures was needed. The S.R.C. data provide such distributions for consumer durables as well as for housing expenditures of house owners and renters. They are shown in lines (3), (4), and (5) o£ Table 1. Expenditure distributions for a number of further items were derived from a series of consumer budget studies conducted by the U. S. Department of Labor from 1946 through 1948. These data, which cover a number of selected cities only, had to be reworked to present a national picture. Also, they had to be assembled into a breakdown of items most useful for the purpose of tax allocation. The results of this rather involved and unsatisfactory procedure are shown in lines (7) to (14) of Table 1. 3. Basic Data: Revenue Sources and Yield Total Total tax revenue collected in 1948 by all levels of government amounted to $57.3 billion. A breakdown of this total between levels of government and among revenue sources is shown in Table 2. No. 1] TAX PAYMENTS BY INCOME GROUPS TABLE 2 4. Tax Tax TAX COLLECTIONS IN 1948 (In millions of dollars) Tax Collections Federal (1) Personal income tax (2) Corporation income tax (3) Excises and customs, total . . (4) Alcohol (5) Tobacco (6) Automotive (7) Amusement (8) Transportation (9) Communication (10) Luxury (11) Electrical (12) Food (13) Other excises (14) Customs (15) Estate and gift (16) Payroll (17) Total 18,045 12,920 7,912 2,177 1,312 1,279 640 610 512 463 265 115 129 410 900 4,015 43,794 State and Local (18) Personal income tax (19) Corporation income tax 499 699 (20) Excises, total 6,093 (21) Automotive (22) General sales (23) Alcohol (24) Tobacco (25) Insurance (26) Amusement (27) Public utility (28) Other excises (29) Property taxes (30) Inheritance taxes 1,989 1,899 545 365 202 184 267 642 6,064 197 (31) Total 13,552 (32) Grand total, all levels . . . . 57,344 Sources: Lines (1), (2), (14), (19), (29), and (30) from Survey of Current Business, July, 1949, Table 8. Lines (3) through (13) from Bureau of Internal Revenue, Release 7, February 23, 1949. Line (16), Survey of Current Business, July, 1949, Tables 34 and 35, and Social Security Agency, Annual Report (adjusted to calendar-year basis). Line (18), State Finances, 1949, U. S. Bureau of the Census, August, 1949. Lines (20) through (28), U. S. Bureau of the Census, State Tax Collections in 1949 (G-SF49, No. 4, August, 1949); fiscal year figures converted to calendar-year basis by averaging fiscal 1948 and 1949. No serious distortion is involved in this averaging, since the change during the period was less than 7 per cent. Allocation: 3 13 Personal Income In prior studies one of the most serious difficulties arose in the allocation of personal income tax payments by family or spending unit income brackets. A distribution of income tax payments by brackets of taxable income may be readily obtained from the Treasury's Statistics of Income, but there is no simple way of moving from a distribution of this type to a distribution by family or spending units. Income splitting and other tax adjustments result in quite different patterns for the two, distributions. Fortunately the need for constructing a bridge between the two has been obviated by the 5.R.C. data which provide us with a percentage distribution of Federal income tax liabilities of spending units by income brackets. 2 A distribution of state and local income tax payments was not available from the S.R.C. data. As state income tax exemptions are considerably higher and rates less progressive, the Federal distribution could not be used in allocating the state taxes. While there are distinct differences among the income taxes of various states, it was not feasible to estimate separate distributions for each of the thirty-five state income tax laws. As an approximation, the distribution of the Wisconsin income tax yield by spending unit income brackets was estimated and this distribution was used to allocate the entire yield of state income taxes. The resting place of the entire personal income tax is assumed to be with the individual upon whom the statutory liability is imposed. Following 2 This distribution is shown in Table 7. 14 NATIONAL TAX JOURNAL [VOL. I V generally accepted practice, we apply earned by the marginal firm. Since the an impact theory to the incidence of price is set by the marginal firm which this tax. Yet, it is quite conceivable pays no tax, the tax cannot be reflected that income tax payments in some in- in a higher price. Under monopolistic stances may result in a rise in income conditions the firm which sets the price before tax. Reward for professional does pay a tax. But since a tax on services, the supply of which may be profits does not alter the price at which adjusted in small increments and which profits are maximized, the seller will do are highly specialized, may be a case in best to remain at his prevailing (optipoint. Collective bargaining demands mum) position and to absorb any tax may be directed at take-home rather imposed on profits. than gross pay. Business income deThis line of reasoning has been acclared under the personal income tax cepted consistently by the profession may be subject to the same shifting and has been objected to with equal considerations as apply to the corpora- consistency by the " practical m a n " tion tax. Nevertheless, we can be who stoutly maintains that he does add fairly certain that such adjustments are his corporation tax to his price. Some the exception rather than the rule. reconciliation is provided by certain Moreover, it seems impossible to estab- obvious exceptions to the academic rule. lish any working hypothesis as to how First, the tax base may not be pure much might be passed on at various in- profit in the economist's sense but may come ranges. In the absence of an include wages of management, return alternative formula, it seemed best to for risk taking, interest on equity capretain the conventional assumption that ital, and other nonrent incomes. To the tax stays where it is imposed. the extent that this is the case, the tax is a cost item and will be reflected in 5. Tax Allocation: Corporation Income price. Second, imperfections in the Tax tax law inevitably lead to differential In determining the allocation of the burdens among various enterprises and corporation income tax yield a number industries. And where this is the case of different problems arise. First, it (i.e. the tax is not truly general), price must be decided whether the tax is adjustments must follow. Third, corshifted; if so, by how much and in poration management may not charge what direction. Next it must be de- the highest price which the market will cided how to distribute the part of the bear. This restraint may reflect an eftax which is assumed to fall on profits. fort to maintain consumer good will or Finally the shifted parts of the tax must a notion that profits should not exceed a tc fair " level (the modern version of be allocated. Shifting Assum ptions.—Economists the old concept of just price); or with few exceptions have held that the prices may be held down merely to apcorporation tax cannot be shifted. pease anti-trust authorities. Under pure competition there are no The extent to which such adjustprofits and hence no tax is paid. Or, if ments are possible will depend on profits arise from efficiency differentials market conditions, but the widely held between firms, no such profits are view that there will always be more No. 1] TAX PAYMENTS BY INCOME GROUPS shifting in a seller's market is not as obvious as it appears.8 In addition to the situations described above where forward shifting is possible, there are situations in which backward shifting may occur. Consider for instance a situation where the spoils of profit exacted from the consumer are shared by the seller and a strong union. In this case wage demands depend upon profits net of tax, and a change in tax may well be reflected in a change in wages. In all these cases the theorist will readily admit that the imposition of a corporation income tax may lead to price or wage adjustments so that the no-shifting rule does not apply. Some other lines of argument need concern us less. One is the practical man's contention that " the pricing process does not conform to economic theory." The businessman, we are told, will treat the tax as if it were a cost. That is, he will include the tax in his computation of average costs to which then is added a " customary" profit (net of tax) margin in order to obtain the price. What gives rise to the " custom " is, of course, the crux of the problem. Its existence either reflects the presence of voluntary restraint as noted above, or it must be that such a margin is a measure, however imperfect or lagging, of optimum profits. If the latter is true, the argument breaks down. The customary margin, sooner or later, will be adjusted to a change in market data so as to maximize profits. Sellers will find 3 To argue that there will be more shifting in a seller's market it must be shown that the tax has more bearing on price policy, not merely that it is easier to raise prices. The situation may be the reverse if the case for shifting is based on the " restrained use of monopoly power " argument. 3 15 out, sooner or later, that adding the tax does not pay and the margin will be adjusted accordingly. A final argument refers to shifting in the long run and is frequently combined with the no-shifting rule for the short run. While the tax is held to fall on profits in the first instance, it is suggested that this will result in a decline in capital formation. The decline in capital formation in turn will result in lower productivity and hence bear upon the standard of living of the entire community, including wage as well as profit recipients. Thus the resulting burden is distributed more broadly in the long run, even though the shortrun incidence of the tax is on profits only. In evaluating this argument, one would have to determine first whether the level of capital formation would be affected significantly by a corporation tax of the 1948 rate level, given the economic conditions which then prevailed. But let us suppose that capital formation does decline. It follows that the community's real income in the future will be lower than it otherwise would be. On the assumption that the lower level of capital formation will not be permitted to reduce the level of employment, a larger fraction of the economy's output will come to be consumer goods. This result is extremely difficult to appraise; we have no way by which to match the loss of real income due to lower productivity with such gains in satisfaction as might be derived from a higher level of immediate consumption. Welfare theory, as it now stands, does not permit us to define an optimum rate of capital formation in this sense. Nor is it an easy matter to assess the 16 NATIONAL TAX distributional effects of the change toward a higher consumption economy. The productivity of labor will be less than it would have been had there been more capital formation. The productivity of capital will be higher than it would have been had the capital stock been larger. The lower productivity of labor is applied to the same labor supply as would have existed otherwise, whereas the higher productivity of capital is applied to a smaller capital stock. There may be a presumption that the profits share in national income will have increased as a result of these adjustments, but no firm conclusion can be drawn on a priori grounds. The results will depend upon the particular circumstances of the case. It seems that the long-run argument is rather inconclusive and that not much is lost by neglecting it in this study. By and large, it may be concluded that the academic view remains essentially correct. But certain exceptions should be allowed for, especially under conditions of a seller's market such as prevailed in 1948. Since this is a controversial matter and the corporation tax is of great quantitative importance, the testing of a number of shifting hypotheses seemed desirable. Thus we may determine the extent to which the results depend upon any particular assumption, and the reader who disagrees with our judgment will be in a position to choose the assumptions best suited to his own appraisal of the problem. Accordingly, the allocation of corporation tax payments by income groups was estimated on the basis of three shifting assumptions. First, it was assumed that one-third of the tax is shifted forward to consumers and one- JOURNAL [VOL. I V eighth of the tax is shifted backward to the wage earners, the remainder falling on profits. This is considered the standard case. While these particular ratios are more or less arbitrary, a choice of what seemed the most likely set of assumptions had to be made. In addition, two limiting cases are considered. One involves the assumption that the entire tax is shifted forward to consumers and the other the assumption that the entire tax remains on profits. A third limiting case of complete backward shifting did not seem to warrant investigation; it is not sufficiently realistic, and the results would not differ greatly from those obtained with complete forward shifting. Treatment of Retained Earnings.— Were it not for the problem of retained earnings, the part of the tax which is assumed to fall on profits could without further discussion be imputed to shareholders. The fact that corporations retain a substantial part of their profits complicates matters. It cannot be assumed that taxes falling on profits will be reflected entirely in reduced dividends; rather they must be spread between dividends and retained earnings. The part imputed to dividends may be traced to shareholders, but the allocation of the remainder requires closer consideration. Two possibilities suggest themselves: We may either disregard the part of the tax which falls on retained earnings or we may impute it to the shareholders, along with the tax component which is taken to fall on dividends. The former procedure has the disadvantage that a considerable part of the total tax yield is not accounted for; the latter has the disadvantage of implying the rather unrealistic assumption that taxes paid No. 1] TAX PAYMENTS BY INCOME GROUPS out of retained earnings are, in effect, taxes paid by shareholders. Since something may be said for either assumption, the corporation tax was allocated on both grounds. For purposes of the standard case the tax allocated to retained earnings was imputed to shareholders, so that the total yield may be accounted for. Six Cases Distinguished.—Our two assumptions regarding the treatment of the tax on retained earnings may be combined now with the above three assumptions with regard to shifting. This gives us six distinct cases for the allocation of the corporation tax. The assumptions applicable to these cases are summarized in lines (6) to (9) of Table 3. In all cases we begin with the data as reported for 1948 and shown in lines (1) to (5) of the table. Profits for the year amounted to $34.7 billion. Income taxes collected from corporations amounted to $13.6 billion, leaving profits net of tax of $21.1 billion. Of this, $7.9 billion was paid out in dividends and $13.2 billion was retained. Following the shifting assumptions of Case A, $1.7 and $4.5 billion of the yield are imputed to wage earners and consumers respectively. The remainder, or $7.4 billion, is taken to fall on profits. Of this, $2.2 billion is assumed to be reflected in reduced dividends and $5.2 billion in reduced retentions; that is, in the absence of a corporation tax, distributions and retentions would have been correspondingly higher. Allocation between the two is based on observation of past movements of profits, dividends, and retained earnings which suggest that changes in profits will be apportioned among dividends and retained earnings on a 3 to 7 basis.4 Since the stockholders are thus deb- 3 17 ited with tax payments made for them by the corporation, they must be credited on the income side of their ledger with a corresponding amount. Thus $2.2 billion of tax allocated to dividends must be imputed to shareholders because, in effect, this tax constituted part of dividend receipts before tax. In Case A, where retained earnings are to be accounted for, we must further impute the tax of $5.1 billion which was allocated to retained earnings as well as the remaining retention of $13.2 billion. The total imputed income to be added to stockholders' money income thus amounts to $20.6 billion. Such imputed income is not allowed for in the S.R.C. distribution of money income. The latter must be adjusted accordingly to permit us to obtain a meaningful ratio of taxes paid to income received. The adjusted distribution is shown in lines (10) and (11) of Table 6 below.5 4 There are two bases for breaking down the tax between the part falling on undistributed profits and the part falling on dividends. One basis is according to distribution of profits between undistributed profits and dividends in 1948. This breakdown was 62 per cent to undistributed profits, 3 8 per cent to dividends. Another basis is according to distribution of marginal profits between undistributed profits and dividends. Additions to profits were examined year by year to see in what proportion they were divided between retained earnings and dividends. If changes in dividends are compared with changes in profits for those years between 1934 and 1948 when profits rose, it may be noted that changes in dividends are in most cases between 14 per cent and 25 per cent of changes in profits. This suggests a marginal rate of distribution of about 20 per cent. The change between 1947 and 1948 was exceptional, however, the change in dividends being 43 per cent of change in profits. In the light of this information, 30 per cent of the tax was assumed to fall on dividends. We thus adopt a ratio which does not differ greatly from the 1948 allocation. Some allowance is made for the fact that between 1947 and 1948 the marginal rate of distribution of dividends was higher than it usually has been. 5 The adjusted distribution, strictly speaking, is not applicable to the unadjusted bracket limits. In- NATIONAL TAX 18 Case B involves the same shifting assumptions as Case A, but retained earnings ' and the tax thereon are disregarded. Shareholders, accordingly are [VOL. I V JOURNAL departure. This raises certain difficulties, as there is an implicit assumption that underlying economic conditions differ from those assumed to prevail in TABLE 3 ASSUMPTIONS FOR CORPORATION INCOME TAX (Money amounts in billions of dollars) Cases Reported data (1) Profits before tax (2) Tax collected from corporations .. (3) Profits after tax (4) Dividends (5) Retained profits Shifting assumptions (6) Per cent absorbed by profits (7) Per cent absorbed by wage earners (8) Per cent absorbed by consumers .. (9) Are retained earnings allowed for? Allocation of tax (amounts) (10) To dividends (11) To retained earnings (12) To wage earners (13) To consumers (14) Total accounted for Imputed income (amounts) (15) From tax on dividends (16) From tax on retained profits (17) From retained profits (18) Total imputed A* B C D E 34.7 13.6 21.1 7.9 13.2 34.7 13.6 21.1 7.9 13.2 34.7 13.6 21.1 7.9 13.2 34.7 13.6 21.1 7.9 13.2 34.7 13.6 21.1 7.9 13.2 34.7 13.6 21.1 7.9 13.2 54.2 12.5 33.3 yes 54.2 12.5 33.3 no 100.0 .... 100.0 .... yes .... no 100.0 yes 100.0 no 2.2 5.2 1.7 4.5 .... 2.2 4.1 9.5 .... .... .... .... .... 1.7 4.5 4.1 .... 13.6 .... 13.6 ma 8.5 2.2 5.2 13.2 .... 4.1 9.5 13.2 .... .... .... 20.6 ~22 26.8 ~41 ~13L2 .... 2.2 4.1 13.2 •Standard case. Note: Details do not necessarily add to totals because of rounding. Source: Survey of Current Business, July, 1949, Tables 8, 17, 19, 20, 21. debited with a tax of only $2.2 billion (i.e. the part of the tax on profits that is taken to be reflected in reduced dividends), and their income is credited by a similar amount. In Case C the entire tax is taken to fall on profits, but the reported data for 1948 are again used as the point of stead of referring to " spending units in the, say, $4,000 to $4,999 group " we should say " spending units which fall between the unadjusted bracket limits of $4,000 to $4,999." Case A. Otherwise, since the entire tax is now assumed to fall on profits, the gross profit figure could not be the same as in Case A where part of the tax was shifted. 6 Proceeding in a manner analogous to our reasoning in Case A, 6 For any given economic situation, gross profits will differ, depending on whether part of the tax is shifted or not. Since gross profits in Table 3 are taken to be the same for all shifting cases, it must be that underlying economic conditions are assumed to differ. Differences in the burden distribution for the different cases, therefore, reflect differences in No. 1] TAX PAYMENTS BY INCOME GROUPS we now debit shareholders with tax payments of $13.6 billion and credit them with imputed income of $26.8 billion. The data for Cases D to F are set up in a similar fashion, as may be seen from Table 3. underlying economic conditions as well as differences in shifting. An alternative procedure might be followed which would remove the obstacle of implied differences in basic economic conditions, so that the measure of differential incidence would not have to be impeded by extraneous differences in the general economic situation. Suppose the standard case is taken to be the true one, i.e., that one-third of the tax is shifted forward and one-eighth back. Observed gross profits are $34.7 billion. Deducting shifted taxes, we find that profits net of shifted tax are $28.5 billion. The picture for the standard case is exactly the same for both methods. Now we work out the other five cases with the same shifting and retained earning assumptions shown in the table. But instead of starting from given gross profits, as in the text method, we take net profits of $28.5 billion as the common starting point for all cases. With this method, taxes would be distributed between groups exactly as with the previous procedure. But income additions would differ in cases C, D, E, and F. These differences in income would be traceable to the fact that retained profits would turn out to be different, and so would dividends. In Case C, for example, gross profits as well as net profits would be $28.5 billion since it is assumed that there is no shifting. Under the text method, gross profits in Case C were $34.7 billion, to equal the observed figure. The difference in profits net of shifted tax leads to a fall in retained profits of $2.1 billion from the figure applicable under the text method, and a fall in dividends of $3.1 billion. Thus income additions under the alternative method will fall short of those under the text method by $5.2 billion. The difficulty with this procedure, however, is that we do not know to begin with which shifting assumption—and hence which interpretation of gross profits—is the correct one. And the results under the alternative method will differ, depending upon which case is chosen as the starting point. The procedure used in the text has the advantage that the results, in each case, are based on the reported figures. It shows how the burden of the tax, would have been distributed had one or the other shaking assumption (and the implicit interpretation of ffefit position in the absence of a tax) been correct. However, in comparing the results under the various cases we must be careful to note that differences not only reflect different shifting assumptions but also different interpretations of the underlying economic situation. 3 19 Allocation of Tax Components.—We may now consider how the various components of the corporation tax are distributed by spending unit income brackets. The part of the tax allocated to shareholders is distributed according to an estimated distribution of dividend income, and the allocation of imputed income is carried out on the same basis. The distribution of dividend receipts was derived from a distribution of dividends by taxable income brackets, available in the Treasury's Statistics of Income for 1947. In the absence of better information, it was assumed that thii 1947 distribution applies for 1948 as well. The distribution by taxable income brackets had then to be translated into a distribution by spending units, comparable to the S.R.C. data. The results of this procedure, which involves a good deal of difficulty and possible error, are shown in line (15) of Table 1. The forward-shifted part of the corporation income tax was treated similarly to excises, as discussed below. Where possible the forward-shifted part of the corporation tax was allocated to specific items of consumer expenditure, about 12 per cent of the total being treated in this fashion. The remainder was distributed among income brackets in accordance with the distribution of total consumer expenditures shown in line (2) of Table 1. The backward-shifted part of the corporation income tax was allocated in accordance with a distribution of wage and salary incomes by spending units. This distribution was estimated again from S.R.C. and Statistics of Income data and is shown in line (16) of Table 1. As in the case of dividends, the 20 NATIONAL TAX derivation of the wage and salary distribution is subject to a considerable margin of error. State Corporation Taxes.—In determining the allocation of the corporation income tax the share levied at the state level is treated as though it were distributed between income brackets exactly like Federal taxes. This introduces some inaccuracy, since in all probability state corporation taxes are less progressive than Federal taxes; items other than net income are frequently included in the state tax base. The above procedure was adopted because it was not feasible to submit each of the state taxes to separate treatirfent. 6. Tax Allocation: Excises Taxes 7 Total excise and sales taxes are included in this study, no exception being made for such " benefit taxes " as state gasoline levies. It might be argued that such earmarked taxes are tied to specific expenditure purposes and that the concept of differential incidence cannot be applied, the only feasible approach being in terms of a combined tax-expenditure incidence. While there is some merit to this view, the line is difficult to draw; and it was decided to include all taxes without distinction. Excise and sales taxes of all kinds are assumed to be entirely shifted forward to the consumer. As noted in section I, this disregards the resulting interindustry shifts in profits and wages. Short of a much more elaborate analysis, there is no way in which such adjustments can be allowed for. And, as noted before, it does not seem unreasonable to assume that such shifts 7 The term excise is here used loosely to include all kinds of taxes assessed largely or wholly on gross receipts, sales, or production costs. JOURNAL [VOL. I V will produce no major changes in the distribution of income by brackets. The yield of indirect taxes, therefore, is allocated by spending unit income brackets in accordance with the distribution of consumer expenditures. Wherever possible, excises are assigned to specific expenditure items and distributed in accordance with the specific expenditure patterns shown in lines (7) to (14) of Table 1. Where no such assignment was possible, as in the case of customs duties, the allocation is made according to the general distribution of consumer expenditures shown in line (2) of the table. In certain cases the entire tax can be assigned to a specific category of expenditures. Thus, proceeds from liquor and tobacco taxes can be distributed wholly in accordance with the respective distributions of consumer expenditures. In other cases, e.g. automotive taxes, it was necessary to estimate a breakdown of the yield between that part reflected directly in automotive expenses of the consumer and another part entering into the costs of operating business in general. The former was allocated in accordance with automotive expenditures of consumers; the latter was assigned according to the distribution of total consumer expenditure. A summary of the amounts of excises allocated to specific expenditure categories is shown in Table 4, which also provides similar information for the forward-shifted part of the corporation income tax. The distfbution for total consumer expenditu®s shown in line (2) of Table 1 was obtained directly from the S.R.C. data. The specific distributions shown in lines (7) to (14), on the TAX PAYMENTS BY INCOME GROUPS No. 1] other hand, involved extensive adjustments in the B.L.S. data. Therefore the advantage gained by allocating excises according to expenditure patterns for specific items may be cancelled by the lesser reliability of these distributions. TABLE 4 ALLOCATION OP EXCISE TAXES BY EXPENDITURE PATTERNS (In millions of dollars) Excises * Allocated According to Table 1: Line Line Line Line Line Line Line Line Line Forwardshifted Part of Corporation Tax t Federal State and Local 2,173 1,312 601 110 576 197 2,177 203 463 1,890 409 994 .... 165 784 583 134 134 3,561 39 232 305 32 250 7,912 6,093 4,540 (2) (7) (8) (9) (10) (11) (12) (13) (14) Total 121 * For explanations, see appendix, Table 19. f Standard case. An alternative allocation of excise taxes was prepared in which all specifically allocated taxes were redistributed according to the pattern for total consumer expenditures. As shown in section IV, the results do not differ greatly from those obtained by the more detailed method. 7. Tax Allocation: Property Tax Allocation of the property tax raises numerous difficulties. Since this tax is of great importance, especially for the distribution of the tax burden among the lower income brackets, these difficulties must be set forth in some detail. Allocation of Tax by Category.— Notwithstanding the scarcity of data, 3 21 it seemed desirable first to determine the principal categories into which the property tax yield should be divided in order to permit us to apply reasonable shifting assumptions to the component parts. Accordingly, the total yield was divided into fourteen component parts. The first division is between taxes paid on real estate and taxes paid on personal property. The tax on real estate is subdivided into taxes paid on owner-occupied homes, leased residential property, business property, and farm property. In each case a further division is made between tax on assessed land value and tax on assessed value of improvements. The tax yield allocated to personal property is divided between property held by farmers, businesses, and nonfarm individuals. In each case, a f u r ther distinction is drawn between tax on tangibles and tax on intangibles. The estimated distribution of the property tax yield according to these categories is shown in column (1) of Table 5. The reader who is at all familiar with the paucity of data in this area will be aware that this implies a great deal of conjecture. While there is fairly adequate information to support the over-all allocation between real estate and personal property, information on which to base the further allocation of real estate taxes is more limited, and there is little if any basis on which to estimate the breakdown of the yield total that is derived from personal property. The detailed breakdown, shown in Table 5, therefore, should not be taken to imply that we are in a position to defend each figure shown. In some instances, it is merely a matter of making our assumptions explicit. Changes in the distribution of 22 NATIONAL TAX property tax payments which might result from alternative yield allocations are explored in section III. Shifting Assumptions.—We now proceed to consider what shifting assump- [VOL. I V JOURNAL housing by home owners, as shown in line (4) of Table 1. The tax on business property is distributed in accordance with the distribution of dividend payments shown in line (15) of Table TABLE 5 ALLOCATION OP PROPERTY TAX YIELD BY TYPE OF PROPERTY * (In millions of dollars) Case A t Case B Case C Allocated According to Table 1, line: 434 217 322 643 412 823 670 1,330 434 217 506 759 374 561 670 1,330 434 217 133 532 307 1,228 670 1,330 (18) (2) (15) (2) (18) (5) (4) (4) 4,851 4,851 4,851 275 274 57 58 275 274 175 175 57 58 225 525 375 375 57 58 105 245 1,213 6,064 1,213 6,064 1,213 6,064 Yield Type of Property Real Estate: (1) Farm, land (2) Farm, improvements (3) Business, land (4) Business, improvements (5) Rental, land (6) Rental, improvements (7) Owner-occupied residential, land (8) Owner-occupied residential, improvements (9) Total, real estate zrsonal Property: (10) Business, tangible (11) Business, intangible (12) Farm, tangible (13) Farm, intangible (14) Non-farm, tangible (15) Non-farm, intangible (16) (17) ! Total, personal property Total, real and personal (2) (2) (2) (2) (3) (6) .... •For sources and explanation see appendix, t Standard case. tions to apply to each of the fourteen parts of the property tax and what pattern of allocation to use. These patterns are also summarized in Table 5. To the extent that the real estate tax is assessed upon the value of land, it is assumed to rest on the owner. This is in accordance with the principle that a tax on land cannot be shifted, since rent is not a determinant of price. The tax on owner-occupied residential property is allocated in accordance with the S.R.C. distribution of expenditures for 1. For leased residential and farm property the distribution of the tax corresponds to the distribution of rental income shown in line (18) of Table 1. To the extent that the tax on real estate is assessed upon the value of improvements y it may or may not be shifted depending upon the type of property. In the case of owner-occupied residential property, this part of the tax is again taken to rest on the owner. As in the case of land value, the tax is distributed on the basis of No. 1] TAX PAYMENTS BY INCOME GROUPS housing expenditures of owners. In the case of leased residential property, the tax on improvements is assumed to be shifted to the tenant since taxes on improvements will enter into cost of production. The tax thus shifted to the tenant is allocated by income brackets on the basis of housing expenditures of renters, as shown in line (5) of Table 1. In the case of business property, the tax on improvements is treated as an excise entering into the general cost of doing business. It is assumed to be shifted forward and is allocated according to the pattern of total consumer expenditures. The same procedure is applied to improvements on farm real estate, it being assumed that the assessed value of improvements in farm real estate reflects business rather than residential facilities. In the absence of information permitting a split between these two types of farm improvements, this appears to be the more reasonable assumption. Turning now to the tax assessed on personal property, let us begin with the tax on tangibles. The tax on tangible property owned by individuals may be expected to rest with the owner. It is allocated according to a distribution of consumer expenditures on durables, obtained from the S.R.C. and shown in line (3) of Table 1. The tax on tangible property owned by businesses and farmers is considered a cost of production. Shifted forward, it is allocated according to the distribution of total consumer expenditures. . In the case of property held by businesses and farmers, the tax falling on intangibles is treated similarly to that on tangibles. In the case of individuals other than farmers, the assumption is again that the tax on intangibles is not shifted. 3 23 The allocation, in this case, is based upon the S.R.C. distribution of liquid asset holdings shown in line (6) of Table 1. 8. Tax Allocation: Social Security Taxes Payroll taxes, including the contribution of employers and employees, are covered in this study along with other taxes. There may be some doubts whether such taxes should be included in a study of this kind. First, it may be argued that payroll tax receipts are linked contractually to benefit payments, so that our concept of differential incidence cannot be applied. Second, it may be argued that payroll taxes are traded on a quid pro quo basis against benefit payments, the entire process being more in the nature of an insurance purchase than a tax. While there is some validity in both points, neither is conclusive. The link between payroll tax receipts and benefit payments is rather legalistic, and alternative methods of finance might well be considered. Moreover, the assumption of a quid pro quo relationship between contributions and benefit payments is subject to considerable qualification. Not only are the contributions mandatory, but there are substantial redistributional elements in the benefit formulas. The very notion of an employer contribution is incompatible with the quid pro quo interpretation. From the employer's point of view the payroll tax is no less a cost of doing business than any other tax levied upon the use of resources. A possible solution might be to include only the employer contribution, but this presumes that the latter is not shifted to the employee. While the whole problem of expenditure treat- 24 NATIONAL TAX ment is particularly acute in connection with the payroll tax, it seemed preferable to exclude it. The reader who wishes to consider the results net of payroll tax may do so readily from the data presented in section III. Shifting Assumptions.—Of total payroll taxes collected in 1948, about twothirds were contributed by employers and one-third by employees. Depending upon circumstances, the employer contribution may be reflected in reduced profits, lower wages, or higher prices. The presumption for a competitive system, however, is that the entire burden is borne by wage earners. Imposition of a payroll tax on the employer raises labor costs; the gross wage rate (including tax) is raised without there being a corresponding increase in productivity. Unless workers are willing to accept a corresponding cut in wages, producers will substitute other factors of production and less labor will be employed. On the assumption that the supply of labor is inelastic, wage rates will fall by the amount of tax. While it is conceivable that the tax may in some instances result in reduced profits, the profit effect is likely to be one of redistribution from more to less labor intensive industries. But this is an over-simplified view. Once a more realistic view is taken, we may point to a number of reasons why complete backward shifting is unlikely. Suppose for a moment that production requires the combination of all factors in fixed proportions. In this case, the producer cannot avoid the payroll tax by substitution of untaxed factors. The tax, in effect, becomes a general excise assessed on the total cost of production, and as such we may expect it to be shifted forward. While the com- JOURNAL [VOL. I V bination of factors is not fixed in practice, this assumption is less absurd than it may appear. Since the payroll tax applies fairly generally to all types of labor, only a general substitution of capital for labor can be resorted to. This is not possible in the short run. In the longer run such substitution may occur, but we may expect that replaced labor will be reabsorbed in capital goods industries. And public policy, in any case, is not likely to permit prolonged unemployment to result; absorption of such labor through an upward adjustment of prices is the more likely outcome. Unions, moreover, may cite the " intent of the law " in resisting employer attempts to recoup their contribution by wage reduction. Considerations of these and other institutional factors suggest that forward shifting to the consumer is more likely than backward shifting to the wage recipients. In view of the uncertainties involved, we again make use of alternative assumptions. Three cases are considered. In Case A the employer is taken to shift one-third of his payments to wage earners and two-thirds to consumers. This is the standard assumption. The two other cases present limiting assumptions, Case B providing for complete backward and Case C for complete forward shifting. The employee contribution is assumed to fall on wage earners in all three cases. This follows the usual practice, although it is by no means evident why the incidence of this part of the tax should differ from that of the employer contribution. A different treatment of the employee contribution may be explained only on psychological grounds. Just as the unions may cite the " intent of the law " in their sup- No. 1] TAX PAYMENTS BY INCOME GROUPS port when resisting backward shifting of the employer contribution, the public mores are against unions that attempt to recover their own contributions through higher wages. While it seems desirable, in principle, to apply alternative assumptions to both parts of the payroll tax, the additional results do not justify the effort. The burden distributions resulting from allocation on the basis of consumer expenditures are rather similar to those obtained by allocation on the basis of wage receipts. Allocation of Tax.—The part of the tax which falls upon wage earners is allocated according to an estimated distribution of covered wage income by spending unit income brackets. In order to obtain this distribution, income received by spending units had to be divided into wage and other income; and wage incomes, in turn, had to be divided into covered and uncovered wages. The resulting estimate shown in line (17) of Table 1 again involves a good deal of conjecture. The part of the tax which falls upon consumers was allocated according to the distribution of total consumer expenditures. An attempt to assign part of the tax to specific expenditure items accounted for too small a fraction of the total to be justified. 9. Tax Allocation: Estate, Inheritance, and Gift Taxes Available data did not permit a breakdown of estate, inheritance, and gift tax payments among income brackets above $7,500. In view of the high level of exemptions permitted under both Federal and state succession taxes, it seemed reasonable to assume that all but a negligible part of the yield should 3 25 be imputed to income recipients in the top bracket* The allocation of the yield of succession duties to high income people as a group avoids considerable difficulties which arise when an attempt is made to allocate the incidence of death duties to particular tax payers. 8 Suppose that Mr. Jones is a typical taxpayer with an income of $50,000 and that an average taxpayer at this level of income is endowed with an estate of, say, $400,000. If Mr. Jones had died this particular year, his death duties would have amounted to about $115,000. But, being an average taxpayer, Mr. Jones did not die during the year under consideration. Yet, as the average taxpayer, he must look forward to a corresponding tax liability which will arise at the time of his death. This may be allowed for by imputing to him a death tax payment equal in amount to the premium payable on an annuity sufficient to discharge his death duty at the time of his death. This premium may be estimated at about 7 per cent of income. No such computation had to be made here. Since it is reasonable to assume that succession duties were paid wholly by spending units with incomes in excess of $7,500, this yield may be related to the income of this group and it may be concluded that spending units in this group paid about 2 per cent of their incomes in such taxes. For taxpayers as a group, the two methods are, however, quite compatible. If instead, we had computed the premiums (as defined above) payable by all taxpayers 8 See Nicholas Kaldor, " The Estimation of the Burden of Death Duties," in G. F. Shirras and L. Rostas, The Burden of British Taxation (New York, 1943), pp. 80-90. 26 NATIONAL TAX in this group, the totals of such premiums would, under certain simplifying assumptions, have to equal the actual yield total obtained. III. D I S T R I B U T I O N O F T A X P A Y M E N T S U N D E R STANDARD ASSUMPTIONS Keeping in mind the conceptual and statistical limitations set forth in the JOURNAL [VOL. I V 1. Distribution of Total Tax Payments The over-all distribution of tax payments, combining total taxes paid at all levels of government, is shown in Table 6 and Chart I. Lines (1), (2), and (3) of Table 6 give the dollar amounts of total tax payments contributed by spending units within the various in- TABLE 6 DISTRIBUTION OP TAX PAYMENTS BY INCOME GROUPS: SUMMARY* (Money amounts in millions of dollars) Spending Unit Income Brackets (Thousands of dollars) Item fyaenrd Total 6,754 2,061 8,815 17,010 3,542 20,552 43,794 13,552 57,344 11.6 12.9 11.9 15.4 15.2 15.4 38.8 26.1 35.8 100.0 100.0 100.0 19.3 6.7 3.5 3.2 26.0 21.1 6.4 3.4 3.0 27.6 30.1 6.3 3.4 2.8 36.3 22.3 6.9 3.6 3.3 29.2 26,283 31,953 56,542 13.4 28.8 16.3 196,619 100.0 Under 1 1-2 2-3 3-4 4-5 5-7.5 Amounts (1) Federal (2) State and local (3) All levels 620 433 1,052 2,243 1,123 3,366 5,392 2,131 7,523 6,682 2,512 9,194 5,079 1,755 6,834 Per cent of yield total (4) Federal (5) State and local (6) All levels 1.4 3.2 1.8 5.1 8.3 5.9 12.3 15.7 13.1 15.3 18.5 16.0 16.2 8.1 3.9 4.2 24.3 18.6 7.3 3.7 3.7 25.9 19.0 7.1 3.7 3.5 26.1 Per cent of income 16.5 (7) Federal 11.6 (8) State and local 5.8 а. State 5.8 б. Local 28.1 (9) AH levels Addenda (10) Income received . . . 3,747 1.9 (11) Per cent of income t (12) Per cent of spending 12.2 units' 13,850 7.0 29,037 35,207 14.8 17.9 17.7 22.9 20.1 11.6 10.2 7 5.3 100.0 •Standard assumptions throughout. t Includes income imputed under standard corporation assumption. Note: Details may not add to totals because of rounding. preceding chapters, let us now turn to the quantitative results of the study. In this section we examine the results obtained on the basis of our standard assumptions. Other results derived from alternative assumptions will be considered in the final section. come brackets. Lines (4), (5), and (6) show the corresponding percentage distributions of total tax payments, and lines (7) to (9) give the dollar amounts as percentages of income received in the respective brackets. The latter ratios, which relate taxes paid to No. 1] TAX PAYMENTS BY INCOME GROUPS income received, provide the most interesting part of the evidence.1 Com1 Our concern is with differences between effective rates at different levels of income rather than with the average level of effective rates as shown in the last column. While the latter reflects the total level of income and tax payments, the former depends upon their distribution only. While there are some doubts about the proper income total to be used, 3 27 monly referred to as " effective rates of tax," these ratios show whether the tax structure is proportional, i.e. tax payments as a percentage of income are the same at all income levels; progresthese doubts do not apply to the underlying distribution. 8in <r \ \ X < H co f - H is O Lj > hO LLI LI. LL_ LU -J < o o -J Q 2 < LJ 1< h_J < tr L U Q LLI U. *< -J < 1- ^ ^ — ^ — ^ \ </) L U X tn LU X <n LU X \ 1 1• 11 • — V — £ _J < cr LU Q LU < 1< o o -J CO LU h- < ho I- Li- J c/> ©® © CM (3IN00NI JO 1N30 U3d SV XVI) 31VU 3AIJL03dd3 28 NATIONAL TAX sive, i.e. tax payments are an increasing percentage of income when moving up the scale; or regressive, i.e. the tax to income ratio declines with rising income.2 As will be seen from line (9) of Table 6, the tax-to-income ratio for 1948 is regressive at the bottom of the income scale and then remains more or less proportional up to about the $5,000 income level. It becomes progressive thereafter. Or, looking at the percentage distribution of tax payments, we find that the lowest 30 per cent of spending units, which receive approxi-* mately 9 per cent of the income, contribute about 8 per cent of the yield total, the tax-to-income ratio moving regressively over this range. The next 54 per cent of spending units, which receive about 46 per cent of the income, contribute some 41 per cent of the yield total. The tax-to-income ratio, over the middle range, remains more or less proportional. The top 15 per cent of spending units, finally, receive 45 per cent of the income and contribute 51 per cent of the total yield, the tax-toincome ratio being decidedly progressive over this range. Special caution is called for in interpreting the picture for the lowest income bracket. There is reason to believe that spending units in this bracket 2 The concepts of " progressive," " regressive," and " proportional" as defined above, are unambiguous, and for the greater part of our discussion these concepts are all that will be needed. When reference is made to the degree of progression or regression, matters are more complicated. These terms may then be defined in a number of different ways. Where reference is made in the present paper to the "degree" of progression, it is measured as percentage change of tax divided by percentage change of income. This is the concept of liability progression as defined in R. A. Musgrave and Tun Thin, " Income Tax Progression, 1929-48," Journal of Political Economy, LVI (December, 1948), 504. JOURNAL [VOL. I V are composed, not only of genuinely low income units, but also of others which have incurred temporary losses but are normally in a higher bracket. This results in a higher rate of expenditures or dividend receipts—and hence greater tax payments—for the group as a whole than is likely to apply to low income units more permanently within this bracket. To some extent, this argument applies to other brackets as well, but the resulting distortion may well be more pronounced in the bottom bracket. This calls for care in interpreting the appearance of regressivity at the bottom of the scale. The reader who has followed our exposition of the difficulties inherent in the preparation of such estimates will not be overly impressed with minor fluctuations in the estimated tax-toincome ratio. Also, he will bear in mind that the implications of alternative assumptions remain to be tested. Nevertheless, the general pattern shown in line (9) of Table 6 should be reasonably accurate. The over-all tax structure is by no means as progressive as is generally surmised, at least not as far as the lower 90 per cent of the taxpayers are concerned. father, the effective rate curve follows a U-shaped pattern with regression at the lower end, a proportional range over the middle and progression at the upper end of the scale. Over a wide range of incomes, including 90 or more per cent of spending units, the progressive elements of the tax structure appear to be balanced or outweighed by others which are proportional or regressive. As will be seen in section IV, this result follows the general pattern of other studies. The important thing for the individual taxpayer, as well as for public No. 1] TAX PAYMENTS BY INCOME GROUPS policy, is the distribution of payments (and hence the tax-to-income ratios) under the composite tax structure and not the separate distribution of payments under one or another particular tax. But, only by considering how tax payments for the various components of the revenue structure are distributed, can it be understood how the over-all pattern of distribution comes about and what may be done to adjust it. 2. Distribution of Federal vs. State and Local Tax Payments The first breakdown to be considered is between levels of government. A comparison of lines (7) and (8) of Table 6 indicates a distinct difference in the distribution of Federal and state and local tax payments* The degree of initial regression in the distribution of state and local payments is pronounced and is subject to little doubt. The distribution of state and local payments continues to be regressive throughout. Some degree of regression at the bottom of the income scale appears for the Federal as well as for the state and local system. However, the decline of the Federal ratio is very slight and falls well within the margin of error which must be applied to these results. This is followed by a distinct element of progression around the $2,000 income level, where the personal income tax makes itself felt. Moving up the scale, we then find a slightly progressive distribution of payments up to the $5,000 range, with distinct progression following at the top of the scale. The progression in the top brackets, of course, reflects almost entirely the personal income tax. Looking again at the percentage distribution of tax payments, as shown in 3 29 lines (4) and (5) of Table 6, we find that both the Federal and state-local revenue structures derive about 27 to 28 per cent of their yield totals from incomes in the $4,000 to $7,500 range. But, whereas the Federal Government derives 39 per cent from incomes above $7,500 and 33 per cent from incomes below $4,000, the state-local system draws 46 per cent from incomes under $4,000 and 26 per cent from the over $7,500 group. And, while the Federal Government obtains only 6.5 per cent of its yield from incomes under $2,000, the share of state-local revenue contributed by these brackets amounts to 11.5 per cent. It is thus evident that the progressive element in the combined revenue structure is provided by Federal taxes, whereas the distribution of state-local tax payments is proportional or regressive. While no separate study was made of the distribution of state as distinct from local tax payments, a rough estimate of this kind is shown in lines (8a) and (8b) of Table 6? It appears that the two patterns are quite similar. However, regression in the distribution of state taxes is more distinct at the beginning of the range and not so great at the upper end of the scale as in the distribution of local taxes. As shown below, this reflects differences in the distribution of excise and property tax payments. 3. Distribution of Federal Tax Payments by Type of Tax The distribution of Federal tax payments by type of tax is shown in Table 7. The distribution for some major 3 In breaking down line (8) into (8a) and (8b), the distribution of state excise and property tax payments is assumed to be the same as the distribution of similar tax payments to local governments. 30 NATIONAL TAX taxes is also shown in Chart II. As shown in lines (13) to (18) of Table 7, the major progressive element is the personal income tax. This tax provides nearly one-half of the yield total and results in a progressive distribution of JOURNAL [VOL. I V Little need be said in explanation of the personal income tax distribution as shown in line (13) of Table 7. The reader will recall that the tax-to-income ratios shown apply to the income of spending rather than taxpaying units. TABLE 7 DISTRIBUTION OF FEDERAL TAX PAYMENTS BY INCOME GROUPS * (Money amounts in millions of dollars) Spending Unit Income Brackets (Thousands of dollars) Item Amounts (1) Personal income tax .., (2) Corporation income tax . (3) Excises (4) Payroll taxes (5) Estate and gift taxes ... (6) Total Per cent of yield total r (7) Personal income tax .. (8) Corporation income tax (9) Excises (10) Payroll taxes (11) Estate and gift taxes .. (12) Total Per cent of income (13) Personal income tax .. (14) Corporation income tax (15) Excises (16) Payroll taxes (17) Estate and gift taxes .. (18) Total Under 1 1-2 2-3 3-4 4-5 5-7.5 7,5 a n d over Total 9 273 226 112 469 712 714 348 1,543 1,331 1,394 1,133 2,328 1,582 1,700 1,072 2,201 1,166 1,117 595 3,537 1,466 1,292 459 ... 7,958 6,388 1,467 297 900 18,045 12,920 7,912 4,015 900 620 2,243 5,392 6,682 5,079 6,754 17,010 43,794 0.1 2.1 2.9 2.8 2.6 5.5 9.0 8.7 8.5 10.3 17.6 28.2 12.9 12.2 21.5 26.7 12.2 9.0 14.1 14.8 19.6 11.3 16.3 11.4 1.4 5.1 12.3 15.3 11.6 15.4 44.1 49.4 18.5 7.4 100.0 38.9 100.0 100.0 100.0 100.0 100.0 100.0 0.2 7.3 6.0 3.0 3.4 5.1 5.2 2.5 5.3 4.6 4.8 3.9 6.6 4.5 4.8 3.0 8.4 4.4 42 2.3 11.1 4.6 4.0 1.4 ... 14.1 11.3 2.6 .5 1.6 9.2 6.6 4.0 2.0 & 21.1 30.1 22.3 ... ... . • • ... ... ... ... ... ... ... ... ... ... ... 16.5 16.2 18.6 19.0 19.3 ... •Standard assumptions throughout. Note: Details do not necessarily add to totals because of rounding. payments over the entire range to which it applies. Excise taxes are regressive throughout, as may be expected. The corporation income and payroll taxes show a fluctuating pattern up to the $5,000 range, above which the former becomes distinctly progressive and the latter distinctly regressive. The estate and gift taxes are highly progressive but do not carry much weight in the total yield picture. Because of the presence of more than one income recipient in the typical spending unit, the splitting of income between spouses, and other factors, the pattern of income tax payments is less progressive when allocated by spending units than when allocated by taxpaying units. Also, it is evident that our data understate the degree of progression applicable to high incomes, since there is no breakdown of incomes above $7,500. (3IAIOONI JO 1N30 d 3 d SV XVI) 31VH 3AI103JJ3 32 NATIONAL TAX The indicated distribution of corporation tax payments seems puzzling at first sight. As shown in line (14) of Table 7, the distribution is distinctly regressive up to the $2,000 to $3,000 range, remains more or less proportional up to the $7,500 level, and becomes progressive only thereafter. In order to understand this pattern, the assump- [VOL. I V JOURNAL retained earnings after tax plus the share of the tax falling on profits are similarly imputed to shareholders' income. An explanation of the over-all pattern of corporation tax payments may be found by examining the respective patterns applicable to the various shifting components. This is shown in Table 8. TABLE 8 DISTRIBUTION OP FEDERAL CORPORATION TAX PAYMENTS FOR SEPARATE SHIFTING COMPONENTS* (Money amounts in millions of dollars) Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 157 39 77 403 148 161 779 314 238 900 381 301 623 284 259 695 259 511 748 190 5,451 4,306 1,615 6,998 (4) Total 273 Per cent oj income (5) Forward-shifted part . . . . 4.2 (6) Backward-shifted part .. 1.0 (7) Shareholders' part 2.1 712 1,331 1,582 1,166 1,466 6,388 12,920 2.9 1.1 2.7 1.1 & 2.6 1.1 .9 2.4 1.1 1.0 2.2 .8 1.6 1.3 .3 9.6 22 & 3.5 (8) Total Per cent of yield total (9) Forward-shifted part . . . . (10) Backward-shifted part .. (11) Shareholders' part (12) Total 71 5.1 4.6 4.5 4.4 4.6 11.3 6^5 3.0 2.4 1.1 2.1 9.4 9.2 2.3 5.5 18.1 19.4 3.4 10.3 20.9 23.6 4.3 12.2 14.5 17.6 3.7 9.0 16.1 16.0 7.3 11.3 17.4 11.8 77.9 49.4 100.0 100.0 100.0 100.0 Amounts (1) Shifted forward (2) Shifted backward (3) On shareholders 12 2-3 3-4 4-5 5-7.5 Total •Standard case. tions underlying this allocation of corporation tax payments must be recalled. Line (14) of Table 7 is based on our standard assumptions which specify that one-third of the tax is shifted to consumers and one-eighth to wage earners, the remainder falling on profits. This entire remainder, including the part coming out of retained earnings as well as the part coming out of dividends, is imputed to shareholders; and 'the distribution of the forwardshifted part of the corporate tax is based largely on the general distribution of consumer expenditures. Accordingly, it is sharply regressive at the bottom of the scale and continues regressive throughout the income range. As may be seen by comparison of line (5) of Table 8 with line (15) of Table 7, this distribution differs somewhat from the distribution of excise payments, which No. 1] TAX PAYMENTS BY INCOME GROUPS rests more largely upon the expenditure pattern for specific consumption items. However, the difference is not substantial.4 The backward-shifted part of the tax is allocated in accordance with wage income. As shown in line (6) of Table 8, it follows a more or less proportional pattern up to the higher brackets, where it becomes regressive. This is as may be expected, since capital income tends to become a rising fraction of total income when moving up the scale. The weight of the backward-shifted part in the total is slight. The distribution of the shareholders' part may appear somewhat surprising. As will be seen from line (7) of Table 8, this part of the tax is distinctly regressive at the bottom of the scale. Since the allocation of this component is based upon the estimated distribution of dividend receipts, it reflects a decline in the ratio of dividend to other income when moving from the first to the second bracket. 5 Regression at the lower end of the scale appears in the part falling on profits as well as in the forward4 Had the forward-shifted part been distributed in accordance with the pattern of Federal excises as given in line (9), Table 7, the effective rates for the first three brackets as shown in line (15) of Table 7 would have been 3.2, 4.3, and 2.6 per cent respectively. For the higher brackets the results would have differed little from those shown in line (5) of Table 8. See also Table 14. 5 Dividend receipts as percentage of spending unit income are estimated at 2.3, 1.3, 0.9, 1.4, 1.1, 1.8, and 10.9 per cent for the seven brackets respectively. This result, it should be noted, is not peculiar to our data but appears in even stronger form in the distribution of dividend receipts by taxable incomes as shown in the Preliminary Statistics of Income for 1947, Part I, Treasury Release 32171, November 25, 1949, p. 8. As noted previously, an explanation may be found in the hypothesis that the bottom group includes a large number of rentiers and of normally higher bracket people who have suffered temporary losses. 3 33 shifted part of the tax. While the former element is more sharply regressive at the bottom, regression in the latter extends further up the scale and weighs more heavily in the total. Both contribute to the [/-shaped form of the effective rate curve for total corporation tax payments. Distributions of corporation tax payments for alternative assumptions will be considered below.6 The allocation of excise tax payments is shown in lines (9) and (15) of Table 7. While the general pattern is more or less regressive, there are a few progressive components. The distribution of payments by components allocated 6 A further complication of the corporation tax distribution .arises from the interrelationship of corporation and personal income tax liabilities. The complication applies only to the unshifted part of the corporation tax. When an additional corporation tax is imposed, the additional liability incurred by the shareholder is equal to the additional corporation tax to be imputed to him, minus such reduction in his personal income tax liability as results from curtailment of his dividend income because of the increased corporation tax. These personal income tax savings will be the higher, per dollar reduction of dividend income, the higher is the dividend recipient's income bracket and hence his marginal rate under the personal income tax. The incremental corporation tax is thus regressive per dollar of reduced dividend income. This offsets, in part, the progressive tendency of the corporation tax which results because (with the exception of the bottom range) dividends tend to increase as a share of income as we move up the income scale. This personal income tax offset does not enter into determining lines (3) and (7) of Table 8 as in lines (3) and (7) we are concerned with the allocation of a given yield total including corporation and personal income taxes. At the same time, line (7) of Table 8 does not accurately reflect the additional liability which would result when adding the corporation tax to the other taxes; there would, in effect, be a partial offset due to lowered personal income taxes. The difficulty might be overcome, for present purposes, by considering the sum of lines (13) and (14), Table 7, as the joint personal and corporation tax liabilities. In considering the joint result of the two taxes, we avoid the difficulties that arise when considering either of the taxes separately. NATIONAL TAX JOURNAL 34 according to various spending patterns is shown in Table 9, details of the components being described in Table 4 above. Among the major elements in the excise tax picture, the distribution of tobacco taxes is distinctly regressive through the entire income scale. The distribution of liquor taxes, on the contrary, is progressive at the bottom of [VOL. I V Note also the sharp initial element of regression in the tax component allocated according to automotive expenditures. As is apparent from these data, various excises show distinctly different payment patterns. The distribution of payroll tax payments as shown in line (16) of Table 7 follows an irregular pattern up to the third income bracket but becomes dis- TABLE 9 DISTRIBUTION OF FEDERAL EXCISE TAX PAYMENTS FOR SEPARATE SHIFTING COMPONENTS: TAX PAYMENTS AS PERCENTAGE OF INCOME Allocated According to Expenditures on: (1) (2) (3) (4) (5) (6) (7) (8) (9) Tobacco Auto transport Other transport Recreation Food Liquor Rent All other Total consumer expenditures Total Total Amount Allocated (Millions of dollars) Spending Unit Income Brackets (Thousands of dollars) Under 1 1-2 5-7.5 7.5 and over 2-3 8-4 4-5 2 a 1.0 .3 .1 .3 .1 1.3 .2 .3 0.9 .3 .1 .3 .1 1.4 .2 .3 0.7 .4 .1 .3 .1 1.1 .2 .3 0.6 .4 .1 .4 .1 1.1 .1 .2 1,312 601 110 576 197 2,177 303 463 1.4 .5 2,173 1.8 1.2 1.1 1.0 1.0 .9 .5 .9 7,912 ~5S 19 Z5 4J6 To 3S Z5 3.8 * .3 .2 .5 .3 .5 1.1 .3 .1 .2 .2 1.4 Total 0.3 .2 * .2 * .8 .1 2 0.7 .3 .1 .3 .1 1.1 .2 2 * Less than 0.05 per cent. the scale; it becomes more or less regressive thereafter, but less so than most other components. The component which is not allocated to specific expenditure categories, but is distributed in accordance with the general pattern of consumer expenditures, shows the sharpest degree of regression at the bottom of the scale. This reflects the occurrence of dis-saving at low levels of income, characteristic of available data on income-expenditure relationships.7 7 This remains a rather puzzling matter. As noted before, the expenditure-income relationship at the lower end of the scale, and hence the distribution tinctly regressive thereafter. This is as may be expected, since only the first $3,000 of wage income for individual earners within any spending unit was subject to payroll tax. The element of regression when moving from the first to the second bracket and the subseof excise payments, may well be distinctly different for spending units which are permanently in the lower income range than for others who find themselves in the low income position due to temporary misfortune and who maintain more nearly customary standards of living by drawing on their savings. T o the extent that this is the case, it should be allowed for in interpreting our excise data for the low income range. TAX PAYMENTS BY INCOME GROUPS No. 1] quent occurrence of progression when going from the second to the third bracket must again be explained in terms of the distributions applicable to the various shifting components. These are shown in Table 10. The distribution of payments is again based on our standard assumption, which in this case postulates that twothirds of the employer contribution is shifted to consumers while the remain- 3 35 4. Distribution of State and Local Tax Payments by Type of Tax A detailed analysis of state and local tax payments by type of tax is shown in Table 11. The personal income tax again provides the progressive element, but its contribution to the yield total is too slight in this case to leave a significant impact on the combined pattern of tax payments. The corporation income T A B L E 10 DISTRIBUTION OF PAYROLL TAX PAYMENTS FOR SEPARATE SHIFTING COMPONENTS t (Money amounts in millions of dollars) Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 Amounts .. (1) Part falling on wages (2) Part falling on consumers . .. 2-3 3-4 4-5 and 5-7.5 7.5 over Total 50 62 200 148 846 287 745 327 366 229 204 255 20 277 2,431 1,584 , (3) Total Per cent of income (4) Part falling on wages (5) Part falling on consumers . .. 112 348 1,133 1,072 595 459 297 4,015 1.3 1.7 1.4 1.1 2.9 1.0 2.1 0.9 1.4 0.9 0.6 0.8 0.5 12 0.8 .. 1u) 2.5 3.9 3.0 ^3 Ti ~0J5 2.0 (6) Total • tCase A (standard). * Less than 0.05 per cent. Note: Details do not necessarily add to totals because of rounding. ing one-third, as well as the entire employee contribution, falls on wage earners. As will be seen from Table 10, the forward-shifted part is distributed according to the general expenditure pattern and hence is regressive throughout the scale. The part falling on wages is progressive up to the $3,000 income level, because covered wages are an increasing fraction of income up to this level. The wage share subsequently becomes regressive, since covered wages decline as a fraction of income received. tax distribution is identical with that at the Federal level, but its quantitative importance is much less* The distribution of excises is generally similar to that shown at the Federal level, although the degree of regression at the bottom of the scale is more marked. This is as may be expected, since a larger part of state and local excises are of the sales tax variety, and taxes on luxury and semi-luxury items are less important than in the Federal structure. 36 NATIONAL TAX The new and most interesting factor in the distribution of state-local tax payments is the property tax. As shown in line (16) of Table 11 and in Chart II, the ratio of property tax payments to income is distinctly regressive at the bottom of the scale and con- [VOL. I V JOURNAL The item carrying the greatest weight is the part of the tax falling on owner-occupied residences. It is slightly regressive throughout and reflects the declining importance of housing expenditures when moving up the scale. Next in importance is the tax T A B L E 11 DISTRIBUTION OP STATE AND LOCAL TAX PAYMENTS BY INCOME GROUPS (Money amounts in millions of dollars) Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 Amounts (1) Personal income taxes (2) Corporation income taxes.. (3) Excises (4) Property taxes (5) Inheritance taxes (6) Total Per cent of yield total (7) Personal income taxes (8) Corporation income taxes.. (9) Excises (10) Property taxes (11) Inheritance taxes (12) Total Per cent of income (13) Personal income taxes (14) Corporation income taxes.. (15) Excises (16) Property taxes (17) Inheritance taxes (18) Total 39 545 539 9 72 1,056 994 32 86 1,267 1,127 37 63 886 769 91 79 1,003 888 ... 331 346 1,121 1,547 197 499 699 6,093 6,064 197 433 1,123 2,131 2,512 1,755 2,061 3,542 13,552 2.1 3.6 3.3 5.6 8.9 8.9 1.8 10.3 17.3 16.4 6.4 12.3 20.8 18.6 7.3 9.0 14.5 12.7 18.3 11.3 16.5 14.6 3.2 8.3 15.7 18.5 12.9 15.2 66.3 49.5 18.4 25.5 100.0 26.1 100.0 100.0 100.0 100.0 100.0 100.0 * .3 3.9 3.9 .2 3.6 3.4 0.1 .2 3.6 3.2 0.1 .4 5.8 5.4 ... 0.3 .2 3.1 2.8 ... 0.6 .6 2.0 2.7 .3 0.3 .4 3.1 3.1 .1 7.3 7.1 6.7 6.4 6.3 6.9 1L6 ... ... ... ... ... 5-7.5 AND F,over R 3-4 15 217 201 4-5 7 2-3 ... 2 3.4 2.9 Total * Less than 0.1 of 1 per cent. Note: Details do not necessarily add to totals because of rounding. tinues to be somewhat regressive throughout the income scale. This over-all pattern again must be explained in terms of the distributions of payment applicable to the various components. This is shown in Table 12 where various parts of the tax are combined according to their underlying patterns of allocation.8 assessed on personal property, which is regressive, especially at the beginning of the scale. As shown in Table 5, this component combines various elements allocated according to different patterns. However, it appears that the initial element of regression may be 8 For explanation of these components see Table S. TAX PAYMENTS BY INCOME GROUPS No. 1] traced to the shares falling on business and farm intangibles, which are taken to be reflected in production costs and allocated according to consumer expenditures. The share of the tax falling on business land reflects the pattern of dividend distribution, while that on farm and rental land reflects the pattern of rental income distribution. 37 with the exception of the part falling on rental improvements show some degree of regression at the lower end of the scale. Moreover, all components with the exception of the part falling on business, farm, and rental land value continue to be regressive from the second bracket up. The pattern, it appears, is fairly uniform. Except for T A B L E 12 DISTRIBUTION OF PROPERTY TAX PAYMENTS FOR SEPARATE COMPONENTS * (Yield in millions of dollars) Percentage of Income Item Total Yield Spending Unit Income Brackets (Thousands of dollars) Under 1 1 - 2 2-3 3-4 4—5 5-7.5 and over 7.5 Total 846 (1) Land: farm and rental . . . 322 (2) Land: business (3) Improvements: business and farm 860 (4) Improvements: rental 823 (5) Owner-occupied residences 2,000 (6) Personal property 1,213 1.07 .11 0.49 .05 0.29 .04 0.28 .04 0.27 .05 0.32 .07 0.68 .44 0.43 .16 .88 .72 1.44 1.15 .58 .81 1.27 .69 .54 .68 1.16 .72 .51 .52 1.21 .65 .47 .43 1.06 .64 .43 .38 .94 .64 .27 .13 .76 .46 .44 .42 1.02 .62 (7) All components 57~ 3IT 3.4 6,064 2S~ 2T 3T •Standard case. Note: Details do not necessarily add to totals because of rounding. Both items are regressive at the bottom of the scale. Both become progressive above the $4,000 range; the tax allocated to business land becomes highly progressive at the upper end of the scale. The two remaining items, finally, are both regressive throughout the entire scale. The distribution of tax payments falling on business and farm improvements reflects the excise pattern, while that of tax payments falling on improvements on rental real estate is based on the pattern of housing expenditure. In short, all the shifting components the impact of the tax on land upon the higher income ranges, it appears that the combined pattern shown in line (16) of Table 11 may be considered fairly reliable. This conclusion is supported by the testing of alternative property tax assumptions in the following section. 5. A Measure of Differential Incidence In the introductory section we concluded that a proper determination of incidence could be in the form of either (1) an absolute measure of the com-, bined incidence of both the revenue 38 NATIONAL TAX and expenditure sides of the budget, or (2) a differential measure of tax incidence. We are here concerned with tax incidence only, but up to this point have approached the problem in absolute rather than differential terms. In order to translate our results into a measure of differential incidence the [VOL. I V JOURNAL a whole; but as noted before, lines (7) through (9) of that table present only a rough approximation to differential incidence. The results are based on the assumption that the same income before tax applies for both tax systems, and this is hardly an acceptable simplification. T A B L E 13 MEASURE OF DIFFERENTIAL INCIDENCE : ALL LEVELS OF GOVERNMENT COMBINED * Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 Estimated Actual Distribution (1) Tax payments in millions 1,052 of dollars (2) Percentage of tax pay1.8 ments (3) Tax payments as per cent 28.1 of income Hypothetical Proportional Distribution (4) Tax payments in millions of dollars 1,093 (5) Percentage of tax pay1.8 ments (6) Tax payments as per cent 29.2 of income Differential Distribution (7) (1) - (4) (8) (2) - (5) (9) ( 3 ) - ( 6 ) - 41 -0.1 -1.1 2-3 3-4* 4-5 5-7.5 3,306 7,523 9,194 6,834 8,815 20,552 57,344 5.9 13.1 16.0 11.9 15.4 35.8 100.0 24.3 25.9 26.1 26.0 27.6 36.3 29.2 4,039 8,469 10,268 7,665 9,319 16,490 57,344 7.0 14.8 17.9 13.4 16.3 28.8 100.0 29.2 29.2 29.2 29.2 29.2 29.2 29.2 - 9 4 6 -1,074 1.9 - 1.7 3.1 - 3.3 - -831 - 1.5 - 3.2 -504 - 0.9 - 1.6 + 4,062 + 7.0 + 7.1 -673 - 1.1 - 4.9 over Total •Standard assumptions throughout. Lines (1) to (3) are taken from Table 6. Line (4) is obtained by allocating ihe total of $57,344 million according to distribution patterns shown in line (11) of Table 6. A similar procedure may be applied to obtain the respective hypothetical distributions for the Federal or state-local taxes. Note: Details do not necessarily add to totals because of rounding. estimated absolute incidence of the actual tax structure may now be compared with that of an alternative structure. For reference purposes, let us consider a structure under which the same yield total is raised but the money burden is distributed proportionally to income before tax. Table 13 provides such a comparison for the tax system as Lines (1) through (3) repeat the estimated actual distribution of tax payments as shown in lines (3), (6), and (9) of Table 6. Lines (4), (5), and (6) show what the pattern of tax payments would have been had the same yield been distributed proportionally. Lines (1) and (4) show the dollar amounts of the tax; lines (2) and (5), No. 1] TAX PAYMENTS BY INCOME GROUPS the percentage distribution of the tax; and lines (3) and (6), the tax as a per cent of income. Lines (7), (8), and (9) indicate the differential between the two systems, obtained by deducting the reference distribution from the actual distribution. It is apparent that spending units with incomes up to $7,500 would bear a heavier tax load under a proportional tax system than under the present distribution. Spending units in the top income bracket, on the other hand, would bear a smaller tax load under a proportional system. IV. T E S T I N G T H E S I G N I F I C A N C E O F ALTERNATIVE ASSUMPTIONS The distribution of tax payments presented in the preceding section was based on what appears to us the " most likely " set of assumptions. However, these assumptions involve highly speculative judgements and we do not wish, in any way, to be dogmatic about them. In order to obtain some notion of the weight carried by the choice of one or another hypothesis and to accommodate the reader whose ideas of " most likely " differ from ours, we now turn to the distribution of tax payments under a number of alternative hypotheses. 1. Corporation Income Tax The testing of alternative assumptions is most important and interesting with regard to the corporation income tax. Not only does this tax contribute a substantial portion of the yield, but its incidence has also been subject to much controversy. As shown in Table 3, six cases are considered. They combine three shifting assumptions with two treatments of retained earnings and the share of tax falling thereon. 3 39 The assumptions applying to each of the six cases are listed in Table 3, and the resulting distributions of corporation tax payments are shown in Table 14. In lines (1) to (6) of Table 14 corporation tax payments are given as a percentage of income. As shown in the last column, total corporation tax payments as a percentage of total income differ for each case. Whereas cases A, C, E, and F account for the entire tax yield, the part of the tax falling on retained earnings is disregarded in cases B and D. These cases, therefore, show a lower average level of rates. Further differences in average rate level arise because taxes paid out of retained earnings, as well as retained earnings after tax, are imputed to the shareholders' income in cases A, C, and E, but not in cases B, D, and F. When comparing the tax distributions for the various cases, the reader should keep in mind that there is a difference in the average level of effective corporation tax rates, as well as in the degree of progression or regression over various parts of the income range. For this reason, a comparison of the results obtained under the various assumptions is difficult. It is facilitated in some respects by reference to the corresponding percentage distributions of corporation tax payments as shown in lines (7) to (10) of Table 14.1 1 As will be seen from Table 14, the distributions are similar for cases C and D and for E and F. This is obvious in the case of E and F, because the entire tax is assumed to be shifted forward. Distributions are similar for C and D because the additional tax, accounted for in C, is distributed in the same way the tax on dividends is distributed in both C and D . The distributions are dissimilar for A and B. While the same shifting assumptions apply in both cases, the inclusion of the tax on retained earnings in A raises the fraction of the total that is allocated according to the dividend pattern over that of case B. NATIONAL TAX JOURNAL 40 These distributions may be compared without reference to differences in the various yield totals accounted for; however, the comparison thus provided is somewhat defective because it disregards the imputed income aspect of the problem. [VOL. I V for these three cases. Since the average effective rates shown in the last column of Table 14 are rather similar, the comparison may be drawn largely in terms of effective rates. In Case C the total payment is assumed to come out of profits. The ef- T A B L E 14 DISTRIBUTION OF CORPORATION TAX PAYMENTS FOR ALTERNATIVE ASSUMPTIONS Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 Corporation Tax Payments as Per Cent of Income * (1) Case A (standard) (2) Case B (3) Case C (4) Case D (5) Case E (6) Case F Per Cent of Corporation Tax Payments Contributed * (7) Case A (standard) . . . . (8) Case B (9) Cases C and D (10) Cases E and F Total Tax Payments as Per Cent of Income t (11) Case A (standard) (12) Case B (13) Case C (14) Case D (15) Case E (16) Case F 2-3 3-4 4-5 5-7.5 over Total 7.3 6.2 3.7 1.2 13.5 13.5 5.1 4.5 2.1 .7 8.8 9.0 4.6 4.1 1.5 .5 8.1 82 4.5 4.0 1.6 .5 7.7 7.9 4.4 3.8 1.8 .6 7.2 7.3 4.6 3.6 2.9 .9 6.6 6.8 11.3 6.1 16.3 6.9 4.4 5.5 6.6 4.5 6.4 2.1 6.8 7.3 2.1 2.7 1.1 3.7 5.5 7.5 2.3 9.3 10.3 14.5 3.4 18.1 12.2 17.1 4.3 20.9 9.0 12.3 3.7 14.5 11.3 13.8 7.3 16.1 49.4 32.1 77.9 17.4 100.0 100.0 100.0 100.0 28.1 28.1 24.0 22.7 34.6 36.0 24.3 24.2 20.9 20.1 28.4 29.0 25.9 25.9 22.5 22.0 29.8 30.3 26.1 26.1 22.9 22.3 29.7 30.2 26.0 25.9 23.0 22.4 29.1 29.7 27.6 27.6 25.5 24.6 30.1 31.1 36.3 39.2 39.8 38.9 31.9 40.0 29.2 29.3 28.3 26.5 30.3 32.6 * Includes Federal corporation tax only. t Includes all taxes and all levels of government. Based on standard payroll tax assumptions. Note: Details do not necessarily add to totals because of rounding. 1. Let us first compare the results of the two alternative shifting assumptions with those of the standard assumption used in Case A. For the purpose, let us consider only those cases in which retained earnings and the tax thereon are allowed, that is, cases A, C, and E. Lines (1), (3), and (5) show tax payments as percentage of income fective rate curve follows the U shape found to prevail in Case A under the standard assumption. Indeed, the initial element of regression is somewhat stronger than in the standard case, especially when moving from the second to the third bracket. 2 This is 2 According to our definition (see note 2, section III), the initial element of regression in line (3) of No. 1] TAX PAYMENTS BY INCOME GROUPS so because dividend receipts as a percentage of income fall off more sharply at the lower end of the income scale than do expenditures as a percentage of income. As in Case A, there follows a proportional middle range, but progression seems to make a somewhat earlier appearance. Most important, the degree of progression at the upper end of the scale is considerably sharper than in the standard case. Whereas the effective rate paid in the highest bracket under Case C is much above that paid in the standard case, the effective rate paid by all other brackets is considerably less. The same picture is obtained also by comparing lines (7) and (9). Whereas spending units in the top bracket contribute 78 per cent of the yield total in Case C, they contribute only 50 per cent in Case A. Case E, where the total corporation tax payment is assumed to fall entirely on consumers, follows the excise pattern and is regressive throughout. Accordingly, the effective rate is much higher at the bottom and much lower at the top of the income scale than in Case A. The contribution of spending units in the top bracket, in this case, is reduced to 17 per cent, as against 50 per cent under the standard assumption. It is apparent from these comparisons that the application of alternative shifting assumptions results in drastically different distributions of the tax payment. The corporation tax, it appears, is an altogether different proposition when one shifting assumption is made instead of another. 8 Moreover, since the corporation tax carries considerable weight in the yield total, the resulting Table 14 is stronger than in line (1) because the ratio of 3.7 to 2.1 is larger than the ratio of 7.3 to 5.1. 3 41 distributions for the revenue structure as a whole are also significantly different for the different assumptions. This may be seen by comparing lines (11), (13), and (15) of Table 14. While the general U shape of the effective rate schedule continues to apply in all cases, it is somewhat more marked in Case C than, for example, in Case E. Whether the reader will consider these divergent results as seriously invalidating the picture presented in the preceding section depends on his views regarding shifting. Even though he may not agree with the assumptions underlying our standard case, the reader should bear in mind that Cases C and E represent extreme and unlikely assumptions.4 3 It is evident from the distributions shown in lines (2) and (16) of Table 1 that differences in assumptions with regard to forward as against backward shifting are of rather minor importance. The important factor is how much of the tax is shifted and how much falls on profits. 4 The reader may wish to consider alternative shifting assumptions as follows: Case 1.—Let us assume that he wishes to consider retained earnings and the tax on these, as in the standard case, but wishes to change shifting assumptions. He may then redistribute the total shown in the last column of Table 8 to suit his preferences and then allocate the new dollar totals by brackets on the basis of lines (9), (10), and (11) of Table 8. He may then obtain a new line (4) in Table 8 by adding vertically. This new line (4) may then be expressed as a percentage of the income shown in line (10) of Table 6. The results obtained will not be quite correct, however, as these income figures provide for imputations which will differ from those properly applied under other assumptions. In order to obtain the appropriate income, the reader may take the difference between his allocation into line (3) of Table 8, added horizontally, and the standard case allocation of $6,998 million. This difference will then be allocated by income brackets in accordance with the percentage distribution shown in line (11) of Table 8. If the allocation to dividends is greater than in the standard case, the bracket distribution thus obtained equals the additional imputed income and is added to the standard case income dis- 42 NATIONAL TAX JOURNAL [VOL. I V 2. Let us now consider the differences may also be seen by comparing lines (7) which result from varying our assump- and (8), which show the percentage of tions regarding the treatment of re- yield contributed by spending units in tained earnings and of the tax thereon. the top bracket to be considerably To bring out this aspect of the prob- smaller in Case B than in Case A. Cases. C and D, where the entire tax lem, let us hold the shifting assumption is assumed to fall on profits, involve constant and compare Cases A and B, sharply different yield totals and hence C and D, and E and F. sharp differences in the average level of For Cases A and B, i.e. the standard effective rates. Since the percentage shifting assumption, the results are distribution of tax payments as shown shown in lines (1) and (2) of Table in line (9) is the same for both cases, 14. Since the yield total accounted for the difference in the pattern of proin Case A is larger than in Case B, the gression and regression is due entirely average level of effective rates is accordto the difference in the imputation of ingly higher. However, the degree of income. Leaving aside the difference in regression shown at the beginning of the average level of effective rates, we the scale is rather similar in the two cases, as is the proportional middle find the general pattern of rates to be range. The only significant difference very similar for the two cases. Tlje in the distribution of payments appears only significant difference is the lesser to be the flattening of progression at degree of progression at the top of the the upper end of the income scale in income scale which arises in Case D. Case B. This reflects disregard of the This may be expected since disregard tax on retained earnings. The same of the retained earnings reduces tax liabilities by a greater fraction than income before tax. tribution shown in line (10) of Table 6. If the allocation to dividends is smaller than in the standard Cases E and F, finally, allow for comcase, the bracket distribution must be deducted. plete forward shifting. Here the averCase 2.—Now assume that the reader wishes to age levels of effective rates are more disregard retained earnings and the tax on them. In nearly comparable. Again the differthis case only a smaller yield total will be accounted for. Suppose that $6,920 million is assumed to be ences in effective rate pattern are due shifted forward or backward and $6,000 million to entirely to differences in income imfall on profits. Using the 3:7 ratio between diviputation, the percentage distributions dends and retained earnings, $1,800 million of this $6,000 million falling on profits is taken to fall on of tax payments being the same for dividends and is substituted for $6,998 million in both cases. As will be seen from a comline (3) of Table 8, the total being reduced correparison of lines (5) and (6) of Table spondingly from $12,920 million to $8,720 million. On this basis a new line (4) of Table 8 is obtained 14, both cases result in a regressive rate as in Case 1. structure throughout the income scale, Again this may be related to income as shown in the degree of regression being slightly line (10) of Table 6, but this will be quite unsatisfactory. In order to obtain the correct income, line more pronounced in Case E, where re(10) of Table 6 must be adjusted. This line allows tained earnings are imputed. for imputation of $13,200 million of retained earnOn the whole, it appears that the difings, plus $6,988 million of tax on profits. Imputation in the present illustration should equal $1,800 ferences in the pattern of effective rates million. Thus the difference, or $18,398 million, arising from the change in the treatshould be allocated according to line (11) of Table ment of retained earnings and of the 8 and be deducted from,line (10) of Table 6. No. 1] TAX PAYMENTS BY INCOME GROUPS tax thereon are not very significant; certainly, they are much less significant than those arising from the variation of shifting assumptions. The difference is largely one of average rate level and merely expresses the fact that different yield totals are accounted for under the two procedures. 2. Excise Taxes As noted in section II, the allocation 3 43 ber of B.L.S. surveys. Since the latter derivations may involve a considerable margin of error, it seemed desirable to compare the results obtained by use of the detailed data with the distribution which results if all excises are allocated in accordance with the pattern of total consumer expenditures. The alternative results, in this case, reflect differences in estimating procedure rather T A B L E 15 DISTRIBUTION OF EXCISE TAX PAYMENTS FOR ALTERNATIVE SPENDING PATTERNS: TAX PAYMENTS AS PERCENTAGE OF INCOME Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 2S 3-4 4-5 5-7.5 7.5 and over Total 6.0 5.8 5.2 3.9 4.8 3.6 4.8 3.6 4.2 3.4 4.0 3.1 2.6 2.0 4.0 3.1 . 1L8 Total General Expenditure Pattern f 8.2 Federal 6.3 State and local 91 8£ SA 7£ 7\2 4~6 71 5.3 4.1 4.9 3.8 4.6 3.6 4.3 3.3 4.0 3.1 2.4 1.9 4.0 3.1 14.5 9.4 87 83 77 71 7.3 71 Detailed Expenditure Pattern5¥ Federal State and local Total * Allocated according to pattern shown in Table 4. This allocation used for excise distribution in all other tables. t Allocated wholly according to line (2), Table 1. Note: Details do not necessarily add to totals because of rounding. of excises, wherever possible, was made in accordance with expenditures on specific consumption categories. Only that part of the excises which could not be allocated in this fashion was distributed in accordance with the pattern of total consumer expenditures. This general pattern, as shown in line (2) of Table 1, was obtained directly from the S.R.C. data, whereas the specific expenditure patterns had to be derived from a num- than in shifting assumptions. The results are shown in Table 15, where the two excise tax distributions are compared. It appears that the element of regression at the bottom of the scale is somewhat sharper if the general expenditure pattern is used throughout. However, the over-all distribution of excise payments is very similar for the two cases. Similar conclusions apply under either method. 44 [VOL. IV NATIONAL TAX JOURNAL 3. Payroll Taxes The distribution of payroll tax payments, shown in section II, was based on the assumption that two-thirds of the employer contribution is shifted forward to consumers, whereas the remainder, as well as the entire employee contribution, is taken to fall on the wage earner. In Table 16 the estimated While these differences in the distribution of payments are obviously significant, the payroll tax contribution to the yield total was relatively slight in 1948, so that the over-all picture is not affected greatly by the variation of payroll tax assumptions. This may be seen in lines (7) to (9) of Table 16. With the growing weight of payroll taxation in the future, uncertainty regarding T A B L E 16 DISTRIBUTION OP PAYROLL TAX PAYMENTS FOR ALTERNATIVE ASSUMPTIONS Item Payroll Tax Payments as Per Cent of Income (1) Case A (standard) (2) Case B (3) Case C Percentage of Payroll Tax Payments Contributed (4) Case A (standard) (5) Case B (6) Case C Total Tax Payments as Per Cent of Income * (7) Case A (standard) (8) Case B (9) Case C Spending Unit Income Brackets (Thousands of dollars) ~ Under 1 1-2 2-3 3-4 4-5 5-7.5 7 f a n c l Total 3.0 2.2 4.6 2.5 2.6 2.7 3.9 4.4 2.5 3.0 3.6 2.4 2.3 2.4 2.2 1.4 1.1 2.0 0.5 .1 12 2.0 2.0 2.0 2.8 2.1 3.9 8.7 8.9 9.3 28.2 32.0 18.1 26.7 31.5 20.6 14.8 16.0 14.4 11.4 8.7 16.1 7.4 .7 17.5 100.0 100.0 100.0 28.1 27.3 29.3 24.3 24.4 24.5 25.9 26.4 24.5 26.1 26.7 25.4 26.0 26.2 25.9 27.6 27.2 28.2 36.3 35.9 37.1 29.2 29.2 29.2 * Standard corporation tax assumptions. Note: Details do not necessarily add to totals because of rounding. distribution of payments is shown for two alternative assumptions. It is assumed in Case B that the entire tax falls on wages and in Case C that the entire tax falls on the consumer. As would be expected, the distribution is more regressive at the lower end of the income scale in Case C than in the standard case. The distribution is progressive at the lower end of the income scale in Case B, with regression appearing only above the $4,000 level. payroll tax shifting will be of increasing importance. In time it may create a difficulty comparable to that presented by the corporation tax. 4. Property Tax Certain alternative assumptions for the property tax remain to be examined. As set forth in Table 5, these relate to the allocation of the yield total among different shifting components, rather than to the shifting assumptions appli- TAX PAYMENTS BY INCOME GROUPS No. 1] cable to each of these components. In the allocation of the yield total for Case B, doubtful allocations were resolved in each instance so as to place as large a part of the burden upon the upper income groups as appeared reasonably possible, while the opposite policy was followed in determining the allocations for Case C. 6 3 45 is more pronounced than in the standard case. This reflects the allocation of a smaller fraction of the total yield to the land component. As a result, the fraction distributed according to the pattern of dividend receipts and rental income is reduced, while the fraction distributed according to the excise pattern is increased. T A B L E 17 DISTRIBUTION OF PROPERTY TAX PAYMENTS FOR ALTERNATIVE ASSUMPTIONS Spending Unit Income Brackets (Thousands of dollars) Item Under 1 1-2 Property Tax Payments as Per Cent o] Income * (1) Case A (standard) (2) Case B (progressive) . . . (3) Case C (regressive) . . . . Percentage oj Property Tax Payments Contributed (4) Case A (5) Case B (6) Case C 5.36 5.28 5.47 3.89 3.71 4.18 2-3 3-4 4-5 5-7.5 over Total 3.42 3.25 3.63 3.20 3.07 3.34 2.93 2.84 3.01 2.78 2.76 2.82 2.74 3.02 2.40 3.08 3.08 3.08 3.31 8.89 16.39 18.58 12.68 14.64 25.51 100.0 3.26 3.38 8.46 9.54 15.56 17.39 17.82 19.40 12.28 13.05 14.52 14.85 28.09 22.38 100.0 100.0 28.08 28.00 28.18 24.30 24.12 24.59 25.91 25.74 26.12 26.11 25.99 26.26 26.00 25.91 26.09 27.59 27.57 27.63 36.35 36.63 36.01 Total Tax Payments as Per Cent oj Income t (7) Case A (8) Case B (9) Case C 29.16 29.16 29.16 * Includes state and local property tax payments. t Includes all taxes and all levels of government. Based on standard corporation and payroll tax assumptions. Note: Details do not necessarily add to totals because of rounding. The results are shown in Table 17. As may be seen from a comparison of lines (1) to (3), resulting differences are very slight. The degree of regression at the lower end of the income scale is about the same for all cases. The standard case, as noted before, is regressive throughout. In Case B some slight progression appears at the upper end of the scale. In Case C regression 5 For detailed assumptions see appendix notes to Table S. Except for the appearance of some degree of progression at the upper end of the income scale in Case B, it appears that variations in property tax payments, introduced by the use of alternative shifting assumptions, are very slight. The inadequacy of the data on which to base the allocation of the total property tax yield among specific components does not seem to do serious damage to the reliability of the estimated distribution of property tax pay- 46 NATIONAL TAX ments. As shown in lines (7) to (9) of Table 17, the distribution of total payments is not seriously altered by the use of alternative property tax assumptions. This concludes our analysis of alternative assumptions. The reader may now combine the effective rate schedules for particular taxes obtained under any of the assumptions in Tables 14 to 17 and thus derive alternative over-all schedules of tax payments comparable to those shown in Tables 6 and 7. Drastic differences in the over-all picture, however, will arise only from rather sharp changes in the shifting assumptions with respect to the corporation tax. The experimentation with alternative methods, except for this tax, appears to strengthen rather than weaken the confidence which may be placed in the general pattern of tax distribution under the standard case. 5. Comparison with Earlier Studies Finally, our results may be compared briefly with the earlier Colm-Tarasov estimate for 1938-39 and with the Adler estimate for 1946-47.® A comparison of effective rates for the combined Federal, state, and local tax systems for the three studies is shown in Chart III and Table 18. (a) Differences in Level of Effective Rates.—The average effective rates for the three studies are 20.2 per cent for the Colm-Tarasov, 24.2 per cent for the Adler, and 29.2 per cent for the present study (standard assumptions). This 6 Helen Tarasov, Who Does Pay the Taxes? (Supplement IV, Social Research, 1942). Reference is to the revised figures for 1938-39 as given on p. S. Also, see John Adler, " The Fiscal System, the Distribution of Income, and Public Welfare," in Kenyon E. Poole (ed.), Fiscal Policies and the American Economy (New York: Prentice-Hall, Inc., 1951). JOURNAL [VOL. I V wide divergence results from the use of both different tax totals and income bases. The difference between our average effective rate and that of the Colm-Tarasov estimate needs no detailed explanation, as it reflects largely the higher level of tax rates in the later period. But a reconciliation with the Adler ratio is required. Our tax total amounts to $57.3 billion as against $49.5 billion for the Adler study. This is due in part to differences in the yield total for the two time periods and in part to the fact that the tax total used in this study includes accrued income taxes whereas the Adler figure is based on collections. Part of the difference in the income base is again due to the difference in time period, but the remainder is due to a difference in the underlying sources of income estimate. The Adler study uses the estimate for personal income by the Department of Commerce, whereas the present study uses the S.R.C. income total. In order to facilitate a comparison with the Adler study, our effective rate schedule was recomputed, using the Department of Commerce income estimate. On this basis, the average effective rate for our standard case is reduced from 29.2 per cent to 24.7 per cent. In Chart III and Table 18 our result for the standard case is shown on both the S.R.C. and the Department of Commerce income base. As far as imputations to income are concerned, there appear to be no major differences between Adler's method and ours. (b) Difference in Shape of Effective Rate Curves.—The shape of the effective rate curve, as noted previously, depends considerably upon the shifting assumptions made with regard to the No. 1] TAX PAYMENTS BY INCOME GROUPS corporation income tax. As the other studies assume that there is no shifting of this tax, they should be compared for statistical compatibility with our noshifting assumption (Case C) rather than with our standard case. Accordingly, Case C, adjusted to the Commerce income base, is also included in 3 47 as the two periods considered and the two tax structures involved are rather similar. The source material and the description of methods presented in the Adler study do not permit a detailed and careful comparison, but it appears that the differences in the pattern for the tax system as a whole are due to T A B L E 18 COMPARISON OF EFFECTIVE TAX RATES FOR VARIOUS, STUDIES (In per cent) Spending Unit Income Brackets (Thousands of dollars) Study Under 1 1-2 Colm-Tarasov * Adler t Case A, unadjusted Case A, adjusted to commerce income Case C, adjusted to commerce income 2-3 3-4 4-5 5-7.5 7 5and IT ~ over Total 18.0 19.6 28.1 17.5 15.1 24.3 17.4 17.3 25.9 17.7 17.7 26.1 18.2 22.9 26.0 18.7 24.2 27.6 32.7 36.3 36.3 20.2 24.2 29.2 23.6 20.3 21.6 21.8 21.7 23.1 31.7 24.7 20.2 17.5 18.8 19.1 19.3 21.4 35.1 24.0 * For 1938-39. See Helen Tarasov, Who Does Pay the Taxest (Supplement IV, Social Research, 1942), p. 5. tFor 1946-47. See John Adler, "The Fiscal System, the Distribution of Income, and Public Welfare," in Kenyon E. Poole (ed.), Fiscal Policies arid the American Economy (New York: Prentice-Hall, Inc., 1951). the chart and table. The average effective rate for Case C, adjusted to Department of Commerce income, is 24.0 per cent, or about the same as Adler's. A study of Chart III and Table 18 shows a fair degree of similarity between the patterns of Case C and the Colm-Tarasov study. The fact that progression in our case begins sooner reflects the downward extension of the personal income tax; the higher level of rates through the middle income brackets similarly reflects the increased severity of personal income taxation. Adler's effective rate pattern, on the other hand, shows marked difference from that of Case C. This is surprising numerous differences in the distribution of particular taxes. One major source of divergence appears to result from differences in the consumption patterns used. The Adler study appears to rely on a smaller sample of B.L.S. data. Also our study uses a general pattern of consumer expenditure, derived from the S.R.C. data, while the Adler study appears to be based on B.L.S. data only. This may well account for the fact that the pattern shown in the Adler study is distinctly more regressive at the bottom of the scale. The greater progressivity of the Adler schedule over the $3,000 to $6,000 income range may reflect the alio- 0 48 X < LL. O \ V -A- E o T- J» oO ;=• to </> C > 2 C ^ ^ C I? = ° ° O I < < o CO -= P $ 0)O 0)w4)v> O ~T5 C o OO o o < o u o CL cn <D LU c r (<r < o LU ro ro o ro CM 'V- NATIONAL TAX JOURNAL CM (3IAI00NI JO 1N30 U3d SV XVI) 31VU 3AI103JJ3 ^ [VOL. I V o o Q: m g o o to N- O O 8 O O o <0 o o o lO o o ? o o o PO o o o CM O o o UJ o o s o z \tt No. 1] TAX PAYMENTS BY INCOME GROUPS cation of $4 billion of " miscellaneous " taxes on a proportional basis. Many of these taxes are of a regressive nature and have in our study been allocated according to specific expenditure patterns. 6. Conclusion In view of the above results, we may reappraise briefly the validity of the incidence picture as presented in section III. The estimated distribution of personal income tax liabilities should be rather accurate. While the assumption that there is no shifting of such liabilities may be open to debate, such shifting as occurred was hardly on a large scale; moreover, there is no basis on which to appraise the possible magnitude of such adjustments. The excise distribution is based on expenditure patterns which in turn had to be derived from rather incomplete B.L.S. data; however, the results obtained by using the more reliable S.R.C. pattern for total consumer expenditures are rather similar. This suggests, although it does not prove, that the errors involved in the excise allocation are not of major importance. The distribution of corporation tax payments provides much the greatest difficulty; and it is evident that the shifting assumptions chosen will affect considerably the shape of the final pattern of tax distribution. A further 3 49 difficulty arises from the inadequacy of data regarding the distribution of dividend income. The property tax problem is complicated by the dearth of data for the allocation of shifting components. However, experimentation with alternative allocations shows less difference in results than might be expected. Hence, the outcome seems fairly reliable. The allocation of payroll taxes again involves difficulties with regard to shifting assumptions; but the differences resulting from alternative assumptions are less serious than for the corporation tax, and the over-all weight of the payroll tax is much less. Finally, a major difficulty of interpretation arises at the bottom of the income scale, owing to the heterogeneous composition of the low spending unit income brackets. At the upper end of the scale no detailed breakdown is possible, since no adequate data for detailed income brackets in excess of $7,500 are available. While these difficulties must be kept in mind, it appears that the results are fairly adequate, if we are satisfied to accept the simplified framework of this analysis. But this is a big i f . The results become much less satisfactory when we recognize that any statistical measure of tax incidence is subject to the conceptual limitations set forth in the introductory section. APPENDIX 1. Notes on Table 1 "When the data shown are carried to more decimal Data for lines (1) through (6) were derived from the " 1948 Survey of Consumer Finances," by the Survey Research Center, University of Michigan. Most of the data were published in the Federal Reserve Bulletin, June through September, 1949, but some unpublished data were obtained from the S.R.C. P l a c e s t h a n a P P e a r i n t h e Published sources, such additional information was obtained directly from the S.R.C. Line 1: F.R.B., July, 1949, p. 780. Line 2: Determined as a residual. The S.R.C. percentage distributions for money income, savings, and JO NATIONAL TAX Federal personal income tax liability (S.R.C.) were converted into dollar distributions, using totals of $176.0, $12.0, and $16.0 billion respectively (S.R.C.). Dollar savings and tax liabilities for each income bracket were deducted from dollar income, and a further deduction was made for state personal income tax liabilities estimated on the basis of the Wisconsin law. The residual was then reconverted into a percentage distribution. Line 3: A percentage distribution of expenditures for the purchase of automobiles and a percentage distribution of expenditures for the purchase of all other durable goods were obtained directly from the S.R.C. These were combined into a weighted average, the weights being equal to $11.5 billion for autos and $7.5 billion for other durables (F.R.B., June, 1949, pp. 647 and 650). The S.R.C. distributions were furnished by deciles of spending units and had to be converted into distributions by spending unit income brackets as used in this study. Line 4: The S.R.C. data do not show a percentage distribution of housing expenditures by home owners. They do show housing expenditures of home owners as a percentage of their incomes (F.R.B., September, 1949, p. 1048). Since this information was given only for three broad income brackets, the first step was to estimate a corresponding distribution for our seven income brackets. Step number two was to estimate the dollar income distribution of home owners. Use was made of S.R.C. data showing the percentage of spending units in each income bracket who own their homes (F.R.B., September, 1949, p. 1040). By applying these percentages to the dollar distribution of money income (see explanation to line 2 above), a dollar distribution of money income by home owners was obtained. Step three was to multiply this money income in each income bracket by the percentage of income spent on housing, and thus to obtain a dollar distribution of housing expenditures by home owners from which the percentage distribution shown in line 4 could be derived. Line 5: The method of derivation was identical with that for line 4, except that data on renters rather than home owners were used. See the F.RJ$., September, 1949, p. 1040, for the percentage of renting families in each income bracket, and p. 1050 for the percentage of income spent for housing by renters. Note that for both lines 4 and 5 the original data are given for family units. Since ninetenths of the family units are single family spending units, the uncorrected application of this data to a spending unit distribution involves no significant error. Line 6: F.R3., August, 1949, p. 910. Lines 7 through 14: To properly allocate the forward-shifted portions of various taxes it was necessary to determine what proportion of expenditures for certain consumption items was made by each income class. The expenditure pattern developed in lines 7 through 14 is based on consumer budget JOURNAL [VOL. I V studies conducted by the U. S. Department of Labor during the years 1946 through 1948. The original data appear in (a) " Consumer Spending: Detroit, Denver, and Houston, 1948," Monthly Labor Review, December, 1949; (b) "Family Income and Expenditures in 1947, Washington, Richmond, and Manchester," Monthly Labor Review, April, 1949; and (c) " Survey of Prices Paid by Families, Milwaukee, Savannah, and Scranton," an unpublished report by the U. S. Department of Labor. These studies conducted during the years 1946 through 1948 were selected in preference to the more comprehensive studies undertaken in 1941 because they are more likely to accurately reflect the changed price and income relationships of the postwar years. Rural families are not included in the postwar studies. Some comparison of rural and urban spending habits, however, reveals no systematic differences for which adjustments could be readily made. No attempt was made to correct for the discrepancy arising out of the fact that this study is conducted in terms of spending units whereas the consumer budget studies surveyed family units. Nor was any attempt made to correct for the fact that although single person spending units are included in the S.R.C. distribution of spending units, the B.L.S. provides useful information only about family units of two or more persons. Any error introduced by this nonidentical treatment was not deemed to be sufficiently significant in this context to warrant working out a complicated conversion system. Since a single consumption pattern for the entire United States is required, the data from these budget studies were consolidated into a single pattern. For this purpose the size of each of the cities was determined according to the 1940 census. Each city pattern was then given a weight equal to the weight carried by a city of such size in the consumer price index prepared by the B.L.S. Since the size distribution of cities included in the B.L.S. surveys provided a fairly representative coverage of the range of cities included in the index, this weighting system appears to be fairly adequate. It is evident, however, that the estimated national expenditure pattern suffers from the fact that it was based on a rather small sample. Line 15: No direct information on the distribution of dividend income by spending units is available. An attempt was made to translate the 1947 dividend distribution by taxable income brackets (Treasury Press Service Release S-2171, November 25, 1949) into a similar distribution by spending unit income brackets. Since the Treasury distribution for 1948 was not available at the time of writing, it was necessary to assume that the distribution for 1948 would be similar to that for 1947. Step number one was to allocate the money income received in each spending unit income bracket to the various brackets of taxable income in which it comes to be declared. This involves making allow- No. 1] TAX PAYMENTS BY INCOME GROUPS ance for income splitting and other factors and is to a considerable extent a matter of judgment. The second step was to obtain from this crossclassification the total spending unit income falling into each taxable income bracket, and to derive for each taxable income bracket a percentage distribution of the total by spending unit income brackets. Step three was to distribute dollar dividend payments by taxable income brackets in accordance with the 1947 pattern. The total of dividend payments going to each taxable income bracket was then distributed among spending unit income brackets contributing to the taxable income bracket in accordance with the pattern developed in step two. The final step was to aggregate for each spending unit income bracket the dividend payments thus allocated to that bracket and from this to derive a percentage distribution of total dividend receipts by spending unit income brackets. Line 16: On a basis of Statistics of Income data (Treasury Release S-2171) it is estimated that between 85 per cent and 90 per cent of income below $5,000 represents wage and salary payments, and that 67 per cent and '37 per cent respectively would be appropriate estimates for the two upper income brackets used in this study. It was assumed, therefore, that 87.5 per cent of incomes up to $5,000 consisted of wages and salaries. An estimate of wage and salary income by income brackets was obtained by multiplying these percentages by the money income for each bracket. The figure for each bracket was then converted to a percentage of the total of all brackets. Line 17: The percentage of spending units in each income class that derive their income from employment covered by social security legislation was estimated using Low Income Families and Economic Stability, by the Joint Committee on the Economic Report, 1949, p. 86. Those units whose principal earner was clearly not covered by social security (e.g., retired, farmers, etc.) were eliminated. The percentage of units remaining multiplied by the wage and salary income in each income bracket (see line 16) resulted in a distribution of covered wage and salary income by income brackets. The figure for each bracket was then converted to a percentage of total for all brackets. In view of substantially higher rates applicable to railroad retirement and Civil Service retirement plans these were treated separately and assigned as though the unit contained a single earner. Government employees were assumed to bear full burden of Federal retirement plans. Line 18: Rental income was determined by translating the 1947 rental income distribution by taxable income brackets (Treasury Press Service Release S2171, November 25, 1949) into a similar distribution by spending unit income brackets. The method was analogous to that used in the determination of line 15. 3 51 2. Notes on Table 4 Excise taxes listed in Table 2 were assigned to specific consumption pattern items. The amounts so assigned were then allocated to spending units according to the consumption pattern developed in lines 7 through 14 of Table 1. The assignment of excises according to the consumption pattern classification is summarized in Table 19. Taxes such as those on food, alcohol, or tobacco are assigned directly to their corresponding items in the consumption pattern. Others involve more difficulty. For example, the automotive excises cannot simply be assumed to be borne by consumers in proportion to their expenditures on automotive transportation. A large part of the tax involves commercial vehicles. This portion of the tax becomes a cost of production to firms that use motor vehicles in their business. Thus, a part of the automotive excises appears in the price of nonautomotive products. It was estimated, after some consultation with the research departments of large automobile manufacturers, that 50 per cent of the automotive excises are subject to this sort of diffusion. The same ratio was used in the assignment of excises on electrical goods, insurance companies, and public utilities. The assignment of communication excises is the same as is made in studies by Mabel Newcomer (Annals of the American Academy of Political and Social Science, November, 1949, p. 56). These same studies suggested a basis for the apportionment of transportation excises. General sales taxes were distributed among appropriate consumption items in proportion to the relative importance of those items as a fraction of total consumer expenditures on taxed items. Customs duties, on the other hand, were distributed according to the general consumption pattern. It was assumed that 10 per cent of amusement taxes were paid by business firms. Although there is no evidence to support this, it seemed reasonable to recognize entertainment as a business expense. 3. Notes on Table 5 Let us first consider Case A, the standard case. Of total property taxes of $6,064 million, 80 per cent or $4,851 million, was assigned to real estate (line 9), and 20 per cent or $1,213 million was assigned to the personal property classification (line 16). This division is justified by the fact that the Bureau of Census shows that in 1940 the assessed value of real property was 80 per cent of the assessed value of all property (2950 Economic Almanac, NICB, p. 484); and that in 1948 in thirtyseven large cities the assessed value of real property constituted 81 per cent of the total (Large City Finances in 1948, City Finances; 1948, No. 3, Washington, D . C., September, 1949, p. 10, Table V ) . Further, the Department of Agriculture estimates that in 1948 farm real estate taxes were 85 per cent NATIONAL TAX JOURNAL 52 of total farm property taxes (1950 Economic Almanac, NICB, p. 190). The real estate component of the property tax, $4,851 million, was further divided into those parts falling on farms (lines 1 plus 2), business property (lines 3 plus 4 ) , rented homes (lines 5 plus 6), and owner-occupied homes (lines 7 plus 8). Of the $4,851 million tax on real property, $651 million was assumed to be a tax on farm land. This [VOL. I V remainder, $217 million, was assigned to improvements (line 2). After appropriate parts of the $4,851 million tax on real property had been assigned to farm, rented homes, and owner-occupied homes, there remained $965 million which was allocated to business property. This remainder of $965 million is simply a residual; no data are available for determining it directly. It was assumed that one-third of the real T A B L E 19 ALLOCATION OF EXCISE TAXES BY CONSUMPTION PATTERN ITEMS (In millions of dollars) Assignment to Consumption Pattern Items Excises by. Industry To- J ^ 1 0 £ t h e r Recrebacco T p ™ n f ation , T. F o o d Ll( uor * Hous- All ing other General Con - ™+ , Total Pattern Federal Taxes Alcohol Tobacco Automotive Amusement Transportation Communication Luxury Electrical Food Other Customs Total State and Local General sales Automotive Alcohol Tobacco Amusement Insurance Public utility Other Total 2,177 1,312 548 10 53 ioo 82 170 iis 1,312 601 44 .• 994 365 110 576 2,177 784 38 303 463 01 19 101 133 642 1,899 1,989 545 365 184 202 267 642 1, 34 1,890 6,093 995 165 165 784 583 7,912 i32 1,033 134 409 2,173 463 545 estimate is based on Department of Agriculture data (1950 Economic Almanac, NICB, p. 190). It was further assumed that two-thirds of the real estate tax on farm land falls on land and one-third on improvements. This is identical with the Tarasov estimate, and is substantiated by data in Studies in Income and Wealth, vol. 12, (NBER, 1946), p. 196. On this basis $434 million of the $651 million falling on farms was assigned to land (line 1), and the 197 i29 410 639 64 457 342 576 i33 2,177 1,312 1,279 640 610 512 463 265 115 129 410 134 estate tax on nonfarm land falls on land itself and that two-thirds falls on improvements. This again is identical with the Tarasov estimate. Thus, $322 million was assigned to business land (line 3), and $643 million was assigned to improvements on business property (line 4 ) . Of the $4,851 million, $1,235 million was assumed to fall on rented homes. This estimate is consistent with S.R.C. data, which show that somewhat lest No. 1] TAX PAYMENTS BY INCOME GROUPS than 50 per cent of all homes are rented (Federal Reserve Bulletin, September, 1949, p. 1040), and that therefore the tax on rented homes should be less than on owner-occupied residences. It is also reasonable to presume that rented homes are less valuable than owner-occupied homes, since the former tend to be occupied by spending units in the lower income brackets {ibid,). The $1,23J million was then divided so that one-third or $412 million fell on land (line 5), and two-thirds or $823 million fell on improvements (line 6). On the basis of an S.R.C. estimate, $2,000 million of the real property tax was assigned to owner-occupied homes (F.R.B., September, 1949, p. 1046). Again one-third or $670 million was assumed to fall on land (line 7), and the remainder, $1,330 million, was assumed to fall on improvements (line 8). The division of the tax on personal property among its several components presented the same sort of problem as did the division of the tax on real property. The task was complicated by the fact that even less information was available on which to base estimates of the proper breakdown. Of the $1,213 million representing the tax on personal property, the Department of Agriculture estimates that $115 million was paid by farmers (1950 Economic Almanac, NICB, p. 190). There was no basis for determining how much of this $115 million was properly a tax on tangibles, and how much on intangibles. In the absence of information, an equal break of this amount between tangibles and intangibles seemed the best procedure. The remainder of the $1,213 million tax on personal property was arbitrarily divided equally between business and individuals, $549 million being assigned to each. It was again assumed in each case that half the tax was on tangibles and half on intangibles. Thus $275 million was assigned to each of these categories (lines 10, 11, 14, and 15). The breakdown between tangibles and intangibles in the case of the tax on business firms is not important, since the entire tax is assumed to be shifted forward to consumers. On the other hand, the breakdown between business firms and individuals is important. Of the tax falling on individuals the part assigned to tangibles was assumed to be distributed on the same basis as the ownership of durable goods and the part assigned to intangibles to be distrbuted the same as 3 53 liquid assets. This is a more progressive allocation than that for the portion of the tax assumed to fall on business firms. Cases B and C, the progressive and regressive cases respectively, differ from the standard case in the assumptions regarding the distribution of the real property tax between rented homes and business property and in the distribution of the personal property tax between business firms and individuals. In addition, different assumptions are made regarding the amounts of real property tax assignable to land and improvements and in the amounts of the personal property tax assignable to tangibles and intangibles. In the progressive case, Case B, $93 5 million of the property tax was assumed to fall on rented homes, and $1,265 million was assumed to fall on business property. In both instances 40 per cent was assigned to land and 60 per cent to improvements. Thus, of the $93 5 million falling on rented homes, $374 million was assigned to land (line 5) and $561 million to improvements (line 6). Of the $1,265 million falling on business property, $506 million was assigned to land (line 3) and $759 million to improvements (line 4 ) . Instead of dividing the residual part of the personal property tax equally between individuals and business firms as in the standard case, in the progressive case $3 50 million was allocated to business firms and $750 million was allocated to individuals. Of the $3 50 million falling on business firms, onehalf or $175 million was assumed to fall on tangibles and one-half on intangibles (lines 10 and 11). Of the $750 million falling on individuals, 30 per cent or $225 million was assumed to fall on tangibles (line 14), and the remainder, $525 million, to fall on intangibles (line 15). In the regressive case $1,535 million of the real property tax was assumed to fall on rented homes, while only $665 million was allocated to business property. In both instances only 20 per cent was assumed to be assignable to land and 80 per cent to improvements. The personal property tax was divided so that $750 million fell on business firms and only $3 50 million on individuals. Again, the part paid by business firms was divided equally between tangibles and intangibles. Of the $3 50 million paid by individuals, 70 per cent was assumed to fall on tangibles and 30 per cent on intangibles.