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Form F. & 131 BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM nDffice Correspondence D a t e July 2 2 , 19t|0 To_ M r . Despres Subject; Economic Effects and Estimated From M r , Krost Yields of a Set of Tax Proposals Designed to Raise Revenue without Restricting Consumption. List of Proposals Proposals relating to corporation taxes: !• Enactment of an excess profits t a x . Excess profits should be defined as the excess of profits in the taxable year over the average of the best two out of the three years preceding the imposition of the t a x . I n order to avoid excessive taxation of corporations making losses or exceptionally small earnings in the base period the taxpayer should be allowed the option of substituting an amount equivalent to a 5 V e r cent return on invested capi- tal for the base as determined under the general rule. In order to prevent corporations having exceptionally high earnings in the base period from escaping the tax entirely the Government should have the option of substituting an amount equivalent to some reasonably high rate of return on invested capital for the base as computed under the general rule # The rates of t a x upon excess profits as thus defined should be high. Such a tax is needed at the present time in order to impose upon industry some sacrifice commensurate with the sacrifices that will be required from the broad masses of the people as a result of the introduction of conscription. It is needed to prevent the weakening of the •2' public morale that w i l l occur if the national defense program becomes an occasion for conspicuous increases in the number and amount of large private fortunes. It is also needed in order to reduce the growth in the public debt which 'will result from the defense expenditures unless the public revenues are appreciably increased. 2. A n increase in the corporate income tax rate from its present level of approximately 2 1 per cent to 25 per cent. The changes in individual income tax rates made by the Revenue Act of 19i|l have resulted in increases ranging from 25 per cent to 60 per cent in tax payments of individuals in the income range from 13,000 to §100,000. The incentive to leave corporate earnings undis- tributed has been appreciably increased. M i increase in the corporate income tax offers the only method of securing an appreciably increased contribution to our national defense effort from recipients of income able to take advantage of this method of tax-avoidance. Moreover, the corporation income tax provides a simple and effective method of collecting taxes at the source upon the incomes of the wealthiest 10 per cent of ^American families, a method that minimizes the possibilities of tax-avoidance and tax-evasion. She corporation income tax rate is now 37.5 per cent in the United Kingdom. It Germany it is now 0 per 6ent. Proposals relating to the estate and gift taxes; 3. (a) Inclusion of gifts during the life of the donor in the computation of the taxable estate; that i s , assessment of the estate tax on the total of estate passing at death plus gifts during life, w i t h a credit for gift taxes previously p a i d . -3- Under existing law the initial transfers made under a tax-avoidance program designed to transfer an appreciable part of an estate by gift avoid taxation at the highest rate of estate tax to w h i c h the estate would be subject by incurring taxation at the lowest rates of gift t a x . For example, a gift of $10,000 from an estate that w i l l amount to slightly more than $1,000,000 at the death of the donor avoids a prospective estate tax of $3,200 by paying a gift tax of only $150. The proposal is designed to equalize the tax treatment of property passing by gift and b y bequest. (b) Substitution for the present specific exemptions of |1|0,000 under the gift tax and |i|D,000 under the estate tax of an exemption of #10,000 to be applied to the total of estate passing at death plus gifts during life. (c) Elimination of the insurance exemption. (d) Increase of estate tax rates to raise more revenue from estates of moderate size. By making use of the |if.0,000 specific exemption under the gift t a x , the |I{.0,000 specific exemption, and the $lj.0,000 insurance exemption under the estate tax, an estate of f120,000, or $120,000 of any estate, no matter h o w large, m a y be transferred to heirs free of t a x . I n additional f80,000 m a y be transferred by gift subject to taxes of only f5,100. Under the British estate duty, the transfer of §200,000 w o u l d be exempt from tax to the extent of only fl|.00 and would involve taxes of $2lj.,000. Proposals relating to the individual income tax: ij.. Abolition of the privilege enjoyed by husbands and "wives of filing separate returns, with possible retention of the privilege for bona fide earned income of wives* Under existing law a net income of 11,000,000 a year pays income taxes of $718,000. If a husband can succeed, by transferring assets to his w i f e , in giving her a taxable income of $500,000 and reducing his own to $500,000, the taxes payable on the two incomes amount to only #660,000, a tax saving of #58,000. For an income of |60,000, the potential saving attributable to the separate filing privilege amounts to $8,000. Income utilized for the maintenance of a common household should be taxed as a single income, regardless of the fact that it m a y have nominally separate sources. The present state of the law repre- sents serious discrimination, both against single individuals and 1 against married persons with income derived solely from the husband s earnings. The practice of filing separate returns is so widely prevalent among high income families that the effectiveness of the progressive income tax is substantially impaired. Of the 5#908 married couples w i t h incomes of more than |100,000 a year in 1957» 5t58U filed separate returns and were taxed at considerably lower rates than applied to equivalent incomes received by couples without property income or received by single persons. 5« Substitution for the present system of personal exemptions and credit for dependents, applied against net income before computation -5- of t a x , of a system of flat credits, applied against the tax itself. The purpose of this proposal is to eliminate the differential subsidy to higher incomes involved in the present system. The #2,000 exemption for married persons is worth $1,580 (79 per cent of #2,000) in tax saving to a person with an income in excess of $5*000,000; it is worth only |80 (if. per cent of |2,000) to a person w i t h an income of 15f000. If subsidies of this type were paid by the Treasury in the form of cash outlays, the unjustified expense would be generally condemned; in their present form they are as costly and just as little justified as if they were paid in cash. A tax credit of #52 might be substituted for the present personal exemption of $800 for single person; a tax credit of |80 for the present personal exemption of $2,000 for married persons; and a tax credit of |16 for the tljDO credit for each dependent. The present rate of U per cent on surtax net income of tij.,000 to |6,000 might be lowered to 1 per cent in order to avoid a sharp increase in taxes for those w h o are now exempt from surtax b y only a small margin and for those w h o n o w p a y small surtaxes. 6. Repeal of the provisions restricting the rate of tax on long-term capital gains to a maximum of 15 per cent. Under the rates of the Revenue Act of 1940, an income of 150,000 derived wholly from wages or salaries pays income taxes of |lJ+, 1 2 8 . Under the existing procedure with respect t o the taxation of capital gains an income of #50,000 derived wholly from long-term capital gains need pay income taxes of only $7#500. The provision -6- that only 50 V e r cant of capital gains on assets held more than two years should be taken into account in computing net income constitutes adequate recognition of the difference between capital gains and other types of income; the present differentiation in the rate of tax is unnecessary. 7* Removal of t a x exemption from future issues of Federal, State and local Government securities. This proposal is opposed only by the comparatively small group of wealthy investors in tax-exempt securities and by State financial officers who believe that it would greatly increase the cost of borrowing to the States. Consideration should be given to a number of means of bringing pressure to bear upon the States to discontinue their opposition to this proposal: a) repeal of the legislation permitting the States to levy income taxes on the salaries of Federal employees, b) less generous allowance of credit for payment of State taxes under the estate tax and under the unemployment compensation tax, c) less generous Federal grants to States for public roads, old-age assistance, w o r k relief and m a n y other purposes. Estimated Yield of Proposals The following tables show the estimated yield of the existing t a x structure and of the proposals listed in this memorandum at varying levels of the national income. -7- TABLE 1 ESTIMATES OF YIELD OF THE EXISTING FEDERAL TAX STRUDTHHE (AS MODIFIED BY THE REVENUE A C T OF 1940) AM? OF THE PROPOSALS ADVANCED IN THIS MEMORANDUM, A T VARYING LEVELS OF THE NATIONAL INCOME l / (Billions of dollars) Tax revenues and other available funds EXISTING TAX STRUCTURE Income, estate, and gift taxes Other budgetary receipts Total budgetary receipts Net social security funds U . S . savings bonds Total funds available without open-market borrowing Additional yield from proposals of this ^ ^ m o r a n d u m 2/ National Income of Preceding Year w 7 S— i — s c — r 1.1 0.8 5.3 3.2 B.b 1.2 0.8 7.6 3.8 11.1; 2.1 0.9 10.3 4.3 14.6 2.5 0.9 8.2 10.5 1^.4 18.0 l.k 1.8 2.2* 3*0 3.5 2.8 l/ """ The amounts shown would be collected in the calendar years following the calendar years in which the national income reached the levels indicated. Estimates of fiscal year collections would differ only slightly from the estimates shown. For purposes of estimating transactions which have a predictable trend over t i m e , the calendar year in which these collections are made are assumed to be 19I4I (year following |70 billion national income), 19i|2 (year following |80 billion national income), 19^5 (year following |90 billion national income), and 19b5 (year following $100 billion national income). 2/ Estimates of the yield of each of the proposals are shown in Table 2 . -S- TABLE 2 REVENUE YIELD OF SE7ES PROPOSALS AOTAJTCED .IS THIS M M O R A H D I M , A T VARYING ^ Y E L S OF FATIOKAL INCOME l / (Millions of dollars) Fiscal year 191+1 Excess profits tax Increase in corporation income tax Estate and gift t a x changes Abolition of privilege of filing separate returns Substitution of flat tax credit for personal exemption Abolition of optional capital gains tax rate 2 / Total 3/ 300 National income of preceding year | 80 70 1 90 1 100 600 250 250 700 280 350 1+75 1,000 550 600 120 200 300 1*50 600 60 100 150 225 300 100 150 2,370 3,000 125 — — 605 — 1,1+00 — 1,780 800 320 l/ """ The figures shown are estimates of collections in calendar years following the calendar years during which the national income reaches the indicated levels. Security prices are assumed to be moving upward without serious break as national income increases and the general price level is assumed to be moving slowly upward without serious reversals in t r e n d . 2/ Since the yield of this proposal depends on its effect on the taking of capital 1 gains, which in turn depends largely on taxpayers views as to whether taxation of capital gains at high rates is to be temporary or permanent, the estimates of yield shown represent merely an indication that anappreciable yield is to be expected from this proposal at high levels of national income if taxpayers do not expect a decrease in the taxes on capital gains for a considerable number of years. 3/ "" The proposal to eliminate tax-exemption from Government securities applies only to future issues of such securities, and hence will yield a negligible amount of revenue in the immediate future.