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ANALYTICAL
PERSPECTIVES

BUDGET OF THE UNITED STATES GOVERNMENT

Fiscal Year 2001

THE BUDGET DOCUMENTS
Budget of the United States Government, Fiscal Year 2001
contains the Budget Message of the President and information on
the President’s 2001 budget proposals. In addition, the Budget includes the Nation’s third comprehensive Government-wide Performance Plan.
Analytical Perspectives, Budget of the United States Government, Fiscal Year 2001 contains analyses that are designed to highlight specified subject areas or provide other significant presentations
of budget data that place the budget in perspective.
The Analytical Perspectives volume includes economic and accounting analyses; information on Federal receipts and collections; analyses
of Federal spending; detailed information on Federal borrowing and
debt; the Budget Enforcement Act preview report; current services
estimates; and other technical presentations. It also includes information on the budget system and concepts and a listing of the Federal
programs by agency and account.
Historical Tables, Budget of the United States Government,
Fiscal Year 2001 provides data on budget receipts, outlays, surpluses or deficits, Federal debt, and Federal employment covering
an extended time period—in most cases beginning in fiscal year 1940
or earlier and ending in fiscal year 2005. These are much longer
time periods than those covered by similar tables in other budget
documents. As much as possible, the data in this volume and all
other historical data in the budget documents have been made consistent with the concepts and presentation used in the 2001 Budget,
so the data series are comparable over time.
Budget of the United States Government, Fiscal Year 2001—
Appendix contains detailed information on the various appropriations and funds that constitute the budget and is designed primarily
for the use of the Appropriations Committee. The Appendix contains
more detailed financial information on individual programs and appropriation accounts than any of the other budget documents. It
includes for each agency: the proposed text of appropriations language, budget schedules for each account, new legislative proposals,
explanations of the work to be performed and the funds needed,
and proposed general provisions applicable to the appropriations of

entire agencies or group of agencies. Information is also provided
on certain activities whose outlays are not part of the budget totals.
A Citizen’s Guide to the Federal Budget, Budget of the
United States Government, Fiscal Year 2001 provides general
information about the budget and the budget process for the general
public.
Budget System and Concepts, Fiscal Year 2001 contains an
explanation of the system and concepts used to formulate the President’s budget proposals.
Budget Information for States, Fiscal Year 2001 is an Office
of Management and Budget (OMB) publication that provides proposed
State-by-State obligations for the major Federal formula grant programs to State and local governments. The allocations are based
on the proposals in the President’s budget. The report is released
after the budget and can be obtained from the Publications Office
of the Executive Office of the President, 725 17th Street NW, Washington, DC 20503; (202) 395–7332.
AUTOMATED SOURCES OF BUDGET INFORMATION
The information contained in these documents is available in
electronic format from the following sources:
CD-ROM. The CD-ROM contains all of the budget documents and
software to support reading, printing, and searching the documents.
The CD-ROM also has many of the tables in the budget in spreadsheet format.
Internet. All budget documents, including documents that are
released at a future date, will be available for downloading in several
formats from the Internet. To access documents through the World
Wide Web, use the following address:
http://www.gpo.gov/usbudget
For more information on access to the budget documents, call (202)
512–1530 in the D.C. area or toll-free (888) 293–6498.

GENERAL NOTES
1.
2.

All years referred to are fiscal years, unless otherwise noted.
Detail in this document may not add to the totals due to rounding.

U.S. GOVERNMENT PRINTING OFFICE
WASHINGTON 2000
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, D.C. 20402–9328

1

TABLE OF CONTENTS
Page

Economic and Accounting Analyses
1.

Economic Assumptions .............................................................................................

3

2.

Stewardship: Toward a Federal Balance Sheet .....................................................

17

Federal Receipts and Collections
3.

Federal Receipts .......................................................................................................

47

4.

User Fees and Other Collections .............................................................................

93

5.

Tax Expenditures .....................................................................................................

107

Special Analyses and Presentations
6.

Federal Investment Spending and Capital Budgeting ..........................................

143

7.

Research and Development Funding ......................................................................

183

8.

Credit and Insurance ...............................................................................................

187

9.

Aid to State and Local Governments ......................................................................

241

10.

Federal Employment and Compensation ................................................................

257

11.

Strengthening Federal Statistics .............................................................................

263

Federal Borrowing and Debt
12.

Federal Borrowing and Debt ...................................................................................

269

Budget Enforcement Act Preview Report
13.

Preview Report .........................................................................................................

285

Current Services Estimates
14.

Current Services Estimates .....................................................................................

297

Other Technical Presentations
15.

Trust Funds and Federal Funds .............................................................................

343

16.

National Income and Product Accounts ..................................................................

361

17.

Comparison of Actual to Estimated Totals for 1999 ..............................................

367

18.

Relationship of Budget Authority to Outlays .........................................................

373

19.

Off-Budget Federal Entities and Non-Budgetary Activities .................................

375

20.

Outlays to Public, Net and Gross ............................................................................

379
i

ii

TABLE OF CONTENTS—Continued
Page

21.

Report on the Government-Wide Rescissions in the Consolidated Appropriations Bill, P.L. 106–113 ............................................................................................

381

Information Technology Investments
22.

Program

Performance

Benefits

from

Major

Information

Technology

Investments ...............................................................................................................

401

Federal Drug Control Funding
23.

Federal Drug Control Funding ................................................................................

441

Budget System and Concepts and Glossary
24.

Budget System and Concepts and Glossary ...........................................................

445

Federal Programs by Agency and Account
25.

Federal Programs by Agency and Account .............................................................

467

List of Charts and Tables ......................................................................................................

665

ECONOMIC AND ACCOUNTING ANALYSES

1

1.

ECONOMIC ASSUMPTIONS

Introduction
The prudent macroeconomic policies pursued since
1993 have fostered the healthiest economy in over a
generation. Budget surpluses have replaced soaring
deficits. During this Administration, fiscal policy has
been augmenting national saving, private investment,
productivity, and economic growth, rather than restraining them. Monetary policy has helped reduce inflation while supporting economic growth, and minimizing the domestic effect of international financial dislocations.
These sound policies have contributed to another year
of outstanding economic achievement—and hold the
promise of more successes to come. Real Gross Domestic
Product (GDP) rose 4.2 percent during 1999, the fourth
consecutive year that growth has been four percent or
more. The last time growth was this strong for so long
was in the mid-1960s.
Strong and sustained growth has created abundant
job opportunities and raised real wages. The Nation’s
payrolls expanded by 2.7 million jobs last year, bringing
the total number of jobs created during this Administration to 20.4 million. The unemployment rate during
the last three months of the year fell to 4.1 percent
of the labor force, the lowest level since January 1970,
and 3.2 percentage points lower than the rate in January 1993.
Despite robust growth and very low unemployment,
inflation has remained low. The Consumer Price Index
excluding the volatile food and energy components rose
only 1.9 percent last year, the smallest increase since
1965. The combination of low inflation and low unemployment pulled the ‘‘Misery Index,’’ defined as the sum
of the inflation and unemployment rates, to the lowest
level since 1965.
Households, businesses and investors have prospered
in this environment. Wage growth has outpaced inflation during each of the last four years, reversing a
two-decade decline in real earnings. In 1998, the poverty rate fell to the lowest level since 1980. Although
the poverty rate for 1999 will not be known until later
this year, another decline is likely in light of the economy’s strong job gains and declining unemployment. The
healthy economy boosted consumer optimism last year
to the highest level on record.
Businesses’ confidence in the future is evident in a
willingness to invest heavily in new, capacity-enhancing
plant, equipment and software. During the past seven
years, equipment and software spending has risen at
a double-digit pace, spurred by purchases of high-tech
capital. Rapid growth of investment has helped return
labor productivity growth to rates not seen since before
the first oil crisis in 1973. Rapid productivity growth

has enabled firms to achieve healthy increases in profits, and to raise real wages while still holding the line
on prices.
Forward-looking financial markets have responded to
these developments. The bull market in equities that
began in 1994 continued in 1999. These past five years
have recorded the largest percentage gains in stock
prices in the postwar period. From December 31, 1994
to December 31, 1999, the Dow Jones Industrial Average rose 200 percent; the S&P 500 gained 220 percent;
and the technology-laden NASDAQ soared 441 percent.
During January, the Dow and the NASDAQ edged into
record territory and the S&P 500 remained close to
its record high.
Short- and long-term interest rates rose during 1999
in response to the increased demand for credit that
accompanied strong private-sector growth and the Federal Reserve’s tightening of monetary policy. Even so,
long-term interest rates during 1998 and 1999 were
still lower than in any year during the prior three
decades. The real long-term interest rate (the nominal
rate minus expected inflation), an important determinant of investment decisions, was also lower in these
two years than in any other two-year period since 1980.
As 2000 began, financial and nonfinancial market indicators were signaling that the economic outlook remains healthy.
The economy has outperformed the consensus forecast during the past seven years, and the Administration believes that it can continue to do so if sound
fiscal policies are maintained. However, for purposes
of budget planning, the Administration continues to
choose projections that are close to the consensus of
private forecasters. The Administration assumes that
the economy will grow between 2.5 and 3.0 percent
yearly through 2010, while unemployment, inflation
and interest rates are projected to remain relatively
low.
Even with the moderation in growth, the economy
is expected to generate millions of new jobs. The unemployment rate, which by mainstream estimates is below
the level consistent with stable inflation, is projected
to edge up slightly until mid-2003. Thereafter, it is
projected to average a relatively low 5.2 percent, the
middle of the range that the Administration estimates
is consistent with stable inflation in the long run. The
Consumer Price Index (CPI), which rose 2.7 percent
during 1999 because of rapidly rising energy prices,
is projected to slow slightly in the next two years and
then increase 2.6 percent per year on average through
2010. Short- and long-term interest rates are expected
to remain in the neighborhood of the levels reached
at the end of 1999.

3

4

ANALYTICAL PERSPECTIVES

As of December, this business cycle expansion had
lasted 105 months since the trough in March 1991.
If the expansion continues through February, as seems
highly likely, it will exceed the previous longevity
record of 106 months set by the Vietnam War expansion of the 1960s. If macroeconomic policies continue
to foster high investment without engendering inflationary pressures, there is every reason to believe that
this expansion will continue for many more years.
This chapter begins with a review of recent developments, and then discusses two statistical issues: the
recent methodological improvements in the calculation
of the Consumer Price Index, which slowed its rise;
and the October comprehensive revisions to the National Income and Product Accounts, which incorporated computer software as a component of investment, among other changes. The chapter then presents
the Administration’s economic projections, followed by
a comparison with the Congressional Budget Office’s
projections. The following sections present the impact
of changes in economic assumptions since last year on
the projected budget surplus, and the cyclical and structural components of the surplus. The chapter concludes
with estimates of the sensitivity of the budget to
changes in economic assumptions.
Recent Developments
The outstanding performance of the economy is due
to a combination of several factors. First, macroeconomic policies have promoted strong growth with
low inflation. Second, thanks in part to robust investment and new, high-tech means of communicating and
doing business, labor productivity growth in the last
four years has approached 3 percent per year—double
the rate that prevailed during the prior two decades,
and comparable to the high rates achieved during the
first three decades following World War II. Third, inflation has been restrained by recession in much of the
world and by the rising exchange value of the dollar.
These forces together—plus intensified competition, including competition from foreign producers—have kept
down commodity prices and prevented U.S. producers
from raising prices. Finally, the labor market appears
to have changed in ways that now permit the unemployment rate to fall to lower levels without triggering
faster inflation.
Fiscal Policy: In 1992, the deficit reached a postwar
record of $290 billion, representing 4.7 percent of
GDP—and the prospects were for growing deficits for
the foreseeable future. When this Administration took
office in January 1993, it vowed to restore fiscal discipline. That goal has been amply achieved. By 1998,
the budget moved into surplus for the first time since
1969; and in 1999 it recorded an even larger surplus
of $124 billion. That is the largest surplus ever, and,
at 1.4 percent of GDP, it is the largest as a share
of the overall economy since 1951. This fiscal year, the
surplus is projected to rise to $167 billion, or 1.7 percent of GDP. The dramatic shift from huge deficits to

surpluses in the last seven years is unprecedented since
the demobilization just after World War II.
The historic improvement in the Nation’s fiscal position during this Administration is due in large measure
to two landmark pieces of legislation, the Omnibus
Budget Reconciliation Act of 1993 (OBRA) and the Balanced Budget Act of 1997 (BBA). OBRA enacted budget
proposals that the Administration made soon after it
came into office, and set budget deficits on a downward
path. The deficit reductions following OBRA have far
exceeded the predictions made at the time of its passage. OBRA was projected to reduce deficits by $505
billion over 1994–1998. The actual total deficit reduction during those years was more than twice that—
$1.2 trillion. In other words, OBRA and subsequent
developments enabled the Treasury to issue $1.2 trillion
less debt than would have been required under previous
estimates.
While OBRA fundamentally altered the course of fiscal policy towards lower deficits, it was not projected
to eliminate the deficit; without further action, deficits
were expected to begin to climb once again. To prevent
this and bring the budget into unified surplus, the Administration negotiated the Balanced Budget Act with
the Congress in the summer of 1997. The BBA was
not expected to produce surpluses until 2002, but like
OBRA, the results of pursuing a policy of fiscal discipline far exceeded expectations. The budget moved
into surplus in 1998, four years ahead of schedule, and
achieved an even larger surplus in 1999. OBRA 1993
and BBA 1997, together with subsequent developments,
are estimated to have improved the unified budget balance compared with the pre-OBRA baseline by a cumulative total of $6.7 trillion over 1993–2005.
The better-than-expected budget results in recent
years have contributed to the better-than-expected economic performance. Lower deficits and bigger surpluses
helped promote a healthy, sustainable expansion by reducing the cost of capital, through both downward pressure on interest rates and higher prices for corporate
equities. A lower cost of capital stimulated business
capital spending, which expanded industrial capacity,
boosted productivity growth, and restrained inflation.
Rising equity prices also increased household wealth,
optimism, and spending. The added impetus to consumer spending created new jobs and business opportunities. The faster-growing economy, in turn, boosted incomes and profits, which fed back into an even
healthier budget.
Though the benefits of fiscal discipline have been
widely recognized, the surprise in recent years has been
the magnitude of the positive impact on the economy.
Growth of production, jobs, incomes, and capital gains
have all exceeded expectations. The outstanding economic performance during this Administration is proof
positive of the lasting benefits of prudent fiscal policies.
Monetary Policy: During this expansion, the Federal
Reserve tightened policy when inflation threatened to
pick up, but eased when the expansion risked stalling
out. In 1994 and early 1995, the monetary authority

1.

ECONOMIC ASSUMPTIONS

raised interest rates when rapid growth threatened to
cause inflationary pressures. During 1995 and early
1996, however, the Federal Reserve reduced interest
rates, because the expansion appeared to be slowing
while higher inflation no longer threatened. From January 1996 until the fall of 1998, monetary policy remained essentially unchanged; the sole adjustment was
a one-quarter percentage point increase in the federal
funds rate target in March 1997 to 51⁄2 percent.
During the second half of 1998, however, financial
turmoil abroad threatened to spread to the United
States. In addition, a large, highly leveraged U.S. hedge
fund, which had borrowed heavily from major commercial and investment banks, nearly failed. In this environment, normal credit channels to even the most credit-worthy private businesses were disrupted. In response to these serious challenges to the financial system and the economy, the Federal Reserve quickly
shifted policy by cutting the Federal funds rate by onequarter percentage point on three occasions in just
seven weeks—the swiftest easing since 1991, when the
economy was just emerging from recession. By early
1999, those actions had restored normal credit flows
and risk spreads among credit market instruments and
returned the stock market to its upward trajectory.
With the return of financial market stability and
amidst an environment of strong growth and falling
unemployment, the Federal Reserve raised the Federal
funds rate by one-quarter percentage point on three
separate occasions during 1999, returning the rate to
the 51⁄2 percent level that prevailed before the 1998
international financial dislocation.
Real Growth: The economy expanded at a 3.7 percent annual rate over the first three quarters of 1999,
and rose at an even faster 5.8 percent pace during
the fourth quarter. Over the four quarters of the year,
real GDP increased 4.2 percent, the fourth year in a
row of robust growth exceeding 4.0 percent.
The fastest growing sector last year was again business spending on new equipment and software, which
rose 11.0 percent during 1999. The biggest gains continued to be for information processing and software, with
added impetus from the need to upgrade systems to
be Y2K compliant. Investment in new structures, in
contrast, edged down during 1999.
The exceptionally strong growth of spending for new
equipment and software in recent years raised trend
productivity growth. This helped to keep inflation in
check by permitting firms to grant real wage increases
without putting upward pressure on prices. The increase in productive capacity resulting from robust capital spending also eased the supply bottlenecks and
strains that normally would accompany tight labor markets. In the fourth quarter of 1999, the manufacturing
operating rate was below its long-term average, even
though the unemployment rate was unusually low.
Overall industrial capacity rose by more than 4 percent
in each of the past six years—the fastest sustained
increase in capacity in three decades.

5
The consumer sector, which accounts for two-thirds
of GDP, made a significant contribution to last year’s
rapid growth, as it did in the previous two years. Consumer spending after adjustment for inflation rose 5.4
percent over the four quarters of 1999, the largest increase in a quarter century. Thanks to low unemployment, rising real incomes, extraordinary capital gains
from the booming stock market and record levels of
consumer confidence, households have the resources
and willingness to spend heavily, especially on discretionary, big-ticket purchases. For example, sales of cars,
minivans and other light-weight trucks reached nearly
17 million units last year, a new record.
In 1999, growth of consumer spending again outpaced
even the strong growth of disposable personal income,
pulling down the saving rate to 2.4 percent, the lowest
level in the postwar period. Because of the enormous
increase in household wealth created by the soaring
stock market, households felt confident enough to boost
spending by reducing saving out of current income.
Partly because of rising wealth, households took on
considerably more debt. As a consequence, household
debt service payments as a percent of disposable personal income rose from 11.7 percent at the end of 1992
to 13.4 percent in the third quarter of 1999. However,
the ratio of debt service to income was still 3⁄4 percentage point below its prior peak, suggesting that the
household sector on average was not overextended, especially considering the rapid rise in household equity
wealth.
The same factors spurring consumption pushed new
and existing home sales during 1999 to their highest
level since record-keeping began. The homeownership
rate reached a record 66.8 percent last year. Buoyant
sales and low inventories of unsold homes provided a
strong incentive for new construction. Housing starts,
which were already at a high level in 1998, increased
further last year to the highest level since the mid1980s. Residential investment, after adjustment for inflation, increased during the first half of the year but
edged down during the second half, reflecting the peak
in housing starts early in the year.
As a result of the healthier fiscal position of all levels
of government, spending by the government sector rose
more rapidly than it has in recent years. State and
local consumption spending after adjustment for inflation rose 4.6 percent last year, while Federal Government spending increased 5.3 percent.
The foreign sector was the primary restraint on GDP
growth in 1999, as during the prior two years. Although
the economic recovery of our trading partners boosted
our exports, this positive contribution to GDP growth
was more than offset by the very rapid rise of imports
that accompanied the exceptionally strong growth of
U.S. domestic demand. Over the year, exports of goods
and services after adjustment for inflation rose 4.0 percent, while imports soared 13.1 percent. As a result,
the net export balance widened considerably, and restrained real GDP growth by an average of 1.2 percentage points per quarter—a larger drag on growth than

6
during the two previous years when recessions abroad
dramatically curtailed U.S. exports. The trade-weighted
value for the dollar, which had risen strongly in recent
years, was little changed, on average, during 1999.
However, the dollar depreciated 7 percent against the
Japanese yen, while it appreciated 15 percent against
the newly launched Euro.
Labor Markets: At the start of the year, most forecasters had expected growth to slow significantly and
the unemployment rate to rise. Instead, the economy
continued to expanded at a rapid pace, pulling the unemployment rate down from 4.3 percent at the end
of 1998 to 4.1 percent during the last three months
of 1999. When the Administration took office, the unemployment rate was 7.3 percent. In December, forty-five
States had unemployment rates of 5.0 percent or less;
rates in the other five were between 5.1 and 6.1 percent. Significantly, all demographic groups have participated in the improved labor market. The unemployment
rates for Hispanics and Blacks during 1999 were the
lowest on record.
The Nation’s payrolls expanded by a sizeable 2.7 million jobs last year. As in 1998, employment did not
increase in all industries; mining and manufacturing,
which are especially vulnerable to adverse developments in international trade, lost jobs. However, a
greater number of jobs were created in the private service sector, construction, and State and local government. The abundance of employment opportunities last
year kept the labor force participation rate at the
record-high level set in 1997 and 1998, and pulled up
the employment/population ratio to the highest level
ever.
Inflation: Despite continued rapid economic growth
and the low unemployment rate, inflation remained low
last year, and the ‘‘core’’ rate even slowed. The core
CPI, which excludes the volatile food and energy components, rose just 1.9 percent over the 12 months of 1999,
down from 2.4 percent during 1998. Last year’s rise
in the core rate was the smallest since 1965. However,
because of a sharp rise in energy prices, driven to a
considerable extent by international economic recovery,
the total CPI rose 2.7 percent last year—up from 1.6
percent during 1998, when energy prices fell substantially.
The broader GDP chain-weighted price index rose
just 1.6 percent during 1999, not much higher than
the 1.1 percent during the four quarters of 1998. This
is the smallest two-year rise in overall prices since
1962–63. The favorable inflation performance was the
result of intense competition, including from imports;
very small increases in unit labor costs because of robust productivity growth; and perhaps structural
changes in the link between unemployment and inflation.
Last year, however, import and export prices exerted
less of a restraint on inflation than in prior years. Because of the overall stability of the dollar last year,
import prices other than petroleum were about un-

ANALYTICAL PERSPECTIVES

changed during 1999; by contrast, import prices had
been falling for several years in response to the dollar’s
rise. Moreover, the price of imported petroleum products doubled last year as a result of a recovery in
world demand and a cutback in OPEC production. On
the other side of the ledger, prices of exported goods
(a component of the GDP price index) were about unchanged during 1999, after having fallen in 1998; the
dollar’s stability enabled U.S. firms to avoid having
to cut prices to remain competitive.
Real wages grew again in 1999; but even with the
low unemployment, hourly earnings and the broader
measures of compensation rose slightly less during 1999
than in the prior year. Robust investment in new equipment contributed to unusually strong productivity
growth for this stage of an expansion, helping to restrain inflation by offsetting the nominal rise in labor
compensation. Unit labor costs rose at only a 1.8 percent annual rate during the first three quarters of 1998,
down from 2.1 percent during 1999.
The absence of any signs of a buildup of inflationary
pressures despite low and falling unemployment and
rapid growth has implications for the estimate of the
level of unemployment that is consistent with stable
inflation. This threshold has been called the NAIRU,
or ‘‘nonaccelerating inflation rate of unemployment.’’
Economists have been lowering their estimates of
NAIRU in recent years in keeping with the accumulating experience of lower unemployment without higher inflation, even after taking into account the influence
of temporary factors. The economic projections for this
Budget assume that NAIRU is in a range centered on
5.2 percent in the long run. That is the same rate
as in the Mid-Session Review published last June, but
0.1 percentage point less than estimated in the 2000
Budget assumptions, and 0.5 percentage point less than
in the 1997 Budget. Most private forecasters have also
reduced their estimates of NAIRU in recent years.
By the end of 1999, the unemployment rate was well
below the current mainstream estimate of the long run
NAIRU. The Administration’s forecast for real growth
over the next three years implies that unemployment
will return to 5.2 percent by the middle of 2003.
Statistical Issues
Statistical agencies must constantly improve their
measurement tools to keep up with rapid structural
changes in the U.S. economy. Last year, the Bureau
of Labor Statistics (BLS) implemented the latest in a
series of planned improvements to the Consumer Price
Index; and the Bureau of Economic Analysis (BEA)
made significant methodological and statistical changes
to the National Income and Product Accounts. On balance, these changes revised real GDP growth and labor
productivity growth significantly upward in recent
years.
Inflation: The CPI is not just another statistic. Perhaps more than any other statistic, it actually affects
the incomes of governments, businesses and households
via statutory and contractual cost-of-living adjustments.

1.

ECONOMIC ASSUMPTIONS

As such, recent improvements in measurement of the
CPI—which, on balance, have slowed its increase—have
significant impacts throughout the economy. Because
the CPI is used to deflate some nominal spending components of GDP as well as household incomes, compensation, and wages, a slower rise in the CPI translates directly into a faster measured real growth of
such key indicators as GDP, productivity, household
incomes and wages.
In recent years, considerable attention has been given
to estimating the magnitude of the bias in the CPI
and how best to reduce it. In December 1996, the Advisory Commission to Study the Consumer Price Index,
appointed by the Senate Finance Committee, issued its
recommendations on this subject.
Beginning in 1995, the Bureau of Labor Statistics
instituted a number of important methodological improvements to the CPI. Taken together, these changes
are estimated to result in about a 0.6 percentage point
slower annual increase in the index in 1999 and every
year thereafter compared with the methodologies and
market basket used in 1994. The most recent significant change, instituted beginning with the January
1999 CPI release, replaced the fixed-weighted
Laspeyres formula, which had been used to aggregate
lower level components of the CPI, with a geometric
mean formula for most such aggregates. A CPI calculated using geometric means more closely approximates a cost-of-living index. Unlike the fixed-weighted
aggregation, the geometric mean formula assumes consumer spending patterns shift in response to changes
in relative prices within categories of goods and services.
Also in 1999, BLS instituted new rotation procedures
in its sampling of retail outlets where it selects items
for price collection. The new procedures focus on expenditure categories rather than geographic areas,
thereby enabling the CPI to incorporate price information on new, high-tech consumer products in a more
timely fashion.
The next scheduled improvement will be an updating
of the consumption expenditure weights used in the
CPI effective with the release of the CPI for January
of 2002, when weights based on spending patterns in
1999–2000 will replace the current 1993–95 marketbasket weights. The BLS has announced that it will
update expenditure weights every two years thereafter.
It is expected that the shift to biennial updates of the
weights will have little impact on measured inflation.
For the Federal Government, slower increases in the
CPI mean that outlays for programs with cost-of-living
adjustments tied to this index or its components—such
as Social Security, Supplemental Security Income (SSI),
retirement payments for railroad and Federal employees, and Food Stamps—will rise at a slower pace, more
in keeping with true inflation, than they would have
without these improvements. In addition, slower growth
of the CPI will raise the growth of tax receipts because
personal income tax brackets, the size of the personal
exemptions, and eligibility thresholds for the Earned

7
Income Tax Credit (EITC) are indexed to the CPI.
Thus, the methodological improvements made in recent
years act on both the outlays and receipts sides of the
budget to increase the budget surpluses.
For the National Income and Product Accounts, the
Bureau of Economic Analysis follows the convention
that changes in concepts and methods of estimation
are incorporated into the historical series whenever possible. In contrast, the Bureau of Labor Statistics (BLS)
follows the convention that the historical CPI series
is never revised. The reasoning is that the public is
probably better served by having an unchanged CPI
series for convenient use in contract escalation clauses
rather than one that is revised historically and might
trigger claims for payment adjustments with every revision.
The BLS, however, has recently published a research
CPI series (the CPI-RS) that backcasts the current
methods to 1978. (See ‘‘CPI Research Series Using Current Methods, 1978–98,’’ Monthly Labor Review, June
1999, for the series and an explanation of all the methodological improvements instituted since 1978.) This
methodologically consistent series shows a slower rise
in inflation, and therefore a faster rise in real measures, than the official CPI: during these 21 years, the
CPI-RS increased 4.28 percent per year on average compared with 4.73 percent for the CPI, a difference of
0.45 percentage point per year.
As discussed below, the National Income and Product
Accounts had already incorporated many of the improvements in methods that have been made over the
years in the CPI. The most recent significant improvement, the use of a geometric mean formula for combining lower level aggregates, was incorporated into the
October benchmark national accounts for the period
1977–94; this change was already in the national accounts for the period since 1994.
National Income and Product Accounts: In October, the BEA released a comprehensive revision of the
National Income and Product Accounts (NIPA), also referred to as a ‘‘benchmark’’ revision. These periodic revisions differ from the usual annual revisions in that
they are much wider in scope and include definitional,
methodological and classification changes in addition
to incorporation of new and revised source data. The
latest comprehensive revision significantly changed the
definition and estimates of nominal and real GDP, investment, and saving. (For details about the revision,
see the August, October and December, 1999 issues
of the Survey of Current Business.)
Real and Nominal GDP: The most significant definitional change was the recognition of business and
government expenditures on computer software (including the costs of in-house production of software) as investment, and therefore as a component of GDP and
the Nation’s capital stock. Until this revision, BEA had
treated software, except that embedded in other equipment, as if it were an intermediate good, and had not
counted it in GDP until it appeared as part of a final

8
product. Intermediate goods do not add directly to GDP;
capital goods do. (The Federal Government investment
estimates presented in Chapter 6 of this volume also
treat software as investment.)
The rapid growth of spending on software in recent
years has made a significant contribution to the new,
upwardly revised estimates of real GDP growth. Although real GDP growth was raised by 0.4 percentage
point per year on average during 1987–93 and by a
similar amount since then, the sources of the revision
differ greatly between the two periods. During 1987–93,
new definitions, notably the inclusion of spending on
computer software as a component of investment, boosted growth by only 0.1 percentage point. The downward
revision to inflation estimates, notably the incorporation of the geometric mean formula to estimate consumer price inflation, contributed another 0.3 percentage point. New source data did not make any contribution to the upward revision of real growth. In contrast,
during 1994–98, about 0.2 percentage point of the upward revision was due to the inclusion of computer
software; and another 0.2 percentage point was due
to revised source data. Revisions to inflation hardly
affected the estimate of real GDP growth.
The sources of the upward revision to nominal GDP
provide another perspective on the importance of including software in the definition of GDP. For calendar
year 1998, the benchmark revision in total raised nominal GDP by $249 billion, or 2.9 percent. Definitional
sources, primarily the new classification of software,
added $169 billion (2.0 percentage points). Statistical
sources (including new and revised source data, the
incorporation of the more recent input-output accounts,
and preliminary data from the 1997 economic census)
accounted for $80 billion (0.9 percentage point).
Saving: By including computer software spending as
investment, the comprehensive revisions boosted measured gross business saving (or undistributed profits and
capital consumption) but increased gross national saving much more than net national saving. That is because including software as investment also increases
capital consumption (depreciation) more than undistributed profits. In fact, most of the gross investment in
software, as measured in NIPA, goes to replace the
large amount of software that is annually ‘‘used up’’
or depreciated through technical obsolescence, as reflected in the short service lives. Therefore, net saving
is only a slightly larger share of Net Domestic Product
in recent years than it was in the previous data, and
for some prior years, in which capital consumption increased more as a result of the revision than did gross
saving, the revised net saving rate is smaller than it
was previously. It is only net saving and its counterpart, net investment, that adds to the Nation’s net capital stock.
In addition to defining software spending as part of
GDP, the comprehensive revisions made other changes
in the NIPA definitions. These did not have a noticeable
effect on nominal or real GDP or overall national saving; they did, however, affect measured saving of gov-

ANALYTICAL PERSPECTIVES

ernment and households. These definitional changes included:
• A shift in the classification of government employee pensions from the public sector to the private sector, which increased measured personal
saving, and reduced the NIPA government surplus
by an equal amount. (For an explanation of the
differences between the NIPA definition of the
Federal Government surplus and the unified surplus referred to in the Budget, see Chapter 16
of this volume.)
• Estate and gift taxes were reclassified as ‘‘capital
transfers.’’ This reduced government saving by reducing current receipts, and increased personal
saving by reducing personal taxes.
• Federal investment grants were also reclassified
as ‘‘capital transfers,’’ which increased Federal
saving by eliminating a category previously counted as a NIPA Federal government expenditure.
As a counterpart, the reclassification reduced
State and local government revenues and, therefore, the saving of that sector.
These changes affected the composition of saving,
shifting some saving from the government sector to the
household sector. The new methodology treats government employee pensions the same as private employee
pensions: the contributions to the pension programs are
treated as saving of the household sector; the earnings
on pension fund assets are treated as household income;
and the benefits paid by the pension funds are defined
as transfers within the household sector, not part of
government transfer payments. The net effect of these
changes is to raise the NIPA measures of personal saving while lowering the NIPA government surplus. The
previously reported nonoperating surplus of State and
local governments, which was composed in large part
of the difference between pension fund receipts and
payments, was nearly eliminated by this change.
Productivity: The upward revisions to real GDP
growth, and in particular, the even larger revisions to
the growth of output in the Nation’s nonfarm business
sector, have significantly raised measured labor productivity growth—especially beginning in 1994, because of
the inclusion of software spending and the revised
source data.
The Administration had already raised its projections
of real GDP and productivity growth in last summer’s
Mid-Session Review. The further increase in trend
growth of GDP and productivity in the 2001 assumptions presented below reflects the new information in
the benchmark revision that revealed that underlying
source data in recent years have been revised upward.
Productivity growth, which had averaged 1.4 percent
per year from 1994 through 1998, was revised up to
1.9 percent per year. During the four years through
the third quarter of 1999, the most recent quarter available, productivity growth averaged an even faster 2.7
percent per year. In other words, the recent growth
of productivity is double the pace experienced from 1973
to 1995, and on a par with the rapid rates that pre-

1.

9

ECONOMIC ASSUMPTIONS

vailed from the end of World War II until the first
oil crisis in 1973.
The growth of productivity would be even faster in
recent years if nonfarm business output were measured
from the income side of the national accounts (using
Gross Domestic Income) rather than from the slowergrowing GDP product side. Since the third quarter of
1995, gross domestic income in real terms has grown
0.4 percentage point per year faster than the growth
of GDP. That is because the statistical discrepancy—
the difference between the product and income sides
of the accounts—has shifted from $3 billion to –$141
billion over these four years. In principle, the product
and income sides of the accounts should be equal. In
practice, this does not occur because the two measures
are estimated from different source data. What is
unique about recent years, however, is the extent of
the difference and the magnitude of the swing. Although there is no perfect measure of productivity and
real growth, the income side perspective provides some

reason to believe that productivity and real growth recently may have been even stronger than the official
series suggest.
Economic Projections
The economy’s outstanding performance last year—
indeed, over the last seven years—and the maintenance
of sound policies raise the possibility that future economic developments may continue even better than assumed. Nonetheless, it is prudent to base budget estimates on a conservative set of economic assumptions,
close to the consensus of private-sector forecasts.
The economic assumptions summarized in Table 1–1
are predicated on the adoption of the policies proposed
in this Budget. The maintenance of unified budget surpluses in the coming years is expected to contribute
to continued favorable economic performance. Growing
Federal Government surpluses reduce real interest
rates, stimulate private-sector investment in new plant

Table 1–1. ECONOMIC ASSUMPTIONS 1
(Calendar years; dollar amounts in billions)
Actual
1998

Projections
1999

2000

8,760
8,516
102.9

9,232
8,850
104.3

9,685 10,156 10,621 11,105 11,644 12,236 12,847 13,477 14,118 14,777 15,471
9,142 9,393 9,629 9,870 10,146 10,451 10,758 11,064 11,360 11,655 11,958
105.9 108.1 110.3 112.5 114.8 117.1 119.4 121.8 124.3 126.8 129.4

5.9
4.6
1.1

5.2
3.8
1.4

4.8
2.9
1.9

4.6
2.6
2.0

4.6
2.5
2.0

4.5
2.5
2.0

5.0
3.0
2.0

5.1
3.0
2.0

4.9
2.9
2.0

4.9
2.8
2.0

4.7
2.6
2.0

4.7
2.6
2.0

4.7
2.6
2.0

5.5
4.3
1.2

5.4
3.9
1.4

4.9
3.3
1.6

4.9
2.7
2.0

4.6
2.5
2.0

4.6
2.5
2.0

4.9
2.8
2.0

5.1
3.0
2.0

5.0
2.9
2.0

4.9
2.8
2.0

4.8
2.7
2.0

4.7
2.6
2.0

4.7
2.6
2.0

Incomes, billions of current dollars:
Corporate profits before tax ...........................................
Wages and salaries ........................................................
Other taxable income 2 ...................................................

782
4,186
1,990

845
4,470
2,088

842
4,711
2,161

828
4,942
2,231

827
5,161
2,293

824
5,388
2,356

852
5,629
2,431

892
5,892
2,518

933
6,176
2,609

971
6,458
2,703

1,001
6,747
2,802

1,034
7,039
2,904

1,062
7,342
3,015

Consumer Price Index (all urban): 3
Level (1982–84 = 100), annual average ........................
Percent change, fourth quarter over fourth quarter ......
Percent change, year over year ....................................

163.1
1.5
1.6

166.7
2.7
2.2

171.0
2.3
2.6

175.1
2.5
2.4

179.6
2.6
2.6

184.3
2.6
2.6

189.1
2.6
2.6

194.0
2.6
2.6

199.0
2.6
2.6

204.2
2.6
2.6

209.5
2.6
2.6

215.0
2.6
2.6

220.6
2.6
2.6

4.4
4.5

4.1
4.2

4.3
4.2

4.7
4.5

5.1
5.0

5.2
5.2

5.2
5.2

5.2
5.2

5.2
5.2

5.2
5.2

5.2
5.2

5.2
5.2

5.2
5.2

2.8
2.8

3.6
3.6

4.8
4.8

3.7
3.7

3.7
3.7

3.2
3.2

3.2
3.2

3.2
3.2

NA
NA

NA
NA

NA
NA

NA
NA

NA
NA

4.8
5.3

4.7
5.6

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

5.2
6.1

Gross Domestic Product (GDP):
Levels, dollar amounts in billions:
Current dollars ................................................................
Real, chained (1996) dollars ..........................................
Chained price index (1996 = 100), annual average ......
Percent change, fourth quarter over fourth quarter:
Current dollars ................................................................
Real, chained (1996) dollars ..........................................
Chained price index (1996 = 100) ..................................
Percent change, year over year:
Current dollars ................................................................
Real, chained (1996) dollars ..........................................
Chained price index (1996 = 100) ..................................

Unemployment rate, civilian, percent:
Fourth quarter level ........................................................
Annual average ...............................................................
Federal pay raises, January, percent:
Military 4 ...........................................................................
Civilian 5 ..........................................................................
Interest rates, percent:
91-day Treasury bills 6 ....................................................
10-year Treasury notes ..................................................

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

NA = Not Available.
1 Based on information available as of late November 1999.
2 Rent, interest, dividend and proprietor’s components of personal income.
3 Seasonally adjusted CPI for all urban consumers.
4 Beginning with the 1999 increase, percentages apply to basic pay only; adjustments for housing and subsistence allowances will be determined by the Secretary of
Defense.
5 Overall average increase, including locality pay adjustments.
6 Average rate (bank discount basis) on new issues within period.

10
and equipment, boost productivity growth, and thereby
raise real incomes and help keep inflation under control. The Federal Reserve is assumed to continue to
pursue the goal of keeping inflation low while promoting growth.
The economy is likely to continue to grow during
the next few years, although at a more moderate pace
than during 1999. While job opportunities are expected
to remain plentiful, the unemployment rate is projected
to rise gradually to the range that mainstream privatesector forecasters estimate is consistent with stable inflation. New job creation will boost incomes and consumer spending, and keep confidence at a high level.
Continued low inflation will support economic growth.
Growth, in turn, will further help the budget balance.
Real GDP, Potential GDP and Unemployment:
During 2000, real GDP is expected to rise 2.9 percent,
then average 2.5 percent during the following three
years. This shift to more moderate growth recognizes
that by mainstream assumptions, growth must proceed
at a pace below the Nation’s potential GDP growth
rate for a while; the unemployment rate would then
rise somewhat, thereby avoiding a build-up of inflationary pressures. Beginning in 2004, real GDP growth
is assumed to match the growth of potential GDP. Inflation-adjusted potential and actual growth are projected
to moderate from 3.0 percent yearly during 2004–2005
to 2.6 percent during 2008–2010.
As has been the case throughout this expansion, business fixed investment is again expected to be the fastest-growing component of GDP, although capital spending is likely to slow from the double-digit pace of recent
years. Consumer spending is also expected to moderate,
as the stimulus from the soaring stock market of the
last few years approaches its full effect. Although residential investment is also expected to benefit from relatively low mortgage rates and strong demand for second homes for vacation or retirement, the high level
of housing starts in recent years and underlying demographic trends may tend to reduce future growth from
the pace of the last few years.
The growth of the Federal and State/local government
components of GDP is also projected to moderate from
the pace of recent years. The net export balance is
expected to be less of a restraint on growth this year
than during 1998–99, because more moderate growth
of domestic demand is expected to slow the growth of
imports. After 2000, the foreign sector is projected to
make a modest, positive contribution to GDP growth
in each year, reflecting the fundamental competitiveness of U.S. business, and the increased demand for
U.S. exports that is likely to accompany a sustained
recovery of activity abroad.
The real GDP growth projection is consistent with
a gradual rise in the unemployment rate to 5.2 percent
by mid-2003. The unemployment rate is then projected
to remain at that level on average thereafter, as real
GDP growth returns to the Administration’s estimate
of the economy’s potential growth rate.

ANALYTICAL PERSPECTIVES

Potential GDP growth depends largely on the trend
growth of labor productivity in the nonfarm business
sector and the growth of the labor force. Productivity
growth is assumed to moderate gradually from the high
rates of recent years. During 2000–2001, productivity
is projected to rise 2.1 percent annually on average,
then phase down to 1.8 percent (which is the average
rate experienced during the 1990s after allowance is
made for the procyclical behavior of productivity) from
2007 onwards. The productivity path in the projection
is a conservative estimate that allows the near-term
projection to rely more heavily on recent experience
and the longer-term projection to rely on the productivity experience over a longer period.
The labor force component of potential GDP growth
is assumed to rise 1.2 percent per year through 2007
and then slow to 1.0 percent yearly as the first of
the baby-boomers begin to retire.
Inflation: With the unemployment rate well below
mainstream estimates of the NAIRU, inflation is projected to creep up. The CPI is projected to increase
2.3 percent during this year, rising to 2.6 percent in
2002 and thereafter. The GDP chain-weighted price
index is projected to increase 1.9 percent during 2000,
and 2.0 percent thereafter.
The 0.6 percentage point difference between the CPI
and the GDP chain-weighted price index matches the
average difference between these two inflation measures during the past five years. The CPI tends to increase relatively faster than the GDP chain-weighted
price index in part because sharply falling computer
prices exert less of an impact on the CPI than on the
GDP price measure.
In the 2000 budget, this ‘‘wedge’’ between the two
measures was projected to be 0.2 percentage point. The
larger wedge assumed in this projection tends to reduce
the Federal budget surplus because Social Security payments and other indexed programs increase with the
faster-rising CPI, while Federal revenues are expected
to increase in step with the slower-rising GDP chainweighted price index. In addition, a relatively fasterrising CPI reduces the rate of growth of Federal receipts because the CPI is used to index personal income
tax brackets, the size of the personal exemptions, and
the eligibility thresholds for the Earned Income Tax
Credit.
Interest Rates: The assumptions, which were based
on information as of late November, project stable
short- and long-term interest rates. The 91-day Treasury bill rate is expected to average 5.2 percent over
the forecast horizon; the yield on the 10-year Treasury
bond is projected to average 6.1 percent. Since the completion of the assumptions, market rates have edged
up somewhat.
Incomes: On balance, the share of total taxable income in nominal GDP is projected to decline gradually.
This is primarily because the corporate profits share
of GDP is expected to fall. That is a consequence of

1.

11

ECONOMIC ASSUMPTIONS

the expected rapid growth of depreciation, a component
of business expenses. Robust growth of capital spending, especially on rapidly depreciating high-tech equipment and software, suggests that depreciation will account for an increasing share of GDP at the expense
of the corporate profits share. The personal interest
income share is also projected to decline, as interest
rates remain relatively low and as households hold less
Federal Government debt because of the projected unified budget surpluses. The share of labor compensation
in GDP is expected to be little changed.
Comparison with CBO
The Congressional Budget Office (CBO) prepares the
economic projections used by Congress in formulating
budget policy. In the executive branch, this function
is performed jointly by the Treasury, the Council of
Economic Advisers (CEA), and the Office of Management and Budget (OMB). It is natural that the two
sets of economic projections be compared with one another, but there are several important differences, along
with the similarities, that should be kept in mind. The
Administration’s projections always assume that the
President’s policy proposals in the budget will be adopted in full. In contrast, CBO normally assumes that
current law will continue to hold; thus, it makes a
‘‘pre-policy’’ projection. In recent years, and currently,
CBO has made economic projections based on a fiscal
policy similar to the budget’s. An additional source of

difference is that CBO and Administration forecasts are
finalized at somewhat different times.
Table 1–2 presents a summary comparison of the Administration and CBO projections. Briefly, they are very
similar for all the major variables affecting the budget
outlook.
Real growth and unemployment: Over the 10-year
projection horizon, the average rates of real GDP
growth projected by CBO and the Administration are
quite close. However, CBO projects somewhat faster
growth through 2003 than does the Administration,
while the Administration assumes somewhat faster
growth than CBO during the following four years. During the last three years of the projection period, CBO
projects a slight pickup in the growth rate to a faster
pace than that projected by the Administration.
These differences in real growth contribute to the
differences in the unemployment rate paths. While both
projections assume that the rate will gradually rise to,
and level off at, 5.2 percent, the Administration’s projection reaches this sustainable level in 2003 while
CBO’s projection reaches it in 2008.
Inflation: The Administration and CBO forecast the
same moderate rates of increase for the CPI for 2000
and 2001, and differ by only 0.1 percentage point thereafter, with the Administration higher. Over the same
period, both project low and steady rates of increase

Table 1–2. COMPARISON OF ECONOMIC ASSUMPTIONS
(Calendar years; percent)
Projections
2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

Real GDP
CBO January ........................................
2001 Budget ..........................................

2.9
2.9

3.0
2.6

2.7
2.5

2.6
2.5

2.6
3.0

2.7
3.0

2.7
2.9

2.7
2.8

2.8
2.6

2.9
2.6

2.9
2.6

Chain-weighted GDP Price Index: 1
CBO January ........................................
2001 Budget ..........................................

1.7
1.9

1.6
2.0

1.7
2.0

1.7
2.0

1.7
2.0

1.7
2.0

1.7
2.0

1.7
2.0

1.7
2.0

1.7
2.0

1.7
2.0

Consumer Price Index (all-urban): 1
CBO January ........................................
2001 Budget ..........................................

2.3
2.3

2.5
2.5

2.5
2.6

2.5
2.6

2.5
2.6

2.5
2.6

2.5
2.6

2.5
2.6

2.5
2.6

2.5
2.6

2.5
2.6

Unemployment rate: 2
CBO January ........................................
2001 Budget ..........................................

4.1
4.2

4.2
4.5

4.4
5.0

4.7
5.2

4.8
5.2

5.0
5.2

5.0
5.2

5.1
5.2

5.2
5.2

5.2
5.2

5.2
5.2

Interest rates: 2
91-day Treasury bills:
CBO January ....................................
2001 Budget .....................................

5.4
5.2

5.6
5.2

5.3
5.2

4.9
5.2

4.8
5.2

4.8
5.2

4.8
5.2

4.8
5.2

4.8
5.2

4.8
5.2

4.8
5.2

10-year Treasury notes:
CBO January ....................................
2001 Budget .....................................

6.3
6.1

6.4
6.1

6.1
6.1

5.8
6.1

5.7
6.1

5.7
6.1

5.7
6.1

5.7
6.1

5.7
6.1

5.7
6.1

5.7
6.1

Taxable income (share of GDP): 3
CBO January ........................................
2001 Budget ..........................................

79.9
79.6

79.3
78.8

78.6
78.0

78.0
77.2

77.5
76.5

77.1
76.0

76.8
75.6

76.4
75.2

76.1
74.7

75.8
74.3

75.4
73.8

(chain-weighted): 1

1 Percent

change, fourth quarter over fourth quarter.
averages, percent.
3 Taxable personal income plus corporate profits before tax.
2 Annual

12

ANALYTICAL PERSPECTIVES

for the GDP price index, with CBO’s projection 0.3 percentage point lower in each year, 2000–2010.
Interest rates: The Administration and CBO have
very similar paths for long- and short-term interest
rates. In 2000 and 2001, CBO’s rates are slightly higher; from 2003 onward, CBO’s are slightly lower.
Income shares: Although both projections envision
a decline in the total taxable income share of GDP,
primarily because of a decline in the profits share, the
CBO total taxable share is higher in every year, and
declines more slowly, than the Administration’s share.
Impact of Changes in the Economic
Assumptions
The economic assumptions underlying this budget are
similar to those of last year. Both budgets anticipated
that achieving a fundamental shift in fiscal posture
from large unified budget deficits to moderate unified
budget surpluses would result in a significant boost
in investment, which would serve to extend the economic expansion at a moderate pace while helping to
maintain low, steady rates of inflation and unemployment. The shift to unified budget surpluses and the
ensuing stronger investment were also expected to continue to have favorable effects on receipts and the budget balance, because of stronger profits, capital gains,
and high taxable incomes.
The changes in the economic assumptions since last
year’s budget have been relatively modest, as Table
1–3 shows. The differences are primarily the result of

economic performance in 1999 that has, once again,
proven more favorable than was anticipated at the beginning of last year. Economic growth was stronger
than expected in 1999, while inflation and unemployment were lower. Because of this favorable performance, the projected annual averages for the unemployment rate and GDP price index have again been reduced slightly this year—but conservatively. At the
same time, interest rates are assumed in this budget
to remain near their current low levels.
The net effects on the budget of these modifications
in the economic assumptions are shown in Table 1–4.
By far the largest effects come from higher receipts
during 2000–2005 resulting from higher nominal incomes. In all years through 2005, there are higher outlays for interest due to the higher interest rates in
the 2001 Budget assumptions than in the 2000 Budget
assumptions, and, in most years, higher outlays for
cost-of-living adjustments to Federal programs due to
higher CPI inflation assumptions. On net, the changes
in economic assumptions since last year increase unified budget surpluses by $61 billion to $85 billion a
year.
Structural vs. Cyclical Balance
When the economy is operating above potential, as
it is currently estimated to be, receipts are higher than
they would be if resources were less fully employed,
and outlays for unemployment-sensitive programs (such
as unemployment compensation and food stamps) are
lower. As a result, the deficit is smaller or the surplus

Table 1–3. COMPARISON OF ECONOMIC ASSUMPTIONS IN THE 2000 AND 2001
BUDGETS
(Calendar years; dollar amounts in billions)
1999

2000

2001

2002

2003

2004

2005

9,108
9,232

9,495
9,685

9,899
10,156

10,345
10,621

10,823
11,105

11,325
11,644

11,850
12,236

2.1
3.8

2.1
2.9

2.1
2.6

2.5
2.5

2.5
2.5

2.5
3.0

2.5
3.0

1.9
1.4

2.1
1.9

2.1
2.0

2.1
2.0

2.1
2.0

2.1
2.0

2.1
2.0

2.3
2.7

2.3
2.3

2.3
2.5

2.3
2.6

2.3
2.6

2.3
2.6

2.3
2.6

4.8
4.2

5.0
4.2

5.2
4.5

5.3
5.0

5.3
5.2

5.3
5.2

5.3
5.2

4.2
4.7

4.3
5.2

4.3
5.2

4.4
5.2

4.4
5.2

4.4
5.2

4.4
5.2

4.9
5.6

5.0
6.1

5.2
6.1

5.3
6.1

5.4
6.1

5.4
6.1

5.4
6.1

Nominal GDP:
2000 Budget assumptions 1 ..................
2001 Budget assumptions ....................
Real GDP (percent change): 2
2000 Budget assumptions ....................
2001 Budget assumptions ....................
GDP price index (percent change): 2
2000 Budget assumptions ....................
2001 Budget assumptions ....................
Consumer
Price
Index
(percent
change): 2
2000 Budget assumptions ....................
2001 Budget assumptions ....................
Civilian unemployment rate (percent): 3
2000 Budget assumptions ....................
2001 Budget assumptions ....................
91-day Treasury bill rate (percent): 3
2000 Budget assumptions ....................
2001 Budget assumptions ....................
10-year Treasury note rate (percent): 3
2000 Budget assumptions ....................
2001 Budget assumptions ....................
1 Adjusted

for October 1999 NIPA revisions.
quarter-to-fourth quarter.
3 Calendar year average.
2 Fourth

1.

13

ECONOMIC ASSUMPTIONS

Table 1–4. EFFECTS ON THE BUDGET OF CHANGES IN ECONOMIC ASSUMPTIONS SINCE
LAST YEAR
(In billions of dollars)
2000

2001

2002

2003

2004

2005

1,899.3
1,793.6

1,947.5
1,835.7

2,004.1
1,893.1

2,076.2
1,960.3

2,166.4
2,041.3

2,259.3
2,128.8

Unified budget surplus .......................................................
Changes due to economic assumptions:
Receipts ..........................................................................................
Outlays:
Inflation .......................................................................................
Unemployment ...........................................................................
Interest rates ..............................................................................
Interest on changes in borrowing .............................................

105.7

111.8

111.0

116.0

125.1

130.5

57.0

71.5

77.1

71.3

69.7

81.6

–1.8
–7.8
6.9
–1.4

–0.9
–7.7
12.2
–4.4

0.3
–3.5
13.2
–7.8

2.0
–0.7
12.5
–11.2

3.7
–0.9
11.5
–14.4

5.8
–1.1
9.9
–17.9

Total, outlay changes (net) ................................................

–4.1

–0.7

2.2

2.6

–0.2

–3.4

Increase in surplus .............................................................
Budget totals under 2001 Budget economic assumptions and
policies:
Receipts ..........................................................................................
Outlays ...........................................................................................

61.0

72.2

74.9

68.7

69.9

85.0

1,956.3
1,789.6

2,019.0
1,835.0

2,081.2
1,895.3

2,147.5
1,962.9

2,236.1
2,041.1

2,340.9
2,125.5

Unified budget surplus .......................................................

166.7

184.0

185.9

184.6

195.0

215.4

Budget totals under 2000 Budget economic assumptions and
2001 Budget policies:
Receipts ..........................................................................................
Outlays ...........................................................................................

Note: The surplus allocation for debt reduction is part of the President’s overall budgetary framework to extend the solvency
of Social Security and Medicare, and is shown in Tale S–1 in Part 6 of the 2001 Budget.

is larger than it would be if unemployment were at
the long-run NAIRU. The portion of the surplus or deficit that can be traced to this factor is called the cyclical
surplus or deficit. The remainder, the portion that
would remain with unemployment at the long-run
NAIRU (consistent with a 5.2 percent unemployment
rate), is called the structural surplus or deficit.
Changes in the structural balance give a better picture of the impact of budget policy on the economy
than do changes in the unadjusted budget balance. The
level of the structural balance also gives a clearer picture of the stance of fiscal policy, because this part
of the surplus or deficit will persist even when the
economy achieves permanently sustainable operating
levels.
In the early 1990s, large swings in net outlays for
deposit insurance (savings and loan and bank bailouts)
had substantial impacts on deficits, but had little concurrent impact on economic performance. It therefore
became customary to remove deposit insurance outlays
as well as the cyclical component of the surplus or

deficit from the actual surplus or deficit to compute
the adjusted structural balance. This is shown in Table
1–5.
For the period 1999 through 2002, the unemployment
rate is slightly below the long-run NAIRU of 5.2 percent, resulting in cyclical surpluses. Thereafter, unemployment is projected to equal the NAIRU, so the cyclical component of the surplus vanishes. Deposit insurance net outlays are now relatively small and do not
change greatly from year to year. Two significant points
are illustrated by this table. First, of the $415 billion
swing in the actual budget balance between 1992 and
1999 (from a $290 billion deficit to a $124 billion surplus), 44 percent ($181 billion) resulted from cyclical
improvement in the economy. The rest of the reduction
stemmed in major part from policy actions—mainly
those in the Omnibus Budget Reconciliation Act of
1993, which reversed a projected continued steep rise
in the unified budget deficit and set the stage for the
remarkable cyclical improvement that has occurred.
Second, the structural surplus is expected to rise sub-

Table 1–5. ADJUSTED STRUCTURAL BALANCE
(In billions of dollars)
1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

Unadjusted deficit (–) or surplus ......................
Cyclical component .......................................

–290.4
–106.1

–255.0
–106.1

–203.1
–73.0

–163.9
–30.9

–107.4
–13.1

–21.9
16.7

69.2
48.3

124.4
74.8

166.7
74.1

184.0
57.9

185.9
35.4

184.6
15.2

195.0
1.7

215.4
..........

Structural deficit (–) or surplus .........................
Deposit insurance outlays ............................

–184.3
–2.3

–148.9
–28.0

–130.1
–7.6

–133.0
–17.9

–94.3
–8.4

–38.6
–14.4

21.0
–4.4

49.6
–5.3

92.6
–1.4

126.1
–1.6

150.5
–1.3

169.5
–1.0

193.3
–0.7

215.4
0.2

Adjusted structural deficit (–) or surplus ..........

–186.6

–176.9

–137.7

–150.9

–102.7

–53.0

16.6

44.3

91.2

124.5

149.2

168.5

192.5

215.7

14

ANALYTICAL PERSPECTIVES

stantially over the projection horizon—in part due to
the effects of the Balanced Budget Act of 1997—even
though the cyclical component of the surplus is projected to vanish by 2005.
Sensitivity of the Budget to Economic
Assumptions
Both receipts and outlays are affected by changes
in economic conditions. This sensitivity seriously complicates budget planning, because errors in economic
assumptions lead to errors in the budget projections.
It is therefore useful to examine the implications of
alternative economic assumptions.
Many of the budgetary effects of changes in economic
assumptions are fairly predictable, and a set of rules
of thumb embodying these relationships can aid in estimating how changes in the economic assumptions
would alter outlays, receipts, and the surplus.
Economic variables that affect the budget do not usually change independently of one another. Output and
employment tend to move together in the short run:
a high rate of real GDP growth is generally associated
with a declining rate of unemployment, while moderate
or negative growth is usually accompanied by rising
unemployment. In the long run, however, changes in
the average rate of growth of real GDP are mainly
due to changes in the rates of growth of productivity
and labor supply, and are not necessarily associated
with changes in the average rate of unemployment.
Inflation and interest rates are also closely interrelated:
a higher expected rate of inflation increases interest
rates, while lower expected inflation reduces rates.
Changes in real GDP growth or inflation have a much
greater cumulative effect on the budget over time if
they are sustained for several years than if they last
for only one year.
Highlights of the budget effects of the above rules
of thumb are shown in Table 1–6.
If real GDP growth is lower by one percentage point
in calendar year 2000 only, and the unemployment rate
rises by one-half percentage point, the fiscal 2000 surplus would decrease by $10.5 billion; receipts in 2000
would be lower by about $8.5 billion, and outlays, primarily for unemployment-sensitive programs, would be
higher by about $2.0 billion. In fiscal year 2001, the
receipts shortfall would grow further to about $18.3
billion, and outlays would increase by about $6.8 billion
relative to the base, even though the growth rate in
calendar 2001 equals the rate originally assumed. This
effect grows because the level of real (and nominal)
GDP and taxable incomes would be permanently lower,
and unemployment higher. The budget effects (including growing interest costs associated with higher deficits or smaller surpluses) would continue to grow slightly in later years.
The budget effects are much larger if the real growth
rate is assumed to be one percentage point less in each
year (2000–2005) and the unemployment rate to rise
one-half percentage point in each year. With these assumptions, the levels of real and nominal GDP would

be below the base case by a growing percentage. The
budget balance would be worsened by $179.3 billion
relative to the base case by 2005.
The effects of slower productivity growth are shown
in a third example, where real growth is one percentage
point lower per year while the unemployment rate is
unchanged. In this case, the estimated budget effects
mount steadily over the years, but more slowly, resulting in a $145.5 billion worsening of the budget balance
by 2005.
Joint changes in interest rates and inflation have
a smaller effect on the budget balance than equal percentage point changes in real GDP growth, because
their effects on receipts and outlays are substantially
offsetting. An example is the effect of a one percentage
point higher rate of inflation and one percentage point
higher interest rates during calendar year 2000 only.
In subsequent years, the price level and nominal GDP
would be one percent higher than in the base case,
but interest rates are assumed to return to their base
levels. Outlays for 2000 rise by $5.8 billion and receipts
by $9.9 billion, for an increase of $4.1 billion in the
2000 surplus. In 2001, outlays would be above the base
by $11.9 billion, due in part to lagged cost-of-living
adjustments; receipts would rise $19.8 billion above the
base, however, resulting in a $7.8 billion improvement
in the budget balance. In subsequent years, the
amounts added to receipts would continue to be larger
than the additions to outlays.
If the rate of inflation and the level of interest rates
are higher by one percentage point in all years, the
price level and nominal GDP would rise by a cumulatively growing percentage above their base levels. In
this case, the effects on receipts and outlays mount
steadily in successive years, adding $50.4 billion to outlays and $117.3 billion to receipts in 2005, for a net
increase in the surplus of $66.9 billion.
The table shows the interest rate and the inflation
effects separately. These separate effects for interest
rates and inflation rates do not sum to the effects for
simultaneous changes in both. This occurs because,
when the unified budget is in surplus and some debt
is being retired, the combined effects of two changes
in assumptions affecting debt financing patterns and
interest costs may differ from the sum of the separate
effects, depending on assumptions about Treasury’s selection of debt maturities to retire and the interest
rates they bear. In any case, the sensitivity of the budget to interest rate changes has been greatly reduced
since the budget shifted into unified surplus. The last
entry in the table shows rules of thumb for the added
interest cost associated with changes in the unified
budget surplus.
The effects of changes in economic assumptions in
the opposite direction are approximately symmetric to
those shown in the table. The impact of a one percentage point lower rate of inflation or higher real growth
would have about the same magnitude as the effects
shown in the table, but with the opposite sign.

1.

15

ECONOMIC ASSUMPTIONS

These rules of thumb are computed while holding
the income share composition of GDP constant. Because
different income components are subject to different
taxes and tax rates, estimates of total receipts can be

affected significantly by changing income shares. However, the relationships between changes in income
shares and changes in growth, inflation, and interest
rates are too complex to be reduced to simple rules.

Table 1–6. SENSITIVITY OF THE BUDGET TO ECONOMIC ASSUMPTIONS
(In billions of dollars)

Budget effect
Real Growth and Employment
Budgetary effects of 1 percent lower real GDP growth:
For calendar year 2000 only: 1
Receipts ...................................................................................................
Outlays .....................................................................................................

2000

2001

2002

2003

2004

2005

–8.5
2.0

–18.3
6.8

–21.5
7.6

–22.4
9.4

–23.3
11.4

–24.3
13.5

Decrease in surplus (–) ......................................................................
Sustained during 2000–2005: 1
Receipts ...................................................................................................
Outlays .....................................................................................................

–10.5

–25.2

–29.1

–31.7

–34.6

–37.8

–8.5
2.0

–27.1
8.9

–49.5
16.7

–73.2
26.4

–98.7
38.5

–126.4
52.9

Decrease in surplus (–) ......................................................................
Sustained during 2000–2005, with no change in unemployment:
Receipts ...................................................................................................
Outlays .....................................................................................................

–10.5

–36.0

–66.1

–99.7

–137.2

–179.3

–8.5
0.2

–27.1
1.2

–49.5
3.4

–73.2
7.1

–98.7
12.3

–126.4
19.1

Decrease in surplus (–) ......................................................................
Inflation and Interest Rates
Budgetary effects of 1 percentage point higher rate of:
Inflation and interest rates during calendar year 2000 only:
Receipts ...................................................................................................
Outlays .....................................................................................................

–8.7

–28.3

–52.9

–80.3

–110.9

–145.5

9.9
5.8

19.8
11.9

19.2
9.5

17.6
8.3

18.3
7.9

19.3
7.7

Increase in surplus (+) .......................................................................
Inflation and interest rates, sustained during 2000–2005:
Receipts ...................................................................................................
Outlays .....................................................................................................

4.1

7.8

9.8

9.3

10.4

11.6

9.9
5.8

30.2
17.5

50.9
26.8

70.8
35.3

92.7
43.0

117.3
50.4

4.1

12.7

24.0

35.5

49.6

66.9

1.4
4.7

3.5
12.0

4.4
15.1

4.8
16.5

5.1
16.9

5.5
16.6

Decrease in surplus (–) ......................................................................
Inflation only, sustained during 2000–2005:
Receipts ...................................................................................................
Outlays .....................................................................................................

–3.4

–8.5

–10.7

–11.7

–11.8

–11.1

8.5
1.1

26.7
5.7

46.5
12.3

66.0
19.8

87.6
27.8

111.8
36.2

Increase in surplus (+) .......................................................................
Interest Cost of Higher Federal Borrowing
Outlay effect of $100 billion reduction in the 2000 unified surplus ...............

7.4

21.0

34.2

46.2

59.8

75.6

2.8

5.7

6.0

6.4

6.7

7.1

Increase in surplus (+) .......................................................................
Interest rates only, sustained during 2000–2005:
Receipts ...................................................................................................
Outlays .....................................................................................................

* $50 million or less.
1 The unemployment rate is assumed to be 0.5 percentage point higher per 1.0 percent shortfall in the level of real GDP.

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET
Introduction
A full evaluation of the Government’s financial condition must consider a broad range of data—more than
would usually be shown on a business balance sheet.
A balanced assessment of the Government’s financial
condition requires several alternative perspectives. This
chapter presents a framework for such analysis. No
single table in this chapter is ‘‘the balance sheet’’ of
the Federal Government. Rather, the chapter taken as
a whole provides an overview of the Government’s financial resources, the current and expected future
claims on them, and what the taxpayer gets in exchange for these resources. This is the kind of assessment for which a financial analyst would turn to a
business balance sheet, but expanded to take into account the Government’s unique roles and circumstances.
Because of the differences between Government and
business, and because there are serious limitations in
the available data, this chapter’s findings should be
interpreted with caution. The conclusions are tentative
and subject to future revision.
The presentation consists of three parts:
• The first part reports on what the Federal Government owns and what it owes. Table 2–1 summarizes this information. The assets and liabilities
in this table are a useful starting point for analysis, but they are only a partial reflection of the
full range of Government resources and responsibilities. Only those items actually owned by the
Government are included in the table; but Government’s resources extend beyond the assets defined
in this narrow way. Government can rely on taxes
and other measures to meet future obligations.
Similarly, while the table’s liabilities include all
of the binding commitments resulting from prior
Government action, Government’s full responsibilities are much broader than this.
• The second part presents possible paths for extending the Federal budget, beginning with an extension of the 2001 Budget. Table 2–2 summarizes
this information. This part offers the clearest indication of the long-run financial burdens that the
Government faces and the resources that will be
available to meet them. Some future claims on
the Government deserve special emphasis because
of their importance to individuals’ retirement

plans. Table 2–3 summarizes the condition of the
Social Security and Medicare trust funds and how
that condition has changed since 1998.
• The third part of the presentation features information on economic and social conditions which
the Government affects by its actions. Table 2–4
presents summary data for national wealth while
highlighting the Federal investments that have
contributed to that wealth. Table 2–5 presents a
small sample of economic and social indicators.
Relationship with FASAB Objectives
The framework presented here meets the stewardship
objective 1 for Federal financial reporting recommended
by the Federal Accounting Standards Advisory Board
and adopted for use by the Federal Government in September 1993.
Federal financial reporting should assist report users in
assessing the impact on the country of the Government’s
operations and investments for the period and how, as a
result, the Government’s and the Nation’s financial conditions have changed and may change in the future. Federal
financial reporting should provide information that helps the
reader to determine:
3a. Whether the Government’s financial position improved
or deteriorated over the period.
3b. Whether future budgetary resources will likely be sufficient to sustain public services and to meet obligations as
they come due.
3c. Whether Government operations have contributed to
the Nation’s current and future well-being.

The presentation here explores an experimental approach for meeting this objective at the Governmentwide level.
What Can Be Learned from a Balance Sheet
Approach
The budget is an essential tool for allocating resources within the Federal Government and between
the public and private sectors; but the standard budget
presentation, with its focus on annual outlays, receipts,
and the surplus/deficit, does not provide all the information needed for a full analysis of the Government’s
financial and investment decisions. A business may ultimately be judged by the bottom line in its balance
sheet, but for the National Government, the ultimate
test is how its actions affect the country.
1 Objectives of Federal Financial Reporting, Statement of Federal Financial Accounting
Concepts Number 1, September 2, 1993. The other objectives relate to budgetary integrity,
operating performance, and systems and controls.

17

18

ANALYTICAL PERSPECTIVES

QUESTIONS AND ANSWERS ABOUT THE GOVERNMENT’S ‘‘BALANCE SHEET’’
1. According to Table 2–1, the Government’s liabilities exceed its assets. No business could
operate in such a fashion. Why does the Government not manage its finances more like a
business?
Because the Federal Government is not a business. It has fundamentally different objectives,
and so must operate in different ways. The primary goal of every business is to earn a profit.
But in our free market system, the Federal Government leaves almost all activities at which a
profit could be earned to the private sector. In fact, the vast bulk of the Federal Government’s
operations are such that it would be difficult or impossible to charge prices for them—let alone
prices that would cover expenses. The Government undertakes these activities not to improve its
own balance sheet, but to benefit the Nation—to foster not only monetary but also nonmonetary
values. No business would—or should—sacrifice its own balance sheet to bolster that of the rest
of the country.
For example, the Federal Government invests in education and research. The Government earns
no direct return from these investments; but the Nation and its people are made richer. A
business’s motives for investment are quite different; business invests to earn a profit for itself,
not others. Because the Federal Government’s objectives are different, its balance sheet behaves
differently, and should be interpreted differently.
2. But Table 2–1 seems to imply that the Government is insolvent. Is it?
No. Just as the Federal Government’s responsibilities are of a different nature than those of a
private business, so are its resources. Government solvency must be evaluated in different
terms.
What the table shows is that those Federal obligations that are most comparable to the liabilities of a business corporation exceed the estimated value of the assets the Federal Government
actually owns. However, the Government has access to other resources through its sovereign
powers, which include taxation. These powers give the Government the ability to meet present
obligations and those that are anticipated from future operations.
The financial markets clearly recognize this reality. The Federal Government’s implicit credit
rating is the best in the United States; lenders are willing to lend it money at interest rates substantially below those charged to private borrowers. This would not be true if the Government
were really insolvent or likely to become so. Where governments totter on the brink of insolvency, lenders are either unwilling to lend them money, or do so only in return for a substantial
interest premium.
However, the Federal Government’s balance sheet was clearly worsened by the budget policies of
the 1980s. Under President Clinton, the deterioration in the balance sheet has been halted, and
as the budget has moved from deficit to surplus, the excess of Government liabilities over assets
has leveled off and begun to shrink both in real terms and relative to the size of the economy.
3. The Government does not comply with the accounting requirements imposed on private
businesses. Why does the Government not keep a proper set of books?
Because the Government is not a business, and its primary goal is not to earn profits or to enhance its own wealth, accounting standards designed to illuminate how much a business earns
and how much equity it has would not provide useful information if applied to the Government,
and might even be misleading. In recent years, the Federal Accounting Standards Advisory
Board has developed, and the Federal Government has adopted, a conceptual accounting framework that reflects the Government’s functions and answers the questions for which Government
should be accountable. This framework addresses budgetary integrity, operating performance,
stewardship, and systems and controls. The Board has also developed, and the Government has
adopted, a full set of accounting standards. Federal agencies are issuing audited financial reports that follow these standards; an audited Government-wide consolidated financial report has
been issued.

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

QUESTIONS AND ANSWERS ABOUT THE GOVERNMENT’S ‘‘BALANCE SHEET’’—Continued
This chapter addresses the ‘‘stewardship objective’’—assessing the interrelated condition of the
Federal Government and of the Nation. The data in this chapter are intended to illuminate the
trade-offs and connections between making the Federal Government ‘‘better off’’ and making the
Nation ‘‘better off.’’ There is no ‘‘bottom line’’ for the Government comparable to the net worth of
a business corporation. Some analysts may find the absence of a bottom line to be frustrating.
But pretending that there is such a number—when there clearly is not—does not advance the
understanding of Government finances.
4. Why is Social Security not shown as a liability in Table 2–1?
Providing promised Social Security benefits is a political and moral responsibility of the Federal
Government, but these benefits are not a liability in the usual sense. In the past, the Government has unilaterally decreased as well as increased Social Security benefits, and the Social Security Advisory Council has suggested further reforms that would alter future benefits if enacted
by Congress. When the amount in question can be changed unilaterally, it is not ordinarily considered a liability.
Furthermore, there are other Federal programs that are very similar to Social Security in the
promises they make—Medicare, Medicaid, Veterans pensions, and Food Stamps, to name a few.
Should the future benefits expected from these programs also be treated as liabilities? It would
be difficult to justify a different accounting treatment for them if Social Security were classified
as a liability of the Government. There is no bright dividing line separating Social Security from
other income-maintenance programs.
Finally, if future Social Security benefits were to be treated as liabilities, logic would suggest
that future Social Security payroll tax receipts that are earmarked to finance those benefits
ought to be considered assets. However, other tax receipts are not counted as assets; and drawing a line between Social Security taxes and other taxes would be questionable.
5. It is all very well to run a budget surplus now, but can it be sustained? When the babyboom generation retires, will the deficit not return larger and meaner than ever before?
The aging of the U.S. population, which will become dramatically evident when the babyboomers retire, poses serious long-term problems for the Federal budget and its major entitlement programs. However, the current budget surplus means the country will be better prepared
to address these problems. If the surplus is maintained, there will be a significant decline in
Federal debt which will substantially reduce Federal net interest payments. This is a key step
towards keeping the budget in balance when the baby-boomers retire.
The second part of this chapter and the charts that accompany it show how the budget is likely
to fare under various possible alternative scenarios.

19

20

ANALYTICAL PERSPECTIVES

QUESTIONS AND ANSWERS ABOUT THE GOVERNMENT’S ‘‘BALANCE SHEET’’—Continued
6. Would it be sensible for the Government to borrow to finance needed capital—permitting
a deficit in the budget—so long as it was no larger than the amount spent on Federal investments?
Probably not, first of all, the Government consumes capital each year in the process of providing
goods and services to the public. The rationale for using Federal borrowing to finance investment really only applies to net investment, after depreciation is subtracted, because only net investment augments the Government’s assets and offsets the increase in liabilities that result
from borrowing. If the Government financed all new capital by borrowing, it should pay off the
debt as the capital acquired in this way loses value. As discussed in Chapter 6 of Analytical Perspectives, net investment in physical capital owned by the Federal Government is estimated to
have been negative recently, so no deficit spending would actually be justified by this borrowingfor-investment criterion.
The Federal Government also funds substantial amounts of physical capital that it does not
own, such as highways and research facilities, and it funds investment in intangible ‘‘capital’’
such as education and training and the conduct of research and development. A private business
would never borrow to spend on assets that would be owned by someone else. However, such
spending is a principal function of Government. Chapter 6 shows that when these investments
are also included, net investment is estimated to be slightly positive. It is not clear whether this
type of capital investment would fall under the borrowing-for-investment criterion. Certainly,
these investments do not create Federally owned assets, even though they are part of national
wealth.
There is another hitch in the logic of borrowing to invest. Businesses expect investments to earn
a profit from which to repay the financing costs. In contrast, the Federal Government does not
generally expect to receive a direct payoff (in the form of higher tax receipts) from its investments, whether or not it owns them. In this sense, Government investments are no different
from other Government expenditures, and the fact that they provide services over a longer period is no justification for excluding them when calculating the surplus/deficit.
Finally, the Federal Government must pursue policies that support the overall financial and economic well-being of the Nation. In this broader context, the Government may need to manage its
fiscal policy to run a surplus, so as to augment private saving and investment even if this means
paying for its own investments from current revenues, instead of borrowing in the credit market
and crowding out private investment. Other considerations than the size of Federal investment
need to be weighed in choosing the appropriate level of the surplus or deficit.
7. Is it misleading to include the Social Security surplus when measuring the Government’s
budget surplus?
Experts say that the Federal budget has three purposes: to plan the Government’s fiscal program; to impose financial discipline on the Government’s activities; and to measure the Government’s effects on the economy. It should not be surprising that, with more than one purpose, the
budget is routinely presented in more than one way. For years, there have been several alternative measures of the budget, each with its appropriate use. None of these measures is always
right, or always wrong; it depends upon the purpose to which the budget is put.

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

QUESTIONS AND ANSWERS ABOUT THE GOVERNMENT’S ‘‘BALANCE SHEET’’—Continued
For the purpose of measuring the Government’s effects on the economy, it would be misleading
to omit any part of the budget; doing so would simply miss part of what we were trying to measure. For example, we would need to know all of the Government’s receipts and outlays to know
whether it will have the wherewithal to meet its future obligations—such as Social Security.
And for purposes of fiscal discipline, leaving out particular Government activities could be dangerous. In fact, the principle of a ‘‘unified,’’ all-inclusive budget was established by President
Johnson’s Commission on Budget Concepts largely to forestall a trend toward moving favored
programs off-budget—which had been done explicitly to shield those programs from scrutiny and
funding discipline.
To plan the government’s fiscal program, however, alternative perspectives can sometimes be
useful. In particular, by law, Social Security has been moved off-budget. The purpose was to
stress the need to provide independent, sustainable funding for Social Security in the long term;
and to show the extent to which the rest of the budget had relied on annual Social Security surpluses to make up for its own shortfall. Policy under this Administration has been consistent
with these goals. The non-Social Security deficit has been eliminated, and the President has
made long-term Social Security soundness a key priority.
In sum, the budget is like a toolbox that contains different tools to perform different functions.
There is a right tool for each task, but no one tool is right for every task. If we choose the right
tool for the job at hand, we can achieve our objectives.
8. What good does it do for the Federal Government to run a budget surplus, if the surplus
is only used to retire Government debt? Is this just another way of pouring the money down
the drain?
When the Government retires its debt, it is not pouring money down the drain. The Government
contributes to the accumulation of national wealth by using a budget surplus to repay Government debt. Because of the large budget deficits of the 1980s and early 1990s, Federal debt,
measured relative to the size of the economy, has reached levels not seen since the early 1960s,
although it is now on a downward trend. Further reducing the accumulated debt will have several desirable economic effects. It will help to hold down real interest rates, which is good for
business investment and home ownership. Lowering the debt will give the Government more
flexibility should it face an unexpected need to borrow in the future. When the Government uses
a budget surplus to reduce its debt, it adds to national saving. Even though the Government is
simply repaying its debt, the resources represented by the surplus are available for private investment in new plant and equipment, new homes, and other durable assets.

21

22
The data needed to judge Government’s performance
go beyond a simple measure of net assets. Consider,
for example, Federal investments in education or infrastructure whose returns flow mainly to the private sector and which are often owned by households, private
businesses or other levels of Government. From the
standpoint of the Federal Government’s ‘‘bottom line,’’
these investments might appear to be unnecessary or
even wasteful; but they make a real contribution to
the economy and to people’s lives. A framework for
evaluating Federal finances needs to take Federal investments into account, even when the return they earn
does not accrue to the Federal Government.
A good starting point for the evaluation of Government finances is to measure its assets and liabilities.
An illustrative tabulation of net liabilities is presented
below in Table 2–1, based on data from a variety of
public and private sources. It has sometimes been suggested that the Federal Government’s assets, if fully
accounted for, would exceed its debts. Table 2–1 clearly
shows that this is not correct. The Federal Government’s assets are less than its debts; the deficits in
the 1980s and early 1990s caused Government debts
to increase far more than Government assets.
But that is not the end of the story. The Federal
Government has resources that go beyond the assets
that appear on a conventional balance sheet. These include the Government’s sovereign powers to tax, regulate commerce, and set monetary policy. However, these
powers call for special treatment in financial analysis.
The best way to incorporate them is to make a longrun projection of the Federal budget (as is done in
the second part of this chapter). The budget provides
a comprehensive measure of the Government’s annual
cash flows. Projecting it forward shows how the Government is expected to use its powers to generate cash
flows in the future.
On the other side of the ledger are the Government’s
binding obligations—such as Treasury debt and the
present discounted value of Federal pension obligations
to Government employees. These obligations have counterparts in the business world, and would appear on
a business balance sheet. Accrued obligations for Government insurance policies and the estimated present
value of failed loan guarantees and deposit insurance
claims are also analogous to private liabilities, and are
included in Table 2–1 with other Government liabilities.

ANALYTICAL PERSPECTIVES

These formal obligations, however, are only a subset
of the Government’s financial responsibilities.
The Government has established a broad range of
programs that dispense cash and other benefits to individual recipients. The Government is not constitutionally obligated to continue payments under these
programs; the benefits can be modified or even ended
at any time, subject to the decisions of the Nation’s
elected representatives in Congress. Such changes are
a regular part of the legislative cycle. Allowing for the
possibility of such changes, however, it is likely that
many of these programs will remain Federal obligations
in some form for the foreseeable future. Again, the best
way to see how future responsibilities line up with future resources is to project the Federal budget forward
far enough in time to capture the long-run effects of
current and past decisions. Projections of this sort are
presented in part two below.
The budget, even when projected far into the future,
does not show whether the public is receiving value
for its tax dollars. Information on that point requires
performance measures for Government programs supplemented by appropriate information about conditions
in the economy and society. Some such data are currently available, but more need to be developed to obtain a full picture. Examples of what might be done
are also shown below.
The presentation that follows consists of a series of
tables and charts. All of them taken together function
as a balance sheet. The schematic diagram, Chart 2–1,
shows how they fit together. The tables and charts
should be viewed as an ensemble, the main elements
of which can be grouped together in two broad categories—assets/resources and liabilities/responsibilities.
• Reading down the left-hand side of Chart 2–1
shows the range of Federal resources, including
assets the Government owns, tax receipts it can
expect to collect, and national wealth that provides the base for Government revenues.
• Reading down the right-hand side reveals the full
range of Federal obligations and responsibilities,
beginning with Government’s acknowledged liabilities based on past actions, such as the debt held
by the public, and going on to include future budget outlays. This column ends with a set of indicators highlighting areas where Government activity
affects society or the economy.

23

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

Chart 2-1. A Balance Sheet Presentation For The Federal Government
Assets/Resources
Federal Assets
Financial Assets
Monetary Assets
Mortgages and Other Loans
Other Financial Assets
Less Expected Loan Losses
Physical Assets
Fixed Reproducible Capital
Defense
Nondefense
Inventories
Non-reproducible Capital
Land
Mineral Rights

Resources/Receipts
Projected Receipts

Liabilities/Responsibilities
Federal Liabilities

Federal
Governmental
Assets
and Liabilities
(Table 2-1)

Financial Liabilities
Debt Held by the Public
Miscellaneous
Guarantees and Insurance
Deposit Insurance
Pension Benefit Guarantees
Loan Guarantees
Other Insurance
Federal Pension Liabilities
Net Balance

Long-Run
Federal
Budget
Projections
(Table 2-2)

Change in Trust
Fund Balances
(Table 2-3)

Responsibilities/Outlays
Discretionary Outlays
Mandatory Outlays
Social Security
Health Programs
Other Programs
Net Interest
Deficit

National Assets/Resources
Federally Owned Physcial Assets
State & Local Physical Assets
Federal Contribution
Privately Owned Physical Assets
Education Capital
Federal Contribution
R&D Capital
Federal Contribution

National
Wealth
(Table 2-4)

Social
Indicators
(Table 2-5)

National Needs/Conditions
Indicators of economic, social,
educational, and environmental
conditions to be used as a guide
to Government investment and
management.

24

ANALYTICAL PERSPECTIVES

PART I—THE FEDERAL GOVERNMENT’S ASSETS AND LIABILITIES
Table 2–1 summarizes what the Government owes
as a result of its past operations netted against the
value of what it owns, for selected years beginning in
1960. Assets and liabilities are measured in terms of
constant FY 1999 dollars. Ever since 1960, Government
liabilities have exceeded the value of assets, but until
the early 1980s the disparity was relatively small, and
it was growing slowly (see chart 2–2).
In the late 1970s, a speculative run-up in the prices
of oil, gold, and other real assets temporarily boosted

the value of Federal holdings, but since then those
prices have declined. 2 Currently, the total real value
of Federal assets is estimated to be only about 18 percent greater than it was in 1960. Meanwhile, Federal
liabilities have increased by 185 percent in real terms.
The sharp decline in the Federal net asset position
was principally due to large Federal budget deficits
along with a drop in certain asset values. Currently,
the net excess of liabilities over assets is about $3.2
trillion, or $11,600 per capita.

Table 2–1. GOVERNMENT ASSETS AND LIABILITIES *
(As of the end of the fiscal year, in billions of 1999 dollars)
1960

1965

1970

1975

1980

1985

1990

1995

1997

1998

1999

ASSETS
Financial Assets:
Foreign Exchange, SDRs, and Gold .....................
Cash and Checking Deposits ................................
Other Monetary Assets ..........................................
Mortgages ...............................................................
Other Loans ............................................................
less Expected Loan Losses ...............................
Other Treasury Financial Assets ...........................

9
40
1
26
96
–1
49

7
58
1
25
133
–3
66

15
36
1
37
166
–4
48

12
29
1
39
165
–9
45

17
45
2
72
211
–16
63

31
30
2
74
276
–16
89

41
40
2
94
194
–19
150

58
41
1
65
150
–23
172

40
51
3
47
156
–42
158

47
48
4
45
168
–46
153

46
63
5
45
179
–50
164

Total ....................................................................
Fixed Reproducible Capital: .......................................
Defense ...................................................................
Nondefense .............................................................
Inventories ...................................................................
Nonreproducible Capital ..............................................
Land ........................................................................
Mineral Rights .........................................................

222
1,042
908
134
254
412
89
323

287
1,101
895
206
220
422
124
299

300
1,123
873
250
204
400
154
246

283
1,015
736
280
182
581
239
342

393
945
643
302
224
925
303
621

485
1,111
778
333
259
1,027
327
701

503
1,159
808
351
229
802
328
474

463
1,145
779
367
162
605
251
354

412
1,075
709
366
139
688
265
423

419
1,037
677
360
136
633
279
354

452
1,030
663
367
135
658
294
364

Subtotal ...............................................................

1,708

1,743

1,727

1,778

2,093

2,397

2,190

1,913

1,902

1,806

1,823

1,930

2,030

2,027

2,061

2,487

2,882

2,692

2,376

2,315

2,225

2,275

12
1,085
14
6

13
1,118
20
3

21
1,011
20
1

21
1,024
30
4

25
1,263
53
0

25
2,105
79
0

29
2,875
114
9

30
3,821
88
7

29
3,867
86
4

28
3,771
84
7

26
3,633
82
7

Total ....................................................................
Insurance Liabilities:
Deposit Insurance ...................................................
Pension Benefit Guarantee 1 ..................................
Loan Guarantees ....................................................
Other Insurance ......................................................

1,117

1,154

1,053

1,079

1,342

2,209

3,027

3,946

3,986

3,890

3,748

0
0
0
30

0
0
0
27

0
0
2
21

0
41
6
20

2
30
12
26

9
42
10
16

69
42
15
19

5
20
29
17

1
30
31
16

1
48
29
16

1
41
29
16

Subtotal ...............................................................
Federal Pension Liabilities ...........................................
Total Liabilities ...........................................................
Balance ........................................................................

30
766
1,913
17

27
971
2,152
–122

24
1,155
2,232
–205

67
1,312
2,457
–396

70
1,734
3,147
–660

78
1,736
4,023
–1,141

146
1,693
4,866
–2,173

70
1,642
5,658
–3,282

79
1,612
5,676
–3,362

94
1,624
5,609
–3,384

86
1,627
5,461
–3,186

Addenda:.
Balance Per Capita (in 1999 dollars) .......................
Ratio to GDP (in percent) .........................................

95
0.7

–626
–3.9

–997
–5.5

–1,836
–9.4

–2,889
–13.0

–4,771
–19.0

–8,669
–31.2

–12,444
–41.4

–12,509
–39.0

–12,474
–37.6

–11,634
–34.1

Total Assets ...................................................
LIABILITIES
Financial Liabilities:
Currency and SDRs ...............................................
Debt held by the Public .........................................
Trade Payables .......................................................
Miscellaneous .........................................................

* This table shows assets and liabilites for the Government as a whole excluding the Federal Reserve System.
1 The model and data used to calculate this liability were revised for 1996–1999.
2 This temporary improvement highlights the importance of the other tables in this presentation. What is good for the Federal Government as an asset holder is not necessarily
favorable to the economy. The decline in inflation in the early 1980s reversed the speculative

runup in gold and other commodity prices. This reduced the balance of Federal net assets,
but it was good for the economy and the Nation as a whole.

25

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

Chart 2-2. Net Federal Liabilities
Percent of GDP

50
40
30
20
10
0
-10
1960

1965

1970

1975

Assets
Table 2–1 shows a comprehensive list of assets—the
financial and physical resources—owned by the Federal
Government. The list corresponds to items that would
appear on a typical balance sheet.
Financial Assets: According to the Federal Reserve
Board’s Flow-of-Funds accounts, the Federal Government’s holdings of financial assets amounted to almost
$0.5 trillion at the end of FY 1999. Government-held
mortgages and other loans (measured in constant dollars) reached a peak in the mid-1980s. Since then, the
value of Federal loans has declined. The holdings of
mortgages, in particular, have declined sharply as holdings acquired from failed Savings and Loan institutions
have been liquidated.
The face value of mortgages and other loans overstates their economic worth. OMB estimates that the
discounted present value of future losses and interest
subsidies on these loans is about $50 billion as of 1999.
These estimated losses are subtracted from the face
value of outstanding loans to obtain a better estimate
of their economic worth.
Reproducible Capital: The Federal Government is a
major investor in physical capital and computer software. Government-owned stocks of such capital
amounted to about $1.0 trillion in 1999 (OMB esti-

1980

1985

1990

1995

2000

mate). About two-thirds of this capital took the form
of defense equipment or structures.
Non-reproducible Capital: The Government owns significant amounts of land and mineral deposits. There
are no official estimates of the market value of these
holdings (and of course, in a realistic sense, much of
this land could or would never be sold). Researchers
in the private sector have estimated what they are
worth, and these estimates are extrapolated in Table
2–1. Private land values fell sharply in the early 1990s,
although they have risen somewhat since 1993. It is
assumed here that Federal land shared in the decline
and the subsequent recovery. Oil prices declined sharply in 1997–1998 but rebounded sharply in 1999, causing
the value of Federal mineral deposits to fluctuate. (The
estimates omit other types of valuable assets owned
by the Government, such as works of art or historical
artefacts, simply because the valuation of such assets
would have little realistic basis in fact, and because,
as part of the Nation’s historical heritage, most of these
objects would never be sold.)
Total Assets: The total real value of Government assets is lower now than at the end of the 1980s, because
of declines in defense capital and the real value of
nonreproducible assets. Even so, the Government’s
holdings are vast. At the end of 1999, the value of

26

ANALYTICAL PERSPECTIVES

Government assets is estimated to have been about
$2.3 trillion.
Liabilities
Table 2–1 includes those liabilities that would appear
on a business balance sheet, and only those liabilities.
These include various forms of Federal debt, Federal
pension obligations to civilian and military employees,
and the estimated liability arising from Federal insurance and loan guarantee programs.
Financial Liabilities: Financial liabilities amounted
to about $3.7 trillion at the end of 1999. The single
largest component was Federal debt held by the public,
amounting to around $3.6 trillion. In addition to debt
held by the public, the Government’s financial liabilities
include approximately $0.1 trillion in miscellaneous liabilities.
Guarantees and Insurance Liabilities: The Federal
Government has contingent liabilities arising from loan
guarantees and insurance programs. When the Government guarantees a loan or offers insurance, cash disbursements may initially be small or, if a fee is
charged, the Government may even collect money; but
the risk of future cash payments associated with such
commitments can be very large. The figures reported
in Table 2–1 are prospective estimates showing the current discounted value of expected future losses. The

present value of all such losses taken together is less
than $0.1 trillion. The resolution of the many failures
in the Savings and Loan and banking industries has
helped to reduce the liabilities in this category by more
than half since 1990.
Federal Pension Liabilities: The Federal Government
owes pension benefits to its retired workers and to current employees who will eventually retire. The amount
of these liabilities is large. The discounted present
value of the benefits is estimated to have been around
$1.6 trillion at the end of FY 1999. 3
The Balance of Net Liabilities
Because of its sovereign powers, the Government
need not maintain a positive balance of net assets, and
the rapid buildup in liabilities since 1980 has not damaged Federal creditworthiness. However, from 1980 to
1992, the balance between Federal liabilities and Federal assets did deteriorate at a very rapid rate. In 1980,
the negative balance was only about 13 percent of GDP;
by 1995, it was 41 percent of GDP. Since then, the
net balance as a percentage of GDP has fallen for four
straight years. The real value—adjusted for inflation—
of net liabilities has also fallen by about $180 billion
since 1997, reflecting the back-to-back budget surpluses
in these years. If a budget surplus is maintained, the
net balance will continue to improve.

PART II—THE BALANCE OF RESOURCES AND RESPONSIBILITIES
As noted in the preceding section, a business-type
accounting of Government assets and liabilities does
not reflect the Government’s unique sovereign powers,
such as taxation. The best way to examine the balance
between future Government obligations and resources
is by projecting the budget over a long enough period
to reveal any long-run stresses. The budget provides
a comprehensive measure of the Government’s annual
financial burdens and resources. By projecting annual
receipts and outlays, it is possible to consider whether
there will be sufficient resources to support all of the
Government’s ongoing obligations.
This part of the presentation describes long-run projections of the Federal budget that extend beyond the
normal 5- to 10-year budget horizon. Forecasting the
economy and the budget over such a long period is
highly uncertain. Future budget outcomes depend on
a host of unknowns—constantly changing economic conditions, unforeseen international developments, unexpected demographic shifts, the unpredictable forces of
technological advance, and evolving political preferences. Those uncertainties increase the further into
the future the projections are pushed. Even so, longrun budget projections are needed to assess the full
implications of current policies and to sound warnings
about future problems that could be avoided by timely
action. Federal responsibilities extend well beyond the
3 These pension liabilities are expressed as the actuarial present value of benefits accruedto-date based on past and projected salaries. The cost of retiree health benefits is not
included. The 1999 liability is extrapolated from recent trends.

next decade. There is no time limit on the Government’s
constitutional responsibilities, and programs like Social
Security are intended to continue indefinitely.
It is evident even now that there will be mounting
challenges to the budget early in this century. By 2008,
the first of the huge baby-boom generation born after
World War II will become eligible for early retirement
under Social Security. In the years that follow there
will be serious strains on the budget because of increased expenditures for Social Security and for the
Government’s health programs—Medicare and Medicaid—which serve the elderly. Long-range projections
can help indicate how serious these strains might become and what would be needed to withstand them.
The retirement of the baby-boomers will dictate the
timing of the future budgetary problem, but the underlying cause is deeper. U.S. population growth has been
slowing down, and because of that and because people
are living longer, a change is inevitably coming in the
ratio of retirees to workers given current retirement
patterns. That change has been held temporarily in
abeyance as the baby-boom cohort has moved into its
prime earning years, while the retirement of the much
smaller cohorts born during the Great Depression and
World War II has been holding down the rate of growth
in the retired population. The suppressed budgetary
pressures are likely to burst forth when the baby-

27

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

boomers begin to retire. However, even after the babyboomers have passed from the scene, later in the century, a higher ratio of retirees to workers will persist,
given the underlying pattern of low fertility and improving longevity, with concomitant problems for Federal retirement programs. These same problems are
gripping other developed nations, even those that never
experienced a baby-boom; in fact, some of the nations
that did not have baby-booms are facing demographic
pressures already.
The Improvement in the Long-Range Outlook.—
Since this Administration first took office, there has
been a major change in the long-run budget outlook.
In January 1993, the deficit was on an unstable trajectory. Had the policies then in place continued unchanged, the deficit was projected to mount steadily
not only in dollar terms, but relative to the size of
the economy. 4 The unified deficit was projected to rise
to over 10 percent of GDP by 2010—an unprecedented
level in peacetime—and to continue sharply upward
thereafter. This pattern of rising deficits also would
have driven Federal debt held by the public to unprecedented levels.
4 Over long periods when the rate of inflation is positive, comparisons of dollar values
are meaningless. Even the low rate of inflation assumed in this budget will reduce the
value of a 1999 dollar by over 50 percent by 2030, and by 70 percent by the year 2050.
For long-run comparisons, it is much more useful to examine the ratio of the surplus/
deficit and other budget categories to the expected size of the economy as measured by
GDP.

The Omnibus Budget Reconciliation Act of 1993
(OBRA) changed that. Not only did it reduce the nearterm deficit, but, aided by the strong economy that
it helped bring about, it also reduced the long-term
deficit. Prior to enactment of the Balanced Budget Act
in 1997, however, the deficit was still expected to persist into the long run, although at a more moderate
level. Under the policies in place at the beginning of
1997, the deficit was projected to remain at around
1.5 percent of GDP through 2010, and only afterwards
to begin a steady rise that would push it above 20
percent of GDP shortly after 2050.
The 1997 Balanced Budget Agreement (BBA) took
the next major step by eliminating the deficit in the
unified budget. When the BBA was passed, that was
expected to happen in 2002; but the unexpected
strength of the economy and the boom in the financial
markets over the last four years have enabled the unified budget to reach balance much sooner than was
expected. The unified budget is now projected to remain
in surplus throughout the coming decade under policies
in this budget. Extending those policies beyond the
usual budget window, a unified budget surplus could
be sustained for many years, although in the very long
run a deficit is projected to reemerge absent further
policy changes. How long the surplus will actually be
preserved depends on certain key factors, some of the
most important of which are illustrated in Chart 2–3.

Chart 2-3. Long Run Budget Projections
Surplus(+)/deficit(-) as a percent of GDP

5

Discretionary Grows with Inflation

0

-5
Continued Rapid
Medicare Growth

-10

Discretionary Grows with
Inflation Plus Population

Pre-OBRA
Baseline

-15

-20
1980

1990

2000

2010

2020

2030

2040

2050

2060

2070

28

ANALYTICAL PERSPECTIVES

Budget discipline is crucial for long-run budget stability. Another key factor is the expected growth of
Federal health care costs. Chart 2–3 illustrates how
the surplus varies depending on assumptions about future growth in discretionary spending and health care
costs. The conventions adopted in past budgets were
to assume future growth in discretionary spending sufficient to preserve a constant real level of spending,
and to base long-range projections for Medicare on the
latest projections of the Medicare actuaries as reflected
in the annual Medicare Trustees’ Report. Those projections include an expected slowdown in the rate of
growth in real per capita Medicare spending. More
rapid growth of Medicare, closer to the historical trend
for the program, would result in a faster return to
deficits, as shown in Chart 2–3.
Under most reasonable alternative assumptions, the
long-run budget outlook contrasts favorably with the
generally prevailing opinion among budget experts just
a few years back. Then, it was held that the longrun outlook for the deficit was necessarily bleak. For
some time, there has been a general consensus among
demographers and economists that population trends
in the 21st century would put strains on the budget,
and it was thought until recently that those strains
must inevitably lead to large deficits. For example, the
1994 report of the Bipartisan Commission on Entitlement and Tax Reform found a ‘‘long-term imbalance
between the Government’s entitlement promises and
the funds it will have available to pay for them.’’ The
Congressional Budget Office (CBO) observed as recently
as 1997: ‘‘If the budgetary pressure from both demography and health care spending is not relieved by reducing the growth of expenditures or increasing taxes,
deficits will mount and seriously erode future economic
growth.’’ 5 On a narrower front, the annual trustees’
reports for both Social Security and Medicare have projected for some time long-run actuarial deficiencies that
would deplete those programs’ Trust funds over the
next several decades.
The consensus has shifted somewhat as a result of
recent policy actions and because of the unexpected
strength of the economy in the second half of the 1990s,
which put the budget on a much sounder footing and
thereby provided a better jumping-off point for longrange budget projections. The General Accounting Office (GAO) in its 1997 report on the long-run budget
outlook observed that, ‘‘Major progress has been made
on deficit reduction ... While our 1995 simulations
showed deficits exceeding 20 percent of GDP by 2024
..., our updated model results show that this point
would not be reached until nearly 2050.’’ 6 GAO continues to find that unsustainable deficits will emerge
in the long run absent major entitlement reforms, but
the date at which the deficit starts to rise has been
postponed significantly as a result of recent actions.
Another sign of the shifting consensus is provided
in CBO’s latest long-run budget projections released

in December 1999. Under current policies, CBO foresees
a unified budget surplus through 2010, reaching 3 percent of GDP in that year. 7 As CBO correctly points
out, how long the surplus can be extended depends
on uncertain future policy and economic developments,
but: ‘‘Saving all of the surpluses projected in CBO’s
10-year baseline could delay the onset of serious fiscal
problems until the second half of the next century.’’
The summary measure that CBO uses to indicate the
magnitude of the long-run fiscal imbalance—the permanent change in taxes needed to stabilize the ratio of
publicly held Federal debt to GDP—has declined to 0.5
percent of GDP in its most optimistic projections, compared with a baseline projection of 5.4 percent of GDP
in its May 1996 projections. Under other assumptions,
CBO shows a larger imbalance, but even under its most
pessimistic alternative, the imbalance is only about half
as large as projected in 1996.
The main reason for this improvement in the outlook
can be traced to the increase in the near-term budget
surplus. If the surpluses are allowed to continue reducing Federal debt, as was done in 1998 and 1999, they
will bring about dramatic reduction in Federal debt
held by the public and in the Government’s net interest
payments over the next several years. In FY 1999, net
interest amounted to 21⁄2 percent of GDP. Under current estimates that could be cut to around 1⁄2 percent
of GDP by 2010, and soon thereafter, if the surpluses
were allowed to continue, the Government would begin
to acquire financial assets that would generate interest
income that would add to the unified budget surplus.
This means that when demographic pressures on Social Security and the Federal health programs begin
to mount around that time, there would be more budgetary resources available to meet the problem, postponing the date on which a deficit in the unified budget
reappears. While the long-range outlook for Social Security has improved only modestly, it now appears that
there could be more resources available in the rest of
the budget when the Social Security shortfall begins
to emerge.
Economic and Demographic Projections.—Longrun budget projections require a long-run demographic
and economic forecast—even though any such forecast
is highly uncertain. The forecast used here extends the
Administration’s medium-term economic projections described in the first chapter of this volume, augmented
by the long-run demographic projections from the most
recent Social Security Trustees’ Report.
• Inflation, unemployment and interest rates are assumed to hold stable at their values in the last
year of the Administration budget projections,
2010—2.6 percent per year for CPI inflation, 5.2
percent for the unemployment rate, and 6.1 percent for the yield on 10-year Treasury notes.
• Productivity growth as measured by real GDP per
hour is assumed to continue at the same constant
rate as it averages in the Administration’s me-

5 Long-Term
6 Analysis

Budgetary Pressures and Policy Options, March 1997.
of Long-Term Fiscal Outlook, October 1997.

7 The

Long-Term Budget Outlook: An Update, December 1999.

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

dium-term projections—1.7 percent per year. (In
1999, there were substantial upward revisions to
recorded productivity growth, which have resulted
in an increase in the budget projections for this
series; see the discussion of statistical issues in
Chapter 1 of this volume.)
• In line with the current projections of the Social
Security Trustees, U.S. population growth is expected to slow over the next several decades. This
is consistent with recent trends in the birth rate,
and it allows for further reductions in mortality
and continuing immigration at around current levels. The slowdown is expected to lower the rate
of population growth from over 1 percent per year
in the 1990s to about half that rate by 2025.
• Labor force participation is also expected to decline as the population ages and the proportion
of retirees in the population increases. The Administration projects a somewhat higher rate of labor
force participation over the next ten years than
is assumed in the latest annual report of the Social Security Trustees. That difference in the level
of labor force participation is preserved in the
long-run projections.
• The projected rate of real economic growth in the
long run is determined by labor force growth plus
productivity growth. Because labor force growth
is expected to slow and productivity growth is assumed to be constant, real GDP growth is expected to decline gradually after 2006 from around
3 percent per year to an average rate of just under
2 percent per year by 2020. This is a logical implication of the other assumptions which are based
on reasonable forecasting conventions; however, it
implies a marked departure from the historical
rate of growth in the U.S. economy, which has
averaged over 3 percent per year.
The economic projections described above are set by
assumption and do not automatically change in response to changes in the budget outlook. This is unrealistic, but it simplifies comparisons of alternative policies. A more responsive (or dynamic) set of assumptions
would serve mainly to strengthen conclusions reached
by the current approach. Both CBO and GAO in their
investigations of the long-run outlook have explored
such feedback effects and found that they accelerate
the destabilizing effects of sustained budget deficits.
Similarly, but in the opposite direction, budget surpluses would be expected to lead to higher national
saving, lower real interest rates, and more economic
growth, which would increase Federal receipts and reduce outlays, further augmenting projected surpluses.
Alternative Budget Baselines.—Chart 2–3 above
shows four alternative budget projections: one based
on the policies in place prior to enactment of OBRA
1993 and three others showing current policy projections under alternative assumptions about discretionary

29
spending and future Federal health care costs. 8 The
chart illustrates the dramatic improvement in the deficit that has already been achieved. Furthermore, it
shows that if the unified budget remains in surplus
throughout the coming decade, as is now expected, the
task of maintaining fiscal stability will be eased when
the demographic bulge begins to hit after 2008. Table
2–2 shows long-range projections for the major categories of spending under the three current policy alternatives shown in Chart 2–3. Under each of these alternatives, the major entitlement programs are expected
to absorb an increasing share of budget resources.
• Social Security benefits, driven by the retirement
of the baby-boom generation, rise from 4.2 percent
of GDP in 2000 to 6.7 percent in 2030. They continue to rise after that but more gradually, eventually reaching 7.4 percent of GDP by 2075.
• Federal Medicaid spending goes up from 1.2 percent of GDP in 2000 to 3.2 percent in 2030 and
to 8.6 percent of GDP in 2075.
• Based on the Medicare actuaries’ long-range projections of future health-care cost trends, Medicare
spending would rise from 2.1 percent of GDP in
2000 to 4.1 percent in 2030 and 4.8 percent by
2075. If the real per capita growth rate in Medicare does not slow as much as the actuaries have
assumed, the program could expand even more
rapidly. In the alternative with faster spending
growth, Medicare outlays reach 4.7 percent of
GDP in 2030, and 8.9 percent by 2075.
• Assuming that discretionary spending grows only
with inflation it would decline as a share of GDP,
from 6.5 percent in 2000 to 3.9 percent in 2030
and 2.3 percent of GDP in 2075. The programs
funded by this spending grow with inflation under
this assumption, but they do not keep pace with
population growth or any growth in real per capita
income. Allowing discretionary spending to expand
with both inflation and population would moderate
the decline in spending as a share of GDP. Under
this assumption, discretionary spending is 4.4 percent of GDP in 2030, and 2.9 percent of GDP
in 2075.
The long-run budget outlook has been much improved
by the actions taken by this Administration in cooperation with the Congress. Eliminating the unified deficit
has set the budget on a solid footing for many years
to come. Under a conservative extension of the Administration’s latest economic assumptions and using various reasonable technical assumptions regarding future
spending and taxes, the budget could continue in surplus for several decades.
As currently projected, receipts are higher and net
interest outlays are lower than they were before meas8 The President’s budget program includes investing no more than 15 percent of the
Social Security trust fund in corporate equities. To be conservative, these projections assume
that the equities in the trust fund have the same yield as Government securities (so
the equity investment does not add to the Government’s projected investment income),
and net the value of the equities against the amount of outstanding Federal debt. This
yields the same numerical outcome as if Social Security did not invest in equities. If,
as expected, Social Security equity investment yields a higher rate of return, the financial
position of the Federal Government will be better than is presented in these projections.

30

ANALYTICAL PERSPECTIVES

Table 2–2. LONG–RUN BUDGET PROJECTIONS OF 2001 BUDGET POLICY
(Percent of GDP)
1995

2000

2005

2010

2015

2020

2030

2040

2050

2060

2075

Discretionary Grows with Inflation
Receipts ........................................................................
Outlays .........................................................................
Discretionary ............................................................
Mandatory ................................................................
Social Security .....................................................
Medicare ..............................................................
Medicaid ..............................................................
Other ....................................................................
Net Interest ..............................................................
Surplus(+)/Deficit(–) ......................................................
Federal Debt Held by Public .......................................
Primary Surplus(+)/Deficit(–) ........................................

18.5
20.7
7.4
10.1
4.6
2.1
1.2
2.2
3.2
–2.2
49.2
0.9

20.4
18.7
6.5
9.9
4.2
2.1
1.2
2.4
2.3
1.7
36.3
4.0

19.4
17.6
5.8
10.4
4.3
2.3
1.5
2.3
1.4
1.8
21.3
3.1

19.1
16.7
5.1
11.1
4.5
2.5
1.8
2.3
0.5
2.4
7.1
2.9

19.2
16.5
4.7
12.0
5.0
2.9
2.1
2.1
–0.3
2.7
–6.3
2.5

19.3
16.9
4.4
13.3
5.7
3.3
2.4
2.0
–0.9
2.5
–16.9
1.6

19.5
18.2
3.9
15.6
6.7
4.1
3.2
1.7
–1.4
1.4
–26.9
0.0

19.7
18.7
3.4
16.7
6.8
4.4
4.0
1.5
–1.4
1.0
–26.9
–0.5

19.9
19.3
3.1
17.6
6.9
4.4
5.0
1.4
–1.3
0.5
–24.5
–0.8

19.9
21.1
2.7
19.1
7.2
4.5
6.2
1.3
–0.8
–1.1
–13.8
–2.0

20.0
26.3
2.3
22.1
7.4
4.8
8.6
1.2
1.9
–6.3
37.3
–4.5

Discretionary Grows with Population and Inflation
Receipts ........................................................................
Outlays .........................................................................
Discretionary ............................................................
Mandatory ................................................................
Social Security .....................................................
Medicare ..............................................................
Medicaid ..............................................................
Other ....................................................................
Net Interest ..............................................................
Surplus(+)/Deficit(–) ......................................................
Federal Debt Held by Public .......................................
Primary Surplus(+)/Deficit(–) ........................................

18.5
20.7
7.4
10.1
4.6
2.1
1.2
2.2
3.2
–2.2
49.2
0.9

20.4
18.7
6.5
9.9
4.2
2.1
1.2
2.4
2.3
1.7
36.3
4.0

19.4
17.6
5.8
10.4
4.3
2.3
1.5
2.3
1.4
1.8
21.3
3.1

19.1
16.7
5.1
11.1
4.5
2.5
1.8
2.3
0.5
2.4
7.1
2.9

19.2
16.6
4.9
12.0
5.0
2.9
2.1
2.1
–0.2
2.6
–5.8
2.3

19.3
17.3
4.7
13.3
5.7
3.3
2.4
2.0
–0.8
2.1
–15.1
1.3

19.5
18.9
4.4
15.6
6.7
4.1
3.2
1.7
–1.1
0.6
–20.3
–0.5

19.7
20.0
4.0
16.7
6.8
4.4
4.0
1.5
–0.7
–0.3
–13.3
–1.0

19.9
21.1
3.6
17.6
6.9
4.4
5.0
1.4
–0.2
–1.2
–2.3
–1.4

19.9
23.3
3.3
19.1
7.2
4.5
6.2
1.3
0.9
–3.4
18.8
–2.5

20.0
29.6
2.9
22.1
7.4
4.8
8.6
1.2
4.6
–9.6
89.0
–5.0

Continued Rapid Medicare Growth.
Receipts ........................................................................
Outlays .........................................................................
Discretionary ............................................................
Mandatory ................................................................
Social Security .....................................................
Medicare ..............................................................
Medicaid ..............................................................
Other ....................................................................
Net Interest ..............................................................
Surplus(+)/Deficit(–) ......................................................
Federal Debt Held by Public .......................................
Primary Surplus(+)/Deficit(–) ........................................

18.5
20.7
7.4
10.1
4.6
2.1
1.2
2.2
3.2
–2.2
49.2
0.9

20.4
18.7
6.5
9.9
4.2
2.1
1.2
2.4
2.3
1.7
36.3
4.0

19.4
17.6
5.8
10.4
4.3
2.3
1.5
2.3
1.4
1.8
21.3
3.1

19.1
16.7
5.1
11.1
4.5
2.5
1.8
2.3
0.5
2.4
7.1
2.9

19.2
16.5
4.7
12.0
5.0
2.9
2.1
2.1
–0.3
2.7
–6.3
2.5

19.3
17.1
4.4
13.5
5.7
3.4
2.4
2.0
–0.8
2.3
–16.4
1.4

19.5
19.1
3.9
16.3
6.7
4.7
3.2
1.7
–1.2
0.5
–21.6
–0.7

19.7
20.9
3.4
18.0
6.8
5.7
4.0
1.5
–0.6
–1.2
–9.6
–1.8

19.9
23.2
3.1
19.5
6.9
6.3
5.0
1.4
0.6
–3.3
–13.5
–2.7

19.9
27.3
2.7
21.7
7.2
7.1
6.2
1.3
2.9
–7.4
56.5
–4.6

20.0
38.1
2.3
26.2
7.4
8.9
8.6
1.2
9.6
–18.2
186.0
–8.6

ures were taken to bring down the deficit, but the longrun demographic challenge has not been changed, and
rising per capita health care costs are also likely to
continue to put pressure on the budget. Extending the
2001 budget under the assumption that discretionary
spending grows with inflation, a primary, or non-interest, deficit reappears in 2030. Although the underlying
imbalance remains small, and the unified budget is projected to continue in surplus for many more years, a
sustained primary deficit is sufficient to begin a slow
but irreversible spiral. The recurrence of a unified deficit is inevitable once this spiral is set in motion unless
there are future changes in policy that eliminate the
primary deficit. 9 Under the alternative baselines shown
in Chart 2–3 and Table 2–2, the primary deficit would
reappear even sooner. When discretionary spending
grows with both population and inflation, the primary
deficit reappears in 2027, and when Medicare grows
9 The primary or non-interest surplus is the difference between all outlays, excluding
interest, and total receipts. It is positive even when the total budget is in deficit provided
that interest outlays exceed the overall deficit. A relatively small primary surplus can
stabilize the budget even when the total budget is in deficit, and similarly, even a small
primary deficit can destabilize a budget. The mathematics are inexorable.

more rapidly, it also recurs in 2027. In all cases, a
unified deficit reappears before the end of the 75-year
forecast period.
The Effects of Alternative Economic and Technical Assumptions.—The results discussed above are
sensitive to changes in underlying economic and technical assumptions. The three alternatives in Table 2–2
illustrate the impact of some of the key assumptions,
but other scenarios are also possible. While the budget
could remain under control for several decades before
underlying problems reemerge, other assumptions can
produce more pessimistic—or more optimistic—outcomes. Some of the most important of these alternative
economic and technical assumptions and their effects
on the budget outlook are described below. Each highlights one of the key uncertainties in the outlook. Generally, negative possibilities receive more attention than
positive ones in these scenarios, because the dangers
would seem to be greater in this direction.
1. Discretionary Spending: By convention, the current
services estimates of discretionary spending are as-

31

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

sumed to rise only with the rate of inflation. This assumption, or any other, is essentially arbitrary, because
discretionary spending is always determined annually
through the legislative process, and no formula can dictate future spending in the absence of legislation. The
current services assumption implies that the real value
of Federal services is unchanging over time, which has
the implication that the size of Federal discretionary
spending would shrink relative to the size of the economy. It also implies that the Nation’s future defense
needs do not vary systematically from currently projected levels.
One alternative to this assumption has already been
presented in Chart 2–3 and Table 2–2. The second alternative for current policy considered there allows discretionary spending to increase with both population
and inflation. Discretionary spending is frozen in real
per capita terms, but not in absolute terms. This might
be the appropriate assumption for such domestic activities as those of the FBI or the Social Security Administration (for program administration, not benefit costs),
which are sensitive to population trends.
Some budget analysts have assumed alternatively
that discretionary spending is proportional to GDP in
the long run; this requires it to increase in real terms
whenever there is positive real economic growth. That
is a more generous assumption for Government spending than the current services assumption or even the
assumption of constant real per capita spending. It
might be argued that with rising real per capita incomes, the public demand for Government services—

more national parks, better roads, and additional Federal support for scientific research—will increase as
well. Some of these demands might be met within fixed
real spending limits through increased productivity in
the Federal sector, such as has accompanied recent reductions of the Federal workforce. The assumption also
flies in the face of recent experience; since its peak
in 1968, the discretionary spending share of GDP has
been cut in half—from 13.6 percent to 6.5 percent in
2000. Thus, there are arguments on both sides. Chart
2–4 compares the baseline alternatives with a scenario
in which discretionary spending rises in step with nominal GDP.
2. Health Spending: After 2010, which is the last
year of the standard budget estimates, real per capita
growth rates for Medicare benefits are based on the
actuarial projections in the latest report of the Medicare
Trustees. These projections slow down markedly in the
long run. At some point, spending for Medicare must
grow at approximately the same rate as GDP. Eventually, the rising trend in health care costs for both Government and the private sector will have to end, but
it is hard to know when and how that will happen.
Improved health and increased longevity are highly valued, and society may be willing to spend an even larger
share of income on them than it has heretofore. As
an alternative, one of the current policy baselines allows real per capita Medicare benefits to rise at an
annual rate of 21⁄4 percent per year. This is about twice
as fast as the actuarial assumption, and implies a rapidly rising level of Medicare spending for many years

Chart 2-4. Alternative Discretionary Spending Assumptions
Surplus(+)/deficit(-) as a percent of GDP

5

Growth with Inflation

0

-5

Growth with Inflation
Plus Population

-10

Growth with Nominal GDP

-15

-20
1995

2005

2015

2025

2035

2045

2055

2065

2075

32

ANALYTICAL PERSPECTIVES

to come. Eventually, Medicare would approach 9 percent of GDP on this assumption (see Table 2–2).
3. Taxes: In the absence of policy changes, the ratio
of taxes to GDP is not assumed to vary much in these
long-range projections. Individual income taxes tend to
rise relative to income, because the assumed rate of
real income growth implies some ‘‘real bracket creep.’’
The tax code is indexed for inflation, but not for increases in real income. Eventually, a larger percentage
of taxpayers will be in higher tax brackets and this
will raise the ratio of taxes to income. However, other
Federal taxes tend to decline in real terms in the absence of policy changes. Many excise taxes are set in
nominal terms, so collections tend to decline as a share
of GDP. In the very long run, Federal receipts are projected to rise by about 1 percentage point of GDP compared with their level in 2010.
The starting point for these projections is the current
ratio of Federal receipts to GDP. That ratio reached
20.0 percent in 1999, and it is expected to be 20.4
percent in 2000—the highest levels since World War
II. This was not the result of new Federal taxes. Tax
rates have been essentially unchanged since 1994, when
the changes enacted in OBRA took effect. Since then,
however, tax collections as a share of GDP have risen
about two percentage points. The reasons for this increase are not yet fully understood. The rapid rise in
the stock market, which has generated large capital
gains for investors and made possible lucrative stock
options and bonuses for executives, is generally believed
to be a major factor. This Budget assumes that there

will be some moderation in the ratio of receipts to GDP
over the next few years. The share of revenues in the
medium term is below the peak levels recently experienced. Even so, receipts are projected to remain above
their historical average relative to the economy. Should
the share of tax receipts instead return to near its
historical average that would have an adverse effect
on the long-range budget projections.
In Chart 2–5, the current services baseline is compared with two alternatives for receipts. In one, the
share of receipts is assumed to return to the level posted in 1996, 18.9 percent of GDP; in the other, to its
level in 1994, before the recent runup in the revenue
share—18.1 percent of GDP. The return to these earlier
levels is completed by 2001. Afterwards, the current
services rules apply, under which the share of receipts
rises over time, but at a very gradual rate. The difference in the starting point for taxes can alter the
outlook for the surplus/deficit quite dramatically. This
is another example of how small differences in the primary surplus can eventually produce large effects on
the total surplus/deficit.
4. Alternative Uses of the Budget Surpluses: Current
projections show the unified budget in surplus for several decades under a wide range of assumptions. These
surpluses dramatically reduce debt held by the public
and net interest outlays, which in turn augments the
surpluses. In a sense, a budget surplus that is used
to reduce debt feeds on itself by reducing future interest
outlays. Thus, if these surpluses were limited by increased spending or reduced taxes, it would change the

Chart 2-5. Alternative Receipts Assumptions
Surplus(+)/deficit(-) as a percent of GDP

5
2001 Budget Policy

0

-5
1996 Receipts Share 18.9
Percent of GDP

-10

-15

1994 Receipts Share 18.1
Percent of GDP

-20

-25
1995

2005

2015

2025

2035

2045

2055

2065

2075

33

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

outlook. Chart 2–6 shows the budget’s path if it were
held exactly in balance rather than being allowed to
run surpluses. This would require policy changes to
increase spending or reduce taxes. These changes could
take two general forms. The spending or tax changes
made possible by the surpluses could be purely temporary. This would be the case for tax rebates or onetime grants. If such changes were made, program
spending and receipts could eventually return to their
original baseline paths after the temporary spending
and taxes came to an end, although interest spending
would be permanently higher. Alternatively, the spending increases or tax reductions could be permanently
built into the budget. This would be the case if the
changes took form of tax rate cuts or increases in entitlements. Such changes would alter the baselines for
outlays or receipts permanently, and have a larger longrun effect on the projected surplus. In both cases, the
deficit returns sooner than it would if the surplus were
used to reduce debt.
5. What Happens When the Federal Debt Is Repaid?
A surplus means the Government takes in more receipts from the public than it pays out in the form
of Government outlays. The extra receipts are used to
retire debt. This is not unlike a family paying off its
mortgage, and like a family with a mortgage, the Government may eventually be free from debt. This has
happened only once before in the history of the United
States, and then only briefly a century and a half ago;

but with the current level of projected surpluses, such
an eventuality has become a real possibility. When the
budget window closes in 2010, the Administration
projects that debt held by the public will be 7 percent
of GDP, a lower level than at any time since before
the United States entered World War I.
With unified budget surpluses projected to be running
between 2 and 3 percent of GDP, it is obvious where
the debt is headed. All of the debt held by the public
could be repaid. At that point, any further surpluses
would no longer be used to retire Federal debt; instead,
they would have to be accumulated in the form of Federal assets. Assuming the Government used them to
acquire financial reserves, these reserves would earn
interest which would add to the surplus further adding
to the assets. In the long-run budget projections, Federal financial assets continue to build up until shifts
in the underlying budgetary position cause the surplus
gradually to unwind. Eventually, a deficit reappears
and the assets are drawn down; ultimately, Federal
debt is issued again. It is a measure of the severity
of the impending demographic pressures that the national asset does not grow into the indefinite future—
which it could, just as easily as did the national debt
in the adverse projections of just a few years ago.
Such a scenario is somewhat artificial and would
have been thought most unlikely just a few years ago,
but to assume any other approach would require a policy judgment. The purpose of these long-range projec-

Chart 2.6. Alternative Uses Of The Surplus
Surplus(+)/deficit(-) as a percent of GDP

5

2001 Budget Policy

0

-5
Surplus Used for Temporary Tax
Rebates or Spending Increases

-10

Surplus Used for Continuing
Tax Cuts or Spending Increases

-15

-20
1995

2005

2015

2025

2035

2045

2055

2065

2075

34

ANALYTICAL PERSPECTIVES

tions, is to show what would happen to the budget
if current policies were extended. That assumption implies that, with sufficient discipline, the Federal debt
would be repaid under an extension of current budget
policies and a Federal asset accumulated. Given the
ground rules, the base scenario presents that result.
Chart 2–7 compares the current services baseline
with a scenario in which spending is permanently increased or taxes permanently cut when Federal debt
held by the public reaches zero. Without the national
asset, the deficit reappears much sooner. The interest
earned by the asset is no longer available to fill the
budgetary hole when the drain of future entitlement
claims begins to mount.
6. Productivity: Productivity growth in the U.S. economy slowed after 1973. This slowdown was responsible
for the slower rise in U.S.real incomes after that time.
Recently, productivity growth has increased. Since the
end of 1995, productivity has grown about as fast as
it did during the 25-year period prior to 1973. The
revival of productivity growth is one of the most welcome developments of the last several years. Productivity is affected by changes in the budget surplus/deficit which alter the level of national saving and investment, but many other factors also influence productivity
as well. The surplus/deficit in turn is affected by
changes in productivity growth which determine the
size of the economy, and hence future receipts. Two
alternative scenarios illustrate what would happen to
the budget deficit if productivity growth were either
higher or lower than assumed. A higher rate of growth

would make the task of preserving a balanced budget
much easier; indeed, it would permit expanded spending or reduced taxes without worsening the budget picture. A lower productivity growth rate would have the
opposite effect. Chart 2–8 shows how the surplus/deficit
varies with changes of one-half percentage point of average productivity growth in either direction.
7. Population: In the long run, shifting demographic
patterns are the main source of change in these projections. The changing rate of population growth feeds
into real economic growth through its effect on labor
supply and employment. Changing demographic patterns also affect entitlement spending, contributing to
the surge of spending expected for Social Security,
Medicare, and Medicaid. The key assumptions underlying these demographic projections concern future fertility, mortality and immigration.
• The main reason for the projected slowdown in
population growth in the 21st century is the expected continuation of a low fertility rate. Since
1990, the number of births per woman in the
United States has averaged between 2.0 and 2.1,
slightly below the replacement rate needed to
maintain a constant population. The fertility rate
was even lower than this in the 1970s and 1980s.
The demographic projections assume that fertility
will average around 1.9 births per woman in the
future. Fertility is hard to predict. Both the baby
boom in the 1940s and 1950s and the baby bust
in the 1960s and 1970s surprised demographers.
A return to higher fertility rates is possible, but

Chart 2-7. Alternative Assumptions About a Federal "Asset"
Surplus(+)/deficit(-) as a percent of GDP

5
2001 Budget Policy

0

-5

No Asset Accumulates

-10

-15

-20
1995

2005

2015

2025

2035

2045

2055

2065

2075

35

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

Chart 2-8. Alternative Productivity Assumptions
Surplus(+)/deficit(-) as a percent of GDP

40
Half Percent Higher
Productivity Growth

20

0
2001 Budget Policy

-20
Half Percent Lower
Productivity Growth

-40

-60

-80
1995

2005

2015

2025

so is another drop in fertility. The U.S. fertility
rate has never fallen below 1.7, but such low rates
have been observed recently in some European
countries. Chart 2–9 shows the effects of alternative fertility assumptions on the surplus/deficit;
higher fertility contributes to a larger labor force,
increased aggregate incomes, and revenues; and
hence increases the projected surplus. Lower fertility has the opposite effect.
• The increasing proportion of the elderly projected
for the U.S. population is due to both low fertility,
which reduces the number of children per adult,
and longer lifespans. Since 1970, the average lifespan for U.S. women has increased from 74.9
years to 79.5 years, and it is projected to rise
to 82.8 years by 2050. Men do not live as long
as women on average, but their lifespan has also
increased from 67.2 years in 1970 to 73.6 years
in 1999, and it is expected to reach 78.1 years
by 2050. If the U.S. population were to experience
much slower improvements in mortality, than in
the recent past, the relatively shorter lifespans
would help to improve the surplus/deficit by reducing Social Security benefits. Conversely, if the population were to live significantly longer than is
now expected, the outlook for the surplus/deficit
would worsen. This is illustrated in Chart 2–10.
Last year, the technical panel to the Social Security Advisory Board recommended raising expected lifespans in the annual Trustees’ Report.
The recommendation essentially is to adopt what
had been the high-cost assumption as the inter-

2035

2045

2055

2065

2075

mediate or base case. This would raise expected
lifespans in 2050 to 85.6 years for women and
to 80.8 years for men.
• A final factor influencing long-run projections is
the rate of immigration. The United States is an
open society. In the 19th century, a huge wave
of immigration helped build the country; the last
two decades of the 20th century have witnessed
another burst of immigration. The net flow of legal
immigrants has been averaging around 850,000
per year since 1992, while illegal immigration
adds to these figures. This is the highest absolute
rate in U.S. history, but as a percentage of population it is only about a third as high as immigration was in 1901–1910. Chart 2–11 presents alternatives in which future immigration is held to
zero and allowed to rise 50 percent above and
below the intermediate actuarial assumptions in
the Social Security Trustees’ Report.
Conclusion.—Under President Clinton, the long-run
budget outlook has improved significantly. When this
Administration took office, the deficit was projected to
continue spiraling out of control until, early in the 21st
century, it was projected to reach levels seen before
only during major wars. The outlook now is drastically
different. Under current policy assumptions, the unified
budget surpluses in 1998–1999 mark the beginning of
a period of sustained budget surpluses. Eventually,
without further reforms to the entitlement programs,
a return to budget deficits is still projected, but how
soon this will occur is difficult to estimate. A quick

36

ANALYTICAL PERSPECTIVES

Chart 2-9. Alternative Fertility Assumptions
Surplus(+)/deficit(-) as a percent of GDP

5

Higher Fertility

0

2001 Budget Policy

-5

Lower Fertility

-10

-15
1995

2005

2015

2025

2035

2045

2055

2065

2075

Chart 2-10. Alternative Mortality Assumptions
Surplus(+)/deficit(-) as a percent of GDP
Shorter Life Expectancy

5

0
2001 Budget Policy

-5

Longer Life Expectancy

-10

-15
1995

2005

2015

2025

2035

2045

2055

2065

2075

37

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

return to deficits can be avoided with continued budget
discipline. Both Social Security and Medicare confront
long-run deficits in their respective Trust Funds, which
must be addressed regardless of the prospects for the
unified surplus. But the favorable outlook for the unified budget should make it easier to solve these otherwise difficult problems.
Actuarial Balance in the Social Security and
Medicare Trust Funds
The Trustees for the Social Security and Hospital
Insurance Trust Funds issue annual reports that include projections of income and outgo for these funds
over a 75-year period. These projections are based on
different methods and assumptions than the long-run
budget projections presented above, although the budget projections do rely on the Social Security assumptions for population growth and labor force growth after
the year 2010. Even with these differences, the message
is similar: The retirement of the baby-boom generation
coupled with expected high rates of growth in per capita
health care costs will exhaust the Trust Funds unless
further remedial action is taken.

The Trustees’ reports feature the 75-year actuarial
balance of the Trust Funds as a summary measure
of their financial status. For each Trust Fund, the balance is calculated as the change in receipts or program
benefits (expressed as a percentage of taxable payroll)
that would be needed to preserve a small positive balance in the Trust Fund at the end of 75 years.
Table 2–3 shows the changes in the 75-year actuarial
balances of the Social Security and Medicare Trust
Funds from 1998 to 1999. There was a small improvement in the consolidated OASDI Trust fund and a larger gain in the HI Trust Fund. The changes were due
to revisions in the actuarial assumptions. In the case
of the OASDI funds, a small improvement in the economic assumptions was made; while for the HI program
the actuaries revised their view of likely health care
cost trends, which helped to prolong the projected surplus in the Trust Fund. The Trustees now project that
the HI Trust Fund will not be depleted until 2015,
which they describe as ‘‘a substantial improvement over
prior estimates.’’

Chart 2-11. Alternative Immigration Assumptions
Surplus(+)/deficit(-) as a percent of GDP

10
Higher Net Immigration

5
0
-5
2001 Budget Policy

-10
Lower Net Immigration

-15
-20

Zero Net Immigration

-25
1995

2005

2015

2025

2035

2045

2055

2065

2075

38

ANALYTICAL PERSPECTIVES

Table 2–3. CHANGE IN 75–YEAR ACTUARIAL BALANCE FOR OASDI AND HI TRUST FUNDS
(INTERMEDIATE ASSUMPTIONS)
(As a percent of taxable payroll)
OASI

Actuarial balance in 1998 Trustees’ Report .............................................................
Changes in balance due to changes in:
Legislation ................................................................................................................
Valuation period .......................................................................................................
Economic and demographic assumptions ..............................................................
Technical and other assumptions ...........................................................................
Total Changes ..........................................................................................................
Actuarial balance in 1999 Trustees’ Report .............................................................

DI

OASDI

HI

–1.81

–0.38

–2.19

–2.10

0.00
–0.07
0.16
0.02

0.00
–0.01
0.02
0.00

0.00
–0.08
0.18
0.02

0.00
–0.05
0.01
0.68

0.10

0.02

0.12

0.64

–1.70

–0.36

–2.07

–1.46

PART III—NATIONAL WEALTH AND WELFARE
Unlike a private corporation, the Federal Government
routinely invests in ways that do not add directly to
its assets. For example, Federal grants are frequently
used to fund capital projects by State or local Governments for highways and other purposes. Such investments are valuable to the public, which pays for them
with taxes, but they are not owned by the Federal
Government and would not show up on a conventional
Federal balance sheet.
The Federal Government also invests in education
and research and development (R&D). These outlays
contribute to future productivity and are analogous to
an investment in physical capital. Indeed, economists
have computed stocks of human and knowledge capital
to reflect the accumulation of such investments. Nonetheless, such hypothetical capital stocks are obviously
not owned by the Federal Government, nor would they
appear on a conventional balance sheet.

To show the importance of these kinds of issues,
Table 2–4 presents a national balance sheet. It includes
estimates of national wealth classified into three categories: physical assets, education capital, and R&D
capital. The Federal Government has made contributions to each of these categories of capital, and these
contributions are shown separately in the table. Data
in this table are especially uncertain, because of the
strong assumptions needed to prepare the estimates.
The conclusion of the table is that Federal investments are responsible for about 7 percent of total national wealth. This may seem like a small fraction,
but it represents a large volume of capital—$4.8 trillion. The Federal contribution is down from around 9
percent in the mid-1980s, and from around 12 percent
in 1960. Much of this reflects the shrinking size of
the defense capital stocks, which have gone down from
12 percent of GDP to 7 percent since the end of the
Cold War.

39

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

Table 2–4. NATIONAL WEALTH
(As of the end of the fiscal year, in trillions of 1999 dollars)
1960

1965

1970

1975

1980

1985

1990

1995

1997

1998

1999

ASSETS

Publically Owned Physical Assets:
Structures and Equipment .................................................................................
Federally Owned or Financed .......................................................................
Federally Owned .......................................................................................
Grants to State and Local Governments .................................................
Funded by State and Local Governments ...................................................
Other Federal Assets .........................................................................................

2.0
1.2
1.0
0.1
0.8
0.7

2.4
1.3
1.1
0.2
1.0
0.6

2.9
1.4
1.1
0.3
1.4
0.6

3.4
1.5
1.0
0.5
1.9
0.8

3.6
1.6
0.9
0.6
2.1
1.1

3.9
1.8
1.1
0.7
2.1
1.3

4.2
2.0
1.2
0.8
2.3
1.0

4.7
2.0
1.1
0.9
2.6
0.8

4.9
2.0
1.1
1.0
2.8
0.8

4.8
2.0
1.0
1.0
2.8
0.8

4.8
2.0
1.0
1.0
2.7
0.8

Subtotal ......................................................................................................

2.7

3.0

3.5

4.2

4.8

5.2

5.3

5.4

5.7

5.6

5.6

Privately Owned Physical Assets:
Reproducible Assets ..........................................................................................
Residential Structures ....................................................................................
Nonresidential Plant & Equipment ................................................................
Inventories ......................................................................................................
Consumer Durables .......................................................................................
Land ....................................................................................................................

6.5
2.5
2.6
0.6
0.8
2.0

7.5
2.9
3.0
0.7
0.9
2.4

9.2
3.5
3.7
0.8
1.1
2.7

11.7
4.5
4.9
1.0
1.3
3.6

15.2
6.1
6.3
1.2
1.6
5.4

16.2
6.3
6.9
1.2
1.7
6.1

18.4
7.3
7.7
1.3
2.2
6.0

20.2
8.2
8.3
1.3
2.4
4.8

21.4
8.7
8.8
1.3
2.5
5.1

22.2
9.1
9.2
1.3
2.6
5.3

23.2
9.4
9.7
1.4
2.7
5.6

Subtotal ..........................................................................................................

8.5

9.8

11.9

15.4

20.6

22.3

24.4

25.0

26.5

27.6

28.8

Education Capital:
Federally Financed .............................................................................................
Financed from Other Sources ...........................................................................

0.1
5.8

0.1
7.4

0.2
10.0

0.3
12.3

0.4
15.9

0.6
19.3

0.7
24.9

0.8
27.5

0.9
29.7

1.0
31.5

1.0
33.3

Subtotal ..........................................................................................................

5.8

7.5

10.2

12.6

16.4

19.8

25.6

28.3

30.6

32.5

34.3

Research and Development Capital:
Federally Financed R&D ....................................................................................
R&D Financed from Other Sources ..................................................................

0.2
0.1

0.3
0.2

0.5
0.3

0.5
0.4

0.6
0.4

0.6
0.6

0.8
0.8

0.9
1.0

0.9
1.2

0.9
1.2

0.9
1.3

Subtotal ..........................................................................................................

0.3

0.5

0.7

0.9

1.0

1.3

1.6

1.9

2.1

2.2

2.2

17.3

20.8

26.2

33.0

42.8

48.6

56.9

60.6

64.8

67.8

70.9

Total Assets ...............................................................................................
Net Claims of Foreigners on U.S. (+) .....................................................................

-0.1

-0.2

-0.1

-0.1

-0.3

0.0

0.8

1.5

2.2

2.5

3.5

Balance .......................................................................................................

17.4

21.0

26.4

33.1

43.1

48.5

56.1

59.1

62.6

65.2

67.4

96.1
7.0
0.4
11.9

107.8
6.7
0.5
11.3

128.7
7.1
0.8
10.3

153.2
7.8
1.2
9.3

188.7
8.5
2.1
8.6

203.0
8.1
3.1
8.9

223.7
8.0
3.8
8.0

224.3
7.5
4.2
7.6

232.9
7.3
4.5
7.4

240.5
7.3
4.6
7.1

246.1
7.2
4.8
7.1

ADDENDA:

Per Capita Balance (thousands of dollars) ...........................................................
Ratio of Balance to GDP (in percent) ...................................................................
Total Federally Funded Capital (trillions of 1999 dollars) ....................................
Percent of National Wealth ....................................................................................

Physical Assets:
The physical assets in the table include stocks of
plant and equipment, office buildings, residential structures, land, and the Government’s physical assets such
as military hardware and highways. Automobiles and
consumer appliances are also included in this category.
The total amount of such capital is vast, around $34
trillion in 1999; by comparison, GDP was about $9 trillion.
The Federal Government’s contribution to this stock
of capital includes its own physical assets plus $1 trillion in accumulated grants to State and local Governments for capital projects. The Federal Government has
financed about one-fourth of the physical capital held
by other levels of Government.
Education Capital:
Economists have developed the concept of human capital to reflect the notion that individuals and society
invest in people as well as in physical assets. Invest-

ment in education is a good example of how human
capital is accumulated.
This table includes an estimate of the stock of capital
represented by the Nation’s investment in formal education and training. The estimate is based on the cost
of replacing the years of schooling embodied in the U.S.
population aged 16 and over; in other words, the idea
is to measure how much it would cost to reeducate
the U.S. workforce at today’s prices (rather than at
its original cost). This is more meaningful economically
than the historical cost, and is comparable to the measures of physical capital presented earlier.
Although this is a relatively crude measure, it does
provide a rough order of magnitude for the current
value of the investment in education. According to this
measure, the stock of education capital amounted to
$34 trillion in 1999, of which about 3 percent was financed by the Federal Government. It is equal in total
value to the Nation’s stock of physical capital. The main
investors in education capital have been State and local

40
governments, parents, and students themselves (who
forgo earning opportunities in order to acquire education).
Even broader concepts of human capital have been
suggested. Not all useful training occurs in a schoolroom or in formal training programs at work. Much
informal learning occurs within families or on the job,
but measuring its value is very difficult. However, labor
compensation amounts to about two-thirds of national
income, and thinking of this income as the product
of human capital suggests that the total value of
human capital might be two times the estimated value
of physical capital. Thus, the estimates offered here
are in a sense conservative, because they reflect the
costs of acquiring only formal education and training.
Research and Development Capital:
Research and Development can also be thought of
as an investment, because R&D represents a current
expenditure that is made in the expectation of earning
a future return. After adjusting for depreciation, the
flow of R&D investment can be added up to provide
an estimate of the current R&D stock. 10 That stock
is estimated to have been about $2 trillion in 1999.
Although this is a large amount of research, it is a
relatively small portion of total National wealth. Of
this stock, about 40 percent was funded by the Federal
Government.
Liabilities:
When considering how much the United States owes
as a Nation, the debts that Americans owe to one another cancel out. This means they do not belong in
Table 2–4, which is intended to show National totals
only, but it does not mean they are unimportant. (An
unwise buildup in debt, most of which was owed to
other Americans, was partly responsible for the recession of 1990–1991 and the sluggishness of the early
stages of the recovery that followed.) The only debt
that appears in Table 2–4 is the debt that Americans
owe to foreign investors. America’s foreign debt has
been increasing rapidly in recent years, because of the
continuing deficit in the U.S. current account which
has been rising; but even so, the size of this debt remains small compared with the total stock of U.S. assets. It amounted to 5 percent of the total assets in
Table 2–4 in 1999.
Most Federal debt does not appear in Table 2–4 because it is held by Americans; only that portion of the
Federal debt held by foreigners is included. However,
comparing the Federal Government’s net liabilities with
total national wealth gives another indication of the
relative magnitude of the imbalance in the Government’s accounts. Currently, the Federal net asset imbalance, as estimated in Table 2–1, amounts to about
5 percent of net U.S. wealth as shown in Table 2–4.
10 R&D depreciates in the sense that the economic value of applied research and development tends to decline with the passage of time, as still newer ideas move the technological
frontier.

ANALYTICAL PERSPECTIVES

Trends in National Wealth
The net stock of wealth in the United States at the
end of 1999 was about $67 trillion. Since 1980, the
stocks of it has increased in real terms at an average
annual rate of 2.4 percent per year—only half the 4.7
percent real growth rate it averaged from 1960 to 1980.
Public physical capital formation has slowed even more
drastically. Since 1980, the stock of public physical capital has increased at an annual rate of only 0.8 percent,
compared with 2.9 percent over the previous 20 years.
The net stock of private nonresidential plant and
equipment grew 2.3 percent per year from 1980 to 1999,
compared with 4.5 percent in the 1960s and 1970s;
and the stock of business inventories increased even
less, just 0.6 percent per year on average since 1980.
However, private nonresidential fixed capital has increased more rapidly since 1992—3.2 percent per year—
reflecting the recent investment boom.
The accumulation of education capital, as measured
here, has also slowed down since 1980, but not as
much. It grew at an average rate of 5.2 percent per
year in the 1960s and 1970s, about 0.9 percentage point
faster than the average rate of growth in private physical capital during the same period. Since 1980, education capital has grown at a 4.0 percent annual rate.
This reflects the extra resources devoted to schooling
in this period, and the fact that such resources were
increasing in economic value. R&D stocks have grown
at about 4.4 percent per year since 1980, the fastest
growth rate for any major category of investment over
this period, but slower than the growth of R&D in
the 1960s and 1970s.
Other Federal Influences on Economic Growth
Federal policies contributed to the slowdown in capital formation that occurred after 1980. Federal investment decisions, as reflected in Table 2–4, obviously
were important, but the Federal Government also contributes to wealth in ways that cannot be easily captured in a formal presentation. The Federal Reserve’s
monetary policy affects the rate and direction of capital
formation in the short run, and Federal regulatory and
tax policies also affect how capital is invested, as do
the Federal Government’s policies on credit assistance
and insurance.
One important channel of influence is the Federal
budget surplus/deficit, which determines the size of
Federal saving when it is positive or the Federal borrowing requirement when it is negative. Had deficits
been smaller in the 1980s, the gap between Federal
liabilities and assets shown in Table 2–1 would be
smaller today. It is also likely that, had the more than
$3 trillion in added Federal debt since 1980 been avoided, a significant share of these funds would have gone
into private investment. National wealth might have
been 3 to 5 percent larger in 1999 had fiscal policy
avoided the buildup in the debt.

41

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

Social Indicators
There are certain broad responsibilities that are
unique to the Federal Government. Especially important are fostering healthy economic conditions, promoting health and social welfare, and protecting the
environment. Table 2–5 offers a rough cut of information that can be useful in assessing how well the Federal Government has been doing in promoting these
general objectives.
The indicators shown here are a limited subset drawn
from the vast array of available data on conditions in
the United States. In choosing indicators for this table,
priority was given to measures that were consistently
available over an extended period. Such indicators
make it easier to draw valid comparisons and evaluate
trends. In some cases, however, this meant choosing
indicators with significant limitations.

The individual measures in this table are influenced
to varying degrees by many Government policies and
programs, as well as by external factors beyond the
Government’s control. They do not measure the outcomes of Government policies, because they generally
do not show the direct results of Government activities,
but they do provide a quantitative measure of the
progress or lack of progress in reaching some of the
ultimate values that Government policy is intended to
promote.
Such a table can serve two functions. First, it highlights areas where the Federal Government might need
to modify its current practices or consider new approaches. Where there are clear signs of deteriorating
conditions, corrective action might be appropriate. Second, the table provides a context for evaluating other
data on Government activities. For example, Government actions that weaken its own financial position

Table 2–5. ECONOMIC AND SOCIAL INDICATORS
General categories

Economic:
Living Standards .........

Economic Security ......
Employment Prospects
Wealth Creation ..........
Innovation ....................
Social:
Families .......................
Safe Communities .......

Health and Illness .......

Learning .......................

Participation .................

Environment:
Air Quality ...................

Water Quality ..............
1 The

Specific measures

1960

1965

1970

1975

1980

1985

1990

1995

1997

1998

1999

Real GDP per person (1996 dollars) .................................
average annual percent change (5-year trend) ............
Median Income (1998 dollars):.
All Households ...............................................................
Married Couple Families ................................................
Female Householder, No Spouse Present ....................
Income Share of Lower 60 percent of All Families ..........

13,038
NA

15,454
3.5

17,306
2.3

18,751
1.6

21,398
2.7

23,857
2.2

26,734
2.3

28,647
1.4

30,467
2.5

31,472
2.9

32,407
2.9

NA
29,730
15,024
34.8

NA
34,626
16,834
35.2

34,471
41,504
20,101
35.2

34,224
43,120
19,850
35.2

35,076
45,832
20,614
34.5

35,778
47,112
20,693
32.7

37,343
49,754
21,116
32.0

36,446
50,335
21,061
30.3

37,581
52,395
21,350
29.8

38,885
54,180
22,163
29.8

NA
NA
NA
NA

Poverty Rate (percent) 1 .....................................................
Civilian Unemployment (percent) .......................................
CPI-U (Percent Change) ....................................................
Increase in Total Payroll Employment (millions) ...............
Managerial or Professional Jobs (percent of total) ...........
Net National Saving Rate (percent of GDP) .....................
Patents Issued to U.S. Residents (thousands) .................
Multifactor Productivity (average annual percent change)

22.2
5.5
1.7
–0.5
NA
10.2
42.1
1.0

17.3
4.5
1.6
2.9
NA
12.1
54.1
3.1

12.6
4.9
5.8
–0.5
NA
8.2
50.1
1.0

12.3
8.5
9.1
0.4
NA
6.5
40.5
1.2

13.0
7.1
13.5
0.2
NA
7.5
40.8
0.7

14.0
7.2
3.5
2.5
24.1
6.0
43.5
0.6

13.5
5.5
5.4
0.3
25.8
4.6
53.0
0.3

13.8
5.6
2.8
2.2
28.3
4.7
64.5
0.2

13.3
5.0
2.3
3.4
29.1
6.2
70.0
0.6

12.7
4.5
1.6
2.9
29.6
6.6
90.7
NA

NA
4.2
2.2
NA
NA
6.5
NA
NA

Children Living with Mother Only (percent of all children)
Violent Crime Rate (per 100,000 population) 2 .................
Murder Rate (per 100,000 population) 2 ............................
Murders/Nonnegligent Manslaughter per 100,000 Persons Age 14 to 17).
Infant Mortality (per 1000 Live Births) 3 .............................
Low Birthweight [<2,500 gms] Babies (percent) ...............
Life Expectancy at birth (years) .........................................
Cigarette Smokers (percent population 18 and older) ......
Bed Disability Days (average days per person) ...............
High School Graduates (percent of population 25 and
older).
College Graduates (percent of population 25 and older)
National Assessment of Educational Progress 3.
Mathematics High School Seniors .................................
Science High School Seniors ........................................
Voting for President (percent eligible population) .............
Voting for Congress (percent eligible population) .............
Individual Charitable Giving per Capita (1999 dollars) .....

9.2
160
5
NA

10.2
199
5
NA

11.6
364
8
NA

16.4
482
10
11

18.6
597
10
13

20.2
557
8
10

21.6
732
9
24

24.0
685
8
24

23.2
611
7
17

23.6
566
6
NA

NA
521
5
NA

26.0
7.7
69.7
NA
6.0
44.6

24.7
8.3
70.2
42.3
6.2
49.0

20.0
7.9
70.8
39.5
6.1
55.2

16.1
7.4
72.6
36.5
6.6
62.5

12.6
6.8
73.7
33.2
7.0
68.6

10.6
6.8
74.7
30.0
6.1
73.9

9.2
7.0
75.4
25.4
6.2
77.6

7.6
7.3
75.8
24.7
6.1
81.7

7.2
7.5
76.5
24.7
NA
82.1

7.2
7.6
76.7
NA
NA
82.8

NA
NA
NA
NA
NA
NA

8.4

9.4

11.0

13.9

17.0

19.4

21.3

23.0

23.9

24.4

NA

NA
NA
62.8
58.5
218

NA
NA
NA
NA
261

NA
305
NA
43.5
313

302
293
NA
NA
332

300
286
52.8
47.6
362

301
288
NA
NA
373

305
290
NA
33.1
413

307
295
NA
NA
398

NA
NA
NA
NA
423

NA
NA
NA
33.4
NA

NA
NA
NA
NA
NA

14,140
22,245
NA
NA

17,424
26,380
NA
NA

21,369
31,161
221
NA

23,151
28,011
160
NA

24,875
25,905
74
NA

23,488
23,230
23
134

23,436
23,678
5
155

23,768
19,189
4
166

23,576
NA
4
NA

NA
NA
NA
NA

NA
NA
NA
NA

Nitrogen Oxide Emissions (thousand short tons) ..............
Sulfur Dioxide Emissions (thousand short tons) ...............
Lead Emissions (thousand short tons) ..............................
Population Served by Secondary Treatment or Better
(millions).

poverty rate does not reflect noncash government transfers such as Medicaid or food stamps.
all crimes are reported, and the fraction that go unreported may have varied over time, 1999 data are preliminary.
3 Some data from the national educational assessments have been interpolated.
2 Not

42

ANALYTICAL PERSPECTIVES

may be appropriate when they promote a broader social
objective.
An example of this occurs during economic recessions,
when reductions in tax collections lead to increased
Government borrowing that adds to Federal liabilities.
This decline in Federal net assets, however, provides
an automatic stabilizer for the private sector. State and
local Governments and private budgets are strengthened by allowing the Federal budget to go into deficit.
More stringent Federal budgetary controls could be
used to hold down Federal borrowing during such periods, but only at the risk of aggravating the downturn
and weakening the other sectors.
The Government cannot avoid making such tradeoffs because of its size and the broad ranging effects
of its actions. Monitoring these effects and incorporating them in the Government’s policy making is
a major challenge.
It is worth noting that, in recent years, many of
the indicators in this table have turned around. The
improvement in economic conditions has been widely
noted, but there have also been some significant social
improvements. Perhaps most notable has been the turnaround in the crime rate. Since reaching a peak in

the early 1990s, the violent crime rate has fallen by
over 25 percent, and preliminary data suggest that the
improvement continued in 1999. The turnaround is especially dramatic in the murder rate, which is lower
now than at any time since the 1960s. Government
policies are only one set of factors in this remarkable
reversal, but more effective policing along with broader
changes that have helped improve economic prospects
for all Americans appear to be having a good effect.
An Interactive Analytical Framework
No single framework can encompass all of the factors
that affect the financial condition of the Federal Government. Nor can any framework serve as a substitute
for actual analysis. Nevertheless, the framework presented here offers a useful way to examine the financial
aspects of Federal policies. Increased Federal support
for investment, the promotion of national saving
through fiscal policy, and other Administration policies
to enhance economic growth are expected to promote
national wealth and improve the future financial condition of the Federal Government. As that occurs, the
efforts will be revealed in these tables.

TECHNICAL NOTE: SOURCES OF DATA AND METHOD OF ESTIMATING
Federally Owned Assets and Liabilities
Assets:
Financial Assets: The source of data is the Federal
Reserve Board’s Flow-of-Funds Accounts. The gold stock
was revalued using the market value for gold.
Physical Assets:
Fixed Reproducible Capital: Estimates were developed from the OMB historical data base for physical
capital outlays and software purchases. The data base
extends back to 1940 and was supplemented by data
from other selected sources for 1915–1939. The source
data are in current dollars. To estimate investment
flows in constant dollars, it was necessary to deflate
the nominal investment series. This was done using
price deflators for Federal investment from the National Income and Product Accounts.
Fixed Nonreproducible Capital: Historical estimates
for 1960–1985 were based on estimates in Michael J.
Boskin, Marc S. Robinson, and Alan M. Huber, ‘‘Government Saving, Capital Formation and Wealth in the
United States, 1947–1985,’’ published in The Measurement of Saving, Investment, and Wealth, edited by Robert E. Lipsey and Helen Stone Tice (The University
of Chicago Press, 1989).
Estimates were updated using changes in the value
of private land from the Flow-of-Funds Balance Sheets
and for oil deposits from the Producer Price Index for
Crude Energy Materials.
Liabilities:
Financial Liabilities: The principal source of data is
the Federal Reserve’s Flow-of-Funds Accounts.

Insurance Liabilities: Sources of data are the OMB
Deposit Insurance Model and the OMB Pension Guarantee Model. Historical data on liabilities for deposit
insurance were also drawn from the CBO’s study, The
Economic Effects of the Savings and Loan Crisis, issued
January 1992.
Pension Liabilities: For 1979–1998, the estimates are
the actuarial accrued liabilities as reported in the annual reports for the Civil Service Retirement System,
the Federal Employees Retirement System, and the
Military Retirement System (adjusted for inflation). Estimates for the years before 1979 are extrapolations.
The estimate for 1999 is a projection.
Long-Run Budget Projections
The long-run budget projections are based on longrun demographic and economic projections. A simplified
model of the Federal budget developed at OMB computes the budgetary implications of this forecast.
Demographic and Economic Projections: For the years
2000–2010, the assumptions are identical to those used
in the budget. These budget assumptions reflect the
President’s policy proposals. The long-run projections
extend these budget assumptions by holding inflation,
interest rates, and unemployment constant at the levels
assumed in the final year of the budget. Population
growth and labor force growth are extended using the
intermediate assumptions from the 1999 Social Security
Trustees’ report. The projected rate of growth for real
GDP is built up from the labor force assumptions and
an assumed rate of productivity growth. The assumed
rate of productivity growth is held constant at the aver-

2. STEWARDSHIP: TOWARD A FEDERAL BALANCE SHEET

age rate of growth implied by the budget’s economic
assumptions.
Budget Projections: For the budget period through
2010, the projections follow the budget. Beyond the
budget horizon, receipts are projected using simple
rules of thumb linking income taxes, payroll taxes, excise taxes, and other receipts to projected tax bases
derived from the economic forecast. Outlays are computed in different ways. Discretionary spending is projected according to current services assumptions in
which it grows at the composite rate of inflation in
Federal pay and non-pay spending; it is also projected
on alternative assumptions which permit it to grow
with both inflation and population, and also to grow
with nominal GDP. Social Security is projected by the
Social Security actuaries using these long-range assumptions. Medicare and Federal pensions are derived
from the most recent actuarial forecasts available at
the time the budget was prepared, repriced using Administration inflation assumptions. OMB’s Health Division projects Medicaid outlays based on the economic
and demographic projections in the model. Other entitlement programs are projected based on rules of thumb
linking program spending to elements of the economic
and demographic forecast such as the poverty rate.
National Balance Sheet Data
Publicly Owned Physical Assets: Basic sources of data
for the federally owned or financed stocks of capital
are the Federal investment flows described in Chapter
6. Federal grants for State and local Government capital are added, together with adjustments for inflation
and depreciation in the same way as described above
for direct Federal investment. Data for total State and
local Government capital come from the revised capital
stock data prepared by the Bureau of Economic Analysis extrapolated for 1998–1999.
Privately Owned Physical Assets: Data are from the
Flow-of-Funds national balance sheets and from the private net capital stock estimates prepared by the Bureau
of Economic Analysis extrapolated for 1998–1999 using
investment data from the National Income and Product
Accounts.
Education Capital: The stock of education capital is
computed by valuing the cost of replacing the total
years of education embodied in the U.S. population 16
years of age and older at the current cost of providing
schooling. The estimated cost includes both direct expenditures in the private and public sectors and an
estimate of students’ forgone earnings, i.e., it reflects
the opportunity cost of education.
Estimates of students’ forgone earnings are based on
the year-round, full-time earnings of 18–24 year olds
with selected educational attainment levels. These yearround earnings are reduced by 25 percent because students are usually out of school three months of the
year. For high school students, these adjusted earnings
are further reduced by the unemployment rate for
16–17 year olds; for college students, by the unemployment rate for 20–24 year olds. Yearly earnings by age

43
and educational attainment are from Money Income in
the United States, series P60, published by the Bureau
of the Census.
For this presentation, Federal investment in education capital is a portion of the Federal outlays included in the conduct of education and training. This
portion includes direct Federal outlays and grants for
elementary, secondary, and vocational education and
for higher education. The data exclude Federal outlays
for physical capital at educational institutions because
these outlays are classified elsewhere as investment
in physical capital. The data also exclude outlays under
the GI Bill; outlays for graduate and post-graduate education spending in HHS, Defense and Agriculture; and
most outlays for vocational training.
Data on investment in education financed from other
sources come from educational institution reports on
the sources of their funds, published in U.S. Department of Education, Digest of Education Statistics.
Nominal expenditures were deflated by the implicit
price deflator for GDP to convert them to constant dollar values. Education capital is assumed not to depreciate, but to be retired when a person dies. An education capital stock computed using this method with
different source data can be found in Walter McMahon,
‘‘Relative Returns To Human and Physical Capital in
the U.S. and Efficient Investment Strategies,’’ Economics of Education Review, Vol. 10, No. 4, 1991. The method is described in detail in Walter McMahon, Investment in Higher Education, Lexington Books, 1974.
Research and Development Capital: The stock of R&D
capital financed by the Federal Government was developed from a data base that measures the conduct of
R&D. The data exclude Federal outlays for physical
capital used in R&D because such outlays are classified
elsewhere as investment in federally financed physical
capital. Nominal outlays were deflated using the GDP
deflator to convert them to constant dollar values.
Federally funded capital stock estimates were prepared using the perpetual inventory method in which
annual investment flows are cumulated to arrive at
a capital stock. This stock was adjusted for depreciation
by assuming an annual rate of depreciation of 10 percent on the estimated stock of applied research and
development. Basic research is assumed not to depreciate. The 1993 Budget contains additional details on
the estimates of the total federally financed R&D stock,
as well as its national defense and nondefense components (see Budget for Fiscal Year 1993, January 1992,
Part Three, pages 39–40).
A similar method was used to estimate the stock
of R&D capital financed from sources other than the
Federal Government. The component financed by universities, colleges, and other nonprofit organizations is
estimated based on data from the National Science
Foundation, Surveys of Science Resources. The industry-financed R&D stock component is estimated from
that source and from the U.S. Department of Labor,
The Impact of Research and Development on Productivity Growth, Bulletin 2331, September 1989.

44
Experimental estimates of R&D capital stocks have
recently been prepared by BEA. The results are described in ‘‘A Satellite Account for Research and Development,’’ Survey of Current Business, November 1994.
These BEA estimates are lower than those presented
here primarily because BEA assumes that the stock
of basic research depreciates, while the estimates in
Table 2–4 assume that basic research does not depreciate. BEA also assumes a slightly higher rate of depre-

ANALYTICAL PERSPECTIVES

ciation for applied research and development, 11 percent, compared with the 10 percent rate used here.
Social Indicators
The main sources for the data in this table are the
Government statistical agencies. Generally, the data
are publicly available in such general sources as the
annual Economic Report of the President and the Statistical Abstract of the United States, and from the agencies’ Web sites.

FEDERAL RECEIPTS AND COLLECTIONS

45

3.

FEDERAL RECEIPTS

Receipts (budget and off-budget) are taxes and other
collections from the public that result from the exercise
of the Federal Government’s sovereign or governmental
powers. The difference between receipts and outlays
determines the surplus or deficit.
The Federal Government also collects income from
the public from market-oriented activities. Collections
from these activities, which are subtracted from gross
outlays, rather than added to taxes and other governmental receipts, are discussed in the following chapter.

Growth in receipts.—Total receipts in 2001 are estimated to be $2,019.0 billion, an increase of $62.8 billion
or 3.2 percent relative to 2000. This increase is largely
due to assumed increases in incomes resulting from
both real economic growth and inflation. Receipts are
projected to grow at an average annual rate of 3.8
percent between 2001 and 2005, rising to $2,340.9 billion.
As a share of GDP, receipts are projected to decline
from 20.4 percent in 2000 to 19.4 percent in 2005.

Table 3–1. RECEIPTS BY SOURCE—SUMMARY
(In billions of dollars)
Estimate
Source

1999 actual
2000

2001

2002

2003

2004

2005

Individual income taxes ...................................................................
Corporation income taxes ...............................................................
Social insurance and retirement receipts .......................................
(On-budget) ..................................................................................
(Off-budget) ..................................................................................
Excise taxes .....................................................................................
Estate and gift taxes .......................................................................
Customs duties ................................................................................
Miscellaneous receipts ....................................................................

879.5
184.7
611.8
(167.4)
(444.5)
70.4
27.8
18.3
34.9

951.6
192.4
650.0
(173.3)
(476.8)
68.4
30.5
20.9
42.5

972.4
194.8
682.1
(182.2)
(499.9)
76.7
32.3
20.9
39.9

995.2
195.4
712.2
(189.9)
(522.2)
79.8
34.9
22.6
41.2

1,025.6
195.7
741.7
(197.4)
(544.2)
80.8
36.3
24.3
43.2

1,066.1
200.0
771.3
(204.7)
(566.7)
81.8
38.7
25.7
52.6

1,116.8
205.9
815.3
(216.7)
(598.6)
83.4
37.0
27.9
54.5

Total receipts .........................................................................
(On-budget) .........................................................................
(Off-budget) .........................................................................

1,827.5
(1,383.0)
(444.5)

1,956.3
(1,479.5)
(476.8)

2,019.0
(1,519.1)
(499.9)

2,081.2
(1,559.0)
(522.2)

2,147.5
(1,603.2)
(544.2)

2,236.1
(1,669.4)
(566.7)

2,340.9
(1,742.3)
(598.6)

Table 3–2. EFFECT ON RECEIPTS OF CHANGES IN THE SOCIAL SECURITY TAXABLE EARNINGS BASE
(In billions of dollars)
Estimate

Social security (OASDI) taxable earnings base increases:.
$76,200 to $80,100 on Jan. 1, 2001 .........................................................................................................................
$80,100 to $83,700 on Jan. 1, 2002 .........................................................................................................................
$83,700 to $87,300 on Jan. 1, 2003 .........................................................................................................................
$87,300 to $90,600 on Jan. 1, 2004 .........................................................................................................................
$90,600 to $93,900 on Jan. 1, 2005 .........................................................................................................................

2001

2002

2003

2004

1.8
................
................
................
................

4.8
1.6
................
................
................

5.2
4.3
1.6
................
................

5.7
4.7
4.3
1.5
................

2005

6.3
5.2
4.7
4.0
1.5

47

48

ANALYTICAL PERSPECTIVES

ENACTED LEGISLATION
Several laws were enacted in 1999 that have an effect
on governmental receipts. The major legislative changes
affecting receipts are described below.
To Extend the Tax Benefits Available With Respect to Services Performed in a Combat Zone to
Services Performed in the Federal Republic of
Yugoslavia (Serbia/Montenegro) and Certain
Other Areas, and for Other Purposes.—This Act,
which was signed by President Clinton on April 19,
1999, provides the same tax relief to military personnel
participating in Operation Allied Force as that provided
as a consequence of the Executive Order that designates the Kosovo area of operations as a combat zone.
In addition, this Act extends the tax filing and payment
deadlines provided as a consequence of the Executive
Order to military personnel outside the United States
who are deployed outside their duty station as part
of Operation Allied Force.
Under the Executive Order, which was issued by
President Clinton on April 13, 1999, the Kosovo area
of operations, including the above airspace, encompasses The Federal Republic of Yugoslavia (Serbia/Montenegro), Albania, the Adriatic Sea, and the Ionian Sea
above the 39th parallel. The tax benefits provided military personnel serving in those areas include extension
of deadlines for filing and paying taxes; exemption of
military pay earned while serving in the combat zone
(subject to a dollar limit for commissioned officers) from
withholding and income tax; and, exemption of toll telephone calls originating in the combat zone from the
telephone excise tax.
Miscellaneous Trade and Technical Corrections
Act of 1999—This Act makes miscellaneous technical
and clerical corrections to U.S. trade laws, corrects obsolete references, and authorizes the temporary suspension or refund of tariffs on over 120 categories of imported items. These items include 13 inch televisions,
chemicals (some of which are used to develop cancer
and AIDS-fighting drugs), textile printing machines,
weaving machines, manufacturing equipment, certain
rocket engines, and a number of pigments and dyes.
The Act also extends tariff credits for wages paid in
the production of watches in the Virgin Islands to the
production of fine jewelry. The receipt losses associated
with the tariff refunds and suspensions are offset by
a provision that clarifies the tax treatment of certain
corporate restructuring transactions, which is described
below.
Restrict basis creation through section 357(c).—A
transferor generally is required to recognize gain on
a transfer of property in certain tax-free exchanges to
the extent that the sum of the liabilities assumed, plus
those to which the transferred property is subject, exceeds the transferor’s basis in the property. This gain
recognition to the transferor generally increases the
basis of the transferred property in the hands of the
transferee. However, if a recourse liability is secured

by multiple assets, prior law was unclear as to whether
a transfer of one asset, where the transferor remains
liable, is a transfer of property ‘‘subject to’’ the liability.
Similar issues exist with respect to nonrecourse liabilities. Under this provision, the distinction between the
assumption of a liability and the acquisition of an asset
subject to a liability generally is eliminated. Except
as provided in regulations, a recourse liability is treated
as assumed to the extent that the transferee has agreed
and is expected to satisfy the liability (whether or not
the transferor has been relieved of the liability). Except
as provided in regulations, a nonrecourse liability is
treated as assumed by the transferee of any asset subject to the liability. However, the amount of nonrecourse liability treated as assumed is reduced by the
amount of the liability that an owner of other assets
not transferred to the transferee and also subject to
the liability has agreed with the transferee to satisfy,
and is expected to satisfy, up to the fair market value
of such other assets. The transferor’s recognition of gain
as a result of assumption of liability shall not increase
the transferee’s basis in the transferred asset to an
amount in excess of its fair market value. Moreover,
if no person is subject to U.S. tax on gain recognized
as the result of the assumption of a nonrecourse liability, then the transferee’s basis in the transferred assets
is increased only to the extent such basis would be
increased if the transferee had assumed only a ratable
portion of the liability, based on the relative fair market
value of all assets subject to such nonrecourse liability.
The Treasury Department has authority to prescribe
regulations necessary to carry out the purposes of the
provision, and to apply the treatment set forth in this
provision where appropriate elsewhere in the Internal
Revenue Code. This provision applies to transfers made
after October 18, 1998.
Consolidated Appropriations Act for FY 2000.—
This Act, which was signed by President Clinton on
November 30, 1999, makes progress on several important fronts: it puts education first, makes America a
safer place, strengthens our effort to preserve natural
areas and protect our environment, and strengthens
America’s leadership role in the world. Although most
of the provisions in this Act affect Federal spending
programs, a transfer from the surplus funds of the Federal Reserve System to the Treasury of $3.752 billion
in FY 2000 affects governmental receipts.
Ticket to Work and Work Incentives Improvement Act of 1999.—This Act, which was signed by
President Clinton on December 17, 1999, ensures that
individuals with disabilities have a greater opportunity
to participate in the workforce and in the American
Dream and extends important tax provisions. Despite
these accomplishments, the President is disappointed
that this Act includes a provision for a special allowance adjustment for student loans, that it delays the
implementation of a proposed Department of Health

3.

FEDERAL RECEIPTS

and Human Services final rule on the distribution of
human organs for transplantation, and that the revenue losses are not fully offset. The major provisions
of this Act affecting governmental receipts are described
below.
Expired and Expiring Provisions
Extend minimum tax relief for individuals.—Certain
nonrefundable personal tax credits (dependent care
credit, credit for the elderly and disabled, adoption credit, child tax credit, credit for interest on certain home
mortgages, HOPE Scholarship and Lifetime Learning
credit, and the D.C. homebuyer’s credit) are provided
under current law. Generally, these credits are allowed
only to the extent that the individual’s regular income
tax liability exceeds the individual’s tentative minimum
tax. An additional child tax credit is provided under
current law to families with three or more qualifying
children. This credit, which may be offset against social
security payroll tax liability (provided that liability exceeds the amount of the earned income credit), is reduced by the amount of the individual’s minimum tax
liability (that is, the amount by which the individual’s
tentative minimum tax exceeds the individual’s regular
tax liability). For taxable year 1998, prior law allowed
nonrefundable personal tax credits to offset regular income tax liability in full (as opposed to only the amount
by which the regular tax liability exceeded the tentative
minimum tax). In addition, for taxable year 1998, the
additional child credit provided to families with three
or more qualifying children was not reduced by the
amount of the individual’s minimum tax liability. This
Act extends the provision that allows the nonrefundable
personal tax credits to offset regular income tax liability
in full to taxable years beginning in 1999. For taxable
years beginning in 2000 and 2001 the nonrefundable
personal credits may offset both the regular tax and
the minimum tax. In addition, for taxable years beginning in 1999, 2000, and 2001, the additional child credit
provided to families with three or more qualifying children will not be reduced by the amount of the individual’s minimum tax liability.
Extend and modify research and experimentation tax
credit.—The 20-percent tax credit for certain research
and experimentation expenditures is extended to apply
to qualifying expenditures paid or incurred during the
period July 1, 1999 through June 30, 2004. In addition,
effective for taxable years beginning after June 30,
1999, the credit rate applicable under the alternative
incremental research credit is increased by one percentage point per step, and the definition of qualified research is expanded to include research undertaken in
Puerto Rico and possessions of the United States.
Under this Act, credits attributable to the period beginning on July 1, 1999 and ending on September 30,
2000 may not be taken into account in determining
any amount required to be paid for any purpose under
the Internal Revenue Code prior to October 1, 2000.
On or after October 1, 2000, such credits may be taken
into account through the filing of an amended return,

49
an application for expedited refund, an adjustment of
estimated taxes, or other means that are allowed by
the Internal Revenue Code. Similarly, research credits
that are attributable to the period beginning on October
1, 2000 and ending on September 30, 2001 may not
be taken into account in determining any amount required to be paid for any purpose under the Internal
Revenue Code prior to October 1, 2001.
Extend exceptions provided under subpart F for certain active financing income.—Under the Subpart F
rules, certain U.S. shareholders of a controlled foreign
corporation (CFC) are subject to U.S. tax currently on
certain income earned by the CFC, whether or not such
income is distributed to the shareholders. The income
subject to current inclusion under the subpart F rules
includes ‘‘foreign personal holding company income’’ and
insurance income. The U.S. 10-percent shareholders of
a CFC also are subject to current inclusion with respect
to their shares of the CFC’s foreign base company services income (income derived from services performed
for a related person outside the country in which the
CFC is organized). For taxable years beginning in 1998
and 1999, certain income derived in the active conduct
of a banking, financing, insurance, or similar business
is excepted from the Subpart F rules regarding the
taxation of foreign personal holding company income
and foreign base company services income. This Act
extends the exception for two years, with very minor
modifications, to apply to taxable years beginning in
2000 and 2001.
Extend suspension of net income limitation on percentage depletion from marginal oil and gas wells.—Taxpayers are allowed to recover their investment in oil
and gas wells through depletion deductions. For certain
properties, deductions may be determined using the
percentage depletion method; however, in any year, the
amount deducted generally may not exceed 100 percent
of the net income from the property. For taxable years
beginning after December 31, 1997 and before January
1, 2000, domestic oil and gas production from ‘‘marginal’’ properties is exempt from the 100-percent of net
income limitation. This Act extends the exemption to
apply to taxable years beginning after December 1,
1999 and before January 1, 2002.
Extend the work opportunity tax credit.—The work
opportunity tax credit provides an incentive for employers to hire individuals from certain targeted groups.
The credit equals a percentage of qualified wages paid
during the first year of the individual’s employment
with the employer. The credit percentage is 25 percent
for employment of at least 120 hours but less than
400 hours and 40 percent for employment of 400 or
more hours. This Act extends the credit to apply to
individuals who begin work on or after July 1, 1999
and before January 1, 2002.
Extend the welfare-to-work tax credit.—The welfareto-work tax credit enables employers to claim a tax
credit on the first $20,000 of eligible wages paid to
certain long-term family assistance recipients. The credit is 35 percent of the first $10,000 of eligible wages

50
in the first year of employment and 50 percent of the
first $10,000 of eligible wages in the second year of
employment. Under this Act the credit is extended to
apply to individuals who begin work on or after July
1, 1999 and before January 1, 2002.
Extend exclusion for employer-provided educational
assistance.—Certain amounts paid by an employer for
educational assistance provided to an employee are excluded from the employee’s gross income for income
and payroll tax purposes. The exclusion is limited to
$5,250 of educational assistance with respect to an individual during a calendar year and applies whether or
not the education is job-related. The exclusion, which
is limited to undergraduate courses, is extended to
apply to courses beginning after May 31, 2000 and before January 1, 2002.
Extend and modify wind and biomass tax credit and
expand eligible biomass sources.—Taxpayers are provided a 1.5-cent-per-kilowatt-hour tax credit, adjusted
for inflation after 1992, for electricity produced from
wind or ‘‘closed-loop’’ biomass. Under prior law, the
credit applies to electricity produced by a facility placed
in service before July 1, 1999, and is allowable for
production during the 10-year period after a facility
is originally placed in service. This Act extends the
credit to apply to facilities placed in service after June
30, 1999 and before January 1, 2002. Electricity produced at a wind facility placed in service during this
period does not qualify for the credit, however, if it
is sold pursuant to a pre-1987 contract that has not
been modified to limit the purchaser’s obligation to acquire electricity at above-market prices. The Act also
expands the credit to apply to poultry waste facilities
placed in service after December 31, 1999 and before
January 1, 2002.
Extend Generalized System of Preferences (GSP).—
Under GSP, duty-free access is provided to over 4,000
items from eligible developing countries that meet certain worker rights, intellectual property protection, and
other criteria. This program, which had expired after
June 30, 1999, is extended through September 30, 2001.
Refunds of any duty paid between June 30, 1999 and
December 17, 1999 are provided upon request of the
importer.
Extend authority to issue Qualified Zone Academy
Bonds.—The Taxpayer Relief Act of 1997 (TRA97) included a provision that allows State and local governments to issue ‘‘qualified zone academy bonds,’’ the interest on which is effectively paid by the Federal government in the form of an annual income tax credit.
The proceeds of the bonds must be used for teacher
training, purchases of equipment, curricular development, and rehabilitation and repairs at certain public
school facilities. Under TRA97, a nationwide total of
$400 million of qualified zone academy bonds was authorized to be issued in each of calendar years 1998
and 1999. Effective December 17, 1999, an additional
$400 million of qualified zone academy bonds is authorized to be issued in each of calendar years 2000 and
2001. In addition, unused authority arising in 1998 and

ANALYTICAL PERSPECTIVES

1999 may be carried forward for up to three years and
unused authority arising in 2000 and 2001 may be carried forward for up to two years.
Extend tax credit for first-time D.C. homebuyers.—
The tax credit (up to $5,000) provided for the firsttime purchase of a principal residence in the District
of Columbia, which was scheduled to expire after December 31, 2000, is extended to apply to residences
purchased on or before December 31, 2001.
Extend expensing of brownfields remediation costs.—
Taxpayers can elect to treat certain environmental remediation expenditures that would otherwise be chargeable to capital account as deductible in the year paid
or incurred. The ability to deduct such expenditures
is extended for one year, to apply to expenditures paid
or incurred before January 1, 2002.
Time-Sensitive Provisions
Prohibit disclosure of advanced pricing agreements
(APAs) and APA background files.—Returns and return
information, as defined by the Internal Revenue Service
(IRS), are confidential and cannot be disclosed unless
authorized by the Internal Revenue Code. In contrast,
written determinations issued by the IRS generally are
available for public inspection. The APA program is
an alternative dispute resolution program conducted by
the IRS, which resolves international transfer pricing
issues prior to the filing of the corporate tax return.
To resolve such issues, the taxpayer submits detailed
and confidential financial information, business plans
and projections to the IRS for consideration. This Act
confirms that APAs and related background information are confidential return information and not written
determinations available for public inspection. Effective
December 17, 1999, APAs or related background files
are prohibited from being released to the public, regardless of whether the APA was executed before or after
that date. The Treasury Department also is required
to produce an annual report that contains general and
statistical information about the APA program, and
general descriptions of the APAs concluded during the
year.
Provide authority to postpone certain tax-related deadlines by reason of year 2000 (Y2K) failures.—The Secretary of the Treasury is permitted to postpone, on
a taxpayer-by-taxpayer basis, certain tax-related deadlines for a period of up to 90 days, if he determines
that the taxpayer has been affected by an actual Y2K
related failure. In order to be eligible for relief, the
taxpayer must have made a good faith, reasonable effort to avoid any Y2K related failures.
Expand list of taxable vaccines.—Under prior law an
excise tax of $.75 per dose is levied on the following
vaccines: diphtheria, pertussis, tetanus, measles,
mumps, rubella, polio, HIB (haemophilus influenza type
B), hepatitis B, rotavirus gastroenteritis, and varicella
(chickenpox). This Act adds any conjugate vaccine
against streptococcus pneumoniae to the list of taxable
vaccines, effective for vaccines sold by a manufacturer
or importer after December 17, 1999.

3.

51

FEDERAL RECEIPTS

Delay requirement that registered motor fuels terminals offer dyed fuel as a condition of registration.—
With limited exceptions, excise taxes are imposed on
all highway motor fuels when they are removed from
a registered terminal facility, unless the fuel is indelibly
dyed and is destined for a nontaxable use. Terminal
facilities are not permitted to receive and store
nontaxed motor fuels unless they are registered with
the IRS. Prior law requires that effective July 1, 2000,
in order to be registered, a terminal must offer for
sale both dyed and undyed fuel (the ‘‘dyed-fuel mandate’’). Under this Act the effective date of the dyedfuel mandate is postponed until January 1, 2002.
Provide that Federal production payments to farmers
are taxable in the year received. —A taxpayer generally
is required to include an item in income no later than
the time of its actual or constructive receipt, unless
such amount properly is accounted for in a different
period under the taxpayer’s method of accounting. If
a taxpayer has an unrestricted right to demand the
payment of an amount, the taxpayer is in constructive
receipt of that amount whether or not the taxpayer
makes the demand and actually receives the payment.
Under production flexibility contracts entered into between certain eligible owners and producers and the
Secretary of Agriculture, as provided in the Federal
Agriculture Improvement and Reform Act of 1996
(FAIR Act), annual payments are made at specific times
during the Federal government’s fiscal year. One-half
of each annual payment is to be made on either December 15 or January 15 of the fiscal year, at the option
of the recipient; the remaining one-half is to be paid
no later than September 30 of the fiscal year. The option to receive the payment on December 15 potentially
results in the constructive receipt (and thus potential
inclusion in income) of one-half of the annual payment
at that time, even if the option to receive the amount
on January 15 is elected. For fiscal year 1999, as provided under The Emergency Farm Financial Relief Act
of 1998, all payments are to be paid at such time or
times during the fiscal year as the recipient may specify. This option to receive all of the 1999 payment in
calendar year 1998 potentially results in constructive
receipt (and thus potential inclusion in income) in that
year, whether or not the amounts are actually received.
The Omnibus Consolidated and Emergency Supplemental Appropriations Act, 1999, provided that effective
for production flexibility contract payments made in
taxable years ending after December 31, 1995, the time
a production flexibility contract payment is to be included in income is to be determined without regard
to the options granted for payment. Effective December
17, 1999, this Act provides that any unexercised option
to accelerate the receipt of any payment under a production flexibility contract that is payable under the
FAIR Act is to be disregarded in determining the taxable year in which such payment is properly included
in gross income. Options to accelerate payments that
are enacted in the future are covered by this rule, providing the payment to which they relate is mandated

by the Fair Act as in effect on the date of enactment
of this Act.
Revenue Offset Provisions
Modify estimated tax requirements of individuals.—
An individual taxpayer generally is subject to an addition to tax for any underpayment of estimated tax.
An individual generally does not have an underpayment
of estimated tax if timely estimated tax payments are
made at least equal to: (1) 100 percent of the tax shown
on the return of the individual for the preceding tax
year (the ‘‘100 percent of last year’s liability safe harbor’’) or (2) 90 percent of the tax shown on the return
for the current year. For any individual with an adjusted gross income (AGI) of more than $150,000 as
shown on the return for the preceding taxable year,
the 100 percent of last year’s liability safe harbor generally is modified to be a 110 percent of last year’s
liability safe harbor. However, under prior law, the 110
percent of last year’s liability safe harbor for individuals
with AGI of more than $150,000 was modified for taxable years beginning in 1999 through 2002, as follows:
for taxable years beginning in 1999 the safe harbor
is 105 percent; for taxable years beginning in 2000 and
2001 the safe harbor is 106 percent, and for taxable
years beginning in 2002, the safe harbor is 112 percent.
Under this Act the estimated tax safe harbor for individuals with AGI of more than $150,000 is modified
as follows: for taxable years beginning in 2000 the safe
harbor is 108.6 percent and for taxable years beginning
in 2001 the safe harbor is 110.0 percent.
Clarify the tax treatment of income and losses on derivatives.—Capital gain treatment applies to gain on
the sale or exchange of a capital asset. Gain or loss
on other assets (stock in trade or other types of inventory, property used in a trade or business that is real
property or subject to depreciation, accounts or notes
receivable acquired in the ordinary course of a trade
or business, certain copyrights, and U.S. government
publications) generally is considered ordinary. This Act
adds three categories to the list of assets the gain or
loss on which is considered ordinary for Federal income
tax purposes: commodities derivatives held by commodities derivatives dealers, hedging transactions, and supplies of a type regularly consumed by the taxpayer in
the ordinary course of a taxpayer’s trade or business.
In defining a hedging transaction, the Act replaces the
‘‘risk reduction’’ standard with a ‘‘risk management’’
standard with respect to ordinary property held or certain liabilities incurred, and provides that the definition
of a hedging transaction includes a transaction entered
into primarily to mange such other risks as the Secretary of the Treasury may prescribe in regulations.
These changes are effective for any instrument held,
acquired or entered into; any transaction entered into;
and any supplies held or acquired on or after December
17, 1999.
Expand reporting of cancellation of indebtedness income.—Gross income generally includes income from
the discharge of indebtedness. If a bank, thrift institu-

52
tion, or credit union discharges $600 or more of any
indebtedness of a debtor, the institution must report
such discharge to the debtor and the IRS. This Act
extends these reporting requirements to additional entities involved in the trade or business of lending (such
as finance companies and credit card companies, whether or not they are affiliated with a financial institution),
effective for discharges of indebtedness occurring after
December 31, 1999.
Limit conversion of character of income from constructive ownership transactions with respect to partnership
interests.—A pass-thru entity, such as a partnership,
generally is not subject to Federal income tax. Instead,
each owner includes his/her share of a pass-thru entity’s income, gain, deduction or credit in his/her own
taxable income. The character of the income generally
is determined at the entity level and flows through
to the owners. A taxpayer can enter into a derivatives
transaction that is designed to give the taxpayer the
economic equivalent of an ownership interest in a partnership but that is not itself a current ownership interest in the partnership. These so-called ‘‘constructive
ownership’’ transactions purportedly allow taxpayers to
defer income and to convert ordinary income and shortterm capital gain into long-term capital gain. This Act
treats long-term capital gain recognized from a constructive ownership transaction as ordinary income to
the extent the long-term capital gain recognized from
the transaction exceeds the long-term capital gain that
could have been recognized had the taxpayer invested
in the partnership interest directly. In addition, an interest charge is imposed on the amount of gain that
is treated as ordinary income. These changes are effective with respect to transactions entered into on or
after July 12, 1999. Generally any contract, option or
any other arrangement that is entered into or exercised
on or after that date, which extends or otherwise modifies the terms of a transaction entered into prior to
such date, will be treated as a transaction entered into
on or after July 12, 1999.
Extend and modify qualified transfers of excess pension assets used for retiree health benefits.—A pension
plan may provide medical benefits to retired employees
through a section 401(h) account that is a part of the
pension plan. Qualified transfers of excess assets of
a defined benefit pension plan (other than a multiemployer plan) to a section 401(h) account are permitted,
subject to amount and frequency limitations, use requirements, deduction limitations, and vesting and minimum benefit requirements. This Act extends the ability
of employers to transfer excess defined benefit pension
plan assets to 401(h) accounts through December 31,
2005. In addition, effective with respect to qualified
transfers made after December 17, 1999, the minimum
benefit requirement is replaced with a minimum cost
requirement.
Modify installment method for accrual basis taxpayers.—Generally, an accrual method requires a taxpayer to recognize income when all events have occurred that fix the right to its receipt and its amount

ANALYTICAL PERSPECTIVES

can be determined with reasonable accuracy. The installment method of accounting provides an exception
to these general recognition principles by allowing a
taxpayer to defer recognition of income from the disposition of certain property until payment is received.
To the extent that an installment obligation is pledged
as security for any indebtedness, the net proceeds of
the secured indebtedness are treated as a payment on
such obligation, thereby triggering the recognition of
income. This Act generally prohibits the use of the installment method of accounting for dispositions of property that would otherwise be reported for Federal income tax purposes using an accrual method of accounting. The present-law exceptions regarding the availability of the installment method for use by cash method taxpayers, for dispositions of property used or produced in the trade or business of farming, and for dispositions of timeshares or residential lots are not affected by this change. This Act also modifies the pledge
rule to provide that entering into any arrangement that
gives the taxpayer the right to satisfy an obligation
with an installment note will be treated in the same
manner as the direct pledge of the installment note.
These changes are effective with respect to sales or
other dispositions entered into on or after December
17, 1999.
Deny charitable contribution deduction for transfers
associated with split-dollar insurance arrangements.—
A taxpayer who itemizes deductions generally is allowed to deduct charitable contributions paid during
the taxable year. The amount of the deduction allowable for a taxable year with respect to any charitable
contribution depends on the type of property contributed, the type of organization to which the property
is contributed, and the income of the taxpayer. In general, to be deductible as a charitable contribution, a
payment to charity must be a gift made without receipt
of adequate consideration and with donative intent.
Under a charitable split-dollar insurance arrangement,
a taxpayer typically transfers funds to a charity with
the understanding that the charity will use the funds
to pay premiums on a cash value life insurance policy
that benefits both the charity and members of the
transferor’s family, either directly or indirectly through
a family trust or partnership. This Act eliminates such
abuses of the charitable contributions deduction by denying a charitable contribution deduction for any transfer to a charity in connection with a charitable splitdollar insurance transaction. Specifically, the denial of
the deduction applies if, in connection with the transfer,
the charity directly or indirectly pays, or has previously
paid, any premium on any ‘‘personal benefit contract’’
with respect to the transferor, or there is an understanding or expectation that any person will directly
or indirectly pay any premium on any ‘‘personal benefit
contract’’ with respect to the transferor. A personal benefit contract with respect to the transferor is any life
insurance, annuity, or endowment contract for whom
the direct or indirect beneficiary under the contract
is the transferor, any member of the transferor’s family

3.

53

FEDERAL RECEIPTS

or any other person (other than a charitable organization) designated by the transferor. The Act also imposes
an excise tax on any participating charity equal to the
amount of any premiums paid by the charity on such
a ‘‘personal benefit contract’’ in connection with a charitable split-dollar insurance transaction. The deduction
is denied for any transfers after February 8, 1999 and
the excise tax applies to premiums paid after December
17, 1999.
Require basis adjustments when a partnership distributes certain stock to a corporate partner.—Under prior
law, generally no gain or loss was recognized on the
receipt by a corporation of property distributed in complete liquidation of a subsidiary corporation in which
it owned 80-percent of the stock. The basis of property
received by the distributee in such a liquidation was
the same as it was in the hands of the subsidiary.
This Act provides for a reduction in basis of the assets
of a corporation if stock in that corporation is distributed by the partnership to a corporate partner that,
as a result of the distribution and related transactions,
owns 80 percent or more of the stock of such corporation. The amount of the reduction generally equals the
amount of the excess of the partnership’s adjusted basis
in the stock of the distributed corporation immediately
before the distribution, over the corporate partner’s
basis in that stock immediately after the distribution,
subject to certain limitations. The corporate partner
must recognize long-term capital gain to the extent the
amount of the basis reduction exceeds the basis of the
property of the distributed corporation. This change
generally is effective for distributions made after July
14, 1999, except that in the case of a corporation that
is a partner in a partnership on July 14, 1999, the
provision is effective for distributions by that partnership to the corporation after December 17, 1999 (or,
for a corporation that so elects, distributions after June
30, 2001).
Modify rules relating to real estate investment trusts
(REITs).—REITs generally are restricted to owning passive investments in real estate and certain securities.
Under prior law, no single corporation could account
for more than five percent of the total value of a REIT’s
assets, and a REIT could not own more than 10-percent
of the outstanding voting securities of any issuer.
Through the use of non-voting preferred stock and multiple subsidiaries, up to 25 percent of the value of a
REIT’s assets could consist of subsidiaries that conduct
otherwise impermissible activities. Under this Act, the
10-percent vote test is changed to a 10-percent ‘‘vote
or value’’ test, meaning that a REIT cannot own more
than 10 percent of the outstanding voting securities
or more than 10 percent of the total value of securities
of a single issuer. In addition, taxable REIT subsidiaries owned by a REIT cannot represent more than
20 percent of the value of a REIT’s assets. For purposes
of the 10-percent value test, securities are generally
defined to exclude safe harbor debt owned by a REIT.

In addition, an exception to the limitation on ownership
of securities of a single issuer applies in the case of
a ‘‘taxable REIT subsidiary’’ that meets certain requirements. The Act also provides rules for the operation
of hotels and health care facilities; defines ‘‘independent
contractor’’ for certain purposes; modifies REIT distribution requirements to conform to the rules for regulated investment companies (RICs); modifies earnings
and profits rules for RICs and REITs; and replaces
the prior law adjusted basis comparison with a fair
market comparison, in determining whether certain
rents from personal property exceed a 15-percent limit.
These provisions generally are effective for taxable
years beginning after December 31, 2000, with transition for certain REIT holdings and leases in effect on
July 12, 1999.
Modify estimated tax rules for closely held REITs.—
If a person has a direct interest or a partnership interest in income-producing assets that produce income
throughout the year, that person’s estimated tax payments generally must reflect the quarterly amounts expected from the asset. However, a dividend distribution
of earnings from a REIT is considered for estimated
tax purposes when the dividend is paid. To take advantage of this deferral of estimated taxes, some corporations have established closely held REITS that may
make a single distribution for the year, timed such
that it need not be taken into account under the estimated tax rules as early as would be the case if the
assets were directly held by the controlling entity. Effective for estimated tax payments due on or after November 15, 1999, with respect to a closely held REIT,
this Act provides that any person owning at least 10
percent of the vote or value of the REIT is required
to accelerate the recognition of year-end dividends attributable to the closely held REIT.
Other Provisions
Simplify foster child definition under the earned income tax credit (EITC).—This Act clarifies the definition
of foster child for purposes of claiming the EITC. Effective for taxable years beginning after December 31,
1999, the foster child must be the taxpayer’s sibling
(or a descendant of the taxpayer’s sibling), or be placed
in the taxpayer’s home by an agency of a State or
one of its political subdivisions or a tax-exempt child
placement agency licensed by a State.
Allow members of the clergy to revoke exemption from
Social Security and Medicare coverage.—Under current
law, ministers of a church who are opposed to participating in the Social Security and Medicare programs
on religious principles may reject coverage by filing
with the IRS before the tax filing date for their second
year of work in the ministry. This Act provides an
opportunity for members of the clergy to revoke their
exemptions from Social Security and Medicare coverage
during a 2-year period beginning January 1, 2000.

54

ANALYTICAL PERSPECTIVES

ADMINISTRATION PROPOSALS
The President’s plan targets tax relief to provide assistance in obtaining higher education for working families, to relieve poverty and revitalize lower-income communities, and to make health care more affordable. The
President’s plan also provides relief from the marriage
penalty and provides child-care assistance, promotes retirement savings, provides relief from the alternative
minimum tax and other simplifications of the tax laws,
encourages philanthropy, and offers assistance in bridging the digital divide. The President’s plan also contains
measures that will curtail the proliferation of corporate
tax shelters, restrict the use of overseas tax havens,
and close other loopholes and tax subsidies.
PROVIDE TAX RELIEF
Expand Educational Opportunities
Provide College Opportunity tax cut—Under current law, individuals may claim a Lifetime Learning
credit equal to 20 percent of qualified tuition and related expenses up to $5,000 (increasing to $10,000 in
2003) incurred during the year for post-secondary education for the taxpayer, the taxpayer’s spouse, or one
or more dependents. The credit phases out for taxpayers filing joint returns with modified AGI from
$80,000 to $100,000, and $40,000 to $50,000 for single
taxpayers. The phase-out ranges will be adjusted for
inflation occurring after 2000. To further assist taxpayers in obtaining post-secondary education throughout their lifetimes, the Administration proposes that
the Lifetime Learning credit rate be increased to 28
percent. In addition, the phase-out range for the credit
would be increased to $100,000 to $120,000 of modified
AGI for joint returns and $50,000 to $60,000 of modified AGI for single taxpayers. To guarantee that all
eligible taxpayers receive the full value of this education assistance, taxpayers may elect to deduct qualified tuition and related expenses instead of claiming
the credit.
Provide incentives for public school construction
and modernization.—The Administration proposes to
institute a new program of Federal tax assistance for
public elementary and secondary school construction or
rehabilitation. Under the proposal, State and local governments (including U.S. possessions) would be able
to issue up to $22 billion of ‘‘qualified school modernization bonds,’’ $11 billion in each of 2001 and 2002. In
addition, $200 million of qualified school modernization
bonds in each of 2001 and 2002 would be allocated
for the construction and renovation of Bureau of Indian
Affairs funded schools. Holders of these bonds would
receive annual Federal income tax credits, set according
to market interest rates by the Treasury Department,
in lieu of interest. Issuers would be responsible for repayment of principal. These qualified school modernization bonds would be similar to qualified zone academy
bonds (QZABs), created by TRA97 and extended by the

Ticket to Work and Work Incentives Improvement Act
of 1999. QZABs allow bonds to be issued for certain
public schools with the interest on the bonds effectively
paid by the Federal government in the form of an annual income tax credit. The proceeds of these bonds
can be used for teacher training, purchases of equipment, curricular development, and rehabilitation and
repair of the school facilities. The Administration proposes to authorize the issuance of additional QZABs
of $1.0 billion in 2001 and $1.4 billion in 2002, and
to allow the proceeds of these bonds also to be used
for school construction.
Expand exclusion for employer-provided educational assistance to include graduate education.—Certain amounts paid by an employer for educational assistance provided to an employee currently
are excluded from the employee’s gross income for income and payroll tax purposes. The exclusion is limited
to $5,250 of educational assistance with respect to an
individual during a calendar year and applies whether
or not the education is job-related. The exclusion currently is limited to undergraduate courses beginning
before January 1, 2002. The exclusion previously applied to graduate courses that began before July 1,
1996. The Administration proposes to reinstate the exclusion for graduate education for courses beginning
on or after July 1, 2000 and before January 1, 2002.
Eliminate 60-month limit on student loan interest deduction.—Current law provides an income tax
deduction for certain interest paid on a qualified education loan during the first 60 months that interest
payments are required, effective for interest due and
paid after December 31, 1997. The maximum deduction
available is $2,500 for years after 2000 (for years 1998,
1999 and 2000, the limits are $1,000, $1,500 and
$2,000, respectively) and the deduction is phased out
for taxpayers with AGI between $40,000 and $55,000
(between $60,000 and $75,000 for joint filers). The 60month limitation under current law adds significant
complexity and administrative burdens for taxpayers,
lenders, loan servicing agencies, and the IRS. Thus,
to simplify the calculation of deductible interest payments, reduce administrative burdens, and provide
longer-term relief to low- and middle-income taxpayers
with large educational debt, the Administration proposes to eliminate the 60-month limitation. This proposal would be effective for interest due and paid on
qualified education loans after December 31, 2000.
Eliminate tax when forgiving student loans subject to income contingent repayment.—Students who
borrow money to pay for postsecondary education
through the Federal government’s Direct Loan program
may elect income contingent repayment of the loan.
If they elect this option, their loan repayments are adjusted in accordance with their income. If after the
borrower makes repayments for a twenty-five year pe-

3.

FEDERAL RECEIPTS

riod any loan balance remains, it is forgiven. The Administration proposes to eliminate any Federal income
tax the borrower may otherwise owe as a result of
the forgiveness of the loan balance. The proposal would
be effective for loan cancellations after December 31,
2000.
Provide tax relief for participants in certain
Federal education programs.—Present law provides
tax-free treatment for certain scholarship and fellowship grants used to pay qualified tuition and related
expenses, but not to the extent that any grant represents compensation for services. In addition, tax-free
treatment is provided for certain discharges of student
loans on condition that the individual works for a certain period of time in certain professions for any of
a broad class of employers. To extend tax-free treatment to education awards under certain Federal programs, the Administration proposes to amend current
law to provide that any amounts received by an individual under the National Health Service Corps
(NHSC) Scholarship Program or the Armed Forces
Health Professions Scholarship and Financial Assistance Program are ‘‘qualified scholarships’’ excludable
from income, without regard to the recipient’s future
service obligation. In addition, the proposal would provide an exclusion from income for any repayment or
cancellation of a student loan under the NHSC Scholarship Program, the Americorps Education Award Program, or the Armed Forces Health Professions Loan
Repayment Program. The exclusion would apply only
to the extent that the student incurred qualified tuition
and related expenses for which no education credit was
claimed during academic periods when the student
loans were incurred. The proposal would be effective
for awards received after December 31, 2000.
Provide Poverty Relief and Revitalize
Communities
Increase and simplify the Earned Income Tax
Credit (EITC).—Low- and moderate-income workers
may be eligible for the EITC. For every dollar a lowincome worker earns up to a limit, between 7 and 40
cents are provided as a tax credit. The applicable credit
rate depends on the presence and number of children
in the worker’s family. Above $13,030 ($5,930 if the
taxpayer does not reside with children), the size of the
tax credit is gradually phased out. Although the EITC
lifts millions out of poverty each year, poverty among
children living in larger families remains at unacceptably high levels. Because the credit initially increases
as income rises, the EITC rewards marriage for very
low-income workers. But the EITC also causes marriage
penalties among two-earner couples whose income falls
in or above the credit’s phase-out range. Further, while
the EITC has been shown, on net, to increase work
effort, phasing out the credit results in high marginal
tax rates for recipients in the phase-out range. To address these problems, the Administration proposes that
the credit rate be increased from 40 percent to 45 per-

55
cent for families with three or more children. If both
spouses work and earn at least $725, the credit would
begin to phase out at $14,480 ($7,380 if the couple
does not reside with children). For taxpayers with two
or more children, the phase-out rate would be reduced
from 21.06 percent to 19.06 percent.
Under current law, nontaxable earned income, such
as 401(k) contributions, is included in earned income
for purposes of calculating the EITC. To encourage retirement savings, simplify the calculation of earned income, and improve compliance, the Administration is
proposing that these nontaxable forms of income would
no longer count toward eligibility for the EITC. The
proposal would be effective for taxable years beginning
after December 31, 1999.
A proposed technical correction would clarify that
taxpayers are eligible to receive the small credit for
workers without qualifying children, if they cannot
claim the credit for workers with children because their
child does not have a social security number. The proposed change will also clarify that taxpayers may not
receive any credit (even the small credit for workers
without qualifying children), if their child is not taken
into account because another taxpayer who may claim
the child has higher modified AGI.
Increase and index low-income housing tax credit per-capita cap.—Low-income housing tax credits
provide an incentive to build and make available affordable rental housing units to households with low incomes. The amount of the first-year credits that can
be awarded in each State is currently limited to $1.25
per capita. That limit has not been changed since it
was established in 1986. The Administration proposes
to increase the annual State limitation to $1.75 per
capita effective for calendar year 2001 and to index
that amount for inflation, beginning with calendar year
2002. The proposed increases in this cap will permit
additional new and rehabilitated low-income housing
to be provided while still encouraging State housing
agencies to award the credits to projects that best meet
specific needs.
Provide New Markets Tax Credit.—Businesses located in low-income urban and rural communities often
lack access to sufficient equity capital. To help attract
new capital to these businesses, taxpayers would be
allowed a credit against Federal income taxes for certain investments made to acquire stock or other equity
interests in a community development investment entity selected by the Treasury Department to receive a
credit allocation. Selected community development investment entities would be required to use the investment proceeds to provide capital to businesses located
in low-income communities. During the period 20012005, the Treasury Department would authorize selected community development investment entities to
issue $15 billion of new stock or equity interests with
respect to which credits could be claimed. The credit
would be allowed for each year during the five-year
period after the stock or equity interest is acquired

56
from the selected community development investment
entity, and the credit amount that could be claimed
for each of the five years would equal six percent of
the amount paid to acquire the stock or equity interest
from the community development investment entity.
The credit would be subject to current-law general business credit rules, and would be available for qualified
investments made after December 31, 2000.
Expand Empowerment Zone (EZ) tax incentives
and authorize additional EZs.—The Omnibus Budget Reconciliation Act of 1993 (OBRA93) authorized a
Federal demonstration project in which nine EZs and
95 empowerment communities were designated in a
competitive application process. Among other benefits,
businesses located in the nine original EZs are eligible
for four Federal tax incentives: an employment wage
credit; an additional $20,000 per year of section 179
expensing; a new category of tax-exempt private activity bonds; and ‘‘brownfields’’ expensing for certain environmental remediation expenses. The Taxpayer Relief
Act of 1997 (TRA97) authorized the designation of two
additional EZs, which generally are eligible for the
same tax incentives that are available within the EZs
authorized by OBRA93. In addition, TRA97 authorized
the designation of another 20 EZs (so-called ‘‘Round
II EZs’’) that are eligible for the same tax incentives
(other than the employment wage credit) available in
the 11 other EZs. To date, the EZ program has promoted significant economic development, but these communities still do not fully share in the nation’s general
prosperity. Therefore, the Administration proposes that
the EZ program be extended and strengthened by making the employment wage credit available in all existing
31 EZs through 2009. Furthermore, the Administration
proposes that, beginning in 2001, an additional $35,000
(rather than $20,000) per year of section 179 expensing
be allowed in all EZs, and that enhanced tax-exempt
financing benefits for private business activities be
available in all EZs. (As described below, the Administration’s budget proposes a permanent extension of the
‘‘brownfields’’ expensing for EZs and other targeted
areas.) Finally, the Administration proposes that an
additional 10 EZs be designated as of January 1, 2002.
Businesses located within these 10 new EZs will be
eligible for the full range of tax incentives available
in the other EZs.
Provide Better America Bonds to improve the environment.—Under current law, State and local governments may issue tax-exempt bonds to finance purely
public environmental projects. Certain other environmental projects may also be financed with tax-exempt
bonds, but are subject to an overall cap on privatepurpose tax-exempt bonds. The subsidy provided with
tax-exempt bonds may not provide a deep enough subsidy to induce State and local governments to undertake beneficial environmental infrastructure projects.
The Administration proposes to allow State and local
governments (including U.S. possessions and Indian
tribal governments) to issue tax credit bonds (similar

ANALYTICAL PERSPECTIVES

to existing Qualified Zone Academy Bonds) to finance
projects to protect open spaces or otherwise to improve
the environment. Significant public benefits would be
provided by creating more livable urban and rural environments; creating forest preserves near urban areas;
protecting water quality; rehabilitating land that has
been degraded by toxic or other wastes or destruction
of its ground cover; improving parks; and reestablishing
wetlands. A total of $2.15 billion of bond authority
would be authorized for each of the five years beginning
in 2001. The Environmental Protection Agency, in consultation with other agencies, would allocate the bond
authority based on competitive applications. The bonds
would have a maximum maturity of 15 years and the
bond issuer effectively would receive an interest-free
loan for the term of the bonds. During that interval,
bond holders would receive Federal income tax credits
in lieu of interest.
Permanently extend the expensing of brownfields
remediation costs.—Under TRA97, taxpayers can
elect to treat certain environmental remediation expenditures that would otherwise be chargeable to capital accounts as deductible in the year paid or incurred.
The provision does not apply to expenditures paid or
incurred after December 31, 2001. The Administration
proposes that the provision be made permanent.
Expand tax incentives for specialized small business investment companies (SSBICs).—Current law
provides certain tax incentives for investment in
SSBICs. The Administration proposes to enhance the
tax incentives for SSBICs. First, the existing provision
allowing a tax-free rollover of the proceeds of a sale
of publicly-traded securities into an investment in a
SSBIC would be modified to extend the rollover period
to 180 days, to allow investment in the preferred stock
of a SSBIC, to eliminate the annual caps on the SSBIC
rollover gain exclusion, and to increase the lifetime caps
to $750,000 per individual and $2,000,000 per corporation. Second, the proposal would allow a SSBIC to convert from a corporation to a partnership within 180
days of enactment without giving rise to tax at either
the corporate or shareholder level, but the partnership
would remain subject to an entity-level tax upon ceasing activity as a SSBIC or at any time that it disposes
of assets that it holds at the time of conversion on
the amount of ‘‘built-in’’ gains inherent in such assets
at the time of conversion. Third, the proposal would
make it easier for a SSBIC to meet the qualifying income, distribution of income, and diversification of assets tests to qualify as a tax-favored regulated investment company. Finally, in the case of a direct or indirect sale of SSBIC stock that qualifies for treatment
under section 1202, the proposal would raise the exclusion of gain from 50 percent to 60 percent. The taxfree rollover and section 1202 provisions would be effective for sales occurring after the date of enactment.
The regulated investment company provisions would be
effective for taxable years beginning on or after the
date of enactment.

3.

57

FEDERAL RECEIPTS

Bridge the Digital Divide
Encourage sponsorship of qualified zone academies and technology centers.—Under current law,
State and local governments can issue qualified zone
academy bonds to fund improvements in certain ‘‘qualified zone academies’’ which provide elementary or secondary education. To encourage corporations to become
sponsors of such academies and technology centers, a
tax credit would be provided equal to 50 percent of
the amount of corporate sponsorship payments made
to a qualified zone academy, or a public library or community technology center, located in (or adjacent to)
a designated empowerment zone or enterprise community. The credit would be available for corporate cash
contributions, but only if a credit allocation has been
made with respect to the contribution by the local governmental agency with responsibility for implementing
the strategic plan of the empowerment zone or enterprise community. Up to $8 million of credits could be
allocated with respect to each of the existing 31 empowerment zones (and each of the 10 additional empowerment zones proposed to be designated under the
Administration’s budget); and up to $2 million of credits
could be allocated with respect to each of the designated
enterprise communities. The credit would be subject
to the current-law general business credit rules, and
would be effective for sponsorship payments made after
December 31, 2000.
Extend and expand enhanced deduction for corporate donations of computers.—The current-law enhanced deduction for contributions of computer technology and equipment for elementary or secondary
school purposes is scheduled to expire for taxable years
beginning after December 31, 2000. The Administration
proposes extending this provision through June 30,
2004. In addition, to promote access of all persons to
computer technology and training, the enhanced deduction would be expanded to apply to contributions of
computer equipment to a public library or community
technology center located in a designated empowerment
zone or enterprise community, or in a census tract with
a poverty rate of 20 percent or more.
Provide tax credit for workplace literacy, basic
education, and basic computer skills training.—
Under current law, employers may deduct the costs
of providing workplace literacy, basic education, and
basic computer skill programs to employees, but no tax
credits are allowed for any employer-provided education. As a result, employers lack sufficient incentive
to provide basic education programs, the benefits of
which are more difficult for employers to capture
through increased productivity than the benefits of jobspecific education. The Administration proposes to allow
employers who provide certain workplace literacy,
English literacy, basic education, or basic computer
training for their eligible employees to claim a credit
against Federal income taxes equal to 20 percent of
the employer’s qualified expenses, up to a maximum

credit of $1,050 per participating employee. Qualified
education would be limited to basic instruction at or
below the level of a high school degree, English literacy
instruction, or basic computer skills. Eligible employees
in basic education or computer training generally would
not have received a high school degree or its equivalent.
Instruction would be provided either by the employer,
with curriculum approved by the State Adult Education
Authority, or by local education agencies or other providers certified by the Department of Education. The
credit would be available for taxable years beginning
after December 31, 2000.
Make Health Care More Affordable
Assist taxpayers with long-term care needs.—
Current law provides a tax deduction for certain longterm care expenses. However, the deduction does not
assist with all long-term care expenses, especially the
costs of informal family caregiving. The Administration
proposes to provide a new long-term care tax credit
of $3,000. The credit could be claimed by a taxpayer
for himself or herself or for a spouse or dependent
with long-term care needs. To qualify for the credit,
an individual with long-term care needs must be certified by a licensed physician as being unable for at
least six months to perform at least three activities
of daily living without substantial assistance from another individual due to loss of functional capacity. An
individual may also qualify if he or she requires substantial supervision to be protected from threats to his
or her own health and safety due to severe cognitive
impairment and has difficulty with one or more activities of daily living or certain other age-appropriate activities. For purposes of the proposed credit, the current-law dependency tests would be liberalized, raising
the gross income limit and allowing taxpayers to use
a residency test rather than a support test. The credit
would be phased out in combination with the child credit and the disabled worker credit for taxpayers with
AGI in excess of the following thresholds: $110,000 for
married taxpayers filing a joint return, $75,000 for a
single taxpayer or head of household, and $55,000 for
married taxpayers filing a separate return. The credit
would be phased in at $1,000 in 2001, $1,500 in 2002,
$2,000 in 2003, $2,500 in 2004, and $3,000 in 2005
and subsequent years.
Encourage COBRA continuation coverage.—Current law provides a tax preference for employer-provided group health plans, but not for individually purchased health insurance coverage except to the extent
that medical expenses exceed 7.5 percent of AGI or
the individual has self-employment income. The Administration proposes to make health insurance more affordable for workers in transition and for retiring workers by providing a nonrefundable tax credit for the purchase of COBRA coverage. Individuals would receive
a 25-percent tax credit for their own contributions towards COBRA coverage. The proposal would be effec-

58
tive for taxable years beginning after December 31,
2001.
Provide tax credit for Medicare buy-in program.—The Administration proposes to make health
insurance more affordable for older workers, retirees
and displaced workers by providing a 25-percent nonrefundable tax credit for individuals purchasing health
insurance through a newly created Medicare buy-in program. Under a separate proposal, all individuals at
least sixty-two years of age and under sixty-five years
of age, and workers displaced from their jobs who are
at least fifty-five years of age and under sixty-two years
of age, would be eligible to buy into Medicare. Taxpayers would be eligible for a credit of 25 percent of
premiums paid under the Medicare buy-in program
prior to age sixty-five. The proposal would be effective
for taxable years beginning after December 31, 2001.
Provide tax relief for workers with disabilities.—
Under current law, disabled taxpayers may claim an
itemized deduction for impairment-related work expenses. The Administration proposes to allow disabled
workers to claim a $1,000 credit. This credit would
help compensate people with disabilities for both formal
and informal costs associated with work (e.g., personal
assistance to get ready for work or special transportation). In order to be considered a worker with disabilities, a taxpayer must submit a licensed physician’s
certification that the taxpayer has been unable for at
least 12 months to perform at least one activity of daily
living without substantial assistance from another individual. A severely disabled worker could potentially
qualify for both the proposed long-term care and disabled worker tax credits. The credit would be phased
out in combination with the child credit and the proposed long-term care credit for taxpayers with AGI in
excess of the following thresholds: $110,000 for married
taxpayers filing a joint return, $75,000 for a single taxpayer or head of household, and $55,000 for married
taxpayers filing a separate return. The proposal would
be effective for taxable years beginning after December
31, 2000.
Provide tax relief to encourage small business
health plans.—Small businesses generally face higher
costs in establishing and operating health plans than
do larger employers. Health benefit purchasing coalitions provide an opportunity for small businesses to
offer a greater choice of health plans to their workers
and to purchase health insurance at a reduced cost.
The formation of these coalitions, however, has been
hindered by limited access to capital. The Administration proposes to establish a temporary, special tax rule
in order to facilitate the formation of health benefit
purchasing coalitions. The special rule would facilitate
private foundation grants and loans to fund initial operating expenses of qualified coalitions by treating such
grants and loans as being made for exclusively charitable purposes. The special foundation rule would apply
to grants and loans made prior to January 1, 2009

ANALYTICAL PERSPECTIVES

for initial operating expenses incurred prior to January
1, 2011. In addition, in order to encourage the use
of qualified coalitions by small businesses, the Administration proposes a temporary tax credit for small employers that currently do not provide health insurance
to their workforces. The credit would equal 20 percent
of small employer contributions to employee health
plans purchased through a qualified coalition. The credit would be available to employers with at least two,
but not more than 50 employees, counting only employees with annual compensation of at least $10,000 in
the prior calendar year. The maximum per policy credit
amount would be $400 per year for individual coverage
and $1,000 per year for family coverage. The credit
would be allowed with respect to employer contributions
made during the first 24 months that the employer
purchases health insurance through a qualified coalition, and would be subject to the overall limitations
of the general business credit. The proposed credit
would be effective for taxable years beginning after December 31, 2000 for health plans established before
January 1, 2009.
Encourage development of vaccines for targeted
diseases.—-The proposed tax credit would encourage
development of new vaccines for diseases that occur
primarily in developing countries by providing a market
for successful vaccines. The proposal would provide a
credit against Federal income taxes for sales of a qualifying vaccine to a qualifying organization. The credit
would equal 100 percent of the amount paid by the
qualifying organization. A qualifying organization
would be a nonprofit organization that purchases and
distributes vaccines for developing countries. A qualifying vaccine would be a vaccine for targeted diseases
that receives FDA approval as a new drug after the
date of enactment. The targeted diseases would include
malaria, tuberculosis, HIV/AIDS, and certain other infectious diseases. The credit would be available only
if a credit allocation has been made with respect to
the sale of a qualifying vaccine to a qualifying organization by the U.S. Agency for International Development
(AID). For the period 2002 - 2010, AID would be allowed to designate up to $1 billion of sales as eligible
for the credit ($100 million per year for 2002 through
2006 and $125 million per year for 2007 through 2010).
Unallocated amounts for any year would be carried over
and available for allocation in the ten following years.
Strengthen Families and Improve Work
Incentives
Provide marriage penalty relief and increase
standard deduction.—Under current law, the standard deduction for single filers is estimated to be $4,500
in 2001. For married couples who file joint individual
returns, the standard deduction will be $7,550, which
is less than the combined amount for two single individuals. To reduce marriage penalties, the Administration
proposes to increase the standard deduction for twoearner couples to double the amount of the standard

3.

59

FEDERAL RECEIPTS

deduction for single filers. The increase would be
phased in evenly over five years. When fully phased
in, the increase (at 2001 levels) would be $1,450. In
addition, beginning in 2005, the Administration proposes to increase the standard deduction by $250 for
single filers, $350 for heads of household, and $500
for joint filers.

year. Any deduction the taxpayer would otherwise be
entitled to take for the expenses would be reduced by
the amount of the credit. Similarly, the taxpayer’s basis
in a facility would be reduced to the extent that a
credit is claimed for expenses of constructing or acquiring the facility. The credit would be effective for taxable
years beginning after December 31, 2000.

Increase, expand, and simplify child and dependent care tax credit.—Under current law, taxpayers may receive a nonrefundable tax credit for a
percentage of certain child care expenses they pay in
order to work. The credit rate is phased down from
30 percent of expenses (for taxpayers with AGI of
$10,000 or less) to 20 percent (for taxpayers with AGI
above $28,000). The Administration believes that the
maximum credit rate is too low. Moreover, because it
is nonrefundable, many families who have significant
child care costs and relatively low incomes are not eligible for the maximum credit. To alleviate the burden
of child care costs for these families, the Administration
proposes to make the credit refundable. Under the proposal, the maximum credit rate would be increased
from 30 percent to 40 percent in 2003, and to 50 percent in 2005 and subsequent years. The credit would
become refundable in 2003. Eligibility for the maximum
credit rate would be extended to taxpayers with AGI
of $30,000 or less. The credit rate would be reduced
by one percentage point for every $1,000 of AGI above
$30,000 but would not be less than 20 percent.
Under current law, no additional tax assistance
under the child and dependent care tax credit is provided to families with infants, who require intense and
sustained care. Furthermore, parents who themselves
care for their infants, instead of incurring out-of-pocket
child care expenses, receive no benefit under the child
and dependent care tax credit. In order to provide assistance to these families, the Administration proposes
to supplement the credit with an additional, nonrefundable credit for all taxpayers with children under the
age of one, whether or not they incur out-of-pocket child
care expenses. The amount of additional credit would
be the applicable credit rate multiplied by $500 for
a child under the age of one ($1,000 for two or more
children under the age of one).
The Administration also proposes to simplify eligibility for the credit by eliminating a complicated household maintenance test. Certain credit parameters would
be indexed. The proposal would be effective for taxable
years beginning after December 31, 2000.

Promote Expanded Retirement Savings,
Security, and Portability

Provide tax incentives for employer-provided
child-care facilities.—The Administration proposes to
provide taxpayers a credit equal to 25 percent of expenses incurred to build or acquire a child care facility
for employee use, or to provide child care services to
children of employees directly or through a third party.
Taxpayers also would be entitled to a credit equal to
10 percent of expenses incurred to provide employees
with child care resource and referral services. A taxpayer’s credit could not exceed $150,000 in a single

The Administration proposes further expansions of
retirement savings incentives, including initiatives that
would expand retirement plan coverage and other workplace-based savings opportunities, particularly for
moderate- and lower-income workers not currently covered by employer-sponsored plans. Many of the new
provisions are focused on employees of small businesses, a group that currently has low pension coverage. Other proposals enhance the fairness of plans
by improving existing retirement plans for employers
of all sizes, increase retirement security for women,
promote portability, expand workers’ and spouses’
rights to know about their retirement benefits, and simplify pension rules. These provisions generally are effective for taxable years beginning after 2000.
Encourage Retirement Savings
The Administration proposes two major initiatives designed to encourage retirement savings for moderateand lower-income workers.
Establish Retirement Savings Accounts.—Current
law tax incentives to save through Individual Retirement Accounts (IRAs) and pensions provide little impetus to saving by moderate- and lower-income workers.
The Administration’s proposal would create Retirement
Savings Accounts, in which participants’ voluntary contributions are matched by employers or financial institutions. The match will be provided in the form of a
tax credit. Participation by financial institutions and
taxpayers would be voluntary. Financial institutions
could also claim a $10 tax credit to defray the administrative costs of establishing each new account.
Under the proposal, eligible taxpayers would qualify
for a match. Participants would make voluntary contributions to an account at a participating financial institution or employer-sponsored qualified retirement
plan. Workers would receive a basic match of as much
as 100 percent for up to $1,000 in contributions ($500
from 2002 to 2004). They would also qualify for a supplemental match of up to $100 for the first $100 contributed to the account.
The basic match phases down to 20 percent for taxpayers with AGI in the following ranges: between
$25,000 and $50,000 ($20,000 and $40,000 from 2002
to 2004) for married taxpayers filing a joint return,
$18,750 to $37,500 ($15,000 to $30,000 from 2002 to
2004) for taxpayers filing a head-of-household return,
and $12,500 to $25,000 ($10,000 to $20,000 from 2002
to 2004) for single taxpayers. The supplemental match
phases out over the same income ranges. The 20 per-

60

ANALYTICAL PERSPECTIVES

cent basic match is available for taxpayers with AGI
up to $80,000 ($40,000 from 2002 to 2004) on joint
returns, $60,000 ($30,000 from 2002 to 2004) on headof-household returns and $40,000 ($20,000 from 2002
to 2004) on single returns.
Taxpayers with at least $5,000 in earnings (which
could be joint earnings for married taxpayers filing a
joint return) and aged 25 to 60 would be eligible for
the match. Withdrawals for certain special purposes
would be permitted after five years; withdrawals for
other purposes would not be permitted until retirement.
The tax treatment would be similar to that afforded
deductible IRAs or contributions to employer pensions:
contributions would be excludable from income, earnings would not be taxed, but withdrawals would be
included in taxable income.
The credits would be effective for tax years beginning
after December 31, 2001.
Provide small business tax credit for automatic
contributions for non-highly compensated employees.—Small employers could claim a nonrefundable tax
credit equal to 50 percent of qualifying contributions
made on behalf of non-highly compensated employees.
Qualifying contributions are nonelective contributions
to defined contribution plans of at least one percent
of pay and nonelective or matching contributions of up
to an additional two percent of pay (for a total of three
percent of pay). Alternatively, qualifying contributions
could be benefits accrued under a non-integrated defined benefit plan if equivalent to a three-percent nonelective contribution (in accordance with regulations
that could provide simplified methods for defined benefit plans to qualify for the credit). Contributions must
be vested at least as fast as either a three-year cliff
or five-year graded schedule, must be subject to withdrawal restrictions, and must be allocated in proportion
to pay. Credits claimed for subsequently forfeited contributions would be subject to recapture at a rate of
35 percent. An employer could claim the credit for three
years. The credit would be effective for tax years beginning after December 31, 2001 and ending on or before
December 31, 2009.
Expand Pension Coverage for Employees of
Small Business
The Administration proposes a number of other incentives to encourage the adoption of retirement plans
by small employers, generally those that have 100 or
fewer employees with $5,000 or more of compensation
in the preceding year.
Provide tax credit for plan start up and administrative expenses.—The Administration proposes a
three-year tax credit for the administrative and retirement education expenses of any small business that
sets up a new qualified defined benefit or defined contribution plan (including a 401(k) plan), savings incentive match plan for employees (SIMPLE), simplified employee pension (SEP), or payroll deduction IRA arrangement. The credit would cover 50 percent of the first

$2,000 in administrative and retirement education expenses for the plan or arrangement for the first year
of the plan and 50 percent of the first $1,000 of such
expenses for each of the second and third years. The
tax credit would help promote new plan sponsorship
by targeting a tax benefit to employers adopting new
plans or payroll deduction IRA arrangements, providing
a marketing tool to financial institutions and advisors
promoting new plan adoption, and increasing awareness
of retirement savings options. The credit would be
available for plans established after 1998 and before
2010.
Provide for payroll deduction IRAs.—Employers
could offer employees the opportunity to make IRA contributions on a pre-tax basis through payroll deduction.
Providing employees an exclusion from income (in lieu
of a deduction) is designed to increase saving among
workers in businesses that do not offer a retirement
plan. Signing up for payroll deduction is easy for an
employee. In addition, saving is facilitated because it
becomes automatic as salary reduction contributions
continue each paycheck after an employee’s initial election. Peer group participation may also encourage employees to save more. Finally, the favorable tax treatment of salary reductions would encourage participation.
Provide for the SMART plan.—In addition to tax
credits for qualified retirement plans, the Administration is proposing a new small business defined benefit
type plan (the ‘‘SMART’’ plan) for calendar years beginning after 2000. The SMART plan combines certain
key features of defined benefit plans and defined contribution plans: guaranteed minimum retirement benefits, an option for payments over the course of an employee’s retirement years, and Pension Benefit Guaranty Corporation insurance, together with individual
account balances that can benefit from favorable investment returns and have enhanced portability.
Enhance the 401(k) SIMPLE plan.—The Administration proposes expanding the small business 401(k)
SIMPLE plan and making it significantly more flexible
without sacrificing fairness in the allocation of contributions to moderate- and lower-wage employees. The proposal would make three major changes to the existing
401(k) SIMPLE plan nonelective contribution alternative. First, non-highly compensated employees would
be permitted to contribute up to $10,500 a year. Second,
the employer’s options under a 401(k) SIMPLE plan
would be expanded: instead of being required to make
a two-percent nonelective employer contribution (with
a $6,000 employee contribution limit), employers could
opt to make a one-percent, two-percent, three-percent
or higher nonelective employer contribution (subject to
the requirement that all eligible employees receive the
same rate of nonelective contribution). The one-percent
401(k) SIMPLE plan would allow highly compensated
employees to contribute up to $3,000 to the plan if
the employer made a non-integrated, fully vested, with-

3.

FEDERAL RECEIPTS

drawal-restricted one-percent automatic contribution on
behalf of all employees. The proposal would not change
the current-law two-percent 401(k) SIMPLE plan, with
its $6,000 contribution limit, except to restrict application of the $6,000 limit to highly compensated employees, allowing others to contribute up to $10,500. In
addition, as is the case under current law with the
401(k) nonelective safe harbor, an employer could make
a three-percent (or greater) nonelective contribution,
permitting all employees, including highly compensated
ones, to contribute up to $10,500. Third, employers
would have the flexibility to wait until as late as December 1 of the year for which the contribution is made
to assess their financial situation for the year and decide on the level of their nonelective contribution.
Eliminate IRS user fees for small business plan
determination letters.—The Administration proposes
the elimination of user fees for requests made after
the date of enactment for an initial determination letter
from the IRS for a qualified retirement plan maintained
by a small business. To obtain the relief, the request
must be made during the first five plan years.
Permit certain S corporation shareholders and
partners to borrow from plans.—S corporation
shareholders and partners owning less than 20 percent
of the business would be able to borrow from the employer’s qualified retirement plan in which they participate under the same rules that apply to all qualified
plan participants for loans first made or refinanced
after 2000.
Enhance Fairness in Pension Plans
The Administration proposes modifications to the
vesting rules, the contribution and deduction limits,
and the 401(k) safe harbor plan rules to enhance the
fairness of pensions to moderate- and lower-income
workers.
Accelerate vesting for qualified plans.—The Administration proposes accelerating the current-law fiveyear (or seven-year graded) allowable vesting schedule
for qualified retirement plans. Given the mobile nature
of today’s workforce, particularly of working women,
there is a significant risk that many participants will
leave employment before fully vesting in their retirement benefits. Under the proposal, plans would be required to provide that an employee would be fully vested after completing three years of service or would vest
in annual 20 percent increments beginning after one
year of service. In addition, time off under the Family
and Medical Leave Act (FMLA) of up to 12 weeks of
unpaid leave to care for a new child, to care for a
family member who has a serious health condition, or
because the worker has a serious health condition
would be included in service for determining retirement
plan vesting and eligibility to participate in the plan.
Modify contribution and annual addition limitations.—The deduction limits for profit sharing plans

61
and the percentage-of-pay limitations of defined contribution plans would be liberalized to ensure that nonhighly compensated employees’ benefits are not inappropriately limited. The general 15-percent deduction
limit for stock bonus and profit sharing plans would
be increased by the amount of elective contributions
on behalf of non-highly compensated employees participating in the plan that exceed, in the aggregate, 15
percent of compensation otherwise paid or accrued on
behalf of such non-highly compensated employees. For
purposes of determining the employer’s deduction under
the combined plan limit that applies when an employer
has both a pension plan and a stock bonus or profit
sharing plan in which the same employee participates,
elective contributions on behalf of non-highly compensated employees would be disregarded. In addition,
the 15-percent-of-compensation deduction limit would
be further liberalized by treating certain salary reduction amounts as compensation in determining the deduction limits. The proposal also would increase the
maximum allowable annual addition for defined contribution plans from 25 percent to 35 percent of compensation.
Expand coverage of non-highly compensated employees under 401(k) safe harbor plans.—The Administration would modify the section 401(k) matching
formula safe harbor by requiring that, in addition to
the matching contribution, either (1) the employer make
a contribution of one percent of compensation for each
eligible non-highly compensated employee, regardless of
whether the employee makes elective contributions, or
(2) the plan provide for current and newly hired employees to be automatically enrolled in the 401(k) plan
at a three-percent contribution rate (where employees
can elect other rates, including zero contribution). The
proposal would also permit nonelective contributions to
replace matching contributions in the 401(k) matching
formula safe harbor.
Simplify the definition of highly compensated
employee.—The Administration proposes to simplify
the definition of highly compensated employee by eliminating the top-paid group election. Under the simplified
definition, an employee would be treated as highly compensated if the employee (1) was a five-percent owner
at any time during the year or the preceding year,
or (2) had compensation in excess of $80,000 (as adjusted) for the preceding year.
Clarify the division of Section 457 assets upon
divorce.—To make consistent the treatment of retirement benefits upon divorce, the Administration proposes to extend to section 457(b) plans the qualified
domestic relations order (QDRO) regime that applies
to distributions from a qualified plan made to a spouse,
former spouse or alternate payee. Accordingly, the proposal would not tax the employee on distributions from
a section 457(b) plan made to an alternate payee pursuant to a QDRO and also clarifies that a section 457(b)

62

ANALYTICAL PERSPECTIVES

plan will not be treated as violating the restrictions
on distributions when it honors the terms of a QDRO.
Offer joint and 75-percent survivor annuity option.—Current law requires certain pension plans to
offer to pay pension benefits as a joint and survivor
annuity; frequently, the benefit for the surviving spouse
is reduced to 50 percent of the monthly benefit paid
when both spouses were alive. Under the proposal,
plans that are subject to the joint and survivor annuity
rules would be required to offer an option that pays
a survivor benefit equal to at least 75 percent of the
benefit the couple received while both were alive. This
option would be especially helpful to women because
they tend to live longer than men and because many
aged widows have incomes below the poverty level.
Promote Retirement Savings Portability
The Administration proposes significant changes to
promote the portability and encourage the preservation
of retirement savings.
Encourage pension asset preservation by default
rollover to IRA.—The direct rollover rules would be
modified to encourage preservation of retirement assets
by making a direct rollover the default option for eligible rollover distributions from a qualified retirement
plan, section 403(b) annuity or governmental section
457(b) plan. The new rule would apply where a participant is entitled to an eligible rollover distribution from
a qualified retirement plan, 403(b) annuity or governmental section 457(b) plan, the distribution is greater
than $1,000, and the distribution is subject to nonconsensual cashout under the plan (i.e, does not exceed
$5,000 or is made after normal retirement age). In
these circumstances, the distribution would be required
to be directly rolled over to an eligible retirement plan
(including an IRA), unless the participant affirmatively
elects to receive the distribution in cash. For convenience, the rollover IRA could be designated when the
employee becomes a participant in the plan; alternatively, it could be designated at termination of employment. If the participant fails to designate a rollover
plan or IRA and does not affirmatively elect to receive
the distribution in cash, then involuntary cashout
amounts could be transferred to an IRA designated by
the payor (for the benefit of the participant) or, at the
election of the plan sponsor, retained in the plan.
Expand permitted rollovers of employer-provided
retirement savings.—Under current law, rollovers are
not allowed between qualified retirement plans, section
403(b) tax-sheltered annuities and governmental section
457(b) plans. The Administration proposes that an eligible rollover distribution from a qualified retirement
plan, a section 403(b) tax-sheltered annuity, or a governmental section 457(b) plan could be rolled over to
a traditional IRA, a qualified retirement plan, a section
403(b) annuity, or a governmental section 457(b) plan.
Amounts distributed from a governmental section
457(b) plan would be subject to the early withdrawal

tax to the extent the distribution consists of amounts
attributable to rollovers from another type of plan. A
governmental section 457(b) plan would be required to
separately account for such amounts. To facilitate the
preservation of the retirement savings of participants
in governmental section 457(b) plans and to rationalize
the treatment of different types of broad-based retirement plans, the Administration also proposes to extend
the direct rollover and withholding rules to governmental section 457(b) plans. These plans, like qualified
plans, would be required to provide written notification
to participants regarding eligible rollover distributions
(but would not be required to accept rollovers). Finally,
the proposal would allow eligible rollover distributions
to be rolled over from a qualified trust sponsored by
a previous employer to a Federal employee’s Thrift Savings Plan (TSP) account.
Permit consolidation of retirement savings.—The
Administration’s proposal would allow individuals to
consolidate their IRA funds and their workplace retirement savings in a single fund. Individuals who have
IRAs with deductible IRA contributions would be permitted to transfer funds from their IRAs to their qualified defined contribution retirement plan, 403(b) taxsheltered annuity or governmental section 457(b) plan,
provided that the retirement plan trustee could qualify
as an IRA trustee. In addition, the proposal would allow
individuals to roll over after-tax IRA or employer plan
contributions to their new employer’s defined contribution plan or to an IRA if the plan or IRA provider
agrees to track and report the after-tax portion of the
rollover for the individual. Finally, surviving spouses
would be permitted to roll over distributions to a qualified plan, 403(b) annuity or governmental section 457(b)
plan.
Allow purchase of service credits in governmental defined benefit plans.—Employees of State
and local governments, particularly teachers, often
move between states and school districts in the course
of their careers. Under State law, they often can purchase service credits in their State defined benefit pension plans for time spent in another state or district
and earn a pension reflecting a full career of employment in the state in which they conclude their career.
Under current law, these employees cannot make a taxfree transfer of the money they have saved in their
403(b) plan or governmental 457(b) plan to purchase
these credits and often lack other resources to use for
this purpose. Under the proposal, State and local government employees would be able to use funds from
these retirement savings plans to purchase service credits through a direct transfer without first having to
take a taxable distribution of these amounts.
Allow immediate participation in Federal Thrift
Savings Plan (TSP).—Under the Administration’s
proposal, all waiting periods for Federal employees’ participation in TSP (including matching and nonelective

3.

FEDERAL RECEIPTS

contributions) would be eliminated for new hires and
rehires.
Improve Pension Security
The Administration proposes a number of changes
to improve pension security in defined benefit plans.
Modify pension plan deduction rules.—For defined benefit plans, the change in the full funding limitation based on current liability would be phased in
more quickly, so that this limitation would be 170 percent of current liability for years beginning after December 31, 2003. In addition, the ten-percent excise
tax on nondeductible contributions would not apply to
the extent a contribution is nondeductible solely as a
result of the current liability full funding limit. The
special deduction rule for terminating plans would be
modified so that, at plan termination, all contributions
needed to satisfy the plan’s liabilities would be immediately deductible. In the case of a plan with fewer
than 100 participants, liabilities attributable to recent
benefit increases for highly compensated employees
would be disregarded for this purpose.
Simplify full funding limitation for multiemployer plans.—The limit on deductible contributions
based on a specified percentage of current liability
would be eliminated for multiemployer defined benefit
plans. Therefore, the annual deduction for contributions
to such a plan would be limited to the amount by which
the plan’s accrued liability exceeds the value of the
plan’s assets.
Modify defined benefit limit rules for multiemployer plans.—Defined benefit limits applicable to
multiemployer defined benefit plans would be modified
to eliminate the 100-percent-of-compensation limit (but
not the $135,000 limit) for such plans. In addition, the
special early retirement provisions for determining the
defined benefit limit that currently apply to defined
benefit plans sponsored by governments, tax-exempt organizations and merchant marine would be expanded
to include multiemployer plans. Finally, the rule requiring aggregation of benefits provided from a single employer for purposes of the defined benefit limit would
be modified so as not to require aggregation of a multiemployer defined benefit plan and a single employer
defined benefit plan for purposes of the 100-percentof-compensation limit.
Increase Disclosure and Right to Know
The Administration proposes to improve disclosure
to workers and their spouses.
Improve disclosure for plan amendments that
significantly reduce future benefit accruals.—The
Administration’s proposal would strengthen the existing
disclosure requirements that apply when a pension plan
is amended to significantly reduce the rate of future
benefit accrual. The proposal would require that the
notice summarize the important terms of the amend-

63
ment, including identification of the effective date of
the amendment, a statement that the amendment is
expected to significantly reduce the rate of future benefit accrual, a general description of how the amendment significantly reduces the rate of future benefit
accrual, and a description of the class or classes of
participants to whom the amendment applies. Participants must receive the notice at least 45 days before
the effective date of the plan amendment. If the plan
has at least 100 active participants, the plan administrator would also be required to provide affected participants an enhanced advance notice of the amendment
that describes, and illustrates using specific examples,
the impact of the amendment on representative affected
participants; to make available the formulas and factors
used in those examples in order to permit similar calculations to be made; and to make available a followup individualized benefit statement estimating the participant’s projected retirement benefits. Regulations
could exempt certain amendments, such as amendments that do not make a fundamental change in a
plan’s formula.
Pension ‘‘right-to-know’’ proposals.—The Administration’s proposal would enhance workers’ and spouses’
rights to know about their pension benefits by, among
other things, requiring that the same explanation of
a pension plan’s survivor benefits that is provided to
a participant be provided to the participant’s spouse.
Provide AMT Relief for Families and Simplify
the Tax Laws
Provide adjustments for personal exemptions
and the standard deduction in the individual alternative minimum tax (AMT).—The Administration
is concerned that the AMT imposes financial and compliance burdens upon taxpayers that have few preference items and were not the originally intended targets. In particular, the Administration is concerned that
the individual AMT may act to erode the benefits of
dependent personal exemptions and standard deductions that are intended to provide relief for middleincome taxpayers—especially those with larger families.
For example, under current law, a couple with five
children and $70,000 of income that claims the standard deduction would be subject to the AMT in 2000.
In response, the Administration proposes to phase out
the tax preference status of dependent exemptions
under the AMT; that is, when fully phased in, claiming
children as personal exemptions on a tax return would
not cause a taxpayer to be subject to the AMT. For
tax years 2000 through 2007, only the first two dependent exemptions would be AMT preference items; in
2008 and 2009, only the first exemption would be a
preference; in 2010 and thereafter, dependent exemptions would no longer be treated as an AMT preference.
The Administration also proposes to allow taxpayers
who claim the standard deduction for regular income
tax purposes to claim the same standard deduction for
AMT purposes for tax years 2000 and 2001. That provi-

64
sion would complement the provision enacted in 1999
that allows the use of personal credits against the AMT
through 2001.
Simplify and increase standard deduction for
dependent filers.—Currently, the standard deduction
for tax filers who can be claimed as dependents by
another taxpayer is the smaller of the standard deduction for single taxpayers ($4,400 for tax year 2000)
or the special standard deduction for dependent filers.
The special standard deduction is the larger of (1) $700
(for tax year 2000) or (2) the individual’s earned income
plus $250 (for tax year 2000). The current provision
requires dependents to file a tax return if they have
at least $250 of interest and dividends from their savings and their earnings plus income from savings is
at least $700. To simplify the standard deduction and
increase it for dependent filers, the Administration proposes that, beginning in 2000, the standard deduction
for dependent filers would be the individual’s earned
income plus $700 (indexed after 2000), but not more
than the regular standard deduction. This proposal
would reduce the number of dependent filers required
to file a tax return by 400,000 and simplify filing for
other dependents with earned income.
Replace support test with residency test (limited
to children).—Under current law, taxpayers must provide over half the support of individuals claimed as
dependents on their tax return. Under the proposal,
taxpayers would be allowed to claim their children as
dependents by meeting a residency test instead of a
support test. If the child is 18 or younger (23 or younger if a full-time student) and is the taxpayer’s son,
daughter, stepchild, or grandchild, then the support test
may be waived if the taxpayer lives with the child
for over half the year. A twelve-month test would apply
to foster children. If more than one taxpayer could
claim the child as a dependent under the proposed rule,
the taxpayer with the highest AGI would be entitled
to the dependency exemption. The proposal would be
effective for taxable years beginning after December
31, 2000.
Index maximum exclusion for capital gains on
sale of principal residence.—Under current law, taxpayers can generally exclude up to $250,000 ($500,000
for married taxpayers filing joint returns) of gain on
the sale of a principal residence. To be eligible for the
full exclusion, the taxpayer must have owned the residence and occupied it as a principal residence for at
least two of the five years preceding the sale. A taxpayer may claim the deduction only once in any twoyear period. Under the proposal, the maximum exclusion amounts would be indexed for inflation effective
January 1, 2001. The proposal will prevent inflation
from subjecting more taxpayers to tax when they sell
their homes, and will prevent more taxpayers from having to maintain complex records regarding the cost of
their homes.

ANALYTICAL PERSPECTIVES

Provide tax credit to encourage electronic filing
of individual income tax returns.—Under current
law, tax return preparation costs of individuals, including any costs of electronic filing, may be deducted only
by taxpayers who itemize deductions and then only to
the extent that such costs, in combination with most
other miscellaneous itemized deductions, exceed two
percent of AGI. The proposal would provide a temporary, refundable tax credit for the electronic filing
of individual income tax returns. The credit would be
for tax years 2001 through 2006 and would be $10
for each electronically filed return, and $5 for each
TeleFile return (which are filed by entering information
through the keypads of telephones). The credit would
encourage taxpayers to try electronic return or Telefile
submission, which reduces taxpayer errors and the need
for subsequent contacts between the taxpayer and the
IRS and which permits taxpayers to receive their tax
refunds faster. The credit would help the IRS achieve
the goal set in the 1998 IRS Restructuring and Reform
Act of having 80 percent of 2006 returns filed electronically. No later than tax year 2002, the IRS would be
required to offer one or more options to the public,
through contract arrangements with the private sector,
for preparing and filing individual income tax returns
over the Internet at no cost to the taxpayer.
Clarify the tax treatment of disabled workers in
a sheltered workshop.—The Administration’s proposal would provide a limited exclusion from the definition of ‘‘employment’’ for certain services rendered by
disabled individuals in a sheltered workshop program
effective the date of enactment. The exclusion would
be limited to service (1) performed for a period of no
more than 18 months under a minimum wage exemption certificate issued by the Department of Labor and
(2) provided in a sheltered workshop operated by a
section 501(c)(3) organization or a State or local government. However, organizations could voluntarily agree
to provide coverage, pursuant to an agreement with
the Social Security Administration. Corresponding
changes would be made to the Social Security Act.
Simplify, retarget and expand expensing for
small business.—In place of depreciation, a taxpayer
with a sufficiently small amount of annual investment
may elect to deduct up to $20,000 of the cost of qualifying property (generally depreciable tangible property)
placed in service in taxable year 2000. The deductible
amount rises to $24,000 in 2001 and 2002, and to
$25,000 in 2003 and subsequent taxable years. The Administration proposes to increase the amount of investment that can be expensed to $25,000 in taxable year
2001; thereafter, this amount would be increased for
inflation in increments of $1,000. In addition, the Administration proposes certain modifications to better
target the applicability of expensing, to allow the deduction to be claimed at the entity level for flow-through
businesses, and to make certain computer software eligible for expensing.

3.

FEDERAL RECEIPTS

65

Provide optional Self-employment Contributions
Act (SECA) computations.—Self-employed individuals
currently may elect to increase their self-employment
income for purposes of obtaining social security coverage. Current law provides more liberal treatment for
farmers as compared to other self-employed individuals.
The Administration proposes to extend the favorable
treatment currently accorded to farmers to other selfemployed individuals. The proposal would be effective
for taxable years beginning after December 31, 2000.

tributions from U.S. mutual funds that hold substantially all of their assets in cash or U.S. debt securities
(or foreign debt securities that are not subject to withholding tax under foreign law). The proposal is designed
to enhance the ability of U.S. mutual funds to attract
foreign investors and to eliminate complications now
associated with the structuring of vehicles for foreign
investment in U.S. debt securities. The proposal would
be effective for mutual fund taxable years beginning
after the date of enactment.

Clarify rules relating to certain disclaimers.—
Under current law, if a person refuses to accept (disclaims) a gift or bequest prior to accepting the transfer
(or any of its benefits), the transfer to the disclaiming
person generally is ignored for Federal transfer tax purposes. Current law is unclear as to whether certain
transfer-type disclaimers benefit from rules applicable
to other disclaimers under the estate and gift tax. Current law is also silent as to the income tax consequences of a disclaimer. The Administration proposes
to extend to transfer-type disclaimers the rule permitting disclaimer of an undivided interest in property as
well as the rule permitting a spouse to disclaim an
interest that will pass to a trust for the spouse’s benefit. The proposal also clarifies that disclaimers are effective for income tax purposes. The proposal would
apply to disclaimers made after the date of enactment.

Expand declaratory judgment remedy for noncharitable organizations seeking determinations
of tax-exempt status. —Under current law, organizations seeking tax-exempt status as charities are allowed
to seek a declaratory judgment as to their tax status
if their application is denied or delayed by the IRS.
A noncharity (an organization not described in section
501(c)(3)) that applies to the IRS for recognition of its
tax-exempt status faces potential tax liability if its application ultimately is denied by the IRS. This creates
uncertainty for the noncharity, particularly when the
IRS determination is delayed for a significant period
of time. To reduce this uncertainty, the declaratory
judgment procedure available to charities under current-law section 7428 would be expanded, so that if
the application of any organization seeking tax-exempt
status under section 501(c) is pending with the IRS
for more than 270 days, and the organization has exhausted all administrative remedies available within
the IRS, then the organization could seek a declaratory
judgment as to its tax-exempt status from the United
States Tax Court. The proposal would be effective for
applications for recognition of tax-exempt status filed
after December 31, 2000.

Simplify the foreign tax credit limitation for
dividends from 10/50 companies.—TRA97 modified
the regime applicable to indirect foreign tax credits generated by dividends from so-called 10/50 companies.
Specifically, the Act retained the prior law ‘‘separate
basket’’ approach with respect to pre-2003 distributions
by such companies, adopted a ‘‘single basket’’ approach
with respect to post-2002 distributions by such companies of their pre-2003 earnings, and adopted a ‘‘lookthrough’’ approach with respect to post-2002 distributions by such companies of their post-2002 earnings.
The application of the three approaches results in significant additional complexity. The proposal would simplify the application of the foreign tax credit limitation
significantly by applying a look-through approach immediately to dividends paid by 10/50 companies, regardless of the year in which the earnings and profits out
of which the dividends are paid were accumulated (including pre-2003 years). The proposal would be effective
for taxable years beginning after December 31, 1999.
Provide interest treatment for dividends paid by
certain regulated investment companies to foreign
persons.—Under current law, foreign investors in U.S.
bond and money-market mutual funds are effectively
subject to withholding tax on interest income and short
term capital gains derived through such funds. Foreign
investors that hold U.S. debt obligations directly generally are not subject to U.S. taxation on such interest
income and gains. This proposal would eliminate the
discrepancy between these two classes of foreign investors by eliminating the U.S. withholding tax on dis-

Simplify the active trade or business requirement for tax-free spin-offs.—In order to satisfy the
active trade or business requirement for tax-free spinoffs, split-offs, and split-ups, the distributing corporation and the controlled corporation both must be engaged in the active conduct of a trade or business.
If a corporation is not itself active, it may satisfy the
active trade or business test indirectly, but only if substantially all of its assets consist of stock and securities
of a controlled corporation that is engaged in an active
trade or business. Because the substantially all standard is much higher than that required if the corporation
is active itself, a taxpayer often must engage in predistribution restructurings that it otherwise would not
have undertaken. There is no clear policy reason that
the standards for meeting the active trade or business
requirement should differ depending upon whether a
corporation is considered to be active on a direct or
indirect basis. Therefore, the Administration proposes
to simplify the requirement by removing the substantially all test and generally allowing an affiliated group
to satisfy the active trade or business requirement as
long as the affiliated group, taken as a whole, is considered active. This proposal would be effective for transactions after the date of enactment.

66
Modify translation of foreign withholding taxes
by accrual basis taxpayers.—Under current law, taxpayers who take foreign income taxes into account
when accrued generally are required to translate such
taxes into dollars by using the average exchange rate
for the taxable year to which such taxes relate. This
rule was intended to be a simplification measure that
would reduce the need for accrual basis taxpayers to
redetermine the amount of foreign tax credits claimed
with respect to foreign taxes accrued prior to the date
of payment. This rule may not clearly reflect income,
however, in the case of foreign withholding taxes paid
by an accrual basis taxpayer, because such taxes are
never accrued prior to the date the tax is paid (regardless of the taxpayer’s method of accounting). Moreover,
certain taxpayers that receive income subject to withholding taxes (such as regulated investment companies
with a taxable year that differs from the calendar year)
may find it impossible to comply with current law. The
proposal would provide that foreign withholding taxes
are to be translated at the spot rate on the date of
payment, regardless of the method of accounting of the
taxpayer. The proposal would be effective for taxable
years beginning after the date of enactment.
Eliminate duplicate penalties for failure to file
annual reports.—Employer penalties for failure to file
an annual report would be simplified by eliminating
the Internal Revenue Code penalties for a plan to which
ERISA applies. Certain other ERISA reporting penalties would be modified or eliminated.
Clarify foreign tax credit rules to provide the
circumstances under which a domestic corporation that owns a foreign corporation through a
partnership will be eligible for the deemed-paid
credit.—A domestic corporation that is a U.S. shareholder of a controlled foreign corporation (CFC) can
claim deemed-paid foreign tax credits with respect to
foreign taxes paid by the CFC on the subpart F income
that the U.S. shareholder currently includes in income
to the same extent that it would be so allowed if the
subpart F inclusion were treated as an actual dividend
distribution. To be eligible for the deemed-paid credit
on an actual dividend distribution, a domestic corporation must own 10% or more of the voting stock of the
foreign corporation from which it receives the dividend.
Under current law, it is not clear how to apply the
deemed-paid foreign tax credit rules when a foreign
corporation is owned through a partnership. The proposal would provide that the deemed-paid credit is
available to a domestic corporation that, through a
partnership, owns 10% or more of the voting stock of
a foreign corporation from which it receives its proportionate share of dividend income. This rule would apply
to both foreign and U.S. partnerships. For purposes
of this provision, a foreign partnership would be treated
as a tier under the rule that allows the deemed-paid
credit only with respect to taxes paid by foreign corporations that are not below the sixth tier.

ANALYTICAL PERSPECTIVES

Encourage Philanthropy
Allow deduction for charitable contributions by
non-itemizing taxpayers.—To provide an incentive for
taxpayers who use the standard deduction to make
large charitable contributions, the Administration proposes a deduction for substantial charitable contributions made by taxpayers who do not itemize their deductions. Under current law, individual taxpayers who
itemize their deductions generally may claim a deduction (subject to certain percentage limitations) for contributions made to qualified charitable organizations.
However, individual taxpayers who elect the standard
deduction (so-called ‘‘non-itemizers’’) may not claim a
deduction for charitable contributions, although the
standard deduction theoretically includes an allowance
for moderate amounts of charitable giving. The proposal
would allow taxpayers who are non-itemizers to deduct
50 percent of their charitable contributions in excess
of $1,000 ($2,000 for married taxpayers filing jointly)
for taxable years beginning after December 31, 2000
and before January 1, 2006. For taxable years beginning after December 31, 2005, non-itemizers would be
allowed to deduct 50 percent of their charitable contributions in excess of $500 ($1,000 for married taxpayers filing jointly).
Simplify and reduce the excise tax on foundation
investment income.—Under current law, private foundations generally are subject to a two-percent excise
tax on their net investment income. In some cases,
the excise tax rate is reduced to one percent, provided
that current-year grantmaking by the foundation is determined under a complex formula to not fall below
the average level of the foundation’s grantmaking in
the five preceding taxable years (with certain adjustments). This complex formula creates a perverse incentive for foundations not to significantly increase their
grantmaking for charitable purposes in any particular
year, because if a foundation does so, it becomes more
difficult for the foundation to qualify for the reduced
one-percent excise tax rate in subsequent years. Accordingly, the Administration proposes that the excise tax
on private foundation investment income be simplified
by reducing the general two-percent excise tax rate to
a 1.25-percent excise tax rate that would apply in all
cases. The complex formula for determining whether
a foundation is maintaining its historic level of charitable grantmaking, and the special excise tax rate
available to only some foundations, would be repealed.
Thus, private foundations would not suffer adverse excise tax consequences if they respond to charitable
needs by significantly increasing their grantmaking in
a particular year. The proposal would be effective for
taxable years beginning after December 31, 2000.
Increase limit on charitable donations of appreciated property.—Under current law, charitable contributions made by individuals who do not claim the
standard deduction are deductible for income tax purposes, up to certain limits depending on the type of

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67

FEDERAL RECEIPTS

property donated and whether the donee organization
qualifies as a public charity or private foundation. Contributions made by an individual to a public charity
generally are deductible in an amount not exceeding
50 percent of the individual’s AGI for the current year
(with any remaining amount carried over for up to five
taxable years). In the case of contributions made by
an individual to a private foundation, a 30-percent AGI
limitation generally applies. However, in the case of
donated stock and other non-cash contributions, a 30percent AGI limitation applies to gifts to public charities, and a 20-percent AGI limitation applies to gifts
to private foundations. These special contribution limits
for non-cash gifts create unnecessary complexity and
could discourage gifts of valuable or unique property
to charitable organizations. Therefore, the Administration proposes that the special contribution limits for
non-cash gifts be repealed, effective for contributions
made after December 31, 2000.
Clarify public charity status of donor advised
funds.—-In recent years, there has been an explosive
growth in so-called ‘‘donor advised funds’’ maintained
by charitable corporations. These funds generally permit a donor to claim a current charitable contribution
deduction for amounts contributed to a charity and to
provide ongoing advice regarding the investment or distribution of such amounts, which are maintained by
the charity in a separate fund or account. In the absence of clear guidelines, donor advised funds potentially may be used to provide donors with the benefits
normally associated with private foundations (such as
control over grantmaking), without the regulatory safeguards that apply to private foundations. Therefore, the
Administration proposes that current-law rules be clarified so that a charitable corporation which, as its primary activity, operates donor advised funds may qualify
as a publicly supported organization only if: (1) there
is no material restriction or condition that prevents
the corporation from freely and effectively employing
the contributed assets in furtherance of its exempt purposes; (2) distributions from donor advised funds are
made only to public charities (or private operating foundations); and (3) the corporation distributes annually
for charitable purposes an amount equal to at least
five percent of the fair market value of the corporation’s
aggregate investment assets. The proposal also would
clarify that, for purposes of the section 4958 excise tax
on certain excess benefit transactions, a person who
provides advice with respect to a particular donor advised fund maintained by a public charity is treated
as having substantial influence with respect to that
particular fund.
Promote Energy Efficiency and Improve the
Environment
Buildings
Provide tax credit for energy-efficient building
equipment.—No income tax credit is provided currently for investment in energy-efficient building equip-

ment. The Administration proposes to provide a new
tax credit for the purchase of certain highly efficient
building equipment technologies, including fuel cells,
electric heat pump water heaters, and natural gas heat
pumps. The credit would equal 20 percent of the
amount of qualified investment, subject to caps of $500
per kilowatt for fuel cells, $500 per unit for electric
heat pump water heaters, and $1,000 per unit for natural gas heat pumps. The credit would be available
for the four-year period beginning January 1, 2001 and
ending December 31, 2004.
Provide tax credit for new energy-efficient
homes.—No income tax credit is provided currently for
investment in energy-efficient homes. The Administration proposes to provide a tax credit to taxpayers who
purchase, as a principal residence, certain newly constructed homes that are highly energy efficient. The
credit would equal $1,000 or $2,000 depending upon
the home’s energy efficiency. The $1,000 credit would
be available for homes purchased between January 1,
2001 and December 31, 2003 that reduce energy usage
by at least 30 percent relative to the standard under
the 1998 International Energy Conservation Code
(IECC). The $2,000 credit would be available for homes
purchased between January 1, 2001 and December 31,
2005 that reduce energy usage by at least 50 percent
relative to the IECC standard.
Transportation
Extend electric vehicle tax credit and provide
tax credit for hybrid vehicles.—Under current law,
a 10-percent tax credit up to $4,000 is provided for
the cost of a qualified electric vehicle. The full amount
of the credit is available for purchases prior to 2002.
The credit begins to phase down in 2002 and is not
available after 2004. The Administration proposes to
extend the present $4,000 credit through 2006 and to
allow the full amount of the credit to be available for
qualified electric vehicles through 2006. The Administration also proposes to provide a tax credit of up to
$3,000 for purchases of a qualified hybrid vehicle after
December 31, 2002 and before January 1, 2007. A qualified hybrid vehicle is a road vehicle that can draw
propulsion energy from both of the following on-board
sources of stored energy: a consumable fuel and a rechargeable battery. The amount of the credit would depend upon the vehicle’s design performance. The credit
would be available for all qualifying light vehicles including cars, minivans, sport utility vehicles, and light
trucks.
Industry
Provide 15-year depreciable life for distributed
power property.—Distributed power technologies can
be more energy efficient and generate fewer greenhouse
gases than conventional generation methods. To promote the use of these technologies, the Administration
proposes to simplify and rationalize the current system
for assigning cost recovery periods to certain depre-

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ANALYTICAL PERSPECTIVES

ciable property by assigning a single 15-year recovery
period to qualifying distributed power property. Distributed power property would include depreciable assets
used by a taxpayer to produce electricity for use in
a nonresidential or residential building that is used
in the taxpayer’s trade or business. Such property also
would include depreciable assets used to generate electricity for primary use in an industrial manufacturer’s
process or plant activity, provided such assets had a
rated total capacity in excess of 500 kilowatts. Qualifying property could be used to produce thermal energy
or mechanical power for use in a heating or cooling
application. However, at least 40 percent of the total
useful energy produced in a commercial or residential
setting must consist of electrical power. When used in
an industrial setting, at least 40 percent of produced
energy must be used in the taxpayer’s manufacturing
process or plant activity. In addition, a taxpayer would
be required to have a reasonable expectation that no
more than 50 percent of the produced electricity would
be sold to, or used by, unrelated persons. The proposal
would apply to assets placed in service after the date
of enactment.
Clean Energy Sources
Extend and modify the tax credit for producing
electricity from certain sources.—Current law provides taxpayers a 1.5-cent-per-kilowatt-hour tax credit,
adjusted for inflation after 1992, for electricity produced
from wind or ‘‘closed-loop’’ biomass. The electricity must
be sold to an unrelated third party and the credit applies to the first 10 years of production. The current
credit applies only to facilities placed in service before
January 1, 2002, after which it expires. The Administration proposes to extend the current credit for wind
and closed-loop biomass for two and one-half years, to
facilities placed in service before July 1, 2004, and to
expand eligible biomass to include certain biomass from
forest-related resources, agricultural sources and other
sources for facilities placed in service after December
31, 2000 and before January 1, 2006. Biomass facilities
that were placed in service before July 1, 1999 would
be eligible for a credit of 1.0 cent per kilowatt hour
for electricity produced from the newly eligible sources
from January 1, 2001 through December 31, 2003. A
0.5-cent-per-kilowatt-hour tax credit would also be allowed for cofiring biomass in coal plants from January
1, 2001 through December 31, 2005. In addition, electricity produced from methane from certain facilities
would be eligible for the following credits: (1) 1.5 cent
per kilowatt hour for methane produced from landfills
not subject to EPA’s 1996 New Source Performance
Standards/Emissions Guidelines (NSPS/EG), or (2) 1.0
cent per kilowatt hour for methane produced from landfills subject to NSPS/EG. The credit would apply to
facilities placed in service after December 31, 2000 and
before January 1, 2006.
Provide tax credit for solar energy systems.—Current law provides a 10-percent business energy invest-

ment tax credit for qualifying equipment that uses solar
energy to generate electricity, to heat or cool, to provide
hot water for use in a structure, or to provide solar
process heat. The Administration proposes a new tax
credit for purchasers of roof-top photovoltaic systems
and solar water heating systems located on or adjacent
to the building for uses other than heating swimming
pools. The proposed credit would be equal to 15 percent
of qualified investment up to a maximum of $1,000
for solar water heating systems and $2,000 for rooftop
photovoltaic systems. The credit would apply only to
equipment placed in service after December 31, 2000
and before January 1, 2006 for solar water heating
systems, and after December 31, 2000 and before January 1, 2008 for rooftop photovoltaic systems. (Taxpayers
would choose between the proposed tax credit and the
current-law tax credit for each investment.)
Electricity Restructuring
Revise tax-exempt bond rules for electric power
facilities.—To encourage restructuring the nation’s
electric power industry so that consumers benefit from
competition, rules relating to the use of tax-exempt
bonds to finance electric power facilities would be modified. To encourage public power systems to implement
retail competition, outstanding bonds issued to finance
transmission facilities would continue their tax-exempt
status if private use resulted from allowing nondiscriminatory open access to those facilities. Outstanding
bonds issued to finance generation or distribution facilities would continue their tax-exempt status if the issuer
implements retail competition. To support fair competition within the restructured industry, interest on newly
issued bonds to finance electric generation or transmission facilities would not be exempt. Distribution facilities could continue to be financed with tax-exempt
bonds. These changes would be effective upon enactment.
Modify taxation of contributions to nuclear decommissioning funds.—Under current law, deductible
contributions to nuclear decommissioning funds are limited to the amount included in the taxpayer’s cost of
service for ratemaking purposes. For deregulated utilities, this limitation may result in the denial of any
deduction for contributions to a nuclear decommissioning fund. The Administration proposes to repeal the
limitation for taxable years beginning after December
31, 2000. As under current law, deductible contributions would not be permitted to exceed the amount
the IRS determines to be necessary to provide for level
funding of an amount equal to the taxpayer’s decommissioning costs.
Modify International Trade Provisions
Extend and modify Puerto Rico economic-activity tax credit.—The Puerto Rico and possessions tax
credit was repealed in 1996. However, both the incomebased credit and the economic-activity-based credit remain available for certain business operations con-

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69

FEDERAL RECEIPTS

ducted in taxable years beginning before January 1,
2006, subject to base-period caps. To provide a more
efficient tax incentive for the economic development of
Puerto Rico and to continue the shift from an incomebased credit to an economic-activity-based credit that
was begun in 1993, the proposal would modify the
phase-out of the economic-activity-based credit for Puerto Rico by (1) opening it to newly established business
operations during the phase-out period, effective for
taxable years beginning after December 31, 1999, and
(2) extending the phase-out period through taxable
years beginning before January 1, 2009.
Extend the Generalized System of Preferences
(GSP) and modify other trade provisions.—Under
GSP, duty-free access is provided to over 4,000 items
from eligible developing countries that meet certain
worker rights, intellectual property protection, and
other criteria. The Administration proposes to extend
the program, which expires after September 30, 2001,
through June 30, 2004. The Administration also is proposing to: (1) enhance trade benefits, through December
31, 2010, for subsaharan African countries undertaking
strong economic reforms; (2) grant, through September
30, 2004, duty-free treatment to certain imports from
the Southeast Europe countries and territories of Albania, Bosnia and Herzegovina, Bulgaria, Croatia, the
Former Yugoslav Republic of Macedonia, Romania, Slovenia, Kosovo and Montenegro; and (3) provide, through
December 31, 2004, expanded trade benefits mainly on
textiles and apparel to Caribbean Basin countries that
meet new eligibility criteria. These proposals will help
Caribbean Basin countries prepare for a future free
trade agreement with the United States and respond
to the effects of Hurricanes George and Mitch, and
will help the countries of Southeast Europe rebuild and
reintegrate their economies and work toward achieving
lasting political stability in the region.
Levy tariff on certain textiles and apparel products produced in the Commonwealth of the Northern Mariana Islands (CNMI).—The Administration
is proposing a tariff on textile and apparel products
that are produced in the CNMI without certain percentages of workers who are U.S. citizens, nationals or permanent residents or citizens of the Pacific island nations freely associated with the U.S.
Miscellaneous Provisions
Make first $2,000 of severance pay exempt from
income tax.—Under current law, payments received
by a terminated employee are taxable as compensation.
The Administration proposes to allow an individual to
exclude up to $2,000 of severance pay from income
when certain conditions are met. First, the severance
must result from a reduction in force by the employer.
Second, the individual must not obtain a job within
six months of separation with compensation at least
equal to 95 percent of his or her prior compensation.
Third, the total severance payments received by the

employee must not exceed $75,000. The exclusion would
be effective for severance pay received in taxable years
beginning after December 31, 2000 and before January
1, 2004.
Exempt Holocaust reparations from Federal income tax.—The Internal Revenue Code defines gross
income as ‘‘gross income from whatever source derived,’’
except for certain items specifically exempt or excluded
by statute. Although the United States - Federal Republic of Germany Income Tax Convention and a series
of rulings issued by the IRS provide that certain Holocaust-related reparations are exempt from Federal income tax, there is no explicit statutory exception from
gross income for amounts received by Holocaust victims
or their heirs. In recent years, several countries and
companies within those countries have acknowledged
that they have not made adequate compensation or restitution to victims or their heirs for the deprivations
inflicted upon them during the Nazi Holocaust, and
have agreed to establish funds or to make direct payments of cash or property to such individuals. To provide clarity and relief for Holocaust victims and their
families, the Administration proposes a statutory exemption from gross income for any amount received
by an individual or heir of an individual from Holocaust-related funds and settlements, including in compensation for or recovery of property confiscated in connection with the Holocaust. The proposal would be effective for amounts received on or after January 1,
2000. No inference is intended as to the tax treatment
of amounts received prior to that date.
ELIMINATE UNWARRANTED BENEFITS AND
ADOPT OTHER REVENUE MEASURES
The President’s plan closes tax shelters and other
loopholes, curtails unwarranted corporate tax subsidies,
improves tax compliance and adopts other revenue
measures.
Limit Benefits of Corporate Tax Shelter
Transactions
The Administration continues to be concerned about
the use and proliferation of corporate tax shelters and
their effect upon both the corporate tax base and the
integrity of the tax system as a whole. The primary
goals of corporate tax shelters are to manufacture tax
benefits that can be used to offset unrelated income
of the taxpayer or to create tax-favored or tax-exempt
economic income.
The growing use of corporate tax shelters was further
described by the Treasury Department in its White
Paper entitled, The Problem of Corporate Tax Shelters:
Discussion, Analysis and Legislative Proposals, issued
in July 1999. The paper concludes that corporate tax
shelters are best addressed by increasing disclosure of
corporate tax shelter activities, increasing and strengthening the substantial understatement penalty, codifying
the judicially-created economic substance doctrine, and
providing consequences to all parties to the transaction

70
(e.g., promoters, advisors, and tax-indifferent, accommodating parties.)
The Administration proposes several general remedies to curb the growth of corporate tax shelters that
focus on these four themes. In addition, the Administration proposes to modify the treatment of certain specific
transactions that provide sheltering potential. No inference is intended as to the treatment of any of these
transactions under current law.
Increase disclosure of certain transactions.—
Greater disclosure of corporate tax shelter transactions
will discourage some corporations from engaging in
such activity and would aid the IRS in identifying questionable transactions and enforcing current law. The
Administration proposes to require disclosure of certain
reportable transactions. Disclosure would be required
if a transaction possesses certain objective characteristics common to corporate tax shelter transactions. Disclosure would be made on a short form or statement
that provides the essence of the transaction, is filed
with the IRS National Office and with the tax return
by the due date of the return, and is signed by a corporate officer with the appropriate knowledge of the
transaction. Significant monetary and procedural remedies would be imposed upon failure to provide the
required disclosure. The proposal would be effective for
transactions entered into after the date of first committee action.
Modify substantial understatement penalty for
corporate tax shelters.—The current 20-percent substantial understatement penalty imposed on corporate
tax shelter items can be avoided if the corporate taxpayer had reasonable cause for the tax treatment of
the item and acted in good faith. In order to change
the cost-benefit analysis of entering a corporate tax
shelter, the Administration proposes to increase the
substantial understatement penalty on corporate tax
shelter items to 40 percent. In order to encourage disclosure, the penalty will be reduced to 20 percent if
the corporate taxpayer provides the requisite disclosure
of the transaction. The 20-percent penalty for disclosed
transactions could be avoided by a showing that the
taxpayer reasonably believed that it had a strong
chance of sustaining its tax position and acted in good
faith. The proposal would be effective for transactions
entered into after the date of first committee action.
Codify the economic substance doctrine.—The
‘‘economic substance’’ doctrine is a longstanding, judicially-created standard providing that in order for a
transaction to be respected for tax purposes, it must
be imbued with economic substance. The economic substance doctrine requires an analysis and balancing of
the claimed tax benefits from a transaction with the
pre-tax profit of the transaction. The Administration
proposes codifying the economic substance standard.
Under the proposal, a transaction will not be respected
for tax purposes if the present value of the expected
economic profit from the transaction is insignificant

ANALYTICAL PERSPECTIVES

compared to the present value of the expected tax benefits. Similar rules would apply to financing transactions. The proposal would apply to transactions entered into on or after the date of first committee action.
Tax income from corporate tax shelters involving tax-indifferent parties.—The Federal income tax
system has many participants who are indifferent to
tax consequences (e.g., foreign persons, tax-exempt organizations, and Native American tribal organizations).
Many corporate tax shelters rely on tax-indifferent participants who absorb taxable income generated by the
shelters so that corresponding losses or deductions can
be allocated to taxable participants. The proposal would
provide that any income received by a tax-indifferent
person with respect to a corporate tax shelter would
be taxable to the extent the person is trading on its
special tax status. The proposal would be effective for
transactions entered into on or after the date of first
committee action.
Impose a penalty excise tax on certain fees received by promoters and advisors..—Users of corporate tax shelters often pay large fees to promoters
and advisors with respect to the shelter transactions.
The proposal would impose a 25-percent penalty excise
tax on fees received in connection with the promotion
of corporate tax shelters and the rendering of certain
tax advice related to corporate tax shelters. The proposal would be effective for payments made on or after
the date of first committee action.
Require accrual of income on forward sale of
corporate stock.—There is little substantive difference
between a corporate issuer’s current sale of its stock
for deferred payment and an issuer’s forward sale of
the same stock. In both cases, a portion of the deferred
payment compensates the issuer for the time-value of
money during the term of the contract. Under current
law, the issuer must recognize the time-value element
of the deferred payment as interest if the transaction
is a current sale for deferred payment but not if the
transaction is a forward contract. Under the proposal,
the issuer would be required to recognize the timevalue element of the forward contract as well. The proposal would be effective for forward contracts entered
into after the date of first committee action.
Modify treatment of ESOP as S corporation
shareholder.—Pursuant to provisions enacted in 1996
and 1997, an employee stock ownership plan (ESOP)
may be a shareholder of an S corporation and the
ESOP’s share of the income of the S corporation is
not subject to tax until distributed to the plan beneficiaries. The Administration proposes to require ESOPs
that are not broad based to pay tax on S corporation
income (including capital gains on the sale of stock)
as the income is earned and to allow the ESOP a deduction for distributions of such income to plan beneficiaries. The deduction would apply only to the extent
distributions exceed all prior undistributed amounts

3.

FEDERAL RECEIPTS

that were previously not subject to unrelated business
income tax. The proposal would be effective for taxable
years beginning on or after the date of first committee
action. In addition, the proposal would be effective for
acquisitions of S corporation stock by an ESOP after
such date and for S corporation elections made on or
after such date.
Limit dividend treatment for payments on certain self-amortizing stock.—Under current law, distributions of property by a corporation to its shareholders are treated as dividends to the extent of the
current or accumulated earnings and profits of the corporation. The Treasury Department previously became
aware of certain abusive transactions involving socalled ‘‘fast-pay’’ stock. Under a typical fast-pay arrangement, a corporation that is subject to tax only
at the shareholder level (a conduit entity) issues preferred stock to one class of investors and common stock
to a second class of investors. The preferred stock is
economically self-amortizing because the distributions
made with respect to the stock (although treated entirely as dividends under current law) represent in part
a return of the investors’ investment and in part a
return on their investment. While The Treasury Department has issued regulations that recharacterize a
fast-pay arrangement involving certain domestic conduit entities, legislation limiting the dividend characterization on self-amortizing stock (including self-amortizing stock issued by foreign conduit entities) may be
a more comprehensive solution. The proposal would provide that, in the case of a distribution with respect
to self-amortizing stock issued by a conduit entity (including a foreign conduit entity), the amount treated
as a dividend shall not exceed the amount of the distribution that would have been characterized as interest had the self-amortizing stock been a debt instrument. The proposal would be effective for distributions
with respect to self-amortizing stock made after the
date of enactment.
Prevent serial liquidation of U.S. subsidiaries
of foreign corporations.—When a domestic corporation distributes a dividend to a foreign corporation, it
is subject to U.S. withholding tax. In contrast, if a
domestic corporation distributes earnings in a subsidiary liquidation under section 332, the foreign shareholder generally is not subject to any withholding tax.
Relying on section 332, some foreign corporations have
used holding companies to avoid the withholding tax.
They establish U.S. holding companies to receive taxfree dividends from operating subsidiaries, and then
liquidate the holding companies, thereby avoiding the
withholding tax. Subsequently, they re-establish the
holding companies to receive future dividends. The proposal would impose withholding tax on any distribution
made to a foreign corporation in complete liquidation
of a U.S. holding company if the holding company was
in existence for less than 5 years. The proposal would
also achieve a similar result with respect to serial terminations of U.S. branches. The proposal would be ef-

71
fective for liquidations and terminations occurring on
or after the date of enactment.
Prevent capital gains avoidance through basis
shift transactions involving foreign shareholders.—A distribution in redemption of stock generally is treated as a dividend if it does not result
in a meaningful reduction in the shareholder’s proportionate interest in the distributing corporation, measured with reference to certain constructive ownership
rules, including option attribution. If an amount received in redemption of stock is treated as a distribution of a dividend, the basis of the remaining stock
generally is increased to reflect the basis of the redeemed stock. The basis of the remaining stock is not
increased, however, to the extent that the basis of the
redeemed stock was reduced or eliminated pursuant
to the extraordinary dividend rules. In certain circumstances, these rules require a corporate shareholder
to reduce the basis of stock with respect to which a
dividend is received by the nontaxed portion of the
dividend, which generally equals the amount of the dividend that is offset by the dividends received deduction.
To prevent taxpayers from attempting to offset capital
gains by generating artificial capital losses through
basis shift transactions involving foreign shareholders,
the Administration proposes to treat the portion of a
dividend that is not subject to current U.S. tax as a
nontaxed portion. Similar rules would apply in the
event that the foreign shareholder is not a corporation.
The proposal would be effective for distributions on or
after the date of first committee action.
Prevent mismatching of deductions and income
inclusions in transactions with related foreign
persons.—Current law provides that if any debt instrument having original issue discount (OID) is held by
a related foreign person, any portion of such OID shall
not be allowable as a deduction to the issuer until
paid. Section 267 and the regulations thereunder apply
similar rules to other expenses and interest owed to
related foreign persons. These general rules are modified, however, so that a deduction is allowed when the
OID is includible in the income of a foreign personal
holding company (FPHC), controlled foreign Department corporation (CFC), or passive foreign investment
company (PFIC). The Treasury Department has learned
of certain structured transactions (involving both U.S.
payors and U.S.-owned foreign payors) designed to
allow taxpayers inappropriately to take advantage of
the current rules by accruing deductions to related
FPHCs, CFCs or PFICs, without the U.S. owners of
such related entities taking into account for U.S. tax
purposes an amount of income appropriate to the accrual. This results in an improper mismatch of deductions and income. The proposal would provide that deductions for amounts accrued but unpaid to related foreign CFCs, PFICs or FPHCs would be allowable only
to the extent the amounts accrued by the payor are,
for U.S. tax purposes, reflected in the income of the
direct or indirect U.S. owners of the related foreign

72
person. The proposal would contain an exception for
certain short term transactions entered into in the ordinary course of business. The Secretary of Treasury
would be granted regulatory authority to provide exceptions from these rules. The proposal would be effective
for amounts accrued on or after the date of first committee action.
Prevent duplication or acceleration of loss
through assumption of certain liabilities.—Generally, if as part of a transaction in which one or more
persons contribute property in exchange for the stock
of a corporation that they control immediately thereafter, the corporation also assumes a liability of a transferor, the transferor’s basis in the stock of the controlled corporation is reduced by the amount of the
liability assumed. To facilitate the incorporation of certain businesses that have liabilities that have not yet
given rise to a deduction, special rules apply to provide
that the assumption of such liabilities does not reduce
the transferor’s basis in the stock of the controlled corporation. Relying on these special rules and other authority, some taxpayers have attempted to accelerate
or duplicate deductions for certain losses by separating
liabilities from the associated business or assets, contributing them to a corporation, and selling stock in
that corporation at a purported loss. The Administration proposes that if the basis of stock received by a
transferor as part of a tax-free exchange with a controlled corporation exceeds its fair market value, then
the basis of the stock received would be reduced (but
not below the fair market value) by the amount of
a fixed or contingent liability that is assumed by the
controlled corporation and that did not otherwise reduce
the transferor’s basis in the corporation’s stock. Except
as provided by the Secretary of Treasury , the proposal
would not apply where the trade or business or substantially all the assets associated with the liability
are also transferred to the controlled corporation. Regulations would be issued to prevent the acceleration or
duplication of losses through the assumption of liabilities in transactions involving partnerships, and may
also be issued to modify the rules of this proposal as
applied to S corporations. The proposal and the regulations addressing transactions involving partnerships
would be effective for assumptions of liability on or
after October 19, 1999. Regulations addressing transactions involving S corporations would be effective on
or after October 19, 1999, or such later date as may
be prescribed by such rules.
Amend 80/20 company rules.—Interest or dividends
paid by a so-called ‘‘80/20 company’’ generally are partially or fully exempt from U.S. withholding tax. A U.S.
corporation is treated as an 80/20 company if at least
80 percent of the gross income of the corporation for
the three-year period preceding the year of the payment
is foreign source income attributable to the active conduct of a foreign trade or business (or the foreign business of a subsidiary). Certain foreign multinationals
improperly seek to exploit the rules applicable to 80/

ANALYTICAL PERSPECTIVES

20 companies in order to avoid U.S. withholding tax
liability on earnings of U.S. subsidiaries that are distributed abroad. The proposal would prevent taxpayers
from avoiding withholding tax through manipulations
of these rules. The proposal would limit the amount
of interest and dividends exempt from withholding to
the amount of foreign active business income received
by the U.S. corporation during the 3-year testing period. The proposal would apply to interest or dividends
paid or accrued more than 30 days after the date of
enactment.
Modify corporate-owned life insurance (COLI)
rules.—In general, interest on indebtedness with respect to life insurance, endowment or annuity contracts
is not deductible unless the insurance contract insures
the life of a ‘‘key person’’ of a business. In addition,
interest deductions of a business generally are reduced
under a proration rule if the business owns or is a
direct or indirect beneficiary with respect to certain
insurance contracts. The COLI proration rules generally
do not apply if the contract covers an individual who
is a 20-percent owner of the business or is an officer,
director, or employee of such business. These exceptions
still permit leveraged businesses to fund significant
amounts of deductible interest and other expenses with
tax-exempt or tax-deferred inside buildup on contracts
insuring employees, officers, directors, and shareholders. The Administration proposes to repeal the exception under the COLI proration rules for contracts
insuring employees, officers or directors (other than certain contracts insuring 20-percent owners) of the business. The proposal also would conform the key person
exception for disallowed interest deductions attributable
to indebtedness with respect to life insurance contracts
to the modified 20-percent owner exception in the COLI
proration rules. The proposal would be effective for taxable years beginning after date of enactment.
Require lessors of tax-exempt-use property to include service contract options in lease term.—
Under current law, a lessor of tax-exempt-use property
is allowed depreciation deductions computed on a
straight-line basis over a period of not less than 125
percent of the term of the lease. The existing depreciation rules do not consider service contracts, which can
be structured to resemble leases. In recent years, lessors have attempted to accelerate depreciation deductions by structuring transactions that have a relatively
short lease followed by a service contract. The proposal
would require lessors to include the term of service
contracts in the lease term for purposes of determining
the depreciation period. The proposal would be effective
for leases entered into after the date of enactment.
Financial Products
Require banks to accrue interest on short-term
obligations.—Under current law, a bank (regardless
of its accounting method) must accrue as ordinary income interest, including original issue discount, on

3.

FEDERAL RECEIPTS

short-term obligations. Some court cases have held that
banks that use the cash receipts and disbursements
method of accounting do not have to accrue stated interest and original issue discount on short-term loans
made in the ordinary course of the bank’s business.
The Administration believes it is inappropriate to treat
these short-term loans differently than other short-term
obligations held by the bank. The Administration’s proposal would clarify that banks must accrue interest
and original issue discount on all short-term obligations, including loans made in the ordinary course of
the bank’s business, regardless of the banks’ overall
accounting method. The proposal would be effective for
obligations acquired (including originated) on or after
the date of enactment. No inference is intended regarding the current-law treatment of these transactions.
Require current accrual of market discount by
accrual method taxpayers.—Under current law, a
taxpayer that holds a debt instrument with market discount is not required to include the discount in income
as it accrues, even if the taxpayer uses an accrual
method of accounting. Under the proposal, a taxpayer
that uses an accrual method of accounting would be
required to include market discount in income as it
accrues. The proposal would also cap the amount of
market discount on distressed debt instruments. The
proposal would be effective for debt instruments acquired on or after the date of enactment.
Modify and clarify certain rules relating to debtfor-debt exchanges.—Under current law, an issuer
can inappropriately accelerate interest deductions by
refinancing a debt instrument in a debt-for-debt exchange at a time when the issuer’s cost of borrowing
has declined. The proposal would spread the issuer’s
net deduction for bond repurchase premium in a debtfor-debt exchange over the term of the new debt instrument using constant yield principles. In addition, the
proposal would modify the measurement of the net income or deduction in debt-for-debt exchanges involving
contingent payment debt instruments. Finally, the proposal would modify the measurement of taxable boot
to the holder in debt-for-debt exchanges that are part
of corporate reorganizations. The proposal would apply
to debt-for-debt exchanges occurring on or after the
date of enactment.
Modify and clarify the straddle rules.—A ‘‘straddle’’ is the holding of two or more offsetting positions
with respect to actively-traded personal property. If a
taxpayer enters into a straddle, the taxpayer must defer
the recognition of loss from the ‘‘loss leg’’ of the straddle
until the taxpayer recognizes the offsetting gain from
the ‘‘gain leg’’ of the straddle. Further, the taxpayer
must capitalize the net interest and carrying charges
properly attributable to the straddle. The proposal
would modify and clarify a number of provisions under
the straddle rules. In particular, to match the timing
of straddle losses with related gains, the proposal would
provide that loss realized on one leg of a straddle would

73
be capitalized into the other leg of the straddle. This
capitalization would operate as an ordering rule eliminating the need for an identification rule when the
legs are of different sizes. In addition, to ensure that
the loss on a straddle leg is properly measured, the
proposal would require taxpayers that physically settle
certain derivatives contracts to determine the amount
of the loss subject to deferral under the straddle rules
immediately before the physical settlement. The proposal would also repeal the current-law exception from
the straddle rules for certain offsetting positions in
stock. Finally, the proposal would clarify that a debt
instrument issued by a taxpayer may itself be a leg
in a straddle and would clarify the situations in which
interest and carrying charges are considered properly
allocable to a straddle and, therefore, must be capitalized. The proposal would be effective for certain losses
incurred and certain straddles entered into on or after
the date of first committee action.
Provide generalized rules for all stripping transactions.—Under current law, it may be possible to separate the right to receive income from the ownership
of underlying income-producing property (other than
debt). In many cases, the tax treatment of income-stripping transactions does not clearly reflect the parties’
economic income from the transactions. As a result,
it is possible for taxpayers to structure income-stripping
transactions that exploit deficiencies of current law.
The proposal would eliminate these planning opportunities by treating income-stripping transactions as loans.
Under this approach, the owner of the property would
be required to account for income from the property
in the period in which it was earned. The proposal
would be effective for income-stripping transactions entered into after the date of first committee action.
Require ordinary treatment for certain dealers
of commodities and equity options.—Under current
law, certain dealers of commodities and equity options
treat the income from their day-to-day trading or dealing activities as giving rise to capital gain. Dealers
of other property typically treat the income from their
day-to-day dealing activities as giving rise to ordinary
income. The proposal would require commodities and
equity-option dealers to treat the income from their
day-to-day activities as giving rise to ordinary income,
not capital gain. The proposal would be effective for
tax years beginning after the date of enactment.
Prohibit tax deferral on contributions of appreciated property to swap funds.—A swap fund is an
investment partnership that is designed to allow taxpayers holding large blocks of appreciated stock to diversify their stock investments without recognizing gain
and paying tax. Typically, a fund is established into
which wealthy individuals transfer their stock. In exchange for the transferred stock, these individuals receive an interest in the fund. Under current law, these
individuals do not have to recognize gain if more than
20 percent of the fund’s assets are comprised of non-

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ANALYTICAL PERSPECTIVES

marketable securities. The proposal would prohibit the
deferral of gain where the fund is a passive investment
vehicle. The proposal would be effective for transfers
occurring on or after the date of enactment.
Corporate Provisions
Conform control test for tax-free incorporations,
distributions, and reorganizations.—For tax-free
incorporations, tax-free distributions, and reorganizations, ‘‘control’’ is defined as the ownership of 80 percent of the voting stock and 80 percent of the number
of shares of all other classes of stock of the corporation.
This test is easily manipulated by allocating voting
power among the shares of a corporation, allowing corporations to retain control of a corporation but sell a
significant amount of the value of the corporation. In
contrast, the necessary ‘‘ownership’’ for tax-free liquidations, qualified stock purchases, and affiliation is at
least 80 percent of the total voting power of the corporation’s stock and at least 80 percent of the total value
of the corporation’s stock. The Administration proposes
to conform the control requirement for tax-free
incorporations, distributions, and reorganizations with
that used for determining affiliation. This proposal is
effective for transactions on or after the date of enactment.
Treat receipt of tracking stock in certain distributions and exchanges as the receipt of property.—‘‘Tracking stock’’ is an economic interest that is
intended to relate to and track the economic performance of one or more separate assets of the issuer, and
gives its holder a right to share in the earnings or
value of less than all of the corporate issuer’s earnings
or assets. Tracking stock issued by a corporation represents an economic interest different than non-tracking stock of the issuer. Under the proposal, the receipt
of tracking stock in a distribution made by a corporation with respect to its stock and tracking stock received in exchange for other stock in the issuing corporation would be treated as the receipt of property
by the shareholders. Under this proposal, the Secretary
of Treasury would have authority to treat tracking
stock as nonstock (debt, a notional principal contract,
etc.) or as stock of another entity as appropriate to
prevent avoidance. No inference is intended regarding
the tax treatment of tracking stock under current law.
This proposal is effective for tracking stock issued on
or after the date of enactment.
Require consistent treatment and provide basis
allocation rules for transfers of intangibles in certain nonrecognition transactions.—No gain or loss
will be recognized if one or more persons transfer property to a controlled corporation (or partnership) solely
in exchange for stock in the corporation (or a partnership interest). Where there is a transfer of less than
‘‘all substantial rights’’ to use property, the Internal
Revenue Service’s position is that such transfer will
not qualify as a tax-free exchange. However, the Claims

Court rejected the Service’s position in E.I. Du Pont
de Nemours and Co. v. U.S., holding that any transfer
of something of value could be a ‘‘transfer’’ of ‘‘property.’’ The inconsistency between the positions has resulted in whipsaw of the government. The Administration proposes to provide that a transfer of an interest
in intangible property constituting less than all of the
substantial rights of the transferor will not fail to qualify for tax-free treatment solely because the transferor
does not transfer all rights, title and interest in an
intangible asset, and the transferor must allocate the
basis of the intangible between the retained rights and
the transferred rights based upon respective fair market values. Consistent reporting by the transferor and
the transferee would be required. This proposal is effective for transfers after the date of enactment.
Modify tax treatment of certain reorganizations
involving portfolio stock.—If a target corporation
owns stock in the acquiring corporation and wants to
combine with the acquiring corporation in a downstream reorganization, the target corporation transfers
its assets to the acquiring corporation and the shareholders of the target corporation receive stock of the
acquiring corporation in exchange for their target corporation stock. Alternatively, if the acquiring corporation owns stock in the target corporation, the target
corporation can merge upstream, transfer its assets upstream, or merge sideways into a subsidiary of the acquiring corporation with the other shareholders of target receiving acquiring corporation stock. Under current
law, all of these reorganizations qualify for tax-free
treatment. Under the proposal, where a target corporation holds less than 20 percent of the stock of an acquiring corporation and the target corporation combines
with the acquiring corporation in a reorganization in
which the acquiring corporation is the survivor, the
target corporation must recognize gain, but not loss,
as if it distributed the acquiring corporation stock that
it held immediately prior to the reorganization. Alternatively, where an acquiring corporation owns less than
20 percent of a target corporation and the target corporation combines with the acquiring corporation or a
subsidiary of the acquiring corporation, the acquiring
corporation must recognize gain, but not loss, as if it
had sold its target corporation stock immediately before
the reorganization. Nonrecognition treatment would
continue to apply to other assets transferred by the
target corporation and to the target corporation shareholders. This proposal is effective for transactions on
or after the date of enactment.
Modify definition of nonqualified preferred
stock.—Subject to certain exceptions, in otherwise taxfree transactions, the receipt of nonqualified preferred
stock is treated as money or other property and, thus,
gain may be recognized. Under current law, nonqualified preferred stock is defined as stock which is
‘‘limited and preferred as to dividends and does not
participate in corporate growth to any significant extent.’’ Taxpayers may be taking positions that are in-

3.

FEDERAL RECEIPTS

consistent with the policy of the nonqualified preferred
stock provisions (i.e., nonrecognition treatment is inappropriate where taxpayers receive relatively secure instruments in exchange for relatively risky instruments),
by including illusory participation rights or including
terms that taxpayers argue create an ‘‘unlimited’’ dividend. The proposal would clarify the definition of preferred stock to eliminate taxpayer arguments that stock
issued is nominally participating or unlimited as to
dividends. The proposal would apply to transactions
that occur after the date of first committee action.
Modify estimated tax provision for deemed asset
sales—Taxpayers can make an election to treat certain
sales of stock as sales of assets. This election may be
made up to 8 1/2 months after the stock sale. Taxpayers
may be taking the position that they do not have to
pay any estimated taxes until after the 8 1/2 month
period has expired and rely on current law as providing
that there will be no penalty for nonpayment. The proposal would clarify the estimated tax provisions to require that estimated taxes be paid based upon gain
from either the stock sale or the deemed asset sale.
The proposal would apply to transactions that occur
after the date of first committee action.
Modify treatment of transfers to creditors in divisive reorganizations.—In order to separate businesses in a tax-free spin-off, a corporation (distributing)
will not recognize gain or loss on the contribution of
property to a controlled corporation solely in exchange
for stock or securities of the controlled corporation.
Under current law, if the distributing corporation also
receives other property or money, it will not recognize
gain as long as it distributes the property or money
to its creditors in connection with the reorganization.
The amount of property or money that may be distributed to creditors without gain to the distributing corporation is unlimited. Thus, taxpayers may avoid gain
that otherwise would be recognized if liabilities are assumed by the controlled corporation that exceed the
basis of assets contributed. The proposal would limit
the amount of property or money that the distributing
corporation can distribute to creditors without gain to
the amount of basis of the assets contributed to the
controlled corporation in the reorganization. In addition, the proposal would provide that acquisitive reorganizations would no longer be subject to gain recognition
where liabilities are assumed in excess of the basis
of assets transferred. The proposal would be effective
for transactions on or after the date of enactment.
Passthroughs
Provide mandatory basis adjustments for partners that have a significant net built-in loss in
partnership property.—Currently, a partner’s share
of basis in partnership property is adjusted in the case
of a distribution of partnership property or a sale of
a partnership interest only if the partnership has a
special election in effect. The electivity of these provi-

75
sions has created numerous opportunities for abuse by
taxpayers. Accordingly, the Administration proposes
that the basis adjustment rules would be made mandatory with respect to any partner (treating related persons as one person), whose share of net built-in loss
in partnership property is equal to the greater of
$250,000 or ten percent of the partner’s total share
of partnership assets (measured by reference to fair
market value). In calculating the ten-percent threshold,
property acquired by the partnership with a principal
purpose of allowing a partner or partners to avoid the
limitation would be disregarded. The proposal would
be effective for distributions and transfers of partnership interest after the date of enactment.
Modify treatment of closely held REITs.—When
originally enacted, the real estate investment trust
(REIT) legislation was intended to provide a tax-favored
vehicle through which small investors could invest in
a professionally managed real estate portfolio. REITs
are intended to be widely held entities, and certain
requirements of the REIT rules are designed to ensure
this result. Among other requirements, in order for an
entity to qualify for REIT status, the beneficial ownership of the entity must be held by 100 or more persons.
In addition, a REIT cannot be closely held, which generally means that no more than 50 percent of the value
of the REIT’s stock can be owned by five or fewer
individuals during the last half of the taxable year.
Certain attribution rules apply in making this determination. The Administration is aware of a number
of tax avoidance transactions involving the use of closely held REITs. In order to meet the 100 or more shareholder requirement, the REIT generally issues common
stock, which is held by one shareholder, and a separate
class of non-voting preferred stock with a relatively
nominal value, which is held by 99 ‘‘friendly’’ shareholders. The closely held limitation does not disqualify
the REITs that are utilizing this ownership structure
because the majority shareholders of these REITs are
not individuals. The Administration proposes to impose
as an additional requirement for REIT qualification
that no person can own stock of a REIT possessing
50 percent or more of the total combined voting power
of all classes of voting stock or 50 percent or more
of the total value of all shares of all classes of stock.
For purposes of determining a person’s stock ownership,
rules similar to current-law rules would apply and stapled entities would be treated as one person. The proposal would be effective for entities electing REIT status for taxable years beginning on or after the date
of first committee action.
Apply regulated investment company (RIC) excise tax to undistributed profits of REITs.—As a
result of legislation passed in 1999, a REIT, like a
RIC, is only required to distribute 90 percent of its
REIT taxable income in order to maintain REIT status.
A RIC is subject to a four-percent excise tax on the
excess of the required distribution for a calendar year
over the distributed amount for such calendar year.

76
The required distribution is equal to the sum of 98
percent of the RIC’s ordinary income for the calendar
year and 98 percent of the RIC’s capital gain net income for the one-year period ending on October 31 of
such calendar year. REITs are subject to a similar rule,
except that the required distribution is equal to the
sum of 85 percent of the REIT’s ordinary income for
the calendar year and 95 percent of the REIT’s capital
gain net income for such calendar year. In order to
conform the treatment of REITs and RICs, the Administration proposes to modify the definition of required
distribution for REITs, requiring a distribution of 98
percent of ordinary and capital gain income in order
to avoid the four-percent excise tax. The proposal would
be effective for calendar years beginning after December 31, 2000.
Allow RICs a dividends paid deduction for redemptions only in cases where the redemption represents a contraction in the RIC.—Under current
law, a RIC is allowed a dividends paid deduction for
dividends paid to shareholders. If a RIC redeems a
shareholder’s stock, the RIC can generally treat a portion of the redemption payment as a dividend for purpose of computing the dividends paid deduction. In situations where the redemption represents a contraction
in the size of the RIC, this treatment ensures that
the remaining shareholders of the RIC are taxed on
no more than their pro rata share of the RIC’s income.
In situations where the redemption is accompanied by
near simultaneous investments in the RIC by other
investors, the RIC is in essentially the same position
it would be in had the redeeming shareholder sold its
shares in the RIC directly to the new investors. In
this case, it is inappropriate to give the RIC a dividends
paid deduction for the redemption. The proposal, therefore, allows a RIC to claim a dividends paid deduction
with respect to a redemption only if the redemption
represents a net contraction in the size of the RIC.
The proposal would be effective for taxable years beginning after the date of enactment.
Require Real Estate Mortgage Investment Conduits (REMICs) to be secondarily liable for the tax
liability of REMIC residual interest holders.—A
REMIC is a statutory pass-through vehicle designed
to facilitate the securitization of mortgages. A REMIC
holds mortgages and issues one or more classes of debt
instruments, called REMIC regular interests, that are
entitled to the cash flows from the underlying mortgages. A REMIC also issues a REMIC residual interest.
The holder of the REMIC residual interest must include
in income the taxable income of the REMIC. In many
cases, when it is issued the REMIC residual interest
has a negative value because the reasonably anticipated
net tax liability associated with holding the residual
is greater than the value of the cash flows on the residual. Many holders of REMIC residual interests do not
pay their tax liabilities when due. To ensure that the
tax on REMIC residuals is paid when due, the proposal
would require a REMIC to be secondarily liable for

ANALYTICAL PERSPECTIVES

the tax liability of its residual interest. Under the proposal, if the tax on the residual was not paid when
due, the REMIC would be required to pay the tax.
Similar rules would apply with respect to Financial
Asset Securitization Investment Trusts (FASITs). The
proposal would be effective for REMICs and FASITs
created after the date of enactment.
Tax Accounting
Deny change in method treatment to tax-free formations.—Generally, a taxpayer that desires to change
its method of accounting must obtain the consent of
the IRS Commissioner. In addition, in certain reorganization transactions a corporation acquiring assets
generally is required to use the method of accounting
used for those assets by the distributor or transferor
corporation. Under current law, this carryover rule does
not apply to tax-free contributions to a corporation or
to a partnership. Consequently, taxpayers who transfer
assets to a subsidiary or a partnership in such transactions may avail themselves of a new method of accounting without obtaining the consent of the IRS Commissioner. The Administration proposes to expand the
transactions to which the carryover of method of accounting rules and the regulations thereunder apply
to include tax-free contributions to corporations or partnerships, effective for transfers on or after the date
of enactment.
Deny deduction for punitive damages.—The current deductibility of most punitive damage payments
undermines the role of such damages in discouraging
and penalizing certain undesirable actions or activities.
The Administration proposes to disallow any deduction
for punitive damages paid or incurred by the taxpayer,
whether upon a judgment or in settlement of a claim.
Where the liability for punitive damages is covered by
insurance, such damages paid or incurred by the insurer would be included in the gross income of the
insured person. The insurer would be required to report
such payments to the insured person and to the IRS.
The proposal would apply to damages paid or incurred
on or after the date of enactment.
Repeal lower-of-cost-or-market inventory accounting method.—Taxpayers required to maintain
inventories are permitted to use a variety of methods
to determine the cost of their ending inventories, including the last-in, first-out (LIFO) method, the firstin, first-out (FIFO) method, and the retail method. Taxpayers not using a LIFO method may determine the
carrying values of their inventories by applying the
lower-of-cost-or-market (LCM) method or by writing
down the cost of goods that are unsalable at normal
prices or unusable in the normal way because of damage, imperfection or other similar causes (subnormal
goods method). The allowance of write-downs under the
LCM and subnormal goods methods is essentially a
one-way mark-to-market method that understates taxable income. The Administration proposes to repeal the

3.

FEDERAL RECEIPTS

LCM and subnormal goods methods effective for taxable
years beginning after the date of enactment.
Disallow interest on debt allocable to tax-exempt
obligations.—No income tax deduction is allowed for
interest on debt used directly or indirectly to acquire
or hold investments that produce tax-exempt income.
The determination of whether debt is used to acquire
or hold tax-exempt investments differs depending on
the holder of the instrument. For banks and a limited
class of other financial institutions, debt generally is
treated as financing all of the taxpayer’s assets proportionately. Securities dealers are not included in the definition of ‘‘financial institution,’’ and under a special
rule are subject to a disallowance of a much smaller
portion of their interest deduction. For other financial
intermediaries, such as finance companies, that are also
not included in the narrow definition of ‘‘financial institutions,’’ deductions are disallowed only when indebtedness is incurred or continued for the purpose of purchasing or carrying tax-exempt investments. These taxpayers are therefore able to reduce their tax liabilities
inappropriately through the double Federal tax benefits
of interest expense deductions and tax-exempt interest
income, notwithstanding that they operate similarly to
banks. Effective for taxable years beginning after the
date of enactment, with respect to obligations acquired
on or after the date of first committee action, the Administration proposes that all financial intermediaries,
other than insurance companies (which are subject to
a separate regime), be treated the same as banks are
treated under current law with regard to deductions
for interest on debt used directly or indirectly to acquire
or hold tax-exempt obligations.
Require capitalization of mutual fund commissions.—An expenditure that results in significant future benefits generally must be capitalized in order to
match the expenditure with the revenues of the taxable
period to which it is properly attributable. Under current securities law, a distributor of mutual fund shares
may be compensated by the fund over a period of years
or by the investors on redemption with respect to ‘‘Class
B’’ shares it distributes. However, the distributor typically will pay an up-front commission to a broker to
sell Class B shares to an investor. In order to more
accurately match the income and expenses of mutual
fund distributors, the Administration proposes that
commissions paid to a broker by a distributor would
be capitalized and recovered over six years (the period
investors would have to hold shares without incurring
a fee on redemption). The proposal would be effective
for commissions paid or incurred in taxable years ending after the date of enactment. No inference is intended with respect to the treatment of distributor’s
commissions under current law.
Cost Recovery
Provide consistent amortization periods for intangibles.—Under current law, start-up and organiza-

77
tional expenditures are amortized at the election of the
taxpayer over a period of not less than five years. Current law requires certain acquired intangible assets
(goodwill, trademarks, franchises, patents, etc.) to be
amortized over 15 years. The Administration believes
that, to encourage the formation of new businesses,
a fixed amount of start-up and organizational expenditures should be currently deductible. Thus, the proposal
would allow a taxpayer to elect to deduct up to $5,000
each of start-up or organizational expenditures. However, for each taxpayer, the $5,000 amount is reduced
(but not below zero) by the amount by which the cumulative cost of start-up or organizational expenditures
exceeds $50,000. Start-up and organizational expenditures not currently deductible would be amortized over
a 15-year period consistent with the amortization period
for acquired intangible assets. The proposal generally
would be effective for start-up and organizational expenditures incurred in taxable years beginning on or
after the date of enactment.
Clarify recovery period of utility grading costs.
—A taxpayer is allowed as a depreciation deduction
a reasonable allowance for the exhaustion, wear and
tear, and obsolescence of property that is used in a
trade or business or held for the production of income.
For most tangible property placed in service after 1986,
the amount of the depreciation deduction is determined
under the modified accelerated cost recovery system
(MACRS) using a statutorily prescribed depreciation
method, recovery period, and placed in service convention. The recovery period may be determined by reference to the statutory recovery period or to the list
of class lives provided by the Treasury Department.
Electric and gas utility clearing and grading costs incurred to extend distribution lines and pipelines have
not been assigned a class life. By default, such assets
have a seven-year recovery period under MACRS. The
Administration believes that applying the default rule
to electric and gas utility clearing and grading costs
is inappropriate. For example, the electric utility transmission and distribution lines and the gas utility trunk
pipelines benefitted by the clearing and grading costs
have MACRS recovery periods of 20 years and 15 years,
respectively. The proposal would assign depreciable
electric and gas utility clearing and grading costs incurred to locate transmission and distribution lines and
pipelines to the class life assigned to the benefitted
assets, giving these costs a recovery period of 20 years
and 15 years, respectively. The proposal would be effective for electric and gas utility clearing and grading
costs incurred on or after the date of enactment.
Apply rules generally applicable to acquisitions
of intangible assets to acquisitions of professional
sports franchises.—In general, the purchase price allocated to most intangible assets (including franchise
rights) acquired in connection with the acquisition of
a trade or business must be capitalized and amortized
over a 15-year period. These rules were enacted in 1993
to minimize disputes regarding the proper treatment

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ANALYTICAL PERSPECTIVES

of acquired intangible assets. Special rules apply to intangible assets acquired in connection with a professional sports franchise. The 15-year amortization rules
do not apply and special allocation rules apply to the
purchase price. In order to provide consistent treatment
among different trades or businesses and to minimize
disputes regarding intangible assets acquired in connection with a professional sports franchise, the Administration proposes to repeal the special rules applicable
to professional sports franchise acquisitions and apply
the rules generally applicable to most intangible assets.
The proposal would be effective for acquisitions after
the date of enactment.
Insurance
Require recapture of policyholder surplus accounts.—Between 1959 and 1984, stock life insurance
companies deferred tax on a portion of their profits.
These untaxed profits were added to a policyholders
surplus account (PSA). In 1984, Congress precluded life
insurance companies from continuing to defer tax on
future profits through PSAs. However, companies were
permitted to continue to defer tax on their existing
PSAs, and to pay tax on the previously untaxed profits
in the PSAs only in certain circumstances. There is
no remaining justification for allowing these companies
to continue to defer tax on profits they earned between
1959 and 1984. Most pre-1984 policies have terminated,
because pre-1984 policyholders have surrendered their
pre-1984 contracts for cash, ceased paying premiums
on those contracts, or died. The Administration proposes that companies generally would be required to
include in their gross income over five years their PSA
balances as of the beginning of the first taxable year
starting after the date of enactment.
Modify rules for capitalizing policy acquisition
costs of life insurance companies.—Under current
law, insurance companies capitalize varying percentages of their net premiums for certain types of insurance contracts, and generally amortize these amounts
over 10 years (5 years for small companies). These capitalized amounts are intended to serve as proxies for
each company’s commissions and other policy acquisition expenses. However, data reported by insurance
companies to State insurance regulators each year indicate that the insurance industry is capitalizing substantially less than its actual policy acquisition costs, which
results in a mismatch of income and deductions. The
Administration proposes that insurance companies be
required to capitalize modified percentages of their net
premiums for certain lines of business. This change
would be treated as a change in the insurance company’s method of accounting. The modified percentages
would more accurately reflect the ratio of actual policy
acquisition expenses to premiums and the typical useful
lives of the contracts. To ensure that companies never
are required to capitalize more under this proxy approach than they would capitalize under normal tax
accounting rules, companies that have low policy acqui-

sition costs generally would be permitted to capitalize
their actual policy acquisition costs.
Increase the proration percentage for property
casualty (P&C) insurance companies.—In computing their underwriting income, P&C insurance companies deduct reserves for losses and loss expenses incurred. These loss reserves are funded in part with
the company’s investment income. In 1986, Congress
reduced the reserve deductions of P&C insurance companies by 15 percent of the tax-exempt interest or the
deductible portion of certain dividends received. In
1997, Congress expanded the 15-percent proration rule
to apply to the inside buildup on certain insurance contracts. The existing 15-percent proration rule still enables P&C insurance companies to fund a substantial
portion of their deductible reserves with tax-exempt or
tax-deferred income. Other financial intermediaries,
such as life insurance companies, banks and brokerage
firms, are subject to more stringent proration rules that
substantially reduce or eliminate their ability to use
tax-exempt or tax-deferred investments to fund currently deductible reserves or to deduct interest expense.
Effective for taxable years beginning after the date of
enactment, with respect to investments acquired on or
after the date of first committee action, the Administration proposes to increase the proration percentage to
25 percent.
Modify rules that apply to sales of life insurance
contracts.—The sale of a life insurance contract insuring a person who is neither terminally nor chronically
ill results in taxable income to the seller equal to the
difference between the sales price and the seller’s basis
in the contract. Buyers generally are not required to
report information to the IRS on these transactions.
The buyer, who receives the death benefit when the
insured dies, generally is liable for tax on his profit
from the transaction under the ‘‘transfer for value’’
rules. However, the life insurance company generally
is not required to report the death benefit payment.
Moreover, the rule that the buyer’s profits are taxable
can be circumvented. The proposal would modify the
transfer for value rules so they could no longer be circumvented. The proposal also would modify the reporting rules to require the buyer of a life insurance contract with a large death benefit to report information
on the sale to the IRS, to the issuer of the life insurance
contract, and to the seller of the life insurance contract.
In addition, the proposal would modify the reporting
rules to require that payment of death benefits under
such previously-sold contracts be reported to the IRS
and to the payee. The proposal would be effective for
sales of life insurance contracts and payments of death
benefits after the date of enactment.
Modify rules that apply to tax-exempt property
casualty insurance companies.—Under current law,
an insurance company with up to $350,000 of premium
income is tax-exempt, regardless of the amount of investment income it has. Another provision allows cer-

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79

FEDERAL RECEIPTS

tain small insurance companies to elect to be taxed
only on their net investment income. Premiums of companies in the same controlled group are combined for
purposes of determining whether an entity is eligible
for tax exemption. An excise tax is imposed on premiums paid to foreign companies with respect to policies insuring U.S. risks. Current law allows foreign insurance companies to elect to be taxed as domestic companies if they meet certain requirements. These rules
have been used by U.S. persons to shift assets into
tax-free or tax-preferred affiliated insurance companies,
which often are located in tax havens and issue ‘‘insurance’’ that is generated directly or indirectly by the
U.S. person. The proposal would modify current law,
beginning the first taxable year after date of enactment,
so that all items of gross income of all affiliated companies would be aggregated in determining whether an
insurance company qualifies for tax-exempt status.
Also, tax-exempt status would not be available to foreign insurance companies beginning the first taxable
year after the date of enactment. Conforming amendments would be made to the current-law election to
be taxed on investment income. The proposal also
would modify current law so that the election to be
taxed as a U.S. corporation would not be available to
a foreign company formed after the date of first Committee action, and would not be available beginning
in the second year after the date of enactment for any
other foreign company that would otherwise qualify for
a tax exemption under current law.
Exempt Organizations
Subject investment income of trade associations
to tax.—Trade associations described in section
501(c)(6) are generally exempt from Federal income tax,
but are subject to tax on their unrelated business income. To eliminate the current-law bias in favor of
trade association members’ making and deducting advance payments to fund future collective activities of
the trade association, the proposal would subject trade
associations to unrelated business income tax on their
net investment income in excess of $10,000 for any
taxable year. As under current-law rules for certain
other tax-exempt organizations, investment income
would not be subject to tax under the proposal to the
extent that it is set aside for a specified charitable
purpose. In addition, any gain from the sale of property
used directly in the performance of the trade association’s exempt function would not be subject to tax under
the proposal to the extent that the sale proceeds are
used to purchase replacement exempt-function property.
The proposal would be effective for taxable years beginning after December 31, 2000.
Impose penalty for failure to file an annual information return.—To encourage voluntary compliance and assist the IRS in its enforcement efforts, the
proposal would impose a penalty on split-interest trusts
(such as charitable remainder trusts, charitable lead
trusts, and pooled income funds) that fail to file an

annual information return on Form 5227. Form 5227
contains information regarding the trust’s financial activities and whether the trust is subject to certain excise taxes. Under the proposal, any failure to file Form
5227 would be subject to a penalty of $20 per day
(up to a maximum of $10,000 per return) or, in the
case of any trust with income in excess of $250,000,
$100 per day (up to a maximum of $50,000 per return).
In addition, any trustee who knowingly fails to file
Form 5227, unless such failure is not willful and is
due to reasonable cause, would be jointly and severally
liable for the amount of the penalty. The proposal
would be effective for any return the due date for which
is after the date of enactment.
Estate and Gift
Restore phaseout of unified credit for large estates.—Prior to TRA97, the benefit of both the estate
tax graduated rate brackets below fifty-five percent and
the unified credit were phased out by imposing a fivepercent surtax on estates with a value above $10 million. When TRA97 increased the unified credit amount,
the phase out of the unified credit was inadvertently
omitted. The Administration proposes to restore the
surtax in order to phase out the benefits of the unified
credit as well as the graduated estate tax brackets.
The proposal would be effective for decedents dying
after the date of enactment.
Require consistent valuation for estate and income tax purposes.—The basis of property acquired
from a decedent generally is its fair market value on
the date of death. Property included in the gross estate
of a decedent is valued also at its fair market value
on the date of death. Recipients of lifetime gifts generally take a carryover basis in the property received.
The Administration proposes to impose a duty of consistency on heirs receiving property from a decedent,
requiring such heirs to use the value as reported on
the estate tax return as the basis for the property for
income tax purposes. Estates would be required to notify heirs (and the IRS) of such values. In addition,
donors making lifetime gifts would be required to notify
the recipients of such gifts (and the IRS) of the donor’s
basis in the property at the time of the gift, as well
as any gift tax paid with respect to the gift. This proposal would be effective for gifts made after, and decedents dying after, the date of enactment.
Require basis allocation for part sale, part gift
transactions.—In a part gift, part sale transaction,
the donee/purchaser takes a basis equal to the greater
of the amount paid by the donee or the donor’s adjusted
basis at the time of the transfer. The donor/seller uses
adjusted cost basis in computing the gain or loss on
the sale portion of the transaction. The Administration
proposes to rationalize basis allocation in a part gift,
part sale transaction by requiring the basis of the property to be allocated ratably between the gift portion
and the sale portion based on the fair market value

80
of the property on the date of transfer and the consideration paid. This proposal would be effective for transactions entered into on or after the date of enactment.
Conform treatment of surviving spouses in community property States.—If joint property is owned
by spouses in a non-community property state, a surviving spouse receives a stepped-up basis only in the
half of the property owned by the deceased spouse.
In contrast, when a spouse dies owning community
property, the surviving spouse is entitled to a steppedup basis not only in the half of the property owned
by the deceased spouse, but also in the half of the
property already owned by the surviving spouse prior
to the decedent’s death. The Administration proposes
to eliminate the stepped-up basis in the part of the
community property owned by the surviving spouse
prior to the deceased spouse’s death. The half of the
community property owned by the deceased spouse
would continue to be entitled to a stepped-up basis
upon death. This treatment will be consistent with the
treatment of joint property owned by spouses in a noncommunity property State. This proposal would be effective for decedents dying after the date of enactment.
Include qualified terminable interest property
(QTIP) trust assets in surviving spouse’s estate.—
A marital deduction is allowed for qualified terminable
interest property (QTIP) passing to a qualifying trust
for a spouse either by gift or by bequest. The value
of the recipient spouse’s estate includes the value of
any such property in which the decedent had a qualifying income interest for life and a deduction was allowed under the gift or estate tax. In some cases, taxpayers have attempted to whipsaw the government by
claiming the deduction in the first estate and then arguing against inclusion in the second estate due to
some technical flaw in the QTIP election. The Administration proposes that, if a deduction is allowed under
the QTIP provisions, inclusion is required in the beneficiary spouse’s estate. The proposal would be effective
for decedents dying after the date of enactment.
Eliminate non-business valuation discounts.—
Under current law, taxpayers are claiming large discounts on the valuation of gifts and bequests of interests in entities holding marketable assets. Because
these discounts are inappropriate, the Administration
proposes to eliminate valuation discounts except as they
apply to active businesses. Interests in entities generally would be required to be valued for gift and estate
tax purposes at a proportional share of the net asset
value of the entity to the extent that the entity holds
non-business assets. The proposal would be effective
for gifts made after, and decedents dying after, the
date of enactment.
Eliminate gift tax exemption for personal residence trusts.—Current law excepts transfers of personal residences in trust from the special valuation
rules applicable when a grantor retains an interest in

ANALYTICAL PERSPECTIVES

a trust. The Administration proposes to repeal this personal residence trust exception. Thereafter, if a residence is to be used to fund a grantor retained interest
trust, the trust would be required to pay out the required annuity or unitrust amount or else the grantor’s
retained interest would be valued at zero for gift tax
purposes. This proposal would be effective for transfers
in trust after the date of enactment.
Modify requirements for annual exclusion for
gifts.—Currently, annual gifts of present interests of
up to $10,000 (in 2000) per donor per donee are excepted from the gift tax. The decision in Crummey v.
Commissioner held that a transfer in trust is a transfer
of a present interest if the beneficiary has a right to
withdraw the property from the trust for a limited period of time. Two recent cases expanded on the
Crummey rule by holding that the annual exclusion
is available, even where the person holding the withdrawal power is not a primary beneficiary of the trust.
The Administration proposes to modify the annual exclusion rule as it applies to gifts and trusts so that
a transfer to a trust would qualify only if: (1) during
the life of the individual who is the beneficiary of the
trust, no portion of the corpus or income of the trust
may be distributed to or for the benefit of any person
other than the beneficiary, and (2) the trust does not
terminate before the beneficiary dies, the assets of the
trust will be includible in the gross estate of the beneficiary. A withdrawal right would not be sufficient to
create a present interest. This proposal would be effective for gifts completed after December 31, 2000. A
grandfather rule would allow continued use of
Crummey powers in existing irrevocable trusts, but
only to the extent that the Crummey powers are held
by primary noncontingent beneficiaries.
Pensions
Increase elective withholding rate for nonperiodic distributions from deferred compensation
plans. —The Administration proposes increasing the
current 10-percent elective withholding rate for nonperiodic distributions (such as certain lump sums) from
pensions, IRAs and annuities to 15 percent, which more
closely approximates the taxpayer’s income tax liability
for the distribution effective for distributions after 2001.
The withholding would not apply to eligible rollover
distributions.
Increase excise tax for excess IRA contributions.—Excess IRA contributions are currently subject
to an annual 6-percent tax rate. With high investment
returns, this annual 6-percent rate may be insufficient
to discourage contributions in excess of the current limits for IRAs. The Administration proposes increasing
from 6 percent to 10 percent the excise tax on excess
contributions to IRAs for taxable years after the year
the excess contribution is made. Thus, the 6-percent
rate would continue to apply for the year of the excess
contribution and the higher annual rate would only

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FEDERAL RECEIPTS

apply if the excess amounts are not withdrawn from
the IRA. This increase would be effective for taxable
years beginning after 2000.
Limit pre-funding of welfare benefits for 10 or
more employer plans.—Current law generally limits
the ability of employers to claim a deduction for
amounts used to prefund welfare benefits. An exception
is provided for certain arrangements where 10 or more
employers participate because it is believed that such
relationships involve risk-sharing similar to insurance
which will effectively eliminate any incentive for participating employers to prefund benefits . However, as
a practical matter, it has proven difficult to enforce
the risk-sharing requirements in the context of certain
arrangements. The Administration proposes limiting
the 10 or more employer plan funding exception to medical, disability, and group-term life insurance benefits
because these benefits do not present the same risk
of prefunding abuse. Thus, effective for contributions
paid after the date of first committee action, the existing deduction rules of the Internal Revenue Code would
apply to prevent an employer who contributes to a 10
or more employer plan from claiming a current deduction for supplemental unemployment benefits, severance pay or life insurance (other than group-term life
insurance) benefits to be paid in future years.
Subject signing bonuses to employment taxes.—
Bonuses paid to individuals for signing a first contract
of employment are ordinary income in the year received. The Administration proposes to clarify that
these amounts are treated as wages for purposes of
income tax withholding and FICA taxes effective after
date of enactment. No inference is intended with respect to the application of prior law withholding rules
to signing bonuses.
Clarify
employment
tax
treatment
of
choreworkers.—Choreworkers, individuals paid by
State agencies to provide domestic services for disabled
and elderly individuals, often provide services for more
than one disabled or elderly individual. The Administration’s proposal would clarify that State agencies, and
not the disabled or elderly individual receiving the services, are responsible for withholding and employment
taxes for choreworkers effective for wages paid after
2000. For this purpose, all wages paid by the State
agency to a choreworker are treated as paid by a single
employer.
Prohibit IRAs from investing in foreign sales
corporations.—Foreign sales corporations (FSCs) are
foreign corporations whose income is partially subject
to US tax. IRAs were never intended to be able to
invest in FSCs. The proposal would prohibit an IRA
from investing in a FSC effective after the date of first
committee action.

Compliance
Tighten the substantial understatement penalty
for large corporations.—Currently taxpayers may be
penalized for erroneous, but non-negligent, return positions if the amount of the understatement is ‘‘substantial’’ and the taxpayer did not disclose the position in
a statement with the return. ‘‘Substantial’’ is defined
as 10 percent of the taxpayer’s total current tax liability, but this can be a very large amount. This has
led some large corporations to take aggressive reporting
positions where huge amounts of potential tax liability
are at stake—in effect playing the audit lottery—without any downside risk of penalties if they are caught,
because the potential tax still would not exceed 10 percent of the company’s total tax liability. To discourage
such aggressive tax planning, the Administration proposes that any deficiency greater than $10 million be
considered ‘‘substantial’’ for purposes of the substantial
understatement penalty, whether or not it exceeds 10
percent of the taxpayer’s liability. The proposal, which
would be effective for taxable years beginning after the
date of enactment, would affect only taxpayers that
have tax liabilities greater than or equal to $100 million.
Require withholding on certain gambling
winnings.—Proceeds of most wagers with odds of less
than 300 to 1 are exempt from withholding, as are
all bingo and keno winnings. The Administration proposes to impose withholding on proceeds of bingo or
keno in excess of $5,000 at a rate of 28 percent, regardless of the odds of the wager, effective for payments
made after the start of the first calendar quarter that
is at least 30 days after the date of enactment.
Require information reporting for private separate accounts.—Direct investments generally result in
taxable income each year of dividends and interest, plus
taxable gain or loss for changes in the value of the
securities in the year that such securities are sold. In
contrast, investments held through insurance contracts—called separate accounts—generally give rise to
tax-free or tax-deferred income unless the policyholder
has too much control over the contract’s investments.
Insurance companies sometimes create private separate
accounts through which only one or a small group of
policyholders may invest their funds. These policyholders generally exercise investor control, and thus
are liable for income tax each year on the investment
income earned. However, the IRS has no efficient way
to identify which insurance contracts’ funds are invested through private separate accounts. The Administration proposal would require insurance companies to
report each insurance contract with funds invested
through private separate accounts, and the policyholder
taxpayer identification number and earnings for such
contract. The proposal would be effective for taxable
years beginning after the date of enactment.

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ANALYTICAL PERSPECTIVES

Increase penalties for failure to file correct information returns.—Any person who fails to file required information returns in a timely manner or incorrectly reports such information is subject to penalties.
For taxpayers filing large volumes of information returns or reporting significant payments, existing penalties ($15 per return, not to exceed $75,000 if corrected
within 30 days; $30 per return, not to exceed $150,000
if corrected by August 1; and $50 per return, not to
exceed $250,000 if not corrected at all) may not be
sufficient to encourage timely and accurate reporting.
The Administration proposes to increase the general
penalty amount, subject to the overall dollar limitations, to the greater of $50 per return or five percent
of the total amount required to be reported. The increased penalty would not apply if the aggregate
amount actually reported by the taxpayer on all returns
filed for that calendar year was at least 97 percent
of the amount required to be reported. The increased
penalty would be effective for returns the due date for
which is more than 90 days after the date of enactment.
Miscellaneous
Modify deposit requirement for Federal Unemployment Act (FUTA).—Beginning in 2005, the Administration proposes to require an employer to pay
Federal and State unemployment taxes monthly (instead of quarterly) in a given year, if the employer’s
FUTA tax liability in the immediately preceding year
was $1,100 or more.
Reinstate Oil Spill Liability Trust Fund tax.—
Before January 1, 1995, a five-cents-per-barrel excise
tax was imposed on domestic crude oil and imported
oil and petroleum products. The tax was dedicated to
the Oil Spill Liability Trust Fund to finance the cleanup
of oil spills and was not imposed for a calendar quarter
if the unobligated balance in the Trust Fund exceeded
$1 billion at the close of the preceding quarter. The
Administration proposes to reinstate this tax for the
period after September 30, 2001 and before October
1, 2010. The tax would be suspended for a given calendar quarter if the unobligated Trust Fund balance
at the end of the preceding quarter exceeded $5 billion.
Repeal percentage depletion for non-fuel minerals mined on Federal and formerly Federal
lands.—Taxpayers are allowed to deduct a reasonable
allowance for depletion relating to certain mineral deposits. The depletion deduction for any taxable year
is calculated under either the cost depletion method
or the percentage depletion method, whichever results
in the greater allowance for depletion for the year. The
percentage depletion method is viewed as an incentive
for mineral production rather than as a normative rule
for recovering the taxpayer’s investment in the property. This incentive is excessive with respect to minerals mined on Federal and formerly Federal lands
under the 1872 mining act, in light of the minimal
costs of acquiring the mining rights ($5.00 or less per

acre). The Administration proposes to repeal percentage
depletion for non-fuel minerals mined on Federal lands
where the mining rights were originally acquired under
the 1872 law, and on private lands acquired under the
1872 law. The proposal would be effective for taxable
years beginning after the date of enactment.
Impose excise tax on purchase of structured settlements.—Current law facilitates the use of structured
personal injury settlements because recipients of annuities under these settlements are less likely than recipients of lump sum awards to consume their awards too
quickly and require public assistance. Consistent with
that policy, this favorable treatment is conditional upon
a requirement that the periodic payments cannot be
accelerated, deferred, increased or decreased by the injured person. Nonetheless, certain factoring companies
are able to purchase a portion of the annuities from
the recipients for heavily discounted lump sums. These
purchases are inconsistent with the policy underlying
favorable tax treatment of structured settlements. Accordingly, the Administration proposes to impose on
any person who purchases (or otherwise acquires for
consideration) a structured settlement payment stream,
a 40-percent excise tax on the difference between the
amount paid by the purchaser to the injured person
and the undiscounted value of the purchased payment
stream unless such purchase is pursuant to a court
order finding that the extraordinary and unanticipated
needs of the original intended recipient render such
a transaction desirable. The proposal would apply to
purchases occurring on or after the date of enactment.
No inference is intended as to the contractual validity
of the purchase or the effect of the purchase transaction
on the tax treatment of any party other than the purchaser.
Require taxpayers to include rental income of
residence in income without regard to the period
of rental.—Under current law, rental income is generally includable in income and the deductibility of expenses attributable to the rental property is subject
to certain limitations. An exception to this general
treatment applies if a dwelling is used by the taxpayer
as a residence and is rented for less than 15 days
during the taxable year. The income from such a rental
is not included in gross income and no expenses arising
from the rental are deductible. The Administration proposes to repeal this 15-day exception. The proposal
would apply to taxable years beginning after December
31, 2000.
Eliminate installment payment of heavy vehicle
use tax.—An annual tax is imposed on the use of heavy
(at least 55,000 pounds) highway vehicles. The tax year
is July 1 through June 30 and the tax return is generally due on August 31 of the year to which it relates.
A taxpayer may, however, elect to pay the tax in installments. The installment option generally permits
payment of one quarter of the tax on each of the following dates: August 31, December 31, March 31, and

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FEDERAL RECEIPTS

June 30. States are required to obtain evidence, before
issuing tags for a vehicle, that the use tax return has
been filed and any tax due with the return (generally
only the first installment) has been paid. To foster compliance, the Administration proposes to eliminate the
installment option for taxable years beginning after
June 30, 2002. Thus, heavy vehicle owners would be
required to pay the entire tax with their returns and
would be unable to obtain State tags without providing
proof of full payment.
Require recognition of gain on sale of principal
residence if acquired in a tax-free exchange within
five years of sale.—Gain of up to $250,000 ($500,000
in the case of a joint return) from the sale or exchange
of property is excluded from income if, during the fiveyear period ending on the date of the sale or exchange,
the property has been owned and used by the taxpayer
as the taxpayer’s principal residence for periods aggregating two years or more. No gain or loss is recognized
if property held for use in a trade or business or for
investment is exchanged solely for other like-kind property held for use in a trade or business or for investment. The current-law exclusion for principal residences, in combination with the tax-free like-kind exchange provision, allows planning opportunities for taxpayers who wish to liquidate real property held for
use in a trade or business or for investment. Such planning opportunities are beyond the intended scope of
the principal residence exclusion. The Administration
proposes to require recognition of gain on the sale of
property that has been owned and used by the taxpayer
as the taxpayer’s principal residence for periods aggregating two years or more if the property was acquired
in a tax-free like-kind exchange within five years of
the sale. The proposal would be effective for sales after
the date of enactment.
International
Identified Tax Havens
The Administration is concerned about the use of
tax havens. Tax havens facilitate tax avoidance and
evasion and many of them, through strict confidentiality rules, substandard regulatory regimes, and uncooperative information exchange practices, inhibit our
law enforcement capabilities. The Administration proposes several remedies to reduce the attractiveness of,
and increase access to information about activity in,
certain tax havens identified by the Secretary of the
Treasury (‘‘Identified Tax Havens’’). To identify tax havens that will be subject to these rules, the Secretary
of the Treasury will use criteria including, but not limited to, whether a jurisdiction imposes no or nominal
taxation, either generally or on specific classes of capital income, has strict confidentiality rules and practices, and has ineffective information exchange practices.
Require reporting of all payments to identified
tax havens—The proposal would provide that all pay-

ments to entities, including corporations, partnerships
and disregarded entities, branches, trusts, accounts or
individuals resident or located in Identified Tax Havens
must be reported on the taxpayer’s annual return unless: (1) information regarding the payment would be
available to the IRS upon request or otherwise, or (2)
the payment is less than $10,000. Failure to report
a covered payment would result in the imposition of
a penalty equal to 20 percent of the amount of the
payment. Special rules would apply to certain financial
services businesses that would permit reporting certain
payments on an aggregate basis. An anti-abuse rule
would require aggregation of related payments for purposes of determining whether a payment is under
$10,000. The proposal would be effective for payments
made after the date of enactment.
Impose limitations on certain tax attributes and
income flowing through Identified Tax Havens.—
Current rules deny foreign tax credits for taxes paid
to (1) countries whose governments the U.S. does not
recognize, (2) countries with respect to which the U.S.
has severed diplomatic relations, or (3) countries that
the State Department cites as supporting international
terrorism. In addition, the foreign tax credit limitation
and other rules are applied separately to income attributable to such countries. The proposal would apply
similar rules to Identified Tax Havens. In addition, the
proposal would reduce by a factor (similar to the international boycott factor) a taxpayer’s (1) otherwise allowable foreign tax credit or FSC benefit attributable to
income from an Identified Tax Haven, and (2) the income, attributable to an Identified Tax Haven, that is
otherwise eligible for deferral. This reduction of tax
benefits would be based on a fraction the numerator
of which is the sum of the taxpayer’s income and gains
from an Identified Tax Haven and the denominator of
which is the taxpayer’s total non-U.S. income and gains.
The proposal would be effective for taxable years beginning after the date of enactment.
Mark-to-Market Proposals
Modify treatment of built-in losses and other attributes trafficking.—Under current law, a taxpayer
that becomes subject to U.S. taxation may take the
position that it determines its beginning bases in its
assets under U.S. tax principles as if the taxpayer had
historically been subject to U.S. tax. Other tax attributes are computed similarly. A taxpayer may thus
‘‘import’’ built-in losses or other favorable tax attributes
incurred outside U.S. taxing jurisdiction to offset income or gain that would otherwise be subject to U.S.
tax. To prevent this ability to import ‘‘built-in’’ losses
or other favorable attributes, the proposal would eliminate tax attributes (including built-in items) and markto-market bases when an entity or an asset becomes
relevant for U.S. tax purposes. The proposal would be
effective for transactions in which assets or entities
become relevant for U.S. tax purposes on or after the
date of enactment.

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ANALYTICAL PERSPECTIVES

Simplify taxation of property that no longer produces income effectively connected with a U.S.
trade or business.—Under current law, a foreign person is subject to tax in the United States on net income
that is effectively connected with a U.S. trade or business (‘‘ECI’’). If a foreign person transfers property from
a U.S. trade or business to its foreign office, the United
States retains the right to tax all of the gain realized
from a subsequent disposition of the property if the
disposition occurs within ten years of the time the property ceased to be used in the U.S. trade or business.
The United States also retains, for ten years, the right
to tax deferred income from an asset attributable to
a U.S. trade or business. These rules are difficult to
administer and may in some cases result in the United
States taxing gain that economically accrued after the
property was removed from U.S. taxing jurisdiction.
The proposal would mark to market property (including
rights to deferred income) at the time that the property
ceases to be used in, or attributable to, a U.S. trade
or business. The proposal would be effective for property that ceases to be used in, or attributable to, a
U.S. trade or business after the date of enactment.
Prevent avoidance of tax on U.S.-accrued gains
(expatriation).—-Under current rules, persons renouncing U.S. citizenship for tax-avoidance purposes
are subject to U.S. taxation for ten years after renunciation. Although these rules were modified in 1996, they
are still easily avoided and impose significant administrative burdens on both taxpayers and the Government.
The proposal would simplify and toughen the taxation
of expatriates by repealing the current regime and imposing a one-time tax on accrued gains at the time
of expatriation. Also, if an expatriate subsequently
makes a gift or bequest to a U.S. person, the proposal
would treat the gift as gross income to the U.S. recipient, taxable at the highest marginal rate applicable
to gifts and bequests. In addition, the proposal would
amend a 1996 law (the ‘‘Reed Amendment’’), which requires the Attorney General to deny re-entry to a taxmotivated expatriate, to coordinate it with the tax proposal, and improve the enforceability of both the tax
proposal and the Reed Amendment. The proposal would
apply for individuals expatriating on or after the date
of first committee action.
Other International Provisions
Expand ECI rules to include certain foreign
source income.—-Under current rules, only certain
enumerated types of foreign source income of a nonresident (rents, royalties, interest, dividends and sales
of inventory property) can be treated as effectively connected with a U.S. trade or business (‘‘ECI’’) and thus
subject to net basis taxation. Economic equivalents of
such enumerated types of foreign source income, such
as interest equivalents (including letter of credit fees)
and dividend equivalents, cannot constitute ECI under
any circumstances. Moreover, some excluded foreign
source income can in large part be attributable to busi-

ness activities that take place in the United States.
For example, a foreign satellite corporation with an
office, satellite ground station or other fixed place of
business in the United States may earn income with
respect to the leasing of a satellite. Under current rules,
such foreign source income would not be subject to U.S.
tax as ECI even if it is attributable to the foreign
corporation’s U.S. office. The proposal would expand
the categories of foreign source income that could constitute ECI to include interest equivalents and dividend
equivalents and to include other income that is attributable to an office or other fixed place of business in
the U.S. The proposal would be effective for taxable
years beginning after date of enactment.
Limit basis step-up for imported pensions.—
Under current law, a nonresident alien individual who
anticipates receiving a distribution from a foreign pension plan may, under certain circumstances, establish
U.S. residency, receive the distribution, claim a high
basis in the plan distribution, and pay little or no U.S.
tax on the distribution. Moreover, as a result of certain
existing U.S. tax treaties, the individual may pay no
foreign tax on the distribution. The proposal would prevent individuals from utilizing internal law and U.S.
tax treaties to produce double non-taxation on foreign
pension plan distributions. The proposal would modify
the Internal Revenue Code to give an individual basis
in a foreign pension plan distribution only to the extent
the individual previously has been subject to tax (either
in the United States or the foreign jurisdiction) on the
amounts being distributed. The proposal would be effective for distributions occurring on or after the date of
enactment.
Replace sales-source rules.—If inventory is manufactured in the United States and sold abroad, Treasury
regulations provide that 50 percent of the income from
such sales is treated as earned in production activities
and 50 percent in sales activities. The income from
the production activities is sourced on the basis of the
location of assets held or used to produce the income.
The income from the sales activities (the remaining
50 percent) is sourced based on where title to the inventory transfers. If inventory is purchased in the United
States and sold abroad, 100 percent of the sales income
generally is deemed to be foreign source. These rules
generally produce more foreign source income for
United States tax purposes than is subject to foreign
tax. This generally increases the U.S. exporters’ foreign
tax credit limitation and allows U.S. exporters that operate in high-tax foreign countries to credit against
their U.S. tax liability foreign income taxes levied in
excess of the U.S. income tax rate. The proposal would
require that the allocation between production and
sales be based on actual economic activity. The proposal
would be effective for taxable years beginning after the
date of enactment.
Modify rules relating to foreign oil and gas extraction income.—To be eligible for the U.S. foreign

3.

FEDERAL RECEIPTS

tax credit, a foreign levy must be the substantial equivalent of an income tax in the U.S. sense, regardless
of the label the foreign government attaches to it.
Under regulations, a foreign levy is a tax if it is a
compulsory payment under the authority of a foreign
government to levy taxes and is not compensation for
a specific economic benefit provided by the foreign country. Taxpayers that are subject to a foreign levy and
that also receive (directly or indirectly) a specific economic benefit from the levying country are referred to
as ‘‘dual capacity’’ taxpayers and may not claim a credit
for that portion of the foreign levy paid as compensation
for the specific economic benefit received. The Administration proposes to treat as taxes payments by a dualcapacity taxpayer to a foreign country that would otherwise qualify as income taxes or ‘‘in lieu of’’ taxes, only
if there is a ‘‘generally applicable income tax’’ in that
country. For this purpose, a generally applicable income
tax is an income tax (or a series of income taxes) that
applies to trade or business income from sources in
that country, so long as the levy has substantial application both to non-dual-capacity taxpayers and to persons who are citizens or residents of that country.
Where the foreign country does generally impose an
income tax, as under present law, credits would be
allowed up to the level of taxation that would be imposed under that general tax, so long as the tax satisfies the new statutory definition of a ‘‘generally applicable income tax.’’ The proposal also would create a new
foreign tax credit basket within section 904 for foreign
oil and gas income. The proposal would be effective
for taxable years beginning after the date of enactment.
The proposal would yield to U.S. tax treaty obligations
that allow a credit for taxes paid or accrued on certain
oil or gas income.
Recapture overall foreign losses when controlled
foreign corporation (CFC) stock is disposed.—
Under the interest allocation rules of section 864(e),
the value of stock in a CFC is added to the value
of directly-owned foreign assets, and then compared to
the value of domestic assets of a corporation (or a group
of affiliated U.S. corporations) for purposes of determining how much of the corporation’s interest deductions should be allocated against foreign income and
how much against domestic income. If these deductions
against foreign income result in (or increase) an overall
foreign loss which is then applied against U.S. income,
section 904(f) recapture rules require subsequent foreign income or gain to be recharacterized as domestic.
Recapture can take place when a taxpayer disposes of
directly-owned foreign assets, for example. However,
there may be no recapture when a shareholder disposes
of stock in a CFC. The proposal would correct that
asymmetry by providing that property subject to the
recapture rules upon disposition under section 904(f)(3)
would include stock in a CFC. The proposal would be
effective on or after the date of enactment.
Modify foreign office material participation exception applicable to inventory sales attributable

85
to nonresident’s U.S. office.—In the case of a sale
of inventory property that is attributable to a nonresident’s office or other fixed place of business within
the United States, the sales income is generally U.S.
source. The income is foreign source, however, if the
inventory is sold for use, disposition, or consumption
outside the United States and the nonresident’s foreign
office or other fixed place of business materially participates in the sale. The proposal would provide that the
foreign source exception shall apply only if an income
tax equal to at least 10 percent of the income from
the sale is actually paid to a foreign country with respect to such income. The proposal thereby ensures that
the United States does not cede its jurisdiction to tax
such sales unless the income from the sale is actually
taxed by a foreign country at some minimal level. The
proposal would be effective for transactions occurring
on or after the date of enactment.
OTHER PROVISIONS THAT AFFECT RECEIPTS
Reinstate environmental tax imposed on corporate taxable income and deposited in the Hazardous Substance Superfund Trust Fund.—Under
prior law, a tax equal to 0.12 percent of alternative
minimum taxable income (with certain modifications)
in excess of $2 million was levied on all corporations
and deposited in the Hazardous Substance Superfund
Trust Fund. The Administration proposes to reinstate
this tax, which expired on December 31, 1995, for taxable years beginning after December 31, 1999 and before January 1, 2011.
Reinstate excise taxes deposited in the Hazardous Substance Superfund Trust Fund.—The excise taxes that were levied on petroleum, chemicals,
and imported substances and deposited in the Hazardous Substance Superfund Trust Fund are proposed
to be reinstated for the period after the date of enactment and before October 1, 2010. These taxes expired
on December 31, 1995.
Convert a portion of the excise taxes deposited
in the Airport and Airway Trust Fund to costbased user fees assessed for Federal Aviation Administration (FAA) services.—The excise taxes that
are levied on domestic air passenger tickets and flight
segments, international departures and arrivals, and
domestic air cargo are proposed to be reduced over time
as more efficient, cost-based user fees for air traffic
services are phased in beginning in fiscal year 2001.
The Administration proposes to phase in implementation of the new fees over two years and raise sufficient
revenue (excise taxes plus new fees) to support expected
FAA operational and capital needs in the subsequent
year.
Increase excise tax on tobacco products and levy
a youth smoking assessment on tobacco manufacturers. —Under current law, the 34-cents-per-pack excise tax on cigarettes is scheduled to increase by 5cents-per-pack effective January 1, 2002. The Adminis-

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ANALYTICAL PERSPECTIVES

tration proposes to accelerate the scheduled 5-centsper-pack increase in the excise tax on cigarettes and
to increase the tax by an additional 25-cents-per-pack
effective October 1, 2000. Tax rates on other taxable
tobacco products will increase proportionately. In addition, beginning after 2003, the Administration proposes
to levy an assessment on tobacco manufacturers if the
youth smoking rate is not reduced by 50 percent.

ground mining and 35 cents per ton for coal produced
by surface mining, or 10 percent of the value of the
coal at the mine. Amounts collected will be used to
continue abandoned coal mine reclamation. The coal
mining states and Indian Tribes have identified over
$4.2 billion in remaining restoration needs. Each year,
states, Indian Tribes and Federal agencies identify additional needs.

Recover State bank supervision and regulation
expenses (receipt effect).—The Administration proposes to require the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve to recover their
respective costs for supervision and regulation of Statechartered banks and bank holding companies. The Federal Reserve currently funds the costs of such examinations from earnings; therefore, deposits of earnings by
the Federal Reserve, which are classified as governmental receipts, will increase by the amount of the
recoveries.

Replace Harbor Maintenance Tax with the Harbor Services User Fee (receipt effect).—The Administration proposes to replace the ad valorem Harbor
Maintenance Tax with a cost-based user fee, the Harbor
Services User Fee. The user fee will finance construction and operation and maintenance of harbor activities
performed by the Army Corps of Engineers, the costs
of operating and maintaining the Saint Lawrence Seaway, and the costs of administering the fee. Through
appropriation acts, the fee will raise an average of $980
million annually through FY 2005, which is less than
would have been raised by the Harbor Maintenance
Tax before the Supreme Court decision that the ad
valorem tax on exports was unconstitutional.

Maintain Federal Reserve surplus transfer to the
Treasury.—In FY 2000, the Federal Reserve System
transferred $3.752 billion from its capital account surplus funds to the Treasury. The Administration proposes in FY 2001 that the Federal Reserve System
maintain the capital account surplus fund at the posttransfer level.
Restore premiums for the United Mine Workers
of America Combined Benefit Fund.—The Administration proposes legislation to restore the previous calculation of premiums charged to coal companies that
employed the retired miners that have been assigned
to them. By reversing the court decision of National
Coal v. Chater, this legislation will restore a premium
calculation that supports medical cost containment.
Extend abandoned mine reclamation fees.—The
abandoned mine reclamation fees, which are scheduled
to expire on September 30, 2004, are proposed to be
extended through September 30, 2014. These fees,
which are levied on coal operators, generally are the
lesser of 15 cents per ton for coal produced by under-

Revise Army Corps of Engineers regulatory program fees.—The Army Corps of Engineers has not
changed the fee structure of its regulatory program
since 1977. The Administration proposes to pursue reasonable changes that would reduce the fees paid from
many applicants and increase recovery from commercial
applicants.
Roll back Federal employee retirement contributions.—The Administration proposes to roll back to pre1999 levels the higher retirement contributions required of Federal employees by the Balanced Budget
Act of 1997. The rollback is proposed to take effect
in January 2001.
Provide government-wide buyout authority (receipt effect).—The Administration proposes to provide
government-wide buyout authority, which will lower
employee contributions to the civil service retirement
fund.

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Table 3–3. EFFECT OF PROPOSALS ON RECEIPTS
(In millions of dollars)
Estimate
2000

Provide tax relief:
Expand educational opportunities:
Provide College Opportunity tax cut ......................................................................................
Provide incentives for public school construction and modernization ..................................
Expand exclusion for employer-provided educational assistance to include graduate education ...................................................................................................................................
Eliminate 60-month limit on student loan interest deduction ................................................
Eliminate tax when forgiving student loans subject to income contingent repayment ........
Provide tax relief for participants in certain Federal education programs ...........................

2001

2002

2003

2004

2005

2001–2005

..............
..............

–395
–36

–2,009
–174

–2,323
–419

–3,103
–739

–3,262
–1,020

–11,092
–2,388

–66
..............
..............
..............

–275
–23
..............
–3

–90
–80
..............
–7

................
–87
................
–7

................
–89
................
–7

................
–93
................
–6

–365
–372
................
–30

Subtotal, expand educational opportunities .......................................................................

–66

–732

–2,360

–2,836

–3,938

–4,381

–14,247

Provide poverty relief and revitalize communities:
Increase and simplify the Earned Income Tax Credit (EITC) 1 ............................................
Increase and index low-income housing tax credit per-capita cap ......................................
Provide New Markets Tax Credit ...........................................................................................
Extend Empowerment Zone (EZ) tax incentives and authorize additional EZs ..................
Provide Better America Bonds to improve the environment .................................................
Permanently extend the expensing of brownfields remediation costs ..................................
Expand tax incentives for specialized small business investment companies (SSBICs) ....
Bridge the Digital Divide .........................................................................................................

..............
..............
..............
..............
..............
..............
–*
..............

–2,293
–6
–30
–36
–8
..............
–*
–107

–1,936
–55
–222
–167
–41
–98
–*
–272

–1,967
–168
–515
–333
–112
–152
–*
–344

–1,992
–306
–743
–452
–214
–146
–*
–289

–2,001
–448
–940
–568
–315
–140
–*
–207

–10,189
–983
–2,450
–1,556
–690
–536
–*
–1,219

Subtotal, provide poverty relief and revitalize communities .............................................

..............

–2,480

–2,791

–3,591

–4,142

–4,619

–17,623

Make health care more affordable:
Assist taxpayers with long-term care needs 2 .......................................................................
Encourage COBRA continuation coverage ............................................................................
Provide tax credit for Medicare buy-in program ....................................................................
Provide tax relief for workers with disabilities 2 .....................................................................
Provide tax relief to encourage small business health plans ...............................................
Encourage development of vaccines for targeted diseases .................................................

..............
..............
..............
..............
..............
..............

–109
..............
..............
–18
–1
..............

–1,150
–41
–5
–128
–9
..............

–1,681
–858
–105
–143
–22
................

–2,427
–1,149
–140
–158
–35
................

–3,028
–1,286
–164
–165
–38
................

–8,395
–3,334
–414
–612
–105
................

Subtotal, make health care more affordable 2 ...................................................................

..............

–128

–1,333

–2,809

–3,909

–4,681

–12,860

Strengthen families and improve work incentives:
Provide marriage penalty relief and increase standard deduction .......................................
Increase, expand, and simplify child and dependent care tax credit 2 .................................
Provide tax incentives for employer-provided child-care facilities ........................................

..............
..............
..............

–248
–121
–42

–843
–589
–88

–1,536
–922
–121

–2,130
–1,288
–140

–4,637
–1,643
–148

–9,394
–4,563
–539

Subtotal, strengthen families and improve work incentives 2 ...........................................

..............

–411

–1,520

–2,579

–3,558

–6,428

–14,496

..............

..............

–657

–2,185

–2,290

–4,034

–9,166

..............

..............

–157

–648

–1,878

–3,074

–5,757

–1
..............
..............
..............
..............

–18
–44
–25
214
–53

–35
–65
–61
137
–207

–61
–66
–108
104
–288

–92
–68
–161
66
–377

–135
–70
–236
29
–450

–341
–313
–591
550
–1,375

Promote expanded retirement savings, security, and portability:
Establish Retirement Savings Accounts ................................................................................
Provide small business tax credit for automatic contributions for non-highly compensated
employees ...........................................................................................................................
Provide tax credit for plan start up and administrative expenses; provide for payroll deduction IRAs .......................................................................................................................
Provide for the SMART plan ..................................................................................................
Enhance the 401(k) SIMPLE plan .........................................................................................
Accelerate vesting for qualified plans ....................................................................................
Other changes affecting retirement savings, security and portability ...................................
Subtotal, promote expanded retirement savings, security and portability ........................

–1

74

–1,045

–3,252

–4,800

–7,970

–16,993

Provide AMT relief for families and simplify the tax laws:
Provide adjustments for personal exemptions and the standard deduction in the individual alternative minimum tax (AMT) ...............................................................................
Simplify and increase standard deduction for dependent filers ............................................
Replace support test with residency test (limited to children) ..............................................
Provide tax credit to encourage electronic filing of individual income tax returns 2 ............
Simplify, retarget and expand expensing for small business ...............................................
Simplify the foreign tax credit limitation for dividends from 10/50 companies .....................
Other simplification .................................................................................................................

–72
–7
..............
..............
..............
–80
–1

–377
–42
–66
..............
–217
–168
–17

–544
–29
–97
–192
–206
–102
–23

–996
–33
–102
–207
–19
–46
–27

–1,312
–51
–107
–208
–86
10
–30

–1,650
–37
–112
–209
–135
27
–35

–4,879
–192
–484
–816
–663
–279
–132

Subtotal, provide AMT relief for families and simplify the tax laws 2 ...............................

–160

–887

–1,193

–1,430

–1,784

–2,151

–7,445

Encourage philanthropy:
Allow deduction for charitable contributions by non-itemizing taxpayers .............................
Simplify and reduce the excise tax on foundation investment income ................................
Increase limit on charitable donations of appreciated property ............................................

..............
..............
..............

–516
–49
–7

–1,062
–70
–47

–733
–71
–29

–765
–73
–20

–817
–75
–12

–3,893
–338
–115

88

ANALYTICAL PERSPECTIVES

Table 3–3. EFFECT OF PROPOSALS ON RECEIPTS—Continued
(In millions of dollars)
Estimate
2000

2001

2002

2003

2004

2005

2001–2005

Clarify public charity status of donor advised funds .............................................................

*

*

*

*

*

*

*

Subtotal, encourage philanthropy ......................................................................................

..............

–572

–1,179

–833

–858

–904

–4,346

Promote energy efficiency and improve the environment:
Provide tax credit for energy-efficient building equipment ....................................................
Provide tax credit for new energy-efficient homes ................................................................
Extend electric vehicle tax credit and provide tax credit for hybrid vehicles .......................
Provide 15-year depreciable life for distributed power property ...........................................
Extend and modify the tax credit for producing electricity from certain sources .................
Provide tax credit for solar energy systems ..........................................................................

..............
..............
..............
..............
..............
..............

–18
–82
..............
–1
–91
–9

–35
–150
–4
–1
–173
–19

–49
–194
–182
–2
–220
–25

–71
–134
–700
–3
–231
–34

–28
–73
–1,192
–3
–261
–45

–201
–633
–2,078
–10
–976
–132

Subtotal, promote energy efficiency and improve the environment .................................
Electricity restructuring ................................................................................................................

..............
..............

–201
3

–382
11

–672
20

–1,173
30

–1,602
41

–4,030
105

Modify international trade provisions:
Extend and modify Puerto Rico economic-activity tax credit ................................................
Extend GSP and modify other trade provisions 3 ..................................................................
Levy tariff on certain textiles/apparel produced in the CNMI 3 .............................................

..............
–10
..............

–35
–454
..............

–67
–858
169

–101
–940
169

–134
–884
169

–166
–248
169

–503
–3,384
676

Subtotal, modify international trade provisions 3 ...............................................................

–10

–489

–756

–872

–849

–245

–3,211

Miscellaneous provisions:
Make first $2,000 of severance pay exempt from income tax .............................................
Exempt Holocaust reparations from Federal income tax ......................................................

..............
–4

–43
–17

–174
–18

–180
–19

–138
–15

................
................

–535
–69

Subtotal, miscellaneous provisions ....................................................................................

–4

–60

–192

–199

–153

................

–604

Subtotal, provide tax relief 2 3 .........................................................................................
Refundable credits ...........................................................................................................

–241
..............

–5,883
–23

–12,740
–679

–19,053
–736

–25,134
–2,218

–32,940
–2,343

–95,750
–5,999

Total gross tax relief including refundable credits 3 ...................................................

–241

–5,906

–13,419

–19,789

–27,352

–35,283

–101,749

..............
1
..............
..............
12

1,872
5
15
22
20

1,392
10
47
37
19

1,357
15
67
39
19

1,351
21
88
40
19

1,374
26
104
42
18

7,346
77
321
180
95

71

328

121

65

45

26

585

..............
4
..............
..............

62
34
21
176

108
36
46
340

112
37
53
417

117
38
54
489

122
40
56
548

521
185
230
1,970

..............
–42

6
–239

11
–175

17
–157

24
–157

30
–160

88
–888

46

2,322

1,992

2,041

2,129

2,226

10,710

6
1
9
14
7
16
..............
13

63
7
73
30
18
29
2
34

21
13
74
34
22
31
5
41

4
19
71
33
21
31
8
39

5
25
70
34
19
31
10
38

5
31
70
35
18
31
11
39

98
95
358
166
98
153
36
191

28

108

158

153

149

151

719

1
17
11

41
49
53

51
66
61

53
71
64

55
77
67

57
83
54

257
346
299

Eliminate unwarranted benefits and adopt other revenue measures:
Limit benefits of corporate tax shelter transactions:
Increase disclosure of certain transactions, modify substantial understatement penalty for
corporate tax shelters, codify the economic substance doctrine, tax income from shelters involving tax-indifferent parties and impose a penalty excise tax on certain fees
received by promotors and advisors .................................................................................
Require accrual of income on forward sale of corporate stock ...........................................
Modify treatment of ESOP as S corporation shareholder ....................................................
Limit dividend treatment for payments on certain self-amortizing stock ..............................
Prevent serial liquidation of U.S. subsidiaries of foreign corporations .................................
Prevent capital gains avoidance through basis shift transactions involving foreign shareholders ................................................................................................................................
Prevent mismatching of deductions and income in transactions with related foreign persons .....................................................................................................................................
Prevent duplication or acceleration of loss through assumption of certain liabilities ..........
Amend 80/20 company rules .................................................................................................
Modify corporate-owned life insurance (COLI) rules .............................................................
Require lessors of tax-exempt-use property to include service contract options in lease
term .....................................................................................................................................
Interaction ................................................................................................................................
Subtotal, limit benefits of corporate tax shelter transactions ............................................
Other proposals:
Require banks to accrue interest on short-term obligations .................................................
Require current accrual of market discount by accrual method taxpayers ..........................
Modify and clarify certain rules relating to debt-for-debt exchanges ...................................
Modify and clarify the straddle rules ......................................................................................
Provide generalized rules for all stripping transactions ........................................................
Require ordinary treatment for certain dealers of commodities and equity options ............
Prohibit tax deferral on contributions of appreciated property to swap funds .....................
Conform control test for tax-free incorporations, distributions, and reorganizations ............
Treat receipt of tracking stock in certain distributions and exchanges as the receipt of
property ...............................................................................................................................
Require consistent treatment and provide basis allocation rules for transfers of intangibles in certain nonrecognition transactions .......................................................................
Modify tax treatment of certain reorganizations involving portfolio stock .............................
Modify definition of nonqualified preferred stock ...................................................................

3.

89

FEDERAL RECEIPTS

Table 3–3. EFFECT OF PROPOSALS ON RECEIPTS—Continued
(In millions of dollars)
Estimate
2000

Modify estimated tax provision for deemed asset sales .......................................................
Modify treatment of transfers to creditors in divisive reorganizations ..................................
Provide mandatory basis adjustments for partners that have a significant net built-in loss
in partnership property .......................................................................................................
Modify treatment of closely held REITs .................................................................................
Apply RIC excise tax to undistributed profits of REITs ........................................................
Allow RICs a dividends paid deduction for redemptions only in cases where the redemption represents a contraction in the RIC ...........................................................................
Require REMICs to be secondarily liable for the tax liability of REMIC residual interest
holders ................................................................................................................................
Deny change in method treatment to tax-free formations ....................................................
Deny deduction for punitive damages ...................................................................................
Repeal lower-of-cost-or-market inventory accounting method ..............................................
Disallow interest on debt allocable to tax-exempt obligations ..............................................
Require capitalization of mutual fund commissions ..............................................................
Provide consistent amortization periods for intangibles ........................................................
Clarify recovery period of utility grading costs ......................................................................
Apply rules generally applicable to acquisitions of tangible assets to acquisitions of professional sports franchises .................................................................................................
Require recapture of policyholder surplus accounts .............................................................
Modify rules for capitalizing policy acquisition costs of life insurance companies ..............
Increase the proration percentage for P&C insurance companies .......................................
Modify rules that apply to sales of life insurance contracts .................................................
Modify rules that apply to tax-exempt property casualty insurance companies ..................
Subject investment income of trade associations to tax .......................................................
Impose penalty for failure to file an annual information return ............................................
Restore phaseout of unified credit for large estates .............................................................
Require consistent valuation for estate and income tax purposes ......................................
Require basis allocation for part sale, part gift transactions ................................................
Conform treatment of surviving spouses in community property States ..............................
Include QTIP trust assets in surviving spouse’s estate ........................................................
Eliminate non-business valuation discounts ..........................................................................
Eliminate gift tax exemption for personal residence trusts ...................................................
Modify requirements for annual exclusion for gifts ...............................................................
Increase elective withholding rate for nonperiodic distributions from deferred compensation plans ............................................................................................................................
Increase excise tax for excess IRA contributions .................................................................
Limit pre-funding of welfare benefits for 10 or more employer plans ..................................
Subject signing bonuses to employment taxes .....................................................................
Clarify employment tax treatment of choreworkers ...............................................................
Prohibit IRAs from investing in foreign sales corporations ...................................................
Tighten the substantial understatement penalty for large corporations ................................
Require withholding on certain gambling winnings ...............................................................
Require information reporting for private separate accounts ................................................
Increase penalties for failure to file correct information returns ...........................................
Modify deposit requirement for FUTA ....................................................................................
Reinstate Oil Spill Liability Trust Fund tax 3 ..........................................................................
Repeal percentage depletion for non-fuel minerals mined on Federal and formerly Federal lands ............................................................................................................................
Impose excise tax on purchase of structured settlements ...................................................
Require taxpayers to include rental income of residence in income without regard to the
period of rental ...................................................................................................................
Eliminate installment payment of heavy vehicle use tax 3 ....................................................
Require recognition of gain on sale of principal residence if acquired in a tax-free exchange within five years of the sale .................................................................................
Limit benefits of transactions with ‘‘Identified Tax Havens’’ .................................................
Modify treatment of built-in losses and other attributes trafficking .......................................
Simplify taxation of property that no longer produces income effectively connected with a
U.S. trade or business .......................................................................................................
Prevent avoidance of tax on U.S.-accrued gains (expatriation) ...........................................
Expand ECI rules to include certain foreign source income ................................................
Limit basis step-up for imported pensions .............................................................................
Replace sales-source rules ....................................................................................................
Modify rules relating to foreign oil and gas extraction income .............................................
Recapture overall foreign losses when CFC stock is disposed ...........................................
Modify foreign office material participation exception applicable to inventory sales attributable to nonresident’s U.S. office .....................................................................................

2001

2002

2003

2004

2005

2001–2005

..............
3

314
15

90
18

–23
19

–15
20

–8
21

358
93

–41
..............
..............

50
1
..............

52
4
1

55
8
1

60
12
1

58
17
1

275
42
4

..............

99

489

457

429

405

1,879

..............
3
16
..............
4
..............
..............
12

5
59
92
459
11
23
–216
40

17
59
130
447
18
111
–220
65

29
59
137
371
24
98
34
82

42
61
144
372
30
83
259
91

55
63
151
154
35
64
445
99

148
301
654
1,803
118
379
302
377

2
..............
..............
..............
..............
..............
..............
..............
..............
1
..............
3
..............
..............
..............
..............

43
65
536
48
13
12
180
..............
33
5
2
19
..............
271
–1
..............

73
174
1,820
82
35
22
309
24
70
10
3
42
2
575
–1
20

113
285
2,191
98
39
23
325
23
78
14
4
59
2
600
................
20

141
522
2,413
115
43
24
341
22
83
18
5
75
2
636
5
22

139
782
1,328
133
48
25
358
21
106
21
5
92
2
618
14
20

509
1,828
8,288
476
178
106
1,513
90
370
68
19
287
8
2,700
17
82

..............
..............
..............
..............
..............
3
..............
..............
..............
..............
..............
..............

..............
1
92
5
48
16
26
20
5
6
..............
..............

47
12
156
3
64
29
44
1
10
15
..............
253

3
13
159
3
64
30
45
1
14
15
................
261

3
14
151
3
63
32
41
1
18
9
................
264

3
14
150
2
63
33
37
1
21
10
1,583
266

56
54
708
16
302
140
193
24
68
55
1,583
1,044

..............
6

94
7

96
5

97
2

99
................

101
–2

487
12

..............
..............

4
..............

11
378

12
27

12
30

13
32

52
467

..............
..............
1

10
36
78

13
52
136

11
40
143

11
36
151

11
35
161

56
199
669

*
3
..............
2
..............
..............
1

*
28
22
26
320
5
1

*
58
38
33
570
69
*

*
107
39
34
600
112
*

*
155
41
36
630
118
*

*
212
42
38
660
124
*

*
560
182
167
2,780
428
1

1

7

10

11

11

11

50

90

ANALYTICAL PERSPECTIVES

Table 3–3. EFFECT OF PROPOSALS ON RECEIPTS—Continued
(In millions of dollars)
Estimate
2000

Subtotal, other

proposals 3

2001

2002

2003

2004

2005

2001–2005

.................................................................................................

143

3,542

7,221

7,635

8,565

9,478

36,441

Subtotal, eliminate unwarranted benefits and adopt other revenue measures 3 ........
Net tax relief including refundable credits 3 .....................................................................

189
–52

5,864
–42

9,213
–4,206

9,676
–10,113

10,694
–16,658

11,704
–23,579

47,151
–54,598

Other provisions that affect receipts:
Reinstate environmental tax on corporate taxable income 4 .....................................................
Reinstate Superfund excise taxes 3 ............................................................................................
Convert Airport and Airway Trust Fund taxes to a cost-based user fee system 3 ..................
Increase excise tax on tobacco products and levy a youth smoking assessment on tobacco
manufacturers 3 .......................................................................................................................
Recover State bank supervision and regulation expenses (receipt effect) 3 ............................
Maintain Federal Reserve surplus transfer to the Treasury ......................................................
Restore premiums for United Mine Workers of America Combined Benefit Fund ..................
Extend abandoned mine reclamation fees 3 ..............................................................................
Replace Harbor Maintenance tax with the Harbor Services User Fee (receipt effect) 3 .........
Revise Army Corps of Engineers regulatory program fees 3 ....................................................
Roll back Federal employee retirement contributions ...............................................................
Provide Government-wide buyout authority (receipt effect) ......................................................

..............
152
..............

725
707
724

432
762
1,399

438
772
1,500

434
785
1,522

437
797
1,522

2,466
3,823
6,667

446
..............
..............
..............
..............
..............
..............
..............
..............

4,084
78
3,752
11
..............
–549
5
–427
–9

3,738
82
..............
10
..............
–602
5
–619
–18

3,532
86
................
10
................
–647
5
–160
–9

10,140
90
................
9
................
–681
5
................
................

9,700
95
................
9
218
–718
5
................
................

31,194
431
3,752
49
218
–3,197
25
–1,206
–36

Total, other provisions 3 4 ....................................................................................................

598

9,101

5,189

5,527

12,304

12,065

44,186

* $500,000 or less
1 The proposal to increase and simplify the Earned Income Tax Credit has both receipts and outlay effects. The receipts effect for the proposal is –$305 million, –$304 million, –$314 million, –$326 million and –$339 million for
fiscal years 2001–2005, respectively. The outlay effect is $2,003 million, $1,936 million, $1,967 million, $1,992 million and $2,001 million for fiscal years 2001–2005, respectively.
2 Amounts shown are the effect on receipts.
3 Net of income offsets
4 Net of deductibility for income tax purposes

3.

91

FEDERAL RECEIPTS

Table 3–4. RECEIPTS BY SOURCE
(In millions of dollars)

Source

1999
Actual

Estimate
2000

2001

2002

2003

2004

2005

Individual income taxes (federal funds):
Existing law ............................................................................................................................
879,480
951,945
Proposed Legislation (PAYGO) ........................................................................................ ..................
–359
Legislative proposal, discretionary offset ......................................................................... .................. ..................

978,249
–5,634
–205

1,005,714
–10,125
–397

1,040,248
–14,215
–424

1,086,039
–19,554
–432

1,143,081
–25,821
–432

Total individual income taxes ................................................................................................

951,586

972,410

995,192

1,025,609

1,066,053

1,116,828

Corporation income taxes:
Federal funds:
Existing law .......................................................................................................................
184,670
192,285
Proposed Legislation (PAYGO) .................................................................................... ..................
110
Legislative proposal, discretionary offset ..................................................................... .................. ..................

189,594
3,942
119

190,189
4,405
102

191,800
3,105
110

196,090
205,076
3,150 ..................
119
131

193,655

194,696

195,015

199,359

Total Federal funds corporation income taxes .....................................................................

879,480

184,670

192,395

205,207

Trust funds:
Hazardous substance superfund ......................................................................................
10 .................. .................. .................. .................. .................. ..................
Proposed Legislation (PAYGO) .................................................................................... .................. ..................
1,115
664
674
668
673
Total corporation income taxes .............................................................................................

184,680

192,395

194,770

195,360

195,689

200,027

205,880

383,559
60,909
132,268

408,583
68,180
136,515

427,322
72,573
143,695

446,421
75,805
150,290

465,244
79,003
156,694

484,401
82,259
163,258

511,676
86,890
172,612

1,515
2,629

1,639
2,621

1,674
2,661

1,697
2,699

1,719
2,736

1,740
2,773

1,762
2,803

Total employment and general retirement ............................................................................

580,880

617,538

647,925

676,912

705,396

734,431

775,743

On-budget ..........................................................................................................................
Off-budget ..........................................................................................................................

136,412
444,468

140,775
476,763

148,030
499,895

154,686
522,226

161,149
544,247

167,771
566,660

177,177
598,566

Unemployment insurance:
Deposits by States 1 .........................................................................................................
19,894
21,453
23,327
24,529
25,594
26,273
Proposed Legislation (PAYGO) .................................................................................... .................. .................. .................. .................. .................. ..................
Federal unemployment receipts 1 ....................................................................................
6,475
6,668
6,873
7,010
7,127
7,260
Proposed Legislation (PAYGO) .................................................................................... .................. .................. .................. .................. .................. ..................
Railroad unemployment receipts 1 ...................................................................................
111
67
54
97
123
124

27,411
1,297
7,405
286
102

Total unemployment insurance .............................................................................................

36,501

Social insurance and retirement receipts (trust funds):
Employment and general retirement:
Old age and survivors insurance (Off-budget) .................................................................
Disability insurance (Off-budget) .......................................................................................
Hospital insurance .............................................................................................................
Railroad retirement:
Social Security equivalent account ..............................................................................
Rail pension and supplemental annuity .......................................................................

26,480

28,188

30,254

31,636

32,844

33,657

Other retirement:
Federal employees’ retirement—employee share ............................................................
4,400
4,221
Proposed Legislation (non-PAYGO) ............................................................................. .................. ..................
Proposed Legislation (PAYGO) .................................................................................... .................. ..................
Non-Federal employees retirement 2 ...............................................................................
73
74

4,269
–9
–427
68

4,194
–18
–619
63

3,547
3,197
3,028
–9 .................. ..................
–160 .................. ..................
51
46
43

Total other retirement ............................................................................................................

4,473

4,295

3,901

3,620

3,429

3,243

3,071

Total social insurance and retirement receipts ...................................................................

611,833

650,021

682,080

712,168

741,669

771,331

815,315

On-budget ..............................................................................................................................
Off-budget ..............................................................................................................................

167,365
444,468

173,258
476,763

182,185
499,895

189,942
522,226

197,422
544,247

204,671
566,660

216,749
598,566

Excise taxes:
Federal funds:
Alcohol taxes .....................................................................................................................
7,386
Proposed Legislation (PAYGO) .................................................................................... ..................
Tobacco taxes ...................................................................................................................
5,400
Proposed Legislation (PAYGO) .................................................................................... ..................
Transportation fuels tax ....................................................................................................
849
Telephone and teletype services ......................................................................................
5,185
Ozone depleting chemicals and products ........................................................................
105
Other Federal fund excise taxes ......................................................................................
368

7,267
–32
6,742
594
787
5,500
73
2,174

7,150
7,158
7,120
7,091
7,080
32 .................. .................. .................. ..................
7,158
7,844
8,013
7,938
7,869
5,446
4,985
4,709
4,018
3,756
808
793
811
817
836
5,821
6,142
6,471
6,833
7,231
73
22
9 .................. ..................
2,200
2,114
1,997
1,987
2,030

92

ANALYTICAL PERSPECTIVES

Table 3–4. RECEIPTS BY SOURCE—Continued
(In millions of dollars)

Source

1999
Actual

Proposed Legislation (PAYGO) .................................................................................... ..................

Estimate
2000

2001

2002

2003

2004

2005

38

–74

–65

–69

–73

–77

28,614

28,993

29,061

28,611

28,725

Total Federal fund excise taxes ...........................................................................................

19,293

23,143

Trust funds:
Highway .............................................................................................................................
Proposed Legislation (PAYGO) ....................................................................................
Airport and airway .............................................................................................................
Legislative proposal, discretionary offset .....................................................................
Aquatic resources ..............................................................................................................
Black lung disability insurance .........................................................................................
Inland waterway ................................................................................................................
Hazardous substance superfund ......................................................................................
Proposed Legislation (PAYGO) ....................................................................................
Oil spill liability ..................................................................................................................
Proposed Legislation (PAYGO) ....................................................................................
Vaccine injury compensation ............................................................................................
Leaking underground storage tank ...................................................................................

39,299
..................
10,391
..................
374
596
104
11
..................
..................
..................
130
216

34,311
..................
9,222
..................
336
577
104
..................
204
173
..................
131
183

Total trust funds excise taxes ...............................................................................................

51,121

45,241

48,062

50,792

51,713

53,141

54,687

Total excise taxes ....................................................................................................................

70,414

68,384

76,676

79,785

80,774

81,752

83,412

Estate and gift taxes:
Federal funds .........................................................................................................................
27,782
Proposed Legislation (PAYGO) ........................................................................................ ..................

30,482
4

31,975
329

34,172
721

35,494
777

37,831
846

36,151
878

Total estate and gift taxes ......................................................................................................

30,486

32,304

34,893

36,271

38,677

37,029

Customs duties:
Federal funds .........................................................................................................................
17,727
20,149
Proposed Legislation (PAYGO) ........................................................................................ ..................
–13
Trust funds .............................................................................................................................
609
739
Proposed Legislation (PAYGO) ........................................................................................ .................. ..................
Legislative proposal, discretionary offset ......................................................................... .................. ..................

21,405
–569
797
–30
–732

23,430
–880
870
–30
–803

25,262
–990
932
–30
–863

26,554
–917
978
–30
–908

27,921
–71
1,030
–30
–958

Total customs duties ...............................................................................................................

18,336

20,871

22,587

24,311

25,677

27,892

MISCELLANEOUS RECEIPTS: 3
Miscellaneous taxes ..............................................................................................................
Proposed youth smoking assessment (PAYGO) .................................................................
United Mine Workers of America combined benefit fund ....................................................
Proposed Legislation (PAYGO) ........................................................................................
Deposit of earnings, Federal Reserve System ....................................................................
Legislative proposal, discretionary offset .........................................................................
Defense cooperation ..............................................................................................................
Fees for permits and regulatory and judicial services .........................................................
Proposed Legislation (PAYGO) ........................................................................................
Legislative proposal, discretionary offset .........................................................................
Fines, penalties, and forfeitures ............................................................................................
Gifts and contributions ..........................................................................................................
Refunds and recoveries ........................................................................................................

101
..................
148
..................
25,917
..................
..................
6,572
..................
..................
2,738
186
–733

119
121
124
126
129
.................. .................. .................. ..................
7,379
142
138
132
127
122
..................
11
10
10
9
32,452
25,664
30,196
31,296
32,489
..................
3,856
109
115
120
6
6
6
6
6
7,509
7,965
8,726
9,549
10,378
..................
–2
–7
–7 ..................
..................
7
7
7
7
2,188
2,157
1,966
1,977
1,977
281
188
156
150
148
–192
–191
–190
–190
–190

132
7,280
118
9
33,662
126
6
10,972
290
7
1,979
149
–190

Total miscellaneous receipts .................................................................................................

34,929

42,505

39,920

41,235

43,166

52,574

54,540

Total budget receipts ..............................................................................................................
On-budget ..............................................................................................................................
Off-budget ..............................................................................................................................

1,827,454
1,382,986
444,468

1,956,252
1,479,489
476,763

2,019,031
1,519,136
499,895

2,081,220
1,558,994
522,226

2,147,489
1,603,242
544,247

2,236,091
1,669,431
566,660

2,340,896
1,742,330
598,566

27,782

20,875

35,148
35,597
36,229
36,870
37,622
..................
383
32
35
37
9,645
10,173
10,630
11,333
12,115
965
1,866
1,999
2,030
2,030
341
376
380
395
401
591
606
619
628
636
107
109
111
114
116
.................. .................. .................. .................. ..................
942
1,016
1,031
1,046
1,063
.................. .................. .................. .................. ..................
..................
338
348
351
355
134
137
139
141
110
189
191
195
198
202

1 Deposits by States cover the benefit part of the program. Federal unemployment receipts cover administrative costs at both the Federal and State levels. Railroad unemployment receipts cover both the benefits and administrative costs of the program for the railroads.
2 Represents employer and employee contributions to the civil service retirement and disability fund for covered employees of Government-sponsored, privately owned enterprises and the District of Columbia municipal government.
3 Includes both Federal and trust funds.

4. USER FEES AND OTHER COLLECTIONS
In addition to collecting taxes and other receipts by
the exercise of its sovereign powers, which is discussed
in the previous chapter, the Federal Government collects income from the public from market-oriented activities. Examples of these collections include the sale
of postage stamps and electricity, fees for admittance
to national parks, premiums for deposit insurance, and
rents and royalties for the right to extract oil from
the Outer Continental shelf.
Depending on the laws that authorize the collections,
they can be credited directly to expenditure accounts
as ‘‘offsetting collections,’’ where they are usually available for expenditure without further action by Congress, or they are credited to receipt accounts as ‘‘offsetting receipts,’’ which may be appropriated to expenditure accounts through action by the Congress. The
budget refers to them as offsetting collections and offsetting receipts, because they are subtracted from gross
outlays rather than added to taxes on the receipts side
of the budget. The purpose of this treatment is to
produce budget totals for receipts, outlays, and budget
authority in terms of the amount of resources allocated
governmentally, through collective political choice, rather than through the market. 1
Offsetting collections and receipts include most user
fees, which are discussed below, as well as some
amounts that are not user fees. Table 4–1 summarizes
these transactions. For 2001, total offsetting collections
and receipts from the public are estimated to be $214.8
billion, and total user fees are estimated to be $148.6
billion.

The following section discusses user fees and the Administration’s user fee proposals. The subsequent section displays more information on offsetting collections
and receipts. The offsetting collections and receipts by
agency are also displayed in Table 20–1, ‘‘Outlays to
the Public, Net and Gross,’’ which appears in Chapter
20 of this volume.
TABLE 4–1. GROSS OUTLAYS, USER FEES, OTHER OFFSETTING
COLLECTIONS AND RECEIPTS FROM THE PUBLIC, AND NET OUTLAYS
(In billions of dollars)

Estimate

Actual
1999

2000

2001

1,910.3

2,001.6

2,049.8

137.0
70.3

137.6
74.4

147.2
67.6

Subtotal, offsetting collections
and receipts from the public ...

207.3

212.0

214.8

Net outlays ................................................

1,703.0

1,789.6

1,835.0

Gross outlays ............................................
Offsetting collections and receipts from
the public:
User fees 1 ........................................
Other .................................................

1 Total

user fees are shown below. They include user fees that are classified on the receipts side of the budget in addition to the amounts shown
on this line. For additional details of total user fees, see Table 4–2. ‘‘Total
User Fee Collections.’’
Total user fees:
Offsetting collections and receipts from the
public ..........................................................
Receipts ..........................................................

137.0
1.0

137.6
1.1

147.2
1.5

Total user fees ....................................................

138.0

138.7

148.6

USER FEES
I.

Introduction and Background

The Federal Government may charge user fees to
those who benefit directly from a particular activity
or those subject to regulation. According to the definition of user fees used in this chapter, Table 4–2 shows
that user fees were $138.0 billion in 1999, and are
estimated to increase to $138.7 billion in 2000 and to
$148.6 billion in 2001, growing to an estimated $176.4
billion in 2005, including the user fee proposals proposed in this budget, which are shown in Table 4–3.
This table shows that the Administration is proposing
to increase user fees by an estimated $3.8 billion in
2001, growing to an estimated $7.7 billion in 2005.

1 Showing collections from business-type transactions as offsets on the spending side of
the budget follows the concept recommended by the 1967 Report of the President’s Commis-

Definition. The term ‘‘user fee’’ as defined here is
fees, charges, and assessments levied on a class directly
benefiting from, or subject to regulation by, a government program or activity, and to be utilized solely to
support the program or activity. In addition, the payers
of the fee must be limited to those benefiting from,
or subject to regulation by, the program or activity,
and may not include the general public or a broad
segment of the public. The user fee must be authorized
for use only to fund the specified programs or activities
for which it is charged, including directly associated
agency functions, not for unrelated programs or activities and not for the broad purposes of the Government
or an agency.

sion on Budget Concepts. The concept is discussed in Chapter 24: ‘‘Budget System and
Concepts and Glossary’’ in this volume.

93

94

ANALYTICAL PERSPECTIVES

Why User Fees?
•

•
•
•
•
•
•

The term ‘‘user fee’’ refers to Government charges to those who use a Government good or service or are subject to Government regulation. For example:
—Park entrance fees charged to visitors to national parks
—Meat, poultry, and egg inspection fees
—Tennessee Valley Authority proceeds from power sales
—Proceeds from the lease of federally-owned buildings and facilities
—Flood insurance premiums
—Sales of commemorative coins
User fees are earmarked to fund part or all of the cost of providing the service or regulation by crediting them to a program account instead of to the general fund of the Treasury.
User fees are different from general revenue, because they are not collected from the general public or broad segments of
the public (e.g., income taxes or customs duties) and they are not used for the general purposes of government (e.g., national defense).
Users are more willing to support and pay fees when they are dedicated to maintaining or improving the quality of the
programs that affect them directly.
Government program managers may be more diligent about collecting and spending fees when funding for their programs
depends on fees, instead of appropriations of general taxpayer money.
Administration policy is to shift to user fee funding wherever appropriate. However, essential government services will
continue to be supported by general fund appropriations from the Treasury as necessary.
The Administration’s user fee proposals generally require authorizing legislation to authorize the fees first and appropriations action before the fees can actually be collected and spent. This is done to preserve the traditional roles of the authorizing and appropriations committees in Congress and to conform to the ‘‘scoring’’ conventions of the Budget Enforcement Act.

• Examples of business-type or market-oriented user
fees include fees for the sale of postal services
(the sale of stamps), electricity (e.g., sales by the
Tennessee Valley Authority), payments for Medicare voluntary supplemental medical insurance,
life insurance premiums for veterans, recreation
fees for parks, NASA fees for shuttle services, the
sale of weather maps and related information by
the Department of Commerce, the sale of commemorative coins, and fees for the sale of books.
• Examples of regulatory and licensing user fees include fees for regulating the nuclear energy industry, bankruptcy filing fees, immigration fees, food
inspection fees, passport fees, and patent and
trademark fees.
User fees do not include all offsetting collections and
receipts, such as the interest and repayments received
from credit programs; proceeds from the sale of loans
and other financial investments; interest, dividends,
and other earnings; cost sharing contributions; the sale
of timber, minerals, oil, commodities, and other natural
resources; proceeds from asset sales (property, plant,
and equipment); Outer Continental Shelf receipts; or
spectrum auction proceeds. Neither do they include earmarked taxes (such as taxes paid to social insurance
programs or excise taxes), or customs duties, fines, penalties, and forfeitures.

poses, such as establishing policy for charging prices
to the public for goods and services regardless of whether the proceeds are earmarked.
Alternative definitions could, for example:
• be narrower than the one used here, by excluding
regulatory fees and analyzing them as a separate
category.
• be broader than the one used here, by:
—eliminating the requirement that fees be earmarked. The definition would then include fees
that go to the general fund in addition to those
that are earmarked to finance the related activity.
—including the sale of resources as well as goods
and services, such as natural resources (e.g.,
timber, oil, or minerals) and property, plant, and
equipment.
—interpreting more broadly whether a program
has private beneficiaries, or whether the proceeds are earmarked to benefit directly those
paying the fee. A broader interpretation might
include beneficiary- or liability-based excise
taxes. 3

Alternative definitions. The definition used in this
chapter is useful because it identifies goods, services,
and regulations financed by earmarked collections and
receipts. 2 Other definitions may be used for other pur-

can be under the jurisdiction of other committees. See the Congressional Record, January
3, 1991, p. H31, item 8.
3 Beneficiary- and liability-based taxes are terms taken from the Congressional Budget
Office, The Growth of Federal User Charges, August 1993, and updated in October 1995.
Examples of beneficiary-based taxes include taxes on gasoline, which finance grants to
States for highway construction, or taxes on airline tickets, which finance air traffic control
activities and airports. An example of a liability-based tax is the excise tax that helps
fund the hazardous substance superfund in the Environmental Protection Agency. This
tax is paid by industry groups to finance environmental cleanup activities related to the
industry activity but not necessarily caused by the payer of the fee.

2 The definition used here is similar to one the House of Representatives uses as a
guide for purposes of committee jurisdiction. The definition helps differentiate between
taxes, which are under the jurisdiction of the Ways and Means Committee, and fees, which

What is the purpose of user fees? The purpose
of user fees is to improve the efficiency and equity
of certain Government activities, and to reduce the bur-

4. USER FEES AND OTHER COLLECTIONS

den on the taxpayer to finance activities whose benefits
accrue to a relatively limited number of people.
• User fees that are set to cover the costs of production of goods and services can provide efficiency
in the allocation of resources within the economy.
They allocate goods and services to those who
value them the most, and they signal to the government how much of the goods or services it
should provide. Prices in private, competitive markets serve the same purposes.
• User fees for goods and services that do not have
special social benefits improve equity, or fairness,
by requiring that those who benefit from an activity are the same people who pay for it. The public
often perceives user fees as fair because those who
benefit from the good or service pay for it in whole
or in part, and those who do not benefit do not
pay.
When should the Government charge a fee? Discussions of whether to finance spending with a tax or
a fee often focus on whether the benefits of the activity
are to the public in general or to a limited group of
people. As a general rule, if the benefits accrue to the
public in general, then the program should be financed
by taxes paid by the public; in contrast, if the benefits
accrue to a limited number of private individuals or
groups, then the program should be financed by fees
paid by the private beneficiaries. For Federal programs
where the benefits are entirely public or entirely private, applying this rule is relatively easy. For example,
according to this rule, the benefits from national defense accrue to the public in general and should be
(and are) financed by taxes. In contrast, the benefits
of electricity sold by the Tennessee Valley Authority
accrue exclusively to those using the electricity, and
should be (and are) financed by user fees.
In many cases, however, an activity has benefits that
accrue to both public and to private groups, and it
may be difficult to identify how much of the benefits
accrue to each. Because of this, it can be difficult to
know how much of the program should be financed
by taxes and how much by fees. For example, the benefits from recreation areas are mixed. Fees for visitors
to these areas are appropriate because the visitors benefit directly from their visit, but the public in general
also benefits because these areas protect the Nation’s
natural and historical heritage now and for posterity.
As a further complication, where a fee may be appropriate to finance all or part of an activity, some consideration must be given to the ease of administering the
fee.
What should be the amount of the fee? For programs that have private beneficiaries, the amount of
the fee should depend on the costs of producing the
goods or services and the portion of the program that
is for private benefits. If the benefit is primarily private, and any public benefits are incidental, the Admin-

95
istration supports fees that cover the full cost to the
Government, including both direct and indirect costs. 4
The Administration is working to put cost accounting
systems in place across the Government that would
make the calculation of full cost more feasible. The
difficulties in measuring full cost are associated in part
with allocating to an activity the full costs of capital,
retirement benefits, and insurance, as well as other
Federal costs that may appear in other parts of the
budget. Guidance in the Statement of Federal Financial
Accounting Standards No. 4, Managerial Cost Accounting Concepts and Standards for the Federal Government
(July 31, 1995), should underlie cost accounting in the
Federal Government.
Classification of user fees in the budget. As
shown in Table 4–1, most user fees are classified as
offsets to outlays on the spending side of the budget,
but a few are classified on the receipts side of the
budget. An estimated $1.5 billion in 2001 are classified
this way and are included in the totals described in
Chapter 3. ‘‘Federal Receipts.’’ They are classified as
receipts because they are regulatory fees collected by
the Federal Government by the exercise of its sovereign
powers.
The remaining user fees, an estimated $147.2 billion
in 2001, are classified as offsetting collections and receipts on the spending side of the budget. Some of these
are collected by the Federal Government by the exercise
of its sovereign powers and would normally appear on
the receipts side of the budget, but are required by
law to be classified as offsetting collections or receipts.
• An estimated $107.0 billion of user fees for 2001
are credited directly to expenditure accounts, and
are generally available for expenditure when they
are collected, without further action by the Congress.
• An estimated $40.1 billion for 2001 are deposited
in offsetting receipt accounts, and generally are
not available to be spent unless appropriated by
the Congress each year.
As a further classification, the following Tables 4–2
and 4–3 identify the fees as discretionary or mandatory.
These classifications are terms from the Budget Enforcement Act of 1990 as amended and are used frequently in the analysis of the budget. ‘‘Discretionary’’
in this chapter refers to fees generally controlled
through annual appropriations acts and under the jurisdiction of the appropriations committees in the Congress. These fees offset discretionary spending under
the discretionary caps. ‘‘Mandatory’’ refers to fees controlled by permanent laws and under the jurisdiction
of the authorizing committees. These fees are subject
to rules of paygo, whereby changes in law affecting
mandatory programs and receipts cannot result in a
net cost. Mandatory spending is sometimes referred to
as direct spending.
4 Policies for setting user charges are promulgated in OMB Circular No. A–25: ‘‘User
Charges’’ (July 8, 1993). These policies are required regardless of whether or not the proceeds
are earmarked to finance the related activity.

96

ANALYTICAL PERSPECTIVES

These and other classifications are discussed further
in this volume in Chapter 24, ‘‘Budget System and Concepts and Glossary.’’
II.

Current User Fees

As shown in Table 4–2, ‘‘Total User Fee Collections,’’
total user fee collections (including those proposed in
this budget) are estimated to be $148.6 billion in 2001,
increasing to $176.4 billion in 2005. User fee collections
by the Postal Service, Medicare premiums, and foreign
military sales are the largest and are estimated to be
more than two-thirds of all existing user fee collections
in 2001.
User fee collections are used to offset outlays in both
the discretionary and mandatory parts of the budget.
Discretionary user fee collections are estimated to be
$16.6 billion in 2001. The Administration is proposing
to make collections from Federal Aviation Administration (FAA) cost-based user fees, the new harbor services
fee, and proposed fees for the Federal Deposit Insurance Corporation available to offset discretionary
spending.
III. User Fee Proposals
The Administration is proposing the new or increased
user fees shown in Table 4–3: ‘‘User Fee Proposals.’’
These proposals would increase user fee collections by
an estimated $3.8 billion in 2001, increasing to $7.7
billion in 2005.
A. User Fee Proposals to Offset Discretionary
Spending
1.

Proposals for Discretionary User Fees

a. Offsetting collections deposited in appropriation accounts
Department of Agriculture
Food Safety and Inspection Service meat, poultry, and
egg inspection fees.—This budget proposes a new user
fee for the Food Safety and Inspection Service. Under
the proposed fee the meat, poultry and egg industries
would be required to reimburse the Federal government
for the cost of the salaries and benefits and other direct
costs for all in-plant inspection. The proposal would
transfer the cost of Federal inspection services to the
industries that directly benefit, and would ensure that
sufficient resources are available to provide the level
of in-plant inspection necessary to meet the demands
of industry. The cost of the user fee would amount
to less than one cent per pound of meat inspected.

Animal and Plant Health Inspection Service
(APHIS).—The budget proposes to establish fees to
cover the cost of providing animal welfare inspections
to recipients of APHIS services such as animal research
centers, humane societies, and kennels. Fees would also
be established to cover the cost of issuing biotechnology
certificates to firms that manufacture products derived
through biotechnological innovation.
Grain Inspection, Packers and Stockyards Administration (GIPSA) licensing fees.—The budget proposes to
charge the grain industry for GIPSA’s costs to review
and maintain standards (such as grain quality and classification) that are used by the industry. In addition,
an annual licensing fee is proposed to fund GIPSA activities that ensure the integrity of the livestock, meat
and poultry market and marketplace, such as fostering
open competition, and protecting consumers and businesses from unfair practices.
Department of Commerce
National Oceanic and Atmospheric Administration
(NOAA), navigational assistance fees.—The Administration proposes to levy a fee on U.S. and foreign commercial cargo carriers to recover the cost of navigational
assistance services, such as nautical charting, provided
by NOAA.
Fisheries management fees.—The budget proposes to
levy a fee to recover a portion of the costs of providing
fisheries management and enforcement services.
Department of Health and Human Services
Food and Drug Administration (FDA) fees.—The
budget seeks $19 million in new fees to finance FDA
activities for the review of new medical devices and
food additives, and for food export certifications. These
fees will be used to augment current funding for these
activities.
Health Care Financing Administration (HCFA).—
These proposals would establish fees for a variety of
activities associated with the Medicare program, including:
Managed care application and renewal fees.—The
Administration proposes to charge managed care organizations a fee to cover the cost of reviewing initial
applications and renewing annual contracts with Medicare. Proceeds from this fee would be used to offset
funding for Federal administrative expenses related to
managed care organization applications and renewals.
Provider initial certification fees.—The Administration proposes to levy a fee on providers (e.g., home
health agencies and skilled nursing facilities) who wish
to enter the Medicare program. The fee would vary
by type of provider. Proceeds from this fee would be
used to offset survey and certification funding.

97

4. USER FEES AND OTHER COLLECTIONS

Table 4–2. TOTAL USER FEE COLLECTIONS
(In millions of dollars)
Estimates

1999
actual

2000

2001

2002

2003

2004

2005

..............
553
172
248

..............
675
188
255

965
..............
215
281

1,866
..............
217
286

1,999
..............
220
287

2,030
..............
223
293

2,030
..............
225
298

973

1,118

1,461

2,369

2,506

2,546

2,553

167
1,021
7,345
508

186
1,123
6,438
631

735
1,304
6,366
655

735
1,304
6,347
645

737
1,319
6,347
643

741
1,352
6,347
641

746
1,382
6,347
619

316
235
343
365
83
1,906
577
848
173
97
85
102
442
756
591
144

338
260
314
411
104
1,935
603
956
191
111
119
111
447
176
634
150

657
250
590
451
464
1,854
496
875
200
165
114
121
454
..............
650
199

657
250
590
451
888
1,854
496
875
200
165
114
121
454
..............
650
187

664
252
596
456
897
1,876
501
875
202
167
114
122
459
..............
658
188

681
260
611
468
921
1,923
515
875
207
171
114
125
471
..............
674
191

696
264
625
478
942
1,965
525
875
212
175
114
128
481
..............
689
195

16,104

15,238

16,600

16,983

17,073

17,288

17,458

883
257
2,889

1,111
276
2,489

1,586
275
2,697

1,557
275
3,162

1,633
275
3,234

1,697
275
3,195

1,727
275
3,140

21,570
610
1,300
460
1,813
1,696
40
1,416
11,624
6,093
860
350
61,957
6,818
244

21,744
575
1,498
824
1,871
1,651
41
1,545
10,560
6,620
374
308
63,998
6,590
287

23,169
586
1,483
1,083
1,922
1,724
1,007
1,756
10,760
7,140
590
326
67,421
6,718
315

25,631
604
1,488
1,013
2,001
1,720
1,004
1,868
10,890
7,677
664
300
70,000
6,826
326

28,214
621
1,516
1,087
2,074
1,686
1,002
1,986
10,920
8,286
1,014
321
72,750
7,078
313

30,854
629
1,524
1,160
2,150
1,643
1,038
2,121
11,020
8,909
1,548
347
74,100
7,419
329

33,694
637
1,531
1,233
2,229
1,606
1,056
2,266
11,150
9,539
2,336
388
75,650
7,565
339

Subtotal, mandatory offsetting collections and receipts ...............................................................

120,880

122,362

130,558

137,006

144,010

149,958

156,361

Subtotal, offsetting collections and receipts ..........................................................................................

136,984

137,600

147,158

153,989

161,083

167,246

173,819

TOTAL, User fees ..................................................................................................................................

137,957

138,718

148,619

156,358

163,589

169,792

176,372

Receipts
Proposed FAA user fees to replace excise taxes 1 ...............................................................................
Harbor maintenance and inland waterway fees 2 ...................................................................................
Agricultural quarantine inspection fees ...................................................................................................
Other governmental receipt user fees ....................................................................................................
Subtotal, governmental receipts ........................................................................................................
Offsetting Collections and Receipts from the Public
Discretionary
Department of Agriculture: Food safety inspection and other fees ..................................................
Department of Commerce: Patent and trademark, fees for weather services, and other fees ......
Department of Defense: Commissary and other fees .......................................................................
Department of Energy: Federal Energy Regulation Commission and other fees ............................
Department of Health and Human Services: Food and Drug Administration, Health Care Financing Administration, and other fees .................................................................................................
Department of the Interior: Bureau of Land Management and other fees .......................................
Department of Justice: Antitrust and other fees ................................................................................
Department of State: Visa, passport, and other fees ........................................................................
Department of Transportation: Coast Guard and other fees ............................................................
Department of the Treasury: Sale of commemorative coins and other fees ...................................
Department of Veterans Affairs: Medical care and other fees .........................................................
National Aeronautics and Space Administration: Reimbursement for the use of NASA services ..
Federal Communications Commission: Regulatory and other fees ..................................................
Federal Trade Commission: Regulatory and other fees ...................................................................
Legislative Branch: Library of Congress and copyright fees .............................................................
National Credit Union Administration: Stock subscription fees .........................................................
Nuclear Regulatory Commission: Regulatory fees ............................................................................
Panama Canal Commission: Fees for use of the canal ...................................................................
Securities and Exchange Commission: Regulatory fees ...................................................................
All other agencies, discretionary user fees ........................................................................................
Subtotal, discretionary offsetting collections and receipts ...........................................................
Mandatory
Department of Agriculture: Federal crop insurance and other fees ..................................................
Department of Defense: Commissary surcharge and other fees ......................................................
Department of Energy: Proceeds from the sale of energy and other fees: .....................................
Department of Health and Human Services: Medicare Part B insurance premiums, and other
fees ..................................................................................................................................................
Department of the Interior: Recreation and other fees .....................................................................
Department of Justice: Immigration and other fees ..........................................................................
Department of Labor: Insurance premiums to guarantee private pensions and other fees ............
Department of the Treasury: Customs, bank regulation, and other fees .........................................
Department of Veterans Affairs: Veterans life insurance and other fees .........................................
Corps of Engineers: Harbor services and other fees ........................................................................
Federal Emergency Management Agency: Flood insurance fees ....................................................
International Assistance Programs: Foreign military sales ................................................................
Office of Personnel Management: Federal employee health and life insurance fees .....................
Federal Deposit Insurance Corporation: Deposit insurance fees ......................................................
National Credit Union Administration: Credit union share insurance and other fees ......................
Postal Service: Fees for postal services (e. g., sale of stamps) ......................................................
Tennessee Valley Authority: Proceeds from the sale of energy .......................................................
All other agencies, mandatory user fees ...........................................................................................

1 Gross

revenue increase from proposed fees. Current aviation excise taxes, which are not user fees, will gradually be converted to cost-based user fees. While considered governmental receipts, the following proceeds from the
fees, net of income tax offsets, would be made available to offset discretionary spending:

FAA collections available for spending .................................................................................................................................................................................................
2 The

1999

2000

............

............

2001
724

2002

2003

2004

2005

1,399

1,499

1,522

1,522

Budget proposes to convert proceeds to offsetting collections for the Corps of Engineers. While the fee collection will be mandatory, proceeds from the fee will be made available to offset discretionary spending.

2000–05
6,667

98

ANALYTICAL PERSPECTIVES

Table 4–3. USER FEE PROPOSALS
(estimated collections in millions of dollars)
2001

2002

2003

2004

2005

2001–2005

A. USER FEE PROPOSALS TO OFFSET DISCRETIONARY SPENDING
1. Proposals for Discretionary User Fees

a. Offsetting collections deposited in appropriation accounts
Department of Agriculture
Food Safety Inspection Service fees ..........................................................................................................................
Animal and Plant Health Inspection Service ..............................................................................................................
Grain Inspection, Packers and Stockyards Administration .........................................................................................

534
11
23

641
11
23

641
11
23

641
11
23

641
11
23

3,098
55
115

Department of Commerce
National Oceanic and Atmospheric Administration, Navigational assistance fees ....................................................
Fisheries management fees ........................................................................................................................................

14
20

14
20

14
20

14
20

14
20

70
100

Department of Health and Human Services
Food and Drug Administration fees ............................................................................................................................
Health Care Financing Administration fee proposals:
Managed care application and renewal fees .........................................................................................................
Provider initial certification fees ..............................................................................................................................
Provider recertification fees .....................................................................................................................................
Paper claims submission fees ................................................................................................................................
Duplicate and unprocessable claims fees ..............................................................................................................
Increase Medicare+Choice fees ..............................................................................................................................
Nursing home criminal abuse registry fee ..............................................................................................................

19

19

19

19

19

95

21
13
50
83
53
131
4

21
13
50
83
53
130
4

21
13
50
83
53
129
4

21
13
50
83
53
128
4

21
13
50
83
53
128
4

105
65
250
415
265
646
20

Department of the Interior
User fees on Outer Continental Shelf lands ..............................................................................................................

10

10

10

10

10

50

Department of Justice
Hart-Scott Rodino pre-merger filing fees ....................................................................................................................

38

38

38

38

38

190

Department of Transportation
Coast Guard, navigational services fees ....................................................................................................................
Federal Railroad Administration, rail safety inspection fees ......................................................................................
Hazardous materials transportation safety fees .........................................................................................................
Surface Transportation Board fees .............................................................................................................................

212
103
19
17

636
103
19
17

644
103
19
17

660
103
19
17

674
103
19
17

2,826
515
95
85

Department of the Treasury
Customs, automation modernization fee .....................................................................................................................

210

210

210

210

210

1,050

Federal Trade Commission
Hart-Scott Rodino pre-merger filing fees ....................................................................................................................

38

38

38

38

38

190

National Transportation Safety Board
Commercial accident investigation fees ......................................................................................................................

10

10

10

10

10

50

Department of Justice
Immigration premium processing fee ..........................................................................................................................
Increase inspection user fees .....................................................................................................................................

17
167

17
167

17
167

17
167

17
167

85
835

Department of Transportation
Pipeline safety fees .....................................................................................................................................................

11

12

12

12

12

59

Environmental Protection Agency
Pesticide registration fees ...........................................................................................................................................
Pre-manufacture notice (PMN) fees ............................................................................................................................

16
4

............
8

............
8

............
8

............
8

16
36

Nuclear Regulatory Commission
Extend Nuclear Regulatory Commission user fees ....................................................................................................

295

295

295

295

295

1,475

Subtotal, proposals for discretionary user fees ......................................................................................................

2,143

2,662

2,669

2,684

2,698

12,856

92

96

102

106

111

507

417

361

313

315

296

1,702

Department of Transportation
Federal Aviation Administration cost-based user fees (governmental receipt) 2 .......................................................

965

1,866

1,999

2,030

2,030

8,890

Subtotal, proposals for mandatory user fees to offset discretionary spending .....................................................

1,474

2,323

2,414

2,451

2,437

11,099

Subtotal, user fee proposals to offset discretionary spending ..............................................................................

3,617

4,985

5,083

5,135

5,135

23,955

b. Offsetting collections deposited in receipt accounts

2. Proposals for Mandatory User Fees to Offset Discretionary Spending

a. Offsetting collections deposited in appropriation accounts
Federal Deposit Insurance Corporation
State bank exam fees .................................................................................................................................................

b. Offsetting collections deposited in receipt accounts
Corps of Engineers
Harbor services user fee, replaces harbor maintenance tax 1 ...................................................................................

c. Receipts

99

4. USER FEES AND OTHER COLLECTIONS

Table 4–3. USER FEE PROPOSALS—Continued
(estimated collections in millions of dollars)
2001

2002

2003

2004

2005

69

............

............

............

............

69

138

122

122

122

122

626

104

107

109

112

114

546

............
6

28
7

36
13

48
13

50
13

162
52

–180

226

392

418

590

1,446

............
3
............

73
3
8

74
4
26

76
4
26

74
5
26

297
19
86

............
............

............
............

............
............

424
1,036

465
1,059

889
2,095

Subtotal user fee proposals to offset mandatory spending ....................................................................................

140

574

776

2,279

2,518

6,287

Total user fee proposals ................................................................................................................................................

3,757

5,559

5,859

7,414

7,653

30,242

B. USER FEE PROPOSALS TO OFFSET MANDATORY SPENDING
a. Offsetting collections deposited in appropriation accounts
Department of Agriculture
Federal crop insurance ................................................................................................................................................
Department of Labor
Implement alien labor certification fees ......................................................................................................................
Federal Emergency Management Agency
Flood map license fee for flood map modernization ..................................................................................................

b. Offsetting collections deposited in receipt accounts
Department of Agriculture
Recreation and entrance fees ......................................................................................................................................
Concession, land use, right of way, and filming permits ............................................................................................
Department of Health and Human Services
Medicare premiums ......................................................................................................................................................
Department of the Interior
Recreation and entrance fees .....................................................................................................................................
Filming and special use permits fees .........................................................................................................................
Hardrock mining production fees ................................................................................................................................
Department of the Treasury
Customs, extend conveyance/passenger fee .............................................................................................................
Customs, extend merchandise processing fee ...........................................................................................................

2001–2005

1 The

amounts shown here are the amounts available to offset discretionary spending. This is the total amount from the proposed harbor services user fee, less three-fourths (to account for the income tax offset) of the tax revenues that would be lost from repealing the existing harbor maintenance tax.
2 Gross revenue increase from proposed fees. Current aviation excise taxes, which are not user fees, will gradually be converted to cost-based user fees. While considered governmental receipts, the
following proceeds from the fees, net of income tax offsets, would be made to offset discretionary spending:
2001
FAA collections available for spending ...............................................................................................................................................................................................

Provider recertification fees.—The Administration proposes to levy a fee on providers who are recertified for the Medicare program. By statute, skilled
nursing facilities must be surveyed every year, home
health agencies every three years, and other providers
about once every ten years. The fee would be charged
every year to spread the costs of the certification program over time. Proceeds from this fee would be used
to offset survey and certification funding.
Paper claims submission fees.—The Administration proposes to charge providers $1.00 for every paper
claim submitted for payment because of the additional
cost of processing paper rather than electronic claims.
Rural providers and very small providers who may not
be able to purchase the necessary hardware to comply
with electronic claims transmission would be exempt
from the fee. Proceeds from the fee would be used to
offset Contractor funding related to claims processing.
Duplicate and unprocessable claims fees.—The
Administration proposes to charge Medicare providers
$1.00 for each duplicate and unprocessable claim submitted for payment to the Health Care Financing Administration. Proceeds from the fee would be used to
offset Contractor funding related to claims processing.
Increase in the Medicare+Choice fees.—The Administration proposes to increase the fee on
Medicare+Choice plans by approximately $131 million

724

2002

2003

2004

2005

1,399

1,499

1,522

1,522

2001–05
6,667

in 2001. The fee was authorized at $100 million in
the Balanced Budget Act of 1997 but reduced to approximately $19 million (for 2001) by the Balanced
Budget Refinement Act of 1999. This increase would
be used to maintain the current level of effort in providing information to Medicare beneficiaries regarding
the Medicare+Choice program.
Nursing home criminal abuse registry fee.—The
Administration proposes to charge nursing facilities a
fee to query a nursing home criminal abuse registry.
Proceeds from the fee would be used to fund the operation and maintenance of the registry.
Department of the Interior
User fees on Outer Continental Shelf lands.—The Administration proposes new and modifications to existing
user fees on the Minerals Management Service program
that supports energy and mineral exploration, development and production on the Outer Continental lands
such as increasing rental rates, implementing a bidding
fee, and charging for violation re-inspections. Collections would be available upon appropriation to fund
royalty and offshore minerals management activities.
Department of Justice
Hart-Scott-Rodino pre-merger filing fees.—The Administration proposes to restructure the Hart- Scott-

100
Rodino fee, which is charged to acquiring firms in mergers. Fees are collected by the Federal Trade Commission (FTC) and divided evenly between the FTC and
the Antitrust Division in the Department of Justice.
Department of Transportation
Coast Guard, navigational services fees.—The Administration proposes to levy a fee on U.S. and foreign
commercial cargo and cruise vessels for the use of Coast
Guard navigational assistance services. Navigational
assistance services include the placement and maintenance of buoys and other short-range aids-to-navigation, radio navigation, ice breaking, and vessel traffic
services. Fishing and recreational vessels would be exempt.
Federal Railroad Administration, rail safety inspection fees.—This proposed fee would offset the costs of
the Federal Railroad Administration’s safety inspection
program. An estimated $103 million in fees would be
collected from railroad carriers based upon a calculation
of their rail usage.
Hazardous materials transportation safety fees.—Beginning late in 2001, hazardous materials transportation safety activities previously financed by general
fund appropriations to the Research and Special Programs Administration are proposed to be financed instead by an increase in hazardous materials registration fees. Authorizing legislation will be proposed to
increase the fees paid by shippers and carriers of hazardous materials by an estimated $19 million in 2001
to fund these safety activities.
Surface Transportation Board fees.—The Administration proposes to create a fee mechanism to completely
offset the expenses of the Surface Transportation Board
(STB), the successor to the Interstate Commerce Commission (ICC). The fees would be collected from those
who benefit from the continuation of the ICC functions
transferred to the STB, i.e. railroads and shippers.
Department of the Treasury
Customs, automation modernization fee.—The Administration proposes to establish a fee to offset the costs
of modernizing automated commercial operations of the
U. S. Customs Service. Fees would finance the development of the Automated Commercial Environment
(ACE), which is critical to maintain the ability of the
U. S. Customs Service to process the increasing volume
of trade. Subsequent to the budget, authorization legislation will be transmitted to allow the Secretary to
establish the fee.
Federal Trade Commission (FTC)
Hart-Scott-Rodino pre-merger filing fees.—The Administration proposes to restructure the Hart- ScottRodino fee, which is charged to acquiring firms in mergers. Fees are collected by the Federal FTC and divided
evenly between the FTC and the Antitrust Division
in the Department of Justice.
National Transportation Safety Board (NTSB)

ANALYTICAL PERSPECTIVES

Commercial accident investigation fees.—To offset a
portion of the growing cost of commercial accident investigations by the NTSB, a new aviation accident recovery and investigation fee is proposed. This fee, which
would be paid by commercial air, motor, ocean, rail,
and pipeline carriers based on an approximation of risk,
would collect an estimated $10 million in 2001.
b. Offsetting collections deposited in receipt accounts
Department of Justice
Immigration premium processing fee.—This is a voluntary fee paid in addition to existing user fees charged
for business visa processing that will guarantee expedited processing and direct liaison with the Immigration and Naturalization Service (INS). The INS estimates that $17 million of the projected $80 million
in annual receipts will be used for expedited processing.
The remainder will be earmarked for fraud investigations ($8 million), reduction of backlog, and infrastructure improvements ($55 million).
Increase inspection user fees.—Congress established
the user fee account to cover the full cost of air and
sea passenger inspections. The Administration is proposing to increase the per passenger inspection fee from
$6 to $8 and eliminate an exemption from the inspection fee for cruise ship passengers. The increase will
be used solely to defray inspection expenses.
Department of Transportation
Pipeline safety fees.—The Administration proposes to
increase offsetting collections from the pipeline safety
fund by an estimated $11 million in user fees in 2001.
These fees would fund grants to States to inspect intrastate pipelines, damage prevention grants to implement
best practices of damage prevention, and additional research, training and risk assessment.
Environmental Protection Agency
Pesticide registration fees.—The budget proposes to
reinstate pesticide registration fees that are statutorily
suspended through 2001. These fees would be used to
offset the cost of reviewing applications for pesticide
registrations, amendments to registrations, and experimental use permits.
Pre-manufacturing notification (PMN) fees.—The Administration proposes to eliminate the statutory cap
on PMN fees and to increase fees charged to chemical
producers to recover the cost of reviewing notifications
of new chemicals prior to production.
Nuclear Regulatory Commission (NRC)
Extend Nuclear Regulatory Commission user fees.—
Under current law, the NRC must recover approximately 100 percent of its budget (less appropriations
from the Nuclear Waste Fund) from licensing, inspection, and annual fees charged to its applicants and
licensees through 2000. Unless the law is extended,
this requirement will revert to 33 percent of NRC’s
budget. Because of fairness and equity concerns related
to charging NRC licensees for expenses that do not

101

4. USER FEES AND OTHER COLLECTIONS

provide a direct benefit to them, the Administration
proposes to extend the requirement to collect fees at
approximately 98 percent of the NRC’s budget in 2001,
96 percent in 2002, 94 percent in 2003, 92 percent
in 2004, and 90 percent in 2005.
2. Proposals for Mandatory User Fees to Offset
Discretionary Spending
a. Offsetting collections deposited in appropriation accounts
Federal Deposit Insurance Corporation (FDIC)
Recovery of supervision and regulation expenses.—The
Administration proposes to require the FDIC and the
Federal Reserve to recover their respective costs for
supervision and regulation of state-chartered banks and
bank holding companies. Currently, supervision and
regulation expenses are funded from deposit insurance
premiums (FDIC) and interest earnings on Treasury
securities (Federal Reserve). The FDIC’s collections
would finance its state bank supervision and regulation
operations.
b. Offsetting collections deposited in receipt accounts
Corps of Engineers
Harbor services fee.—The Administration proposes to
replace collection of the ad valorem harbor maintenance
tax with a cost-based user fee, the harbor services user
fee. The user fee will finance construction, operation,
and maintenance of harbor activities performed by the
Corps of Engineers, the costs of operating and maintaining the Saint Lawrence Seaway, and the costs of
administering the fee. Through appropriations acts, the
fee will raise an average of $980 million annually
through 2005, which is less than would have been
raised by the harbor maintenance tax before the Supreme Court decision that the ad valorem tax on exports was unconstitutional. While the collections from
the harbor services fee would be mandatory, collections
would be available to offset discretionary spending.
c. Receipts
Federal Aviation Administration (FAA), cost-based
user fees.—The Budget proposes to reduce the existing
aviation excise taxes over time as more efficient, costbased user fees for air traffic services are phased in
beginning in 2001. Under this proposal, the collections
each year from the new cost-based user fees and the
existing excise taxes combined would be equal to the
total budget resources requested for the FAA in each
succeeding year. In 2001, this proposal would result
in the collection of $1.0 billion in additional aviation
user charges. These charges will be deposited into a
governmental receipt account and be made available
for FAA discretionary spending.
Proposals

to

Department of Agriculture
Federal crop insurance.—The President’s Budget contains a proposal to strengthen the farm safety net that
includes nearly $1 billion in crop insurance reforms.
These reforms include a crop insurance premium discount which is expected to attract new participants to
the crop insurance program and induce current participants to purchase higher coverage levels. Both of these
expected outcomes will result in an increase in gross
premiums, a portion of which are paid by producers.
The estimated increase in producer-paid premiums as
a result of the safety net proposal is $69 million, as
shown in Table 4–3.
Department of Labor
Implement alien labor certification fees.—The proposal would establish a new fee, charged to businesses,
for processing of alien labor certification applications
by the Department of Labor. The fee proceeds would
offset the costs of administering and enforcing the alien
labor program, and provide reemployment and training
assistance to U.S. workers who have been dislocated
from their jobs.
Federal Emergency Management Agency (FEMA)
Flood map license fee.—The Administration proposes
to establish a $12 license fee on the use of FEMA’s
flood hazard maps to support a multi-year program to
update and modernize FEMA’s inventory of flood-plain
maps (100,000 maps). Accurate and easy to use flood
hazard maps are essential in determining if a property
is located in a flood plain. The maps allow lenders
to meet their statutory obligation of requiring the riskprone homes they insure to carry flood insurance, and
allow homeowners to assess their risk of flood damage.
The maps are the basis for developing appropriate riskbased flood insurance premium charges, and improved
maps will result in a more actuarially sound insurance
program.
b. Offsetting collections deposited in receipt accounts

Department of Transportation

B. User Fee
Spending

a. Offsetting collections deposited in appropriation accounts

Offset

Mandatory

Department of Agriculture
Recreation and entrance fees.—The Administration
proposes to permanently extend the current pilot program which expires in 2001. The United States Forest
Service would be allowed to collect increased recreation
and entrance fees and use the receipts without further
appropriation for facility improvements and new services. The Forest Service would also be authorized to
use collections from existing fees for similar improvements and services.
Concession, land use, right of way, and filming permits. This budget proposes to collect fair market value
from a variety of forest uses, including special use permits for rights-of-way on Forest Service lands (e.g., for
oil and gas pipelines, phone lines, and optic cables),
recreational concessions, marinas, and film, motion pic-

102

ANALYTICAL PERSPECTIVES

ture, and other similar uses. Funds would be available
for spending one year after these collections.
Department of Health and Human Services
Medicare premiums for retirees under the age of 65
and displaced workers.—The Administration proposes,
in the context of the President’s Medicare Reform Plan,
to charge premiums based on an actuarially fair rate
to people between the ages of 62 and 65 and displaced
workers between 55 and 61 who elect to participate
in the Medicare buy-in premium based program. This
increase in premium collections is offset by the reduction in premium collections due to the Medicare savings
proposals.
Medicare premiums for prescription drug benefit.—
The President’s Medicare reform plan includes a prescription drug benefit which is financed through a 50
percent premium. After paying the premium, Medicare
beneficiaries receive first-dollar coverage of prescription
drugs up to a $5,000 limit once the benefit is fully
implemented.
Department of the Interior
Recreation and entrance fees.—The Administration
proposes to permanently extend the current pilot program which expires in 2001. The National Park Service,
Fish and Wildlife Service, and the Bureau of Land

Management would be allowed to collect increased
recreation and entrance fees and use the receipts without further appropriation for facility improvements and
new services.
Filming and special use permits fees.—The Administration proposes to authorize the National Park Service
and other land management agencies, including the Department of Agriculture’s Forest Service, to increase
fees for permits to use land and facilities for the making of motion pictures, television productions, still
photos, sound tracks and other similar purposes. Collections would be available without further appropriations
to cover related Government costs (as currently authorized) and provide a fair return to the Government.
Hardrock mining production fees.—The Administration proposes to charge mining companies a 5% fee
on net smelter production from hard rock mining on
public domain or reserved public domain Federal lands.
Department of the Treasury
Extend Customs conveyance and passenger and merchandise processing fees.—Under existing legislation,
the Customs Conveyance/Passenger Fee and the Merchandise Processing Fee will expire on September 30,
2003. The Administration proposes to extend both of
these fees starting on October 1, 2003.

OTHER OFFSETTING COLLECTIONS AND RECEIPTS
Table 4–4 shows that total offsetting collections and
receipts from the public are estimated to be $214.8
billion in 2001. Of these, an estimated $141.4 billion
are offsetting collections credited to appropriation accounts and an estimated $73.4 billion are deposited
in offsetting receipt accounts.
The user fees in Table 4–4 were discussed in the
previous section. Major offsetting collections deposited
in expenditure accounts that are not user fees are precredit reform loan repayments, collections from States
to supplement payments in the supplemental security
income program, and collections for the Federal Savings
and Loan resolution fund. Major offsetting receipts that
are not user fees include spectrum auction receipts,
rents and royalties for oil and gas on the Outer Continental Shelf, and interest income.

Table 4–5 includes all offsetting receipts deposited
in receipt accounts. These include payments from one
part of the Government to another, called
intragovernmental transactions, and collections from
the public. These receipts are offset (deducted) from
outlays in the Federal budget. In total, offsetting receipts are estimated to be $413.2 billion in 2001—
$339.9 billion are intragovernmental transactions, and
$73.4 billion are from the public, shown in the table
as proprietary receipts and offsetting governmental receipts.
As noted above, offsetting collections and receipts by
agency are also displayed in Table 20–1, ‘‘Outlays to
the Public, Net and Gross,’’ which appears in Chapter
20 of this volume.

103

4. USER FEES AND OTHER COLLECTIONS

Table 4–4. OFFSETTING COLLECTIONS AND RECEIPTS FROM THE PUBLIC
(In millions of dollars)

1999
Actual

Estimate
2000

2001

Offsetting collections credited to expenditure accounts:
User fees:
Postal service stamps and other postal fees ....................................................................................................................................................
Defense Commissary Agency ............................................................................................................................................................................
Employee contributions for employees and retired employees health benefits funds ....................................................................................
Sale of energy:
Tennessee Valley Authority ...........................................................................................................................................................................
Bonneville Power Administration ...................................................................................................................................................................
All other user fees ..............................................................................................................................................................................................

61,957
4,967
4,853

63,998
4,999
5,249

67,421
4,999
5,622

6,818
2,539
17,904

6,590
2,309
17,290

6,718
2,345
19,929

Subtotal, user fees .........................................................................................................................................................................................

99,038

100,435

107,034

Other collections credited to expenditure accounts:
Pre-credit reform loan repayments ....................................................................................................................................................................
Supplemental security income (collections from the States) ............................................................................................................................
Federal Savings and Loan Insurance Corporation resolution fund ..................................................................................................................
All other collections ............................................................................................................................................................................................

14,919
3,219
3,784
15,417

14,977
3,310
2,188
16,524

14,787
3,410
624
15,564

Subtotal, other collections .......................................................................................................................................................................................

37,339

36,999

34,385

Subtotal, collections credited to expenditure accounts ..............................................................................................................................................

136,377

137,434

141,419

User fees:
Medicare premiums ............................................................................................................................................................................................
Foreign military sales program ...........................................................................................................................................................................
Immigration fees .................................................................................................................................................................................................
Customs fees ......................................................................................................................................................................................................
All other user fees ..............................................................................................................................................................................................

21,561
11,624
1,053
1,210
2,498

21,735
10,560
1,219
1,255
2,396

23,160
10,760
1,389
1,294
3,521

Offsetting receipts:

Subtotal, user fees deposited in receipt accounts ........................................................................................................................................

37,946

37,165

40,124

Other collections deposited in receipt accounts:
Spectrum auction receipts ..................................................................................................................................................................................
OCS rents, bonuses, and royalties ....................................................................................................................................................................
Interest income ...................................................................................................................................................................................................
All other collections deposited in receipt accounts ...........................................................................................................................................

1,505
3,098
9,441
18,941

2,076
3,550
10,971
20,794

3,559
3,691
13,564
12,426

Subtotal, other collections deposited in receipt accounts ............................................................................................................................

32,985

37,391

33,240

Subtotal, collections deposited in receipt accounts ...............................................................................................................................................

70,931

74,556

73,364

Total, offsetting collections and receipts from the public ...................................................................................................................................

207,308

211,990

214,783

Total, offsetting collections and receipts excluding off-budget ...................................................................................................................................

145,331

147,976

147,346

ADDENDUM:
User fees that are offsetting collections and receipts 1 .........................................................................................................................................
Other offsetting collections and receipts from the public ......................................................................................................................................

136,984
70,324

137,600
74,390

147,158
67,625

207,308

211,990

214,783

Total, offsetting collections and receipts from the public ...............................................................................................................................
1 Excludes

user fees that are classified on the receipts side of the budget. For total user fees, see Table 4.1 or Table 4.2.

104

ANALYTICAL PERSPECTIVES

Table 4–5. OFFSETTING RECEIPTS BY TYPE
(In millions of dollars)

Source

1999
Actual

Estimate
2000

INTRAGOVERNMENTAL TRANSACTIONS
On-budget receipts:
Federal intrafund transactions:
Distributed by agency:
Interest from the Federal Financing Bank ...................................................................
2,503
2,412
Interest on Government capital in enterprises ............................................................
1,473
1,634
Other .............................................................................................................................
1,119
1,721
Proposed Legislation (non-PAYGO) ............................................................................. .................. ..................
Total Federal intrafunds ................................................................................................

2001

2002

2003

2004

2005

2,159
1,633
2,084
65

1,988
1,400
2,190
79

1,853
1,269
2,298
82

2,205
1,138
2,361
85

2,472
1,059
2,354
96

5,095

5,767

5,941

5,657

5,502

5,789

5,981

Trust intrafund transactions:
Distributed by agency:
Payments to railroad retirement ...................................................................................
3,816
Other ............................................................................................................................. ..................

3,760
1

3,637
1

3,749
1

3,763
1

3,786
1

3,810
1

Total trust intrafunds .....................................................................................................

3,816

3,761

3,638

3,750

3,764

3,787

3,811

Total intrafund transactions ..............................................................................................

8,911

9,528

9,579

9,407

9,266

9,576

9,792

Interfund transactions:
Distributed by agency:
Federal fund payments to trust funds:
Contributions to insurance programs:
Military retirement fund ........................................................................................
Supplementary medical insurance .......................................................................
Proposed Legislation (non-PAYGO) ....................................................................
Hospital insurance ................................................................................................
Proposed Legislation (non-PAYGO) ....................................................................
Railroad social security equivalent fund .............................................................
Rail industry pension fund ...................................................................................
Civilian supplementary retirement contributions ..................................................
Proposed Legislation (non-PAYGO) ....................................................................
Unemployment insurance ....................................................................................
Other contributions ...............................................................................................
Proposed Legislation (non-PAYGO) ....................................................................
Miscellaneous payments ......................................................................................
Proposed Legislation (non-PAYGO) ....................................................................

15,250
62,185
..................
7,367
..................
98
394
21,706
..................
403
438
..................
597
..................

15,302
65,063
..................
7,865
..................
105
265
21,496
..................
399
541
..................
960
..................

15,914
69,777
–280
7,571
15,400
88
238
21,760
1
454
441
38
569
1,467

Subtotal .....................................................................................................................

108,438

111,996

133,438

Trust fund payments to Federal funds:
Quinquennial adjustment for military service credits .............................................. .................. ..................
Other .........................................................................................................................
1,082
1,051
Proposed Legislation (non-PAYGO) ........................................................................ .................. ..................

16,551
17,213
17,901
18,618
75,983
83,259
89,121
96,212
–780
3,636
9,668
11,404
7,855
8,409
8,952
9,476
12,600 .................. .................. ..................
88
89
91
94
243
248
255
262
22,074
22,491
22,860
23,250
1
1
2
3
474
500
543
574
492
488
485
482
37
36
36
34
577
566
570
580
–1
–1
–1
–1
136,194

136,935

150,483

160,988

1,152 .................. .................. .................. ..................
1,076
1,103
1,130
1,160
1,188
3,226 .................. .................. .................. ..................

Subtotal .....................................................................................................................

1,082

1,051

5,454

1,103

1,130

1,160

1,188

Total interfunds distributed by agency .........................................................................

109,520

113,047

138,892

137,297

138,065

151,643

162,176

Undistributed by agency:
Employer share, employee retirement (on-budget):
Civil service retirement and disability insurance (CSRDI) ......................................
9,094
8,879
Proposed Legislation (non-PAYGO) ........................................................................ .................. ..................
CSRDI from Postal Service .....................................................................................
6,001
6,437
Hospital insurance (contribution as employer) 1 .....................................................
1,965
2,043
Postal employer contributions to FHI ......................................................................
611
633
Military retirement fund .............................................................................................
10,417
11,454
Other Federal employees retirement .......................................................................
121
129

9,335
–34
6,624
2,093
659
11,413
135

9,729
22
6,799
2,211
687
11,781
141

9,839
–17
6,919
2,292
717
12,114
144

10,344
–24
7,041
2,384
749
12,459
150

10,895
–26
7,166
2,499
781
12,825
157

Total employer share, employee retirement (on-budget) ........................................

28,209

29,575

30,225

31,370

32,008

33,103

34,297

Interest received by on-budget trust funds .............................................................
66,561
Proposed Legislation (non-PAYGO) ........................................................................ ..................

71,291
65

73,735
377

76,779
1,413

79,629
2,297

82,210
2,556

84,782
2,804

100,931

104,337

109,562

113,934

117,869

121,883

Total interfund transactions undistributed by agency ..................................................

94,770

105

4. USER FEES AND OTHER COLLECTIONS

Table 4–5. OFFSETTING RECEIPTS BY TYPE—Continued
(In millions of dollars)

Estimate

1999
Actual

2000

2001

2002

2003

2004

2005

Total interfund transactions ..............................................................................................

204,290

213,978

243,229

246,859

251,999

269,512

284,059

Total on-budget receipts .......................................................................................................

213,201

223,506

252,808

256,266

261,265

279,088

293,851

Off-budget receipts:
Interfund transactions:
Distributed by agency:
Federal fund payments to trust funds:
Old-age, survivors, and disability insurance ............................................................
10,824
11,663
Undistributed by agency:
Employer share, employee retirement (off-budget) .................................................
7,385
7,860
Proposed Legislation (non-PAYGO) ........................................................................ .................. ..................
Interest received by off-budget trust funds .............................................................
52,070
59,656

10,985

11,494

12,048

12,813

13,725

8,212
–271
68,138

8,919
–321
77,622

9,493
–285
87,895

10,144
–289
98,812

10,905
–291
110,493

Source

Total off-budget receipts: ......................................................................................................

70,279

79,179

87,064

97,714

109,151

121,480

134,832

Total intragovernmental transactions ...................................................................................

283,480

302,685

339,872

353,980

370,416

400,568

428,683

PROPRIETARY RECEIPTS FROM THE PUBLIC
Distributed by agency:
Interest:
Interest on foreign loans and deferred foreign collections ..............................................
Interest on deposits in tax and loan accounts ................................................................
Other interest (domestic—civil) 2 ......................................................................................

888
935
7,617

753
1,152
9,066

749
1,104
10,369

758
1,052
11,372

823
1,052
12,368

812
1,052
13,324

806
1,052
14,216

Total interest ......................................................................................................................

9,440

10,971

12,222

13,182

14,243

15,188

16,074

Royalties and rents ...............................................................................................................
1,097
1,510
1,318
Proposed Legislation (PAYGO) ........................................................................................ .................. .................. ..................

1,355
9

1,339
33

1,354
33

1,401
33

453
–1
219
21
776
59

438
–1
262
21
758
64

423
–1
288
14
753
64

446
–1
286
20
750
65

425
–1
293
17
690
66

Sale of products:
Sale of timber and other natural land products ...............................................................
366
618
Proposed Legislation (non-PAYGO) ................................................................................. .................. ..................
Proposed Legislation (PAYGO) ........................................................................................ .................. ..................
Sale of minerals and mineral products ............................................................................
38
27
Sale of power and other utilities ......................................................................................
731
737
Other ..................................................................................................................................
65
61
Total sale of products .......................................................................................................

1,200

1,443

1,527

1,542

1,541

1,566

1,490

Fees and other charges for services and special benefits:
Medicare premiums and other charges (trust funds) ......................................................
Proposed Legislation (PAYGO) ........................................................................................
Nuclear waste disposal revenues .....................................................................................
Veterans life insurance (trust funds) ................................................................................
Other 2 ...............................................................................................................................
Proposed Legislation (non-PAYGO) .................................................................................
Proposed Legislation (PAYGO) ........................................................................................
Legislative proposal, discretionary offset .........................................................................

21,561
..................
662
204
1,860
..................
..................
..................

21,735
..................
663
189
1,892
..................
..................
..................

23,340
–180
550
179
2,565
–3
–157
966

25,396
226
550
168
2,520
–3
–66
963

27,813
8,052
550
157
2,543
–3
–56
960

30,427
10,921
545
145
2,578
–3
–42
996

33,095
13,703
535
133
2,619
–3
–41
1,015

Total fees and other charges ...........................................................................................

24,287

24,479

27,260

29,754

40,016

45,567

51,056

Sale of Government property:
Sale of land and other real property ................................................................................
58
59
Proposed Legislation (PAYGO) ........................................................................................ .................. ..................
Military assistance program sales (trust funds) ...............................................................
11,624
10,560
Other ..................................................................................................................................
172
170

114
3
10,760
220

419
5
10,890
224

79
13
10,920
188

77
14
11,020
73

77
14
11,150
88

11,097

11,538

11,200

11,184

11,329

Total sale of Government property ..................................................................................
Realization upon loans and investments:
Foreign military credit sales ..............................................................................................
Negative subsidies and downward reestimates ...............................................................
Repayment of loans to foreign nations ............................................................................
Other ..................................................................................................................................
Total realization upon loans and investments .................................................................

11,854

10,789

367 .................. .................. .................. .................. .................. ..................
5,914
10,606
894
5,176
5,424
5,690
6,323
175
253
254
67
80
81
87
96
84
88
136
116
113
111
6,552

10,943

1,236

5,379

5,620

5,884

6,521

106

ANALYTICAL PERSPECTIVES

Table 4–5. OFFSETTING RECEIPTS BY TYPE—Continued
(In millions of dollars)

1999
Actual

Source

Estimate
2000

2001

Recoveries and refunds 2 .....................................................................................................
3,831
4,028
Proposed Legislation (PAYGO) ............................................................................................ .................. ..................
Legislative proposal, discretionary offset .............................................................................. .................. ..................
Miscellaneous receipt accounts 2 .........................................................................................
4,724
1,426
Total proprietary receipts from the public distributed by agency ........................................

62,985

2002

2003

2004

2005

3,406
4,440
3,436
3,514
3,688
22
–180
–16
–24
–21
1,309 .................. .................. .................. ..................
1,436
1,437
1,442
1,449
1,452

65,589

60,833

68,456

78,854

85,715

93,023

Undistributed by agency:
Other interest: Interest received from Outer Continental Shelf escrow account ................
1 ..................
1,342 .................. .................. .................. ..................
Rents and royalties on the Outer Continental Shelf:
Rents and bonuses ...........................................................................................................
791
365
809
401
277
249
236
Royalties ............................................................................................................................
2,307
3,185
2,882
2,881
2,705
2,604
2,469
Sale of major assets ............................................................................................................. .................. .................. .................. ..................
323 .................. ..................
Total proprietary receipts from the public undistributed by agency ....................................

3,099

3,550

5,033

3,282

3,305

2,853

2,705

Total proprietary receipts from the public 3 ........................................................................

66,084

69,139

65,866

71,738

82,159

88,568

95,728

2,318
8
1,460
6

2,342
8
1,524
6

770
200

675
200

OFFSETTING GOVERNMENTAL RECEIPTS
Distributed by agency:
Regulatory fees ......................................................................................................................
3,020
3,264
3,640
3,603
3,692
Proposed Legislation (non-PAYGO) ..................................................................................... .................. ..................
20
8
8
Proposed Legislation (PAYGO) ............................................................................................ .................. .................. .................. .................. ..................
Other ......................................................................................................................................
74
77
79
81
6
Undistributed by agency:
Spectrum auction proceeds ..................................................................................................
1,753
2,076
3,559
5,535
2,480
Proposed Legislation (non-PAYGO) ..................................................................................... .................. ..................
200
200
200
Total offsetting governmental receipts ............................................................................

4,847

5,417

7,498

9,427

6,386

4,762

4,755

Total offsetting receipts ..........................................................................................................

354,411

377,241

413,236

435,145

458,961

493,898

529,166

1 Includes
2 Includes
3 Consists

provision for covered Federal civilian employees and military personnel.
both Federal funds and trust funds.
of:
1999
Actual
Federal funds ......................................
Trust funds ..........................................
Off-budget ............................................

27,796
38,267
21

Estimate
2000

2001

2002

2003

2004

2005

35,402
33,708
29

30,725
35,099
42

34,052
37,644
42

34,218
47,899
42

35,065
53,461
42

36,661
59,025
42

5. TAX EXPENDITURES
Tax expenditures are revenue losses due to preferential provisions of the Federal tax laws, such as
special exclusions, exemptions, deductions, credits, deferrals, or tax rates. They are alternatives to other policy instruments, such as spending or regulatory programs, as means of achieving Federal policy goals. Tax
expenditures are created for a variety of reasons: to
encourage certain activities, to improve fairness, to ease
compliance with and administration of the tax system,
and to reduce certain tax-induced distortions. The Congressional Budget Act of 1974 (Public Law 93–344) requires that a list of tax expenditures be included in
the budget.
The largest tax expenditures tend to be associated
with the individual income tax. For example, sizeable
tax preferences are provided for pension contributions
and earnings, employer contributions for medical insurance, mortgage interest payments on owner-occupied
homes, capital gains, and payments of State and local
individual income and property taxes. Tax expenditures
under the corporate income tax tend to be related to
the rate of cost recovery for various investments; as
is discussed below, the extent to which these provisions
are classified as tax expenditures varies according to
the conceptual baseline used. Charitable contributions
and credits for State taxes on bequests are the largest
tax expenditures under the unified transfer (i.e., estate
and gift) tax.
Because of potential interactions among provisions,
this chapter does not present a grand total for the

revenue loss estimated from tax expenditures. Moreover, past tax changes entailing broad elimination of
tax expenditures were generally accompanied by
changes in tax rates or other basic provisions, so that
the net effects on Federal revenues were considerably
(if not totally) offset. Nevertheless, in aggregate, tax
expenditures have revenue impacts of hundreds of billions of dollars, and are some of the most important
ways in which the Federal Government affects economic
decisions and social welfare.
Tax expenditures relating to the individual and corporate income taxes are considered first in this chapter.
They are estimated for fiscal years 1999–2005 using
three methods of accounting: revenue loss, outlay equivalent, and present value. The present value approach
provides estimates of the revenue losses for tax expenditures that involve deferrals of tax payments into the
future or have similar long-term effects. Tax expenditures relating to the unified transfer tax are considered
in a section at the end of the chapter.
The section of the chapter on performance measures
and economic effects presents information related to
assessment of the effect of tax expenditures on the
achievement of program performance goals. This section
is a complement to the government-wide performance
plan required by the Government Performance and Results Act of 1993. Tax expenditures are also discussed
in Section V of the Budget, which considers the Federal
Government’s spending, regulatory, and tax policies
across functional areas.

TAX EXPENDITURES IN THE INCOME TAX
Tax Expenditure Estimates
The Treasury Department prepared all tax expenditure estimates presented here based upon tax law enacted as of December 31, 1999. Expired or repealed
provisions are not listed if their revenue effects result
only from taxpayer activity occurring before fiscal year
1999. Due to the time required to estimate the large
number of tax expenditures, the estimates are based
on mid-session economic assumptions; exceptions are
the earned income tax credit and child credit provisions,
which involve outlay components and hence are updated to reflect the economic assumptions used elsewhere in the budget.
The total revenue loss estimates for tax expenditures
for fiscal years 1999–2005 are displayed according to
the budget’s functional categories in Table 5–1. Descriptions of the specific tax expenditure provisions follow
the tables of estimates and discussion of general features of the tax expenditure concept.

As in prior years, two baseline concepts—the normal
tax baseline and the reference tax law baseline—are
used to identify tax expenditures. For the most part,
the two concepts coincide. However, items treated as
tax expenditures under the normal tax baseline, but
not the reference tax law baseline, are indicated by
the designation ‘‘normal tax method’’ in the tables. The
revenue losses for these items are zero using the reference tax rules. The alternative baseline concepts are
discussed in detail following the tables.
Table 5–2 reports the respective portions of the total
revenue losses that arise under the individual and corporate income taxes. Listing revenue loss estimates
under the individual and corporate headings does not
imply that these categories of filers benefit from the
special tax provisions in proportion to the respective
tax expenditure amounts shown. Rather, these breakdowns show the specific tax accounts through which
the various provisions are cleared. The ultimate beneficiaries of corporate tax expenditures could be stock-

107

108

ANALYTICAL PERSPECTIVES

holders, employees, customers, or others, depending on
economic forces.
Table 5–3 ranks the major tax expenditures by fiscal
year 2001 revenue loss. This table merges several individual entries provided in Table 5–1; for example, Table
5–3 contains one merged entry for charitable contributions instead of the three separate entries found in
Table 5–1.
Interpreting Tax Expenditure Estimates
The revenue loss estimates shown for individual tax
expenditures in Tables 5–1, 5–2, and 5–3 do not necessarily equal the increase in Federal revenues (or the
change in the budget balance) that would result from
repealing these special provisions, for the following reasons:
Eliminating a tax expenditure may have incentive
effects that alter economic behavior. These incentives
can affect the resulting magnitudes of the formerly subsidized activity or of other tax preferences or Government programs. For example, if deductibility of mortgage interest were limited, some taxpayers would hold
smaller mortgages, with a concomitantly smaller effect
on the budget than if no such limits were in force.
Tax expenditures are interdependent even without
incentive effects. Repeal of a tax expenditure provision
can increase or decrease the revenue losses associated
with other provisions. For example, even if behavior
does not change, repeal of an itemized deduction could
increase the revenue losses from other deductions because some taxpayers would be moved into higher tax
brackets. Alternatively, repeal of an itemized deduction
could lower the revenue loss from other deductions if
taxpayers are led to claim the standard deduction instead of itemizing. Similarly, if two provisions were
repealed simultaneously, the increase in tax liability
could be greater or less than the sum of the two separate tax expenditures, because each is estimated assuming that the other remains in force. In addition, the
estimates reported in Table 5–1 are the totals of individual and corporate income tax revenue losses reported
in Table 5–2 and do not reflect any possible interactions
between the individual and corporate income tax receipts. For this reason, the estimates in Table 5–1 (as
well as those in Table 5–5, which are also based on
summing individual and corporate estimates) should be
regarded as approximations.
Revenues raised by changes to tax expenditures are
sensitive to timing effects and effective dates. Changes
in some provisions could yield their full potential revenue gains relatively quickly, whereas changes to other
provisions would only gradually yield their full revenue

potential, especially if certain deductions or exemptions
were grandfathered.
The annual value of tax expenditures for tax deferrals is reported on a cash basis in all tables except
Table 5–4. Cash-based estimates reflect the difference
between taxes deferred in the current year and incoming revenues that are received due to deferrals of taxes
from prior years. Although such estimates are useful
as a measure of cash flows into the Government, they
do not accurately reflect the true economic cost of these
provisions. For example, for a provision where activity
levels have changed, so that incoming tax receipts from
past deferrals are greater than deferred receipts from
new activity, the cash-basis tax expenditure estimate
can be negative, despite the fact that in present-value
terms current deferrals do have a real cost to the Government. Alternatively, in the case of a newly enacted
deferral provision, a cash-based estimate can overstate
the real cost to the Government because the newly
deferred taxes will ultimately be received. Presentvalue estimates, which are a useful supplement to the
cash-basis estimates for provisions involving deferrals,
are discussed below.
Repeal on major tax provisions may have some impact on overall levels of income and rates of economic
growth and, thus, on the budget economic assumptions.
In practice, however, most changes in particular provisions are unlikely to have significant macroeconomic
effects.
Present-Value Estimates
Discounted present-value estimates of revenue losses
are presented in Table 5–4 for provisions that involve
tax deferrals or other long-term revenue effects. These
estimates complement the cash-based tax expenditure
estimates presented in the other tables.
The present-value estimates represent the revenue
losses, net of future tax payments, that follow from
activities undertaken during calendar year 1999 which
cause the deferrals or other long-term revenue effects.
For instance, a pension contribution in 1999 would
cause a deferral of tax payments on wages in 1999
and on pension earnings on this contribution (e.g., interest) in later years. In some future year, however,
the 1999 pension contribution and accrued earnings
would be paid out and taxes would be due; these receipts are included in the present-value estimate. In
general, this conceptual approach is similar to the one
used for reporting the budgetary effects of credit programs, where direct loans and guarantees in a given
year affect future cash flows.

109

5. TAX EXPENDITURES

Table 5–1. TOTAL REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX
(In millions of dollars)
Total revenue loss from corporate and individual Income taxes
1999

2000

2001

2002

2003

2004

2005

2001–2005

1

National Defense
Exclusion of benefits and allowances to armed forces personnel .......................................................

2,120

2,140

2,160

2,180

2,200

2,220

2,240

11,000

2
3
4
5
6
7

International affairs:
Exclusion of income earned abroad by U.S. citizens ...........................................................................
Exclusion of certain allowances for Federal employees abroad ..........................................................
Exclusion of income of foreign sales corporations ................................................................................
Inventory property sales source rules exception ...................................................................................
Deferral of income from controlled foreign corporations (normal tax method) ....................................
Deferred taxes for financial firms on certain income earned overseas ................................................

2,330
635
3,640
1,050
5,800
960

2,550
665
3,890
1,100
6,200
1,190

2,790
695
4,160
1,150
6,600
1,290

3,040
725
4,460
1,250
7,000
540

3,285
760
4,770
1,350
7,450
0

3,545
795
5,100
1,450
7,900
0

3,825
830
5,460
1,550
8,400
0

16,485
3,805
23,950
6,750
37,350
1,830

8
9

General science, space, and technology:
Expensing of research and experimentation expenditures (normal tax method) .................................
Credit for increasing research activities .................................................................................................

1,890
1,705

1,865
1,010

1,885
3,360

1,965
3,710

2,090
2,970

2,245
2,605

2,410
1,505

10,595
14,150

10
11
12
13
14
15
16
17
18
19
20

Energy:
Expensing of exploration and development costs, fuels .......................................................................
Excess of percentage over cost depletion, fuels ..................................................................................
Alternative fuel production credit ............................................................................................................
Exception from passive loss limitation for working interests in oil and gas properties .......................
Capital gains treatment of royalties on coal ..........................................................................................
Exclusion of interest on energy facility bonds .......................................................................................
Enhanced oil recovery credit ..................................................................................................................
New technology credit ............................................................................................................................
Alcohol fuel credits 1 ...............................................................................................................................
Tax credit and deduction for clean-fuel burning vehicles .....................................................................
Exclusion from income of conservation subsidies provided by public utilities .....................................

–80
265
1,025
30
65
115
225
50
15
85
85

–15
275
960
25
65
115
260
60
15
90
80

–30
280
905
25
70
115
295
80
15
105
80

–10
280
845
25
70
120
340
90
15
100
80

15
285
125
25
75
120
390
90
15
80
85

15
290
125
25
80
120
450
90
15
55
85

15
290
125
25
85
120
515
85
15
20
85

5
1,425
2,125
125
380
595
1,990
435
75
360
415

21
22
23
24
25
26
27

Natural resources and environment:
Expensing of exploration and development costs, nonfuel minerals ....................................................
Excess of percentage over cost depletion, nonfuel minerals ...............................................................
Exclusion of interest on bonds for water, sewage, and hazardous waste facilities ............................
Capital gains treatment of certain timber income .................................................................................
Expensing of multiperiod timber growing costs .....................................................................................
Investment credit and seven-year amortization for reforestation expenditures ....................................
Tax incentives for preservation of historic structures ............................................................................

15
225
460
65
495
10
210

15
230
460
65
500
10
220

20
245
470
70
530
10
240

20
250
475
70
565
15
250

20
265
480
75
590
15
265

20
275
480
80
605
15
280

20
285
490
85
630
15
295

100
1,320
2,395
380
2,920
70
1,330

28
29
30
31
32
33

Agriculture:
Expensing of certain capital outlays ......................................................................................................
Expensing of certain multiperiod production costs ................................................................................
Treatment of loans forgiven for solvent farmers ...................................................................................
Capital gains treatment of certain income .............................................................................................
Income averaging for farmers ................................................................................................................
Deferral of gain on sale of farm refiners ...............................................................................................

70
85
10
635
75
10

70
85
10
665
75
10

75
90
10
695
80
10

75
95
10
725
80
10

80
105
10
760
80
15

85
110
10
795
85
15

90
110
10
830
85
15

405
510
50
3,805
410
65

1,470
60
13,920
5
220
100

1,550
65
14,985
5
225
100

1,650
55
16,130
5
235
100

1,765
45
17,365
5
240
100

1,890
35
18,870
5
250
100

2,020
20
20,130
5
255
105

2,155
5
21,680
5
265
105

9,480
160
94,175
25
1,245
510

905
155
56,920
21,215
995
18,000
5,315
2,820
3,710

915
155
58,815
22,185
1,015
18,540
5,035
3,055
3,985

920
160
60,925
23,075
1,035
19,095
4,790
3,195
4,225

930
160
63,240
24,000
1,055
19,670
4,555
3,300
4,500

940
160
65,955
24,980
1,075
20,260
4,330
3,405
4,765

950
160
68,965
25,915
1,095
20,870
4,100
3,485
4,975

955
160
72,160
26,840
1,115
21,495
3,885
3,540
5,145

4,695
800
331,245
124,810
5,375
101,390
21,660
16,925
23,610

40
160
39,405
5
25,800
175
35

25
160
40,575
5
27,090
185
35

15
160
41,780
5
28,240
195
40

15
165
43,025
5
29,370
205
40

20
165
44,300
5
30,545
210
40

20
165
45,615
5
31,765
220
40

25
165
46,965
5
33,035
230
40

95
820
221,685
25
152,955
1,060
200

34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55

Commerce and housing:
Financial institutions and insurance:
Exemption of credit union income .....................................................................................................
Excess bad debt reserves of financial institutions ............................................................................
Exclusion of interest on life insurance savings .................................................................................
Special alternative tax on small property and casualty insurance companies ................................
Tax exemption of certain insurance companies owned by tax-exempt organizations ....................
Small life insurance company deduction ...........................................................................................
Housing:
Exclusion of interest on owner-occupied mortgage subsidy bonds .................................................
Exclusion of interest on rental housing bonds ..................................................................................
Deductibility of mortgage interest on owner-occupied homes ..........................................................
Deductibility of State and local property tax on owner-occupied homes .........................................
Deferral of income from post-1987 installment sales .......................................................................
Capital gains exclusion on home sales .............................................................................................
Exception from passive loss rules for $25,000 of rental loss ..........................................................
Credit for low-income housing investments .......................................................................................
Accelerated depreciation on rental housing (normal tax method) ....................................................
Commerce:
Cancellation of indebtedness .............................................................................................................
Exceptions from imputed interest rules .............................................................................................
Capital gains (except agriculture, timber, iron ore, and coal) (normal tax method) ........................
Capital gains exclusion of small corporation stock ...........................................................................
Step-up basis of capital gains at death ............................................................................................
Carryover basis of capital gains on gifts ...........................................................................................
Ordinary income treatment of loss from small business corporation stock sale .............................

110

ANALYTICAL PERSPECTIVES

Table 5–1. TOTAL REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX—Continued
(In millions of dollars)
Total revenue loss from corporate and individual Income taxes
1999

2000

2001

2002

2003

2004

2005

2001–2005

56
57
58
59
60
61

Accelerated depreciation of buildings other than rental housing (normal tax method) ...................
Accelerated depreciation of machinery and equipment (normal tax method) .................................
Expensing of certain small investments (normal tax method) ..........................................................
Amortization of start-up costs (normal tax method) ..........................................................................
Graduated corporation income tax rate (normal tax method) ..........................................................
Exclusion of interest on small issue bonds .......................................................................................

1,660
26,445
1,465
200
6,360
310

710
27,740
1,590
205
6,300
315

–435
32,830
1,925
205
6,275
315

–755
33,345
1,965
215
6,460
320

–1,115
34,265
1,920
215
6,490
320

–1,695
36,390
1,895
220
6,710
325

–2,145
37,330
1,905
225
6,815
330

–6,145
174,160
9,610
1,080
32,750
1,610

62
63
64

Transportation:
Deferral of tax on shipping companies ..................................................................................................
Exclusion of reimbursed employee parking expenses ..........................................................................
Exclusion for employer-provided transit passes ....................................................................................

15
1,725
130

15
1,805
150

15
1,895
170

15
1,995
190

15
2,100
215

15
2,210
235

15
2,330
260

75
10,530
1,070

65
66
67
68
69

Community and regional development:
Investment credit for rehabilitation of structures (other than historic) ..................................................
Exclusion of interest for airport, dock, and similar bonds .....................................................................
Exemption of certain mutuals’ and cooperatives’ income .....................................................................
Empowerment zones and enterprise communities ................................................................................
Expensing of environmental remediation costs .....................................................................................

25
730
60
330
115

25
735
60
445
150

30
740
60
500
175

30
750
65
465
60

30
755
65
330
–30

30
765
65
300
–35

30
770
70
260
–30

150
3,780
325
1,855
140

1,085
4,595
2,170
0
240
120
245
590
5
10
915
19,435
2,525
220

1,110
4,925
2,375
10
265
175
250
595
10
15
965
19,575
2,650
235

1,120
5,125
2,420
25
310
225
255
600
20
15
1,015
19,480
2,765
250

1,130
5,145
2,465
40
350
275
255
600
35
15
1,055
18,970
2,910
175

1,140
4,745
4,405
60
375
320
255
610
50
15
1,105
18,155
3,035
0

1,150
4,615
4,430
80
395
350
260
615
65
20
1,155
17,535
3,140
0

1,165
5,335
4,630
105
430
385
260
620
70
20
1,185
16,855
3,300
0

5,705
24,965
18,350
310
1,860
1,555
1,285
3,045
240
85
5,515
90,995
15,150
425

84
85
86
87
88
89
90
91
92
93
94

Education, training, employment, and social services:
Education:
Exclusion of scholarship and fellowship income (normal tax method) ............................................
HOPE tax credit ..................................................................................................................................
Lifetime Learning tax credit ................................................................................................................
Education Individual Retirement Accounts ........................................................................................
Deductibility of student-loan interest ..................................................................................................
Deferral for State prepaid tuition plans .............................................................................................
Exclusion of interest on student-loan bonds .....................................................................................
Exclusion of interest on bonds for private nonprofit educational facilities .......................................
Credit for holders of zone academy bonds .......................................................................................
Exclusion of interest on savings bonds redeemed to finance educational expenses .....................
Parental personal exemption for students age 19 or over ...............................................................
Child credit 2 ........................................................................................................................................
Deductibility of charitable contributions (education) ..........................................................................
Exclusion of employer-provided educational assistance ...................................................................
Training, employment, and social services:
Work opportunity tax credit ................................................................................................................
Welfare-to-work tax credit ..................................................................................................................
Exclusion of employer-provided child care ........................................................................................
Adoption assistance ............................................................................................................................
Exclusion of employee meals and lodging (other than military) ......................................................
Credit for child and dependent care expenses .................................................................................
Credit for disabled access expenditures ...........................................................................................
Expensing of costs of removing certain architectural barriers to the handicapped ........................
Deductibility of charitable contributions, other than education and health .......................................
Exclusion of certain foster care payments ........................................................................................
Exclusion of parsonage allowances ...................................................................................................

270
35
645
125
650
2,420
50
0
19,220
35
320

455
60
670
140
680
2,390
50
0
20,015
40
340

465
80
700
140
710
2,360
55
5
20,860
40
365

350
80
725
125
740
2,330
55
5
21,780
45
390

215
60
765
40
775
2,305
55
5
22,750
45
415

95
25
805
15
810
2,275
60
5
23,765
50
445

35
10
850
10
845
2,250
60
5
24,895
50
475

1,160
255
3,845
330
3,880
11,520
285
25
114,050
230
2,090

95
96
97
98
99
100
101
102
103

Health:
Exclusion of employer contributions for medical insurance premiums and medical care ...................
Self-employed medical insurance premiums .........................................................................................
Workers’ compensation insurance premiums ........................................................................................
Medical Savings Accounts ......................................................................................................................
Deductibility of medical expenses ..........................................................................................................
Exclusion of interest on hospital construction bonds ............................................................................
Deductibility of charitable contributions (health) ....................................................................................
Tax credit for orphan drug research ......................................................................................................
Special Blue Cross/Blue Shield deduction .............................................................................................

69,610
935
4,420
20
3,695
1,210
2,675
70
245

75,095
1,250
4,585
30
3,910
1,225
2,800
80
315

80,570
1,380
4,555
30
4,160
1,235
2,930
90
200

86,175
1,545
4,935
30
4,440
1,250
3,080
100
135

90,655
2,070
5,120
30
4,720
1,265
3,210
115
180

95,960
2,905
5,315
30
5,005
1,275
3,315
130
245

102,725
3,210
5,515
25
5,305
1,290
3,490
140
315

456,085
11,110
25,440
145
23,630
6,315
16,025
575
1,075

395
5,185
345
75
130

405
5,330
360
75
130

410
5,785
375
70
135

415
6,040
390
70
140

420
6,310
405
65
140

430
6,575
420
60
145

430
6,865
435
55
150

2,105
31,575
2,025
320
710

83,780
13,350
5,230

88,830
15,050
5,550

92,390
15,975
5,895

97,085
17,030
6,255

102,575
17,630
6,635

108,020
18,250
7,040

113,705
18,750
7,465

513,775
87,635
33,290

70
71
72
73
74
75
76
77
78
79
80
81
82
83

104
105
106
107
108
109
110
111

Income security:
Exclusion of railroad retirement system benefits ...................................................................................
Exclusion of workers’ compensation benefits ........................................................................................
Exclusion of public assistance benefits (normal tax method) ...............................................................
Exclusion of special benefits for disabled coal miners .........................................................................
Exclusion of military disability pensions .................................................................................................
Net exclusion of pension contributions and earnings:
Employer plans ...................................................................................................................................
Individual Retirement Accounts ..........................................................................................................
Keogh plans ........................................................................................................................................
Exclusion of other employee benefits:

111

5. TAX EXPENDITURES

Table 5–1. TOTAL REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX—Continued
(In millions of dollars)
Total revenue loss from corporate and individual Income taxes
1999

2000

2001

2002

2003

2004

2005

2001–2005

112
13
114
115
116
117
118
119
120

Premiums on group term life insurance ............................................................................................
Premiums on accident and disability insurance ................................................................................
Income of trusts to finance supplementary unemployment benefits ....................................................
Special ESOP rules ................................................................................................................................
Additional deduction for the blind ...........................................................................................................
Additional deduction for the elderly ........................................................................................................
Tax credit for the elderly and disabled ..................................................................................................
Deductibility of casualty losses ..............................................................................................................
Earned income tax credit 3 .....................................................................................................................

1,700
185
0
1,130
30
1,785
35
255
4,825

1,740
195
0
1,175
30
1,830
35
265
4,700

1,780
205
0
1,205
30
1,890
35
275
4,790

1,820
215
5
1,250
30
1,955
35
285
4,985

1,860
225
5
1,300
35
1,985
35
295
5,205

1,915
235
5
1,360
35
2,030
35
310
5,440

1,970
245
5
1,425
35
2,110
35
325
5,740

9,345
1,125
20
6,540
165
9,970
175
1,490
26,160

121
122
123

Social Security:
Exclusion of social security benefits:
Social Security benefits for retired workers .......................................................................................
Social Security benefits for disabled .................................................................................................
Social Security benefits for dependents and survivors .....................................................................

17,135
2,390
3,775

18,010
2,595
3,900

18,885
2,830
4,050

19,995
3,090
4,210

21,230
3,375
4,385

22,505
3,700
4,555

16,515
3,150
3,625

99,130
16,145
20,825

124
125
126
127

Veterans benefits and services:
Exclusion of veterans death benefits and disability compensation ......................................................
Exclusion of veterans pensions ..............................................................................................................
Exclusion of GI bill benefits ....................................................................................................................
Exclusion of interest on veterans housing bonds .................................................................................

2,940
65
75
40

3,070
70
85
40

3,200
75
90
40

3,335
80
90
40

3,490
85
95
40

3,655
85
100
40

3,830
90
105
40

17,510
415
480
200

128
129
130

General purpose fiscal assistance:
Exclusion of interest on public purpose bonds .....................................................................................
Deductibility of nonbusiness State and local taxes other than on owner-occupied homes ................
Tax credit for corporations receiving income from doing business in U.S. possessions ....................

22,750
37,740
2,515

22,975
40,240
2,590

23,205
42,390
2,670

23,440
44,735
2,600

23,670
47,610
2,550

23,905
50,530
2,600

24,145
53,480
2,650

118,365
238,745
13,070

131

Interest:
Deferral of interest on U.S. savings bonds ...........................................................................................

1,015

1,065

1,115

1,175

1,235

1,295

1,355

6,175

21,215
37,740

22,185
40,240

23,075
42,390

24,000
44,735

24,980
47,610

25,915
50,530

26,840
53,480

124,810
238,745

22,750
115
460
310
905
155
730
245
590
1,210
40
5

22,975
115
460
315
915
155
735
250
595
1,225
40
10

23,205
115
470
315
920
160
740
255
600
1,235
40
20

23,440
120
475
320
930
160
750
255
600
1,250
40
35

23,670
120
480
320
940
160
755
255
610
1,265
40
50

23,905
120
480
325
950
160
765
260
615
1,275
40
65

24,145
120
490
330
955
160
770
260
620
1,290
40
70

118,365
595
2,395
1,610
4,695
800
3,780
1,285
3,045
6,315
200
240

Addendum: Aid to State and local governments:
Deductibility of:
Property taxes on owner-occupied homes ........................................................................................
Nonbusiness State and local taxes other than on owner-occupied homes
Exclusion of interest on State and local bonds for:
Public purposes ..................................................................................................................................
Energy facilities ...................................................................................................................................
Water, sewage, and hazardous waste disposal facilities .................................................................
Small-issues ........................................................................................................................................
Owner-occupied mortgage subsidies .................................................................................................
Rental housing ....................................................................................................................................
Airports, docks, and similar facilities .................................................................................................
Student loans ......................................................................................................................................
Private nonprofit educational facilities ...............................................................................................
Hospital construction ..........................................................................................................................
Veterans’ housing ...............................................................................................................................
Credit for holders of zone academy bonds ...........................................................................................

1 In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003
$815; 2004 $825; and 2005 $830.
2 The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004
$450; and 2005 $420.
3 The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $25,632; 2000 $25,676; 2001 $25,799; 2002
$26,876; 2003 $27,638; 2004 $28,701; and 2005 $29,722.
Note: Provisions with estimates denoted normal tax method have no revenue loss under the reference tax law method. All estimates have been rounded to the nearest $5 million. Provisions with estimates that rounded to zero in each year are not included in the table.

112

ANALYTICAL PERSPECTIVES

Table 5–2. CORPORATE AND INDIVIDUAL INCOME TAX REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES
(In millions of dollars)
Revenue Loss
Corporations
1999

1

2
3
4
5
6
7

8
9
10
11
12
13
14
15
16
17
18
19
20

21
22
23
24
25
26
27

28
29
30
31
32
33

34
35

2000

2001

2002

2003

Individuals
2004

2001–
2005

2005

National Defense
Exclusion of benefits and allowances to
armed forces personnel ....................... ............ ............ ............ ............ ............ ............ ............ ..............

1999

2000

2001

2002

2003

2,120

2,140

2,160

2,180

International affairs:
Exclusion of income earned abroad by
U.S. citizens ......................................... ............ ............ ............ ............ ............ ............ ............ .............. 2,330 2,550 2,790 3,040
Exclusion of certain allowances for Federal employees abroad ........................ ............ ............ ............ ............ ............ ............ ............ ..............
635
665
695
725
Exclusion of income of foreign sales corporations ...............................................
3,640 3,890 4,160 4,460 4,770 5,100 5,460 23,950 ............ ............ ............ ............
Inventory property sales source rules exception ..................................................
1,050 1,100 1,150 1,250 1,350 1,450 1,550
6,750 ............ ............ ............ ............
Deferral of income from controlled foreign corporations (normal tax method)
5,800 6,200 6,600 7,000 7,450 7,900 8,400 37,350 ............ ............ ............ ............
Deferred taxes for financial firms on certain income earned overseas ..............
960 1,190 1,290
540
0
0
0
1,830 ............ ............ ............ ............
General science, space, and technology:
Expensing of research and experimentation expenditures (normal tax method) ........................................................
Credit for increasing research activities ..

1,855
1,675

1,830
995

1,850
3,300

1,925
3,650

2,050
2,925

2,200
2,565

2,365
1,490

10,390
13,930

Energy:
Expensing of exploration and development costs, fuels ..................................
–70
–15
–30
–10
15
15
15
5
Excess of percentage over cost depletion, fuels ..............................................
220
225
230
230
235
240
240
1,175
Alternative fuel production credit .............
975
915
860
805
125
125
125
2,040
Exception from passive loss limitation for
working interests in oil and gas properties ..................................................... ............ ............ ............ ............ ............ ............ ............ ..............
Capital gains treatment of royalties on
coal ....................................................... ............ ............ ............ ............ ............ ............ ............ ..............
Exclusion of interest on energy facility
bonds ....................................................
30
30
30
30
30
30
30
150
Enhanced oil recovery credit ...................
205
235
270
310
355
410
470
1,815
New technology credit ..............................
45
50
60
70
70
70
65
335
Alcohol fuel credits 1 .................................
10
10
10
10
10
10
10
50
Tax credit and deduction for clean-fuel
burning vehicles ...................................
70
75
85
80
65
45
15
290
Exclusion from income of conservation
subsidies provided by public utilities ...
–5
–5
–5
–5
0
0
0
–10
Natural resources and environment:
Expensing of exploration and development costs, nonfuel minerals ..............
10
10
15
15
15
15
15
75
Excess of percentage over cost depletion, nonfuel minerals ...........................
180
185
195
200
210
220
230
1,055
Exclusion of interest on bonds for water,
sewage, and hazardous waste facilities ........................................................
115
115
120
120
120
120
125
605
Capital gains treatment of certain timber
income .................................................. ............ ............ ............ ............ ............ ............ ............ ..............
Expensing of multiperiod timber growing
costs .....................................................
305
310
330
350
365
375
390
1,810
Investment credit and seven-year amortization for reforestation expenditures ... ............ ............ ............ ............ ............ ............ ............ ..............
Tax incentives for preservation of historic
structures ..............................................
170
180
195
205
215
230
240
1,085
Agriculture:
Expensing of certain capital outlays ........
10
10
10
10
10
10
10
50
Expensing of certain multiperiod production costs ..............................................
10
10
10
10
15
15
15
65
Treatment of loans forgiven for solvent
farmers ................................................. ............ ............ ............ ............ ............ ............ ............ ..............
Capital gains treatment of certain income ............ ............ ............ ............ ............ ............ ............ ..............
Income averaging for farmers .................. ............ ............ ............ ............ ............ ............ ............ ..............
Deferral of gain on sale of farm refiners
10
10
10
10
15
15
15
65
Commerce and housing:
Financial institutions and insurance:
Exemption of credit union income .......
Excess bad debt reserves of financial
institutions ........................................

2004

2001–
2005

2005

2,200

2,220

2,240

11,000

3,285

3,545

3,825

16,485

760

795

830

3,805

.............. .............. .............. ..............
.............. .............. .............. ..............
.............. .............. .............. ..............
.............. .............. .............. ..............

35
30

35
15

35
60

40
60

40
45

45
40

45
15

205
220

–10

0

0

0

0

0

0

0

45
50

50
45

50
45

50
40

50
0

50
0

50
0

250
85

30

25

25

25

25

25

25

125

65

65

70

70

75

80

85

380

85
20
5
5

85
25
10
5

85
25
20
5

90
30
20
5

90
35
20
5

90
40
20
5

90
45
20
5

445
175
100
25

15

15

20

20

15

10

5

70

90

85

85

85

85

85

85

425

5

5

5

5

5

5

5

25

45

45

50

50

55

55

55

265

345

345

350

355

360

360

365

1,790

65

65

70

70

75

80

85

380

190

190

200

215

225

230

240

1,110

10

10

10

15

15

15

15

70

40

40

45

45

50

50

55

245

60

60

65

65

70

75

80

355

75

75

80

85

90

95

95

445

10
635
75

10
665
75

10
695
80

10
725
80

10
760
80

10
795
85

10
830
85

50
3,805
410

1,470

1,550

1,650

1,765

1,890

2,020

2,155

9,480 ............ ............ ............ ............ .............. .............. .............. ..............

60

65

55

45

35

20

5

160 ............ ............ ............ ............ .............. .............. .............. ..............

113

5. TAX EXPENDITURES

Table 5–2. CORPORATE AND INDIVIDUAL INCOME TAX REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES—Continued
(In millions of dollars)
Revenue Loss
Corporations
1999
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61

62
63
64

65
66
67
68
69

Exclusion of interest on life insurance
savings .............................................
Special alternative tax on small property and casualty insurance companies ...................................................
Tax exemption of certain insurance
companies owned by tax-exempt
organizations ....................................
Small life insurance company deduction ...................................................
Housing:
Exclusion of interest on owner-occupied mortgage subsidy bonds .........
Exclusion of interest on rental housing
bonds ...............................................
Deductibility of mortgage interest on
owner-occupied homes ....................
Deductibility of State and local property tax on owner-occupied homes
Deferral of income from post-1987 installment sales .................................
Capital gains exclusion on home sales
Exception from passive loss rules for
$25,000 of rental loss .....................
Credit for low-income housing investments ...............................................
Accelerated depreciation on rental
housing (normal tax method) ..........
Commerce:
Cancellation of indebtedness ...............
Exceptions from imputed interest rules
Capital gains (except agriculture, timber, iron ore, and coal) (normal tax
method) ............................................
Capital gains exclusion of small corporation stock ..................................
Step-up basis of capital gains at
death ................................................
Carryover basis of capital gains on
gifts ...................................................
Ordinary income treatment of loss
from small business corporation
stock sale .........................................
Accelerated depreciation of buildings
other than rental housing (normal
tax method) ......................................
Accelerated depreciation of machinery
and equipment (normal tax method)
Expensing of certain small investments (normal tax method) .............
Amortization of start-up costs (normal
tax method) ......................................
Graduated corporation income tax rate
(normal tax method) ........................
Exclusion of interest on small issue
bonds ...............................................

2000

2001

2002

Individuals

2003

2004

2001–
2005

2005

1999

2000

2001

2002

2,825 13,500 14,535 15,645 16,845

2003

2004

2005

2001–
2005

18,305

19,525

21,030

91,350

420

450

485

520

565

605

650

5

5

5

5

5

5

5

25 ............ ............ ............ ............ .............. .............. .............. ..............

220

225

235

240

250

255

265

1,245 ............ ............ ............ ............ .............. .............. .............. ..............

100

100

100

100

100

105

105

510 ............ ............ ............ ............ .............. .............. .............. ..............

230

230

230

235

235

240

240

1,180

675

685

690

695

705

710

715

3,515

40

40

40

40

40

40

40

200

115

115

120

120

120

120

120

600

............ ............ ............ ............ ............ ............ ............ .............. 56,920 58,815 60,925 63,240

65,955

68,965

72,160 331,245

............ ............ ............ ............ ............ ............ ............ .............. 21,215 22,185 23,075 24,000

24,980

25,915

26,840 124,810

260
265
270
275
280
285
290
1,400
735
750
765
780
............ ............ ............ ............ ............ ............ ............ .............. 18,000 18,540 19,095 19,670

795
20,260

810
20,870

825
3,975
21,495 101,390

............ ............ ............ ............ ............ ............ ............ ..............

5,315

5,035

4,790

4,555

4,330

4,100

3,885

21,660

2,115

2,290

2,395

2,475

2,555

2,615

2,655

12,695

705

765

800

825

850

870

885

4,230

110

120

135

160

180

200

230

905

3,600

3,865

4,090

4,340

4,585

4,775

4,915

22,705

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

40
160

25
160

15
160

15
165

20
165

20
165

25
165

95
820

............ ............ ............ ............ ............ ............ ............ .............. 39,405 40,575 41,780 43,025

44,300

45,615

5

5

5

............ ............ ............ ............ ............ ............ ............ .............. 25,800 27,090 28,240 29,370

30,545

31,765

............ ............ ............ ............ ............ ............ ............ ..............

5

5

5

46,965 221,685
5

25

33,035 152,955

............ ............ ............ ............ ............ ............ ............ ..............

175

185

195

205

210

220

230

1,060

............ ............ ............ ............ ............ ............ ............ ..............

35

35

40

40

40

40

40

200

–1,545

465

55

–665

–770

–855

–1,070

–1,240

–4,600

21,100 22,085 26,970 27,265 27,965 29,825 30,465 142,490

5,345

5,655

5,860

6,080

6,300

6,565

6,865

31,670

3,195

1,070

1,100

1,295

1,300

1,290

1,270

1,260

6,415

655

80

80

80

85

85

85

90

425

1,195

395

655

490

230

630

15

665

–260

630

–625

625

–905

645

120

125

125

130

130

135

135

6,360

6,300

6,275

6,460

6,490

6,710

6,815

80

80

80

80

80

80

85

32,750 ............ ............ ............ ............ .............. .............. .............. ..............
405

230

235

235

240

240

245

245

1,205

Transportation:
Deferral of tax on shipping companies ...
15
15
15
15
15
15
15
75 ............ ............ ............ ............ .............. .............. .............. ..............
Exclusion of reimbursed employee parking expenses ........................................ ............ ............ ............ ............ ............ ............ ............ .............. 1,725 1,805 1,895 1,995
2,100
2,210
2,330 10,530
Exclusion for employer-provided transit
passes .................................................. ............ ............ ............ ............ ............ ............ ............ ..............
130
150
170
190
215
235
260
1,070
Community and regional development:
Investment credit for rehabilitation of
structures (other than historic) ............
Exclusion of interest for airport, dock,
and similar bonds .................................
Exemption of certain mutuals’ and cooperatives’ income ...............................
Empowerment zones and enterprise
communities .........................................
Expensing of environmental remediation
costs .....................................................

15

15

15

15

15

15

15

75

10

10

15

15

15

15

15

75

185

185

185

190

190

195

195

955

545

550

555

560

565

570

575

2,825

60

60

60

65

65

65

70

325 ............ ............ ............ ............ .............. .............. .............. ..............

150

205

220

185

130

110

90

735

180

240

280

280

200

190

170

1,120

95

125

145

50

–25

–30

–25

115

20

25

30

10

–5

–5

–5

25

114

ANALYTICAL PERSPECTIVES

Table 5–2. CORPORATE AND INDIVIDUAL INCOME TAX REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES—Continued
(In millions of dollars)
Revenue Loss
Corporations
1999

70
71
72
73
74
75
76
77
78
79

80
81
82
83

84
85
86
87
88
89
90
91

92

93
94
95

96
97
98
99
00
101
102
103
104
105
106

Education, training, employment, and social services:
Education:
Exclusion of scholarship and fellowship income (normal tax method) ...
HOPE tax credit ...................................
Lifetime Learning tax credit .................
Education Individual Retirement Accounts ...............................................
Deductibility of student-loan interest ...
Deferral for State prepaid tuition plans
Exclusion of interest on student-loan
bonds ...............................................
Exclusion of interest on bonds for private nonprofit educational facilities
Credit for holders of zone academy
bonds ...............................................
Exclusion of interest on savings bonds
redeemed to finance educational
expenses ..........................................
Parental personal exemption for students age 19 or over ......................
Child credit 2 .........................................
Deductibility of charitable contributions
(education) .......................................
Exclusion of employer-provided educational assistance ..........................
Training, employment, and social services:
Work opportunity tax credit .................
Welfare-to-work tax credit ....................
Exclusion of employer-provided child
care ..................................................
Adoption assistance .............................
Exclusion of employee meals and
lodging (other than military) ............
Credit for child and dependent care
expenses ..........................................
Credit for disabled access expenditures .................................................
Expensing of costs of removing certain architectural barriers to the
handicapped .....................................
Deductibility of charitable contributions, other than education and
health ...............................................
Exclusion of certain foster care payments ...............................................
Exclusion of parsonage allowances ....
Health:
Exclusion of employer contributions for
medical insurance premiums and
medical care .........................................
Self-employed medical insurance premiums ...................................................
Workers’ compensation insurance premiums ...................................................
Medical Savings Accounts ...................
Deductibility of medical expenses ...........
Exclusion of interest on hospital construction bonds .....................................
Deductibility of charitable contributions
(health) .................................................
Tax credit for orphan drug research .......
Special Blue Cross/Blue Shield deduction

2000

2001

2002

Individuals

2003

2004

2001–
2005

2005

2003

2004

2001–
2005

1999

2000

2001

2002

2005

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

1,085
4,595
2,170

1,110
4,925
2,375

1,120
5,125
2,420

1,130
5,145
2,465

1,140
4,745
4,405

1,150
4,615
4,430

1,165
5,335
4,630

5,705
24,965
18,350

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

0
240
120

10
265
175

25
310
225

40
350
275

60
375
320

80
395
350

105
430
385

310
1,860
1,555

60

65

65

65

65

65

65

325

185

185

190

190

190

195

195

960

150

150

150

150

155

155

155

765

440

445

450

450

455

460

465

2,280

5

10

20

35

50

65

70

240 ............ ............ ............ ............ .............. .............. .............. ..............

............ ............ ............ ............ ............ ............ ............ ..............

15

15

20

20

85

............ ............ ............ ............ ............ ............ ............ ..............
915
965 1,015 1,055
............ ............ ............ ............ ............ ............ ............ .............. 19,435 19,575 19,480 18,970

1,105
18,155

1,155
17,535

1,185
16,855

5,515
90,995

485

2,135

2,220

2,315

2,420

2,530

2,650

12,135

............ ............ ............ ............ ............ ............ ............ ..............

220

235

250

175

0

0

0

425

990
215

40
5

70
10

70
15

50
10

30
10

15
5

5
0

170
40

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

645
125

670
140

700
140

725
125

765
40

805
15

850
10

3,845
330

............ ............ ............ ............ ............ ............ ............ ..............

650

680

710

740

775

810

845

3,880

............ ............ ............ ............ ............ ............ ............ ..............

2,420

2,390

2,360

2,330

2,305

2,275

2,250

11,520

35

35

40

40

40

45

45

210

3,740 18,620 19,380 20,180 21,040

21,990

23,010

45
390

45
415

50
445

............ ............ ............ ............ ............ ............ ............ .............. 69,610 75,095 80,570 86,175

90,655

395
65

595

300
70

615

185
50

610

80
20

650

15

2,040

385
50

545

15

3,015

230
30

515

10

30
10

15

15

15

15

15

15

15

75

0

0

5

5

5

5

5

25

600

635

680

740

760

755

805

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

35
320

40
340

40
365

24,090 110,310
50
475

230
2,090

95,960 102,725 456,085

............ ............ ............ ............ ............ ............ ............ ..............

935

1,250

1,380

1,545

2,070

2,905

3,210

11,110

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

4,420
20
3,695

4,585
30
3,910

4,555
30
4,160

4,935
30
4,440

5,120
30
4,720

5,315
30
5,005

5,515
25
5,305

25,440
145
23,630

905

915

925

935

945

955

965

4,725

305

310

310

315

320

320

325

1,590

585
70
245

620
80
315

660
90
200

720
100
135

740
115
180

735
130
245

780
140
315

3,635 2,090 2,180 2,270 2,360
2,470
2,580
2,710 12,390
575 ............ ............ ............ ............ .............. .............. .............. ..............
1,075 ............ ............ ............ ............ .............. .............. .............. ..............

Income security:
Exclusion of railroad retirement system
benefits ................................................. ............ ............ ............ ............ ............ ............ ............ ..............
Exclusion of workers’ compensation benefits ....................................................... ............ ............ ............ ............ ............ ............ ............ ..............
Exclusion of public assistance benefits
(normal tax method) ............................. ............ ............ ............ ............ ............ ............ ............ ..............

395

405

410

415

420

430

430

2,105

5,185

5,330

5,785

6,040

6,310

6,575

6,865

31,575

345

360

375

390

405

420

435

2,025

115

5. TAX EXPENDITURES

Table 5–2. CORPORATE AND INDIVIDUAL INCOME TAX REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES—Continued
(In millions of dollars)
Revenue Loss
Corporations
1999
107
108

109
110
111
112
113
114
115
116
117
118
119
120

121
122
123

124
125
126
127

128
129

130

131

Exclusion of special benefits for disabled
coal miners ...........................................
Exclusion of military disability pensions ..
Net exclusion of pension contributions
and earnings:
Employer plans ....................................
Individual Retirement Accounts ...........
Keogh plans .........................................
Exclusion of other employee benefits:
Premiums on group term life insurance .................................................
Premiums on accident and disability
insurance ..........................................
Income of trusts to finance supplementary unemployment benefits .....
Special ESOP rules .............................
Additional deduction for the blind ........
Additional deduction for the elderly .....
Tax credit for the elderly and disabled
Deductibility of casualty losses ...........
Earned income tax credit 3 ..................

2000

2001

2002

2003

Individuals
2004

2005

2001–
2005

............ ............ ............ ............ ............ ............ ............ ..............
............ ............ ............ ............ ............ ............ ............ ..............

1999

75
130

2000

75
130

2001

70
135

2002

70
140

2003

65
140

2004

60
145

2005

55
150

2001–
2005
320
710

............ ............ ............ ............ ............ ............ ............ .............. 83,780 88,830 92,390 97,085 102,575 108,020 113,705 513,775
............ ............ ............ ............ ............ ............ ............ .............. 13,350 15,050 15,975 17,030 17,630 18,250 18,750 87,635
............ ............ ............ ............ ............ ............ ............ .............. 5,230 5,550 5,895 6,255
6,635
7,040
7,465 33,290

............ ............ ............ ............ ............ ............ ............ ..............

1,700

1,740

1,780

1,820

1,860

1,915

1,970

9,345

............ ............ ............ ............ ............ ............ ............ ..............

185

195

205

215

225

235

245

1,125

0
860
............
............
............
............
............

0
890
............
............
............
............
............

0
915
............
............
............
............
............

5
950
............
............
............
............
............

5
990
............
............
............
............
............

5
1,040
............
............
............
............
............

5
1,090
............
............
............
............
............

20 ............ ............ ............ ............ .............. .............. .............. ..............
4,985
270
285
290
300
310
320
335
1,555
..............
30
30
30
30
35
35
35
165
.............. 1,785 1,830 1,890 1,955
1,985
2,030
2,110
9,970
..............
35
35
35
35
35
35
35
175
..............
255
265
275
285
295
310
325
1,490
.............. 4,825 4,700 4,790 4,985
5,205
5,440
5,740 26,160

Social Security:
Exclusion of social security benefits:
Social Security benefits for retired
workers ............................................. ............ ............ ............ ............ ............ ............ ............ .............. 17,135 18,010 18,885 19,995
Social Security benefits for disabled ... ............ ............ ............ ............ ............ ............ ............ .............. 2,390 2,595 2,830 3,090
Social Security benefits for dependents and survivors ........................... ............ ............ ............ ............ ............ ............ ............ .............. 3,775 3,900 4,050 4,210
Veterans benefits and services:
Exclusion of veterans death benefits and
disability compensation ........................ ............ ............ ............ ............ ............ ............ ............ ..............
Exclusion of veterans pensions ............... ............ ............ ............ ............ ............ ............ ............ ..............
Exclusion of GI bill benefits ..................... ............ ............ ............ ............ ............ ............ ............ ..............
Exclusion of interest on veterans housing
bonds ....................................................
10
10
10
10
10
10
10
50

21,230
3,375

22,505
3,700

16,515
3,150

99,130
16,145

4,385

4,555

3,625

20,825

2,940
65
75

3,070
70
85

3,200
75
90

3,335
80
90

3,490
85
95

3,655
85
100

3,830
90
105

17,510
415
480

30

30

30

30

30

30

30

150

General purpose fiscal assistance:
Exclusion of interest on public purpose
bonds ....................................................
5,735 5,790 5,850 5,910 5,965 6,025 6,085 29,835 17,015 17,185 17,355 17,530 17,705 17,880 18,060 88,530
Deductibility of nonbusiness State and
local taxes other than on owner-occupied homes ........................................... ............ ............ ............ ............ ............ ............ ............ .............. 37,740 40,240 42,390 44,735 47,610 50,530 53,480 238,745
Tax credit for corporations receiving income from doing business in U.S.
possessions ..........................................
2,515 2,590 2,670 2,600 2,550 2,600 2,650 13,070 ............ ............ ............ ............ .............. .............. .............. ..............
Interest:
Deferral of interest on U.S. savings
bonds .................................................... ............ ............ ............ ............ ............ ............ ............ ..............

1,015

1,065

1,115

1,175

Addendum: Aid to State and local governments:
Deductibility of:
Property taxes on owner-occupied
homes .............................................. ............ ............ ............ ............ ............ ............ ............ .............. 21,215 22,185 23,075 24,000
Nonbusiness State and local taxes
other than on owner-occupied
homes .............................................. ............ ............ ............ ............ ............ ............ ............ .............. 37,740 40,240 42,390 44,735
Exclusion of interest on State and local
bonds for:
Public purposes ....................................
5,735 5,790 5,850 5,910 5,965 6,025 6,085 29,835 17,015 17,185 17,355 17,530
Energy facilities ....................................
30
30
30
30
30
30
30
150
85
85
85
90
Water, sewage, and hazardous waste
disposal facilities ..............................
115
115
120
120
120
120
125
605
345
345
350
355
Small-issues .........................................
80
80
80
80
80
80
85
405
230
235
235
240
Owner-occupied mortgage subsidies ..
230
230
230
235
235
240
240
1,180
675
685
690
695
Rental housing .....................................
40
40
40
40
40
40
40
200
115
115
120
120
Airports, docks, and similar facilities ...
185
185
185
190
190
195
195
955
545
550
555
560
Student loans .......................................
60
65
65
65
65
65
65
325
185
185
190
190
Private nonprofit educational facilities
150
150
150
150
155
155
155
765
440
445
450
450
Hospital construction ............................
305
310
310
315
320
320
325
1,590
905
915
925
935
Veterans’ housing ................................
10
10
10
10
10
10
10
50
30
30
30
30

1,235

1,295

1,355

6,175

24,980

25,915

26,840 124,810

47,610

50,530

53,480 238,745

17,705
90

17,880
90

18,060
90

88,530
445

360
240
705
120
565
190
455
945
30

360
245
710
120
570
195
460
955
30

365
245
715
120
575
195
465
965
30

1,790
1,205
3,515
600
2,825
960
2,280
4,725
150

116

ANALYTICAL PERSPECTIVES

Table 5–2. CORPORATE AND INDIVIDUAL INCOME TAX REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES—Continued
(In millions of dollars)
Revenue Loss
Corporations
1999
Credit for holders of zone academy
bonds ....................................................
1 In

2000

5

10

2001

20

2002

35

2003

50

Individuals
2004

65

2005

70

2001–
2005

1999

2000

2001

2002

2003

2004

2005

2001–
2005

240 ............ ............ ............ ............ .............. .............. .............. ..............

addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003
$815; 2004 $825; and 2005 $830.
2 The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004
$450; and 2005 $420.
3 The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $25,632; 2000 $25,676; 2001 $25,799; 2002
$26,876; 2003 $27,638; 2004 $28,701; and 2005 $29,722.
Note: Provisions with estimates denoted normal tax method have no revenue loss under the reference tax law method. All estimates have been rounded to the nearest $5 million. Provisions with estimates that rounded to zero in each year are not included in the table.

117

5. TAX EXPENDITURES

Table 5–3. MAJOR TAX EXPENDITURES IN THE INCOME TAX, RANKED BY TOTAL 2001 REVENUE LOSS
(In millions of dollars)
Provision
Net exclusion of pension contributions and earnings: Employer plans .............................................................................
Exclusion of employer contributions for medical insurance premiums and medical care .................................................
Deductibility of mortgage interest on owner-occupied homes ............................................................................................
Deductibility of nonbusiness State and local taxes other than on owner-occupied homes ..............................................
Capital gains (except agriculture, timber, iron ore, and coal) (normal tax method) ..........................................................
Accelerated depreciation of machinery and equipment (normal tax method) ...................................................................
Step-up basis of capital gains at death ..............................................................................................................................
Deductibility of charitable contributions, total ......................................................................................................................
Exclusion of interest on public purpose bonds ...................................................................................................................
Deductibility of State and local property tax on owner-occupied homes ...........................................................................
Child credit 2 .........................................................................................................................................................................
Capital gains exclusion on home sales ...............................................................................................................................
Exclusion of Social Security benefits for retired workers ...................................................................................................
Exclusion of interest on life insurance savings ...................................................................................................................
Net exclusion of pension contributions and earnings: Individual Retirement Accounts ....................................................
Deferral of income from controlled foreign corporations (normal tax method) ..................................................................
Graduated corporation income tax rate (normal tax method) ............................................................................................
Net exclusion of pension contributions and earnings: Keogh plans ..................................................................................
Exclusion of workers’ compensation benefits ......................................................................................................................
HOPE tax credit ...................................................................................................................................................................
Exclusion of interest on non-public purpose State and local debt ....................................................................................
Earned income tax credit 3 ...................................................................................................................................................
Exception from passive loss rules for $25,000 of rental loss ............................................................................................
Workers’ compensation insurance premiums ......................................................................................................................
Accelerated depreciation on rental housing (normal tax method) ......................................................................................
Exclusion of income of foreign sales corporations .............................................................................................................
Deductibility of medical expenses ........................................................................................................................................
Exclusion of Social Security benefits for dependents and survivors .................................................................................
Credit for increasing research activities ..............................................................................................................................
Exclusion of veterans death benefits and disability compensation ....................................................................................
Credit for low-income housing investments .........................................................................................................................
Exclusion of Social Security benefits for disabled ..............................................................................................................
Exclusion of income earned abroad by U.S. citizens .........................................................................................................
Tax credit for corporations receiving income from doing business in U.S. possessions ..................................................
Lifetime Learning tax credit ..................................................................................................................................................
Credit for child and dependent care expenses ...................................................................................................................
Exclusion of benefits and allowances to armed forces personnel .....................................................................................
Expensing of certain small investments (normal tax method) ............................................................................................
Exclusion of reimbursed employee parking expenses ........................................................................................................
Additional deduction for the elderly .....................................................................................................................................
Expensing of research and experimentation expenditures (normal tax method) ..............................................................
Exclusion of other employee benefits: Premiums on group term life insurance ...............................................................
Exemption of credit union income .......................................................................................................................................
Self-employed medical insurance premiums .......................................................................................................................
Deferred taxes for financial firms on certain income earned overseas .............................................................................
Special ESOP rules ..............................................................................................................................................................
Inventory property sales source rules exception .................................................................................................................
Exclusion of scholarship and fellowship income (normal tax method) ..............................................................................
Deferral of interest on U.S. savings bonds .........................................................................................................................
Deferral of income from post-1987 installment sales .........................................................................................................
Parental personal exemption for students age 19 or over .................................................................................................
Alternative fuel production credit .........................................................................................................................................
Exclusion of employee meals and lodging (other than military) ........................................................................................
Exclusion of employer-provided child care ..........................................................................................................................
Capital gains treatment of certain income from agriculture ................................................................................................
Exclusion of certain allowances for Federal employees abroad ........................................................................................
Expensing of multiperiod timber growing costs ...................................................................................................................
Excess of percentage over cost depletion, fuels and nonfuel minerals ............................................................................
Empowerment zones and enterprise communities .............................................................................................................
Work opportunity tax credit ..................................................................................................................................................
Exclusion of railroad retirement system benefits ................................................................................................................
Exclusion of public assistance benefits (normal tax method) ............................................................................................
Exclusion of parsonage allowances .....................................................................................................................................
Deductibility of student-loan interest ....................................................................................................................................
Enhanced oil recovery credit ...............................................................................................................................................
Deductibility of casualty losses ............................................................................................................................................
Exclusion of employer-provided educational assistance .....................................................................................................
Tax incentives for preservation of historic structures .........................................................................................................
Tax exemption of certain insurance companies owned by tax-exempt organizations ......................................................

2001
92,390
80,570
60,925
42,390
41,780
32,830
28,240
26,555
23,205
23,075
19,480
19,095
18,885
16,130
15,975
6,600
6,275
5,895
5,785
5,125
4,850
4,790
4,790
4,555
4,225
4,160
4,160
4,050
3,360
3,200
3,195
2,830
2,790
2,670
2,420
2,360
2,160
1,925
1,895
1,890
1,885
1,780
1,650
1,380
1,290
1,205
1,150
1,120
1,115
1,035
1,015
905
710
700
695
695
530
525
500
465
410
375
365
310
295
275
250
240
235

2001–2005
513,775
456,085
331,245
238,745
221,685
174,160
152,955
145,225
118,365
124,810
90,995
101,390
99,130
94,175
87,635
37,350
32,750
33,290
31,575
24,965
24,720
26,160
21,660
25,440
23,610
23,950
23,630
20,825
14,150
17,510
16,925
16,145
16,485
13,070
18,350
11,520
11,000
9,610
10,530
9,970
10,595
9,345
9,480
11,110
1,830
6,540
6,750
5,705
6,175
5,375
5,515
2,125
3,880
3,845
3,805
3,805
2,920
2,745
1,855
1,160
2,105
2,025
2,090
1,860
1,990
1,490
425
1,330
1,245

118

ANALYTICAL PERSPECTIVES

Table 5–3. MAJOR TAX EXPENDITURES IN THE INCOME TAX, RANKED BY TOTAL 2001 REVENUE LOSS—
Continued
(In millions of dollars)
Provision
Deferral for State prepaid tuition plans ...............................................................................................................................
Amortization of start-up costs (normal tax method) ............................................................................................................
Exclusion of other employee benefits: Premiums on accident and disability insurance ...................................................
Special Blue Cross/Blue Shield deduction ..........................................................................................................................
Carryover basis of capital gains on gifts .............................................................................................................................
Expensing of environmental remediation costs ...................................................................................................................
Exclusion for employer-provided transit passes ..................................................................................................................
Exceptions from imputed interest rules ...............................................................................................................................
Adoption assistance ..............................................................................................................................................................
Exclusion of military disability pensions ..............................................................................................................................
Tax credit and deduction for clean-fuel burning vehicles ...................................................................................................
Small life insurance company deduction .............................................................................................................................
Expensing of certain multiperiod production costs ..............................................................................................................
Exclusion of GI bill benefits .................................................................................................................................................
Tax credit for orphan drug research ....................................................................................................................................
Welfare-to-work tax credit ....................................................................................................................................................
Income averaging for farmers ..............................................................................................................................................
New technology credit ..........................................................................................................................................................
Exclusion from income of conservation subsidies provided by public utilities ...................................................................
Exclusion of veterans pensions ...........................................................................................................................................
Expensing of certain capital outlays ....................................................................................................................................
Capital gains treatment of royalties on coal .......................................................................................................................
Exclusion of special benefits for disabled coal miners .......................................................................................................
Capital gains treatment of certain timber income ...............................................................................................................
Exemption of certain mutuals’ and cooperatives’ income ..................................................................................................
Credit for disabled access expenditures .............................................................................................................................
Excess bad debt reserves of financial institutions ..............................................................................................................
Ordinary income treatment of loss from small business corporation stock sale ...............................................................
Exclusion of certain foster care payments ..........................................................................................................................
Tax credit for the elderly and disabled ...............................................................................................................................
Medical Savings Accounts ...................................................................................................................................................
Additional deduction for the blind ........................................................................................................................................
Investment credit for rehabilitation of structures (other than historic) ................................................................................
Education Individual Retirement Accounts ..........................................................................................................................
Exception from passive loss limitation for working interests in oil and gas properties .....................................................
Credit for holders of zone academy bonds .........................................................................................................................
Expensing of exploration and development costs, nonfuel minerals .................................................................................
Cancellation of indebtedness ...............................................................................................................................................
Alcohol fuel credits 1 .............................................................................................................................................................
Exclusion of interest on savings bonds redeemed to finance educational expenses .......................................................
Deferral of tax on shipping companies ...............................................................................................................................
Deferral of gain on sale of farm refiners .............................................................................................................................
Investment credit and seven-year amortization for reforestation expenditures .................................................................
Treatment of loans forgiven for solvent farmers .................................................................................................................
Capital gains exclusion of small corporation stock .............................................................................................................
Special alternative tax on small property and casualty insurance companies ..................................................................
Expensing of costs of removing certain architectural barriers to the handicapped ..........................................................
Income of trusts to finance supplementary unemployment benefits ..................................................................................
Expensing of exploration and development costs, fuels ....................................................................................................
Accelerated depreciation of buildings other than rental housing (normal tax method) .....................................................

2001

2001–2005

225
205
205
200
195
175
170
160
140
135
105
100
90
90
90
80
80
80
80
75
75
70
70
70
60
55
55
40
40
35
30
30
30
25
25
20
20
15
15
15
15
10
10
10
5
5
5
0
–30
–435

1,555
1,080
1,125
1,075
1,060
140
1,070
820
330
710
360
510
510
480
575
255
410
435
415
415
405
380
320
380
325
285
160
200
230
175
145
165
150
310
125
240
100
95
75
85
75
65
70
50
25
25
25
20
5
–6,145

1 In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as follows: 1999
$760; 2000 $800; 2001 $805; 2002 $810; 2003 $815; 2004 $825; and 2005 $830.
2 The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $445; 2000
$550; 2001 $520; 2002 $505; 2003 $460; 2004 $450; and 2005 $420.
3 The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999
$25,630; 2000 $25,675; 2001 $25,800; 2002 $26,875; 2003 $27,640; 2004 $28,700; and 2005 $29,720.
Note: Provisions with estimates denoted ‘‘normal tax method’’ have no revenue loss under the reference tax law method. All estimates have been rounded to the nearest $5 million. Provisions with estimates that rounded to zero in each year are not included in the table.
Note: Three categories in the table are aggregated: Deductibility of charitable contributions, exclusion of interest for non-public purpose State and local
debt, and excess of percentage over cost depletion for fuels and nonfuel minerals.

119

5. TAX EXPENDITURES

Table 5–4. PRESENT VALUE OF SELECTED TAX EXPENDITURES FOR ACTIVITY IN
CALENDAR YEAR 1999
(In millions of dollars)
Present
Value of
Revenue
Loss

Provision

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

Deferral of income from controlled foreign corporations (normal tax method) ...................................................
Deferred taxes for financial firms on income earned overseas ..........................................................................
Expensing of research and experimentation expenditures (normal tax method) ...............................................
Expensing of exploration and development costs—fuels ....................................................................................
Expensing of exploration and development costs—nonfuels ..............................................................................
Expensing of multiperiod timber growing costs ...................................................................................................
Expensing of certain multiperiod production costs—agriculture ..........................................................................
Expensing of certain capital outlays—agriculture ................................................................................................
Deferral of income on life insurance and annuity contracts ................................................................................
Accelerated depreciation of rental housing (normal tax method) .......................................................................
Accelerated depreciation of buildings other than rental housing (normal tax method) ......................................
Accelerated depreciation of machinery and equipment (normal tax method) ....................................................
Expensing of certain small investments (normal tax method) ............................................................................
Amortization of start-up costs (normal tax method) .............................................................................................
Deferral of tax on shipping companies ................................................................................................................
Deferral for state prepaid tuition plans .................................................................................................................
Credit for holders of zone academy bonds .........................................................................................................
Credit for low-income housing investments .........................................................................................................
Exclusion of pension contributions—employer plans ...........................................................................................
Exclusion of IRA contributions and earnings .......................................................................................................
Exclusion of contributions and earnings for Keogh plans ...................................................................................
Exclusion of interest on public-purpose bonds ....................................................................................................
Exclusion of interest on non-public purpose bonds .............................................................................................
Deferral of interest on U.S. savings bonds ..........................................................................................................

Outlay Equivalents
The concept of ‘‘outlay equivalents’’ complements
‘‘revenue losses’’ as a measure of the budget effect of
tax expenditures. It is the amount of outlay that would
be required to provide the taxpayer the same aftertax income as would be received through the tax preference. The outlay-equivalent measure allows a comparison of the cost of the tax expenditure with that
of a direct Federal outlay. Outlay equivalents are reported in Table 5–5.
The outlay-equivalent measure is larger than the revenue-loss estimate when the tax expenditure is judged
to function as a Government payment for service. This

5,960
965
2,570
110
10
240
90
75
22,100
2,845
335
32,780
1,030
170
15
170
220
2,730
95,620
6,005
3,510
26,995
3,950
405

occurs because an outlay program would increase the
taxpayer’s pre-tax income. For some tax expenditures,
however, the revenue loss equals the outlay equivalent
measure. This occurs when the tax expenditure is
judged to function like a price reduction or tax deferral
that does not directly enter the taxpayer’s pre-tax income.1
1 Budget outlay figures generally reflect the pre-tax price of the resources. In some instances, however, Government purchases or subsidies are exempted from tax by a special
tax provision. When this occurs, the outlay figure understates the resource cost of the
program and is, therefore, not comparable with other outlay amounts. For example, the
outlays for certain military personnel allowances are not taxed. If this form of compensation
were treated as part of the employee’s taxable income, the Defense Department would
have to make larger cash payments to its military personnel to leave them as well off
after tax as they are now. The tax subsidy must be added to the tax-exempt budget
outlay to make this element of national defense expenditures comparable with other outlays.

120

ANALYTICAL PERSPECTIVES

Table 5–5. OUTLAY EQUIVALENT ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX
(In millions of dollars)
Outlay Equivalents
1999

2000

2001

2002

2003

2004

2005

2001–2005

1

National Defense
Exclusion of benefits and allowances to armed forces personnel .......................................................

2,470

2,495

2,520

2,545

2,570

2,600

2,630

12,865

2
3
4
5
6

International affairs:
Exclusion of income earned abroad by U.S. citizens ...........................................................................
Exclusion of income of foreign sales corporations ................................................................................
Inventory property sales source rules exception ...................................................................................
Deferral of income from controlled foreign corporations (normal tax method) ....................................
Deferred taxes for financial firms on income earned overseas ............................................................

3,940
5,600
1,620
5,800
960

4,270
5,980
1,690
6,200
1,190

4,625
6,400
1,770
6,600
1,290

5,000
6,860
1,920
7,000
540

5,370
7,340
2,080
7,450
0

5,760
7,850
2,230
7,900
0

6,185
8,400
2,380
8,400
0

26,940
36,850
10,380
37,350
1,830

7
8

General science, space, and technology:
Expensing of research and experimentation expenditures (normal tax method) .................................
Credit for increasing research activities .................................................................................................

1,890
2,625

1,865
1,550

1,875
5,175

1,960
5,710

2,090
4,570

2,245
4,010

2,415
2,320

10,585
21,785

9
10
11
12
13
14
15
16
17
18
19

Energy:
Expensing of exploration and development costs, fuels .......................................................................
Excess of percentage over cost depletion, fuels ..................................................................................
Alternative fuel production credit ............................................................................................................
Exception from passive loss limitation for working interests in oil and gas properties .......................
Capital gains treatment of royalties on coal ..........................................................................................
Exclusion of interest on energy facility bonds .......................................................................................
Enhanced oil recovery credit ..................................................................................................................
New technology credit ............................................................................................................................
Alcohol fuel credits 1 ...............................................................................................................................
Tax credit and deduction for clean-fuel burning vehicles .....................................................................
Exclusion from income of conservation subsidies provided by public utilities .....................................

–80
325
1,495
30
85
165
315
70
15
110
115

–20
330
1,400
25
85
165
360
85
15
125
110

–30
335
1,315
25
95
165
415
120
15
135
105

–10
340
1,235
25
95
170
480
130
15
125
110

15
345
775
25
100
170
550
125
15
105
115

15
350
180
25
105
170
635
125
15
70
115

15
355
180
25
115
170
730
125
15
25
115

5
1,725
3,685
125
510
845
2,810
625
75
460
560

20
21
22
23
24
25
26

Natural resources and environment:
Expensing of exploration and development costs, nonfuel minerals ....................................................
Excess of percentage over cost depletion, nonfuel minerals ...............................................................
Exclusion of interest on bonds for water, sewage, and hazardous waste facilities ............................
Capital gains treatment of certain timber income .................................................................................
Expensing of multiperiod timber growing costs .....................................................................................
Investment credit and seven-year amortization for reforestation expenditures ....................................
Tax incentives for preservation of historic structures ............................................................................

15
275
660
85
495
15
205

15
285
660
85
500
15
225

15
295
670
95
530
15
240

15
310
680
95
565
15
255

15
320
685
100
585
15
265

20
335
685
105
610
15
280

20
350
705
115
630
15
295

85
1,610
3,425
510
2,920
75
1,335

27
28
29
30
31
32

Agriculture:
Expensing of certain capital outlays ......................................................................................................
Expensing of certain multiperiod production costs ................................................................................
Treatment of loans forgiven for solvent farmers ...................................................................................
Capital gains treatment of certain income .............................................................................................
Income averaging for farmers ................................................................................................................
Deferral of gain on sale of farm refiners ...............................................................................................

65
85
10
845
75
10

70
85
10
885
75
10

75
90
10
925
80
10

75
95
10
965
80
10

80
100
10
1,015
80
15

85
105
10
1,060
85
15

85
110
10
1,105
85
15

400
500
50
5,070
410
65

1,910
75
13,920
5
295
135

2,015
85
14,985
5
300
135

2,160
70
16,130
5
315
135

2,320
55
17,365
5
320
135

2,490
40
18,870
5
335
135

2,675
25
20,130
5
340
140

2,865
5
21,680
5
355
140

12,510
195
94,175
25
1,665
685

1,300
220
56,920
21,215
995
22,500
5,315
0
3,710

1,310
220
58,815
22,185
1,015
23,175
5,035
0
3,985

1,320
230
60,925
23,075
1,035
23,870
4,790
0
4,225

1,330
230
63,240
24,000
1,055
24,590
4,555
5
4,495

1,345
230
65,955
24,980
1,075
25,325
4,330
5
4,760

1,365
230
68,965
25,915
1,095
26,090
4,100
5
4,975

1,370
230
72,160
26,840
1,115
26,870
3,885
5
5,145

6,730
1,150
331,245
124,810
5,375
126,745
21,660
20
23,600

40
160
52,540
5
34,400
175
45
1,655

25
160
54,100
5
36,120
185
45
705

15
160
55,705
5
37,655
195
55
–435

15
165
57,365
5
39,160
205
55
–755

20
165
59,065
5
40,725
210
55
–1,110

20
165
60,820
5
42,355
220
55
–1,695

25
165
62,620
5
44,045
230
55
–2,140

95
820
295,575
25
203,940
1,060
275
–6,135

33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55

Commerce and housing:
Financial institutions and insurance:
Exemption of credit union income .....................................................................................................
Excess bad debt reserves of financial institutions ............................................................................
Exclusion of interest on life insurance savings .................................................................................
Special alternative tax on small property and casualty insurance companies ................................
Tax exemption of certain insurance companies owned by tax-exempt organizations ....................
Small life insurance company deduction ...........................................................................................
Housing:
Exclusion of interest on owner-occupied mortgage subsidy bonds .................................................
Exclusion of interest on rental housing bonds ..................................................................................
Deductibility of mortgage interest on owner-occupied homes ..........................................................
Deductibility of State and local property tax on owner-occupied homes .........................................
Deferral of income from post-1987 installment sales .......................................................................
Capital gains exclusion on home sales .............................................................................................
Exception from passive loss rules for $25,000 of rental loss ..........................................................
Credit for low-income housing investments .......................................................................................
Accelerated depreciation on rental housing (normal tax method) ....................................................
Commerce:
Cancellation of indebtedness .............................................................................................................
Exceptions from imputed interest rules .............................................................................................
Capital gains (except agriculture, timber, iron ore, and coal) (normal tax method) ........................
Capital gains exclusion of small corporation stock ...........................................................................
Step-up basis of capital gains at death ............................................................................................
Carryover basis of capital gains on gifts ...........................................................................................
Ordinary income treatment of loss from small business corporation stock sale .............................
Accelerated depreciation of buildings other than rental housing (normal tax method) ...................

121

5. TAX EXPENDITURES

Table 5–5. OUTLAY EQUIVALENT ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX—Continued
(In millions of dollars)
Outlay Equivalents
1999

2000

2001

2002

2003

2004

2005

2001–2005

56
57
58
59
60

Accelerated depreciation of machinery and equipment (normal tax method) .................................
Expensing of certain small investments (normal tax method) ..........................................................
Amortization of start-up costs (normal tax method) ..........................................................................
Graduated corporation income tax rate (normal tax method) ..........................................................
Exclusion of interest on small issue bonds .......................................................................................

26,440
1,465
200
9,790
445

27,735
1,590
205
9,690
450

32,825
1,920
205
9,655
450

33,340
1,965
215
9,940
460

34,260
1,915
215
9,985
460

36,380
1,890
220
10,325
465

37,325
1,900
225
10,485
475

174,130
9,590
1,080
50,390
2,310

61
62
63

Transportation:
Deferral of tax on shipping companies ..................................................................................................
Exclusion of reimbursed employee parking expenses ..........................................................................
Exclusion for employer-provided transit passes ....................................................................................

20
2,225
180

20
2,330
205

20
2,450
235

20
2,575
265

20
2,710
295

20
2,855
330

20
3,005
360

100
13,595
1,485

64
65
66
67
68

Community and regional development:
Investment credit for rehabilitation of structures (other than historic) ..................................................
Exclusion of interest for airport, dock, and similar bonds .....................................................................
Exemption of certain mutuals’ and cooperatives’ income .....................................................................
Empowerment zones and enterprise communities ................................................................................
Expensing of environmental remediation costs .....................................................................................

25
1,045
60
325
150

25
1,050
60
445
200

25
1,060
60
500
235

25
1,075
65
470
80

25
1,085
65
325
–40

25
1,095
65
300
–50

30
1,105
70
265
–40

130
5,420
325
1,860
185

1,190
5,890
2,780
0
300
120
355
845
5
15
1,010
25,915
3,435
275

1,220
6,310
3,045
10
335
175
360
855
15
20
1,070
26,100
3,685
290

1,235
6,570
3,100
25
390
225
365
860
30
20
1,125
25,975
3,850
310

1,240
6,595
3,160
40
440
275
365
860
50
20
1,165
25,290
4,040
215

1,255
6,080
5,645
60
470
320
365
875
75
20
1,225
24,205
4,250
0

1,265
5,915
5,675
80
495
355
370
880
90
30
1,280
23,385
4,395
0

1,280
6,845
5,935
105
535
385
370
890
100
30
1,310
22,475
4,610
0

6,275
32,005
23,515
310
2,330
1,560
1,835
4,365
345
120
6,105
121,330
21,145
525

83
84
85
86
87
88
89
90
91
92
93

Education, training, employment, and social services:
Education:
Exclusion of scholarship and fellowship income (normal tax method) ............................................
HOPE tax credit ..................................................................................................................................
Lifetime Learning tax credit ................................................................................................................
Education Individual Retirement Accounts ........................................................................................
Deductibility of student-loan interest ..................................................................................................
Deferral for State prepaid tuition plans .............................................................................................
Exclusion of interest on student-loan bonds .....................................................................................
Exclusion of interest on bonds for private nonprofit educational facilities .......................................
Credit for holders of zone academy bonds .......................................................................................
Exclusion of interest on savings bonds redeemed to finance educational expenses .....................
Parental personal exemption for students age 19 or over ...............................................................
Child credit 2 ........................................................................................................................................
Deductibility of charitable contributions (education) ..........................................................................
Exclusion of employer-provided educational assistance ...................................................................
Training, employment, and social services:
Work opportunity tax credit ................................................................................................................
Welfare-to-work tax credit ..................................................................................................................
Exclusion of employer provided child care ........................................................................................
Adoption assistance ............................................................................................................................
Exclusion of employee meals and lodging (other than military) ......................................................
Credit for child and dependent care expenses .................................................................................
Credit for disabled access expenditures ...........................................................................................
Expensing of costs of removing certain architectural barriers to the handicapped ........................
Deductibility of charitable contributions, other than education and health .......................................
Exclusion of certain foster care payments ........................................................................................
Exclusion of parsonage allowances ...................................................................................................

270
35
860
160
795
3,225
65
0
25,750
45
395

455
60
890
175
830
3,185
65
0
26,955
50
420

465
80
930
180
865
3,145
75
5
28,115
50
450

350
80
970
160
905
3,110
75
5
29,380
55
480

215
60
1,020
55
945
3,075
75
5
30,790
55
515

95
25
1,075
20
990
3,035
80
5
32,200
60
550

35
10
1,135
10
1,030
3,000
80
5
33,755
60
585

1,160
255
5,130
425
4,735
15,365
385
25
154,240
280
2,580

94
95
96
97
98
99
100
101
102

Health:
Exclusion of employer contributions for medical insurance premiums and medical care ...................
Self-employed medical insurance premiums .........................................................................................
Workers’ compensation insurance premiums ........................................................................................
Medical Savings Accounts ......................................................................................................................
Deductibility of medical expenses ..........................................................................................................
Exclusion of interest on hospital construction bonds ............................................................................
Deductibility of charitable contributions (health) ....................................................................................
Tax credit for orphan drug research ......................................................................................................
Special Blue Cross/Blue Shield deduction .............................................................................................

88,730
1,145
5,520
30
3,695
1,735
3,640
70
325

95,950
1,535
5,730
40
3,910
1,755
3,910
80
420

103,085
1,700
5,945
45
4,160
1,770
4,095
90
270

110,390
1,900
6,170
45
4,440
1,790
4,300
100
180

115,840
2,550
6,400
45
4,720
1,815
4,525
115
240

122,545
3,580
6,645
40
5,005
1,830
4,665
130
325

131,495
3,955
3,895
35
5,305
1,850
4,900
140
420

583,355
13,685
29,055
210
23,630
9,055
22,485
575
1,435

395
5,185
345
75
130

405
5,330
360
75
130

410
5,785
375
70
135

415
6,040
390
70
140

420
6,310
405
65
140

430
6,575
420
60
145

430
6,865
435
55
150

2,105
31,575
2,025
320
710

97,960
18,290
6,630

104,060
20,025
7,040

108,190
21,360
7,475

113,770
22,770
7,930

120,275
23,695
8,415

126,700
24,645
8,925

133,400
25,445
9,465

602,335
117,915
42,210

2,240

2,290

2,340

2,395

2,445

2,520

2,590

12,290

69
70
71
72
73
74
75
76
77
78
79
80
81
82

103
104
105
106
107
108
109
110
111

Income security:
Exclusion of railroad retirement system benefits ...................................................................................
Exclusion of workers’ compensation benefits ........................................................................................
Exclusion of public assistance benefits (normal tax method) ...............................................................
Exclusion of special benefits for disabled coal miners .........................................................................
Exclusion of military disability pensions .................................................................................................
Net exclusion of pension contributions and earnings:
Employer plans ...................................................................................................................................
Individual Retirement Accounts ..........................................................................................................
Keogh plans ........................................................................................................................................
Exclusion of other employee benefits:
Premiums on group term life insurance ............................................................................................

122

ANALYTICAL PERSPECTIVES

Table 5–5. OUTLAY EQUIVALENT ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX—Continued
(In millions of dollars)
Outlay Equivalents
1999

2000

2001

2002

2003

2004

2005

2001–2005

112
113
114
115
116
117
118
119

Premiums on accident and disability insurance ................................................................................
Income of trusts to finance supplementary unemployment benefits ....................................................
Special ESOP rules ................................................................................................................................
Additional deduction for the blind ...........................................................................................................
Additional deduction for the elderly ........................................................................................................
Tax credit for the elderly and disabled ..................................................................................................
Deductibility of casualty losses ..............................................................................................................
Earned income tax credit 3 .....................................................................................................................

235
0
1,565
35
2,155
45
280
5,360

250
0
1,630
35
2,215
45
290
5,220

260
0
1,670
40
2,285
45
300
5,320

275
5
1,730
40
2,360
45
315
5,540

290
5
1,800
40
2,400
45
325
5,785

305
5
1,885
45
2,455
45
340
6,045

315
5
1,975
45
2,555
45
355
6,380

1,445
20
9,060
210
12,055
225
1,635
29,070

120
121
122

Social Security:
Exclusion of social security benefits:
Social Security benefits for retired workers .......................................................................................
Social Security benefits for disabled .................................................................................................
Social Security benefits for dependents and survivors .....................................................................

17,135
2,390
3,775

18,010
2,595
3,900

18,885
2,830
4,050

19,995
3,090
4,210

21,230
3,375
4,385

22,505
3,700
4,555

16,515
3,150
3,625

99,130
16,145
20,825

123
124
125
126

Veterans benefits and services:
Exclusion of veterans death benefits and disability compensation ......................................................
Exclusion of veterans pensions ..............................................................................................................
Exclusion of GI bill benefits ....................................................................................................................
Exclusion of interest on veterans housing bonds .................................................................................

2,940
65
75
60

3,070
70
85
60

3,200
75
90
60

3,335
80
90
60

3,490
85
95
60

3,655
85
100
60

3,830
90
105
60

17,510
415
480
300

127
128
129

General purpose fiscal assistance:
Exclusion of interest on public purpose bonds .....................................................................................
Deductibility of nonbusiness State and local taxes other than on owner-occupied homes ................
Tax credit for corporations receiving income from doing business in U.S. possessions ....................

32,600
37,740
3,590

32,925
40,240
3,700

33,250
42,390
3,815

33,590
44,735
3,715

33,920
47,610
3,640

34,255
50,530
3,715

34,600
53,480
3,785

169,615
238,745
18,670

130

Interest:
Deferral of interest on U.S. savings bonds ...........................................................................................

1,015

1,065

1,115

1,175

1,235

1,295

1,355

6,175

21,215
37,740

22,185
40,240

23,075
42,390

24,000
44,735

24,980
47,610

25,915
50,530

26,840
53,480

124,810
238,745

32,600
165
660
445
1,300
220
1,045
355
845
1,735
60
5

32,925
165
660
450
1,310
220
1,050
360
855
1,755
60
15

33,250
165
670
450
1,320
230
1,060
365
860
1,770
60
30

33,590
170
680
460
1,330
230
1,075
365
860
1,790
60
50

33,920
170
685
460
1,345
230
1,085
365
875
1,815
60
75

34,255
170
685
465
1,365
230
1,095
370
880
1,830
60
90

34,600
170
705
475
1,370
230
1,105
370
890
1,850
60
100

169,615
845
3,425
2,310
6,730
1,150
5,420
1,835
4,365
9,055
300
345

Addendum: Aid to State and local governments:
Deductibility of:
Property taxes on owner-occupied homes ........................................................................................
Nonbusiness State and local taxes other than on owner-occupied homes .....................................
Exclusion of interest on State and local bonds for:
Public purposes ..................................................................................................................................
Energy facilities ...................................................................................................................................
Water, sewage, and hazardous waste disposal facilities .................................................................
Small-issues ........................................................................................................................................
Owner-occupied mortgage subsidies .................................................................................................
Rental housing ....................................................................................................................................
Airports, docks, and similar facilities .................................................................................................
Student loans ......................................................................................................................................
Private nonprofit educational facilities ...............................................................................................
Hospital construction ..........................................................................................................................
Veterans’ housing ...............................................................................................................................
Credit for holders of zone academy bonds ...........................................................................................

1 In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003
$815; 2004 $825; and 2005 $830.
2 The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004
$450; and 2005 $420.
3 The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $25,632; 2000 $25,676; 2001 $25,799; 2002
$26,876; 2003 $27,638; 2004 $28,701; and 2005 $29,722.
Note: Provisions with estimates denoted normal tax method have no revenue loss under the reference tax law method. All estimates have been rounded to the nearest $5 million. Provisions with estimates that rounded to zero in each year are not included in the table.

5. TAX EXPENDITURES

Tax Expenditure Baselines
A tax expenditure is a preferential exception to the
baseline provisions of the tax structure. The 1974 Congressional Budget Act did not, however, specify the
baseline provisions of the tax law. Deciding whether
provisions are preferential exceptions, therefore, is a
matter of judgment. As in prior years, this year’s tax
expenditure estimates are presented using two baselines: the normal tax baseline, which is used by the
Joint Committee on Taxation, and the reference tax
law baseline, which has been reported by the Administration since 1983.
The normal tax baseline is patterned on a comprehensive income tax, which defines income as the
sum of consumption and the change in net wealth in
a given period of time. The normal tax baseline allows
personal exemptions, a standard deduction, and deductions of the expenses incurred in earning income. It
is not limited to a particular structure of tax rates,
or by a specific definition of the taxpaying unit.
The reference tax law baseline is also patterned on
a comprehensive income tax, but is closer to existing
law. Reference law tax expenditures are limited to special exceptions in the tax code that serve programmatic
functions. These functions correspond to specific budget
categories such as national defense, agriculture, or
health care. Tax expenditures under the reference law
baseline are generally tax expenditures under the normal tax baseline, but the reverse is not always true.
Both the normal and reference tax baselines allow
several major departures from a pure comprehensive
income tax. For example:
• Income is taxable only when it is realized in exchange. Thus, neither the deferral of tax on unrealized capital gains nor the tax exclusion of imputed income (such as the rental value of owneroccupied housing or farmers’ consumption of their
own produce) is regarded as a tax expenditure.
Both accrued and imputed income would be taxed
under a comprehensive income tax.
• There is a separate corporation income tax. Under
a comprehensive income tax, corporate income
would be taxed only once—at the shareholder
level, whether or not distributed in the form of
dividends.
• Values of assets and debt are not adjusted for
inflation. A comprehensive income tax would adjust the cost basis of capital assets and debt for
changes in the price level during the time the
assets or debt are held. Thus, under a comprehensive income tax baseline, the failure to take account of inflation in measuring depreciation, capital gains, and interest income would be regarded
as a negative tax expenditure (i.e., a tax penalty),
and failure to take account of inflation in measuring interest costs would be regarded as a positive tax expenditure (i.e., a tax subsidy).
Although the reference law and normal tax baselines
are generally similar, areas of difference include:

123
• Tax rates. The separate schedules applying to the
various taxpaying units are included in the reference law baseline. Thus, corporate tax rates
below the maximum statutory rate do not give
rise to a tax expenditure. The normal tax baseline
is similar, except that it specifies the current maximum rate as the baseline for the corporate income tax. The lower tax rates applied to the first
$10 million of corporate income are thus regarded
as a tax expenditure. Similarly, under the reference law baseline, preferential tax rates for capital gains generally do not yield a tax expenditure;
only capital gains treatment of otherwise ‘‘ordinary income,’’ such as that from coal and iron
ore royalties and the sale of timber and certain
agricultural products, is considered a tax expenditure. The alternative minimum tax is treated as
part of the baseline rate structure under both the
reference and normal tax methods.
• Income subject to the tax. Income subject to tax
is defined as gross income less the costs of earning
that income. The Federal income tax defines gross
income to include: (1) consideration received in
the exchange of goods and services, including labor
services or property; and (2) the taxpayer’s share
of gross or net income earned and/or reported by
another entity (such as a partnership). Under the
reference tax rules, therefore, gross income does
not include gifts—defined as receipts of money or
property that are not consideration in an exchange—or most transfer payments, which can be
thought of as gifts from the Government.2 The
normal tax baseline also excludes gifts between
individuals from gross income. Under the normal
tax baseline, however, all cash transfer payments
from the Government to private individuals are
counted in gross income, and exemptions of such
transfers from tax are identified as tax expenditures. The costs of earning income are generally
deductible in determining taxable income under
both the reference and normal tax baselines.3
• Capital recovery. Under the reference tax law
baseline no tax expenditures arise from accelerated depreciation. Under the normal tax baseline,
the depreciation allowance for machinery and
equipment is determined using straight-line depreciation over tax lives equal to mid-values of
the asset depreciation range (a depreciation system in effect from 1971 through 1980). The normal
tax baseline for real property is computed using
40-year straight-line depreciation.
• Treatment of foreign income. Both the normal and
reference tax baselines allow a tax credit for foreign income taxes paid (up to the amount of U.S.
2 Gross income does, however, include transfer payments associated with past employment,
such as social security benefits.
3 In the case of individuals who hold ‘‘passive’’ equity interests in businesses, however,
the pro-rata shares of sales and expense deductions reportable in a year are limited. A
passive business activity is defined to be one in which the holder of the interest, usually
a partnership interest, does not actively perform managerial or other participatory functions.
The taxpayer may generally report no larger deductions for a year than will reduce taxable
income from such activities to zero. Deductions in excess of the limitation may be taken
in subsequent years, or when the interest is liquidated.

124
income taxes that would otherwise be due), which
prevents double taxation of income earned abroad.
Under the normal tax method, however, controlled
foreign corporations (CFCs) are not regarded as
entities separate from their controlling U.S. shareholders. Thus, the deferral of tax on income received by CFCs is regarded as a tax expenditure
under this method. In contrast, except for tax
haven activities, the reference law baseline follows
current law in treating CFCs as separate taxable
entities whose income is not subject to U.S. tax
until distributed to U.S. taxpayers. Under this
baseline, deferral of tax on CFC income is not
a tax expenditure because U.S. taxpayers generally are not taxed on accrued, but unrealized,
income.
Beyond these examples, there are still more areas
of difference where the Joint Committee on Taxation
considers a somewhat broader set of tax expenditures
under its normal tax baseline than under the reference
baseline considered here.
Performance Measures and the Economic
Effects of Tax Expenditures
The Government Performance and Results Act of
1993 (GPRA) directs Federal agencies to develop annual
and strategic plans for their programs and activities.
These plans set out performance objectives to be
achieved over a specific time period. Most of these objectives will be achieved through direct expenditure programs. However, tax expenditures may also contribute
to achieving these goals. The report of the Senate Governmental Affairs Committee on GPRA 4 calls on the
Executive branch to undertake a series of analyses to
assess the effect of specific tax expenditures on the
achievement of agencies’ performance objectives.
One finding of pilot studies on selected tax expenditures undertaken by Treasury’s Office of Tax Analysis
is that much of the data needed for thorough analysis
are not currently available. Hence, assessment of data
needs and availability from Federal statistical agencies,
program-agency studies, or private-sector sources,
should prove valuable to broader efforts to assess the
effects of tax expenditures and to compare their effectiveness with other policy means of achieving important
public objectives. This effort will complement information published by the Joint Committee on Taxation and
the Senate Budget Committee on tax expenditures.5
Over the next few years, the Executive Branch’s focus
will be on the availability of the data needed to assess
the effects of the tax expenditures designed to increase
savings. As one part of this effort, Treasury’s Office
of Tax Analysis and its Statistics of Income Division
(IRS) are developing the specifications for a new data
sample which will follow the same individual income
tax filers over an extended period of time. Such a sam4 Committee on Government Affairs, United States Senate, ‘‘Government Performance and
Results Act of 1993’’ (Report 103–58, 1993).
5 Joint Committee on Taxation, ‘‘Estimates of Federal Tax Expenditures for Fiscal Years
1999–1993,’’ JCS–7–98, December 14, 1998; and Committee on the Budget, United States
Senate, ‘‘Tax Expenditures: Compendium of Background Material on Individual Provisions,’’
prepared by the Congressional Research Service (S. Prt. 104–69, December 1996).

ANALYTICAL PERSPECTIVES

ple is called a ‘‘panel’’ sample. Current economic analyses of the effect of Federal tax laws are generally
based on data from ‘‘cross-section’’ samples, which capture the demographic and economic circumstances of
individuals and the provisions of Federal tax law only
at a single point in time. However, over time, the demographic and economic status of individuals changes in
ways that can significantly change how they are affected by current (or proposed) Federal tax laws. In
addition, some provisions of the tax law have effects
over multiple years, and the effects of some tax provisions change over time due to phase-ins, phase-outs,
and other factors. The new panel sample will capture
the changing demographic and economic circumstances
of individuals and the effects of changes in tax law
over an extended period of time. Data from the panel
sample will therefore permit more extensive, and better, analyses of many tax provisions than can be performed using only cross-section data. In particular, data
from the panel sample will enhance our ability to analyze the effect of tax expenditures designed to increase
savings. Other efforts to improve data available for the
analysis of savings tax expenditures will be undertaken
over the next several years by OMB, Treasury and
other agencies.
Comparison of tax expenditure, spending, and
regulatory policies. Tax expenditures by definition
work through the tax system and, particularly, the income tax. Thus, they may be relatively advantageous
policy approaches when the benefit or incentive is related to income and is intended to be widely available.6
Because there is an existing public administrative and
private compliance structure for the tax system, the
incremental administrative and compliance costs for a
tax expenditure may be low in some cases. In addition,
some tax expenditures actually simplify the tax system
(for example, the exclusion for up to $500,000 of capital
gains on home sales). Tax expenditures also implicitly
subsidize certain activities. Spending, regulatory or taxdisincentive policies, can also modify behavior, but may
have different economic effects. Finally, a variety of
tax expenditure tools can be used—e.g., deductions,
credits, exemptions and deferrals; floors and ceilings;
and phase-ins and phase-outs, dependent on income,
expenses, or demographic characteristics (age, number
of family members, etc.). This wide range means that
tax expenditures can be flexible and can have very different economic effects.
Tax expenditures also have limitations. In many
cases they add to the complexity of the tax system,
which raises both administrative and compliance costs.
For example, various holding periods and tax rates for
capital gains can complicate filing and decisionmaking.
The income tax system may have little or no contact
with persons who have no or very low incomes, and
does not inquire into certain characteristics of individ6 Although this section focuses upon tax expenditures under the income tax, tax preferences
also arise under the unified transfer, payroll, and excise tax systems. Such preferences
can be useful when they relate to the bases of those taxes, such as an excise tax exemption
for certain types of consumption that are deemed meritorious.

5. TAX EXPENDITURES

uals used in some spending programs, such as wealth.
These features may reduce the effectiveness of tax expenditures for addressing certain income-transfer objectives. Tax expenditures also generally do not enable
the same degree of agency discretion as outlay programs. For example, grant or direct Federal service
delivery programs can prioritize which activities are
addressed with what amount of resources in a way
that is difficult to emulate with tax expenditures. Finally, tax expenditures may not receive the same frequency or level of scrutiny afforded to other programs.
Outlay programs, in contrast, have advantages where
direct government service provision is particularly warranted—such as equipping and providing the armed
forces or administering the system of justice. Outlay
programs may also be specifically designed to meet the
needs of low-income families who would not otherwise
be subject to income taxes or need to file a return.
Outlay programs may also receive more year-to-year
oversight and fine tuning through the legislative and
executive budget process. In addition, the availability
of many different types of spending programs—including direct government provision; credit programs; and
payments to State and local governments, the private
sector, or individuals in the form of grants or contracts—provides flexibility for policy design. On the
other hand, certain outlay programs—such as direct
government service provision—may rely less directly on
economic incentives and private-market provision than
tax incentives, which may reduce the relative efficiency
of spending programs for some goals. Spending programs also require resources to be raised via taxes,
user charges, or government borrowing. Finally, spending programs, particularly on the discretionary side,
may respond less readily to changing activity levels
and economic conditions than tax expenditures.
Regulations have more direct and immediate effects
than outlay and tax-expenditure programs because regulations apply directly and immediately to the regulated party (i.e., the intended actor)—generally in the
private sector. Regulations can also be fine-tuned more
quickly than tax expenditures, because they can generally be changed by the executive branch without legislation. Like tax expenditures, regulations often rely
largely upon voluntary compliance, rather than detailed
inspections and policing. As such, the public administrative costs tend to be modest, relative to the private
resource costs associated with modifying activities. Historically, regulations have tended to rely on proscriptive
measures, as opposed to economic incentives. This reliance can diminish their economic efficiency, although
this feature can also promote full compliance where
(as in certain safety-related cases) policymakers believe
that trade-offs with economic considerations are not of
paramount importance. Also, regulations generally do
not directly affect Federal outlays or receipts. Thus,
like tax expenditures, they may escape the type of scrutiny that outlay programs receive. However, most regulations are subjected to a formal type of benefit-cost
analysis that goes well beyond the analysis required

125
for outlays and tax-expenditures. To some extent, the
GPRA requirement for performance evaluation will address this lack of formal analysis.
Some policy objectives are achieved using multiple
approaches. For example, minimum wage legislation,
the earned income tax credit, and the food stamp program are regulatory, tax expenditure, and direct outlay
programs, respectively, all having the objective of improving the economic welfare of low-wage workers.
Tax expenditures, like spending and regulatory programs, have a variety of objectives and effects. These
include: encouraging certain types of activities (e.g.,
saving for retirement or investing in certain sectors);
increasing certain types of after-tax income (e.g., favorable tax treatment of social security income); reducing
private compliance costs and government administrative costs (e.g., the exclusion for up to $500,000 of capital gains on home sales); and promoting tax neutrality
(e.g., accelerated depreciation in the presence of inflation). Some of these objectives are well suited to quantitative measurement, while others are less well suited.
Also, many tax expenditures, including those cited
above, may have more than one objective. For example,
accelerated depreciation may encourage investment. In
addition, the economic effects of particular provisions
can extend beyond their intended objectives (e.g., a provision intended to promote an activity or raise certain
incomes may have positive or negative effects on tax
neutrality).
Performance measurement is generally concerned
with inputs, outputs, and outcomes. In the case of tax
expenditures, the principal input is usually the tax revenue loss. Outputs are quantitative or qualitative measures of goods and services, or changes in income and
investment, directly produced by these inputs. Outcomes, in turn, represent the changes in the economy,
society, or environment that are the ultimate goals of
programs.
Thus, for a provision that reduces taxes on certain
investment activity, an increase in the amount of investment would likely be a key output. The resulting
production from that investment, and, in turn, the associated improvements in national income, welfare, or security, could be the outcomes of interest. For other provisions, such as those designed to address a potential
inequity or unintended consequence in the tax code,
an important performance measure might be how they
change effective tax rates (the discounted present value
of taxes owed on new investments or incremental earnings) or excess burden (an economic measure of the
distortions caused by taxes). Effects on the incomes of
members of particular groups may be an important
measure for certain provisions.
An overview of evaluation issues by budget function. The discussion below considers the types of measures that might be useful for some major programmatic
groups of tax expenditures. The discussion is intended
to be illustrative and not all encompassing. However,
it is premised on the assumption that the data needed
to perform the analysis are available or can be devel-

126
oped. In practice, data availability is likely to be a
major challenge, and data constraints may limit the
assessment of the effectiveness of many provisions. In
addition, such assessments can raise significant challenges in economic modeling.
National defense.—Some tax expenditures are intended to assist governmental activities. For example,
tax preferences for military benefits reflect, among
other things, the view that benefits such as housing,
subsistence, and moving expenses are intrinsic aspects
of military service, and are provided, in part, for the
benefit of the employer, the U.S. Government. Tax benefits for combat service are intended to reduce tax burdens on military personnel undertaking hazardous service for the Nation. A portion of the tax expenditure
associated with foreign earnings is targeted to benefit
U.S. Government civilian personnel working abroad by
offsetting the living costs that can be higher than those
in the United States. These tax expenditures should
be considered together with direct agency budget costs
in making programmatic decisions.
International affairs.—Tax expenditures are also
aimed at promoting U.S. exports. These include the
exclusion for income earned abroad by nongovernmental
employees and preferences for income from exports and
U.S.-controlled foreign corporations. Measuring the effectiveness of these provisions raises challenging issues.
In addition to determining their effectiveness in markets of the benefitting firms, analysis should consider
the extent to which macroeconomic factors lead to offsetting effects, such as increased imports, which could
moderate any net effects on employment, national output, and trade deficits. Similar issues arise in the case
of export promotion programs supported by outlays.
General science, space and technology; energy;
natural resources and the environment; agriculture; and commerce and housing.—A series of
tax expenditures reduces the cost of investment, both
in specific activities—such as research and experimentation, extractive industries, and certain financial activities—and more generally, through accelerated depreciation for plant and equipment. These provisions can
be evaluated along a number of dimensions. For example, it could be useful to consider the strength of the
incentives by measuring their effects on the cost of
capital (the interest rate which investments must yield
to cover their costs) and effective tax rates. The impact
of these provisions on the amounts of corresponding
forms of investment—such as research spending, exploration activity, or equipment—might also be estimated.
In some cases, such as research, there is evidence that
the investment can provide significant positive
externalities—that is, economic benefits that are not
reflected in the market transactions between private
parties. It could be useful to quantify these externalities
and compare them with the degree of tax subsidy provided. Measures could also indicate the provisions’ effects on production from these investments—such as

ANALYTICAL PERSPECTIVES

numbers or values of patents, energy production and
reserves, and industrial production. Issues to be considered include the extent to which the preferences increase production (as opposed to benefitting existing
producers) and their cost-effectiveness relative to other
policies. Analysis could also consider objectives that are
more difficult to measure but still are ultimate goals,
such as promoting the Nation’s technological base, energy security, environmental quality, or economic
growth. Such an assessment is likely to involve tax
analysis as well as consideration of non-tax matters
such as market structure, scientific, and other information (such as the effects of increased domestic fuel production on imports from various regions, or the effects
of various energy sources on the environment).
Housing investment also benefits from tax expenditures, including the mortgage interest deduction and
preferential treatment of capital gains on homes. Measures of the effectiveness of these provisions could include their effects on increasing the extent of home
ownership and the quality of housing. In addition, the
mortgage interest deduction offsets the taxable nature
of investment income received by homeowners, so the
relationship between the deduction and such earnings
is also relevant to evaluation of this provision. Similarly, analysis of the extent of accumulated inflationary
gains is likely to be relevant to evaluation of the capital
gains preference for home sales. Deductibility of State
and local property taxes assists with making housing
more affordable as well as easing the cost of providing
community services through these taxes. Provisions intended to promote investment in rental housing could
be evaluated for their effects on making such housing
more available and affordable. These provisions should
then be compared with alternative programs that address housing supply and demand.
Transportation.—Employer-provided parking is a
fringe benefit that, for the most part, is excluded from
taxation. The tax expenditure revenue loss estimates
reflect the cost of parking that is leased by employers
for employees; an estimate is not currently available
for the value of parking owned by employers and provided to their employees. The exclusion for employerprovided transit passes is intended to promote use of
this mode of transportation, which has environmental
and congestion benefits. The tax treatments of these
different benefits could be compared with alternative
transportation policies.
Community and regional development.—A series
of tax expenditures is intended to promote community
and regional development by reducing the costs of financing specialized infrastructure, such as airports,
docks, and stadiums. Empowerment zone and enterprise community provisions are designed to promote
activity in disadvantaged areas. These provisions can
be compared with grants and other policies designed
to spur economic development.

127

5. TAX EXPENDITURES

Education, training, employment, and social
services.—Major provisions in this function are intended to promote post-secondary education, to offset
costs of raising children, and to promote a variety of
charitable activities. The education incentives can be
compared with loans, grants, and other programs designed to promote higher education and training. The
child credits are intended to adjust the tax system for
the costs of raising children; as such, they could be
compared to other Federal tax and spending policies,
including related features of the tax system, such as
personal exemptions (which are not defined as a tax
expenditure). Evaluation of charitable activities requires consideration of the beneficiaries of these activities, who are generally not the parties receiving the
tax reduction.
Health.—Individuals also benefit from favorable
treatment of employer-provided health insurance. Measures of these benefits could include increased coverage
and pooling of risks. The effects of insurance coverage
on final outcome measures of actual health (e.g., infant
mortality, days of work lost due to illness, or life expectancy) or intermediate outcomes (e.g., use of preventive
health care or health care costs) could also be investigated.
Income security, social security, and veterans
benefits and services.—Major tax expenditures in the
income security function benefit retirement savings,
through employer-provided pensions, individual retirement accounts, and Keogh plans. These provisions
might be evaluated in terms of their effects on boosting
retirement incomes, private savings, and national savings (which would include the effect on private savings
as well as public savings or deficits). Interactions with
other programs, including social security, also may
merit analysis. As in the case of employer-provided
health insurance, analysis of employer-provided pension
programs requires imputing the benefits provided at
the firm level to individuals.
Other provisions principally affect the incomes of
members of certain groups, rather than affecting incentives. For example, tax-favored treatment of social security benefits, certain veterans benefits, and deductions
for the blind and elderly provide increased incomes to
eligible parties. The earned-income tax credit, in contrast, should be evaluated for its effects on labor force
participation as well as the income it provides lowerincome workers.
General purpose fiscal assistance and interest.—
The tax-exemption for public purpose State and local
bonds reduces the costs of borrowing for a variety of
purposes (borrowing for non-public purposes is reflected
under other budget functions). The deductibility of certain State and local taxes reflected under this function
primarily relates to personal income taxes (property tax
deductibility is reflected under the commerce and housing function). Tax preferences for Puerto Rico and other
U.S. possessions are also included here. These provi-

sions can be compared with other tax and spending
policies as means of benefitting fiscal and economic conditions in the States, localities, and possessions. Finally, the tax deferral for interest on U.S. savings
bonds benefits savers who invest in these instruments.
The extent of these benefits and any effects on Federal
borrowing costs could be evaluated.
The above illustrative discussion, although broad, is
nevertheless incomplete, both for the provisions mentioned and the many that are not explicitly cited. Developing a framework that is sufficiently comprehensive,
accurate, and flexible to reflect the objectives and effects of the wide range of tax expenditures will be a
significant challenge. OMB, Treasury, and other agencies will work together, as appropriate, to address this
challenge. As indicated above, over the next few years
the Executive Branch’s focus will be on the availability
of the data needed to assess the effects of the tax expenditures designed to increase savings.
Descriptions of Income Tax Provisions
Descriptions of the individual and corporate income
tax expenditures reported upon in this chapter follow.
National Defense
1. Benefits and allowances to armed forces personnel.—The housing and meals provided military personnel, either in cash or in kind, as well as certain
amounts of pay related to combat service, are excluded
from income subject to tax.
International Affairs
2. Income earned abroad.—U.S. citizens who lived
abroad, worked in the private sector, and satisfyied
a foreign residency requirement in 1999 may exclude
up to $74,000 in foreign earned income from U.S. taxes.
The exclusion increases in 2000, 2001, and 2002 to
$76,000, $78,000, and $80,000, respectively. In addition,
if these taxpayers receive a specific allowance for foreign housing from their employers, they may also exclude the value of that allowance. If they do not receive
a specific allowance for housing expenses, they may
deduct against their U.S. taxes that portion of such
expenses that exceeds one-sixth the salary of a civil
servant at grade GS-14, step 1 ($63,567 in 1999). Beginning this year, the value of U.S. tax benefits provided
to employees of the U.S. government who live and work
overseas is not included under this heading. Those tax
benefits now are included under their own heading,
Exclusion of Certain Allowances for Federal Employees
Abroad (#3).
3. Exclusion of Certain Allowances for Federal
Employees Abroad.—U.S. Federal civilian employees
and Peace Corps members who work outside the continental United States are allowed to exclude from U.S.
taxable income certain special allowances they receive
to compensate them for the relatively high costs associated with living overseas. The allowances supplement
wage income and cover expenses like rent, education,
and the cost of travel to and from the United States.

128

ANALYTICAL PERSPECTIVES

4. Income of Foreign Sales Corporations.—The
Foreign Sales Corporation (FSC) provisions exempt
from tax a portion of U.S. exporters’ foreign trading
income to reflect the FSC’s sales functions as foreign
corporations. These provisions conform to the General
Agreement on Tariffs and Trade.
5. Sales source rule exceptions.—The worldwide
income of U.S. persons is taxable by the United States
and a credit for foreign taxes paid is allowed. The
amount of foreign taxes that can be credited is limited
to the pre-credit U.S. tax on the foreign source income.
The sales source rules for inventory property allow U.S.
exporters to use more foreign tax credits by allowing
the exporters to attribute a larger portion of their earnings abroad than would be the case if the allocation
of earnings was based on actual economic activity.
6. Income of U.S.-controlled foreign corporations.—The income of foreign corporations controlled
by U.S. shareholders is not subject to U.S. taxation.
The income becomes taxable only when the controlling
U.S. shareholders receive dividends or other distributions from their foreign stockholding. Under the normal
tax method, the currently attributable foreign source
pre-tax income from such a controlling interest is considered to be subject to U.S. taxation, whether or not
distributed. Thus, the normal tax method considers the
amount of controlled foreign corporation income not distributed to a U.S. shareholder as tax-deferred income.
7. Exceptions under subpart F for active financing income.—Financial firms can defer taxes on income earned overseas in an active business. Taxes on
income earned through December 31, 2001 can be deferred. The Tax Relief Extension Act of 1999 extended
the expiration date from December 31, 1999 to December 31, 2001.
General Science, Space, and Technology
8. Expensing R&E expenditures.—Research and
experimentation (R&E) projects can be viewed as investments because, if successful, their benefits accrue
for several years. It is often difficult, however, to identify whether a specific R&E project is successful and,
if successful, what its expected life will be. Under the
normal tax method, the expensing of R&E expenditures
is viewed as a tax expenditure. The baseline assumed
for the normal tax method is that all R&E expenditures
are successful and have an expected life of five years.
9. R&E credit.—The research and experimentation
(R&E) credit, which expired on June 30, 1999, was
reinstated (retroactively) in the Tax Relief Extension
Act of 1999 for five years (through June 30, 2004).
The Act also increased the credit rates for the alternative credit by one percentage point and extended the
research credit to include research conducted in Puerto
Rico and the U.S. possessions. The tax credit is 20
percent of qualified research expenditures in excess of
a base amount. The base amount is generally determined by multiplying a ‘‘fixed-base percentage’’ by the
average amount of the company’s gross receipts for the
prior four years. The taxpayer’s fixed base percentage

generally is the ratio of its research expenses to gross
receipts for 1984 through 1988. Taxpayers may also
elect an alternative credit regime. Under the alternative credit regime the taxpayer is assigned a threetiered fixed-base percentage that is lower than the
fixed-base percentage that would otherwise apply, and
the credit rate is reduced (the rates range from 2.65
percent to 3.75 percent). A 20-percent credit with a
separate threshold is provided for a taxpayer’s payments to universities for basic research.
Energy
10. Exploration and development costs.—For successful investments in domestic oil and gas wells, intangible drilling costs (e.g., wages, the costs of using machinery for grading and drilling, the cost of
unsalvageable materials used in constructing wells)
may be expensed rather than amortized over the productive life of the property. Integrated oil companies
may deduct only 70 percent of such costs and must
amortize the remaining 30 percent over five years. The
same rule applies to the exploration and development
costs of surface stripping and the construction of shafts
and tunnels for other fuel minerals.
11. Percentage depletion.—Independent fuel mineral producers and royalty owners are generally allowed
to take percentage depletion deductions rather than
cost depletion on limited quantities of output. Under
cost depletion, outlays are deducted over the productive
life of the property based on the fraction of the resource
extracted. Under percentage depletion, taxpayers deduct a percentage of gross income from mineral production at rates of 22 percent for uranium; 15 percent
for oil, gas and oil shale; and 10 percent for coal. The
deduction is limited to 50 percent of net income from
the property, except for oil and gas where the deduction
can be 100 percent of net property income. Production
from geothermal deposits is eligible for percentage depletion at 65 percent of net income, but with no limit
on output and no limitation with respect to qualified
producers. Unlike depreciation or cost depletion, percentage depletion deductions can exceed the cost of the
investment.
12. Alternative fuel production credit.—A nontaxable credit of $3 per barrel (in 1979 dollars) of oilequivalent production is provided for several forms of
alternative fuels. The credit is generally available if
the price of oil stays below $29.50 (in 1979 dollars).
The credit generally expires on December 31, 2002.
13. Oil and gas exception to passive loss limitation.—Owners of working interests in oil and gas properties are exempt from the ‘‘passive income’’ limitations.
As a result, the working interest-holder, who manages
on behalf of himself and all other owners the development of wells and incurs all the costs of their operation,
may aggregate negative taxable income from such interests with his income from all other sources.
14. Capital gains treatment of royalties on
coal.—Sales of certain coal under royalty contracts can
be treated as capital gains rather than ordinary income.

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15. Energy facility bonds.—Interest earned on
State and local bonds used to finance construction of
certain energy facilities is tax-exempt. These bonds are
generally subject to the State private-activity bond annual volume cap.
16. Enhanced oil recovery credit.—A credit is provided equal to 15 percent of the taxpayer’s costs for
tertiary oil recovery on U.S. projects. Qualifying costs
include tertiary injectant expenses, intangible drilling
and development costs on a qualified enhanced oil recovery project, and amounts incurred for tangible depreciable property.
17. New technology credits.—A credit of 10 percent
is available for investment in solar and geothermal energy facilities. In addition, a credit of 1.5 cents is provided per kilowatt hour of electricity produced from
renewable resources such as wind and biomass. The
renewable resources credit applies only to electricity
produced by a facility placed in service on or before
December 31, 2001. The Tax Relief Extension Act of
1999 extended the expiration date from June 30, 1999
to December 31, 2001 and expanded the credit to apply
to electricity produced from poultry waste facilities
(placed in service after December 31, 1999).
18. Alcohol fuel credits.—An income tax credit is
provided for ethanol that is derived from renewable
sources and used as fuel. The credit equals 54 cents
per gallon in 1998, 1999, and 2000; 53 cents per gallon
in 2001 and 2002; 52 cents per gallon in 2003 and
2004; and 51 cents per gallon in 2005, 2006, and 2007.
To the extent that ethanol is mixed with taxable motor
fuel to create gasohol, taxpayers may claim an exemption of the Federal excise tax rather than the income
tax credit. In addition, small ethanol producers are eligible for a separate 10 cents per gallon credit.
19. Credit and deduction for clean-fuel vehicles
and property.—A tax credit of 10 percent (not to exceed $4,000) is provided for purchasers of electric vehicles. Purchasers of other clean-fuel burning vehicles
and owners of clean-fuel refueling property may deduct
part of their expenditures. The credit and deduction
are phased out from 2002 through 2005.
20. Exclusion of utility conservation subsidies.—
Subsidies by public utilities for non-business customer
expenditures on energy conservation measures are excluded from the gross income of the customer.
Natural Resources and Environment
21. Exploration and development costs.—Certain
capital outlays associated with exploration and development of nonfuel minerals may be expensed rather than
depreciated over the life of the asset.
22. Percentage depletion.—Most nonfuel mineral
extractors may use percentage depletion rather than
cost depletion, with percentage depletion rates ranging
from 22 percent for sulfur to 5 percent for sand and
gravel.
23. Sewage, water, and hazardous waste
bonds.—Interest earned on State and local bonds used
to finance the construction of sewage, water, or haz-

ardous waste facilities is tax-exempt. These bonds are
generally subject to the State private-activity bond annual volume cap.
24. Capital gains treatment of certain timber.—
Certain timber sold under a royalty contract can be
treated as a capital gain rather than ordinary income.
25. Expensing multiperiod timber growing
costs.—Most of the production costs of growing timber
may be expensed rather than capitalized and deducted
when the timber is sold. In most other industries, these
costs are capitalized under the uniform capitalization
rules.
26. Credit and seven-year amortization for reforestation.—A 10-percent investment tax credit is allowed for up to $10,000 invested annually to clear land
and plant trees for the production of timber. Up to
$10,000 in forestation investment may also be amortized over a seven-year period rather than capitalized
and deducted when the trees are sold or harvested.
The amount of forestation investment that may be amortized is not reduced by any of the allowable investment credit.
27. Historic preservation.—Expenditures to preserve and restore historic structures qualify for a 20percent investment credit, but the depreciable basis
must be reduced by the full amount of the credit taken.
Agriculture
28. Expensing certain capital outlays.—Farmers,
except for certain agricultural corporations and partnerships, are allowed to expense certain expenditures for
feed and fertilizer, as well as for soil and water conservation measures. Expensing is allowed, even though
these expenditures are for inventories held beyond the
end of the year, or for capital improvements that would
otherwise be capitalized.
29. Expensing multiperiod livestock and crop
production costs.—The production of livestock and
crops with a production period of less than two years
is exempt from the uniform cost capitalization rules.
Farmers establishing orchards, constructing farm facilities for their own use, or producing any goods for sale
with a production period of two years or more may
elect not to capitalize costs. If they do, they must apply
straight-line depreciation to all depreciable property
they use in farming.
30. Loans forgiven solvent farmers.—Farmers are
forgiven the tax liability on certain forgiven debt. Normally, a debtor must include the amount of loan forgiveness as income or reduce his recoverable basis in
the property to which the loan relates. If the debtor
elects to reduce basis and the amount of forgiveness
exceeds his basis in the property, the excess forgiveness
is taxable. For insolvent (bankrupt) debtors, however,
the amount of loan forgiveness reduces carryover losses,
then unused credits, and then basis; any remainder
of the forgiven debt is excluded from tax. Farmers with
forgiven debt are considered insolvent for tax purposes,
and thus qualify for income tax forgiveness.

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31. Capital gains treatment of certain income.—
Certain agricultural income, such as unharvested crops,
can be treated as capital gains rather than ordinary
income.
32. Income averaging for farmers.—Taxpayers can
lower their tax liability by averaging, over the prior
three-year period, their taxable income from farming.
33. Deferral of gain on sales of farm refiners.—
A taxpayer who sells stock in a farm refiner to a farmers’ cooperative can defer recognition of gain if the taxpayer reinvests the proceeds in qualified replacement
property.
Commerce and Housing
This category includes a number of tax expenditure
provisions that also affect economic activity in other
functional categories. For example, provisions related
to investment, such as accelerated depreciation, could
be classified under the energy, natural resources and
environment, agriculture, or transportation categories.
34. Credit union income.—The earnings of credit
unions not distributed to members as interest or dividends are exempt from income tax.
35. Bad debt reserves.—Small (less than $500 million in assets) commercial banks, mutual savings
banks, and savings and loan associations may deduct
additions to bad debt reserves in excess of actually
experienced losses.
36. Deferral of income on life insurance and annuity contracts.—Favorable tax treatment is provided
for investment income within qualified life insurance
and annuity contracts. Investment income earned on
qualified life insurance contracts held until death is
permanently exempt from income tax. Investment income distributed prior to the death of the insured is
tax-deferred, if not tax-exempt. Investment income
earned on annuities is treated less favorably than income earned on life insurance contracts, but it benefits
from tax deferral without annual contribution or income
limits generally applicable to other tax-favored retirement income plans.
37. Small property and casualty insurance companies.—Insurance companies that have annual net
premium incomes of less than $350,000 are exempt
from tax; those with $350,000 to $2.1 million of net
premium incomes may elect to pay tax only on the
income earned by their investment portfolio.
38. Insurance companies owned by exempt organizations.—Generally, the income generated by life
and property and casualty insurance companies is subject to tax, albeit by special rules. Insurance operations
conducted by such exempt organizations as fraternal
societies and voluntary employee benefit associations,
however, are exempt from tax.
39. Small life insurance company deduction.—
Small life insurance companies (gross assets of less
than $500 million) can deduct 60 percent of the first
$3 million of otherwise taxable income. The deduction
phases out for otherwise taxable income between $3
million and $15 million.

40. Mortgage housing bonds.—Interest earned on
State and local bonds used to finance homes purchased
by first-time, low-to-moderate-income buyers is tax-exempt. The amount of State and local tax-exempt bonds
that can be issued to finance such private activity is
limited. The combined volume cap for mortgage housing
bonds, rental housing bonds, student loan bonds, and
industrial development bonds is $50 per capita ($150
million minimum) per State. The volume cap increases
to $55 per capita ($165 million minimum) in 2003 and
ratably annually thereafter until the cap reaches $75
per capita ($225 million minimum) in 2007. States may
issue mortgage credit certificates (MCCs) in lieu of
mortgage revenue bonds. MCCs entitle home buyers
to income tax credits for a specified percentage of interest on qualified mortgages. The total amount of MCCs
issued by a State cannot exceed 25 percent of its annual
ceiling for mortgage-revenue bonds.
41. Rental housing bonds.—Interest earned on
State and local government bonds used to finance multifamily rental housing projects is tax-exempt. At least
20 percent (15 percent in targeted areas) of the units
must be reserved for families whose income does not
exceed 50 percent of the area’s median income; or 40
percent for families with incomes of no more than 60
percent of the area median income. Other tax-exempt
bonds for multifamily rental projects are generally
issued with the requirement that all tenants must be
low or moderate income families. Rental housing bonds
are subject to the volume cap discussed in the mortgage
housing bond section above.
42. Interest on owner-occupied homes.—Owner-occupants of homes may deduct mortgage interest on
their primary and secondary residences as itemized
nonbusiness deductions. The mortgage interest deduction is limited to interest on debt no greater than the
owner’s basis in the residence and, for debt incurred
after October 13, 1987, it is limited to no more than
$1 million. Interest on up to $100,000 of other debt
secured by a lien on a principal or second residence
is also deductible, irrespective of the purpose of borrowing, provided the debt does not exceed the fair market value of the residence. Mortgage interest deductions
on personal residences are tax expenditures because
the taxpayers are not required to report the value of
owner-occupied housing services as gross income.
43. Taxes on owner-occupied homes.—Owner-occupants of homes may deduct property taxes on their
primary and secondary residences even though they are
not required to report the value of owner-occupied housing services as gross income.
44. Installment sales.—Dealers in real and personal
property (i.e., sellers who regularly hold property for
sale or resale) cannot defer taxable income from installment sales until the receipt of the loan repayment.
Nondealers (i.e., sellers of real property used in their
business) are required to pay interest on deferred taxes
attributable to their total installment obligations in excess of $5 million. Only properties with sales prices
exceeding $150,000 are includable in the total. The pay-

5. TAX EXPENDITURES

ment of a market rate of interest eliminates the benefit
of the tax deferral. The tax exemption for nondealers
with total installment obligations of less than $5 million
is, therefore, a tax expenditure.
45. Capital gains exclusion on home sales.—A
homeowner can exclude from tax up to $500,000
($250,000 for singles) of the capital gains from the sale
of a principal residence. The exclusion may not be used
more than once every two years.
46. Passive loss real estate exemption.—In general, passive losses may not offset income from other
sources. Losses up to $25,000 attributable to certain
rental real estate activity, however, are exempt from
this rule.
47. Low-income housing credit.—Taxpayers who
invest in certain low-income housing are eligible for
a tax credit. The credit rate is set so that the present
value of the credit is equal to 70 percent for new construction and 30 percent for (1) housing receiving other
Federal benefits (such as tax-exempt bond financing),
or (2) substantially rehabilitated existing housing. The
credit is allowed in equal amounts over 10 years. State
agencies determine who receives the credit; States are
limited in the amount of credit they may authorize
annually to $1.25 per resident.
48. Accelerated depreciation of rental property.—
The tax depreciation allowance provisions are part of
the reference law rules, and thus do not give rise to
tax expenditures under the reference method. Under
the normal tax method, however, a 40-year tax life
for depreciable real property is the norm. Thus, a statutory depreciation period for rental property of 27.5
years is a tax expenditure. In addition, tax expenditures arise from pre-1987 tax allowances for rental
property.
49. Cancellation of indebtedness.—Individuals are
not required to report the cancellation of certain indebtedness as current income. If the canceled debt is not
reported as current income, however, the basis of the
underlying property must be reduced by the amount
canceled.
50. Imputed interest rules.—Holders (issuers) of
debt instruments are generally required to report interest earned (paid) in the period it accrues, not when
paid. In addition, the amount of interest accrued is
determined by the actual price paid, not by the stated
principal and interest stipulated in the instrument. In
general, any debt associated with the sale of property
worth less than $250,000 is excepted from the general
interest accounting rules. This general $250,000 exception is not a tax expenditure under reference law but
is under normal law. Exceptions above $250,000 are
a tax expenditure under reference law; these exceptions
include the following: (1) sales of personal residences
worth more than $250,000, and (2) sales of farms and
small businesses worth between $250,000 and $1 million.
51. Capital gains (other than agriculture, timber, iron ore, and coal).—Capital gains on assets held
for more than 1 year are taxed at a lower rate than

131
ordinary income. The lower rate on capital gains is
considered a tax expenditure under the normal tax
method but not under the reference law method.
For assets held for more than 1 year, the top tax
rate is 20 percent (10 percent for taxpayers who would
otherwise pay capital gains tax at the 15-percent rate).
In addition, for assets acquired after December 31,
2000, the maximum capital gains tax rates for assets
held more than 5 years are 8 percent and 18 percent
(rather than 10 percent and 20 percent). On January
1, 2001, taxpayers may mark-to-market existing assets
to start the 5-year holding period.
52. Capital gains exclusion for small business
stock.—An exclusion of 50 percent is provided for capital gains from qualified small business stock held by
individuals for more than 5 years. A qualified small
business is a corporation whose gross assets do not
exceed $50 million as of the date of issuance of the
stock.
53. Step-up in basis of capital gains at death.—
Capital gains on assets held at the owner’s death are
not subject to capital gains taxes. The cost basis of
the appreciated assets is adjusted upward to the market value at the owner’s date of death. The step-up
in the heir’s cost basis means that, in effect, the tax
on the capital gain is forgiven.
54. Carryover basis of capital gains on gifts.—
When a gift is made, the donor’s basis in the transferred property (the cost that was incurred when the
transferred property was first acquired) carries-over to
the donee. The carryover of the donor’s basis allows
a continued deferral of unrealized capital gains.
55. Ordinary income treatment of losses from
sale of small business corporate stock shares.—
Up to $100,000 in losses from the sale of small business
corporate stock (capitalization less than $1 million) may
be treated as ordinary losses. Such losses would, thus,
not be subject to the $3,000 annual capital loss writeoff limit.
56. Accelerated depreciation of non-rental-housing buildings.—The tax depreciation allowance provisions are part of the reference law rules, and thus
do not give rise to tax expenditures under reference
law. Under normal law, however, a 40-year life for nonrental-housing buildings is the norm. Thus, the 39-year
depreciation period for property placed in service after
February 25, 1993, the 31.5-year depreciation period
for property placed in service from 1987 to February
25, 1993, and the pre-1987 depreciation periods create
a tax expenditure.
57. Accelerated depreciation of machinery and
equipment.—The tax depreciation allowance provisions
are part of the reference law rules, and thus do not
give rise to tax expenditures under reference law. Statutory depreciation of machinery and equipment, however, is accelerated somewhat relative to the normal
tax baseline, creating a tax expenditure.
58. Expensing of certain small investments.—In
1999, qualifying investments in tangible property up
to $19,000 can be expensed rather than depreciated

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ANALYTICAL PERSPECTIVES

over time. (The expensing limit increases annually until
2003, when it reaches $25,000). To the extent that
qualifying investment during the year exceeds
$200,000, the amount eligible for expensing is decreased. In 1999, the amount expensed is completely
phased out when qualifying investments exceed
$219,000.
59. Business start-up costs.—When taxpayers enter
into a new business, certain start-up expenses, such
as the cost of legal services, are normally incurred.
Taxpayers may elect to amortize these outlays over 60
months even though they are similar to other payments
made for nondepreciable intangible assets that are not
recoverable until the business is sold. The normal tax
method treats this amortization as a tax expenditure;
the reference tax method does not.
60. Graduated corporation income tax rate
schedule.—The corporate income tax schedule is graduated, with rates of 15 percent on the first $50,000
of taxable income, 25 percent on the next $25,000, and
34 percent on the next $9.925 million. Compared with
a flat 34-percent rate, the lower rates provide an
$11,750 reduction in tax liability for corporations with
taxable income of $10 million. This benefit is recaptured for corporations with taxable incomes exceeding
$100,000 by a 5-percent additional tax on corporate
incomes in excess of $100,000, but less than $335,000.
The corporate tax rate is 35 percent on income over
$10 million. Compared with a flat 35-percent tax rate,
the 34-percent rate provides a $100,000 reduction in
tax liability for corporations with taxable incomes of
$10 million. This benefit is recaptured for corporations
with taxable incomes exceeding $15 million by a 3percent additional tax on income over $15 million but
less than $18.33 million. Because the corporate rate
schedule is part of reference tax law, it is not considered a tax expenditure under the reference method.
A flat corporation income tax rate is taken as the baseline under the normal tax method; therefore the lower
rates is considered a tax expenditure under this concept.
61. Small issue industrial development bonds.—
Interest earned on small issue industrial development
bonds (IDBs) issued by State and local governments
to finance manufacturing facilities is tax-exempt. Depreciable property financed with small issue IDBs must
be depreciated, however, using the straight-line method.
The annual volume of small issue IDBs is subject to
the unified volume cap discussed in the mortgage housing bond section above.
Transportation
62. Deferral of tax on U.S. shipping companies.—
Certain companies that operate U.S. flag vessels can
defer income taxes on that portion of their income used
for shipping purposes, primarily construction, modernization and major repairs to ships, and repayment
of loans to finance these investments. Once indefinite,

the deferral has been limited to 25 years since January
1, 1987.
63. Exclusion of employee parking expenses.—
Employee parking expenses that are paid for by the
employer or that are received in lieu of wages are excludable from the income of the employee. In 1999,
the maximum amount of the parking exclusion was
$175 (indexed, except in 1999) per month. The tax expenditure estimate does not include parking at facilities
owned by the employer.
64. Exclusion of employee transit pass expenses.—Transit passes, tokens, fare cards, and vanpool expenses paid for by an employer or provided in
lieu of wages to defray an employee’s commuting costs
are excludable from the employee’s income. In 1999,
the maximum amount of the exclusion wasis $65 (indexed, except in 1999) per month.
Community and Regional Development
65. Rehabilitation of structures.—A 10-percent investment tax credit is available for the rehabilitation
of buildings that are used for business or productive
activities and that were erected before 1936 for other
than residential purposes. The taxpayer’s recoverable
basis must be reduced by the amount of the credit.
66. Airport, dock, and similar facility bonds.—
Interest earned on State and local bonds issued to finance high-speed rail facilities and government-owned
airports, docks, wharves, and sport and convention facilities is tax-exempt. These bonds are not subject to
a volume cap.
67. Exemption of income of mutuals and cooperatives.—The incomes of mutual and cooperative telephone and electric companies are exempt from tax if
at least 85 percent of their revenues are derived from
patron service charges.
68. Empowerment zones and enterprise communities.—Qualifying businesses in designated economically depressed areas can receive tax benefits such as
an employer wage credit, increased expensing of investment in equipment, special tax-exempt financing, and
accelerated depreciation. A tax credit for contributions
to certain community development corporations can also
be available. In addition, certain first-time buyers of
a principal residence in the District of Columbia can
receive a tax credit on homes purchased on or before
December 31, 2001, and investors in certain D.C. property can receive a capital gains break.
69. Expensing of environmental remediation
costs.—Taxpayers who clean up hazardous substances
at a qualified site may expense the clean-up costs, rather than capitalize the costs, even though the expenses
will generally increase the value of the property significantly or appreciably prolong the life of the property.
The expensing only applies to clean-up costs incurred
on or before December 31, 2001. Tax Relief Extension
Act of 1999 extended the expiration date from December 31, 2000 to December 31, 2001.

5. TAX EXPENDITURES

Education, Training, Employment, and Social
Services
70. Scholarship and fellowship income.—Scholarships and fellowships are excluded from taxable income
to the extent they pay for tuition and course-related
expenses of the grantee. Similarly, tuition reductions
for employees of educational institutions and their families are not included in taxable income. From an economic point of view, scholarships and fellowships are
either gifts not conditioned on the performance of services, or they are rebates of educational costs. Thus,
under the reference law method, this exclusion is not
a tax expenditure because this method does not include
either gifts or price reductions in a taxpayer’s gross
income. The exclusion, however, is considered a tax expenditure under the normal tax method, which includes
gift-like transfers of government funds in gross income
(many scholarships are derived directly or indirectly
from government funding).
71. HOPE tax credit.—The non-refundable HOPE
tax credit allows a credit for 100 percent of an eligible
student’s first $1,000 of tuition and fees and 50 percent
of the next $1,000 of tuition and fees. The credit only
covers tuition and fees paid during the first two years
of a student’s post-secondary education. The credit is
phased out ratably for taxpayers with modified AGI
between $80,000 and $100,000 ($40,000 and $50,000
for singles).
72. Lifetime Learning tax credit.—The non-refundable Lifetime Learning tax credit allows a credit for
20 percent of an eligible student’s tuition and fees. For
tuition and fees paid before January 1, 2003, the maximum credit per return is $1,000. For tuition and fees
paid after December 31, 2002, the maximum credit per
return is $2,000. The credit is phased out ratably for
taxpayers with modified AGI between $80,000 and
$100,000 ($40,000 and $50,000 for singles). The credit
applies to both undergraduate and graduate students.
73. Education Individual Retirement Accounts.—
Contributions to an education IRA are not tax-deductible. Investment income earned by education IRAs is
not taxed when earned, and investment income from
an education IRA is tax-exempt when withdrawn to
pay for a student’s tuition and fees. The maximum contribution to an education IRA is $500 per year per
beneficiary. The maximum contribution is phased down
ratably for taxpayers with modified AGI between
$150,000 and $160,000 ($95,000 and $110,000 for singles). Contributions may not be made to an education
IRA in any year in which a contribution has been made
to a State tuition plan for the same beneficiary.
74. Student-loan interest.—Taxpayers may claim
an above-the-line deduction of up to $2,500 ($1,000 in
1998, $1,500 in 1999, and $2,000 in 2000) on interest
paid on an education loan. Interest may only be deducted for the first five years in which interest payments are required. The maximum deduction is phased
down ratably for taxpayers with modified AGI between
$60,000 and $75,000 ($40,000 and $55,000 for singles).

133
75. State prepaid tuition plans.—Some States
have adopted prepaid tuition plans and prepaid room
and board plans, which allow persons to pay in advance
for college expenses for designated beneficiaries. Taxes
on the earnings from these plans are paid by the beneficiaries and are deferred until the tuition is actually
paid.
76. Student-loan bonds.—Interest earned on State
and local bonds issued to finance student loans is taxexempt. The volume of all such private activity bonds
that each State may issue annually is limited.
77. Bonds for private nonprofit educational institutions.—Interest earned on State and local government bonds issued to finance the construction of facilities used by private nonprofit educational institutions
is not taxed. The aggregate volume of all such private
activity bonds that each State may issue during any
calendar year is limited.
78. Credit for holders of zone academy bonds.—
Financial institutions that own zone academy bonds
receive a non-refundable tax credit (set by the Treasury
Department) rather than interest. The credit is included in gross income. Proceeds from zone academy
bonds may only be used to improve impoverished
schools. The total amount of zone academy bonds that
may be issued is limited to $1.6 billion—$400 million
in each year between 1998 and 2001. The Tax Relief
Extension Act of 1999 allowed bonds to be issued in
2000 and 2001.
79. U.S. savings bonds for education.—Interest
earned on U.S. savings bonds issued after December
31, 1989 is tax-exempt if the bonds are transferred
to an educational institution to pay for educational expenses. The tax exemption is phased out for taxpayers
with AGI between $79,650 and $109,650 ($53,100 and
$68,100 for singles) in 1999.
80. Dependent students age 19 or older.—Taxpayers may claim personal exemptions for dependent
children age 19 or over who (1) receive parental support
payments of $1,000 or more per year, (2) are full-time
students, and (3) do not claim a personal exemption
on their own tax returns.
81. Child credit.—Taxpayers with children under
age 17 can qualify for a $500 child credit. The credit
is phased out for taxpayers at the rate of $50 per
$1,000 of modified AGI above $110,000 ($75,000 for
singles). The child credit is refundable for taxpayers
with three or more children.
82. Charitable contributions to educational institutions.—Taxpayers may deduct contributions to
nonprofit educational institutions. Taxpayers who donate capital assets to educational institutions can deduct the assets’ current value without being taxed on
any appreciation in value. An individual’s total charitable contribution generally may not exceed 50 percent
of adjusted gross income; a corporation’s total charitable
contributions generally may not exceed 10 percent of
pre-tax income.
83. Employer-provided educational assistance.—
Employer-provided educational assistance is excluded

134
from an employee’s gross income even though the employer’s costs for this assistance are a deductible business expense. This exclusion applies only to non-graduate courses beginning on or before December 31, 2001.
The Tax Relief Extension Act of 1999 extended the
expiration date from May 31, 2000 to December 31,
2001.
84. Work opportunity tax credit.—Employers can
claim a tax credit for qualified wages paid to individuals who begin work on or before December 31, 2000
and who are certified as members of various targeted
groups. The Tax Relief Extension Act of 1999 extended
the expiration date from June 30, 1999 to December
31, 2000. The amount of the credit that can be claimed
is 25 percent for employment of less than 400 hours
and 40 percent for employment of 400 hours or more.
The maximum credit per employee is $2,400 and can
only be claimed on the first year of wages an individual
earns from an employer. Employers must reduce their
deduction for wages paid by the amount of the credit
claimed.
85. Welfare-to-work tax credit.—An employer is eligible for a tax credit on the first $20,000 of eligible
wages paid to qualified long-term family assistance recipients during the first two years of employment. The
credit is 35 percent of the first $10,000 of wages in
the first year of employment and 50 percent of the
first $10,000 of wages in the second year of employment. The maximum credit is $8,500 per employee. The
credit applies to wages paid to employees who are hired
on or before December 31, 2001. The Tax Relief Extension Act of 1999 extended the expiration date from June
30, 1999 to December 31, 2001.
86. Employer-provided child care.—Employer-provided child care is excluded from an employee’s gross
income even though the employer’s costs for the child
care are a deductible business expense.
87. Adoption credit and exclusion.—Taxpayers can
receive a nonrefundable tax credit for qualified adoption
expenses. The maximum credit is $5,000 per child
($6,000 for special needs adoptions, except foreign adoptions). The credit is phased-out ratably for taxpayers
with modified AGI between $75,000 and $115,000. Unused credits may be carried forward. In lieu of the
tax credit, taxpayers may exclude qualified adoption
expenses from income, subject to the same maximum
amounts and phase-out as the credit. The non-special
needs adoption assistance and foreign special needs assistance expire on December 31, 2001.
88. Employer-provided meals and lodging.—Employer-provided meals and lodging are excluded from
an employee’s gross income even though the employer’s
costs for these items are a deductible business expense.
89. Child and dependent care expenses.—Married
couples with child and dependent care expenses may
claim a tax credit when one spouse works full time
and the other works at least part time or goes to school.
The credit may also be claimed by divorced or separated
parents who have custody of children, and by single
parents. Expenditures up to a maximum $2,400 for one

ANALYTICAL PERSPECTIVES

dependent and $4,800 for two or more dependents are
eligible for the credit. The credit is equal to 30 percent
of qualified expenditures for taxpayers with incomes
of $10,000 or less. The credit is reduced to a minimum
of 20 percent by one percentage point for each $2,000
of income between $10,000 and $28,000.
90. Disabled access expenditure credit.—Small
businesses (less than $1 million in gross receipts or
fewer than 31 full-time employees) can claim a 50-percent credit for expenditures in excess of $250 to remove
access barriers for disabled persons. The credit is limited to $5,000.
91. Expensing costs of removing architectural
barriers.—Taxpayers can expense (up to $15,000 annually) the cost of removing architectural barriers to the
handicapped rather than depreciate the cost over the
useful life of the asset.
92. Charitable contributions, other than education and health.—Taxpayers may deduct contributions to charitable, religious, and certain other nonprofit organizations. Taxpayers who donate capital assets to charitable organizations can deduct the assets’
current value without being taxed on any appreciation
in value. An individual’s total charitable contribution
generally may not exceed 50 percent of adjusted gross
income; a corporation’s total charitable contributions
generally may not exceed 10 percent of pre-tax income.
93. Foster care payments.—Foster parents provide
a home and care for children who are wards of the
State, under contract with the State. Compensation received for this service is excluded from the gross incomes of foster parents; the expenses they incur are
nondeductible.
94. Parsonage allowances.—The value of a minister’s housing allowance and the rental value of parsonages are not included in a minister’s taxable income.
Health
95. Employer-paid medical insurance and expenses.—Employer-paid health insurance premiums
and other medical expenses (including long-term care)
are deducted as a business expense by employers, but
they are not included in employee gross income. The
self-employed also may deduct part of their family
health insurance premiums.
96. Self-employed medical insurance premiums.—Self-employed taxpayers may deduct a percentage of their family health insurance premiums.
Taxpayers without self-employment income are not eligible for the special percentage deduction. The deductible percentage is 60 percent in 1999 through 2001,
70 percent in 2002, and 100 percent in 2003 and thereafter.
97. Workers compensation insurance premiums.—Workers compensation insurance premiums
are paid by employers and deducted as a business expense, but the premiums are not included in employee
gross income.
98. Medical savings accounts.—Some employees
may deduct annual contributions to a medical savings

5. TAX EXPENDITURES

account (MSA); employer contributions to MSAs (except
those made through cafeteria plans) for qualified employees are also excluded from income. An employee
may contribute to an MSA in a given year only if the
employer does not contribute to the MSA in that year.
MSAs are only available to self-employed individuals
or employees covered under an employer-sponsored high
deductible health plan of a small employer. The maximum annual MSA contribution is 75 percent of the
deductible under the high deductible plan for family
coverage (65 percent for individual coverage). Earnings
from MSAs are excluded from taxable income. Distributions from an MSA for medical expenses are not taxable. The number of taxpayers who may benefit annually from MSAs is generally limited to 750,000. No
new MSAs may be established after December 31, 2000.
99. Medical care expenses.—Personal expenditures
for medical care (including the costs of prescription
drugs) exceeding 7.5 percent of the taxpayer’s adjusted
gross income are deductible.
100. Hospital construction bonds.—Interest earned
on State and local government debt issued to finance
hospital construction is excluded from income subject
to tax.
101. Charitable contributions to health institutions.—Individuals and corporations may deduct contributions to nonprofit health institutions. Tax expenditures resulting from the deductibility of contributions
to other charitable institutions are listed under the education, training, employment, and social services function.
102. Orphan drugs.—Drug firms can claim a tax
credit of 50 percent of the costs for clinical testing required by the Food and Drug Administration for drugs
that treat rare physical conditions or rare diseases.
103. Blue Cross and Blue Shield.—Blue Cross and
Blue Shield health insurance providers in existence on
August 16, 1986 and certain other nonprofit health insurers are provided exceptions from otherwise applicable insurance company income tax accounting rules that
substantially reduce (or even eliminate) their tax liabilities.
Income Security
104. Railroad retirement benefits.—Railroad retirement benefits are not generally subject to the income tax unless the recipient’s gross income reaches
a certain threshold. The threshold is discussed more
fully under the social security function.
105. Workers’ compensation benefits.—Workers
compensation provides payments to disabled workers.
These benefits, although income to the recipients, are
not subject to the income tax.
106. Public assistance benefits.—Public assistance
benefits are excluded from tax. The normal tax method
considers cash transfers from the government as taxable and, thus, treats the exclusion for public assistance
benefits as a tax expenditure.
107. Special benefits for disabled coal miners.—
Disability payments to former coal miners out of the

135
Black Lung Trust Fund, although income to the recipient, are not subject to the income tax.
108. Military disability pensions.—Most of the
military pension income received by current disabled
retired veterans is excluded from their income subject
to tax.
109. Employer-provided pension contributions
and earnings.—Certain employer contributions to pension plans are excluded from an employee’s gross income even though the employer can deduct the contributions. In addition, the tax on the investment income earned by the pension plans is deferred until the
money is withdrawn.
110. 401(k) plans and Individual Retirement Accounts.—Individual taxpayers can take advantage of
several different tax-preferenced retirement plans: deductible IRAs, non-deductible IRAs, Roth IRAs, and
401(k) plans (and 401(k)-type plans like 403(b) plans
and the government’s Thrift Savings Plan).
In 1999, an employee could exclude up to $10,000
(indexed) of wages from AGI under a qualified arrangement with an employer’s 401(k). Employees can annually contribute to a deductible IRA up to $2,000 (or
100 percent of compensation, if less) or $4,000 on a
joint return with only one working spouse if: (a) neither
the individual nor spouse is an active participant in
an employer-provided retirement plan, or (b) their AGI
is below $40,000 ($25,000 for singles). The IRA deduction is phased out for taxpayers with AGI between
$50,000 and $60,000 ($30,000 and $40,000 for singles).
The phase-out range increases annually until it reaches
$80,000 to $100,000 in 2007 ($50,000 to $60,000 for
singles). Taxpayers whose AGI is above the start of
the IRA phase-out range or who are active participants
in an employer-provided retirement plan can contribute
to a non-deductible IRA. The tax on the investment
income earned by 401(k) plans, non-deductible IRAs,
and deductible IRAs is deferred until the money is
withdrawn.
An employed taxpayer can make a non-deductible
contribution of up to $2,000 (a non-employed spouse
can also contribute up to $2,000 if a joint return is
filed) to a Roth IRA. Investment income of a Roth IRA
is not taxed when earned. Withdrawals from a Roth
IRA are tax free if (1) the Roth IRA was opened at
least 5 years before the withdrawal, and (2) the taxpayer either (a) is at least 59-1/2, (b) dies, (c) is disabled, or (d) purchases a first-time house. The maximum contribution to a Roth IRA is phased out for
taxpayers with AGI between $150,000 and $160,000
($95,000 and $110,000 for singles). Total annual contributions to a taxpayer’s deductible, non-deductible,
and Roth IRAs cannot exceed $2,000 ($4,000 for joints).
111. Keogh plans.—Self-employed individuals can
make deductible contributions to their own retirement
(Keogh) plans equal to 25 percent of their income, up
to a maximum of $30,000 per year. In addition, the
tax on the investment income earned by Keogh plans
is deferred until the money is withdrawn.

136
112. Employer-provided life insurance benefits.—
Employer-provided life insurance benefits are excluded
from an employee’s gross income even though the employer’s costs for the insurance are a deductible business expense.
113. Employer-provided accident and disability
benefits.—Employer-provided accident and disability
benefits are excluded from an employee’s gross income
even though the employer’s costs for the benefits are
a deductible business expense.
114. Employer-provided supplementary unemployment
benefits.—Employer-provided
supplementary unemployment benefits are excluded from an
employee’s gross income even though the employer’s
costs for the benefits are a deductible business expense.
115. Employer Stock Ownership Plan (ESOP)
provisions.—ESOPs are a special type of tax-exempt
employee benefit plan. Employer-paid contributions (the
value of stock issued to the ESOP) are deductible by
the employer as part of employee compensation costs.
They are not included in the employees’ gross income
for tax purposes, however, until they are paid out as
benefits. The following special income tax provisions
for ESOPs are intended to increase ownership of corporations by their employees: (1) annual employer contributions are subject to less restrictive limitations; (2)
ESOPs may borrow to purchase employer stock, guaranteed by their agreement with the employer that the
debt will be serviced by his payment (deductible by
him) of a portion of wages (excludable by the employees) to service the loan; (3) employees who sell appreciated company stock to the ESOP may defer any taxes
due until they withdraw benefits; and (4) dividends
paid to ESOP-held stock are deductible by the employer.
116. Additional deduction for the blind.—Taxpayers who are blind may take an additional $1,000
standard deduction if single, or $800 if married.
117. Additional deduction for the elderly.—Taxpayers who are 65 years or older may take an additional $1,000 standard deduction if single, or $800 if
married.
118. Tax credit for the elderly and disabled.—
Individuals who are 65 years of age or older, or who
are permanently disabled, can take a tax credit equal
to 15 percent of the sum of their earned and retirement
income. Income is limited to no more than $5,000 for
single individuals or married couples filing a joint return where only one spouse is 65 years of age or older,
and up to $7,500 for joint returns where both spouses
are 65 years of age or older. These limits are reduced
by one-half of the taxpayer’s adjusted gross income over
$7,500 for single individuals and $10,000 for married
couples filing a joint return.
119. Casualty losses.—Neither the purchase of property nor insurance premiums to protect its value are
deductible as costs of earning income; therefore, reimbursement for insured loss of such property is not reportable as a part of gross income. Taxpayers, however,
may deduct uninsured casualty and theft losses of more

ANALYTICAL PERSPECTIVES

than $100 each, but only to the extent that total losses
during the year exceed 10 percent of AGI.
120. Earned income tax credit (EITC).—The EITC
may be claimed by low income workers. For a family
with one qualifying child, the credit is 34 percent of
the first $6,800 of earned income in 1999. The credit
is 40 percent of the first $9,540 of income for a family
with two or more qualifying children. When the taxpayer’s income exceeds $12,460, the credit is phased
out at the rate of 15.98 percent (21.06 percent if two
or more qualifying children are present). It is completely phased out at $26,928 of modified adjusted gross
income ($30,580 if two or more qualifying children are
present).
The credit may also be claimed by workers who do
not have children living with them. Qualifying workers
must be at least age 25 and may not be claimed as
a dependent on another taxpayer’s return. The credit
is not available to workers age 65 or older. In 1999,
the credit is 7.65 percent of the first $4,530 of earned
income. When the taxpayer’s income exceeds $5,670,
the credit is phased out at the rate of 7.65 percent.
It is completely phased out at $10,200 of modified adjusted gross income.
For workers with or without children, the income
level at which the credit’s phase-outs begin and the
maximum amounts of income on which the credit can
be taken are adjusted for inflation. Earned income tax
credits in excess of tax liabilities owed through the
individual income tax system are refundable to individuals. This portion of the credit is shown as an outlay,
while the amount that offsets tax liabilities is shown
as a tax expenditure.
Social Security
121. Social Security benefits for retired workers.—Social security benefits that exceed the beneficiary’s contributions out of taxed income are deferred
employee compensation and the deferral of tax on that
compensation is a tax expenditure. These additional
retirement benefits are paid for partly by employers’
contributions that were not included in employees’ taxable compensation. Portions (reaching as much as 85
percent) of recipients’ social security and tier 1 railroad
retirement benefits are included in the income tax base,
however, if the recipient’s provisional income exceeds
certain base amounts. Provisional income is equal to
adjusted gross income plus foreign or U.S. possession
income and tax-exempt interest, and one half of social
security and tier 1 railroad retirement benefits. The
tax expenditure is limited to the portion of the benefits
received by taxpayers who are below the base amounts
at which 85 percent of the benefits are taxable.
122. Social Security benefits for the disabled.—
Benefit payments from the Social Security Trust Fund,
for disability and for dependents and survivors, are excluded from the beneficiaries’ gross incomes.
123. Social Security benefits for dependents and
survivors.—Benefit payments from the Social Security

137

5. TAX EXPENDITURES

Trust Fund for dependents and survivors are excluded
from the beneficiaries’ gross income.
Veterans Benefits and Services
124. Veterans death benefits and disability compensation.—All compensation due to death or disability paid by the Veterans Administration is excluded
from taxable income.
125. Veterans pension payments.—Pension payments made by the Veterans Administration are excluded from gross income.
126. G.I. Bill benefits.—G.I. Bill benefits paid by
the Veterans Administration are excluded from gross
income.
127. Tax-exempt mortgage bonds for veterans.—
Interest earned on general obligation bonds issued by
State and local governments to finance housing for veterans is excluded from taxable income. The issuance
of such bonds is limited, however, to five pre-existing
State programs and to amounts based upon previous
volume levels for the period January 1, 1979 to June
22, 1984. Furthermore, future issues are limited to veterans who served on active duty before 1977.

General Government
128. Public purpose State and local bonds.—Interest earned on State and local government bonds
issued to finance public purpose construction (e.g.,
schools, roads, sewers) is tax-exempt.
129. Deductibility of certain nonbusiness State
and local taxes.—Taxpayers may deduct State and
local income taxes and property taxes even though
these taxes primarily pay for services that, if purchased
directly by taxpayers, would not be deductible.
130. Business income earned in U.S. possessions.—U.S. corporations receiving income from investments or businesses located in a U.S. possession (e.g.,
Puerto Rico) can claim a credit against U.S. tax, which
effectively excludes some of this income from tax. The
credit expires December 31, 2005.
Interest
131. U.S. savings bonds.—Taxpayers may defer paying tax on interest earned on U.S. savings bonds until
the bonds are redeemed.

TAX EXPENDITURES IN THE UNIFIED TRANSFER TAX
Exceptions to the general terms of the Federal unified
transfer tax favor particular transferees or dispositions
of transferors, similar to Federal direct expenditure or
loan programs. The transfer tax provisions identified
as tax expenditures satisfy the reference law criteria
for inclusion in the tax expenditure budget that were
described above. There is no generally accepted normal
tax baseline for transfer taxes.
Unified Transfer Tax Reference Rules
The reference tax rules for the unified transfer tax
from which departures represent tax expenditures include:
• Definition of the taxpaying unit. The payment of
the tax is the liability of the transferor whether
the transfer of cash or property was made by gift
or bequest.
• Definition of the tax base. The base for the tax
is the transferor’s cumulative, taxable lifetime
gifts made plus the net estate at death. Gifts in
the tax base are all annual transfers in excess
of $10,000 (indexed) to any donee except the donor’s spouse. Excluded are, however, payments on
behalf of family members’ educational and medical
expenses, as well as the cost of ceremonial gatherings and celebrations that are not in honor of
the donor.
• Property valuation. In general, property is valued
at its fair market value at the time it is transferred. This is not necessarily the case in the valuation of property for transfer tax purposes. Executors of estates are provided the option to value
assets at the time of the testator’s death or up
to six months later.

• Tax rate schedule. A single graduated tax rate
schedule applies to all taxable transfers. This is
reflected in the name of the ‘‘unified transfer tax’’
that has replaced the former separate gift and
estate taxes. The tax rates vary from 18 percent
on the first $10,000 of aggregate taxable transfers,
to 55 percent on amounts exceeding $3 million.
A lifetime credit is provided against the tax in
determining the final amount of transfer taxes
that are due and payable. For decedents dying
in 1999, this credit allows each taxpayer to make
a $650,000 tax-free transfer of assets that otherwise would be liable to the unified transfer tax.
This figure is scheduled to increase in steps to
$1 million in 2005.7
• Time when tax is due and payable. Donors are
required to pay the tax annually as gifts are
made. The generation-skipping transfer tax is payable by the donees whenever they accede to the
gift. The net estate tax liability is due and payable
within nine months after the decedent’s death.
The Internal Revenue Service may grant an extension of up to 10 years for a reasonable cause.
Interest is charged on the unpaid tax liability at
a rate equal to the cost of Federal short-term borrowing, plus three percentage points.
Tax Expenditures by Function
The estimates of tax expenditures in the Federal unified transfer tax for fiscal years 1999–2005 are dis7 An additional tax, at a flat rate of 55 percent, is imposed on lifetime, generationskipping transfers in excess of $1 million. It is considered a generation-skipping transfer
whenever the transferee is at lease two generations younger than the transferor, as it
would be in the case of transfers to grandchildren or great-grandchildren. The liability
of this tax is on the recipients of the transfer.

138

ANALYTICAL PERSPECTIVES

played by functional category in Table 5–6. Outlay
equivalent estimates are similar to revenue loss estimates for transfer tax expenditures and, therefore, are
not shown separately. A description of the provisions
follows.
Natural Resources and Environment
1. Donations of conservation easements.—Bequests of property and easements (in perpetuity) for
conservation purposes can be excluded from taxable estates. Use of the property and easements must be restricted to at least one of the following purposes: outdoor recreation or scenic enjoyment for the general public; protection of the natural habitats of fish, wildlife,
plants, etc.; and preservation of historic land areas and
structures. Conservation gifts are similarly excluded
from the gift tax. Up to 40 percent of the value of
land subject to certain conservation easements may be
excluded from taxable estates; the maximum amount
of the exclusion is $200,000 in 1999 and increases by
$100,000 in each year through 2002.
Agriculture
2. Special-use valuation of farms.—Up to $750,000
(indexed) in farmland owned and operated by a decedent and/or a member of the family may be valued
for estate tax purposes on the basis of its ‘‘continued
use’’ as farmland if: (1) the value of the farmland is
at least 25 percent of the gross estate; (2) the entire
value of all farm property is at least 50 percent of
the gross estate; and (3) family heirs to the farm agree
to continue to operate the property as a farm for at
least 10 years.
3. Tax deferral of closely held farms.—The tax
on a decedent’s farm can be deferred for up to 14 years
if the value of the farm is at least 35 percent of the
net estate. For the first 4 years of deferral, no tax
need be paid. During the last 10 years of deferral, the
tax liability must be paid in equal annual installments.
Throughout the 14 year period, interest is charged at
a special, favorable rate.

Commerce and Housing
4. Special-use valuation of closely-held businesses.—The special-use valuation rule available for
family farms is also available for nonfarm family businesses. To be eligible for the special-use valuation, the
same three conditions previously described must be
met.
5. Tax deferral of closely-held businesses.—The
tax-deferral rule available for family farms is also available for nonfarm family businesses. To be eligible for
the tax deferral, the value of stock in closely-held corporations must exceed 35 percent of the decedent’s
gross estate, less debt and funeral expenses.
6. Exclusion for family-owned businesses.—Certain family-owned businesses that are bequeathed to
qualified heirs can be excluded from taxable estates.
The exclusion generally cannot exceed $1.3 million less
the exemption value of the unified credit. The exclusion
is recaptured if certain conditions are not maintained
for 10 years.
Education, Training, Employment, and Social
Services
7. Charitable contributions to educational institutions.—Bequests to educational institutions can be
deducted from taxable estates.
8. Charitable contributions, other than education and health.—Bequests to charitable, religious,
and certain other nonprofit organizations can be deducted from taxable estates.
Health
9. Charitable contributions to health institutions.—Bequests to health institutions can be deducted
from taxable estates.
General Government
10. State and local death taxes.—A credit against
the Federal estate tax is allowed for State taxes on
bequests. The amount of this credit is determined by
a rate schedule that reaches a maximum of 16 percent
of the taxable estate in excess of $60,000.

139

5. TAX EXPENDITURES

Table 5–6. REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES IN THE FEDERAL UNIFIED TRANSFER TAX
(In millions of dollars)
Description

1999

2000

2001

2002

2003

2004

2005

2001–2005

1

Natural Resources and Environment:
Donations of conservation easements ..........................................................

10

25

40

55

75

95

105

370

2
3

Agriculture:
Special use valuation of farm real property ..................................................
Tax deferral of closely held farms .................................................................

95
5

100
15

105
20

110
20

115
20

125
25

120
30

575
115

4
5
6

Commerce:
Special use valuation of real property used in closely held businesses .....
Tax deferral of closely held business ............................................................
Exclusion for family owned businesses .........................................................

10
35
505

10
100
520

10
110
535

10
110
550

15
120
495

15
130
440

15
180
395

65
650
2,415

7
8

Education, training, employment, and social services:
Deduction for charitable contributions (education) ........................................
Deduction for charitable contributions (other than education and health) ...

682
2,015

760
2,240

830
2,450

855
2,525

910
2,680

930
2,750

1,020
3,015

4,545
13,420

9

Health:
Deduction for charitable contributions (health) ..............................................

615

685

750

775

820

840

925

4,110

10

General government:
Credit for State death taxes ..........................................................................

5,825

6,070

6,345

6,640

6,945

7,265

7,595

34,790

SPECIAL ANALYSES AND PRESENTATIONS

141

6.

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Investment spending is spending that yields longterm benefits. Its purpose may be to improve the efficiency of internal Federal agency operations or to increase the Nation’s overall stock of capital for economic
growth. The spending can be direct Federal spending
or grants to State and local governments. It can be
for physical capital, which yields a stream of services
over a period of years, or for research and development
or education and training, which are intangible but also
increase income in the future or provide other longterm benefits.
Most presentations in the Federal budget combine
investment spending with spending for current use.
This chapter focuses solely on Federal and federally
financed investment. These investments are discussed
in the following sections:
• a description of the size and composition of Federal investment spending;

• a discussion of capital assets used to provide Federal services, and efforts to improve planning and
budgeting for these assets. An Appendix to Part
II presents the ‘‘Principles of Budgeting for Capital Asset Acquisitions,’’ which are being used to
guide the analysis of Administration requests for
spending for capital assets;
• a presentation of trends in the stock of federally
financed physical capital, research and development, and education;
• alternative capital budget and capital expenditure
presentations; and
• projections of Federal physical capital outlays and
recent assessments of public civilian capital needs,
as required by the Federal Capital Investment
Program Information Act of 1984.

The President’s Commission to Study Capital Budgeting
The President established the Commission to Study Capital Budgeting in 1997 with a charge to prepare a wide-ranging report on different aspects of capital budgeting including practices outside the
Federal Government, the definition of capital, the role of depreciation, and the effect of a capital budget on budgeting choices, macroeconomic stabilization, and budgetary discipline. The Commission issued
its report in February 1999. The Commission proposed a series of recommendations to improve each
part of the budget process: setting priorities, making current budget decisions, reporting on these decisions, and subsequently evaluating them.
The Commission’s broadest and most fundamental conclusion was that insufficient attention is paid
to the long-run consequences of all budget decisions. The report included two recommendations to facilitate the setting of priorities among all programs, not just those involving capital expenditures. The
first recommended integration of the planning under the Government Performance and Results Act
(GPRA) with budgeting in the form of annually revised five-year plans, and greater emphasis by decision-makers in the Executive Branch and Congress on the longer-run implications of current year decisions. The second recommended an ongoing effort within the Federal government to analyze the benefits and costs of all major government programs as a guide to future policies. The report also recommended evaluating the benefits and costs of major investment projects undertaken in the past.
In the instructions for the FY 2001 budget, the Administration encouraged agencies to integrate
their annual performance plan and budget justification. Although time for this undertaking was short,
several agencies submitted integrated documents or more information on the budgetary resources to be
applied to specific performance objectives. The same instructions provided guidance for the first annual performance reports due to Congress this March. They are to include, not only comparisons of actual performance with the projected levels that had been set forth in agency performance plans and
analysis of those comparisons, but also summaries of all program evaluations, cost-benefit studies, and
other policy, program, and management analyses. As noted in Section V of the Budget, the Admini(Continued on next page)

143

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ANALYTICAL PERSPECTIVES

The President’s Commission to Study Capital Budgeting—Continued
stration’s Priority Management Objective #1 includes implementing greater integration of planning
with budgeting, informing both with performance measures, and working to align cost with programs
to better track what taxpayers are getting for their dollars. These steps will provide needed improvements to essential information and infrastructure to support attention to program performance and
the long-range consequences of budget decisions in future years.
The Commission did not endorse a single definition of capital, but said distinctions among different
types of capital spending were warranted for different purposes. It did not recommend changing the
budget to make the size of the deficit or surplus depend on the amount of expenditures defined as capital, to finance capital spending by borrowing, or to make a single decision about how much to spend
for ‘‘capital’’ under some definition. The Commission found that the current system has biases toward
both too much and too little capital spending, but did not believe anyone could say authoritatively
which effect was stronger. It recommended up-front full funding for capital projects, or usable segments thereof, and strict adherence to existing rules that govern the scoring of leases. The Administration plans to continue these policies.
However, the Commission concluded that capital spending is inefficiently allocated among projects,
and that the current process shortchanges the maintenance of existing assets. To promote better planning and budgeting of capital expenditures for federally owned facilities, the Commission recommended that the Executive Branch and the Congress experiment with capital acquisition funds
(CAFs) that would help smooth lumpiness in appropriations by aggregating capital requests for the
agency, and match cost with program results by a capital usage charge on the asset-using programs.
Another recommendation was to experiment with incentives for agencies to manage their assets more
efficiently, for example by permitting them to keep a limited portion of revenues from selling assets.
Other recommendations concerned developing and publishing more detailed information about the
composition and condition of capital assets, and retrospectively assessing the extent to which major investment projects have produced returns in excess of the cost of capital.
The Administration is exploring options for capital acquisition funds as part of its effort to integrate
planning and budgeting, and to charge for resources in alignment with their use to achieve program
results. Implementation would require better information on existing assets, and would provide an incentive for more attention to efficient asset management. The Capital Programming Guide is being updated to provide specific examples and to improve understanding of the linkages between its four
stages: planning, budgeting, acquisition, and management-in-use. In particular, this will emphasize
how knowledge of the condition, maintenance, use, and value of existing assets feed back into the next
cycle of planning. An inter-agency task force is working to develop standardized methods to estimate
deferred maintenance. Meanwhile, a variety of other efforts are ongoing to improve information on existing assets and new capital projects and to more fully implement existing guidance on improving capital planning and acquisition. Furthermore, the General Services Administration has developed a draft
legislative proposal allowing agencies to keep a share of the proceeds from disposing of real property,
which should give them an incentive to dispose of real property they no longer need.
1 The Report of the President’s Commission to Study Capital Budgeting (February 1999) was published
by the U.S. Government Printing Office and is also available, together with testimony and other supporting materials, on the Internet at http:/www.whitehouse.gov/pcscb.

6.

145

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Part I: DESCRIPTION OF FEDERAL INVESTMENT
For almost fifty years, a chapter in the budget has
shown Federal investment outlays—defined as those
outlays that yield long-term benefits—separately from
outlays for current use. Again this year the discussion
of the composition of investment includes estimates of
budget authority as well as outlays and extends these
estimates four years beyond the budget year, to 2005.
The classification of spending between investment
and current outlays is a matter of judgment. The budget has historically employed a relatively broad classification, including physical investment, research, development, education, and training. The budget further
classifies investments into those that are grants to
State and local governments, such as grants for highways or for elementary and secondary education, and
all other investments, called ‘‘direct Federal programs,’’
in this analysis. This ‘‘direct Federal’’ category consists
primarily of spending for assets owned by the Federal
Government, such as defense weapons systems and general purpose office buildings, but also includes grants
to private organizations and individuals for investment,
such as capital grants to Amtrak or higher education
loans directly to individuals.
Presentations for particular purposes could adopt different definitions of investment:
• To suit the purposes of a traditional balance sheet,
investment might include only those physical assets owned by the Federal Government, excluding
capital financed through grants and intangible assets such as research and education.
• Focusing on the role of investment in improving
national productivity and enhancing economic
growth would exclude items such as national defense assets, the direct benefits of which enhance
national security rather than economic growth.
• Concern with the efficiency of Federal operations
would confine the coverage to investments that
reduce costs or improve the effectiveness of internal Federal agency operations, such as computer
systems.
• A ‘‘social investment’’ perspective might broaden
the coverage of investment beyond what is included in this chapter to encompass programs
such as childhood immunization, maternal health,
certain nutrition programs, and substance abuse
treatment, which are designed in part to prevent
more costly health problems in future years.
The relatively broad definition of investment used
in this section provides consistency over time—historical figures on investment outlays back to 1940 can
be found in the separate Historical Tables volume. The
detailed tables at the end of this section allow
disaggregation of the data to focus on those investment
outlays that best suit a particular purpose.
In addition to this basic issue of definition, there
are two technical problems in the classification of investment data, involving the treatment of grants to
State and local governments and the classification of

spending that could be shown in more than one category.
First, for some grants to State and local governments
it is the recipient jurisdiction, not the Federal Government, that ultimately determines whether the money
is used to finance investment or current purposes. This
analysis classifies all of the outlays in the category
where the recipient jurisdictions are expected to spend
most of the money. Hence, the community development
block grants are classified as physical investment, although some may be spent for current purposes. General purpose fiscal assistance is classified as current
spending, although some may be spent by recipient jurisdictions on physical investment.
Second, some spending could be classified in more
than one category of investment. For example, outlays
for construction of research facilities finance the acquisition of physical assets, but they also contribute to
research and development. To avoid double counting,
the outlays are classified in the category that is most
commonly recognized as investment. Consequently outlays for the conduct of research and development do
not include outlays for research facilities, because these
outlays are included in the category for physical investment. Similarly, physical investment and research and
development related to education and training are included in the categories of physical assets and the conduct of research and development.
When direct loans and loan guarantees are used to
fund investment, the subsidy value is included as investment. The subsidies are classified according to their
program purpose, such as construction, education and
training, or non-investment outlays. For more information about the treatment of Federal credit programs,
refer to Chapter 24, ‘‘Budget System and Concepts and
Glossary.’’
This section presents spending for gross investment,
without adjusting for depreciation. A subsequent section discusses depreciation, shows investment both
gross and net of depreciation, and displays net capital
stocks.
Composition of Federal Investment Outlays
Major Federal Investment
The composition of major Federal investment outlays
is summarized in Table 6–1. They include major public
physical investment, the conduct of research and development, and the conduct of education and training. Defense and nondefense investment outlays were $240.2
billion in 1999. They are estimated to increase to $254.3
billion in 2000 and to increase further to $267.2 billion
in 2001. Major Federal investment will comprise an
estimated 14.6 percent of total Federal outlays in 2001
and 2.7 percent of the Nation’s gross domestic product
(GDP). Greater detail on Federal investment is available in tables 6–2 and 6–3 at the end of this section.
Those tables include both budget authority and outlays.

146

ANALYTICAL PERSPECTIVES

Physical investment.—Outlays for major public physical capital investment (hereafter referred to as physical
investment outlays) are estimated to be $130.2 billion
in 2001. Physical investment outlays are for construction and rehabilitation, the purchase of major equipment, and the purchase or sale of land and structures.
An estimated three-fifths of these outlays are for direct
physical investment by the Federal Government, with
the remaining being grants to State and local governments for physical investment.
Direct physical investment outlays by the Federal
Government are primarily for national defense. Defense
outlays for physical investment were $53.9 billion in
1999 and are estimated to increase to $56.2 billion in
2001. Almost all of these outlays, or $51.1 billion, are
for the procurement of weapons and other defense
equipment, and the remainder is primarily for construction on military bases, family housing for military personnel, and Department of Energy defense facilities.
These outlays are estimated to increase in 2002 and
beyond in response to increases in defense budget authority enacted for 2000 and requested for 2001 and
later years in this budget.

Outlays for direct physical investment for nondefense
purposes are estimated to be $22.4 billion in 2001.
These outlays include $13.3 billion for construction and
rehabilitation. This amount includes funds for water,
power, and natural resources projects of the Army
Corps of Engineers, the Bureau of Reclamation within
the Department of the Interior, the Tennessee Valley
Authority, and the power administrations in the Department of Energy; construction and rehabilitation of
veterans hospitals and Postal Service facilities; facilities
for space and science programs, and Indian Health
Service hospitals and clinics. Outlays for the acquisition
of major equipment are estimated to be $8.2 billion
in 2001. The largest amounts are for the air traffic
control system and the Postal Service. For the purchase
or sale of land and structures, disbursements are estimated to exceed collections by $0.8 billion in 2001.
These purchases are largely for buildings and land for
parks and other recreation purposes.
Grants to State and local governments for physical
investment are estimated to be $51.7 billion in 2001.
Almost two-thirds of these outlays, or $33.6 billion, are
to assist States and localities with transportation infra-

Table 6–1. COMPOSITION OF FEDERAL INVESTMENT OUTLAYS
(In billions of dollars)
1999
actual

Estimate
2000

2001

Federal Investment
Major public physical capital investment:
Direct Federal:
National defense ...................................................................................................
Nondefense ...........................................................................................................

53.9
20.8

53.3
22.4

56.2
22.4

Subtotal, direct major public physical capital investment ...............................
Grants to State and local governments ........................................................................

74.7
43.9

75.7
48.7

78.5
51.7

Subtotal, major public physical capital investment ........................................
Conduct of research and development:
National defense ........................................................................................................
Nondefense ................................................................................................................

118.6

124.4

130.2

40.3
33.9

40.4
36.1

40.9
39.4

Subtotal, conduct of research and development .............................................
Conduct of education and training:
Grants to State and local governments ...................................................................
Direct Federal ............................................................................................................

74.1

76.5

80.4

28.4
19.0

33.1
20.3

34.9
21.7

Subtotal, conduct of education and training ....................................................

47.4

53.4

56.6

Total, major Federal investment outlays ..................................................................
MEMORANDUM
Major Federal investment outlays:
National defense ........................................................................................................
Nondefense ................................................................................................................

240.2

254.3

267.2

94.2
146.0

93.7
160.6

97.1
170.1

Total, major Federal investment outlays .......................................................................
Miscellaneous physical investments:
Commodity inventories ..............................................................................................
Other physical investment (direct) ............................................................................

240.2

254.3

267.2

–*
2.6

–0.2
3.3

–0.3
4.1

Total, miscellaneous physical investment ............................................................

2.5

3.1

3.8

Total, Federal investment outlays, including miscellaneous physical investment .......

242.7

257.4

271.0

* Indicates $50 million or less.

6.

147

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

structure, primarily highways. Other major grants for
physical investment fund sewage treatment plants,
community development, and public housing.
Conduct of research and development.—Outlays for
the conduct of research and development are estimated
to be $80.4 billion in 2001. These outlays are devoted
to increasing basic scientific knowledge and promoting
research and development. They increase the Nation’s
security, improve the productivity of capital and labor
for both public and private purposes, and enhance the
quality of life. Slightly more than half of these outlays,
an estimated $40.9 billion in 2001, are for national
defense. Physical investment for research and development facilities and equipment is included in the physical investment category.
Nondefense outlays for the conduct of research and
development are estimated to be $39.4 billion in 2001.
This is largely for the space programs, the National
Science Foundation, the National Institutes of Health,
and research for nuclear and non-nuclear energy programs.
Conduct of education and training.—Outlays for the
conduct of education and training are estimated to be
$56.6 billion in 2001. These outlays add to the stock
of human capital by developing a more skilled and productive labor force. Grants to State and local governments for this category are estimated to be $34.9 billion
in 2001, more than three-fifths of the total. They include education programs for the disadvantaged and
the handicapped, vocational and adult education programs, training programs in the Department of Labor,
and Head Start. Direct Federal education and training
outlays are estimated to be $21.7 billion in 2001. Programs in this category are primarily aid for higher
education through student financial assistance, loan
subsidies, the veterans GI bill, and health training programs.

This category does not include outlays for education
and training of Federal civilian and military employees.
Outlays for education and training that are for physical
investment and for research and development are in
the categories for physical investment and the conduct
of research and development.
Miscellaneous Physical Investment Outlays
In addition to the categories of major Federal investment, several miscellaneous categories of investment
outlays are shown at the bottom of Table 6–1. These
items, all for physical investment, are generally unrelated to improving Government operations or enhancing
economic activity.
Outlays for commodity inventories are for the purchase or sale of agricultural products pursuant to farm
price support programs and the purchase and sale of
other commodities such as oil and gas. Sales are estimated to exceed purchases by $0.3 billion in 2001.
Outlays for other miscellaneous physical investment
are estimated to be $4.1 billion in 2001. This category
includes primarily conservation programs. These are
entirely direct Federal outlays.
Detailed Tables on Investment Spending
This section provides data on budget authority as
well as outlays for major Federal investment. These
estimates extend four years beyond the budget year
to 2005. Table 6–2 displays budget authority (BA) and
outlays (O) by major programs according to defense
and nondefense categories. The greatest level of detail
appears in Table 6–3, which shows budget authority
and outlays divided according to grants to State and
local governments and direct Federal spending. Miscellaneous investment is not included in these tables
because it is generally unrelated to improving Government operations or enhancing economic activity.

148

ANALYTICAL PERSPECTIVES

Table 6–2. FEDERAL INVESTMENT BUDGET AUTHORITY AND OUTLAYS: DEFENSE AND NONDEFENSE PROGRAMS
(in millions of dollars)

1999
Actual

Description
NATIONAL DEFENSE
Major public physical investment:
Construction and rehabilitation ....................................................................

Estimate
2000

2001

2002

2003

2004

2005

BA
O
BA
O
BA
O

5,083
4,871
51,165
49,040
–31
–31

5,556
4,915
54,351
48,444
–30
–30

4,568
5,120
60,045
51,076
–27
–27

4,775
4,577
62,276
53,405
–29
–29

4,434
4,471
65,915
59,248
–29
–29

4,590
4,444
67,063
62,874
–29
–29

4,810
4,588
70,444
65,607
–29
–29

Subtotal, major public physical investment ............................................

BA
O

56,217
53,880

59,877
53,329

64,586
56,169

67,022
57,953

70,320
63,690

71,624
67,289

75,225
70,166

Conduct of research and development ...........................................................

BA
O
BA
O

41,275
40,276
3
6

41,263
40,409
8
8

41,369
40,914
7
7

41,867
40,990
10
10

41,096
40,827
10
10

40,890
40,621
10
10

39,794
39,987
10
10

BA
O

97,495
94,162

101,148
93,746

105,962
97,090

108,899
98,953

111,426
104,527

112,524
107,920

115,029
110,163

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

29,164
22,723
4,753
4,024
6
61
2,382
1,619
4,893
4,804
1,552
1,289
4,118
3,749
3,176
2,845
6,982
6,389
957
955
1,479
1,427
1,629
1,675
1,452
958
3,760
2,884

31,115
25,420
5,513
4,301
11
61
1,973
1,969
4,781
4,856
1,523
1,512
4,064
3,917
3,166
3,771
6,849
7,122
977
975
1,237
1,302
1,457
1,225
753
976
2,815
3,734

33,339
27,210
6,136
4,466
37
10
2,037
1,984
4,900
4,826
2,015
1,572
3,505
4,111
3,782
3,740
7,196
7,675
865
863
1,323
1,402
1,017
1,044
1,501
1,116
3,932
3,644

30,579
27,875
6,558
5,223
37
26
2,088
2,031
4,900
4,957
2,015
1,713
3,505
4,065
3,819
3,821
7,196
7,479
906
903
1,325
1,399
1,485
1,457
1,199
1,155
4,125
3,711

30,595
27,348
7,025
5,740
37
32
2,142
2,086
4,959
4,998
2,034
1,868
3,545
4,013
3,866
3,974
7,282
7,779
892
889
1,316
1,350
1,742
1,574
1,180
1,295
4,024
3,993

31,192
27,166
7,166
6,403
18
32
2,198
2,144
5,077
5,073
2,085
2,019
3,628
4,012
3,965
4,009
7,463
8,443
1,128
1,126
1,345
1,352
1,509
1,609
1,189
1,387
3,721
3,950

31,802
27,184
7,309
6,755
18
27
2,254
2,191
5,188
4,979
2,124
2,078
3,706
4,045
4,056
4,106
7,627
8,656
1,200
1,198
1,376
1,368
1,625
1,580
1,154
1,324
3,768
3,756

BA
O

66,303
55,402

66,234
61,141

71,585
63,663

69,737
65,816

70,639
66,939

71,684
68,726

73,207
69,249

BA
O
BA
O
BA
O

2,130
2,234
580
467
5,754
4,598

2,032
1,806
848
736
5,230
5,480

2,455
1,965
818
714
6,422
5,568

2,505
2,294
745
778
6,384
5,953

2,567
2,410
744
588
6,388
6,207

2,643
2,576
530
832
6,398
6,217

2,733
2,650
610
520
6,490
6,340

Subtotal, acquisition of major equipment ...........................................

BA
O

8,464
7,299

8,110
8,022

9,695
8,247

9,634
9,025

9,699
9,205

9,571
9,625

9,833
9,510

Purchase or sale of land and structures ....................................................

BA
O

676
1,014

921
910

688
866

365
581

375
640

700
896

704
921

Acquisition of major equipment ...................................................................
Purchase or sale of land and structures ....................................................

Conduct of education and training (civilian) ....................................................
Subtotal, national defense investment ....................................................
NONDEFENSE
Major public physical investment:
Construction and rehabilitation:
Highways ..................................................................................................
Mass transportation .................................................................................
Rail transportation ....................................................................................
Air transportation .....................................................................................
Community development block grants ....................................................
Other community and regional development ..........................................
Pollution control and abatement .............................................................
Water resources ......................................................................................
Housing assistance ..................................................................................
Energy ......................................................................................................
Veterans hospitals and other health .......................................................
Postal Service ..........................................................................................
GSA real property activities ....................................................................
Other programs ........................................................................................
Subtotal, construction and rehabilitation .............................................
Acquisition of major equipment:
Air transportation .....................................................................................
Postal Service ..........................................................................................
Other ........................................................................................................

6.

149

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–2. FEDERAL INVESTMENT BUDGET AUTHORITY AND OUTLAYS: DEFENSE AND NONDEFENSE PROGRAMS—Continued
(in millions of dollars)

1999
Actual

Description

Estimate
2000

2001

2002

2003

2004

2005

Other physical assets (grants) .....................................................................

BA
O

990
1,048

1,074
1,023

1,481
1,280

1,504
1,314

1,555
1,379

1,587
1,446

1,629
1,491

Subtotal, major public physical investment ............................................

BA
O

76,433
64,763

76,339
71,096

83,449
74,056

81,240
76,736

82,268
78,163

83,542
80,693

85,373
81,171

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

12,983
12,547
1,196
1,285
1,665
1,582
15,476
13,696
1,997
1,732
3,245
3,018

13,386
13,100
1,259
1,373
1,495
1,249
17,683
15,448
1,911
1,671
3,294
3,213

14,355
13,564
1,340
1,543
1,534
1,507
18,634
17,703
1,941
1,689
3,504
3,441

14,792
14,327
1,341
1,660
1,524
1,531
18,626
18,759
1,943
1,748
3,379
3,560

15,297
15,098
1,356
1,667
1,557
1,558
18,821
18,652
1,967
1,797
3,423
3,712

15,928
15,638
1,401
1,660
1,583
1,581
19,283
18,895
2,017
1,825
3,506
3,793

16,345
16,191
1,432
1,658
1,601
1,597
19,706
19,284
2,062
1,852
3,581
3,873

BA
O

36,562
33,860

39,028
36,054

41,308
39,447

41,605
41,585

42,421
42,484

43,718
43,392

44,727
44,455

BA
O
BA
O
BA
O
BA
O
BA
O

16,804
17,530
13,674
11,773
2,277
2,036
6,683
4,890
7,371
7,178

17,113
21,240
12,356
11,634
2,303
2,409
2,849
6,024
6,668
7,708

26,744
22,406
13,448
12,387
2,424
2,427
5,997
6,441
9,187
8,277

26,742
24,088
14,849
4,043
2,439
2,389
5,950
5,930
8,910
8,697

26,876
26,590
16,046
5,130
2,477
2,407
6,022
6,186
9,060
8,715

27,161
26,916
16,436
15,833
2,504
2,463
6,171
6,108
9,299
8,841

27,419
27,170
17,086
16,397
2,560
2,514
6,306
6,152
9,524
9,033

Subtotal, education, training, and social services ..............................

BA
O

46,809
43,407

41,289
49,015

57,800
51,938

58,890
45,147

60,481
49,028

61,571
60,161

62,895
61,266

Veterans education, training, and rehabilitation ..........................................

BA
O
BA
O
BA
O

1,360
1,643
1,021
891
1,663
1,453

1,697
1,737
1,090
1,007
1,680
1,641

1,886
1,937
1,067
1,050
1,824
1,658

1,906
1,904
1,067
1,083
1,724
1,717

1,909
1,909
1,079
1,071
1,745
1,755

1,925
1,923
1,103
1,083
1,790
1,761

1,955
1,968
1,125
1,104
1,835
1,779

Subtotal, conduct of education and training ...........................................

BA
O

50,853
47,394

45,756
53,400

62,577
56,583

63,587
49,851

65,214
53,763

66,389
64,928

67,810
66,117

Subtotal, nondefense investment ............................................................

BA
O

163,848
146,017

161,123
160,550

187,334
170,086

186,432
168,172

189,903
174,410

193,649
189,013

197,910
191,743

Total, Federal investment ..............................................................................

BA
O

261,343
240,179

262,271
254,296

293,296
267,176

295,331
267,125

301,329
278,937

306,173
296,933

312,939
301,906

Conduct of research and development:
General science, space and technology .....................................................
Energy ..........................................................................................................
Transportation ...............................................................................................
Health ...........................................................................................................
Natural resources and environment ............................................................
All other research and development ...........................................................
Subtotal, conduct of research and development ....................................
Conduct of education and training:
Education, training, employment and social services:
Elementary, secondary, and vocational education .................................
Higher education ......................................................................................
Research and general education aids ....................................................
Training and employment ........................................................................
Social services .........................................................................................

Health ...........................................................................................................
Other education and training .......................................................................

150

ANALYTICAL PERSPECTIVES

Table 6–3. FEDERAL INVESTMENT BUDGET AUTHORITY AND OUTLAYS: GRANT AND DIRECT FEDERAL PROGRAMS
(in millions of dollars)

Estimate

1999
Actual

2000

2001

2002

2003

2004

2005

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

28,964
22,722
4,753
4,024
..................
32
2,322
1,565
2,769
2,180
52
53
4,893
4,804
1,208
983
6,956
6,368
166
126

31,115
25,416
5,517
4,301
..................
17
1,896
1,896
2,787
2,470
46
72
4,781
4,856
1,210
1,252
6,821
7,096
264
220

33,339
27,205
6,136
4,466
..................
..................
1,950
1,899
2,071
2,726
17
59
4,900
4,826
T21,435
1,222
7,156
7,643
251
294

30,579
27,875
6,558
5,223
..................
..................
1,999
1,943
2,071
2,656
17
39
4,900
4,957
1,435
1,307
7,156
7,440
253
305

30,595
27,348
7,025
5,740
..................
..................
2,050
1,994
2,096
2,551
17
34
4,959
4,998
1,449
1,356
7,242
7,739
254
295

31,192
27,166
7,166
6,403
..................
..................
2,103
2,049
2,147
2,486
18
26
5,077
5,073
1,483
1,447
7,422
8,402
260
283

31,802
27,184
7,309
6,755
..................
..................
2,158
2,095
2,195
2,466
18
27
5,188
4,979
1,511
1,493
7,585
8,614
264
287

Subtotal, construction and rehabilitation .............................................

BA
O

52,083
42,857

54,437
47,596

57,255
50,340

54,968
51,745

55,687
52,055

56,868
53,335

58,028
53,900

Other physical assets ..................................................................................

BA
O

1,050
1,081

1,121
1,102

1,639
1,344

1,662
1,416

1,694
1,505

1,691
1,581

1,737
1,609

Subtotal, major public physical capital ...................................................

BA
O

53,133
43,938

55,558
48,698

58,894
51,684

56,630
53,161

57,381
53,560

58,559
54,916

59,767
55,509

BA
O
BA
O

239
210
178
98

257
233
209
134

273
255
239
222

258
239
228
227

261
256
227
232

268
261
230
234

273
261
233
236

BA
O

417
308

466
367

512
477

486
466

488
488

498
495

506
497

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

15,548
16,684
157
65
573
389
5,110
3,712
7,072
7,027
437
416
114
92

15,336
20,035
190
157
438
592
1,774
4,558
6,340
7,235
434
460
114
107

22,582
20,804
233
190
508
501
3,882
4,938
8,814
7,933
443
432
119
108

22,441
21,267
233
168
524
476
3,852
4,394
8,753
8,485
428
433
117
114

22,549
22,789
236
175
532
479
3,898
4,585
8,901
8,560
433
438
117
111

22,776
22,793
242
220
522
490
3,995
4,465
9,136
8,691
444
444
121
111

22,983
22,969
248
225
532
497
4,082
4,476
9,358
8,880
454
451
123
113

Subtotal, conduct of education and training ...........................................

BA
O

29,011
28,385

24,626
33,144

36,581
34,906

36,348
35,337

36,666
37,137

37,236
37,214

37,780
37,611

Subtotal, grants for investment ...............................................................

BA
O

82,561
72,631

80,650
82,209

95,987
87,067

93,464
88,964

94,534
91,185

96,293
92,625

98,051
93,617

BA

3,553

4,053

3,193

3,625

3,255

3,376

3,568

Description
GRANTS TO STATE AND LOCAL GOVERNMENTS
Major public physical investments:
Construction and rehabilitation:
Highways ..................................................................................................
Mass transportation .................................................................................
Rail transportation ....................................................................................
Air transportation .....................................................................................
Pollution control and abatement .............................................................
Other natural resources and environment ..............................................
Community development block grants ....................................................
Other community and regional development ..........................................
Housing assistance ..................................................................................
Other construction ...................................................................................

Conduct of research and development:
Agriculture .....................................................................................................
Other .............................................................................................................
Subtotal, conduct of research and development ....................................
Conduct of education and training:
Elementary, secondary, and vocational education .....................................
Higher education ..........................................................................................
Research and general education aids ........................................................
Training and employment ............................................................................
Social services .............................................................................................
Agriculture .....................................................................................................
Other .............................................................................................................

DIRECT FEDERAL PROGRAMS
Major public physical investment:
Construction and rehabilitation:
National defense:
Military construction .............................................................................

6.

151

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–3. FEDERAL INVESTMENT BUDGET AUTHORITY AND OUTLAYS: GRANT AND DIRECT FEDERAL PROGRAMS—Continued
(in millions of dollars)

1999
Actual

Description

Estimate
2000

2001

2002

2003

2004

2005

O
BA
O
BA
O

3,369
709
731
821
771

3,274
772
898
731
743

3,660
752
801
623
659

3,468
527
445
623
664

3,335
549
464
630
672

3,292
566
467
648
685

3,407
581
481
661
700

Subtotal, national defense ..............................................................

BA
O

5,083
4,871

5,556
4,915

4,568
5,120

4,775
4,577

4,434
4,471

4,590
4,444

4,810
4,588

International affairs ..................................................................................

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

544
368
424
413
3,124
2,793
1,818
1,809
957
955
1,629
1,675
501
242
26
21
1,389
1,387
364
387
1,452
958
1,992
1,537

370
395
377
494
3,125
3,705
1,699
1,845
977
975
1,457
1,225
224
309
28
26
1,147
1,238
441
365
753
976
1,199
1,992

726
455
612
616
3,765
3,682
1,810
1,742
865
863
1,017
1,044
284
269
40
32
1,263
1,317
713
568
1,501
1,116
1,734
1,619

824
565
621
634
3,802
3,783
1,813
1,756
906
903
1,485
1,457
286
287
40
39
1,265
1,314
807
650
1,199
1,155
1,721
1,528

922
650
625
641
3,849
3,941
1,828
1,800
892
889
1,742
1,574
292
287
40
40
1,255
1,275
590
811
1,180
1,295
1,738
1,681

1,021
732
632
646
3,947
3,984
1,867
1,871
1,128
1,126
1,509
1,609
280
294
41
41
1,283
1,292
137
650
1,189
1,387
1,783
1,759

1,021
782
640
655
4,038
4,080
1,903
1,926
1,200
1,198
1,625
1,580
285
296
42
42
1,312
1,308
140
376
1,154
1,324
1,819
1,782

BA
O

19,303
17,416

17,353
18,460

18,898
18,443

19,544
18,648

19,387
19,355

19,407
19,835

19,989
19,937

BA
O
BA
O

50,983
48,824
182
216

54,191
48,282
160
162

59,890
50,918
155
158

62,121
53,243
155
162

65,760
59,082
155
166

66,902
62,706
161
168

70,281
65,436
163
171

Subtotal, national defense ..............................................................

BA
O

51,165
49,040

54,351
48,444

60,045
51,076

62,276
53,405

65,915
59,248

67,063
62,874

70,444
65,607

General science and basic research ......................................................

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

398
372
666
662
123
123
580
467
2,130
2,234
418
266
609
244
..................
72
253
172
389
338

410
382
582
581
121
121
848
736
2,032
1,806
254
282
571
597
..................
44
550
474
566
686

476
411
587
575
118
118
818
714
2,455
1,965
343
269
989
598
..................
21
626
561
612
570

481
448
586
581
241
241
745
778
2,505
2,294
343
313
521
686
..................
22
626
555
613
628

477
473
558
562
247
247
744
588
2,567
2,410
347
317
527
901
..................
24
634
562
619
644

482
481
559
554
165
165
530
832
2,643
2,576
356
328
540
958
..................
26
649
574
636
659

488
488
555
551
187
187
610
520
2,733
2,650
364
340
552
1,025
..................
27
663
587
650
673

Family housing ....................................................................................
Atomic energy defense activities and other .......................................

General science, space, and technology ...............................................
Water resources projects ........................................................................
Other natural resources and environment ..............................................
Energy ......................................................................................................
Postal Service ..........................................................................................
Transportation ..........................................................................................
Housing assistance ..................................................................................
Veterans hospitals and other health facilities .........................................
Federal Prison System ............................................................................
GSA real property activities ....................................................................
Other construction ...................................................................................
Subtotal, construction and rehabilitation .............................................
Acquisition of major equipment:
National defense:
Department of Defense .......................................................................
Atomic energy defense activities ........................................................

Space flight, research, and supporting activities ....................................
Energy ......................................................................................................
Postal Service ..........................................................................................
Air transportation .....................................................................................
Water transportation (Coast Guard) ........................................................
Other transportation (railroads) ...............................................................
Social security ..........................................................................................
Hospital and medical care for veterans ..................................................
Department of Justice .............................................................................

152

ANALYTICAL PERSPECTIVES

Table 6–3. FEDERAL INVESTMENT BUDGET AUTHORITY AND OUTLAYS: GRANT AND DIRECT FEDERAL PROGRAMS—Continued
(in millions of dollars)

1999
Actual

Description
Department of the Treasury ....................................................................

Estimate
2000

2001

2002

2003

2004

2005

BA
O
BA
O
BA
O

852
594
585
534
1,401
1,188

293
489
610
610
1,226
1,135

403
406
644
644
1,466
1,331

571
452
676
676
1,568
1,249

574
516
709
709
1,557
1,126

581
530
744
744
1,582
1,063

588
539
781
781
1,554
1,024

BA
O

59,569
56,306

62,414
56,387

69,582
59,259

71,752
62,328

75,475
68,327

76,530
72,364

80,169
74,999

BA
O
BA
O
BA
O
BA
O

–31
–31
83
83
..................
..................
593
931

–30
–30
254
167
..................
..................
667
743

–27
–27
27
177
..................
..................
661
689

–29
–29
31
195
..................
..................
334
386

–29
–29
35
204
–323
–323
663
759

–29
–29
38
186
..................
..................
662
710

–29
–29
38
194
..................
..................
666
727

Subtotal, purchase or sale of land and structures ............................

BA
O

645
983

891
880

661
839

336
552

346
611

671
867

675
892

Subtotal, major public physical investment ............................................

BA
O

79,517
74,705

80,658
75,728

89,141
78,541

91,632
81,526

95,208
88,293

96,608
93,065

100,833
95,828

BA
O
BA
O

38,569
37,571
2,706
2,705

38,471
37,619
2,792
2,790

38,254
37,805
3,115
3,109

38,752
37,845
3,115
3,145

37,945
37,653
3,151
3,174

37,633
37,364
3,257
3,257

36,492
36,691
3,302
3,296

Subtotal, national defense ..................................................................

BA
O

41,275
40,276

41,263
40,409

41,369
40,914

41,867
40,990

41,096
40,827

40,890
40,621

39,794
39,987

International affairs .......................................................................................

BA
O

190
220

142
179

114
189

114
304

115
329

118
342

120
365

BA
O
BA
O
BA
O

8,281
8,316
2,477
2,144
2,225
2,087

8,481
8,479
2,676
2,364
2,229
2,257

8,813
8,503
3,193
2,701
2,349
2,360

9,240
8,849
3,189
3,010
2,363
2,468

9,732
9,419
3,227
3,196
2,338
2,483

10,291
9,938
3,306
3,229
2,331
2,471

10,614
10,388
3,378
3,323
2,353
2,480

Subtotal, general science, space and technology .............................

BA
O

13,173
12,767

13,528
13,279

14,469
13,753

14,906
14,631

15,412
15,427

16,046
15,980

16,465
16,556

Energy ..........................................................................................................

BA
O

1,196
1,285

1,259
1,373

1,340
1,543

1,341
1,660

1,356
1,667

1,401
1,660

1,432
1,658

BA
O
BA
O

428
395
1,098
1,117

422
403
924
759

566
511
819
826

535
540
851
815

542
516
877
869

555
527
888
883

571
538
887
887

BA
O

2,722
2,797

2,605
2,535

2,725
2,880

2,727
3,015

2,775
3,052

2,844
3,070

2,890
3,083

BA
O
BA
O

14,778
13,027
688
659

16,900
14,702
772
735

17,909
16,932
714
760

17,909
18,025
706
723

18,098
17,930
712
711

18,546
18,172
725
711

18,953
18,553
741
719

BA

15,466

17,672

18,623

18,615

18,810

19,271

19,694

GSA general supply fund ........................................................................
Other ........................................................................................................
Subtotal, acquisition of major equipment ...........................................
Purchase or sale of land and structures:
National defense ......................................................................................
International affairs ..................................................................................
Privatization of Elk Hills ...........................................................................
Other ........................................................................................................

Conduct of research and development:
National defense
Defense military .......................................................................................
Atomic energy and other .........................................................................

General science, space and technology
NASA ........................................................................................................
National Science Foundation ..................................................................
Department of Energy .............................................................................

Transportation:
Department of Transportation .................................................................
NASA ........................................................................................................
Subtotal, transportation .......................................................................
Health:
National Institutes of Health ....................................................................
All other health ........................................................................................
Subtotal, health ...................................................................................

6.

153

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–3. FEDERAL INVESTMENT BUDGET AUTHORITY AND OUTLAYS: GRANT AND DIRECT FEDERAL PROGRAMS—Continued
(in millions of dollars)

1999
Actual

Description

Estimate
2000

2001

2002

2003

2004

2005

O

13,686

15,437

17,692

18,748

18,641

18,883

19,272

BA
O
BA
O
BA
O
BA
O
BA
O

1,049
990
1,997
1,732
392
404
641
637
705
539

1,148
1,069
1,911
1,671
336
377
652
643
710
676

1,177
1,139
1,941
1,689
449
412
652
666
760
739

1,117
1,147
1,943
1,748
449
387
652
658
710
785

1,133
1,168
1,967
1,797
454
441
660
663
722
807

1,158
1,178
2,017
1,825
466
458
676
678
742
825

1,181
1,188
2,062
1,852
476
468
691
693
762
846

BA
O

77,420
73,828

79,825
76,096

82,165
79,884

82,986
82,109

83,029
82,823

84,110
83,518

84,015
83,945

BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O
BA
O

1,256
846
13,517
11,708
1,704
1,647
1,573
1,178
1,007
877
1,360
1,643
673
560
3
6
293
273
459
277

1,777
1,205
12,166
11,477
1,865
1,817
1,075
1,466
1,076
993
1,697
1,737
684
649
8
8
209
247
581
665

4,162
1,602
13,215
12,197
1,916
1,926
2,115
1,503
1,053
1,036
1,886
1,937
750
680
7
7
226
226
673
570

4,301
2,821
14,616
3,875
1,915
1,913
2,098
1,536
1,053
1,068
1,906
1,904
725
691
10
10
226
231
399
475

4,327
3,801
15,810
4,955
1,945
1,928
2,124
1,601
1,065
1,056
1,909
1,909
734
709
10
10
229
235
405
432

4,385
4,123
16,194
15,613
1,982
1,973
2,176
1,643
1,088
1,068
1,925
1,923
752
720
10
10
234
236
417
415

4,436
4,201
16,838
16,172
2,028
2,017
2,224
1,676
1,110
1,088
1,955
1,968
768
736
10
10
239
238
432
410

Subtotal, conduct of education and training ...........................................

BA
O

21,845
19,015

21,138
20,264

26,003
21,684

27,249
14,524

28,558
16,636

29,163
27,724

30,040
28,516

Subtotal, direct Federal investment ........................................................

BA
O

178,782
167,548

181,621
172,087

197,309
180,109

201,867
178,161

206,795
187,752

209,880
204,308

214,888
208,289

Total, Federal investment ..............................................................................

BA
O

261,343
240,179

262,271
254,296

293,296
267,176

295,331
267,125

301,329
278,937

306,173
296,933

312,939
301,906

Agriculture .....................................................................................................
Natural resources and environment ............................................................
National Institute of Standards and Technology .........................................
Hospital and medical care for veterans ......................................................
All other research and development ...........................................................
Subtotal, conduct of research and development ....................................
Conduct of education and training:
Elementary, secondary, and vocational education .....................................
Higher education ..........................................................................................
Research and general education aids ........................................................
Training and employment ............................................................................
Health ...........................................................................................................
Veterans education, training, and rehabilitation ..........................................
General science and basic reserach ..........................................................
National defense ..........................................................................................
International affairs .......................................................................................
Other .............................................................................................................

154

ANALYTICAL PERSPECTIVES

Part II: PLANNING, BUDGETING, AND ACQUISITION OF CAPITAL ASSETS
The previous section discussed Federal investment
broadly defined. The focus of this section is much narrower—the review of planning and budgeting during
the past year and the resultant budget proposals for
capital assets owned by the Federal Government and
used to deliver Federal services. Capital assets consist
of Federal buildings, information technology, and other
facilities and major equipment, including weapons systems, federally owned infrastructure, and space satellites.1 With proposed major agency restructuring, organizational streamlining, and other reforms, good
planning may suggest reduced spending for some assets, such as office buildings, and increased spending
for others, such as information technology, to increase
the productivity of a smaller workforce.
In recent years the Administration and the Congress
have reviewed the Federal Government’s performance
in planning, budgeting, risk management, and the acquisition of capital assets. The reviews indicate that
the performance is uneven across the Government; the
problems have many causes, and as a result, there is
no single solution. However, in meeting the objective
of improving the Government’s performance, it is essential that the caliber of Government planning and budgeting for capital assets be improved.
Improving Planning, Budgeting, and Acquisition
of Capital Assets
Risk Management
Recent Executive Branch reviews have found a recurring theme in many capital asset acquisitions—that
risk management should become more central to the
planning, budgeting, and acquisition process. Failure
to analyze and manage the inherent risk in all capital
asset acquisitions may have contributed to cost overruns, schedule shortfalls, and acquisitions that fail to
perform as expected. Failure to adopt capital asset requirements that are within the capabilities of the market and budget limitations may also have contributed
to these problems. For each major project a risk analysis that includes how risks will be isolated, minimized,
monitored, and controlled may help prevent these problems. The proposals in this budget, together with recent
legislation enacted by Congress, are designed to help
the Government manage better its portfolio of capital
assets.
Long-Term Planning and Analysis
Planning and managing capital assets, especially better management of risk, has historically been a low
priority for some agencies. Attention focuses on comingyear appropriations, and justifications are often limited
to lists of desired projects. The increased use of long1 This is almost the same as the definition in Part I of this chapter for spending for
direct Federal construction and rehabilitation, major equipment, and purchase of land, except
that capital assets excludes grants to private groups for these purposes (e.g., grants to
universities for research equipment and grants to AMTRAK). A more complete definition
can be found in the glossary to the ‘‘Principles of Budgeting for Capital Asset Acquisitions,’’
which is at the end of this Part.

range planning linked to performance goals required
by the Government Performance and Results Act would
provide a better basis for justifications. It would increase foresight and improve the odds for cost-effective
investments.
A need for better risk management, integrated lifecycle planning, and operation of capital assets at many
agencies was evident in the Executive Branch reviews.
Research equipment was acquired with inadequate
funding for its operation. New medical facilities sometimes were built without funds for maintenance and
operation. New information technology sometimes was
acquired without planning for associated changes in
agency operations.
Congressional concern.—Congress has expressed its
concern about planning for capital assets with legislation and other actions that complement Administration
efforts to ensure better performance:
• The Government Performance and Results Act of
1993 (GPRA) is designed to help ensure that program objectives are more clearly defined and resources are focused on meeting these objectives.
• The Federal Acquisition Streamlining Act of 1994
(FASA), Title V, requires agencies to improve the
management of large acquisitions. Title V requires
agencies to institute a performance-based planning, budgeting, and management approach to the
acquisition of capital assets. As a result of improved planning efforts, agencies are required to
establish cost, schedule, and performance goals
that have a high probability of successful achievement. For projects that are not achieving 90 percent of original goals, agencies are required to discuss corrective actions taken or planned to bring
the project within goals. If they cannot be brought
within goals, agencies should identify how and
why the goals should be revised, whether the
project is still cost beneficial and justified for continued funding, or whether the project should be
canceled.
• The Clinger-Cohen Act of 1996 is designed to ensure that information technology acquisitions support agency missions developed pursuant to
GPRA. The Clinger-Cohen Act also requires a performance-based planning, budgeting, and management approach to the acquisition of capital assets.
• The General Accounting Office published a study,
Budget Issues: Budgeting for Federal Capital (November 1996), written in response to a congressional request, which recommended that the Office
of Management and Budget (OMB) continue its
focus on capital assets.
Administration concern.—Since 1994, the Administration has devoted particular attention to improving the
process of planning, budgeting, and acquiring capital
assets. After seeking out and analyzing the problems,
which differed from agency to agency, OMB issued
guidance on this issue in 1994. This guidance has been

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FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

issued for several years, most recently as OMB Circular
A–11: Part 3: ‘‘Planning, Budgeting, and Acquisition
of Capital Assets’’ (July 1999) (hereafter referred to
as Part 3). Part 3 identified other OMB guidance on
this issue. 2
Part 3 requests agencies to approach planning for
capital assets in the context of strategic plans to carry
out their missions, and to consider alternative methods
of meeting their goals. Systematic analysis of the full
life-cycle expected costs and benefits is required, along
with risk analysis and assessment of alternative means
of acquiring assets. The Administration proposes to
make agencies responsible for using good capital programming principles for managing the capital assets
they use, and to work throughout the coming year to
improve agency practices in risk management, planning, budgeting, acquisition, and operation of these assets.
In support of this, in July 1997 OMB issued a Capital
Programming Guide, a Supplement to Part 3. This
Guide was developed by an interagency task force with
representation from 14 executive agencies and the General Accounting Office. The Guide’s purpose is to provide professionals in the Federal Government a basic
reference on capital assets management principles to
assist them in planning, budgeting, acquiring, and managing the asset once in use. The Guide emphasizes
risk management and the importance of analyzing capital assets as a portfolio. In addition, other recent actions by the Administration include:
• OMB memorandum 97–02, ‘‘Funding Information
Systems Investments’’ (October 25, 1996) was
issued to establish clear and concise decision criteria regarding investments in major information
technology investments. This guidance is now part
OMB Circular A–11.
• As part of this budget, the Administration is:
—requesting full funding in regular or advance
appropriations for new capital projects and for
many capital projects formerly funded incrementally. These requests are shown in Table 6–5 and
discussed in the accompanying text.
—reissuing the ‘‘Principles of Budgeting for Capital Asset Acquisitions,’’ which appear at the end
of this Part. These principles offer guidelines to
agencies to help carry out better planning, anal2 Other guidance published by OMB with participation by other agencies includes: (1)
OMB Circular No. A–109, Major System Acquisitions, which establishes policies for planning
major systems that are generally applicable to capital asset acquisitions. (2) OMB Circular
No. A–94, Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs,
which provides guidance on benefit-cost, cost-effectiveness, and lease-purchase analysis to
be used by agencies in evaluating Federal activities including capital asset acquisition.
It includes guidelines on the discount rate to use in evaluating future benefits and costs,
the measurement of benefits and costs, the treatment of uncertainty, and other issues.
This guidance must be followed in all analyses in support of legislative and budget programs.
(3) Executive Order No. 12893, ‘‘Principles for Federal Infrastructure Investments,’’ which
provides principles for the systematic economic analysis of infrastructure investments and
their management. (4) OMB Bulletin No. 94–16, Guidance on Executive Order No. 12893,
‘‘Principles for Federal Infrastructure Investments,’’ which provides guidance for implementing this order and appends the order itself. (5) the revision of OMB Circular A–130,
Management of Federal Information Resources (February 20, 1996), which provides principles
for internal management and planning practices for information systems and technology
(a further revision is currently under review); and (6) OMB Circular No. A–127, Financial
Management Systems, which prescribes policies and standards for executive departments
and agencies to follow in developing, evaluating, and reporting on financial management
systems.

ysis, risk management, and budgeting for capital
asset acquisitions.
From Planning to Budgeting
Long-range agency plans should channel fully justified budget-year and out-year capital acquisition proposals into the budget process. Agencies were asked
to submit projections of both budget authority and outlays for high-priority capital asset proposals not only
for the budget year but for the four subsequent years
through 2005 as well. In addition, agency-specific capital asset issues were highlighted in the agency reviews.
Attention was given to whether the ‘‘lumpiness’’ of
some capital assets—large one-year temporary increases in funding—disadvantaged them in the budget
review process. In some cases, agencies aggregate capital asset acquisitions into budget accounts containing
only such acquisitions; such accounts tend to smooth
out year-to-year changes in budget authority and outlays and avoid crowding other expenditures. In other
cases, agencies or program managers do not hesitate
to request ‘‘spikes’’ in spending for asset acquisitions,
and the review process accommodates them. But some
agencies go out of their way to avoid such spikes, and
some agencies have trouble accommodating them. Part
3 encouraged agencies to accommodate justified spikes
in their own internal reviews.
Full funding of capital assets.—Good budgeting requires that appropriations for the full costs of asset
acquisition be provided up front to help ensure that
all costs and benefits are fully taken into account when
decisions are made about providing resources. Full
funding was endorsed by the General Accounting Office
in its report, Budgeting for Federal Capital (November
1996). This rule is followed for most Department of
Defense procurement and construction programs and
for General Services Administration buildings. In other
areas, however, too often it is not. When it is not followed and capital assets are funded in increments,
without certainty if or when future funding will be
available, it can and occasionally does result in poor
risk management, weak planning, acquisition of assets
not fully justified, higher acquisition costs, cancellation
of major projects, the loss of sunk costs, and inadequate
funding to maintain and operate the assets. Full funding is also an important element in managing large
acquisitions effectively and holding management responsible for achieving goals. As noted at the beginning
of this chapter, the Report of the President’s Commission to Study Capital Budgeting endorsed full funding
of capital assets.
This budget requests full funding with regular or advance appropriations for new capital projects and for
many capital projects funded incrementally in the past.
Projects that might have been funded in increments
in past years and are fully funded in this budget are
identified below in Table 6–5 and discussed in the accompanying text. Efforts continue to include full funding for new capital projects, or at least economically

156
and programmatically viable segments (or modules) of
new projects.
Other budgeting issues.—Other budgeting decisions
can also aid in acquiring capital assets. Availability
of funds for one year often may not be enough time
to complete the acquisition process. Most agencies request that funds be available for more than one year
to complete acquisitions efficiently, and Part 3 encourages this. As noted, many agencies aggregate asset acquisition in budget accounts to avoid lumpiness. In
some cases, these are revolving funds that ‘‘rent’’ the
assets to the agency’s programs.
To promote better program performance, agencies are
also being encouraged by OMB to examine their budget
account structures to align them better with program
outputs and outcomes and to charge the appropriate
account with significant costs used to achieve these results. The asset acquisition rental accounts, mentioned
above, would contribute to this. Budgeting this way
would provide information and incentives for better resource allocation among programs and a continual
search for better ways to deliver services. It would also
provide incentives for efficient capital asset acquisition
and management.
Acquisition of Capital Assets
Improved planning, budgeting, and acquisition strategies are necessary to increase the ability of agencies
to acquire capital assets within, or close to, the original
estimates of cost, schedule, and performance used to
justify project budgets and to maintain budget discipline. The Administration initiative along with enactment of FASA (Title V) and the Clinger-Cohen Act require agencies to institute a performance-based planning, budgeting, and management approach to the acquisition of capital assets.
OMB, working with the agencies over the last several
years, began separate but related efforts to develop an
integrated management approach that employs performance based acquisition management as part of a
disciplined capital programming process. The Administration also wants the capital asset acquisition goals
incorporated into the annual performance plan called
for by GPRA so that a unified picture of agency management activities is presented and acquisition performance goals are linked to the achievement of program
and policy goals. This integrated approach will not only
eliminate duplication in reporting agency actions but,
most importantly, will foster more effective implementation of performance-based acquisition management.
One of the first efforts was the issuance of OMB
Circular A–11, Part 3, ‘‘Planning, Budgeting and Acquisition of Capital Assets,’’ in July 1996. Part 3 has been
reissued annually since then. The Capital Programming
Guide was issued as a Supplement to Part 3 in June
1997. These documents present unified guidance on
planning, budgeting, acquisition, and management of
capital assets. They also present unified guidance designed to coordinate the collection of agency information
for reports to the Congress required by FASA Title
V. Part 3 for this year asked agencies to report on

ANALYTICAL PERSPECTIVES

all major acquisitions and provide information on the
extent of planning and risk mitigation efforts accomplished for new projects to ensure a high probability
that the cost, schedule and performance goals established will be successfully achieved. For ongoing
projects agencies are to provide information on the
achievement of, or deviation from, goals. For projects
that are not achieving 90 percent of original goals,
agencies are required to discuss corrective actions
taken, or contemplated, to bring the project within
goals. If the project cannot be brought within goals,
agencies should explain how and why the goals should
be revised and whether the project is still cost beneficial
and justifies continued funding, or whether the project
should be canceled. Approved acquisition goals submitted with the 2001 budget are the baseline goals
for all future monitoring of project progress for both
management purposes and reporting to Congress as required by FASA Title V. This more disciplined capital
management approach is new to many agencies, and
some agencies were not yet able to provide all the required information for all major acquisitions for this
year. OMB expects that agencies will be able to meet
the requirements for next year’s budget.
Part 3 incorporates OMB memorandum 97–02,
‘‘Funding Information Systems Investments’’ (October
25, 1996), which was issued to establish clear and concise decision criteria regarding investments in major
information technology investments. These policy documents establish the general presumption that OMB will
recommend new or continued funding only for those
major investments in assets that comply with good capital programming principles.
At the Appendix to this Part are the ‘‘Principles of
Budgeting for Capital Asset Acquisitions,’’ which incorporate the above criteria and expand coverage to all
capital investments. The Administration recognizes that
many agencies are in the middle of projects initiated
prior to enactment of the Clinger-Cohen Act and FASA
Title V, and may not be able to satisfy the criteria
immediately. For those systems that do not satisfy the
criteria, the Administration considered requests to use
2000 and 2001 funds to support reevaluation and replanning of the project as necessary to achieve compliance with the criteria or to determine that the project
would not meet the criteria and should be canceled.
As a result of these two initiatives, capital asset acquisitions are to have baseline cost, schedule, and performance goals for future tracking purposes or they
are to be either reevaluated and changed or canceled
if no longer cost beneficial.
Outlook
The effort to improve planning and budgeting for capital assets will continue in 2000 and 2001.
• The Administration will work with the Congress
to increase the number of projects that are fully
funded with regular or advance appropriations.
• OMB will be working with congressional committees, the President’s Management Council, the
Chief Financial Officers Council, the Chief Infor-

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157

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

mation Officers Council, the Procurement Executives Council, and other groups to help agencies
with their responsibility for capital assets through
the alignment of budgetary resources with program results. OMB will also work with these
groups to implement the ‘‘Principles of Budgeting
for Capital Asset Acquisitions,’’ which are shown
as an Appendix to this Part.
• Interagency working groups will be established to
address: (1) program manager qualification standards; (2) enhanced systems of incentives to encourage excellence in the acquisition workforce; and
(3) government-wide implementation of performance-based management systems (e.g., earned
value or similar systems) to monitor achievement
or deviation from goals of in-process acquisitions.
• In the review process, proposals for the acquisition
of capital assets and related issues of lumpiness
or ‘‘spikes’’ will continue to receive special attention. Agencies will be encouraged to give the same
special attention to future asset acquisition proposals.
• To ensure that the full costs and benefits of all
budget proposals are fully taken into account in
allocating resources, agencies will be required to
propose full funding for acquisitions in their budget requests.
Major Acquisition Proposals
For the definition of major capital assets described
above, this budget requests $86.0 billion of budget authority for 2001. This includes $63.8 billion for the Department of Defense and $22.2 billion for other agencies. The major requests are shown in the accompanying Table 6–4: ‘‘Capital Asset Acquisitions,’’ which
distributes the funds according to the categories for
construction and rehabilitation, major equipment, and
purchases of land and structures.
Construction and Rehabilitation
This budget includes $17.0 billion of budget authority
for 2001 for construction and rehabilitation.
Department of Defense.—The budget requests $3.9 billion for 2001 for general construction on military bases
and family housing. This funding will be used to:
• support the fielding of new systems;
• enhance operational readiness, including deployment and support of military forces;
• provide housing for military personnel and their
families;
• implement base closure and realignment actions;
and
• correct safety deficiencies and environmental problems.
Corps of Engineers.—This budget requests $3.4 billion
for 2001 for construction and rehabilitation for the
Corps of Engineers. These funds finance construction,
rehabilitation, and related activity for water resources
development projects that provide navigation, flood control, environmental restoration, and other benefits.

Table 6–4. CAPITAL ASSET ACQUISITIONS
(Budget authority in billions of dollars)

MAJOR ACQUISITIONS
Construction and rehabilitation:
Defense military construction and family housing ........
Corps of Engineers .......................................................
General Services Administration ...................................
Department of Energy ...................................................
Other agencies ..............................................................

1999
actual

2000
estimate

2001
proposed

4.3
2.7
1.5
1.2
7.8

4.8
2.7
0.8
1.1
6.4

3.9
3.4
1.5
1.2
7.0

Subtotal, construction and rehabilitation ..................
Major equipment:
Department of Defense .................................................
Department of Transportation .......................................
General Services Administration ...................................
Department of Justice ...................................................
NASA .............................................................................
Department of Commerce .............................................
Department of Veterans Affairs ....................................
Other agencies ..............................................................

17.4

15.8

17.0

51.0
2.5
0.6
0.4
0.7
0.6
0.3
2.7

54.2
2.2
0.6
0.6
0.6
0.6
0.6
2.2

1 59.9

Subtotal, major equipment ........................................
Purchases of land and structures .....................................

58.8
0.6

61.6
0.9

68.4
0.7

Total, major acquisitions 2 ..................................................

76.9

78.3

86.0

2.8
0.7
0.6
0.6
0.6
0.6
2.5

1 Does

not include $0.4 billion of non-equipment expenditures related to procurement for 2001. The 2001
request for total Procurement for the Department of Defense is $60.3 billion.
2 This total is derived from the direct Federal major public physical investment budget authority on Table
6–3 ($89.1 billion for 2001). Table 6–4 excludes an estimate of spending for assets not owned by the Federal Government ($3.1 billion for 2001).

General Services Administration (GSA).—The 2001
budget includes $1.5 billion in budget authority for GSA
for the construction or major renovation of buildings.
These funds will allow for new construction and the
acquisition of courthouses, border stations, and general
purpose office space in locations where long-term needs
show that ownership is preferable to leasing.
Department of Energy.—This budget requests $1.2
billion for 2001 for construction and rehabilitation for
the Department of Energy. One of the largest projects
is the National Ignition Facility, which will be used
to perform experiments, including inertial confinement
fusion experiments, at high pressures and temperatures. The Spallation Neutron Source is discussed in
the text that accompanies Table 6–5.
Other agencies.—This budget includes $7.0 billion for
construction and rehabilitation for other agencies in
2001. The largest items are for the Postal Service ($1.0
billion); the Department of the Interior ($1.0 billion),
largely for the Bureau of Indian Affairs, water resources, and parks; and the Department of Justice ($0.8
billion), mostly for prisons.
Major Equipment
This category covers capital purchases for major
equipment, including weapons systems; information
technology, such as computer hardware, major software,
and renovations required for this equipment; and other
types of equipment. This budget requests $68.4 billion
in budget authority for 2001 for the purchase of major
equipment. For information on information technology
investments, see Chapter 23 in this volume, ‘‘Program

158

ANALYTICAL PERSPECTIVES

Performance Benefits from Major Information Technology Investments.’’
Department of Defense.—The budget includes $59.9
billion for equipment purchases and $0.4 billion for nonequipment purchases related to procurement for 2001
of weapons systems, related support equipment, and
purchase of other capital goods. This includes tactical
fighter aircraft, airlift aircraft, naval vessels, tanks, helicopters, missiles, and vehicles.
Department of Transportation.—The budget requests
$2.8 billion in budget authority for the Department of
Transportation for major equipment, which includes
$2.4 billion to modernize the air traffic control system
and $0.3 billion for the Coast Guard to acquire vessels
and other equipment. Requests for advance appropriations for the air traffic control system in the Federal
Aviation Administration are discussed with Table 6–5.
Department of Justice.—The budget requests $0.6 billion for the Department of Justice, largely for the Federal Bureau of Investigation and the Drug Enforcement
Administration.
National Aeronautics and Space Administration
(NASA).—The budget requests $0.6 billion in budget
authority to procure major equipment for programs in
human space flight, science, aeronautics, and technology. Most of the equipment is to be acquired for
Space Shuttle upgrades, such as orbiter improvements,
Space Shuttle main engines, solid rocket booster improvements, and launch site equipment.
Department of Commerce.—The budget requests $0.6
billion for the Department of Commerce, largely for
the continued acquisition of more sophisticated and advanced weather satellites and related technology.
Department of Veterans Affairs.—This budget requests $0.6 billion for medical equipment for health
care facilities. These funds will be used to continue
to provide quality health care services for veterans.
Other agencies.—This budget requests $2.5 billion for
major equipment for other agencies for 2001. The largest amount is for the Postal Service ($0.8 billion). Other
agencies include the General Services Administration
($0.7 billion), largely for vehicles; and the Department
of Energy ($0.5 billion) for science and other projects.
Purchase and Sale of Land and Structures
This budget includes $0.7 billion for 2001 for the
purchase of land and structures. This includes $0.4 billion for purchases by the Department of the Interior
for parks and other recreational purposes.
Full Funding of Major Projects
This budget proposes full funding for new capital
projects and for many projects formerly funded incrementally. The requests for advance appropriations
shown in Table 6–5 demonstrate the Administration’s
continuing support for full funding of capital investments.
The importance of full funding was discussed earlier
in this Part and is also explained in the ‘‘Principles
of Budgeting for Capital Asset Acquisitions,’’ which appears as an Appendix to this Part. Full funding was

also supported by the Report of the President’s Commission to Study Capital Budgeting, as noted at the beginning of this chapter.
This budget requests $5.9 billion in budget authority
for 2001 and $22.9 billion in advance appropriations
for later years, for a total request of $28.8 billion for
these projects for these years.
Department of Commerce
National Oceanic and Atmospheric Administration
(NOAA).—This budget requests $635 million for 2001
and $6,417 million in advance appropriations for capital
asset acquisitions in NOAA for 2002–2019.
These acquisitions support the largest modernization
in the history of the National Weather Service. The
modernization is well underway and demonstrating improvements in weather forecasts and warnings that
lead to lives and property saved. The budget supports
this multi-year effort to develop and deploy advanced
technology, including advanced radar equipment, other
ground observing systems, and geostationary and polarorbiting satellites that will greatly improve the timeliness and accuracy of severe weather and flood warnings
while reducing staffing requirements.
Department of Defense
This budget requests $821million in advance appropriations for 2002–2005 to fully fund selected military
construction and family housing projects in the Department of Defense. The budget requests $414 million for
these projects in 2001.
Department of Energy
This budget requests $281 million in 2001 and $797
million in advance appropriations to finance the Spallation Neutron Source (SNS). This facility is being built
at Oak Ridge National Laboratory in Tennessee and
will deliver the world’s highest power neutron pulse
to a suite of ‘‘best of class’’ scientific instruments. Neutron scattering and materials irradiation research helps
scientists design higher performing electronic, magnetic, ceramic, and plastic materials and design better
pharmaceuticals by providing information about the
shapes of biological molecules.
Department of Health and Human Services
This budget requests $259 million for 2001 in regular
appropriations and $109 million in advance appropriations for projects in the Department of Health and
Human Services for the Food and Drug Administration,
the Indian Health Service, the Centers for Disease Control and Prevention, and the National Institutes of
Health. The funds will allow for the construction of
new facilities and improvements to existing facilities.
Department of the Interior
National Park Service.—This budget requests $20
million in budget authority for 2001 and $49 million
in advance appropriations for 2002–2004 to fully fund
projects in the National Park Service.

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FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–5. PROPOSED SPENDING TO FULLY FUND SELECTED CAPITAL ASSET ACQUISITIONS
(Budget authority in millions of dollars)
Advance appropriations
Regular
appropriations
2001

2002

2003

2004

2005

After
2005

Total Advance
Appropriations

DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration Procurement, acquisition and construction ........................

635

732

705

706

657

3,617

6,417

DEPARTMENT OF DEFENSE
Military construction and family housing ...............................................................................................................

414

510

231

61

19

............

821

DEPARTMENT OF ENERGY
Science programs ..................................................................................................................................................

281

300

232

150

115

............

797

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration ..............................................................................................................................
Indian Health Service ............................................................................................................................................
Centers for Disease Control and Prevention .......................................................................................................
National Institutes of Health ..................................................................................................................................

20
65
127
47

23
18
21
26

............
............
21
............

............
............
............
............

............
............
............
............

............
............
............
............

23
18
42
26

Subtotal, Department of Health and Human Services ....................................................................................

259

88

21

............

............

............

109

DEPARTMENT OF THE INTERIOR
National Park Service: Construction and major maintenance .............................................................................

20

21

17

11

............

............

49

DEPARTMENT OF JUSTICE
Federal Prison System buildings and facilities .....................................................................................................

713

791

535

............

............

............

1,326

DEPARTMENT OF STATE
Embassy security, construction, and maintenance ..............................................................................................

500

650

800

950

950

............

3,350

DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration: Facilities and equipment ..................................................................................

622

638

590

565

537

614

2,944

DEPARTMENT OF THE TREASURY
Internal Revenue Service: Information technology investments ..........................................................................

119

375

............

............

............

............

375

DEFENSE CIVILIAN PROGRAMS
Armed forces retirement home .............................................................................................................................

8

6

............

............

............

............

6

GENERAL SERVICES ADMINISTRATION
Federal buildings fund ...........................................................................................................................................

101

219

163

96

............

............

478

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
Human space flight ................................................................................................................................................

2,115

1,859

1,452

1,327

1,275

............

5,913

NATIONAL SCIENCE FOUNDATION
Major research equipment .....................................................................................................................................

119

144

58

50

14

............

266

SMITHSONIAN INSTITUTION
Repair, restoration, and alteration of facilities ......................................................................................................
Construction ...........................................................................................................................................................

17
2

17
2

18
............

............
............

............
............

............
............

35
2

Subtotal, Smithsonian Institution .......................................................................................................................

19

19

18

............

............

............

37

Total ..................................................................................................................................................................

5,925

6,352

4,822

3,916

3,567

4,231

22,888

Note: For these capital projects, budget authority for the project is requested partly in the budget year and partly in future years in advance appropriations.

Department of Justice

Department of State

This budget requests $713 million in 2001 and advanced appropriations of $791 million in 2002 and $535
million in 2003 for the Federal Prison System to support a multi-year prison construction program aimed
at reversing worsening overcrowding in Federal facilities.

This budget requests $500 million in regular appropriations in 2001 and $3,350 million in advance appropriations for 2002–2005 for embassy and consultate construction. This request would support a program to provide a sustained, increasing funding path to meet overseas facility security needs.

160
Department of Transportation
Federal Aviation Administration.—This budget requests $622 million in 2001 and an additional $2,944
million for 2002–2008 for 11 multi-year capital projects
to improve and modernize the FAA’s air traffic control,
communications, and aviation weather information systems. These projects are: Aviation Weather Services Improvements, Terminal Digital Radar, Terminal Automation (STARS), Wide Area Augmentation System for
GPS, Display System Replacement, Weather and Radar
Processor, Voice Switching and Control System, Oceanic
Automation, Aeronautical Data Link, Operational and
Supportability Implementation System (OASIS), and
Beacon Interrogation Replacement.
Department of the Treasury
Internal Revenue Service (IRS).—This budget requests $119 million in 2001 and $375 million in advance appropriations for 2002 to finance information
technology investments. The IRS and the Treasury Department are significantly modifying the business plans
for modernizing the IRS tax administration and systems by focusing on reengineering work processes and
exploring private sector technology opportunities. These
efforts will ensure that future capital investments by
the IRS will improve customer service by providing alternative means of filing returns and paying taxes, improve telephone service for taxpayers; and give employees immediate access to complete information and modern tools to do their jobs.
Defense Civilian Programs
Armed Forces Retirement Home. This request for $8
million in regular appropriations in 2001 and $6 million
in 2002 in advance appropriations will allow for construction of a 110-bed health care addition to the Naval
home in Gulfport, Mississippi.
General Services Administration
This budget requests $101 million for 2001 and $478
million in advance appropriations for 2002–2004. The
Budget requests $219 million in advance appropriations
for 2002, including $185 million for the construction
of new laboratory and office space for the Food and
Drug Administration’s Center for Devices and Radiological Health in White Oak, Maryland, and $34 million
for construction of a new office building to replace the
deteriorating National Oceanic and Atmospheric Administration building in Suitland, Maryland. In addition, advance appropriations of $163 million in 2003
and $96 million in 2004 are provided for the FDA consolidation project in White Oak, MD.

ANALYTICAL PERSPECTIVES

National Aeronautics and Space Administration
(NASA)
Human Space Flight (International Space Station).—
This budget requests $2,115 million in budget authority
for 2001, and $5,913 million in advance appropriations
over the years 2002–2005 for the space station. This
will be an international laboratory in low earth orbit
on which American, Russian, Canadian, European, and
Japanese astronauts will conduct unique scientific and
technological investigations in a microgravity environment. During 1993 the program underwent a major
redesign to reduce program costs. The first two
launches beginning construction of the Station took
place in 1998 and final assembly will be complete by
2005. Advance appropriations will enable NASA to complete the development program on schedule and at
minimal total cost.
National Science Foundation (NSF)
This budget requests $119 million in 2001 and $266
million in advance appropriations for 2002–2005 for five
NSF projects.
The Large Hadron Collider will be the largest particle
accelerator in the world and will be owned and operated
by the European Laboratory for Particle Physics
(CERN). NSF is collaborating with the Department of
Energy in the development of detectors for the project.
The Network for Earthquake Engineering Simulation
is a network to connect and integrate a distributed
collection of earthquake engineering facilities that will
facilitate the future replacement of mechanical earthquake simulation with model-based computer simulation.
The Terascale Computing System will provide two
sites in the United States with supercomputer capability of at least 10 teraflops that will be available
for use by U.S. researchers through a merit-based, competitive process.
Earthscope: SAFOD/U.S. Array is an array of seismic
instruments that will be displayed at depth in the San
Andreas fault and on the surface throughout the United
States to greatly improve resolution of subsurface and
fault structure.
The National Ecological Observatory Network is a
pole-to-pole network of research sites with state-of-theart platforms and equipment to enable ecological and
biocomplexity research.
Smithsonian Institution
The budget requests $19 million in budget authority
in 2001 and $37 million in advance appropriations for
2002–2003 primarily for the major capital renewal of
the Patent Office Building. This building houses the
Smithsonian’s Museum of American Art and the National Portrait Gallery.

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FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Appendix to Part II: PRINCIPLES OF BUDGETING FOR CAPITAL ASSET ACQUISITIONS
Introduction and Summary
The Administration plans to use the following principles in budgeting for capital asset acquisitions. These
principles address planning, costs and benefits, financing, and risk management requirements that should
be satisfied before a proposal for the acquisition of capital assets can be included in the Administration’s
budget. A Glossary describes key terms. A Capital Programming Guide has been published that provides detailed information on planning and acquisition of capital assets.
The principles are organized in the following four
sections:
A. Planning. This section focuses on the need to ensure that capital assets support core/priority missions
of the agency; the assets have demonstrated a projected
return on investment that is clearly equal to or better
than alternative uses of available public resources; the
risk associated with the assets is understood and managed at all stages; and the acquisition is implemented
in phased, successive segments, unless it can be demonstrated there are significant economies of scale at
acceptable risk from funding more than one segment
or there are multiple units that need to be acquired
at the same time.
B. Costs and Benefits. This section emphasizes that
the asset should be justified primarily by benefit-cost
analysis, including life-cycle costs; that all costs are
understood in advance; and that cost, schedule, and
performance goals are identified that can be measured
using an earned value management system or similar
system.
C. Principles of Financing. This section stresses that
useful segments are to be fully funded with regular
or advance appropriations; that as a general rule, planning segments should be financed separately from procurement of the asset; and that agencies are encouraged
to aggregate assets in capital acquisition accounts and
take other steps to accommodate lumpiness or ‘‘spikes’’
in funding for justified acquisitions.
D. Risk Management. This section is to help ensure
that risk is analyzed and managed carefully in the acquisition of the asset. Strategies can include separate
accounts for capital asset acquisitions, the use of apportionment to encourage sound management, and the selection of efficient types of contracts and pricing mechanisms in order to allocate risk appropriately between
the contractor and the Government. In addition cost,
schedule, and performance goals are to be controlled
and monitored by using an earned value management
system or a similar system; and if progress toward
these goals is not met there is a formal review process
to evaluate whether the acquisition should continue or
be terminated.
A Glossary defines key terms, including capital assets. As defined here, capital assets are land, structures, equipment, and intellectual property (including
software) that are used by the Federal Government,

including weapon systems. Not included are grants to
States or others for their acquisition of capital assets.
A. Planning
Investments in major capital assets proposed for
funding in the Administration’s budget should:
1. support core/priority mission functions that need
to be performed by the Federal Government;
2. be undertaken by the requesting agency because
no alternative private sector or governmental
source can support the function more efficiently;
3. support work processes that have been simplified
or otherwise redesigned to reduce costs, improve
effectiveness, and make maximum use of commercial, off-the-shelf technology;
4. demonstrate a projected return on the investment
that is clearly equal to or better than alternative
uses of available public resources. Return may include: improved mission performance in accordance with measures developed pursuant to the
Government Performance and Results Act; reduced
cost; increased quality, speed, or flexibility; and
increased customer and employee satisfaction. Return should be adjusted for such risk factors as
the project’s technical complexity, the agency’s
management capacity, the likelihood of cost overruns, and the consequences of under- or non-performance;
5. for information technology investments, be consistent with Federal, agency, and bureau information architectures which: integrate agency work
processes and information flows with technology
to achieve the agency’s strategic goals; reflect the
agency’s technology vision and compliance plan for
this budget year; and specify standards that enable information exchange and resource sharing,
while retaining flexibility in the choice of suppliers
and in the design of local work processes;
6. reduce risk by: avoiding or isolating custom-designed components to minimize the potential adverse consequences on the overall project; using
fully tested pilots, simulations, or prototype implementations when necessary before going to production; establishing clear measures and accountability for project progress; and, securing substantial involvement and buy-in throughout the project
from the program officials who will use the system;
7. be implemented in phased, successive segments as
narrow in scope and brief in duration as practicable, each of which solves a specific part of an
overall mission problem and delivers a measurable
net benefit independent of future segments, unless
it can be demonstrated that there are significant
economies of scale at acceptable risk from funding
more than one segment or there are multiple units
that need to be acquired at the same time; and

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ANALYTICAL PERSPECTIVES

8. employ an acquisition strategy that appropriately
allocates risk between the Government and the
contractor, effectively uses competition, ties contract payments to accomplishments, and takes
maximum advantage of commercial technology.
Prototypes require the same justification as other
capital assets.
As a general presumption, the Administration will
recommend new or continued funding only for those
capital asset investments that satisfy good capital programming policies. Funding for those projects will be
recommended on a phased basis by segment, unless
it can be demonstrated that there are significant economies of scale at acceptable risk from funding more than
one segment or there are multiple units that need to
be acquired at the same time. (For more information,
see the Glossary entry, ‘‘capital project and useful segments of a capital project.’’)
The Administration recognizes that many agencies
are in the middle of ongoing projects, and they may
not be able immediately to satisfy the criteria. For
those projects that do not satisfy the criteria, OMB
will consider requests to use 2000 and 2001 funds to
finance additional planning, as necessary, to support
the establishment of realistic cost, schedule, and performance goals for the completion of the project. This
planning could include: the redesign of work processes,
the evaluation of alternative solutions, the development
of information system architectures, and, if necessary,
the purchase and evaluation of prototypes. Realistic
goals are necessary for agency portfolio analysis to determine the viability of the project, to provide the basis
for fully funding the project to completion, and setting
the baseline for management accountability to deliver
the project within goals.
Because the Administration considers this information essential to agencies’ long-term success, the Administration will use this information both in preparing

its budget and, in conjunction with cost, schedule, and
performance data, as apportionments are made. Agencies are encouraged to work with their OMB representative to arrive at a mutually satisfactory process, format, and timetable for providing the requested information.
B. Costs and Benefits
The justification of the project should evaluate and
discuss the extent to which the project meets the above
criteria and should also include:
1. an analysis of the project’s total life-cycle costs
and benefits, including the total budget authority
required for the asset, consistent with policies described in OMB Circular A–94: ‘‘Guidelines and
Discount Rates for Benefit-Cost Analysis of Federal Programs’’ (October 1992);
2. an analysis of the risk of the project including
how risks will be isolated, minimized, monitored,
and controlled, and, for major programs, an evaluation and estimate by the Chief Financial Officer
of the probability of achieving the proposed goals;
3. if, after the planning phase, the procurement is
proposed for funding in segments, an analysis
showing that the proposed segment is economically
and programmatically justified—that is, it is programmatically useful if no further investments are
funded, and in this application its benefits exceed
its costs; and
4. show cost, schedule, and performance goals for the
project (or the useful segment being proposed) that
can be measured throughout the acquisition process using an earned value management system
or similar system. Earned value is described in
OMB Circular A–11, Part 3, ‘‘Planning, Budgeting
and Acquisition of Capital Assets,’’ (July 1999),
Appendix 300C.

C. Principles of Financing
Principle 1: Full Funding
Budget authority sufficient to complete a useful segment of a capital project (or the entire capital project,
if it is not divisible into useful segments) must be appropriated before any obligations for the useful segment
(or project) may be incurred.
Explanation: Good budgeting requires that appropriations for the full costs of asset acquisition be enacted
in advance to help ensure that all costs and benefits
are fully taken into account at the time decisions are
made to provide resources. Full funding with regular
appropriations in the budget year also leads to tradeoffs
within the budget year with spending for other capital
assets and with spending for purposes other than capital assets. Full funding increases the opportunity to
use performance-based fixed price contracts, allows for
more efficient work planning and management of the

capital project, and increases the accountability for the
achievement of the baseline goals.
When full funding is not followed and capital projects
or useful segments are funded in increments, without
certainty if or when future funding will be available,
the result is sometimes poor planning, acquisition of
assets not fully justified, higher acquisition costs, cancellation of major projects, the loss of sunk costs, or
inadequate funding to maintain and operate the assets.
Principle 2: Regular and Advance
Appropriations
Regular appropriations for the full funding of a capital project or a useful segment of a capital project in
the budget year are preferred. If this results in spikes
that, in the judgment of OMB, cannot be accommodated
by the agency or the Congress, a combination of regular
and advance appropriations that together provide full

6.

163

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

funding for a capital project or a useful segment should
be proposed in the budget.
Explanation: Principle 1 (Full Funding) is met as long
as a combination of regular and advance appropriations
provide budget authority sufficient to complete the capital project or useful segment. Full funding in the budget year with regular appropriations alone is preferred
because it leads to tradeoffs within the budget year
with spending for other capital assets and with spending for purposes other than capital assets. In contrast,
full funding for a capital project over several years with
regular appropriations for the first year and advance
appropriations for subsequent years may bias tradeoffs
in the budget year in favor of the proposed asset because with advance appropriations the full cost of the
asset is not included in the budget year. Advance appropriations, because they are scored in the year they become available for obligation, may constrain the budget
authority and outlays available for regular appropriations of that year.
If, however, the lumpiness caused by regular appropriations cannot be accommodated within an agency
or Appropriations Subcommittee, advance appropriations can ameliorate that problem while still providing
that all of the budget authority is enacted in advance
for the capital project or useful segment. The latter
helps ensure that agencies develop appropriate plans
and budgets and that all costs and benefits are identified prior to providing resources. In addition, amounts
of advance appropriations can be matched to funding
requirements for completing natural components of the
useful segment. Advance appropriations have the same
benefits as regular appropriations for improved planning, management, and accountability of the project.
Principle 3: Separate Funding of Planning
Segments
As a general rule, planning segments of a capital
project should be financed separately from the procurement of a useful asset.
Explanation: The agency must have information that
allows it to plan the capital project, develop the design,
and assess the benefits, costs, and risks before proceeding to procurement of the useful asset. This is especially important for high risk acquisitions. This information comes from activities, or planning segments,
that include but are not limited to market research
of available solutions, architectural drawings, geological
studies, engineering and design studies, and prototypes.
The construction of a prototype that is a capital asset,
because of its cost and risk, should be justified and
planned as carefully as the project itself. The process
of gathering information for a capital project may consist of one or more planning segments, depending on
the nature of the asset. Funding these segments separately will help ensure that the necessary information
is available to establish cost, schedule, and performance
goals before proceeding to procurement.
If budget authority for planning segments and procurement of the useful asset are enacted together, the
Administration may wish to apportion budget authority

for one or several planning segments separately from
procurement of the useful asset.
Principle 4: Accommodation of Lumpiness or
‘‘Spikes’’ and Separate Capital Acquisition
Accounts
To accommodate lumpiness or ‘‘spikes’’ in funding justified capital acquisitions, agencies, working with OMB,
are encouraged to aggregate financing for capital asset
acquisitions in one or several separate capital acquisition budget accounts within the agency, to the extent
possible within the agency’s total budget request.
Explanation: Large, temporary, year-to-year increases
in budget authority, sometimes called lumps or spikes,
may create a bias against the acquisition of justified
capital assets. Agencies, working with OMB, should
seek ways to avoid this bias and accommodate such
spikes for justified acquisitions. Aggregation of capital
acquisitions in separate accounts may:
• reduce spikes within an agency or bureau by providing roughly the same level of spending for acquisitions each year;
• help to identify the source of spikes and to explain
them. Capital acquisitions are more lumpy than
operating expenses; and with a capital acquisition
account, it can be seen that an increase in operating expenses is not being hidden and attributed
to one-time asset purchases;
• reduce the pressure for capital spikes to crowd
out operating expenses; and
• improve justification and make proposals easier
to evaluate, since capital acquisitions are generally analyzed in a different manner than operating expenses (e.g., capital acquisitions have a
longer time horizon of benefits and life-cycle
costs).
D. Risk Management
Risk management should be central to the planning,
budgeting, and acquisition process. Failure to analyze
and manage the inherent risk in all capital asset acquisitions may contribute to cost overruns, schedule shortfalls, and acquisitions that fail to perform as expected.
For each major capital project a risk analysis that includes how risks will be isolated, minimized, monitored,
and controlled may help prevent these problems.
The project cost, schedule and performance goals established through the planning phase of the project
are the basis for approval to procure the asset and
the basis for assessing risk. During the procurement
phase performance-based management systems (earned
value or similar system) must be used to provide contractor and Government management visibility on the
achievement of, or deviation from, goals until the asset
is accepted and operational. If goals are not being met,
performance-based management systems allow for early
identification of problems, potential corrective actions,
and changes to the original goals needed to complete
the project and necessary for agency portfolio analysis
decisions. These systems also allow for Administration
decisions to recommend meaningful modifications for

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ANALYTICAL PERSPECTIVES

increased funding to the Congress, or termination of
the project, based on its revised expected return on
investment in comparison to alternative uses of the
funds. Agencies must ensure that the necessary acquisition strategies are implemented to reduce the risk of
cost escalation and the risk of failure to achieve schedule and performance goals. These strategies may include:
1. having budget authority appropriated in separate
capital asset acquisition accounts;
2. apportioning budget authority for a useful segment;
3. establishing thresholds for cost, schedule, and performance goals of the acquisition, including return
on investment, which if not met may result in
cancellation of the acquisition;
4. selecting types of contracts and pricing mechanisms that are efficient and that provide incentives to contractors in order to allocate risk appropriately between the contractor and the Government;
5. monitoring cost, schedule, and performance goals
for the project (or the useful segment being proposed) using an earned value management system
or similar system. Earned value is described in
OMB Circular A–11, Part 3, ‘‘Planning, Budgeting
and Acquisition of Capital Assets’’ (July 1999), Appendix 300C; and
6. if progress is not within 90 percent of goals, or
if new information is available that would indicate
a greater return on investment from alternative
uses of funds, institute senior management review
of the project through portfolio analysis to determine the continued viability of the project with
modifications, or the termination of the project,
and the start of exploration for alternative solutions if it is necessary to fill a gap in agency
strategic goals and objectives.
E. Glossary
Appropriations
An appropriation provides budget authority that permits Government officials to incur obligations that result in immediate or future outlays of Government
funds.
Regular annual appropriations: These appropriations
are:
• enacted normally in the current year;
• scored entirely in the budget year; and
• available for obligation in the budget year and
subsequent years if specified in the language. (See
‘‘Availability,’’ below.)
Advance appropriations: Advance appropriations may
be accompanied by regular annual appropriations to
provide funds available for obligation in the budget year
as well as subsequent years. Advance appropriations
are:
• enacted normally in the current year;

• scored after the budget year (e.g., in each of one,
two, or more later years, depending on the language); and
• available for obligation in the year scored and subsequent years if specified in the language. (See
‘‘Availability,’’ below.)
Availability: Appropriations made in appropriations
acts are available for obligation only in the budget year
unless the language specifies that an appropriation is
available for a longer period. If the language specifies
that the funds are to remain available until the end
of a certain year beyond the budget year, the availability is said to be ‘‘multi-year.’’ If the language specifies that the funds are to remain available until expended, the availability is said to be ‘‘no-year.’’ Appropriations for major procurements and construction
projects are typically made available for multiple years
or until expended.
Capital Assets
Capital assets are land, structures, equipment, and
intellectual property (including software) that are used
by the Federal Government and have an estimated useful life of two years or more. Capital assets exclude
items acquired for resale in the ordinary course of operations or held for the purpose of physical consumption
such as operating materials and supplies. The cost of
a capital asset includes both its purchase price and
all other costs incurred to bring it to a form and location suitable for its intended use.
Capital assets may be acquired in different ways:
through purchase, construction, or manufacture;
through a lease-purchase or other capital lease, regardless of whether title has passed to the Federal Government; through an operating lease for an asset with
an estimated useful life of two years or more; or
through exchange. Capital assets include leasehold improvements and land rights; assets owned by the Federal Government but located in a foreign country or
held by others (such as Federal contractors, state and
local governments, or colleges and universities); and
assets whose ownership is shared by the Federal Government with other entities. Capital assets include not
only the assets as initially acquired but also additions;
improvements; replacements; rearrangements and reinstallations; and major repairs but not ordinary repairs and maintenance.
Examples of capital assets include the following, but
are not limited to them: office buildings, hospitals, laboratories, schools, and prisons; dams, power plants, and
water resources projects; furniture, elevators, and printing presses; motor vehicles, airplanes, and ships; satellites and space exploration equipment; information
technology hardware and software; and Department of
Defense weapons systems. Capital assets may or may
not be capitalized (i.e., recorded in an entity’s balance
sheet) under Federal accounting standards. Examples
of capital assets not capitalized are Department of Defense weapons systems, heritage assets, stewardship
land, and some software. Capital assets do not include
grants for acquiring capital assets made to State and

6.

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

local governments or other entities (such as National
Science Foundation grants to universities or Department of Transportation grants to AMTRAK). Capital
assets also do not include intangible assets such as
the knowledge resulting from research and development
or the human capital resulting from education and
training, although capital assets do include land, structures, equipment, and intellectual property (including
software) that the Federal Government uses in research
and development and education and training.
Capital Project and Useful Segments of a
Capital Project
The total capital project, or acquisition of a capital
asset, includes useful segments that are either planning
segments or useful assets.
Planning segments: A planning segment of a capital
project provides information that allows the agency to
develop the design; assess the benefits, costs, and risks;
and establish realistic baseline cost, schedule, and performance goals before proceeding to full acquisition of
the useful asset (or canceling the acquisition). This information comes from activities, or planning segments,
that include but are not limited to market research
of available solutions, architectural drawings, geological
studies, engineering and design studies, and prototypes.
The process of gathering information for a capital
project may consist of one or more planning segments,
depending on the nature of the asset. If the project
includes a prototype that is a capital asset, the prototype may itself be one segment or may be divisible
into more than one segment. Because of uncertainty
regarding the identification of separate planning segments for research and development activities, the application of full funding concepts to research and development planning will need more study.
Useful asset: A useful asset is an economically and
programmatically separate segment of the asset procurement stage of the capital project that provides an
asset for which the benefits exceed the costs, even if
no further funding is appropriated. The total capital
asset procurement may include one or more useful assets, although it may not be possible to divide all procurements in this way. Illustrations follow:
Illustration 1: If the construction of a building meets
the justification criteria and has benefits greater than
its costs without further investment, then the construction of that building is a ‘‘useful segment.’’ Excavation
is not a useful segment because no useful asset results
from the excavation alone if no further funding becomes
available. For a campus of several buildings, a useful
segment is one complete building if that building has
programmatic benefits that exceed its costs regardless
of whether the other buildings are constructed, even
though that building may not be at its maximum use.
Illustration 2: If the full acquisition is for several
items (e.g., aircraft), the useful segment would be the
number of complete aircraft required to achieve benefits
that exceed costs even if no further funding becomes
available. In contrast, some portion of several aircraft
(e.g., engines for five aircraft) would not be a useful

165

segment if no further funding is available, nor would
one aircraft be a useful segment if two or more are
required for benefits to exceed costs.
Illustration 3: For information technology, a module
(the information technology equivalent of ‘‘useful segment’’) is separable if it is useful in itself without subsequent modules. The module should be designed so that
it can be enhanced or integrated with subsequent modules if future funding becomes available.
Earned Value
Earned value refers to a performance-based management system for establishing baseline cost, schedule,
and performance goals for a capital project and measuring progress against the goals. Earned value is described in OMB Circular A–11, Part 3, ‘‘Planning, Budgeting and Acquisition of Capital Assets’’ (July 1999),
Appendix 300C.
Funding
Full funding: Full funding means that appropriations—regular appropriations or advance appropriations—are enacted that are sufficient in total to complete a useful segment of a capital project before any
obligations may be incurred for that segment. Full
funding for an entire capital project is required if the
project cannot be divided into more than one useful
segment. If the asset can be divided into more than
one useful segment, full funding for a project may be
desirable, but is not required to constitute full funding.
Incremental (partial) funding: Incremental (partial)
funding means that appropriations—regular appropriations or advance appropriations—are enacted for just
part of a useful segment of a capital project, if the
project has useful segments, or for part of the capital
project as a whole, if it is not divisible into useful
segments. Under incremental funding for a capital
asset, which is not permitted under these principles,
the funds could be obligated to start the segment (or
project) despite the fact that they are insufficient to
complete a useful segment or project.
Risk Management
Risk management is an organized method of identifying and measuring risk and developing, selecting, and
managing options for handling these risks. Before beginning any procurement, managers should review and
revise as needed the acquisition plan to ensure that
risk management techniques considered in the planning
phase are still appropriate.
There are three key principles for managing risk
when procuring capital assets: (1) avoiding or limiting
the amount of development work; (2) making effective
use of competition and financial incentives; and (3) establishing a performance-based acquisition management system that provides for accountability for program successes and failures, such as an earned value
system or similar system.
There are several types of risk an agency should consider as part of risk management. The types of risk
include:

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•
•
•
•

ANALYTICAL PERSPECTIVES

schedule risk;
cost risk;
technical feasibility;
risk of technical obsolescence;

• dependencies between a new project and other
projects or systems (e.g., closed architectures); and
• risk of creating a monopoly for future procurement.

Part III: FEDERALLY FINANCED CAPITAL STOCKS
Federal investment spending creates a ‘‘stock’’ of capital that is available in the future for productive use.
Each year, Federal investment outlays add to the stock
of capital. At the same time, however, wear and tear
and obsolescence reduce it. This section presents very
rough measures over time of three different kinds of
capital stocks financed by the Federal Government:
public physical capital, research and development
(R&D), and education.
Federal spending for physical assets adds to the Nation’s capital stock of tangible assets, such as roads,
buildings, and aircraft carriers. These assets deliver
a flow of services over their lifetime. The capital depreciates as the asset ages, wears out, is accidentally damaged, or becomes obsolete.
Federal spending for the conduct of research, development, and education adds to an ‘‘intangible’’ asset, the
Nation’s stock of knowledge. Although financed by the
Federal Government, the research and development or
education can be performed by Federal or State government laboratories, universities and other nonprofit organizations, or private industry. Research and development covers a wide range of activities, from the investigation of subatomic particles to the exploration of
outer space; it can be ‘‘basic’’ research without particular applications in mind, or it can have a highly
specific practical use. Similarly, education includes a
wide variety of programs, assisting people of all ages
beginning with pre-school education and extending
through graduate studies and adult education. Like
physical assets, the capital stocks of R&D and education provide services over a number of years and
depreciate as they become outdated.
For this analysis, physical and R&D capital stocks
are estimated using the perpetual inventory method.
In this method, the estimates are based on the sum
of net investment in prior years. Each year’s Federal
outlays are treated as gross investment, adding to the
capital stock; depreciation reduces the capital stock.
Gross investment less depreciation is net investment.
A limitation of the perpetual inventory method is that
investment spending may not accurately measure the
value of the asset created. However, alternative methods for measuring asset value, such as direct surveys
of current market worth or indirect estimation based
on an expected rate of return, are especially difficult
to apply to assets that do not have a private market,
such as highways or weapons systems.
In contrast to physical and R&D stocks, the estimate
of the education stock is based on the replacement cost
method. Data on the total years of education of the
U.S. population are combined with data on the cost
of education and the Federal share of education spend-

ing to yield the cost of replacing the Federal share
of the Nation’s stock of education.
Additional detail about the methods used to estimate
capital stocks appears in a methodological note at the
end of this section. It should be stressed that these
estimates are rough approximations, and provide a
basis only for making broad generalizations. Errors may
arise from uncertainty about the useful lives and depreciation rates of different types of assets, incomplete
data for historical outlays, and imprecision in the
deflators used to express costs in constant dollars.
The Stock of Physical Capital
This section presents data on stocks of physical capital assets and estimates of the depreciation on these
assets.
Trends.—Table 6–6 shows the value of the net federally financed physical capital stock since 1960, in constant fiscal year 1996 dollars.3 After rising in the
1960s, the total stock held constant through the 1970s
and began rising again in the early 1980s. The stock
amounted to $2,013 billion in 1999 and is estimated
to increase slightly to $2,065 billion by 2001. In 1999,
the national defense capital stock accounted for $671
billion, or 33 percent of the total, and nondefense stocks
for $1,342 billion, or 67 percent of the total.
Real stocks of defense and nondefense capital show
very different trends. Nondefense stocks have grown
consistently since 1970, increasing from $536 billion
in 1970 to $1,342 billion in 1999. With the investments
proposed in the budget, nondefense stocks are estimated to grow to $1,417 billion in 2001. During the
1970s, the nondefense capital stock grew at an average
annual rate of 4.3 percent. In the 1980s, however, the
growth rate slowed to 2.7 percent annually, with growth
continuing at about that rate since then.
Real national defense stocks began in 1970 at a relatively high level, and declined steadily throughout the
decade, as depreciation from the Vietnam era exceeded
new investment in military construction and weapons
procurement. Starting in the early 1980s, however, a
large defense buildup began to increase the stock of
defense capital. By 1987, the defense stock had exceeded its size at the height of the Vietnam War. In the
last few years, depreciation on this increased stock and
a slower pace of defense investment have begun to reduce the stock from its recent levels. The stock is estimated to fall from $671 billion in 1999 to $648 billion
in 2001.
3 Constant dollar stock estimates are expressed in chained 1996 dollars, consistent with
the October 1999 revisions to the National Income and Product Accounts (NIPAs). The
shift to a more recent base year changes the reported level of real stocks, but leaves
the year-to-year trends largely the same.

6.

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FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–6. NET STOCK OF FEDERALLY FINANCED PHYSICAL CAPITAL
(In billions of 1996 dollars)
Nondefense
Fiscal Year

Five year intervals:
1960 ....................................................
1965 ....................................................
1970 ....................................................
1975 ....................................................
1980 ....................................................
1985 ....................................................
1990 ....................................................
Annual data:
1995 ....................................................
1996 ....................................................
1997 ....................................................
1998 ....................................................
1999 ....................................................
2000 est. .............................................
2001 est. .............................................

Total

National
Defense

Direct Federal Capital
Total
Nondefense

Total

Water
and
Power

Capital Financed by Federal Grants

Other

Total

Transportation

Community and
Regional

Natural
Resources

Other

978
1,056
1,200
1,245
1,338
1,550
1,823

682
644
664
587
518
606
756

296
412
536
658
820
944
1,068

145
181
205
226
253
278
309

89
108
123
139
159
171
180

56
72
82
88
94
107
129

151
231
331
432
567
666
759

93
163
237
291
350
406
473

27
33
47
75
116
140
151

21
23
27
41
76
96
108

10
12
20
25
26
25
27

1,956
1,969
1,982
1,993
2,013
2,038
2,065

742
721
701
685
671
658
648

1,214
1,248
1,281
1,308
1,342
1,380
1,417

347
355
362
364
372
380
387

187
188
187
187
187
188
189

160
168
175
178
185
192
199

867
893
919
944
970
1,000
1,030

546
562
578
594
611
631
651

160
163
166
169
171
174
177

117
119
120
121
123
124
125

44
49
54
60
65
71
77

Another trend in the Federal physical capital stocks
is the shift from direct Federal assets to grant-financed
assets. In 1960, 49 percent of federally financed nondefense capital was owned by the Federal Government,
and 51 percent was owned by State and local governments but financed by Federal grants. Expansion in
Federal grants for highways and other State and local
capital, coupled with relatively slow growth in direct
Federal investments by agencies such as the Bureau
of Reclamation and Corps of Engineers, shifted the composition of the stock substantially. In 1999, 28 percent
of the nondefense stock was owned by the Federal Government and 72 percent by State and local governments.
The growth in the stock of physical capital financed
by grants has come in several areas. The growth in
the stock for transportation is largely grants for highways, including the Interstate Highway System. The
growth in community and regional development stocks
occurred largely with the enactment of the community
development block grant in the early 1970s. The value
of this capital stock has grown only slowly in the past
few years. The growth in the natural resources area
occurred primarily because of construction grants for
sewage treatment facilities. The value of this federally
financed stock has increased about 30 percent since
the mid-1980s.
Table 6–7 shows nondefense physical capital outlays
both gross and net of depreciation since 1960. Total
nondefense net investment has been consistently positive over the period covered by the table, indicating
that new investment has exceeded depreciation on the
existing stock. For some categories in the table, such
as water and power programs, however, net investment
has been negative in some years, indicating that new
investment has not been sufficient to offset estimated
depreciation. The net investment in this table is the

change in the net nondefense physical capital stock displayed in Table 6–6.
The Stock of Research and Development Capital
This section presents data on the stock of research
and development, taking into account adjustments for
its depreciation.
Trends.—As shown in Table 6–8, the R&D capital
stock financed by Federal outlays is estimated to be
$898 billion in 1999 in constant 1996 dollars. About
two-fifths is the stock of basic research knowledge;
about three-fifths is the stock of applied research and
development.
The total federally financed R&D stock in 1999 was
about evenly divided between defense and nondefense.
Although investment in defense R&D has exceeded that
of nondefense R&D in every year since 1981, the nondefense R&D stock is actually the larger of the two,
because of the different emphasis on basic research and
applied research and development. Defense R&D spending is heavily concentrated in applied research and development, which depreciates much more quickly than
basic research. The stock of applied research and development is assumed to depreciate at a ten percent geometric rate, while basic research is assumed not to
depreciate at all.
The defense R&D stock rose slowly during the 1970s,
as gross outlays for R&D trended down in constant
dollars and the stock created in the 1960s depreciated.
A renewed emphasis on defense R&D spending from
1980 through 1990 led to a more rapid growth of the
R&D stock. Since then, real defense R&D outlays have
tapered off, depreciation has grown, and, as a result,
the net defense R&D stock has stabilized.
The growth of the nondefense R&D stock slowed from
the 1970s to the late 1980s, from an annual rate of

168

ANALYTICAL PERSPECTIVES

Table 6–7. COMPOSITION OF GROSS AND NET FEDERAL AND FEDERALLY FINANCED NONDEFENSE PUBLIC PHYSICAL
INVESTMENT
(In billions of 1996 dollars)
Total nondefense investment

Direct Federal investment

Investment financed by Federal grants

Composition of net
investment
Fiscal Year
Gross

Five year intervals:
1960 ........................
1965 ........................
1970 ........................
1975 ........................
1980 ........................
1985 ........................
1990 ........................
Annual data:
1995 ........................
1996 ........................
1997 ........................
1998 ........................
1999 ........................
2000 est. .................
2001 est. .................

Depreciation

Net

Depreciation

Gross

Net

Water
and
power

Composition of net investment
Gross

Depreciation

Net

Other

Transportation
(mainly
highways)

Community and
regional
development

Natural
resources
and
environment

Other

26.6
35.4
33.9
34.8
49.2
46.2
46.5

5.7
7.8
10.2
12.3
15.0
18.0
22.4

21.0
27.6
23.7
22.4
34.2
28.1
24.1

9.8
11.7
7.4
10.1
12.0
14.1
16.2

3.3
4.3
5.0
5.4
6.0
7.4
10.2

6.4
7.4
2.5
4.7
6.1
6.7
6.1

3.4
3.4
2.0
3.7
3.9
2.2
1.9

3.0
4.0
0.4
1.0
2.1
4.6
4.1

16.9
23.8
26.5
24.6
37.1
32.1
30.3

2.3
3.6
5.2
6.9
9.0
10.7
12.2

14.5
20.2
21.3
17.7
28.1
21.4
18.1

13.8
17.0
13.3
8.0
13.6
14.2
13.0

0.1
2.2
5.4
4.4
7.7
4.1
1.6

0.1
0.4
1.0
4.6
7.0
3.2
2.0

0.5
0.5
1.7
0.7
–0.2
–0.1
1.4

59.9
61.1
60.9
55.7
63.1
67.7
68.8

26.1
26.9
27.8
28.5
29.2
30.1
31.1

33.9
34.1
33.1
27.2
33.9
37.6
37.7

19.5
20.7
20.0
15.5
21.1
22.3
21.9

12.2
12.6
13.1
13.3
13.6
14.0
14.5

7.4
8.1
6.9
2.2
7.4
8.3
7.4

1.4
0.4
–0.5
–0.4
0.2
1.1
0.8

6.0
7.7
7.5
2.6
7.2
7.2
6.6

40.4
40.3
40.9
40.2
42.1
45.4
46.9

13.9
14.3
14.8
15.2
15.6
16.1
16.6

26.5
26.0
26.1
25.0
26.5
29.3
30.3

16.4
16.1
16.5
15.5
17.4
19.5
20.1

2.7
3.0
2.8
2.7
2.7
2.7
2.5

2.0
1.5
1.4
1.0
1.1
1.3
1.5

5.4
5.5
5.3
5.8
5.2
5.7
6.2

Table 6–8. NET STOCK OF FEDERALLY FINANCED RESEARCH AND DEVELOPMENT 1
(In billions of 1996 dollars)
National Defense
Fiscal Year
Total

Five year intervals:
1970 ..................................................................
1975 ..................................................................
1980 ..................................................................
1985 ..................................................................
1990 ..................................................................
Annual data:
1995 ..................................................................
1996 ..................................................................
1997 ..................................................................
1998 ..................................................................
1999 ..................................................................
2000 est. ..........................................................
2001 est. ..........................................................
1 Excludes

Basic
Research

Nondefense

Applied
Research
and
Development

Total

Basic
Research

Total Federal
Applied
Research
and
Development

Total

Basic
Research

Applied
Research
and
Development

245
260
263
302
379

15
19
23
28
34

231
240
240
274
345

202
247
292
319
360

63
91
124
164
215

139
155
169
155
145

447
507
555
621
739

78
111
147
192
249

370
396
408
429
490

398
400
402
403
404
405
405

40
41
42
43
44
46
47

358
359
359
359
360
359
359

434
447
461
477
494
512
532

277
289
303
315
329
343
359

157
157
158
161
165
169
173

832
847
863
879
898
917
938

317
331
345
359
373
389
406

515
516
518
521
524
528
532

outlays for physical capital for research and development, which are included in Table 6–6.

3.8 percent in the 1970s to a rate of 1.8 percent from
1980 to 1988. Gross investment in real terms fell during much of the 1980s, and about three-fourths of new
outlays went to replacing depreciated R&D. Since 1988,
however, nondefense R&D outlays have been on an upward trend while depreciation has edged down. As a
result, the net nondefense R&D capital stock has grown
more rapidly.
The Stock of Education Capital
This section presents estimates of the stock of education capital financed by the Federal government.
As shown in Table 6–9, the federally financed education stock is estimated at $964 billion in 1999 in

constant 1996 dollars, rising to $1,085 billion in 2001.
The vast majority of the Nation’s education stock is
financed by State and local governments, and by students and their families themselves. This federally financed portion of the stock represents about 3 percent
of the Nation’s total education stock.4 Nearly threequarters is for elementary and secondary education,
while the remaining one quarter is for higher education.
Despite a slowdown in growth during the early 1980s,
the stock grew at an average annual rate of 5.4 percent
from 1970 to 1999, and the expansion of the education
stock is projected to continue under this budget.
4 For estimates of the total education stock, see Table 2–4 in Chapter 2, ‘‘Stewardship:
Toward a Federal Balance Sheet.’’

6.

169

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–9. NET STOCK OF FEDERALLY FINANCED EDUCATION
CAPITAL
(In billions of 1996 dollars)
Total
Education
Stock

Fiscal Year

Five year intervals:
1960 ...............................................................................
1965 ...............................................................................
1970 ...............................................................................
1975 ...............................................................................
1980 ...............................................................................
1985 ...............................................................................
1990 ...............................................................................
Annual data:
1995 ...............................................................................
1996 ...............................................................................
1997 ...............................................................................
1998 ...............................................................................
1999 ...............................................................................
2000 est. ........................................................................
2001 est. ........................................................................

Note on Estimating Methods
This note provides further technical detail about the
estimation of the capital stock series presented in Tables 6–6 through 6–9.
As stated previously, the capital stock estimates are
very rough approximations. Sources of possible error
include:
Methodological issues.—The stocks of physical capital
and research and development are estimated with the
perpetual inventory method. A fundamental assumption
of this method is that each dollar of investment spending adds a dollar to the value of the capital stock in
the period in which the spending takes place. In reality,
the value of the asset created could be more or less
than the investment spending. As an extreme example,
in cases where a project is canceled before completion,
the spending on the project does not result in the creation of any asset. Even where asset value is equal
to investment spending, there might be timing differences in spending and the creation of a capital asset.
For example, payments for constructing an aircraft carrier might be made over a period of years, with the
capital asset only created at the end of the period.
The historical outlay series.—The historical outlay series for physical capital was based on budget records
since 1940 and was extended back to 1915 using data
from selected sources. There are no consistent outlay
data on physical capital for this earlier period, and
the estimates are approximations. In addition, the historical outlay series in the budget for physical capital
extending back to 1940 may be incomplete. The historical outlay series for the conduct of research and development began in the early 1950s and required selected
sources to be extended back to 1940. In addition, separate outlay data for basic research and applied R&D
were not available for any years and had to be estimated from obligations and budget authority. For education, data for Federal outlays from the budget were
combined with data for non-Federal spending from the

Elementary
and Secondary
Education

Higher
Education

66
92
212
305
432
533
701

48
66
166
245
336
397
517

19
26
46
60
96
136
184

791
822
859
912
964
1,027
1,085

574
596
623
663
705
756
804

217
226
237
249
260
271
282

institution or jurisdiction receiving Federal funds,
which may introduce error because of differing fiscal
years and confusion about whether the Federal Government was the original source of funding.
Price adjustments.—The prices for the components of
the Federal stock of physical, R&D, and education capital have increased through time, but the rates of increase are not accurately known. Estimates of costs
in fiscal year 1996 prices were made through the application of price measures from the National Income and
Product Accounts (NIPAs), but these should be considered only approximations of the costs of these assets
in 1996 prices.
Depreciation.—The useful lives of physical, R&D, and
education capital, as well as the pattern by which they
depreciate, are very uncertain. This is compounded by
using depreciation rates for broad classes of assets,
which do not apply uniformly to all the components
of each group. As a result, the depreciation estimates
should also be considered approximations. This limitation is especially important in capital financed by
grants, where the specific asset financed with the grant
is often subject to the discretion of the recipient jurisdiction.
Research continues on the best methods to estimate
these capital stocks. The estimates presented in the
text could change as better information becomes available on the underlying investment data and as improved methods are developed for estimating the stocks
based on those data.
Physical Capital Stocks
For many years, current and constant-cost data on
the stock of most forms of public and private physical
capital—e.g., roads, factories, and housing—have been
estimated annually by the Bureau of Economic Analysis
(BEA) in the Department of Commerce. With two recent
comprehensive revisions of the NIPAs in January 1996
and October 1999, government investment has taken

170
increased prominence. Government investment in physical capital is now reported separately from government
consumption expenditures, and government consumption expenditures include depreciation as a measure
of the services provided by the existing capital stock.
Government purchases of software are now included
as investment.5 In addition, as part of the most recent
revisions, a new table will explicitly link investment
and capital stocks by reporting the net stock of Government physical capital and decomposing the annual
change in the stock into investment, depreciation, extraordinary changes such as disasters, and revaluation.6
The BEA data are not directly linked to the Federal
budget, do not extend to the years covered by the budget, and do not separately identify the capital financed
but not owned by the Federal Government. For these
reasons, OMB prepares separate estimates for budgetary purposes, using techniques that roughly follow
the BEA methods.
Method of estimation.—The estimates were developed
from the OMB historical data base for physical capital
outlays and grants to State and local governments for
physical capital. These are the same major public physical capital outlays presented in Part I. This data base
extends back to 1940 and was supplemented by rough
estimates for 1915–1939.
The deflators used to convert historical outlays to
constant 1996 dollars were based on composite NIPA
deflators for Federal, State, and local consumption of
durables and gross investment, as revised in BEA’s October 1999 comprehensive NIPA revisions. Because
BEA had not yet released certain revised data prior
to calendar year 1959, deflators were estimated for
1930 to 1959 based on the growth rates in BEA’s prerevision data. For 1915 through 1929, deflators were
estimated from Census Bureau historical statistics on
constant price public capital formation.
The resulting capital stocks were aggregated into
nine categories and depreciated using geometric rates
roughly following those of BEA, which estimates depreciation using much more detailed categories.7 The geometric rates were 1.9 percent for water and power
projects; 2.4 percent for other direct non-defense construction and rehabilitation; 20.3 percent for non-defense equipment; 14.0 percent for defense equipment;
2.1 percent for defense structures; 1.6 percent for transportation grants; 1.7 percent for community and regional development grants; 1.5 percent for natural resources and environment grants; and 1.8 percent for
other nondefense grants.
Research and Development Capital Stocks
Method of estimation.—The estimates were developed
from a data base for the conduct of research and devel5 This change aligns BEA’s treatment of software with OMB’s definitions, which include
purchase and in-house development of major software as investment.
6 BEA’s most recent estimates of capital stocks, prepared prior to the October 1999 comprehensive revisions, appear in ‘‘Fixed Reproducible Tangible Wealth in the United States:
Revised Estimates for 1995–97 and Summary Estimates for 1925–97,’’ Survey of Current
Business, September 1998, pp. 36–46. Estimates reflecting the October 1999 revisions are
tentatively scheduled for publication in the March 2000 Survey of Current Business.

ANALYTICAL PERSPECTIVES

opment largely consistent with the data in the Historical Tables. Although there is no consistent time series
on basic and applied R&D for defense and nondefense
outlays back to 1940, it was possible to estimate the
data using obligations and budget authority. The data
are for the conduct of R&D only and exclude outlays
for physical capital for research and development, because those are included in the estimates of physical
capital. Nominal outlays were deflated by the chained
price index for gross domestic product (GDP) in fiscal
year 1996 dollars to obtain estimates of constant dollar
R&D spending.
The appropriate depreciation rate of intangible R&D
capital is even more uncertain than that of physical
capital. Empirical evidence is inconclusive. It was assumed that basic research capital does not depreciate
and that applied research and development capital has
a ten percent geometric depreciation rate. These are
the same assumptions used in a study published by
the Bureau of Labor Statistics estimating the R&D
stock financed by private industry.8 More recent experimental work at BEA, extending estimates of tangible
capital stocks to R&D, used slightly different assumptions. This work assumed straight-line depreciation for
all R&D over a useful life of 18 years, which is roughly
equivalent to a geometric depreciation rate of 11 percent. The slightly higher depreciation rate and its extension to basic research would result in smaller stocks
than the method used here.9
Education Capital Stocks
Method of estimation.—The estimates of the federally
financed education capital stock in Table 6–9 were calculated by first estimating the Nation’s total stock of
education capital, based on the current replacement
cost of the total years of education of the population,
including opportunity costs. To derive the Federal share
of this total stock, the Federal share of total educational
expenditures was applied to the total amount. The percent in any year was estimated by averaging the prior
years’ share of Federal education outlays in total education costs. For more information, refer to the technical note in Chapter 2, ‘‘Stewardship: Toward a Federal Balance Sheet.’’
The stock of capital estimated in Table 6–9 is based
only on spending for education. Stocks created by other
human capital investment outlays included in Table
6–1, such as job training and vocational rehabilitation,
were not calculated because of the lack of historical
data prior to 1962 and the absence of estimates of
depreciation rates.

7 BEA presented its depreciation methods and rates in ‘‘Improved Estimates of Fixed
Reproducible Tangible Wealth, 1929–95,’’ Survey of Current Business, May 1997, pp. 69–76.
8 See U.S. Department of Labor, Bureau of Labor Statistics, The Impact of Research
and Development on Productivity Growth, Bulletin 2331, September 1989.
9 See ‘‘A Satellite Account for Research and Development,’’ Survey of Current Business,
November 1994, pp. 37–71.

6.

171

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Part IV: ALTERNATIVE CAPITAL BUDGET AND CAPITAL EXPENDITURE PRESENTATIONS
A capital budget would separate Federal expenditures
into two categories: spending for investment and all
other spending. In this sense, Part I of the present
chapter provides a capital budget for the Federal Government, distinguishing outlays that yield long-term
benefits from all others. But alternative capital budget
presentations have also been suggested, and a capital
budget process may take many different forms.
The Federal budget mainly finances investment for
two quite different types of reasons. It invests in capital—such as office buildings, computers, and weapons
systems—that primarily contributes to its ability to provide governmental services to the public; some of these
services, in turn, are designed to increase economic
growth. And it invests in capital—such as highways,
education, and research—that contributes more directly

to the economic growth of the Nation. Most of the capital in the second category, unlike the first, is not
owned or controlled by the Federal Government. In the
discussion that follows, the first is called ‘‘Federal capital’’ and the second is called ‘‘national capital.’’ Table
6–10 compares total Federal investment as defined in
Part I of this chapter with investment in Federal capital, which was defined as ‘‘capital assets’’ in Part II
of this chapter, and with investment in national capital.
Some Federal investment is not classified as either Federal or national capital, and a relatively small part
is included in both categories.
Capital budgets and other changes in Federal budgeting have been suggested from time to time for the
Government’s investment in both Federal and national

Table 6–10. ALTERNATIVE DEFINITIONS OF INVESTMENT OUTLAYS, 2001
(In millions of dollars)
Investment Outlays
All types
of capital 1
Construction and rehabilitation:
Grants:
Transportation ............................................................................................
Natural resources and environment ..........................................................
Community and regional development ......................................................
Housing assistance ....................................................................................
Other grants ...............................................................................................
Direct Federal:
National defense ........................................................................................
General science, space, and technology ..................................................
Natural resources and environment ..........................................................
Energy ........................................................................................................
Transportation ............................................................................................
Veterans and other health facilities ...........................................................
Postal Service ............................................................................................
GSA real property activities .......................................................................
Other construction ......................................................................................

Federal
capital

National
capital

33,570
2,785
6,048
7,643
294

................
................
................
................
................

33,570
2,785
1,009
................
182

5,120
616
5,424
863
269
1,317
1,044
1,116
2,674

5,120
584
4,128
863
259
1,317
1,044
1,116
2,193

................
616
5,129
863
269
1,317
1,044
................
1,237

Total construction and rehabilitation .....................................................
Acquisition of major equipment (direct):
National defense .............................................................................................
Postal Service .................................................................................................
Air transportation ............................................................................................
Other ...............................................................................................................

68,783

16,624

48,021

51,076
714
1,965
5,504

51,076
714
1,965
4,728

................
714
1,965
3,333

Total major equipment ...............................................................................
Purchase or sale of land and structures ...........................................................
Other physical assets (grants) ...........................................................................

59,259
839
1,344

58,483
839
................

6,012
................
64

Total physical investment ...............................................................................
Research and development:
Defense ...........................................................................................................
Nondefense .....................................................................................................

130,225

75,946

54,097

40,914
39,447

................
................

1,184
38,889

Total research and development ...............................................................
Education and training ........................................................................................

80,361
56,590

................
................

40,073
56,214

Total investment outlays .....................................................................................

267,176

75,946

150,384

1 Total

outlays for ‘‘all types of capital‘‘ are equal to the total for ‘‘major Federal investment outlays’’ in Table
6–1. Some capital is not classified as either Federal or national capital, and a relatively small part is included in
both categories.

172

ANALYTICAL PERSPECTIVES

capital. These proposals differ widely in coverage, depending on the rationale for the suggestion. Some
would include all the investment shown in Table 6–1,
or more, whereas others would be narrower in various
ways. These proposals also differ in other respects, such
as whether investment would be financed by borrowing
and whether the non-investment budget would necessarily be balanced. Some of these proposals are discussed below and illustrated by alternative capital
budget and other capital expenditure presentations, although the discussion does not address matters of implementation such as the effect on the Budget Enforcement Act. The planning and budgeting process for capital assets, which is a different subject, is discussed
in Part II of this chapter together with the steps this
Administration is taking to improve it.
As discussed at the beginning of this chapter, the
Report of the President’s Commission to Study Capital
Budgeting considered both capital budgets and the
broader question of the planning and budgeting process
for capital assets. It made a series of recommendations
to improve budgeting for capital and setting priorities
for the Federal Government, but it did not recommend
changing the budget to make the size of the deficit
or surplus depend on the amount of expenditures defined as capital, to finance capital spending by borrowing, or to make a single decision about how much
to spend for ‘‘capital’’ under some definition.
Investment in Federal Capital
The goal of investment in Federal capital is to deliver
the right amount of Government services as efficiently
and effectively as possible. The Congress allocates resources to Federal agencies to accomplish a wide variety of programmatic goals. Because these goals are diverse and most are not measured in dollars, they are
difficult to compare with each other. Policy judgments
must be made as to their relative importance.
Once amounts have been allocated for one of these
goals, however, analysis may be able to assist in choosing the most efficient and effective means of delivering
service. This is the context in which decisions are made
on the amount of investment in Federal capital. For
example, budget proposals for the Department of Justice must consider whether to increase the number of
FBI agents, the amount of justice assistance grants
to State and local governments, or the number of Federal prisons in order to accomplish the department’s
objectives. The optimal amount of investment in Federal capital derives from these decisions. There is no
efficient target for total investment in Federal capital
as such either for a single agency or for the Government as a whole.
The universe of Federal capital encompasses all federally owned capital assets. It excludes Federal grants
to States for infrastructure, such as highways, and it
excludes intangible investment, such as education and
research. Investment in Federal capital in 2001 is estimated to be $75.9 billion, or 28 percent of the total
Federal investment outlays shown in Table 6–1. Of the

investment in Federal capital, 74 percent is for defense
and 26 percent for nondefense purposes.
A Capital Budget for Capital Assets
Discussion of a capital budget has often centered on
Federal capital, called ‘‘capital assets’’ in Part II of this
chapter—buildings, other construction, equipment, and
software that support the delivery of Federal services.
This includes capital commonly available from the commercial sector, such as office buildings, computers, military family housing, veterans hospitals, research and
development facilities, and associated equipment; it also
includes special purpose capital such as weapons systems, military bases, the space station, and dams. This
definition excludes capital that the Federal Government
has financed but does not own.10
Some capital budget proposals would partition the
unified budget into a capital budget, an operating budget, and a total budget. Table 6–11 illustrates such a
capital budget for capital assets as defined above. It
is accompanied by an operating budget and a total
budget. The operating budget consists of all expenditures except those included in the capital budget, plus
depreciation on the stock of assets of the type purchased through the capital budget. The capital budget
consists of expenditures for capital assets and, on the
income side of the account, depreciation. The total
budget is the present unified budget, largely based on
cash for its measure of transactions, which records all
outlays and receipts of the Federal Government. It consolidates the operating and capital budgets by adding
them together and netting out depreciation as an
intragovernmental transaction. The operating budget
has a smaller surplus than the unified budget. This
reflects both the relatively small Federal investment
in new capital assets and the offsetting effect of depreciation on the existing stock. Depreciation is larger than
capital expenditures by $4 billion. The figures in Table
6–11 and the subsequent tables of this section are
rough estimates, intended only to be illustrative and
to provide a basis for broad generalizations.
Some proposals for a capital budget would exclude
defense capital (other than military family housing).
These exclusions—weapons systems, military bases,
and so forth—would comprise three-fourths of the expenditures shown in the capital budget of Table 6–11.
If they were excluded, the operating budget would have
a surplus that was a little more than the unified budget
surplus: a surplus $6 billion higher than the unified
budget surplus instead of $4 billion lower as shown
above for the complete coverage of Federal capital. Excluding defense makes such a large difference because
of its large relative size and the recent pattern of capital asset purchases. The large defense buildup that
began in the early 1980s raised the capital stock and
depreciation; the buildup was followed by a sharp decline in purchases, while the capital stock and depreciation have declined more slowly. (See the previous sec10 This definition of ‘‘capital assets’’ is the same as used in the budget in recent years.
Narrower definitions of ‘‘fixed assets’’ were used in earlier budgets.

6.

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–11. CAPITAL, OPERATING, AND UNIFIED BUDGETS:
FEDERAL CAPITAL, 2001 1
(In billions of dollars)
Operating Budget
Receipts ..................................................................................................
Expenses:
Depreciation .......................................................................................
Other ..................................................................................................

80
1,759

Subtotal, expenses ........................................................................

1,839

Surplus or deficit (–) ..........................................................................
Capital Budget
Income: depreciation ..............................................................................
Capital expenditures ..............................................................................

180

Surplus or deficit (–) ..........................................................................
Unified Budget
Receipts ..................................................................................................
Outlays ...................................................................................................

4
2,019
1,835

Surplus or deficit (–) 2 .......................................................................

184

2,019

80
76

1 Historical

data to estimate the capital stocks and calculate depreciation are not readily available for Federal
capital. Depreciation estimates were based on the assumption that outlays for Federal capital were a constant
percentage of the larger categories in which such outlays were classified. They are also subject to the limitations explained in Part III of this chapter. Depreciation is measured in terms of current cost, not historical cost.
2 The surplus allocation for debt reduction is part of the President’s overall budgetary framework to extend
the solvency of Social Security and Medicare, and is shown in Table S–1 in Part 6 of the 2001 Budget.

tion of this chapter.) As a result, capital expenditures
for defense in 2001 are estimated to be $10 billion
less than depreciation, whereas capital expenditures for
nondefense purposes (plus military family housing) are
estimated to be $6 billion more.
Budget Discipline and a Capital Budget
Many proposals for a capital budget, though not all,
would effectively dispense with the unified budget and
make expenditure decisions on capital asset acquisitions in terms of the operating budget instead. When
the Government proposed to purchase a capital asset,
the operating budget would include only the estimated
depreciation. For example, suppose that an agency proposed to buy a $50 million building at the beginning
of the year with an estimated life of 25 years and
with depreciation calculated by the straightline method.
Operating expense in the budget year would increase
by $2 million, or only 4 percent of the asset cost. The
same amount of depreciation would be recorded as an
increase in operating expense for each year of the asset’s life.11
Recording the annual depreciation in the operating
budget each year would provide little control over the
decision about whether to invest in the first place. Most
Federal investments are sunk costs and as a practical
matter cannot be recovered by selling or renting the
asset. At the same time, there is a significant risk
that the need for a capital asset may change over a
period of years, because either the need was not perma11 The amount of depreciation that typically would be recorded as an expense in the
budget year is overstated by this illustration. First, most assets are purchased after the
beginning of the year, in which case less than a full year’s depreciation would be recorded.
Second, assets may be constructed or built to order, in which case no depreciation would
be recorded until the work was completed and the asset put into service. This could be
several years after the initial expenditure.

173

nent, it was initially misjudged, or other needs become
more important. Since the cost is sunk, however, control
cannot be exercised later on by comparing the annual
benefit of the asset services with depreciation and interest and then selling the asset if its annual services
are not worth this expense. Control can only be exercised up front when the Government commits itself to
the full sunk cost. By spreading the real cost of the
project over time, however, use of the operating budget
for expenditure decisions would make the budgetary
cost of the capital asset appear very cheap when decisions were being made that compared it to alternative
expenditures. As a result, there would be an incentive
to purchase capital assets with little regard for need,
and also with little regard for the least-cost method
of acquisition.
A budget is a financial plan for allocating resources—
deciding how much the Federal Government should
spend in total, program by program, and for the parts
of each program. The budgetary system provides a process for proposing policies, making decisions, implementing them, and reporting the results. The budget
needs to measure costs accurately so that decision makers can compare the cost of a program with its benefit,
the cost of one program with another, and the cost
of alternative methods of reaching a specified goal.
These costs need to be fully included in the budget
up front, when the spending decision is made, so that
executive and congressional decision makers have the
information and the incentive to take the total costs
into account in setting priorities.
The unified budget does this for investment. By recording investment on a cash basis, it causes the total
cost to be compared up front in a rough and ready
way with the total expected future net benefits. Since
the budget measures only cost, the benefits with which
these costs are compared, based on policy makers’ judgment, must be presented in supplementary materials.
Such a comparison of total cost with benefits is consistent with the formal method of cost-benefit analysis
of capital projects in government, in which the full cost
of a capital asset as the cash is paid out is compared
with the full stream of future benefits (all in terms
of present values).12 This comparison is also consistent
with common business practice, in which capital budgeting decisions for the most part are made by comparing cash flows. The cash outflow for the full purchase price is compared with expected future cash
inflows, either through a relatively sophisticated technique of discounted cash flows—such as net present
value or internal rate of return—or through cruder
methods such as payback periods.13 Regardless of the
12 For example, see Edward M. Gramlich, A Guide to Benefit-Cost Analysis (2nd ed.;
Englewood Cliffs: Prentice Hall, 1990), chap. 6; or Joseph E. Stiglitz, Economics of the
Public Sector (2nd ed.; New York: Norton, 1988), chap. 10. This theory is applied in formal
OMB instructions to Federal agencies in OMB Circular No. A–94, Guidelines and Discount
Rates for Benefit-Cost Analysis of Federal Programs (October 29, 1992). General Accounting
Office, Discount Rate Policy, GAO/OCE-17.1.1 (May 1991), discusses the appropriate discount
rate for such analysis but not the foundation of the analysis itself, which is implicitly
assumed.
13 For a full textbook analysis of capital budgeting techniques in business, see Harold
Bierman, Jr., and Seymour Smidt, The Capital Budgeting Decision (8th ed.; Saddle River,
N.J.: Prentice-Hall, 1993). Shorter analyses from the standpoints of corporate finance and
cost accounting may be found, for example, in Richard A. Brealey and Stewart C. Myers,

174
specific technique adopted, it usually requires comparing future returns with the entire cost of the asset
up front—not spread over time through annual depreciation.14
Practice Outside the Federal Government
The proponents of making investment decisions on
the basis of an operating budget with depreciation have
sometimes claimed that this is the common practice
outside the Federal Government. However, while the
practice of others may differ from the Federal budget
and the terms ‘‘capital budget’’ and ‘‘capital budgeting’’
are often used, these terms do not normally mean that
capital asset acquisitions are decided on the basis of
annual depreciation cost. The use of these terms in
business and State government also does not mean that
businesses and States finance all their investment by
borrowing. Nor does it mean that under a capital budget the extent of borrowing by the Federal Government
to finance investment would be limited by the same
forces that constrain business and State borrowing for
investment.
Private business firms call their investment decision making process ‘‘capital budgeting,’’ and they
record the resulting planned expenditures in a ‘‘capital
budget.’’ However, decisions are normally based on upfront comparisons of the cash outflows needed to make
the investment with the resulting cash inflows expected
in the future, as explained above, and the capital budget records the period-by-period cash outflows proposed
for capital projects.15 This supports the business’s goal
of deciding upon and controlling the use of its resources.
The cash-based focus of business budgeting for capital
is in contrast to business financial statements—the income statement and balance sheet—which use accrual
accounting for a different purpose, namely, to record
how well the business is meeting its objective of earning
profit and accumulating wealth for its owners. For this
purpose, the income statement shows the profit in a
year from earning revenue net of the expenses incurred.
These expenses include depreciation, which is an allocation of the cost of capital assets over their estimated
useful life. With similar objectives in mind, the Office
of Management and Budget, the Treasury Department,
and the General Accounting Office have adopted the
use of depreciation on general property, plant, and
equipment owned by the Federal Government as a
Principles of Corporate Finance (5th ed.; New York: McGraw-Hill, 1996), chap. 2, 5, and
6; Charles T. Horngren et al., Cost Accounting (9th ed.; Upper Saddle River, N.J.: PrenticeHall, 1997), chap. 22 and 23; Jerold L. Zimmerman, Accounting for Decision Making and
Control (Chicago: Irwin, 1995), chap. 3; and Surendra S. Singhvi, ‘‘Capital-Investment Budgeting Process’’ and ‘‘Capital-Expenditure Evaluation Methods,’’ chap. 19 and 20 in Robert
Rachlin, ed., Handbook of Budgeting (4th ed.; New York: Wiley, 1999).
14 Two surveys of business practice conducted a few years ago found that such techniques
are predominant. See Thomas Klammer et al., ‘‘Capital Budgeting Practices—A Survey
of Corporate Use,’’ Journal of Management and Accounting Research, vol. 3 (Fall 1991),
pp. 113–30; and Glenn H. Petry and James Sprow, ‘‘The Theory and Practice of Finance
in the 1990s,’’ The Quarterly Review of Economics and Finance, vol. 33 (Winter 1993),
pp. 359–82. Petry and Sprow also found that discounted cash flow techniques are recommended by the most widely used textbooks in managerial finance.
15 A business capital budget is depicted in Glenn A. Welsch et al., Budgeting: Profit
Planning and Control (5th ed.; Englewood Cliffs: Prentice Hall, 1988), pp. 396–99.

ANALYTICAL PERSPECTIVES

measure of expense in financial statements and cost
accounting for Federal agencies.16
Businesses finance investment from net income, cash
on hand, and other sources as well as borrowing. When
they borrow to finance investment, they are constrained
in ways that Federal borrowing is not. The amount
that a business borrows is limited by its own profit
motive and the market’s assessment of its capacity to
repay. The greater a business’s indebtedness, other
things equal, the more risky is any additional borrowing and the higher is the cost of funds it must
pay. Since the profit motive ensures that a business
will not want to borrow unless the expected return
is at least as high as the cost of funds, the amount
of investment that a business will want to finance is
limited; it has an incentive to borrow only for projects
where the expected return is as high or higher than
the cost of funds. Furthermore, if the risk is great
enough, a business may not be able to find a lender.
No such constraint limits the Federal Government—
either in the total amount of its borrowing for investment, or in its choice of which assets to buy—because
of its sovereign power to tax and the wide economic
base that it taxes. It can tax to pay for investment;
and, if it borrows, its power to tax ensures that the
credit market will judge U.S. Treasury securities free
from any risk of default even if it borrows ‘‘excessively’’
or for projects that do not seem worthwhile.
Most States also have a ‘‘capital budget,’’ but the
operating budget is not like the operating budget envisaged by proponents of making Federal investment decisions on the basis of depreciation. State capital budgets
differ widely in many respects but generally relate some
of the State’s purchases of capital assets to borrowing
and other earmarked means of financing. For the debtfinanced portion of investment, the interest and repayment of principal are usually recorded as expenditures
in the operating budget. For the portion of investment
purchased in the capital budget but financed by Federal
grants or State taxes, which may be substantial, State
operating budgets do not record any amount. No State
operating budget is charged for depreciation.17
States also do not record depreciation expense in the
financial accounting statements for governmental
funds. They currently record depreciation expense only
in their proprietary (commercial-type) funds and in
those trust funds where net income, expense, or capital
16 Office of Management and Budget, Statement of Federal Financial Accounting Standards
No. 6, Accounting for Property, Plant, and Equipment (November 30, 1995), pp. 5–14 and
34–35. This Statement was recommended by the Federal Accounting Standards Advisory
Board. Depreciation is not used as a measure of expense for heritage assets, or for weapons
systems and other national defense property, plant, and equipment. Depreciation also is
not used as a measure of expense for physical property financed by the Federal Government
but owned by State and local governments, or for investment that the Federal Government
finances in human capital and research and development.
17 The characteristics of State capital budgets were examined in a survey of State budget
officers for all 50 States in 1986. See Lawrence W. Hush and Kathleen Peroff, ‘‘The Variety
of State Capital Budgets: A Survey,’’ Public Budgeting and Finance (Summer 1988), pp.
67–79. More detailed results are available in an unpublished OMB document, ‘‘State Capital
Budgets’’ (July 7, 1987). Two GAO reports examined State capital budgets and reached
similar conclusions on the issues in question. See Budget Issues: Capital Budgeting Practices
in the States, GAO/AFMD–86–63FS (July 1986), and Budget Issues: State Practices for
Financing Capital Projects, GAO/AFMD–89–64 (July 1989). For further information about
state capital budgeting, see National Association of State Budget Officers, Capital Budgeting
in the States (September 1997).

6.

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

175

maintenance is measured.18 Under new financial accounting standards, however, depreciation on most capital assets will be recognized as an expense in government-wide financial statements. This will become effective for fiscal periods beginning during 2001–03, depending on the size of the government.19
State borrowing to finance investment, like business
borrowing, is subject to limitations that do not apply
to Federal borrowing. Like business borrowing, it is
constrained by the credit market’s assessment of the
State’s capacity to repay, which is reflected in the credit
ratings of its bonds. Rating agencies place significant
weight on the amount of debt outstanding compared
to the economic output generated by the State. Furthermore, borrowing is usually designated for specified investments, and it is almost always subject to constitutional limits or referendum requirements.
Other developed nations tend to show a more systematic breakdown between investment and operating
expenditures within their budgets than does the United
States, even while they record capital expenditures on
a cash basis within the same budget totals. The French
budget, for example, is divided into separate titles of
which some are for current expenditures and others
for capital expenditures. However, a recent study of
European countries found only four that had a real
difference between a current budget and a capital budget (Greece, Ireland, Luxembourg, and Portugal); 20 and
a survey by the Congressional Budget Office in 1993
found only two developed nations, Chile and New Zealand, that recognize depreciation in their budgets.21
New Zealand, moreover, while budgeting on an accrual
basis that generally includes depreciation, requires the
equivalent of appropriations for the full cost up front
before a department can make net additions to its capital assets or before the government can acquire certain
capital assets such as state highways.22
More recently, Australia has adopted an accrual
budget as of its 1999–2000 fiscal year, although appropriations are required for departments with inadequate
funds to replace capital assets. The budget has several
measures of fiscal position: the operating balance is
fully accrual; while the fiscal balance, the primary fiscal
measure, is closer to a cash basis and includes the
purchase of property, plant, and equipment rather than
depreciation. The United Kingdom has adopted a rule
that it will borrow only for net investment (after depreciation), averaged over the economic cycle. It plans to
budget on an accrual basis, including the depreciation
of capital assets, beginning with its budget for 2001–02;

an appropriation would be required for cash payments
for capital assets made in the fiscal year, but this would
not be included in the ‘‘resource budget.’’ On the other
hand, some countries—including Sweden, Denmark,
Finland, and the Netherlands—formerly had separate
capital budgets but abandoned them a number of years
ago.23
Many developing countries operate a dual budget
system comprising a regular or recurrent budget and
a capital or development budget. The World Bank staff
has concluded that:
‘‘The dual budget may well be the single most
important culprit in the failure to link planning,
policy and budgeting, and poor budgetary outcomes. The dual budget is misconceived because
it is based on a false premise that capital expenditure by government is more productive than current expenditure. Separating development and recurrent budgets usually leads to the development
budget having a lower hurdle for entry. The result
is that everyone seeks to redefine their expenditure as capital so it can be included in the development budget. Budget realities are left to the
recurrent budget to deal with, and there is no
pretension that expenditure proposals relate to
policy priorities.’’ 24

18 Governmental Accounting Standards Board (GASB), Codification of Governmental Accounting and Financial Reporting Standards as of June 30, 1999, sections 1100.107 and
1400.114–1400.118.
19 Governmental Accounting Standard Board, Statement No. 34, Basic Financial Statements—and Management’s Discussion and Analysis—for State and Local Governments (October 1999), paragraphs 18–29 and 44–45. For discussion, see paragraphs 330–43.
20 M. Peter van der Hoek, ‘‘Fund Accounting and Capital Budgeting: European Experience,’’
Public Budgeting and Financial Management, vol. 8 (Spring 1996), pp. 39–40.
21 Robert W. Hartman, Statement before the Subcommittee on Economic Development,
Committee on Public Works and Transportation, U.S. House of Representatives (May 26,
1993). Hartman stated: ‘‘to our knowledge, only two developed countries, Chile and New
Zealand, recognize depreciation in their budgets.’’
22 New Zealand’s use of depreciation in its budget is discussed in GAO, Budget Issues:
The Role of Depreciation in Budgeting for Certain Federal Investments, GAO/AIMD–95–34
(February 1995), pp. 13 and 16–17.

23 The budgets in Sweden, Great Britain, Germany, and France are described in GAO,
Budget Issues: Budgeting Practices in West Germany, France, Sweden, and Great Britain,
GAO/AFMD–87–8FS (November 1986). Sweden had separate capital and operating budgets
from 1937 to 1981, together with a total consolidated budget from 1956 onwards. The
reasons for abandoning the capital budget are discussed briefly in the GAO report and
more extensively by a government commission established to recommend changes in the
Swedish budget system. One reason was that borrowing was no longer based on the distinction between current and capital budgets. See Sweden, Ministry of Finance, Proposal for
a Reform of the Swedish Budget System: A Summary of the Report of the Budget Commission
Published by the Ministry of Finance (Stockholm, 1974), chapter 10.
24 The World Bank, Public Expenditure Management Handbook (Washington, D.C.: The
World Bank, 1998), Box 3.11, page 53.
25 GAO, Budget Issues: Incorporating an Investment Component in the Federal Budget,
GAO/AIMD–94–40 (November 1993), p. 11. GAO had made the same recommendation in
earlier reports but with less extensive analysis.

Conclusions
It is for reasons such as these that the General Accounting Office issued a report in 1993 that criticized
budgeting for capital in terms of depreciation. Although
the criticisms were in the context of what is termed
‘‘national capital’’ in this chapter, they apply equally
to ‘‘Federal capital.’’
‘‘Depreciation is not a practical alternative for the
Congress and the administration to use in making
decisions on the appropriate level of spending intended to enhance the nation’s long-term economic
growth for several reasons. Currently, the law requires agencies to have budget authority before
they can obligate or spend funds. Unless the full
amount of budget authority is appropriated up
front, the ability to control decisions when total
resources are committed to a particular use is reduced. Appropriating only annual depreciation,
which is only a fraction of the total cost of an
investment, raises this control issue.’’ 25
After further study of the role of depreciation in
budgeting for national capital, GAO reiterated that con-

176

ANALYTICAL PERSPECTIVES

clusion in another study in 1995.26 ‘‘The greatest disadvantage . . . was that depreciation would result in a
loss of budgetary control under an obligation-based
budgeting system.’’ 27 Although that study also focused
primarily on what is termed ‘‘national capital’’ in this
chapter, its analysis applies equally to ‘‘Federal capital.’’ In 1996 GAO extended its conclusions to Federal
capital as well. ‘‘If depreciation were recorded in the
federal budget in place of cash requirements for capital
spending, this would undermine Congress’ ability to
control expenditures because only a small fraction of
an asset’s cost would be included in the year when
a decision was made to acquire it.’’ 28
Investment in National Capital
A Target for National Investment
The Federal Government’s investment in national
capital has a much broader and more varied form than
its investment in Federal capital. The Government’s
goal is to support and accelerate sustainable economic
growth for the Nation as a whole and in some instances
for specific regions or groups of people. The Government’s investment concerns for the Nation are two-fold:
• The effect of its own investment in national capital
on the output and income that the economy can
produce. Reducing expenditure on consumption
and increasing expenditure on investment that
supports economic growth is a major priority for
the Administration. It has reordered priorities in
its budgets by proposing increases in selected investments.
• The effect of Federal taxation, borrowing, and
other policies on private investment. The Administration’s deficit reduction policy has brought about
an expansion of private investment, most notably
in producers’ durable equipment.
In its 1993 report, Incorporating an Investment Component in the Federal Budget, the General Accounting
Office (GAO) recommended establishing an investment
component within the unified budget—but not a separate capital budget or the use of depreciation—for this
type of investment.29 GAO defined this investment as
‘‘federal spending, either direct or through grants, that
is directly intended to enhance the private sector’s longterm productivity.’’ 30 To increase investment—both
public and private—GAO recommended establishing
targets for the level of Federal investment and for a
declining path of unified budget deficits over time.31
Such a target for investment in national capital would
focus attention on policies for growth, encourage a conscious decision about the overall level of growth-enhancing investment, and make it easier to set spending
priorities in terms of policy goals for aggregate forma26 GAO, Budget Issues: The Role of Depreciation in Budgeting for Certain Federal Investments, GAO/AIMD–95–34 (February 1995), pp. 1 and 19–20.
27 Ibid., p. 17. Also see pp. 1–2 and 16–19.
28 GAO, Budget Issues: Budgeting for Federal Capital, GAO/AIMD–97–5 (November 1996),
p. 28. Also see p. 4.
29 Incorporating an Investment Component in the Federal Budget, pp. 1–2, 9–10, and
15.
30 Ibid., pp. 1 and 5.
31 Ibid., pp. 2 and 13–16.

tion of national capital. GAO reiterated its recommendation in another report in 1995.32
Table 6–12. UNIFIED BUDGET WITH NATIONAL INVESTMENT
COMPONENT, 2001
(In billions of dollars)
Receipts ....................................................................................................
Outlays:
National investment .............................................................................
Other ....................................................................................................

2,019
150
1,685

Subtotal, outlays ..............................................................................

1,835

Surplus or deficit (–) 1 .........................................................................

184

1 The

surplus allocation for debt reduction is part of the President’s overall budgetary framework to extend
the solvency of Social Security and Medicare, and is shown in Table S–1 in Part 6 of the 2001 Budget.

Table 6–12 illustrates the unified budget reorganized
as GAO recommends to have a separate component for
investment in national capital. This component is
roughly estimated to be $150 billion in 2001. It includes
infrastructure outlays financed by Federal grants to
State and local governments, such as highways and
sewer projects, as well as direct Federal purchases of
infrastructure, such as electric power generation equipment. It also includes intangible investment for nondefense research and development, for basic research
financed through defense, and for education and training. Much of this expenditure consists of grants and
credit assistance to State and local governments, nonprofit organizations, or individuals. Only 10 percent of
national investment consists of assets to be owned by
the Federal Government. Military investment and some
other ‘‘capital assets’’ as defined previously are excluded, because that investment does not primarily enhance economic growth.
A Capital Budget for National Investment
Table 6–13 roughly illustrates what a capital budget
and operating budget would look like under this definition of investment—although it must be emphasized
that this is not GAO’s recommendation. Some proponents of a capital budget would make spending decisions within the framework of such a capital budget
and operating budget. But the limitations that apply
to the use of depreciation in deciding on investment
decisions for Federal capital apply even more strongly
in deciding on investment decisions for national capital.
Most national capital is neither owned nor controlled
by the Federal Government. Such investments are sunk
costs completely and can be controlled only by decisions
made up front when the Government commits itself
to the expenditure.33
In addition to these basic limitations, the definition
of investment is more malleable for national capital
than Federal capital. Many programs promise long-term
intangible benefits to the Nation, and depreciation rates
32 The

Role of Depreciation in Budgeting for Certain Investments, pp. 2 and 19–20.
conclusions about the loss of budgetary control that were quoted at the end
of the section on Federal capital came from studies that predominantly considered ‘‘national
capital.’’
33 GAO’s

6.

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Table 6–13. CAPITAL, OPERATING, AND UNIFIED BUDGETS:
NATIONAL CAPITAL, 2001 1
(In billions of dollars)
Operating Budget
Receipts ..................................................................................................
Expenses:
Depreciation 2 .....................................................................................
Other ..................................................................................................

74
1,685

Subtotal, expenses ........................................................................

1,758

Surplus or deficit (–) ..........................................................................
Capital Budget
Income:
Depreciation 2 .....................................................................................
Earmarked tax receipts 3 ...................................................................

222

Subtotal, income ............................................................................
Capital expenditures ..............................................................................

112
150

Surplus or deficit (–) ..........................................................................
Unified Budget
Receipts ..................................................................................................
Outlays ...................................................................................................

–38
2,019
1,835

Surplus or deficit (–) 4 ...................................................................

184

1,981

74
38

1 For

the purpose of this illustrative table only, education and training outlays are arbitrarily depreciated over
30 years by the straight-line method. This differs from the treatment of education and training elsewhere in this
chapter and in Chapter 2. All depreciation estimates are subject to the limitations explained in Part III of this
chapter. Depreciation is measured in terms of current cost, not historical cost.
2 Excludes depreciation on capital financed by earmarked tax receipts allocated to the capital budget.
3 Consists of tax receipts of the highway and airport and airways trust funds, less trust fund outlays for operating expenditures. These are user charges earmarked for financing capital expenditures.
4 The surplus allocation for debt reduction is part of the President’s overall budgetary framework to extend
the solvency of Social Security and Medicare, and is shown in Table S–1 in Part 6 of the 2001 Budget.

are much more difficult to determine for intangible investment such as research and education than they
are for physical investment such as highways and office
buildings. These and other definitional questions are
hard to resolve. The answers could significantly affect
budget decisions, because they would determine whether the budget would record all or only a small part
of the cost of a decision when policy makers were comparing the budgetary cost of a project with their judgment of its benefits. The process of reaching an answer
with a capital budget would open the door to manipulation, because there would be an incentive to make the
operating expenses and deficit look smaller by
classifying outlays as investment and using low depreciation rates. This would ‘‘justify’’ more spending by
the program or the Government overall.34
A Capital Budget and the Analysis of Saving
and Investment
Data from the Federal budget may be classified in
many different ways, including analyses of the Government’s direct effects on saving and investment. As Parts
I and III of this chapter have shown, the unified budget
provides data that can be used to calculate Federal
34 These problems are also pointed out in GAO, Incorporating an Investment Component
in the Federal Budget, pp. 11–12. They are discussed more extensively with respect to
highway grants, research and development, and human capital in GAO, The Role of Depreciation in Budgeting for Certain Federal Investments, pp. 11–14. GAO found no government
that budgets for the depreciation of infrastructure (whether or not owned by that government), human capital, or research and development (except that New Zealand budgets
for the depreciation of research and development if it results in a product that is intended
to be used or marketed).

177

investment outlays and federally financed capital
stocks. However, the budget totals themselves do not
make this distinction. In particular, the budget surplus
or deficit does not measure the Government’s contribution to the nation’s net saving (i.e., saving net of depreciation). A capital budget, it is sometimes contended,
is needed for this purpose.
This purpose, however, is now fulfilled by the Federal
sector of the national income and product accounts
(NIPA) according to one definition of investment. The
NIPA Federal sector measures the impact of Federal
current receipts, current expenditures, and the current
surplus or deficit on the national economy. It is part
of an integrated set of measures of aggregate U.S. economic activity that is prepared by the Bureau of Economic Analysis in the Department of Commerce in
order to measure gross domestic product (GDP), the
income generated in its production, and many other
variables used in macroeconomic analysis. The NIPA
Federal sector for recent periods is published monthly
in the Survey of Current Business with separate releases for historical data. Estimates for the President’s
proposed budget through the budget year are normally
published in the budget documents. The NIPA translation of the budget, rather than the budget itself, is
ordinarily used by economists to analyze the effect of
Government fiscal policy on the aggregate economy.35
Until four years ago the NIPA Federal sector did
not divide government purchases of goods and services
between consumption and investment. With the comprehensive revision of the national income and product
accounts in early 1996, it now makes that distinction.36
The revised NIPA Federal Government account is a
current account or an operating account for the Federal
Government and accordingly shows current receipts and
current expenditures. It excludes expenditures for
structures, equipment, and software owned by the Federal Government; it includes depreciation on the federally owned stock of structures, equipment, and software
as a proxy for the services of capital assets consumed
in production and thus as part of the Federal Government’s current expenditures. It applies this treatment
to a comprehensive definition of federally owned structures, equipment, and software, both defense and nondefense, similar to the definition of ‘‘capital assets’’ in
this chapter.37
35 See chapter 16 of this volume, ‘‘National Income and Product Accounts,’’ for the NIPA
current account of the Federal Government based on the budget estimates for 2000 and
2001, and for a discussion of the NIPA Federal sector and its relationship to the budget.
36 This distinction is also made in the national accounts of most other countries and
in the System of National Accounts (SNA), which is guidance prepared by the United
Nations and other international organizations. Definitions of investment vary. For example,
the SNA does not include the purchase of military equipment as investment.
37 The treatment of investment (except for the recent recognition of software) in the
NIPA Federal sector is explained in Survey of Current Business, ‘‘Preview of the Comprehensive Revision of the National Income and Product Accounts: Recognition of Government
Investment and Incorporation of a New Methodology for Calculating Depreciation’’ (September 1995), pp. 33–39. As is the case of private sector investment, government investment
does not include expenditures on research and development or on education and training.
Government purchases of structures, equipment, and software remain a part of gross domestic product (GDP) as a separate component. The NIPA State and local government account
is defined in the same way and includes depreciation on structures, equipment, and software
owned by State and local governments that were financed by Federal grants as well as
by their own resources. Depreciation is not displayed as a separate line item in the government account: depreciation on general government capital assets is included in government
‘‘consumption expenditures’’; and depreciation on the capital assets of government enterprises
is subtracted in calculating the ‘‘current surplus of government enterprises.’’

178

ANALYTICAL PERSPECTIVES

The NIPA ‘‘current surplus or deficit’’ of the Federal
Government thus measures the Government’s direct
contribution to the Nation’s net saving (given the definition of investment that is employed). The 1999 Federal
Government current account surplus was increased $2
billion by including depreciation rather than gross investment, because depreciation of federally owned
structures, equipment, and software was less than gross
investment. The 2001 Federal current account surplus
is estimated to be increased $16 billion. 38 A capital
budget is not needed to capture this effect.
Borrowing to Finance a Capital Budget
A further issue raised by a capital budget is the
financing of capital expenditures. Some have argued
that the Government ought to balance the operating
budget and borrow to finance the capital budget—capital expenditures less depreciation. The rationale is that
if the Government borrows for net investment and the
rate of return exceeds the interest rate, the additional
debt does not add a burden onto future generations.
Instead, the burden of paying interest on the debt and
repaying its principal is spread over the generations
that will benefit from the investment. The additional
debt is ‘‘justified’’ by the additional assets.
This argument is at best a justification to borrow
to finance net investment, after depreciation is subtracted from gross outlays, not to borrow to finance
gross investment. To the extent that capital is used
up during the year, there are no additional assets to
justify additional debt. If the Government borrows to
finance gross investment, the additional debt exceeds
the additional capital assets. The Government is thus
adding onto the amount of future debt service without
providing the additional capital that would produce the
additional income needed to service that debt.
This justification, furthermore, requires that depreciation be measured in terms of the current replacement cost, not the historical cost. Current cost depreciation is needed in order to measure all activities in the
budget on a consistent basis, since other outlays and
receipts are automatically measured in the prices of
the current year. Current cost depreciation is also needed to obtain a valid measure of net investment. This
requires that the addition to the capital stock from
new purchases and the subtraction from depreciation
on existing assets both be measured in the prices of
the same year. When prices change, historical cost depreciation does not measure the extent to which the
capital stock is used up each year.
As a broad generalization, Tables 6–11 and 6–13 suggest that this rationale would not currently justify a
great deal of Federal borrowing, if any at all, under
the two capital budgets roughly illustrated in this chapter. For Federal capital, Table 6–11 indicates that current cost depreciation is more than gross investment
for Federal capital—the capital budget surplus is $4
billion. The rationale of borrowing to finance net invest38 See actuals and estimates for 1990–2001 in table 16–2 of chapter 16 of this volume,
‘‘National Income and Product Accounts.’’

ment would not justify the Federal Government borrowing at all to finance its investment in Federal capital; instead, it would have to repay this amount of
debt ($4 billion). For national capital, Table 6–13 indicates that current cost depreciation (plus the excise
taxes earmarked to finance capital expenditures for
highways and airports and airways 39) is less than gross
investment but not by a great deal—the capital budget
deficit is $38 billion. The rationale of borrowing to finance net investment would justify the Federal Government borrowing this amount ($38 billion) and no more
to finance its investment in national capital.40
Even with depreciation calculated in current cost, the
rationale for borrowing to finance net investment is
not persuasive. The Federal Government, unlike a business or household, is responsible not only for its own
affairs but also for the general welfare of the Nation.
To maintain and accelerate national economic growth
and development, the Government needs to sustain private investment as well as its own national investment.
For more than a decade, however, net national saving
has been low, both by historical standards and in comparison to the amounts needed to meet the challenges
expected in the decades ahead.
To the extent that the Government finances its own
investment in a way that results in lower private investment, the net increase of total investment in the
economy is less than the increase from the additional
Federal capital outlays alone. The net increase in total
investment is significantly less if the Federal investment is financed by borrowing than if it is financed
by taxation, because borrowing primarily draws upon
the saving available for private (and State and local
government) investment whereas much of taxation instead comes out of private consumption. Therefore, the
net effect of Federal investment on economic growth
would be reduced if it were financed by borrowing. This
would be the result even if the rate of return on Federal
investment was higher than the rate of return on private investment. For example, if a Federal investment
that yielded a 15 percent rate of return crowded out
private investment that yielded 10 percent, the net social return would still be positive but it would only
be 5 percent.41
From its outset, this Administration has taken major
steps to increase the saving available for private investment while also increasing Federal investment for national capital. During the past seven years, the large
deficit has been replaced by a substantial surplus, and
available resources have been shifted to investment in
education and training and in science and technology.
The present budget proposes to continue to run substantial surpluses, paying down the debt to make room
for financing private investment, while protecting high
39 The capital budget deficit would be about $27 billion larger if current cost depreciation
were used instead of earmarked excise taxes for investment in highways and airports
and airways.
40 This discussion abstracts from non-budgetary transactions that affect Federal borrowing
requirements, such as changes in the Treasury operating cash balance and the net financing
disbursements of the direct loan and guaranteed loan financing accounts. See chapter 12
of this volume, ‘‘Federal Borrowing and Debt,’’ and the explanation of Table 12–2.
41 GAO considered deficit financing of investment but did not recommend it. See Incorporating an Investment Component in the Federal Budget, pp. 12–13.

6.

179

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

priority Federal investment. A capital budget is not
a justification to relax the budget constraints that are
contributing to this accomplishment. Any easing would

undo the gains from achieving a surplus that have already been achieved and the further gains from the
proposals in this budget.

PART V: SUPPLEMENTAL PHYSICAL CAPITAL INFORMATION
The Federal Capital Investment Program Information
Act of 1984 (Title II of Public Law 98–501; hereafter
referred to as the Act) requires that the budget include
projections of Federal physical capital spending and information regarding recent assessments of public civilian physical capital needs. This section is submitted
to fulfill that requirement.
This part is organized in two major sections. The
first section projects Federal outlays for public physical
capital and the second section presents information regarding public civilian physical capital needs.
Projections of Federal Outlays For Public
Physical Capital
Federal public physical capital spending is defined
here to be the same as the ‘‘major public physical capital investment’’ category in Part I of this chapter. It
covers spending for construction and rehabilitation, acquisition of major equipment, and other physical assets.
This section excludes outlays for human capital, such
as the conduct of education and training, and outlays
for the conduct of research and development.
The projections are done generally on a current services basis, which means they are based on 2000 enacted
appropriations and adjusted for inflation in later years.
The current services concept is discussed in Chapter
14, ‘‘Current Services Estimates.’’
Federal public physical capital spending was $118.6
billion in 1999 and is projected to increase to $154.4
billion by 2009 on a current services basis. The largest
components are for national defense and for roadways
and bridges, which together accounted for almost twothirds of Federal public physical capital spending in
1999.
Table 6–14 shows projected current services outlays
for Federal physical capital by the major categories
specified in the Act. Total Federal outlays for transportation-related physical capital were $31.0 billion in
1999, and current services outlays are estimated to increase to $45.3 billion by 2009. Outlays for nondefense
housing and buildings were $11.3 billion in 1999 and
are estimated to be $15.6 billion in 2009. Physical capital outlays for other nondefense categories were $22.4
billion in 1999 and are projected to be $27.8 billion
by 2009. For national defense, this spending was $53.9
billion in 1999 and is estimated on a current services
basis to be $65.7 billion in 2009.

Table 6–15 shows current services projections on a
constant dollar basis, using fiscal year 1996 as the base
year.
Public Civilian Capital Needs Assessments
The Act requires information regarding the state of
major Federal infrastructure programs, including highways and bridges, airports and airway facilities, mass
transit, railroads, federally assisted housing, hospitals,
water resources projects, and space and communications investments. Funding levels, long-term projections, policy issues, needs assessments, and critiques,
are required for each category.
Capital needs assessments change little from year
to year, in part due to the long-term nature of the
facilities themselves, and in part due to the consistency
of the analytical techniques used to develop the assessments and the comparatively steady but slow changes
in underlying demographics. As a result, the practice
has arisen in reports in previous years to refer to earlier discussions, where the relevant information had
been carefully presented and changes had been minimal.
The needs assessment material in reports of earlier
years is incorporated this year largely by reference to
earlier editions and by reference to other needs assessments. The needs analyses, their major components,
and their critical evaluations have been fully covered
in past Supplements, such as the 1990 Supplement to
Special Analysis D.
It should be noted that the needs assessment data
referenced here have not been determined on the basis
of cost-benefit analysis. Rather, the data reflect the
level of investment necessary to meet a predefined
standard (such as maintenance of existing highway conditions). The estimates do not address whether the benefits of each investment would actually be greater than
its cost or whether there are more cost-effective alternatives to capital investment, such as initiatives to reduce demand or use existing assets more efficiently.
Before investing in physical capital, it is necessary to
compare the cost of each project with its estimated
benefits, within the overall constraints on Federal
spending.

180

ANALYTICAL PERSPECTIVES

Table 6–14. CURRENT SERVICES OUTLAY PROJECTIONS FOR FEDERAL PHYSICAL CAPITAL SPENDING
(In billions of dollars)
1999
Actual

Nondefense:
Transportation-related categories:
Roadways and bridges ...................................................................................
Airports and airway facilities .........................................................................
Mass transportation systems .........................................................................
Railroads ........................................................................................................

Estimate
2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

22.8
3.9
4.0
0.3

25.5
3.8
4.3
0.7

27.2
3.8
4.5
0.6

28.1
4.1
5.2
0.6

28.7
4.1
5.7
0.6

29.2
4.3
6.4
0.6

29.8
4.4
6.8
0.7

30.5
4.5
7.0
0.7

31.1
4.6
7.2
0.7

31.7
4.6
7.4
0.7

32.3
4.8
7.5
0.7

Subtotal, transportation ...............................................................................
Housing and buildings categories:
Federally assisted housing ............................................................................
Hospitals .........................................................................................................
Public buildings 1 ............................................................................................

31.0

34.3

36.1

38.0

39.2

40.6

41.6

42.6

43.6

44.5

45.3

7.0
1.3
3.0

7.6
1.4
3.5

8.0
1.9
3.6

7.7
1.9
3.6

8.0
1.9
3.8

8.7
1.9
3.8

8.9
2.0
3.9

9.2
2.0
4.0

9.1
2.1
4.1

9.0
2.1
4.2

9.1
2.2
4.3

Subtotal, housing and buildings .................................................................
Other nondefense categories:
Wastewater treatment and related facilities .................................................
Water resources projects ..............................................................................
Space and communications facilities ............................................................
Energy programs ...........................................................................................
Community development programs ..............................................................
Other nondefense ..........................................................................................

11.3

12.5

13.5

13.2

13.7

14.5

14.8

15.2

15.2

15.3

15.6

2.5
2.8
3.6
1.1
5.4
7.1

2.9
3.8
3.2
1.1
5.6
7.7

3.1
3.4
3.1
1.0
5.6
7.3

3.4
3.3
3.6
1.0
5.8
6.9

3.6
3.5
3.6
1.1
5.9
7.1

3.8
3.6
3.9
1.0
6.0
7.6

3.9
3.7
3.6
0.9
6.0
7.8

3.9
3.8
3.9
0.8
6.1
8.0

4.0
3.8
4.0
0.8
6.2
8.2

4.0
3.9
3.9
0.8
6.3
8.4

4.1
4.0
3.9
0.8
6.4
8.6

Subtotal, other nondefense ........................................................................

22.4

24.1

23.5

24.0

24.8

25.9

25.9

26.5

27.0

27.3

27.8

Subtotal, nondefense ......................................................................................
National defense ......................................................................................................

64.8
53.9

71.0
53.3

73.1
56.1

75.2
57.7

77.6
60.2

80.9
61.8

82.3
63.3

84.3
61.9

85.8
63.1

87.1
64.4

88.7
65.7

Total ..........................................................................................................................

118.6

124.3

129.2

132.9

137.8

142.8

145.6

146.2

148.9

151.4

154.4

1 Excludes

outlays for public buildings that are included in other categories in this table.

Table 6–15. CURRENT SERVICES OUTLAY PROJECTIONS FOR FEDERAL PHYSICAL CAPITAL SPENDING
(In billions of constant 1996 dollars)
1999
Actual

Nondefense:
Transportation-related categories:
Roadways and bridges ....................................................................................................
Airports and airway facilities ..........................................................................................
Mass transportation systems .........................................................................................
Railroads .........................................................................................................................

Estimate
2000

2001

2002

2003

2004

21.8
3.8
3.9
0.3

23.7
3.6
4.0
0.7

24.7
3.6
4.1
0.6

24.9
3.7
4.6
0.6

24.7
3.7
4.9
0.6

24.6
3.8
5.4
0.6

Subtotal, transportation ................................................................................................
Housing and buildings categories:
Federally assisted housing .............................................................................................
Hospitals .........................................................................................................................
Public buildings 1 ............................................................................................................

29.8

32.1

33.0

33.8

34.0

34.3

6.8
1.3
3.1

7.1
1.4
3.5

7.2
1.8
3.6

6.8
1.8
3.5

6.9
1.8
3.6

7.3
1.8
3.5

Subtotal, housing and buildings ..................................................................................
Other nondefense categories:
Wastewater treatment and related facilities ..................................................................
Water resources projects ...............................................................................................
Space and communications facilities .............................................................................
Energy programs ............................................................................................................
Community development programs ...............................................................................
Other nondefense ...........................................................................................................

11.1

12.0

12.6

12.1

12.3

12.6

2.4
2.8
3.7
1.1
5.2
7.1

2.7
3.8
3.2
1.1
5.2
7.5

2.8
3.4
3.0
1.0
5.1
7.0

3.0
3.2
3.4
0.9
5.1
6.5

3.1
3.3
3.4
1.0
5.1
6.6

3.2
3.3
3.6
0.9
5.1
6.9

Subtotal, other nondefense .........................................................................................

22.2

23.4

22.3

22.2

22.5

23.0

Subtotal, nondefense ...........................................................................................................
National defense .......................................................................................................................

63.1
54.6

67.5
53.2

67.9
54.9

68.2
55.4

68.7
56.6

69.9
57.0

Total ..........................................................................................................................................

117.7

120.8

122.8

123.5

125.3

126.9

1 Excludes

outlays for public buildings that are included in other categories in this table.

6.

181

FEDERAL INVESTMENT SPENDING AND CAPITAL BUDGETING

Significant Factors Affecting Infrastructure Needs Assessments
Highways
1. Projected annual average growth in travel to the year 2015 ...................................................................................
2. Annual cost to maintain overall 1995 conditions and performance on highways eligible for Federal-aid ...........
3. Annual cost to maintain overall 1995 conditions on bridges ....................................................................................

1.96 percent
$33.4 billion (1995 dollars)
$5.6 billion (1995 dollars)

Airports and Airway Facilities
1. Airports in the National Plan of Integrated Airport Systems with scheduled passenger traffic ..........................
2. Air traffic control towers ..............................................................................................................................................
3. Airport development eligible under airport improvement program for period 1993–1997 ....................................

528
451
$29.7 billion ($9.4 billion for
capacity) (1992 dollars)

Mass Transportation Systems
1. Yearly cost to maintain condition and performance of rail facilities over a period of 20 years ............................
2. Yearly cost to replace and maintain the urban, rural, and special services bus fleet and facilities .....................

$6.1 billion (1995 dollars)
$3.6 billion (1995 dollars)

Wastewater Treatment
1. Total remaining needs of sewage treatment facilities ...............................................................................................
2. Total Federal expenditures under the Clean Water Act of 1972 through 2000 ......................................................
3. The population served by centralized treatment facilities: percentage that benefits from at least secondary
sewage treatment systems ...........................................................................................................................................
4. States and territories served by State Revolving Funds ...........................................................................................

$128 billion (1996 dollars)
$74 billion
98 percent
51

Housing
1. Total unsubsidized very low income renter households with worst case needs (5.3 million*)
A. In severely substandard units .................................................................................................................................
B. With a rent burden greater than 50 percent .........................................................................................................
* The total is less than the sum because some renter families have both problems.

0.4 million
5.0 million

Indian Health (IHS) Care Facilities
1.
2.
3.
4.
5.

IHS hospital occupancy rates (1999) ...........................................................................................................................
Average length of stay, IHS hospitals (days) (1999) .................................................................................................
Hospital admissions (1999) ..........................................................................................................................................
Outpatient visits (1998) ...............................................................................................................................................
Eligible population (2000) ............................................................................................................................................

48.0 percent
3.9
49,753
4,407,000
1,511,135

1.
2.
3.
4.
5.

Department of Veterans Affairs (VA) Hospitals (1998)
Hospitals ........................................................................................................................................................................
Ambulatory clinics ........................................................................................................................................................
Domiciliaries .................................................................................................................................................................
Vet centers ....................................................................................................................................................................
Nursing homes ..............................................................................................................................................................

166
544
40
206
132

Water Resources
Water resources projects include navigation (deepwater ports and inland waterways); flood and storm damage protection; irrigation; hydropower; municipal and industrial water supply; recreation; fish and wildlife mitigation, enhancement, and restoration; and soil conservation.
Potential water resources investment needs typically consist of the set of projects that pass both a benefit-cost test for economic feasibility
and a test for environmental acceptability. In the case of fish and wildlife mitigation or restoration projects, the set of eligible projects
includes those that pass a cost-effectiveness test.

Investment Needs Assessment References
General
U.S. Advisory Commission on Intergovernmental Relations (ACIR). High Performance Public Works: A New
Federal Infrastructure Investment Strategy for America,
Washington, D.C., 1993.
U.S. Advisory Commission on Intergovernmental Relations (ACIR). Toward a Federal Infrastructure Strategy: Issues and Options, A–120, Washington, D.C.,
1992.
U.S. Army Corps of Engineers, Living Within Constraints: An Emerging Vision for High Performance

Public Works. Concluding Report of the Federal Infrastructure Strategy Programs. Institute for Water Resources, Alexandria, VA, 1995
U.S. Army Corps of Engineers, A Consolidated
Performance Report on the Nation’s Public Works: An
Update. Report of the Federal Infrastructure Strategy
Program. Institute for Water Resources, Alexandria,
VA, 1995.
Surface Transportation
Department of Transportation. 1997 Status of the Nation’s Surface Transportation System: Conditions and

182
Performance: Report to Congress. 1997. This report discusses roads, bridges, and mass transit.
Airports and Airways Facilities
Federal Aviation Administration. The National Plan
of Integrated Airport Systems Report, April 1995.
Federally Assisted Housing
U.S. Department of Housing and Urban Development, Office of Policy Planning and Development, Tabulations of 1993 American Housing Survey.
Indian Health Care Facilities
Indian Health Service. Priority System for Health Facility Construction (Document Number 0820B or
2046T). September 19, 1981.
Indian Health Service. Trends in Indian Health—
1998. 1998.
Office of Audit, Office of Inspector General, U.S. Department of Health and Human Services. Review of
Health Facilities Construction Program. Indian Health

ANALYTICAL PERSPECTIVES

Service Proposed Replacement Hospital at Shiprock,
New Mexico (CIN A–09–88–00008). June, 1989.
Office of Technology Assessment. Indian Health Care
(OTA 09H 09290). April, 1986.
Wastewater Treatment
Environmental Protection Agency, Office of Water.
1996 Needs Survey Report to Congress. (EPA
832–R–87–003).
Water Resources
National Council on Public Works Improvement. The
Nation’s Public Works, Washington, D.C., May, 1987.
See ‘‘Defining the Issues—Needs Studies,’’ Chapter II;
Report on Water Resources, Shilling et al., and Report
on Water Supply, Miller Associates.
Frederick, Kenneth D., Balancing Water Demands
with Supplies: The Role of Demand Management in a
World of Increasing Scarcity, Report for the International Bank of Reconstruction and Development,
Washington, D.C. 1992.

7. RESEARCH AND DEVELOPMENT FUNDING
Investments in scientific discovery and technological
development—both public and private—have driven
economic growth and improvements in the quality of
life in America for long as our Nation has existed. In
the last 50 years, developments in science and technology have generated at least half of the Nation’s productivity growth, creating millions of high-skill, highwage jobs and leading to advances in the economy,
national security, the environment, transportation and
medical care. Federal government support for science
and technology has helped put Americans on the moon,
boosted agricultural productivity, harnessed the atom,
devised more effective treatments for cancers, tracked
weather patterns and earthquake faults, and deciphered the chemistry of life.
Because technological advances are key to progress
and economic growth, in 1993 President Clinton took
office committed to expanding Federal investment in
civilian research and development. The President’s economic strategy relied upon the critical element of investing in people and proposed targeted investments
to help the Nation compete in the global economy and
improve our quality of life.
The Administration’s support for R&D has been essential to the flow of innovative ideas, which have resulted in everything from the discovery of the first
multi-planet system beyond our own to unraveling
human, plant and microbial genomes, a critical step
in understanding the function of genes, and, in turn,
potentially treating and curing diseases that are now
beyond the reach of medical science. Investments in
science and technology can bring us breakthroughs in
the areas of the environment, health, national security,
and more, including, for example: fuel economies that
are double those of today; a strong defense that continually hones its technological edge; and fundamental research that may be able to unlock the answers to some
of the most basic questions: why cells age and die,
how human beings learn and remember information,
and whether there is life on other planets.
Over the last several years, private industry has expanded its support for research and development, but
most of these efforts focus on bringing new products
to market rather than funding the basic research that
can lead to break-through applications in a wide range
of fields. By supporting fundamental research that can
provide the foundation for tomorrow’s technologies, the
Federal Government can act as a catalyst for these
breakthroughs. Federal investment in basic research increased by nearly 45 percent from 1993 to 2000, with
emphasis on health research. The budget proposes

$20.3 billion to advance a balanced portfolio in basic
research, an increase of $1.3 billion, or 7 percent, over
2000.
Basic university-based research plays a special role
in the development of scientific advances. The competitive grants process upon which university research relies fosters innovation and expands scientific frontiers.
At the same time, these research grants provide a
training ground for the next generation of scientists
and engineers. Funding support for universities has
grown to roughly $17.8 billion, a 53 percent increase,
since 1993. Funding the academic researcher through
a peer-reviewed, merit-based competitive process is the
Federal government’s strategy for pursuing the most
promising long-term research. Researchers at national
laboratories, in the private sector, and at non-profit
companies may also be funded through such a competition. In 2001, $28.2 billion in research funds will be
awarded through a peer-reviewed, merit-based competitive process.
Other processes for allocating research dollars are
appropriate in special cases. For example, agencies may
decide that they wish to spearhead research in a particularly risky, but highly promising, field that can further the agency’s mission. Agency program managers
with in-depth knowledge and expertise are likely to
have the best judgement for making such decisions.
One example of this approach is the National Science
Foundation, where program managers may award up
to 5 percent of their funds through ‘‘Small Grants for
Exploratory Research,’’ which are made at the program
manager’s discretion, without peer review. In other
agencies, there are well-known centers of excellence at
the national laboratories, where there are unique capabilities. An agency may determine that maintaining and
exploiting this excellence requires long-term financial
stability for expensive world-class machines that will
ultimately benefit many researchers.
In the appropriations process, Congress may require
awards to be made to a single performer or collection
of performers without competitive selection. This Congressional direction may be established in law, report
language, or by other means. As a result of a recommendation in the National Science and Technology
Council’s report on the Government-University Partnership, agencies have reported the amount of funding that
was awarded through such Congressional direction. The
Administration is in the process of developing consistent measures across Federal agencies for these latter two categories of research, in order to publish the
data in the 2002 budget.

183

184

ANALYTICAL PERSPECTIVES

The tables below provide data on Federal spending
for research and development. Table 7–1 shows agencyby-agency spending on basic and applied research, development, and equipment and facilities. Table 7–2

shows agency-by-agency spending for two initiatives of
the National Science and Technology Council, which
are required by statute.

Table 7–1. FEDERAL RESEARCH AND DEVELOPMENT SPENDING
(Budget authority, dollar amounts in millions)
1999 Actual

2000 Estimate

2001 Proposed

Dollar Change:
2000 to 2001

Percent Change:
2000 to 2001

By Agency
Defense ......................................................................................................................
Health and Human Services .....................................................................................
National Aeronautics and Space Administration ......................................................
Energy ........................................................................................................................
National Science Foundation ....................................................................................
Agriculture ..................................................................................................................
Commerce .................................................................................................................
Interior ........................................................................................................................
Transportation ............................................................................................................
Veterans Affairs .........................................................................................................
Environmental Protection Agency .............................................................................
Education ...................................................................................................................
Other ..........................................................................................................................

38,850
15,797
9,715
6,992
2,702
1,645
1,084
786
670
644
500
205
752

38,719
18,063
9,753
7,091
2,903
1,773
1,073
585
648
655
584
233
664

38,640
18,998
10,035
7,655
3,464
1,828
1,152
731
679
655
590
271
635

–79
935
282
564
561
55
79
146
31
0
6
38
–26

0%
5%
3%
8%
19%
3%
7%
25%
5%
0%
1%
16%
–4%

TOTAL ...................................................................................................................

80,342

82,744

85,333

2,589

3%

Basic Research
Defense ......................................................................................................................
Health and Human Services .....................................................................................
National Aeronautics and Space Administration ......................................................
Energy ........................................................................................................................
National Science Foundation ....................................................................................
Agriculture ..................................................................................................................
Commerce .................................................................................................................
Transportation ............................................................................................................
Environmental Protection Agency .............................................................................
Veterans Affairs .........................................................................................................
Interior ........................................................................................................................
Education ...................................................................................................................
Other ..........................................................................................................................

1,082
8,642
1,981
2,228
2,330
634
39
42
57
263
50
2
118

1,175
9,857
1,947
2,242
2,512
692
39
46
58
268
61
2
128

1,230
10,422
1,895
2,379
3,000
740
52
69
76
268
63
2
132

55
565
–52
137
488
48
13
23
18
0
2
0
4

5%
6%
–3%
6%
19%
7%
33%
50%
31%
0%
3%
0%
3%

SUBTOTAL ...........................................................................................................

17,468

19,027

20,328

1,301

7%

Applied Research
Defense ......................................................................................................................
Health and Human Services .....................................................................................
National Aeronautics and Space Administration ......................................................
Energy ........................................................................................................................
National Science Foundation ....................................................................................
Agriculture ..................................................................................................................
Commerce .................................................................................................................
Transportation ............................................................................................................
Environmental Protection Agency .............................................................................
Veterans Affairs .........................................................................................................
Interior ........................................................................................................................
Education ...................................................................................................................
Other ..........................................................................................................................

3,064
4,998
2,306
1,810
147
743
799
368
401
365
418
141
355

3,383
5,728
2,365
1,913
164
807
770
384
387
370
482
150
290

3,087
5,935
2,817
2,174
193
821
834
477
377
370
486
165
290

–296
207
452
261
29
14
64
93
–10
0
4
15
0

–9%
4%
19%
14%
18%
2%
8%
24%
–3%
0%
1%
10%
0%

SUBTOTAL ...............................................................................................................

15,915

17,193

18,026

833

5%

Development
Defense ......................................................................................................................
Health and Human Services .....................................................................................
National Aeronautics and Space Administration ......................................................
Energy ........................................................................................................................
National Science Foundation ....................................................................................
Agriculture ..................................................................................................................
Commerce .................................................................................................................
Transportation ............................................................................................................
Environmental Protection Agency .............................................................................

34,423
1,919
5,092
2,003
0
109
137
161
96

33,913
2,229
5,093
2,036
0
109
106
145
93

33,937
2,408
4,920
2,163
0
118
176
171
84

24
179
–173
127
0
9
70
26
–9

0%
8%
–3%
6%
NA
8%
66%
18%
–10%

185

7. RESEARCH AND DEVELOPMENT FUNDING

Table 7–1. FEDERAL RESEARCH AND DEVELOPMENT SPENDING—Continued
(Budget authority, dollar amounts in millions)
1999 Actual

2000 Estimate

2001 Proposed

Dollar Change:
2000 to 2001

Percent Change:
2000 to 2001

Veterans Affairs .........................................................................................................
Interior ........................................................................................................................
Education ...................................................................................................................
Other ..........................................................................................................................

16
25
62
259

17
24
81
225

17
34
104
189

0
10
23
–36

0%
42%
28%
–16%

SUBTOTAL ...........................................................................................................

44,302

44,071

44,321

250

1%

Facilities and Equipment
Defense ......................................................................................................................
Health and Human Services .....................................................................................
National Aeronautics and Space Administration ......................................................
Energy ........................................................................................................................
National Science Foundation ....................................................................................
Agriculture ..................................................................................................................
Commerce .................................................................................................................
Transportation ............................................................................................................
Environmental Protection Agency .............................................................................
Veterans Affairs .........................................................................................................
Interior ........................................................................................................................
Education ...................................................................................................................
Other ..........................................................................................................................

281
238
336
951
225
159
109
215
116
0
7
0
20

248
249
348
900
227
165
158
10
110
0
17
0
21

386
233
403
939
271
149
90
14
142
0
7
0
24

138
–16
55
39
44
–16
–68
4
32
0
–10
0
3

56%
–6%
16%
4%
19%
–10%
–43%
40%
29%
NA
–59%
NA
14%

SUBTOTAL ...........................................................................................................

2,657

2,453

2,658

205

8%

NA = Not applicable.

Table 7–2. AGENCY DETAIL OF MAJOR INITIATIVES
(Budget authority, dollar amounts in millions)
1999 Actual

2000 Estimate

2001 Proposed

Dollar Change:
2000 to 2001

Percent Change:
2000 to 2001

Information Technology R&D*
National Science Foundation ....................................................................................
Energy (Defense—Advanced Strategic Computing Initiative) ..................................
Energy (Civilian programs) ........................................................................................
Defense ......................................................................................................................
Health and Human Services .....................................................................................
National Aeronautics and Space Administration ......................................................
Commerce .................................................................................................................
Environmental Protection Agency .............................................................................

393
301
139
215
118
106
25
4

517
397
120
282
191
174
36
4

740
477
190
397
233
230
44
4

223
80
70
115
42
56
8
0

43%
20%
57%
41%
22%
32%
22%
0%

TOTAL ...................................................................................................................

1,301

1,721

2,315

594

35%

U.S. Global Change Research Program
National Aeronautics and Space Administration ......................................................
National Science Foundation ....................................................................................
Energy ........................................................................................................................
Commerce .................................................................................................................
Agriculture ..................................................................................................................
Health and Human Services .....................................................................................
Interior ........................................................................................................................
Environmental Protection Agency .............................................................................
Smithsonian Institution ..............................................................................................

1,155
182
114
63
52
40
27
17
7

1,173
187
120
67
53
46
27
21
7

1,149
187
123
93
85
48
25
23
7

–24
0
3
26
32
2
–2
2
0

–2%
0%
2%
39%
60%
4%
–7%
10%
0%

TOTAL ...................................................................................................................

1,657

1,701

1,740

39

2%

* Merges both the High Performance Computing and Communications program and the Information Technology Initiative (IT2).

8. CREDIT AND INSURANCE
Federal programs offer direct loans and/or loan guarantees for a wide range of activities, primarily housing,
education, business, and exports. At the end of 1999,
there were $234 billion in Federal direct loans outstanding and $976 billion in guaranteed loans. The Federal Government also insures bank, thrift, and credit
union deposits up to $100,000, guarantees private vested defined-benefit pensions, and insures against disasters, specified international investment risks, and various other risks.
In addition, the net loans outstanding of Governmentsponsored enterprises (GSEs)—privately owned companies and cooperatives that operate under Federal charters—totaled $2.4 trillion, including asset-backed securities guaranteed by the GSEs. GSEs are chartered to
carry out specified public purposes through financing
activities in the housing, education, and agriculture sectors. GSEs are not part of the Federal Government,
however, and their securities are not federally guaranteed. By law, the GSEs’ securities carry a disclaimer
of any U.S. obligation. Congress has authorized the Secretary of the Treasury, at his discretion, to purchase
up to $2.25 billion of obligations issued by Fannie Mae
and Freddie Mac, up to $4 billion by the Federal Home
Loan Bank System, and up to $1 billion by Sallie Mae.
Farmer Mac may sell up to $1.5 billion of its obligations
to Treasury under specified, limited conditions.
These diverse programs and GSEs are operating in
the context of an accelerating evolution of financial
markets that is generating many new risks, as well
as new opportunities. Federal program managers will
need to reassess their roles and improve their effectiveness to adapt to dynamic market conditions.
The introduction to this chapter summarizes key
changes in financial markets and their effects on Federal programs.
• The first section is a crosscutting assessment of
the rationale for a continued Federal role in providing credit and insurance, performance measures for credit programs, and criteria for re-engineering credit programs so as to enhance their
benefits in relation to costs.
• The second section reviews Federal credit programs and GSEs in four sectors: housing, education, business and community development, and
exports. It notes the rationale and goals of these
programs and the related activities of the GSEs.
• The final section assesses recent developments in
Federal deposit insurance, pension guarantees,
and disaster insurance.
Evolving Financial Markets
The Financial Services Modernization Act, signed November 12, 1999, replaces a legal structure created in

the Great Depression with one that is more appropriate
to the rapidly changing and integrated financial markets of today. The Act repeals restrictions on bank affiliation with securities firms and removes the remaining statutory limitations on the financial activities allowable in banking organizations for qualified bank
holding companies. It permits securities and insurance
agency activities to be conducted in bank and financial
holding company subsidiaries, municipal securities underwriting to be conducted in a national bank or in
bank subsidiaries, and merchant banking and insurance underwriting to be conducted in financial holding
company subsidiaries.
The financial sector has already undergone substantial change. The number of banking organizations has
shrunk by a quarter in the last decade and is roughly
half the level 20 years ago. Consolidation has raised
the share of industry assets at the 100 largest banks
to 70 percent in 1998 from about 50 percent in the
mid-1980s. With easing restrictions over the years,
interstate banking and branching have become nationwide, and 51 securities affiliates are operating in bank
holding companies. International lending by U.S. commercial banks resumed growth in the early 1990s following large losses on developing country loans in the
1980s, but has become increasingly concentrated in
large banks. Meanwhile, U.S. banking assets of foreign
banks have grown from 12 percent of all U.S. commercial banking assets in 1980 to a 23–25 percent share
during the 1990s.
Financial innovation and integration have enabled
funds to flow more readily to their most productive
uses across the country and around the world. Capital
market financing is available to smaller companies and
for a broader range of purposes than before. Specialized
financial firms and nonfinancial firms, particularly suppliers, are helping to funnel funds from capital markets
to small clients in cities and in rural areas. Venture
capital providers and sub-prime lenders are fueling the
growth of new businesses. Data on small business lending show that institutions outside the local community
have become an important source of credit for many
businesses.
The 1990s have been a time of robust growth in
mortgage markets; the net change in home mortgages
rose from $180 billion in 1995 to $424 billion in the
second quarter of 1999. Federal Reserve staff estimate
that about 40 percent of the growth in outstanding
home mortgage debt during the past five years financed
the extraction of home equity. Secondary markets are
the main source of financing for mortgages, and a rapidly growing source of financing for household durables,
consumer credit, and small business loans.

187

188

ANALYTICAL PERSPECTIVES

Both intermediaries—banks and the many nonbank
firms engaged in financial services—and capital markets have been reaching out to new clients that they
did not serve a few years ago. Massive data bases and
increasingly sophisticated analytical methods are finding creditworthy borrowers among people and businesses previously unlikely to receive private credit.
Faster and cheaper information and communications
systems also have revolutionized ‘‘back office’’ functions.
These have been consolidated to achieve economies of
scale and located anywhere in the world where capable
workers are available. From these locations, satellite
communications can bring the ‘‘back office’’ to any desktop computer. From a timely information base, credit
servicing and workout have become much more efficient.
While the increased globalization of financial institutions and capital markets provides extensive benefits,
it also makes domestic market conditions more sensitive to events abroad. In 1997 and 1998, the Asian
crisis and further events in Russia and Brazil resulted
in a flight to liquidity and safety. Market conditions
also worsened in 1998 when a heavily exposed hedge
fund required a capital contribution from major lenders
to avoid bankruptcy and further market disruption.
These events drove down U.S. Treasury bond yields
dramatically, and raised rates on all but the highest
quality corporate bonds. Some credit markets were temporarily disrupted; related to this was an increase in
business borrowing from banks, rather than directly
from capital markets. Less-creditworthy borrowers
faced higher rates or were temporarily unable to find
funds.
Conditions returned to near normal liquidity during
1999, but rate spreads between most private loans and
securities and Treasury debt remained abnormally
high. Problem loans at banks have increased about 70
percent compared with 1998, and banks have tightened
underwriting standards. As a result of these experiences, awareness of the potential for discontinuities in
financial markets has increased.
Impact on Federal Programs
These changes are affecting the roles, risks, and operations of Federal credit and insurance programs.
I.

• In some cases, private credit and insurance markets may evolve sufficiently to take over functions
previously left to Federal programs. More likely,
they may take away the best risks among those
who have been borrowing from the Government
or with its guarantee, leaving Federal programs
facing a smaller pool of riskier clients. If the Government is aware of this in time, the result may
be new benefit/cost calculations that might help
to redesign—or to end—a particular program. If
the Government is caught unaware, the result
may be greater cost for taxpayers.
• At the same time, managers of Federal programs
can take advantage of the growing private capability. With careful attention to the incentives
faced by the private sector, they can develop a
variety of partnerships with private entities. And
they can contract with the private sector wherever
it can provide specific credit servicing, collection,
or asset disposition services more efficiently.
Insurance programs, too, are affected by the evolution
of the financial marketplace. That is most obvious for
deposit insurance. It now backs a recovered industry,
but one with an increasing concentration of ‘‘large complex banking organizations’’ that have assumed the
risks inherent in providing a growing array of increasingly sophisticated services, including many off-balance
sheet activities, often on a worldwide basis. Regulators
face challenges ranging from the complexity of assessing the risks of evolving financial services firms to the
continuing need to monitor for fraud. In pensions, the
Government guarantees defined benefit plans, but their
role is diminishing as defined contribution plans attract
the support of younger workers in an aging workforce.
This trend may accelerate as the retirement of the baby
boom generation nears. In disaster insurance, private
firms are gaining a better understanding of their risks
and exploring ways to diversify them in capital markets.
In this changing environment for Federal credit and
insurance programs, this chapter asks three questions.
First, what is our current understanding of the roles
of these programs? Second, how well are they achieving
their goals? And finally, could they be re-engineered
to achieve greater benefits in relation to costs?

A CROSS-CUTTING ASSESSMENT

The Federal Role
In most lines of credit and insurance, the private
market efficiently allocates resources to meet societal
demands, and Federal intervention is unnecessary.
However, Federal intervention may improve on the
market outcome in some situations. The following are
six standard situations where this may be the case 1,
1 Economics textbooks also list pure public goods, like national defense, where it is difficult
or impossible to exclude people from sharing the full benefits of the goods or services
once they have been produced. It is hard to imagine credit or insurance examples in this
category.

together with some examples of Federal programs that
address them.
• Information failures occur when there is an asymmetry in the information available to different
agents in the marketplace. A common Federal
intervention in such cases is to require the more
knowledgeable agent, such as a financial institution, to provide certain information to the other
party, for example, the borrower or investor. A
different sort of information failure occurs when
the private market deems it too risky to develop
a new financial instrument or market. This is rare

8. CREDIT AND INSURANCE

nowadays, but it is worth remembering that the
Federal Government developed the market for amortized, fixed-rate mortgages and other innovations in housing finance.
• Externalities occur when people or entities either
do not pay the full cost of their activities (e.g.,
pollution) or do not receive the full return. Federal
credit assistance for students is justified in part
because, although people with more education are
likely to have higher income and better health,
these individuals do not receive the full benefits
of their education. Their colleagues at work, the
residents of their community, and the citizens of
the Nation also benefit from their greater knowledge and productivity.
• Economic disequilibrium is a third rationale for
Federal intervention. This is one rationale for deposit insurance. If many banks and thrifts are
hurt simultaneously by an economic shock, such
as accelerating inflation in the 1970s, and depositors have a hard time knowing which ones may
become insolvent, deposit insurance prevents a
contagious rush to withdraw deposits that could
harm the whole economy.
• Failure of competition, resulting from barriers to
entry, economies of scale, or foreign government
intervention, may also argue for Federal intervention—for example, by reducing barriers to entry,
as has often been done recently, by negotiating
to eliminate or reduce foreign government subsidies, or by providing countervailing Federal credit assistance to American exporters.
• Incomplete markets occur if producers do not provide credit or insurance even though customers
might be willing to pay for it. One example would
be catastrophic insurance, where there is a small
risk of a very large loss; a disaster that occurred
sooner rather than later could bankrupt the insurer even if premiums were set at an appropriate
level to cover long-term cost. Another example is
caused by ‘‘moral hazard’’ problems, where the
borrower or insured could behave so as to take
advantage of the lender or insurer. This is the
case for pension guarantees, where sponsors might
underfund plans, and for deposit insurance, where
banks might take more risk to earn a higher return. In these cases, the Government’s legal and
regulatory powers provide an advantage in comparison with a private insurer.
• In addition to correcting market failures, Federal
credit programs are often used to redistribute resources by providing subsidies from the general
taxpayer to disadvantaged regions or segments of
the population.
In reviewing its credit and insurance programs, the
Federal Government must continually reassess whether
the direct and indirect benefits to the economy exceed
the direct and indirect costs. This assessment should
include the costs associated with redirecting scarce resources away from other investments. In some situa-

189
tions, the market may have recently become capable
of providing financial services, and older Federal programs may need to be modified or ended to make room
for private markets to develop. Private providers in
similar circumstances might go bankrupt, merge, or
change their line of business; for Federal programs,
a policy decision and usually a change in law are needed to eliminate overcapacity. In other instances, Federal
programs may be redesigned to encourage the development of private credit market institutions or to target
Federal assistance more efficiently to groups still unable to obtain credit and insurance in the private market.
What Are We Trying to Achieve?
If the main Federal role is to provide credit and insurance that private markets would not provide—to
stretch the boundaries in providing credit and insurance—the Federal goal is to achieve a net impact that
benefits society. Together, these objectives make the
standard for success of a Federal credit or insurance
program more daunting than for a private credit or
insurance firm.
For credit and insurance, as for all other programs,
implementation of the Government Performance and
Results Act (GPRA) will help to assess whether programs are achieving their intended results in practice—
and will improve the odds for success. GPRA requires
agencies to develop strategic plans in consultation with
the Executive Branch, the Congress, and interested parties; this process should refine and focus agency missions. The strategic plans set long-range goals, annual
performance plans set milestones to be reached in the
coming year, and annual performance reports measure
agency progress toward achieving their goals.
GPRA defines four kinds of measures for assessing
programs: inputs (the resources used), outputs (the
goods or services produced), outcomes (the gross effects
on society achieved by the program), and net impacts
(the effects net of those that would have occurred in
the absence of the program, e.g., with private financing). For credit and insurance programs, interesting
interrelationships among these measures provide the
keys to program success.
Net impacts assess the net effect of the program
on intended outcomes compared with what would have
occurred in the absence of the program. They exclude,
for example, effects that would have been achieved with
private credit in the absence of the program. Among
the net impacts toward which Federal credit programs
strive are: a net increase in home ownership, a net
increase in higher education graduates, a net increase
in small businesses, a net increase in exports, and a
net increase in jobs.
For credit programs, the first key to achieving any
of these net impacts is