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January 15, 1998

Federal Reserve Bank of Cleveland

Assessing Fundamental Tax Reform
by David Altig, Alan J. Auerbach, Laurence J. Kotlikoff,
Kent A. Smetters, and Jan Walliser

F

undamental tax reform remains a hot
topic, for reasons that should come as no
surprise. The current U.S. tax structure is
complex, distortionary, and replete with
tax preferences.
The adjective “fundamental” is important here. Although the personal income
tax code has undergone six major revisions during the past two decades, none
of those changes can be deemed truly
fundamental in the sense of significantly
simplifying the U.S. tax code. On the
contrary, the 1997 tax bill introduced
further complexity, distortions, and
preferences.
Now, there seems to be genuine interest
in fundamental tax reform among Capitol Hill policymakers, but there is also a
wide range of opinions about how to
accomplish it.1 The complexity that surrounds changing the federal tax code
arises in no small measure from the fact
that feasible reforms often involve tradeoffs among competing objectives. The
issues were clearly articulated by President Clinton in a December 16, 1997,
press conference:
I would not rule out a further substantial action to simplify the tax code. But I
will evaluate any proposal, including
any one that our people might be working on, by the following criteria: First of
all, is it fiscally responsible? Secondly,
is it fair to all Americans? That is, we
don’t want to shift the burden to middleclass taxpayers to lower income taxes
on upper-income people....Thirdly,
will it be good for the economy? And
fourthly, will it actually lead to a simpler tax system?
ISSN 0428-1276

Our goal in this Economic Commentary
is to examine a few broad, and typical,
variants of fundamental tax reform along
the dimensions emphasized by the president. The information we report is based
on formal quantitative experiments that
appear in our research paper, “Simulating U.S. Tax Reform.” 2

■ The Criteria
The issues identified by the president
probably reflect the concerns of many
American voters. It is difficult, however,
to debate the merits of alternative reform
proposals without a clear idea about how
each of his four criteria can be quantified.
How, for example, does one define “fairness”? Before proceeding, we will look
at each requirement a bit more precisely.

Is It Fiscally Responsible?
At its most basic level, this one is relatively easy. We could simply require that
any new policy yield the same stream of
expected revenues before and after the
reform, a property commonly referred to
as “revenue neutrality.” Revenue neutrality does not, however, imply that the
government’s budget outlook is independent of tax policy. Suppose, for example, that interest rates fall as a consequence of a policy change. This would
reduce outlays and cause the government’s surplus to rise over time.
We can resolve this complication by
stipulating that any change in policy
must yield the same flow of government
revenues less interest payments that
would occur without the change. This
property, which we will refer to as “net
revenue neutrality,” is equated with “fiscal responsibility” in the discussion that
follows.3,4

President Clinton recently stated that
he would consider legislation aimed
at simplifying the U.S. tax code if it
were fiscally responsible, fair to all
Americans, good for the economy,
and truly created a simpler tax system. This article looks at how some
basic tax reform proposals—including the flat tax and an alternative
known as the X tax—stack up against
these sometimes competing criteria.

Will It Be Good for the Economy?
This, of course, is a subjective matter.
However, in strictly material terms, we
define this question as analogous to the
relatively straightforward query, “Does
the tax reform lead to an increase in per
capita GDP and per capita income?”

Will It Actually Lead
to a Simpler Tax System?
We define simplification to mean eliminating most deductions and preferences
from both the corporate and personal tax
codes. All of the reforms considered
below impose some form of simplification, the specifics of which we will discuss as we consider each change in turn.

Is It Fair to All Americans?
The issue of fairness is undoubtedly one
of the most contentious problems surrounding any change in government policy, and it is central in discussions of tax
reform. We could certainly examine
shifts in tax burdens to assess fairness,
but we suspect that people would generally accept a doubling of their taxes if
doing so would guarantee a tripling of
their income. To skirt that particular

problem, we might look at changes in
the distribution of after-tax income, but
a better position on the income distribution ladder would likely be a small comfort to someone who gained only because he was forced to work harder as
a result of distortions or wealth losses
wrought by tax policy.
What we are really concerned with here
is whether individuals would likely perceive themselves to be better or worse off
after a change in tax policy once we account for both how much consumption
they can enjoy and how much work effort they have to expend to afford it. In
the jargon of economists, we are asking
how policy-induced changes in consumption and leisure flows affect the
level of an individual’s lifetime “utility.”
Insight into how we are measuring the
concepts “better off” and “worse off”
can be gained by considering the following scenario: Suppose we could tell you
the consequences—in terms of how
much consumption you will enjoy and
how many hours you will need to work
to obtain it—of moving from the present tax system to some alternative
scheme. We then might ask whether you
would be willing to pay money to live
under the alternative regime. If you can
honestly answer yes, then clearly you
would perceive that you are better off
with tax reform. If, on the other hand,
your answer is no, I would have to be
compensated to accept tax reform, then
clearly you would feel better off under
the existing tax structure.
What we report below is whether our
experiments indicate that particular
groups of people would pay to see tax
reform implemented or whether they
would have to be compensated to accept
the reform. The answers correspond to a
formal measurement of “winners and
losers” in terms of a broad concept of
economic well-being, or utility. Modified in this way, the president’s fairness
condition means that wealthier individuals will not be made “utility winners” at
the price of making the less wealthy
“utility losers.”
We want to emphasize that our discussion will be framed in what economists
refer to as the life-cycle perspective.
That is, we do not define concepts such
as “high income” and “low income” in
terms of an individual’s income at a specific point in time, but in terms of his rel-

ative income over a lifetime. Thus, a
person in medical school would likely
have very low current income, but
would be defined as a member of a highincome group by virtue of the fact that
his income will be higher than most
when viewed over an entire lifetime.
The life-cycle perspective is the appropriate vantage point for considering the
wisdom of a given tax reform. A policy
change in which a 40-year-old, for instance, loses in the first year but gains in
every subsequent year of his working life
will probably look like a pretty good deal
to that person. For this reason, we focus
our attention on how tax reform could be
expected to affect different groups of taxpayers over their remaining lifetime.

■ The Flat Tax (A Consumption
Tax by Any Other Name . . . )
Many economists and policymakers
believe that a system which raises revenue by taxing consumption is superior
to the income-based tax structure that
currently exists at the federal level in the
United States. In terms of the multiple
objectives of tax reform, however, some
fundamental trade-offs exist between
these two types of systems.
On one hand, the consumption tax base
is smaller than the income tax base. It
follows that at any point in time, a consumption tax will require a higher rate
to raise a given level of revenue. Because a consumption tax is in many
ways similar to a wage tax (a point we
will return to below), these higher rates
may lower the incentives to earn labor
income. On the other hand, by not taxing returns to new saving, a consumption tax promotes saving and capital accumulation. (Furthermore, higher
after-tax returns to saving introduce an
incentive for households to shift leisure,
as well as consumption, to the future,
which works against the negative wage
effect on labor supply.5) Theoretically,
then, the net economic impact of moving to a consumption-based tax system
is ambiguous.
The emphasis on “new” saving is important and helps to clarify both the nature
of consumption-based tax reforms and
their ultimate economic impact. Often
unstated in the reform debates is that a
shift toward a consumption tax base
need not take the form of direct taxation
of consumption expenditures, as in, say,

a national sales tax. Consumption-based
taxation can be implemented indirectly
by way of a tax system in which 1) only
labor income is taxed at the household
level, and 2) businesses are subject to a
cash-flow tax, implying that firms’
investment expenditures are completely
expensed at the time they are incurred.
In fact, true flat-tax proposals based on
the original work of economists Robert
E. Hall and Alvin Rabushka are designed to implement consumption taxation with this type of a labor-income/
cash-flow tax base.6
The expensing provision of a Hall–
Rabushka-type reform means that a firm
can immediately write off the full value
of new purchases, instead of depreciating them over time, as required by current law. New investments are thus
effectively tax free at the margin, since a
firm’s tax on its cash flow is reduced by
the amount of the investment. Existing
assets, however, lose their depreciation
allowances and do not enjoy the favorable tax treatment applied to new investments. As a consequence, implementing
a consumption-based tax via a laborincome/cash-flow tax base exempts new
saving from taxation, but not old saving.
This feature of the flat-tax reform implies a one-time “lump-sum” tax, or
wealth levy, on existing assets. Although
this levy reduces the tax rate (and resulting distortions) necessary to maintain
revenue neutrality, it comes at the expense of individuals who have been high
savers prior to the reform. Appreciating
the full consequences of shifting the
U.S. tax system toward a consumption
base therefore requires disentangling the
various tensions between the potentially
higher labor taxes, greater saving incentives, and implicit wealth levies inherent
in a consumption tax implemented
through a Hall–Rabushka-style flat tax.

■ Economic Effects of a Flat Tax
Consider first the case of a relatively
straightforward, single-rate consumption
tax that, like the flat tax, eliminates most
major tax-base reductions, but, unlike
the flat tax, provides no personal exemptions or tax shelters for housing wealth.
Our study shows that under such a plan,
national income would be 7 percent
higher than in the no-reform case. We
also find that in the long run, real output
would increase by nearly 11 percent—
about $800 billion in 1996.

Unfortunately, the rising tide of the flat
tax does not, in this case, raise all boats
(at least not in utility terms): The least
wealthy taxpayers (in terms of lifetime
income) would indeed lose, while more
affluent Americans would gain. An obvious way to resolve this problem is to
maintain standard deductions that absolve the poorest individuals of any tax
liability. This is, in fact, a feature of most
flat-tax reform proposals in the Hall–
Rabushka tradition. In addition, taxation
of housing wealth is not seriously contemplated in the current reform plans, so
a more accurate picture of any probable
flat-tax system would include tax sheltering of housing wealth.
With standard deductions and full tax
exemption of existing housing, the economic benefits of a flat tax are lower but
still large. Our analysis indicates that
relative to the no-reform case, output
would increase about 2½ percent in the
short run and just over 6 percent in the
long run.
On the economic welfare side, the flat
tax with standard deductions delivers
long-run across-the-board utility gains.
Although these gains are again relatively
large for the wealthiest group of taxpayers, they are also sizeable for the poorest
Americans. However, a potentially serious drawback to this type of reform is
that middle-income groups—those with
peak lifetime incomes between about
$20,000 and $50,000—are made worse
off in the short run.
The short-run utility losses suffered by
middle-income taxpayers are a consequence of imposing revenue neutrality.
In the near term, the tax rates required
to satisfy this requirement are higher for
these groups than they would be under
current policy. As the positive effects of
the reform take hold in the economy, tax
rates do fall, but too late to overcome the
negative effects that occur at the time of
the transition to the flat-tax system.
Continuing existing depreciation allowances and interest-expense deductions on
capital in place at the time tax reform is
implemented—thus providing some transition relief for owners of old nonhousing
capital—further reduces the advantages
of reform. With these provisions, our
experiments indicate very little short-run
gain in output and a long-run expansion
of less than 2 percent.

Providing this type of transition relief
helps to protect the elderly, who generally hold a relatively large share of their
wealth in capital assets. Without such
relief, the current elderly tend to lose in
the transition to a flat tax. Transition relief, however, exacerbates the burden on
current middle-income groups, because
a reduction in the value of the wealth
levy means that distortionary taxes must
be higher in order to generate the same
amount of net revenue. In fact, our
analysis shows that even in the long run,
middle-income Americans lose if transition relief is granted to older generations.

■ An Alternative Proposal:
The X Tax
An alternative scheme for moving to
consumption-based taxation is the socalled X tax proposed by economist
David Bradford. Like the standard Hall–
Rabushka flat tax, the X tax system
would shift the federal tax base toward
consumption via expensing. However,
it would maintain progressivity of marginal tax rates on labor income, and
would also set the marginal tax rate on
business cash flows at the highest rate
applied to labor income.
Introducing tax rate progressivity on
labor income does not distort the accumulation of new capital: Expensing
implies that the effective rate is still zero.
Increasing the business cash-flow tax
does, however, substantially boost the
effective tax on old capital. In fact, this
wealth levy is large enough to maintain
revenue neutrality while at the same time
lowering the tax rate enough on middleincome groups to make them better off
under the reform, even in the short run.
The cost, of course, is that older individuals who hold substantial amounts of
wealth lose even more under the X tax
than under the Hall–Rabushka flat tax.
Nonetheless, given the criteria noted
above, the X tax stacks up fairly well.
In addition to being revenue neutral
(by construction) and simpler (although
somewhat less simple than the other
proposals we have considered), it has a
tremendous positive effect on output:
Long-run GDP is only slightly lower
under the X tax than under the flat-tax
scheme without the standard deductions
and housing shelter. Furthermore, the
long-run utility effects of the X tax are
quite progressive, with lower-income

groups being the biggest winners (in
percentage terms). Obviously, the elderly lose at the time the reform is implemented, but these losses are highest
for the wealthiest individuals. Even in
the short run, the poorest elderly gain.

■ Some Lessons
We suspect that President Clinton’s tax
reform requirements are shared by many
Americans. But whenever policy has
multiple objectives, trade-offs inevitably
arise that require some prioritization
informed by serious discussions about
ultimate social goals. Our analysis incorporates many complexities and omits
some others, but it is doubtful that a
more complicated study will overturn
our key findings.
In general, the trade-offs between
growth in overall output and the relative
welfare of different income groups and
generations seem to be significant. As an
example, the treatment of potential
wealth levies created by shifting to a
consumption-based tax system has a
marked impact on whether output and
welfare increase in the long run. Such
transition taxes allow lower tax rates
over the long haul, but generate fairly
large redistributions of wealth across
both living and future generations. Proposals aimed at mitigating these distributional effects can, in the extreme, completely undermine any positive effects
of shifting to a consumption tax.
Among the stylized reforms considered
here, the X tax appears to come closest
to meeting President Clinton’s entire set
of requirements. However, even this
scheme involves some substantial transfer from the current elderly to younger
and future generations. The “correct”
approach, then, inherently becomes a
question of what the nation decides is a
“fair” intergenerational distribution of
resources. The issue of intergenerational
fairness is an area of active research and
debate. It is also, as this paper shows, of
great relevance to tax reform.7

■ Footnotes
1. Among the most prominent proposals are
the flat tax introduced by House Majority
Leader Dick Armey (R–Tex.) and Senator
Richard Shelby (R–Ala.), a retail sales tax
favored by Representative Billy Tauzin
(R– La.) and Senator Richard Lugar (R–Ind.),
and the “unlimited savings allowance (USA)
tax,” a combined value-added tax and progressive personal consumption tax proposed
by Senator Pete Domenici (R–N. Mex.) and
former Senator Sam Nunn (D–Ga.).
2. Congressional Budget Office, Technical
Working Paper No. 97–6. This paper also
appeared as National Bureau of Economic
Research Working Paper No. 6248, October 1997.
3. This requirement does not presume that
revenue raised from specific sources—wage
income, for example—is unaltered by tax
reform, a point that will become clear as
we proceed.
4. Although the revenue neutrality concept
is typically invoked, many economists and
policymakers believe that a more appropriate
definition of “fiscal responsibility” would
ensure that there is no increase in the fiscal

Federal Reserve Bank of Cleveland
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burden placed on future generations. Satisfaction of this requirement is not guaranteed
by revenue neutrality. The connection (or
lack thereof) between the deficit and intergenerational equity is explored in Laurence J.
Kotlikoff, Generational Accounting: Knowing Who Pays, and When, for What We
Spend. New York: The Free Press, 1992.
5. For a more complete discussion of this
effect, see Alan J. Auerbach, “The Future of
Fundamental Tax Reform,” American Economic Review, vol. 87, no. 3 (May 1997),
pp. 143–46.
6. A complete discussion of the Hall–
Rabushka proposal is contained in Robert E.
Hall and Alvin Rabushka, The Flat Tax, 2d
ed. Stanford, Calif.: Hoover Institution Press,
1995.
7. Recent research on intergenerational fairness shows that under baseline policy, future
generations might face lifetime net tax rates
exceeding those faced by current generations.
See Jagadeesh Gokhale, Benjamin R. Page,
and John R. Sturrock, “Generational Accounts for the United States: An Update,”
Federal Reserve Bank of Cleveland, Economic Review, vol. 33, no. 4 (Quarter 4 1997),
pp. 2–22.

David Altig is a vice president and economist
at the Federal Reserve Bank of Cleveland,
Alan J. Auerbach is a professor of economics
at the University of California–Berkeley,
Laurence J. Kotlikoff is a professor of economics at Boston University, and Kent A.
Smetters and Jan Walliser are economists
at the Congressional Budget Office.
The views stated herein are those of the
authors and not necessarily those of the Federal Reserve Bank of Cleveland, the Board of
Governors of the Federal Reserve System, or
the Congressional Budget Office.
Economic Commentary is available electronically through the Cleveland Fed’s site on
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