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FRBSF

WEEKLY LETTER

January 25, 1985

The Flat Tax And Housing
The United States Treasury recently presented suggestions for reforming the Federal individual and
corporate income tax systems. Its proposal, identified as a "modified flat tax," was the latest in a
numberof proposals generically refered to as "flat
tax" systems. Many of these flat tax systems alter
the tax treatment of housi ng sign ificantly. The pu rpose of this Letter is to discuss briefly the rationale
behind a flat tax system and the implications of
such a system for the housing market.
In its most general sense, a flattax system is simply
one that imposes a tax on income, profits, wages
or some other base at a rate that is independent of
that base. Thus, most of the sales, property and
excise taxes levied in the United States today are
flat taxes. A sales tax, for example, applies a
flat rate to the volume of retail sales. The present
flat tax reform movement applies the flat rate
principle to the Federal income tax system in
which individual income tax rates rise progressively with income.
Rationale
The rationale for replacing a progressive tax system with a flat tax system lies in the effects of
taxation in distorting economic behavior. Taxation of wage income, for example, is believed to
reduce labor supply and, hence, to depress national income. Under a progressive rate scheme,
the highest marginal tax rates - and, hence, the
greatest disincentives to additional work - are
imposed on those who earn the highest wage, who
usually are considered the most productive workers. Thus, although a progressive tax rate system
may have desirable consequences for equity,
namely, by placing most of the tax burden on
those best able to pay, it may have a more than
offsetting deleterious effect on the performance of
the economy.

The economist Edgar Browning, for example, has
demonstrated that when the tax burden is shifted
from the lowest income taxpayers to the highest
income taxpayers by progressive taxation, the loss
to the economy as a whole far exceeds the benefits
to the low income taxpayers. Converting a progressive rate system to a flat rate system generating
equivalent tax revenue, therefore, could be ex-

pected to increase national income. Economist
Jerry Hausman estimates that converting our present income tax system to a 20 percent flat tax
system would result in an 8 percent increase in
income because it would encourage individuals
to work harder.
In a similar way, the progressive taxation of income earned from invested savings is believed to
result in lower aggregate saving and, hence, less
rapid accumulation of productive capital in the
economy. Households in the top 1 percent of t.~e
income distribution are responsible for approximately 25 percent of all saving that occurs in the
U.S. economy. Although it has proved difficult to
document empirically the effect of econom ic conditions on saving behavior, a flat rate tax system
can be expected to reduce the tendency to substitute consumption for saving. Economists Auerbach, Kotlikoff, and Skinner estimate that a flat
rate income tax generating the same total revenue
would increase national wealth 6 percent more
than a progressive system.
Marginal vs. average rates
Critics believe that the present Federal income
tax system is flawed not only because of the
progressivity of the current rate structure but also
because of the level of tax rates. In an attempt to
correct the disincentive effects of high marginal
tax rates on productive economic activity, a tremendously complex system of deductions and
exemptions has been employed. The result is a
system with a very high marginal tax rate (estimated by economist Robert Barro to average
about 33 percent) and a wasteful useof resources
to avoid paying taxes.

Because of such considerations, most current
"flat tax" proposals call not only for "flattening"
the rate schedule but also for reducing the average marginal tax rate applied to taxable income.
However, for the reform to generate the same
amount of revenues in total, allowable deductions and exemptions must be reduced or eliminated. Although the various tax reform proposals differ significantly in their detai Is, there
are four major changes in deductions or exemp-

FRBSF
tions that conceivably might have an effect on
the housing market.

Mortgage interest deduction
First, virtually all of the major "flat tax" proposals
impose some limitations on the deductibility of
mortgage interest. The Treasury plan, for example,
disallows deductions of mortgage interest on second homes. The Bradley-Gebhardt "FAIR" plan
implicitly reduces mortgage interest deductibility
as taxpayer income rises. And the DeConcini
"FLAT" plan eliminates mortgage interest deductibility altogether. All of the major tax reform
proposals continue to allow mortgage interest on
rental property to be deductible. By itself, limiting
the deductibility of mortgage interest on owneroccupied residences would encourage the use of
equity financing (also known as "self-financing")
in home purchases and renting rather than homeownership. The overall effect would be to reduce
the demand for housing capital and to depress the
price of housing. It is not clear how big the effect
on housing prices would be, however. Many western economies, including Australia and Canada,
limit or disallow the deduction of mortgage interest, yet the relationship between their housing
costs and income is similar to that observed in the
United States.

Decelerated depreciation
A third, specific, feature of many flat tax reform
proposals relevant for housing is the el imination of
accelerated deductions for depreciation of capital
assets. The Treasury proposal, for example, recommends lengthening the depreciable life of
capital assets such as rental housing. Forthe existing stock of housing to be heldvoluntarily by
investors after such a change, the price of housing
must fall. In addition, the change would give rise
to a greater desire for owner-occupancy.

Marginal tax rates and capital gains treatment

Property taxes

Finally, the changes in marginal tax rates could
themselves disturb housing markets. Finance
theory provides a guide to the potential effects. It
stresses that the demand for capital - such as
housing -depends upon the "user cost" of that
capital. The user cost of housing capital can be
approximately represented by the foregone interest earnings on equity in the house (that is, foregone from an alternative investment of the same
funds) plus the cost of debt service minus any
anticipated capital gains - all on an after-tax
basis. Even when mortgage interestremains
deductible, the reduction in marginal tax rates
increases the after-tax return on non-housing investments and thereby the opportu nity cost of
equity in housing. It also increases the after-tax
cost of debt service, everything else being equal.

A second feature of many "flat tax" reform proposals that would influence the housing market is
the el imi nation or restriction of the deductibil ity of
property taxes against income. The property tax is
a component of the cost of consuming housing
services. Limiting the deductibility of property
taxes, therefore, will increase the implicitafter-tax
cost of obtaining housing services. This, too,
wou Id tend to depress the demand for and, hence,
the price of housing.

In addition, most of the tax reform proposals
reduce or eliminate the current preferential treatment of capital gains. The consequent red!Jction
in after-tax capital gains also increases the user
cost of housing capital as defined above. Thus, the
reduction in marginal tax rates and the changes in
the preferential treatment of capital gains tend to
increase the user cost of capital and thereby reduce the demand for housing capital.

This price effect will be smaller in states such as
California that rely more on tax revenues from
income or retail sales rather than property to
support public services. If the deductibility of
property taxes were el iminated by law, one cou Id
expect a further shifting of the tax burden for
financing public services away from property to
other bases. This shift would, in turn, ameliorate
the depressing effect of this aspect of tax reform
on housing prices.

The current Treasury proposal adds some other
considerations to this analysis. By indexing both
interest income and capital gains receipts to the
inflation rate, it would tax only the real (and not
nominal) income from these two sources. Moreover, it retains a $125,000 capital gains exclusion
on private residences that, in effect, continues
the current, favored capital gains treatment of
owner-occupied housing. Nevertheless, in an
environment of low inflation, the Treasury's pro-

posed change in capital gains treatment would
still increase the user cost of capital to investors
on the margin.

Overall effects
It should be apparent from this discussion that a
careful inventory of the myriad features of tax
reform proposals is needed to determine their effect on housing. Eliminating the mortgage deduction, for example, would introduce a bias toward
rental hou sing, but elim inating accelerated depreciation would encourage owner-occupancy.
Similarly, although a.1I ofthe reform features
discussed above would, by themselves have a
tendency to depress housing prices, the comparative treatment of housing versus other assets could
have an offsetting effect. The Treasury has stated,
for example, that its reform proposal represents a
shift of the Federal tax burden away from households to corporations. Ifthis were indeed the case,
the proposal may make owning housing more
attractive than owning corporate equity. This
wou Id tend to offset, at least partially, the downward pressure on housing prices exerted by the
features discussed above.

proposals. If the economy is, in fact, responsive to
reductions in marginal tax rates in the directions
assumed by the architects of these plans, interest
rates would fall and national income would rise.
Both of these effects would tend to increase the
demand for housing and further offset the effects
caused by less favorable tax treatment of housing
alone.
It is also important to point out that none of the
major tax reform proposals eliminates a major tax
feature that favors housing in general(and owneroccupancy in particular) over other capital-the
failure of the tax system to tax "imputed income"
enjoyed by owner-occupants of housing. An owner of a home enjoys a continuous flow of services,
such as shelter, security, and various aesthetic
amenities. These services have value in the marketplace and thus represent income to the household. However, because this income is received in
the form of services that are consumed directly by
the household, it escapes taxation as income.
Regardless of theu Itimate direction of tax reform,
therefore, housing will retain most of its favored
treatment in ou r economy.

RandallJ.Pozdena
In addition, one must distinguish between the
short-term and long-term effects of such reform

Opinions expressed in this newsletter do not necessarily reflect the views of the management of the Federal Reserve Bank of San
Francisco, or of the Board of Governors of the Federal Reserve System.
Editorial comments may be addressed to the editor (Gregory Tong) or to the author .... Free copies of Federal Reserve publications
can be obtained from the Public Information Department, Federal Reserve Bank of San Francisco, P.O. Box 7702, San Francisco
94120. Phone (415) 974-2246.

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BANKING DATA-TWELFTH FEDERAL RESERVE DISTRICT

Loans, Leases and Investments 1 2
Loans and Leases 1 6
Commercial and Industrial
Real estate
Loans to Individuals
Leases
U.S. Treasury and Agency Securities 2
Other Securities2
Total Deposits
Demand Deposits
Demand Deposits Adjuste<j3
Other Transaction Balances4
Total Non-Transaction Balances 6
Money Market Deposit
Accounts-Total
Time Deposits in Amounts of
$100,000 or more
Other Liabilities for Borrowed MoneyS

Two Week Averages
of Daily Figures
Reserve Position, All Reporting Banks
Excess Reserves (+ )/Deficiency (-)
Borrowings
Net free reserves (+ )/Net borrowed( -)
1
2

3
4

5
6
7

IOJapa:::l

~uaw~Jodaa 4)Joasa~

(Dollar amounts in millions)

Selected Assets and Liabilities
Large Commercial Banks

~UQ8

Change from 01/11/84
Dollar
Percent!

Amount
Outstanding

Change
from

01/09/85
188,371
170,043
52,364
61,841
32,363
5,282
11,183
7,145
195,073
45,141
30,925
13,275
136,657

01/02/85
-1,186
-1,178
- 724
- 133
104
69
10
3
-5,372
-5,871
-2,252
41
541

13,449
15,743
6,189
2,599
5,649
227
1,331
961
8,192
27
465
853
7,367

7.7
10.2
13.4
4.4
21.1
4.5
- 10.6
- 11.8
4.4
0.1
1.5
6.9
5.7

45,593

542

2,825

6.6

134
504

2,153
2,600

5.6
14.1

40,487
21,090

-

Period ended

Period ended

12/31/84

12/17/84

75
30
45

40
44
3

Includes loss reserves, unearned income,excludes interbank loans
Excludes trading account securities
Excludes U.S. government and depository institution deposits and cash items
ATS, NOW, Super NOW and savings accounts with telephone transfers
Includes borrowing via FRB, TI&L notes, Fed Funds, RPs and other sources
Includes items not shown separately
Annualized percent change