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FRBSFWEEKLY LETTER
July 11, 1986

"Tax Reform
Tax reform took a major step forward in June
when the Senate approved a bill with many of
. the hallmarks of earlier proposals by the Administration and a bill passed by the House of
Representatives. Both the House and Senate bills
would make significant changes in the federal
tax system. This Letter discusses the objectives of
recent tax reform proposals and their likely economic consequences.

Base broadening
All three tax proposals would broaden the tax
base by such means as limiting consumer interest deductions, repealing the two-earner deduction, and allowing only 80 percent of business
entertainment expenses to be deducted. Both the
House and Senate Finance Committee plans
would limit tax-deferred contributions to IRAs
and 401 (k) plans.

Equity (or fairness), economic neutrality, and
increased economic growth have emerged as
three main objectives of tax reform. An objective
such as "equity" clearly can mean very different
things to different people. In the current discussions of tax reform, equity has been interpreted
to mean that individuals with equal incomes
should be treated equally by the tax system,
regardless of the source or use of their incomes.

However, both the House and Senate bills
would broaden the base less than the Admin~
istration's proposal. Both bills would retain
major deductions from taxable income now in
the tax system. These include the exclusion of
pension contributions under employer plans,
employer contributions to health insurance,
social security benefits, and the continued
deductibility from taxable income of mortgage
interest on owner-occupied, including second,
homes.

Implementing this concept requires a sizable
broadening of the tax base. A wider tax base
permits marginal tax rates to be cut while still
maintaining the same overall level of federal tax
revenues. By carefully choosing the extent to
which the tax base is broadened and tax rates
cut, tax reform can remain consistent with President Reagan's requirement that any tax bill be
"revenue neutral", i.e., leave the total federal
deficit unaffected over the next five years.

The Administration's bill would have taxed some
health benefits, allowed mortgage interest
deductibility only for an individual's principal
residence, and eliminated completely the
deductibility of state and local taxes. The House
bill would restore full deductibility of state and
local taxes; the Senate bill would do the same
but place a cap on sales tax deductions.

Objectives

Economic neutrality means the tax system
should not interfere with incentives to channel
resources into their most productive economic
uses, and not create incentives for investments
designed merely to avoid taxes. Thus, economic
neutrality means a reduction in the current large
variation of effective tax rates across industries.
It has been argued that a "fair" and economically neutral tax system would by itself promote
economic growth. By broadening the base and
lowering marginal personal tax rates, such a tax
system may provide greater incentives to work
and save. Moreover, such a system also would
reduce nonproductive activities undertaken
simply to avoid taxation,and encourage productive investment.

Personal and corporate taxes
Carried out to its logical conclusion, the principle of making an individual's tax liability independent of his source of income requires the
integration of the personal and corporate tax systems. Each of the three current plans treat this
issue differently. All three remove the current
personal dividend exclusion, and the Administration and House plans allow corporations to
deduct from income 10 percent of dividends
paid.
The taxation of long-term capital gains also
receives different treatment in the different
plans. Here, the Senate version goes farthest by
treating all capital gains as ordinary income. The
Administration cuts the current 60 percent
exclusion to 50 percent, and the House bill cuts
it to 42 percent.

FRBSF
The treatment of capital gains is likely to be a
key issue affecting tax simplification since the
current law's preferential treatment of such gains
has generated much of the industry devoted to
tax avoidance. As just noted, the Senate bill, by
taxing all realized capital gains as ordinary
income and thereby eliminating many tax shelters, is likely to simplify the tax system more
than the other proposals.
Two changes contained in all three tax reform
proposals that will lead to tax simplification for
many individuals are increases in the personal
exemption and the standard deduction. As currently proposed, this means that many lowincome families will not have to file a tax return.
Appreximately 6 million working poor would be
removed from the tax rolls under the Senate
plan. Many other individuals who currently
itemize will be able to use the standard deduction.
Long-run growth

Supply-side economists have supported lower
marginal tax rates on households as a way to
promote economic growth. All three plans
woula significantly cut marginal personal tax
rates. In addition, the maximum corporate tax
rat~\X()uld be reduced to 33 percent by the Senate bill, and 36 percent by the House bill.
Despite this, none of the tax reform proposals is
likely to have a major impact on economic
growth. In fact, they may slightly lower the rate
of growth the economy is capable of sustaining
over the longer run. This adverse effect on
longer run growth is due to the plans' provisions
for shifting taxes from the household sector to
the corporate sector, which can be expected to
reduce investment in plant and equipment.
The chart shows the esti mated increase in total
direct tax payments by the corporate sector over
the next five years under each of the three proposals. Each proposal would lower the maximum corporate tax rate, but each would also
offset that drop by removing the investment tax
credit, increasing the minimum tax on corporations, and, particularly in the case of the House
plan, slowing the schedule for depreciation
allowances.

In addition, all three proposals provide more
favorable tax treatment for existing plant and
equipment than for new acquisitions. The lower
corporate tax rate and a 10 percent dividend
deduction contained in the Administration and
House plans would reduce the tax burden on
existing capital as they raise the tax burden on
new investment by repealing the investment tax
credit and extending depreciation schedules. By
discouraging new capital formation, compared
to incentives under existing law, the proposed
tax plans would adversely affect longer run economic growth.
The adverse effect on investment could potentially be offset by a number of factors. First, as
discussed in more detail below, tax reform
would provide a tax system that treats different
types of investment more uniformly. More uniform treatment would tend to reduce the inefficiencies that have been produced by the current
tax system. However, empirical evidence suggests that the gains in economic activity from
this "uniformity" are likely to be small.
Second, a lower personal tax rate on returns to
saving and, in the Senate bill, the elimination of
the deductibility of interest on consumer loans,
may liftthe personal saving rate. A rise in personal saving would provide more funds for
investment and thereby reduce the cost of
financing for firms. Existing empirical evidence
suggests, however, that such an effect would be
weak at best. The experience followi ng the 1981
reduction in personal tax rates, for example, is
not encouraging in this regard.
Moreover, the Senate bill might actually reduce
personal saving by dropping the current deduction for IRA contributions (except for workers
not covered by an employer pension plan).
Since corporations save a higher fraction of their
after-tax income than do households, transferring taxes from households to corporations
would lower business retained earnings in the
short-run, and thus also may result in a net
reduction in total savings by the private sector as
a whole, even if household saving rises.
Lower personal tax rates could increase economic growth by raising after-tax wages and

Increase in Corporate Tax Payments
Under Various Tax Reform Proposals
(1987· 1991)

allow assets to be written off more quickly than
would a neutral system that took account of
their true rate of economic depreciation.

Billions
of Dollars

All three plans would eliminate the ITe. The
Administration and House bills both are less
generous than ACRS in allowing depreciation
deductions. The Senate version retains ACRS,
but redefines asset classes and gives more generous depreciation allowances to equipment
than to real estate.

150
139

Administration

House

Senate

thereby induce a greater work effort, although
existing empirical evidence suggests this effect is
likely to be fairly small. Repeal of the two-earner
deduction also would tend to offset this effect
somewhat. A variety of estimates suggests that
the hours supplied by workers might increase by
around 1 percent under any of the plans. Over
the next few years, the resulting increase in
labor would serve only to offset some of the
plans' depressing effect on capital investment. It
would have little net effect on the growth of the
economy's productive potential.

Economic neutrality
Under current tax law, the effective rates of taxation vary greatly across industries and affect
investors differently depending on the types of
assets they hold. A neutral tax system would
minimize the impact of taxes on private economic decisions. The current depreciation system of Accelerated Cost Recovery (ACRS)
together with the investment tax credit (lTC)

In contrast to the Administration and House proposals, the Senate bill retains many of the special treatments current tax law provides to
specific industries. It maintains oil percentage
depletion allowances and special deductions for
reserves held against bad debts at financial
institutions. It also keeps the special capital
gains rate for corporations in the timber industry.
Tax reform will affect firms' choice of debt and
equity financing, as well as the way they divide
profits between dividends and retained earnings.
A 10wercQrporate tax rate willreduce the value
of the interest rate deduction and raise the cost
of debt relative to equity financing. The diyidend
deduction contained in the Administration and
House plans, plus the increased tax rate on capitalgains, will increase dividend payouts relative
to retained earnings.
The tax reform package that seems likely to
emerge from Congress later this year will have
profound effects on the structure of the American economy. Most of these effects will occur
slowly as savings and investment funds are reallocated away from those areas that have benefited from special tax treatment. Because many
of the economic forces set into motionby a
change in the tax system operate over a long
period of time, it will be several years before we
can judge the full impact of tax reform.

Carl E. Walsh

Opinions expressed in this newsletter do not necessarily reflect the views of the managementof 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 Bankof San Francisco, P.O. Box 7702, San Francisco
94120. Phone (415) 974-2246.

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BANKING DATA-TWELFTH FEDERAL RESERVE DISTRICT
(Dollar amounts in millionsl

Selected Assets and Liabilities
large Commercial Banks
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 Secu rities 2
Total Deposits
Demand Deposits
Demand Deposits Adjusted 3
Other Transaction Balances 4
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

Amount
Outstanding

Change from 6/19/85
Dollar
Percent 7

Change
from

6/18/86

6/11/86

200,024
181,714
51,568
66,719
38,986
5,600
10,732
7,579
203,819
51,699
36,022
16,261
135,859

-

-

182
12
318
2
21
21
25
144
595
159
30
284
470

46,736

-

87

2,507

5.6

35,606
21,824

- 115
-2,247

-2,810
-2,143

- 8.9

-

-

-

-

-

-

-

-

-

Period ended

Period ended

6/16/86

6/2/86

7,761
7,650
687
3,235
4,553
226
492
603
6,512
4,924
5,602
2,676
1,087

4.0
4.3
- 1.3
5.0
13.2
4.2
- 4.3
8.6
3.3
10.5
18.4
19.6
- 0.7

Reserve Position, All Reporting Banks
Excess Reserves (+ l/Deficiency (- l
Borrowings
Net free reserves (+ l/Net borrowed( - l
1

59
15
44

127
18
109

Includes loss reserves, unearned income, excludes interbank loans

2 Excludes trading account securities
3 Excludes
government and depository institution deposits and cash items
4 ATS, NOW, Super NOW and savings accounts with telephone transfers

u.s.

S Includes borrowing via FRB, TT&L notes, Fed Funds, RPs and other sources
6 Includes items not shown separately
7

Annualized percent change

-

7.3