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[rea^t H X 10 ,f f)3 p y v, s'* U iS (Press, He leases »* n" a* lr “ wwar u w v ^^ R A R Y P ™ M 5030 JUN 1 4 1972 TREASURY DEPARTMENT *' P- PRESS RELEASES 39-51 39-99 Nov. 16, 1943 Dec. 17, 1943 stability of our postwar economy. Unfortunately, it becomes even i more apparent that existing taxes are, in fact, not playing any such role. Instead of building bulwarks against postwar inflation and unemployment, our inadequate taxes provide aid and comfort to these disruptive forces. Instead of distributing the bulk of war's costs once and for all, our inadequate taxes will saddle the postwar tax system — and incidentally our fighting men — with a heavier burden of debt service. Postwar considerations heavily underscore the need for a courageous program of additional taxes. Failure to meet that need will expose our postwar economy to the ravages of inflation and unemployment. In this setting, the Treasury*s proposal for $10.5 billion of additional taxes stands out even more clearly than before as truly a minimum program. to recapture, corporations unable to reconvert rapidly will find their competitive position impaired. Small and medium-sized concerns would be most likely to suffer in the postwar scramble for the financial and material wherewithal of reconversion. Thus, forces which hinder reconversion will not only bring on a postwar economic crisis, but also encourage the growth of monopolies. Insofar as corporate tax policy in wartime removes postwar stumbling blocks, it contributes tellingly to the reestablishment of a strong peacetime economy* VII. Conclusi on I have said comparatively little this evening about specific provisions of current tax proposals* review some of the principles — principles” — It seemed more urgent to perhaps I should say "neglected that should govern wartime tax decisions. It becomes apparent in the course of review that wartime taxes play a major role in providing for the health and stability of The Treasury has recognized, however, that the carry-hacks will not serve their maximum purpose unless the promise of refunds is quickly converted into the fact of cash payments* Immediate access to cash will be the vital need in the demobilination period. The Treasury has therefore recommended a number of measures to accelerate refunds of war taxes under the carry-back provisions. If these measures are adopted, a substantial sector of the war economy will be guaranteed the lubricant of cash for the process of postwar reconversion. Nearly 50 percent of American industry is currently engaged in the production of war goods. Delay in reconverting it to peacetime production might mean inflation, or unemployment, or both. It might also spell loss of markets for the firms caught in the bottleneck. Since lost markets will be difficult or even impossible to recapture, evidence the credits do not mature immediately upon the cessation of hostilities, they become negotiable at that time* sold or used as the basis for loans. They may be The excess-profltsjjtax credit will thus supply many corporations with badly needed funds for the process of reconversion* Our existing tax law provides further assistance to many corporations by allowing the so-called carry-back of losses and unused excess-profits|tax credits* Under the loss carry-back provision, the corporation may offset its currentjyear losses against profits in the preceding two years and obtain a corresponding tax refund# Unused credits under the excess-profits tax may be similarly carried back# These provisions-recognise the arbitrariness of the annual accounting period* They will grant corporations whose wartime profits are converted into postwar losses a refund of at least part of their wartime taxes* These refunds are a potential source of funds for the difficult transition period* The Treasury reserve figures indicate that wartime taxes have performed this function generously. The average total annual profits after taxes for 1941* 1942, and 1943 will equal the peak profits of 1929 and will more than double the profits for 1937, Even after taxes and dividends, corporations will have accumulated over $15 billion of undistributed corporate profits during 1942, 1943, and 1944, These figures do not, of course, imply that every corporation will have a sound financial position at the end of the war. But they do indicate that wartime taxes have not, generally speaking, prevented the attainment of such a position* With respect to the postwar liquidity of corporate assets, tax policy can serve a positive function, One source of reconversion funds with roots in tax policy is the postwar credit under the excess profits tax. Corporations are entitled to a rebate of 10 percent of their @xcess*profitsitax payments. Although the bonds Issued to evidence the to exceed reasonable bounds, it mould be difficult to justify denials of wage and price increases* If the defense line against such increase crumbles, costs will rise sharply* But on the other hand, unduly high corporate taxes may weaken the resistance of management to pressures for higher costs* Once costs have pushed upward, it is very difficult to put them back into their former place* Since a high cost level tends to hobble production, wartime taxes on corporations /■ must walk a perilous tight rope* They must be high enough not to give labor and farmers & cause for action on the wage and price fronts, yet, they must not be so high as to remove the profit brake on costs* Effect on Financial Position, The postwar health of corporations depends also on the amount and liquidity of corporate accumulations. ■]f V : ' ' V'-? '!■//' ' R 9 H B With respect to their amount, taxes have a negative function, namely, to avoid impeding their normal growth, Corporate profit and reserve figures From this cursory resume, it becomes clear that the taxes we levy in wartime powerfully affect postwar distributions of costs among income groups* If war finance leaves a legacy of huge war debts and regressive taxes, we shall be ill-equipped to follow the traditional precepts of equity in government finance* To guard against this outcome, war finance should rely heavily on taxes, especially personal income taxes, and should^direct a large part of its bond-selling efforts to the lower Income groups* VI. Corporate Tax Policy In appraising the postwar effects of wartime taxes it is also important to examine the postwar impact vOf corporate tax policy* This impact revolves around the effect of corporation taxes on both cost structures and financial positions* Effect on Cost Structures. 'Corporate taxes must be high enough to prevent disproportionate war profits. If profits were allowed to exceed difficult to uproot xt after the war# The burden of postwar taxes would press snore heavily on the low income groups in that case than if the same revenue were raised through the income tax. By the same token, increased wartime reliance on personal income taxes will have long-run advantages in distributing war costs. From this cursory ♦ 37 * Large wartime accumulations of paper money are also generally thought to represent savings from low and moderate incomes. In addition* many people whose incomes and savings have risen sharply during the war will slide hack into moderate or low income brackets after the war. These factors reduce the likelihood that Government bonds will be as heavily concentrated in the hands of the higher income groups as they have been in previous wars. In terms of an undesirable postwar redistribution of burdens* then* the social cost of inadequate war taxes* though high, may be lower in this than in previous wars. Not only the magnitude but also the type of wartime taxes we levy will affect the postwar distribution of burdens. If* for example, we adopted a sales tax during the war, we might find it difficult to ** Sll » I n ■the pro-eeni waa^the larger part of the public debt is being absorbed by savers in the higher income brackets sums ofL at least $3f5, are very widely bought out of tjm current savings of people with low or moderate incomes, Uflt we find that in the year endin^peptember 30, 1943, the jgflesl of Series 1 Bonds jw /jf/ mjm of less than $500 face \^.lue amounte<M^fonly $$}7 billion. the same period, sales of In Series 1 Bdhds were $2,9 billion, while sales of tjpfr serielNfco tailed $fjL7 billion* Out of jF \ 1 total sales of $16.6 Jfi 11 ion to individuals r a p t he year, nearly I $10 billion reiupsent| bonds which do not gener investo^^pr lower income groups savers in the lower income brackets are accounting for a substantial share of total savings,^ the other to share pro rata in the burden of servicing the bonds held by civilians who were prospering at home. let* by setting wartime taxes too low, we^w^EL be causing precisely this injustice. Distribution Among Income Groups, Our decisions on war finance will affect the distribution of war costs not only between soldiers and civilians but also among different income groups after the war* 5 the level of wartime taxes, through its effect on borrowing!, governs the amount of taxes we shall have to levy after the war to service the public debt. Moreover, it determines in large part what income (j groups become government creditors. A war financed mainly by / rwadS^IW^/borrowing, especially if accompanied by inflation, builds up heavy credits in the hands of high-income groups against the rest of the population. Depending on the postwar distribution of tax burdens, such debt financing may lead to a postwar redistribution of burdens bearing heavily on the lower income groups. In the present Despite tax and price increases and a huge war effort, they are maintaining consumption comfortably above subsistence levels* At the same time, they are saving as never before, and with these savings will exercise a claim on postwar goods and services. In large part, these savings reflect our failure to tax more heavily in wartime* As one would expect, they take the form primarily of direct or indirect ownership of public debt* The combination of insufficient taxes in wartime and the handmaiden of a huge public debt means heavier taxes in the postwar period than would otherwise be necessary. These taxes will fall partly on the fortunate owners of wartime savings, but also in part on people who have not shared in the savings boom because they were in military service. j||§ It seems & curious way of distributing war burdens to ask our fighting men on one hand to bear the dangers and forego the profits of war, and on the other to share 33 - and thus leave the future with a better equipped economic system. On the other hand, borrowing may have a psychological advantage over taxation because the fallacy of postponement persists. People m y feel that they are postponing costs and therefore accept more willingly the direct sacrifices of war. Distribution of Costs Between Civilians and Servicemen. What \ is really postponed through borrowing is not the cost of war but the distribution of its cost. War finance can do a great deal to shift burdens among the people who will be members of the community after the war. As I hinted previously, the patterns of war finance into which we are drifting involve a discrimination against men now serving in the armed forces. Civilians at home are, with few exceptions, better paid than they ever have been in their lives. Despite tax and | - 32 - V. Distribution of Tax Burdens Costs of War# The fallacy still persists that the cost of the war in economic terms can be postponed after the war* It persists in spite of the fact that exploding this particular fallacy is one of the favorite "indoor sports" of economists* They are fond of pointing out that no method of war finance can shift real burdens from the war to the postwar period. Methods of finance cannot give people more food, housing, and clothing during the war at the expense of less after the war, can any financial legerdemain levy on the future to put weapons into the hands of our fighting forces in Italy and the Solomons* Whether we borrow or whether we tax will have only a minor effect on our total burden. Generally speaking, heavy taxes tend to minimize the wear and tear on the plant and equipment of our civilian economy and and thus leave X 31 « BooiaX Security, Another wartime fiscal measure which does yeoman service for the postwar period is the Social Security program* Expansion of unemployment insurance, and schemes providing for dismissal or separation pay on an insurance basis, offer an attractive hedge against our combination of inflation and unemployment dangers. They withdraw spending power steadily during periods of strong employment, both during and after the war. During periods of weak employment, they offer life blood to a faltering economic system. If unemployment is widespread, a strong Social Security program will support markets. If unemployment is spotty, which is more likely, Social Security will protect the Individuals whose luck is bad. On all counts, the strengthening of Social Security deserves high rank as a war measure which provides insurance against postwar instability. V* Distribution of Tax Burdens Cur pent payment has another important advantage in this connection. It permit® speedy legislative adjustment of tax collections to the fluctuating requirements of our economy. It permits tax adjus touts to be paired with Government spending policy in smoothing out the extreme fluctuations of the business cycle. m Under our present withholding system, we have not yet achieved the maximum exactness in current collection of liabilities. Year-end adjustments are necessary, and some of these will be fairly substantial. The Treasury has, therefore, recommended that the withholding system be adjusted to match the amount withheld more closely with the amount of taxes owed. This would be accomplished by graduating the withholding rates and by narrowing wage brackets in withholding tables. This adjustment is urged with an eye to avoiding a tax overhang in the demobilization period. Social Security. Another wartiml consumer markets and reinforce the downtrend* The situation during the rising phase of the cycle is analogous. If taxes In the current year are based on the smaller income of the preceding year, people will be in a fictitiously easy financial position. Upward pressures may be unduly reinforced* In connection with the effects of taxation on the business cycle, the Current Tax Payment &ct, passed earlier this year, Is an extremely important safeguard. For the most part, and especially in the lower brackets, current payment avoids the lag which tends to accentuate fluctuation®. current payment has a countercycle effect* income drops, and rise when income rises. Or, put positively, Taxes drop when The drain on purchasing power is minimized when incomes are on the downgrade, and maximized when Incomes are on the upgrade. Current payment has some pressure toward higher prices may actually be tenefici&l, since it will activate production and employment. But until we have cleared the decks for action, we are only too likely to burn up our wartime savings accumulations in a post-armistice spending spree that will express itself not in more goods, but only in higher prices. The Impact of Current Tax Payment. Given the prospect of unemployment and cyclical fluctuation after the war, it becomes important to correlate tax payments closely with the receipt of income. During an economic downturn and a period of developing unemployment, a mass of accruing but unpaid taxes can have a seriously depressing effect* If taxes payable out of a declining income in the current year are based on a higher income in the preceding year, the effect will be to dampen consumer markets and 27 * metaphor, it is even possible that we will have to wrestle with both at the same time! Nature of the Problem* The inflation d m g e r and the unemployment danger unfortunately do not cancel out* It is true, of course, that the same pressure of spending power which threatens inflation creates a strong market for many key products. It does not follow, however, that it automatically creates employment* The danger of unemployment during demobilization results not from any lag in consumer demand but from a lack of y the equipment and materials needed to employ labor in satisfying that demand* The initial problem of post**annistice unemployment is thus likely to be a bottleneck problem, ^fter the bottlenecks are broken, the danger of unemployment becomes largely one of inadequate purchasing power, in this situation, some pressure from the cumulative effects of increases in money and bank deposits during the war. Heavy wartime taxes and maintenance of such taxes until it is d e a r that postwar inflationary pressure is under control are the best weapons against these dangerous inflationary forces. The inflation thunderheads on the postwar horizon should have a sobering effect on any optimism about wartime taxation. They afford little aid and comfort to the enemies of a vigorous additional tax program. IV. Postwar Unemployment Dangers Our economic system in the postwar period faces not only the menace of inflation, but also the rigors of unemployment. Inflation and unemployment are the Seylla and Charybdis of demobilization periods. If we escape one, we are reasonably sure to have trouble with the other. V*e may, in fact, run athwart both in the same stormy voyage; and contrary to the metaphor, it is ©von "X * 25 - ending September 30, 1943, will be a further inflationary threat after the war* Business will quite naturally want to draw these funds out end put them into circulation. With business, as well as with consumers, any signs of a runaway market will be the signal for & rush to spend accumulated funds before their value melts away* A flash flood of business spending will eventually pour into the same stream as consumer spending* In the postwar period, the two forces will oe reinforcing and not offsetting, ana will tend to make a Joint attack on price stability* Records of past wars make it clear that post-armistice inflations are commonly more drastic than actual wartime inflations* This is no mere coincidence. It results from a relaxation of wartime controls, from impatience with restrictions, from the unleashing of speculative motives, and from the cumulative 24 \ During the war, business is steadily piling up cash balances* It is selling inventories it cannot replace* wearing out machinery It cannot fully maintain. It is And, because credit restrictions m l shortages of aid table goods severely limit new sales on m installment basis, it is reducing outstanding installment debts. Its opportunities and temptations to spend these balances are severely restricted by wartime regulations* Thus, liquid funds of business are fairly non-inflammable as regards wartime inflation. return of peace, business will naturally strive co repxenxsn xus inventories, renovate its equipment, and again push instalment selling* accumulated funds of business will tend to go into circulation at least as repdily as those held by consumers* Some 116 billion of reserve funds which corporations have put into Government bonds during the year ending September 20, 1943, to rely heavily on self-restraint and very likely also on an extension of direct oontrols into the immediate postwar era. The total increase in the money supply in recent years is enormous* Combined business and individual accumulations of currency and checking deposits rose $26.5 billion, or 59 percent, in the two years ended last June. Of this growth, $19 billion occurred in the second of the two years. Although we lack figures showing who holds the added currency, Federal Reserve figures are available on checking deposits, §» lear tha1 Lded checking deposits belong to business rather than to consumers, by this fact. From these it is Some people are very much comforted This sense of comfort is legitimate in wartime, when liquid business funds are largely tied down by priorities and other restrictions. However, in the postwar period, these business accumulations will be a real source of concern. During the war, aocountsj $21 billion are in the form of redeemable or marketable bonds* ,jj| our direct and Indirect controls, on one bandy and our jjj&pacity to revert to peacetime production, on the other, prove sufficient to cope with postwar inflation, these accumulations may settle down into permanent savings. But if people make up their minds that prices are rising and are likely to keep on rising, the process of spontaneous combustion may kindle the fires of inflation. People will want to spend their funds before price rises sap their purchasing power and devaluate their savings. To keep these combustible funds within manageable limits is one of the chief assignments of wartime taxes. I must ionfess that the taxes we have and seem likely to get may not keep liquid savings within manageable limits, We shall have to rely heavily • 21 * rather as one of our best guarantees, though a negative one, of of the free democratic system we are fighting to retain. However, if the impatience of the American people with wartime control bursts its bounds too soon after the war, we may be faced with economic disaster, A great fund of accumulated war savings will overhang our postwar market, Desirable as it is to hajpr a large volume of savings out of current income to lessen current inflationary pressure, such savings art not an unmixed blessing. In fact, the greater the contribution they make to the present fight against inflation, the greater the threat they offer to future price stability. In the three and one-half years ending June 30, 1943, the American people added the staggering total of $55 billion to their accumulated savings. Of this total increase in individual savings, $24 billion are in the form of currency and checking accounts; $21 billion 20 It is especially in the post-armistice period that inflation may disrupt our economic processes* || $ aB" ^ > Inflation forces* The end of active hostilities will unleash political and economic forces that m y irresistibly drive us to ||| post-armistice inflation. There will be an inevitable dilution of patriotism and of the willingness to accept controls that smack of regimentation* Patriotic appeals to saving will no longer have their present effectiveness. The red tape of price control and rationing, which is accepted as a necessary nuisance in wartime, will become a galling and intolerable restriction when victory has been won. Enforcement of controls will become much more difficult when civilians regain their mobility by renewed access to gasoline and rubber. I do not decry the unwillingness of the American people to retain restrictive wartime controls for a long period after the waiv I regard it rather as one of -In speaking of inflation and its dangers, whether in time of war or in the postwar period, I am not talking about sh the German type of inflation P l ’ ^r |* , * || | I| after the last war when German money became valueless. We are in virtually no danger of such a catastrophe* Rather I have in mind the kind of inflation we had after the last war when the cost of living m a went to 211 percent of its prewar level and wholesale prices WHQc went to 240 percent of their prewar level, That kind of inflation, even if no worse than it was after the last war, would be disastrous enough to warrant very great effort and sacrifice to avoid it. HI* Postwar Inflation Dangers Every day the press is full of nows about measures to hold the line against inflation* I cannot refrain from adding parenthetically that such news rarely assigns taxes their rightful place in the fight to hold the line. However that Is probably quite natural, since taxes are a background force, operating to relieve pressure on the front-line forces of price control and rationing. Most students of the question have been agreeably surprised at the degree of success achieved by our inflation controls to date, wherever they have not been breached by direct political pressure. inflation will not stay put. But it must be recognized that It will crop up at the first, and, indeed, at every opportunity where the aggregate of spending power exceeds the available supply of consumer goods and services. It is especially demanding that they stop learning from experience and giving the nation the benefit. True, our war outlays are so huge that a saving of only a small fraction justifies diligent effort in rooting out inefficiency. But we must not overestimate the amount of genuine economy that can result from our efforts. Incidentally, even where we find serious inefficiency, it does not follow that aggregate government outlays should be cut. Where inefficiency is exposed and corrected, it means that somebody has discovered a way of getting the same supplies with less work and less expense. But it also means that, if we do as much work as before by && more efficient methods, we can get more supplies for the same money. Where heightened efficiency opens this sort of opportunity, we should seize it for the same reason that we should reject suggestions to expand consumption goods output by skimping our fighting men. III. Postwar Inflation Dangers Every day the always easy to find fifty glaring examples of situations which in fact are very rare. By such “examples* you can readily make out a case that Americans stand over six feet six in their stocking feet or that they are under five feet tall — just as you can make out a case for astounding efficiency or outrageous inefficiency in war production. Secondly, there is a tendency to identify inefficiency with higher costs. A good deal of what looks like “inefficiency,1* is simply the cost of adapting to changes in war conditions. To start producing anti-submarine craft, for instance, and then shift suddenly to other types of production raises costs. But it i»n*t necessarily inefficient, any more than it is inefficient to pay money for fire insurance on a factory and then not have a fire. To demand that our procurement agencies should cut costs by blocking costly shifts in war production would amount to demanding that they - 16 * production to civilian production would be perverted economy. It would be extravagant squandering of the time needed for victory and, more important, of the lives of countless fighting men. Few of the advocates of economy, of course, are so extreme as to advocate reducing war production in such a short-sighted effort to benefit civilian consumers. Most of them center their attention on eliminating inefficiency in war production — is, on getting value for our money* that Getting value for money spent Is genuine economy, and the Treasury is deeply concerned about such economy# But opportunities for cutting government expenditures through the elimination of waste and inefficiency are smaller than many people suppose. In the first place, the prevalence of "inefficiency1* is exaggerated. The vivid examples often mentioned are unrepresentative. In a country of 130,000,000 people, it is always easy to 15 The Possibility of Effecting Economy. As I implied a moment ago, it is far from clear that we can in fact cut war expenditures at all sharply without impairing the war effort* Economy at the expense of war output is unthinkable. To my mind, economy means to buy only what is needed and to make sure that full value is received for the money outlay* In a global war, there is practically no limit to what is needed. of war are insatiable. The gods Expenditures could, of course, be cut and inflationary pressure eased by cutting war production. But the fact is that while we civilians have enough, and even more than enough, to take care of our minimum needs, our own armed forces and those of our fighting allies still have unfilled war needs. Moreover, the rapidly changing technology of modern war constantly turns up new and pressing needs. To sacrifice war production to * 14 fraction of any cut in expenditures* Ifce designers of the Treasury's $10.5 billion revenue program were conscious that it was uncomfortable close to the wartime economic minimum, But it was difficult to go beyond this goal in the face of the limited taxable capacity of taxpayers in lower and middle brackets, who have not shared in wartime increases in income or who are bound by pre-war commitments There is little likelihood that a wartime economy program will affect the taxable capacities of this group. Consequently, the $10.5 billion program continues to be the smallest we can conscientiously recommend. The most we can expect from any feasible out in expenditures is a narrow and much-needed margin of taxes above the economic minimum demanded by war* The Possibility of Effecting As I implied too anxious to have more manpower and materials to tool up for postwar production and to provide more housing, transportation, equipment, and so forth# Accordingly, any drop in the income of war workers as a result of reductions in government expenditures would probably be offset in large part by increases in the employment and income of workers in civilian industry. If a net decrease in the income paid to consumers did occur, moreover, it would be more likely to cut into their savings than into their attempted spendings. Some lessening of inflationary pressure would, of course, be achieved to the extent that supplies of goods were expanded. i 4m ^gf faJ& j /udtd* The upshot is that the wartime economic minimum of revenue I|j •- . .I‘ |1'•jf ‘-I •, needed for inflation control could be reduced only by a small fraction of any - 12 - would.be/imdwas6- If economy materially lessened inflationary 71 pressure. Actually, the reduction in this pressure would be only a fraction of the cut in expenditures. In the first place, insofar as the cut resulted from/n w n g sttnM w .v t m w n wit t e w * ^ jy -urt-uML 1^ ffpM'O' -ow &0 tit: uacLa** U u ._ Ho real easing of the/^ituation results from taking what was going to be excess-profits tax revenue and re christening it "reduction of expenditures," «***► In the second place, even where the cut in expenditures is real and not nominal, it Is unlikelyto result in reduction in inflationary pressure. Civilian industry is only too anxious to have * 11 * expenditures can in large part be substituted for additional taxes. It is a matter of record that the Treasury has strongly and repeatedly urged the adoption of rigid economy measures in §1 government. But such eeonoay must be consistent with the demands of an unstinting war effort. I cannot visualise a cut in expenditures during total war that would give us license to set our revenue sights below the Treasury's $10.5 billion program. The Effect of EcoHony on Tax Heeds. However, to forestall the charge that I am evading the issue, let me entertain for a moment the unrealistic assumption that we can do justice to the a j tion's war needs and yet pare expenditures far below estimates. How would such economy affect our tax goals? case for higher taxes 10 - economic maximum, the more we can restrict the growth of the public debt and the piling up of potentially explosive holdings of currency, bank deposits, and redeemable or negotiable bonds* The closer we can get to the wartime economic maximum, the stronger will be our postwar tax weapons against the forces of postwar inflation# The danger of spontaneous combustion of our vast savings backlog will be greatly reduced if we go into the immediate postwar period with a strong and even severe tax structure# Finally, the closer we can get to the wartime maximum, the less we shall be in the position of discriminating against our fighting men. It would be discrimination of the rankest sort to levy on the postwar earnings % A jl civilians, that is* # jU x ourselves % Yhe Panacea of Substituting Economy for jtoftg It is argued in some quarters that economy in government expenditures can When we refer to "revenue needs#" we are really referring to the need to avoid borrowing# and thus to hold down the debt with v&ich we shall have to deal in the postwar period. $&&&*'vjm M&skm m zJ, we will,# finance the war. need. The get the money needed to The crucial question is how we get the money we ore taxes we have now, the less the chance that our wartime borrowing will put our postwar taxes into a strait jacket of debt service. Postwar Considerations. We begin to see that between the maximum and minimum tax limits set by the wartime situation the optimum level will be determined by postwar considerations. And those considerations point toward the economic maximum rather than the economic minimum. The closer we can get to the wartime economic maximum# the more 8 * ia much blacker* There are ominous signs that during 1943 the two limits may have crossed, bringing the political maximum below the economic minimum. Applying the measuring rods I have just discussed to the $10.5 billion tax program advocated by the Treasury, I am forced to conclude that it is the minimum needed to bring us into the safety zone of wartime taxation. Congressional action to date is not in fact bringing us into that zone. Only by a trebling or quadrupling of the present Congressional tax effort can the Treasury goal be approximated and the safety zone be reached. You will note that ia discussing wartime tax considerations X have not mentioned the traditional factor of revenue need as an element in tax policy. J s t mmmm®- im *ir*± v 7 most of it should be made by somebody else. Allied to this is the irrational hope that by refusing to accept the fiscal symbol of wartime hardships* the hardships themselves can be conjured recognize that, in wartime, customary ways of living and customary values have to give way to the all-embracing effort to preserve freedom and prevent further aggression. This witches’ brew of limiting factors is familiar to every intelligent observer of the home front in this war. Setting the various limits side by side, we find that the economic maximum of wartime taxes lies a long way above the necessary minimum. Taxes can pull their share of the wartime load without cutting into incentives and production. But setting the political maximum against the necessary minimum, the picture is much blacker* the smaller the share of the job left for taxation to do* If taxes were left with the whole job of curbing inflation, the necessary minimum would be high* Consequently, there would be a narrow spread between the economic minimum and the economic maximum of wartime taxation* In fact, the measures I have just listed do an important part of the job and therefore broaden the area between ;||| the upper and lower limits* fhe Political Maximum* So far, I have talked in terms of the economic limits of taxation* No one is more aware than I that there is also a political maximum, a limit compounded, I might say, of quite different elements than the economic maximum* One of these elements is an almost sentimental fear that taxes will reach levels where they really hurt* Mother is the tendency of each group in the community to feel that sacrifice is needed, but that most of it The type of taxes we choose to do our wartime tax job will also affect the minimum and maximum economic limits. If we choose a sales tax with its callous indifference to variations in individual circumstances and it® tendency to work against* not with* our direct controls* the necessary minimum war taxes will be igher and the economic maximum will be lower. If, on the other hand* we depend most heavily on the income tax and tailor it carefully to individual circumstances* we increase the spread between the economic minimum and maximum. The size of our necessary minimum program also depends on the other measures we take to deal with the problem of inflation | . and the problem of distributing our short supply of consumer goods. The larger the share of the job done by such measures as bond-selling campaigns, credit restrictions, price and wage control, and rationing the smaller the financial incentives and morale that war production would suffer* The upper economic limit of war taxes* then* is found where the taxes reduce total output either by impairing incentives or by releasing resources from civilian production which cannot be utilised in war production# Spread Between Minimum and Maximum# I do not mean to imply that the upper and lower economic limits of wartime taxation are absolute limits, nor that they are a question merely of the amount of taxes we levy# These limits will depend in substantial degree on the understanding of the people and their willingness to participate in an all-out war effort# The greater the understanding and sense of sacrifice, the lower we can set the minimum needed to prevent inflation, and the higher we can push the maximum to which taxes can go without impairing morale and war production,# The type of taxes They are conditioned by the scale of war expenditures and by the character of the non-tax controls we have set up to curb inflation and distribute fairly the necessities of life* Until taxes reach a level where, in concert with other control measures, they give us & fighting chance to throttle inflation and to distribute the costs of war fairly, they are dangerously inadequate* The Economic Maximum* Turning to the upper limit of wartime taxes, we find both an economic and a political maximum for efficient war taxation* The economic maximum is reached at the lower of the two following levels* The first is the level at which further taxes would so reduce the demand for consumer goods that men and machinery would be released that could not be absorbed by the war sector of our economy and would therefore run to waste* The second is the level at which further taxes would so impair financial incentives * 2 slacken our current war effort. And, as this audience knows, the Treasury's recent tax recommendations were designed to intensify, not slacken, that effort. But the makers of wartime tax policy must increasingly have in mind the impact of current tax legislation on the postwar economy. I. Determinants of Wartime Tax Levels In attempting to set in proper perspective the demands of the present and the demands of the future on our wartime tax system, it may be helpful to examine the factors that determine the upper and lower limits of efficient war taxation. The Necessary Minimum. The minimum level, the lower limit of safety in war taxes, is primarily a function of the need for inflation control and the companion need for equitable distribution of warfs economic burdens. These needs do not operate in a vacuum* They are conditioned WARTIME TAXES AMD THE POSTWAR ECOHOlff Just a year ago I had the privilege of speaking at the new School for Social Research, and it is a real pleasure to be able to be with you again. a wartime revenue act* At that time I spoke on the birth of To&»w I address myself to the later stages of the life history of wartime tax acts, namely, their postwar effects. A year ago our major preoccupation on the military fronts, as well as on the home fronts, was overwhelmingly with the immediate job of winning the war* of tax policy. That preoccupation was also a characteristic While postwar considerations were important, they were not given major emphasis* I think we face a somewhat different situation today. The postwar element of all our activities, Including our tax activities, looms ever larger* It would be tragic to assume that this growing significance of postwar problems gave us license to slacken our current B * 7 ^ <?' 7y <f&-?4g-. -2- 3 S , 3 ^rotti pAT fa* Gene rax School for Social R e s e a r c h JSww--t-C^i£L gy, is scheduled for delivery at 8 p,irug Eastern War Time, November 16* 1943* and is for release at that txmeT) ,;'V; ■.V TiiEASOHT DEPARTMENT Washington (The following address by Randolph !* Paul, General Counsel of the Treasury, before the New School for Social Research, New York City, is scheduled for delivery at S p.m., Eastern War Time, November 16, 1943, and is Tor releaseat that time.) . .. y >v ■ TREASURY DB^AHjMSNT ■■ Washington, 7 ■ .. (The foilowing, address by Randolph E* ;Paul , General Counsel of the Treasury, •before the .Hew School for Social Research,. New York’City,- is..scheduled for delivery at S-p.m,-, Das tern War, .Time.,; November 16, 19^3 * and js for release at that; time WARTIME TAXES AH) THE .POSTWAR SQQHQHY' " «’ iT r l ’!;/-' .1.' 'v *‘Y“ ' * : ’ * r• ; ’• Just a year ago I had the privilege .of speaking at the new School for Social Research, and it is a real pleasure.,tp'he able to "be with you again. At that time J spoke oii-the birth•of •a wartime revenue act. . Tonightpaddress myself- to the later stages'of, the life history of wartime tax acts; namely, their postwaf -effects. . A.year ago our major preoccu pation on the military.fronts, as well as.,on the home frohts, was overwhelmingly with the’immediate job of winning the war. That pre occupation was also a characteristic of tax policy*. While postwar considerations were important"; they were, not given-major emphasis. .. X think we face a somewhat different situation-today. ' The postwar element of all our activities including, .our tax activities,' looms ever, larger. It would, be tragic to-assuhe ;that this, growing-significance of postwar problems gave us license to slacken* our-current war effort* And, as this audience knows,-'the Treasury';s .recent t a y recommendations were designed to intensify, not ‘slacken, that effort. But the makers of wartime tax policy must increasingly have-an-mind the -impact of current tax legislation on. the postwar economy; '" .’ It-: -Detarmihants’of Wartime. Tax-.levels In attempting- to set: i n jproper.perspectiye the demands of the present and the demands of the .-.future on our wartime tax-system, it may be help ful to examine the faot-ors' that' determine ..the, upper and' lower limits of. ■ efficient war taxation-* '' * .;, ’ ,' " i The Necessary, Minimum'. The minimum level, the lower limit of safety in war taxes, is primarily a function of the need for inflation • control and the companion need for equitable, distribution '-of warJs • economic burdens, These needs do not operate., in a vacuum, "They are conditioned by the scale of War expenditures .and. by -the character of the . non-tax controls we have set up to curb inflation .and distribute, fairly the necessities of. life. ; Until taxes reach a level -where, in concert . with other. Control measures, they give us a .fighting chance to throttle, inflation and to distribute the Costs of. war .fairly, they are dangerously inadequate,. '';■ . ’ ... . •. ' . -r 39-?l 2 ‘’ The Economic Maximum, Turning to the upper limit of wartime taxes, we find "both an economic and a political maximum for efficient war taxa tion. The economic maximum is reached at the lower of•the two following levels. The first is the level at' which''■■further' faxes would so reduce the demand for consumer goods; that .men. and machinery."would he released that could not. he absorbed by- the wap sector-- of our'economy and would therefore run to waste, The* second is the level at which further taxes would so impair financial incentives and morale that war production would suffer. The upper economic limit of war taxes, then, is found where the taxes reduce total output either by impairing incentives or by releasing resources from civilian -production which.cannot be utilized in war production, Spread Between Minimum and Maximum.' I do/nat mean t:o imply that the Upper and lower1 economic limits of wartime taxation .’are absolute limits, nor that they are a question merely of the amount of taxes we,', levy. These limits will depend in’ substantial degree On the understanding of the people and their willingness' to participate in an all^OUt war effort.;.The-greater the understanding and sense of sacrifice, the lower we can 'set..the minir* mum needed t o 'prevent inflation, and-the higher we can .push the maximum t o ‘which taxes can go- without'impairing morale and*war production*• The type of taxes we -choose to do our. wartime tax job will also affect.the minimum and maximum economic limits. If we choose a sales tax with its callous' indifference to variations in individual circumstances and its-tendency to' work against,'not with, our- direct Controls, the necessary'minimum war" taxes Will be higher and the economic maximum •.wi 11 be lower. If, on'the other hand; we depend'most heavily o n ;the income tax and tailor i t jcarefully tc individual circumstances* we-increase the spread between the economic minimum and maximum. The size of our necessary' minimum program' also depends on the other measures we take to deal with the problem of inflation and the problem of distributing our short'supply of consumer' goods.- -The -larger -the share of the job done by such measure's as bond-”selling campaigns., ?.credit,-restrict firms, price and wage control, and rationing, -the smaller the share -of the job left for taxation to do. If taxes were: left .with the, whole job of curbing inflation, the necessary minimum would be high*. Consequently, there would be a narrow spread'between the ecbn'omic minimum and the economic maximum .of wartime taxation. In fact,- the measures: 1 have jus-f listed do an important part 'of the job and therefore .broaden .'the area- between the upper and lower•limits. % Lk , -.'i ’ The political Maximum. So -far, I have talked in .terms of- the economic limits of taxation. Uo one -is more' awia're than I that, there is. also a po litical' maximum, a-limit compounded,. I might say, .of .quite different element's than the-economic maximum. One of these' elements is. an almost sentimental fear that taxes will reach levels where they .really hurt, Another is the tendency of each group ip the community to feel that sacrifice is needed, but that m°st of it should be made by somebody else. Allied to tpis is the irrational hope that by refusing to accept the fiscal symbol of wartime hardships, the hardships themselves can be con jured out of existence. Finally, ope encounters sheer unwillingness to - 3 recognize^ that, in wartime, customary ways of living and have to give way to the all-embracing'effort to preserve vent further aggression# This witches* brew of limiting familiar to every intelligent observer of the home•front customary values freedom and pre factors is in this war. Setting the various limits side by side, we find that the economic maximum.of wartime taxes lies a long way above the necessary minimum# Taxes can pull their share of the wartime load without cutting into incentives and: production*- But setting the political maximum against the necessary minimum,- the picture is much blacker# There are ominous signs that during 1943 the two limits may have crossed, bringing the ' political maximum below the economic minimum# Applying the measuring rods I have just discussed to the $>10#.5 billion tax program advocated by the Treasury, I-am forced to conclude that it is the minimum needed to bring us into the safety zone of wartime taxation. Congressional action to date is not in fact bringing us into that zone#' Only by a trebling or quadrupling of the present Congressional tax effort' can the Treasury goal be approximated and the safety zone be reached. You, will note'that in discussing -wartime tax considerations I have not ■mentioned'’the traditional factor of Revenue need as an .element in tax policy*". When we refer to *•*revenue heeds,** we are really referring to-the need to avoid’borrowing,;and thus to hold down the debt with which we shall -have to deal in the postwar period. There can be no doubt that we w i l l -get the money needed to finance the war#\ The crucial question is how we get the money we need# ■ The more taxes we have now, the less the chance that our wartime borrowing will put our postwar taxes into a strait jacket of debt service# '■ v* Postwar Considerations# We begin to see -'that between the “maximum .and minimum tax limits set by the wartime situation’the optimum level will be determined by postwar considerations# « 'And those considerations point toward the economic’maximum rather than the economic minimum. The .closer we can get to the-wartime'economic maximum, the more we can restrict the growth of the public d'ebt'and the piling up'of potentially explosive holdings of currency, bank deposits> and redeemable or nego tiable bonds# The closer we can. get to the,wartime economic maximum, the stronger will be our- postwar tax weapons against the force’ s of postwar inflation# The danger of spontaneous combustion of our vast savings backlog will be greatly reduced if we go into the immediate post war period with a strong and even severe tax structure# Finally, the closer we can get to the wartime maximum, the less we shall be in the position of discriminating against our fighting men# It would be dis-. criminationV of the rankest sort to levy on the postwar earnings of servicemen the'taxes that well-paid civilians, that is, ourselves,’ ought to have paid during the war# II. The panacea of Substituting Economy for Taxes It is argued in some quarters that economy in government expend!- . tures can in large part be substituted for additional taxes. It is a matter of record that the Treasury has strongly and repeatedly urged the adoption of rigid economy measures in government. But such economy must be consistent .with the demands of an unstinting war effort. I cannot visualize a cut in'expenditures du-Hng total war that would give us license to set our revenue'sights below the Treasury’s $10*5 billion program. The Effect of Economy pa Tax Heeds. However, to forestall the charge that I am evading tite ‘issue, let me entertain for a moment the . unrealistic assumption that we can do justice to the nation’s war needs and yet pare expenditures far below estimates. How would such economy affect our tax goals? The case for higher taxes would not be so urgent if economy materially lessened inflationary pressure. Actually, the reduction in this pressure would be only a fraction o f ‘the cut in expenditures. In the first place, insofar as the cut resulted from reduction of prices for war supplies, it would be offset largely by a reduction in excess profits and income tax revenues* Ho real easing of the inflationary situation results from taking what was going to be excess-profits tax revenue.and rechristening it ’’reduction of expenditures.” In the second place, even where the cut in expenditures is'real and not -nominal, it does not. result in an equivalent reduction in inflationary pressure. Civilian industry is only too anxious to have more manpower and materials to tool up for postwar production and to provide more housing, transportation, equipment, and so forth. Accordingly, any drop in the income of war workers as a result of reductions in government expenditures would probably be offset in large part by increases in the employment and income of workers-in civilian industry. If a net decrease in the income paid to consumers did occur, moreover, it would be more likely to cut into their savings than into their attempted spendings. Some lessening of inflationary pressure would, of course, be achieved to the extent that supplies of consumption goods were expanded. But any resources released to civilian industry would in large part be used for repairs, maintenance and retooling rather than to produce finished consumers’ goods. The upshot is that the wartime economic minimum of revenue needed for inflation control could be reduced only by a small fraction of any cut in expenditures. The designers of the Treasury’s $10.5 billion revenue program were conscious that it was uncomfortably close to the wartime economic minimum* 3ut it was difficult to go beyond this goal in the face of the limited taxable capacity of taxpayers in the - 5 lower and middle "brackets, who have not shared in wartime increases in income or who -are bound by pre-war commitments, There is'little likeli hood that a wartime economy program will affect the taxable capacities of this group. Consequently, the $10,5 billion program continues to be the smallest we can conscientiously recommend. The most we can expect from any feasible cut in expenditures is a narrow and much^needed margin of taxes above the economic minimum demanded by war. fhe Possibility of Effecting Economy. As I implied a moment ago, ; it is far from clear that we can in fact cut war expenditures at all sharply without impairing the war effort. Economy at the expense of • war output is unthinkable* To- my mind, economy means to buy oxyly what is needed and to make sure that full value is received for the money outlay. . In a global war, there is practically no limit: to what is needed. The gods of war are insatiable, Expenditures could, of course, be cut and inflationary pressure eased by cutting war production. But the fact is that while we civilians have enough, and even more than enough, to take care of our minimum needs, our own armed forces and those of our fighting allies still have unfilled war needs. Moreover, the rapidly changing technology of modern war constantly turns qp new and pressing needs. To sacrifice war production to civilian production would be perverted economy. It would be extravagant squandering of the time needed for victory and, pore important, of the lives of countless fighting men. Few of the advocates of •economy, of course, are so extreme as to advocate reducing war production in such a short-sighted effort to benefit•civilian consumers. Most of them center their attention on eliminating inefficiency in war production -v that is, on getting value for our money, (Jetting value for money spent is genuine economy, and the Treasury is deeply concerned about such economy. But opportunities for cutting government expenditures through the elimination of wast.e and inefficiency are smaller than many people suppbse. In the first place, the prevalence of "inefficiency1* is exaggerated. The vivid examples often mentioned are unrepresentative. In a country of 130,000,000 people, it is always easy to find fifty glaring examples of situations which-in fact are very rare* By such "examples" you can readily make out a case' that Americans stand over six feet six in their stocking feet or that they are under five feet tall — just as you can make out a case for astounding efficiency or outrageous inefficiency in . war' production. 3'ct^v Secondly, there is a tendency to identify inefficiency with highs* costs, A.good deal of what looks like "inefficiency," is simply the cost of adapting to changes in war conditions, To start producing anti~ submarine craft, for instance, and then shift suddenly to other, types of production raises costs. But it isn*t necessarily inefficient, any more than it is inefficient to pay money for fire insurance on a factory and then not have a fire. To demand that our procurement agencies should cut costs by blocking costly shifts in war production would amount to de manding that they stop learning from experience and giving the nation - 6the benefit* True, our war outlays are so huge that a saving of only a small fraction justifies diligent effort in rooting out inefficiency. But we must not overestimate the amount of genuine economy-that can result from our efforts. Incidentally, even where we find serious inefficiency, it does not follow that aggregate government outlays should be cut. Where inefficiency is exposed and corrected, it means that somebody has discovered a way of getting the same supplies with less work and less, expense. . But it also means that, if we do as much work as before by more efficient methods, we can get more supplies for the same money. Where heightened efficiency opens this sort of opportunity, we should seize it for the same reason that w© should reject suggestions to expand consump tion goods output by skimping .our fighting men, XII. Postwar Inflation Dangers Every day the press is full of news about measures to hold the line against inflation. I -cannot refrain from adding parenthetically that such news rarely assigns taxes their rightful place in the fight to hold the line. Howevdr, that is probably .quite natural, since taxes are a background force, operating'to 're lieve pressure on the front-line forces of price control and rationing. Most students of the question have been agreeably surprised at the degree of success achieved by our inflation controls to date,.wherever they have not been breached by direct political pressure. But it must be recognized that inflation will not stay put. It will crop up. at the first, and, indeod, at every opportunity of consumer goods and services. It is especially in the post-armistice period that inflation may disrupt our economic processes. In speaking of inflation and its dangers, whether in time of war or in the postwar period, X am not talking about the German type of inflation after the last war when German money became valueless. W e are in virtually no danger of such a catastrophe. Bather. I have in. mind the kind of inflation we had after the last war when the cost of living went to 211 percent of its prewar level and wholesale prices went: to 240 percent of their prewar level. That kind of infla tion, even if no worse than it was after the last war, would be disastrous enough to warrant very great effort and sacrifice to avoid it. Inflation Forces. The end of active hostilities will unleash political and economic forces that raay irresistibly drive us to post-armistice inflation. There will be an inevitable dilution of patriotism and o f 'the willingness to accept controls that smack of regimentation. Patriotic appeals to saving will no longer have their present effectiveness. The red tape of price control and rationing, which is accepted as a necessary nuisance in ^wartime, will become a galling and intolerable restriction when victory has been won. Enforcement of controls will become much more difficult when civilians regain their mobility, by renewed access to gasoline and rubber. ■ I do not decry the unwillingness of the American people to retain restrictive wartime controls for a long period after*the war. I regard it rather as one of our best guarantees, though a negative, one, of the free democratic system we are fighting to retain. However, if the impatience*of the American people with wartime control' bursts its bounds too soon after the w a r , :we may be faced with economic disaster. A great fund of •.accumulated war savings will overhang our postwar market. Desirable as it is to have a large volume of savings out of current income to lessen current inflationary pressure, •• ~ 7 such savings are not an unmixed 'blessing* In fact, the greater the contribution they make to the. present fight against inflation, the greater the threat they^offer to future price stability. In the three and one-half years ending June 3°» 19^3* the American people added the staggering total of $55 billion to their accumulated' savings. Of this total increase in individual savings, $2*+ billion are in the form of currency and checking accounts; $21 billion are in the form of redeemable or marketable bonds. If our direct and indirect controls, on one hand, and our capacity to revert to peacetime’production, on the other, prove sufficient to cope with postwar inflation, these accumulations may settle down into permanent savings* But if people make up their minds that prices are rising and are likely to keep on rising; the process of spontaneous combustion may kindle the fires of inflation. People will want to spend their funds before price rises sap their purchasing power and ' devaluate their savings. To keep these combustible funds within manageable limits is one of the chief assignments of wartime taxes. I must confess that the taxes we have and seem likely to get may not keep liquid savings within manageable limits. We shall have to rely heavily On self-restraint and very likely also on an extension of direct controls into the immediate postwar era. Increased Money Supply and the Role of Business Savings. The total increase in the money supply in recent years is enormous. Combined business and individual accumulations of currency and checking deposits rose $26.5 billion, or 59 percent, in the two years ended last June. Of this growth, $19 billion occurred in the second of*the two years. Although we lack figures showing who holds the added currency, Pederal Reserve figures are available oh checking deposits* Prom these it is clear that most o f ‘the added checking deposits belong to business rather than to consumers. Some people are very much comforted by this fact. This sense of comfort is legitimate in wartime, when liquid business funds are largely tied down by priorities and other restric tions. However, in the postwar period; these-business accumulations will be a real source of concern.* During the war, business is steadily piling up cash balances. It is selling inventories it cannot replace* It is wearing out machinery it cannot fully maintain. And, because credit restrictions ’and shortages of suitable goods severely limit new sales on an in stallment basis, it is reducing outstanding installment debts. Its opportunities and temptations to spend these balances are severely restricted*by wartime regulations. Thus, liquid funds of business are fairly non-inflammable as regards wartime inflation* -8 But with the return of peace*, business will naturally strive to replen ish its inventories* renovate its. equipment, and again push installment selling. Accumulated funds of business will tend to go into circulation at least as rapidly as those held by consumers* Some $15 billion of reserve funds which corporations have put into Government bonds during.the year ending September 30, 1943, will be a further inflationary threat after the war* Business will quite naturally- want to draw these funds out and put them into circulation* With business,, as well as with consumers, any signs of a run away market will be the signal.for a rush to spend accumulated funds before their value melts away* A flash flood of business spending will eventually pour into the same stream as consumer spending* In the .postwar period, the two forces vail be reinforcing and not offsetting, and will tend to makea joint attack on price stability. Records of past wars make it clear that post-armistice inflations are commonly more drastic than aptual wartime inflations* Tnis is no mere coin cidence. It results from a relaxation of wartime controls, from impatience with restrictions, from the unleashing of speculative motives, and from the cumulative effects of increases in,money and bank deposits during the war* Heavy wartime taxes and maintenance of such taxes until it is clear that postwar inflationary pressure is under control are the best weapons against these dangerous inflationary forces* The inflation thunderheads on the postwar horizon should have a. sobering effect on any optimism about wartime taxation. They afford little aid and comfort to the enemies of a vigorous additional tax program, IV. Postwar Unemployment Dangers Our economic system in the postwar period faces not only the menace of inflation, but also the rigors of unemployment. Inflation and unemployment are the Scylla and Charybdis of demobilization periods*. If we escape one, we are reasonably sure to have trouble with.the other* We may, in fact, run athwart both in the same stormy voyage;, and contrary to.the metaphor, it is even possible that we will have to..wrestle with .both..at the same time] Nature of the Problem* The inflation danger and the unemployment , danger unfortunately do not cancel out* ..It is true, of course, that the same pressure of spending powrer which threatens inflation creates a strong market for many key products* It does not follow, however, that .it auto matically creates employment. The danger of unemployment during demobiliza tion results not from any lag in consumer demand, but from a lack of the equipment and materials needed to employ labor in satisfying tnat demand* The initial problem of post-armistice unemployment is thus.likely to be a bottleneck problem* After the bottlenecks are, .broken, the danger of un— employment becomes largely one of inadequate purchasing power* In this situation, some pressure toward higher prices may actually be beneficial, since it m i l activate production and employment* But until we have cleared the decks for action, we are only too likely to burn up our wartime savings accumulations in a post-armistice spending spree that will express itself not in more goods, but only in higher prices. c «• Q *• The Impact of Current Tax Payment. Given the prospect of unemployment and cyclical fluctuation after the war,-it becomes important to correlate tax payments closely with the receipt of inoome. During an economic down turn and. a period of developing unemployment, -a mass of accruing but unpaid taxes can have a' seriously depressing effect* ‘ If taxes payable out of a declining'income in., the. current'year are based on a higher income in the preceding year, ‘the effect will’be -to dampen consumer markets, and .reinforce the -downtrend* " The situation during- the rising phase of the cycle is .analogous* '.. if taxes in the current'year are based on the smaller income of t h e ,preceding year,3 people will be in a fictitiously easy-financial position* Upward pressures-may'be unduly reinforced. In '.connection with the, effects of taxation on the business cycle,; the Current Tax Payment Act, passed earlier this year, is an •extremely ‘important safeguard* For the most part, and especially in the lower brackets,.cur rent payment avoids the lag which tends to accentuate fluctuations*.. Or, •put positively, -current payment has: a countercycle effect* Taxes drop when •income drops, and rise when income rises*/ The .drain ori-purchasing power is minimized ’when incomes-are on the downgrade, and maximized when incomes are on'the upgrade* •' -■ Current payment has another important advantage-in 'this connection# It permits speedy legislative adjustment of tax collections to the fluctuat ing requirements of our economy. It' permits .tax 'adjustments to be paired with Government spending policy in smoothing out-the extreme fluctuations of the business cycle*' , , Under Our present withholding‘.system, .we have not yet achieved the maximum exactness in current collection of liabilities* Yeartrend adjust•m.ents are necessary, and some of these will be fairly substantial* The •Treasury has,-therefore, recommended that the withholding system be adjusted .to .match the 'amount, withheld 'more closely with the amount; of taxes owed* •This wotiid be' accomplished by graduating^ the .withholding rates and b y nar rowing wage brackets.;in withholding tables*. This adjustment is urged with ■ an eye to avoiding a tax .overhang in the demobilization period. . Social -Security. Another wartime fiscal measure-which does ..yeoman ■service for the postwar period is the Social, Security program*. Expansion . of unemployment insurance, and schemes providing for dismissal or separa tion pay on an'insurance-basis,, offer an attractive hedge against our com bination of inflation .and .unemployment dangers# They withdrawn spending powrer steadily during, periods of strong; employment, both during...and after the war*, During periods-, of wreak employment,., they offer life blood to a faltering economic system*..' If unemployment is widespread, •a, strong Social Security program "will .support markets* If unemployment is spotty, Which is more likely, Social Security wall -protect the individuals whose -luck.is bad* On all counts, the strengthening of;Social Security deserves high rank as1 a war measure which, provides insurance against postwar .instability*' .. ? . 10 V. Distribution, of Tax Bardens Costs oif War. The fallacy still persists that the cost of the war in economic.tends can be postponed until after the war. It persists in spite' of the fact that exploding this particular fallacy is one of the favorite ^indoor sports” of economists. They are fond of. pointing out that no method of war finance can shift real burdens from the war to the postwar period. Methods of .finance 'cannot give people more food, hous ing, and clothing during the war at the expense of less after the war. Nor can any financial legerdemain levy on the future to put weapons into the hands of our fighting forces in Italy and the Solomons. 'Whether we borrow or whether we tax will have only a minor effect on our total burden. Generally speaking, heavy taxes tend to minimize the wear and tear on the plant and eauipment of our civilian economy and thus leave the future with a better equipped economic system. On' the 6 the r hand, borrowing may have a psychological advantage over taxation because the fallacy of postponement persists. People may feel that they are postponing costs and therefore accept more willingly the direct' sacrifices of war, ' Distribution of Costs Between Civilians and Servicemen, Whet is really postponed through borrowing is not the cost of war but the dis tribution of its cost. War finance can do a great deal to shift burdens among the people who will be members of the community after the war. As I hinted previously, the patterns of war finance into which we are drifting involve a discrimination against men now serving in the armed" forces. Civilians at home are, with few exceptions, better paid than they ever have been in their lives. Despite tax and price increases and a- huge war effort, they are maintaining consumption comfortably above subsistence levels. At the same time, they are saving as never before, and with these savings will exercise a claim on postwar goods and services. In large part, these savings reflect our failure to tax more heavily in wartime. As one would expect, they take the form primarily of direct or indirect ownership of public debt.' The combination of insufficient taxes in wartime and the handmaiden of a huge public debt means heavier taxes in the postwar period than would otherwise be necessary. Thes-e taxes will fall partly on the fortunate owners of wartime savings,■but also in part on people who have not shared in the savings boom because they were in military service. It seems a curious way of distributing war burdens to ask our fighting men on one hand to bear the dangers end forego the nrofits of "war, and on the other t o ‘share pro rata in the burden of servicing the bonds held by civilians who were prospering at home, Yet, by setting wartime taxes too low, we shall be causing pre cisely, this injustice. Distribution Among Income Groups. Our decisions on war finance will affect the distribution of war costs not only'between soldiers and ' civilians but also among different income groups after the *war.- The level of wartime taxes, through its effect on borrowings, governs the amount of taxes we shall have to levy after the war to service the public debt. Moreover, it determines:, in U r g e p^rt what income, groups become, government •creditors.- A war financed mainly by borrowing,. especially. accompanied b y inflation;, builds up: heavy -credits in. the. hands...of high-income groups against the rest of the population., Depending on the postwar distribu tion of tax burdens, such debt financing may lead to a postwar redistribution of burdens.bearing heavi ly on. the- lower income groups. ... r Although as in previous wars the. larger part of the. public debt is . being absorbed by savers in the higher.income brackets, savers, in the lower income brackets are accounting.for- a substantia^ share- of total -savings*' They are buying a large volume of War Bonds* Large wartime accumulations ..of paper-money are also generally thought to represent -savings from low- and moderate incomes. In addition, many people whose income § 'and. savings have risen sharply during the war ,wi.ll slide back into moderate:.or- low-income brackets, after the war* . .These factors reduce the likelihood that Government bonds will, be as. heavily concentrated „in the hands of the higher income groups as they have been in previous wars. In terms of an undesirable postwar redistribution of burdens, then, the social cost .of inadequate war tajces, though.-high,, may be .lower in this than in previous wars.-. ■ • \ EJ . . Wot only the magnitude but-also-the type of wartime taxes .we levy '.will aff eqt'the- postwar.distribution of burdens. If, for^ example, we adopted a sales tax during the war, we'might find.it difficult to uproot it after the war. The burden .of postwar-.taxes would press more heavily .on-;the low income groups in that case than if the same revenue were raised through the income tax. By the same,token! increased wartime'reliance on personal income- taxes will,have long-run advantages in distributing war costs* . , .. • ' . '• '• Prom this cursory resume, it becomes clear that the,taxes we levy in wartime powerfully affect postwar distributions of’ costs among income groups. If war finance leaves, a legacy of huge war debts,and regressive taxes, we shall be i.ll-*equipped to follow the traditional, precepts of equity in government finance* ..- To. guard against this outcome, war finance should rely heavily on taxes, especially personal income taxes, emd should continue to direct a large part of its bond-selling efforts to.the lower income groups. V - VI. 12 - Corporate Tax Policy In appraising the postwar effects of wartime taxes it is also 'important to examine the postwar impact of corporate tax policy. This impact revolves around the effect of corporation taxes bp "both cost structures and financial positions., Effect on Cost Structures. Corporate taxds must he high enough to prevent, disproportionate war profits. If profits were allowed to exceed reasonable bounds, it would be difficult to justify denials‘of wage and price,increases. If the defense,line.against such increases crumbles, costs will rise sharply. But on the other hand* unduly high, corporate taxes may weaken the resistance of management to pressures for*higher costs. Once costs have pushed upward, it is very difficult to put them back into their former place.. Since a high cost level tends to hobble production, wartime taxes on corporations must walk a perilous tight rope. They must be high enough'not to give labor and farmers a cause for action on the' wage.and price fronts; yet, they must not be so high as to remove the profit brake on costs. Effect on Financial Position. The postwar health of corporations depends also on the amount and liquidity of corporate accumulations. With respect to their;.amount» , taxes have a negative function*, namely, to avoid impeding their normal growth. Corporate profit, and reserve figures indicate that wartime taxes have performed this function.generously. The average total annual profits after taxes for 19^1, 19^2, and 19U 3 will equal the peak profits of 1929 end will more than double the ..profits for 1937a Even "after taxes and dividends, corporations will have accumulated over.$15 .billion of undistributed corporate, profits during 19^-2 , 19^+3* and 19W*, These figures do not, of course, imnly that every corporation will have a sound financial position at the end of the war. But they do indicate that wartime taxes have not, generally speaking,, prevented the attainment of such a position. With resnect to the postwar liquidity of corporate assets, tax policy can serve a positive function. One source of reconversion funds with roots in tax policy is the postwar credit undeh the excess-profits tax. Corporations .are entitled to a rebate of 10 percent of their excessprofits tax payments. Although the bonds issued to evidence the credits do not mature immediately upon the cessation of hostilities, they become negotiable at that time. They may be sold or used as the basis for loans. The excess-profits tax credit will thus supply many corporations with badly needed funds for the process of reconversion. Our existing tax law provides further assistance to many corporations by allowing the so-called carry-back of losses and unused excess-profits tax credits. Under the loss carry-back provision, the corporation may offset its current year losses against profits in the preceding two years and obtain a corresponding tax refund. Unused credits under the excessprofits tax may be similarly carried ba.ck, These provisions pecognize the arbitrariness of the annual accounting period. They will grant corporations whose wartime profits are converted into postwar losses a refund of at least part of their wartime taxes. These refunds are a potential source of funds for the difficult transition period. - 13 The Treasury has recognized, however, that the carry-backs will not serve their maximum purpose unless the promise of refunds is quickly con verted into the fact of cash payments. Immediate access to cash Twill be the vital need in the demobilization period. The Treasury has therefore recommended a number of measures to accelerate refunds of war taxes under the carry-back provisions. If these measures are adopted, a siibstantial sector of the war economy will be guaranteed the lubricant of cash for the process of postwar reconversion. Nearly 50 percent of American industry is currently engaged in the production of war goods. Delay in reconverting it to peacetime production might mean inflation, or unemployment, or both. It might also spell loss of markets for the firms caught in the bottleneck. Since lost markets will be difficult or even impossible to recapture, corporations unable to reconvert rapidly will find their competitive position impaired. Small and medium-sized concerns would be most likely to suffer i n the postwar scramble for the financial and material wherewithal of reconversion. Thus, forces which hinder reconversion will not only bring on a postwar economic crisis, but also encourage the growth of monopolies, Insofar as corporate tax policy in wartime removes postwar stumbling blocks, it contributes tellingly to the reestablishment of a strong peacetime economy, VII, Conclusion I have said comparatively little this evening about specific provisions of current tax proposals. It seemed more urgent to review some of the prin ciples t— perhaps 1 should say ^neglected principles** — that should govern wartime tax decisions. It becomes apparent in the course of review that wartime taxes could play a major role in providing for the health and stability of our postwar economy. Unfortunately, it becomes even more apparent that existing taxes are, in fact, not playing any such role* Instead of building bulwarks against postwar inflation and unemployment, our inadequate taxes provide aid and comfort to these disruptive forces. Instead of distributing the bulk of war*s costs once and for all, our inadequate taxes vail saddle the postwar tax system — and incidentally our fighting men — with a heavier burden of debt service. Postwar considerations heavily underscore the need for a courageous program of additional taxes. Failure to meet that need will expose our post war economy to the ravages of inflation and unemployment, In this setting, the Treasury* s proposal for 010,5 billion of additional taxes stands out even more clearly than before as truly a minimum program. oOo TREASURY DEPARTMENT Washington FOR IMEDIATE RELEASE, ^ 0 rg»i r - rl i j , D c i umlr'U Ji Press Service _ 1 ?% ?! / J", / $ y 3, During the month of no market trans actions took place in direct and guaranteed secur ities of the Government for Treasury investment and other accounts, Secretary Morgenthau announced today. -foOo- o O & TREASURY DEPARTMENT V/ashington FOR IMMEDIATE RELEASE, Monday, November 15> 1943* During the month of October, 1943? Press Service No. 39-52 no market transactions took place in direct and guaranteed secur ities of the Government for Treasury investment and other accounts, Secretary Horgenthau announced today. TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, TUesd&y, November 16. 1943* Presa Service The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts, of 91-day Treasury bills to b e dated November 18, 1943, and to mature February 1?, 1944, which were offered on November 12, were opened at the Federal Reserve Banks on November 15* The details of this issue are as follows: Total applied for - $1,221,697,000 Total accepted - 1,001,415,000 Average price (includes $74,198,000 entered on a fixedprice basis at 99.905 and accepted In full) - 99.905/ Equivalent rate of discount approx. 0 ,375% per annum Range of accepted competitive bids: High Low - 99.925 - 99.905 Equivalent rate of discount approx. 0.297* per annua * * * • •% 0.376* * * (82 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco $ $ TOTAL 18,3110,000 810,755,000 28 ,760,000 29,920,OCX) 25,441,000 13,250,000 145,951,000 20,498,000 U , 560,000 24,715,000 21,382,000 71.125.000 $1,221,697,000 16,864,000 627,346,000 24,692,000 28,643,000 24,820,000 12,944,000 128,725,000 18,738,000 10,800,000 23,833,000 19,887,000 64.123.000 11,001,415,000 Washington Press Service FOR RELEASE, WORKING NEWSPAPERS, Tuesday t November 16. 1943* 3 1 - O I The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts, of 91-day Treasury bills to be dated November 18, 1943,1 and to mature February 17, 1944, which were offered on November 12, were opened at the I Federal Reserve Banks on November 15. The details of this issue are as fellowss Total applied for - $1,221,697,000 Total accepted * 1,001,415,000 Average price (includes 174,198,000 entered on a fixedprice basis at 99.905 and accepted in fwll)| - 99.905/ Equivalent rate of discount approx. 0.375$ per annum Range of accepted competitive bides - 99.925 - 99.905 High Low Bqulvalent rate of discount approx. 0.297$ per annum * • » 0.376$ * * (82 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco $ $ 18,340,000 810.755.000 28,760,000 29,920,OCX) 25 ,441,000 13 ,250,000 145.951.000 20,498,000 11,560,000 24,715,OCX) 24,692,000 2 8 ,643,000 24 ,820,000 12.944.000 128,725,(XX) 18.738.000 10,800,000 23,833,000 71.125.000 19,887,000 64.123.OCX3 $1,221,697,000 11,001,415,000 21,382,000 TOTAL 16,864,000 627 ,346,000 3 TREASURE BETAfifjflBfft Washington Press No, FOR R E L E A S E , MOHN£N0 NEWSPAPERS, T u e s d a y , N o v e m b e r jL6t 1 9 4 3 > The S e cretary of the t e n d e r s for $ 1 , O O O ,000,000, Treasury bills F e b r u a r y IV, ope n e d at ^de the T r e a s u r y a n n o u n c e d l a s t thereabouts, to be d a t e d N o v e m b e r 1944, the or which were Federal details of offered Reserve Banks this 18, that of 91-day and to m a t u r e were o n N o v e m b e r 15, I s s u e a r e as price evening o n N o v e m b e r 12, follows: Total applied for * $1,221,697,000 Total a c c e p t e d 1,001,415,000 Average 1943, Service 39-53 (includes $74,198,000 entered on a fixedprice basis at 99.905 a n d a c c e p t e d i n full) M-t'fO#- jl E q u i v a l e n t r a t e o f d i s c o u n t approx, 0#375$ per annum - 99.925 Equivalent rate of discount approx, 0*291% per annum - 99,905 E q u i v a l e n t rate of disc o u n t approx, 0.376$ per annum High Low {82 p e r c e n t o f the a m o u n t b i d for at Federal Reserve District Total Applied Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St, L o u i s Minneapolis Kansas City Dallas San Francisco $ TOTAL the l o w p r i c e for 18,340,000 810.755.000 28.760.000 29.920.000 25.441.000 13.250.000 145.951.000 20.498.000 11.560.000 24.715.000 21.382.000 71.125.000 ,221,697,000 -oOo was accepted) Total Accepted $ 16,864,000 627.346.000 24.692.000 28.643.000 24.820.000 12.944.000 128.725.000 18.738.000 10,80q,000 25.833.000 19.887.000 64.123.000 $1,001,415,000 FOR IMMEDIATE RELEASE, .lew-ember 16* 1943. The Bureau of Customs announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1# 1943, provided for in the Inter-American Coffee Agreement , proclaimed "by the President on April 15, 1941, as follows: • * Country of Production ... - - ... - - --------- -.... -........... - - : : - ■ Authorized for entry for consumption As of (Date) t (Pounds) Qjiota Quantity (Pounds) % J ------ ------- ............. — ....... — - Signatory Countries: Brazil Colombia Costa Rica Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela 1,353,183,480 458,336,340 29,100,720 11,640,288 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 3,910,072 69,114,210 28,373,202 3*637,590 61,111,512 Nov, 6, 1943 H ff H N H U tt fl H tt tt tt 153,277,118 58,077,233 1,620,560 1,409,396 2,455,868 5,798,917 787,587 412,724 1,379,312 460*402 1,880*472 - tt 59,587 2,204,542 tl 1,993,028 Non-signatory Countries: 51,653,778 1/ Qjaotas as established by action of the Inter-American Coffee Board on March 11, 1943, -o0o> TREASURY PEP ARB'ENT ' Washington FOB IMMEDIATE RELEASE* Tuesday*.November 16,: .1943 Press Service No. 39-54 The Bureau of Custoir s announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the auotas for the 12 months commencing October 1, 1943, provided for in the Inter-American Coffee Agreement, proclaimed by the President on April 15, 1941, as follows: Country of Production f • ,* : * : Authorized for entry for consumut ion Quota Quantity : (Pounds) 3J :As of (Date): VPounds) Signatory Countries? 1,353,183,480 458,336,340 29,100,720 11,640,288 17,460,432 21,825,540 87,303,160 77,844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 Brazil Colombia Costa Rica Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela Non*-signatory Countries: 81 l ) ■ ■ |V- ill1 !j II > 51,653,778 Nov. 6, 1943 it it it « it it n it it it it it 153,277,118 58,077,233 1,620,560 1,409,396 2,455,868 5,798,917 787,587 412,724 1,379,312 460,402 1,880,472 59,587 2,204,542 it 1,993,028 ii ■' Quotas as established by action of the Inter-Anerican Coffee Board on March 11, 1943♦ 0O0- ;pV. IS l&woniltional surrender is a largeorder, and there sif I* a temptation to tattle for l i u as the possibility of pesos approaches. 1 hope you will remember that. V I hope you will ft pot your minds to doing etnethlsf about It, sad thus continue the patriotic record that some of you started back la those early days of Defense. it o k0 s 0 I bells and newspaper boys soiling extras* end tbs war tbs bard way, because they here no choice except to do it that way, or not at all* so oftsn im I m glad that you the use of over the in it* I lished a this is no job is going that tbs war got sore difficult osul Because we are go * 16 * war than I ago. I had m opportunity to U tennis the actual fighting and tim nature of o w enemy with many imeriean and British officers arid men* I m u given a pretty clear idea of the heroism required of our man whan they face fin tough, fanatic la&ie, and as a result I achieved a healthy respect far thus blood m i w e n t that goes into every foot of enemy ground wo take, dad I found no evidence anywhere along the line that we art near the and, un less the end should com through some freak of circumstance* I do not want to underesili sever, the effects that the terrible defeats in Russia, or the destruction of Germany, must have on the Iasi Home front* fantastic. That destruction must be In Italy I $ m what bombs can do# of Naples, lying in a mass of ruins. I itw the Fort I taw the Port of Palermo in Sicily battered so badly that om sizable ship lay high and dry on a wharf, blown completely out of the water. But General Patton assured m that Palermo w ® only three or four percent desire - <land ~5i percent destroyed, ,ve4 -atotffft destruction. Yes, it is conceivable that the Germans eanft take it. is possible that the same thing will happen that happened the last time, fa m y be awakened some morning by whistles and It IB I wondered wh&t the effect would be an Wm d^ive* long finding out. One of ® I m e not State Cbair^en called up and m M t •11# 1 ^uees the Third, ilar Loan la off tiie wai* *s oirei* end there fs m need to raise suaey.11 e called in the Advertising Council, ^^0*^*'**.« "}"\~wif* -Write us an advertieeapnt that will stop this in its tracks*" wfent to w o r k a g A s t advertisement, *■£ Tau a y re-amber it. It galas saan a Home Front Defeat?" "Will the Surrender of ItaLy Then, because of the smooth working arrangement between your people *ta£ ours, the ad started running, the nest day, in 970 newspapers throughout the latfos, «e followed this up by telling the people the bitter truth about our equlpaent lueses in ficily. We must hare had a soberly effect on a lot of people, because we didn't get any asore phone calls* and that particular surge of optimism soon faded away. 1 want to make one more observation. A year ago^ I^weat to England. What I saw there gave use a lot of inspiration, and a lot of confidence about the outcome of this war. to win. I came tack knowing in ay heart that we ware going The British had survived the Blits; the Russians had stopped the German advance| we had halted the Jap drive In the far last. Slowly and painfully the lilies were overtaking the snowy's lead. Obviously, it would take & long tiaa, but in the end we would win. 14 Mach of this change » # due to th« Jap attack at Pearl Rarbor* But even m i l s the laps were pulling their sneak attack, three out of every ten O r l e a n s still felt that It wm most important to stay out of the European war#. the striking reversal of public sentiment from narrow isolationism to a complete acceptance off International respondV bllity is a momnaest to public education# And am % of you who are bora in this room, by writing end financing advertising campaigns, ha! as much tt do with that education over a period of time as any other group of people# Since the early days, ?hen * i t of the work was done in spare time by patriotic volunteers you have taken the war as your professional assignment# operation# it is no longer a spare time You are putting your best brains on and converting JsikJ^ble portions of your appropriations to this war information job# This job which I want to repeat must be stepped up, not tapered off, as w# march toward Victory* \ Bourn of this increased war information effort can and should be channeled through, bond advertising# is a double-headed job* frnoting bonds, I feel, Half the job is raising money, but the other half is maintenance of interest in this war, and what It means to every American# We hit a high spot in this job, I believe, the day the Third War Loan opened, which also was the day Italy surrendered* m X3 • A tom month* later there « g another educational job to bo # W * B u i I f b u t o wore preventing our * hipping froa reaching its destination. It became necessary either to convoy our freighter* or limply to canalgn a good part of our aatoriol to Davy Jonas. An advertising campaign u s planned by you ad a ® to tall the public about the problem, and again you n n helped by many Influential editorial columns. of the advertisements. I reauber oae It u a headed "Okay, Mr. President, go ahead and clear the Atlantic.* what the President u s able to do in a fireside chat, pins ahat you were able to do, gained the support of a majority of American voters behind the idea of arsing and convoying our. •hips. Fifty-five percent of the people inched the decision, and only thirty-eight percent definitely opposed it. I few weeks before, fifty percent of the people had been definitely against it ana only forty-one percent were willing to see it done. Here again was a victory for the policy of letting the people know the facts. Public sentiment is such improved now. Today the Kation is not only solidly behind the war, but has gone on record ae wishing to take on a big share of the responsibility in helping keep the world peace through world organisation. <m > ||lt m lot long after that* advertising began to appear. It was bought arui pals far by patriotic Anaricaas who took upon thaw* 4j«* the responsibility of asking their friends s&c neighbor* of the situation* They m m written by atom of you awwe advertising mn, I think* who we hero tonight* Ton sere pioneers-then* Ton sere pioneering the biggest Jab ef public irifara&tian in history* And you sere pioneering too la giving advertising the dignity of social responsibility* Obviously so could not cantinas indefinitely to find aatipasted guns and odd bits of e%aip*at in private beads for the British to bay and use. steps. the tin* had cons to tabs drastic We knew far exawple that a few snaths later there w m l d be a cri*ls I® the British Bevy* that with the rising poser of the S e m s a levy* Britain would have too few ships to defend herself^letjalman keep the Invading Maxis in say kind of check* The pobli# had to bs aade aware of this situatlsa. H# aajority of newspapers went to work an the prablen editorially and you prepared an advertising ©asspalga that helped-achieve awaiting rasa its. That was only three souths after Dunkirk, but the Gallup box Scare began to look much different then it had before* Sixty percent of the American people stood solidly beck of the President in transferring over-aged destroyers to the British to help bolster their Savy* ginning to eee.j The people were be • § § w i more important, we found that this equipment could hs sold legally to the British without involving the American GoTerrassat ia as act of n r , Ihea I look hack over the last three or four year#, I think this seating stands out above all else ia ay mind, because the stakes ware so great* 1 as proud and happy to have had a haad ia arranging far thia materiel to go to England ia her darkest aoeent. I ahudder a little to think of our c&st- off equipment being throws iato battle against ths !asi*s s o d s m machinery of war, bat it was certainly better than nothing Britain «aa again armed, inefficient and meager though the armament may have been, and civilisation passed a crisis. But it was a mighty narrow squeak. It was hack in these days when we were struggling to the public see what stark dangers lay ahead that American advertising ®aa first came to the aid of their Govenamint. It seemed obvious, at least to as, that the American people wars not getting ths true significance of the sews reports. did not see the approaching danger. had to be done. They Something ®ore positive That something, it seemed to me, was s o ® good, factual, hard hitting advertising to help the people see and feel aduit we were up against. Si* British needed help* fomehow, by some means, we had to get them sea® rifles, end enough ether equipment to pre pare then for the invasion which seemed iaaiasnt — end which, if it had been imminent, almost certainly would have been successful. General Marshall, and a group frost the «ar and Raty Departments c a m several tines to *y offlee to discuss what night be dose. After twenty y e a n of peace, we had very little equipment of any sort to use in fighting a war. Bat we felt that if we dug deeply enough we could find sows obsolete aateriel, end perhaps sons equipment in private hands, that would help out. Before long we found quite a collection of usable materiel. For example, we found five hundred old 75 millimeter gusts, sad four hundred Thompson sub-machine guns left aver from the last war. The levy t u n e d up five thousand obsolete ,63-pound bombs and the A n y found 560 hundred pounders. S a w place, t o found 80 out of date torpedoes, and someone came up with five hundred 38 caliber revolvers which antedated even the first World War. To arm the foot soldiers sad the Bene Guard, we managed to dig up nearly a half million rifles. We might hams added to this several thousand more old Springfield 30-30*8, but there was no ammunition to be found anywhere in the world, and the gluts were no good without bullets. 9 inviting warj inviting war simply because we admitted its approach* But even then we had a good Idea of Hitler’s program Wo felt stir# ho intended to take Britain in the Spring of 1941, and then join forces with Japan and go to w k on us in t h ^ ^ U U Ind we could not be' sure that this program would not succeed* Today everyone everywhere agrees that we were scheduled on the aggressors’ program as much as Poland, Chechoslovakia, or Britain* But things were different then* Ivon Dunkirk, and the Fall of France, did not arouse the American people to a sense of the reality of the danger ahead* Here was the very moment when the light of civilisation in Europe came nearest to dying, perhaps forever* desperate* The British were their entire future, their whole defense depended upon getting materiel, and getting it quickly* Winston Churchill had made it clear that equipment losses at Dunkirk had been staggering* Britain needed everything — artillery, aawunition, aircraft, m i most of all rifles* Every able-bodied man in England had to be prepared to fight off invasion, but in all Britain there were no rifles for them* and not much of anything else, and you can’t stop Sasis with stocks and stones* A c t i o n a l m rvey m e © aftexmrd revealed that 90$ of the people In the country knew about the Bond Drive, and understood that sgfcm Bond pirch&ses were the mature m o t of participation* This mm an important contribution, for la previous Driver, too much of the public took the position that *?k©y don’t moan me**1. You see, therefore, eceasthiwg; of the job advertising has done* You jsey be interested to -know that sy experience with advertising la connection with this war started even before the War Loans* It started back in the days when those of ns who felt that an attack on the United States was inevitable, were trying to get the country ready to defend our shores against any aggressor. Oar biggest job was trying to make the people see that, as the President said, w© couldn’t simply climb Into bed and pull the covers over our heads* jn those days -*» about four years- ago ** Gallup polls pointed out that 92$ of all Democrats and 94$ of all mpublicaas were saying that we simply should not fight* let steps had to be taken to protect ourselves — steps that worried sob © Americans because they thought we were m by the far Advertising Council* Throughout the Drive* 1 m told* practically all of the 10*000 weeklies carried advertisements which war# pall for by on# or more local businesses* In.A ally and weekly news papers* business supported the campaign with m r t than eight mi' d#-h&Xf million dollars worth of space* On the radio j m A M a fsagmlfieeiit job# Thu Eatioiml Association of Broadcasters tells as 3*3Qd hours of radio time and 200*000 mnmnemmat^ (valued at l E *000*000} carried. Third lar Loan messages to the public* throughout the days and nights of the Drive* Through the Allocation flan and additionally contributed time* advertisers played a nost ■ Important part*' Tou gave m the -use of your beet radio audiences* At least $3*000*000 la msfasiae apace m s provided by advertisers tad the isagaaints themselves*^%0^eneral mgaainea* P f e w journals and 458 business and trad# g a m i n e s each contributed a full page* Advertisers and the Outdoor Industry provided by all odds the mmi m p m s ive outdoor showing of all tines* I i® told this had ft vain# of $1*700*000* This 3^sek campaign* provided by advertisers, would S « « cost a ecjanercial advertiser ^M>*O0Q*(X)0 — 10 million dollars a weiikI litisasl surrender ffeils her troops are planted within gunshot of Croat Britain? But because the basis promts#, through th#lr propaganda bureau, to fold up} sad because w e ’d like to get on with the peace, too many of us are gattiag eager to sidetrack the main job Parsanally# I think it is serious enough to call for some body to do something} sad I csathsre tonight because I think you advertisers aad advertising people who ar® already using your talents and facilities and genius to make the American people understand many ef the facts of war, can do still more. I asked your help once before. Representatives of your group came to Saafelagtaa a year ago and I told them, if I recall correctly, that we were faced with the biggest selling job in history with practically no precedent to go o n * J Through your advertising council, you secured the volunteer help of the ablest advertising people in the Halted States and the cooperation of advertisers and media, sad went to work. I think everyone knows what a splendid job has been done. During the Thirl ter Loan, advertisers sponsored 89,000 advertisements in the daily newspapers - s total of 61,573,588 lines, at a cost to themselves of sore than sis sad oae-half million dollars. Two-thirds of ths advertisements were prepared by the advertisers themselves, and one—third were prepared for - 5 I talked to General Doolittle about that in Tunis. In M s war room, lined with huge maps of the entire Allied battle front, he showed me how aircraft are dispatched almost on a moment *s notice to any fighting sector to take care of difficult enemy implficements or stubborn resistance^ Jtest two days fori I /6w^ta 04TVU4. % «■' j y TfH caught arrived in Tunis, Doolittle said I I in what might have been a serious trap had it not been for the medium bombers ^pin a . (IIX xZ mt^ . ^ called to the scene. b m i r d o r^cnll.11 ary w r l u Zfrit ^ v + o JU i ~t£ u s -L. n e u rr^ J-A ^ ^t^Jen^g kt-yti?0 — fc£+-tr#~y Tftnnfir iinp'i'nlf"* This was only one case that Doolittle pointed out where a temporary setback had been turned, through immediate air support, into a victory. But now the winter is here, and the weather is closing in. Jimmie Doolittle and /i^Marshal Tedder cannot send airplanes anywhere, at any time, on a moment1s notice, as they did this summer. Is there any promise of early peace about that? Or, can you find hope of fuick victory in the fact that the Allies have still not crossed that narrow ditch called the English Channel, for the simple reason that the other side is lined s o lid ly with sudden death? Can anyone really think it is going to be easy to bring Germany to her knees in uncon- - 4 - slow arid difficult process* When I broadcast from Algiers, I pointed out some of the difficulties of fighting oyer there* I had no idea,* 1 said, *oi the terrible terrain in this area oyer which we must fight the -Nazis* The area between Naples and Rome is mountainous and thick with trees and foliage* It is ideal for defensive action, because the Nazi forces can hide high in the mountains, and fire on our forces without being seen* And when they are driven fro® one mountain, they need only to retreat & few hundred yards to another and it is the same tiling' all over again** / o i n c e I left Dragoni, the Allied Armies have managed to get fifteen miles closer to Rome* Five bloody, hard-earned miles £ week, that«sAall* But it isn't the fault of our fight<£Sjerr ■£ JUs,A, ing MU.^They are tough and in the pink of condition. The / fact is that no army in the world could move any faster, ft— And that's the picture on the Italian front while we, back here, are congratulating ourselves on polishing off the war in a hurry* Rut even that's not the whole story* The weather is closing in over there. Our troops may be without air protection more of the time than they will have it, and they tell me that air protection is just about the most important single factor in modern invasion* ~ 3 this, gentlemen ~ next great war* they their next Fuehrer will win the So here they are these defeated prisoners — already planning another assault on civilisation* This is one reason why we must concentrate on fighting the war right up to the last bitter day. There is a good chance that letting down now can needlessly prolong the war for weeks and months* I was in Italy three weeks ago* Clark up to the front lines* I went with General Mark I drove in a j#§g through the mountains to a spot within a mile of the Iasi troops* through a small village — a village — I went or what had, a few days before, been called Dragon!* It m s still smouldering* American bulldozers were busy clearing debris out of the streets so that our supply trucks could get through.; and at one spot our jeep had to climb high over a pile of masonry and stones that the day before had been a public building* there was left of Dragon! — That was about all that huge pile of wreckage. It was the same in a half dozen other small towns that we passed through. That happens because the Nazis don’t like fighting in the open. They run from building to building, and lark Clark’s ]p '■ M Fifth /rmy or Jimmy Doolittle’s planes simply have to take the buildings down around them. It is, I can tell you, a mighty - 2 - But If the Iasi #ome^/ront should crack, that would he a wind-fall* In the meantime, we are only playing Hitlerfs game when we see peace just around the corner* I am convinced, by the m y , that the Has is have a pro prietary interest in this wave of optimism* The early signs of German collapse came frof^stories printed in Nazi controlled newspapers; then from travelers out of Germany, who reported their observations to neutral newspaper chiefly those with prollazi tendencies* Finally, Hitler himself managed to convey the impression in his most recent speech that life in Germany is hell* I cannot think that he and Mr* Goebbels would be so tender about keeping us posted of a coming crisis unless there is a rabbit in the hat somewhere* Those hail an early crack-up of the German nation have not talked to German prisoners, I can assure you of that* I had some first hand reports on the state of mind of prisoners when I was in Italy* They are mighty arrogant. They believe in Adolf Hitler, and say the Russian campaign is the fault of the German generals* them about Democracy* Fuehrer? They don’t understand when you talk to They say; That is chaos1" "What? A nation without a Then if you pursue the subject of their present leader, they may admit he is not perfection — tAtfUf he will >hftvo -4a- do until they ^ find another* And — get Gentlemen: I an glad to have this opportunity tonight to talk to the Kalian’s- leading advertising people, because 1 have confidence in Uia ability of advertising m n to bring ike facts of the war to the American public* And today, perhaps more than at any til since the war began, there is a vital job to be done on that front* The dangerous dream of a quick end to this war grows more serious ©very day* It is particularly pressing right now* On every h»"«* we see a surge of activity to prepare for post-war, sometimes at the expeuse of the vital job at hand, m r k e t has bean in 11 steady "pitiiirft s w The stock sine© word u r s t got around that the liable arc about to crack* The newspapers regularly report new signs of the coming collapse of Germany* In Washington the exodus to after-the-war jobs has started in earnest* ho one in Washington can give m any concrete evidence that Germany is tottering on the brink of capitulation ~ and I have sought out practically everyone who would have any reason to know* And I can tell you that on the Italian front the itaai troops are not near cracking* It is always possible, of course, that the people on the Kasi io vte A vm t will be uaalle to take the bad news from Russia / W ' '’ft ■ ■ $r the terrible destruction our bombs are raining upon them; TREASURY DEPARTMENT Washington FCE RELEASE AT 8 jOO EWT, Thursday. November 18. 19£3* Press Service ho. 7rf- (The following address by Secretary Morgenthau before the annual convention of the Association of National Advertisers at the Hotel Commodore, New York City, is scheduled for delivery at 8.00 P.M.. E.W.T.. Thursday. November 18. 1943. , 7.7 . - - U. J . and is for release at that time.) TREASURY DEPARTMENT Washington FOR RELEASE AT 8:00 P,M., EWT, Thursday, November 18/ 1943. Press Service No. 39-55 (The following address by Secretary Morgenthau before the annual convention of the Association of National Advertisers at the Hotel Commodore, New York City, is scheduled for delivery at 8:00, P.M., E.W.T., Thursday,^November 18, 1943, and is for release at that time.) Gentlemen: I am glad to have this opportunity tonight to taljc to the Nation's leading advertising people, because I have con fidence in the ability of advertising men to bring the facts of the war to the American public. And today, perhaps more than at any time since the war began, there is a vital job to be done on that front. The dangerous dream of a quick end to this war, grows more serious every day. It is particularly pressing right now. On every hand we see a surge of activity to prepare for postwar, sometimes at the*expense of the vital job at hand. The stock market has been in a steady decline ever since word first got around that the Nazis are about to crack. The newspapers regularly.report new signs of the coming collapse of Germany. In Washington the exodus to after-the-war jobs has started in earnests No one in Washington can give me any concrete evidence that Germany is tottering on the brink of capitulation — and I have sought out practically everyone who would have - 2 - any reason to know. And I canf|e,ll you that on the Italian front the Nazi troops are hot hefir cracking. It is always possible, of course, that the people of the Nazi home front will be unable to take the bad news from Russia or the terrible destruction our bombs are raining upon them. But if the Nazi home front should crack, that would be a wind-fall. In the meantime, we are only playing Hitlerfs game when we see peace just around the corner. I am convinced, by the way, that the Nazis have a pro prietary interest in this wave of optimism. The early signs of German collapse came from stories printed in Nazi controlled newspapers; then from travelers out of Germany, who reported their observations to neutral newspapers, chiefly those with pro-Nazi tendencies. Finally, Hitler himself managed to convey the impression in his most recent speech that life in Germany is hell. I cannot think that he and Mr. Goebbels would be so tender about keeping us posted of a coming crisis unless there is a rabbit in the hat somewhere. Those who hail an early crack-up of the German nation have not talked to German prisoners, I can assure you of that. I had some first hand reports on the state of mind of prisoners when I was in Italy. They are mighty arrogant. They believe in Adolf Hitler, and say the Russian campaign is the fault,of the German generals. They don't understand when you talk to them about Democracy. They say: "What? A nation without a Fuehrer? That is chaos.1" Then if you pursue the subject of their present leader, they may admit he is not perfection — but he will do very well until they find another. And — get this, gentlemen — they say their next Fuehrer will win the next great war. So here they are -- these defeated prisoners — already planning another assault on civilization. This is one reason why we must concentrate on fighting the war right up to the last bitter day; There is a good chance that letting down now can needlessly prolong the war for weeks and months. I was in Italy three weeks ago. I went with General Mark Clark up to the front lines. I drove in a jeep through the mountains to a spot within a mile of the Nazi troops. - 3 I went through a small village -- or what had, a few days before, been a village — called Dragoni. It was still smoul dering. American bulldozers were busy clearing debris out of the streets so that our supply trucks could get through; and at one spot our jeep had to climb high over a pile of masonry and stones that the day before had been a public building. That was about all there was left of Dragoni — that huge pile of wreckage. It was the same in a half dozen other small towns that we passe-d through. That happens because the Nazis don’t like fighting in the open. They run from building to building, and Mark Clark’s Fifth Army or Jimmie Doolittle’s planes simply have to take the buildings down around them. It is, I can tell you, a mighty slow and difficult process. When I broadcast from Algiers, I pointed out some of the difficulties of fighting over there. "I had no idea," I said, "of the terrible terrain in this area over which we must fight the Nazis. The area between Naples and Rome is mountainous and thick with trees and foliage. It is ideal for defensive action, because the Nazi forces can hide high in the mountains, and fire on our forces without being seen. And when they are driven from one mountain, they need only to retreat a few hundred yards to another and it is the same thing all over again." Since I left Dragoni, the Allied Armies have managed to get fifteen miles closer to Rome. Five bloody, hard-earned miles a week, that’s all. But it isn’t the fault of our fighting men. They’ve got what it takes to lick the. Nazis, man for man. They are tough and in the pink of condition. The fact is that no army in the world could move any faster. And that’s the picture on the Italian front while we, back here, are congratulating ourselves on polishing off the war in a hurry. But even that’s not the whole story. The weather is closing in over there. Our troops may be without air protection more of the time than they will have it, and they tell me that air protection is just about the most important single factor in modern invasion. I talked to General Doolittle about that in Tunis, in his war room, lined with huge maps of the entire Allied battle - 4 front, he showed me how aircraft are dispatched almost on a moment’s notice to any fighting sector to take care of difficult enemy implacements or stubborn resistance. Just two days before I arrived in Tunis, Doolittle said, some of the forces in Italy were caught in what might have been a serious trap had it not been for the medium bombers called to the scene. In an hour or two the bombers had done a job that would have been next to impossible without them and certainly would have meant heavy, bloody losses. This was only one case that Doolittle pointed out where a temporary setback had been turned, through immediate air support, into a victory. But now the winter is here, and the weather is closing in. Jimmie Doolittle and Air Marshal Tedder cannot send air planes anywhere, at any time, on a moment’s notice, as they did this summer. : Is there any promise of early peace about that? Or, can you find hope of quick victory in the fact that the Allies have still not crossed that narrow ditch called the English Channel, for the simple reason that the other side is lined solidly with sudden death? Can anyone really think it is going to be easy to bring Germany to her knees in uncon ditional surrender while her troops are planted within gunshot of Great Britain? But because the Nazis promise, through their propaganda bureau, to fold up; and because w e ’d like to get on with the peace, too many of us are getting eager to sidetrack the main job. Personally, I think it is serious enough to call for some body to do something; and I came here tonight because I think you advertisers and advertising people who are already using your talents and facilities and genius to make the American people understand many of the facts of war, can do still more. I asked your help once before. Representatives of your group came to Washington a year ago and I told them, if I recall correctly, that we were faced with the biggest selling job in history with practically no precedent to go on. - 5 Through your advertising council, you secured the vol unteer help of the ablest advertising people in the United States and the^cooperation of advertisers and media, and went to work. I think everyone knows what a splendid job has been done. During the Third War Loan, advertisers sponsored 89,000 advertisements in the daily newspapers - a total of 61,573,588 lines, at a cost to themselves of more than six and one-half million dollars. Two-thirds of the advertisements were pre pared by the advertisers themselves, and one-third were pre pared for us by the War Advertising Council. Throughout the Drive, I am told, practically all of the 10,000 weeklies carried advertisements which were paid for by one or more local businesses. In daily and weekly newspapers, business supported the campaign with more than eight and one-half million dollars worth of space. On the radio you did a magnificent job. The National Association of Broadcasters tells me 3,382 hours of radio time and 200,000 announcements (valued at $12,000,000) carried Third War Loan messages to the public, throughout the days and nights of the Drive. Through the Allocation Plan and addi tionally contributed time, advertisers played a most important part. You gave us the use of your best radio audiences. At least $3,000,000 in magazine space was provided by advertisers and the magazines themselves. Two hundred and fifty general magazines, 56 farm journals and 450 business and trade magazines each contributed a full page. Advertisers and the Outdoor Industry provided by all odds the most expansive outdoor showing of all time. I am told this had a value of $1,700,000. This 3-week campaign, provided by advertisers, would have cost a commercial advertiser $30,000,000 — 10 million dollars a week.1 A national survey made afterward revealed that 90$ of the people in the country knew about the Bond Drive, and .* ? - 6 understood that extra Bond purchases were the measurement of participation. This was an important contribution, for in previous Drives, too much of the public took the position that ™They don't mean me.” You see, therefore, something of the Job advertising has done. You may be interested to know that my experience with advertising in connection with this war started even before the War Loans. It started back in the days when those of us who felt that an attack on the United States was inevitable, were^ trying to get the country ready to defend our shores against any aggressor. Our biggest job was trying to make the^people see that, as the President said, we couldn't simply climb into bed and pull the covers over our heads. In those days — about four years ago — Gallup polls pointed out that 92$ of all Democrats ana 94$ of all Republicans were saying that we simply should not fight. Yet steps had to be taken to protect ourselves — steps that worried some Americans because they thought we were inviting war; inviting war simply because we admitted its approach. But even then we had a good idea of Hitler's pro gram. We felt sure he intended to take Britain in the spring of 1941, and then join forces with Japan and go to work on us in the fall. And we could not be sure that this program would not succeed. Today everyone everywhere agrees that we were scheduled on the aggressors1 program as much as Poland, Czechoslovakia, or Britain. But things were different then. Even Dunkirk, and the Fall of France, did not arouse the A m e r i c a n people to a sense of the reality of the danger ahead. Here was the very moment when the light of civilization in Europe came nearest to dying, perhaps forever. The British were desperate. Their entire future, their whole defense depended upon getting materiel, and getting it quickly. ~ 7 Winston Churchill had made it clear that equipment losses at Dunkirk had been staggering, Britain needed everything -artillery, ammunition, aircraft, and most of all rifles. Every able-bodied man in England had to be prepared to fight off invasion, but in all Britain there were no rifles for them, and not much of anything else, and you can't stop Nazis with sticks and stones. The British needed help. Somehow, by some means, we had to get them some rifles, and enough other equipment to pre pare them for the invasion which seemed imminent -- and which, if it had been imminent, almost certainly would have been successful. General Marshall, and a group from the War and Navy De partments came several times to my office to discuss what might be done. After twenty years of peace, we had very little equipment of any sort to use in fighting a war. But we felt that if we dug deeply enough we could find soma obsolete materiel, and perhaps some equipment in private hands, that would help out. Before long we found quite a collection of usable materiel. For example, we found five hundred old 75 millimeter guns, and four hundred Thompson sub-machine guns left over from the last war. The Navy turned up five thousand obsolete 30-pound bombs and the Army found 560 hundred pounders. Some place, we found 80 out-of-date torpedoes, and someone came up with five hundred 38 caliber revolvers which antedated even the first World War. To arm the foot soldiers and the Home Guard, we managed to dig up nearly a half million rifles. We might have added to this several thousand more old Springfield 3 0 - 3 0 % but there was no ammunition to be found anywhere in the world, and the guns were no good without bullets. What was more important, we found that this equipment could be sold legally to the British without involving the American Government in an act of war. When I look back over the last three or four years, I think this meeting stands out above all else in my mind,* because the stakes were so great. I am proud and happy to have had a hand in arranging for this materiel to go to England in her darkest moment. I shudder a little to think of our cast-off equipment being thrown into battle against the Nazifs modern machinery of war, but it was certainly better than nothing. Britain was again armed, inefficient and meager though the armament may have been, and civilization passed a crisis. But it was a mighty narrow squeak. It was back in these days when we were struggling to make the public see what stark dangers lay ahead that American advertising men first came to the aid of their Government. It seemed obvious, at least to me, that the American people were not getting the true significance of the news reports. #They did not. see the approaching danger. Something more positive had to be done. That something, it seemed to me, was some good, factual, hard hitting advertising to help the people see and feel what we were- up against. Not long after that, advertising began to appear. It was bought and paid for by patriotic Americans who took upon them selves the responsibility of making their friends and neighbors aware of the situation. They were written by some of you advertising men, I think, who are here tonight. You were pioneers then. You were pioneering the biggest job of public information in history. And you were pioneering too in giving advertising the dignity of social responsibility. Obviously we could not continue indefinitely to find anti quated guns and odd bits of equipment in private hands for the British to buy and use. The time had come to take drastic steps. We knew for example that a few months later there would be a crisis in the British Navy; that with the rising power of the German Navy, Britain would have too few ships^to defend herself, let alone keep the invading Nazis in any kind of check. The public had to be made aware of this situation. The majority of newspapers went- to work on the problem editorially and you-prepared an advertising campaign that helped achieve amazing results. That was only three, months after Dunkirk, but the Gallup box score began to look much different than it had before. Sixty percent of the American people stood solidly back of the President in transferring over-aged destroyers to the British to help bolster their Navy. The people were be ginning to s e e . xsfm. ai/tJ 1 ^ r:a sr SkWJ'- "bad' -9 A few months later there was another educational job to be done.. ^Nazi U-boats were preventing our shipping from .reaching its destination. It became necessary either to con voy our freighters or simply to consign a good part of our materiel to Davy Jones, An advertising campaign was planned by you ad men to tell the public about the problem, and again you^were helped by many influential editorial columns. I re member one of the advertisements. It was headed "Okay, Mr. President, go ahead and clear the Atlantic." _ What the President was able to do in a fireside chat, plus what you were able to do, gained the support of a maiority of American voters behind the idea of arming and convoying our S percent of the people backed the decision, and only thirty-eight percent definitely opposed it. A few weeks before, fifty percent of the people had been definitely against it and only forty-one percent were willing to see it done. Here again was a victory fop the policy of letting the people know the facts. b Public sentiment is much improved now. Today the Nation is not_only solidly behind the war, but has gone on record as wishing to take on a big share of the responsibility in helping keep the world peace through world organization. Much of this change was due to the Jap attack at Pearl Harbor. But even while the Japs were pulling their sneak attack, three out of every ten Americans still felt that it was most important to stay out of the European war. • i striking reversal of public sentiment from narrow ^®slationxsm to a complete acceptance of international respon sibility is a^monument to public education. And some of you wbo are here in this room, by writing and financing advertising had as much to do with that education over a period 01 time as any other group of people. Since the early days, when most of the work was done in spare time by patriotic volunteers, you have taken the war as your professional assignment. It is no longer a spare time operation. You are putting your best brains on and converting sizable portions of your appropriations to this war information job. This job which I want to repeat must be stepped up, not tapered off, as we march toward Victory. - 10 - Some of this increased war information effort can and should he channeled;through bond advertising. Promoting bonds, I feel, is a double-headed job. Half the job is raising money, but the other half is maintenance of interest in this war, and what it means to every American. We hit a high spot in this job, I believe, the day the Third War Loan opened, which also was the day Italy surrendered. I wondered what the effect would be on the drive. I was not long finding out. One of our State Chairmen called up and said: ,fWell, I guess the Third War Loan is off — the war’s over and there1s no need to raise money.” So we called in the Advertising Council. I asked them: "Write us an advertisement that will stop this in its tracks." They went to work and in a few hours produced what I think was a^great advertisement. You may remember it. It said: "Will the Surrender of Italy mean a Home Front Defeat?" Then, because of the smooth working arrangement between your people and ours, the ad started running, the next day, in 970 newspapers throughout the Nation. We followed this up by telling the people the bitter truth about our equipment losses in Sicily. We must have had a sobering effect on a lot of people, because we didn’t get any more phone calls, and that particular surge of optimism soon faded away. I want to make one more observation. A year ago I went to England. What I saw there gave me a lot of inspiration, and a lot of confidence about the out come of this war. I came back knowing in my heart that we were going to win. The British had survived the Blitz; the Russians had stopped the German advance; we had halted the Jap drive in the far East. Slowly and painfully the Allies were overtaking the enemy’s lead. Obviously, it would take a long time, but in the end we would win. When I returned from the front early this month, I still felt sure we would win but I felt far more grim about the war than I did a year ago. I had an opportunity to discuss the actual fighting and the nature of our enemy with many American and British officers and men. I was given a pretty clear idea of the heroism required of our men when they face the tough, fanatic Nazis, and as a result I achieved a healthy respect - 11 - for the blood and sweat that goes into every foot of enemy ground we take. And I found no evidence anywhere along the line that we are near the end, unless the:end should come through some freak of circumstance. I do not want to underestimate, however, the effects that the terrible defeats in Russia, or the destruction of Germany, must have on the Nazi home front* That destruction must be fantastic. in*Italy I saw what bombs can do. I saw the Port of Naples, lying in a mass of ruins. I saw the Port of Palermb in Sicily battered so badly that one sizable ship lay high and dry on a wharf, blown completely out of the water. But General Patton assured me that Palermo was only three or four percent destroyed. Hamburg has been seventy percent destroyed, the Germans themselves admit, and several other Nazi cities have received even more destruction. Yes, it is conceivable that the Germans canTt take it. It is possible that the same thing will happen that happened the last time. We may be awakened some morning by whistles and bells and newspaper boys selling extras. But is is also possible that we can waste a great deal of precious time thinking about that morning, and we can divert a great deal of our precious energy into making ready for it, and then find that it shows no signs of coming. And in the meantime, good American young men are losing their lives trying to end the war the hard way, because they have no choice except to do it that way, or not at all. I am glad that you and I have been partners so often in the use of advertising in connection with this war. I have gone over the whole story because I thought you would be in terested in it. I have liked working with you. I think you have established a remarkable record. I think the stature of advertising has improved immeasurably as a result of what you people, who have thrown aside all thought of political differences, have done. But this is no funeral oration. Your job is barely begun. And the job is going to get more difficult every week, and every month, that the war wears on. Because we are going - 12 - to get tired. Everybody is going to get tired. Yfe are going to want peace and relief from the restrictions that war puts on what we do, and what we eat, and what we have. Unconditional surrender is a large order, and there may be a temptation to settle for less as the possibility of peace approaches. I hope you will remember that. I hope you will pux your minds to doing something about it, and tnus continue the patriotic record that some of you started back in those early days of Defense. o 0 o V - 3 for such bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made, as ordinary gain or loss. Treasury Department Circular Ildf 418, as amended, and this notice, pre scribe the terms of the Treasury bills and govern the conditions of their issue. Copies of the circular may be obtained from any Federal Reserve Bank or Branch. |g' | ' 0f O IlfflJ Ifljfjf m m - 2 - Reserve Banks and Branches, following which public announcement will be made by the Secretary of the Treasury of the amount and price range of accepted bids. Those submitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final, Subject to these reservations, tenders for $100,000 or less from any one bidder at 99.905 entered on a fixed-price basis will/be accepted in full. Payment of accepted tenders at the prices offered must be made or completed at the Federal Reserve Bank in cash or other immediately available funds on November 26, 1943 The income derived from Treasury bills, whether interest or gain from the sale or other disposition of the bills, shall not have any exemption, as such, and loss from the sale or other disposition of Treasury bills shall not have any special treatment, as such, under Federal tax Acts now or hereafter enacted. The bills shall be subject to estate, inheritance, gift, or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority. For purposes of taxation the amount of discount at which Treasury bills are originally sold by the United States shall be considered to be interest. Under Sections 42 and 117 (a) (l) of the Internal Revenue Code, as amended by Section 115 of the Revenue Act of 1941, the amount of discount at which bills issued hereunder are sold shall not be considered to accrue until such bills shall be sold, redeemed or otherwise disposed of, and such bills are excluded from consideration' as capital assets. Accordingly, the owner of Treasury bills (other than life insurance companies) issued hereunder need include in his income tax return only the difference between the price paid mm TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Friday , November 19* 1943------ • The Secretary of the Treasury, by this public notice, invites tenders for $ 1,000,000>000 , or thereabouts^ of ^Q^day Treasury bills, to be issued on a discount basis under competitive and fixed^price bidding as hereinafter pro vided. The bills of this series will be dated November 26. 1943 * and will w mature Febp^i^^Y^Aj TRVi interest. when the face amount will be payable without They will be issued in bearer form only, and in denominations of $1,000, $ 5 ,0 0 0 , $ 1 0 ,0 0 0 , $ 1 0 0 ,0 0 0 , $ 5 0 0 ,0 0 0 , and $ 1 ,0 0 0 ,0 0 0 (maturity value). Tenders will be received at Federal Reserve Banks and Branches up to the closing hour, two o ’clock t>. m., Eastern War time, Monday. November 22. 1943___ • Tenders will not be received at the Treasury Department,' Washington. Each tender must be for an even multiple of $1,000, and the price offered must be expressed on the basis of 100, with not more than three decimals, e. g., 99*925* may not be used. Fractions It is urged that tenders be made on the printed forms and for warded in the special envelopes which will be supplied bjr Federal Reserve Banks or Branches on application therefor. Tenders will be received without deposit from incorporated banks and trust companies and from responsible and recognized dealers in investment securi ties . Tenders from others must be accompanied by payment tof 2 percent of the face amount of Treasury bills applied for, unless the tenders are accompanied by an express guaranty of payment by an incorporated bank or trust company. Immediately after the closing hour, tenders will be opened at the Federal TREASURY DEPARTMENT Washington POR RELEASE, MORNING NEWSPAPERS, Friday, November 19, 1943*_____ The Secretary of the Treasury, by this public notice, invites tenders for .$>1,GOO,000,000, or thereabouts, of 90-day Treasury bills, to be issued on a discount basis under compet itive and fixed-price bidding as hereinafter provided. The bills of this series will be dated November 26, 1943, and will mature February 24, 1944, when the face amount will be payable without interest. They will be issued in bearer form only, and in denominations of $1,000, $>5,000, $10,000, $100,000, $5 0 0 ,0 0 0 , and $1,000,000 (maturity value). Tenders will be received at Federal Reserve Banks and Branches up to the closing hour, two o’clock p, n f, Eastern War time, Monday, November 22, 1543. Tenders will not be received at the Treasury Department, Washington. Each tender must be for an even multiple of $1,000, and the price offered must be expressed on the basis of 100, with not more than three decimals e, g., 99.925. Fractions may not be used. It is urged that tenders be made on the printed forms and forwarded in the specia envelopes which will be supplied, by Federal Reserve Banks or Branches on application therefor, Tendei's vail be received without deposit from incorporated banks and trust companies and from responsible and recognized dealers in investment securities. Tenders from others must be accompanied by payment of 2 percent of the face amount of Treasury bills applied for, unless the tenders are accompanied by an express guaranty of payment by an incorporated bank or trust company. Immediately after the closing hour, tenders will be opened at the Federal Reserve Banks and Branches, following which pub lic announcement will be made by the Secretary of the Treasury of the amount and pxace range of accepted bids, Those sub mitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in anjr such respect shall be final. Sub ject to these reservations, tenders for 4?100,000 or less from any one bidder at 99.905 entered on a fixed-price basis will (Ojer) - 2 * be accepted in full. Payment of accepted tenders at the prices offered must be made or completed at. the Federal Reserve Bank in cash or other immediately available funds on November 26, 1943. The income derived from Sraa^ury bills,''Whether interest or gain from the sale or other disposition of the bills, shaj,l not have any exemption, &$ such* ehd lose from the sale or other dis position of Treasury bille ehall hot have any special treatment, as such, under Federal tot* Mte* IW* §f hereafter enacted. The bills shall be subject to inheritance, §fftt otliex ^ excise taxes, whether PedeSl State, but shall be exempt from all taxation now or hdre&fter imposed on the principal or inter est thereof by any or Of the possessions of the United States, -or -by at i f 'p m X authority. For purposes of taxation the amnto^t of at Which Treasury bills are originally sold by the United States shall be considered to be interest/ Under Sections 42 and 11? (a) W of the Internal Revenue Code, as amended by Section 115 of the Revenue Act of 1941, the amount of discount at which bills issued hereunder are sold shall not he considered to accfu.a until such bills shall be sold, redeemed or otherwise disposed of, and such bills are ex-* eluded from consideration as capital assets. Accordingly, the owner of Treasury bills, (other than life insurance companies > issued hereunder need include in his income tax return only the ♦difference between the price paid for such bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity .during the taxable year for which the return is made, as ordinary gain or loss • Treasury Department Circular Uo. 418, as amended, and this notice prescribe the terms of the Treasury bills and govern the conditions of their issue. Copies of the circular may be ob tained from any Federal Reserve Rank or Branch. **oCo** November 12, 19^3 Dear Mr* Lilienthal: I have just learned th^t the Tennessee Valley Authority is the first federal agency or department whose employees are regularly devoting o v e r 15 P er cent of their pay checks for the purchase of war bonds. 1 want, through you, to congratulate your entire organisation for this outstanding achievement. Last February, the President expressed a desire that Government employees lead the way in this essential part of our war program. Applying 15 P er cent every pay check to the purchase of war bonds is not only a sure method for the individual to accumlate financial reserves, but it also is a positive means whereby every citizen render an additional essential service to his country at home and abroad. I hope that this standard of investment in war bonds achieved by Tennessee Talley Authority employees will eoon be attained throughout the Federal service. 1 wish to commend you and your entire organisation of over 2^,000 employees for the whole-hearted support of this part of our national program to defeat tyranny abroad and to combat inflation at home. Sincerely, (Signed) H. Mergenthan, Jr. Secretary of the Treasury Honorable David Lilienthal, Chairman, Tennessee Valley Authority, Knoxville, Tennessee. SlB:FS:gr 11/12/^3 TREASURY DEPARTMENT Washington Secretary Morgenthau today commended the Tennessee Valley Authority on becoming the first Federal age~~~ — 1 department whose employees are regularly devoting o-vcr~ 15 percent of their pay checks to the purchase of War Bonds• The Secretary, in a letter to Chairman David E. Lilienthal, conveyed his congratulations to the more than 24,000 employees of the agency for ”this outstanding achievement.” MLast February, the President expressed a desire that Government employees lead the way in this essential part of our war program,” the Secretary1s letter said. ”Applying 15 percent of every pay check to the purchase of War Bonds is not only a sure method for the individual to accumulate financial reserves, but it also is a pos itive means whereby every citizen can render an addi tional essential service to his country at home and abroad. I hope that this standard of investment in War Bonds achieved by Tennessee Valley Authority employees will soon be attained throughout the Federal Service.” In closing the Secretary s a i d I wish to commend you and your entire organization of over 24,000 employees for the whole-hearted support of this part of our national program to defeat tyranny abroad and to combat inflation at home.” -oOo- TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE Thursday, November 18, 1943* Press Service No, 39-57 Secretary Morgenthau today commended the Tennessee Valley Authority on becoming the first Federal agency or department whose employees are regularly devoting more than 15 percent of their pay checks to the purchase of War Bonds. The Secretary, in a letter to Chairman David E. Lilienthal, conveyed his congratulations to the more than 24,000 employees of the agency for ’’this outstand ing achievement.” ’’Last February, the President expressed a desire that Government employees lead the way in this essential part of our war program,” the Secretary’s letter said. ’’Applying 15 percent of every pay check to the purchase of War Bonds is not only a sure method for the individual to accumulate financial reserves, but it also is a pos itive means whereby every citizen can render an addi tional essential service to his country at home and abroad. I hope that this standard of investment in War Bonds achieved by Tennessee Valley Authority employees will soon be attained throughout the Federal service,” In closing the Secretary said ”1 wish to commend you and your entire organization of over 24,000 employees for the whole-hearted support of this part of our national program to defeat tyranny abroad and to combat inflation at home,” oOo- - 41 - So oft In thoologio m r * th© diaputaats* X f c * Hull on In utter igAor&aoe Of *&©t fiffe. other mt&m* And prute about an olephant lot one of thes%o oetnl Xu slspllfylag ou^tex laws we need, like the nea of Indostan, to reoovcp our sight, '•'« need the sireele of ptstored vision so we cen see the whole elephant. 0O0 Is mighty plain,* quoth he 2 "♦Tis clear enough the elephant Is very like a tree!** The fifth who chanced to touch the ear Said: *E*en the blindest man Can tell what this resembles most) Deny the fact who can, This marvel of an elephant Is very like a fan!11 The sixth no sooner had begun About the beast to grope Than, seising on the swinging tail That fell within his scope, *1 see,” quoth he, "the elephant Is very like a rope!® And so these men of Indostan Disputed loud and long, Each in his own opinion Exceeding stiff and strong, Though each was partly in the right, And all were in the wrong! So oft in theologic The first approached the elephant lndy happening to fall Against his broad and sturdy side At once began to bawl5 *Gad bless met but the elephant Is very like a walll® The second feeling of the tusky Criedt *Bol what have we here So very round and smooth and sharp? To me H i s mighty clear This wonder of an elephant Is very like a spearI® The third approached the animal And happening to take The squirming trunk within his hands Thus boldly up and spakes *1 see** quoth he, *the elephant Is very like a snakel * The fourth reached out his eager hand, And felt about the kneex *¥«fhat most this wondrous beast is like Is mighty plain Conclusion “Simplify Our Tax Laws’* Las become & kind of slogan* t Slogans ape valuable instruments at times* enthusiasm needed to produce results* dangerous weapons. They engender the But they may also be Applied to tax law they are dangerous because they compress too much Into too few words * a fault* I hasten to add* which cannot always be fairly ascribed to lawyers* They end by meaning nothing, or perhaps whatever anyone wants them to mean. In meaning all things to all men they mean nothing to any man* There is profound significance in the tale of “The Blind Men and the Elephantj * It was six men of Indostan To learning much inclined Who went to see the elephant (Though all of them were blind). That each of observation Might satisfy his mind. The first approached 37 - the present tax the amount of tax paid by deficit corporations is relatively small - only about 11 percent of total collections at 1942 levels of income. Nor does this small amount of revenue come in an equitable fashion from deficit corporations. The taxes falling on such corporations bear no relation to equity, to capital, to total assets, to invested capital, to gross sales, to the size of the deficit, or to any reasonable measure of privilege or taxpaying ability. The impact of the tax is capricious* It depends upon the accuracy of a forecast made by the corporate directors at a time when prophecy is a perilous adventure. In all these circumstances there remains little excuse for encumbering corporate tax structure with this freakish tax r Conclusion "Simplify Our Tax Laws’* -36- under $5,000 paid capital stock and excess profits taxes equal to 6.5 percent of their aggregate net income while corporations with net incomes of $5 million and over paid taxes of only 1 percent of their net*incoiae* It is argued by some that this tax is a suitable method of taxing deficit corporations. 1 had thought that our purpose today should be in the other direction - to tax corporations with swollen war profits at high rates and to relieve corporations with deficits occasioned in large part by economic events beyond their control. It is true that the old capital stock tax of the Twenties fell to a considerable extent on deficit corporations because those corporations were obliged to pay taxes on the fair value of capital stock regardless of their expectations of income or deficit. the present tax Under upon this point leads to the very clear conclusion that small corporations are relatively harder hit by the tax than are larger corporations. This is because small corporations experience fluctuating earnings to much greater extent than do large corporations. For example, in 1937 corporations with total assets of less than $50,000 had an average declared value of 197 percent of their equity capital while corporations with 50 million dollars or more of total assets had an average declared value of less than 62 percent of equity capital. In 1937 the ratio of tax to normal tax net income was 2.7 percent for corporations with under $50,000 of total assets. The ratio for corporations with assets of $100,000,000 and over was 1.8 percent. In 1936 corporations with net income of under $5,000 paid based upon actual, and not declared, value.. abandoned because of valuation difficulties* The tax was The year 1933 saw the origin of the present type of capital stock tax, w p h totally disregards actual value and is based upon the value the corporation wishes to declare, with no regard for book, market value of assets, or earnings record* The function of & declaration is simply to take out insurance against the declared value excess profits tax; this tax penalises corporations which guess wrong in making their declaration* In actual practice corporations make their declaration of value entirely with the purpose of saving themselves from the heavier i pact of the declared value excess-profits tax. You may be interested in the relative impact of the tax upon large and small corporations. The Treasury’s research upon this point leads not the least of which Is that the same revenues c o u M he collected from substantially the same corporations by Increasing the corporate tax rate. These taxes are, therefore, nothing more than an unreasonable duplication in the corporate tax structure, requiring for compliance scarce manpower and trained personnel. The Treasury did not again in 1943 specifically recommend the elimination of the capital stock and declared value excess-profits taxes, but I would like to discuss the subject briefly with you because I believe the days of these taxes are numbered. I would also like to secure your cooperation in effecting their ultimate repeal. You all know the history of the capital stock tax. Beginning in 1917 and through 1926 we had a capital stock tax based upon actual, Corporate Tax So far I have been talking about simplification on behalf of individual taxpayers, I have limited my discussion of that subject to the return front. Much more remains to be said on other individual tax fronts, but I should like to say a few words before I close regarding one item of corporate, tax simplification. Capital Stock and the Declared-Value Excess Profits Tax In 1942 I attempted on behalf of the treasury to persuade Congress to eliminate the capital stock and the declared-value excess-profits taxes. I was unable to persuade the «aya and Means Committee, but was more successful with the Senate Finance Committee. The latter committee receded in conference, however, and we still have in the statute these utterly indefensible taxes. They are indefensible for many reasons, not the least of which • 31 - addition we raised the present requirement relating to outside income, other than salaries, from $100 to a somewhat higher figure* Additional Suggestions for Simplifying Returns I do not want you to think that I have attempted to cover even the limited subject of simplification on the return front* Many additional suggestions are in the mill which, I might add, grinds slowly. Gould we have different filing dates by classes of taxpayers, corporate and individual, or by divisions within one class of taxpayers on an alphabetical basis? How may return forms be set up to enable taxpayers to do their arithmetic more easily? These are merely examples of activity in the Treasury in Its constant effort to improve the administration of our tax laws and to make taxpayer compliance less burdensome than it now is* Corporate Tax Simplification So far I have been 30 Investigation of this proposal reveals further interesting data* At present the first $2,000 bracket oovers about ,000,000 taxpayers* The remaining 23 brackets cover less than 7,000,000 taxpayers* The lesson of these figures is that our rate structure lacks refinement for the great majority of taxpayers. However, the moment we try to provide better progression, we have to face the necessity for graduated withholding. \As I have said, this can be accomplished. ►product of graduated withholding — The which enables us to accomplish the desirable objective of refining the rate structure for the great majority of taxpayers is the elimination of many quarterly declarations for persons in receipt of salaries above the present first bracket of surtax. A greater number of declarations could be eliminated if in addition we raised Employer groups with whom withholding problems have been sp*>— v. discussed have indicated the desirability of graduated withholding from the standpoint of their relationships with employees* At the time for filing the first of the new quarterly declarations this past .September, several large employers reported that requests from employees for information as to total amounts of wage and of withholding over the year, as well as for assistance in the computations and the / preparation of the form, resulted in significant additional burdens for their tax and accounting staffs* the question arises whether graduated withholding would unduly complicate the preparation of payrolls. Careful study, as well as discussions with employer groups, indicates that little or no extra burden upon employers would result* Investigation of this I 28 | Treasury has recommended to the Committee that collection at the source be made to apply to the taxpayer’s full liability rather than merely to his partial liability under the normal tax and the first bracket of surtax. The method for accomplishing this result mould be to have a series of withholding rates applicable to gross wages, as a substitute for the present precise rates. This series of withholding rates would be expressed in tables based on the status of the taxpayer. There could also be tables calculating the amounts to be withheld, as at the present time*. Any objections to the inaeeuraoles resulting from the wide brackets in the present-law tables would be minimized by providing substantially narrower brackets over the ranges of \A".'"/■ ' '._v :v wage within which most employees fall. Employer groups with *27 - to claim refunds and those who have substantial additional taxes to pay would bo permitted or required to file. 1 third into pretation of "elimination" i» that taxpayers would be required to furnish only a minimum of information! their taxes would be computed for them by the government and refunds or additional assessments would be issued without further action I 11 / n on their part. These alternative solutions and others are being closely examined in the Treasury. graduated. Withholding Simplification is possible also in the domain of * withholding. One suggestion, originat#tf^rith Judge Vineon and recently made to the iaye and Means Committee, was that withholding would be on a gross basis under a system which would enable taxpaye rs to understand instantly what percentage 0f their salaries was being withheld at the source* The Treasury has recommended - 26 - returns play In educating citizens in their role as taxpayers and in stimulating a sense of direct participation in government should not be overlooked# In discussing the elimination of returns it is important to recognize that different people mean different things by the phrase, “elimination of returns11, Some mean that we should ' 7 go from an annual accounting period to a payroll accounting period, and that withholding should itself be the tax. Ikder this interpretation a broad class of taxpayers would be neither required nor permitted to file. The inequities of such a solution and the great difficulty of drawing a line between l filers and non-filers make its adoption highly questionable* Other people mean by "elimination of returns" that the annual ac counting period be retained, but that only those who wish to claim refunds and find the making of returns most difficult. It is also argued that paper work would he reduced and administration simplified* On the other hand, several important considerations militate against the elimination of returns* If returns are eliminated* administrative controls over taxpayers and employers will he weakened* The morale value of a tax return made under penalty of perjury will he lost* The possibility of a cross-check of employee returns against employer reports will he gone* It is well to remember also that taxpayer returns serve as the basis for adjusting the over—collections and under-collections which are inevitable in any withholding system. In oases of part-year unemployment* change of family status, and double employment, for example* these adjustments may be quite substantial* Then, too* the function which returns play in ■till ooaputa their tax both ways la order to he aure that they were paying the loweet peealhle tax. *• are worklag oa this problem la the Treasury and. hope to presmt definite recoacendatloM to the Congress in the aear future. Ellnlnatlne horns &aroh IS Returns So* that we hare collection at the eouree, you have heart amfli discussion of the possibility of ellaiaatlag March IS return* for persona entirely In the first surtax bracket, whose liabilities are collected at the source. This is another wetter _ I & under serious consideration in the Treasury. There are arguments on both aides of the question. On the one hand, it is osrtain that the slialnation of laroh IS returns would simplify taxpayer compliance and reduce taxpayer irritation. The persons relieved of filing retoms would be those in the lowest taxable bracket; these taxpayers are least familiar with tax procedures and find the waking w..ieh permits ths u m of form 1G4GI by taxpsysrs hating gross income of not mere than §3,000 consisting of salariss, dividends interest and asittitts#. boundary be raised, It has beet suggested that the 13,000 there are 6 million taxpayers having gross incow between S3,000 sat §5,000, of which 2 million taxpayers ■miil be eligible to use form 10401, if it were extended. It would be a convenience to t axpeyert with iacaaes above $3,00© to uat fora 10401. taxpayer convenience coincide# with administrative economy, since the estimated cost of handling the simpler fora is less than half tbs cost of handling ths longer Fora 1040. On ths other hand, ths extension 1 havt suggested would cost about SI? million In revenue, sad no doubt sany persons entitled to use ths simplified fora under the extension would still compute their - 22 ~ outlines of which can be explained by one neighbor to another. The minimum tax, and the table it requires, can be explained by one expert to another, but not by neighbors over the back fence. It seems clear that the collection of about $300,000,000 of tax from these particular individuals, less than 2 percent of our income tax collections from individuals, is not worth the complexity involved in this minimum tax. Moreover, to exact a tax from incomes at the subsistence level is a questionable contribution to the fight against inflation. The revenue will not be lost, since it can be distributed throughout the surtax brackets. Extending use of Form 1Q4Q& I now turn to a possible simplification — for the deductions tangle. a homely remedy You are familiar with Supplement T, which permits the use c»11b for a set of exemption* different from those applicable for purposes of the regular Income tax. This necessitates a table, giving a series of breaking points showing which tsx applies — the minimum tax or the regular Income tax. The treatment of Joint and separate returns presents further complications as to choice of return. There are several sones in which one of two forms of filing is more desirable, the limits of the sones varying with dependency status and division of income between husband and wife. Taxpayers will be forced to make alternative computations in order to ascertain whether to file form 1040k or Form 1040 and whether to file joint or separate returns. Simplicity is not to be found in mechanical forms which are not easily understood. It calls for a tax the baslo outlines of which • 80 • elimination of the Victory tax. The adoption of these proposals would have enormously simplified returns. Indeed, it is doubtful whether any adequate simplification can be It ' 1 £| ' h m‘ •• I - $ i|| i ■ r - - . >\ - • ~ : | <?'~&y v . lv , i ' i ■/ . achieved without the elimination of the Victory tax* ■ f i if -t • !- - | ' The Ways and Means Committee has adopted a minimum tax plan in lieu of the Victory tax. The minimum tax is three percent of regular statutory net income with exemptions of $500 for a single person, $700 for married persons without dependents, and $100 for each dependent* Married persons filing separate returns are entitled to a single person’s minimum tax exemption, and are required to t ake a single person’ regular tax exemption* This proposal also increases the normal tax to 10 percent. I shall not burden you with a long explanation of the defects of this substituted proposal. You will note that it calls for a set * 19 a separate concept of taxable income* set of exemptions# The tax has a different The dependency credit is recognised only ij in a oomplicatad poatwar eradit. The faulty structura of th# tax was racognised by Congress when it eliminated the postwar aspects of the credit for 1943. The lays and Means Committee jig has fallowed by integrating the tax with the regular income tax for 1944* In his statement of October 4 before the % y s and Means Committee, the Secretary of the Treasury proposed the elimination of the Victory tax and the lowering of the regular exemptions for married per sons without dependents from $1,200 to $1,100, and from $$60 for each dependent to $300. The Secretary also proposed raising the surtax and the elimination of the earned income credit to recapture some of the revenue lost by the elimination of the * 18 • Elimination of the Victory Tax In the 1942 Act the Senate Finance Committee inserted, and the conference committee accepted, the famous "Victory" tax. The object was to reach by a special tax incomes below the exemption levels of the 1942 Act $1^200 for a married person without dependents, $500 for a single person and $350 for each dependent* As a matter of fact, the Victory tax collected from persons in these low brackets only about iif $300,000,000 of revenue. The balance of the $3 billion yield of the tax came from persons already subject to the regular income tax. It is a matter of indifference to these higher bracket taxpayers whether a particular dollar of tax paid is labeled Victory or income tax. To you, I need not elaborate upon the complications of the Victory tax. Its special set of deductions results in a separate cone ept . __ tax-exempt bondholders the exact benefit they possess today and would limit extra computations to the few taxpayers who own tax exempt bonds* I am confident that such an amendment would be constitutional* Our rate for the first $2*000 of set income could then be 19 percent — 6 percent present normal tax plus IS percent* the first surtax bracket* could be 22 percent — For the second $2*000* the rate # percent plus 16 percent. This simplification can be extended throughout the rate structure. Treatment of Tax-Exempt Securities One precaution need be taken. About ^ 7 billion of partially tax-exempt securities are outstanding. We do not wish to enlarge the benefits of this exemption* nor do we wish to repudiate a contract of exemption. The status quo can be preserved by allowing* in lieu of the present credit against net income* a credit against the tax of 6 percent of partially tax exempt interest, or of net Income after the exemption* whichever is lower. This would give partially tax-exempt bondholders • 15 “ palliative remedy, the treasury has recommended the consolidation of the normal tax and the surtax* well aware of the defects of the present system* You are the earned income credit and the issuance prior to 1941 of partially exempt federal bonds are the only remaining excuses for two concepts of net income «*«• one for normal tax purposes and the other for surtax purposes* If we eliminate the earned Income credit, only one reason remains for submitting to the difficulty involved in expressing the rates of tax* This complicates returns, making necessary two statements ©f net income and two computations of separate tax liability which must be added together. The obvious solution is to integrate rates into one schedule and limit ourselves to one concept of net incoma. Our rate for the first V If this earned income credit were a true earned income credit, it might be worth the complication it involves* The extension of the credit to the first $3,000 of net income, irrespective of its character, thwarts the objective of favoring earned income* This presumption is required by administrative necessity; it would be impossible for the Bureau to check the type of income received by the millions of taxpayers in the lowest brackets* Since we cannot achieve a practicable discrimination in favor of earned income, we may as well avoid the complexities inherent in an unsuccessful attempt* The elimination of the credit will be a distinct step toward simplification* Consolidation of Normal Tax and Surtax Part of the trouble with tax calculation arises from the fact that we have so many different rates* As a partial and palliative remedy, the this level* I should like to discuss some of these changes with you in detail. We shall need your help. In the campaign for simplification you can help best if you understand what we are trying to do. The Earned Income Credit It the suggestion of the Treasury the House Ways and Means Committee voted the elimination of the earned income credit new in the statute. This credit, as you know, is 10 percent of earned net income or of net income, whichever is lower, up to $14,000. The first $3,000 of income, ■whatever its character ~~ even though it be dividends or bond interest - is presumed to be earned income. The credit is only for normal tax purposes, which means that its maximum value at the $14,000 level is $84. If this earned income Simplification at the Return Level la 1932 exemptions aad national income were at such a level that slightly less than 2 million returns were filed with the Bureau <tf Internal Revenue* For the year 1944 it is expected that more than 44 million returns will he received. This increase in the number of taxpayers intensifies the need fo r simplification. The income tax must permit of simple acts by taxpayers if full compliance is to be achieved. Most taxpayers are not concerned with what the statute or the regulations or the court decisions say. To the man in the street the income tax return and the instructions on that return are the whole story* It is logical then that simplification should commence at the return level. The Treasury has recommended a number of changes in our tax structure which will help to achieve simplification at this level. I should may be done quickly on the basis of sufficient knowledge at hand, and there are things which it would be unwise to attempt without a further clarification of issues and considerable additional investigation of law and facts. In this latter category fall changes in the "reorganisation" provisions and more satisfactory correlation of the income, estate and gift taxes. Jm 'j Mm Powers of appointment remain troublesome, but perhaps it is well to make haste slowly in this highly technical field of estate tax law. Trusts are a thorn in the flesh of the income, estate, and gift taxes. The Treasury is working upon these and many other problems, and has called upon the outside Tax Bar for suggestions and advice; a special committee is working upon estate and gift tax correlation. We hope to be able to deal intelligently with these problems when we get to the 1944 administrative revenue act. Simplification at the Return Levej In 1932 exemptions and be handled by the Bureau of Internal Revenue ia a vital matter, but it is even more vital that theae returns be aa simple aa poaalble. The difficulty with oomplieated return* does not end with their filing} they m a t be audited. Correspondence may be necessary • Interviews with taxpayer* and their representatives may be required. The number of direct oontaots with tire individual taxpayer, and the clerical work of keeping accounts with him wad hi* employer, are matters of intense concern to a Bureau of Internal Revenue which desires to afford evety aid possible to pus*1*4 taxpayers. Finally, there is the process of Judicial review.\ The simpler cur tax laws are made, the easier the whole process of administration and interpretation become*. Dual Batura of the Problem Simplification is a vast subject. There are things that may bs done quickly Basie polio/ conflicts are frequent in the statutej the essential pattern of objective is vague* Concepts have changed; the desire to prevent inflation is a novel tax motive* Taxation has new folkways* The future is & black imponderable. In all this whirl taxpayers glance with nostalgia toward the old certainties they once thought they had, and the present becomes more uncertain than ever. From the standpoint of the Treasury simplification has vstill another definition. We certainly recognise that the success of the income tax depends on achieving the utmost desirable simplicity. This is essential to taxpayer good-will, which in turn is essential to successful administration. But we have our own internal problems, which at the moment are greatly intensified by our inability to secure accounting machinery and hold personnel. The number of returns which must be handled by the Bureau a few lixies which can he filled in swiftly without digging deep into old papers. In short* it means a tax structure which the casual newspaper reader can understand with no more mental strain than it takes to follow Joe Palooka. Some taxpayers probably use the word "simplification the sense of certainty. in They are perplexed by our tax laws. They don't know how much they owe. The statute is filled with provisions which only the expert can understand, and he sometimes has a hard time. jy In fact, the expert's difficulty ffcm * parallels the situation in idiich Robert Browning found himself in "The Barretts of Wimpole Street." You remember that Elisabeth Barrett asked the poet the meaning of some of his lines. times he said? After Browning had read them aloud three "Elizabeth, when those lines were written, Ood and Robert Browning knew what they meant. Now God alone knows. Basic policy conflicts * 7 | The Meaning of Simplification Ihen any words become as popular as the words *tax simplification” have recently become, one may be very sure that the phrase means many different things to many different people. The words may mean so much that they mean little or nothing. Certainly the tern ”tax simplification” is a vague abstraction, and it is necessary to look behind it for the concrete meanings which it holds. I have tried to gather together from conversations, newspaper stories, and revenue hearings some of these diverse meanings. From the standpoint of individual taxpayers and the small business man simplification means a number of things. a minimization of tax arithmetic. unnecessary records. It means It means the elimination of It means the reduction of tax forms to a few lines which can be m ' I ' ' • 6 ♦ In the pay-as-you-go procedure we were putting a burden upon employers. In one sense we were asking them to become deputy collectors of internal revenue. It was only fair, f. therefore, to consider their convenience, as well as the |p convenience of employees. This meant that we had to reduce the classification of employees to a minimum in order that the accounting problems of employers would not be too Irksome. In other words, we had to withhold on an approximate basis, grouping particular employees according to the band method, le did not wish to require employers to make specific computations which would result in exact withholding. Nor did we want to permit too many changes In exemption status during the year. 4 choice had to be made between the relative convenience of employers and employees. •/jngg I • . ••****, || The Meaai&R of Simplification. --------U P S &hy vroras become 11 \ • - 5 - For example, It seemed very desirable when we were working on the 1942 Revenue Act to introduce collection at the source into our tax structure. You will remember that such a system was introduced at the beginning of 1943 to expedite the collection of the Victory tax. It was extended in the Current Tax Payment Act to cover the normal tax and the first bracket of surtax. In connection with collection at the source we found specific application of the maxim that one man’s meat is another man’s poison. It Is to the interest of employees that the amount of tax withheld at the source be matched as closely as possible with final tax liability. Government. Under-withholding may mean loss to the Over-withholding may mean inconvenience, and even hardship, to employees. But the question cannot be approached only from this one angle. In the pay-as-you-go - 4 What is simple may not be equitable* of necessity be complicated* What is equitable may In other words* simplicity and equity are often incompatible and we are forced to choose between them. In choosing we must weigh advantages gained against advantages lost, knowing what we are doing when we make an election. A sufficiently desirable objective, either by way of relief pr by way of preventing tax avoidance, may be worth some complication. A particular item of simplicity may not be worth the inequity it entails* The question is one of price, and our first choice should be the simplicities that are the best bargains* Then, too, there is something ad hogiinem about simplification. What is simple to one taxpayer may not be simple to another who plays a part in administering the tax. for example, it seemed very simply* But the relief provisions which that rate makes imperative must be extremely complicated* Still another contribution to complexity stems from oar manifold system of administrative and judicial interpretation# War taxation adds its own complications* You are all familiar with the paradox on the economic front that in wartime increased purchasing power means fewer purchasable goods* The same condition that produces plentitude of income also produces scarcity of goods. On the simplification front one finds another curious paradox* War taxation leads at the same time to a general demand for simplification and a maximum of specific requests for complicating amendments* Competing Considerations We have then a basic conflict* In tax law, as more generally, there are almost always competing considerations. What is simple may - 2 ~ Apparently I did not talk for thirty minutes when I was last In Chicago for I do not believe tbat I said everything there is to say about simplification* Perhaps you will allow me to begin now where I left off then* today we sometimes think that we are victims of a malady which never attacked anyone before* But complaints about the complexity of our tax laws are an old story* The patient has been suffering for a long time; the disease has become a national scourge| it has even crossed national boundary lines* Causes of Complexity The first thing we discover when we attempt to diagnose this complaint is that there is no single cause. did not become complicated overnight* Our tax system Some complexity originates in a commendable Congressional desire to prevent tax avoidance. Sometimes a commendable desire to give tax relief results in complication. A 90 percent excess profits tax can be written very simply. SIMPLIFYING OPR TAX LAWS I fti it i piculiif disidvi&tigi thii h littli more than a month ago here in Chicago* I addressed a group of business men# My subject was "Simplification of Our Tax Laws#" I am here today to discuss "Simplifying Our Tax Laws*" You see my dilemma* It reminds me of a story which is told of the eminent naturalist* Agassis. When he was to deliver his first visiting lecture in Zurich, he hau grave doubts about his ability to occupy the prescribed three-quarters of an hour* He was speaking without notes, and from time to time he glanced anxiously at the watch that lay before hi® on the desk. When he had spoken half an hour* he felt that he had told the audience everything he knew in the world. "From that point on", he said, "I began to repeat myself and I have done nothing else ever since." Apparently I did not ..1.1- M S' I TREASURY DEPARTMENT Washington (The following address by Randolph E. Paul, General Counsel of the Treasury, before the National Tax Association at the Palmer House, Chicago, is scheduled for delivery at 1:30 p. a.. Central War Time, Monday, November 22'. 1^43, and is Tor release at that time.) ■ i Hi: r f^o % I|1|IM I—IH ■'I'lef e i M * liirw|ll»l» m 'W W W *" 111 " 1* * y 1 ~X * ^ LX ' ^ 1 d *k ft T TREASURY DEPARTMENT Washington (The following address by Randolph E. Paul, General Counsel of the Treasury, before the National Tax Association at the Palmer House, Chicagoj is scheduled for delivery at 1:30 p. n u t Central Way Time, Monday, November 22, 1943* and is for release at that time*) SIMPLIFYING OUR TAX LAWS I, am at a peculiar disadvantage this afternoon. A little more than a month ago here in Chicago, I addressed a group of business men. My subject was nSimplification of Our Tax Laws.’L I am here today to discuss uSimplifying Our Tax Laws.51 You see m y dilemma. It reminds me of a story which is told of the eminent naturalist, Agassiz. When he was to deliver his first visiting lecture in Zurich, he had grave doubts about his ability to occupy the prescribed three-quarters of an hour. He was speaking without notes, and from time to time he glanced anxiously at the watch that lay before him on the desk. When he had spoken half an hour, he felt that he had told the audience everything he knew in the world. ”From that point on” , he said, ”1 began to repeat myself and I have done nothing else ever since*” Apparently I did not talk for thirty minutes when I was last in Chicago for I do not believe that I said everything there is to say about simplification* Perhaps you will allow me to begin now where I left off then. Today we sometimes think that we are victims of a malady which never attacked anyone before* But complaints about the complexity of our tax laws are an old story* The patient has been suffering for a long time; the dis ease has become a national scourge; it has even crossed national boundary lines. Causes of Complexity The first thing we discover when we attempt to diagnose this complaint is that there is no single cause* Our tax system did not become complicated overnight. Some complexity originates in a commendable Congressional desire to prevent tax avoidance. Sometimes a commendable desire to give tax relief results in complication# 90 percent excess profits tax can be written very simply. But the relief provisions which that rate makes imperative must be extremely complicated. Still another contribution to complexity stems from our manifold system of administrative and judicial interpretation. 39-38 ~2 War taxation adds its own complications. You are all familiar with the paradox on the economic front that in wartime increased purchasing power means fewer purchasable goods. The same condition that produces plentitude of income also produces scarcity of goods. , On the simplification front one finds another curious paradox.. War taxation..leads at the same time to a general .demand for simplification and.a maximum of specific re quests for complicating .amendments. . Competing Considerations W e have then a basic conflict. In tax law, as more generally, there are almost always competing considerations. What is simple may not be equitable. What is equitable may of necessity be complicated. In other words, simplicity and'equity are often incompatible and we are forced to choose between' them. In 'choosing we must weigh advantages gained against advantages lost,-knowing whap we are doing when we make an'election. A sufficiently desirable objective, 'either, by way of relief or by way of pre venting tax avoidance, may be worth some complication. A particular item of. simplicity may not be worth the, inequity it entails. The question is one of, price, and our first choice should be the simplicities that are.the best bargains. ■ . 'Then, too, there is something ad.hominem about simplification. What is simple to one taxpayer may not be simple to another who plays a part in administering the tax. For example, it seemed very desirable when we were working on the 194^ Revenue Act to introduce collection at the source into our tax structure. You will remember that such a system was introduced at the beginning of 1943 to expedite the collection of the Victory tax. It was extended in the Current Tax Payment Act to cover the normal tax and the iirst bracket of surtax. In connection with collection at the source we found specific application of the maxim that one m a n ’s meat is another m a n ’s poison, :. It is to the' interest of employees that the amount* of tax withheld at tne source. be .matched as closely as possible with final fax liability, Under-withholding may mean loss to the Government, Over—withholding may mean inconvenience, and even hardship, to employees. But the question cannot be approached only from this one -angle* .In the pay-as-you-go procedure we were putting a burden upon employers. In one sense we- were asking them to become .deputy collectors, of internal revenue. It was only fair, therefore, to consider their convenience, as well as^the^convenience of employees. This meant, that we had to reduce the classification of employees to a minimum in order that ..the accounting'prob lems of employers would not be too irksome, .. In other words > we had to with hold on an approximate basis,.grouping particular employees according to the band method. We did not wish to require employers.to make specific compu tations which would result in exact withholding. Nor did we want to permit too many changes in exemption status during the year. A choice had to be made between the relative convenience of employers and employees. «*•3- "** The Meaning of Simplification When any words become as popular as the words ’’tax simplification’* have recently become* one may be very sure that the phrase means many dif ferent tnings to many different people * The words may mean so much that they mean little or nothing* Certainly the tern **tax simplification’* is a vague abstraction, and it is necessary to look behind it for the concrete meanings which^it holds* I have tried to gather together from conversations, newspaper stories, and revenue hearings some of these diverse meanings* From tne standpoint of individual taxpayers and the small business man simplification means a number of things* It means a minimization of tax arithmetic* It means the elimination of unnecessary records. It means the reduction of tax forms to a few lines which can be filled in swiftly without digging deep into old papers* In short, it means a tax structure which the casual newspaper reader can understand with no more mental strain than it takes to follow Joe Palooka* Some taxpayers probably use the word «simplification” in the sense of certainty. They are perplexed by our tax laws* They don’t know how much ! they owe. The statute is filled with provisions which only the expert can understand, and he sometimes has a hard time. . In fact, the expert’s difIiculty n°¥/ and then parallels the situation in which Robert Browning found himself in ’’The Barretts of Wimpole Street.’’ Xou-remember that Elizabeth Barrett asked the poet the meaning of some of his lines. After Browning had read them aloud three times he saidt .^Elizabeth, when those alone G °d ^ Robei-t Bro™ i n g knew what they meant. Now God P°licy ° onflio'ts are frequent in the statute; the essential i^aSon f VaS? ? ’ C0ncepts ^ ohan8ed5 the desi« to prevent niisition is a novel tax motive. Taxation has new folkways. The future is to¥fardkthePoi1derab+ e^ +?* ^ moTunoertSn t h ^ l v ^ f this whi;rl taxP ay ^ s glance with nostalgia 3 ^ had> *"d ^ Wcome definite, the'Standpoint of the Treasury simplification has still another ? certainly recognize that the success of the income tax t 2 S v L L o r i l b f i T 5 t V < * e s i * a h i e Simplicity. This is essential to n, x y , ® which in turn is essential to successful administration t e n J f ^ r °ur y y rnal Probl« ^ which at the moment t e “ Syin! The number°nf°f + b 0 secure accounting machinery and hold personnel, is a vital m t t e r W h S+W ^ ° ^ mUSt b® handled b-/ the B’oreau of Internal Revenue as p o S i M e T h P d J ’m 1 i f 7 X m v s vital htat these re thcny with complicated returns does not end with view* £ t + w ’ they must be audited. Correspondence may be necessary. Intero / d i r e o f ^ ^ r 5 ^ ^ r®Presentatives may be required. The number k e e n i ™ = oontacts.™'yb the individual taxpayer, and the clerical work of to a B u r ^ r 011^ ? f3? and h13 are matters of intense concern to Intel,nal R e w m u 0 whi<* desires to afford .every aid possible puzzled taxpayers, Finally, there is the process of judicial review. -4 The simpler our tax laws are made,- the easier the whole process of admin-*istration and interpretation becomes* Dual Nature of -the Problem Simplification is a vast subject. There are things that may be done quickly on the basis of sufficient knowledge at hand, and there are things which it would be unwise to attempt:without a further clarification of issues and considerable additional investigation of law and facts. In this latter category fall changes in the ^reorganization11 provisions and more satisfactory correlation of the income, estate and gift taxes. Powers of appointment remain troublesome, ..but-..perhaps it is well to make haste slowly in this highly technical field of estate tax law. Trusts are a thorn in the flesh of the income, estate, and gift taxes. The Treasury is working upon these and many other problems, and has called upon the outside Tax Bar for suggestions and advices a-special committee is working upon estate and gift tax correlation, YTa hope to be able to. deal intelligently with these problems when we get to the 1944 administrative revenue act. Simplification at the Return Level In 1932 exemptions and national income Were at such a level that slightly less than 2 million returns were filed, with the Bureau of Internal Bevenue.- For the year 1944 it is expected that more than 44 million returns will be received. This increase in the number of taxpayers intensifies the need for simplification, The income tax must permit of simple acts by tax payers if full compliance is to be achieved. Most taxpayers are not con-* cerned with what the statute or the regulations or the court decisions say. To the man in the street the inpome tax return and the instructions on that return are the whole story. It is logical then that simplification should commence at the return level, The Treasury has recommended a number of changes in our tax structure which will help to achieve simplification at this level, I should like to discuss some of these changes with you in detail* We shall need your help. In the campaign for simplification you can help best if you understand what we are trying to dof The Barned Income Credit At the suggestion of the Treasury the House Ways and Means Committee •voted the elimination of the earned income credit now in the statute* This credit, as you know, is 10 percent of earned net income or of not income, whichever is lower, up to $14,000. The first $3,000 of income, whatever its character *— even though it be dividends or bond interest - is presumed to be earned income. The credit is only for normal tax purposes, which means that its maximum value at .the $14,000 level is $ 84, If this earned income credit wore a true earned income credit, it might be worth the complication it involves. The extension of the credit to the first $3,000 of net income, irrespective of its character, thwarts •t - 5 - the objective of favoring earned income* This presumption is required by administrative necessity; it would be impossible for the Bureau to check the t;ype of income' received by the millions of taxpayers in the lowest brackets. Since we cannot achieve a practicable discrimination in favor of earned income, we may as well avoid the complexities inherent in an un successful attempt. The elimination of the credit will be a distinct step toward simplification. Consolidation of Normal Tax and Surtax Part of the trouble with tax calculation arises from the fact that we have so many different rates. As a partial and.palliative remedy, the Treasury has recommended the consolidation of the normal tax and the surtax. You are well aware of the defects of the present system, The earned income credit and the issuance prior to 1941 of partially exempt federal bonds are the only remaining excuses for two concepts of net income — * one for normal tax purposes and the other for surtax purposesf If we eliminate the earned income credit, only one reason remains for submitting to the difficulty involved in expressing the rates of tax. This complicates returns, making necessary two statements of net income and.two computations of separate tax liability which must be added together. The obvious solution is to integrate rates into one schedule and limit ourselves to one concept of net income. Our rate for the first $2,000 of net income could then be 1 9 -percent — * 6 percent present normal tax plus 13 percent, the first surtax bracket. For the second $2,000, the rate could be 22 percent — r 6 percent plus 16 percent. This simplification can be extended throughout, the rate structure. Treatment' of Tax-Exempt Securities One precaution need be taken. About $7 billion of partially taxexempt securities are outstanding. W e do not wish to enlarge the benefits of this exemption, nor do we wish to repudiate a contract of exemption. The status quo can be preserved by allovdng, in lieu of the present credit against net income, a credit against the tax of 6 percent of partially tax exempt interest, or, of net income after the exemption^ whichever is lower. This would give partially tax-exempt bondholders the exact benefit, they possess today and would limit extra computations to the few taxpayers who own tax exempt bonds, I am confident that such an amendment would be con stitutional, • .. . - Elimination of the Victory Tax In the 194^ Act the Senate Finance Committee inserted, and the con ference committee accepted, the famous ^Victory” tax. The object was to reach by a special tax incomes below the exemption levels of the 1942 Act — $1,200 for a married person without dependents, $500 for a single person and $350 for each dependent* As a matter of fact, the Victory tax collected from persons in these low brackets only about $300,000,000 of revenue# 1 — 6— The balance of the $3 billion yield of the tax caup from persons already subject to the regular income tax. It is a matter of indifference to these higher bracket taxpayers whether a particular dollar of tax paid is labeled Victory or income tax* * To you, I need not elaborate upon the complications of the Victory tax* Its special set of deductions results in a separate‘concept of taxable income, The tax has a different set of exemptions* The dependency credit is recognized only in a complicated postwar credit* The faulty structure of the tax was recognized by Congress when it eliminated the postwar aspects of the credit for 1943. .The Ways and Means Committee has followed by inte*? grating the tax with the regular income tax for 1944* In his statement of.October 4 before the Ways and Means Committee, the Secretary of the Treasury proposed the elimination"of the Victory tax and the lowering of the regular exemptions for married persons without dee pen dents from $1,200 to $lj100, and from $350 for each dependent to $300* The Secretary also proposed raising the surtax and the elimination of the .earned income credit to recapture some of the revenue lost by the elim ination of the Victory tax. The adoption of these proposals.would have, enormously simplified returns* Indeed* it is doubtful whether any adequate •simplification can be achieved without the elimination of the Victory tax* The Ways and Me’ans Committee has adopted a minimum tax plan in lieu of the Victory tax*. The minimum tax is three percent of .regular statutory net income with exemptions of $500 for a single person, $700 for married persons without dependents, and $100 for each dependent* Married persons filing separate returns are entitled to a single person1s minimum tax exemption, and are required to take a single person's regular tax exemption* This proposal also increases the normal tax to 10 percent* I shall not burden you with a long] explanation .of the defects of this substituted proposal. You will note that it calls for a set of exemptions different from those applicable for purposes of the regular income tax. This necessitates a table, giving a series of breaking points showing which .tax applies — the minimum tax or the regular income tax,* The treatment of joint and separate returns presents further complications as to choice of return* . There are several zones in which one of two forms of filing is more desirable, the limits of the zones varying with dependency status and division of income between husband and wife. Taxpayers will be forced to make alternative computations in order to ascertain whether to file Form 1040A or Form 1040 and whether to file joint or separate retui’ns* Simplicity is not to be found in mechanical forms which are not easily understood. It calls for a tax the basic outlines of which can be explained by one neighbor to another. The ininimuxa tax, and the table it requires, can be explained by one expert to another, but not by neighbors over thq back fence. It seems clear that the collection of about $300,000,000 of tax from thqse particular individuals, less than 2 percent of our income tax col lections from individuals, is not worth the complexity involved in this minimum tax* Moreover, to exact a tax from incomes at the subsistence level is a questionable contribution to the fight against inflation. The revenue will not be lost, since it can be distributed throughout the surtax brackets Ex-bending Use of Form I04QA I now turn to a possible simplification — - a homely remedy for the deductions tangle. You are familiar with SupplementT, which permits the use of Form 1040A’by taxpayers having gross income of not ipore than $3,000 consisting of salaries, dividends, interest and annuities, it has been suggested that the $3*.000 boundary be. raised. There are' 5 million taxpayers having gross income between $3,000 'and $5>000, of which 2 million taxpayers would be eligible to use Form 104QA, if it were extended. It would be a convenience to taxpayers with incomes above $3,000 to use Form 1040A. Tax payer convenience coincides with administrative economy, since the estimated cost of handling the simpler form is less than half the cost of handling the longer Form 1040. v J m* On the other hand, the extension 1 have suggested would cost about $17 million in revenue, and no doubt many persons entitled to use the simplified form under the extension would still compute their tax both ways in order to be sure that they were paying the lowest possible tax. We are working on this problem in the Treasury and hope to present definite recommendations to the Congress in the near future. Eliminating Some March 1$ Returns Now that we. have collection at the source, you have heard much dis cussion of the possibility of eliminating March 15 returns for persons entirely in the first’ surtax bracket, whose liabilities are collected at the source. This is another matter under serious consideration in the Treasury. There are arguments on both sides of the question. On the one hand,’ it is certain that the elimination of March 15 returns would simplify taxpayer compliance and reduce taxpayer irritation. The persons relieved of filing returns would be those in the lowest taxable bracketj these taxpayers are least familiar with, tax procedures and find the making of returns most dif ficult. 'It is also argued that paper work would be reduced and adminis tration simplified. On the other hand, several important considerations militate .against the elimination of returns* If returns are eliminated, administrative con trols over taxpayers and employers will be weakened. The morale value of & t a x return made under penalty of perjury will be lost.. The possibility of a cross-check of employee returns against employer report's will be gone. It is well to remember also that taxpayer returns serve as the basis for adjusting the over-collections and under-collections which are inevitable in any withholding system. In cases of part-year unemployment, change of family status, and double employment, for example, these adjustments may • e quitesubstantial. Then, too, the function Which returns play in edu cating citizens in their role as taxpayers and in stimulating a sense of direct participation in government should not be overlooked. discussing the elimination•of retufns.it is important to recognize that' different people mean different things by the. phrase, '‘elimination d returns'’, Some mean that we should go from an annual accounting period - 8 - to a payroll accounting period, and that withholding should itself be the tax# Under this interpretation a broad class of taxpayers would be neither required nor permitted to file# The inequities of such.a solution and the great difficulty of drawing a line between filers and non-filers make its adoption highly questionable. Other people mean by “elimination of returns" that the annual accounting period be retained, but that only those.who wish to claim refunds and those who have substantial additional taxes to pay would be permitted or required to file# A third interpretation of “ elim ination" is that taxpayers would be required to furnish only a minimum of information; their taxes would be computed for them by the government and refunds or additional assessments would be issued without further action on their part. These alternative solutions- and others are being closely examined in the Treasury. Graduated Withholding Simplification is possible also in the domain of withholding# One. suggestion,.originating with Judge Vinson and recently made to the Ways and Means Committee, was that withholding would be on a gross basis under a system which would enable taxpayers to understand instantly what percentage of their salaries was being withheld at the source. The Treasury has recommended to the Committee that collection at the source be made to apply to the taxpayer's full liability rather than merely to his partial liability under the normal tax and the first bracket ,of surtax. The method for accomplishing this result would be to have a series of.^withholding rates applicable to gross wages, as a substitute for the present precise fates. This series of with holding rates would, .be expressed in tables based, on the status o f ,the tax payer. There could also be tables calculating the amounts to be withheld, as a£ the present time. Any objections to the inaccuracies resulting from the wide brackets in the present-law tables would be minimized by providing substantially narrower brackets over the ranges of wage within which most employees fall. Employer groups with whom vtithholding problems have been discussed have indicated the desirability of graduated withholding from the standpoint of their relationships with employees., At the time for filing the first of the new quarterly declarations this past September, several large employers reported that requests from employees for information as to total amounts of wage and of withholding over the year, as well as for assistance in the computations and tii6 preparation of the form, resulted in significant addi tional burdens for,their tax and accounting staffs. The question arises whether graduated withholding would unduly complicate the preparation of payrolls. Careful study, as well as discussions with employer groups, indicates that little or no extra burden upon employers would result# Investigation of this proposal reveals further interesting data. At present the first $2,000 bracket covers about 33,000,000 taxpayers# The remaining 23 brackets cover less than 7,000,000 taxpayers. The lesson of these figures is that our rate structure lacks refinement for the great majority of taxpayers. However, the moment we try to provide better pro gression, we have to face the necessity for graduated withholding. - 9 - As I have said, this can be accompli shed. The by-product of graduated with-* holding — which enables us to accomplish the desirable objective of refining the rate structure for the great majority of taxpayers. — is the. elimination of many quarterly declarations for persons in receipt of salaries above the present first bracket of surtax. A greater number of declarations could be/, eliminated if in addition we raised the present requirement relating to out side income, other than salaries* from $100 to a somewhat higher' figure, ■ Additional forSimplifying Returns v I do not want you to think that 1 hare attempted. -to cover even the limited subject of simplification m tb© return front. Many additional suggestions, are in the mill which,, 1 might aid, grinds slowly. Could w© ’ have different- filing' dates by c r a n e s of taxpayers, corporate and individual, or by divisions within oh© class of taxpayers on an alphabetical basis?. How ■: may return forms be set up to enable taxpayers to do their arithmetic more easily?...These are merely examples of activity in the Treasury in its constant effort to-improve the administration of our .'tax laws and to make taxpayer . compliance less burdensome than it now is* C orporate Tax Simplification So far I have been talking about simplification,on behalf -of indi vidual taxpayers, I have limited m y discussion of that subject to the return front. Much more remains' to. be said on other individual tax fronts, but I should like to say a f e w words before X close regarding one item of cor porate tax simplification. Capital Stock and the Declared-Value Excess Profits- Tax. ^In 1942 I attempted op behalf-of the Treasury to persuade Congress .to eliminate the capital stock and the declared-value excess-profits taxes, X was unable to persuade the Ways and Means Cordmittee, but was more suc cessful with the Senate finance Committee. .The -latter committee receded in, conference, however, and we. still have in the statute these utterly indefen sible taxes. They are indefensible for many reasons, not the least of which is that the same, revenues could be collected from substantially the same corporations by increasing the corporate tax rate. These taxes are, there fore, nothing more than an unreasonable duplication in the corporate tax .. structure, requiring for compliance scarce manpower and trained personnel* ^The Treasury did not again in 1943 specifically recommend ination of the capital stock and declared value bxcess-profits I would like to discuss the subject briefly with you .because I days of these ...taxes are numbered* , 1 would also like to .secure eration in effecting their ‘ultimate repeal* the elim taxes,.but believe the your coop You all know the history of .the capital stock tax. Beginning in 1917 and through 1926 we had a capital stock tax based upon actual, and not declared, value. The tax was abandoned because of valuation difficulties. The year 1933 saw the origin of the present type of capital stock tax, which , - 10 totally disregards actual value and is based upon the value the corporation wishes to declare, with no regard for book, market value of assets, or earnings record. The function of a declaration is simply to take out InV surance against the declared value excess profits tax; this tax penalizes corporations which guess wrong in making their declaration. In actual practice corporations make their declaration of value entirely with the purpose of saving themselves from the heavier impact of the declared value excess-profits tax. You may be interested in the relative impact of the tax upon large and small corporations. The Treasury’s research upon this point leads to the very clear conclusion that small corporations are relatively harder hit by the tax than are larger corporations. This is because small corporations experience fluctuating earnings to much greater extent than do large cor porations . For example, in 1937 corporations with total assets of less than $50,000 had an average declared value of 197 percent' of their equity capital while corporations with 50 million dollars or more of total assets had an average declared value of less than 62 percent of equity capital. In 1937 the ratio of tax to normal tax net income was 2*7 percent for corporations with under $50,000 of total assets* The ratio for corporations with assets of $100,000,000 and over was 1.8 percent. In 1936 corporations with net income of under $5,000 paid capital stock and excess profits taxes equal to 6.5 percent of their aggregate net income while corporations with net incomes of $5 million and over paid taxes of only 1 percent of their net income* It is argued by some that this tax is a suitable method of taxing deficit corporations. I had thought that our purpose today should be in the other direction to tax corporations with swollen war profits at high rates and to relieve corporations with deficits occasioned in large part by economic events beyond their control. It is true that the old capital stock tax of the Twenties fell to a considerable extent on deficit corporations because those corporations were obliged to pay taxes on the fair value of capital stock regardless of their expectations of income or deficit* Under the present tax the amount of tax paid by deficit corporations is rela tively small - only about 11 percent of total collections at 1942 levels of income* Nor does this small amount of revenue come in an equitable fashion from deficit corporations. The taxes falling on such corporations bear no relation to equity, to capital, total assets, to invested capital, to gross sales, to the size of the deficit, or to any reasonable measure of privilege or taxpaying ability* The impact of the tax is capricious* It depends upon the accuracy of a forecast made by the corporate directors at a time when prophecy is a perilous adventure* In all these circumstances there remains little excuse for encumbering corporate tax structure with this freakish tax* Conclusion “Simplify Our Tax laws’1 has become a kind of slogan*. Slogans are valuable instruments at times* They engender the enthusiasm needed to produce results* But they may also be dangerous weapons* Applied to tax law they are dangerous because they compress too much into too few Tjords — a fault, I hasten to add, which cannot always be fairly ascribed to lawyer They end by meaning nothing, oh* perhaps-whatever anyone wants them to mean In meaning all things to all men they mean nothing to any man* There is profound significance in the tale of “The Blind Men and the Elephant:” It was six men of Indostan To learning much inclined Who went to see the' elephant (Though all of them were blind). That each of observation Might satisfy •his mind* The first' approached the elephant And,-happening:to fall Against his broad and sturdy side At once began to bawd: “God bless meJ but the elephant Is- very like a wall The second feeling of the tusk^ Cried:.“Hoi what have we here ,• So very round and smooth and shprp? To me *tis mighty clear This wonder of an elephant Is very like a spearl“ The third approached the animal And happening to take The squirming trunk within his hands Thus boldly up and spake: “I see,“ quoth he, “the elephant 'Is very like a snakei" The fourth reached out his eager hand, And felt about the knee: “What most this wondrous beast is like Is mighty plain,” quoth he: “ ’Tis clear enough the elephant Is very like a treelu The fifth who chanced to touch the ear Said: “S*en the blindest man Can tell what this resembles most; Deny the fact who can, Tliis marvel of an elephant Is very like a fanl” - 12 - The sixth no sooner had begun About the beast to grope Than, seizing on the swinging tail That fell within his scope, nI see,?1 quoth he, l,the elephant Is very like a rope!11 And so these men of Indostan Disputed loud and long, Each in his own opinion Exceeding stiff and strong, Though each was partly in the right, And all were in the wrong! So oft in ideologic wars Tlie disputants, I ween, Rail on in utter ignoranceOf what each other mean, And prate about an elephant Not one of them has seen! ' In simplifying our tax laws we need, like the men of Indostan, to recover our sight* We need the miracle of restored vision so hare can see the whole elephant* 0O0 !» 11 TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Monday, November 22, 1943» Press Service 9 -S f Secretary of the Treasury Morgenthau today announced an offering, through the Federal Reserve Banks, of ?/8 percent Treasury Certificates of Indebtedness of Series G-1944, open on an exchange basis, par for par, to holders of Treasury Certificates of Indebtedness of Series $-1943, maturing December 1, 1943* Cash subscriptions will not be received. The certificates now offered will be dated December 1, 1943 , and will bear interest from that date at the rate of seven-eighths of one percent per annum, payable semiannually on June 1 and December 1, 1944* They will mature December 1, 1944* They will be issued in bearer form only, with two interest coupons attached, in denominations of $1,000, $5,000, $10,000, |100,000 and $1,000,000. Pursuant to the provisions of the Public Debt Act of 1941, interest upon the certificates now offered shall not have any exemption, as such, under Federal tax Acts now or hereafter enacted. The full provisions relating to taxability are set forth in the official circular released today. Subscriptions will be received at the Federal Reserve Banks and Branches and at the Treasury Department, Washington, and should be ac companied by a like face amount of the maturing certificates. Subject to the usual reservations, all subscriptions will be allotted in full. There are now outstanding $3,799,736,(XX) of the Series $-1943 cer tificates. The text of the official circular follows: TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Monday, November 22, 194-3*____ Press Service 39-59 Secretary of the Treasury Morgenthau today announced an offering, through the Federal Reserve Banks, of 7/8 percent Treasury Certificates of Indebtedness of Series G-1944* open on an exchange basis, par for par, to holders of Treasury Certificates of Indebtedness of Series E-1943* maturing December 1, 194.3* Cash subscriptions will not be received. The certificates now offered will be dated December 1, 194-3* and will bear interest from that date at the rate of seven^eighths of one percent per annum, payable semiannually on June 1 and December 1, 1944* They will mature December 1, 194-4* They will be issued in bearer form only, with two interest coupons attached, in denominations of $1,000, $5,000, $10,000, $100,000 and $1,000,000. Pursuant to the provisions of the Public Debt Act of 1941* interest upon the certificates now offered shall not have any exemption, as such, under Federal tax Acts now or hereafter enacted, The full provisions relating to taxability are set forth in the official circular released today. Subscriptions will be received at the Federal Reserve Banks and Branches and at the Treasury Department, Washington, and should be accompanied by a like face amount of the maturing certificates. Subject to the usual reservations, all subscriptions will be allotted in full. There are now outstanding $3*799*736,000 of the Series E-rl943 certificates. The text of the official circular follows: UNITED STATES OF AMERICA 7/8 PERCENT TREASURY CERTIFICATES OF INDEBTEDNESS OF SERIES G-1944 Dated and bearing interest from December 1, 1943 1943 Department Circular No. 727 Due December 1, 1944 TREASURY DEPARTMENT, Office of the Secretary, Washington, November 22, 1943* Fiscal Service Bureau of the Public Debt 1, The Secretary of the Treasury, pursuant to the authority of the Second Liberty Bond Act, as amended, invites subscriptions, at par, from the people of the United States for certificates of indebtedness of the United States, designated 7/8 percent Treasury Certificates of Indebtedness of Series G-1944, in exchange for Treasury Certificates of Indebtedness of Series E-1943, maturing December 1, 1943* from that date at the rate of 7/8 percent per annum, payable semiannually on June 1 and December 1, 1944* They will mature December 1, 1944, and will not be subject to call for redemption prior to maturity, 2, The income derived from the certificates shall bo subject to all Federal exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority. 3, The certificates will be acceptable to secure deposits of public moneys, T„ey will not be acceptable in payment of taxes. 4» Bearor certificates with interest coupons attached will be i s s u e d d e n o m — not ke issued in registered form. now or hereafter prescribed, governing United States certificates 2 - III. 1. - SUBSCRIPTION AND ALLOT* SNT Subscriptions will bo roceived at tho Federal Reserve Banks and Branches and at the Treasury Department, Washington. Banking institutions generally may sub mit subscriptions for account of customers, but only the Federal Reserve Banks and the Treasury Department are authorized to act as official agencies. Others than banking institutions will not be permitted to enter subscriptions except for their own account. 2, The Secretary of the. Treasury reserves the right to reject any subscrip tion, in whole or in part, to allot less than the amount of certificates applied for, and to close the books as to any or all subscriptions at any time without notice; and any action he may takf in thebe respects shall be final. these reservations, all subscriptions Will b© allotted in full. Subject to Allotment notices will be sent out promptly upon allotment* IV. 1. PATlSllT Payment at par for certificates allotted hereunder must be made on or be fore December 1, 1943* or on later allotment, and may be made only in Treasury Certificates of Indebtedness of Series E-1943, maturing December 1, 1943, which will be accepted at par, and should accompany the subscription. V. 1. GENERAL PROVISIONS As fiscal agents of the United States, Federal Reserve Banks are authorized and requested to receive subscriptions, to make allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the Federal Reserve Bc.nks of the respective districts, to issue allotment notices, to receive payment for certificates allotted, to make delivery of certificates on full-paid subscriptions allotted, and they may issue interim receipts pending delivery of the definitive certificates. 2. The Secretary of the Treasury may at any time, or from time to time, pre scribe supplemental or amendatory rules and regulations governing the offering, which Will be communicated promptly to the Federal Reserve ’Brinks. HENRY MORGENTHAU, JR., Secretery of the Treasury. ▼» tom m hm * M ta f«f* Mfe iff tiW*K S&* <Mroito*e* *ai& tiMi tfttanO. Wto&* *§» WMflt f tar 4 CS«mfc«p. P*#0* 3C0* iStm nm tills A irn m m im of th * gift tox po**i01tiit*s rslesssd tar * vo**£t*r m f fepf«3? ipit# ggrl* to son** of *•» *•*% Oofs tart m otb& r oft«0 ottast* M so of tO* Italian 0# woffc out loglo* lertlvoly a o&Ooroat %m& p H ^ s » m m i l «o ife# l m ® m i#*» In osar si to to* ostoto .gift to* m * ottyjioA to I0® &seao*rts o f Mr* Arties Oof&oso oaoo os#«?oo4* *tos ooooopt * tfosofoi1* lift* fOOS*& * fMMTi®M of piiafSiX Oovolopooxit* #it it*** %m *oajrt* Osar* tat*& t & f & M t w ith to# Ooroolooa took o f oioofloo * potto ottOort too m m m m » of wO*t i*y tas^osd. $o**14orlsg to* o i f f loottio* l£*olv*&, ttosgr too** itataft rmmxkMtol? M **H» If m Altoeoxrt oofl^ ovorsisa to to* **t*t* too* @oMotafcto41jr* hosoirsf, itoo i t s # O s*' f l a o l l y orrlvod for t, m rnptm m m l*# rm g p **lm \ of imf trim*for *oxt«spt* is, to* ilgtet of sof rich, If ttriMtartitc* m x m flm m mm r**rlooted %m o ta l* * !!* * # . tmm fc»M Ills! * vwwmlmrnxp i*%*r*m% &*pet&m% mpo» $&• $*&$* &m*h «# flit- ^rmior** wtiasttt i*#ao iiaroirtog i* too jrimol# to Ini f s M * t&# mpp*Xl*%* oporto* &wt*mx# m n m to t o ssoso fMtte is tlw* to* Coast* • $m% #*#*« Coatsoi Itoovo* Btftfc $ fs»*t Co* f, Cw«n UC f« CM) S ft % IfM )* ** ** * of U # m b- tokU**m% nay *m **& **1*1? m %fcw» cmSif*« lit* *m$w*mw» %&** i» 1* TUmm** f f.f* aei, its# m m % m *»«#**•& & r ! # $ t» *•**!» * « U i « d ■pmtf&m t>f Starts* Jm t Uf#tl»# kjemI tfe# i w s t t * ? mm m tm x im llp m m m M L* if ilia m%%r* « & p * In tassoi* t&rnm i» Hi# siditi#ise& ^ 7 ttetStor s r*i***a #f H*» rmmmlmm? tm***m% at *;Utst &&%« wcmld Us asiijtti t» gift tm * a *MMF #f fistic*. flit tax, m H m initial tr»**af«r *fc«ri4 m tiim * #* Pii»ft»t«ft* S9S lit# £6 <1934)» gf* jMMr «r us Mss* u* ass Ip* »«• Mat* ( i M i « Xai* 2**f* US** i m « M ®m>* mo (» m)i «f* Mss* ** swt* itNrt tn»t 6*., 13» I. (a*) «i« t«JSUk la*. IMS). Z7 0 Cf. *rl*f far SaapMIttMi. g» 9, KoM»»tl« V. E»It «!»Ie*. 31* 184 V.»./<U«3). t M Cam. v. fenfeU. iSS V. 13*) M»* W8(C.e.*. 3*, IMS). 7 V - M M *. K*l»«d S M m , H B.J. (1938). Of. w t w ot 6m$mt Mfe *.T. as?, S48» S W . (3*) IH, SSI U*37). SttilBa* ****&# T* Yvwik, 13* *. 1**} XOOf? (8»C«ls if* rauilM ftdMoaa, I f . f , MS 13*8) U943). &# tea ft* fisif, f t*c. ax# m fiMiljjCfts# mwm# e&*.3*X«» 4# i M i § A S#»* H* at®. M i l s # U)»l a 4#»»* In m% U*fel* m trmmfmwm hmmm %im »lii «t M # m&%Ssssftt !**&*•«%* i« ti# 1fhm i ^ i s M l l * t*wr Y*l**tieft« Aeslslsa i* eil«& is ssg^srl «f fix# Is H a g M # v* «#&*% 104 f* C M ) 144, X4§ ( M l S | if&* 1 ^ 0 ) , M M s f * m s % r f sfeaslA m o M y N ? s s M a l Jtsslffc fm%®m la Is M s ®m$mm%wmim mmmML ft Hi# «K$*4iili4f if* ^ ^ 1 pvsstis* Is I# tbs sssinjyr Css# i « # MspsaSgr <1#®?> *41* f#i# | ; l * | 4 ? Isis !*• J. m tw m m & p* m *Ss*f # f th* Is# M U v f e n f *« $X&£lft«t U H f* C M ) ti$§f Xii® Mi l f W » hk rtm #£ Itossa Vvssf is* 4* M M M ftetss, M l 0#l# U X { X S M | , m m im ®£%m list' 4s%« #£ ftfi s M & f »«i4 sttse* Mft vMMifeNI «• #£ iweft 4 *sfs* fc&s«4 sis $&# i4t.#us4tt ## ti$* jssg$«xitr tafiss* M m is# f ^ r ^ s r Hsisis «f 1 f«i* M S UMtt* »♦!. iii, m am* wt (mutt# £*«a* u @ 4 , i » i t m ft* M m «*. mm u$ms> * fax# m « If Is Slfftp< t* ssttaftt* M s #£ of fMfs* M Is M s pm m m t ▼«T&yXs*t M S I?*S* 939 19 -umifeis m dsflelsssgr v&xm Is *sjpflt**n**r M m tm im ssssssiMf 4#S;tlf4i M s ta»p#^#r*# Sm ibam t» s#f*biii& M s sswrsst mmm% #f ftsau fhm t l p t f i t t a M of tto ralaotioa footer i* t o l w a h®*« V IH# aaoeafortatlo foot that llin ttur&aa of ralaatioa to plaeod upoa tto tax apoa taxpoyor* who aaot M r o gift tho *»tifo ▼olu* if tto aotaarial ort to mot oaffloifttMr *atu*o to doai with Jftff tto oeaploaitioo of fcio i r n p i i » O f tsiwxoo* tta gift to* ero< ttould prorid* oaao eoaool&tloa. %*itt m **> whieh M i / t ooo extraao to M « t l U « to tto a m r a a t i r o tto ipootloa h o t t e r a r o y « r * l o i u ^ ^ t » r » « t dofwmdoat wpoa to® of «AO of too pftVMMM > to doduOtitla I t * ttO to* ^*MM> A t too ottor to tto m t i a * % i * ooeioioa* including tto «*tiro oorpua whor® tt* m m w m » €m pm d» upon tt® grantor1* tirtt of ohlidroa* iueut tt* ohltdroa** reaching aajoritf* # £ ® u l d tt* M looted® &te oatlr® carpa® if tto co»tiag«m<gr ooro aeialy anrrloge or tt® tirtt of i*#a«t Court b m t e to aaottor context tt* o t U I K to o r a l m t o tit# f*«*ihilttjr of ro~ a*rriogo#“ l a t it dooo mot folio* that tt would to prepared to laport tt* *a*o aottod of appraioal into tt« gift to* statute J At oar rat#. It would hardly roouiro * v o t t o t U * of tto rorartor Involved in th® licLoa* oooo* whor® tto grantor*# reaotulsltlon of tt® property hlagod upon tto oarlior death of hi# opouoo and d o c t o r , oad tto i*tt®r«# failure to loav® Im m tto property of tor ranching tto ago of twon ty-f iro ^ t® appoint aittation noeoosarliy ejlLfefor & go®#*# tat it **a#t at toast to ®a “educated m m d W deriving fraa raoooftably eoariaoiag data. *** A t tto present ttao it io aot j l r a r chore education «»d« end guessing. par# aad slaplo# hogiffir $®r®»tt Circuit too refused to allow §*sy deduetioa for tto reverter where it depended Of. Boris Bond Sitymii, 41 $*$*&* «»$ B&*isd Bold ihfti a ooyoy $&& to axtaod Hit i m t fcoaaflts I# efclldroa from thoroafto r wm p « i M taft tfea* t&o gift m i laaoaplat** ty $mfov& i a t t tfc* Japroa# Court ha* iid lo a ia i. In «asa#«tioii» tfeat t e eoattagoaoy «f n a a r r U it 1# m% wmtmtlm ef control stun# tiic ao&saat of naolher party is roomirod* » Irot&orliood ? . Hals* tea* «.s. m* ioo cim>* la oltfeor i » | tfeo property should sufeject I# •elate tax Bat c f , drethortaed a* i*laiee%o«*# f i t l « i * f § (1 9 $ * } { 6 o w . it### stre e t tru st Ce.» 1 M t« ($ d ) i l * (C .C .A . I I I , 1942)» y tfca ftai^ sad tfoMaatta dsoisiaas i t s w apaa at laaat I w tell# f»r®fcla*i»s. Fha firat iasalires tha dat*f»twtti©» o f ofcaihar ecynoalc ©oalroX haa $aai?ad sat «f Ht@ gfaator*.and th# aaeoad rsvslsaa shamt tfea vaJLastlatt faelor* la sa far a# iha first la aeaearaed, It la aot slwara a slagda aattor to eoaeimfta that tha donor h m m 'lim mlafcad aaosoals ecmtral* a*jr prsrlda far a Far «s*»?}ia, tfca 4 e » f af tha trust prime tpal t© bin If hs aatrlaa or has ebll&vaa* | Is it ©orrset ta tell la omah a saaa that eoatrol hi s baati raliaaulshad* rahjact te a prsftalaa far Its rat||p If a apaeiflad eoatiagaiier ©aamra# or is It m tm to aoaelmda that sostral la still ratalaad feseausa tha ©airarrw&ea of ih# ecMitla«M«r dasaada, to aa in&sflaafrla axtsat, w pm tha doaor M a s e l f t RaallatlaaXI/ apaatedag* af aaarsa# m » h m a difficult dagrta aaaatlaa hor© and it is aaaally difficult to prapsrtr ©mild la sul praha&i<y !• taaad j & tafta ©a tha ground that tha aotmarial art la not pr*j>ar©d to sop# with «ooh tlagsa&laa > V u sob- triaga ms to tha saeoad important lass* fallat©* ia| la tha waha of tha liilth sad hafrlftei&a eaa« ' Ibi vslJlu# of %hm v ororoloaoJy a s I iaWw#t orftinnriir doollao* •nor tfeo Anto of Initial. t»sasf#ir ant tho dift^tox render of tfeo ror»«ii«Mfc*y. lntotooi * | J L . on *&» #**" xoducod onion* probate « U U involved* to o « m ton b m e m m m of tHo U M o r t o i n t U * lot of* noiorhof v* Mlgglno, 129 I. tiJHI Ik w m * W>2 . IT m m ia t e low If1 li tm %U * t e t e t Vkmm m goof. a M i l a* the Hcdlaak dooioioa wsayr A* rwiata s w o t o t e o i g r iatoroolo^wro iiaxlmo la tat rIA of t e a * fhm e x t e t of t e e®«% in gift lax* t e o t e * wm not oloor. *te te ins »i#t to eoaftetjfc te mtn**f te revorotoaiury tateoot / At t e ao*to of wtmnAos £ rnmm t e t e t e jaropanr •» t e I T A o A t e l t e original t e a o f o r ana not ooxptoio w l U roioa** of tei- n v a u XA M w txtoreot* te tba tailor oiloraoiiro I t e fr«*a i*r* fmotioo I t e r i o * pooitioiu la o t e of t e Saitk *&& Koto loot to deotoiOftii t e gift t o woult to lnp©»«4 oaly ti$oa t e r * t e of tei m s n t r t e a r o U a t j u t e o d or t m i f i m d , Aloe# o t e r proporly ialoroolo eowpooiag t e truol *to t e j o o l to , T T t 1 t e nl t e Solo- of t e initial troaofor** ® a t * U « & to » ' ' ' £ 3 }* ft# gift tax root ooeopo froa t e t e t e t e of t e Ij&ytflll t e l o t e «n aoy t e a to oxooodiagto mm&X jf ^ m m * Qp** &p*n w* wm> ittt, u * i« 4, i*y»«9 mm* H & H*t* HI 183* Of. Geo&wiA f. N $ « w * a * 4f f# & * p p » fSH |1M)# iai#r«.*t «f iii# grs»i«* M m r * t o » x * % i m r X p m m A i»4* y * * * * l& & Hui ii* tr®n»f«r woi a * * * m * i * » * ®tAJ««i©4 in gifl iHE« Mm Wmtrm* Qevr#lm%im of ®ttt and &»**%• tun* (1944) 66 Harr* %-* Swr# l. Xf* daathar ^Jaattai* apoarantly m&m b y Hr* » N » U m by m im m m to tha 0* r a m r o d to jmv apiataa* li tins! %hm baoaflaiaria* * 0/ tar* in aatiafaetiaa of thalr aaeoadary liability, daaplta th# faet that tha^ nay b* daprlrad of thalr baaefita uadar tan tra&afar* l|J tim aaaa tafartaaata aaa~ tim & m *? b***ta * U truat# aoatatalac a coaplax of rwrtad l»t*ra«ta •van though %h& graator ha* railoaulabad nil •atrlaga* H w t w » raaote* Hr* d a a U a a M a r t a a ^ a m r ^ r aaisaodaa* though* that auah » tr&aafar would b# a taaaahl# M r at bm t raiult would abaolra from tax^fca t«tr typo of § rsaafar iataadad ta ha ra*eh«& fcy CoiMpraaa* ^ f h a unhappy paaaibliltiaa feraaaaa hr tha dastlaa ftMM to ha aaually taaigatfiaaat whara tha grantor baa » *oatlogout raYaraftaanry iatoraat* ®hiaf M U « * Stan# had axnggaratad e4»lnlatr*J|*a difficult!#* and paaaibla iaa^uitiaa la tha e a » a A * » d tha Oourt ooaduotad an ardarly ratraat fra® tha su^aaoisary and i*at©iij&.hi,.a paaltloaa aansuplad la that oaaa* n# ist* Ssepyre* #»$«, t&s ©ssffmtutios rs^utrsft ss&»r i m I& m i W & 'p yi M #»tfilgr* a** p p # l i i out of tho ptoportr sss Harrison ▼* Soi^ww tru st fts** <&t 4S1 (1942) • .Hit sourts *r« »s* ,|S y4 ii<»|g aov ^ r 4 m t of solusties* Bopoolt it ttm it Go. of **itl*toro, W *« ^ hssltss* i#« X o i w r i m i w* loft «*** «• < * * » > * & » » * f, Stats Sirs#* trust 6o«* 128 t* (M) lift (0*48*1. i»*# 1143); Ooaitsl Hsaovor ftssft ft trust fts* r* Cows.# lift t* (M) ftfO (C.C.A. 3ft# m i l * Mr* t o t t o to v o t o t t o t o # not p ^ w i ^ M a i t o t o t «i l » i ! » * f « » t o 0 1 « ot»4»«tio» to tox* «n a * tm m m difficult!** yauil otooaftly M K f m % mtotto too t o •stto t o u T t o toft w f i i t i a g ft forototoftfr i a l m i i *aul* prtotoiy to ntftjM* to «||% ^tax if t o lt#P)¥j a * r i « tofloftoi** g | doototo **« *, « * *« *• « * » « « » t o t o * 1**** %»ftlljr ***$&•* f r u o t m t o d t o t o i a i f t t o i t o of t o « * w s t t o of t o foooito* io t o f * — m% upon t o t o l o of t o o o t o t t o t o t o v * m%l& t o d to oxfcptoir nMttlto* If ft croator* for *x sm p l** « i t o U * t o ft m tot rosorria# » lifft o o t o o to fctoolf, &* w t o * to i t o l o fo* ft gift -|®s oft t&« roftftloAof* lost .if too t * M w f o » * o 4 mm& tteo oftiito pyopoapty ojowipi f#£ oft oacifoftoiy r w » l # e<mtiair®R#y» bft o o o M ¥• Safe StfgfiMS r. C g a # t 12# V. (24) 287, 241 (C.C.1. l*t» 1943}, •art. <m M i 817 B.S. K M (1942). tS«« 3 i’anl, r«d«rel £•**»« «■* Sift taxation (1543) Il7.13. It## §it*G9* Urn 14. M i m*tt m.% is #»• #14* quasi lent timt aria* uadtr ateii«»a a£ tht #sti»fe® in* t«* olh«r t o n ISOS i&*t lit ft #*»»•£**>• tsfetag |to®i »l dtalli. m e t i e a $92 (•) 4tt»is *it3i property m% % *<8mlamll? peetiiMg mt &*&%h tmt vitfe iiiitrtti* t ^ u m t o f o f v o*v*t«4« Vfe* tfesa&l* m *m t it a trm m tm r later f t f M . Hat tit* mtmmkTfs o f %Mm t m it tht *»!«• «f III# tr»**a£«rr»4 proptrty *t tfta *s*«a lato m (1349)* M f » r i B « Pa M i o n i t $•# ft Otaau* » A m t h $rt»i3i it «*$* 19$. U Q - U f. |i$J 3$f* 2ti (0*4*4. iti* 1942). otrt. denied. Sit Sf.S. §§§ (1443). Of * HoateaNot, ite&ft* on Oifit $a$Jtei to Oeatlagtaeiat (1941) 20 feu** $B0* $94. Of. e®a*. f. Beek1# ittai#, i*t »* ( m l m $ * 194$). m (tJL* m* L mjl&I I** if Araftoto *»•& &m*ply $ m m Iirrlo# of lfie iita M i oxoopt fo f o» Ito lo tM fel»f» I t ** »**»«iglH j|^ voooiikod « U m i wfcoa U « o n mmy o*pH oi% . th e r * Is U n i t to add, in the way of Jnettflcatioa or criticism, to the C e m r t U disposition of the m t f l i r probleiu t o t o of Hr* K a t i e s a M f c * « opinions — «*i» that a gift is eeapleted vhm i economic centrel 1» surrendered by the doner — - 1* adeenately tome* « $ Certainly this concept of a transfer by gift 1« Ihadaaemtnl, any theory of watunl exelasireness U hardly m adegn&te response to sey taalifledly hold* M p i t aside. the It is opinion an- & m t r i t f readers * transfer ineoaplete, end that the § t o t slows either hot or cold t© salt the rogulroaants of taxability# She estate tax reachee fnricm* traaefera which are ordinarily regarded ae acoylata gifts, hat are^lwrerthelea# treated m % m Oowmoa ae incomplete aatli death ewertrkes the greater., .. examples are an irrevocable transfer reserving a U f a eetate la the grantor* a treat reweoeble % the grantor is e e a J u n c U o n with persons possess ing a substantial adverse l & f c m e « » * and tenancies h y the entirety created % one of the spoases* la of a slailar character.® 1 transfer subject to a referter the theory that the estate and gift tax concept* of completeness are coterminous w l i siaply wife the gift tax off the booh# unless the grantor released all possible contacts with the property. la other words, Congress weald be pre~ rowed to haws intended that only a transfer in c o a t e a p l a U o a of death should feel both the eetate aad gift tax.* «r. Justice Blade1* theory that the gift tax ie a fora of de*n-pey*«at or security with respect to the eetate tax seeas to be a each aore logical deduction frees the present system of transfer taxation t S t c * Sm his t l i M i t l a g oplnlous la Btsaomaim a. tf» 0, Panasgr ®e, ail tf.8. 436, 446 u * 4 0 ) | »hltasy a. »te** Ta* O a a l w U t . « 8 8.8. sao, 648 (1940); *#la*ria* f. O U f f o r * , 809 8.8, 331, 386 (1940); I c l m t i f a. Ballask. 309 9.9, 106, 188 (1940); Sajstty v. aat-'ont, 308 9.9. 486, 499 (1940); Blsglaa r. Salt®, 80S 8.8. 473, 480 (1940); Baltsd Stataa T. i M t t a , 806 8.8. 363, 878 (1989); Seififc a. Baary, 806 8.8. 184, 181 (1988). Bat caapara U a opinion la Bslaorlag a, Braaa. 309 8.8. 461 (1940). l y 'i i y * b l n i l t C ». St. leala ttaln Trust 6a., 896 8.8. 39 (IBM); Bee'sar t. 8t. k a i l Baton Trust 6o.« 898 8.8. 48 (1936)• Osrapsrs the dissenting opinion la Belaoring a. St. leule Balsa Trust 0® „ 318 8.8. at 168. 896 8.8. 89. 4? (1936). **& *• laapirad a fh© raaooalag la tha &alth and &%u*m% hr «r# Jaattoa M a r t a * tfloa law rapaatadly a?$»asad tha a f rm cm t shift# la tha 6 w f l * » tax illite4*«. *• »«w *4 ***** ** loaf aa a traaafar rssarrla# a rsrartar wao eaaj&sta for t « U I # tax purpaaaa uadar th© xula of th© diaaardad ftftl !3U decisions, th© ©aas txanafar sigh* jirafsrly ha soaaldarsd a d*fiaittra taaafcXa *lft. f e t th# M j ^ S dactalaa fed craatad a diffaraat context, and the & ls*r aaraaas af a raaartar %ma plaaod ia tik* 9mm eatsgovy a« a traat reserving to th© grantor aatll tha Instant af death a pa*©r to revoke a r ofea«a f e a a f l a t a r l W9 of the Sanford aaaa accordingly required tha coaolueloa that a transfer reserving a reverter vea aa incomplete gift* -IKr* Jostle© M a r t a referred to the $esrtfa e e n a e m , la that aaaa, ever *the difficult!©* af aSaialatratiaa «ad jarohahle ineauilie* of a contrary decision,* and aoataadad that the aaaa considerations vara sjif&ie&hie here* * Indeed,* he concluded. * a a y i W a of taxation vhieh requires valuation af tha donor1# rotalaad lataraai, la tha U # t of tha eontingeaeiee iavoivod, and calculation of tha value of tha outeecuant remainders h y reeert ta higher mathematics heyond tha fees af tha taxpayer, a a h l M | » tha artificiality of tha d o r a r m « a t fa apfdlaatlen af tha d a t * * ^ Sag, 79 (1936 Kd.), Art. 3. Cf. ^ W * aiggtHB T. G otm ., 189 f. e«rt. «*ai«4, SIT 8.8. 888 (1942)j I m u (M ) 6 9 1 , «R6 (0.8.4. 24, 1941 )i Sapp. 874, 878 (1948) 818 9.8. a 187. ». Kerartiult U * *• TV « M y , 4T f. I* H | M g w t l M teUMtti to. * » « « • » « * dl.jwww* of two odfittioooi. t t s u f t O ^ M W « M . **»• ***** * * *° •fta#t that the gift# e#r# not e##pi#t# fc###**## t h « w i « « *® do*### in ©▼cactus© ^ to accept the r##»i»d*r#* fki# arguae&t m # paint tag eat that th# gift tan ©tfetut## *• correctly oo».t™*4 nr *>» n i o * U M ^ f *• • » 4wMMf‘* ♦***•*•* 0? aarrender of doalnloc ever the p r e t t y . •purported to give the property to «©»#eae X»ter &ceert&lned end this v m eaoagh.^ t»^»^r««r# identity could he **>• •#«*»& objection t# tn# Ceeatcaioner1# poeltioio w&m Wiat I# any event h# hfcd erred la refusing to ante# ell#*#### for the m i n # of to# donor* # roverelonery Inhoreet* however* the #omrt concluded that dea lt# peat progroee • Im epifeifttag the value of that which a#©#© to 0# nneppfaiaabl©,* the eotaiiri&l art we© not coasp#tent to cop# vlth a W f e f a i o i u u y inter##* dependent #$## «»«h factor# #• wh#th*r tfc# daubster could flurry » M ha## children and toother th* children could attain few me Veemetm to^ww® « K « « » «•***• 31* B,8. m* g«* a o t ^ U ^ {s' IS' J6r* «Jm*ti©e Blmok ftlio roforrod to log* 7» \ \ ( m e Id.)* Art*, a. S, If* If* *ho rifft t w artleioo doml wit1 % € concept of a t m t f w to vmiumtioa. la aad th© other two rolmt© T. Humphrey** SOf 0.3* id* SI ^ (itii)* tins Coart M L mot toon vtiy Utpr©*«od fcgr;4moi© 8 mo off meting roomrwod poworo to aitor boaofici&i internet*, io© also M lm im w* Comm** m f* (2d) 3f*« M S imz), wort* «©&!**, 31? 0 .B* IW Jp « > * § ^ i § 318 8,8. •« lift.. IIf k 14. at 181. 1 Of. Albert B. U s t s r , 1 *.*. 308 (1943) (C.O. X«t, Haying disposed ©f Its# annoying theory of «xclualve"» ness* tho f#«ri i o & « y i M tfc* *fc»nts eiisetlon* vhsthsr tad ©©assisted a gift of th* rsnoindsr* fhs % rolled oa the already feailior ergunsat that #ao r s a l l e U e T u l a # ©sold 0© planed ©a the Interest Oesous© of the eoatiagea©!©* surrounding It* ffe» Court, however* refused to *o©es^i any m m sotlen that the complex! ty of # property interest ©ronhsd hy a trust con serve to defeot a tax* for ashy year© Congress fee# sought vigorously to ©loss tax loopholes ogoiast Ingenious trust instruments* though these eoneept* of property end Sow rmXum m y h* slippery sad elusive they ©an mot escape taxation s© long am they are mood la TV* tli# world of husinees* H @ t statutory isuguage, on reinforced fcy the House and Senate CeaasUtee deports. ' «»• considered suf ficiently W o o d to sahraee «property* however conceptual or ©onCourt then defined a gift la ti . over tho property put la trust,* ' finally. ©eeaon*© eoatrei woe ©smoldered ahsndenad ©t o r though tho torao ©f tho | return la the event that the grantor ms m* IHA* ©rttiuisn tft 2 Fa»l* litoral ****** fflft §,*•§* a t lift* $tas Saprsa# Co art gyamtsd esriiorari im the Balth sad lehlaett# cess* hecant# of an alleged conflict *ith the Court1* ®pl»iq*« la a»© mi rfanfard b s »m 7 I* **» U i <®s* the B e v e n w e n t again conceded that t^jp value of the reversionary interest we* iamtuie free gift tar* *asi the Court* through hr* bustle* Blech* addressed itself solely to the remainder interest* $h* Justice emphatically disapproved the notion that the s&nford opinion * imtiaated a p g § m i poller against allowing the sans property to he taxed hath a* am estate and a gift.*# he alluded to language In the % p f e r ^ eplaion whleh had meted that the two taxes are met "always Mutually sxeluslvs* and had referred to the gift tax credit* designed to soften the Blew of two levies* la the Sanford ease the eaphasis obviously had heea against everlapplag* hat the Court was r o w apparently aware ef the feet that It had unfortunately swept toe far afield in testify* lag the previous d e c i s i o n . ^ hr* Justice Blest? mow articulated a ■ aew philosophy as a fraaeworh for the interpretative process* 11 tinder the statute the gift tax)eaounts im sene instances to a security* a fora ef down-paynent #m the estate tax which secure# the eventual payment of the .latter; It is in no sense doolie taxation M as the taxpayer suggests*** this system of down~paynsnts was 1^ regarded by ths(^ourt as the Congressional plan for integrating ths estate and gift levies* 128 ». (24) ?42 (C.6.A. 24, 1942), ror*g 40 f. Sapp. 19 (1941) M B s . \ L See Brief for Boenondont. p. 8. Snlth r. Shaughnosey, SI# 9 V. S. 176 (1943). m >■ bs- Compere the Supreme Court* • acquiescence la fee CoTeruuont'e concession In the Bollock cooo. See M 1 m l , Federal Setate and Sift * M » t l o m (1942) 1 7.26. But of. Sstute of Sanford r. C o n . , 308 U. S. 39, 60*1 (1939). L ^ x *. . « & ♦ 116 f. (24) 691 (C.C.A. 24, 1941). *3?hs ays ter;/ deepeas ahaa it Is acted that oat of the throo judges who concurred la the MarshalX opiaioa participated la the Ssith dseistoa The reverter question appeared once sere is the Second Circuit in Smith v, Shauidmeasy. which dealt with a trust pro viding fo r a life estate in the grantor*s wife and a return of the corpus to the grantor If he survived her* In the event that the grantor predeceased her, the property was to pass to her ap pointees, or, In default of appointment, to her distributees* The district court had allowed a gift tan confined to the wlfc*s life estate. The Second Circuit, on the other hand, imposed a tax upon the entire value of the trust property despite the Govern ment* s concession that the tax base should he reduced by the value the court*e refusal to reeogniss the concession was its method of reversal. The opinion was mr curlast, consisted of one sentence, made no mention of the painstaking opinion in the Marshall case which was directly In point, end relied exclusively upon Hersog v. Commissioner, which involved a different problem Upon a rehearing the court considered the m p p tm m tm g question whether an allowance should, ha «*de for the value of the reversion*^ interests. the court refused to sanction an adjustment in tax base on the ground that the value of the remainders was not affected ty the jjosslbility that the daughter ai^ht never have off«?>rtng attaining Majority* if her children eventually reoeived the remainders* they would enjoy their full value* unimpaired by the alternative possibility under the scheme of disposition* But this disposition of the valuation issue ignores all contingencies which affect the ehanees of realisation. The remainders are* in effect, treated as if they were entirely free of contingencies, rue loss of control by the grantor should be decisive in determining whether or not a taxable gift has been node; other contingencies, however, nay still affect the value of the gift, although as a practical natter they nay not be amenable to the art of valuation and are therefore ignored for administrative reasons. % 5^0*9^ Helverlag f. Boblnelfc®* 12# F» (2d) 832 (C#C#A., 3d* 1942) 139 I. (24) id 834* Cf. Coma. T. M^raiuO.!, IBS F* (2d) 948* 947 (€.0«d. 2d, 1942), Q problem ©f/^eversionsyy I a n d the gift tax tura-a «p «caln/W the MoMnaU, owe deolfled hjr the «hir* Circuit. this ease involved two taxpayers, a aether and daughter. the latter had created tee trusts proriding for tli# payment of income to herself for life* and thereafter to her aether and stepfather, and, upon the death of either* to the survivor. After the tei^tiaation of the life estates the principal was to he paid over to the daughter's issue attaining the age of twenty-one, or, in default of such issue, to the appointees of the survivor of the three life tenants* the mother had estab lished a similar trust except that the initial life estate was for her benefit, the court again sustained the Commissioner, selecting &• the vital factor the grantor1s surrender of economic control over the trusts except for the possibility that the A (A ^ daughter rs&ain childless or her children fall to reach majority« "thus* the settlors could not themselves bring about the exercise v of their powers of appointment without committing a crime. m %o furthermore, since the gift tax is iapes^jupoa the donor's transfer rather than the donee's receipt* It was deemed immaterial that the ultimate takers of the remainder were not in existence. mm o . ^ |%% 1 2 ? F. (34) 942 (C.C.A. §th* 1942). Another quest ion in the ease related to reciprocal transfers as affecting the concept of adequate and full consideration. /4 % 12? I. (2d) at 943. Of. Estate of Horatio Oates Bloyd* 4? B.f .A. M 9 (1942). Id. at 944. Of. hstate of J. §» Bodson, 1 f. 0. 416* 423 (1943)# / Hi /S ^ C£. Holies r. Oowa.« 104 I, (2d) 144 (C.6.A, 9th* 1939). A similar issue came before the fifth Circuit la Commissioner v. fochean. Involving trusts which provided for a reverter coatlugest upon the prior death of the grantor*® spouse and daughter* and the latter* s failure to leave issue and to appoint the property after attaining the age of twenty-five. It was held that a taxable gift had been effected *to t extent end value of the estates and interests in the property then transferred*9 and that the provision for a reverter did not affect the complete ness of the gift but only its value, fhe court refused to delve deeply into the problem because sines the Hallock and Sanford decisions *caste down to confuse and confound followers and expounders of gift tax law, the voices of both board members and circuit Judges are merely voices crying in the wilderness*, and perhaps until the Supreme Court has spoken authoritatively on the question they would do best to decide the ouestions posed with as little bewordling end as f m reasons as possible.* this left only the troublesome question of valuation* the Coma-ssloner claiming that the entire value was taxable either because the reverter was too remote to make allowance therefor or because Its value had not been established. fhe court rejected the first reason* and considered the second Inadequate since no valuation issue had been raised below, fhe case was accordingly remanded to the Board in order to evaluate the reverter. / 1 LS B . 1. Rep, Ho* 708, 72d Cong., let Sees., p . 27 (CJI. 193S-1, Fart 2, p. 476); Sea. Rep. Id. 665, 72nd Cong., 1st Sees., p. Stf (0,2. 1929*1, Fart 2, p, 524), See also Hughes Ooaau, 104 7. (2d) 144 (C.C.R. 9th, 1939), approved la the Marshall opinion. I B ill _i A s im ila r "parade of imaginary horribles* takes place ia £ the Sanford opinion* 308 C. S* at 46. Power* of Appointment and Estate faxes* Cf • Kisenstein, II (1943) 52 Tale A* «T, 494, 639* & 125 f * (24) at 946, referring to Ithaca Trust Co. r* United States, 279 If. S. 151 (1929). Guggenheim, 1 f. 0. 845 (1943). See also Estate of Simon fudge Prank urges that the fallacy la the taxpayer's contention "stems largely f r < m ^ — ^ lack of recognition of the eely character of the word (Walua'. It is a bewitching word which, for years, has disturbed mental peace and caused numerous useless debates. Perhaps it would be better for the peace of men's minds if the word were abolished, leans of good paper and gallons of good ink hare been wasted by those who hare tried to giro it a constant and precis# meaning." See also fudge Frank’s opinion In Andrews ▼. Corns., 135 f. (2d) 314, 317 (C.C.A. 3d, 1943), cert. tS denied, Oct. I I , 1943. 4b For some mysterious reason the court observes (at 947) that it is not settled whether the remainders in question would bo included in the decedent's gross estate under the Haliock ease, but that such inclusion is assumed for present purposes, does not seem to bo any doubt on the subject. There in th# resent f»®o edBirol hud passed outj of the donor9s bands sad a ©oapXeted transfer dad ©eea effected %ritdi» the broad and comprehensive Xanguoge of the statute as rolaforood by the explanatory committee reports' wjH fti© first argument endeavored to distinguish, for gift tax purposes, between a rested and contingent remainder* on the theory that a coat ingest remainder is not a e m u l a t e d gift. this dogged reliance on property lav vas dismissed by a reference to the Hallock case, which had conclusively “destroyed such a word-Juggling c o n t e n t i o n . * ^ Another argument advanced by the taxpayer emphasised that Congress did not intend to impose a tax determined by estimates of value which nay turn out to he wrong In actuality* especially since the donees night he required te pay a II tax on property which they never finally enjoyed.*1 hut* replied the court* this argument “would preclude a tax on any *value1 which is not almost certain to correspond with actual enjoyment** although value “ seldom does so correspond.* In tax law* *as almost always* •value* Involves a conjecture* a guess* a prediction, a prophecy, bith reference to the taxation of life estate# the Supreme Court has relied on educated guesses* as of a given date based on the mortality tables* disregarding the fact that actually* In the particular ease before it* the prophecy has turned out to be wrong because the life tenant did not live up to her expectancy.* L ' Finally* the court rejected the argument thriving on the Sanford case* namely* that since the remainders would feel the Impact of as estate tax they were immtne from gift tax. Judge Frank confined the broad language of the Sanford opinion to a trust wherein the donor retains the power to determine the recipients of its benefits. L- tjjjjj $## BiMit *At 701 (1941) » HoiTl.® m & m U 43 ».*.&. 1036 (1941 )5 Curl 3. 329 (1941 )5 43 H.f W M t ® Marshall, 43 &•£•&• 99 (1940)5 8 arr* &©!««». 41 B.9.4. 1333 (1940) • |j M f * C M ) 943 (9.6.*. 34. 1943). I»# M r . 747. I Me (1943) 9 W* of &*i. ttm Interpretation* which accented taxpayers* understanding of the ialloclc and ^ n f o r d eases* underwent initial 9 appellate scrutiny la Seagals*loner y. Marshall. She greater la t ile ea*e had established two irrevocable tract# providing that the property was to r e t e a to her If she survived the life tenant* If the grantor died first* the property was to pass to her children and their issue* She Casuals* loner and taxpayer agreed that the life estate urns taxable and that the value of the reversionary interest was not taxable* Hence the only euestion left for consideration was whether the value of the remainder -** described as contingent — was subject to gift tax* this issue was resolved ®y the Second Circuit in the Ceauissloaer* s favor after painstaking analysis by Judge frank of the taxpayer*s various arguments* c P 309 If* S. 106 (1940), overruling Helrering v. St. r Union trust Co.* 296 0. S. ® Union trust Co.» 296 If. 3. 48 ■/y * / /% * r y * \ f/* (1936); Beefcer »* St. l«mte (X936). See 2 Foul* federal Estate end 0ift taxation (1943) 8 17.14, a. I lk See* e.g.# Elagins r* Saith, 308 If. S. 473, 477 (1940). Is tat e of Sanford f* Coma., 308 8. 8. 39 (1939)* See 2 Faul, federal Satate sad 61ft taxation (1943) 88 17.06, V \ A 17.07. (/7^3) \ /^ 6 318 0. S. 176 (1943), noted W s i Harr. 1. See. 1010 (1848). 318 If. S. 184 (1943). ■■ m m mm /y 1 Jglp f HO VIS1343 ) "V I A? V ■Mmm / m jKBESLeS6jB flie mounting est* to tax misfortunes of grantors who have 1 retained reversionary interests have recently be«n paralleled ©y similar unhappy experiences with the gift tax* // h * r In Belverlmt W v* Halloed*^ /on will recall, it was valiantly contended that « reverter did not subject a transfer to estate tax since it did not prevent the conviction of the gift frier to the decedent1# demise, fhis argument having failed to convince a reconstituted ^ A ^ cA j^ l L \ j t * '- * r r ~ * s Supreme Court* no re allviwt© the pitfalls of property law,** ™ Jp*-** taxpayers thereupon argued that a reverter was equally potent to reader a transfer incomplete for gift tax purposes, fhe claim that what is good for the goose should In all fairness be good for the gander — we know* of course, that this canon is not J unyielding in the tax field was bolstered by the unnecessarily -** ji/' broad language of the Sanford opinion which dwelt upon the jsr mutually exclusive character of the estate snd gift taxes** Again the Hupresse Court was not impressed, and la Smith v * J* 4# *>«d B o S i a a t f y. iielvgrlag r tt Interred, with * minimum of ceremony, the attractive theory of mutual exclusiveness* I have Choaen to discuss today in mmm detail tills new and provocative chapter in gift tax incidence. Proceeding on the familiar principle (L^J that the present and future m y be better understood if we glance ^ ^ m the past, I shall preface my analysis of the recent Supreme Court decisions and their implications with a running review of i\ earlier decisions In the lower courts* TREASURY DEPARTMENT Washington (The following address by Randolph E. Paul, General Counsel of the Treasury, before the session on "Taxation of Trusts and Estates" of the National lax Association Convention at the Palmer House, Chicago, is scheduled for delivery at 11 a. m», Central War Time, Monday, November 22, 1943, and is for release at that time») TREASURY DEPARTMENT Washington (The following address by Randolph E. Paul, General Counsel of the Treasury,.before the session on .“Taxation of Trusts and Estates1’ of the National Tax Association Convention at the Palmer House, Chicago, is scheduled for delivery at 11 a* m,, Central War Time, Monday, November 22, 1943s and is for release at that time*! REVERTERS UNDER THE GIFT TAX The mounting estate tax misfortunes of grantors who have retained re versionary interests have recently been paralleled by similar unhappy experiences with the gift tax* In Helvering v* Hallock, l/ you will recall, it was valiantly contended "that a reverter did not subject a transfer to estate tax since it did not prevent the completion of the gift prior to the decedents demise* This argument having failed to convince a reconstituted Supreme Court which had become more alive than ever to tne pitfalls of property law, 2/ taxpayers thereupon argued that a reverter was equally potent to render a transfer incomplete for gift tax purposes* The claim that what is good for the goose should in all fairness be good for the gander — we know, of course, that this canon is not unyielding in the tax field 3/ — was bolstered by the unnecessarily broad language of the Sanford opinion hj which dwelt upon the mutually exclusive character of the estate and gift taxes#_ 5/ Again the Supreme Court was not impressed, and in Smith v. Shaughnessy 6/ and Robinette v# Helvering 7/ it interred, with a minimum of ceremony, the attractive theory of mutual exclusiveness* I have chosen to discuss today in some detail this new and provocative chapter in gift tax incidence^ Proceeding on the familiar principle that the present and future may be better understood if we glance back to the past, I shall preface my analysis of the recent Supreme Court decisions and their implications with a running review of earlier decisions in the lower courts* The Board* s, interpretation, which accepted taxpayers! understanding of the Hallock and Sanford cases, 8/ underwent initial appellate scrutiny in Commissioner v* Marshall* .9/ The grantor in this case had established two 1/ 309 ,U. S. 106 (1940), overruling Helvering v. St* Louis Union Trust Co*, 296 U. S t 39 (1935); Becker v. St* Louis Union Trust Co., 296 U. S* 48 (1935). 2/ See 2 Paul, Federal Estate and Gift Taxation (1942) § 17.14* n* 11. 3/ See, e.g., Higgins v* Smith, 308 U. S. 473, 477 (1940). 4/ Estate of Sanford v. Comm., 308 U. S. 39 (1939)* 5/ See 2 Paul, Federal Estate and Gift Taxation (1942) §§ 17.06, 17.07* ' 6/ 318 U. S. 176 (1943), noted in (1943) 56 Harv* L. Rev. 1010. 7/ 318 U. S. 184 (1943). • v . . „ mA 8/ See Meta Biddle Robinette, 44 B.T.A. 701 (1941)'; Morris Michel, 43 B.T.A. 1036 (.1941); Carl j. Schmidlapp, 43 B.T.A. 829 (1941); 'Margaret White Marshall, 43 B.T.A* 99 (1940); Marrs McLean, 41 B.T.A. 1266 (1940). 9 / 1 2 5 F. (2d) 943 (C.C.A. 2d, 1942). See (1942) 9 U. of Chi. L. Rev. 747. 39-60 - 2irrevocable trusts providing that the property -was to return to her if she survived the life tenaht. If the grantor died first, the property was to pass to her children and their; issue* The Commissioner and taxpayer agreed that the life estate was taxable and that the value of the reversionary interest was not taxable. Hence the only question left, for consideration was whether the value of fhe remainder — - described as contingent — was subject to gift tax. This issue was resolved by the Second Circuit in the Commissioner’s favor after painstaking analysis by Judge Frank of the tax payer 1s various.arguments* The first argument endeavored to distinguish, for gift tax purposes, between a vested and contingent remainder, on the theory that a contingent remainder is not a completed gift* This dogged reliance on property law was dismissed by a reference to the Hallock.case, which had conclusively "destroyed such a word-juggling contention. " u Another argument advanced by the taxpayef emphasized that Congress did not intend to impose a tax determined by estimates of value which may turn out- to be wrong in actuality, especially since the donees might be required to pay a tax on property which they never finally enjoyed* 2/ But, replied the court, this argument "would preclude a tax on any 1value* which is not almost certain to correspond with actual enjoyment," although value "seldom does so correspond.!* In tax law, "as almost always, *value* involves a conjecture, a guess, a prediction, a prophecy. With reference to the taxation of life estates the Supreme Court has relied on educated guesses, as of a given date based on the mortal ity tables, disregarding the fact that actually, in the particular case before it, the prophecy has turned out to be wrong because the life tenant did not live up to her expectancy." j/ Finally, the court rejected the argu ment thriving on the Sanford case, namely, that since the remainders would feel the impact of an estate tax they were immune from gift tax* Judge Frank 125 F. (2d) at 945. 1 A similar "parade of imaginary horribles" takes place in the Sanford opinion* 308 U* S. at 46* Cf. Eisensiein, Powers of Appointment and Estate Taxes: II (1943) 52 Tale L. J. 494, 539* 3/ 125 F* (2d) at 946, referring to Ithaca Trust, Co. v. United,States, 279 U. S. 151 (1929). See also Estate of Simon Guggenheim, 1 T* C* 845 ■ (1943). Judge Frank urges that the fallacy in the taxpayer 1s contention "stems largely from lack of recognition of.the eely character of the word ‘value1. It is a bewitching word which, for years, has disturbed Cental peace and caused numerous useless debates. Perhaps it would be better for the peace of m e n fs minds if the word were abolished. Reams of good •paper and gallons of good ink have been wasted by those who have tried to give it a constant and precise meaning*" See also Judge Frank’s opinion in Andrews v. Comm,, 135 F. (2d) 314, 317 (C.C.A. 2d, 1943), cert, denied, Oct. 11, 1943* 1/ 2/ - 3 - confined the broad language of the Sanford opinion .to a trust wherein the donor retains the power to determine the recipients of its benefits. 1 / In the present case control had passed out of the donor*s hands and a com pleted transfer had been effected within the broad and comprehensive language of the statute as reinforced by the explanatory committee reports. 2/ A^ similar issue came before the Fifth Circuit in Commissioner v, McLean, 3/ involving trusts which provided for a reverter contingent upon the prior death of the grantor1s spouse and daughter, and the latter*s. failure to leave issue and to appoint the property after attaining the age of twenty-five. It was held that a taxable gift had been effected "to the extent and value of the estates and interests in the property then transferred , 11 lj and that the provision for a reverter did not affect the completeness of the gift but only its value. The court refused to delve deeply into the problem because since the Hallock and Sanford decisions" ’’came,down to confuse and confound followers' and expounders of gift tax law, the voices of both board members and^ circuit judges are merely voices ciying in the wilderness, and perhaps until the Supreme Court has spoken authoritatively on the question they would do best to decide the questions posed with as little bewordling and as few reasons as possiole.” 5/ This left only the troublesome question of valua tion, the Commissioner claiming that the entire value was taxable either because the .reverter was too remote to make allowance therefor or because its value had not- been established. 6j The court rejected the first reason, and considered the second inadequate since no valuation issue had been raised below. The case -was accordingly remanded to the Board in order to evaluate the reverter. i r i b ? some mysterious reason the court observes (at 947 ) that it is not settled whether the remainders in question would be included in the decedent’s gross estate under the Hallock case, but that such inclusion is assumed for present purposes. There does not seem to be any doubt on the subject. u H. R. Rep, No. 708, 72d Cong., 1st Sess,, p. 27 (C.B. 1939-1, Part 2, p. 476); Sen, Rep. No, 665, 72nd Cong.*, 1st Sess., p. 396 (C.B. 1939-1, Part 2, p. 524)* See also Hughes v. Comm., 104 F. (2d) 144 (C.C.A. 9th, 1939), approved in the Marshall opinion. 3/ 127 F, (2d) 942 (C.C.A. 5th, 1942),- Another question in the case re lated to reciprocal transfers as affecting the concept of adequate and full consideration. v 127 F. (2d) at 943. Cf. Estate of Horatio Gates Lloyd. 47 B.T.A. 349 (1942). 5/ Id. at 944. Cf. Estate of J. G, Dodson, 1 T, C, 416 , 422 (1943). y Cf. Hughes v, Comm,, 104 F, (2d) 144 (C.C.A. 9th, 1939). ~ 4 The problem of reversionary interests and the gift tax turned up again in the Robinette case l/ decided by the Third Circuit* This case involved two taxpayers, a mother and daughter* The latter had created two trusts pro viding for the payment of income to herself for life, and thereafter to her mother and stepfather, and, upon the death of either, to the survivor* After the termination of the life estates the principal was to be paid over to the d a u g h t e r s issue attaining the age of twenty-one, or, in default of such issue, to the appointees of the survivor of the three life tenants* The mother had established a similar trust except that the initial life estate was for her benefit* The court again sustained the Commissioner, selecting as the vital factor the grantor*s surrender of economic control over the trusts except for the possibility that the daughter might remain Childless or her children fall to reach majority* ’’Thus, the settlors could not ttoamselves bring about the exercise of their powers of appointment with out committing a crime*” 2/ Furthermore, since the gift tax is imposed.upon the donor* s transfer rather than the donee*s receipt, it was deemed immaterial that the ultimate takers of the remainder were not in existence* Upon a rehearing 2/ the court considered the supplementary question whether an allowance should be made for the value of the reversionary in terests, The court refused to sanction an adjustment in tax base on the^ ground that the value of the remainders was not affected by the possibility that the daughter might never have offspring attaining majority* If her children eventually received the remainders, they would enjoy their full value, unimpaired by the alternative possibility under the scheme of dis position, But this disposition of the valuation issue ignores all contin gencies which affect the chances of realization* The remainders are, in effect, treated as if they were entirely free of contingencies* The loss of control by the grantor should be decisive in determining whether or not a taxable gift has been made 5 other contingencies, however, may still affect the value of the gift, although as a practical matter they may not be amend able to the art of valuation and are therefore ignored for administrative reasons* The reverter question appeared once more in the Second Circuit in Smith V, Shaughnessy, 4/ which dealt with a trust providing for a life testate in the grantor* s wife and a retuwn of the corpus to the grantor if he survived her* In t h e 'e v e n t 'that the grantor predeceased her, the property was to pass to her appointees, or, in default of appointment, to her distributees* The district court had allowed a gift tax,confined to the wife *s life estate* The Second Circuit, on the other hand, imposed a tax upon the entire value of the trust property despite the Government concession that the tax: base should be reduced by the value of the grantor s 17 H u Helve ring v, Robinette, 129 F* (2d)' 832 (C*C«A* 3d, 194-2 )• 129 F. (2d) at 834* Cf. Comm* v* Marshall, 125 F. (2d) 943, 947 (C*C*A* 2d, 1942)* 129 F* (2d) at 835. ,___ _ 128 F* (2d) 742 (C*C.A. 2d, 1942), rev*g 40 F* Supp* 19 (1941). - 5 - reversionary interest* 1/ More baffling than the .court’s refusal to recognize the concession 2/ was its method of reversal* The opinion was per curiam, consisted of one sentence, made no mention of the painstaking opinion in the Marshall case which was directly in point, and relied ex clusively upon Herzog v* Commissioner, 3/ which involved a different problem*. M The Supreme Court granted certiorari in the Smith and Robinette cases because of an alleged conflict with the Court’s opinions in the Kallock and Sanford cases* 5/ In the Smith case the Government again conceded that the value of the reversionary interest was immune from gift tax, 6/ and the Court, through Mr* Justice Black, addressed itself solely to the remainder interest* The Justice emphatically disapproved the notion that the Sanford opinion ’’intimated a general policy against allowing the same property to be taxed both as an estate and a gift.” if He alluded to language in the Sanfox-d opinion which had noted that the two taxes are not ’’always mutually exclusive” and had referred to the gift tax credit, designed to soften the blow of two levies* In the.Sanford case the emphasis obviously had been against overlapping, but the Court was now apparently aware of the fact that it had unfortunately swept too far afield in justifying the previous decision* 8/ Mr* Justice Black'now articulated a new philosophy as a frame work for the interpretative process: ’’tinder the statute the gift tax amounts in some instances to a security, a form of down-payment on the estate tax which secures the eventual payment of the latter $ it is in no sense double taxation as the taxpayer suggests.” 9/ This system of downpayments was regarded by the Court as the Congressional plan for inte grating the estate and gift levies* Having disposed of the annoying theory of mutual exclusiveness, the Court considered the ’’basic question” whether the grantor had completed a gift of the remainder* The taxpayer relied on the already familiar argument that ”no realistic value” could be placed on the interest because 1 / See Brief for Respondent, p. 8, Smith v. Shaughnessy, 318 U. S* 176 (1943)* 2/ Compare the Supreme Court’s acquiescence in the Government’s conces sion in the Hallock case. See Paul, Federal Estate and Gift .Taxation (194-2) § 7*25* But cf. Estate of Sanford v. Comm*,. 308 U. S*. 39, 50-1 (1939). 3/ 116 F. (2d) 591 (C.C.A. 2d,. 1941). y The mystery deepens when it is noted that one of the three judges who concurred in the Marshall opinion participated in the Smith decision* 5/ 313 U,S. at 178. 6/ Ibid* 7/ Ibid. 8/ Compare criticism in 2 Paul, Federal Estate and Gift Taxation (194-2) §17.07. 9/ 318 U.S. at 179. 6of the contingencies surrounding it* he Court, however, refused to ’accept any suggestion that the complexity of a property interest created by a trust can serve to defeat a tax* For many years Congress has sought'vigorously to close tax loopholes against ingenious trust instruments. Even though these concepts of property and value may be slippery and elusive they can not escape taxation so long as they are used in the world of business*” 1/ The statutory language, as reinforced by the House and Senate Committee Reports,2/ was considered sufficiently broad to embrace " property, however conceptual or contingent." 3/ The Court then defined a gift in trust as "the abandonment of control over the property put in trust." y Finally, economic control was considered'abandoned even though the terms of the transfer stipule, ted for its return in the event that the grantor survived another person* 5/ In the companion Robinette case Mr* Justice Black disposed of two aaditional taxpayer objections. The first was to the effect that the gifts were not complete because there were no donees in existence to accept the re mainders. This, argument was overcome by pointing out that^the gift tax statute, as correctly construed by the regulations, 6/ is imposed upon the donor’s transfer or surrender of dominion over the property* 7/ xhe taxpayers "purported to give the property to someone whose identity could be later ascertained and this was enough." 8/ The second objection to the Commissioner's position was that in any event he had erred in refusing to make allowance for the value of the donor’s reversionary interest. However, the Court concluded that despite past progress "in appraising the value of that which seems to be unappraisable,” the actuarial art was not competent to cope with a reversion ary interest dependent upon such factors as whether the daughter would marry and have children and whether the children would attain majority. 9/ Gift tax was therefore imposed upon the entire corpus* 1/ 2/ 318 IT.S. at 180. See note 2/ page 3. Mr. Justice Black also referred to Reg. 79 (1936 Ed.), w # 17, 19. _ ^ I'hg first two articles deal with the concept of Arts. 2, 3, a transfer^and7the other two relate to valuation. In Rasquin v. Humphreys, 308 U.S-. 54, 56 (1939), the Court had not been very impressed by A r t i c l e ; as affecting reserved powers to alter beneficial interests. See also Higgins v. Coram,, 129 F. (2d) 237, 243 (C.C.A. 1st, 1942), cert, denied, 317 U.S. 658 (1942). 318 U.S, at 180. u*^ 3^ffij,^ Cf. Albert D. Lasker, 1 T.C. Reg-. 79 (1936 Ed.), Art. 3. Cf. Higgins v. Comm., 129 F. denied, "317 U.S. 658 (1942); (C.C.A, 2d, 1941)3 Hernstadt 318 U.S. at 187* Id. at 188, 208 (1942). See note 2/ above. (2d) 237, 242 (C.C.A. 1st, 1942), cer • Herzog v. Comm., 116 S 5 v. Hoey, 47 F. Supp. 874, &«6 (142). - 7.- . The reasoning,in the Smith and Robinette cases, inspired a dissent by Mr. Justice Roberts, who has repeatedly opposed the- recent shifts in the Court’s tax attitudes* 1/ He agreed that as long-.as a transfer reserving a reverter was complete for estate tax purposes under the rule of the dis carded St, Louis Trust decisions* %J the same transfer might properly be considered a definitive taxable gift. But the Hallock decision had created a different context,:and the disappearance of a reverter was placed in the same category as a power reserved, until the instant of death, to revoke the trust or change beneficiaries* 2/ The reasoning of the Sanford case ac cordingly required the conclusion that a transfer Reserving a reverter was an.incomplete gift, Mr, Justice Roberts referred to the Court’s concern, in that case, over "the difficulties of administration and probable inequities of a contrary- decision,” and contended that the same considerations were applicable here, "Indeed,” he concluded, "a system of taxation vdrLch requires valuation of .the donor’s retained interest, in the light of the Contingen cies involved, and calculation of the value of the subsequent remainders by resort to. higher mathematics beyond the ken of the taxpayer, exhibits the artificiality of the Government’s application of the Act." 4/ : • 4 ■ - ■ ;* -4 ■ ’■ 1 ... ,,r a ' jf. ' l' ■ . ? : There is little to add, in the way- of justification or criticism, to the Court’s, disposition of the reverter problem. The main burden of Mr* Justice Black’s opinions — that a gift is comple ted when economic con trol is surrendered by the donor ^ is adequately borne* Certainly .this concept of a transfer by gift is fundamental, once any-theory of mutual exclusiveness is cast aside. It is hardly an adequate-response to say that the • Hallock-opinion unqualifiedly holds that a reverter renders a transfer incomplete,^and that the Court blows either hot or cold to suit the re quirements of taxability, The estate tax reaches various transfers which are ordinarily -regarded as completed gifts, but are nevertheless treated as incomplete, until death overtakes the grantor, 5/ .Common examples’are an ir revocable transfer reserving .-a life estate in the grantor, 6/ a trust 1/ See his dissenting opinions in-Wisconsin’v, J„ Cc Penney Co,, 311 U,S*~ 435, 446 (.1940); Whitney v0 State Tax Commission, 309 U,S* 530, 542 (1940); Helvering vj Clifford, 309 U,S<, 331, 332 (1940); -Helvering v* Hallock, 3p9 UoS, 106,. 123 (1940.) 1 Deputy v* duPont, .308 U.S, 422, 499 ' (1940); Higgins v, Smith, 308 U.S. 473* 420 (1940)$ United- S*tates v, .Jacobs, 306 U.S0:363, 373 (1939); ^elch v* Henry, 305 U'.S. 134* 151 (1932)., But compare his .opinion in Helvering v. Bruun, 309 U„Sc 461(1940), 2/ Helvering. v P S t L o u i s Union-Trust CoP, 296 U*S„ 39 (1935); Becker Vf • St, Louis Union Trust Co,, 296 U.S, 42 (1935)* 3/ Compare the dissenting opinion in Helvering v, St,* Louis Union Trust Co,, 296 U f5,, 39, 47 (1935), * y 318 U.S,1'at 183, $ . 5/ See Higgins v. Comm., 129 F, (2d) 237, 241 (CfC.A. Ist,-1942)> cert* denied, 317 U.S, 658 (1942), 6/ See 2 Paul, Federal Estate and Gift Taxation (1942) §17,12. - 8revocable by the grantor in conjunction with persons possessing a substan tial adverse interest, l/ and a tenancy by the entirety created by-one of the spouses, 2/ A transfer subject to a reverter is of a similar character,3/ The theory that the estate and gift tax concepts of completeness are coter- ~ minous would simply wipe the gift tax off the books unless the grantor re leased all possible estate tax contacts with the property. In other words, Congress would be presumed to have intended that only a transfer in contem plation of death should feel both the estate and gift tax, 4/ \Mr, Justice Black*s theory that the gift tax is a form of down-payment or security with respect to the estate tax seems to be a much more logical deduction from the present system of transfer taxation. For if the drafters contemplated such sharply drawn lines of incidence, except for an isolated blur, it is strange that they remained silent when it was so easy to be explicit, 5/ Mr. Justice Roberts’ emphasis upon the intricacies of valuation does not present a formidable objection to tax. Even he admits that a transfer reserving a reversionary interest ?Jould probably be .subject to gift tax if the Hallock decision had never arrived on the scene, 6/ In that event, the same valuation difficulties would obviously confront taxpayers. Equally complex valuation problems have not frustrated the administration of the estate tax, 7/ The erection, of tax results, in the present case, upon the 1/ 2/ 3/ y 5/ 6/ 7/ See Id, §17.09. See id. §16.09. MWe mast put to one side questions that arise under sections of the estate tax law other than §302 (c) /now §811 ( c — sections, that is, relating to transfers taking place at death. Section 302 (c) deals with property not technically passing at death but with interests theretofore created, The taxable event is a transfer inter vivos, Bat the measure of the tax is the.value of the transferred property at the time when death brings it into enjoyment,1* Helvering v. Hallock, 309 U.S. 106, 110-11 (1.940). See Higgins v. Comm-., 129 F. (2d) 237, 241 (C^C.A. 1st, 1942), cert, denied, 317 U.S. 658 (1942). Cf, Nossaman, Taxes on Gifts Subject to Contingencies (1941) 20 Taxes 650, 694. Cf. Comm. v. Beck’s Estate, 129 F. (2d) 243* 245 (C.C.A. 2d, 1942), 318 U.S, at 182. Compare, e.g., the computation required under section 812 (d), where taxes are payable out of the property bequeathed to charity* See Harrison v. Northern Trust Co., 317 U.S. 476, 481 (1942). The courts themselves are not always hesitant in adding new burdens of valuation. See Helvering v. Safe Deposit & Trust Co. of Baltimore, 316 U.S. 56 (1942); Comm, v. State Street Trust Co., 128 F. (2d) 618^ (C.C.A, 1st, 1942); Central Hanover Bank & Trust Co. v. Comm., 118 F.^ (2d) 270 (C.C.A. 2d, 1941). -9basis of the valuation factor, would lead to extremely anomalous results# If a grantor, for example, established a trust reserving a life estate to himself, he would be liable for a gift tax on the remainder, but if he transferred away, the entire property except for an extremely remote contin gency, he would be free of gift tax on the same interest# ' Another objection apparently.made by Mr. Justice Roberts, by reference to the Sanford opinion, is that the.beneficiaries may be required to pay tax, in satisfaction of their secondary liability, despite the fact that they may be deprived of their benefits under-the transfer# But the same unfortunate contingency besets all trusts containing a complex of varied interests even though the grantor, has relinquished all ’’strings” however remote. Mr, Justice Roberts apparently concedes, though, that such a transfer would be a taxable gift# 1/ Any other result would absolve from tax the very type of transfer intended to be reached by Congress# 2/ The unhappy possibilities foreseen by the justice seem to be equally insignifi cant where the grantor has a contingent reversionary interest# Chief Justice Stone had exaggerated administrative difficulties and possible inequities in the Sanford case, 3/ and the Court conducted an orderly retreat from the un necessary and untenable positions occupied in that case. Even in tax law it, is an ill wind that blows no good# As a result of the Hallock decision many grantors having remote reversionary interests in trusts created many years ago were anxious to get rid of them. The extent of the cost in gift tax, however, was not clear# Thus the tax might be con fined to the value of the reversionary interest at the moment of surrender 4/ or it might embrace the entire property on the ground that the original transfer was not complete until thq release of the reversionary interest# The latter alternative would flow from Mr# Justice Roberts’ position# In view of the Smith and Robinette decisions the gift tax would be imposed only upon the value of the reverter when relinquished or transferred, since other property interests composing the trust are subject to tax at the date of the initial transfer. 5/ The gift tax cost entailed by an es.cape from the tentacles of the Hallock decision may thus be exceedingly small, 6/ 1/ Cf. E. A. Hayes, B.T.A# Memo; Op,, April 20,'1942, C.C.H# Dec. 12, 506-A. —/ H#S* at 183# Of. Goodwin v# McGowan, 47 F* Supp. 798 (-1942), where the interest of the grantor never ripened into possession but its.transfer was nevertheless subjected to gift tax# y See- Warren, Correlation of -Gift and Estate Taxes (1941) 55 Harv. L# Rev. 1,17. 4/ It is assumed that the statute of limitations as to all other interests, running from the date of creation of the trust, has expired. 5/ This result, it seems, would allow some value to escape tax# The value of the reversionary interest ordinarily declines after the date of initial transfer and the gift tax on the surrender of the reversionary interest would apparently be on the' reduced value# 6/ Even if the reverter were assigned to charity, there would probably still be a gift tax because of the uncertainties involved. But cf# Meierhof v# Higgins, 129 F. (2d) 1002 (C.C.A. 2d, 1942). - 10 - The Smith and Robinette decisions leave open at least two basic prob lems. The first involves the determination of1;whether economic control has passed out of t h e grant or, -and the second revolves about the valuation factor. In so far as the first is concerned, it is not always a simple matter to conclude that the donor has relinquished economic control. For example, the donor may provide for a return of the trust principal to him if he marries or has children. Is it correct to hold in such a case tnat control has been relinquished, subject to a provision for its return if a specified contingency occurs, or is it more appropriate to conclude that control is still retained because the occurrence of the contingency depends, to an indefinable extent, upon the donor himself? Realistically speaking, of course, one has a difficult degree question here and it is equally dif ficult to predict how the courts will react* l/ If e contingency of this character is not regarded as the'retention of control, 2/ the property would in all probability, be taxed in toto on the ground that the ^actuarial art is not prepared to cope with such contingencies. 2/ This brings us to the second important issue following in- the wake of the Smith and Robinette cases.' .* ^ The significance of the valuation factor is driven home b y the uncom fortable fact that the burden of valuation is placed upon the taxpayer, who must pay a gift tax upon the entire value if the actuarial art is not suf ficiently mature to deal with the complexities of his arrangement* 4/ Of course, the gift tax credit should -provide some consolation. 5/ At one extreme is the Smith case, w h i c h should settle in the affirmative the question whether a reversionary interest dependent upon the prior death of w 2/ 2/ Cf. Doris Bond Sherman, 41 B.T.A. 898 (1940), wherein the Board held that a power to extend the trust benefits to children born thereafter was governed by the Sanford case and that the gift was incomplete. The Supreme Court has indicated, in another connection, that the con tingency of remarriage is not the retention of control since the con sent of another party is required. Brotherhood v* Pinkston, 293 96, 100 (1934). In either event the property should be subject to estate tax* But cf. Brotherhood v. Pinkston, 293 U.S. 96 (1934); Comm, v* State Street Trust Co., 128 F# (2d) 618 (C.C.A. 1st, 19421. See, however, Charles A. E# Goodhart, T.C. Memo# Op#, June 14, 1943> C.C.H# Dec. 13, 279, holding that; a donee is not liable as transferee because his contingent interest-is too remote, for valuation# The Robinette decision is cited in support of the conclusion# Cf# Estate of Lester Field, 2 T.C* 21, 24 (1943)f one of two persons 1/ is deductible from the tax base* 2/ At the other is the Robinette decision, including the entire corpus where the reverter is affected b y the grantor^s marriage, birth o f .children,•and the childrens reaching majority, 3/ Would ,the Court include the entire corpus- i f .the contingency were solely marriage or the birth of issue? In another context the Court has been willing to evaluate the possibility of.remarriage, ij but it does not- fpllow t’hat it would be prepared to import the same method of appraisal-into the-gift'tax statute, .5/. At, any rate, it would hardly re quire a valuation of the reverter involved in- the McLean case, where the l/ In Hughes v. Comm,, 104 F. (2d) 144, 148 (C.C.A, 9th, 19397, the court indicated that the Treasury should consider actual health factors in addition to the expectancies revealed by the mortality tables. The general practice is to the contr.ary (see 2 Bonbright, Valuation of Property (1937) (1938) 47 Tale L, J. 1354, 1358, including : that-of the' Treasury, See Meierhof v, Higgins, 129 F* (2d) 1002, 1006 (C.C.A* 2d, 1942)c In view of Ithaca Trust Co* v, United States, 279 U,S, 151.(1929). events after the date of gift should not affect the valuation as of such date, based on the teachings of the mortality tables. See further Estate of Simon Guggenheim, 1 T,C,. 843 (1943)* Cf, Matter of White* 208 N.T. 64, 101 N.E. 793 (1913). But cf. Note (1938) 47 Tale L, J, 1354, 1358-9, 1381. • 2/ 3/ 4/ 5/ It is difficult to estimate the effect, in the present context, of -Helvering v®. Taylor, 293 U eS, 507 (1935), refusing to sustain a defi4ciehCy^which was ,le.rbitrary and excessive” despite the taxpayers failure to establish the correct amount of tax. -The value o f ‘the reversionary interest may depend sQlely on the grantor life expectancy. Thus in Daisy B. Plummer, 2 T.C, 263, the grantor re served a right to regain a stated portion of principal during her life time and the reverter was actuarially computed, If the entire.corpus is taxed, there is the additional question whether a release of the reversionary interest at a later date would be subject to gift tax* As a matter of justice, the tax on the initial-transfer should suffice, Brotherhood v, Pinkston, 293 U,S, 96 (1934), Cf, Matter of Rothfeld, 163"'Mis c. 11, 296 N.T. Suppf|320 (1937); see Note (1938) 47 Yale L, J, 1354, 1361, But cf. Comm. v. State Street'1Trust Co,, 128 F. (2d) 618 (C.C.A. 1st, 1942). TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE Press Service No. ? - — j) vj | If ’ - 1 U The report made to Secretary Morgenthau last March by the Committee on Intergovernmental Fiscal Relations will receive i&arj-e-r attention at the annual conference of the National Tax Association opening its business sessions in Chicago today, the Treasury has been advised* In its report, the committee, made up of leading authorities •on taxation and public finance, recommended an action program to resolve conflicts between Federal, Stat^aad local governments over taxation and to improve generally all intergovernmental fiscal relationships. A session of the National Tax Conference starting at 2:30 P.M. Sunday in the Palmer House, Chicago, will be devoted to a study of these recommendations and of a report to be made by an NTA committee on Coordination of Federal, State and Local Taxes. Speakers will include Roy Blough, Director of Tax Research, Treasury Department, and Harold M. Groves, Professor of Economics at the University of Wisconsin. Pro|*. Groves w%s a member of the Committee on Intergovernmental Fiscal Relations and served as its chief of staff. The Intergovernmental Fiscal Relations report has just been made available to the public in revised form. It was printed at the order of the Senate Finance Committee, to which "the Secretary/of the Treasury transmitted the report in accordance with a Senate /resolution authorizing the study which the committee made. The title of the printed version is ’’Federal, Statehnd Local Government Fiscal Relations”, and copies may be had frcm the Superintendent of D0cuments, G0vernment Printing Office, Washington, at 75 cents'each. 'The official designation is Senate Document 69. TREASURY .DEPARTMENT Y/ashington FOR IMMEDIATE RELEASE Saturday, November 20, 1943■« Press Service No* 39-61 The report made to'Secretary,Morgenthau last March by the Committee on Intergovernmental Fiscal Relations will receive prominent attention at the annual conference of the Rational Tax Association opening its business sessions in Chicago today, the Treasury has been advised* In its report., the committee, made up of leading author ities on taxation and public finance, recommended an action program to resolve conflicts between Federal, State and local governments over taxation and to improve generally all inter governmental fiscal relationships, A session of the National Tax Conference starting at 2?30 p.ml Sunday in the Palmer House, Chicago, will be devoted to a study of these recommendations and of a report to be made by an NTA committee, on Coordination of Federal, State and Local Taxes. Speakers will include Roy Blough, Director of Tax Research, Treasury Department, and Harold M f G-roves, Professor of Economics at the University of W i s c o n s i n P r o fessor Groves was a member of the Committee on Intergovern mental Fiscal Relations and served as its chief of staff. The Intergovernmental Fiscal Relations report has just been made avai lable to the public in revised form. It was printed at the order of the Senate Finance Committee, to which the Secretary of the Treasury transmitted the report in accordance with a Senate resolution authorizing the study which the committee made. The title of the printed version is "Federal, State and Local Government Fiscal Relations", and copies may be had from the "Superintendent of Documents, Government Printing Office, Y/ashington, at 75 cents each. The official designation is Senate Document 69,..-oOo- m - U - of Indebtedness offered, and that the market not trade in any of the marketable securities offered in the Drive* [To avoid unnecessary transfers of funds from one locality to another, the Treasury requests that all subscriptions by corporations and firms be entered and paid for through the banking institutions where funds are located. This request is made to prevent disturbance to the money market and the banking situation. The Treasury will undertake to see that statistical credit is given to any locality for such subscriptions that the corporations and firms may request; except subscriptions from insurance companies will be credited to the State of the fiome ^ffice as in the past. X [in order to help in achieving its objective of selling as many securities as possible outside of the \ banking system, the Treasury requests the cooperation of all banking institutions in declining to make specu lative loans for the purchase of Government securities. The Treasury is in favor of the banks making loans to facilitate permanent investment in Government securities*. / provided such loans are made in accord with the /oint % ^Statement issued by the National and State Bank Supervisory Authorities on November 23, 19h2. £) (Q 0 in the 2-l/U% and 2-1/2% Bends-under a formula to be announced later. The 2-1/2% Bond will be dated February 1. 19^* due March 15, 1970, callable March 15, 1965* I be issued in coupon or registered form at the option of the buyers, in denominations from $500 to $1,000,000. if? Commercial banks, which are defined for this purpose as banks accepting demand deposits^ will not be permitted I to own these bonds until I 19^» except for the limited investment of time deposits. The 2-1/M# Bond will be dated due Sept. 15, 1359 # callable Sept. 15*/ , will be issued in coupon or registered form at the option of the buyers, in denominations of $500 to $1,000,000. Commercial banks, I which are defined for this purpose as banks accepting demand deposits, will not be permitted to own these bonds } of time deposits. (The 7/8% Certificate of Indebtedness will be dated February 1, 194U, due February 1, 19^5. and will be issued in denominations of $1,000 to $1,000,000 and in coupon for® only. Treasury will request that, until after February 15, 19Uh, commercial banks not buy the 7/8% C ertificates 2 - investors * the quota for which is $g-l/2 billion. This will not preclude the acceptance of subscriptions from other non-banking investors at any time during the Drive. MI subscriptions for Savings Bonds and Savings Notes received at the Federal Reserve Banks or at the Treasury of the United States between January 1 and February 29, 19^4, will be credited to the Drive. The goal and the type of securities to be offered were determined by the Treasury after consultation with the Chairmen of the State War Finance Committees, officials of the Federal Reserve System, the American Bankers ‘Association and other investment authorities. The securities to be sold under the direction of the War Finance Committees will consist of: Series I Savings Bonds Series F and G Savings Bonds Series C Savings Motes 2-1/2# Bonds of 1965-70 2-1A # Bonds of 1956-59 7/S# Certificate of Indebtedness In view of the fact that many commercial banks accept time deposits and perform in their own communities the same functions as those performed by other savings insti tutions, the Treasury will permit such commercial banks to make a limited investment of their time deposits only PRESS RELEASE Secretary Morgenthau announced today that the Fourth War Loan Drive would start January 18* and would run until February 15# 1944. The goal has been set at $14 billion. Five and one-half billion dollars of this amount is to be raised directly from individuals. The State War Finance Committees will have the task of raising this $14 billion. These committees are being strengthened and expanded to meet the necessity of increasing the number of people who are buying War Bonds. Millions of volunteer salesmen are now ready to carry this campaign for funds to every individual investor in hoses and in plants throughout the nation. The major emphasis throughout the entire peiod of the Drive, January IS to February 15, will be placed on the quota of $5-1/2 billion for individuals. During the period from January IS to February 1 only sales to individuals will be reported by the Treasury. The report ing of sales to individuals will be supplemented starting February 1 with reports of sales to other non-banking - 2 - investors - the quota for which is $8 This will not preclude the acceptance of subscriptions fro® other non-banking investors at any time during the Drive. p U l subscriptions for Savings Bonds and Savings Notes received at the Federal Reserve Banks or at the Treasury of the United States between January 1 and February 29, I9HH, will be credited to the Drive. jThe goal and the type of securities to be offered were determined by the Treasury after consultation with the ^fhairmen of the State far finance Committees, officials of the Federal Reserve System, the American Bankers Association and other investment authorities. IS.' securities to be sold under the direction of the War Finance Committees will consist of: - Series 1 Savings Bonds Series F and G Savings Bonds Series G Savings Notes 2-1/2$ Bonds of 1965-70 / 2-1/H$ Bonds of 1956-59 7/8$ Certificate of Indebtedness j~In view of the fact that many commercial banka accept time deposits and perform in their own communities the same functions as those performed by other savings insti tutions, the Treasury will permit such commercial banks to make a limited investment of their time deposits only Cj^ ~ (Zj a (c , Secretary Morgenthau announced today that the > Fourth War Loan Drive would start January 18, and would run until February 1§, igLU. phe^goal has been set at $\kj b i M W h . Five and one-half billion dollars of this amount is to be raised directly from individuals. The State War Finance Committees will have the cbO~&, task of raising this SlH, billion « These committees are being strengthened and expanded to meet the necessity of increasing the number of people who are buying War Bonds. Millions of volunteer salesmen are now ready to carry this campaign for funds to every individual investor in homes and in plants throughout the nation. jjThe major emphasis throughout the entire peiod of the Drive^January 18 to February 157-will be placed on the quota of $5^ for individuals. During the period from January 18 to February 1 only sales to individuals will be reported by the Treasury. The report ing of sales to individuals will be supplemented starting February 1 with reports of sales to other non-banking TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Monday, November 22, 19A3._____ Press Service Ho. 39-62 Secretary Morgenthau announced today that the Fourth War Loan Drive would start January 18, and would run until February 15, 1944.* The goal has been set at 114,000,000,000. Five and one-half billioj dollars of this amount is to be raised directly from individuals* The State rrar Finance Committees will have the task of raising this $14,000,000,000. These committees are being strengthened and expanded t< meet the necessity of increasing the number of people who are buying War Bonds* Millions of volunteer salesmen are now ready to carry this campaign for funds to every individual investor in homes and in plants throughout the nation. The major emphasis throughout the entire period of the Drive - January 18 to February 15 - m i l be placed on the quota of $5,500,000,000 for individuals. During the period from January 18 to February 1 only sales to individuals will be reported by the Treasury, The reporting of sales to individual wall be supplemented starting February 1 with reports of sales to other non-banking investors - the quota for which is $8,500,000,000. This will not preclude the acceptance of subscriptions from other non-banking investors at any time during the Drive. All subscriptions for Savings Bonds and Savings Notes received at the Federal Reserve Banks or at the Treasury of the United Stages between January 1 and February 29, 1944, will be credited to the Drive, a- cd The goal and the type of securities to be offered -were determined by th Treasury after consultation with the chairmen of the State War Finance Commi tees, officials of the Federal Reserve System, the American Bankers Associati and other investment authorities. The securities to be sold under the direction of the War Finance Commit tees will consist of: Series E Savings Bonds Series F and G Savings Bonds Series C Savings Notes 2-1/2$ Bonds of 1965-70 2-1 / 4$ 'nonds of 1956-59 7/8$ Certificate of Indebtedness In view of the fact that many commercial banks accent time denosits and - 2 - to make a limited investment of their time deposits only in the 2-1/4# and 2-1/2# Bonds under a formula to be announced iater. The 2-1/2# Bond will be dated February 1, 1944, due March 15, 1970, callable March 15, 1965, and m i l be issued in coupon or registered form at the option of the buyers, in denominations from $500 to $1,000,000. Com mercial banks, which are defined for this purpose as banks accepting demand deposits, will hot be permitted to own these bonds until February 1, 1954, except for the limited investment of time deposits. The 2-1/4# Bond m i l be dated February 1, 1944, due Sept. 15, 1959, callable Sept* 15, 1956, and m i l be issued in coupon or registered form at the option of the buyers, in denominations of $500 to $1,000,000. Commercial banks, which are defined for this purpose as banks accepting demand deposits, will not be permitted to own these bonds until September 15, 1946, except for the limited investment of time deposits. The 7/8# Certificate of Indebtedness will be dated February 1, 1944, 1 due February 1, 1945, and will be issued in denominations of $1,000 to $1,000,000 and in coupon form only. The Treasury will request that, until after February 15, 1944, com mercial banks not buy the 7/8# Certificates of Indebtedness offered, and that the market not trade in any of the marketable securities offered in the Drive, To avoid unnecessary transfers of funds from one locality to another, the Treasury requests that all subscriptions by corporations and firms be entered and paid for through the banking institutions where funds are located. This request is made to prevent disturbance to the money market and the bank ing situation. The Treasury will undertake to see that statistical credit is given to any locality for such subscriptions that the corporations and firms may request; except subscriptions from insurance companies will be credited to the State of the home office as in the past. In order to help in achieving its objective of selling as many securi ties as possible outside of the banking system, the Treasury requests the cooperation of all banking institutions in declining to make speculative loans for the purchase of Government securities. The Treasury is in favor of the banks making loans to facilitate permanent investment in Government securities provided such loans are made in accord with the joint statement issued by the National and State Bank Supervisory Authorities on November 23, 1942. o 0 0 TREASURY DEPARTMENT Washington -$ FOR RELEASE, MORNING NEWSPAPERS, Tuesday, November 23» 1943» Press Service \ ' 1 The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts of 90-day Treasury bills to be dated November 26, 1943, and to mature February 24, 1944, which were offered on November 19, were opened at the Federal Reserve Banks on November 22. The details of this issue are as follows: Total applied for - $1,621,636,000 Total accepted - 1,003,704,000 Average price (includes $73,132,000 entered on a fixedprice basis at 99.905 and accepted in full) - 99-906/Equivalent rate of discount approx. 0-376% per annum Range of accepted competitive bids: High Low „ - 99.910 Equivalent rate of discount approx. 0.360% per annum - 99.906 « « h » n o.376% w M (63 percent of the amount bid for at the low price was accepted) Federal Reserve District_______ Total Applied for______ Total Accepted______ Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco # $ TOTAL 48,235,000 1,123,203,000 28,815,000 49,146,000 18,275,000 31,362,000 131,520,000 19,079,000 7,825,000 23,581,000 ' 20,320,000 119.775,000 $1,621,636,000 34,543,000 683,667,000 20,216,000 35,725,000 15,615,000 14,525,000 74,613,000 10,430,000 7 441,000 20,399,000 10,600,000 80*925.000 , $1,008,704,000 TREASURY DEPARTMENT V/ashington FOR RELEASE, MORNING- NEWSPAPERS, Tuesday, November 23. 1943. 11-22-43 ’ Press Service No* The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts of 90-day Treasury bills to be dated November 26, 1943. and to mature February 24, 1944, which were offered on November 19, were opened at the Fed eral Reserve Banks on November 22. The details of this issue are as follows: Total applied for - $1,621,636,000 Total accepted - 1,008,704,000 (includes $78,182,000 . entered on a fixed-price basis at 99.905 and accepted in full) Average price - 99.906/Equivalent rate of discount approx. 0.376/a per annum Range of accepted competitive bids: High Pew - 99*910 0.360$ - 9 9 .9 0 6 0.376$ Equivalent rate of discount approx, per annum Equivalent rate of discount approx. per annum (63 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis $ # Minneapolis Kansas City Dallas San Francisco TOTAL 48,235,000 1 , 1 2 3 , 203,000 2 8 , 815,000 . 49.146.000 18 275.000 31.362.000 131.520.000 19.079.000 34,548,000 683,567,000 20,2X6,000 . 23.581.000 20.820.000 119.775.000 35.725.000 15 615.000 14.525.000 74.613.000 10.430.000 7,441,000 20.399.000 10.600.000 80,925.000 $1,621,636,000 $1,008,704,000 7,825,000 oQo trkasuht depabteekt Washington fo e immediate w m kS E , m rnm Service Tuesday. November 2 3. 1943. ^ f / Secretary df the Treasury Morgenthau announced today that the subscription books for the current offering of 7/8 percent Treasury Certificates of Indebtedness of Series 0-1944* ©pen to the holders of Treasury Certificates of Indebtedness of Series S-1943 maturing December 1, 1943* will close at the close of business tomorrow, Hoes®ber 24* Subscriptions addressed to a Federal Reserve Bank o r Branch, or to the Treasury Department, and placed in the nail before 12 o'clock isidnight, Wednesday, Horeisber 24, will be considered as hairing been ‘entered before the d o s e of the subscription books. Announcement of t h e amount of subscriptions a n d their division among the several Federal Reserve Districts w i l l be m d e 0 0 c? later. TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, Tuesday^ November 25, 1943. Press Service No. 39-64 Secretary of the Treasury Morgenthau announced today that the subscription books for the current offering of 7/8 percent Treasury Certificates of Indebtedness of Series G-I9 4 4 , open to the holders of Treasury Certificates of Indebtedness of Series B-1943 maturing December 1, 1943, will close at the close of business tomorrow, November 24. Subscriptions addressed to a Federal Reserve Bank or Branch, or to the Treasury Department, and placed in the mail before 12 o ’clock midnight, Wednesday, November 24, will be considered as having been entered before the close of the subscription books. Announcement of the amount of subscriptions and their division among the several Federal Reserve Districts will be made later. -0 O 0 - November 23, 194-3 STATEMENT BT SEC RETART MORGENTHA.U: When the Treasury made public the tentative proposal for an International Stabilization Fund, I said that we were studying means of encouraging and facilitating international investment for reconstruc tion and development* A few weeks ago I appeared before the Congressional Committees and summarized for them the principles which we believe should guide us in the establishment of a United Nations Bank for Reconstruction and Development© The technical staffs of the Treasury and other interested departments and agencies have now prepared a tentative proposal for such a Bank0 This tentative proposal is being sent to the Finance Ministers of the United Nations and the countries associated with them, for consideration and for study fcy their technical staffs© The Finance Ministers have been informed that this tentative proposal does not represent the official views of this Government but it is an indication of the views held by our technical staffs© We are releasing for publication the tentative proposal for a United Nations Bank for Reconstruction and Development and a covering memorandum on the problem of international investment* These two documents, sent to the Finance Ministers, are being released to make them available for public discussion© It is our intention to discuss the tentative proposal with business, banking and other interested groups in this country© The technical staffs of the Treasury and other departments of this Government are of the opinion that an International Stabilization Fund and a Bank for Reconstruction and Development could help provide a sound financial foundation on which private enterprise can build a prosperous world economy* A United Nations Bank For Reconstruction and Development One of the important international economic and financial problems which will confront the United Nations at the end of the war will be the unprecedented need for foreign capital. In the areas devastated by war or plundered and ravaged by the enemy, factories and mines, public utili ties and railroads, public buildings and public works will have to be re* paired or restored. In all of the United Nations, industries now produc ing war goods will require capital for reconversion to peacetime production* Finally, in many areas of the world, large investment will be needed for industrial/ agricultural and commercial development. Countries whose productive capacity has been seriously impaired by war will find-that their industries cannot provide the capital goods and their people cannot provide the savings they require for reconstruction. Most non-industrial countries will of necessity be dependent upon foreign invest*ment to acquire the funds for the purchase of machinery, equipment, and other capital goods for development# And .even in those countries where a considerable part of the need for capital can be met locally, there will be some need for foreign capital to supplement the funds that can be raised at home. With the return of an assured peace, private financial agencies may be expected to supply most of the needed short-term foreign capital# When the shipping situation is improved and peacetime industry' here and abroad has recovered, many business firms will be eager to sell their products abroad on reasonable and even generous credit terms. And banks likewise will hasten to expand their foreign business, reopening and establishing branches abroad, and assisting in the financing of international trade. It is not unreasonable to hope that with the return of peace there will afso be a gradual resumption of long-term international investment, particularly in the form of the establishment of foreign "branch plants and the acquisition of shares in established foreign enterprises. With the groY/th of confidence in monetary stability, foreign investments m i l gradually assume the form of publicly floated loans to governments and municipalities, and to public utilities and other industries. This flow of private capital to war stricken countries will be en couraged by an adequate program of international relief and rehabilitation which helps to quickly restore to a working basis the economic life of those countries. Another, and possibly even more important, stimulant to foreign investments, Y/ould be the existence of an international agency, such as the International Stabilization Fund, designed to promote stability of foreign exchange rates and freedom from restrictions on the vathdrawal of earnings. Such an agency could do much to enhance the attractiveness of foreign investments* - 2 - ■'■Tiile there will undoubtedly be substantial amounts of long-term foreign investment even in the early postv/ar period, the flow of capital to countries greatly in need of foreign capital is likely to be inadequate for many years to come* Private capital will understandingly hesitate to venture abroad in anything like the required volume* It has suffered too many losses from war, from depreciating currencies, from exchange restric tions, and from business failures and defaults* There is little evidence to justify the hope that in the years immediately after the war investors will lend the large sums that can be economically used in foreign countries* Obviously, it would be desirable to encourage in every way, the pro** vision of capital for productive purposes through the usual private invest ment channels, and to the extent that private investment is inadequate, to provide supplemental, facilities* The problem is fundamentally an inter national problem and only an international governmental agency equipped with broad powers and large resources can effectively encourage private capital to flow abroad in adequate amounts and provide a part of the capital n o t .otherwise available. The primary aim of such an agency should be to encourage private capital to go abroad for productive investment by sharing the risks of private investors and by participating with private investors in large ventures* The provision of some of the capital needed for reconstruction and development, where private-capital is unable to take the risk, is intended to remain secondary in the operations of such an agency* It should, of course, scrupulously avoid undertaking loans that private in vestors are willing to make on reasonable terms. It should perform only that part of the task which private capital cannot do alone. The need for foreign capital will be so great and the provision of adequate capital so important that it would be extremely shortsighted to neglect this urgent international problem. If private capital should suf fice there would then be little for an international agency to do, beyond encouraging private investment. If, however, private capital were to prove unable fully to meet the needs, then such an international agency would be able to fill the breach until private capital again flowed freely and the demand for foreign capital throughout the world became less urgent.’ It is imperative that we recognize that the investment of productive capital in undeveloped and in capital needy countries means not only that those countries will be able to supply at lower costs more of the goods the world needs, but that they wii1 at the same time become better markets for the world’s goods. By investing in countries in need of capital, the lend ing countries, therefore, help themselves as well as the borrowing countries. If the capital made available to foreign countries vijquld not ~ 3 - otherwise have been currently employed, and if it is used for productive purposes, then the whole world is truly the gainer* Foreign trade everywhere will be increased,* the real cost of producing the goods the world consumes will be lowered; and the economic well-being of the borrowing and lending countries will be raised* One great contribution that the United Nations can make to sustained peace and world-wide prosperity is to make certain that adequate capital is available on reasonable terms for productive uses in capital-poor countries* With abundant capital, the devastated countries can move steadily toward rehabilitation and a constantly improving standard of liv ing. Nothing could be more conducive to political stability and to inter national collaboration* Without adequate supplies of capital, however, recovery in Europe and Asia m i l be slow and sporadic, and economic dis content and international bitterness will in time assume disturbing pro portions, To spend hundreds of billions to fight a war thrust upon us, and then to balk at investing a few billions to help assure peace and prosperity would appear to be a singularly unwise policy. Accompanying this memorandum is a draft proposal for a Bank for Reconstruction and Development of the United and Associated Nations* The draft was prepared by the technical staff of the'United States Treasury in consultation with the technical staffs of other department§^of this Government. The proposal has neither official status nor the approval of any department of this Government* It is in outline form touching on the more important points and is intended only to stimulate thoughtful dis cussion of the problem in the hope that such discussion will call forth constructive criticism, suggestions, and alternative proposals for pos sible later submission to the appropriate authorities* and to the public* A United Nations Bank for Reconstruction and Development is proposed as another international agency needed to help attain and maintainworld wide prosperity after the war* It is designed as a companion agency to an International Stabilization Fund. Each agency could stand and function effectively without the other; but the establishment of such a Bank mould make easier the task of an International Stabilization Fund, and the suc cessful operation of an International Stabilization Fund woutd enhance the effectiveness of the Bank. Together, the two institutions could help provide a sound financial foundation on which private enterprise can build a prosperous world economy. Henry Morgenthau, Jr* Secretary of the Treasury* Washington, D* C. November, 1943. U? $.* Treasury November, 19*+3 preliminary Draft Outline of a proposal for A United nations Bank For Reconstruction and Development Preamble 1* The provision of foreign capital will be one of the important international economic and financial problems of the postwar period. Many countries will require capital for reconstruction, for the conversion of their industries to peacetime needs, and for the development of their productive resources* Others will find that foreign investment provides a growing market for their goods. Sound international invest ment can be of immense benefit to the lending as. well as to the borrowing countries* 2. Even in the ear^y ;posbwar. yeans It may be hoped that a considerable part for international investment will be provided % r 6ugh private investment chan nels* It will undoubtedly bq. necessary, however, to encour age private investment by assuming some of the risks that will be especially large immediately after the war and to supple ment private investment with capital provided through inter na ti onal cooperation* The United nations Bank for Recon struction and Development Is proposed as a permanent institu tion to encourage and facilitate international investment for sound and productive purposes. 3* The Bank is intended to cooperate with private finan cial agencies in making available long-term capital for recon struction and development and to supplement such investment where private agencies are unable to meet fully the legitimate needs for capital for productive purposes. The Bank would make no loans or investments that could be secured from pri vate investors on reasonable terms? The principal function of the Bank would be to guarantee and participate in loans made by private investment agencies and to lend directly from its own resources whatever additional capital may be needed. The facilities of the Bank would be available only for approved governmental and industrial projects which have been guaran teed by national governments. Operating under these princi ples, the Bank should be a powerful factor in encouraging the provision of private capital for international investment. \ - 2 - H. By making certain that capital is available for producf i ^ d h s e s 'oncreasonable terms, 'the Bank'can’make ah im portant ;;:contrihutioH"-’to‘-'enduring peace'and'prdSpe^ity.' With "adequate-’Capital/:cdunthies affected'by”the war can move steadily;toward‘reconstruction, and the newer countries can uhdertaka'the-ecoiiomic development of which 'they-are capable. International investment for these purposes'Cdn'b^ a signifi cant factor in expanding trade and in helping to maintain af,Hi'gb ley4l' df-business activity'"throughout -the world. }'■'?' . "IV The purposes of t h e ‘Bank 1. To assist in the reconstruction and development of member'countries by booperating/with private.financial ''agencies' -in. the provision Of capital’.for. sound and ’• ' • constructive international' investment. ■ ; 2. 'To provide Capital' for-reconstruction arid-'(development, under conditions''Which will amply safeguard the Bank’s 'funds/ when-private financial agencies'-are unable to supply the'-'needed'capital for -such purposes on reason-? _able terms consistent with the borrowing policies of member countries. ••i; y-.-. •• ..y-; 3* •To facilitate a rapid-and smooth' transition from a wartime'economy'to;:a peacetime"economy by increasing the flow o f ’international investment, ■'and thus to ,help ■ ^y-avpid serious''disruption of the'economic "life of mem•’ bei•Countries* •••. ~A To assist in raising the productivity of member countries • by Helping to make available through international col• laboration long-term capital for-the sound development of product ive'resources'. ’. 5* To-promote the long-range balanced growth-of international • • trade among member countries* ‘ * IT> "Capital Structure of the ‘Bank /• $10 billion consisting of ‘shares -having a par ‘value equal to $100,000* 2* CThe' shares of the Bank shall be non-transferable, nonassessable, ‘and non-taxable. The' liability on shares ’ shall be limited to the unpaid portion of the subscrip tion price, ' ' ■ ;T ' -33* EaOfr-government which is a member of the International * 'Stabilization Fund'shall subscribe- to a-number’-of shares ' y to be determined by an agreed upon formula, The formula shall take into account such relevant data as the national income arid the international trade of the mem ber couhtry. 1) Such a formula woujid make the subscription of the United States approximately one-third of the total. 4* payments on subscriptions to the shares of the Bank shall be made as follow^;. "a, b. The initial payment of each member country shall be 20 percent of its subscription, some portion of which (not to exceed- 20 perc'ent) shall be in gold and the remainder in local currency. The proportions to be, paid.in gold and local currency shall be graduated according to ek agreed, .upon schedule which" shall take 'into account t h e .adequacy of .the gold and' free foreign .exchange holdings' pf 'dach member- country. The member countries shall 'make the initial payments within '$0 days after the date set for the ; operations' of the Bank to begin. 'The remainder ' of their respective- •subscriptions shall be paid in such amounts' and'at such times as the Board of Directors may determine, but ■not more than 20 percent of the subscription may be called in any one. year,. c. Calls for further'payment on subscriptions shall be Uniform on all shares, and no calls shall be made unless funds are needed fo'r the operations of the Bank. The proportion of subsequent pay‘ ments to be made in gold shall be determined by the schedule irt iT-U-a-as it applies to each mem-* ber country at the time of each call. 5. A substantial part- Of the subscribed-capital of the Bank shall be reserved in the form of unpaid sub-* scriptions as a surety'fund for the securities guaran teed by the Bank or issued by the Bank. 6* When the cash resources of the Bank are substantially in excess of prospective needs, the Board m a y return, subject to future call, uniform proportions of the sub scriptions. When the local currency holdings'of the Bank exceed 20 percent of the subscription of any member country, the Board may arrange to repurchase with local currency some of the shares held by such a country. - k - 7* Each member country agrees to repurchase each year its lbbai^cu^rihc^ held by the Bank amounting to not more t h a n '-2''percent; of its paid subscription, paying for it with §9 id; 'provided, ‘ however, that» a* ‘ b, c. ^Hfs reddirement may be generally suspended for any yeiar:by a ‘three-fourths vote of the Board, 1Tb country shall be required to repurchase local currency ih any given year in excess of one-half of the addition to its official holdings of gold during the preceding year * The obligation of a member country to repurchase it is local currency shall be limited to the amount of the local currency paid on its subscription, 8* All member countries agree that all of the local cur rency holdings and other assets of the Bank located in their countries shall be free from any special restric tions" as to their use, except such restrictions as are consented to by the Bank,, and subject to IV-13,. below, 9. The resources and the facilities of the Bank shall be used exclusively for the benefit of member countries. III, The International Monetary Unit 1, The monetary unit of the Bank shall be the TJnitas of the International Stabilization Fund (137-1/7 grains of find gold, that is,, equivalent to $10 U*S.), 2* The Bank shall keep its accounts in terms of unitas. The local currency assets of the Bank are to be guaranteed against any depreciation in their value in terms of unitas* IV* 1, Powers and Operations To achieve the purposes stated in Section I, the Bank may guarantee, participate in, or make loans to any member Country and through the government of such country to any of its political subdivisions or to business or industrial enterprises therein under con ditions provided below. a. The payment of interest and principal is fully guaranteed by the national government. b. The borrower is otherwise unable to funds from other sources, even with government's guaranty of repayment, ditions which in the opinion of the reasonable. secure the the national under con Bank are .5 - c0 A cbmpetent'committee has made a careful study » ’ of the merit3' of 'the project or the program and, in a;written report, Concludes that the loan would serve directly or 'indirectly t o •raise-' the productivity of the borrowing country and that ■ the 'prospects' 'are favorable' to the servicing of *• the'loan0 The majority of the committee making the report shall consist of members of the tech— • ’ • nical staff of the Bank* •The committee shall in■ ‘ elude an expert selected by the country requesting • ' the loan ¥rho;may or may not be a member of the technical staff of .the Bank* 'dV • The Bank shall make arrangements to assure-the use of the proceeds of''any loan-which it guar•'antees, participates in', or makes, for the pur poses for which the loan was approved* e * •;The Bank shall guarantee, participate in or make ’• ■loans only at reasonable.'fates of interest with a schedule of'repayment, appropriate to the 1 ; ' *. .character ■of -the -project and the -balance of pay ments prospects of the country,of the borrower* ■” 2 % >&£! decordance* w ith the ■provisions in IV-1, above, t he Bank may guarantee in whole or in part loans made by private investors provided further: . a* The rate of interest and other conditions of the loan are'reasonable* " • . * b*' The'Bank is compensated, for its jrisk in guaranteeing the loan0 * Tlie Bank may participate in loans .placed through the usual investment channels, provided all the' conditions listed under IV*-1 above are met except that the "rate of interest may be higher than if the loans were guaranteed by the Banko *0 ', M * -The Bank may encourage and facilitate international . investment in equity, securities' by securing .the guarantee of governments o f conversion into, foreign exchange of the current earnings of such foreign held investments* In promoting this objective the^ Bank may also participate in such investments, but its aggregate participation in such equity securities shall not exceed 10 percent of its paid in capitalo . " > ' ■„- 6 - 5* - The Bank-may-publicly offer any securities- it has « previously acquired© To facilitate-the’placing of such securities, the Bank may, in its discretion, guarantee them© 6© The Bank shall make no loans or investments that can be placed through the usual private investment .channels on reasonable terms© The Bank shall by regulation prescribe procedure for its operations t h a t - m i l assure the appli^ cation of this-principle© 7o The Bank shall impose no condition upon a loan as to the particular member country in which the .proceeds of the loan must-be spent j provided, however, that, the proceeds of a loan may not be spent in any country which is not a member countxy without the approval of the Bank© So The Bank in making loans shall provide that: a0 The foreign exchange in connection with the project or program shall be provided by the ....Bank in the currencies of the. countries in which the proceeds of the loan will be spent and only with the approval of such countries© bo The local currency needs in connection with the project shall be largely financed locally without the assistance of the Banko Co In special circumstances, where the Bank con siders that the local part of any project cannot be financed at home except on very un reasonable terms, it can lend that portion to the borrower in local currency© , , d© i/i/here the developmental program will give rise to an increased need for foreign exchange, for . purposes not directly needed for.that program yet resulting from the program, the Bank will provide an appropriate part of the loan in gold or desired foreign exchange© ~*9o When a loan is made by the Bank it shall credit, the account of the borrower with the. amount of the loan© Payment shall be made from this account to meet { drafts covering audited expenses© . - 7 - 10© Loans participated in or made by the Bank shall contain the following payment provisions; a«, Payment of interest due on loans shall be made in currencies acceptable to the Bank or in gold*, Interest will be payable only on amounts withdrawn© b0 Payment on account of principal of a loan shall be in currencies acceptable to the Bank or in gold© If the Bank and the borrower should so agree at the. time a loan is made, payment on principal may be in gold, or at the option of the borrower, in the currency actually borrowed0 Co In event of an acute exchange stringency the Bank may in its judgment accept for periods not exceeding 3 years at a time the payments of interest and principal in local currency® The Bank shall arrange with the borrowing country for the repurchase of such local cur-rrency over a period of years on appropriate terms that safeguard the value of the Bank *s holdings of such currency0 do Payments of interest and principal, whether made in member currencies or in gold, must be equivalent to the unitas value of the loan and of the contractual interest thereon® llo The Bank may levy a charge against the borrower for its expenses in investigating any loan placed, guaranteed, participated in, or made in whole or in part by the Bank© 12© The. Bank may guarantee, participate in, or make loans to international governmental agencies for objectives consonant vdth the purposes of the Bank, provided that one-half of the participants in the international agencies are members of the Bank© 13© In considering any application to guarantee, participate in, or make a loan to a member country, the Bank shall give due regard to the effect of such a loan on business and financial conditions in the country in which the loan is to he spent, and shall accordingly obtain the consent of the country affected© ~ 8,- 14-0 15. At the request of the countries in which portions of the loan, are spent, the Bank Yd 11 repurchase for gold or needed foreign exchange a part of the expenditures in the currencies of those countries made by the borrower from the proceeds of the loan0 With the approval of the representatives of the governments of the member countries involved, the Bank may engage in the' following operations: a© It may issue, buy' or sell, pledge, or discount any of its own securities and obligations, or securities and obliga tions taken from its portfolio, or secur ities which it has guaranteed© b© It may borrow from any member governments, fiscal a g e n q i e s , central banks, stabilization funds, private financial institutions in member countries, or from international finan cial agencies© c© 16© It may buy or sell foreign exchange, after consultation with the. International Stabili* zatioh Fund, where such transactions are necessary in connection with its operations© The .Bank may act as agent or correspondent for the governments of member countries,, their central banks, stabilization funds and fiscal urgencies, and for international financial'institutions. The B a n k ‘may act as trustee, registrar or agent in connection Y d t h loans guaranteed, participated in, made, or placed through the Bank© 17© Except as otherwise indicated the Bank shall deal only Y d t h or through: , a 0 .The governments of member countries, their central banks,■stabilization, funds and fiscal agencies© b0 The International Stabilization Fund and any other international ^financial agencies owned predominantly by member governments© The Bank may, nevertheless, W i t h the approval of the member of the Board representing the government of the country concerned deal Ydth the public or institutions of member countries in its (the Bank*s) oym securities or securities Which it has guaranteed© — 9 - 18. If the Rink shall declare any country as suspended from membership* the member governments and their agencies agree not to extend any financial assistance to that country without the approval of the Bank until the country has been restored, to membership* 19* The Bank and its officers shall scrupulously avoid interference in the political affairs of any member country* This provision shall not limit the right of an officer of the Bank to participate in the political life of his own country* The Bank shall not be influenced in its decisions with respect to applications for loans by the political character of the government of the country requesting a loano Only economic considerations shall be relevant to the Bankfs decisions* V* 1. Management The administration of the Bank shall be vested in a Board of Directors composed of one director and one alternate appointed by edph member government in a manner to be determined by it* The director arid alternate shall serve for a period of three years, subject to the pleasure of their government* Directors and alternates may be reappointed* 2* Voting by the Board shall be as follows: a* The director or alternate of each member country shall be entitled to cast 1,000 votes plus one vote for each share of stock held* Thus a government owning one share shall cast 1,001 votes, while a government having 1,000 shares shall cast 2,000 votes* b* No country shall cast more than 25 percent of the aggregate votes* c* Except where otherwise provided, decisions of the Board of Directors shall be by simple majority of the votes cast, each member of the Board casting the votes allotted to his govern ment* When deemed to b e in tire best interests of the Bank, decisions of the Board may be made, without a meeting, by polling the directors on specific questions submitted to them in such manner as the Board shall by regulation provide* ..* ,, ’ . IQ w The Board of Directors shall' select a- President' of1 the Bank, who 'Shall be the ^chief of- the-operating staff of the Bank and ex-officio a member 'of -the Board, and one or more vice presidents, Slie President .and V i c e -presi dents of'-the Bank* shall(hold office for four years, Shall b e ’eligible for reelect,ion ,.;and ..may. be removed for cause'at any time %■ the Board. i:The. staff of the .B a n k 'shall be selected 'in accordance with regulations established by the Board of Directors : .The'. 'Board of Directors shall appoint.from.among its members, -an Executive Committee ’of: not more'than nine members. The President of the Bank shall be; ah exOfficio niember of the .Executtve 0ommi-ttee,. The Executive Committee shall be continuously' avail able at the head office of the' Bank and, shall exer-rcise the authority delegated to it by the. Board, In the absence o f any member of the Executive Committee, his alternate on the Board shall .-act in his place. Members’of. the Executive Committee shall receive ap propriate .remuneration, ■ • '• The Board of Directors shall select on Advisory Council of seven members. The Council shall advise with the-Board and the'officers of the. Bank "on mat ters of general policy. The Council shall meet annually and on such other occasions as the Board may request. The members of the Advisory Council shall be selected from men of outstanding ability, but not more than one member shall be selected from the same* country. They shall serve for two years, and the term of any member may be renewed. Members of the Council shall be paid their expenses and a remuneration to be fixed by the -Board, The Board of Directors may appoint such other com mittees as it finds necessary for the work of the Bank. It .may also appoint advisory committees chosen wholly or partially from persons not regularly em^ ployed by the Bank. The Board of Directors may at any meeting authorize any officers or committees of the Bank to exercise any specified powers of the Board except the power to mak e < guarantee or participate in loans. Such powers shall be exercised in a manner consistent with the general policies and practices of the Board. - u - The Board may by a three-fourths vote delegate to the Executive Committee the power to make, guarantee or participate in loans in such amounts as may "be fixed by the Board, In: passing upon amplications for loans, the Executive Committee shall act under the requirements specified for each-type of loan. 8. A member country failing ,jto meet-its financial obli'gations to the Bank may be declared in default and it may be suspended from membership during the period of its default provided a -majority of the member countries : • so decide. While undor suspension, the country .shall *be denied the privileges of membership, but shall be subject to the obligations of membership. At the end of one year the country shall be automatically, dropped from membership in the Bank unless it has been restored to good standing by.a majority of the member countries. If a member count ry elects to vithdraw or is dropped from the Bank its shares 'of stock shall,, if the Bank has a'surplus, be repurchased at the. price paid,. If the B a n k ’s books show a loSsV-such country shall bear a pro portionate sharb of the 16ss..The Bank shall have 5 years in which to liquidate its., obligations to a member withdrawing or dropped .from the Bank5 . „ Any member country that withdraws or is dropped from, the International Stabilization Bund, shall relinquish its membership in the Bank unless three-fourths. of-th£ member votes favor its remaining as a member, . 9. 10. The yearly net profits shall be applied as follows: a. All profits shall be distributed in proportion to shares held, except that one-fourth of the - . profits shall be applied to surplus until the surplus equals 20 percent of the capital, b. Profits shall be payable in a country's local currency, or in gold at the option of the Bank. The Bank' shall collect and make available to member countries and to the International Stabilization Bund financial and economic information, and reports re lating to the operations of the Bank. countries shall furnish the Bank with all information and data, that- would facilitate the operations of the Bank. Member -oOo- POE IMMEDIATE EELEASE, November 23» 1943 The Bureau of Customs announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1, 1943, provided for in the Inter-American Coffee Agreement, proclaimed by the President on April 15* 1941* as follows: Country of Production * • : : t « Quota Quantity (Pounds) Xj : Authorized for entry : for consumption f * ♦ « _ lAs of (Date) : (Pounds) Signatory Countries: Brazil Colombia Costa Eica Cuba Dominican Eepublic Ecuador El Salvador Guatemala Haiti Honduras Mexico Hicaragua Peru Venezuela 1*353,183,480 458,336*340 29,100,720 11,640*288 17,460,432 21,825,540 87*302,160 77*844,426 40*013,490 2,910*072 69,114*210 28,373*202 3,637*590 61 *111, £>12 Hon-signatory Countries: 51,653,778 X/ Hov, 13, 1943 it it it ii it it | ft w ii H ft II II 169,986*734 66*797,382 1*620*537 1,716,157 2*569,114 5*979,455 787*587 450,791 1,379,312 460*402 3,094,976 59,587 3*205*675 1,993*069 Quotas as established by action of the Inter-American Coffee Board on March 11* 1943* ►oOo- TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, Wednesday. November 34. 1943* Press Service No. 39-65 The Bureau of Customs announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1, 1943, provided for in the InterAmerican Coffee Agreement, proclaimed by the President on April 15, 1941, as follows: Countxy of Production : : : Authorized for entry Quota Quant ity : for consumution • • (Pounds) ] J :As of (Date) : (Pounds) Signatory Countries: Brazil Colombia Costa Rica Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela Non-signatory Countries: 1/ 1,353,183,480 458,336,340 29,100,720 11,640,388 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 51,653,778 Nov. 13, 1943 it it it tt « it it it ti it ti it IT 169,986,734 66,797,382 1,620,537 1,716,157 2,569,114 5,979,455 787,587 450, 791 1,379,312 460,402 3,094,976 59,587 3,205,675 1,993,069 Quotas as established by action of the Inter-American Coffee Board on March 11, 1943, oOo- for such bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made, as ordinary gain or loss. Treasury Department Circular No. 418, as amended, and this notice, pre scribe the terms of the Treasury bills and govern the conditions of their issue. Conies of the circular may be.obtained from any Federal Reserve Bank or Branch. Reserve Banks and Branches, following which public announcement will be made by the Secretary of the Treasury of the amount and price range, of accepted bids. Those submitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final. Subject to these reservations, tenders for $100,000 or less from any one bidder at 99.905 entered on a fixed-price basis will be accepted in full. Payment of accepted tenders at the prices offered must be made or completed at the Federal Reserve Bank in cash or other immediately available funds on December 2, 1943 . The income derived from Treasury bills, whether interest or gain from the sale or other disposition of the bills, shall not have any exemption, as such, and loss from the sale or other disposition of Treasury bills shall not have any special treatment, as such, under Federal tax Acts now or hereafter enacted. The bills shall be subject to estate, inheritance, gift, or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by an3r State, or any of the possessions of the United States, or by any local taxing authority. For purposes of taxation the amount of discount at which Treasury bills are originally sold by the United States shall be considered to be interest. Under Sections 42 and 117 (a) (1) of the Internal Revenue Code, as amended by Section 115 of the Revenue Act of 1941, the amount of discount at which bills issued hereunder are sold shall not be considered to accrue until such bills shall be sold, redeemed or otherwise disposed of, and such bills are excluded from consideration as capital assets. Accordingly, the owner of Treasury bills (olpher than life insurance companies) issued hereunder need include in his income tax return only the difference between the price paid TREASURY DEPARTMENT Washington , FOR RELEASE, MORNING NEWSPAPERS, Friday* November 26, 1943 — ------ The Secretary of the Treasury, by this public notice, invites tenders for $ 1,000,000,000 , or thereabouts, of 91 -day Treasury bills, to be issued fgjt ' 5SS” on a discount basis under competitive and fixed-price bidding as hereinafter pro vided, The bills of this series will be dated December 2, 1943 % and will ifa-r»eh 2, 1944________ , when the face amount will be payable without njb Si interest. They will be issued in bearer form only, and in denominations of $1,000,; mature |5,000, $10,000, $100,000, $500,000, and $1,000,000 (maturity?- value). Tenders will be received at Federal Reserve Banks and Branches up to the closing hour, two o ’clock p. m., Eastern War time, Monday, November 29, 1943 Tenders will hot be received at the Treasury Department, Washington. Each tender must be for an even multiple of $1,000, and the price offered must be expressed on the basis of 100, with not more than three decimals, e. g., 99.925. may not be used. Fractions It is urged that tenders be made on the printed forms and for warded in the special envelopes which vd.ll be supplied by Federal Reserve Banks or Branches on application therefor. Tenders will be received without deposit from incorporated banks and trust companies and from responsible and recognized dealers in i n v e s t m e n t securi ties. Tenders from others must be accompanied by payment of 2 percent of the face amount of Treasury bills applied for, unless the tenders are accompanied by an express guaranty of payment by an incorporated bank or trust company. Immediately after the closing hour, tenders will be opened at the Federa TREASURY DEPARTMENT Washington The tenders bills, Secretary FOR RELEASE, MORNING NEWSPAPERS, F r i d a y , N o v e m b e r 26, 1 943. 11-24-43 ' : --------------of* t h e T r e a s u r y , for $1,000,000,000, to. b e .series w i l l 1944, when or thereabouts, i s s u e d on a d i s c o u n t f i x e d - p r i c e b i d d i n g as 2, the face amount will issued $ 5,000, $10,000, basis 1943, of $500,000, and invites 91-day Treasury competitive and •T h e b i l l s 'of t h i s and will mature March be paya b l e w i t h o u t in b e a r e r f o r m only, $100,000, p u b l i c notice, under hereinafter provided. be da t e d D e c e m b e r will be by this interest. in denominations and $1,000,000 2, They of $ 1 , 0 0 0 , (maturity value! T e n d e r s w i l l b e r e c e i v e d at. F e d e r a l R e s e r v e B a n k s a n d B r a n c h e s u p t o t h e closing' h o u r , t w o o ^ l o c k p, m., E a s t e r n W a r t i m e , M o n day, N o v e m b e r 29, 1943.: T e n d e r s w i l l n o t b e r e c e i v e d a t t h e T r e a s ury Department, Wash i n g t o n . E a c h t e n d e r must be f or an even m u l t i p l e o f $ 1 , 0 0 0 , a n d t h e p r i c e o f f e r e d m u s t be' e x p r e s s e d on t h e b a sis of 1 00, w i t h n o t m o r e t h a n t h r e e d e c i m a l s , e. g., 9 9 , 9 2 5 Fractions m a y not be used. It i s u r g e d t h a t t e n d e r s b e m a d e on t h e p r i n t e d f o r m s a n d f o r w a r d e d in t h e s p e c i a l e n v e l o p e s w h i c h w i l l b e s u p p l i e d b y F e d e r a l * R e s e r v e B a n k s o r B r a n c h e s on a p p l i c a tion there f o r . Tenders will be received without deposit from incorporated banks a n d t r u s t c o m p a n i e s a n d f r o m r e s p o n s i b l e a n d r e c o g n i z e d d e a l e r s in i n v e s t m e n t s e c u r i t i e s * Tenders f r o m others must be a c c o m p a n i e d b y p a y m e n t of 2 p e r c e n t o f t h e f a c e a m o u n t of T r e a s u r y b i l l s a p p l i e d for, u n l e s s t h e t e n d e r s a r e a c c o m p a n i e d b y a n e xpress g u a r a n t y of p a y m e n t b y a n " i n c o r p o r a t e d b a n k or t r u s t company. . I m m e d i a t e l y a f t e r t h e c l o s i n g h our, t e n d e r s w i l l b e o p e n e d at t h e F e d e r a l R e s e r v e B a n k s a n d B r a n c h e s , f o l l o w i n g w h i c h p u b lic a n n o u n c e m e n t w i l l b e m a d e b y t h e S e c r e t a r y of t h e T r e a s u r y of h e a m o u n t a n d p r i c e r a n g e of a c c e p t e d b i d s . Those submitting t e n d e r s w i l l b e a d v i s e d of t h e a c c e p t a n c e o r r e j e c t i o n t h e r e o f , he S e c r e t a r y of t h e T r e a s u r y e x p r e s s l y r e s e r v e s t h e r i g h t to a c c e p t or r e j e c t a n y o r a l l t e n d e r s , in w h o l e o r in p a r t , a n d h i s a c t i o n in a n y s u c h r e s p e c t s h a l l b e f i n a l . Subject to these r e s e r vations, t e n d e r s f o r $ 1 0 0 , 0 0 0 o r l e s s f r o m a n y o n e b i d d e r a t 9 9 . 9 0 5 e n t e r e d on a f i x e d - p r i c e b a s i s w i l l b o a c c e p t e d in f u l l . Payment t e n d e fs a t t h e p r i c e s o f f e r e d m u s t b e m a d e o r c o m p l e t e d F e £ e r a l R e s e r v e , B a n k in c a s h or o t h e r i m m e d i a t e l y A v a i l a b l e t u n d s on D e c e m b e r 2, 1 9 4 3 . 39-66 (O v e r ) T h e i n c o m e d e r i v e d f r o m T r e a s u r y b i l l s y .whether- interest) or g a i n f r o m . t h e s a l e or o t h e r d i s p o s i t i o n of t h e b i l l s , s h a l l n o t h a v e a n y e x e m p t i o n , as such,, a n d l o s s f r o m t h e s a l e o r o t h e r d i s p o s i t i o n of T r e a s u r y b i l l s s h a l l n o t h a v e a n y s p e c i a l t r e a t m e n t , as such, " u n d e r F e d e r a l 'tax A c t s n o w o r h e r e a f t e r e n a c t e d * The b i l l s s h a l l b e s u b j e c t t o estate, i n h e r i t a n c e , gift, o r o t h e r e x c i s e ta x e s , w h e t h e r ■F e d e r a l o r S t a t e , b u t s h a x l . b e e x e m p t f r o m a l l t a x a t i o n n o w or h e r e a f t e r i m p o s e d on t h e p r i n c i p a l o r i n t e r est t h e r e o f b y a n y S t a t e , or a n y of t h e - p o s s e s s i o n s of t h e U n i t e d S t a t e s , or b y a n y l o c a l t a x i n g a u t h o r i t y , For purposes o f t a x a ' t i o n ' t h e a m o u n t of d i s c o u n t at w h i c h T r e a s u r y b i l l s a r e o r i g i nally sold by the U n i t e d States shall be considered to be i n ter est'. U n d e r S e c t i o n s 42 a n d 1 1 7 (a) (1) of t h e I n t e r n a l R e v e n u e C o d e , as a m e n d e d b y S e c t i o n 1 1 5 of t h e R e v e n u e A c t of 1941, t h e a m o u n t ■of d i s c o u n t a t w h i c h b i l l s i s s u e d h e r e u n d e r a r e s o l d shall n o t b e c o n s i d e r e d t o a c c r u e u n t i l s u c h b i l l s s h a l l b e sold, r e d e e m e d or o t h e r w i s e d i s p o s e d of, a n d s u c h b i l l s a r e e x c l u d e d f rom c o n s i d e r a t i o n as c a p i t a l a s s e t s . A c c o r d i n g l y , t h e o w n e r of T r e a s u r y bills (other than l ife i n s u rance companies) issued hereunder n e e d i n c l u d e in h i s i n c o m e t a x return, o n l y t h e d i f f e r e n c e b e t w e e n t h e p r i c e p a i d f o r S u c h b i l l s , w h e t h e r o n 'o r i g i n a l i s s u e o r on s u b s e q u e n t - p u r c h a s e , a n d t h e a m o u n t a c t u a l l y - - r e c e i v e d e i t h e r upon s a l e or r e d e m p t i o n " a t m a t u r i t y d u r i n g t h e . t a x a b l e - y e a r f o r w h i c h t h e r e t u r n is m ade, a s o r d i n a r y g a i n o r l o s s . ; , T r e a s u r y D e p a r t m e n t C i r c u l a r U o. 418, as a m e n d e d , a n d t h i s n o t i c e , p r e s c r i b e t h e t e r m s o f t h e T r e a s u r y b i l l s a n d g o v e r n the c o n d i t i o n s of t h e i r I s s u e . C o p i e s o f t h e c i r c u l a r m a y b e obtained f r o m any F e d eral R e s e r v e B a n k or Branch* , . , 3 income tax and also for any taxes withheld from wages. The payments of estimated tax, to be made in connection with the filing, are only the difference between the total estimated tax and these credits. While most farmers do not work for wages, some of them who work parttime during slack farming seasons house, or stock yard — — perhaps at a near-by cannery, packing may have had some tax withheld from such wages and therefore will be entitled to take credits accordingly. The general requirements for filing a declaration, for both farmers and non-farmers, include all persons who had in the calendar year 1942 or expect to have in the calendar year 1943 any of the following amounts or types of income: 1. More than $100 gross income from a source outside of wages subject to withholding and also sufficient gross income to require filing an income tax return (#500 for a single person, #1200 for a married couple, or $624 for an individual married person)* 2. Wages subject to withholding totaling more than $2,700 if single, or $3,500 if married (married couples must file declarations if such wages of husband and wife, together exceed $3,500). In addition, the declaration is required of any person who was required to file an income tax return for 1942 and who expects his wages subject to withholding in 1943 to be less than similar wages were in 1942. - 0- Anyone who filed a declaration on or before September 15 but who underestimated his tax substantially — 20 per cent in the case of a non-farmer, or 33-1/3 per cent in the case of a farmer — should file an amended declaration by December 15 to avoid penalties prescribed by law for such substantial under estimates. The special provisions relative to farmers will apply to all persons who expect that at least 80 per cent of their total estimated gross income from all sources will be from farming. The other persons who must file by December 15 are those who did not file in September because they anticipated that their income for the year would not be sufficient to require filing but who now find that their income will be high enough to require filing a declaration. "Extensive efforts have been made to provide farmers with all the information they will need to complete this filing, and I have instructed ^ the Collectors' offices to give every possible assistance to farmers," Commissioner Hannegan said. "Many farmers already have the forms which were sent them in August. These forms are still good and may be used. Any farmers needing more forms, however, will be supplied promptly upon request to the Collectors. "In addition, any farmer who desires to make a precise estimate, for which Form 1040F (Schedule of Farm Income and Expenses) is useful, may also get these forms from Collectors. their tax — However, farmers desiring only to approximate within the permissible 33-1/3 per cent margin of error — will find the simplified worksheet, which is supplied to all taxpayers, adequate for this purpose." Farmers and others filing declarations for the first time will find that the form provides credit for any tax paid this year on account of their 1S42 I -rvL fyi December 15, 1943 is a special tax date for American farmers, farmers, '~2co_ Commissioner of Internal Revenue Robert 1. Hannegan said today* Although a limited number of non«*farmers also will have tax payments to make or declarations of estimated tax to file, Commissioner Hannegan explained that December 15 will be the first date by which farmers will be required to file "Declarations of Estimated Income and Victory Tax", similar #0 the declarations filed by nearly twelvexmillion persons on September 15. "By the very nature of his business, the farmer could not be put on quite the same basis as the city wage earner when Congress adopted the payas-you-go system," Commissioner Hannegan explained. "In the first place, the farmer usually has no wages from which tax can be withheld. In the second place, because of the hazards of weather and other conditions of agriculture, the farmer could hot be expected to estimate his income until most of the crops were gathered and sold. "Therefore, to make the pay-as-you-go system as fair as possible to farmers, the law makes two special provisions. Eirst, farmers who file returns on a calendar year basis need not estimate their income and tax until December 15 of each year, and second, a farmer’s estimate will be exempt from penalties for understatement if the tax estimate is within a 33-1/3 per cent margin of error(based on the annual tax return to be filed, as usual, the following March)• "Under these provisions, the farmer is enabled to pay his income taxes substantially in the same year as the income is received, which is the primary objective of the pay-as-you-go system — with due regard for the special difficulties of the farming business." Dedember 15 is also a filing date for two other groups of citizens 7 / TREASURY DEPARTMENT Washington •FOR RELEASE HORNING NEWSPAPERS, Thursday, December 2, I9h3. Press Service No.. 39-67 . December 15, 19^3 is a special tax date for American farmers, Commissioner of Internal Revenue Robert E* Hannfcgan said today.. Although a limited number of non-farmers also will have tax payments to make or declarations of estimated tax to file, Commissioner Hannegan explained that December 15 will be the first date by which farmers will be required to file "Declarations of Estimated Income and Victory Tax", similar to the declarations filed by nearly twelve million persons on September 15* "By the very nature of his business, the farmer could not be put on quite the same basis as the city wage earner when Congress adopted the payas-you-go system," Commissioner Hannegan explained, "Xn the first place, the farmer psually has no wages from which tax can be withheld* In the second place, because of the hazards of weather and other conditions of agriculture, the farmer could not be expected to estimate his income until most of the crops were gathered and sold, fTherefore, to make the pay-as-you-go system as fair as possible to farmers, the law makes two special provisions. First, farmers who file returns on a calendar year basis need not estimate their income and tax until December 15 of each year, and second, a farmer*s estimate will be exempt from penalties for understatement if the tax estimate is within a 33-1/3 per cent margin of error (based on the annual tax return to be filed, as usual, the following March). "Under these provisions, the farmer is enabled to pay his income taxes substantially in the same year as the income is received, which is the primary objective of the pay-as-you-go system — with due regard for the special difficulties of the farming business," December 15 is also a filing date for two other groups of citizens. Anyone who filed a declaration on or before September 15 but who under estimated his tax substantially — 20 per cent in the case of a non-farmer, or 33-1/3 Per cent in the case of a farmer — should file an amended declaration by December 15 to avoid penalties prescribed by law for such substantial underestimates.. The special provisions relative to farmers will apply to all persons who expect that at least SO per cent of their total estimated gross income from all sources will be from farming, The other persons who must file by December 15 are those who did not file in September because they anticipated that their income for the year would not be sufficient to require filing but who now find that their in come will be high enou^a to require filing a declaration, 2 ^Extensive efforts have been made to .provide farmers with all the information they will need to complete this filing, and I have instructed the Collectors' offices to give every possible assistance to farmers,” Commissioner Hannegan said, "Many farmers already have the forms which were sent them in August, These forms are still good and may he used. A&y farmers need ing more forms, however, will he supplied promptly upon request to the Collectors, ”In addition, any farmer who desires to make a precise estimate, for which Form lObOF (Schedule of Farm Xacome and Expenses) is useful, may also get these forms from Collectors, However, farmers desiring only to approximate their tax — within the permissible 33 ~l / 3 Per cent margin of error — will find the simplified worksheet, which is supplied to all tax payers, adequate for this purpose,” Farmers and others filing declarations for the first time will find that the form provides credit for any tax paid this year on account of their 19^2 income tax and also for any taxes withheld from wages. The payments of estimated tax, to be made in connection with the filing, are only the difference between the total estimated tax and these credits. While most farmers do not work for wages, some of them who work parttime during slack farming seasons * perhaps at a near-by cannery, packing house, or stock yard — may have had some tax withheld from such wages and therefore will be entitled to take credits accordingly, The general requirements for filing a declaration, for both farmers and non-farmers, include all persons who had in the calendar year 19^2 or expect to have 1in the calendar year 19^-3 any of the following amounts or types of income: 1, More than $100 gross income from a sourcq outside of wages subject to withholding and also sufficient gross income to require filing an income tax return ($500 for a single person, $1200 for a married couple, or $ 62 b for an individual married person), 2* Wages subject to withholding totaling more than $2,700 if single, or $ 3,500 if married (married couples must file declarations if such wages of husband and wife, together exceed $3 *500 ), In addition, the declaration is required of any person who was re quired to file an income tax return for 19^-2 and \irho expects his wages subject to withholding in 19*+3 to be less than similar wages were in 19 ^ 2 . - 0- 3 placed in charge of the Memphis office in 1901. Later assignments carried him to New Tork City, Philadelphia, St, Louis, and other, districts, and in 1903 he was placed in charge of the New England district, with headquarters at Boston, remaining there, with inter ruptions for assignments with President Taft, until he "became a part of Woodrow Wilson’s official family in 1912* While with Wilson at Versailles, Mr. Murphy surprised himself hy readily picking up the rudiments of conversational French, and quickly found himself at ease with Europeans. He later was able to turn this faculty into good account on a tour of European capitals in which he did much to further cooperation and friendly relations "between United States authorities and foreign police organizations. Information he obtained on operations of international counterfeit rings proved of great value to the Service. Mr. Murphy was "born in Columbus, Ohio, November 29, 1878. He was educated in the public schools there. His father was a Secret Service Officer for thirteen years, until his death in 1906, being Agent in Charge in the St. Louis District for much of this time, and it was natural for his son to turn to the Service. The retiring Assistant Chief is an enthusiastic golfer apd bridge^ player. He is a member of the National Press Club and the Country Club of Washington. He 1 "•» and will continue to make his hon the World War presid White House Detail i Chief on direction 0 placed at the head of the 1919, "became Assistant J, Mr. Murphy accompanied President Wilson to Versailles after the armistice, and on visits to Belgium, Italy, Prance, England and Scotland, and later on a trip to the West floast of the United States. In November 1920 ed President Elect Harding on a vacation in Plorida, ith him until the inauguration on March U, 1921. After ,th on August 2, 1923, Mr. Murphy was in charge of the Detail with President Coolidge until after Warren Harding was buried. He later headed the Detail with PresidentElect Herbert Hoover until"Hoover took: office March 4, ~ 1 The Assistant Chief was on vacation in Plorida on the night Zangara attempted to assassinate President-Elect Pranklin D. Roosevelt, and he promptly took charge of the investigation of the crime and cooperated with the State's Attorney until Zangara was con victed. When President Roosevelt decided to visit South America in 1937* Secretary Morgenthau placed the protective responsibility on Mr. Murphy, and he has had similar assignments on several other of the Roosevelt trips. Mr. Murphy made a spectacular debut with the Service in which his father, John E. Murphy, also served with distinction. When young Joe entered the service in 1899 the Elder Murphy had for more than a year been on the trail of one of the shrewdest counterfeiting gangs ever known to the Service, the Philadelphia-Lancaster gang. These clever and wealthy criminals had selected a location for their manufacturing plant that was extremely difficult of observation, the exit being visible only from the nearby home of a wealthy, elderly lady. Young Joe "obtained a job" with an express company at Lancaster. He approached the old lady as a young stranger far from home, urgently in need of living quarters, and was permitted to occupy her front room. Prom this vantage he and the agents assigned to the case covered the operations of the counterfeiters. In a few weeks the country was astounded by the news of arrest of persons prominent in society, charges of bribery against public officials and the subsequent withdrawal of a $100 note from circulation because of the clever counterfeits intro duced by the gang. The investigation disclosed that the same gang had defrauded the government of millions of dollars throu^i use of counter feit revenue stamps as well as currency. Having thus established himself as an investigator, the >unger Murphy rose rapidly in the Secret Service organization. He 3 given temporary charge of the Kansas City office the next year, and was Joseph E. Murphy, Assistant Chief of the United States Secret Service since 1919. who more than any other one man has carried personal responsibility for the safety of Presidents of the United States, will retire from active service November a* , the Treasury announced today* Mr* Murphy is 65 years old. For most of his ^5 years with the Secret Service Mr. Murphy’s major assignment has been guarding'or directing the protection of Chief Executives, from Theodore Roosevelt to Franklin Delano Roosevelt. Yet during this period he figured prominently in scores of counter feiting and other law enforcement investigations, including the Teapot Dome oil frauds * Mr. Murphy is the second veteran Secre' “ vice intimate of presidents to retire ois year. Colonel Ed W. Starling retired on November 1 after years with the White House Detail. Colonel Starling joined the Service in 191*+, served under Mr* Murphy, like Mr. Murphy accompanied President Wilson to the Versailles peace conference and on his later European tour, and participated in the protective arrangements thrown about subsequent presidents at home and abroad. Colonel Starling hteseirf headed the White House Detail Lief Wilson ret Service Chief Wilson^.-fr»-"ft)mgugplii|, tiiu 11ittroacw --- efficient piperformance sai t vthe lengthy aei---- -efficient of duties of performance of duties of Xity constituted a bright brig] exceptional responsibility chapter in the history of the organization. first duty as a protector of Presidents came when he was a youngster both in years and in the Service. When president Theodore Roosevelt visited Seattle in May 1903. Mr* Murphy was one of the guarding force. Later he went with wppflny-W rm a t.riji to Panama, the first time a President had left the Continental United States* k ^ For most of a decade Mr. Murphy matched his wits against the counterfeiters that were plaguing the New England district, but he was detached for White House duty frequently during the Taft Adminis tration* He spent four seasons with the President at his summer home, and accompanied Mr. Taft on two trips across the continent, to Panama, and on other tours. In November 1912 Mr* Murphy was assigned to the protection of President-Elect Woodrow Wilson, and he remained with the White House Detail of the Secret Service after Mr* Wilson took office and throughout TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, F r i d a y , N o v e m b e r 26, 1 9 4 3 * J o s e p h E* Secret Service Murphy, since Press Service No, 3 9 - 6 8 Assistant 1919, Chief who more than any carried personal responsibility for the of t h e U n i t e d S t a t e s , will retire of the U n i t e d other safety from active States one man has of p r e s i d e n t s service November 30, the Treasury announced today, Mr* Murphy is 65 years old* For most of his 4-5 years with the Secret Service Mr. Murphy’s major assignment has been guarding or directing the protection of seven Chief Executives, from Theodore Roosevelt to Franklin Delano Roosevelt* Yet during this period he figured prominently in scores of counterfeiting and other lav/ enforcement investi gations, including the Teapot Dome oil frauds case. M r . M u r p h y is t h e s e c o n d v e t e r a n S e c r e t S e r v i c e i n t i m a t e of p r e s i d e n t s t o r e t i r e t h i s y e a r . C o l o n e l E d m u n d W* S t a r l i n g r e t i r e d on N o v e m b e r 1 a f t e r 2.9 y e a r s w i t h t h e W h i t e H o u s e D e t a i l . C o l o n e l S t a r l i n g j o i n e d t h e S e r v i c e in 1914, s e r v e d u n d e r Mr* M u r p h y , l i k e Mr. M u r p h y a c c o m p a n i e d P r e s i d e n t W i l s o n t o t h e V e r s a i l l e s p e a c e c o n f e r e n c e a n d on h i s l a t e r E u r o p e a n t our, a n d p a r t i c i p a t e d in t h e p r o t e c t i v e a r r a n g e m e n t s t h r o w n a b o u t s u b s e quent p r e s i d e n t s at h o m e a n d abroad. Colonel years. Starling headed the White House Detail for seven S e c r e t S e r v i c e C h i e f F r a n k J. V/ilson s a i d t o d a y t h a t t h e l e n g t h y s e r v i c e s o f t h e t w o m e n in e f f i c i e n t p e r f o r m a n c e of d u t i e s of e x c e p t i o n a l r e s p o n s i b i l i t y c o n s t i t u t e d a b r i g h t c h a p t e r in t h e h i s t o r y of t h e o r g a n i z a t i o n * J o e M u r p h y ’s f i r s t d u t y a s a p r o t e c t o r o f p r e s i d e n t s c a m e w h e n h e w a s a y o u n g s t e r b o t h in y e a r s a n d in t h e S e r v i c e . When P r e s i d e n t T h e o d o r e R o o s e v e l t v i s i t e d S e a t t l e in M a y 1903, Mr* M u r p h y w a s o n e o f . t h e g u a r d i n g f o r c e * L a ter he went w i t h T. R . ” on a t r i p t o P a n a m a , t h e f i r s t t i m e a p r e s i d e n t h a d left t h e C o n t i n e n t a l U n i t e d States. * 2 > ; F o r m o s t of a d e c a d e Mr* M u r p h y m a t c h e d h i s w i t s a g a i n s t t h e counterfeiters that w e r e p l a g u i n g the N e w E n g l a n d district, but he was d e t a c h e d f o r W h i t e H o u s e d u t y f r e q u e n t l y d u r i n g t h e T a f t A d m i n i s t r a t i o n * . H e spent f o u r s e a s o n s w i t h t h e P r e s i d e n t a t his s u m m e r h ome, a n d a c c o m p a n i e d M r • T a f t o n t w o t r i p s a c r o s s t h e c o n t i n e n t , t o P a n a m a , a n d on o t h e r t o u r s . In N o v e m b e r 1 9 1 2 Mr, M u r p h y w a s a s s i g n e d t o t h e p r o t e c t i o n of P r e s i d e n t - E l e c t W o o d r o w W i l s o n , a n d h e r e m a i n e d w i t h t h e W h i t e H o u s e D e t a i l of t h e S e c r e t S e r v i c e a f t e r Mr, W i l s o n t o o k o f f i c e a n d t h r o u g h o u t t h e W o r l d W a r P r e s i d e n t ’s t e n u r e , He was placed at t h e h e a d o f t h e W h i t e H o u s e D e t a i l in 1912, a n d on J u l y 27, 1919, b e c a m e A s s i s t a n t C h i e f on d i r e c t i o n o f P r e s i d e n t W i l s o n . Mr, M u r p h y a c c o m p a n i e d P r e s i d e n t W i l s o n t o V e r s a i l l e s a f t e r the a r m i s t i c e , a n d on v i s i t s t o B e l g i u m , Italy, F r a n c e , E n g l a n d a n d S c o t l a n d , a n d l a t e r on a trip; t o t h e W e s t C o a s t of t h e U n i t e d Stat e s , In N o v e m b e r 1920, h e a c c o m p a n i e d P r e s i d e n t - E l e c t H a r d i n g on a v a c a t i o n in F l o r i d a , a n d r e m a i n e d w i t h h i m u n t i l t h e i n a u g u r a t ion on M a r c h 4, 1 9 2 1 . A f t e r P r e s i d e n t H a r d i n g ’s d e a t h on A u g u s t 2, 1923, Mr, M u r p h y w a s in c h a r g e of t h e D e t a i l w i t h P r e s ident C o o l i d g e u n t i l a f t e r W a r r e n H a r d i n g w a s b u r i e d . He later headed the D e tail w i t h P r e s i d e n t - E l e c t H e r b e r t H o o v e r unt i l Mr. H o o v e r t o o k o f f i c e M a r c h 4, 1 9 2 9 . T h e A s s i s t a n t C h i e f w a s o n v a c a t i o n in F l o r i d a on t h e n i g h t Giuseppe Zangara a t t e m p t e d to a s s a s s i n a t e P r e s i d e n t - E l e c t Franklin D. R o o s e v e l t , a n d h e p r o m p t l y t o o k c h a r g e of t h e i n v e s t i g a t i o n of the c r i m e a n d c o o p e r a t e d w i t h ' t h e S t a t e ’s A t t o r n e y u n t i l Z a n g a r a was c o n v i c t e d . When President Roosevelt decided to visit South A m e r i c a in 1937, S e c r e t a r y M o r g e n t h a u p l a c e d t h e p r o t e c t i v e r e s p o n s i b i l i t y on Mr. M u r p h y , a n d h e h a s h a d s i m i l a r a s s i g n m e n t s on s e v e r a l o t h e r of t h e R o o s e v e l t t r i p s . Mr, M u r p h y m a d e a s p e c t a c u l a r d e b u t w i t h t h e S e r v i c e in w h i c h h i s f a t h e r , J o h n E. M u r p h y , a l s o s e r v e d w i t h d i s t i n c t i o n * W h e n y o u n g J o e e n t e r e d t h e s e r v i c e in 1 8 9 9 t h e e l d e r M u r p h y h a d for m o r e t h a n a y e a r b e e n on t h e t r a i l o f o n e o f t h e s h r e w d e s t counterfeiting gangs ever kno w n to the Service, th e Phi l a d e l p h i a Lancaster gang. These clever and wealthy criminals had selected a location for their manufacturing plant that was extremely dif f i cult of o b s e r v a t i o n , t h e e x i t b e i n g v i s i b l e o n l y f r o m t h e n e a r b y home o f a w e a l t h y , e l d e r l y l a d y . - 3 Y o u n g J o e " o b t a i n e d a job" w i t h a n e x p r e s s c o m p a n y a t L a n c a s ter. H e a p p r o a c h e d t h e o l d l a d y as a y o u n g s t r a n g e r f a r f r o m hom e , u r g e n t l y in n e e d of l i v i n g q u a r t e r s , a n d w a s p e r m i t t e d t o o c c u p y her fr o n t room. P r o m this v a n t a g e h e a n d t h e age n t s a s s i g n e d to t he case c o v e r e d t h e o p e r a t i o n s of t h e c o u n t e r f e i t e r s . In a f e w w e e k s t h e c o u n t r y w a s a s t o u n d e d b y t h e n e w s of a r r e s t o f p e r s o n s p r o m i n e n t in s o c i e t y , c h a r g e s of b r i b e r y a g a i n s t p u b l i c o f f i c i a l s a n d t h e s u b s e q u e n t w i t h d r a w a l of a $ 1 0 0 n o t e f r o m c i r c u l a t i o n b e c a u s e of the c l e v e r c o u n t e r f e i t s i n t r o d u c e d b y t h e g a n g . The investigation d i s c l o s e d t h a t t h e s a m e g a n g h a d d e f r a u d e d t h e G o v e r n m e n t of m i l lions o f d o l l a r s t h r o u g h u s e of c o u n t e r f e i t r e v e n u e s t a m p s as w e l l as c u r r e n c y . H a v i n g t h u s e s t a b l i s h e d h i m s e l f as a n i n v e s t i g a t o r , t h e y o u n g e r M u r p h y r o s e r a p i d l y in t h e S e c r e t S e r v i c e o r g a n i z a t i o n . He was g i v e n t e m p o r a r y c h a r g e of t h e K a n s a s C i t y o f f i c e t h e n e x t ye a r , a n d was p l a c e d in c h a r g e of t h e M e m p h i s o f f i c e in 1 9 0 1 , Later assign men t s c a r r i e d h i m t o H e w Y o r k City, P h i l a d e l p h i a , St, L o u i s , a n d oth e r d i s t r i c t s , a n d in 1 9 0 3 h e w a s p l a c e d in c h a r g e of t h e H e w England district, w i t h h e a d q u a r t e r s at Boston, r e m a i n i n g there, with i n t e r r u p t i o n s f o r a s s i g n m e n t s w i t h P r e s i d e n t Taft, u n t i l he b e c a m e a p a r t o f W o o d r o w W i l s o n ’s o f f i c i a l f a m i l y in 1 9 1 2 . W h i l e w i t h W i l s o n at V e r s a i l l e s , Mr. M u r p h y s u r p r i s e d h i m s e l f by^readily p i c k i n g up the r u d i m e n t s of c o n v e r s a t i o n a l French, a n d quickly f o u n d h i m s e l f at ease w i t h Europeans. He later was able to t u r n t h i s f a c u l t y i n t o g o o d a c c o u n t on a t o u r of E u r o p e a n c a p i tals i n w h i c h h e d i d m u c h t o f u r t h e r c o o p e r a t i o n a n d f r i e n d l y r e l a tions b e t w e e n U n i t e d S t a t e s a u t h o r i t i e s a n d f o r e i g n p o l i c e o r g a n i zations, I n f o r m a t i o n h e o b t a i n e d on o p e r a t i o n s of i n t e r n a t i o n a l c o u n t e r f e i t r i n g s p r o v e d of g r e a t v a l u e t o t h e S e r v i c e , Mr. M u r p h y w a s b o r n in C o l u m b u s , Ohio, N o v e m b e r 2 9 , 1 878. He was e d u c a t e d in t h e p u b l i c s c h o o l s t h e r e , His f a t h e r was a Secret S e r v i c e O f f i c e r f o r t h i r t e e n y e a r s , u n t i l h i s d e a t h in 1906, b e i n g A g ent in C h a r g e in t h e St, L o u i s D i s t r i c t f o r m u c h of t h i s t ime, and it w a s n a t u r a l f o r h i s s o n t o t u r n t o t h e S e r v i c e . T h e r e t i r i n g A s s i s t a n t C h i e f is a n e n t h u s i a s t i c g o l f e r a n d bridge p l a y e r , H e is a m e m b e r o f t h e N a t i o n a l P r e s s C l u b a n d t h e B u r n i n g T r e e C o u n t r y C l u b of W a s h i n g t o n . "-He l i v e s a t 2 9 1 5 C o n n e c t i c u t A v e n u e , N. W , , a n d w i l l c o n t i n u e t o m a k e h i s h o m e in W a s h i n g t o n a f t e r ' s p e n d i n g t h e w i n t e r in F l o r i d a . H e is a b a c h e l o r . -oOo- the March return, the Collector will then give you a refund or credit. q. Suppose I made a big mistake and overestimated in September, what pan I do? A. You too may file an amended declaration by December 15. In this case if you receive a bill from, the Collector for an instalment resulting from your September declaration, you should send this bill with your amended declaration to the Collector, along with any revised payment shown to be due for December on your anended declaration. q. Can a husband and wife make a joint declaration, and If they do can they file separately next March? A. Yes. q. What if I don’t file a declaration? A. There is a penalty Of 10 percent of the tax for failure to file a declaration on time. q. What if I don’t pay an estimated tax instalment on time? A* If the payment is late, there is a penalty of |2«50 or 2-1/2 percent of the tax, whichever is greater, for each instalment which is late. ,q. Where can I get copies of the forms or assistance in filling them in? A. S*om your local Collector of Internal Bevenue. If you have forms left over from September, however, they are still good* q. Hasn’t the Victory tax been changed lately? A. The only change In the Victory tax which affects the declaration relates to the post-war credit. If you use the simplified worksheet, no change is necessary. If you use the more precise worksheet, give yourself credit for all of the post-war credit (formerly, taking this credit depended on purchases of war bonds, etc.)* q. Will I still have to file an annual tax return by next March 15? A. Yes. Nothing in the pay-as-you-go system changes the requirement for filing an annual tax return. The only difference Is that when you do file your annual return you will have paid all or a substantial part of the tax, and the only payment that you will have to make on the annual return will be any amount o*f tax which your annual return may show that you owe after deducting the amounts already paid under the pay-as-you-go system. In fact, many persons may be eligible for refunds or credits because their annual returns may show that they have paid somewhat more than the correct tax. 1 - 2 - sources to require filing an annual income tax return ($500 for a single person, $1200 for a married couple, or #624 for an individual married person). b. Wages subject to withholding exceeding #2700 if single or exceeding $3500 if married ($3500 either individually or together in the case of husbands and wives both receiving wages). In addition, a declaration must be filed by any person who was required to file an income tax return for 1942 and who expects his wages subject to withholding in 1943 to be less than the wages received in 1942. Q. How accurate must m y estimate be? A. It should be as accurate as you can reasonably make it, especially since by December 15 there will be only two weeks of the year left. However, no penalty will be assessed if the tax is not underestimated by more than 20 percent in the case of a non-farmer or 33-1/3 percent in the case of farmers. Q. How much is. the penalty far underestimating? A. Generally 6 percent of the deficiency, but in some cases it may be less, as shown in the examples below: Examp3.es where margin of error is 20 percent: (a) Net estimated tax plus taxes withheld is $500; tax shown on final return is $650; 80$ of $650 Is $520. Since $500 is outside the margin of error, the penalty is 6$ of $150 (the difference between $500 and $650) or $9. This penalty of $9 is applicable because it is less than $20, the difference between $500 and $520. (b ) Net estimated tax plus taxes withheld is $500; tax shown on final return is $630; 80$ of $630 is $504. Since $500 is outside the margin of error, a penalty is due. The amount of the penalty is $4, the difference between $500 and $504. This penalty of $4 is applicable because it is less than $7*80, which is & f o of $130, the difference between $500 and $630. For farmers the margin of error is 33-1/3 pereent instead of 20 percent, and in computing the penalty, 66-2/3 percent is used instead of 80 percent. Q c When will the penalties, if any, be determined? A. After the taxpayer files his March 15 annual income tax return showing the correct tax for the year* Q. Suppose I overestimate,' what happens? A. If an overestimate results in overpayment of the correct tax shown in A&VANCM TOT RErs^gffi / WEDNESDAY, DECEMBER'^ 1 9 4 3 . . QUESTIONS AND ANSWERS ABOUT TBS DECEMBER 15 INCOME TAX DECLARATION Q* What kind of tax filing is to be made December 15? A* Declarations of estimated income and Victory tax, estimating how much tax certain persons will owe on their 1943 income in excess of income tax payments already made or of income tax withheld from wages or salary during the year* Q,* Wasn’t that done.September 15? A. Yes. Nearly twelve million taxpayers filed declarations September 15* The only persons who have to file now are those who did not file then but are required to do so by December 15 either because, in the case of farmers, they had an automatic postponement, or because they did then not expect enough income to require filing but now anticipate higher incomes which do require filing of declarations. Also, any persons who filed in September 'Who underestimated the tax— by 20 percent if nonx farmers or 33-1/3 percent if farmers— should file amended declarations by December 15 to avoid penalties* Q. What is an amended declaration? A* It is, in reality, a substitute declaration It is file, on a similar form and is distinguished only by writing the word "amended” at the top of the front page of the form* Q> What is the purpose of these declarations? A* To put all taxpayers, as nearly as possible, on the pay-as-you-go system of tax payment, so that they will be able to pay their taxes in the same year that they get their income* Q* What, information is required? A* You estimate your 1943 income and Victory tax, based, on your estimate of 1943 income and then deduct any payments made this year on 1942 tax (probably instalments in March and June)— and also any taxes withheld and estimated to- be withheld from wages* The remainder is the amount you owe and must be paid on or before December 15* Q* How do I know if I have to file a declaration by December 15? A* If you filed in September you don’t need to file now unless you believe you underestimated the tax by more than 20 percent (33-1/3 percent if a farmer) in which case you should file an amended declaration to avoid penalties. If you did not file in September you should file a declaration if you had in 1942 or expect to have in, 1943. income of any of the following amounts or types; a. More than $100 gross income other than wages which are subject to withholding aid also expect sufficient gross income from all TREASURY DEPARTMENT W A S H IN G TO N 25 O F F IC E O F COMMISSIONER OF INTERNAL REVENUE A D D R E S S R E P L Y TO November 26, 1943 C O M M IS S IO N E R O F IN TERN A L R EV EN U E AND R E F E R TO M EM ORANDUMFOR: Mr* Schwarz or Mr. Shaeffer: Attached questions and answers have been approved by Mr. Hannegan and all other necessary persons in the Bureau* Please distribute them as soon as possible to your regular lists, also your farm list and please advise me if copies can also be mailed promptly to all individual daily and weekly newspapers* Irving Perimeter, Public Relations Officer. TREASURE DEPARTMENT Washington FOR R E L E A S E , M O R N I N G N E W S P A P E R S , W e d n e s d a y , D e c e m b e r S, 1 9 4 3 . 11-27-43 Press No* Service 39-69 QUESTIONS AND ANSWERS ABOUT THE D E C E M B E R 15 INCOME TAX DECL A R A T I O N Q* What kind of tax filing is to b e m a d e D e c e m b e r 1 5 ? A* D e c l a r a t i o n s o f e s t i m a t e d i n c o m e a n d V i c t o r y tax, e s t i m a t i n g h o w m u c h tax c e r tain persons will owe on their 1 9 4 3 i n c o m e in e x c e s s o f i n c o m e t a x p a y m e n t s a l r e a d y m a d e o r o f i n c o m e t a x w i t h h e l d f r o m w a g e s or s a l a r y d u r i n g the y e a r . Q* W a s n ’t t h a t d o n e A. Yes* Ne a r l y twelve mill i o n taxpayer^ filed declarations S e p t e m b e r 15* T h e o n l y p e r s o n s w h o h a v e to f i l e n o w a r e t h o s e w h o d i d n o t f i l e t h e n b u t a r e r e q u i r e d to d o so b y D e c e m b e r 3,5 e i t h e r b e c a u s e , i n t he c a s e o f f a r m e r s , t h e y h a d an a u t o matic postpo n e m e n t , or b e c a u s e they did then n o t N e x p e c t e n o u g h i n c o m e to r e q u i r e f i l i n g b u t n o w a n t i c i p a t e h i g h e r i n c o m e s w h i c h d o r e q u i r e f i l i n g o f declara' tions. A l s o , a n y p e r s o n s w h o f i l e d in S e p t e m b e r w h o u n d e r e s t i m a t e d t he t a x - - b y 2 0 p e r c e n t if n o n - f a r m e r s o r 3 3 - 1 / 3 p e r c e n t if f a r m e r s - - s h o u l d f i l e a m e n d e d d e c l a r a t i o n s b y ' D e c e m b e r 1 5 to a v o i d p e n a l t i e s . Q. What A. It is, in r e a l i t y , a s u b s t i t u t e d e c l a r a t i o n * It is f i l e d o n a s i m i l a r f o r m a n d Is d i s t i n g u i s h e d o n l y b y w r i t i n g the w o r d ’’a m e n d e d ” a t the t o p o f the f r o n t p a g e o f the f o r m . Q. What A. T o p u t a l l t a x p a y e r s , a s n e a r l y a s p o s s i b l e , o n the p a y - a s - y o u - g o s y s t e m o f t a x p a y m e n t , so t h a t t h e y w i l l b e a b l e to p a y t h e i r t a x e s in the s a m e y e a r t h a t t h e y get their income* Q. What A. Y o u e s t i m a t e y o u r 1 9 4 3 i n c o m e a n d V i c t o r y tax, b a s e d on y o u r estimate of 1 943 income an d then d e d u c t a ny p a y m e n t s m a d e this y e a r o n 194 2 tax ( p r o b a b l y i n s t a l m e n t s in M a r c h a n d J u n e ) - - a n d a l s o a n y t a x e s w i t h h e l d a n d e s t i m a t e d to be w i t h h e l d f r o m w a g e s . The remainder is the a m o u n t y o u o w e a n d m u s t b e p a i d o n o r b e f o r e D e c e m b e r 15 <> S e p t e m b e r 15? is a n a m e n d e d d e c l a r a t i o n ? is the p u r p o s e information of these declarations? is r e q u i r e d ? 2 Q. H o w do I k n o w D e c e m b e r 15? if I h a v e to f i l e a d e c l a r a t i o n b y A. I f y o u f i l e d in S e p t e m b e r y o u d o n ft n e e d to f i l e n o w u n l e s s y o u b e l i e v e y o u u n d e r e s t i m a t e d the tax b y m o r e than 20 p e r c e n t (53-1/5 p e r c e n t if a farmer) in w h i c h c a s e y o u s h o u l d f i l e a n a m e n d e d d e c l a r a t i o n to a v o i d penalties. If yo u did n o t file in S e p t e m b e r y o u should f i l e a d e c l a r a t i o n if y o u h a d in 1 9 4 2 o r e x p e c t to h a v e in 1 9 4 3 i n c o m e o f a n y o f t h e f o l l o w i n g a m o u n t s o r t y p e s : a. More than $100 gross income o t h e r than wages w h i c h a r e s u b j e c t to w i t h h o l d i n g a n d a l s o expect sufficient gross income from a l l s o u r c e s to r e q u i r e f i l i n g a n a n n u a l i n c o m e t a x r e t u r n ($500 for a single person, $ 1 2 0 0 for a m a r r i e d c o u p l e , o r $ 6 2 4 f o r a n i n d i v i d u a l m a r r i e d person.) b. W a g e s s u b j e c t to w i t h h o l d i n g e x c e e d i n g $ 2 7 0 0 i f single or exceeding $ 3 500 if marr i e d ($3500 e i t h e r i n d i v i d u a l l y o r t o g e t h e r in t h e c a s e o f husbands and wives b o t h receiving wages). In addition, a d e c l a r a t i o n m u s t be filed b y a n y p e r s o n w h o w a s r e q u i r e d to f i l e a n i n c o m e t a x r e t u r n f o r 1 9 4 2 a n d w h o e x p e c t s h i s w a g e s s u b j e c t to w i t h h o l d i n g in 1 9 4 3 to b e l e s s t h a n the w a g e s r e c e i v e d i n 1 9 4 2 . Q. How accurate must my A. It s h o u l d b e a s a c c u r a t e a s y o u c a n r e a s o n a b l y m a k e it, e s p e c i a l l y s i n c e b y D e c e m b e r 1 5 t h e r e w i l l b e o n l y two w e e k s o f t he y e a r l e f t . However, no p e n a l t y will be a s s e s s e d if t h e t a x is n o t u n d e r e s t i m a t e d b y m o r e t h a n 20 p e r c e n t in the case o f a n o n - f a r m e r o r 33-1/3 p e r c e n t in the c a s e o f f a r m e r s . Q. H o w m u c h is A. G e n e r a l l y 6 p e r c e n t o f the d e f i c i e n c y , b u t i n s o m e it m a y b e l e s s , as s h o w n in t he e x a m p l e s b e l o w : Examples (a) estimate be? the p e n a l t y f o r u n d e r e s t i m a t i n g ? where m a r g i n of cases e r r o r is 2 0 p e r c e n t : N e t e s t i m a t e d t a x p l u s t a x e s w i t h h e l d Is $ 5 0 0 ; t a x s h o w n o n f i n a l r e t u r n is $ 6 5 0 ; 8 0 $ o f $ 6 5 0 is $ 5 2 0 . S i n c e $ 5 0 0 is o u t s i d e t h e m a r g i n o f e r r o r , the p e n a l t y is 6 $ o f $ 1 5 0 ( t h e d i f f e r ence b e t w e e n $ 5 0 0 a n d $650) o r $9. This penalty o f $ 9 is a p p l i c a b l e b e c a u s e it is l e s s t h a n $ 2 0 , t he d i f f e r e n c e b e t w e e n $ 5 0 0 a n d $ 5 2 0 . 5 (b) N e t e s t i m a t e d t a x p l u s t a x e s w i t h h e l d is $ 5 0 0 ; t a x s h o w n o n f i n a l r e t u r n is $ 6 3 0 ; 8 0 $ o f $ 6 3 0 is $ 5 0 4 . S i n c e $ 5 0 0 is o u t s i d e the m a r g i n o f e rror, a p e n a l t y is due. T h e a m o u n t o f the p e n a l t y is $4, the d i f f e r e n c e b e t w e e n $ 5 0 0 a n d $504. T h i s p e n a l t y o f $ 4 is a p p l i c a b l e b e c a u s e it is l e s s t h a n $ 7 . 8 0 , w h i c h is 6$ o f $ 1 3 0 , the d i f f e r e n c e b e t w e e n $ 5 0 0 a n d $630. F o r f a r m e r s the m a r g i n o f e r r o r is 3 3 - 1 / 3 p e r c e n t i n s t e a d of 2 0 p e r c e n t , a n d in c o m p u t i n g the p e n a l t y , 6 6 * 2 / 3 p e r c e n t is u s e d i n s t e a d o f 8 0 p e r c e n t . Q. When will the p e n a l t i e s , A. A f t e r the t a x p a y e r f i l e s h i s M a r c h 1 5 a n n u a l r e t u r n s h o w i n g t he c o r r e c t t ax f o r the y e a r . Q. Suppose A. If a n o v e r e s t i m a t e t a x s h o w n in the M a h o i give you a refund or Q. Suppose I made a big mistake S e p t e m b e r , w h a t c a n I do? A. Y o u too m a y f i l e a n a m e n d e d d e c l a r a t i o n b y D e c e m b e r 15. In t his c a s e if y o u r e c e i v e a b i l l f r o m the C o l l e c t o r for an instalment resulting from your September d e c l a r a tion, y o u s h o u l d s e n d t his b i l l w i t h y o u r a m e n d e d d e c l a r a t i o n to the C o l l e c t o r , a l o n g w i t h a n y r e v i s e d p a y m e n t s h o w n to b e due f o r D e c e m b e r , o n y o u r a m e n d e d d e c l a r a t i o n . Q. Can a h u s b a n d and wife m ake a joint declaration, t h e y do c a n t h e y f i l e s e p a r a t e l y n e x t M a r c h ? A. Yes. Q,. What A. T h e r e is a p e n a l t y o f 1 0 p e r c e n t to f i l e a d e c l a r a t i o n o n time. of Q. What tax I n s t a l m e n t A. If the p a y m e n t is l ate, t h e r e is a p e n a l t y o f $ 2 . 5 0 2 - 1 / g p e r c e n t o f the tax, w h i c h e v e r is g r e a t e r , f o r i n s t a l m e n t w h i c h is l ate. I overestimate; if I d o n 5 t f i l e a if I don't pay an if any, be determined? income tax what happens? I n o v e r p a y m e n t o f the c o r r e c t the C o l l e c t o r w i l l t h e n . and overestimated in and if declaration? estimated the tax for failure on ti m e ? or each 4 o f the « forms or a s s i s t a n c e Q. W h e r e can I get i n g t h e m in? copies A. Prom your local have forms left still good. Colle c t o r of Internal Revenue. If you o ver from September, however, they are Q. H a s n Tt the V i c t o r y t a x b e e n A. T h e o n l y c h a n g e in t he V i c t o r y t a x w h i c h a f f e c t s the d e c l a r a t i o n r e l a t e s to the p o s t - w a r c r e d i t . If y o u use the s i m p l i f i e d w o r k s h e e t , no c h a n g e is n e c e s s a r y . If y o u u s e the m o r e p r e c i s e w o r k s h e e t , g i v e y o u r s e l f c r e d i t f o r a l l o f the p o s t - w a r c r e d i t ( f o r m e r l y , t a k i n g this credit d e p e n d e d on p u r c h a s e s of war bonds, etc.). Q. Will I still have M a r c h 15? A. Yes. N o t h i n g i n the p a y - a s - y o u - g o s y s t e m c h a n g e s the r e q u i r e m e n t for filing a n annual tax return. The only d i f f e r e n c e is t h a t w h e n y o u do f i l e y o u r a n n u a l r e t u r n y o u w i l l h a v e p a i d a l l or a s u b s t a n t i a l p a r t o f the tax, a n d the .only p a y m e n t t h a t y o u w i l l h a v e to m a k e o n the a n n u a l r e t u r n w i l l b e a n y a m o u n t of t a x w h i c h y o u r a n n u a l r e t u r n m a y s h o w t h a t y o u o w e a f t e r d e d u c t i n g the a m o u n t s a l r e a d y p a i d u n d e r t he p a y - a s - y o u - g o s y s t e m . In f act, m a n y p e r s o n s m a y b e e l i g i b l e f o r r e f u n d s o r cr e d i t s b e c a u s e their a n n u a l r e t u r n s m a y show that they h a v e paid, s d m e w h a t m o r e t h a n the c o r r e c t tax. changed lately? to f i l e an a n n u a l o in f i l l Oq - tax return b y next (22 A p p e n d i x d . ) The exemption provisions require the determination of the questions ■whether sales are made to governmental agencies and whether the articles or services are for the exclusive use of these agencies* Because of the numerous types of contracts under which sales are made to the Government and the greatly expanded scope of its activities, considerable work is required to establish proof of the conditions upon which the exemptions depend* The services of employees taking care of these details could be better utilized in other activities. Repeal of the exemption privileges also may well increase the net revenues of the Federal Government because it is believed that the present system results in considerable loss of revenue through care lessness, errors, and possible fraud* The tremendous volume of paper work involved makes it impossible for the personnel now available to check adequately transactions for which tax exemptions are requested, (21 Appendix^ 'cont* d.) r Termination of certain governmental excise tax exemptions Section 307 of the House bill provides for the termination of numerous excise tax exemptions on sales of goods and services to the Federal Government as requested by the President in a letter dated August 11, 194-3, to the Chairman of the Committee on Ways and Means, The chief taxes affected are the manufacturers* and retailers* excise taxes, the taxes on the transportation of persons and property, and those upon charges for the use of communication facilities. It is believed that this amendment would achieve considerable savings in the manpower now used by the Federal Government and private business to administer these exemptions (20 Appendix J&'cont'd.) Another consideration involves the retailers* excise taxes. At the present time these are levied at 10-percent rates. The House bill follows the Treasury’s proposals in providing for 25-percent rates on fur and fur—trimmed articles, toilet preparations, and luggage and related goods. With respect to the jewelry excise, however the bill provides for a 20—percent rate, compared to the 30-percent rate recommended by the Treasury. In the light of the optional character of the bulk of the items covered by the jewelry tax, the unprecedentedly high demand for these items, and the limited supplies that are available, the Treasury believes that the jewelry tax should be at least as high as the other retailers* excises. or (19 Appendix^^ont*d.) The Federal Communications Commission has indicated the desirability of maintaining the present 10-percent rate on inter national cable and radiotelegraph messages in order to facilitate its efforts in promoting international communications* The Commission has also indicated the desirability of continuing the existing tax differential between the taxes on telephone toll message charges and domestic telegraph charges* The House bill proposes to tax these two services at 25-percent rates. It should also be noted that because of competitive relationships existing between domestic telegraph messages and leased wire services, the taxes on these two types of services should preferably be at the same level. The House bill provides for a 25 -percent tax on domestic telegraph messages and a 20-percent tax on leased wire, teletypewriter, and talking circuit special services (18 AppendixjSfcon^d.) r Finally, special problems are raised by "the excise "tax provisions in the House bill* The first relates to the amount of tax increase on fermented malt liquors. An increase of $1 per barrel as provided in the House bill would represent .2 cents per 8-oz. glass and .3 cents per 12—oz. bottle# Xf distributors were permitted to increase their unit selling prices by a full cent they would gain larger profits because of the tax and the Treasury would not get the full benefit of the higher consumer outlays. On the other hand, if price increases were not permitted, distributors would be compelled to absorb a part of the higher tax. A $3 per barrel tax increase as originally recommended by the Treasury would more nearly approximate full cent price increases on customary units of sale. (17 r cont*d.) A further difference between the House bill and the Treasury* s excise proposals is the failure to repeal the tax on transportation of property -which was enacted last year. This tax is undesirable, since it disturbs existing price and competitive relationships and results in discrimination among competing producers. It conflicts with the Government*s efforts to stabilize prices and the advantages ■which would follow its repeal would more than offset the $170 million decrease in revenue. (16 Appendix >nt*d.) The second reason why the House bill does not meet the Treasury’s $22 billion excise tax goal is that it includes rate increases below the levels recommended by the Treasury for the taxes on distilled spirits, fermented malt liquors, wines, general admissions, trans portation of persons, and jewelry* The higher rates proposed by the Treasury would raise $689 million more than those in the House bill* The Treasury again recommends the wartime increases originally proposed for these taxes. These increases are fully warranted in view of the great wartime increases in demand for these articles and services and the prevailing scarcities in their supply. Taxing soft drinks and candy and chewing gum as recommended by 7 the Treasure would raise $367 million* The supplies of these items are appreciably below the wartime demands of consumers and, consequently, the proposed taxes could be shifted forward to consumers without reducing the total volume of sales* While vending machine operators probably could not find a satisfactory method of shifting the taxes on these products, it is believed that they generally could continue to operate profitably by distributing non-taxable products such as nuts, raisins, cookies, and non-aerated soft drinks The first reason is that the recommended increases in tobacco taxes and the proposals for taxing soft drinks and candy and chewing gum were not adopted in the House# These recommendations would raise $852 million# Failure to provide for wartime increases in the tobacco taxes cannot be justified on the basis of the prevailing demand and supply conditions in the industries involved. The proposed tax increases could be passed forward to consumers without burdening tobacco growers, manufacturers or distributors* From the standpoint of the probable effects on consumers and the industries, there are just as good reasons for obtaining additional revenue from the tobacco taxes as from the other excise taxes included in the House bill. \ (13 Append! 35 Analysis of excise tax provisions in House Bill The magnitude of our war finance requirements and the need for absorbing excess consumer spending power to the greatest extent possible demand that every effort be made to reach the excise tax goal recommended b y the Treasury* billion The provisions in the House bill would go only about half the way toward meeting the Treasury1s goal. There are two principal reasons for this difference 12. A detailed comparison of the Treasury’s excise tax proposals Tan. and m t h iKe changes contained in the House- the existing rate together -with the estimated revenue effects, is showi in Exhibit 11. (Appendix^ cont’d.) The Treasury also proposed to raise an additional $852 mil lion from rate increases in the tobacco taxes and from new taxes on soft drinks and candy and chewing gum. None of these proposals is included in the House bill/Urtinally, the House bill does not provide for repeal of the tax on transportation of property, 10 ♦ (Appendix^ ^ o n t *d •) Excise tax changes included in the House bill, but not in the Treasury’s proposals, are the increases in rates on electric light bulbs, international telegraph messages, and -wire equipment services, and the new excise on pari-mutuel betting* The addition al revenue from these changes is estimated to be about $51 million In most cases the items selected for heavier taxation in the House bill are the same as those in the Treasury*s recommendations. Some of the rate increases in the House bill, however, are not as great as those suggested by the Treasury. As a result the House bill would raise an additional $1.1 billion from items included in the Treasury’s proposals, -whereas the Treasury suggested raising about $1.8 billion from these same sources. 8, ( A p p e n d i x ^ c o n t 1d.) 2 m General comparison of Treasury recommendations and the House action on excise taxes and postal rates The Treasury’s excise tax proposals to the Committee on Ways and ■. •■ ■' ;;r‘■ ' ,/ ■ ■ : Means were designed to raise an additional $2 A r. AV. ’ : ■ . billion of revenue # \fe. ■ V n nn K The excise tax changes embodied in the House bill are estimated to raise an addi tional fl.2 billion of revenue. The bill also provides for higher postal rates estimated to_ produce an increase of $184 million in postal revenues, ■ 7, ( A p p e n d i x 'eont1d) Third, under the excise method, we would be certain that a net gain, rather than a loss, would be achieved on the anti-inflation front. The excise tax proposals -would not affect the farm parity index, while a gen eral retail sales tax designed to raise the same amount of revenue would increase the index by more than 2 per cent. The excise proposals would increase the cost-of-living index by about 1 per cent, while an equivalent sales tax would raise it by almost 3 per cent. These increases would occur at a time when vigorous action is being taken along many fronts to living costs down. keep The net effect on business costs would be minor under the excise method, particularly if the recommended repeal of the tax on transportation of property is accepted. Under the sales tax method price ceiling adjustments to compensate for the sales tax on various business cost items would be unavoidable. From the standpoint of the effects on the parity index, the cost-of-living index, and on business costs, therefore, the excise method offers significant advantages. Therew o u l d be no risk of upsetting the Government’s wartime stabilization program, particularly because the costs of basic necessities would not be affected. 6. (Appendix^^pont*d.) Second, the lower income groups -®ould not be forced to reduce their consumption of the necessities of life as they inevitably would under a sales tax. A retail sales tax, ap plying to the bulk of consumer purchases, does not give these groups any real choice between paying the tax and escaping it by cutting their taxable purchases. Higher prices for the things they buy, whether induced by a sales tax or any other cause, simply mean that many low-income consumers must exist at a still lower living standard 5* (Appendj ont*) There are at least three fundamental reasons "why the (excise '****Jl' • method is to be preferred* V“rvyVv'yv\ First, the added administrative and compliance effort would be only a small fraction of what would be entailed by a retail sales tax* There would be no substantial enlargement of Bureau of Internal Revenue staff* Few new adminis trative procedures would have to be established, and the added number of taxpayers would be far less than the 2 l/2 million firms jWhiftU would be covered by a retail sales tax, While formulating the Treasury’s excise program, we made comparisons with a sales tax proposal designed to yield an equivalent amount of revenue* To raise $2 l/2 billion by means of a sales tax would require about a 4, per cent rate on all retail sales, on basic living needs as well as on non-essentials and luxuries* If food sales were exempted, the required rate would be more than 6 per cent, and if the exemption were extended to cover also medicines and clothing, the required rate would be over 9 per cent. (Append! J0<Jpnt 'd.) Similarly, there is every reason to believe that the higher taxes would not cause hardship for consumers. The prices of only a relatively few non-basic commodities and services would be affected. Consumers in a difficult economic situation would be given a real choice between paying the higher taxes and de creasing their purchases of these non-essentials and thereby relieving themselves of part or all of the taxes 2. (Appendix Substantial wartime increases in our excise taxes on consumer goods and services are justified on several grounds. The additional administrative costs would be relatively small for the Government, as would the taxpayers* costs of compliance. There is every reason to believe that few, if any, of the business concerns affected would be unduly burdened, since the higher levies generally could be shifted to consumers with little dif ficulty. Wartime supply shortages are troublesome for many industries, to be sure, but these very shortages, coupled with the high level of consumer income, create a market situation extremely favorable to forward shifting of excise taxes. Excise taxes 1, General basis for recommendations — We have recommended that an additional $2 l/2 billion be raised through increases in the rates and changes in the basis of several existing excise taxes and through enacting two new excises. In addi- I tion,\^he tax on the transportation of pr ope r t ^ i s re commended repeal^^The specific items selected for heavier taxation, as well as the level of the proposed rates, were determined after detailed anal ysfs had been made of the demand and supply conditions in the different industries, and after consideration had been given to the manner in which producers and consumers would be affected. Moreover the Treasury recommendations on excises are part of a.program* ttfat- ropt--ffi-ijitftrt. ^ ijr'win!nf»i^iinrV^i ifi >frih‘f“A‘*K*ft - 7 - (Appendix However, if the coal « a ^ i r o n Sw*ee9Mkls to be retained j fy A in Section 735, the amendments introduced in the House Bill^ In the case of coal mines and timber blocks, the distinction between new and old properties appears to be a tenuous one which has resulted in some inequities. Q m to. »q^«,ii5 imaatey corporate lessors of coal amfe A iron and timber properties should be entitled to the same relief now granted by the law to the operators of such properties - 6 - (Append! Last year, when the Revenue Bill of 1942 was being considered by your Committee, the Treasury w 1r the rinmi11irin1 formula which was made applicable to producers of coal, iron, and timber* We believed then, as we believe today, that a measure which distributes tax relief without regard to need not only deprives the Government of much needed revenues, but also results in an inequitable distri bution of the wartime tax burden among business enterprises. tl,4 - (Appendix* Second, we believe that the problem faced by the natural gas industry as a result of accelerated output is rather than a^fraa* problem, /Heliyf* primarily a "ffwniitai. Srorft '.taxes is ouerght layisfae its ^bfiS ewnr^i 4’n to 11,^ - ^ r waiU ^ 1* §? in'" v"** The Treasury is of the opinion that the position of the natural gas industry is not so unique jgf thag respectxthat it should be relieved of the wartime taxes which Congress has imposed upon industry as a -whole. -'3 Our reasons are twofold* ,CT^tiSfi -•madar. (Appendix First, we bolimim 'bloat CttU flrmfl.ft*!1 i? < ^ ro ic ijm ^ H£0fau/t44rt ^<SL— * steadies of\^ number of the representative companies in this industry it appears that the Industry, as a Dhole, is now t 11 UAC&njQ earning as much per unit of output, after excess-profits taxes^ 7 ■ ' “'v'v as it earned during the base period years. It is our belief that the excess-profits tax cannot be said to be injuring an industry if this tax allows the industry to retain its normal unit profits. -"2 (Appendix The Treasury recognizes that natural gas is a depletable resource, the production of -which has greatly increased since the beginning of the -war. It "would not be opposed to the amendment of Section 735 to include ^rodgcers of natural gas. However, the natural gas companies -which will benefit under r\ the provisions of the House bill are primarily engaged in the operation of pipe lines. Some of these companies produce no natural gas and all of them buy a substantial percentage of the gas carried in their pipe lines. would be The Treasury believes it to extend the relief now afforded to depletable resource industries to these companies. Appendix Special excess-profits tax treatment -with respect to the accelerated output of certain natural resources A. The extension of the coal and iron gartee of Section 735 to the natural gas industry The House bill provides special excess-profits tax treatment for natural gas companies -with respect to income from the production, storage and transportation by pipe lines of natural gas. The treatment given -would be the same as that now granted under Section 735 (b)(2) with respect to income from coal and iron mines. - 4 - (Appendix m Cont *d*) On the other hand, the Treasury does not believe that the extension of percentage depletion to vermiculite, feldspar, lepidolite, spodmene and potash can be justified even as a war measure* Although the first four of these minerals are used in war production, we have been informed by the War Production Board that the current output of all of them is adequate to meet present wartime requirements* Con sequently, these four minerals stand in no different position from all the other minerals which have important wartime uses but with respect to which no critical supply situation exists* Potash also has important wartime uses, but officials of the War Production Board do not believe that the granting of percentage depletion to this mineral can be ex pected to bring about the discovery and development of any new potash deposits* The vast bulk of the potash reserves in this country were discovered by Government geologists and are found on public lands* The exploitation of these deposits is controlled by the Department of the Interior, and without the approval of the Secretary of this Department it would be impossible for new companies to engage in the production of potash# ->* (Appendixfl^tfont *d) The Treasury’s position with respect to the extension of percentage depletion to strategic minerals as a wartime measure is the same as that with respect to the exemption of these minerals from excess~profits taxes. If, hut only if, the allowance of percentage depletion for the duration of hostilities will contribute to the war tth%tI effort, the Treasu] P Such allowances despite our firm conviction that the percentage depletion provisions in the present law have, in general, enabled many individual and corporate taxpayers to avoid their fair share of the Nation’s tax burden. Generally, our position with respect to percentage depletion is the same as was expressed in hearings on the 19^2 Bevenue Bill. 1/ However, on the basis of the representations of the War Production Board that percentage depletion for these metals for the duration of the war will contribute to the war effort, we concur in the action taken in the House Bill in granting percentage depletion to fluorspar, flake graphite, sheet mica, and beryl. 1 / See Secretary Morgenthau’s statement, page S, and testimony v pp. SU, 2.9&S, 3^32, Hearings Before Ways and Means Committee, 0 77th Congress, Second Session. A year ago the Treasury, after consultation with officials of the War Production Board, recommended that the income from the production of 11 strategic minerals be exempt from excess- U U X — and flake graphite, to this list of minerals; both of these minerals are of jfesfestrategic importance* However, we see no possible reason for the inclusion of vermiculite among these strategic minerals* Although this mi _ > the opinion of officials in the War Production Board that the present supply is more than adequate# The bulk of this mineral is used for building insulation in competition with rock wool and asbestos, products which no one mould presume to say were of strategic importance* EFFECTIVE NET* TAX RATES ON CORPORATION INCOME AS THE PROPORTION OF TAXABLE EXCESS PROFITS VARIES > Under Present Law, H. R. 3 6 8 7 and Suggested Revisions in 8 0 Percent Limitation * A fte r p o s tw a r re fu n d . N o te : N o rm a l ta x a n d s u rta x n e t incom e assum ed e q u a l and g re a te r th a n $ 5 0 ,0 0 0 . Office of the Secretary of the Treasury Dwiston of Tax Research B-476 Appendix w Table I Effective tax rates on corporation income as the proportion of taxable excess-profits varies, under present law, H. R. 3687, and suggested revisions in the 80-percent limitation Taxable excess profits as a percent of taxable income Notes Total taxes as a percent of income under • Present law : H. R. 3687 i Revision A Revision B : Revision C • 4 4 , Net l Gross ! Net! Gross* Net Gross * Net ! Gross! Net 1 Gross « 4 4 4 4 4- 4 0 10 20 30 40 50 40.0 45.0 50.0 55.0 60.0 65.0 40.0 44.1 43.2 52.3 56.4 60.5 40.0 45.5 51.0 60 70 80 90 100 70.0 75.0 80.0 80.0 80.0 64*6 68.7 73.0 78.5 80.0 80.0 80.0 7 2 .3 72.4 7 2 .0 5 6 .5 62.0 67.5 4 40.0 44.6 49.1 53*7 58.2 62.8 67.3 71.9 7 2 .8 7 2 .4 72.0 4 4 4 40.0 44.5 49.0 53.5 58.0 62.5 40.0 44.5 49.0 53.5 58.0 62.5 40.0 45.5 51.0 67.0 71.5 76.0 80.0 80.0 6 7 .0 71.5 76.0 80.0 80.0 62.0 67.5 40.0 44* 6 49.1 53.7 58.2 62.8 40.0 45.5 51.0 56.5 62.0 67.5 40.0 44.6 49*1 53.7 58.2 62.8 73.0 78.5 80.0 80.0 80.0 67.3 71.9 76.4 80.0 80.0 73.0 78.5 80.0 80.0 80.0 67.3 71.9 76.4 76.9 76.5 5 6 .5 ‘’Gross** and ’’Net” refer to taxes before and after the postwar refund, respectively. The capital-stock and declared-value excess-profits tax are not included in this computation. Normal-tax and surtax net income are assumed equal and greater than $50,000. - 3 - (Appendix W . excess profits, and in order that a smoother graduation in effective tax rates may be provided as taxable excess-profits represent a larger and larger percentage of total incorn^ revisions aawbe made in the SO-percent limitation. Revision A would substitute an 85-percent excess-profits tax with no postwar refund for the 95-P@rcent excess-profits tax and 10-percent postwar refund in the House Bill. The SO-percent limitation would re main in effect. Revision B wouldJ^flHS?’ the SO-percent limitation^ 1W taxes (after ra th e r thai^ t?efnrfi . t . h g ■ -a kin ^ , 1 a ^ _ sM jla ^ z U ~ffrrt h M U u JtA i ^ y u , 7 t ji in most instances, of charging the reduction in taxes resulting from the SO-percent limitation against the taxpayer’s postwar refund, rather than against gross taxes. Revision C would raise the present limit of SO percent to 85 per cent, but would not change the basic structure of the limitation. The effective tax rates which would result from these changes are presented in Table I, both before and after the postwar refund, if any. In Chart I the effective tax rates after the postwar refund are shown, 1( | ____ J H I \ I _ _ __ I I* OlJ M a * j - 2 - (Appendix taxable excess profits reduces taxable normal profits. A, reduction in normal profits, and, therefore, a reduction in normal taxes and surtaxes, increases the portion of total tax liabilities (SO percent of surtax net income which remains unchanged) called excess-profits taxes and increases the postwar credit. Although gross taxes remain at SO percent of income, net taxes after the postwar refund are thus reduced. Therefore, increases in the excess-profits-tax base will reduce taxes on corporations subject to the 80-percent limitation, and increases in the excess-profits-tax rate will leave them unaffected. Only increases in the normal-tax or surtax rate, by reducing their postwar refunds, can increase the overall tax burden on these corporations without a change in the limitation. Under a 95-percent excess-profits tax, or 85^- percent after deducting the postwar refund, a still greater limitation in the excess-profits tax results. In order that an increase in excess- profits taxes will apply to those corporations earning the largest Appendix f( t / Possible revisions in the gO-percent limitation to effect a more satisfactory graduation in effective rates The Revenue Act of 19^2 provided for a limitation on the excess- profits tax so that in combination with the normal tax and surtax it will not exceed gO-percent of surtax net income. This limitation was cent of excess-profits taxes as limited. The excess-profits tax as limited is computed by taking gO per- this figure. The balance is termed excess-profits taxes and is used in computing the postwar refund of 10 percent of excess-profits taxes. Thus on a given level of income subject to the gO-percent limi tation, effective tax rates after the postwar refund are- rodueed as the percentage of that income represent«fced by taxable excess profits increases. Since normal profits (normal-tax net income) are determined by subtracting taxable excess profits’from total income, an increase in ■ »< « T»vvx fHx> X U v ¥ o B 8 iM .e _ c o m p u t a t io iB ^ n f t e r t h e tax 1 iabi 1i tvy^jr-ori n. hus band > House a i l j r i j M t i t f ¥nw i Net income a i (g) in llfy t o d e t e r m in e th e s m a lle s t ^>1, c_50 uet income and^wife wi ‘ trW.$375 net income T^*'"tr TVUL Regular personal exemption and credit for depend ents f t » . y » > t« ,^ P en^l3t__g Income subject to regular rates (3) Regular tax Personal ex emption and | Income credit for subject to dependents minimum for purpose■ | tax of minimum tax (R\ A2 jL Jh) j >SW Tax liability (^he larger of column U or 7 for each numbered line) Minimum tax (I) _____ Joint return $ 2,125 ^4 m Separ*ate returns (2 ) 1 (V, VP/ Husband Wife Total Sspar*ate returns $ 2 ,250 None None $1 ,0 0 0 $1 , 1 2 5 $3 3 * 7 5 Husband claiming credit f o r *3 dependents, wife claiming credit for no dependents 1,250 875 2,125 • 1,550 None 500 2,050 375 375 None 56.25 86.25 soo 500 1 ,3 0 0 U50 375 825 13.50 1 3 .5 0 86*25 ( 2 k+•7! 99.75 1111 Husband{claiming\credit for 2 dependents, wife claiming credit for 1 dependent IsM w (5) Husband Wife Total Separ?ite returns (6 ) (V J) 1J Husband 1 ,2 5 0 875 2 ,1 2 5 1,250 Total Husband (9) it* n il S u t l\ V ) 1 7 .2 5 700 600 1 ,3 0 0 16*50 8 .2 5 2*1.75 16*50 8*25 2^.75 S50 1,200 400 None 92*00 2,050 Uoo 9 2*00 None 600 70 0 1 ,3 0 0 19.50 92.00 5.25 2^.75 97*25 5.25 Husband claiming credit for no dependents, wife claiming credit for .3 (dependents 1,2 50 875 u ij P “31 PR o f TW*VV i VVfltI 500 1 7 2 .5 0 None 1 7P RO r. LGVtvNWv llO i 75© TR 1-/ 22.50 OO OP C. 1 7 2 .5 0 2 .2 5 825 1 7 ^ .7 5 LO Sov>YCfc *. 5*75 OJ -fa e Total 1 1 .5 0 h• -rf (Vfi?° N/ 50 25 75 Husband claiming credit for 1 dependent, wife claiming credit for 2 dependents ftll B Separate returns 1 ,200 850 2 ,0 5 0 1 3 s - (Appendix B) The following table shows the number of taxpayers and the amount of tax increase or tax decrease and the net change 3 by net income classes under the House bill and the Treasury integration plan. Net income plass (in thousands) House s Number of s taxpayers : (millions) * Treasury integration Plan bill • Number of s Amount 4k taxpayers s Amount (millions) (millions) : (millions) Reduced taxes $ 0 - 1 3 3 5 Over 5 Total 23.2 2.7 .3 26.2 1 - 342.3 - 24.5 3^ - 370.3 Ml 15.7 1.8 ,5__ 18.0 $ - 357.2 - 27.9 - 50.7 . - 435.9 Increased taxes $ 0 - $-3 3 - 5 Over 5 20.2 Total 26.2 2.0 . 189.6 27.5 5.0 52.7 217.1 ^ ___ 3^2____ 406 .0 99.0 206 f3 4.59.2 34.4 ‘ 711.3 11.8 3.2 1.4 48 .8 71.1 155.6 Net change & $ 0 - $ 3 3 5 Over 5 Notes 3.2 1.4 1.7 - 152.7 28 .2 213.6 Due to rounding the sum of the individual items may not add to totals. — 7a - (Appendix B) The Treasury plan would exempt 9.1 million taxpayers who now pay a net Victory tax of $274*9 million. Including these^ there would be IB million taxpayers with a total reduction in tax of $435*9 million. The Treasury plan would increase the liability of approximately 3 4 million taxpayers by $711*3 million - Y - (Appendix B) 7* The House would exempt only about 130,000 taxpayers who now pay. a net Victory tax of about $600,000• Including these taxpayers, a total of approximately 26 million taxpayers would obtain a reduction in tax of $370.3 million. On the other hand, another 26 million tax payers would pay an increase in tax aggregating $459.2 million. - - (Appendix B) Ti .......... rFi ffi i I'll" I1" 1 ni ’.... rii --tii n m *— thR i|nnom^.to||ijvith t s r ^ r s r sm n^llion ! ------ | r ....... T .. ' i a m . r w e m i m - t i m e ^ m o ,i.. 1lrvW t h ie Treasury plan (fcJ $ a (Appendix B) 6# It is clear that the House $ i l l would make the income tax more complicated and would impose greater administrative burdens than the Treasury integration plan* The repeal of the Victory tax is an important step toward simplification but under the House ^ i l l this is offset to a large extent by other complications introduced by the Sill, which would not exist under the Treasury plan. tl « 5* 6v- (Appendix B) Another difficulty under the House Bill is that some taxpayers who may now file a simplified return would be precluded from doing so. Under the regular income tax, the exemptions^on separate returns are lower than those on a joint return. Many married couples with a combined gross income of more than $3 ,000, wishing to file a joint return to take advantage of the higher exemptions, will therefore not be able to file a simplified form, since Form 10A0A is limited to a return with a gross income of $3,000 or less. jO^ 5& (Appendix B) 5 using form 1040A) after making IB different computations of tax the •wife before ascertaining the least f- the Treasury integration plan and under the present law the multiplicity of computations is not necessary. /O (Appendix B) J*,* A. further complication for many taxpayers introduced by the House bill is the necessity/ if separate returns are filed, to allocate as the dependent exemption in such manner as to reduce the tax liability to a minimum. Many computations m a y be needed by taxpayers ■with several dependents to find the procedure that -will result in the least tax for a couple. It is true that in many cases it Yjould be possible for infor mation to be provided to guide married couples to the expeditious determination of their tax liability under either the minimum tax or the regular tax. Nonetheless, the problem of complying with the income tax law will be much more complicated for many couples with low incomes under the House bill than under the present law or/under; the Treasury integration plan. Many couples with low incomes in the area where it is now a matter of indifference whether they filed Joint or separate returns or how they divided the dependent credit would, under the House bill, need to make numerous computations before reaching the most advantageous tax result. i §1 j§ ; /■/■. ■ i| •;SB / For example, a married couple with an aggregate net income of $2,125 and with three dependents could, depending upon the procedure that happened to be selected, reach 10 different tax results (5 using form 1040 and - 9 - (Appendix B) The relationship between the personal exemptions and dependent credits under the minimum tax and the regular tax may result in much confusion. For example, a husband and -wife having two dependents may lift: file separate returns } each claiming one dependent. B i l l on^spouseynay have an exemption of subject to a 3 exemption of 1350 tax rate. #100 Under the House for one dependent and be percent tax rate, while the other spouse may have an for the other dependent and be subject to a 23 percent - B - (Appendix B) The complexities with respect to joint or separate returns under the House2bill follow from (a) the provision that a married couple filing separate returns shall each be allowed an exemption of $500 in contrast with the $1,200 allowed on a joint return under the ordinary income tax, (b) the provision that no part of the personal exemption allowed on a separate return may be transferred from one spouse to another, and (c) the variation between the personal exemption and dependent credit under the minimum tax as compared with the regular tax. - 7 - (Appendix B) Under the simple integration plan suggested by the Treasury, there is only one breaking point which can be stated in terms of surtax net income for all taxpayers, just as under present law. ^ >elkduA^ 4» <*> Con*j g&e, The accompanying J chart/illustrates the difference in this respect between the Treasury proposal and the House Jill. - 6 — (Appendix B) culation can be simplified, but for those required to use the regular income tax form, complexities could not be avoided. The breaking points are difficult to compute and -would not be known to most taxpayers unless the Treasury undertook to supply a complicated series of tables indica ting the zones of advantage under joint and separate returns. A sample of this type of table, relating only to one assumed division of income (50- 50) between husband and wife, and only to a married couple with one dependent, follows: Combined net income $ *TyPe of return resulting in lesser tax m 800.00 - $1,070.60 1,070.60 - £ t 083»33 Over &)Q&3w3&5’iU.L1 Separate Joint Separate - 5 - (Appendix B) Under present law it is to the^advantage pf a married couple to file separate.returns' if their combined surtax net income exceeds $2 ,000. If their surtax net income is below that amount, it is ordinarily a matter of indifference to them whether they file separate or joint returns. House bill, heavever, igpnnrrag illn l i The md makes it advantageous for some such couples to file^ — nt returns and for others to file /separate returns. At the same time, however, it makes the determination of whether a joint return or separate returns should be filed, a complex problem for many of these taxpayers. law, there are two. Instead of one breaking pbint, as under present Instead of one breaking point fixed in terms of sur- tax net income, as under present law, the House bill results in twoAbreaking points. On incomes above the higher breaking point and on incomes' below the lower breaking point separate returns are advantageous. In the area between, joinl OJVL. is primarily onIthe division of of income income between husband and wife and also^S* ths number of dependents. For individuals filing under Supplement T the cal- 4 — 3* (Appendix B) Married taxpayers would find it much easier to comply with the income tax under the simpler Treasury integration plan than under the House 6 q.11, since under the bill the determination of whether a joint return or separate return would be more advantageous may involve numerous complications. 3 - (Appendix^ B) Under the simpler integration plan suggested by the Treasury, there would be 4-3.2 million taxpayers, a reduction of 9.1 million. number of taxable returns would be would be joint returns 36.5 million, of which 6*7 The total million *- 2 — 2* (Appendix B) The administration of the income tax would be much easier under the simpler Treasury integration plan than under the House bill. For one thing, there would be a large reduction in the number of returns involving a small amount of tax. Under the present income tax and Victory tax the estimated number of taxpayers for calendar year 1944 is approximately 52.3 million. Under the House B i l l the number of tax payers would remain approximately the same as under present law. Because of the filing of joint returns, the number of taxable returns is less than the number of taxpayers. 'The number of taxable returns would be reduced from 44.1 million (aider present law to 41.7 million^inder the House bill. $ Compared with the 8.2 million joint returns under present law there would be 10.7 million joint returns under the House Bd.ll. Appendix B Integration of the Victory tax with the income tax under the House bill and the Treasury integration proposal, com pared with present law 1* Both integration plans, the one contained in the House bill and the Treasury proposal, would repeal the Victory tax and the earned income* credit. The House R i l l increases the normal tax rate from L 6 percent to 10 JbffVuZ- percent, reduces the surtax rateslin some brackets and increases thenkin others. A taxpayer would be required to pay the tax computed on the basis of these changes but not less than a minimum tax of 3 percent on net income in excess of exemptions of person or a married person filing a separate return, $$00 $700 couple filing a joint return, and $100 for each dependent. for a single for a married Under the Treasuiy integration proposal exemptions are reduced from $500, $1,200 and $350 3 to to $ 500, $1,100 and $300 , and/surtax rates are increased ty 7 percentage points, s APPENDIX »A” (CONTINUED) The Treasury recommended increases in corporate surtax rates, but no change in the amount of excess-profits taxes. does not change surtax rates. The House bill It increases the revenue from excess- profits taxes by increasing the rate from 90 to 95 percent and by making changes in the excess—profits credit.WThe Treasury recommended an increase in estate and gift tax rates and a reduction in exemptions The House bill does not change the estate and gift t a x e s J f ^ n the case of excise taxes, the House bill differs from the Treasury’s rec3ommendations in that (l) it does not increase tobacco taxes, (2) it does not tax soft drinks, candy and chewing gum, (3) its rate increases generally are lower than those recommended, and (A) it retains the tax on transportation of property^fEinally, the House bill provides for increases in postal rates on which the Treasury made no recommendations / APPENDIX A Summary Comparison of the Treasury Proposals With the House Bill v . \M / It may be helpful to the Committee to compare, the major provisions of the Treasury proposals -with those of the House bill as background for its consideration of that bill. While the Treasury proposals rely heavily on the individual income tax for additional revenue, the income tax changes in the House bill are designed primarily to integrate the Victory tax -with the income tax. the earned income credit. Both would repeal the Victoiy tax and The Treasury proposal would effect a small reduction in the credit for dependents and the exemption for married persons 5 it would increase surtax rates substantially, both to replace the Victory tax and to increase revenues. a 3-oercent The House bill imposes minimum tax with lower exemptions than the regular tax$ it also increases normal tax rates and adjusts surtax rates, primarily in order to replace the Victoiy tax burden. LIST OF APPENDIXES Summery Comparison of the Treasury Proposals with the House Bill Integration of the Victory Tax with the Income Tax Under the House Bill and the Treasuiy Integration Proposal $ Compared with the Present Law Possible Hevisions of the 80-»peroent Limitation to Effect More Satisfactory Graduation in Effective Hates Additional Tax Relief for Corporations Engaged in the Mining of Certain Strategic Minerals Special Exeess-Profits Tax Treatment with Respect to the Accelerated Output of Certain Natural Resources Excise Taxes Corporation income and excess profits tax rates 1, m r r^i t o s Fre sent.»&&&« Normal tax rates Normal tax net income Not over 3 2 5 ,0 0 0 First $5 ,0 0 0 . Next 1 5 ,0 0 0 Next 5»000 Over $25,000 to $50,000 (notch) X ' t 19 i No change $h,250 plus 31# of excess over 3 2 5 ,0 0 0 2 Over $5 0 ,0 0 0 2. f b f o Surtax rates Surtax net income 10 Not over $2 5 ,0 0 0 Over $2 5 ,0 0 0 to $5 0 ,0 0 0 (notch) $ 82,500 plus 22/0 of excess over $25,000 26 $ ItoJ $ Combined normal and surtax rates 25$ to 29 Not.over $25,000 Over 3 2 5 ,0 0 0 to $50,000' (notch) Over $50,000 h. $3,500 ulus 3g$ of excess over $25,000 16 Over $5 0 ,0 0 0 3, 'l Excess profits tax rates fo ' . 29 $ 55$ 69$ ho 30 $ $ 9 0 $ No change Treasury Department, Division of Tax fiesearch ^0 33$ lij^v ■ | / d Exhibit 10 IN D IV ID U A L I N C O M E T A X Effective Rates for Married Person without Dependents * I n c lu d e s N e t V ic to r y Tax; n e t i n c o m e Office of the Secretary of the Treasury Division of Tax Research * a s s u m e d to b e 9 0 % ^ E x e m p tio n s $ 5 0 0 ~ $ 1 , 1 0 0 $ 3 0 0 ; a n d n o t V i c t o r y o f g r o s s in c o m e . T a x a n d e a r n e d i n c o m e c r e d i t e lim in a t e d . B-450-2 Estimated excise tax liability under the Treasury proposal as presented to the Committee on Ways and Means of the House of Representatives on October 4, 1943, as compared with present law for a full year of operation 1 / Present tax 1. Distilled spirits. $6 per gallon (draw-back of $3.75 per gallon on nonbeverage alcohol). 2. B eer---------------- ------------- -~i------3. W ine: (а) Still: Under 14 percent alcohol.. . 14 to21 percent alcohol------Over 21 percent alcohol— (б) Sparkling.----------— -----------(c) Other----------------------- - - - -----4. Cigarettes_____ A ---------- - - ------------ $7 per barrel----------------- $10 per gallon (draw. back of $7 per gallon on nonbeverage alco hol) . $10 per barrel--------------- 10 cents per gallon— 40 cents per gallon— $1 per gallon-----------10 cents per half pint. 5 cents per half pint. $3.50 per thousand. _ 50 cents per gallon------$1 per gallon_________ A $2 per gallon_________J20 cents per half pin t. . j . . 10 cents per half p in t..y $5 per thousand______ > Article or service Intended retail price— 5. Cigars. Over N ot over Cents Cents Intended retail price— T ax per 4 6 8 15 20 Cents $2.50 3.00 4.00 7.00 10.00 19. Candy and chewing gum . N one. T otal additional revenue, items 1 to 1 9 . . --------- repeal of tax bp . . Less transportation of property, 3H f m 87.2 210.5 61.1 371.3 T ax per f thousand N ot over Oyer 6. Chewing and smoking tobacco' 18 cents per pound. and snuff. 7. General admissions---------------------- I cent per 10 cen ts.. . 8. Cabarets_________________________ 5 percent of charge. . 9. Club dues and initiation fees-------- II percent of charge . f$10 per alley—— -----10. Bowling alleys, billiard p a rlo rs.... \$10 per table— . — 11. Transportation of persons------------ 10 percent of charge. 12. Communications: 20 percent of charge. (o) Toll service____ _________, (6) Telegraph, etc.: 15 percent of charge------(1) Domestic_______ , - - t 10 percent of charge------(2) In tern atio n al..- - - - - - 15 percent of charge----- (c) Leased wires, etc/.----- -------10 percent of charge------13. Local telephone service--------------10 percent of retail price. 14. Jew elry . . . — — ------15. F u r and fur-trimmed articles.......... ____do____ i..-.-- - - - - - - - - 16. Luggage, handbags, wallets, e t c ... 10 percent of manufac turers’ sales price on luggage only. 10 percent of retail price 17. Toilet preparations. None_____ L—-------!----- 1 18. Soft drinks______ _ 20 Estim ated additional revenue from proposals (iii millions) 1 Proposed tax - 5 7 9 17 22 Cents 3H 5 7 9 17 . 22 67.7 $12.56 13. 06 14.00 17.00 30.00 35.00 40.00 34 cents per pound. 3 cents per 10 cen ts.. 30 percent of charge-----20 percent of charge-----20 percent of charge-----$20 per table----------------25 percent of charge____ 46.2 327.0 91.3 5.1 27.0 212.7 .d o . 20 percent of charge. . 10 percent of charge— ._ 20 percent of ch a rg e ..-. 1. 15 percent of charge 30 percent of retail price. 25 percent of retail price. ____ d o . . . . , ........... 25 percent of retail price. Bottled drinks, 1 cent y'perj&ach 5 cents of inTerfaed retail price; the equivalent taxes of $1 per gallon on sirup and 25 cents per pound on carbonic acid gas used in unbottled soft drinks. Articles intended to re tail from 5 to 15 cents per bar or package, 1 cent per each 5 cents of intended retail price; other items, the equi valent tax of 35 per cent of manufacturers’ sales price. 3.15 167.3 -54,-8-' 53.4 51.4 177.0 0^90.0 2,681.4 170,5 5J Total additional revenue, items 1 to 2 0 ... .^2,511.1 Treasury Department, Division of Research and Statistics. November 29, 1 ^ 3 1/ Estimates of additional revenue are for a full year of operation at levels of business estimated for calendar year 1944. 2/ Estimated additional net revenue yield after allowance for in creased drawback on nonbeverage alcohol of & 12 .8 millions. 5/ Including the effects of H. R. 5359, Public Law 180, approved November 4, 1943. BxkiiUit 9 - Table 3a Effective rates of individual income tax under present law* the Treasury proposal of Oct* 4 , 1943, and two alternative schedules Married person «* two dependents Present law - $1,200, $350 Proposals - $1,100, $300 Exemptions: #0 Net income l before ftf Present law personal ft0 including exemption * net Victory tax 1 / t $ 1,7 0 0 1,800 1,9 0 0 2,000 2,50 0 3 ,0 0 0 4,000 5,000 6,000 8,000 10 ,0 0 0 12 ,5 0 0 15 ,0 0 0 20,000 25,000 50,000 * 75,000 100,000 500,000 1,000,000 5 ,000,000 2 .1 # 2*2 2*2 2 .? 6*4 8.9 12 .1 14.6 1 6 .3 1 9 .4 22*1 25*2 28.0 33*5 38.3 5 2 .8 6 1 .6 6 7.8 88.0 89.9 2 / 90*0 2/ : Treasury : S proposal, J Treasury 1 Oct* 4, t proposal A 1 « 2/ Increase 1 % Treasury i Treasury ft proposal, # 1 proposal B I Oct. 1*. t 0 s 19“*3 ... - - 2.156 - .7 «• 1.556 2*8 1.656 1.756 4,1 9*0 >*.2 2.9 3.2 4*5 9-3 13.2 19.4 23.9 27.1 9 .8 .6 1,2 2 .6 13.7 3.9 24.2 27 .1* 6 .7 8 .7 1 0 .2 1 2 .1 1 2 .8 18*8 23.3 2 6 .5 1 9 .8 31,5 3 2 ,0 3 2 ,0 3 5 .6 35.5 39.0 1*1.9 1*6.9 51.1 35.0 39.7 4 3 .3 *19.6 55.0 70.1 77.2 81.1* 93.1 94.5 95.7 13.5 14.5 3 8 .0 1*0.2 1*3.8 H6.7 5 7 .0 6 2 .7 68.9 1 5 .2 16 * 1 1 6 .7 1 7 .3 1 5 .6 1 3 .6 5 .1 6 3 .6 6 8 .7 73.2 88*6 88.4 9 0 .8 9 2 .6 Treasury Department, Division of Tax He search 1/ 1 t Effective rates 9 1 .2 93*4 ' S **»7 5.7 +'SfB j1 Treasury 1 Treasury : proposal A 1i proposal B i 111 i 5 i - 2 *1 $ - .6 .7 1.3 3.0 4 .3 7 .3 9.3 10 .8 1 2 .6 1 3 .4 1 3 .8 1 3 .S 1 3 .5 12.8 9*9 7.2 5.4 *6 •9 2 .6 - 2.156 - .5 .9 1.6 3.5 4.8 7.7 9.6 1 1 .1 1 2 .6 12 .9 12.8 1 2 .2 10.3 8 .4 4.2 2.0 .4 ,.1#3 3.5 November 29, 19^3 Maximum earned income credit assumed, Victory tax net income assumed to he ten-ninths of net income* Talcing into account maximum effective rate limitation of 90 percent* Exhibit 9 - Sable 3 Amounts of individual income tax under present law, the Treasury proposal of Oct* 4, 19 U 3 , and two alternative schedules Married person - two dependents Exemptions; $ 1,700 1,900 2,000 2,500 1,800 i5.000 ,000 ,000 5 ; Present law including l l net Victory tax 1/ $ 10,000 12,500 15.000 20.000 25.000 50.000 75.000 100,000 500,000 1 ,000,000 5,000,000 $ : Treasury : : : t :Treasury s Treasury t proposal,; Treasury r Treasury lproposal A : proposal B l Oct* 4, s proposal A {proposal B I s 27 28 56 $ 5* 84 233 397 776 81 225 384 485 SIS 753 . 1*163 1,588 1*196 1,628 2,523 3*555 2,557 3.546 6,489 9*912 13*750 35*037 57.919 81,435 465.418 6,284 9*388 4,870 4*962 4,207 6,693 9*574 26,392 46,209 67,803 ^39*931 898,800 2j 4,1*98,800 2/ 945.418 ,785,418 12,780 31*3^ 2/ 51,642 73*17^ 443,089 908,089 4,628,089 Treasury Department, Division of Tax Research 1/ Amount of increase 22 2a. ** ** 159 267 1.553 2,208 8.000 19U 3 i58 6,000 ’ Treasury proposal, Oct* 35 9 730 A Jl Amount of tax I Net income before personal exemption 1 200, $350 1 100, $300 $ , $ , Present law Proposals $ 30 60 90 246 412 791 , ll 1.643 12 2*563 3*%5 4,745 6,034 8,753 11,678 28,481 47,678 68,726 442,107 912,107 Ij^,672,107 - $35 - 12 12 23 66 117 268 433 609 970 1*3^7 1,818 2,282 3*219 4,176 8,645 11,710 13*632 25.^87 46,618 286,618 - $35 9 18 32 - $35 14 11 26 7^ 130 87 306 11*5 291 466 481 664 6119 1,010 1.287 1,601 1.827 2,060 * 2,104 2,089 1,004 1*338 1,726 2,077 2*695 >206 4,952 5*433 5*371 3,158 129 2 9*289 * #) 1,469 923 2,176 13*307 173,307 November 29* 19^3 Maximum earned income credit assumed* Victory tax net income assumed to "be ten-ninths of net income* Taking into account maximum effective rate limitation of 90 percent* Effective rates of individual income tax under present law* the Treasury proposal of Oct* 4, 19143, and two alternative schedules Married person — no dependents Exemptions} Present law - $1,200 Proposals - $1*100 i before t Present law : Treasury™nr™ § • personal t including : proposal, ; Treasury : Treasury exemption i net Victory : Oct. 4, l proposal A ^proposal B f » tax I f i • * 19^3 $ 1 ,1 0 0 1*6$ m 1,2 0 0 1*8 2 .% 2 .5$ 2.3# 1 ,5 0 0 8.0 7.2 5.3 7 .5 1,6 0 0 8.4 8*8 6.3 9.4 1,800 8.0 10.8 11.2 11.9 1,9 0 0 11.8 3.7 12.9 12.3 2,000 9*4 12.8 1 3 .2 13.9 2,500 11*9 1 6 .7 17.2 17.8 3,000 19.3 2 0 .4 20.9 1 3 .5 4,000 16.2 2 5 .0 2 6 .1 25.7 5»ooo 28.2 2 9 .0 1 7.9 29.3 6,000 1 9 .6 32.0 31.1 31*7 8,000 3 5 .4 22.3 3 5 .4 35*5 24.7 10,000 38.6 38.0 '38.9 12 ,5 0 0 42.5 * £l*6 *40,4 27.5 15,0 0 0 30.2 45.8 44.2 42.3 20,000 51.3 48.9 45.4 35*5 25*000 40.1 56.9 52.8 *48.2 50,000 54.2 63*6 7X.1 5 7 .8 75,0 0 0 62.6 78.0 64.2 69.5 100,000 68.6 82.0 69.2 73*7 500,000 88.1 93.2 8 8 .7 , 8 S.5 1,000,000 9 4 .6 89.9 2/ 90.9 91.3 5 ,000,000 9 0 .0 2/ 9 2 .6 95.7 93*5 mm i j Treasury l fti • • proposal, : l Treasury # Oct* 4, 1 proposal j .* i 1943 ;t - 1 .6# 0 .5 1.9 2.1 2*8 3*1 3*4 4 .8 6 .3 8*8 10,3 11*5 13*1 14.2 15.0 1/ Maximum earned income assumed* 0 .6 2.2 2.4 3.2 3*5 3 .8 5 .4 '6.9 9*5 11.1 1 2 .2 1 3 .4 17.0 13*9 14.1 14^0 13.4 12.7 9*5 5.0 4.7 5.7 5*1 .6 1.0 2.6 1 5 .6 1 6 .3 16 .8 1 5 .4 1 3 .4 Treasury Department, Division of Tax Research Z j - 1*6$ 6.9 $ Treasury :proposal B - 1*6$ 0*8 2*7 3*1 3.9 4.2 M . 6*0 7.^ 9.9 11*4 12.4 13.2 13.3 12*9 12*1 9.9 8*0 3*7 1 .6 .7 .4 1.4 3.5 November 297 19^3 Victory tax net income assumed to be ten-ninths of net income* Taking into account maximum effective rate limitation of 90 percent* y a o r r a f s 04 j ugTArgrrsrj gu oo m © m sqex. c is B e u f J » m * Effective rates of individual income tax under present law, the Treasury proposal of October 4, 19 4 3 , and two alternative schedules Single person « no dependents Exemptions; Present law - $300 Proposals - $500 Net incomes________________ Effective rates_____________ s____________ Increase_________ ____ before * Present law s Treasury ^Treasury j Treasury : Treasury : Treasury : Treasury personal : Including net : proposal : proposal : proposal : proposal : proposal s proposal B A • .•Oct.4, 1943s : B A exemption jVictory tax l/s0ct*4, 1943s $ 500 600 1.855 5.055 »+.5?6 2 *8# 1*7# 4.7$ 2 .8 2 . 1 * 10.5 1 0 .1 SOO 11.3 7.8 2 .6 3.0 12.4 1 2 .0 9.4 900 13.3 1 5 .0 i 4 .o 2 .8 3.3 1,0 0 0 13.5 10,7 3.2 1 6 .5 3.7 1 ,1 0 0 15.0 11* 8 15.5 4.1 1 6 .8 1 7 .8 3.5 1,2 0 0 1 2 .8 1 6 .3 5.0 14.7 2 0 .7 4.3 19.0 1,5 0 0 19.7 4 .7 5 .4 20 .6 21*5 1,6 0 0 15*2 19.9 6.6 2l*.0 2,000 5.9 16.7 23.3 22.5 8 .2 7.4 2 6 .6 26.0 2 5 .2 2,500 17.8 29*2 9.5 2 7 .8 8.7 * 28.7 3,000 19.1 1 0 .1* 32.4 32 .0 11.3 4,000 31.1 20*7 1 2 .3 34.4 11.5 22.1 3 M 5,000 33.6 1 3 .0 1 2 .3 36.6 23.4 6,000 36.3 35.7 13.7 13.5 3«.9 8,000 . 39.2 39.3 2 5 .7 4l,0 1*2.2 13.9 1 ^ .3 10,000 2 7 .8 41.7 14.9 1*2.8 1 3 .8 1*4.2 30.4 4 5 .4 12 ,50 0 4 4 .5 46.6 bs.b 13.5 15.3 15,0 0 0 33.1 1 2 .8 5 4 .0 47.1 15.9 3 8 .1 20,000 50.9 4 9 .6 58.8 1 6 .3 11.9 42.6 25,000 5^ .5 8.1* 1 6 .1 61*. 6 7 2 .2 50,000 5 8 .7 5 6 .1 6.2 14.7 6l*.9 70 .2 64.0 75,000 7 8 .7 4.6 12.9 69.8 82.6 74.2 100,000 6 9 .7 88.6 88.8 .5 88.4 4.9 500,000 93.3 1*0 4.7 1,000,000 90.0 2/ 90.9 91.3 94.7 2*6 9 2 .6 5.7 90 .0 2/ 93.5 5 ,000,000 95.7 November 2 9 , Treasury Department, Division of Tax Besearch 1J Maximum earned net income assumed. For Victory tax purposes, gross income is assumed ten-ninths of net income. 2I Taking into account maximum effective rate limitation of 90 percent. 2 .25s 3.5 3.9 4.3 4.7 5.1 6.0 6.3 7.4 8*8 10*0 11*7 12.6 1 3 .2 1 3 .3 1 3 .1 12*3 1 1 .3 9 .0 7 .1 2.6 .9 .1 ,3 1.4 3*5 1943 to be aRnTuTT TatJT X Amounts of individual income tax under present law, the Treasury proposal of October 1+, 19H3, and two alternative schedules : Treasury : proposal : B VJ1 O o Single person - no dependents Exemptions! Present lav — $900 Proposals - $900 ITet income\X # Amounts o f ta x In crease s Presen t law : Treasury ; Treasury : Treasury : Treasury : Treasury before personal {in clu d in g n e t : proposal ; proposal : proposal : proposal : propo sa l A A : B :0ct*l+ . 191+3! ^Scemption'l sV ictory t a x l / :0 c t .l + , 19^3* — •* — *» 600 $ 28 $ 10 $ 11 $ 30 $ 17 $ 27 800 900 . 1 ,0 0 0 1 ,1 0 0 1 ,2 0 0 1 ,9 0 0 1 ,6 0 0 2 ,0 0 0 2 ,9 0 0 3 ,0 0 0 l+,000 9 ,0 0 0 6 ,0 0 0 8*000 1 0 ,0 0 0 1 2 ,9 0 0 1 9 ,0 0 0 2 0 ,0 0 0 2 9 ,0 0 0 9 0 ,0 0 0 7 5 ,0 0 0 1 0 0 ,0 0 0 9 0 0 ,0 0 0 1 ,0 0 0 ,0 0 0 9 ,0 0 0 ,0 0 0 1/ 2 J 62 89 107 130 153 220 2U3 333 m 57U S29 1 ,1 0 9 1,1(01 2 ,0 9 2 2 .7 8 3 3 ,8 0 2 X ,g68 7 ,6 2 6 10,61*1+ 2 8 ,0 9 8 1+8,001 6 9 ,6 6 9 1*1+1,863 8 9 9 ,5 0 0 2 / M 9 9 .5 0 0 2 / 81 108 135 165 195 285 316 1*50 630 835 1,2X 5 1 ,6 8 0 2,11(0 3 ,1 3 5 X .215 5 ,6 7 0 7 ,2 6 5 1 0 ,8 0 0 ll(, 710 3 6 ,1 0 5 5 9 ,0 3 5 8 2 ,5 7 5 1(66,570 91(6,570 >(,786,570 81+ 112 llJO 171 202 295 329 I+63 630 860 1 ,2 8 0 1 ,7 2 0 2 ,1 8 0 3 ,ll(5 U.170 5 ,5 3 0 6 ,9 9 5 1 0 ,1 8 0 1 3 ,6 2 0 3 2 ,2 8 0 5 2 ,6 5 0 7U.230 X % ,2 0 5 9 0 9 ,2 0 5 1(,629,205 90 120 150 182 2ll( 310 3lA 1+80 663 875 1 .2 9 5 1 ,7 3 5 2 ,1 9 5 3 ,1 1 5 X ,0?5 5 ,3 * 5 6 ,6 7 0 9,1(25 12,1+10 29 .3x5 1+8,690 6 9 ,7 7 0 XX3.235 9 1 3 ,2 3 5 X ,6 7 3 ,2 3 5 19 23 28 35 1+2 63 75 117 181+ 26l 1+16 575 739 1 ,0 8 3 1.X 32 1 ,8 6 8 2 ,2 9 7 3.17X i+,066 8,01+7 11,031+ 2^707 1+7,070 2 8 7 ,0 7 0 22 27 33 1+1 *+9 75 86 132 20l+ 286 1+91 615 779 1 ,0 9 3 l ,3 « 7 1 ,7 2 8 2 ,0 2 7 2.55X 2 ,9 7 6 l+,222 l+,6l+9 X .565 2,3X 2 9 ,7 0 9 1 2 9 ,7 0 3 $ 13 28 39 &3 52 6l 90 101 1X7 219 301 1+66 630 79X 1 ,0 6 3 1 ,3 1 2 1 ,5X 3 1 ,7 0 2 1 ,7 9 9 1 ,7 6 6 1 ,2 8 7 61+9 103 1 ,3 7 2 1 3 .7 3 5 1 7 3 ,7 3 5 Maximum earned net income assumed. Por Victory tax purposes, gross incot^^Ls assumed to be ten-ninths of net income* ...y: J S i g Taking into account maximum effective rate limifet'ion of 90 P rrt‘r>^auM>f^ ipcprpT-P ? — £€rpX© 5 jsacnxd i x h- xaollj Amounts of individual income tax and effective rates under present law, under the proposal to integrate the Victory tax, and under H. R. 3 ^ 7 Married person® Exemptions* t 9f Ret income* Present before * law, personal * including exemption *net Victory * tax 1/ $ 600 $ 1 800 7 14 1,000 20 1,200 1 ,5 0 0 29 1*700 35 1 ,9 0 0 42 2 ,0 0 0 58 2 ,3 0 0 116 2 ,5 0 0 199 267 3 ,0 0 0 Amount of tax f i * : Proposal * to * * * integrate * H.R* * Victory * 3^87 tax * S ** two dependents Present law and H.R. 3^87 m $1,200, $350 $ 1 ,1 0 0 , $300 Integration proposal Effective rates 1 • f Increase | • # : Present *<TroposaJ) : s 1 Proposal law, * to : * * * to 1 Integrate 1 H . R * including * integrate * H.R. Victory * 3 ^ 7 1 net Victory Victory * 3&87 * 1 tax 1/ S tax tax * I * f m Increase f • Proposal : to * * «9 integrate * H . R . * Victory *3687 f ♦ tax * mm $ - 1 .2 $ — $ - l m m m m Mr m - 7 - 7 •? 0m 1.4 ** - 14 - 11 •3t 1 / 3 tl. 0k .8 W - 20 - 11 k 9 2/ 1*7 99 m - ll 1*2 2 / - 29 1*9 18 2 / ** 1.4 2*1 ll 2^ h - 35 2/ 1 .6 2 / 2 *2 $ 44 2 - 12 30 W 2 .3 * 8 - 25 66 2*9 3*3 1*7 1 / 33 1 / 16 - 24 4.0 5 .1 92 i3 2 5 -7 6*4 176 138 - 21 7 .0 5 .5 17 8*4 14 286 8*9 19 9 *5 253 4gb U s5 1 1 2 .1 12*9 12*2 5 ,o o o 30 515 1U.9 16 l 4 .6 746 5 ,0 0 0 765 1 5 -3 730 35 69 22*9 2 2 .8 2 ,2 0 s 1 0 ,0 0 0 2 2 .1 83 2 ,2 9 1 2 ,2 7 7 188 2 5 ,0 0 0 38*3 3 8 .9 9 .7 6 2 139 9 .5 7 1* 3 9 .0 9 ,7 1 3 5 0 ,0 0 0 2 6 ,6 6 2 2 6 . 9 3 5 270 5 2 .8 53*9 53*3 2 6 ,3 9 2 5&3 6 8 .7 6 7 .3 0 3 &7 6 7 .8 6 8 ,1 9 0 6 8 ,6 5 0 6 8 .2 1 0 0 ,0 0 0 387 1 ,5 8 0 8 2 .4 8 3 .0 2 0 7 ,6 2 2 2 0 8 ,0 7 4 2 5 0 ,0 0 0 2 0 6 ,0 4 2 2 ,0 3 2 S 3 .2 4 4 2 ,6 2 2 4 4 3 ,0 7 4 8 8 .0 88*5 8 8 .6 500 ,0 0 0 3 ,1 4 3 2 .6 9 1 ^ 3 9 .9 3 1 1 ,2 0 0 1 ,0 0 0 ,0 0 0 1 3 ,8 2 2 8 9 8 ,6 0 0 2 / 8 9 .9 U 9 1 .3 9 1 2 ,6 2 2 9 0 0 ,0 0 0 2 / 9 ° ; 0 J Z . Treasury Department, Division of Tax Research, 1/ Maximum earned income assumed. For Victory tax purposes,gross income is assumed to beTTisiP^ 2/ Minimum tax 2 j Taking into account maximum effective rate limitation of 90 percent* * Less than *05 percent* EG- - .256 - .25S ■ 1.4 - 1*7 - 1*9 2 .1 - .1 •4 .7 *7 •6 •8 *7 .8 •6 •5 .4 .6 •5 1 .4 - .9 -1.1 - *9 - *7 - .6 - .6 -1 * 3 - 1 .0 - .8 - *5 • •3 *7 .8 1 .1 •8 •8 .6 * income* Exhibit 4 - Table 2 Amounts of individual income tax and effective rates under present law, under the proposal to integrate the Victory tax and under H* R, 3687 Married person — no dependents * v I Exemptions: Present law and H.R* 3687 - #1,200 \ Integration proposal-#1,100 „ '*}. —. Amounts ef tax Effective rates Net income/ Increase : Present *Pr©posal : : Increase s before 8 Present ^Proposal 5 • • Proposal Proposal : .• V * ■ law, t te : : 1 to 5 H«R* | law, personal te te : H*R* : including :integrate: : !h *r * exemption * including l integrate* 3687 integrate *3687 integrate: 3687 nlet Victory■: Victory * : s Victory : aet Victory o o : tax X/ : tax : s Victory s : Victory 3 tax i/ 1 tax * * *• tax t : s 1 : : : tax e• $ 600 •2 % $ i - .2 K - .2 K $ - 1d # - 1 800 8 — —O $ 3_2/ 1*0 1*0 . 4 * 2 / -5 - *6 - 6 1,000 — , *• 15 15 - *6 1«5 *9 2 ] - 1*5 9 2/ - 6 1,200 21 $ 22 1 1*8 15 1.8 |K/ 1.J 2/ •1 - «5 88 1 ,5 0 0 - 10 69 79 ♦6 9 5*3 5.9 U 4.6 - .7 1,700 132 -8 7.2 123 7.8 6*8 9 115 *5 - .5 1,900 166 161 176 10 8 .7 -5 8 .5 9.3 .5 - «3 2,000 188 198 10 —4 184 9.2 9*4 - *2 9.9 .5 2,300 11 264 0 11*0 253 253 0 11*5 11*0 .5 2,500 308 11 2 297 299 12*3 12*0 11*9 *1 •4 3,000 418 414 13 405 13.9 13.8 13*5 •4 •3 9 4,000 668 18 21 16.2 647 665 16.6 16.7 .5 .5 5,000 928 21 894 915 34 17*9 18*3 18.6 .4 *7 10,000 2,536 46 2,467 2 ,5 1 3 69 24*7 2 5 .1 25.4 .7 .5 25,000 161 4 0 .1 10,079 10,196 U 10,035 *2 .6 40*3 40.8 50,000 27,075 2 7,1 0 6 27,460 5 4 .2 31 385 .8 •1 54.2 54*9 100,000 68,584 68,730 69,280 146 696 68*6 6 8 .7 •1 6 9.3 *7 208,186 208,732 250,000 206,858 1,328 1,874 82*7 83.3 © .5 .7 .5 500,000 440,747 443,186 4 4 3 ,73 2 88*1 88.6 8 8 .7 2,439 2,985 *6 .5 1,000,000 899,000 2/ 913,186 900,000 3J 14,186 1,000 91.3 9 0 .0 2/ 89.9 2/ 1.4 Treasury Department, Division of Tax Research November 29, 1943 1/ Maximum earned income assumed* For Victory tax purposes, gross income assumed to be ten-ninths of net income* 2 j Minimum tax* 2/ Taking into account the maximum effective rate limitation of 90 percent* # Less than #05 percent* _____ ■ ___________V , • _____ | mm, mm ______ _______ mm a/y - -- - 'VV • Exhibit 4 - Table 1 Amounts of individual income tax and effective rates under present law, under the proposal to integrate the Victory tax and under H. R. 3687 Single person - no dependents Exemptions: Amounts of tax PwnAQO 1 before personal exemption $ 600 800 1,000 1,200 1,500 1,700 1,900 2,000 2,300 2,500 3,000 4,000 5,000 10,000 25,000 50,000 100,000 250,000 500,000 1 ,000,000 to law, including integrate net Victory Victory tax tax l/ $ 17 62 107 $ 153 220 265 310 333 4oi 446 57U 829 1,105 2,783 10,644 28,058 22 $ 66 110 15^ 220 264 308 330 396 44o 565 815 1,085 2,735 10,445 27,550 69,665 69,270 207,97*4 208,750 1*3,750 913,750 441,863 899,500 2/ Present law - $500 Proposal — $500 N Effective rates * H.R. 3637 23 69 115 l6l 230 276 322 3 U5 4l4 46o 590 Increase Proposal * to 1 H.R. integrate *3687 Victory tax $ 5 4 3 1 0 -1 -2 -3 -5 -6 $ 6 7 8 8 10 11 12 12 13 l4 j 16 2,795 -14 -20 -48 2 7 ,9 2 5 -199 -508 776 21 25 12 -14 -73 r-245 I,4i6 1,887 14,250 2,527 500 850 1,130 10,630 69,9*0 209,390 * * ,3 9 0 900,000 2 / -395 Proposal to law, including integrate net Victory Victory tax 1J tax 3 .7$ 2.8$ 7.8 8.3 11.0 10,7 12.8 1 *4.7 12.8 1 *4.7 15.6 16.3 16.2 16.7 16.5 17* 17.2 17.6 15.5 17.8 19 .I 20.7 22.1 18.8 20.4 21.7 27.*4 41.8 55.1 27.8 42.6 56.1 69.7 83.2 88.4 90.0 69.3 2/ 83.5 88/f) 91 . V H.R. 3687 .8$ 3.*$ 8.6 11.5 13 .^ 15.3 .5 .3 .1 0 -.1 -.1 16.2 16.9 -.2 17.3 18.0 18.4 19.7 21.3 22.6 28.0 >42.5 -.2 - .2 -.3 -.4 -.4 -.5 -.8 -1.0 -.4 56.0 69.9 83.8 88.9 90.0 : Increase ^Proposal s : to * H.R. :integrate *3687 : Victory ♦ f ♦ : tax 2/ .3 .4 1.4 1.0$ .9 .8 .7 .7 •6 .6 .6 ,6 .6 .5 .5 .5 .1 -.1 -.1 .2 .6 PL © Treasury Department, Division of Tax Research November 29, 19^3 1/ Maximum earned income assumed. For Victory tax purposes, gross income is assumed to be ten-ninths of net income. 2/ Taking into account maximum effective rate limitation of 90 percent. * Less than .05 percent. LIST OF EXHIBITS EXHIBIT 1 -• Estimated Inorease of Treasury Proposals Over; Yield of Present Law X / EXHIBIT 2 "i x EXHIBIT 3 « Comparison of Combined Normal and Surtax Hates Under Present Law# Treasury Proposal to Integrate Viotory Tax, and House Bill EXHIBIT 4 Amounts of Individual Income Tax and Effective Hates Under Present Law, Treasury Proposal to Integrate Victory Tax# and Ho^se Bill X * tfYkrf?•»K < ilIH m •*•“ ! _ 1 1"~*----------- * I** «nd Propoa»l* Tables 1# 2# and 3 Comparison of Surtax RateJUnder Present law and Proposal EXHIBIT 5 Amounts of Individual Income Tax and Effective Hates Under Present Law and Proposal / EXHIBIT 6 Tables 1# 2# and 3 X EXHIBIT 7 - Charts Individual Income Tax — Comparison of Effective Rates for Married Person Without Dependents Under Present Law and Proposal x EXHIBIT 8 — Comparison of Surtax Rates Under Present Daw# Treasury Proposal, and ,1Alternative Schedules EXHIBIT 9 — Amounts of Individual Income Tax Under Present Law, Treasury Proposal, and^ Alternative Schedules ^ ^pM- L jzTvf° - Tables 1# la, 2, 2a, 3 and 3a 3^ EXHIBIT 10 - OJx >posali -JrnatV EXHIBIT 11 .. Comparison Corporation Income and Excess Profits iax v EXHIBIT 12 mm Corporate Net Income, Inoome Taxes and Dividends, 1936*194. ? EXHIBIT 13 ..The Effeot of Borrowing on Net Income After Taxes of an Excess-Profits Taxpayer Using the Invested-Capital Creai EXHIBIT 14 — / EXHIBIT 15 — Comparison of Estate Tax R a t o S U n d e r Law and Proposal Present Amounts of Estate Tax4» and Effective Rates Under Law and Proposal Present Coaparison of excise taxes and postal rates under present law, Treasury proposal and House bill (H.B. (concluded) 1/ 3687} Estimated change in budget position of the United States for a fu ll year of operation at levels of income for the calendar 2/ Estimated*additional net revenue yield after allowance for increased drawback on nonbeverage alcohol of $12.8 > illio a. 2/ Estimated additional net revenue yield after allowance for increased drawback on nonbeverage alcohol of $ 4-9 million. Comparison of excise taxes and postal rates under present law, Treasury proposal and House M il (H.B. 3^8?) (continued - 4) • • e Article or service Present law •• •• . • e Treasury proposal 1 1 : Estimated additional : revenue i f s Treasury : House h ill : proposal ; House h ill f• t EXCISES - (Concluded) 21. Pari-mutuel wagering 22. Transportat ion of property Hone Hone 3i» of charge ( 4)6 per Repeal 5io of amount wagered - $ 29.I $ - 170.3 Ho change - short ton on coal) $2,511.1 Additional revenue :from excises $1 , 194-8 POSTAL RATES a. First class — local 2fi per oz. Ho change 3^ P®* oz. - h. Airmail 6{s per oz. Ho change 8)6 per oz. - 10.4 c. Third class 1^ end l|)6 per 2 oz. Ho change 2fi and 3j^ per 2 oz. - 73.8 d. Fourth class Various Ho change 3io of present law rate or1 1)6, whichever is greater - 4-7 - 4*3 e. .Registered mail 15)6 to $1 per article Ho change 20)6 to $1.35 per article f . Insured mail 5 j6 to 35/6 P®* article Ho change 10^ to 70)6 per article ) g. C.O.D. mail 12)6 to 45{* P®* article Ho change 24^ to 90)6 per article ) h. Money orders 6)6 to 22)6 per article Ho change 10)6 to 37/6 per article $ 58.6 •p 4 / Additional revenue from postal rates Additional revenue from excise taxes and postal rates Treasury Department, Division of Tax Research. ITooWotes cqn.tlnu.od oaa following page. - 12.1 - 21.9 - $ 2 , 5 1 1 .1 $ 18 3 .8 $ 1 ,3 7 8 .6 November 26, 1943 Comparison of excise taxes and postal rates tinder present law, Treasury proposal and House till (H.R. 3687) (continued - 3) Article or service t • : • s • • 9 # House bill Treasury proposal Present law • : • # : Estimated additional revenue if Treasury s House -proposal s bill EXCISES - (cont’d.) $ 167.3 10$ of retail price 30$ of retail price 20$ of retail price (exempts silver-plated flatware) 10$ of retail price 25$ of retail price 23$ of retail price 54.8 54-8 l6. luggage, handbags, wallets, etc. 10$ of mfrs. sales price on luggage only 25$ of retail price 25$ of retail price 53-4 53*4 17- Toilet preparations 30$ of retail price 23$ of retail price 25$ of retail price 51.4 51.4 18. Electric light bulbs and tubes 3$ of mfrs. sales price No increase 23$ of mfrs. sales price - 20.0 14. Jewelry 15. Fur and fur-trimmed articles 19. Soft drinks None Bottled drinks, 1/6 per each 3$ of intended retail price; the equivalent taxes of $1 per gal* on sirup and 25p per lb. on carbonic acid gas used in unbottled soft drinks None 177.0 20. Candy and chewing gum None Articles intended to retail from 5$ to 15^ per bar or package, 1/£ per each 5f1°* intended retail price; other items, the equivalent tax of 35$ of mfrs. sales price None 190.0 $ 81*9 \ Comparison, of excise taxes and postal, rates under present law, Treasury proposal and House bill (H.B* 3^ 7) (continued - 2) e • • . Article or service t • e Present law • 9 : } Treasury proposal ♦ .. . : : Estimated additional : revenue 1/ -i Treasury : House i proposal s bill House bill EXCISES - (conVd.) 6. Chewing, smoking l8$ per lb. 34$ per lb* Ho increase 1$ per 10$ 3$ per 10$ 2$ per 30$ 11$ of charge 30$ of charge 20$ of charge 8. Cabarets 5$ of charge 30$ of charge 9. Club dues and initiation fees 11$ of charge 10. Bowling alleys, billiard parlors 11. Transportation of persons tobacco and snuff 7- General admissions, lease of boxes or seats, etc. 12. Communications a. Toll service b. Telegraph, etc. (1) Domestic (2) International c. leased wires, etc. ( d. Wire and equip ment services 13. Local telephone service $ ) ) ) 46.2 327-0 $ I63.5 30$ of charge 91.3 91.3 20$ of charge 20$ of charge 5-1 5*1 $10 per alloy $10 per table 20$ of charge $20 per table 20$ of charge $20 per table 27.0 27.0 10$ of charge 25$ of charge 15$ of charge 212.7 70.9 20$ of charge 25$ of charge 25$ of charge 15$ of cjjarge 10$ jpF' charge of charge 20$ of charge 10$ of charge 20$ of charge 25$ of charge 15$ of charge 20$ of charge 31-5 36.9 5$ of charge Ho increase 7$ of charge 10$ of charge 15$ of charge 15$ of charge 48.9 43.9 ) ) ) Comparison of excise taxes and postal rates under present lair, treasury proposal and House bill (H.B. 3^ 7) * Treasury proposal Present law Article or service 1 House bill t ;_____________________ i : s Estimated additional revenue 1/______ Treasury : House i proposal___ s---- M U EXCISES 1. Distilled spirits $6 per gal* (drawback of $3.75 per gal* on nonbeverage alcohol) 2. Beer $10 per gal. (drawback of $7 per gal. on nonbev erage alcohol) $ 487.22/ $9 per gal. (drawback of $5 per gal. on nonbev erage alcohol) $7 per barrel $10 per barrel $8 per barrel 10$ per gal* 50$ per gal* $1.00 per gal. $2,00 per gal. 20$ per half pt. 10$ per half pt. 15$ per gal. 60$ per gal. $2.00 per gal. 15$ per half pt. 10$ per half pt. $ 370.13/ 210.5 70*5 8l.l 20.0 3. Wine a. Stills Under 14$ alcohol 14-21$ alcohol Over 21$ alcohol b. Sparkling o. Other 40$ per gal* $1.00 per gal. 10$ per half pt. 5$ per half pt. ) ) ) ) ) 4. Cigarettes a. Small b. large 5. Cigars $3.50 per M $8.40 per M No increase Intended retails Over 4* 4$ M 8 $ 15 20 $ 1 s Not s over 4$ 4$ 6A 8 $ 15 > 20 $ 1 Tax per - I • M $ 2.50 3.00 4.00 7.00 10.00 15.00 20.00 Intended retail: Over 5 7 9 17 $ $ $ $ 22 $ Not a over 5 A 7 $ 17 ^ 22 $ - 5 Tax ) ) ) ) per 5 M s $12.50 13.00 14.00 17.00 30.00 35*00 40.00 No increase ) ) ) ) ) ) 67.7 ' N d r T fev 5 fetteated change in the position of the M M States resulting t*m the WU1 tf IM S {8.8. 888?) M y m r i Ijr 18* Haase #£ Swwfew M, **r • fall yearof n m U * *t Intel* Of inseas oetiaated for tin* calendar year K M J/ flu stiJUUUpoo of doXlsrs) ll»»»«l 9 W _ m i w t li» a> individual i w taxi Sliafnate the earned incus* eroditj tm sm m the m d tax rate fine* * percent to lfl p n w t , d ^ r M m U m M r I M m l excise tarn exoedt as incurred *® Jf£* «* b,“ ia?w * irerM# a jpaelal deduction M r hltad individrolaj alter w i n rates applicable 86,000 sari**(net Jaroaef repeal the notary is*. s » M ® M r a -t»«— tea ef • percent ef the exeeee a f / M i n w star « J Ser a single person er a nsrried m m ,u i *f * «**•*• retwa, i » Sec « ***8 ef a fseily «r a serried amyl* filing o m return, aad flse far each dependent} require a earned person filing a separate roturo te Me# personal asaaptlae ef » j Unit tea te 80 percent ef taxpayer's aet insane ......... . m » e Corporation imn ad eneeae profits taws* increase excess profits tax rate free 96 percent te 96 percent* isarease eases* profits tas spasm* exenpUro «ro*JM0O to «10,C00| ndnee ***** preflts erodit based on invested capita! 1a tanutets o»«f «8Mllion| alls* rollaf ' M e r Section T » of t.* Internal Hmmmm M e te seal -^6»an^>wro»rtiee aad t U h v tracts sat in operation daring the base period aad te aataTOl W ^ e U a r o i M Halt the eeepe ef tbe let pertaining to roasgetiatis* ef ror contrasts — - fetal (gross) **ee*#**#***•#* o §X*e8 too* |m stm r crodit ...... . «* 4I*$ ' fOtOii 45®JP3jNS9PS"t*S43It Cast) eaoooooee*steoeeeoeeeeeeeeet*oo-**ee****»eeoeo*e«*oeee»»eee 48?.t KSTOilf® *»**'******•*.***»*•*♦»■•**«#****■■*****»♦#♦*♦***e-*.**e.**-*e»e*ep-****#-e#*****#(**.#***#»*^«e*#* l J | P § J/ E t M D U m e w ***** JjBM510030 p08%s2« V9&00 ease***•*•**•eooewe*eee««»e*eoe»oao see#tiietttiea•••esee*# U«it too of to* tot portototog to of m » contract* fOtOix ^OOjOi180 S#<M»***#*!*♦*-*«a-♦**•##*• a*#**-#*s* oeoeeeee eitottott •*a*##a• I.M I in .. . ii,iiiiiuau>wo!ii cmi newajiiL mmium ie ^ w n w ro raw a ttron^ronw»Miw ^ r iroroM nraniroaMn..ia.aroiae>i«MieTrtir, nnjron inn■i tmmmvf i/ M*totoo p t l » •^Hwkt«a *** i r r.r.TJrlnW M M t e r to ro flo o t t l » not fc^roragMKit to too ^3P0® ^ ** position o f tto lie I 0 H . 5t«tos r»ff*dt- po*^toa of too tilX totiok iaeiooso® F«d«m3l coooifpto uadi o a t p m A l t a P M to wcteat * * ^»**to»ttoo w to t o govKronxxtai sasolso tax ./ X99.8 *“ ( f lt t o IIZ , 3oetto« 007 o f tho V Zpfl>” Bt •?**— *» « ■ M * . r o t yield ef tbe falU oror p r o m t law. ***** *»■****■ « t b « r t i n tbe c r o w V i i t w y tan, U r o t t M in tho yield ef growth of the public debt, and the imminence of inflation, force the conclusion that the Treasury1s $10*5 billion additional revenue goal is much nearer the minimum than the maximum demanded by total war* Conclusion I. This states®nt has dealt largely with the technical aspects of the Treasury proposals and the Bouse Bill* I believed that I could be of most assistance to the Committee by concentrating on these aspects of the pending bill. I have given special emphasis to simplification because of the crucial necessity of simplifying our tax laws* Unnecessary complications can put our entire wartime income tax program in jeopardy* I hope that the Committee will not misunderstand my emphasis upon simplification and technical matters* Total war makes broad demands on our tax system* Present taxes do not meet these demands, either in terms of paying for the war as we go, or in terms of combatting inflation* The legacy of taxes at present levels will be not only a huge debt, but may also be a demoralized price structure both during and after the war* The growth 5? post-par crisis, witnout the addition of complex renego tiation- of-contracts issues to its calendar* The renegotiation statute is not a taxing statute, but tide proposal would tend to confuse renegotiation with taxes. It is also to be recognized that renegotiation cases, under the terms of the House amendments, will demand a large part of the time of any tribunal* Many issues will be presented, often difficult of proofj take for example the issue of a large contractor’s efficiency or lack of it, whicji might occupy the Court for weeks* It seems inevitable that few cases will be susceptible of quick disposition* It Is my very firm conviction that if the trial of renegotiation cases is added to the task that will con front the Tax Court, the prompt collection of revenue will be impaired, the rights of the Government and of taxpayers will be prejudiced, and the deservedly high reputation of the Court may greatly suff er* Any Impair ment of the reputation and efficiency of the Court would constitute a most serious blow to the proper administration of the tax law* 66 * Renegotlatl on of Contracts f— I think the agencies principally concerned may wish to present their views on the renegotiation provi sions of the House 6111* However, I should like to present the Treasury position on one of the renegotiation provisions that vitally airacts the revenue system* I refer to the provision permitting aggrieved contractors to secure a redetermination of excessive profits by fee Tax Court of the United States* I think it cannot be too strongly emphasised that the choice of the Tax Court as a forum for renegotiation litigation Is an unwise one* For many years it has been recognised that the volume and complexity of Federal tax cases require a specially qualified and skilled tribunal, such as the Tax Court, fVV whichjshall devote its entire time and efforts to their consideration and disposition. ‘This need threatens to become even more pressing after the war* The inevitable accumulation of cases during the war and the development of many excess profits tax cases, particularly those arising under the general relief provisions of Jection TBS, make it obvious that the Tax Court faces a possible post-war crisis, vuVi x V t v It is very doubtful M A a general sales tax without the exemption of necessities of life would really be helpful in financing the war or restraining inflationary price rises. The imposition of a substantial sales tax would almost surely be the signal for widespread demands for higher wages and farm prices which* if allowed* would result in large additional costs to Government and Increases in the cost of living over and beyond the amount of the tax. These dangers are much greater In the sales tax than in excise taxes or income taxes. Excise taxes touch in only minor respects commodities that are necessities of life* while income taxes have personal exemptions which protect minimum living standards. Personal exemptions could be Introduced into the sales tax, but the inconvenience of distributing and using exemption coupons and the resultant reduction in revenue would be serious factors. Even the most simple sales tax would require the use of much precious manpower and machines by Government and tVeit business. It is doubtful ^ m a n p o w e r and those machines could be secured without interfering with the war effort# t|« Renegotiation of Contracts. at that point. A sale a tax with such exemptions would yieldI about *2.6 billion. however , of that amount about |1*2 billion would come from goods and services already subject to Federal excise taxes. The tax yields from the sale of these commodities can be increased or decreased by adjusting the excise t&x rates. to produce revenue from them; Mo sales tax is needed All that is left after excluding such commodities is 11.4 billion. Mearly *600 million of the $1.4 billion would come from equipment, chemicals, and materials used in business and thus entering into the costs of doing business, with resultant increases in the costs of doing business and in prices to the Government and to the public. Most of the remaining $800 million tax would be on items that might properly be subject to sales taxation. It is hardly necessary to point out that the expenses to 2 1/2 million businessmen and increased costs to Government, as well as the use of precious manpower, would not be justified by yields of this kind when there are other methods of raising money at hand which do not call for heavy increases in costs of administration and compliance. It is very doubtful Sudh a tax would be very harsh, especially on low income families with children* It is completely lacking in any relation to ability to pay because it hits families much harder than single individuals at the same interns levels and it hits people with small incomes much harder than people with larger ones* Such a tax would be opposed to every principle of tax equity and would in my opinion interfere with the war effort* There are many proponents of the sales tax who would agree with these criticisms and who propose to meet them by allowing exemptions of the necessities of life* Such exemptions would indeed improve the character of the tax, although they would still leave the discrimination against large families* However, the exemptions would quickly remove so much of the tax base as to leave little more than an empty shell. The exemption of food would reduce the yield by $£•£ billion; the exemption of medicine would reduce the yield another fBOO million; the exemption of clothing would reduce the yield by another $1*1 billion* Those exemptions do not include all of the necessities of life, but let/us stop at that point# For an elaboration of the points just made, I should like to refer you to Appendix fr. This appendix also co pares the Treasury excise tax proposals with the House M i l provisions, analyses those provisions, and in dicates why it is desirable to terminate excise tax exemptions on sales to the Federal Government, as recommended by the President* G. *-$5— -The Sales Tax The Treasury proposals do not include a general sales tax* I should like briefly to state the reasons for our decision. The form of sales tax which would produce the most revenue and cause the least rupturing of price ceilings is the retail sales tax. The highest rate I have heard f mentioned is 10 per cent* That is over three times as high as the rate now in force in any State, A 10 per cent sales tax with no exemptions for necessities of life would raise at current sales levels about $6 billion, or about one-tenth of this year1a estimated deficit. Such a tax would 51 * taxation and in setting the proposed rates, the Treasury gate careful consideration to the demand and supply conditions in affected industries and to the impact on producers sad consumers* The t&*5 billion excise tax reo> amende tioa^^Sa^ designed to he a part of a balanced oterall program. Selected excises have much to commend th«a as a source of wartime revenue, They iatohr e little increase in administrative machinery and compliance costs* it the same time, in most cases the higher levies would be shifted to consumers, thus avoiding undue burdens on business concerns. Since only & few non-essentials are affected, and since theXtax can be avoided or reduced by cutting consumption of the taxed Items, the excises will not cause hardship for consumers* Excise taxes are far superior to a sales tax. They involve only a small fraction of the administrative and compliance effort demanded by a sales tax* Second, they bear on non-essentials rather than necessities. Third, they support rather than jeopardise the Government's program to stabilise the cost of living* For an elaboration I should like to report to the Committee that the Treasury is b o w making an extensive study of all phases of estate and gift taxation. For example, we are investigating the possibility of integrating the estate and gift taxes and correlating them with the income tax. An advisory committee, comprising some of the leading tax practitioners in the estate and gift tax field, is aiding us in this study. It is hoped that the study will lead to recommendations which will simplify these taxes and make them more effective and more equitable. It is anticipated that this study will be completed before the Congress considers the next tax bill. F ‘4 — 3^,— Excise T a x e s The Treasury recommended that an additional $2.5 billion be raised through increases in the rates and changes in the base of several existing excise taxes L ^ . (Stt 6»W«Wt » 0 anu through tne enactment of two new excises, . It further recommended that the tax on transportation of property be repealed. In selecting specific items for heavier taxation and in The proposed changes in the estate and gift tax pro visions should be permanent, rather than simply for the I duration of the war. 1/ I should like XT Tib technical estate and gift tax provisionsof the House Bill deserve comment. As passed by the House, the bill contains an estate tax amendment mien provides that in valuing stock or securities the value of which cannot be determined by reference to bid and asked prices or to sales prices by reason of the absence of listings for sales, there shall be considered, in addition to all other factors, the value, of stock or.securities of comparable corpora tions which are listed on an exchange. It is believed that this amendment is highly undesirable because it can only lead to continuous, unnecessary and costly litigation, and harbors dangerous poten tialities for imposing unjust tax burdens upon the recipients of closely held stock. The House Bill also provides that in certain instances the appointment of a trustee, the vesting of discretion in a trustee as to the selection of beneficiaries or the distribution of benefits, or the exercise by a trustee of such discretion shall not fee deemed a taxable gift. this provision is completely divorced from any reasonable classification of trusts and is enmeshed in ambiguities which can only produce manifold administrative difficulties and increase the litigation burden of taxpayers. - 48 E, f— 9 c — •Estate and ftifjfc *axes In seeking sources of additional wartime revenue, we cannot afford to overlook estate and gift taxes* Increases in these taxes have not kept pace with tax increases generally. Small as their relative contribution to the total has been in the past, it has fallen during the war. Estate and gift tax collections £6r the fiscal year 1944 are expected to represent a smaller proportion of total ,Ux receipts than at any time during the past 10 years. * (SfcflL WKVuVft Ifc, ) In a period when huge additional revenues are needed, the beneficiaries of estates and gifts should contribute their full share to the cost of the war along with other groups of taxpayers. Yet, relatively few estates are subject to tax, and rates in the lower and middle brackets continue to be moderate. The Treasury has, therefore, recommended that the estate tax exemption be reduced from 160,000 to $40,000 and that estate tax rates be raised. Corresponding increases in the gift tax are also suggested. For a comparison of rates and tax under the present law and the proposals, see Exhibits 14, 15 and 17. These changes would add $400 million to our revenue* on a full-year basis. The proposed changes part ceased, and that a taxpayer seeks to use the deduction or credit as an offset to the profits of an enterprise to which the deduction or credit does not bear a reasonable business relationship* The amendment in no m y abridges the privilege of doing business in individual, partnership, or corporate form, or the privilege of filing a separate or a consolidated return, or any of the numerous choices which the structure of the tax system is intended to afford* But the amendment does operate whenever under any of these privileges or choices such a distortion or perversion of a deduction or credit appears. Hence tie scope of the amendment in its field is precisely the same as that of Sections 46 and 141 of the present law, where analogous distortions or perversions have been frequently described by the Committee as "milking* or shifting of deductions and credits* The Treasury believes with the House that the amendment is a significant part of an equitable tax structure and that it is well adapted to accomplish its purpose* &at»te and Sift * « • £ defunct corporation having large current, fast, or prospec tive losses, deficits, or large current or unused profits credits. The utilisation and advertisement of such devices . has disturbed resp onsible taxpayers and their attorneys iriib have refused to use these schemes. It is also disturbing to the Government in its effort to administer the revenue laws equitably and uniformly. The amendment disallows the part of the deduction or credit involved in the tax avoidance device, but only if the acquisition of an interest in or control of a corporation or property has occurred on or after October 8, 1940, and then only if one of the principal purposes "for which (the) acquisition was made or availed of is the avoidance of tax by securing the benefit of’ such deduction or credit. The ■ amendment is directed solelgf at those devices which distort’ or pervert the natural business relationship between a deduction or credit and the enterprise which produced it, and for the benefit of vhieh the deduction or credit was provided by law. The gist of the distortion is the cir cumstance that such natural relationship has in whole or in part ceased, / - 45 producers of natural gas, this provision in the louse Eill appears to be undesirable* developed in Appendix f* this point is further This appendix also contains a statement of the Treasury position with respect to the broadening of the excess-profits-tax relief for coal and iron mines and timber tracts* Tax relief measures can serve very useful purposes. But unless they are handled very carefully, they may simply become tax loopholes* If tax relief is distributed without regard to need, it deprives the (roveroaent of much needed revenue, and distributes tax burdens inequitably among business enterprises* It must not be forgotten than reduction in the tax liabilities of especially favored taxpayers means increased tax burdens on all other taxpayers. If. Acquisitions to frvoid Income or faxcess-^rofits Taxy^ ~ At this point I would like to discuss one technical amendment which is of major importance. Section 115 of the House Bill is intended to curb the development of a public market in which alleged tax benefits may be bought and sold. The currently advertised schemes are designed to enable a taxpayer with large war profits to avoid income and excessprofits taxes by purchasing for such purpose a losing or defunct corporation — • generally has a higher credit standing than the small and therefore gets larger tax benefits from borrowing than the small corporation* this advantage will be reduced by the reduction in percentage allowances on invested capital* 1/ Specific belief treasures in the House Sill ^ The House Sill provides special tax treatment for certain mine owners and operators. It extends percentage depletion and excess-profits~tax exemption to several minerals as a means of stimulating their wartime production. In so far as these fall within the category of strategic minerals designated by the War Production Board, the Treasury con curs with tax measures which will accelerate their output. But for minerals not so designated it is believed that the ✓ The House ®L11 also extends to. the natural gas industry the special excess-profits-tax treatment now granted with respect to the accelerated output of depletable natural resources. In so far as this treatment is extended to non after taxes of an excess-profits taxpayer using the invested capital credit will be found in Exhibit 13. 43 The Treasury il o agrees with the provisions reducing by one percentage point the invested capital credit in / each of the brackets above 15 Million* Invested capital is generally used as a base for computing excess-profits credits only by those corporations which earned a low rate of return during the base period* ~ Where such earnings were abnormally low, corporations are protected by the remedy \ in Section 722* But corporations the base-period earnings of which were normally low should not be provided an escape from taxes on war-increased profits* Since a large in- vested^capital credit unrelated to base-period earnings tends to provide such an escape, the proposed reduction will reduce an unfair advantage gained by large corporations having a history of low normal earnings* The proposed reduction of the invested capital credit will also reduce the advantage gained by large corporations on borrowed capital* Because 50 percent of borrowed capital is included in invested capital, corporations can get a tax advantage by borrowing at rates of interest below the percentages allowed Wn invested capital* The large corporation generally has a - 4k&. / Changss la Exemption* and gfredits under the Souse flllll the House gill provides for an increase fro* 15,000 to $10,000 in the specific excess-prof it a-tax exemption. 1/ This provision, which m s recommended by the Treasury last year, will distribute the exeess-profita-tax burden more equitably between large and small business enterprises. The profits of small business are likely to fluctuate more widely than profits of large business. Base-period earnings under the average-earnings method are, therefore, a lees reliable index of normal earning! for small business than for large. An increase in exemption tends to avoid a penalty on normal fluctuations and earnings without forcing a resort to the relief provisions of See^ 723. .JProfits of small business are e=bsa more likely to A reflect a return on managerial efforts than & return on invested capital* Consequently * the increased ex swaption also aids small corporations using the invested capital base for determining excess profits* the treasury also excess-profits-tax rates will reach only a limited 1/ range of excess profits.^ ✓ 1/ A revision of the 80 percent limitation will improve the relationship of net taxes payable by corporations not subject to the tax ceiling and those which are subject to the tax ceiling* in Appendix C to this statement, there are outlined three alternative methods of revising the 80 percent limitation to gain these advantages, which would still prevent net corporate taxes from exceeding 80 percent of net income* 40 • It is recognised that tha combined corporate and Individual taxes on dividend income are higher in this country than in England and in Canada* and that steps Bust he talign, after the war to relieve corporate stock holders of their dieproportionate tax burden. However, ao long as the war continues and corporations generally are able to maintain present abnormally high level* of earnings, the discrimination against this elass of inoome recipient will continue to be more apparent than real. The taxation of the excessive profits of corporation imposes no real burden on corporate stockholders I have indicated why the Treasury prefers to raise « additional revenue by means of an increase in surtax ' rather than an increase in excess-profits tax. However, if your Committee should decide in favor of an inereass in the excess-profits-tax rate, the Treasury suggests an upward revision of the 80 percent limitation on corporate taxes. Without this revision the increase in { excess-profi ta-tax rates 39 waj^distributadJr la spite of war taxes, dividends for 1941, 1942, and 1943 are estimated at $4*5 billion, $4.1 billion, and $4*0 billion, respectively* It is estimated that even after paying taxes and dividends, American corporations will accumulate over $13*.billion 114 -00*1 of undistributed profits for the three years 1942, 1943, A A ifoil IMPt* Recent studies show that liquid assets of corpora tions have risen even taster than retained earnings. Mon-financial corporations increased their holdings of currency, bank deposits, and United States Government securities by $12 billion during the two years 1941 and 1942 according to an estimate prepared by the Securities and Exchange Commission* If the accumulation of liquid assets in the first half of 1943 should continue at the present rate through the year, the total increase would be $25 billion for the three years 1941, 1942^and 1943. k study just released by the Federal Reserve Board indicates that business deposits, both corporate and non-corporate, totalled $30 billion on July 31, 1943. It Is recognised i" 3/ h imhiIhi i i: i i i ,i i ,j „ :r n ht i________ (— * * * * * * * * ** Dividend payments in 1936 and 1937 are generally con ceded to have been abnormally high as a result of the undistributed profits tax in effect during those years. and without impairing the sound financial condition of corporations generally# Corporate prefits (excluding dividends received) will reach an estimated level of $22*6 billion for M B . This is more than four times the corporate profits for the year 1937, one of the most prosperous years of the Thirties* Taxes have also risen sharply during this period, both because of increases in corporate incoxae and because of increases in rates* But they have failed to keep pace with earnings* In 193'/^corporations had left less than $4 billion, after paying $1-1/4 billion of taxes* In 1943,corporations .'0m- will have left nearly $9*2 billion, even after paying $18.5 billion of taxes* In 1944* corporate profits after taxes at present rates are expected to reach $9*9 billion, or three times the average annual profits after taxes from 1986 through 1989* pi^gYCS OK A dividend* and undistributed prof Its figures are also impressive*]/ Average dividends from 1986 to 1940 were $4*1 billion, 1937 being the pefck year^ when $4*8 billion wi Y, www distributed* V See Exhibit 12* - 37 credit) on each dollar of excess-profita from 81 to 85-1/2 cents* tinder the Treasury proposal for an increase in surtax rates, not more than 50 cents would ordinarily be taken out of each dollar of normal profits, and the present figure of 81 cents for would not be touched* a The increase in surtax proposed by the Treasury is less likely to impair financial incentives than would an increase in the excess-profits** tax rate. With corporate rates at their present levels, the impact on incentives cannot be ignored in making tax decisions* The Treasury agrees that our corporations should be kept *in a sound financial condition so that they may be able to convert to peacetime production and provide employment for sen leaving the armed forces after the war.** But figures on corporate earnings, dividends, and accumulations make it clear that added taxes can be levied without unduly burdening irofits and profit incentives, and without impairing 1/ Corporations with income between'$25,000 and $50,000 will, of course, be subject to higher marginal surtax rates as a result of the^not^h provision. 2/ See |iijS 5, House Report on the Revenue Bill of 1943* 38 ** capital but low normal earnings, receive substantial war profits without becoming subject to excess-prof its taxes* The same is true of corporations with high b&se- period earnings now engaged in the production of war materials* Other corporations have had their excess- profits tax liabilities substantially reduced by the special relief provisions in the tax law* Still others will ultimately have a substantial proportion of their excess-profits taxes refunded to them under the operation of the carry-back provisions. The surtax thus offers greater assurance that all corporations which have benefited from the war will make an additional tax contribution* A further reason in favor of a surtax-rate increase, as distinguished from an excess-profits—tax rate increase, may be found in the comparative effect on managerial profit incentives* Financial incentives to efficient management depend upon the number of cents the corpora tion retains out of each additional dollar of profit* The House Sill would increase the net tax (after postwar credit) 36 corporate profits* On. the other hand, it will not strike approximately one-half of the excess-profits, nor will It touch the most profitable corporations* To reach corporate profits generally, an increase in surtax rates would be necessary. To reach the bulk of excess- profits and the most profitable corporations, added excess-profits taxes would have to be coupled with an upward revision of the 80 percent limitation* Because of its broad coverage, the corporate surtax affords an instrument for tapping war profits that are not defined as excess^rofits in our tax law* At best, it is extremely difficult to single out excess^profits and war profits by legal definition* An excess-profits tax cannot be a perfect instrument; a 90 percent or a 95 percent excess-profits-tax rate does not mean that the Government will recapture 90 or 95 percent of the war profits of corporations. In the area labelled "normal profits" there are bound to be some war profits. For example, many corporations with large invested capital 34 become subject to the BO percent ceiling as y a result of the 5 percentage-point increase in the excess-profits tax rate# The effect will.be to limit still further the range of corporations to who® the full increase would apply. It would apply only to the residual class, namely, corporations that pay excess-profits taxes, but will not become subject to the 80 percent tax ceiling# ^ In contrast with the House Bill, the Treasury proposal would increase the net liability of all corporations# For those subject to the 80 percent ceiling, an increase in the surtax would mean a decrease in the share of their 80 percent tax represented by excess-profits taxes# As a result, their postwar credit would be smaller and their net liabilities correspondingly larger, even though their gross tax payments were unaffected* For all other corporations, both the gross payment and the net liability would be increased# From the foregoing analysis it is apparent on the f one hand that the House Bill will not strike corporate profits generally, but only a restricted segment of corporate profits# $ L H h v u i <U*J*x£ZL-f e . /a^>u4^a *"* 3 3 — * unused excess-profits credits? and (£) provides special tax treatment for certain natural resources industries* 1/ / I should like to discuss these matters in detail* 4* Comparative fj'fects of Increases in Surtax and increases in Excess-ftofits faXr^ST Unlike an increase in surtax rates, which would increase the net tax liability (after postwar credit) of all taxpaying corporations, the increase in the excessprof its-tax rate under H. E* 8687 will increase liabilities for comparatively few corporations* Corporations not subject to the excess-prof its tax {and those already subject to the 80 percent ceiling on corporate taxes will have ; | ^ no added tax to pay* ' $ ! coo Of 263,-§ii taxable corporate returns -©00. ^ estimated for 1944, 71, ©Si* or about 27 percent will be subject to excess-profits tax* Moreover,^ the 80 percent ceiling will apply to 4,300 corporations or approximately 6 percent of all excess-profits taxpayers. This 6 percent, however, will pay about 40 percent of total excess-profits taxes in 1944. An additional 3,200 corporations will become subject 2/ A comparison of corporation income and excess-prof its tax rates is shown in Exhibit 11* * 32 » years are combined with the net income for two years, jf ^’ey should be, it becomes apparent that the 75@percent cancellation is a windfall which has made it easier, not harder, to pay taxes on 1944 income* The Treasury suggested to the Ways and Means Committee T (a) that the surtax on larger corporations (those with net income in excess of $26,000) be increased by 10 percen tage points and on smaller corporations by 4 percentage ^ point s; (b) that no change be made in the excess-prof its ~ tax rates; and (c) that certain changes be made in the existing provisions for carry-back of losses and unused excess-profits credits* CtAsjwuau A The bill passed by the House (a) makes no change in x the surtax rate; (b) raises the excess-profits-tax rate to 96 percent; (c) reduces the excess-profits credit for some corporations by lowering the percentages allowed on invested capital; (d) raises the specific exemption for excess-profits taxes from $6,000 to $10,000; (e) makes no change in the carry-back of losses and unused - 31 * existing income tax rates are confiscatory* Those who mke this contention point to the combined burden of current taxes, uncanceled 1342 liabilities, and State income taxes* It is said that this combination will i exceed 100 percent of income in 1944* Such statements are grossly misleading. They ignore two facts. The first is that the Federal income tax allows for the deduction of State income taxes in comput ing net income* This deduction protects the taxpayer from & confiscatory combination of State and Federal taxes, even if the State tkx does not permit the deduction of the Federal tax* The second fallacy lies in comparing two years* taxes, or 1-2/8 year*s taxes, with one year’s income* The uncanceled part of the 1942 tax is, in no sense a tax on 1944 income. This becomes entirely clear when it is realised that a person having no 1942 income has no uncanceled tax to pay in 1944, and would therefore not be covered by the schedules combining the two year?* taxes* is a matter of fact, when the taxes for two years ♦ 30 m In an attempt to prove that American taxes are too high, it is argued that taxes in the United States aije higher in terms of dollars per capita than in the United Kingdom and CanadaJt/ This argument is, of course, grossly misleading, since it gives absolutely no indication of real burdens# How burdensome a given tax will be is determined by the ratio of the tax to the income from wtiich the tax is paid* Personal incomes here are larger than in either Canada or Great Britain* Furthermore, the rates of income tax and excise taxes are higher in the Allied countries than here. Practically any citizen of the United States,- if given the choice of paying'American, Canadian, or British taxes, would \ V\orc W 0 S*U. w V\A choose the American tax systeia since his tax^rrould he lowefe # c# The argument of oonflgcation*-"^ In connection with the argument that taxes will exceed capacity to pay, it is contended that our existing 1/ See fc4o\s41 'vfc< ^ 4. \3v\i of hM I T i e . /tV the fiscal year 1944. r lh© corresponding figures hefore subtracting personal taxis are $88 billion and $148 billion* _ In other words# personal taxes show an increase of $18 .111cn while incones before 11 show an inoreasej .of $8Chbillion# -Less than ©ne*fourth of the-increase|in annual Income payments generated by defense and War activities is being absorbed by taxes* In an attempt to prove before taxes will be $3j580,and after existing taxes, about $1*500* The demands of wartime living on incomes of this siz® leave little margin for additional taxes and afford few opportunities for inflationary spending* Nevertheless, the urgent requirements of war finance demand that we tap even this small margin of disposable income* Under the Treasury proposal^ one-half of the income tax increases would fall oi, persons with net incomes of less than $5,000 and about one-fourth on persons with' less than $3,000* Much the same proportions hold for the complete Treasury program, including proposed changes in corporation taxes and in excise taxes* b* Capacity to pay A second contention is that the American people do not have the capacity to pay additional income taxes, the facts contradict this contention* Individual incomes after personal taxes amounted to $65 billion in the fiscal year 1939 and are expected to amount to $126 billion in the fiscal year 1944. a* Tax burdens on the lower income groups It is contended that persons with incomes of less than $6,000 are the ma^or source of inflationary pressure and that these persons would ©scape their fair share of the additional tax load under the Treasury proposals. Although at 1944 levels of income about 81 percent of the bbotal cash income will be received by persons with incomes under $6,000, only 65 percent of the net income above income tax exemptions will be received by this group* Likewise, although 61 percent of total income will bo received by persons with incomes under $8,000, only 89 percent of the net income above income tax exemptions will be received by this group* Looking behind these aggregates to individual cases, we find that the margin of disposable income over and above wartime needs is very narrow for the millions of persons in the lower income brackets* Out of 67*3 million income recipients in the calendar year 1944, 68.2 million a rt expected to receive net incomes of less than $8,000* The average cash income per recipient before taxes b. The House Sill v Revenue id only an incidental consideration in the income tax provisions of Hie House Bill# Those provisions will add $228 million to income tax revenues* Of this amount about $90 million is attributable to the changes made in connection with Victory tax integration. About $150 million is attri butable to the disallowances of deductions for Federal import duties and miscellaneous excise and stamp taxes not otherwise deductible as business expenses. 1/ The other individual income tax changes made by the Mouse bill are of a technical character* 3* > Answer to Criticisms of the Treasury proposals for i tm m m• Higher Income Ttoas ^-rr ■>mtm I should now like to examine with you some criticisms that have been made of the Treasury*s affirmative income tax proposal! The three arguments 1 shall examine are (1) that the Treasury proposals would not bear heavily enough on the lower income brackets; (3) that the American people do not have the capacity to pay more income taxes; and (3) that income tax rates in 1944 will he confiscatory* ____ _ 1/ This disallowance was recommended by the Treasury* At ~ present, the allowance of deductions under Section 23(c) is inconsistent and depends entirely on the legal language used in imposing the tax* For example, admissions taxes are allowed as deductions, hut the cabaret tax is not. Uniformity in the matter of deductibility is desirable. Revenue, administrative, and equity considerations also suggest disallowance of these taxes in so far as they constitute personal expenses. integration segment of the Treasurer individual income tax proposal* the Treasury has also recos® ended as part of & $10# billion program of wartime taxes that an a additional $8*5 billion of revenue be raised in individual income taxes* The surtax rate increases suggested to raise this revenue of course include the changes designed to absorb the Victory tax* Exhibit 5 appended to this statement shows the schedule of surtax rates proposed to tne Ways and Means Com!ttee on October 4, 1943. (See also Exhibits 6 and 7)) 1/ ^Two alternative schedules for raising approximately $8.5 billion of added income tax revenue are also attached for the convenience of your Committee (See Exhibits 8, 8 and 10). It will be seenjthat these alternative schedules would impose a heavier burden in the lower income brackets than the October 4 proposal. Zj 17 It will be seen from exhibit 5 that the treasuryis 2/ recomending that 4 separate surtax brackets of $500 each be substituted for the present first bracket of $£,000. This change enables, a better adjustment of taxes to capacities to pay in the lower income brackets. Persons with net incomes of less than $5,000 would pay $8*5 billion out of the total of $8.5 billion additional Income tax under the Treasury proposal of October 4$ $3.9 billion out of $8.7 billion under Alternative proposal A; and $4.4 billion out of $6.8 billion under Alternative proposal B* b* The Mouse bill - 24 - / Putting the minimum tax in its proper perspective, it is not an overstatement to say that its complexities will jeopardize the whole income tax system* Merely to v/ collect $161 million from 9 pillion taxpayers near the bottom of the income scale, it endangers the collection of more than $17 billion from over 60 million taxpayers y' throughout the scale* The Bouse Sill offers the American taxpayer a minimum tax *cure* that is worse than the Victory tax ^disease'*. We cannot afford to disappoint the mass of taxpayers-who have been promised relief from the complexities of our present dual tax structure. cannot risk* a break down in the mainstay of our f ederal tax system in the midst of total war. The question of Victory tax integration Is of crucial importance. I am firmly convinced that the Treasury in tegration proposal would achieve real simplification at a / • modest and entirely reasonable cost.^ y 2. Increase in Revenue a. The Treasury proposal Thus far, 1 have discussed only the Victory tax integration segment e* Conclusion on simplification Simplicity in Income taxation implies both mechanical ease of compliance and understandabllifcy of the basic tax rules* The integration scheme in H* E* 3687 violates both of these standards* It has been amplyj'illustrated that the mechanical problems of compliance under the mini rum tax may be even more burdensome than those associated with the Victory tax. But even assuming that master tables could be developed to cope with most of the mechanical S ' complexities of the House Sill, the problem of simplicity would not be solved* / The minimum tax and its relationship to the regulaY tax completely defy understanding on the part of the average taxpayer* A tax law which affects over 50 million people must be made understandable to them if it is to survive. It must be explainable to them over the radio, in the press, and through the mails* I might be able to visualise mechanical guides which would help To ^ taxpayers^in robot fashion atnafehs through income tax y compliance under the House I cannot visualise an information campaign that could make this tax understandable to taxpayers generally. Putting the ** 2 2 m proposal would simplify the entire income tax structure in eliminating $275 million of tax for the 9 million taxpayers least able to pay and most expensive to tax* In contrast, the House bill complicates that structure and multiplies the compliance burdens of over 50,000,000 persons merely to keep the 9 million taxpayers on the rolls, and to exact from them the relatively small sum of $161 million* It seems utterly unreasonable to erect a mountain of complexity for such a molehill of revenue* e* Conclusion on simplification* iiHiHUn Mumu' mi« — iummgwiwn m u» iin i< iw i<ii'ftl>*nii>w..... . <mH m *~ m # m m *"m **** • El * ^ totaling $711 million* The House Bill increases liabilities for 26*3 million taxpayers, the increases totaling $459 million* While the 9 million taxpayers who would be exempted under the Treasury proposal pay $275 million under present law, they would pay only ^ $161 million under the House Bill, This figure of $161 million measures the reduction involved in their elimination from the income tax rolls* Any integration plan will inevitably change liabilities of many taxpayers* The major concern should be that the changes meet the tests of simplicity and fairness* The Treasury changes meet these tests far better than the changes in H« R* 3687* While the Treasury integration proposal would reduce taxes only for tax payers in the lowest brackets and subject to family X responsibilities, the House Bill would apply reductions to taxpayers with incomes as high as $3,981 (married person with 2 dependents) and $4,672 (married person with 3 dependents)* More important, the Treasury proposal - m ~ their necessarily complicated annual return next March < with the assurance that future income tax returns would be both more understandable an# simpler. d. fax increases and decreases under the House Bill and the Treasury integration proposal**^ Some contend that the Treasury proposal achieves simplicity at an excessively high cost in tax reduction for taxpayers in the lowest brackets and that the House r Bill Involves no corresponding cost. I should like to cite the facts refuting this contention. The Treasury integration proposal would exempt entirely 9.1 million taxpayers who now pay a net fictory tax of $275 million. Including these, it would reduce taxes for 18 million taxpayers, the combined reduction ✓ totaling $436 million. The louse Bill exempts only 130,000 taxpayers, but reduces taxes for a total of 26.2 million taxpayers; the aggregate reduction is $370 million, only $66 million less than the Treasury proposal. The Treasury proposal would increase liabilities for 34.4 million taxpayers, the increases totaling - 19 c* Contrast of House Bill with Treasury Integration proposal from the standpoint of simplicity*^*" The contrast between the House Bill and the Treasury proposal on the score of simplicity is complete* What the House Bill gains in removing the Victory tax, it loses in introducing the minimum tax* It retains the complexities of a double tax system and adds special vagaries of its om* It burdens administration with new problems at a time when it is still faced by the enormous task of adjusting itself to current collection* Worst of all, it will require taxpayers to struggle with the new minimum tax concept even before they finish hurdling the Victory tax barrier* Under the Treasury proposal, on the other hand, there would be no double tax base, no double exemptions, and no multiple choices and computations* Administration would be simplified by dropping the Victory tax* Similarly, withholding would be simplified by dropping the Tai'niispim withholding feature necessary to guarantee collection of the Victory tax. Most important, compliance would be simplified* Taxpayers could face the prospect of filing their - 18 of 41*7 million returns, representing 52*4 million taxpayers, in contrast with the Treasury proposal, which would require only 38*5 million returns representing 43*2 million taxpayers* 2/ The House Bill, like the present law, requires millions of returns from persons in those income brackets in which the ratio of adminis trative effort to tax proceeds is hipest* Moreover, the complexity and confusion generated by the double exemptions and computations and by the involved choice between joint and separate returns will inevitably burden administration* Both in terms of the taxpayers who will throng the collectors9 offices for help, and in terms of the volume of errors that taxpayers will r make, the House Bill magnifies the problems of administration* s / s c* Contrast of House Bill with Treasury integration, etc* ^' "irhxfer presant Taw the 'figures would, W returns and 53*3^taxpayers* Ws \VIib ^ 44*1 million No shift of part of the exemption from one to the other is permitted as under present l a w a n argilopiM?a&e d-ivifi1 on*Sf the.ftwta l 1exesiption»> Situations will frequently arise, therefore, where one spouse is entitled to a refund1and the other is subject to additional tax* Yet, because the exemption is fixed at $500, the opportunity that exists today for canceling out the refund and. the additional liability is removed* For example, if the wife works part of the year but does not take any of the withholding exemption, she is entitled to a refunli The husband, who takas the entire withholding ||| exemption, will probably have to pay additional tax* But oven if the wife’s refund is equal to or greater than the husband’s remaining liability, there is no way of shifting the personal exemption and thus offsetting one against the other. He will have to pay the tax and she will, have to wait for a refund* (5) Complication of the administrative process The House Bill also makes heavy I emends upon adminis tration* For 1944, it will require the filing and processing of 41.7 million 16 r (4) Complication of the withholding process^ " In addition to complicating tax returns and the filing process, K* R* 3687 complicates collection at the source and raises new problems for employers* Many employers withhold on the "exact* basis instead of by wage brackets, either to approximate the final liability more clo oly or because their mechanical equipment requires the use of the exact commutation* Since the Victory tax exemption is $624 regardless of family status, present law requires the employer to apply only one act of exemptions varying with family status* But under the House Bill the minimum tax will also have variable exemptions* with two Employers will thus be confronted ets of varying exemptions, as well as two tax rates, in determining how much to withhold* The problem of year-end refunds and additional tax payments is also aggravated* J / Husbands and wives filing separate returns have fixed exemptions of $500 each* 17 The treasury'lias r e c o m ^ ^ i T n "the withholding procedure that would minimize the problem of year-end refunds and additional tax payments* The Treasury proposed that withholding e applied on a graduated basis to the taxpayerfs full liability rather than merely to his partial liability under the normal tax and the first bracket of surtax* It also proposed narrower withholding brackets to adjust amounts withheld more closely to actual tax liabilities* ^ (3) Decreased us# of the simplified r e t u m r ^ Another undesirable b^produdi*of the House bill is that it would in offset &@ny the use of the simplified f o m (104OA) to many taxpayers now able to u*>e that 1o m » Husband ami wife mgr use F o m 104OA as a separate return m long as both 'u>e it and neither has more 1:< 'than $3,000 f gross income# * the House BAH# by providing married couples with a $1*200 exemption if they file joint returns but a combined exemption of only $1*000 if they file separate returns, places a premium on joint returns* As a result, many married persons with combined gross incomes between $3*000 and 16,000* who now file separate returns on Form 1Q4QA, will be penalized by a $200 reduction X continue fco use Vvm, 1040A* ^ in exemption if they Plainly, they will turn to the' more complicated Form 1040* Since it is desirable to extend rather than restrict the use of the simplified / f om, this affect of the House Bill is unfortunate# (4) Complication of the irithholdiM (b) — 14 * The illustration in Appendix B shows that the tax differentials under the various procedures for competing the tax can be very substantial* On the modest 4 |._ H , iaoosie of ^2,12S in the sxaapla cited, the tax liability computed on Form 1040 ranges from $24*75 under the most I||p n ■ • ' adv&itagaous method to $174*75 under the least advan tageous method of filing# (c) Estimates indicate that the House Bill will confront well over 10 million married couples with the choice between Joint and separate returns# Under that bill it Is estimated that 10#7 million joint returns will be filed for 1944* 1/ In addition* a number of separate returns will also be filed by married couples where both receive income* T m great majority of millions of married couples will decide to file either joint or separate returns only after making difficult* time-consuming comparisons* (3) 1/ Decreased use of m i o S .joint rSfSSTlrf expected, while under the Treasury integration proposal, the figure would be 6*7 million* vlVuftroJC low "n of the dependents between husband and wife*A To bo absolutely certain that they have arrived at their lowest possible tax, this couple would also have to make nine tax determinations on the short fora (1040A)* the actual case in which 18 tax computations would be loads to ascertain the lowest tax would be rare* But the mere fact that such cases can occur and that a problem similar in kind, if not in decree, will be faced by many taxpayers is a serious indictment of this phase of the House Bill* With such extreme complexity established beyond; any doubt, the question might still arise (a) whether tli© number of necessary tax computations is much larger than under present law, (b) whether the tax differentials involved are substantial, and (c) whether many taxpayers will be affected* (a) There is no incentive under present law for married persons with small incomes to file separate returns, and the problem of allocating dependents is thereby avoided* (b) The illustra The regular tax exemption, on the other| hand, will be creator under a joint return than under separate returns, thus offering an inducement to file joint returns* By setting the credit for dependents at $100 for the minimum tax in contrast with $360 for the regular tax, the House fell further complicates the choice between joint and separate returns* The large number of variables injected by the House %ill will force husband and wife who both receive income to compute a series of alternative taxes to ascertain their lowest possible liability* I should like to cite an example which brings home more forcibly than any lengthy explanation the nature of the compliance burden imposed on these taxpayers* The example is that of a married couple with three children, and a net income of $2,125, of which the husband receives $1,250 and the wife, $875* Using Form 1040, this couple could reach five different tax results* separate tax computations* This would involve nine These computations are necessary to determine the maximum tax advantage under (1) joint or separate returns and (2) different divisions 11 * Because of these variables* no clear dividing lines or income zones can be established to guide taxpayers into one type of return or the other* In order to determine their lowest tax ^liability, they will have to resort to a method of trial and error Involving numerous alter-* native computations* Merely stating the provisions of the House Bill on this point demonstrates how bewildered the taxpayer will be* Under the minimus tax husband and wife receive an exemption of $500 each, or a total of $1,000, if they file separate returns, but only one $TO) exemption if they file a joint return* Under the regular income tax, their exemption is still $500 each, or a total of $1,000, on separate returns, but is $1,200 on a joint return* J/ In other words, the minimum tax exemption will be smaller under a joint return than under separate returns, thus offering an inducement to file separate returns* the regular 37 ''Hone of "'the ""$500 exemption allowed on & separate return may be shifted from one spouse to the other under either the minimum or the regular tax* but is forced upon millions of taxpayers not now affected by it because of the difference in aggregate exemptions depended! upon whether separate or joint returns are filed* Under present law the problem is restricted to the comparatively few married couples having combined net incomes reaching beyond the first surtax bracket* The choice is fairly clear* It involves persons who are for the most part familiar with tax procedure* To married couples with surtax net incomes below $2,GOG, it is generally a matter of indifference whether they file separate or joint returns* However, under the House Sill it is no longer a matter of indifference* Married taxpayers in even the lowest income brackets, many of them newcomers to the income tax, will be driven to compare the tax advantages of joint and separate returns* They will find that the advantage shifts with the size of income, with the particular division of income between husband \, and wife, and with the number and division of dependents* Because of these ~ 9 tax applies and below which the minimum tax applies* / But this mechanical guide eanjiot remove the confusion inherent in having two alternative taxes side by side* The confusion caused by the House Bill may perhaps best be visualized by a specific example* Take the case of i married couple with two dependents, the husband having $900 of net income from business and the wife $700. their minimum combined liability under the House Sill will be realised by filing separate returns, each claiming one dependent, the husband will be subject to the regular tax, the wife, to the minimum tax. The husband will get a $350 credit for the one dependent and will apply a 23 percent rate to his income. The wife will get a $100 credit for the other dependent and will apply a 3 percent rate to her income. The confusion in this family is apparent. (2) The necessity of comparing taxes under separate and joint re turns ~ -r:e,yn;rir:- -— —--------------------- ✓ — - --- »■ ■* «"} Under the House Bill the problem of choosing between joint and separate returns is not only greatly complicated, but is provided for users of the simplified form# This is all to the good, but it is only a small part of the simpli fication that is needed# The House gill does not eliminate the dual set of personal exemptions and will still require users of the "long form* (Form 1040) to determine which of two taxes applies to their income^* in addition, it will confuse taxpayers with its complicated minimum tax# It will make it disadvantageous for many taxpayers now using the simplified form to use that form in the future. It will require millions of married couples to go through a series of alternative tax computations to ascertain their lowest possible liability* (1) Confusion caused by minimum tax The House Bill provides that taxpayers shall pay either the minimum tax or the regular tax, whichever is larger. Two alternative taxes with different rates and exemptions will confront taxpayers using the long f o n ^ J A table can be appended to that form showing the net income ’’breaking points” above which the regular b. % Analysis of the integration plan in B»R» 8687 In the process of absorbing the Victory tax Into the regular income tax structure, both the louse Sill and the Treasury proposal eliminate the earned income credit and thereby simplify tax computation* But the real promise of simplification this year lies in substituting a single income base for a double base, a single set of exemptions for a double set, and a single tax computation for a double one* The Treasury integration proposal would realise this promise in full* The louse M i l realises the same promise only in a minor degree, and at the same time adds some complexities found neither in the present law nor in the Treasury proposal* The House Bill eliminates the f>gross” base of the Victory tax and substitutes a single for a doublo tax computation on the simplified fora (Form 10401}* Both . the regular income tax and the minimum tax are computed on the basis of income tax net income* Moreover, a table indicating the regular tax and minimum tax is proyided for «* 0 ** new sxsBptlanSjfop th e ¥£otarr<— Inn-iraa rftng^ff rip*" nr,M r' ' ■ ' *LI W th n tp p rn T T flis ta tssn the Treasury proposal employs no minimum tax but would reduce the credit for dependents by $50 and the exemption for a married oouple by $100, Comparative burdens under the House Bill and the Treasury integration proposal are shown in Exhibit 4, Hf 4 comparison of surtax and normal tax rates under the Bouse and Treasury proposals will bs found in Exhibit 3 appended to this statement* The combined normal tax ana surtax under the House Bill is one percentage point higher than the combined taxes under the Treasury inte gration proposal in the ranges from sew to |6,0w* «» 112,000 to §70,000. In the ranges between $6,000 and $1J£O0O# and above.$70,000, the two plans apply the same combined tax rates* m 5 ** spueini personal ($500 fur it sliigl# individual m a tmrried ptrsoa filiag a aoparato return* and $700 far a aarriai couple filing a Joint return* plus $100 for each dependant) 1 / j (d) s*ts the personal exesaption under 'the pegul&f income tax at 1500 for each married person filing a separate return; (e) increases the normal tax rqte from 6 percent to 10 percent; and (f) decrease# surtax rate# by 1 percentage point on surtax net income between $6*000 and $12*000 and increases by 1 to 3 percentage points on surtax net income above $38,000. The combined normal tax and surtax increase would be 4 percentage points on net taxable income up to $6*000; 8 points between $6*000 and $12,000; 4 points between $12,000 uni $38,000; and 5 to ? points above that level. Comparing the Treasury proposal with the House Bill, we find that they differ sharply in the technique of integration. The principal difference is thin The House Bill TV< VvcToxy -tea substitutes a 3 percent minimum tax^vith new exemptions..^. .. _... ._ 2/ The taxpayer pays either this minimum tax or the tax ~ eoznuted at the regular rates and exemptions* whichever is higher. - 4- Victory tax. Both the Treasury proposal and the Boose Bill recognize this fact by replacing the Victory tax with adjustments in the regular income tax* 1/ a. Comparison of Treasury and Bouse Bill Methods of integration*^ The method suggested by the Treasury to absorb the Victory tax into the regular insane tax structure would (a) repeal the Victory tax} (b) ellainate the earned income credit; (o) reduce the personal exemption for a carried person or head of family fro* $1,200 to $1,100, and the dependent credit from $350 to $300, leaving the single person*s exemption unchanged; and (d) increase surtax rates by 3 percentage points on surtax net income up to $38,000, and by 4 to 7 point® above that level. The Bouse Bill (a) repeals the Victory tax; (b) eliminates the earned income credit; (e) imposes a minimum tax of 3 percent on the excess of net income over 1/ One proposal for simplification recommended by the Treasury Ms already been adopted and will apply to 1943 tax returns filed next March* In Public Law 1 the Congress changed the Victory tax rate from a gross to a net basis by providing for automatic current allowance of the postwar credit. This change eliminates a complicated step In computing the Victory tax. <m 3 ** C. The Individual Income Taxi The major objectives of the Treasury individual income tax proposal ar« (1) to simplify the income tax by absorbing the Victory tax into the regular incometax structure, and (2) to add $©»5 billion to tax revenues. The major objective of the incus* tax provi sions in the House Bill is to replace the Victory tax with a minimum tax and adjustments in the regular inoom The Chairman of this Committee and many others have expressed concern over the complexities of our tax laws urgent desire to simplify our tax structure xum irvasury shares the view that simplification is a first order of business, and on several occasions has made specific suggestions to this end. Especially in the case of the individual income tax, which directly affects more than SO million taxpayers, simplification has become crucially important. Bo really effective simplification is possible without eliminating the Victory tax. ** 2 '*■ m follows: Under House Bill Individual income taxes 6*528.5 Billion I 226.0 million 1*128.1 467.9 1,194.8 Postal revenues m s V There attached as oomp&ring and Means V For a detailed comparison of the present lew %f This estimate is^'ln contrast of a yield of $2*13$ million* of Hons# liabilities under t see Exhibit 2< W a >j j <k *\& W\1<k >*£ • i A A . Introduction The purpose of ny statement today is, first, to explain in detail the apeeiXio recommendations of the Treasury and to compare then with the provisions of H. E. 3667, the Bouse Bill; second, to indicate acme of the technical considerations underlying the Treasury proposals; and, third, to examine with you some of the principal criticisms which have been made of the Administration* s proposals for $20.5 billion of additional taxes. B. Revenue comparison of the Treasury proposals and the House Bill (!i. g, 3687) In his statement to the Ways and Keans Committee on October 4, 1*3, the Secretary recommended wartime tax S8 . . increases totaling $1019 billion for a full year of operation. (See Exhibit 1) would raise $2.05 billion. The bill now before you These totals are made up as follower Statement of Randolph Paul* General Counsel of the Treasury, 8|mp| belore tiie Smate Finaaa® Coaaitta# Nov amber S%. 1^43 Statement'of Randolph Paul, General Counsel of the Treasury, before the Senate Finance Committee--- - -■ November 29, 1943 A. • Introduction '• - v * 1* The purpose of my statement today is, first, to explain.in detail the specific recommendations of the Treasury and to compare them with.the pro visions of H. R. 3687, the House Bill; second, to indicate "some of the. technical considerations underlying the ;Treasury proposals'j and, third, to examine 'with ybu some of the principal criticisms which have- been made of the Administration’s proposals for $10,5 billion of additional taxes. B. Revenue comparison of the Treasury-proposals and the House Bill (H.R. 3687) In his statement to; the Ways and' Means Committee1 oh October 4, 1943, the Secretary r e commended wartime tax *increases totaling $10*58 billion for' a full year ■ofoperation* (See Exhibit 1) The bill now .before you would raise $2.05 billion/- These totals are made up as follows: Increases Under Treasury 1 Hou’ se proposals 1/ Bill Incftvidual income taxes Corporate taxes Estate and' Gift taxes Excise taxesPostal revenues M - £ yd xe S'^u j '$ 6,528.5 million 1.138.1 ' 401.6 2.511.1 $10,579.3 *• If 226.0 million ; 467.9 ; 1 ,194.8 1 5 8 .8 ~ $2047.5 2/ There is attached hereto as appendix A a statement comparing the proposals made by the Treasury to the Ways and Means Committee with the provisions of..the House Bill,,. C. The Individual Income Tax The major obje ctives, of the Treasury individual income tax proposal are (1) to simplify the income tax by absorbing the Victory tax into* the regular income tax structure, and (2) to add $ 6.5 billion t o ‘tax revenues.. The major -objective of the income tax provisions in the House Bill is to replace the Victory tax with a minimum tax and adjustments in the regular income tax. 1/ £or a detailed comparison of estimated.liabilities under.the present law and the Treasury proposals, see Exhibit 2.. . i 2/ This estimate is in contrast with the Ways and Means.Committee’s estimate of a yield of $2,139 million, a 39-70 ' o 1. Simplification Through Victory -Tax Integration The Chairman of this Committee and many others have expressed concern over the complexities of our tax laws and a n urgent desire to simplify our tax structure* The Treasury shares the view that simplification is a first order of business, and on several occasions has made specific suggestions to this end.' Especially in the case of the individual income tax, which directly affects more than 50 million taxpayers, simplification'has become crucially important. No really effective simplification is possible without eliminate ing the Victory tax. Both the Treasury proposal and the House Bill recognize this fact by replacing the Victory tax with adjustments in the regular income tax. 1/ *r a. |Hi i p I .!|! j - • Comparison of Treasury and House Bill meunods of integration |1 The method suggested by the Treasury to absorb the Victory tax into the regular income tax structure would (a) repeal the Victory tax; (b) eliminate the earned income credit; (c) reduce the personal exemption for a married person or head of family from $1,200 to $1,100, and the dependent credit from $350 to $300, leaving the single person's exemption unchanged; ana (d) increase surtax rates by 3 percentage points on surtax net income up to $38*000, and by 4 to 7 points above that level* The House Bill (a) repeals the Victory tax; (b) eliminates^ the earned income credit; (c) imposes a p t tax of 3 percent on the excess of net incoke over special personal exemptions ($500 for a single- individual or a married person filing a ‘separate return, and $700 for a married couple filing a joint return* plus $100 for each dependent) 2/; (d) sets the^ personal exemption under the regular income tax at $500 for each married person filing a separate return; (e) increases the normal tax r’ ate from ^ 6 percent to 10 percent; and (f) decreases surtax rates by 1 percentage point on surtax net income between $6,000 and $12,000 and increases them by o 3 percentage points on surtax net income above $38,000*. The combined normal tax and .surtax increase would be 4 percentage points on net taxable up to $6,000; 3 points between $6,000 and $12,000; 4 points between $12,00 and $38,000; and 5 to 7 points above that level. Comparing the Treasury proposal with the House Bill, we find that they differ sharply in the technique of integration. The principal difference is t h i s T h e House Bill substitutes for the Victory tax a 3 percent minimum tax with new exemptions; t h e .Treasury'proposal employs no minimum tax but would reduce the credit for dependents by $50 and the exemption 1/ One proposal for simplification recommended by the Treasury has already been adopted and will apply to 1943 tax returns filed next March* h Public Law 178, the Congress changed the Victory tax rate from a gro 3 a net basis by providing for automatic current allowance of the P°st™?;+ T M-fr change eliminates a complicated step in computing the i "t$3tX ' 2/ The taxpayer pays either this minimum tax or the tax computed at the regula rates and exemptions, whichever is higher* - 3 ~ a married couple by $100* Comparative burdens under the House Bill and the Treasury integration proposal are shown in Exhibit 4* %f V'. b# Analysis of the integration plan in H.K# 3687 In the process of absorbing the Victory tax into the regular income tax structure, both the House Bill and the Treasury proposal eliminate the earned income credit and thereby simplify tax computation# But the real promise of simplification this year lies in substituting a single income base for a double base, a single set of exemptions for a double set, and a single tax computation for a double one# The Treasury integration proposal would realize this promise in full* The House Bill realizes the. same promise only in a minor degree, and at the same time Adds some complexities found, neither in the present law nor'in the Treasury .proposal# . . . The House Bill eliminates the ^gross’1 base, of the Victory tax and substitutes a single for a double tax computation on the simplified f o r m (Form 1040A)# Both the regular income..tax and the "minimum tax are, computed on the basis of. income tax net .income.# ..'Moreover, 'a table .indicating the '. regular tax and; minimum tax is provided, for users of the simplified form. This is all to the good, 'but. it is only a small, part of the simplification that is needed#' The House Bill does not eliminate the dual set of. personal exemptions and will still, require users of the .’'long form’1 (Form, 1040) to determine which of two. taxes applies to their incomes# In addition, it will confuse taxpayers with its complicated minimum tax# ’I t will make it disadvantageous for many taxpayers now using the. simplified form to! use that form in the future# It will require millions of married couples to go through a series of alternative tax computations to ascertain.their lowest possible liability# (1) Confusion caused by minimum tax The House Bill provides that taxpayers, shall pay either the minimum tax or the regular tax, whichever is larger* Two alternative taxes with different rates and exemptions will .confront taxpayers using the ."long, form." A. table can be appended to that ‘form showing, the net income "breaking, points" above which the1regular tax applies and below which' the minimum tax applies*. But this mechanical guide cannot remove the confusion- inherent, in having two alternative taxes side by side# The confusion caused by the House Bill m a y perhaps best be visualized by a specific example#' Take the case of a married couple with two dependents, the husband having $900 of net income from business and the wife $700f 1/ A comparison of surtax and normal tax rates -under the- House and. Treasury proposals will be found in Exhibit 3 appended to this .statement# The combined normal tax and surtax under the House Bill is one percentage point higher than the combined taxes under the Treasury integration proposal in the ranges from zero to $6,000, and $12,000 to $70,000# In the ranges between $6,000 and $12,000, and above $70,000, the two plans apply the same combined tax rates# A *“ Their minimum combined liability under-the House Bill will be realized by filing' separate returns,-' each claiming one dependent#;,: The husband will be subject to the regular.tax, the wife, to the 'minimum tax* The husband will get a.;£35Q. credit'for the one dependent, and. will apply a 23 percent rate to his income* The. wife will get. a £1QQ: credit for the other dependent and.will'apply a. 3 percent rate t’o her,.income. The, confusion in this family-is apparent* . (2) The necessity of comparing taxes'under separate 'and . • ' joint returns# ; . * * ‘‘ '* ,. 1AV,- SliSSy™ .Under the'House Bill-'the problem of -choosing, between joint and separate returns is not only greatly complicated, but is forced upon millions of taxpayers not now affected by it because of;the difference in aggregate exemptions depending.upon whether separate .or joint returns are filed. Under present law the problem is restricted to the- compara tively few -married couples having combined net incomes., reaching beyond the. first surtax bracket, 'The choice is- fairly clear-. . It. -involves persons;who hre, for the most part familiar with tax .procedure. - To mar ried couples witli surtax net incomes below-•2,000, it is generally a matter of indifference whether 'they file separate or joint returns.... However , under the House Bill, it is -no'longer ..a matter ,of indiff er-ence. Harried taxpayers in'even t h e ■lowest•income" brackets, 'many of them newcomers to the income tax*■will be driven'to compare the taxi advantages of joint and separate returns. " They will find that the advantagp shifts with the -size of income, with thfe particular‘division of income between husband, "and wife, and .-with the- number and division of dependents. Because .of-these variables, ho clear, dividing lines or income zones, can be ,established to guide taxpayers into one type of return-o'r the other* In order to determine their lowest tax liability,- they will have to resort to a method of trial and error involving numerous alternative computations. Merely stating the provisions'of the House Bill on this, point demonstrates how bewildered the taxpayer will be* Under the minimum -tax husband-and- wif e" receive, an exemption of £.500 each,.or a total of £l, 000, if. they,file separate returns, but only one £700 exemption,if they file a joint return. '.Under -the regular income tax* their exemption is still |500 each, or a total of £1,000, on separate returns, but is £1,200 on a joint return. 1/ In other words, the minimum tax exemption will be smaller under a joint return than under separate returns, thus offering an induce ment to file separate returns. The regular tax exemption, on the other 1/ None of the $500 exemption allowed on a separate return may be -shifted from one spouse to the other under either-the minimum or .the regular tax. '*■’r ':5 ;,;i* ,v y ** * . , hand, m i l be greater under a joint return than under separate returns, thus offering an inducement to file joint returns,. By setting the credit for dependents at $100 for the minimum tax in contrast with $350 for the regular tax, the.. House Bill further complicates the choice between joint and separate returns e • ' ■ j Sj The large number of variables injected-by the--House-.Bill m i l force husband and wife w h o both, receive income to compute a series of alternative taxes, to ascertain their lowest possible liability, 1 should like to cite ■an example Yrhich brings home more forcibly than any lengthy explanation the nature of the compliance burden imposed on these taxpayers, : The example is that of a. married couple witlr three ■children and a net income1-'-of $2 ,125 , of which the husband receives $1,250 and the wife, $875® Using Form'10^0, this couple could reach five different, tax results, .This would involve nine separate tax computationso These computations are necessary to determine the maximum tax advantage, under (l) joint or separate returns' and (2) different divisions of the dependents between husband, and wife0 (See..illusr* tration in Appendix B,) To be absolutely certain that they have arrived at their lowest possible- tax, this couple would also have to make nine tax determinations on the short form (1040A),. The actual case in which 18 tax computations would be made to ascertain the lowest tax v/ould be rare. But the mere fact that such-cases can occur and that a problem similar in kind, if not in degree, will be'faced by many taxpayers i s <a serious indictment of this phase of the House Bill, . With such extreme complexity established beyond any doubt, the question might still arise .(a) whether the number of necessary tax computations is much larger than under- present law, (b) Whether the 'tax differentials in volved are substantial, and (c) whether many taxpayers will be affectedo (a) There is no incentive u n d e r present law for married -.persons* with small incomes to file separate returns, and the problem of allocating dependents is thereby avoided, (b) The illustration in Appendix B shows that the tax differentials under the various *procedures for computing the tax can be very substantial. On the modest income of $2,125 in the example cited, the tax liability computed on Form 1040 ranges from $24-,75 under the m ost.advantageous method to $174-o75 under the least advantageous method of filingo (c) ; Estimates indicate that the House Bill will confront well over 10 million married couples’with the choice between- joint--and. separate returnso Under that bill it .is estimated that 10,7 million joint returns will be filed for 1944-o 1/ In addition, a number of separate returns will l 1/ under'present law,'8,2 million joint, returns are expected, while under the*Treasury integration proposal, the figure would be 6,7 million. also be filed by married couples -where both receive income® The great majority of millions of married couples will decide to file either joint or separate returns only after making difficult, time-consuming comparisons0 (3) Decreased use of the simplified return Another undesirable by-product of tbs House bill is that it would in effect deny the use of the simplified form (104.0A) to many taxpayers now able to use that form® Husband and wife may use Form 1040A as a separate return as long as both use it and neither has more than tD^OOO ox gross incomeo The House Bill, by providing married couples with a 51,200 exemption if they file joint returns but a. combined exemption of only $1,000 if they file separate returns, places a premium on joint returns0 As'a result, many married persons with combined gross incomes between 53,000 and -§6,000, who now file separate returns on Form 1040A, will be penalized by a $200 reduction in exemption if they continue to use Form IO4OA 0 Plainly, they will turn to the more complicated Form 1040© Since it is desirable to extend rather than restrict the use of ths simplified form, this effect of the House Bill is unfortunate© (4) Complication of the withholding; process In addition to complicating tax returns and the filing process, Ho R® 3687 complicates collection at the source and raises^new problems for employerso Many employers witliliold ori the ^oxact** basis instead 01 by wage brackets, either to approximate the final liability more closely or because their mechanical equipment requires the use of the exact computation© Since the Victory tax exemption is $624 regardless of family status, present law requires the employer to apply only one set of exemp tions varying with family status© But under the House Bill the minimum tax will also have variable exemptions© Employers will thus oe ^confronted with two sets of varying exemptions, as well as two tax rates, in deter mining how much to withhold© The problem of year-end refunds and additional tax payments is also aggravated© 1/ Husbands and wives filing separate returns have ximed exemptions of $500 each® No shift of part of the exemption from one to the other is permitted as under present law© Situations will frequently 1/ 'The ? reasiiiy hits ^reciWaerded changes in the vmthholQing procedure uhat would minimize the ^-oblem of year-end refunds and additional tax paymentso The. Treasury proposed that withholding be applied on a graduated basis to the taxpayer*s full liability rather m a n mere y to his partial liability under the normal tax and the first bracket of surtax® It also proposed narrower withholding brackets to adjust amounts withheld more closely to actual tax liabilities# 7 arise, therefore, "where one spouse is entitled to a refund And the other is subject to additional tax0 Yet, because, the exemption is fixed at' $500, the opportunity- that exists today for canceling out the refund and the additional liability is removed,® For:.example., if.the -wife works part of the year but does not take any of the Ydfhholding exenption, she is entitled to a refund* The husband, who takes the e^tir^iy^t.Jiholding exemption, will probably have to pay additional’'tax®,. Butfeyen if the w i f e 's refund is equal to or greater than the husbandfs remaining liability, there is no way of shifting the personal exemption and thus offsetting one against the other© He will have to pay the tax and she will have to wait for a refund© V u . (5) Compileat ion of the administrative nr ocess ■ *The House Bill also makes heavy demands tpon administration© For 194-4* it will require the. filing and .processing of 41©7 million returns, representing 52*4 million., taxpayers, in contrast with the Treasury proposal, which'would require qnly 36©5 million returns representing 43o2 million taxpayers© The & $ $$, Bill, like the present'law, requires millions of returns from persons in those income brackets in which the ratio; of administrative effort to tax proceeds .is highest© Moreover, the complexity and confusion generated by the double exemptions and computations and by the •involved choice between joint and separate returns will inev« itably burden administration® Both in terms of the taxpayers Yfho trill' throng the collectors1 offices for help, and in terras of the volume of errors that taxpayers will mate, the House Bill magnifies the problems of administration- V Co Contrast of .House Bill with Treasury integration proposal ■ from the standpoint of s d ^ l j S ^ « u> JJ" 1'• : • The contrast between the House Bill and the Treasury proposal on the score of simplicity is complete© What the House- Bill gains in removing "the Victoiy tax, it loses in introducing the minimum tax© It retains the complexities of a double tax system and adds special vagaries of'its ov/n0 It burdens administration with new problems at a time when it is .still faced by the-enormous task of adjusting itself to, current collection©1* Worst' of all, it .will require taxpayers to .struggle with the :hew minimum tax concept even before they finish hurdling the Victory tax barrier© ■ \ * ' ✓ • . .v*■' "it ,\ I‘ Under the Treasury proposal, on the other hand, there would be n o ’' double tax base, no double exemptions, and no. multiple choices, and computations© Administration would be simplified by dropping the Victory tax0 Similarly, vdthholding would be simplified by dropping the minimum Under present law the figures"wouff 52©3 .million taxpayers© and X s «• ■withholding feature necessary to guarantee collection. of the Victory .tax0 M o s t ’important, compliance would be simplified* Taxpayers -could face, the prospect of filing -their necessarily ■.complicated annual, return next March with the assurance that future income- tax /-returns .would be both more- understandable and simpler* •.* *r " •" .. ' ^ ■ d0 Tax increases and decreases under the. House Bill and the. Treasury integration proposal \ ?■ f. - HE ’ Some contend that the Treasury proposal- achieves simplicity at an excessively high cost in tax reduction for taxpayers in the lowest brackets and that the House Bill involves no corresponding costo I should like to cite the facts refuting this Contention* • The Treasury integration, proposal -would, exenpt entirely. 9ol million taxpayers who now pay a net Victory tax of $275 million® Including these, it would reduce taxes for IS million paxpa&av#, the .combined !reduction totaling $436 million* The % h s e Bill exempts only 130,000 taxpayers, but reduces taxes for a total -of # ^ -i4illion taxpayers; the aggregate reduction is $370 million, only ^ BifliiOn less than the Treasury proposal® The Treasury proposal would increase liabilities, for 34 04 million taxpayers, the increases totaling $7ll ndlllon* The -Hox^e Bill increases liabilities for 2 6 03 million taxpayers, the increases totaling $459 million* While the 9 million taxpayers who Would be exempted under the Treasury proposal pay $275 million under present law, they would pay only $161 million under the House Billo This figure of $161' million,measures the reduction involved in their elimination from the income-tax rolls0 Any integration, plan wifi inevitably change, liabilities of many tax payers* The major concern should be that the changes meet the tests of simplicity and fairness* The treasury changes meet these tests far better than the changes in H* R* 3687* While the Treasury integration proposal would.reduce taxes only for taxpayers in the -lowest brackets and subject to family responsibilities, the House Bill would apply- reductions, to tax payers'with incomes as high as $3y931 (married person with 2 dependents) and $4,572 (married person with 3 dependents)* ;More important, the Treasury proposal would simplify the entire income tax structure in , eliminating $275 million of~tax for the 9 million taxpayers least able to pay and most expensive to tax* In contrast, the House Bill' complicates that structure and multiplies the compliance burdens of over 50,000,000 persons merely to keep the 9 million taxpayers on the rolls, and to exact from them the relatively small sum of $161 million* It seems utterly unreasonable to erect a mountain of complexity for such .a molehill of revenue* -— e* --.Conclusion, .on .pimolif jcatj on Simplicity in income taxation implies both mechanical ease of compliance and understandability of the basic tax rules* The i n t e g r a t i o n scheme in H* R* 3687 violates both of these standards * It has been amply - 9 ~ illustrated that the mechanical problems of* compliance under the minimum tax may be even more burdensome than those associated with the Victory tax0 But even assuming that master.tables could'be developed to cope with most of the mechanical complexities of the House Bill, the problem of simplicity would not be Solved® The 'minimum tax and its relationship to the regular tax completely defy understanding on the part of the average taxpayer® A tax law which affects over SO- million people must be made understandable to them if it is to survive® It must be explain able to them over the radio, in the press, and through the mails® I might be able to visualize mechanical guides which would help taxpayers to stumble in robot fashion through income tax conpliance under the House Billo I cannot visualize.an information campaign that could make this tax understandable to taxpayers generally® Putting the m i n m u m tax in its. proper perspective, it is not an over statement to say that its complexities will jeopardise the whole income tax system® Merely to- collect $161 million.from 9 million taxpayers near the bottom of the income scale, it endangers•the collection of more than $17 billion from over 50 million taxpayers throughout'the scale® The House Bill offers the American taxpayer a minimum tax “cure" that is worse than the Victory tax “disease"® ' We cannot /afford to disappoint the mass of taxpayers who have been promised relief from the complexities of our present dual tax structure® We cannot risk a breakdown in the mainstay of our •Federal t a x ,system in the midst of total war® The question of Victory tax integration is of crucial importance® I am firmly convinced that the Treasury integration proposal would achieve real simplification at a modest and entirely reasonable cost0 2® Increase in Revenue a,® The Treasury proposal Thus far, I have discussed only the Victory tax integration segment of the Treasury individual income tax proposal®- The Treasury has also recommended as part of a $1005 billion program of wartime taxes that an additional $6®5...billion of revenue be raised in individual income taxes® The surtax rate increases suggested to raise this revenue of course in clude the changes designed to absorb the Victory tax® Exhibit 5 appended to this statement shows the schedule of surtax rates‘proposed to the Ways and Means Committee on October A* 1943® 1/ (See also Exhibits 6 and 7®) 1/ It will be seen Trom exhibit 5 that the Treasury is recommending that 4^ separate surtax brackets of $500 each be substituted for the present first bracket of $2,000® This change enables a better adjustment of taxes to capacities to pay in the lower income brackets® .10 — Two alternative schedules for raising approximately $605 billion of added income tax revenue are also attached, for the convenience of your Committee (See Exhibits 8, 9 and 10)o It will be eeenthat these alternative schedules would impose a heavier burden in the lower income brackets than the October % proposal0 1 / . ■ b0 The House Bill •j v, Revenue is only an incidental consideration in the income tax provisions of the House Bill© Those provisions will add $226 million to income tax revenues0 Of this.amount about $90 million is attributable to the changes made in connection with Victory tax integration© About $150 million is attributable to the disallowances of deductions"for Federal import duties and miscellaneous excise and stamp taxes not other wise deductible as business expenses© 2/ The other individual income tax changes made by the House Bill are of a technical character© 3® Answer to Criticisms of the Treasury Proposals for Higher Income Taxes . I should now like to examine with yo(u some criticisms that have been made of the Treasuiy*s affirmative income tax proposals©' The three arguments I shall examine are (l) that the Treasury proposals would not bear heavily enough on the lower income bracketsj (2) that the American people do not have the capacity to pay more income taxes, and (3) that income tax rates in 1944 will be. confiscatory© a© Tax burdens on the lower income groups It is contended that persons with incomes of less than $5,000 are the major source of inflationary pressure and that these persons would escape their fair share of the additional tax load under the Treasury proposalso Although at 1944 levels of income about 81 percent of the 1/ Persons with net incomes of less than $5,000 would pay $3©5 billion out of the total of $605 billion additional income tax under the .Treasury proposal of October 4j $3«9 billion out of $6©7 billion under Alternative proposal A* and $4o4 billion out of $6©8 billion under Alternative proposal Bo 2/.This disallowance was recommended by the Treasury© At present, the allowance of deductions under Section 23(c) is inconsistent and depends entirely on the legal language used in imposing the tax© For' 'example, admissions taxes are allowed as deductions, but the cabaret tax is not© Uniformity in the matter of deductibility is desirable© Revenue, administrative, and equity considerations also ’suggest disallowance of these taxes in so far as they constitute personal expenses© - 11- - total cash income will, be received by persons with incomes under $5,000, only 65 percent of the net income'above income tax exemptions will be * received by this group0 Likewise^ alt hough 6l percent of total income will be received by persons with incomes under $3,000, only 39. percent of the net income above income tax exemptions Yd.ll be received by this'group6Looking.behind:these aggregates to individual cases,.we find that the margin of disposable income over and above wartime needs is very *:: narrow^for the millions of persons in the lower income brackets® Out of 67o3 million income recipients in the calendar year 1944, 58®2 million are expected, to receive net incomes of less than $3,000o The average cash income per recipient before taxes will be $1,650, and after existing taxes, about $1,500o The demands of wartime living on incomes of this size leave little margin for additional taxes and afford few opportunities for infla^ tionary spending® Nevertheless, the urgent requirements of war finance demand that m tap even this small margin of disposable income® Under the Treasury proposal one-half of the income tax increases Y/ould fall on persons with net incomes of less than $5,000 and about one-fourth on persons Yirith less than $3,000® Much the same proportions hold for the complete Treasury program, including proposed changes in corporation taxes and in excise taxes o ■ .. |j h , .r., . bo Capacity to pa?/- A second contention xs that the American people do not have the ' capacity to pay additional income taxes® The facts contradict this con tention^. Individual incomes after personal taxes amounted to.$65 billion ■in the fiscal year 1939 and are expected to amount to $126 billion in the fiscal year 194-4-0 The corresponding figures before subtracting personal taxes are $68 billion and $148 billion® In other words,, personal taxes show an Increase of $19 billion While' incomes before taxes show an increase of $80 billion. Less than one— fourth of the increase in annual income payments generated, by.defense and war activities is being absorbed by taxes. In an attempt to prove that American taxes are too high, it is argued that, taxes in the United States are higher in terms-of dollars per capita than in the United Kingdom and Canada® 1/ This argument is, of course, grossly misleading, since it gives absolutely no indication of real burdens® How burdensome a given tax will; be is determined by the ratio of the tax 0 the income from Y/hich the tax. is p aid0 Personal incomes here are larger than In either Canada or-Great Britain® Furthermore, the rates’ -of income tax and excise taxes are higher in the Allied countries than here® Pracically any citizen of the United States, if given the choice of paying V See Page 8, House Report No® 871.on the Revenue Bill of 1943® American, Canadian, or British taxes, would choose the American tax system, since his tax here would be the lowest© Co The argument of confiscation In connection with the argument that taxes will exceed capacity to pay, it is contended that our existing income tax rates are confiscatory© Those who make, this contention point to the combined burden of current taxes, uncanceled 1942 liabilities, and State income taxes© It is said that this combination will exceed 100 percent of income in 1944o Such statements are grossly misleading.-, They ignore two facts© The first is that the Federal income tax allows for the deduction of State income taxes in computing net income© This deduction protects the tax payer from a confiscatory combination of State and Federal taxes, even if the State tax does not permit the deduction of the Federal tax© The second fallacy lies, in comparing two years’ taxes, or 1-1/8, y e a r ’s taxes, with one y e a r ’s Income0 The uncanceled part of the 1942 tax is in no sense a tax on 1944 incomeo This becomes entirely clear when it is realized that a person having no 1942 income has no uncanceled tax to pay in 1944* and would therefore not be covered by. the schedules combining the two y e a r s ’ taxes© As a matter of fact, when the taxes for two years are combined with the net income for two years, as they should be, it becomes apparent that the 75 percent cancellation is a windfall which has made it easier, not harder, to pay taxes on 1944 incomeo Bo Corporation Taxes The Treasury suggested to the Hays and Means Committee (a) that the surtax on larger corporations (those with net income in excess of $25 ,000) be increased by 10 percentage points and on smaller corporations by 4 percentage points; (b) that no change be made in the excess-profitstax rates; and (c) that certain changes be made in the existing provi sions for carry-back of losses and unused excess-profits credits© The Treasury proposals would increase corporate tax revenues by $1,138 million© The bill passed by the House (a) makes no change in the surtax rate; (b) raises the excess-profits**tax rate to 95 percent; (c) reduces the excess-profits credit for some corporations ty lowering the percentages allowed on invested capital; (d) raises the specific exemption for excessprofits taxes from $5,000 to $10,000; (e) makes no change in the carry back of losses and unused excess-profits credits; and (f) provides special tax treatment for certain natural resources industries© 1/ The House Bill y A comparison of corporation income and excess*profits tax rates is shown in Exhibit 11© ~ 13 - Increases^corporate tax revenues try discuss these, matters, in-detail 0 ' 1® $468 ■, million* I should like to .. ' -; Comparative Effects of Increases in Surtax and Increases in Excess-Profits Tax Unlike an increase in surtax rates., which would increase the net tax liability (after postwar credit) .of all taxpaying corporations, the increase in the excess-profits-tax-rate under .ft© R© 3687 will increase liabilities for comparatively few. corporations.* . Corporations not subject to the excess—profits tax and those already subject to the 80 percent ceiling on corporate taxes will have no added tax to pay© Of 263,000 taxable corporate returns estimated for 1944, '71,000, or about 27 percent will be subject to excess—profits tax 0 Moreover, the 80 percent ceiling will apply to 4 , 3 0 0 ’corporations or approximately 6 percent of all excessprofits taxpayers© This 6 percent,.however, will pay about 40 percent of total excess—profits taxes in 1944® An additional 3,200 corporations will become subject to the 80 percent•ceiling as a result of the 5 percentagepoint increase in the excess-profits tax rate© The effect will be to limit still further the range of corporations to whom the full increase would apply 0 It would apply only to the residual class, namely, corpora tions that pay excess—profits taxes, but will not become subject to the 80 percent tax ceiling© ’ ' In contrast with the House Bill, the Treasury proposal would increase the net liability of all corporations® For those subject to the 80 per cent ceiling, an increase in the surtax would mean a decrease in the share of their 80 percent tax represented by excess—profits taxes 0 As a result, their postwar credit would be smaller and their net liabilities corres pondingly larger, even though their gross tax payments were unaffected© For all other corporations, both the gross payment and the net liability would be increased© " -1 ’ / y From the foregoing analysis it is apparent on the one hand that the House Bill will not strike corporate profits generally, but only a re stricted segment of corporate profits© * On the other hand, it m i l not strike approximately one—half of the excess—profits, nor will it touch the most profitable corporations© To reach corpoiate profits generally, an increase in surtax rates would be necessary© To reach the bulk of excess—profits and the most profitable corporations, added excess—profits taxes would have to be coupled with an upward revision of the 80 percent limitation© ' Because of its broad coverage, the corporate surtax affords an in strument for tapping war profits that are not defined- as excess profits in our tax law© At best, it is extremely difficult to single out excess profits and war proxlts ’ ey legal definition© An excess—profits tax can not be a perfect instrument^ a 90 percent or a- 95 percent excess—profits— tax rate does not mean that the Government.mil recapture 90 or 95 percent of the war profits of corporationso In the area labelled "normal profits” there are bound to be some war profits*; For-example, many corporations ■with large invested capital but low normal earnings, receive substantial war profits, without becoming subject to; excess—profits taxes 0 The same is true o f ' “corporations' with' high' bas'e^bribd e'arnipgs now engaged in the production of war materialso Other corporations have had^ their excess*, profits.tax liabilities substantially reduced by the special relief provisions in the tax law* Still others, m i l ultimately have a substantial proportion of their excess-profits: ta?ces. refunded to them under the opera* tion of the carry-back previsions* The surtax thus offers greater assurance that all corporations which ha^e: benefited, from the war will make an addi tional tax, contribution* ■ .A further reason in. favor"of a surtax-rate increase, as distinguished from an exc e s s-p r ofit s-t ax rate increase,:may be found in^ the comparative effect on managerial profit incentives*. Financial incentives to efxicient management depend upon the number of cents the corporation... retains out ox each additional dollar of profit* The. House Bill would increase the net tax (after postwar credit), on each.dollar.,of excess—profits^ from 81 to 85-1/2 cents* Under the Treasury proposal for an increase in surtax: rates, not more-than 50 cents would ordinarily be taken out of each dollar of normal'profits, and the present 'figure of ,81 cents for excess profits would not be touched* 1/ The increase in surtax .proposed by bhe Treasury is less likely to impair financial incentives than would an increase m the excess—profits—tax rate* ,.TJfth; -corporate rates at their present levels, the impact on incentives cannot be. ignored- in making tax decisions* The Treasury, agrees^hat our corporations should be kept fin^a sound financial condition=so that, they may be able to convert to peacetime pro duction and provide employment- .for men leaving the armed forces after .he war*” 2/ But figures on corporate earnings, dividends, and-accumulations make it clear that added taxes can be levied without unduly..burdening profits and profit incentives, and without impairing^ the sound^financial condition of corporations generally* Corporate profits (excluding dividends received) vid.ll reach an estimated level ox ^ 2*6 billion or l9A3o This is more than four times the corporate profits for the year 1937 one of'the most prosperous years of the ...Thirties* Taxes have also risen sharply .during this period, both because of increases^in corpora e income and because of increases in rates* But they have failed to xeep pace .with earnings* In 1937 corporations had left less^tban 74 bxllion, after paying $1—1/4 billion of taxes* In 1943 corporations wil ave_ left nearly $9*2 billion, even after paying $13o5 billion of taxes* xn 1944. corporate profits after taxes at present rates are expected to reacn .$909 billion, or three times the average annual profits after taxes from 193^ through 1939> l/ 2/ C.orp orations with income between $25 <000 and $ 50,000 Will> of cours , be subject to higher-marginal surtax' rates as a result of t h e notch provision* See Fage 5, House Report No* 871 on the Revenue Bill of 1943o 15 - Figures on dividends and undistrp.but ed profits are also impressiveo^/ Average dividends f r o m '1936 to 1940 were' $4®1 billion, 1937 being the peak year, when $ 4*8 billion were distributed® 2/ In spite of war taxes, dividends for 1941, 1942, and 194-3 are estimated at $4..5 billion, $4*1 billion, and $4*0 billion, respectively*, It is estimated-that even after paying’taxes and dividends, American corporations will accumulate over $12 billion of undistributed profits for the three years 1941, 1942, and 1943 i Recent studies show that liquid assets of corporations have risen even faster than retained earnings©. Hon*financial corporations increased their holdings of currency, bank deposits, and United States Government securities by $12 billion during the two years 1941 and 1942 according to an estimate prepared by. the Securities and Exchange Commission© If •the accumulation of liquid assets in the first half of 1943 should continue at the present rate through the year, the total increase would be $25 billion for .the three years 1941, 1942, and 1943® 4 study just released by the Federal Reserve Board indicates that business deposits, both corporate and non—corporate, totalled $30 billion on July 31, 1943o It is recognized that the combined corporate and individual taxes on dividend income are higher in this country than in England and in Canada, and that steps must be taken after the war to relieve corporate stock holders of their disproportionate tax burden* However, so long as the war continues and corporations generally are able to maintain present abnormally high levels'" of earnings, the discrimination against this class of income recipient wi 11 continue to be more apparent than real* The taxation of the excessive .profits of corporation imposes no real burden on corporate stockholders® I have.indicated why the Treasury prefers to raise additional revenue by means of an increase in surtax rather than an increase in excess** profits tax* However, if your Committee should decide in favor of an increase in.the excess—profits—tax rate, the,Treasury suggests an upward revision of the 80 percent limitation on corporate taxes* Without this revision tlie increase in, oxcess-rprofits—' tax rates m i l reach only < a limited range of excess profits*2/ * 1/ y 2/ See Exhibit' 12 * Dividend payments in 1936 and 1937 are generally conceded to .have been abnormally high as a result of the undistributed profits tax in effect during those years* A revision of the 80 percent limitation will improve the relationship of net taxes payable by corporations not subject to the tax ceiling and those which are subject to the tax ceilingo In Appendix G to tills statement, there are outlined three alternative methods of revising the 80 percent limitation to gain these advantages, which would still prevent net corporate taxes from exceeding 80 percent of net income* -16 - oo ^ Changes in Excess-Profits Tax Exemptions and Credits under the House Bill The House Bill provides for an increase from. j>5',000 to $10,000 in the specific excess—profits—tax exemption© 1 / This provision,'Which was 'recommended by the Treasury last year, will'distribute the excessyprofitstax burden more equitably between large and small business enterprises© The profits of small business are likely to fluctuate more widely than profits of large business© Base—period earnings under the averagerearnings method are, therefore, a less reliable index of normal earnings for small business than for large© An increase in exemption tends to avoid a penalty on normal fluctuations and earnings without forcing a resort to the relief provisions of Section 7220 Moreover, profits of small business are more likely to reflect a rer turn-on managerial efforts than a return on invested capital© Consequently, the increased exemption-also aids small corporations using the invested capital base for determining excess profits© The. Treasury also agrees with the provisions reducing by one per— centage point the invested capital credit in each of the brackets above $5.million© Invested capital is generally used as a base for computing excess—profits credits only by those corporations which earned a low' rate of return during the base period© Where such earnings were abnormally low, corporations are protected by the remedy in Section 722 © But corporations the base—period earnings of Which were normally low should not be provided an escape from taxes on war— increased profits© Since a large invested— capital credit unrelated to base,—period earnings tends to provide such an escape, the proposed reduction will reduce an unfair ad vantage gained by large corporations having a history of low normal earnings© ¥he proposed reduction of the invested capital credit will also re duce the advantage gained by large corporations on borrowed capital© Be cause $0 percent of borrowed capital Is included in invested capital, corporations can get a tax advantage by borrowing at rates of interest below the percentages allowed on invested capital© The large corporation generally has a higher credit standing than the small and. therefore -gets • larger tax benefits from borrowing -than the small corporation© This ad vantage will be reduced by the reduction in percentage allowances on in— " vested capital© 2/ V 2/ See Page '57, House Report Ho© £71 on'the Revenue Bill of 19A3© An illustration of the effect of borroiving on net income after taxes of an excess-profits taxpayer using the invested—capita!! credit m i l be found in Exhibit 13© - XI ~ 3o Specific Relief Maasures in the House Bill The House Bill provides special tax treatment for certain mine owners and operatorso I f extends percentage depletion and excess—profits-tax exemption to several minerals as a means of stimulating their wartime production® In so far as these fall within the category, of strategic minerals designated by the War Production Board, the Treasury concurs with tax measures which will accelerate their output 0 But for minerals not so designated it is believed that the proposed treatment'if un warranted o A further statement on the Treasury positi:on is contained in Appendix Do ' ■ The Honse Bill also extends to the-natural gas industry the special excess-profits-tax treatment now granted with respbct to the accelerated output of depletable natural resources® w in so far as this treatment -is ••ext'Ghded'-to non—pkdducers of natural gas, this provision in .the House Bill appears to be undesirable® This p o i n t ,is further developed in ' . Appendix E© ;This appendix, also contains a statement of the Treasury • position with respect to the broadening of the excess-profits^tax relief for coal and iron miners and timber tracts® Tax relief measures can serve very useful purposes® But unless they are handled very carefully, they may simply become tax loopholes0. If tax relief is distributed without regard, to need, it deprives the Government of much needed revenue, and distributes tax burdens inequitably'among ■business enterprises® It must not be forgotten tha f reduction in the tax liabilities of especially favored taxpayers means increased tax burdens on all other taxpayers© 4-o Acquisitions to Avoid Income or Excess^Profits Tax At this point I would like to discu.ss one technical amendment which is of major importance © Section 115 of. the House Bill is intended to curb-the development of a public market in-Which alleged tax' benefits may be bought and soldo The currently, advertised schemes are .designed to enable a< taxpayer with large war profits to avoid income and excess— . profits taxes b y purchasing for such purpose a losing:or defunct corpora tion having large' current, .past, or prospective losses, deficits, or large current or unused profits credits®; The .utilization and advertisement of such-devices has disturbed responsible taxpayers and their'attorneys who have refused to use these schemes® It is also disturbing to the Government in its effort to administer the revenue layers equitably and uniformly® The amendment disallows the part of the deduction or credit involved in the tax avoidance device, but only if the acquisition of an interest inor control of a corporation or property has occurred on or after October B, 194-0, and then only if one of the principal purposes nfor which (the) -x-x-xacquisition was made or availed of is the avoidance of tax by securing the benefit of" such deduction or credito The amendment is directed solely 18 - at those devices which distort or pervert the natural business relationship between a deduction or credit'and the enterprise which produced it, and for the benefit of which the deduction or credit was provided by law0 The gist of the distortion is the circumstance that such natural relationship has in whole or in part ceased, and that a taxpayer seeks to use the deduction or credit as an offset to the profits of an enterprise to which the deduction or credit does not bear a reasonable business relationship* The amendment in no way abridges the privilege of doing business in indi vidual, partnership, or corporate form, or the privilege of filing a separate or a consolidated return, or any of the numerous choices which the structure of the tax system is intended to afford* But the amendment does operate whenever under ary of these privileges or choices such a dis tortion or perversion of a deduction or credit appears* Hence the scope of the amendment in its field is precisely the same as that of Sections 4.5 and l^l of the present law, where analogous distortions- or perversions have been frequently described, by tile Committee as nmilking" or shifting of deductions and credits0 The Treasury believes with the House that the amendment is a significant part of an equitable tax structure and that it is well adapted to accomplish.its purpose* E, Estate and Gift Taxes _ :: In seeking sources of. additional wartime revenue, we cannot afford to overlook estate and gift taxes* Increases in these taxes have not kept pace with tax increases generally* Small as' their.relative contri bution to the total has been in the. past, it has fallen during the. war0 Estate and gift tax collections for the fiscal' year 194-4 are expected to represent a smaller proportion of total tax receipts than at any time during the past 10 years 0 (See Exhibit 1 6 o) In a period when huge additional revenues are needed, the benefi ciaries of estates and gifts should contribute their full share to the cost, of the war along with other groups of taxpayers0; Yet, relatively few estates are subject to tax, and .rates in the lower and middle, brackets continue to be moderate* The Treasury has, therefore, recom mended that the estate tax exemption be reduced from $60,.000;.t o .$40,000 and that estate tax rates be raised* Corresponding increases in the gift tax are also suggested* For a comparison of rates and tax under the present law and the proposals, see Exhibits 1*4, 15 and 1 7 o ,These'. changes would add $4.00 million to our revenues on a full-year basis* . : >~19 - The proposed changes in the estate and gift tax provisions should be permanent, rather,-than simply for the duration of.the war© 1/ I should like to report to the- Committee that the Treasuiy is now making an extensive study of all phases of estate and gift taxation0 For example, w e .are investigating the possibility of integrating the estate and gift taxes and correlating them with the. inccane tax® An advisory committee, comprising some of the leading tax practitioners in the estate and gift tax field, is aiding us in this study® It is hoped that the study will lead to recommendations which will simplify these taxes and make them more effective and more equitable® It is anticipated that this study will be completed before the Congress considers the next tax bill* F. Excise Taxes ■ . :M The Treasury recommended that an additional #2*5 billion be raised through increases in the rates and changes in the base of several existing excise taxes and through the enactment .of ;two new excises0 (See Exhibit 18*) It further recommended that the tax on transportation of property be re pealed® In selecting specific items for heavier taxation and in setting the proposed -rates, the:'Treasuiy gave, careful consideration to the demand and supply conditions- in- affected•industries and to the impact on pro ducers and consumers® The M i l i o n excise,rtax.'recommendation was "de-, signed to be a part of a balanced overall program® Selected excises have much to commend them-'as a source of wartime revenue® They.involve little increase in administrative machinery and compliance costs® At the same time, in most cases the higher levies would be shifted to consumers, thus avoiding undue burdens on business concerns® Since only a few non-essentials are affected, and since the 1/ Two technical estate and gift tax provisions of the House Bill deserve comment,® As passed by the House, the bill contains an estate tax amendment which provides that in valuing stock or securities the value of which cannot be determined by reference to bid and asked prices or to sales prices by reason of the absence of listing for sales, there shall be Considered, i n addition to- all other factors, the value of stock or securities of comparable corporations which are listed on an exchange® It is believed that this amendment ‘is highly undesirable because it can only lead to continuous, unnecessary and costly litigation, and harbors dangerous potentialities for imposing-'unjust tax burdens upon the recipients of closely held stock® The House Bill also provides that in certain instances the appoint ment of a trustee, the vesting of discretion in a trustee as to the selection of beneficiaries or the distribution of benefits, or the exercise by,a trustee of such discretion shall not be deemed a taxable gift® This provision is completely divorced from aiy reasonable classi fication of, trusts and is enmeshed.in ambiguities which can only produce manifold administrative difficulties and increase the litigation burden of taxpayers® tax can be avoided or. reduced by cutting consumption of the taxed items, the excises will not-„ cause..hardship -for consumers0 Excise taxes are far. superior, to a sales tax0 They involve only a small fraction of the administrative and compliance effort demanded by a sales taXo Second, they bear pn non-essentials rather .than neces sities,) Third, they support rather than jeopardize the Governments program to stabilize the cost of livingo For an elaboration of the points just made, I should like to refer you to Appendix F e This appendix also compares the Treasury excise tax proposals with the House Bill provisions, analyzes those provisions, and indicates why it is desirable to terminate excise tax exemptions on sales to the Federal Government, as recommended by the President* ' p Go The Sales Tax The Treasury proposals do not include a general sales tax* like briefly to state the reasons for our decision,) I should The form of sales tax which wpuld prpduce the most revenue and cause the least rupturing of price ceilings is the retail sales tax* The highest rate I have heard mentioned is 10 per cento That is over three times as high as the rate now i n force in any State* A 10 per cent sales tax with no exemptions for necessities of life would raise at current sales levels about $S billion, or about onetenth of this year*s estimated deficit* Such a tax would be very harsh, especially on low income families with children* It is completely lacking in any relation to ability to pay because it hits families much harder than single individuals at the same income levels and it hits people with small incomes, much harder than people with larger ones0 Such a tax would be opposed to every principle of tax equity and would in iry opinion interfere with the war effort* There are many proponents of the sales tax who would agree with these criticisms and who propose to meet them by allowing exemptions of the necessities of life* Such exemptions would indeed improve the character of the tax, although they would still leave the discrimination against large families* However, the exemptions would -quickly remove so much of the tax base as to leave little more than an empty shello The exemption of food would reduce the yield by $2*4 billion^ the exemption of medicine would reduce the yield another $200 million$ the exemption of clothing would reduce the yield by another $1*1 billion* Those exemptions do not include all of the necessities of life,' but let us stop at that point* A sales tax with such exemptions would yield - 21 - about $2*6 billion® However, of that amount about $1*2 billion would come from goods and services already subject to Federal excise taxes0 The ta x yields from the sale of these commodities can'be; increased or decreased by adjusting.the excise-tax rates* No sales tax is needed to produce revenue from them* .All that is left after excluding such commodities, is $1*4 billion* Nearly.$600 pillion of the $1*4 billion would come'from equipment, chemicals, and•materials -used in business and thus entering*into^the costs of doing business with resultant & increases in t h e .costs 'of doing business arid in prices- to the Govern ment and to the public <> Most;of the remaining $800 million, tax.would be on items that ' might^ properly oe subject to sales taxation* It is hardly -necessary to point out that the expenses, to 2 .1/2 million businessmen and ./ increased costs to Government^ as well as the use of prqcious manpower would not be. justified by yields of this kind when-there-are-other methods of raising money at hand which- do not call for heavy increases in costs of administration and compliance* It is very doubtful whether,-a general sales tax, without the exemption of;necessities of life would really be helpful in' financing the war of. restraining inflationary price rises* The imposition of -■ a substantial sales tax would almost purely be the signal for wide— spread demands for-higher wages and f arm prices which, if allowed, *' would result in large additional costs to Government and increases in the cost o f living over and beyond the amount of the tax* These ' dangers are much greater in the sales tax than in excise taxes or income taxes* Excise taxes touch in only minor respects/.commodities: that are necessities of life, while income taxes have personal .exemptions which protect minimum living standands* ■ • .Personal exemptions could be introduced'into the sales tax, bub the inconvenience of distributing and using exemption coupons and-' the resultant reduction in revenue would be serious factors* Sven the most simple sales.tax would.require the use cf much precious manpower and machines.by Government and business* It is doubtful whether t h a t ‘man power and those, machines could be .secured without-interfering with the war effort*' H* Renegotiation of Contracts . * think the agencies principally-epneerned may wish to present their views on the renegotiation provisions of the: House Bill* - However, I should ike to' present the Treasury position on .one- of the renegotiation provi sions that vitally affects the revenue, system* I refer- to the provision permitting Aggrieved contractors to secure a; redetermination of excessive profits by tbp. Tax Court of the United...States. I think-it cannot be too strongly emphasized^that the choice of the Tax Court as a forum for re negotiation litigation is an unwise.one* For mary years it has been recognized that the volume and complexity of Federal tax cases require a specially qualified and skilled tribunal, such as the Tax Court, which - 22 shall devote its entire.time and efforts to their consideration and disposition* This need threatens to become even more pressing after the war* The inevitable accumulation of cases during the, war and tne „ development of many excess profits tax cases, particularly those arising under the general relief provisions of Section 722, make it obvious that the Tax Court faces a possible postwar crisis, without the addition of complex . .renegotiation-of^contracts issues to its calendar* The renegotiation statute is not a taxing statute, but this proposal would tend to-confuse renegotiation with taxes* It is also to be recog nized that renegotiation cases, under the terms of tne House ^amendments, will demand a large part of the time of any tribunal* Many issues m i l be presented, often difficult of proof* take 'for example the issue of •a large contractor*s efficiency or lack of it, which might occupy the Court.for weeks* It seems inevitable that few cases will be; susceptible of quick disposition* -^ It is my .very firm conviction'that--if the-trial of renegotiation cases is added to tbte task that will confront the"Tax; Court, the prompt collection of revenue w.ill .be impaired,-the rights of the Government and of taxpayers m i l be prejudiced, and'the deservedly high reputation of the Court may greatly suffer* Any. impairment of the reputation and efficiency of the' C o u r t :would 'constitute:a most';serious blow t o the proper administration of .the. tax law* . ... I* Conclusion V. . - This statement has dealt largely ,vdth:the technical aspects of the Treasury proposals and the House Bill® I believed that I could be of most assistance to the Committee■byConcentratingon these aspects of the pending ’bill* " X have given special emphasis to simplificiation because bf the crucial necessity of simplifying our tax laws * -•'Unnecessary complications can put our entire'wartime income tax.program i n jeopardy*• I hope that the Committee will not misunderstand my emphasis upon simplification and technical matters* Total.,war..'makes--broad-demands on our tax system* Present taxes' do not meet these, demands, .either^in terms of paying for t.he war as we go, or in terms -of combatting inflation* inG legacy of taxes at present levels will be not only a huge debt, but may also be a demoralized price structure.both during and after the war* m e growth of the public debt, and the imminence of inflati on, force the con clusion that the Treasury »s & Q * 5 billion .additional revenue goal is macn nearer the minimum.than the maximum demanded by total war* -• oOo ■ \ LIST OF EXHIBITS EXHIBIT I - - Estimated Increase of Treasury Proposals Over Yield of Present Law EXHIBIT 2 -- Estimated Tax Liability by Sources, Present Law and Proposals EXHIBIT 3 -- Comparison of Combined Normal and Surtax Rates Under Present Law, Treasury Proposal to Integrate Victory Tax, and House Bill EXHIBIT 4 ~ - Amounts of Individual Income Tax and Effective Rates Under Present Law, Treasury Proposal to Integrate Victory Tax, and House Bill Tables 1, 2, and 3 EXHIBIT 5 - - Comparison of Surtax Rates Under Present Law. and Proposal EXHIBIT 6 - - Amounts of- Individual Income Tax and Effective Rates Under Present Law. and Proposal Tables 1, 2, and 3 EXHIBIT 7 - - Chart: Individual Income Tax — - Comparison of Effective Rates for Married Person Without Dependents Under Present Law and Proposal EXHIBIT 8 - - Comparison of Surtax Rates Under Present Law, Treasury Proposal, and Two Alternative Schedules EXHIBIT 9 - ~ Amounts of Individual Income Tax Under Present Law, Treasury Proposal, and Two Alternative Schedules Tables 1, la, 2, 2a, 3 and 3a EXHIBIT 10 •— To be Supplied later EXHIBIT 11 -— Comparison of Present and Proposed Corporation Income and Excess Profits Tax Rates EXHIBIT 1 2 - — Corporate Net Income, Income Taxes and Dividends, 1936-1944 EXHIB.IT 13 *— The Effect of Borrowing on Net Income After Taxes of an Excess-Profits Taxpayer Using the Invested-Capital Credit EXHIBIT 14 >* — Comparison of Estate Tax Rates. Under Present Law and Proposal EXHIBIT 15 ■— Amounts of Estate Tax and Effective Rates Under Present Law and Proposal EXHIBIT 16 -— Estate and Gift Tax Collections as a Percent of Net Receipts EXHIBIT 17 -— Chart: Federal Estate Tax — for State Death Taxes Effective Rates Before Credit EXHIBIT 18 -— Comparison of Excise Tax Liability Under Treasury Proposal and Present Law __ Exhibit X Estimated increase of the revenue program of the Treasury presents^ to the Committee on Ways and Means of the House of Representatives on October h, "19^3♦ over the yield of the present law assuming a full year of operations at levels of income estimated for the calendar year 19 UU (In billions of dollars) : Increase ; over ; present Individual.income tax; Increase surtax rates; reduce the personal exemption of married couples and heads of families to $1*100 and reduce the dependent credit to $300; repeal the Victory tax and repeal the earned income credit f .............., f...,. ,...... * 6,53 Corporation income taxes; Increase surtax rates, the combined normal and surtax rate reaching a maximum of 50 percent as compared with the present maximum of ho percent on corporations with income in excess of $50,000 ,<•••• r. ... ....................... .......... .. rrf . lr1^ Estate and g^ft taxes; Increase estate tax rates, reduce specific exemption from $60,000 to $40*000, and increase gift tax rates to three-quarters of the new ana higher estate tax rates ., ?....... t..... * .^0 m Excise taxes ^........... f Total increase Treasury Department, Division of Research and Statistics. 1/ * ...... .*......» 2 .51 10 ,5s November 2 9 , 19^3 The net Victory tax after postwar credit, rather than the gross Victory tax, is contained in the yield of the present 2,aw, , Exhibit 2 Estimated tax liability under the Treasury proposal as presented to the Committee on fays and of the House of Representatives on October 4 . 1943. as compared with the tax liability under the present law for a full year of operation l/ (in millions of dollars) ; : Increase or Yield of ; Yield of : decrease (-) tax program : present law : over yield of ______________:________________ : present law General and special accounts 1. Internal revenue; (l) Income and excess profits taxes: Corporation: Income 2] Excess profits tax Declared value excess profits tax Total corporation (gross) Less postwar credit Total corporation (net) Individual; Net income tax (gross) Victory tax (gross) Less postwar credit Victory tax (net) Total individual Total income and excess profits taxes (2 ) Miscellaneous internal revenue: Capital stock, estate, and gift taxes: Capital stock tax Estate tax Gift tax Total capital stock, estate, and gift taxes Taxes on commodities and services: Liquor taxes: Distilled spirits (domestic and imported) (excise tax) Fermented malt liquors 2j Rectification tax 2j Vines (domestic and imported) (excise tax) 2( Special taxes in connection with liquor occupations Container stamps Floor stocks taxes All other Total liquor taxes Tobacco taxes; Cigarettes (small) 2[ Tobacco (chewing and smoking) Cigars (large) 2j Snuff Cigarette papery and tubes All other 2j Total tobacco taxes 5.872.7 10,888.8 105.6 16,867.1 1 .088.9 I 5 .77S.2 4 .734.6 10,888.8 105.6 15 .729.0 1.088.9 i4 ,64o.l 1,138.1 23.892.1 — — — 23 ,b92.1 14.105.5 5 .324-1 - 2.066.0 3 ,256.1 17 .3&3 .5 9.786.6 - 5.324.1 2.066.0 - 7 T238VT 6 ,528.5 39 .670.3 32.003.6 7.666.6 400.0 902.1 62.1 400.0 522.4 4 0.2 96£75 4oi.b 735-2 504.0 487.2 210.5 11.5 36.6 11.0 9 .| 61.1 -- im .2 2j 2j 1,222.4 714.5 11.5 97.7 11.0 H 1.6 2 ,066.7 892.8 Retailers* excise taxes: Jewelry, etc* Furs Toilet preparations Luggage , handbags, wallets, etc* Total retailers' excise taxes 99-5 31.7 21.9 -- 758-8 .1 .1 1 .463-2 977.9 485.2 25.0 19.0 25.0 19.0 7-5 4/ 51.6 7-5 4/ 5i7& 251.1 251.1 54.3 •9 3.5 54-3 •9 3-5 25.0 40.0 48.5 3.6 25.0 40.0 5-0 5.0 3-5 1.1 2.8 ii »9 10.5 -2.0 .8 190.0 177-0 45*0 7-0 1.3 — — — — | -— -— 48.5 3-6 — — -- 3.5 -- 1.1 2.8 11.9 10.5 5.0 2.0 1 — — - 5.0 _ — — 190.0 177.0 831.5 469-5 §S£o 256.5 89.2 38.2 167.3 54.8 51.4 $8 .4 331-9 93-0 Miscellaneous taxes: Telephone, telegraph, radio and cable facilities, leased wires, etc. Telephone bill Transportation of oil by pipe line Transportation of persons Transportation of property General admissions Cabarets, etc. Club dues and initiation fees Leases of safe deposit boxes Use of motor vehicles and boats Coconut and other vegetable oils processed 2j Oleomargarine, etc*, including special taxes and adulterated butter Sugar tax Coin-operated amusement and gaming devices Bowling alleys and billiard and pool tables All other, including repealed taxes 2 / Total miscellaneous taxes 379-7 371.3 40.0 67.7 6.2 — — 1-3 Manufacturers' excise taxes: Gasoline Lubricating oils Passenger automobiles and motorcycles Automobile trucks, busses and trailers Parts and accessories for automobiles Tires and inner tubes Electrical energy Electric, gas, and oil appliances Electric light bulbs Radio receiving sets, phonographs, phonograph records, and musical instruments Refrigerators, refrigerating apparatus and air-conditioners Business and store machines Photographic apparatus Matches Luggage 5/ Sporting,goods Firearms, shells, pistols and revolvers Candy and chewing gum Soft drinks Total manufacturers' excise taxes 1.138.1 1.6 1,309.9 1,264.1 85.O 13.2 Stamp taxes: Issues of securities, bond transfers, and deeds of conveyance Stock transfers Playing cards 2] Silver bullion sales or transfers Total stamp taxes 1,138.1 -s. — 86.4 35*0 58.4 494-3 15213 152.7 146.7 14.5 354-5 490-4 110.7 11.3 6.5 115.5 2.0 — 121.2 97.8 14.5 141.8 170.3 6/ 163-5 19.4 6.2 6.5 115.5 2.0 ..... 31.5 48.9 — 212.7 - 170.3 327.0 91.3 5.1 — — — 3-1 3-1 61.0 12.2 28.8 1.2 61.0 12.2 1.8 1.2 27.0 — 573-2 1 .511-1 ~ ~ W .6 Total taxes on commodities and services 6,420.4 3 .909-3 2,511.1 Total miscellaneous internal revenue 7 .784.6 4 .871.9 2,912.7 2 ,799.0 207.0 3 ,006.0 2 ,799.0 207.0 3 ,006.0 * 3,268.7 262.7 3.268.7 50,723.6 40.144.2 10 ,579-3 12.1 12.1 -- (3 ) Employment taxes: Employment by other than carriers: Federal Insurance Contributions Act Federal Unemployment Tax Act Total Taxes on carriers and their employees (Chap. Internal Revenue Code) Total employment taxes 9, — — Subchap, B of the Total internal revenue 2- Railroad unemployment insurance contributions 3* Customs 400.0 400.0 4- Miscellaneous receipts 581.0 581.0 51.716.7 41.137.3 Total yield, general and special accounts — 10 .579-3 Treasury Department, Division of Research and Statistics. Note: l/ 2/ 3/ /jj 5/ 6/ 2/ Figures are rounded and will not necessarily add to totals. Estimates of the yield of the tax program and of present law are at levels of income estimated for the calendar year 1944 * Collections for credit to trust funds are not included. These estimates are after allowances for drawbacks of $ 27*6 millions under the proposal and of $ 14*8 millions under present law. Less than $.03 million. The tax on luggage has been changed from a manufacturers' excise to a retailers' excise tax. Including the effects of H.R. 3338 , Public Law l80 , approved November 4 » 1943* Includes collections from taxes on narcotics; taxes wider the National Firearms Act; and the tax on hydraulic mining, all of which are effective currently. In addition includes collections from repealed taxes not reinstated by the Revenue Act of 1941 and collec tions from the following excise taxes repealed by the Revenue Act of 1942: Rubber articles, electric signs, optical equipment, and washing machines. Exhibit 3 Comparison of combined normal and surtax rates under present law, under the proposal to integrate the Victory tax, and under H.R.3587 l/ Surtax net income (in thousands) 2 0 4 2 4 6 8 6 8 - 10 ] Present law 2/ : Proposal to : integrate : Victory : tax 2/ H. R. 3687 19 22 26 30 34 22 25 29 33 37 23 26 30 33 37 38 42 46 49 ^52 41 45 49 52 55 41 46 50 53 56 22 20 22 26 26 - 32 32 - 38 44 38 55 58 61 64 67 58 61 64 67 71 59 62 65 68 72 44 50 50 - 60 70 60 70 - 80 80 - 90 69 72 75 78 81 74 77 80 84 87 75 78 81 84 87 83 85 87 88 90 92 93 94 90 92 93 94 mm - - «• 12 | 14 - 16 - 18 - 20 10 12 14 16 18 - a. - - 90' 100 150 Over - - 100 150 200 200 Treasury Department, Division of Tax Research November 29, 194-3 l/ The present exemptions of $500 for a single person, $1,200 for a married couple, and $350 for each dependent are retained in H. R. 3687, Under the proposed integration plan, they are $500, $1,100, and $300, respectively. The earned income credit is eliminated under both H. R. 3687 and the proposed integration plan. 2/ Includes 6 percent normal tax. However, under present law the earned income credit reduces the normal tax rate by 0.6 percent with respect to earned net income up to $14,000. 3/ Includes 10 percent normal tax. Exhibi t' H - Table- 1 ' .. Amounts of individual income tax and effective rates under present law, under the proposal to integrate the Victory tax and under H* R. 3687 Single person - no dependents Exemptions:; Present law - $500 Proposal - $500 Amounts of tax Effective ..rates ~ Net income ^Proposal Increase Increase Present Present Proposal r before Proposal to Proposal law., law, to H.E. personal HJU. including integrate to including Integra tel H.E. i' H.E. --to exemption net Victory Victory integrate . 3687 net Victory Victory : 3687 integrate : 3687 3687 tax tax 1f Vic tory tax 1/ Victory taxr ;/ l. " < tax •1 tax 22 $ 6 17 $ $ 600 & 23 $ ..8$ 1 .0$ 5 $ 5*W 3• 62 800 % .6-6 8.6 69 7.S 7 8.3 .9 *-5 8 1,000 107 110 10.7 11.0 115 11.5 .8 3 -.3 I5U 161 1 8 12.8 1,200 12.8 13 .5+ ...1 I53 *7 1,500 220 230 10 220 0 0 15+.7 1^.7 15.3 .7 1,700 265 261* 276 11 15.6 16.2 .6 15.5 - .1 322 -2 12 16.2 1,900 3O 8 310 lb . 3 .6 .1 16.9 0 3^5 12 2,000 16 .-7 16.5 .6 330 333 -3 1 7.3 kOl Uik 2,300 396 -.-2 X % k 18.0 -6 13 17.2 1*6© 2,500 me -6 17 .s 1*1*0 t k 17.6 18. 1* .6 - .2 16 3,000 19 . . 1 565 18.8 590 -9 19-7 -3 •5 ^,000 829 815 21 850 20 .1* 21.3 20.-7 -.1* .5 25 5,000 22.1 1 ,105 . 1,085 1,130 -20 21.7 22.6 -.5+ -3 10,000 1*8 12 27.3+ 27.8 28.0 .1 2,-783 2,735 2,795 -.5 -3-1* 1*2.6 10 ,-6Hi* 25,000 10 ,1*1*5 10,630 1*2.5 5+1.8 -.8 -199 -.1 50,000 28.,05g - 5O 8 56.1 56 .O 55 .-1 - 1.0 ~.l -73 27,550 27,985 21*5 100,000 69,665 69.7 69,910 69,270 .2 -.u . 69.9 69.3 -395 208,750 83.2 250,000 1 ,1*16 83.5 83.8 209,390 776 ,6 207,97^ •3 500,000 1*1+1,863 1*1*3,750 1*1*1*,3 90 88 .U 88.1* 88.9 1,887 2,527 A .5 * 1 ,000,000 899,500 2/ 913,750 900,000 2/ 1^,250 500 90..0 2/ 90.0 2/ 1 .1* 91.5+ Treasury Department, Division of Tax Research 1/ Maximum earned income assumed. For Victory tax purposes,.- gross income is assumed to he ten-ninths of net income... 2/ Taking into account maximum effective rate limitation of 90 percent. * Less than .0 5 percent. Exhibit 4 - Table 2 Amounts of individual income tax and effective rates under present law, under the proposal to integrate the Victory tax and under H. R. 3687 Married person - no dependents Exemptions: Net income before exemption - - $ 600 Amounts of tax ■rre sent Proposal 19.Wf H.R. ^ to including integrate 3687 net Victory Victory tax 1 f tax fp_J ._■— .— jj, 8 15 800 1,000 1,200 1,500 1*700 1,900 2,000 2,300 2*500 3,000 1+.000 5,000 10,000 25,000 50,000 100,000 250,000 506,000 1 ,000,000 1 21 79 123 — - — — * * 22 88 132 166 176 188 253 297 198 26U 308 3 9 2/ 2/ 15 w 69 115 l 6l 181+ 253 299 '1+05 1+18 1+11+ 61+7 668 665 89U 928 915 2 Ml 2,536 2.513 10,035 10,079 10,196 27,106 27 *1+60 27,075 68,531+ 68,730 69,280 206,858 208,186 208*732 Hi+3,186 Ui+3,732 i+i+o,7^7 899,000 2 / 913,186 900,000 3 / Present law and H.R. 3687 - $1,200 Untegration proposal - ipl,100 Effective rates Present: : Proposal: n increase -nropo sal » law, : to to : H.R. ^including iintegrate H.R. integrate 3687 : net Victory • Victory: 3^87 vlatory *_ _ I .tax X f t___tax » #tax j; • m ■ § - 1 .2# $ - 1 - 8 m 1.0 5 .1+# 2/ — -66 - 15 1-5 .9 2/ 1 - 6 1.8 1 .8 # 1 .3 w -10 9 1+.6 5.3 5*9 8 7.2 9 7*8 6.8 10 8.5 8.7 9-3 10 - 1+ 9*1+ 9.9 9*2 11 11 If 13 18 21 13.5 13.9 16.2 16.6 3^ 17*9 2I+.7 1+0.1 5^*2 18.3 25*1 U0 .3 21 1+6 1+1+ 31 ll+6 0 9 69 161 385 696 1,328 l, 87l> 2.H39 2,985 ii+,is6 1,000 11.0 11.9 68.6 82.7 88.1 89.9 1 / 11.5 12.3 5%*s 68.7 83.3 88.6 91.3 11.0 12.0 13.8 16.7 18.6 25.1+ 1+0.8 5U.9 69.3 8 3 .5 88.7 90.0 2 / : Increase :r roT)o sal : : to : : H.H. :integrate: 3687 : Victory : * ’tax *;: -.2j> -.2# -1.0 — .6 - .6 -1*5 .1 .6 .5 •5 *5 *5 .1+ .1+ .5 .1+ .5 .2 .1 .1 .5 .5 1 .1+ Treasury Department, Division of Tax Research November 29, 19I+3 1/ Maximum earned income assumed* Eor Victory tax purposes, gross income assumed to be ten-ninths of net income. 2 / Mini mujn t a x , 3 / Taking into account the maximum effective rate limitation ©f 90 percent. * Less than .05 percent. - .5 -♦7 -.5 - .3 - .2 0 .1 .3 .5 .7 .7 .6 .8 *7 .7 4 Exhibit 1+ - Table 3 Amounts of individual income tax and effective rates under present law, under the proposal to integrate the Victory tax, and under EL R. 3 ^ 7 H.R. 3687 - $ 1 ,200 , $350 posal ~ $ 1 ,100 , $300 exemptions; P.ff0* ti3tp. rat <=ts___ ___ * ____________ Increase •• * Amount of tax Net income: Present before i law personal : including exemption : net Victory tax 1/ Too" $ 800 1,000 1 ,2 0 0 1.500 1 ,70 0 1,900 2,000 2,300 2.500 3.0 0 0 1+,000 5.000 10,000 25.000 50.000 100,000 250r000 500,000 1 000,000 , 1/ 2/ 3/ * $ Proposal to integrate Victory tax c. Increase Proposal to H.R. integrate Victory 3687 tax H.R. 3687 1 $ 7 3 £/ 9 18 £/ l b U 20 29 35 1+2 58 116 159 267 1+85 $ 66 132 176 286 515 730 2,208 9r57>+ 26,392 67,803 206 ,0^2 *69*931 U1+ , 8 9 8 ,8 0 0 3 / 2l+ 2/ 30 2/ 765 2,291 9,713 26,662 68,190 207,622 1+1+2,622 912,622 Maximum earned income assumed. Minimum tax 92 * 138 253 1+86 7 I+6 2,277 9 ,76 2 26,935 68,650 208 ,071+ 1+1+3 ,07 !+ 900,000 2 / - 1. $ - U 11 ir 11 12 * 35 2 8 16 1? m 1 16 69 188 5^3 8I+7 2,032 3 ,1^3 1,200 .2$ .9 .9 1 . 1+ 1.7 1*9 2 .1 2 .2 2 .9 5*1 6 .1+ 8.9 1 2 .1 lU .6 2 2 .1 3 3 .3 52 .8 6 7.8 82.1+ 88.0 89.9 3 / .8 1.2 1 .1+ 2*3? 1 .6 3-3 5*7 7*0 1+.0 9*5 1 2 .9 15*3 22.9 38 .9 53*3 68.2 83.0 88 .5 91*3 Research, For Victory tax purposes, gross income is assumed to stive rate limitation of Less than .05 percent. '2R21+ - 21 - Ik 19 30 35 23 139 270 337 1,580 2,691 13,822 1 7 - 7 * lb - 20 - 29 Proposal t to : integrate:H.R. Victory : 3687 tax : ; Proposal : Present : to t law including : integrate: H.R* net Victory: Victory : 3687 : tax : tax l/ 30 percent. 1.7 2/ g g £/ 2/ 5*5 8 .1+ 12 .2 1 I+.9 22.8 1 . 1+ 1*7 1*9 2.1 .1 .1+ *7 *7 .6 .8 .7 .8 .6 39*0 53*9 .5 6 8 .7 8 3 .2 88.6 90.0 3 / .1+ .6 *5 l»l+ - *9 *1 .1 - *9 * *7 - .6 - .6 -1*3' -l.O .8 - - -5 * .3 .7 .8 1.1 .8 November 29, 19*+3 .8 .6 He EXHIBIT 5 Comparison of individual surtax rate schedule under present law and proposal 1/ Surtax net income (In thousands) 1 0 .5 1 1.5 2 -T r* -r -• Bracket rate : Present law ; : Total surtax cumulative Proposal ; Present law ; $ $ .5 1 1.5 2 4 13 % 13 13 13 16 21 % 24 27 30 35 130 195 260 580 $ 105 225 360 510 1,210 4 6 8 10 12 V T *T — 6 8 10 12 14 20 24 28 32 36 40 45 49 53 57 980 1,460 2,020 2,660 3,380 2,010 2,910 3,890 4,950 6,090 14 16 18 20 22 — 16 18 20 22 26 40 43 61 46 65 49 52 68 71 741 4,180 5,040 5,960 6,940 9,020 7,310 8,610 9,970 11,390 14,350 26 32 38 44 50 32 38 44 *fi ’ 5Q 60 55 58 61 63 66 77 79 81 83 85 12,320 15,800 19,460 23,240 29;840 18,970 23,710 28,570 33,550 42,050 60 •* 69 86 87 88 200 over 72 75 77 79 81 82 90 90 90 36,740 43,940 51,440 59,140 98,640 139,140 50,650 59,350 68,150 77,050 122,050 167,050 - 6 6 70 80 90 100 150 200 and — *— -r 70 ** 80 -»■ 90 — 100 150 Normal tax 89 Treasury Department, Division of Tax Research i/ 65 Proposal November 29, 1943 Under the proposal, the Victory tax and earned income credit are eliminated. The proposed exemptions are $500 for' a single person, $>1100 for a married couple, and $300 for each dependent; under present law, the exemptions are $500, $1200, and $350, respectively. v Exhibit 6 - Table 1 Amounts of individual income tax and effective rates under present law and proposal Single person - 1T0 dependents Exemptions: Present law - $500 Proposal - $500 Net income ________ Amounts of tax_____ r. before : present law, j ; personal : including net{Proposal;Increase : exemption ;Vjctory tax 1 /;______ 2/; 600 soo 900 1,000 1,100 1,200 $ 17 62 85 107 130 153 1,500 1,600 2k} 2,000 333 2,500 220 $& 2?. $ 81 108 165 195 10 19 23 28 35 42 285 318 75 135 65 117 446 630 6,000 829 1,105 1 ,401 835 1,2% 1,680 2,l4o 184 26l 4i6 575 739 8,000 10,000 2,052 2,783 3,135 4,215 5,670 7,265 1,083 1,432 1,868 2,297 10,800 14,710 36,105 59 »035 3.174 3,000 *+,000 5,000 12,500 15,000 20,000 25,000 50,000 75,000 100,000 500,000 x.000,000 5,000,000 571+ 3,802 4,968 7 ,62b 10,644 28.058 48,001 69,665 t o , 863 82,575 466,570 899,500 jl/ 946,570 4 ,t o . 500 1 / 4,786,570 4,066 8,047 11,034 12,910 24,707 47,070 287,070 treasury Department, Division of Tax Research :__________ Effective rates_______ : Present law, : ♦ ; including net{Proposal:Increase :Victory tax j\J~\______ 2/;_________ 2.8$ 7.8 9.4 10.7 11.8 12.8 14.7 15.2 16.7 17.8 19,1 20.7 22,1 23,4 25.7 -27.8 30.4 33.1 38.1 M $ 10,1 12.0 13.5 15.0 16.3 19.0 19.9 22.5 25,2 27*8 31.1 42.6 33.6 35-7 39.2 42.2 45.4 48.4 54.0 58,8 56,1 72,2 64.0 69*7 88.4 78.7 82.6 90,0 1 / 90.0 y 93.3 94.7 95-7 1.7* 2.4 2,6 2.8 3.2 3.5 %3 4.7 5.9 7,4 8.7 10,4 11.5 12.3 13,5 l4.3 i 4,9 15.3 15,9 16.3 16.1 14.7 12.9 4.9 4.7 5-7 November 29 , i/ Maximum earned income credit assumed. Victory tax net income assumed to be ten-ninths of net income. zJ. Victory tax and earned income credit eliminated, £i Taking into account maximum effective rate limitation of 90 percent. 19^3 Exhibit 6 - Table 2 Amounts of individual income tax and effective rates under present law and proposal Married person - No dependents Exemptions: $ ’" T' J-r-Amounts of tax : ctive rates * %f : Present law ; :Present law, • .T. : including net : Proposal: :Increase :i.neluding net :Proposal :Increase • : Victory tax l/: ~.... 2/:t 7'ictory tax 1/: 2/ 1,000 1,250 1,500 1,750 2,000 2,250 2,500 2,75© 3,000 4-,000 5,000 6,000 8,000 10,000 15 ,000.; 20,000 25,000 50,000 75,000 100,000 500,000 1,000,000 5,000,000 % O Net income before personal exemptions Present law - $1^200 Proposal 1,100 1 15 29 79 134188 242 297 351 405 647 894 1,173 1,780 2,467 4,533 7,100 10,035 27,075 46,955 68,584 $ $ ~X5 22 29 41" 108 180 255 335 417 504 594 999 1,409 1,864 2,829 3,885 46 67 93 120 153 189 352 515 6,867 10,356 14,230 35.;5711 58,477 82,005 440,747 465.994 899,000 2/ 945.994 4,499,000 2/4,785,994 13.5 691 19.6 22.3 24.7 2,334 30,2 35.5 8,496 11,522 13,421 25,247 46,994-, 286,994 3.2/ 7.2 10.3 12.3 14.9 16.7 18.3 19 .S 25.0 16.2 17.9 1,049 1,418 3,256 4,195 Treasury Department, Division of Tax Research 1 .5 % 2,3 5.3 7.7 9.4 10.8 11.9 12,8 40.1 54.2 62.6 68.6 ' SS.l 89.9 90.0 4.8 5.6 6.3 38.9 8.8 10.3 11.5 13.1 1 /l 0 J-4 45.8 15.6 51.3 16.3 16.8 17.0 15.4 13.4 5 .0 4.7 5.7 28.2 31.1 35.4 56.9 71.1 78.0 .82.0 93.2 94.6 2/ - 1 .5/ 1.0 1.9 2.6 3.4 4;i 9 5.7 November 29* 194-3 i/ Mo.xi.mum earned income credit assumed. Victory tax net income assumed to l ye ten-ninths of net incomd, J Vicoory Tax and earned income credit eliminated. 2/ Talcing into account maximum effective rate limitation of 90 percent. Exhibit 6 - table 3 Amounts of individual income tax and effective rates under present law and proposal Married person - two dependents Exemptions: Present law - |1200, Proposal - $1100, 1350 $300 Net income before personal exemption : Amounts of tax : Effective rates • Present law, ; . * ': Present law, • : including net:Proposal* Increase; including net :Proposal: Increase :Victory tax l/; 2/: •Victory tax 1/ 2/: f 27 39 $ 58 81 116 165 159 225 267 384 485 753 730 1,163 979 1,588 1,553 2,523 2,208 3,555 3,144 4,962 4,207 6,489 6,693 9,912 9,574 13,750 26,392 35,037 46,209 57,919 67,803 81,435 439,931 46®,418 898,800 3/ 945,418 4,498,800 V 4, 785,418 1,800 2,000 2,300 2,500 3,000 4,000 5,000 6,000 8,000 10,000 12,500 15,000 20,000 25,000 50,000 75,000 100,000 500,000 1,000,000 5,000,000 1 # - 12 23 49 66 117 268 433 609 970 1,347. 1,818 2,282 3,219 4,176 8,645 11,710 13,632 25,487 46,618 286,618 Treasury Department, Division of Tax Research 2.2$ 2.9 5.0 6.4 . 8.9 | 12.1 14.6 16.3 19.4 22,1 25.2 28.0 33.5 38.3 52. 8 61.6 67.8 88,0 89.9 3/ 90.0 V 1,5% 4.1 7.2 9.0 12.8 18.8 23.3 26.5 31.5 35.6 39.7 43.3 49.6 55•0 70.1 77,2 81.4 93.1 94.5 95.7 November 29, 1943 Maximum earned income credit assumed. Victory tax net income assumed to be ten-ninths of net income. 2/ Victory tax and earned income credit eliminated. V Taking into account maximum effective rate limitation of 90 percent. ]/ - .7% 1.2 2.1 2.6 3.9 6.7 8.7 10.2 12.1 13.5 14.5 15.2 16.1 16.7 17.3 15.6 13.6 5.1 4.7 5.7 Exhibit 7 IN D IV ID U A L IN CO M E TAX Effective Rates for M arried Person without Dependents * I n c lu d e s N e t V ic to r y Tax; n e t i n c o m e a s s u m e d t o b e 9 0 % o f g r o s s in c o m e . *Exemptions $500 - $1,100~ $300; and n e t Victory Tax ond earned income cre d it e/iminoted Office of the Secretary o f the Treasury Division o f Tax Research b -*s o -i ------ ----- -- ------------- ----- --- ................... - Exhibit 8 Comparison of surtax rates under present law, the Treasury Proposal of October h, 19^+3» and two alternative schedules l/ Surtax : net income : (In thousands) : $ 0 -* * •5 1,0 1,5 2 - •5 1.0 1*5 2 k k 6 8 10 12 6o 70 80 90 100 150 200 61 65 68 55 ^7 50 n 55 58 kk 61 63 50 - — - 70 80 90 100 150 200 and over Normal tax 2k 66 7h 77 79 81 83 58 60 62 6h 66 68 70 72 50 53 55 58 61 6h 66 69 85 69 86 72 75 77 79 87 90 76 78 80 82 8h 81 82 90 90 87 88 6 6 6 6 88 88 Treasury Department, Division of Tax Research 1/ 28 ho ^3 h6 32 38 60 26 28 32 36 h9 52 - 2k$ ho ho hh hh 20 22 26 - 25 28 ho h3 h6 h9 52 20 - - 22fo 2k ho h5 h9 53 57 16 18 - 21$ Treasury alternative proposal~B 31 36 — - : Treasury : alternative ; proposal-A 31 36 Ik 16 Treasury Proposal \ October h, ; 19^3 27 30 35 — — 26 32 38 hh 50 13 13 13 - 18 20 22 13 f 6 8 10 12 — lh 16 ] Present law 86 72 75 78 81 8h 87 November 29» 19^3 Under each of the proposals, the Victory tax and earned income credit are eliminated and the exemptions are $ 500 , $ 1 ,100 , and $300 . Exhibit -9 - .Table. 1 - .........“ ts of indi.idual T C l ^ S tertetive* schedules the Treasury proposal of Oet-^er h . Single person - no dependents Bxemptionsi Present law - $500 Proposals - $500 Increase Net income "before personal exemption- $ 500 600 Amounts of~tax Present law : * Treasury "•Treasary including m e t ::proposal ^Proposal Victory tax 1./rOct^U.. 10M •— -- - $ goo 900 1.000 1*100 1,200 1.500 1. bOO 2, -000 220 2'43 2.500 333 m 3 .0 0 0 57^ U,ooo 5.000 6.000 8.000 10,000 12.500 15.000 2 0 .0 0 0 25.000 50.000 75.000 106,000 >00,000 1 , 00,000 5 ,000 ,00c 27 17 62 85 107 130 153 829 1*105 81 108 135 165 195 285 US 450 630 235 1,2^5 1,680 i*Uoi 2,lU0 2.052 2r?S3 ^,135 3,802 U, 96g 7,626 10,6UU 28.052 u s,001 69,665 UUi ,863 899?500 2/ U,U 99,500 2 / U*215 5^ 70 7,265 _m,soo 710 36,105 59,035 -82,575 A U66,570 9^6,57® U, 786,570 $ :Treasury .-Treasury : Treasury*, :Proposal :proposal I proposal: A ; : B iOct>4,19^31 8U 10 19 112 23 lUO 28 171 35 U2 65 75 $ 28 202 310 3UU US0 665 875 1,295 295 329 U65 650 860 1,280 1*735 1,720 2,180 3.1*+5 U,170 5,^30 6,995 10,180 13,620 32,280 52,650 7^ 2 30 UUU,-205 909,205 U, 629,205 , 2,-195 3,115 U,095 5,3^5 6,670 9^25 12,Ul0 29,3^5 U8,650 69,770 UU3.235 913,235 U.673*235 I 90 101 18U 132 20U 261 286 U16 575 U£ll 117 739 l#083 l,U 32 I, 86s 2,297 3? 17^ U,o 66 8,oUj Treasury propo sal B 615 779 1,093 1,387 1,728 2,027 2,55^ 2,976 Ur222 II, 03** 12*930' U,6U9 U,565 2U,707 2,3**2 U7,070 287,070 129,705 9,705 lU? 219 301 U 66 630 79U 1,063 1,312 1*5^3 1,702 1,799 1,766 1,287 6U9 105 1,372 13,735 171*135. November 29, 19U3 . ten-ninths 01 asury Depart,. T.t, Division of Tax Research purposes, gross income is assumed to be .'laximuu earned net income assumed^ Por Victory tax into account Baxlmum effective jrate limitati on of 90 percent. Exhibit 9 - Table la Effective rates of individual income tax under present law, the Treasury proposal of October 4, 19^3» and. two alternative schedules Single person - no dependents ________________________ ________ Exemp tions: Present law - $500 Proposals - $500 Net income:_____ _____________Effective rates _____ ___________ ; Increase : Present law : Treasury : Treasury Treasury 1 Treasury ; Treasury before personal : in clu din g net : proposal : proposal proposal : proposal t proposal exemption :Victo!ry tax l / : 0 c t . 4 f 19^3 » B A A : 0c t . 4 , 1943: _ — _ — $ 500 6oo 2.8# *t.5# 5.0# 1.8$ 1.7 # ^.7# 7 .S goo 10 .1 10 .§ 2.8 2.4 11.3 9*4 12.0 12.4 900 2.6 3.0 13.3 1,000 10 .7 2 .g 14.0 15.0 13.5 3.3 1 1 .g 1*100 15.0 I6 .5 15 .5 3.2 3.7 1 2 .g 1,200 16.3 1 6 .s 17,6 4.1 3.5 1,500 14.7 19.0 20.7 5.0 19.7 4.3 2 1.5 15 .2 20.6 1,600 5.4 19.9 4.7 22.5 16 .7 2*000 24.0 6.6 23.3 5.9 25.2 2,500 26.6 26.0 7*4 8.2 17.8 2 7 .g 28.7 29.2 3,000 19*1 8.7 9*5 4,000 32.0 32.4 10.4 31.1 1 1 .3 20.7 2 2 .1 5,000 34.4 33-6 1 1 .5 12.3 3 U -7 23. 4 36.3 36.6 13.0 6,000 35*7 12.-3 8,000 39.2 38*9 25*7 13 .7 39.3 13.5 27 *g 42.2 10,000 14.3 4l . o h i .7 13*9 44.2 42.8 45.4 12,500 30. 4 14.9 l$ .g 15,000 46.6 48.4 44.5 15-3 33-1 13*5 12.8 20,000 54.0 38.1 47.1 50.9 15 .9 25,000 42.6 5H .5 49.6 16.3 5 8 .g 11.9 72.2 50,000 5 6 .1 64.6 58.7 1 6 .1 8.4 75,000 70.2 14 .7 64.0 64.9 6.2 78.7 100,000 82.6 69.8 12,-9 74.2 4.6 69.7 g g.6 500,000 gg.il 88,8 4*9 93*3 *5 9U .7 1,000,000 90.0 2/ 1.0 90.9 91.3 92.6 5,000,000 90.0 2/ 2.6 95.7 93. 5 _____ 5 -2_____ Treasury Department, Division of Tax Research November l/ 2/ : Treasury : propo sal : B 2.2# 3*5 3*9 4.3 H.7 5.1 6.0 6.3 7A 8,8 10.0 1 1 .7 12.6 13-2 13.3 1 3 .1 12.3 1 1 .3 9.0 7*1 2.6 .9 .1 •3 1.4 ___ 3-5_________ 29, 19^3 Maximum earned net income assumed. For Victory tax purposes, gross income is assumed to be ten-ninths of net income. Talcing into account maximum effective rate limitation of 90 percent. Exhibit 9 - Table 2 Amounts of individual income tax under present law, the Treasury proposal of Get. 4, 19^3 and two alternative schedules Married person - no dependents Exemptions* Present law - $1,200 Proposals - $1,100 Net income Present law before including personal * net Victory exemption tax l/ $ 1,100 1,200 1,500 1,600 $ h : t l IS 21 79 101 Amounts of tax Treasury •propo sal,r Treasury Oct. 4 , t proposal A 19^3 t - $ 27 233 264 1,900 2,000 2,500 3,000 166 1SS 225 255 4,000 647 5,000 6,000 8 ,000 10,000 12,500 15,000 20,000 25,000 50,000 894 75,000 100,000 500,000 1 ,000,000 ^'5,000,000 1,173 1,780 2,*67 3 .1*37 *+r533 7,100 10,035 27,075 U6,955 68,584 440,747 28 202 m 297 $ 112 1,800 405 - . 10S 135 195 U17 594 999 1,409 1,8 64 2,829 3,885 5,316 6,867 10,356 14,230 35,-571 58,1*77 82,005 465,994 899,000 2/ 945,994 4 ,499,000 2/ 4,785,99^ r Treasury £ proposal B i 4q - $18 30 120 150 7 33 39 - $18 Q J? 4l 49 214 246 51 59 58 67 70 80 278 67 120 189 352 515 691 1,01*9 76 90 149 223 446 613 1,028 1,448 1,#0U 2,851 3,858 5,200 6,632 9 ,78U 13,200 31,812 52,146 73,702 443,647 908,647 4 ,628,647 :Treasury ; proposal B - $18 6 29 3^ - $ Increase Treasury - proposal, r Treasury Oct. U, propo sal A I9U3 628 1.0U3 1,1*63 1,919 2,839 3,795 5 ,oi*5 6,352 9,089 12,044 1,418 1*879 2.331* 3^56 48,164 lj.,195 8,496 11,522 69,248 442,671 912,671 i*.672,671 13,421 25,21*7 46,994 286,994 28,913 134 208 381 551* 731 1*071 1,391 396 569 746 1,763 1,059 1,328 l,lo8 2,099 2 ,684- 1,819 1,989 3.165 2,009 1,838 1,209 >+,737 5,191 5,118 2,900 9 ,61*7 129,647 664 1,924 13,671 173,671 Treasury Department, Division of Tax Research November 29,. 19^3 if Maximum^ earned income assumed.. Victory tax net income assumed to be ten-ninths of net income. 2./ Taking into account maximum effective rate limitation of 90 nercent. Exhibit 9 - Table 2a Effective rates of individual income tax under present law, the Treasury proposal of Oct. 4, 1943, and two alternative schedules Married person - no dependents Exemptions;- Net income before personal exemption $ 1,100 1,200 1,500 1,600 Effective rates Present law including net Victory tax l/ 1 *6# 1.8 5-5 6,3 1,800 8.0 1,900 2,000 8.7 9.4 2-35i 7.2 8.4 10.8 11.8 12.8 11.9 3,000 13,5 4,000 16.2 19.8 25*0 5,000 6,000 8,000 10,000 12,500 15,000 17-9 28.2 19.6 22.3 24.7 31.1 35 .^ 25,000 50,000 75,ooo 100,000 5oorooo 1,000,000 5,000,000 27,5 30.2 35.5 4o.i 54.2 62.6 68.6 88.1 89-9 2/ 90.0 2/ Increase ; Treasury r : proposal,; Treasury ; Treasury ; CTct. 4, ; proposal A :proposal B : 19U 3 : _ — 2 , 5 0 0 20,000 Present law - $1,200 proposals - $1,100 16.7 38,9 42.5 45.8 51.8 56*9 71.1 78.0 62*0 93-2 94.6 95,7 2.3$ 7.5 8.8 1 1.2 12.3 13.2 1 7.2 20.4 25.7 29.0 Z - % 8v0 9,4 11.9 12.9 13-9 17.8 20.9 2fo.l 29-3 31*7 32.0 35.6 38.6 38.0 35-5 90.9 * 4o.4 42.3 45-4 48.2 57*8 64.2 69.5 88.5 91-3 92.6 93,5 41.6 44.2 48.9 52.8 63.6 69.5 73.7 88.7 Treasury Department, Division of Tax Research Treasury proposal, Treasury ; Treasury Oct. 4, proposal A rproposal B 19U 3 ; - 1 .6# 0.5 l«9 2.1 2.8 - 1 .6# 0.6 2.2 3.4 3,1 2.4 3.2 3,5 3,8 4.8 5-4 6.3 8.8 6.9 10.3 11.5 13.1 14.2 15.0 15.6 16.3 16.8 17.0 15 .U 13 .^ 5,0 '4.7 5-7 9-5 11.1 12.2 13.4 13,9 l4.l l4.o 13-4 12 .7 9-5 6.9 5-1 .6 1.0 2.6 - 1 .6 # 0*8 2.7 3,1 3-9 4.2 4.5 6.0 7-4 9,9 11.4 12.4 13.2 13*3 12*9 12.1 9,9 8.0 3-7 1.6 -7 .4 1.4 3*5 November 29, 1943 l/ Maximum earned income assumed. Victory tax net income assumed to be ten-ninths of net income. 2/ Taking into account maximum effective rate limitation of 90 percent. Exhibit 9 - Table 3 Amounts of individual income tax under present law, the Treasury proposal of Oct. 1, and two alternative schedules 19U3 , Married person - two dependents Exemptions: iNlet income before persona.! exemption $ 1,700 t : 1 : * Present law including net Victory tax l7 35 1,800 39 1,900 2,000 2,500 3,000 12 l,ooo 5,000 6,000 8,000 10,000 12,500 15,000 20,000 25,000 50,000 75,000 100,000 500,000 1,000,000 5,000,000 58 159 267 1*85 730 979 1,553 2,208 3.1W* >-,207 6,693 9,57>+ 26,392 Present law - $1 ,200, $350 Proposals - ’♦'1 ,100 , $300 Amount of tax :Treasury Treasury tproposal iOct. 1 , proposal A :■ l9>+3 $ 28 $ 27 56 5^ 81 8l 225 233 38l 397 . :Treasury ‘ .proposal B $ 30 60 753 1,163 1,523 776 1,196 1,628 90 216 ll 2 791 1,211 +1,61+3 2,523 3.555 3 ,5U 6 2,557. 2,563 1,962 >+,870 6,23l' 9*388 12,780 .... 6,189.. - 9,912 13.750 35.037 31V.31* 51,612 16,209 57.919 81,: >+35 1+65 ,Ul8 >+39,931 898,800 2/ 9 k % lis 1,198,800 2/ l+,785,Ul8 67,203 1 73,17>+ 113,089 908,089 « m -r. Treasury Department, Division of Tax Research 628,089 3, >+95 >+.7>+5 6,031+ 8.753 11,678 28,181 >+7,673 68,726 112,107 912,107 1+,672,107 Amount of increase : Treasury 1Treasury t Treasury £ proposal : Oct. 1, :proposal A proposal : 19>*7 ~$35 - $35 -$35 - 12 - 11 - 9 12 ll 18 26 32 23 66 7^ 87 ll 5 130 117 1 268 >♦ 33 609 970 1 .3>+7 1,818 2,282 3,219 >+,176 8,615 l l ,710 13,632 25, >+87 16,618 286,618 291 306 166 619 1,001 1 ,33 s 181 661 1,010 1,287 1,601 1,726 2,077 2.695 3,206 >+,952 5, >+33 5 .37 I 3,158 9,289 129,289 1,827 2,060 2,101 2,089 i ,->+69 923 2,176 13,307 173.307 November 29, 19I3 X./ Maximum earned income credit assumed. Victory tax net income assumed to be ten-ninths of net income. 2:/ Taking into account maximum effective rate limitation of 90 percent. »• V< AWUVVU pAV* J 176 145 ..............** X\ . 374 Exhibit 9 - Table 3a Effective rates of individual income tax under present law* the Treasury nroposal of Oct*. 9, 1993, and two alternative schedules Married person - two dependents Exemptions: Present law - $1*200, $350 Proposals - $1,100, $300 ~rp-rp Net income before personal exemntion 1 1 .T00 1 ,soo 1,900 2,000 2,500 3*000 Effective rates Present law including net Victory tax l/ 2.1$ 2.2 2.2 2*9 i.9 :8.9 9,000 5 »ooo 12.1 6,000 16.3 19.9 22.1 29.2 8,000 10,000 12,500 15,000 20,000 25,000 50,000 75,000 100,000 500,000 i9.6 28.0 33.5 38.3 52.8 61.6 67*8 88.0 89.9 2/ 90.0 2/ ; : : : Increase Treasury: proposal Treasury Oct. 9, : proposal A 19^3 1.5# 2.8 9.1 9.0 12.8 18.8 23>3 26.5 31*5 35.6 39.7 ^ 3 .3 99.-6 55*0 7011 77*2 81.9 93*1 9^* jT 95*7 Treasury proposal B : Treasury r proposal,; Treasury Oct. 9, : proposal A 19^3 - 1 .6$ 2-9 9.2 9*3 1.3,2 19.9 23.9 27*1 32,0 35,5 39*0 91.9 96.9 i,?5 3-2 9.5 9.8 1 3 .7 19*6 29 *,2 27.9 32.0 35*0 38.0 90.2 93.8 51.1 62.7 68.9 63.6 73.2 88.6 68.7 88*9 96.7 57*0 - 2.1$ *7 .6 1 .2 2.6 3*9 6.7 8*7 10.2 12.1 13*5 19.5 15.2 16.1 16.7 17*3 15*6 13*6 5.1 : : Treasury proposal B : - 2.1 $ .6 *7 U3 . 3.0 U.3 7*3 9*3 10.8 12,6 13.9 13.8 13.8 13*5 12.8 9*9 7.2 5*9 .6 *9 2.6 - 2 .1$ - *5 *9 1.6 3*5 9.8 7*7 9*6 11.1 12.6 12.9 12.8 12.2 10.3 8.9 9.-2 2.0 *9 .9 1*3 3.5 91.2 90.8 9.7 33.U 92.6 5*7 November 29 , 1993 Treasury Department, Division of Tax Research l/ Maximum earned income credit assumed. Victory tax net income assumed to be ten-ninths of net income. 2/ Taking into account maximum effective rate limitati on of 90 percent. 1,000,000 5 ,000,000 3 .35? Exhibit 11 Corporation income and excess profits tax rates Present law {Treasury proposal H.R, 3687 1 . Normal tax rates Normal tax net income Not over $25*000 first $5,000 Next 15,000 Next; 5,000 Over $25,000 to $50,000 (notch) 15 $ No change 17$ No change $U,250 plus of excess over $ 25,000 Over $50,000 2. Surtax rates Surtax net income Not over $25,000 Over $25,000 to $50,000 (notch) 100 $ 2,500 plus 22$ of excess over $25,000 Over $50,000 3- ^ l 6$ $3,5 0 0 plus 38$ | No of excess over ; change $25,000 26$ Combined normal and surtax rates Not over $ 25,000 25 Over $25,000 to $50,000 (notch) 5% 6$ Over $50,000 ko$ 50$ Excess nrofits tax rates treasury Department, Division of {Tax'Research $ 30p to 2 to 33 0 % No change No change November 29, 19^3 Exhibit 12 Corporate net income, income taxes and dividends, 1936 “ 1944 (in millions of dollars) t i Actual 1936 i 1937 t 1938 t :s 1999 : l94o Estimated 1^4Tl/ 1942 1943 j/s 1944 All returns 1. 2. 3* 4> 5- Compiled net profit .... .............. ........... ........... *........ .................................... Net operating loss deduction ................ .............................................................. Net income (line 1 minus line 2 ) ]§/• ........... ......................................... *........... ......... Dividends received 6/ ..... ................................. ................................................. Tax-exempt interest^/ ................. ......... .......... •••.............. .................... ............ o. Net income excluding dividends received and tax-exempt interest (line 3 minus line 4 minus line 5 ) 5 / ....... . Net income excluding dividends received (line 3 minus line 4 ) 5 /***’................. .................. . . Compiled net profit excluding dividends received (line 1 m inus line 4 ) ................. . 2 9. Income and excess p ro fits taxes: Income tax ................................................................................................. .................................. . 7 '.. rlO.11. 12. 13 . ........ Undistributed profits tax .... vTV .VTTTrrvr-.*.... ;rf-^. i.c^V.-'fv’Trrrr............ . . ................. Excess profits tax (after deduction of entire postwar credit) ............................................ Declared value excess profits tax .......................................... ............................... Total income and excess profits taxes .................... .............................................. 14 . 15 . Compiled net profit excluding dividends received, after taxes (line 8 minus line 13) ....................... Net dividends paid 9 / .......................................... ........ ................ *.................... lb. Compiled net profit or loss excluding dividends received, after taxes and net dividends paid (line 14 minus line 1 5 ) .... *.................. ............................................................. 17 . Net income excluding dividends received, after taxes (line 7 minus line 13) 5 / ........ ..................... l8. Net income or deficit excluding dividends received, after taxes and net dividends paid (line Y] minus 7.830 7.771 7.771 2 ,b77 724 4 .37o 5.094 5.094 7 .89o 2,682 741 4,407 5.148 5.148 1,025 145 — 22 1,191 ___ 1.057 176 3.903 .4.703 43 1,576 3.872 .. £.832___ 800* 3.903 960* 3.872 8oo* line 15) £/•••••............................................................ ........................ .......... 960* 4.131 4.131 1.791 732 7.178 9.348 7.178 123 9.225 2,021 it§o6 4 #50^ 5.272 5.272 1,608 2,340 2,340 1.216 854.. — — 6 ----- 860— -ee — l6 1.232 35Q____ 21,400 1.550 ’ l 30 6.421 7.204 2.23? 809 13.296 14,107 7.327 14.437 783 21,750 16,675 800 19.050 19.850 20,200 . , 2.144 ,-r -- 374 31 2,549 4,300 . — 7.350 3.357 64 7.166 8/ 100 11,750 8/ 26,100 500 25,600 1,60b 700 23,30c 24,000 24,500 24.100 600 23.500 1,500 800 21,200 22,000 22,600 4..wy) 4 ,700 |gjgj — 8,850 100 13.450 8 T -9,800 100 i4,6bo g/ 1,480 4.040 4.778 ._._3 i.8. 4i-, 4.068 7.271 4.463 8,450 4.100 9.150 3.222 710 2,808 4.350 5.150 5,800 1 .742* 199 9,900 4.100 4.000 4.040 4,655 6.941 8,100 8,550 9,400 199 587 2,478 4,000 4,550 5.300 6,725 9,028 11,406 22,550 25,300 600 6.725 9.028 l )779 18,316 33p 17.986 2 ,09 ^ 27,400 500 267900 1,400 500 1,480 1 .742* uae Returns with net income 1. 2. 34* 5* Compiled net profit ............... ................................................ ......................... Net operating loss deduction ............................ ....................................... ......... . Net income (line 1 minus line 2 ) .......................... .......... ........................... ............. Dividends received 6 ( ............-..... ............................. ................... ................ Tax-exempt interest j/ .......................................................................... *............ 0. Net income excluding dividends received and tax-exempt interest (line 3 minus line 4 minus line 5 ) .... * •• • 7 . Net income excluding dividends received (line 3 minus line 4 ) ...............*.......................... . o. Compiled net profit excluding dividends received (line 1 minus line 4 ) ...................................... 9. 10 . 11, 12. 13. Income and excess profits taxes: Income t a x ..................................... ........ ................................ .................. . Undistributed profits t a x ....................................... .......................................... Excess profits tax (after deduction of entire postwar c r e d i t ) ........................ ................... Declared value excess p r ofits-tax ............................................ .............. *............. Total income and excess profits taxes ................................. ................................. 14. Compiled net profit excluding dividends received, after taxes (line 8 minus line 13) ••»•»«................. Net dividends paid 2 / .... ...................................................... .............................. lb- Compiled net profit excluding dividends received, after taxes and net dividends paid (line 14 minus line 13 ) 15 . 17 . Net income excluding dividends received, after taxes (line 7 minus line 13) ............... *................ l8. Net income excluding dividends received, after taxes and net dividends paid (line 17 minus line 19) ..... .. 9.726 9,848 — 9.726 2,504 T7fW 9.848 2.515 419 ^915 1,625 W 420 123 1085 ^7946 350 50£_ 157391 22.200 1 ,35° 24.700 1.300 25,000 7)248 15.894 20,250 20,850 22,800 9.431 9.554 23.400 25.500 16,224 21,200 24,000 26,000 854 1,216 2.144 3.745 4,300 4.500 4.700 6 ---- 860 16 1,232 31 2.549 64 7.166 100 13.450 9,800 100 1 14,600 6,016 3,783 27133 7.005 4.036 2,969 9.058 4.426 7.222 7.222 7.334 7.334 5.100 5.100 1.023 145 1.057 22 43 1,276 1.191 — 176 6,031 6,058 4.240 4.675 1.356 4.794 3.155 l,2bd 1,08$ 6.031 6,058 4.240 1.356 1,264 1,085 1.955 171 2,018 16b 2,594 : i 8/ 100 11.750 8/ 9.450 y 10,550 4.000 11,400 4.000 4.632 5.450 6,650 7.400 9.950 10,900 6,900 1,200 200 .200 1,600 6,016 2,233 6,882 2,846 8,728 4,302 9.100 5,100 1.850 12b 300 2.058 169 299 2.525 1,641 146 307 2,094 1.787 800 200 200 1,200 1,000 37 1,824 100 1,100 6,050 Returns with no nel 1. 2. 3* Compiled net loss or deficit 2/ .......... *....... ..... ......... ........................................... . Dividends received 6/ .............................................................................. .......... Tax-exempt interest’j J ................... ............................. ................... *.................. 4. Deficit, excluding dividends received and tax-exempt interest (line 1 plus line 2 plus line 3 ) ............. 9. Deficit, excluding dividends received (line 1 plus line 2 ) ....................... ......... ............. •••* 236 2.364 2,128 322 2,507 3.072 2,186 2,760 6. Net dividends paid 2 / ............................ *........................................................... Deficit, excludii£ dividend# received after net dividends paid (line 3 plus line 6) 10/ ..... .............. 27 2.155 38 67 58 32 2,223 2,827 2,035 2,258 7« 166 312 17275 1.977 2,22b (*) l/ 2j Figures are rounded and will not necessarily add to totals. Source for years 1936- 1941 . Statistics of Income, Fart 2 . Compiled net loss or defioit. Preliminary figures. Estimates prepared in connection with the Statement by the President on the Summation of the 1944 Budget, released August 1, $ 43 . 2/ Compiled net profit (or loss) as defined in.Statistics of Income, equals compiled receipts which include dividends received and tax-exempt interest, minus compiled deductions, which exclude net operating loss deduction. 4/ The first year's net loss allowed to be carried over is for a taxable year beginning on or after January 1 , 1939: the first year in which this loss is allowed as a deduction is in a taxable year beginning on or after January 1 , 194O. 2 / Cumulation of this item for the years 1940-1944 would involve double counting of net operating loss dkluction; once in the year in which the net operating loss occurs, once in the year to which it is carried forward. 6/ Dividends froa domestic corporations subjeot to income taxation under the Federal tax law. This is tb amount used for computation of dividends received credit. j] Includes both partially and wholly tax-exempt interest. 0/ Excludes the effect of the carryback of net operating losses and the carryback of unused excess profit! credit. 9/ Dividends paid to stockholders other domestic corporations; includes cash end assets other than corporation'• own stock. 10/ 100 1,500 November Treasury Department, Division of Research and Statistics. Note: 1.400 D e ficit corporations are lia b le fo r only the ca p ita l stock tax which is included as a deduction in c.spiled net p ro fit or loee. 1.300 200 200 1.700 1,500 100 1,600 2% 1943* Exhibit 13 The effect of borrowing on net income after taxes of an excess-profits taxpayer using the invested-capital credit A corporation with an invested capital of $5,000,000 earns $500,000. It is, therefore, subject to the excess-profits tax which it computes by using the invested-capital credit. Assume that it borrows $100,000 at 3-percent interest and uses the funds for building up working capital, therefore, actually decreases its net profits before taxes by the amount of interest - $3,000. Yet, its net profits aJdter taxes are increased by this debt# The computation is as follows, Ignoring the specific excess profits' exemption of $5,000. s-profits tax Before borrowing After borrowing Net income before taxes and before interest deduction $500,000 $500,000 0 1,500 Net income before taxes 500,000 498,500 Excess-profits credit: $5,000,000 x 8 percent 400,000 400,000 0 3,500 400,000 100,000 403,500 95,000 81,000 76,950 $500,000 $500,000 3,000 Interest deduction (50 percent) $100,000 x 7 percent (50 percent) Total Taxable excess profits Excess-profits tax (81 percent) Normal-tax and surtax Net income before taxes and before interest deduction Interest deduction (100 percent) 0 Net income before taxes Income subject to excess—profits tax 500,000 Taxable normal profits Normal-tax and surtax (40 percent) 400,000 160,000 497,000 95,000 402,000 160,800 241,000 237,750 $259,000 $259,250 Total tax Net income after interest and taxes 100,000 The taxpayer, therefore, gained $250 after taxes, merely by borrowing and increasing working capital. This gain may be compared with the effect on n®t income after taxes if this taxpayer had used the average-earning credit. In this event, net income after taxes would have decreased by $570. The advantage to the corporation with the invested-capital credit is almost 1 percent of the loan EXHIBIT 14 Comparison of estate tax rate schedule under present law and proposal 1/ Net estate after specific exemption (000) 2/ | Ak r Not over il 5 10 1 5 — 10 15 20 15 30 20 * r 40 30 — 50 40 60 50 70 60 70 100 150 100 — 200 150 250 200 300 250 300 350 400 350 ** 450 400 — — 500 450 600 500 700 600 _ 800 700 900 BOO 1,000 ■900 1,250 1,000 1,500 1,250 2,000 1,500 2,000 T» 2,500 2,500 ** 3,000 4,000 3,000 5,000 4,000 5,000 ~r» 6,000 7,000 6,000 7,000 mmm 8,000 9,000 8,000 9,000 — 10,000 Over 10,000 . s ; : Bracket rate Present law 3 I 7 11 11 14 18 22 25 28 28 30 30 30 32 32 32 32 32 35 35 35-37 37 37 39 42 45 49 53 56-59 63 67 70 73 76 76 77 Total estate tax cumulative Present ; Proposal : : s Proposal : • • c cf O/o 8 12 16 20 24 28 31 34 37 40 43 45 40 51 54 57 60 63 66 69 72 75 78 79 80 80 80 80 80 80 80 80 80 80 80 $ 150 500 1,050 1,600 3,000 4,800 7,000 9,500 12,300 20,700 35,700 50,700 65,700 81,700 97,700 113,700 129,700 145,700 180,700 215,700 251,700 288,700 325,700 423,200 528,200 753,200 998,200 1,263,200 1,838,200 2,468,200 3,138,200 3-,838,200 4,568,200 5,328,200 6,088,200 Treasury Department, Division of Tax Research 1/ 2/ $ 250 650 1,250 2,050 4,050 6,450 9,250 12,350 15,750 26,850 46,850 68,350 90,850 114,850 140,350 167,350 195,850 225,850 288,850 354,850 423,850 495,850 570,850 765,850 963,350 1,363,350 1,763,350 2>163,350 2,963,350 3,763)350 4)563,350 5,363',350 6,163,350 6,963,350 7,763,350 do 1943 IQ/.d November 29, Before deduction of credit for State Death taxes# The specific exemption under present law is $60,000, under the proposal 340 ,000 * EXHIBIT 15 Amount of estate taxes and effective rates under present lav and proposal 1J Net estate Before specific exempt ion (000 ) 2 / $ 50 * ' i f ,v ; proposal * ♦ Present law $ 0 60 0 so 100 150 200 1+00 1,6 0 0 600 soo 1,000 2,000 M o o 6,000 10,000 20,000 1+0,000 100,000 ( Amount of tax $ 650 2.050 6 ,1+50 M o o 17,900 12,350 32.700 51,150 1 ^ 5 .7 5 0 9 M oo 159,700 229.700 303,500 726,200 1,802,800 3,093,000 6 ,01+2,600 13,7^2,000 29 ,11+2,000 7 5 .31+2,000 30,350 263,650 396,250 51+0,350 1,331,350 2.931,350 “+,531.350 7.731.350 15,731,350 31,731,350 79,731.350 ♦ * j • • increase in tax •Increase < ?Present Proposal! in effec law <tive rates 5 650 $ 2.050 “+,850 7,550 12,950 1 8 ,1+50 51,250 103,950 16 6 ,5 5 0 237,350 60 5.150 1,123,550 M 33.350 1,633,750 1 ,939,350 2 ,539,350 “+.339,350 Treasury Pepartment, Division of Tax Research 1/ 2/ Effective rate i <•> 2.0# l+*3 11.-9 l6.lt 23,6 26*6 28.7 30 .1+ 36.3 1+5.1 51.6 6o«l+ 68.7 72.9 75.3 1,3# 3.H sa 1 2 .1+ 20,6 2 5 .6 36.1+ “+3-9 1+9.5 5“+.l 66.6 73.3 75*5 77.3 73,7 79*3 79.7 ITpvowrber 39, 19 U 3 Before deduction of credit for State death taxes, The specific exemption under the present lav is $60,000, under the proposal $Uo,000* 1 ,3* 3.H 6a 7.6 8.6 9.2 12,3 17.3 20.8 23.7 30.3 23.2 23.9 1 6 .9 9.9 6,5 M EXffi'XI? 16 Estate and gift tax collections as a percent of net receipts Fiscal years 1 9 1 7 ~ ^ (Dollar amounts in millions) • t Fiscal ; year : * Estate tax 1913 6-1 97.5 m s 82.0 m i 1920 1921 1922 1923 192U 1925 1926 1927 192s 1929 1930 1931 1932 1933 1931* 1935 1936 1937 $ 15^.0 139 .h 126.7 103 .O 101 .h 116.0 100.3 60.1 61.9 6 U. 8 29.7 loh.o lUo.h 1939 3 3 2 .3 19^2 19^3 19UU 330.9 3 5 5 .2 3U0.3 U1U.5 511. s $ 6 .1 ^7-5 82.0 i§ *? 103.6 156*.0 - m if $ ; Tlotal estate ! Total estate l 3Sfet :and gift taxes l and * receipts : as $ of net 1 gift taxes j t receipts — 7.5 3.2 «* *T *r hg.l h 7 .h 1938 19^1 Gift tax *T 103.5 21S. 8 281.6: 362,2 1940 ? ; h.6 9.2 11*1 160.1 23.9 3^ -7 2 S.h 29.2 5 1 ,9 92.2 33.0 hh.g $ 1.129-3 3 , 66 h .6 5.152.3 6 ,69^.6 5.62U.9 ^, 109,1 u,007.1 U, 012.0 3.760.1 3 .962.8 h fl 29 .U 139 126.7 103.0 10^.9 119-2 100.3 60.1 61.9 6M U 8.1 U 7 J4 h,o^2f3 k,033-3 9.177-9 3 .I9O.O 2.005-7 2.079.7 -$4 l.JO 1*59 1.55 2 .7 b 3*39 3.16 2.57 2 .8 8 3,01 2.^3 1 .U9 if 53 1.55 1.51 2.36 1.65 3.63 3^*3 113.2 212.1 376-9 3 . U 5 .6 3 .600*5 M lM 3 0 5 .5 5.028.8 5-58 9.21 6.08 5.859.7 5 , l 6 h .8 7.12 6 .9s 5.367.1 6.68 &I6.9 360.7 360.1 ^07.1 ^32-5 7.607,2 5.35 3^36 Uii7.5 12.799.1 22 ,071.6 556.6 32.1^7.9 2.03 1 .U6 (est.) Treasury Departin cat, Divi sion of Tax Besearch Source: uQVemhcr 2 9 , ' 19^3 Annual Heport of the Secretary of the Treasury t 19^2 and S tat ernent of' the President on the Summation of the 19hh Budget* August 19^3* Exhibit 17 FEDERAL ESTATE TAX Effective Rates, Before Credit for State Death Taxes S p e c ific E x e m p t io n $ 6 0 ,0 0 0 * Specific Exemption $40,000 Exhibit 18 Estimated excise tax liability under the Treasury proposal as presented to the Committee on Ways and Means of the House of Hepesentatives on October 4, 19^3* as compared with present law for a full year of operation 1 / 1. Distilled spirits ...... $.6 B e e r ........ Wine ? (a) Still: Under l4 percent alcohol ..... 14 to 21 percent alcohol Over 21 percent alcohol ...... (b) Sparkling ....... (c) Other Cigarettes per gallon (drawback of $3*75 P er gallon on nonbev©rage alcohol). $10 per gallon (draw-back of $7 per gallon on nonbeverage alcohol). $7 per barrel ..... $10 per barrel •* •♦ 10 cents per gallon 50 40 cents per gallon $1 per gallon $1 per gallon 10 cents pep half pint ..... 5 cents x>er half pint $ 3.50 per thousand. $2 per gallon 20 cents per half pint ...... 10 cents per half nint ...... $5 per thousand ... Intended retail price. ‘Hot Over ever 5. Cigars 8 15 20 6. Chewing and smoking tobacco and snuff. 7. General admissions ..... 8. Cabarets ...... . 9. Club dues and initiation fees ................. 10. Bowling alleys, billiard parlors ia. Transportation of persons 12 . Communications t (a) Tf>ll service ..... (b) Telegraph, etc,: (1) Domestic *... (2) International (c) leased \/ires, etc* 13 . Local telephone service 14* .Jewelry 16 . Pur and fur-trimmed f' a r t i c l e s .... ....... Luggage, handbags, wallets, etc*.............. . lax per thousand 2* 4 Over 6 8 15 20 Hot over CentsCents — 3i 3t 5 5 7 7 9 9 17 $ 2.50 3.00 4.00 7.00 10.00 15.00 20,00 2/ $487.2 210.5 cents per gallon Intended retail price- Cents Cents — 24 4 b 15 . Proposed tax Present tax Article of service Estimated additional revenue from proposals (in millions)!/ 17 22 ..... 6l.l 371.3 Tax per thousand 67.7 $ 12.50 13.00 l4.oo 22 17.00 30.00 35.00 — 40.00 46.2 18 cents per pound $4 cents per pound I cent per 10 cents 5 percent of charge 3 cents per 10 cents 30 percent of charge 327.0 II percent of charge 2J percent of charge 5.1 $10 per alley ..... 20 percent of charge ) $10 per table ..... $20 per table ...... ) 10 percent of charge 20 percent of charge. 15 10 15 10 10 of of of of of percent percent percent percent percent •price 25 percent of charge 27,0 212.7 ...... d o .... . charge 20rpercent charge 10 percent charge 20 percent charge 15 percent retail 30 percent \ ..price - of of of of of ) ) charge) charge) charge) charge retail 91.3 .....do*.......t .... 25 percent of retail price 10 percent of manu- ....*&oT ...........•* facturers* sales price on luggage only. 3*15 48,9 167.3 53*4- 3^ Exhibit IB (Continued) Article or service Present tax 18. Soft drinks.......•>.* 10 percent of re tail price........ None...............f 19. Candy and Chewing gum. None........ . 17. Toilet preparations... Total additional revenue, items 1 to 19... 20. Less repeal of tax on transportation of property................ Total additional revenue, items 1 to 20 Treasury Department, Division of Research and Statistics* Proposed tax Estimated additional revenue from proposals (in millions) 1/ 25 percent of re51*4 tail price....... Bottled d r i n k % l cot per 177*0 each 5 cents of in tended retail price; the equivalent taxes of $1 per gallon on sirup and 25 cents per pound on carbonic acid gas used in un— bottled soft drinks. Articles intended to ’190.0 retail from 5 to 15 cents per bar or package, 1 cent per each 5 cents of in tended retail price; other items, the equivalent tax of 35 percent of manufac turers’ sales price. ........ ........... ... 2,681*4 ...................... - 170.3 2/ .............. ..... ..42,511.1 November 29, 1943 1/ Estimates of additional revenue are for a full year of operation at levels of business estimated for calendar year 1944. 2/ Estimated additional net revenue yield after allowance for increased drawback on nonbeverage alcohol of $12*8 millions. 2/ Including the effects of H# R* 3338, Public Law 180, approved November 4, 1943* Inevitably we shall experience much greater financial sacrifice than we have thus far. Taxation now, during the war, is the easiest way to make that sacrifice. In presenting our national fiscal problem to you, I have endeavored to perform the duty placed on the Secretary of the Treasury by law and tradition. I have endeavored to show you as objectively and as clearly as I can that a tax program of not less than $10,5 billion is needed to safeguard the financial and economic future of this country during the war and after the war. From every point or vies it is a minimum fiscal program in the light of the deficit, the accumulated debt, and the inflationary pressure. In view of all these facts, the House Bill, in my opinion, falls far short even of an attempt to meet our fiscal needs in a realistic or courageous way. Let us bear in mind that an essential part of fighting a war is paying for it in the right way at the right time. of war. There is no escape from the costs It is a great fallacy to suppose that we can fight history*s greatest war to save what we hold most dear without financial sacrifice. that we can pay much higher taxes; they do not In any degree affect our moral obligation to meet now all of the costs of the war that can be met by current taxation; and they do not affect In significant jdegree the serious inflationary dangers that face us for the balance of this fiscal year# the succeeding fiscal years as long as the war shall last, and In the postwar period* Our tax goal# as I pointed out to the Ways and Means Committee* was the amount that we believed could be fairly distributed without undue sacrifice and hardship. There is nothing in the new budget figures in our opinion to warrant reducing our goal below $10*5 billion of additional wartime taxes. If no one had * originally expected more than a $57 billion deficit for the fiscal year 191*1*, the amount would appear tremendous which it truly is. It is no less so because it represents a reduction from a previously estimated higher figure. $57 billion is equal to last year’s record deficit, and is almost three times the deficit of 191*2. ~ 15 ~ The Bureau of the Budget has just released estimates that total expenditures for the fiscal year 1941; y which ends next June will amount to $98 billion '/ ; instead of the last August. $106 billion in the estimate issued It is understood that this decrease In expenditures represents a combination of changes in the war program and a delay in reaching the production goals of some items. Revenues were estimated at s $1^1 billion instead of $58 billion. The over-all result of the revision is to reduce the previously ✓ ^ expected deficit from $68 billion to $5? billion for the fiscal year 19W+ - 12 That means we cannot significantly relax our spending. 1 am not In sympathy with any measures or any proposal to cut expenditures In any way that will make our total production anything less than an all-out effort. At the time 1 appeared before the lays and Means Committee, I said that KJille it may be possible, and I hope it is, to curtail some governmental expenditures, even that will not lessen our need for getting at this time all that the American people can possibly give us in additional taxation.* still my position. That Is 11 - Perhaps the most superficially plausible and therefore the most insidious argument I have recently heard Is that economy In governmental expenditures is a substitute for higher taxes. Economy Is always an Important objective and a tax bill makes It neither more nor less desirable. I am In complete and hearty sympathy with any measure that can be adopted to reduce governmental costs, to reduce even war costs so long as the reductions do not Impair our war effort. But If we are to fight the war to a speedy conclusion we cannot relax our fighting or our production for war. I think this would be a poor excuse to give to the returning soldier who will be interested to know what sacrifices we incurred at home to protect his future. In fact, however, $10.5 billion of additional taxes would have very important effects on the deficit, the debt, and the inflationary pressure, in its direct effects on spending, in the renewed assurance it would ' give that the elected and appointed representatives of the people take the problems of the public debt seriously, and in the sobering influence it would have on public understanding of the true cost of the war, a $10.5 billion increase in taxes would be immensely beneficial. 9 There are few indeed who have followed with care the developments of the recent past who are not concerned over the possible breakdown of the stabilization program. Higher wartime taxes obviously cannot meet the danger alone but they are necessary If It is to be met. I have also been told that some people have a defeatist attitude toward our fiscal problem. They argue that since the deficit is so large, the Government debt so huge, and the Inflationary possibilities of surplus Income and accumulated private savings so great, a few billion dollars more or less will not make a great deal of difference and that therefore we might as well avoid the unpopularity of imposing additional taxes. I have been told that the American people do not believe In the dangers of inflation. 1 cannot believe that Is true* but there may be a confusion of meaning. If by Inflation Is meant a situation where money becomes worthless, I agree that the danger now is not of that character. It is rather the danger of substantial and continuous and, at least In part, permanent rises in prices that would undermine standards of living, reduce the value of investments and impair the security we seek to achieve through savings and Insurance. Unfortunately, lack of belief In the But we cannot expect these controls to hold Indefinitely In the face of a continued large surplus of income over goods and a great accumulation of spendable liquid wartime savings. Day after day, the continuous pressure of spending power has been cracking our price controls a little here and a little there and threatens to produce a major breakdown. We are courting danger if we do not do all that is possible through the tax mechanism to strengthen the foundations of our stabilization program. — 6— If those who hold this surplus income try to spend It on consumer goods the inevitable result will be black markets, ruptured price ceilings, and substantial increases in the cost of living, followed by tremendous pressures for higher wages and farm prices, which will set in motion further forces in the spiral of Inflation. Up to this point spending has been held down and we have avoided disastrous price Increases. We have done this through a variety of measures. Price ceilings and rationing, wage and salary stabilization, and the taxes already Imposed have all had a restraining effect. The campaigns for the voluntary purchase of War Bonds with their emphasis on saving have been a strong Influence in curbing spending. The incomes of the American people are not only ample to pay much higher taxes. The spending power of these incomes is so great as to threaten rapid and burdensome increases in the cost of living. About half of American productive effort is going into war equipment and supplies for our armed forces. These products are not available for civilian consumption. Yet our people are being paid for all they produce. They thus have far more money to spend than there are I goods on which to spend it* In the fiscal year 19ii4 this surplus of Income over goods is expected to amount to about taxes. $56 billion after payment of personal It Is clear that we are not paying all the wartime taxes that we can and should pay. We are not now fighting an all-out war on the fiscal front. All the estimates of national income, by whomever made, bear eloquent testimony to the fact that the ability of the American people to pay increased taxes is far from being exhausted. In the fiscal year 1959 individuals had incomes, after personal taxes, of $65 % billion. In the fiscal year 19^4» it is estimated that individuals will have Incomes of / $126 billion, after allowance for all present taxes. That is, after paying taxes, incomes of people in the s United states will have almost doubled since 1959* If In this situation we pay in taxes any less than we can now afford to pay, we shall be unfair to those who must face the accumulated bill after the war has been fought and won. Ve shall be doing a particularly great injustice to the men who are fighting our battles on foreign the 10,000,000 soil. le snail not only be asking members of the armed forces to give the most Important years out of their lives to fight the war. fe shall also be requiring them as a large body of future taxpayers to pay in taxes after the war what we could and should have paid while they were fighting. — 2 *• The outstanding fact In our financial picture is the stupendous bill which this war will leave behind. On that point there can be no quibbling. We are accumulating debt at the rate of over $150 million a day. Last month (October, 1945) the Federal Government I spent $5.6 billion more than it collected in revenue. / In the fiscal year 19l|2 the deficit was $21 billion, in 1.945 It was $ 57'"billion, and in 191*4 it is expected to be $57"billion again. On the basis of any estimates we can now make, we foresee a public debt at the end of the present fiscal year of about $200 billion. On such a debt the interest charges alone will be close to $ v billion a year. As the war continues, the debt, the interest, and the problems of repayment will grow larger and larger. When I appeared before the lays and Means Committee of the House on October ij. to present the Administration’s suggestions for increased war taxes, I gave to that Committee as best I could a picture of the financial position of the nation and its wartime revenue needs. I stated that the fiscal situation required much heavier wartime taxation and that It was our opinion that the people could pay additional wartime taxes of at least $10.5 billion. The lays and Means committee and the House reached a different result and approved a bill increasing revenues by only $2 billion. In view of this wide difference on a matter so important to the present and future welfare of this nation, we have carefully reviewed the fiscal situation. I am appearing before you today to present our conclusions. Statement of Secretary Morgenthau before the Finance Committee of the United States Senate November 29, 1943. When I appeared before the Ways and Means Committee of the House on October 4 to present the Administrations sugges tions for increased war taxes, I gave to that Committee as best I could a picture of the financial position of the nation and its wartime revenue needs, I stated that the fiscal situ ation required much heavier wartime taxation and that it was our opinion that the people could pay additional wartime taxes of at least $10.5 billion. The Ways and Means Committee and the House reached a different result and approved a bill in* creasing revenues by only $2 billion. In view of this wide ■' difference on a matter so important to the present and future welfare of this nation, we have carefully reviewed the fiscal situation. I am appearing before you today to present our conclusions. The outstanding fact in our financial picture is the stupendous bill which this war will leave behind. On that point there can be no quibbling. We are accumulating debt at the rate of over $150 million a day. Last month (October, 1943) the Federal Government spent $5.6 billion more than it collected in revenue. In the fiscal year 1942 the deficit was $21 billion, in 1943 it was $57 billion, and in 1944 it is expected to be $57 again. On the basis of any estimates v/e can now make, we foresee a public debt at the end of the present fiscal year of about $200 billion. On such a debt the interest charges alone will be close to $4 billion a year. As the war continues, the debt, the interest, and the problems of repayment will grow larger and larger. In this situation if we pay in taxes any less than we can now afford to pay, we shall be unfair to those who must face the accumulated bill after the war has been fought and won. We shall be doing a particularly great injustice to the men who 39-71 - 2 - are fighting our battles on foreign soil. We shall not only be asking the 10,000,000 members of the armed forces to give the most important years^out of their lives to fight the war. We shall also be requiring them as a large body of future taxoayers to pay m taxes after the war what we could and should have paid while they were fighting. It is clear that we are not paying all the wartime taxes that we can and should pay. We are not now fighting an all-out war on the fiscal front. All the estimates of national income, by whomever made, bear eloquent testimony to the fact that the ability of the American people to pay increased taxes is far from being exhausted. In the fiscal year 1939 individuals had incomes, after personal taxes, of $65 billion. In the fiscal 1944, it is estimated that individuals will have incomes of $126 billion, after allowance for all present taxes. That is, after paying taxes, incomes of people in the United States will have almost doubled since 1939. The incomes of the American people are not only ample to pay much higher taxes. The spending power of these incomes is so great a s t o threaten rapid and burdensome increases in the cost of living. About half of American productive effort is going into war equipment and supplies for our armed forces. These products are not available for civilian consumption. Yet our people are being paid for all they produce. They thus have far more money to spend than there are goods on which to spend it. In the fiscal year 1944 this surplus of income over goods is expected to amount to about $36 billion after payment of personal taxes. If those who hold this surplus income try to spend it on consumer^goods the inevitable result will be black markets, ruptured price ceilings, and substantial increases in the cost of living, followed by tremendous pressures for higher wages and farm prices, which will set in motion further forces m the spiral of inflation. Up to this point spending has been held down and we have avoided disastrous price increases. We have done this through a variety of measures. Price ceilings and rationing, wage and salary stabilization, and the taxes already imposed have all had a restraining effect. The campaigns for the voluntary purchase of War Bonds with^their emphasis on saving have been a strong influence in curbing spending. - 3 But we cannot expect these controls to hold indefinitely in the face of a continued large surplus of income over goods and a great accumulation of spendable liquid wartime savings. Day after day, the continuous pressure of spending power has been cracking our price controls a little here and a little there and threatens to produce a major breakdown. We are courting danger if we do not do all that is possible through the tax mechanism to strengthen the foundations of our stabili zation program. I have been told that the American people do not believe in the dangers of inflation. I cannot believe that is true, but there may be a confusion of meaning. If by inflation is .meant a situation where money becomes worthless, I agree that the danger now is not of that character. It is rather the danger of substantial and continuous and, at least in part, permanent rises in prices that would undermine standards of living, reduce the value of investments and impair the security we seek to achieve through savings and insurance. Unfortunate ly, lack of belief in the danger of inflation does not remove that danger. There are few indeed who have followed with care the developments of the recent past who are not concerned over the possible breakdown of the stabilization program. Higher wartime taxes obviously cannot meet the danger alone but they are necessary if it is to be met. I have also been told that some people have a defeatist attitude toward our fiscal problem. They argue that since the deficit is so large, the Government debt so huge, and the infla tionary possibilities of surplus income and accumulated private savings so great, a few billion dollars more or less will not make a great deal of difference and that therefore we might as well avoid the unpopularity of imposing additional taxes. I think this would be a poor excuse to give to the returning soldier who will be interested to know what sacrifices we in curred at home to protect his future. In fact, however, $10.5 billion of additional taxes would have very important effects on the deficit, the debt, and the inflationary pressure. In its direct effects on spending, in the renewed assurance it would give that the elected and appointed representatives of the people take the problems of the public debt seriously, and in the sobering influence it would have on public understanding of the true cost of the war, a $10.5 billion increase In taxes would be immensely beneficial. - 4 Perhaps the most superficially plausible and therefore the most insidious argument I have recently heard is that economy in governmental expenditures is a substitute for higher taxes. Economy is always an important objective and a tax bill makes it neither more nor less desirable, I am in complete and hearty sympathy with any measure that can be adopted to reduce govern mental costs, to reduce even war costs so long as the reductions do not impair our- war effort. But if we are to fight the war to a speedy conclusion we cannot relax our fighting or our produc tion for war. That means we cannot significantly relax our spending. I am not in sympathy with any measures or any pro posal to cut expenditures in any way that will make our total production anything less than an all-out effort. At the time I appeared before the Ways and Means Committee, I said that 11while it may be possible, and I hope it is, to curtail some governmental expenditures, even that will not less en our need for getting at this time all that the American people can possibly give us in additional taxation.” That is still my position. The Bureau of the Budget has just released estimates that total expenditures for the fiscal year 1944 which ends next June 30 will amount to $98 billion instead of the $106 billion in the estimate issued last August. It is understood that this decrease in expenditures represents a combination of changes in the war program and a delay in reaching the production goals of some items. Revenues were estimated at $41 billion instead of $38 billion. The over-all result of the revision is to reduce the previously expected deficit from $68 billion to $57 billion for the fiscal year 1944. There is nothing in the new budget figures in our opinion to warrant reducing our goal below $10.5 billion of additional wartime taxes. If no one had originally expected more than a $57 billion deficit for the fiscal year 1944, the amount would appear tremendous, which it truly is. It is no less so because it represents a reduction from a previously estimated higher figure. $57 billion is equal to last year’s record deficit, and is almost three times the deficit of 1942. The budget revisions do not alter the fact that we can pay much higher taxes; they do not in any degree affect our moral obligation to meet now all of the costs of the war that can be met by current taxation; and they do not affect in significant - 5 degree the serious inflationary dangers that face us for the balance of this fiscal year, the succeeding fiscal years as long as the war shall last, and in the postwar period. Our tax goal, as I pointed out to the Ways and Means Committee, was the amount that we believed could be fairly distributed without undue sacrifice and hardship. From every point of view it is a minimum fiscal program in the light of the deficit, the accu mulated debt, and the inflationary pressure. In view of all these facts, the House Bill, in my opinion, falls far short even of an attempt to meet our fiscal needs in a realistic or courageous way. Let us bear in mind that an essential part of fighting a war is paying for it in the right way at the right time. There is no escape from the costs of war. It is a great fallacy to suppose that we can fight history’s greatest war to save what we hold most dear without financial sacrifice. Inevitably we shall experience much greater financial sacrifice than we have thus far. Taxation now, during the war, is the easiest way to make that sacrifice. In presenting our national fiscal problem to you, I have endeavored to perform the duty placed on the Secretary of the Treasury by law and tradition. I have endeavored to show you as objectively and as clearly as I can that a tax program of not less than $10.5 billion is needed to safeguard the financial and economic future of this country during the war and after the war. 0O 0 TREASURY DEPARTMENT Washington Press Service FOR RELEASE, MORNING NEWSPAPERS, Tuesday, November 30» 1943* <37-7 2- The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts,of 91-day Treasury bills to be dated December 2, 1943, and to mature March 2, 1944, which were offered on November 26, were opened at the Federal Reserve Banks on November 29. The details of this issue are as follows: Total applied for - $1,544,032,000 Total accepted - 1,006,307,OCX) Average price (includes $63,543,000 entered on a fixedprice basis at 99.905 and accepted in full) - 99.905^ Equivalent rate of discount approx. 0.3753* per annum Range of accepted competitive bids: High Low (Excepting one tender o f $10,000) - 99.925 Equivalent rate of discount approx* 0.297$ per annum - 99*905 " « * « « 0*376$ * " (61 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St* Louis Minneapolis Kansas City Dallas San Francisco * 17,705,000 1,144,478,000 29,945,000 42,798,000 14,191,000 19,180,000 148,838,000 17,785,000 5,140,000 17,857,000 8 ,445,000 77.670,000 ♦ $1,544,032,000 $1,006,307,000 TOTAL 15,053,000 690,244,000 20,234,000 37,565,000 11,578,000 18,818,000 109,542,000 14,431,000 5,062,000 17,038,000 8,182,000 58.560,000 TREASURY DEPARTMENT Washihgtbn'' Pre88 Sorvic# FOR RELEASE, UORK1KG H3SSPAPKRS, Tuesday, November 30. 1910. The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts,of 91-day Treasury bills to be dated December 2, 1943, and to mature March 2, 1944, which were offered on November 26, were opened at the Federal Reserve Banks on November 29. The details of this issue are as follows: Total applied for - $1,544,032,000 Total accepted - 1,006,307,000 Average price (includes $63,543,000 entered on a fixedprice basis at 99*905 and accepted in full) - 99.905/Equivalent rate of discount approx. 0.375$ per annum Range of accepted competitive bids: (Excepting one tender of $10,OCX)) - 99.925 Equivalent rate of discount approx. 0.297$ per annua - 99.905 * » • " * 0.376$ * * Hi*h Low (61 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco # 17,705,000 1,144,47B, 000 29,945,000 42,796,000 1 4 ,19 1,0 0 0 19,160,000 14 6 ,838,000 17,785,000 5,140,000 17,857,000 0,445,000 7 7 ,670,000 1 $1,544,032,000 $1,006,307,000 TOTAL 1 5 ,053,000 690,244,000 20 ,234,000 37,565,000 1 1 ,578,000 10,818,000 10 9 ,542,000 1 4 ,431,000 5 ,062,000 17,038,000 0 ,102,000 S8.560.0Qg TREASURY DEPARTMENT Washington' F O R R E L E A S E , M O R N I N G NEWSPAPERS', T u e s d a y , N o v e m b e r 30, 1 9 4 3 . The S e c r e t a r y of tenders bills the. T r e a s u r y a n n o u n c e d for $1,000,000,000, to b e which were or thereabouts, d a t e d D e c e m b e r 2, 1943, offered on November 26, serve B a n k s The Press No. on N o v e m b e r details of last evening Service 39-72 that the of 91-d a y T r e a s u r y and to m a t u r e M a r c h 2, were opened at the 1944, Federal Re 29. this issue are as follows: Total Total applied for - $1,544,032,000 accepted. 1,006,307,000 (includes $63,543,000 e n tered on a f i x e d - p r i c e basis at 9 9 . 9 0 5 a n d a c c e p t e d in full) Average price - 99*905 / E q u i v a l e n t rate of discount approx. 0.375$ per a n num Range of a c c e p t e d competitive bids: High - 99.925 Equivalent How - 99.905 (61 p e r c e n t of the amount bid Federal R e s e r v e Dis t r i c t n for at Total Applied Boston New Y o r k Philadelphia Cleveland Ric h m o n d Atlanta Chicago St, L o u i s Minneapolis Kansas C i t y Dallas San F r a n c i s c o $ TOTAL rate tf the for 17,705,000 1,144,478,000 29.945.000 42.798.000 14.191.000 19.180.000 148,838,000 17.785.000 5.140.000 17.857.000 8.445.000 77.670.000 $1,544,032,000 -oOo- (Excepting one tender of $10,000) of discount approx. 0,297$ per annum of d i scount approx, Q*376$ per annum low price was accepted) Total Accepted $ 15,053,000 690.244.000 20.234.000 37.565.000 11.578.000 18.818.000 109.542.000 14.431.000 5.062.000 17.038.000 8.182.000 58.560.000 $1,006,307,000 Tt'i-'1 1 FOB IMMEDIATE RELEASE, November SO. 1945,___ The Bureau of Customs announced today preliminary figures shoving the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1, 1943, provided for in the InterAmerican Coffee Agreement, proclaimed by the President on April 15, 1941, as follows: $ : S Quota Quantity I Authorized for entry $ (Pounds) 1/ ; for consumption ________ __________________;__ __________________ i As of (Date) : (Pounds) Country of Production Signatory Countries; Brazil Colombia Costa Rica Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela 1,353,1^480 458,336,340 29,100*720 11,640,288 17,460,432 21,825,540 87,302,160 77*844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 Non-signatory Countries; 51,653,778 1,/ Nov it ti H II H t! II ft It It It It 0 171,490,961 73,659,174 1,696,892 1,716,157 2,569,114 6,449,376 940,160 2,512,417 1,379,318 460,324 3,582,062 499,439 307,182 3,687,973 ft 1,991,001 20, 1943 Quotas as established by action of the Inter-American Coffee Board on March 11, 1943. -oOo- TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, Wednesday, December 1. 1943. Press Service 3 9 -73 The Bureau of Customs announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months conmencing October 1, 1943, provided for in the InterAmerican Coffee Agreement, proclaimed by the President on April 15, 1941, as follows: Country of Production ___ ... : : 1 Quota Quantity : (Pounds) 1/ ; * Authorized for entry for c o n s u m p t i o n ______ As of (Date) i (pounds) 1;353,183,480 458,336,340 29,100,720 11,640,288 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 Nov. 20, 1943 it ft n if it Signatory Countries: Braz il Colombia Costa Rica Cuba , Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela Non-signatory Countries: 1/ 51,653,778 11 it »» 11 it tr it »» n 171,490,961 73,659,174 1,696,892 1,716,157 2,569,114 6,449,376 940,160 2*512,417 1,379,318 460,324 3,582,062 499,439 307,182 3,687,973 1,991,001 Quotas as established by action of the Inter-American Goffee Board on March 11, 1943, - 0O 0- 1HMS8HT DSPAHMEBT Washington Press Seriice FOB IMMEDIATE RELEASE, Wodnsaday, Docaafoer X, 1943. 3 ?- 7 f The Secretary of the Treasury today announced the final subscription and i allotment figures with respect to the current offering of 7/8 percent Treasury Certificates of Indebtedness of Ssrlss 0*1944* Subscriptions and allotments were divided among the several Federal Re* serve Districts and the Treasury as follows s Total Subscriptions Received and Allots Federal Reserve t e M g i l ------ | 084,829,000 1,9X8,558,000 138,438,000 140,937,000 79,521,000 96,005,000 414,034,000 86,099,000 82,577,000 79,064,000 76,300,000 222,554,000 1.236.000 #3,520,152,000 Boston M M Tor* Philadelphia Cleveland Richmond Atlanta Chicago St* Louis Minneapolis Kansas City Dallas San Francisco Treasury TOTAL 0 (O & I* c TREASURY A P A R T M E N T Washington FOR IMMEDIATE RELEASE, Wednesday. December 1. 1943 Press Service No. 39-74 The Secretary of the Treasury today announced the final subscription and allotment figures with respect to the current offering of 7/8 percent Treasury Certificates of Indebtedness of Series G-1944* Subscriptions and allotments were divided among the several Federal Re serve Districts and the Treasury as follows: Federal Reserve District Total Subscriptions Received and Allotted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco Treasury TOTAL $ 184,829,000 1,918,558,000 138.438.000 140.937.000 79.521.000 . 96 005.000 414.034.000 86 ,099,000 82.577.000 79.064.000 76.300.000 222.554.000 1 .236.000 )3,520,152,000 oOo 5 New London, Connecticut.” Age matched the spirit of the California youngster’s contribution, in a letter from Kingston, New York, reading: ’’Enclosed please find a small contribution (five dollars). I am an elderly man inearly 77) who can have only temporary employment, but I want to help a little, if I can, and want no interest on anything I can do.” There was a heart throb, too, in a note from a Brooklyn woman: ’’Please accept the enclosed for the Treasury of the United States as a New Year token ($18.75) for the safe returi/of my son.” The names of four sergeants, four corporals, eleven privates first class and eleven privates were listed as contributors to platoon a fund of $40 which the Treasury received from a/GHsaspKHy of *\ Army Engineers, apparently on foreign service. This is a voluntary patriotic gesture to our fine Government,” wrote the sergeant who collected the fund. An unnamed officer of the company gave $8 of the $40, the sergeant said, and the enlisted men gave the rest. If a donation is made unconditionally, it goes into the general fund of the Treasury. If the donor specifies a particular use of his money, the amount is added to a Congressional appropriation covering such a purpose. Every contributor receives a Treasury acknowledgement. the Treasury Department. I am therefore enclosing herewith $100 as such.” A woman living in Brooklyn, N.Y., said: ”1 am enclosing $5 as a donation to our American soldiers on the fighting front who are giving their lives to protect our civilians.” The proprietor of a second-hand store in Seymour, Missouri, sent $25 with the explanation that the sum represented the proceeds of a pie supper at his place of business November 11. ”Please use this money to help whip Hitler and the Japs,” he added. Two recent remittances not only aided the war effort but also helped relieve the penny shortage. The postmaster at Oran, MiBBOuri, forwarded 149 pennies to the Treasury, reporting that a resident of Oran turned them in at the Post Office and asked that the Government make use of them. ”He wanted nothing in return,” the postmaster's message said. A woman's Bible class in Austin, Texas, at about the same time sent 1,503 pennies to be used for the purchase of oxygen for the Army Air Force. A nine-year-old of Sacramento, California, became a benefactor of the Coast Guard when he sent $20 with this letter: ”0n October 28 I will be 9 years old. My grandfather is giving me $20 for my birthday. Here it is. My birthday will be a very happy one if you will give this $20 to the Coa$fTGuard Academy at ‘3 "Some time ago I sent you one hundred and ten dollars. I am now sending you four defense bonds I purchased while in the Army. This will make up in full the money I received over $21 a month, which I feel is sufficient pay for a soldier. Use this money to purchase medical supplies for wounded soldiers." Hundreds of regular contributors began making weekly or monthly remittances in 1942 or 1943. One of these, an American oil company official stationed at Maracaibo, Venezuela, has had his hew York bank send the Treasury $416 each month for the last fourteen months, his total now being $5,824. Thirty-one checks totaling $4,650.48 have been received since March, 1942, from the proprietor of a souvenir store in Mexico City. The storekeeper explained in the beginning that he intended to remit 25 percent of each month’s sales by his store to American citizens, and would add $200 occasionally out of his own means. It is not unusual for a regular contributor to regard his writers or her donation schedule as a definite pledge. Letter^ now and then apologize to the Treasury for failure to remit "on time." Most of the expressions accompanying the gifts are brief but heartfelt, such as this recent one from a Dayton, Ohio, resident: "Because of the many blessings received from the goodness of this country, I felt that I should make a gift to General Dwight D. Eisenhower, Allied ^ ommander/-in-chief in North Africa-Sicily-Italy, has just joined the list of contributors. General Eisenhower received a $25 war bond as a gift from a Philadelphia admirer, and forwarded it to the adjutant general of the War Department at Washington with a memorandum stating: "I request that you deliver this to the United States Treasury with the request that proceeds be used to further the war effort.’1 In the same mail was another $25 war bond which Private Gilbert M. Tuoni, member of an Army boat company on duty at an eastern port of embarkation, said he was presenting to the Treasury "as my modest contribution toward our victory." There have been many other gifts from military or near-military sources. A Missourian who felt that he was overpaid for the time he spent in the Army recently squared his account in accordance with that view. Writing from St. Louis, he said: "Being an ex-soldier, having served seven months in the U.S. Army, I feel that fifty dollars and up a month is too much money to pay a soldier, especially one in training. W9mx«xmm* TREASURY D EPARBIENT Washington K E RELEASE,MORNING NEWSPAPERS Sunday, December 5 , 1943 Press Service No. 3 9 - 7 5 1275743 In the two years since the Japanese attacked Pearl Harbor, men, women and children have donated to the Government for war purposes a total of $ 3 , f ^ a freasury report revealed today. Hie cash gifts, in amounts ranging upward from one cent, came from almost as wide a variety of persons as could he found in the returns from a Federal census. Seme of the contributors not only made their donations hut also paid taxes and bought bonds in large amounts; sane sent their gifts because they had no taxes to pay; some donated their money instead of buying bonds or war savings stamps because they "wanted nothing in return." • . Thousands of letters, all warm with simply-phrased love of country, -have accompanied the contributions. The letters are filed in the Treasury's Division of Bookkeeping and Warrants, and it is not a mere figure of speech to say that in the rooms where the files are kept, the wartime beat of the American heart can be heard. TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS Sunday, December 5, 1943 12/2/43 Press Service No. 39-75 In the two years since the Japanese attacked pearl Harbor, approximately 40,000 men, women and children have donated to the Government.for war purposes a total of $5,106,989*44, a Treasury report revealed today. The cash gifts, in amounts ranging upward from one cent* came from almost as wide a variety of persons as could be found in the returns from a Federal census. Some of the contributors not only made their donations but also paid taxes and bought bonds in large amounts; some sent their gifts because they had no taxes to pay; some dohated their money instead of buying bonds or war savings stamps because they ’’wanted nothing in return.” Thousands of letters, all warm with simply-phrased love of country, have accompanied the contributions. The letters are filed in the Treasury’s Divi sion of Bookkeeping and Warrants, and it is not a mere figure of speech to say that in the rooms where the files are kept, the wartime beatof the American heart can be heard. General Dwight D. Eisenhower, Allied cammander-in-chief in North AfricaSicily-Italy, has just joined the list of contributors. General Eisenhower received a $25 war bond as a gift from a Philadelphia admirer, and forwarded it to the adjutant general of the War Department at Washington with a memo randum stating: ”1 request that you deliver this to the United States Treasury with the request that proceeds be used to further the war effort.” In the same mail was another $25 war bond which privateGilbert M. Tuoni, member of an Army boat company on duty at an eastern port of embarkation, said he was presenting to the Treasury ”as my modest contribution toward our victory. There have been many other gifts from military or near-military sources. A Missourian who felt that he was overpaid for the time he spent in the Army recently squared his account in accordance with that view. Writing from St. Louis, he said* ’’Being an ex-soldier, having served seven months in the U. S. Army, I feel that fifty dollars and up a month is too much money to pay a soldier, especially one in training. ’’Some time ago I sent you one hundred and ten dollars. I am now sending you four defense bonds I purchased while in the Army. This will make up in full the money I received over $21 a month, which I feel is sufficient pay for a soldier. Use this money to purchase medical supplies for wounded soldiers.” Hundreds of regular contributors began making weekly or monthly remittances in 1942 or 1943. One of these, an American oil company official stationed at Maracaibo, Venezuela, has had his New York bank send the Treasury $416 each month for the last fourteen months, his total now being $5,824. Thirty-one checks totaling $4,650.48 have been received since March, 1942, from the proprietor of a souvenir store in Mexico City, The storekeeper explained in the beginning that he intended to remit 25 percent of each month’s sales by his store to American citizens, and would add $200 occasionally out of his own means• It is not unusual for a regular contributor to regard his or her donation schedule as a definite pledge. Letter writers now and then apologize to the Treasury for failure to remit "on time." Most of the expressions accompanying the gifts are such as this recent one from a Dayfcon, Ohio, resident: blessings received from the goodness of this country, I make a gift to the Treasury Department. I am therefore $100 as such." brief but heartfelt, "Because of the many felt that I should enclosing herewith A woman living in Brooklyn, N. Y., said: "I am enclosing $5 as a donation to our American soldiers on the fighting front who are giving their lives to protect our civilians." The proprietor of a second-hand store in Seymour, Missouri, sent $25 with the explanation that the sum represented the proceeds of a pie supper at his place of business November 11. "Please use this money to help whip Hitler and the Japs," he added. Two recent remittances not only aided the war effort but also helped relieve the penny shortage. The postmaster at Oran, Missouri, forwarded 149 pennies to the Treasury, reporting that a resident of Oran turned them in at the Post-Office and asked that the Government make use of them. "He wanted nothing in return," the postmaster's message said. A woman’s Bible class in Austin, Texas, at about the same time sent 1,503 pennies to be used for the purchase of oxygen for the Army Air Force. A nine-year*i*old of Sacramento, California, became a benefactor of the Coast Guard when he sent $20 with this letter; "On October 28 I will be 9 years old, My grandfather is giving me $20 for my birthday. Here it is. My birthday will be a very happy'one if you will give this $20 to the Coast Guard Academy at New London, Connecticut." Ago matched the spirit of the California youngster’s contribution, in a letter from Kingston, New York, reading; "Enclosed please find a small contri bution (five dollars). I am an elderly man (nearly 77) who can have only temporary employment, but I want to help a little, if I can, and want no interest on anything I can do." There was a heart throb, too, in a note from a Brooklyn woman: "Please accept the enclosed for the Treasury of the United States as a New Year token ($18.75) for the safe return of my son." 3 The names of four sergeants, four corporals, eleven privates first class and eleven privates were listed as contributors to a fund of $>40 which the Treasury received from a platoon of Army Engineers, apparently on foreign service. ’’This is a voluntary patriotic gesture to our fine Government,” wrote the sergeant who collected the fund. An unnamed officer of the company gave $>8 of the $40, the sergeant said, and the enlisted men gave the rest. If a donation is made unconditionally, it goes into the general fund of the Treasury. If the donor specifies a particular use of his money, the amount is added to a Congressional appropriation covering such a purpose. Every contributor receives a Treasury acknowledgment. oOo / ( M S P ; 0ft for such bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made, as ordinary gain or loss. Treasury Department Circular Ho. 418, as amended, and this notice, pre scribe the terms of the Treasury bills and govern the conditions of their issue. Copies of the circular may be obtained from any Federal Reserve Bank or Branch. - 2 - Reserve Banks and Branches, following which public announcement will be made by the Secretary of the Treasury of the amount and orice range of accepted bids. Those submitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury exoressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final. Subject to these reservations, tenders for $100,000 or less from any one bidder at 99.905 entered on a fixed-phioe basis will be'accepted in full. Payment of accepted tenders at the prices offered must be made or completed at the Federal Reserve Bank in cash or other immediately available funds on - December 9. 1943 £ 2^. ; The income derived from Treasury bills, whether interest or gain from the sale or other disposition of the bills, shall not have any exemption, as such, and loss from the sale or other disposition of Treasury bills shall not have any special treatment, as such, under Federal tax Acts now or hereafter enacted. The bills shall be subject to estate, inheritance, gift, or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority. For purposes of taxation the amount of discount at which Treasury bills are originally sold by the United States shall be considered to be interest. Under Sections 42 and 117 (a) (l) of the Internal Revenue Code, as amended by Section 115 of the Revenue Act of 1941, the amount of discount at which bills issued hereunder are sold shall not be considered to accrue until such bills shall be-sold, redeemed or otherwise disposed of, and such bills are excluded from consideration as capital assets. Accordingly, the. owner of Treasury bills (o^her than life insurance companies) issued hereunder need include in his income tax return only the difference, between the price paid / & M k TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Friday. December 3. 1943______ * £5 The Secretary of the Treasury, by this public notice, invites tenders for $ 1,000.000.000 , or thereabouts, of „ 2 J _ -day Treasury bills, to be issued fii" ,lt & T on a discount basis under competitive and fixed-price bidding as hereinafter pro vided. The bills of this series will be dated March 9. 1944 mature interest. December 9. 1943 . and will , when the face amount will be payable without They will be issued in bearer form only, and in denominations of $1,000, $5,000, $10,000, $100,000, $500,000, and $1,000,000 (maturity value). Tenders will be received at Federal Reserve Banks and Branches up to the Monday. December 6. 1943___ • Tenders will not be received at the Treasury Department, Washington. Each tender closing hour, two o Tclock p. m . , Eastern War time, must be for an even multiple of $1,000, and the price offered must be expressed on the basis of 100, with not more than three decimals, e. g., 99.925. may not be used. Fractions It is urged that tenders be made on the printed forms and for warded in the special envelopes which will be supplied by Federal Reserve Banks or Branches on application therefor. ' Tenders will be received without deposit from incorporated banks and trust companies and from responsible and recognized dealers in investment securi ties. Tenders from others must be accompanied by payment of 2 percent ef the face amount of Treasury bills applied for, unless the tenders are accompanied by an express guaranty of payment by an incorporated bank or trust company. > Immediately after the closing hour, tenders will be opened at the Federal TREASURY DEPART M I T Washington POR RELEASE* MORNING NEWSPAPERS, Friday, December 3, 1943«______ 15 2-43 - The Secretary of the Treasury, by this .public notice* invites tenders for §!,•0 0 0 ,0 0 0 ,0 0 0 * or thereabouts, of 9 1 -day Treasury bills* to be issued, on a', discount basis under compet itive and fixed-price bidding as hereinafter provided. The bills of this series, will be dated December 9, 1943, and will mature March. 9, 1944, when the face amount will be payable without interest. They will" be issued in bearer form only, and in denominations of $>1 ,0 0 0 , $5 ,0 0 0 , $1 0 ,0 0 0 , $1 0 0 ,0 0 0 , $5 0 0 ,0 0 0 , and $1 ,0 0 0 , 0 0 0 (maturity' value). Tenders will be received at Federal Reserve Banks and Branches up to the closing hour, two o’clock p. m., Eastern War time, Monday, December 6 , 1943* Tenders will not be re ceived at the Treasury Department, Washington. Each tender must be for an even multiple.of $1 ,0 0 0 , and the price offered must be expressed on the basis or 1 0 0 , with not more than three decimals, e. g., 9 9 .9 2 5 . Fractions may not be used. It is urged that, tenders be made.on the printed forms and forwarded in the special envelopes;which will be supplied by Federal Reserve Banks or Branches on application therefor. Tenders will be received without deposit from incorpo rated banks and trust companies and from responsible and recognized dealers in investment securities. Tenders from others must be accompanied .by payment of .2 percent' of the face amount of Treasury bills applied for,.unless the tenders are accompanied by an express guaranty of payment by an in corporated bank or trust company. Immediately after‘the'-closing hour, tenders will be opened at the Federal Reserve Banks and Branches, following which public announcement will be made by the Secretary of the Treasury of the amount and price range of accepted bids. Those submitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury ex pressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final, Subject to these reservations, 39-76 (Over) 2 tenders for $j>100,GOQ or less from any one bidder at 99*905 entered on a fixed-price basis will be accepted in full. Pay ment of accepted tenders at the prices offered must be made or completed at the Federal Reserve Bank in cash or other immedi ately available funds on December-9, 1943i. : The income derived from Treasury bills* whether interest or gain from the sale or other disposition of the bills, shall not have any exemption, as such, and loss from the sale or other disposition of Treasury bills shall not have any special treatment, as such, under Federal tax'Acta-now or hereafter enacted. The bills shall be subject to estate, inheritance, gift, or other excise taxes, whether Federal or State, but. shall be exempt from all taxation now or hereafter imposed on the principal or interest'thereof by any State, or any of the possessions of the United States, or by any local taxing authority. For purposes of taxation the amount of discount at which Treasury bills are originally sold by the United States shall be considered to be interest. Under Sections-42 and 117 (a) (1) of the Internal Revenue Code, as amended by Section 115 of the^Revenue Act,of 1941* the amount of discount at which bills issued.hereunder are sold shall not be considered to accrue until such bills shall be sold, redeemed or otherwise disposed of, and such bills are excluded from consideration as ■capital assets. Accordingly, the owner of Treasury bills (other than life insurance companies) issued hereunder need include in his income tax return only the difference between the price paid for such bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made, as ordinary gain or loss* Treasury Department Circular ITo. 418, as .amended, and this notice, prescribe the terms of the Treasury bills and'govern the conditions of their issue. Copies of the circular may be obtained from any Federal Reserve Bank or Branch. oOo- «- 7 r In both drives a minimum of from t■vro and one-half to seven times as many people personally solicited bought bonds compared to those who •were not personally solicited* What is more, it was precisely in the non-urban market that the greatest increases in bond buying were evidenced as a result of personal solicitation.., It is clear that we have not reached the point of diminishing returns insofar as personal solicitation is concerned. That is the area of opportunity we are more fully cultivating. But to do so effectively unnecessary hazards and obstacles must not be placed in our path. To us, at the War Finance Division, this means one thing, above all, at the present time — that S. 1457 should not be enacted. - 0O 0- - 4 ..Some sponsors of: S. 1457 have charged that the Government is in directly paying the cost of .War.Bond advertising inasmuch as the individuals engaged in such advertising are permitted as a- practical matter to charge the cost/1 of the advertising as a part of the cost of operating the business* fiitvt |. 8 . . . . . This is a dangerous half-truth* What those who favor Government paid advertising fail to point out is that the very same firms; who are sponsoring War Bond advertising today would be" advertising their own products rather than War Bonds if 3. 1457 were enacted. And what they fail to mention also is that advertising expenses incurred irithe promotion of commercial products or a trade name is likewise deductible as a legitimate cost of operating a business. The great merit of voluntary sponsored advertising has been its ability to induce many advertisers to replace straight commercial copy with War Bond copy. Surveys of the Second and Third War Loan Drives indicate pretty clearly where the areas for real improvement in our War Bond campaigns really lie. It is not primarily in advertising - rural or otherwise. And in saying this I want to emphasize as strongly as I know how that no group in' our national life has made a greater; contribution to the success of the War Finance program than the rural.?press of this nation. Ffom its raided has developed the rural advertising offensive of which we at the Treasury are so proud. From its ranks•have been recruited many of our greatest leaders. In- its columns, our messages have found thrilling expression and the most faithful support,, The militant volunteer support that we have received from this field is in the finest traditions of the free press. It is because of the truly American, volunteer support that w e have, received in such great measure from the nation*s rural press that we are so reluctant to have the relationship disturbed. According to the surveys we have made, the real areas for impr ove— ment in coming War Bond Drives lie, not in advertising, but in utiliz ing more fully the opportunities for personal solicitation. Every in vestigation that we have made and every report we receive from the field underline again and again the importance of searching •out Mr. John Q. Citizen at his home, approaching him at the factory bench, calling on him at his office, seeking, him out, if necessary, in- the fieldo This we have begun to dof During the Third Drive, both in urban and rural areas, solicitors, reached more than twice 'as many people as in the April Drive. Of more importance, while the solicita tion campaign reached many more people than before, the effectiveness of solicitation remained uh dimini shed* - 5 - It was also contended before the Senate Committee that War Bond advertising copy is not of proper quality# The advertising released to daily and weekly newspapers by the Treasury Department is written by leading advertising agencies whose outstanding ability is recognized by commercial advertisers and the advertising fraternity generally. The best advertising brains in America*, specialists in framing appeals to all strata of the population', are Available to the Treasury Depart ment, without charge, through the facilities of the War Advertising^ Council - the very people who would have to be consulted, and paid, if S. 1457 Were enacted into Taw* An argument levelled against the present voluntary sponsored pro gram is that the Treasury* is spending a very large sum of money in the preparation of mats and materials which are sent to all newspapers in the United States and which are not being used. Government paid advertising, it is claimed, will eliminate this waste. This charge is completely unjustified, since all Treasury mats and materials, with what we consider to be only unavoidable exceptions, are distributed only on request. r It has been stated, also, that the nsme of the Government should appear in,War Bond advertising. Advertisements now released by the Treasury Department already include the statement nThis advertisement prepared under the auspices of the U. S. Treasury Department and the War Advertising Council”, thereby signifying its official nature. It is regrettable that the Canadian experience has been drawn upon to justify Government sponsored advertising. I have tie greatest admiration for the Canadian war effort and nothing that I say is intended as a reflection upon it. I do believe, however, that while there are many lessons in the Canadian experience we might profitably take to heart, there are many pointers too that they might profitably pick up from us. There is no warrant for the inference that "the high productivity of the Canadian paid advertising plan in volume of sale s to individuals and at l o w cost attest to the feasibility of the Government using its own resources and controlling its official messages1*. It may well be true, as the Committee Report asserts, that in Canada "all the press advertising amounts to four and one—half hundredths of one percent of the amount of bonds sold". But we repeat again what we said in another connection *— <- there simply is no evidence whatsoever that advertising, and advertising alone, is responsible for the notable War Bond record, either of the Canadians or of ourselves, to date. Furthermore, to declare, as does the Report, that "paid Government advertisements must be used to persuade earlier buyers to retain these Bonds" and, thus, cut down the number of redemptions, is to show a lack of understanding of the Canadian experience. The redemption of Canadian War Savings Certificates and the resale of their Victory Loan Bonos to the banks are proceeding at a rate considerably higher than in the United States. _ an awareness in the minds of the public as to the .desirability of a given product. That, voluntary sponsored advertising has done In greater measure than -we ever had reason to expect. Surveys conducted for the Treasury indicate that from 84 to 90 percent of the-American public, in urban and rural regions, are aware of War Bonds and War Bond Drives# What is more, these suryeys indicate an ever-growing awareness of War Bonds and War Bond. Drives* And the growth in awareness is greatest precisely in those rural areas that, the sponsors of S. 1457 declare are most in need of Government paid advertising# In the Second War Loan Drive 67 percent of all those living in*rural areas knew of the drive; in the Third War Loan, this awareness figure had jumped to 84 percent, A recent study of Bond buying during the Third War Loan Drive in dicates, moreover, that there was no difference whatsoever in the per centage of the .non-farm population that bought extra Bonds in counties with a town of *10,000 or over as, compared with the percentage of the non-farm population that bought esetra Bonds in counties without a town of 10,000# In both types, of co^dniti^s precisely the same proportion of the people bought extra.War Bonds r-r 39 percent to be exact. And since the income of people in counties with no large towns is lower, it appears that they were more e$-equately covered by the Drive as many of them bought extra Bonds in, spite of their lower incomef Of equal interest in this connection, the advertising appearing in weekly newspapers — and the weeklies, for the most part, circulate in the smaller towns and cities — increased in Vfilue from $1,201,000 in the Second w ar Loan Drive to $1,942,000 in the Third War Loan# There .was' also an increase in the number of separate advertisements run — from 33,164 in the Second War Loan Drive to 63,846 in the Third. This is'a striking refutation to the claim b y various witnesses before the Senate Committee of ”the growing resistance to locally sponsored Bond advertising in smaller communities”# It would be erroneous to infer that the striking results achieved in counties with towns of population of 10,000 or less were produced by advertising in weeklies alone, and we draw no such inference# We.do not imagine that these smaller communities are closed off from,the rest of America — that radio wave lengths stop at county boundaries -- that farm and other magazines do not regularly go into these areas — that newspapers published in larger cities are not read in the smaller com munities — that these areas have been stripped of all the bill-boards which carried War Bond messages in the Third War Loan Drive — • that theaters viere suddenly nailed up in these areas, m th all their War Bond trailers and patriotic posters# N o / ’we d o n ’t imagine any of these things any more than we believe that, the 67,976,376 lines — the-equivalent of about 40,000 pages — of Third War Loan advertising printed in weekly newspapers was not read. But the report of the Senate Banking and Cur rency Committee declared thats”the heavy barrage of eye appeals is seldom, if ever, seen by 52$ of our population residing in the smaller cities, towms and rural regions#” * nThe question of paid advertising presents a serious problem for the Government* The value of such advertising cannot be doubted, and if the operation could be 'governed by the same considerations as those which de termine the action of private enterprises, it would be much simplified* A private en terprise may advertise in a selected number of mediums most useful for its purpose with out any limitation except its own desires or ability to pay, If the Government engages in such a campaign, it must advertise in every newspaper and periodical in America without discrimination* All must have equal treatment, and should have equal treatment* The Government mu at be thoroughly democratic and impartial in a matter of' this sort* To make the advertisement thorough and effective, it should be done on a broad and liberal scale* The cost of .such ah undertaking vould be very great and would exceed the appropriation which the Congress has thus far made available for the sale of Liberty Bohds*n The development, since the Liberty Loan days, of radio broadcast ing and the motion picture only give added force to this reasoning of Secretary McAdop* So much by way of general remarks on the proposed legislation* I come now to the arguments advanced in favor of Senate Bill 14-57* The sponsors of the measure take the position.that Government paid advertising will evoke a sustained demand for Government securities on the part of all citizens even though the advertising would- be permit ted in weekly, semiweekly and triweekly newspapers wherever-published, but as to daily newspapers would be limited to those published in cities, towns, villages, townships and communities of 10,000 population ’ or less, We of the War Finance Division do not share this view* While we have a healthy respect for advertising learned from intimate association With the industry and from experience in the War Bond Drives, we also have a pretty fair idea of what may legitimately be expected from advertising, and what may not* There is no exact, automatic cause — effect relationship between advertising and the sale of War Bonds any more than there is such a relationship between commercial advertising and the sale of any product. The purpose of advertising, as tab understand it, is to create Advertisers and the Outdoor Industry provided by all odds the most expansive outdoor showing of all time, with 20,000 sponsored 24-sheet poster panels and 30,000 donated by the industry* The estimated value of the outdoor advertising was f>l,800,000, including car cards and three-sheets; The National Association of Broadcasters reports that advertisers and radio stations devoted radio time and talent which they valued at 112,000,000 to Third War Loan messages to the public, throughout the days and nights of the Drive. This 5-week campaign put on by advertisers alone would have cost a commercial sponsor 124,000,000 — double the proposed annual appropria tion under S. 1457J Add to this the value of publicity contributed by the motion picture industry — producers, distributers, and exhibitors; chain radio and news papers; department store displays; bank, school and railroad displays; and most important of all, the selfless, untiring work of five million War Bond volunteers, who without by-line or credit-line, carried the national message, by word of mouth into every nook and cranny of the country; — and one begins to form some comprehensive idea of the staggering scope of this unparalleled undertaking. Senate Bill 1457 authorizes and directs the Secretary of the Treasury to purchase from 12-J- to 15 million dollars of advertising. To attempt to duplicate out of public funds the estimated value of measurable advertis ing contributed in support of the War Bond campaign during 1943 would re quire, however, an authorization to spend a minimum of 100 million dollars. And this estimate takes no account of the voluntary assistance of adver tising agencies and millions of individuals whose contribution to the sell ing effort is literally incalculable* A 12 or 15 million dollar subsidy wall add nothing to the advertising and publicity the Bond effort is already receiving. On the contrary, it may wrork ’irreparable harm. The War Finance•Division cannot, in good conscience, ask some newspapers to contribute War Bond advertising volun tarily as a patriotic service while others are free to withhold their support until they receive a Government subsidy. Far from increasing the total amount of advertising, a Government subsidy on the scale envisaged by S, 1457 might decidedly lessen the volume we now enjoy. The demand for Government sponsored advertising is nothing new. Secretary McAdoo, directly in charge of the Nation’s Bond effort in the last w?ar, had to face the problem. His words are worthy of quotation for they express in essential particulars our views today: Statement of Ted R* Gamble, National Director of the War Finance Division of the Treasury Department, before the Committee on Ways and Means of the House of Representatives. December 3, 1943* -V As National Director of the United States Treasury Department’s War Finance Division, entrusted with the task of promoting the sale of Government securities, I feel it my duty to lay before you my views on Senate Bill 1457 and the majority report of the Committee on Banking and Currency which accompanies it* Permit me to say, first of all, that, given the total tax revenues under existing legislation, ’’The broad objective of a Nationwide stabilization plan can best be achieved”, as the Committee Report correctly points out, ”by Government borrowing from all its citizens by means of Bond sales to individuals*” It is iry considered opinion, however, that the passage of S* 1 4 5 7 'and its enactment into law might well be the means of retarding the very stabilization program it sets out to aid* The Treasury today is already favored with the greatest advertising operation in the history of the world — a consistent, carefully con ceived effort reaching, we have reason to believe, into every city, town, hamlet and county In America* This nation-wide effort, conducted along voluntary lines, attains volume peaks, during drive periods, which have never before been equalled on either a paid or a voluntary basis* Let me itemize briefly the advertising record for the recent Third War Loan Drive in September 1943* Daily and Sunday newspapers published 88,947,War Bond advertisements *• a total of 6l,573,5S8 agate lines, with a value at published national rates of $6,697,353,45* Approximately 92*5 per cent of this space was paid for by advertisers and about 7. 5 per cent was contributed by the newspapers* Weekly aid semi-weekly newspapers carried 63,846 advertisements aggregating 67,976,376 agate lines valued at $1,942,181*60* About 87 per cent of this space was paid for by advertisers* Daily and weekly newspapers published Third War Loan advertising with a value of $8,639,540*05 of which 91*2 per cent was purchased by advertisers* At least $1,380,000 in magazine space was provided by advertisers and the magazines themselves* Twro hundred and thirty-six general magazines 55 farm journals, and 513 business and trade magazines each contributed a free Vfar Bond advertisement* ^ | | ^ ip i« p ^ q w « p p ig iP ()n ig m ia iM > w iiiu ii*iiv ii.i| iiiu i ........ .............................. . ‘ y .-* — |' - 2 As you know, we now depend upon cooperation by advertisers, publications, radio, and the advertising industry generally,, to provide, without cost to the Treasury, the huge amount of advertising space and time required to reach and convince 130 million people. By this means we are amply reaching all the important markets that; would be available through this subsidy. The added impact, if there is any, would be of doubtful value. So far, our cooperative plan has worked very successfully. Had the Treasury paid, for the advertising used during the three weeks of the Third War Lba'n, it would have cost $30 millions. This includes the value of only those advertisements, radio programs, or billboards given over to War Bond promotion; it does not take into account the innumerable ^reminders’* in advertisements for products. But we cannot continue this method if we pay some of those cooperating, and leave the others in status quo* Hither we must pay all or none. And it certainly seems wasteful to pay any of them as long as the vast majority are willing to continue supporting Bond drives on a patriotic basis. At the Senate hearings on this Bill, it was indicated that firms advertising Bonds can, as a result, take certain credits on their tax liabilities which are not otherwise avail able. This is untrue,. Under present regulations, a firm is permitted to regard a reasonable amount of advertising, if this has been its custom in the past, as legitimate business expense. Advertising, used to promote War Bends represents conversion of publication or billboard space, or radio time, which the advertiser would use otherwise to promote his products or to keep his trade name alive during the war* It cannot be said, therefore, that the Treasury is paying for Bond advertising even indirectly. I think it might be wise for your Committee to lend its weight now in stopping this proposal from becoming law, rather than waiting until it has become law, and then attempting to curtail the funds involved. Judging by any standards, the money involved in this useless and dangerous subsidy repre sents non-essential spending. Sincerely, (Signed) Henry Morgenthau, Jr* Senator Harry 2, Byrd United States Senate Washington, D. C* TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Friday. December 3. 194.3 o Press Service No0 39—73 Secretary Morgenthau last night made public the following letter to Senator Byrd, voicing the Treasuryfs opposition to the Bankhead Bill scheduled to be taken up by the Ways and Means Committee of the House of Representatives at 10:00 AoM©, today: December 2, 194-3 Hjy dear Senator: On November 14., 194-1> I made to the Joint Committee on Reduction of Non-Essential Federal Expenditures, of which I am a member, a number of recommendations for reducing non- essential Government costs© Most of these recommendations were taken, and resulting savings are noted in your recent reporto I should like now to call the attention of the Committee to another potential waste of Government funds which, in my estimation, should be stopped in its tracks0 I refer to the $15 million subsidy to certain small newspapers, recently voted by the Senate in the Bankhead Billo A companion bill ■ now in the House, calls for a similar subsidy of $30 millionso At this time, when your Committee and most of the rest of us are seeking ways of curtailing non-ressential Government spending, I think this proposal to distribute a sizable amount of the taxpayers* money'in such a way that it will not contri bute to winning the war, or to any legitimate requirement-of our economy, is inexcusable© Ostensibly, this proposal was made in an effort to help sell War Bonds0 I should like to have it on the record that it will not help sell War Bonds, and as a matter of fact, it is likely to prove an almost insurmountable hurdle to the continued promotion of War Bonds© TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Friday. December 1943o Press Service No0 39-78 Secretary Morgenthau last night made public the following letter to Senator Byrd, voicing the Treasury’s opposition to the Bankhead Bill scheduled to be taken up try the Ways and Means Committee of the House of Representatives at 10:00 A oil®, todays December 2, 194-3 My dear Senator: On November 14, 1941, I made to the Joint Committee on Reduction of Non-Essential Federal Expenditures, of which I am a member, a number of recommendations for reducing nonessential Government costs© Most of these recommendations were taken, and resulting savings are noted in your recent report© I should like now to call the attention of the Committee to another potential waste of Government funds which, in my estimation, should be stopped in its tracks© I refer to the §15 million subsidy to certain small newspapers, recently voted by the Senate in the Bankhead Bill© A companion bill now in the House, calls for a similar subsidy of §30 millions© At this time, vrhen your Committee and most of the rest of us are seeking ways of curtailing non-ressential Government spending, I think this proposal to distribute a sizable amount of the taxpayers* money'in such a way that it will not contri bute to winning the war, or to any legitimate requirement of our economy, is inexcusable© Ostensibly, this proposal ?ras made in an effort to help sell War Bondso I should like to have it.on the record that it will not help sell War Bonds, and as a mat ten of fact, it is likely to prove an almost insurmountable hurdle to the continued promotion of War Bonds© - 2 - As you know, we now depend upon cooperation "by advertisers, publications, radio, and the advertising industry generally, to provide, without cost to the Treasury, the huge amount of advertising space and time required to reach and convince 130 million people. By this means we are amply reaching all the important markets that would be available through this subsidy. The added impact, if there is any, would be of doubtful value. So far, our cooperative plan has worked very successfully. Had the Treasury paid for the advertising used during the three weeks of the Third War loan, it would have cost $30 millions. This includes the value of only those advert!sements, radio programs, or billboards given over to War Bond promotion; it does not take into account the innumerable ”reminders” in advertisements for products* But we cannot continue this method if we pay some of those cooperating, and leave the others in status quo? Bither we must pay all or none. And it certainly seems wasteful to pay any of them as long as the vast majority are willing to continue supporting Bond drives on a patriotic basis. At the Senate hearings on this Bill, it was indicated that firms advertising Bonds can, as a result, take certain credits on their tax liabilities which are not otherwise avail able. This is untrue. Under present regulations, a firm is permitted to regard a reasonable amount of advertising, if this has been its custom in the past, as legitimate business expense. Advertising used to promote War Bonds represents conversion of publication or billboard space* or radio time, which the advertiser would use otherwise to promote his products or to keep his trade name alive during the war. It cannot be said, therefore, that the Treasury is paying for Bond advertising even indirectly. I think it might be wise for your Committee to lend its weight now in stopping this proposal from becoming law, rather than waiting until it has become law, and then attempting to curtail the funds involved, Judging by any standards, the money involved in this useless and dangerous subsidy repre sents non-essential spending. Sincerely, (Signed) Henry Morgenthau, Jr. Senator Harry ?• Byrd United States Senate Washington^ D. 0. Comparison of principal items of assets and. liabilities of national banks — continued Page h (In thousands of dollars) ? Oct. 18, : • 1943 LIABILITIES Deposits of individuals, partner ships and corporations: Demand.........................J |.$ “i®® 30,901,323 . 9.501,37? 6.139 30, 1943 ‘ June s $30,518,146 , 6,918 4.582,436 8 971,178 31, 9**2 ! Dec. i : $ ! ; m 26,730,691 8,307.5,19 , 9.073 4,833.109 2,695,194 Increase or decrease : since June 30. 19k3 : Amount : Percent : $383,177 530,201 -784 6,264,617 - 1.26 5.91 - 11.33 136.71 4 170,632 1 193,860 , 6 ,013.994 14.37 -32.39 124.43 -91,310 -87,771 -3,39 -1.19 -58,177 11,138,239 -8.66 33.202 944.31 24,350 6.24 12.86 11.195.791 21.93 3.61 -13.921 6,694 -9.53 2.60 -7,227 72,092 95,315 20.035 ~ -^*8 5.01 17.63 7* 84 187.kk2 180,215 8.39 k»82 11.376.006 20.77 11.178 3.20 Postal Savings deposits..... . Deposits of U. S. Government.... . 10,8^7,053 Deposits of States and political subdivisions.... ............. . 2,603.884 2.900,361 -10.22 -296,477 Deposits of hanks 1/*,.... . 7,156.360 7.401,534 • 7.313.763 157,403 2.20 Other deposits (certified and cashiers1 cheeks, etc.)......... -20,kk3 633.962 Total deposits 1/............ .61,787.055 54,769.361 50,648,816 , 12.81 Bills payable, rediscounts & other liabilities for borrowed money....• 36.718 4.231 3.516 32,487 Other liabilities................ . UlH,6Ui 41,286 373.355 390,291 Total liabilities, excluding . 62,238,^ 55.146,947 51,042,623 , CAPITAL ACCOUNTS Capital stock: Preferred stock....... . 137,076 146,047 -4,950 Common stock...••••••• . 1.364.329 1.360,932 1.357.635 3.397 .25 Total.......................... . 1,^98,008 1.503.682 -.10 •1,553 Surplus......................... .^ 1,438,645 . 1.510,737 , k 2*k5 Undivided profits............... 584,169 5*t0.524 51,670 8.85 Reserves..... .................. 255.504 •____ 275.539 ____ 268,555 6.98k Total surplus, profits, and reserves...... .......... . 2,422.115 2.327.397 9k.718 2.234,673 4.07 Total capital accounts........► 3.918,570 3,825,405 2.kk 3,738,355 Total liabilities & capital accounts 1/............... , 66.156.98*1 58,972.352 54,780,978 .7,184,632 12*18 Reciprocal balances with banks in the United States................ . . 360,484 ____ 327.657 349.306 10.02 32.827 Ratio of loans to total deposits... lbTW NOTE: Minus sign denotes decrease. 1/ Excludes reciprocal interbank demand balances with banks in the United States, the amounts of 613,519 671,696 7 017,694 3.22 767.83 11.06 7 091.467 132,126 1 496.455 635.839 1 74.673 36 06 93.165 Increase or decrease since Dec. 31. 19k2 Amount : Percent $ , , 15.60 21.99 which are shown above. statement showing comparison of principal items of assets and. liabilities of active national baxtfcs as of October IS, 19^3, June J>0, l9*+3» and December 31 , 1942 (in thousands of dollars) s : i • dumber of banks,................... ASSETS Loans on real estate........ ...... Other loans, including overdrafts*. Total loans................... . U. S, Government securities: Direct obligations.............. Obligations fully guaranteed,.,. Total U. S. securities..... . Obligations of States and political subdivisions.......... Other bonds, notes and debentures....................... Corporate stocks, including stock of federal Reserve Banks........ Total investments......... . Total loans and investments...• Currency and coin.................. Reserve with federal Reserve Banks. Balances with other banks 1/...... Total cash, balances with other banks, including re serve balances and cash items in process of collection l/........ .......... Other assets....................... Total assets l / ................ Oct. 18, : June 3 0 , 1943 : 19*+3 • « 5.058 5,066 : Dec* 3 1 , 19 I+2 * • • 5,087 : Increase or decrease : Increase or■ decrease : since June 30, 1943 ! since Dec. 31, 1942 Amount : Percent : Amount : Percent -8 - .1 6 -29 -.57 ($2 ,136,260 ( 7 .053.883 9 ,1 9 0 ,1^3 1 0 ,7 7 5 .3 16 $2,187,264 ) 8 ,0 13 ,5 3 4 )$1 ,5 8 5 ,17 3 10,200,798 1 .5 8 5 .17 3 (2 g. 5 1 4 .63 u ( 1,675.768 35.709.814 30,190,1+02 2 2 ,2 6 1,4 10 > 5 ,5 19 ,4 12 1 ,56 3.9 4 1 ) 5 .5 19 .4 12 2 3 .8 2 5 .3 5 1 $ 1 0 ,7 7 5 ,3 1 6 3 5 .70 9 .8 1 ^ 17.25 $ 5 7 4 ,5 18 5 .6 3 17.25 5 7 4 ,5 18 5 .6 3 18.28 11,884,463 49.88 18.28 11,884,463 49.88 1,984,169 2 .026,333 2,022,493 -42,164 -2.08 -38,324 -1.89 1,266,527 1,340,099 1,441,184 -73.572 - 5.4 9 -174,657 -12.12 1 4 5 ,8 1 1 171.744 33.728.578 42,918,721 806,51+6 7.853.296 6,567.5^9 19 3 .76 0 -25.933 , 6 ,9 62,9 16 6 ,5 2 1 2 3 ,0 17 166,30 9 - 1 5 .1 0 1 5 .9 4 16.22 .81 .29 2.53 -47,949 11.623.533 12,198,051 79.568 -373.200 -533.400 - 2 4 ,7 5 42.29^ 3 2 .3 7 10 .8 5 -4 .5 2 - 7 .3 4 195.847 25,869 7,184,632 1.29 3.13 12,18 -827,032 4,987 " 1 1 ,376,006 - 5.09 .5 9 2 0 .7 7 39.106.321 U 9 ,8 8 1,6 3 7 8 13,0 6 7 7 .3 7 6 .3 13 6 ,733.858 15,U23,238 15.227,391 826 ,21+0 852,109 6 6 ,1 5 6 ,981+ 58,972,352 27,1+82,788 37.683,586 733.499 8,249.513 7 ,267,258 1 6 ,250,270 81+7,122 5 4 .780,978 5 377,743 - 2 decreased $1^2,000,000 since June and $261,000,000 since December last year. Cash of $613,000,000, balances with other hanks, including cash items in process of collection, of $ 6 ,73 ^»000 ,000 , and reserves with federal Reserve hanks of $ 7 >6 7 6 ,000 ,000 , a total of $1 5 »^-2 3 »000 ,000 , increased $1 9 6 ,000,000 since June hut showed a decrease of $627,000,000 under the amount reported in December last year. The unimpaired capital stock of the hanks on October 16, 19 U 3 , was $1,^96,000,000 including $132,000,000 of preferred stock. Surplus of $1,511 undivided profits of $6 36 ,000 ,000 , and reserves of $ 2 7 5 ,000 ,000 , a total of $2,^22,000,000, increased $95,000,000 since June and $167,000,000 since December 19^2. The percentage of loans and discounts to total deposits on October 16, 19 ^3 , was 1 7 .I&, in comparison with 1 6 .7 8 on June 3 0 , 19 ^ 3 , and 20.lU on December 3 1 , 19^2. TREASURY DEPARTMENT Washington FOR RELEASE, Press Service 7, / r/ ~7c^ 3 9- 7 ? The total assets of national hanks on October IS of this year amounted to more than $66 ,000 , 000 , 000 , it was announced today by Comptroller of the Currency Preston Delano* Returns from the call covered the 5*^58 active national banks in the United States and possessions. The assets reported were greater by $ 7 , 000 , 000,000 than those reported by the 5,066 national banks on June 30, 19^3 , the date of the previous call, and an increase of $11,000,000,000 over the amount reported by the 5>087 active banks on December 31 * 19^2 . The deposits of the national banks on October IS, 19^3* were nearly $ 62 , 000 ,000 , 000 , an increase since June 3^* 19^-3 of $ 7 *000 , 000 , 000 , and an in crease since December 31 last year of $11 , 000 , 000 , 000 . Included in the current deposit figures are demand and time deposits of individuals, partnerships and corporations of $ 30 , 901 , 000,000 and $9 , 501 , 000 , 000 , respectively, United States Government deposits, including War loan and Series E bond accounts of $10,8^7,000,000, deposits of States and political subdivisions of $2,600,000,0 J postal savings of $ 6 ,000 ,000 , deposits of banks of $ 7 ,31 ^,000 ,000 , and certified and cashiers* checks, cash letters of credit and travelers1 checks outstanding of $ 61 ^,000 ,000 . Loans and discounts were $10,775*000,000, an increase of $1,585*000,000, or 17 percent, since June 30 , 19^3* and an increase of $575»000,000, or nearly 6 percent, since December 31* 19^2, Investments in United States Government obligations, direct and guaranteed, of $ 3 5 ,7 1 0 ,000 ,000 , showed an increase of $ 5 *5 1 9 *000 ,000 , or over IS percent, since June 30 , 19^3, and an increase of $11,SS^,000,000, or nearly 50 percent, since December 19^2. Other bonds, stocks and securities held of $ 3 ,39 7 »°00 »000, which included obligations of States and political subdivisions of $1 ,98^,000,000, TREASURY DEPART MEM? Washington FOR RELEASE, MORNING NEWSPAPERS, Tuesday, December 7,1945*______ 12-4-43 Press Service No. 39-79 The total assets of national Banks on October 18 of this year amounted to more than $6 6 ,0 0 0 ,0 0 0 ,0 0 0 , it was announced today by Comptroller of the Currency Preston Delano. from the call covered the 5,0 5 8 United States and possessions. Returns active national banks in the The assets reported were greater by $7 )0 0 0 ,000,000 than those reported by the 5,066 national banks on June 30^1943, the date of the previous call, and an increase of $1 1 ,0 0 0 ,0 0 0 ,000 over the amount reported by the 5,087 active banks on December 1942. The deposits of the National banks on October 18, 1943, were nearly $62,000,000,000, an increase since June 30, 1943 of $7,000,000,000, and an increase since December 31 last year of $1 1 ,0 0 0 ,0 0 0 ,0 0 0 . Included in the current deposit figures are demand and time deposits of individuals, partnerships and cor porations of $3 0 ,9 0 1 ,000,000 and $9 ,5 0 1 ,0 0 0 ,0 0 0 , respectively, United States Government deposits, including War loan and Series E bond accounts of $10,847,000,000, deposits of States and political subdivisions of $2,600,000,000, postal savings of $6 ,0 0 0 ,0 0 0 , deposits of banks of $7 ,3 1 4 ,0 0 0 ,0 0 0 , and certified and cashiers’ checks, cash letters of credit and travelers’ checks outstanding of $6 1 4 ,0 0 0 ,0 0 0 . Loans and discounts were $10,775,000,000, an increase of $1,585,000,000, or 17 percent, since June 30, 1943, and an in crease of $575,000,000, or nearly 6 percent, since December 31, 1942. Investments in,United States Government obligations, direct and guaranteed, of $35,710,000,000, showed an increase of $5,519,000,000, or over 18 percent, since June 3 0 , 1943, and an increase of $11,884,000,000, or nearly 50 percent, since Decem ber 1942. Other bonds, stocks and securities held of $3,397,000,000, which included obligations of States and politi cal subdivisions of $1 ,9 8 4 ,0 0 0 ,0 0 0 , decreased $1 4 2 ,000,000 since June and $261,000,000 since December last year# - 2 - Cash of $813,000,000, balances with other banks, including cash items in process of collection, of $>6 ,7 3 4 ,0 0 0 ,0 0 0 , and re serves with Federal Reserve banks of $>7,876,000,000, a total of $15,423,000,000, increased $196,000,000 since June but showed a decrease of $827,000,000 under the amount reported in December last year. The unimpaired capital stock of the banks on October 18, was $1,496,000,000 including $1 3 2 ,0 0 0 , 0 0 0 of preferred stock. Surplus of $1,511,000,000, undivided profits of $636 ,0 0 0 ,0 0 0 , and reserves of $2 7 5 ,0 0 0 ,0 0 0 , a total of $2 ,4 2 2 ,0 . 6 0 ,0 6 0 , increased $95,000,000 since June and $187,000,000 since December 1942. 1943 , The percentage of loans and discounts to total deposits qn October 18, 1943, was 17.44, in comparison with 16.78 on June 30, 1943, and 20.14 on December 31, 1942. Page 3 Statement showing comparison of principal items of assets and liabilities of active national banks as of October 18, 1943* June 30» 1943, and December 31, 1942 (In thousands of dollars) : t Number of banks......................... Oct. IS, i 19^3 : June 30* : Dec. 3 1 , 19^3 1942 5,-058 5,066 5,087 $1 0 ,7 7 5 ,3 1 6 ($2 ,136,260 7 ,0 53,8 83 10.775,316 9,l90,lte Increase or decrease ; Increase or decrease ; since June 30, 1943 : since Dec. 31, 1942 ;■ Amount : Percent : Amount. : Percent -8 -. 16 -29 -,57 ASSISTS Loans on real estate...... ........... Other loans, including overdrafts... Total loans..,...... ........ ...... U. S. Government securities; Direct obligations....... .... ..... Obligations fully guaranteed..... Total U. S. securities. ........ . Obligations of States and political subdivisions............. Other bonds, notes and debentures..... .... . ...... ..... .... Corporate stocks, including stock of Federal Reserve Banks..-.*...,. .. Total investments...... ......... Total loans and investments*,.... Currency and coin............... . Reserve with Federal Reserve Banks.. Balances with other banks l/....— •. Total cash, balances with other banks, including reserve balances and cash items in process of collection l/...............,.. Other as sets# *•• assets X/» * • • • •# 35l709.8l4 (28,514,634 ( 1 ,6 75,76 8 35,709.81^ 30,190,402 $2,187,26!* ) $1,585,173 17.25 $57“+,518 5 .6 3 10,200,798 1,585,173 17.25 574,518 5.63 22 .261,410 ) 1 .56 3 ,9“a ) 5 .519 ,412 18.28 11.884,463 49.88 23,825,-351 5 ,519.^12 18.28 11,884.463 49.88 8 ,013.53“+ ) l . J Z k . l b S 2,026,333 2 .022,493 -42,164 -*2.08 1.266,527 l,3te,099 1.441.184 - 7 3 ,5 7 2 -5.“+9 -17“+,657 -12.12 1^5.811 39,106,321 49 ,88 1,6 37 193.760 -25,933 5,-377,743 6 .962,916 6,521 - 1 5 .1 0 1 5 .f t 6,733.858 171,7^ 33,728,578 42,918.721 806,546 7,853,296 6 ,5 6 7 ,5te .81 .29 2.53 -+*7.9“*9 11,623,-533 12,198,051 79.568 -373.200 -533,“+00 -2+*. 75 42.29 32.37 10.85 -4.52 - 7 , 3 “* 15.te3.238 852,109 66 ,156 ,9 ft 15,227,391 826,240 58,972,352 1.29 3.13 12.18 - 827,032 “+,987 1 1 .3 7 6 ,00 b -5.09 .59 20.77 813,067 7 ,8 76 ,313 27,482,788 37,683,586 7 3 3 ,“+99 2 3 ,0 1 7 8,2te.513 7 ,26 7,2 58 166.309 16 .250,270 195,81*7 847,122 5“)-.780.978 25,869 7 ,13l*, 632 16 .22 - 3 8 ,32 !* -I .8 9 Comparison of principal items of assets and liabilities of national banks - continued Page *+ (in thousands of dollars) Oct. 18, ; June 30, : Dec. 31, 1 Increase or decrease : Increase or decrease 19*+2 : 1943 : since June 30, 19*+3 + since Dec.- 3 1 , 1942 1943 : Amount : percent : Amount ; Percent * LIABILITIES Deposits of individuals, partner ships and corporations: $3 0 ,518 ,l *+6 $ 26 ,730 ,6 9 1 $*+,170 ,6 32 1 .2 6 15.60 **».*• $30*901,323 Demand ....... . #383,177 530,201 1 ,193,860 8,971,178 Time. ....... -.......... . 9*501, 379 8 ,30 7,5 19 l*+.37 5*91 -78*+ 6,918 Postal Savings deposits.... . 6,13*+ -32*39 “ 2,-939 -11*33 9 ,0 73 6 ,26*+,617 6 ,0 1 3 ,9 *+*+ 12*+.-*+3 *+,582 ,*+36 1 3 6 .7 1 4,833,109 Deposits of 17- S. Government...... 10,8*+7,053 Deposits of States and political - 10 .2 2 2 ,900,361 2,695,194 subdivisions. ............... . 2 ,603 ,88 *+ - 296 ,*+77 “91,310 -3.39 2.2 0 7 ,156,360 7,401,534 Deposits of banks l/ .............. 7*313*763 -1*19 157, *+03 -87*771 Other deposits (certified and -8.66 633.962 - 20 ,l+*+3 -3 * 2 2 671,696 cashiers* checks, etc.)...*.*..* 6 13,519 -58,177 12.81 7 ,0 17,6 9 4 5076*+8,8l6 Total deposits 1/.... ........ 61,787,055 21.99 54 ,76 9 ,36 1 11,138,239 Bills payable, rediscounts & other9*+*+.3l 33,202 32,487 liabilities for borrowed money.. 767*83 3,516 36,718 4,231 6 .2*+ I I .06 *+l, 286 2 * +, 350 4i4,64i Other liabilities.. .. ............. 390,291 373,355 Total liabilities, excluding 12.86 7 ,091,467 55,146,947 capital accounts l/ .......... 62,238,1+1 *+ 51,0*+2.623 21*93 11,195*791 CAPITAL ACCOUNTS Capital stock; - 3.61 132,126 -4,950 “13,921 preferred stock* ................ 137,076 146, o 47 -9.53 6 ,69*+ Common stock........ ........ *25 .*+9 1,357,635 3,397 1,364,329 1,360,932 -.10 1,*+98,008 1*503,682 Total......................... -7,227 1,496,455 -1*553 72,092 5 .0 1 1,438,645 Surplus...... . ... .......... 1,510,737 36768 * 2.*+5 1 ,474,673 8.85 534,169 540,524 17.63 51,670 Undivided profits*. ............... 95,315 635,839 255,504 7.8*+ 6 ,98*+ 2.60 R 6S 6PV 6S« •«••r# •••••r••» •♦♦♦•••• 20,035 268,555 275*539 Total surplus, profits, and 94.718 187, *+*+2 reserves *...*. ..........»*- 2,1+22,115 *+.07 8*39 2.327,397 2,234,673 *+.82 " 2.*+*+ Total capital accounts.......* 3,918.570 180,215 93,165 3,825.405 3,738,355 Total liabilities & capital 11 ,376,006 12.18 54,780,978 7,184,632 accounts 1/. ........ ..... ... 66 ,156 ,98*+ 20.77 58,972,352 Reciprocal balances with banks in 10.02 3*20 11,178 3*+9,306 32,827 360,*+8*+ --the United States. .............. 327,657 20.1 *+$ Ratio of loans to total deposits.. — lb.78$ 1 7 .41$ . 1 /ExcludesUr e c ip r o c a l ° i n t e r banked emand balances with hanks in the United States, the amounts of which are shown above. December 2, 1943 STATUTORY DEBT LIMITATIOS AS OP NOVEMBER. ^P* 1943 ^Section 21 of the Second Liberty Bond Act, as amended, provided that the face amount of obligations issued under authority of that Act, * shall not exceed in the aggregate $210,000,000,000 outstanding at any one time* The following table shows the face amount of obligations outstanding and the face amount which can still be issued under this limitations Total face amount that may be outstanding at any one time $210 ,000 ,000,000 Outstanding as of November 3®» 19^3* Inters st-bearing s Bonds $67,940,349,000 Treasury Savings (Maturity 33,022,858,825 value)* Depositary 399,82*4,25© 719*672,907 Adjusted Service i $ 1 0 2 ,0 8 2 ,7 0 * ,9 8 2 27,687,610,400 Treasury notes Certificates of Indebtedness Treasury Bills (Maturity value) 28 ,066 ,911.000 13*073*822,000 Matured obligations, on which interest has ceased Bearing no interest (W,S, Savings stamps ) 68.828.343.400 200,825,575 202,415,459 Face amount of obligations issuable under above authority 171.3l4,289,4l6 $ 38 ,6 8 5 *7 10*534 Beconcilement with Daily Statement of the United States Treasury November 10* 1943 Total face amount of outstanding public debt obligations issued under authority of the Second Liberty Bond Act, Deduct, unearned discount on Savings bonds (difference between current redemption value and maturity value) Add other public debt obligations outstanding but not subject to the statutory limitations Interest-bearing (Pre-War, etc*) $195*942,720 Matured obligations on which - ^ interest has ceased Bearing no interest 9bbtQ7b tlS2 Total gross debt outstanding as of November 3®» 19^3 ♦Approximate maturity value* Principal amount V current redemption valuei according to preliminary public debt statement $26,697»013*319 3 9 - Z 0 $171,314,289*416 164.988.W3,910 1.164.956.325. 8i66.l58.4QO.235 December 6, 1943 STATUTORY DEBT LIMITATION AS OR NOVEMBER 30. 1943 Section 21 of the Second Liberty Bond Act, as amended, provided that the face amount of obligations issued under authority of that Act, 11shall not exceed in the aggregate $210,000,000,000 outstanding at any one time." The following table shows the face amount of obligations outstanding and the face amount which can still be issued under this limitation; Tbtal face amount that may be outstanding at any one time $ 210 , 000 , 000,000 Outstanding as of November 30, 1943: Int e re st-b ear ing: Bonds Treasury $67,940,349,000 Savings (Maturity value)* 33,022,858,825 Depositary 399,824,250 Adjusted Service 719.672.907 Treasury notes Certificates of Indebtedness Treasury Bills (Maturity value) $102,082,704,982 27,687,610,400 28.066.911.000 13.073.822.000 Matured obligations, on which interest has ceased Bearing no interest (U.S. Savings stamps) 68.828.343.400 $170,911,048,382 200,825,575 202.415.459 Face amount of obligations issuable under above authority 171,,314.289.416 $ 38,685.710.584 Reconcilement with Daily Statement of the United States Treasury. November 30, 1943 Total face amount of outstanding public debt obligations issued under authority of the Second Liberty Bond Act. Deduct, unearned discount on Savings bonds (difference between current redemption value and maturity value) Add other public debt obligations outstanding but not subject to the statutory limitation: Interest-bearing (Pre-War, etc.) $195,942,720 Matured obligations on which interest has ceased 7,936,840 Bearing no interest 966.076.765 Total gross debt outstanding as of November 30, 1943 *Approximate maturity value, principal amount (current redemption value) according to preliminary public debt statement $26,697,013,319 39-80 oOo- $171,314,289,416 6.325.845.506 164,988,443,910 1.169.956.325 $166,158,400,235 wii.. , ,ys. .‘tt,, 1s csgssssacsv* TBEASUHT S « l l S S B fvaehington tor b e u a s k , m m m b w s p a p o s Press Service , Ttt«»day. Pac M t e w 7. 1943.------ The Secretary of the treasury announced last evening that the tenders for H fQG0,0OO,OQO# or thereabouts, of 91-day treasury bills to be dated Deeeaber 9, 1943, m iiftto nature March 9, 1944, which were offered on Decesteer 3, mere flfsod at the Fed eral Reserve Banks on December 6* The details of this Issue are as follows: Total applied for — $1,694,400,000 Total accaptad - 1,011,652,000 ill) Average price M (include. £3.887,000 entered on a fi»d-prio. basis at 99.905 and accepted in full) - 99 ^905/ Equivalent rate of discount approx. 0.375s per annua Hangs of accepted cospetitive bids: - 99.910 Equivalent rate of discount approx. 0.35M per s s » - 9 9 .9 0 5 low * e e * « 0 .3 7 6 $ « * (5 2 parent of the awrant bid for at the low price was accepted) Total Federal Beeerve Total District------ teSAgaisE. Boston New fork Philadelphia Cleveland # 15,155,000 1,153,216,000 82,836,000 63.705.000 . 13 862.000 Richaond 8,665*000 Atlanta 167 ,263,000 Chicago Minneapolis Kansas City Dallas San Francisco 110 . 686.000 #1,696,600,000 51,011,652,000 . 23 821.000 19,966,000 TOTAL 8 ,003,000 109 ,2a , 000 19.990.000 6 ,366,000 21.589.000 18.862.000 77.776.006 31.270.000 6,395,000 St. louia 10.067.000 612,977,000 66.660.000 50.985.000 10.958.000 TREASURY DEPARTMENT Washington Press Service FOR RELEASE| MOEKING HEWSPAPSRS, Tuesday. December 7. 1943. 3 f 'M The Secretary of the Treasury announced last evening that the tenders for 11,000,000,000, or thereabouts, of 91-day Treasury bills to be dated December 9, 1943, and to mature larch 9, 1944, which were offered on December 3, were opened at the Fed eral Reserve Banks on December 6. The details of this issue are as follows; Total applied for - $l,694j400,GQ() Total accepted - 1,011,452,000 Average price (includes $63,887,000 entered on a fixed-price basis at 99.905 and accepted in full) - 99.905/ Equivalent rate of discount approx. 0.375$ per annum Range of accepted competitive bids: High Low - 99.910 Equivalent rate of discount approx. 0.356$ per annum - 99.905 ** » » M ** 0.376$ n tt (52 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Aoolied for Total Accepted Boston Mew York Philadelphia Cleveland Richmond Atlanta Chicago St, Louis Minneapolis Kansas City Dallas San Francisco 1 i TOTAL 15,155,000 1,153,216,000 82,836,000 63.705.000 13.862.000 8.145.000 167,263,000 31.270.000 4.395.000 23.821.000 19,946,000 110.486.000 $1,694,400,000 10 ,067 ,ocx) 612.977.000 66,660,000 50.985.000 10.958.000 8,003,000 109.241.000 19.990.000 4,366,000 21.589.000 18.842.000 77.774.000 |1,011,452 ,000 TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, T u e s d a y , D e c e m b e r 7* 1 9 4 3 • 1 2 - 6 - 4 2 ----— ----- ---------The Secretary the te n d e r s ury bills 1944, of t h e T r e a s u r y a n n o u n c e d for $1,000,000,000, details 1943, o f f e r e d on D e c e m b e r eral R e s e r v e B a n k s on D e c e m b e r of t h i s last or thereabouts, t o b e d a t e d D e c e m b e r 9, which were The Press Service N o . 39*^81 and to 3, w e r e evening that of 9 1 - d a y T r e a s m a t u r e M a r c h 9, o p e n e d at t h e F e d 6* issue are as follows: Total applied for - $1,694,400,000 Total accepted 1,011,452,000 (includes $63,887,000 e n t e r e d on a f i x e d - p r i c e b a s i s a t 9 9 . 9 0 5 a n d a c c e p t e d in f u l l ) Average price - 9 9 * 9 0 5 / E q u i v a l e n t r a t e of d i s c o u n t a p p r o x 0 . 3 75/o p e r a n n u m Range c o m p e t i t i v e b ids: of a c c e p t e d High - 99*910 Equivalent 0 . 3 5 6/o p e r - 9 9 .9 0 5 E q u i v a l e n t 0.37^o per Dow (52 p e r c e n t of t h e a m o u n t bid for at t he l o w p r i c e wa s accepted) Federal R eserve District Total Applied for Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. L o u i s Minneapolis Kansas C i t y Dallas San F r a n c i s c o $ TOT A D r a t e of d i scount a p p r o x annum r a t e of d i s c o u n t a p p r o x annum 1 5 ,1 5 5 , 0 0 0 1 ,1 5 3 ,2 1 6 , 0 0 0 8 2 ,8 3 6 , 0 0 0 63.705.000 13.862.000 8.445.000 167,263,000 Total Accepted $ 10,067,000 612.977.000 66,660,000 50.985.000 . 1 0 958.000 8 ,0 0 3 ,0 0 0 4.395.000 23,821,000 19,946,000 110,486,000 109.241.000 19.990.000 4,366,000 21.539.000 18.842.000 77,774,000 $1,694,400,000 $1,011,452,000 31,270,000 2 • C P m * QAkD M H f r S j / GOMBSR i-Ap WASTE, SLIVER WASTE, AND ROVING WASTE,. * W H E T H E R 'OR N O T MANUFAC^U&JSD O R O T H E R W I S E A D V A N C E D 1 $ T O p * commencing September 20, 'by- Coun tries of Origin: A nnual ,quo,tas Total quota, provided, However, that not more than, 33-0./3 percent/, of- t^e,, quotas shall he filled by cotton wastes other than card strips/.jan.d comber wastes made from cottons of-1— 3/16 inches or more in staple ■lepgth in the • case of the following countries: United Kingdom, France, Netherlands, Switzerland, Belgium, Germany and Italy: — -------------------- — __________ (In, Pounds)_________ _ _ _ ___________________ t ■ TOTAL IMPORTS*"1'*:EStABDTSHEDTImports Sept* 20, Country of Origin : Established :Sept, 20,. 1943 :33~l/3$ of :1943, to ■ ... , { TOTAL QUOTA : 37, 1943 iTotal- Quota: Nov« 27, 1943 l/ Unitea Kingdom...... 4,323,457 Canada../.........,.239,690 * France......... 227,420 British India....... 69,627 Netherlands......... 68,240 Switzerland....,...* 44,388 * Belgium........... * 38,559 Japan«•*** *.*••**..• 341,535 China......... . 17,322 T Egypt*...... ....... 8,135 T Cuba....................... 6,544 Germany....,.... . 76,329 Italy........ 21,263 ft^-ALS .■*/*■*/— ' * — v ' 1,441,152 ‘ ‘ 75,807 22,747 -• ,14,796 l£,853 * — - -' 1 5,482,509 — — « ' W; ■' ' ~ «.» ■ ^4 ’ - ~ 25,443 7,088 ' " • 1,599,886 ----=----------------------- - Xj— Included in total imports,-column 2. 5/- The BreBident‘s proclamation, signed March 31, 1942, exempts from import - quota restrictions card strips made from cottons having a staple 1-3/16 inches or more in length. — OUCH* POE IMMEDIATE RELEASE, December 7. 1943. The Bureau of (histoms announced today that preliminary reports'from the collectors of customs fehov imports of cotton and cotton waste chargeable to the import quotas established ^y the President’.s proclamations of September 5, 1939 and December 19, 1940, as follows, during the.period September 20, 1943, to November 27, 1943s :' COTTON HAVING A STAPLE OP LESS THAN 1-11/l6 INCHES■(OTHER-THAN' HARSH OR HOUGH COTTON OF LESS THAN 3/4 INCH IN STAPLE.LENGTH AND CHIEFLY USED-IN THE' MANU FACTURE OF BLANKETS AND BLANKETING, AND OTHER THAN LINTERS);'" Annual quotas commencing September 20, by Countries of Origin*. (In Pounds) Country of Origin-1 • _ ___ _______ : Staple length less : Staple length 1-1/8" or more I________ than 1-1y 8 11 ■: but: less than 1-11/1611 * {Imports Sept*: Established - Imports Sept. :Established! 20, 1943, to l Qqota ; 20, 1943, to i Quota" {Nov, 27, 1943* 45.6fi6.42Q-r ffPV* S7,. I94g Egypt and the Anglo— Egyptian Sudan........ P e n n ........... ...... . • British India........... China.............. Mexico................. . Brazil.......... . Union of Soviet Socialist Republics... Argentina.......... . Haiti.. ........ . Ecuador........ ...... .. Honduras.... .......... . Paraguay. ................ Colombia................ IT°&C^, • • ^» • ••• *> ♦*<►♦■*•••# British East Africa..... Netherlands East Indies. Barbado s..............•• Other British West Indies l / ........... * Nigeria.,................ Other British West ■Africa j Other French Africa 2>/. Algeria and Tunisia..... 783,816 247,952 2,003,483 1,370,791 8,883,259 618,723 475,124 5,203 237 9,333 752 871 124 195 2,240 71,388 Z j --- 16,362,697 * 368,913 — . *•* — ** — ** — — ■- 21,321 5,377 — — . - — ** ** — - — m* 16,004 689 14,516,882 1j 73,576 *** V — h 8,883,259 410,330 — — ** m 9,367,165 ■ 45,656,420 .Other than Barbados, Bermuda, Jamaica, Trinidad, and Tobago. Other than Gold Coast and Nigeria. ..Other than Algeria, Tunisia, and Madagascar* (Over) 16,731,610 TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, Wednesday, December 8. 1943. Press Service No. 39-^82 The Bureau of Customs announced today that preliminary reports from collectors of customs show imports of cotton and cotton waste chargeable import quotas established by the President’s proclamations of September and December 19, 1940, as follows, during the period September 20, 1943, November 27, 19435 the to the 5, 1939, to COTTON HAVING- A STAPLE OF LESS THAN 1-11/1$ INCHES (OTHER THAN HARSH OR ROUGH COTTON OF LESS THAN 3/4 INCH IN STAPLE LENGTH AND CHIEFLY USED IN THE MANU FACTURE OF BLANKETS AND BLANKETING, AND OTHER THAN LIFTERS). Annual quotas commencing September 20, by Countries of Origin? ______ ____________________(jn Pounds) ________ 1 ■ : Staple length less : Staple length 1-1/8” or more 5 _____ than 1-1/8” : but less than 1-11/16”____ _ Country of : :Imports Sept.: Established : Imports Sept. Origin :Established:20, 1943, to ♦ Quota ' 20, 1943, to ___________ _____________ ? Quota :Nov. 27, 1943: 45,656,420 : Nov, 27, 1943 Egypt and the Anglo^Egyptian Sudan*....... P e r u . t.,. British India. China..........'. Mexico,................ Brazil............y#* Union of Soviet Socialist Republics... Argentina............ . Haiti, Ecuador,................. Honduras. Paraguay. Colombia. Iraq.................... British East Africa..... Netherlands last Indies. Barbados............... * Other British West Indies 1/............. Nigeria, Other British West Africa 2/............, Other French Africa 3/.. Algeria and Tunisia..,.. .783,816 247,952 2,003,483 1,370,791 8,883,259 618,723 73,576 7* 8,883,259 410,330 16,362,697 368,913 - 475,124 5,203 237 9,33? 752 871 124 195 2,240 71,388 . *r - r — — — — - T* T* *r T■1* ** ' 21,321 5,377 - — 16,004 689 — 14,516,882 — -r 9,367,165 — — — 16,731,610 45,656,420 1/ Other than Barbados, Bermuda, Jamaica, Trinidad, and Tobago. 2/ 3/ Other than Gold Coast and Nigeria, Other than Algeria, Tunisia, and Madagascar. - 2 - COTTON CARD STRIPS, 2/ COMBER WASTE, LAP WASTE, SLIVER WASTE, AND ROVING WASTE, WHETHER OR NOT.MANUFACTURED OR OTHERWISE ADVANCED IN VALUE. Animal quotas commencing September 20, by Countries of Origin: Total quota, provided, however, that not more than 33-1/3 percent of the quotas shall be filled by cotton wastes other than card strips 2 ] and comber wastes made from cottons of 1-3/16 inches or more in staple length in the case of the following countries* United Kingdom, France, Netherlands, Switzerland, Be Ig ium, Ge rmany and 11 aly ? (In Pounds) • f :TOTAL IMPORTS :ESTABLISHED: Imports Sept, 20, Country of Origin : Established :Sept. 20, 1943 *33-1/3^ of ?1943, to * TOTAL QUOTA SNov. 37. 1943 :Total QuotaiNov. 27* 1943 , 1/ United Kingdom...... Canada.............. France Brit ish India; Netherlands..;....#* Switzerland. Belgium* Japan* China...*;....... *.* Egypt, .. .......... Cuba, *■» * Germany..,,».«...*.. Italy,**, ..«•« *•*« *'.«* 4,323,457 239*690 227*420 69|627 68,240 44,388 38,559 341*535 17,322 8,135 6,544 76,329 21,263 — rr ■j *«* r - 5,482,509 1,441,152 *** 75,807 22,747 14,.79 6 12,.853 •r •r 25,443 7,088 1,599,886 ** r * * 4 - - 1/ Included in total imports, column 2. 2/ The President *s proclamation* signed March 31,' 1942, exempts from import quota restrictions card strips made from cottons having a staple 1-3/16 inches or more in length. voOof - Commodity Silver or "black foxes, furs, and articles* Foxes valued under $250 each and whole furs and skins Tails 2 - *Imports as of • Unit • of :Nov. 27, : s Established Quota *Period and Country * Quantity: Quantity: 1943 Period * May — Nov. 1943 All countries 33,229 12 months from Dec* 1, 1942 5,000 Number Piece Paws, heads, or other separated parts n 500 Pounds Piece plates it 550 Pounds It 500 Unit Articles, other than piece plates **oOo*w ( Quota. filled) 463 (Qiota filled) - 105 FOR IMMEDIATE RELEASE, December 7* 1943« The Bureau of Customs announced today preliminary figures for imports of commodities within quota limitations provided for under trade agreements, from the beginning of the quota periods to November 27, 1943, inclusive, as follows; Commodity ♦ • Established Quota : « Quantity tPeriod and Country! i J t 5 Unit :Imports as of ; Nov. 27, of 1943 Quantity : Whole milk, fresh or sour Calendar year 3,000,000 Gallon 6,566 Cream, fresh or spur Calendar year 1,500,000 Gallon 844 Fish, fresh or frozen, filleted, etc*, cod, haddock, hake, pollock, cusk and rosefish Calendar year 17,804,128 White or Irish potatoes! certified seed Other 12 months from Sept* 15, 1943 Red cedar shingles Calendar year 90.000. 60.000. 2,506,072 Cuban filler tobacco, unstemmed or stemmed (other than cigarette leaf tobacco), and scrap tobacco Calendar year 22,000,000 Molasses and sugar sirups containing soluble nonsugar solids equal to more than 6$ of total soluble solids Calendar year 1,500*000 Pound 14,828,350 000 Pound 000 Pound 14,303,720 3,158*658 Square Pound (unstemmed equivalent) Gallon 1,339,824 (Quota filled) 310,055 TREASURE DEPARTMENT Washington FOR IMMEDIATE RELEASE, Wednesday, December •8 1 9 4 3 * .. Press Service ■' jj0> 3 9 - 8 3 The Bureau of Customs announced today preliminary figures for imports Of commodities within quota limitations provided for under trade agreements, from the beginning of the quota periods to November 27, -1943, inclusive, as follows: Commodity '■»' '-’ Unit :Imports as i : Established Quota ; of : Nov. 27, :Period and Country ; Quantity : ■ Quantity 1943 ; Whole milk, fresh or sour Cream;.fresh or sour Fishjr fresh or frozen, filleted, etc., cod, haddock, hake, pollock, cusk and .rosef ish White or Irish potatoes; certified seed Other Red cedar shingles Calendar year 3,000,000 Gallon •~ Calendar year 1,500,000 Gallon Calendar year 17,804,128 ' 6*,566 •'•r' 844 Pound 14,828,350 000 Pound 000 Pound 14,303,720 3,158,658 .1.2 months from Sept. 15, 1943 90.000. 60.000. Calendar year Cuban filler tobacco, unstemmed or stemmed (other than cigarette leaf tobacco), and scrap tobacco Calendar year Molasses and sugar sirups containing soluble nonsugar solids eaual to more than Qfo of total soluble solids • Calendar year 2,506,073 Square Pound (unstemmed 22,000,000 equivalent) (Over) 1,500,000 Gallon 1,339,824 (Quota filled) 310,055 p : : Unit : Imports as of Commodity; . -•£ Established Quota * of . *( .•.Uov. 27, *--*• ■vr,,v.;v }.Pe.Tiod and Country: Quantity; Quantity : 1943 SiIvey or hlack .j,•- •v: r i;M ‘■ ■ foxss, 'furs,' and apt iclesi ,.. ftp Poxes valued u n d e r ;$250 each . Period - ’May v and #hoie furs Nov, 1943 and- skins: ;.'-V 'All countries 33,229 12 months f rom Dec. 1, 1942 5,000 Piece f- 500 Pounds 550 Pounds Tails * .... ‘ Paws, heads, or ether separated varts ti piece plates it Articles, other than piece plates...... nr ; . . 500 Number Unit (Qpota filled) 463 : (Qpota filled) % & d m f " : - 105 1942, and April 29* 1943* for the 12 months commencing May 29, 1943, as follows: | i * • Country of Origin • 2Wheat flour* semolina, crushed :or cracked wheat, and similar 2 : wheat products 2 Imports 2 Imports X x 2 *Established:May 29* 1943 2EstablishedtMay 29, 1943 • * Quota I to Nov. .27. 1943 Quota :to Nov. 27. iL943: (Pounds) (Pounds) (Bushels) (Bushels) WHEAT 795,000 Canada *» China Hungary «* Hong Hong Japan 100 United Kingdom Australia 100 Germany 100 Syria Hew Zealand ** Chile 100 Netherlands 2,000 Argentina 100 Italy mm Cuba 1,000 France • Greece 100 Mexico Panama Uruguay mm Poland and Danzig <m Sweden Yugo slavia • Norway m Canary Islands 1*000 Humania 100 Guatemala 100 Brazil Union of Soviet Socialist Republics 100 100 Belgium 800,000 795*000 mm *• mm mm m « mm mm «H» «9 * mm mm mm 4Hi / • mm nm mm 3,815*000 24,000 13,000 13,000 8,000 75*000 1,000 5,000 5,000 1,000 1,000 1,000 14,000 2,000 12,000 1,000 1,000 1,000 1*000 1,000 1,000 1,000 * 1,000 1*000 1,000 — 196*840 • «*» *» — — mm « — mm mm — — . ~ mm mm «w ** mm mm mm mm mm ** • - 795,000 4*000,000 ■ ** * -oOo- mm m 196*840 __ — TREASI&? DEPARTMENT Washington immediate r e l e a s e , Wednesday, December 8, 1943. Press Service No. 39-84 for The Bureau of Customs announced today preliminary figures showing the quantities of wheat and wheat flour entered, or withdrawn from warehouse, for consumption under the import quotas established in the Presidents proclamation of May 28, 1941, as modified by the President’s proclamations of April 13, 1942, and April 29, 1943, for the 12 months commencing May 29, 1943, as follows? WHEAT Country of Origin Wheat flour, semolina, crushed or cracked wheat, and similar wheat products ■ ' . imports • : Imports Established:May 29, 1943 Established : May 29, 1943 ? to Nov. 27, 1943 Qpota Quota :to Nov, 27,1943 (Bushels) (pounds) (Pounds) (Bushels) 795,000 Canada China Hungary — Hong Kong Japan 100 United Kingdom Australia 100 Germany 100 Syria New Zealand Chile 100 Netherlands 2,000 Argentina 100 Italy Cuba 1,000 France Greece 100 Mexico Panama Uruguay -T Poland and Danzig Sweden Yugoslavia Norway -r Canary Islands 1,000 Rumania 100 Guatemala 100 Brazil Union of Soviet Socialist Republics 100 100 Belgium 795,000 — 800,000 795,000 *r ISj§ V - * T —■ r* —. 3,815,000 24,000 13t000 13,000 8,000 75,000 1,000 5,000 5,000 1,000 1,000 1,000 14,000 2,000 12,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 196,840 T — ** - r rr r* - — — A — — — — 4,000,000 196,840 *9* FOR IMMEDIATE RELEASE, December 7. 1943. 2Jhe Bureau of Customs announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1, 1943, provided for in the Inter*** American Coffee Agreement* proclaimed by the President on April 15, 1941, as follows l Country of Production * • S l Quota Qjaantity (Pounds) 2 j § f • ♦ ? i t Authorized for entry for consumption As of (Date) : (Pounds) Signatory Countries? Brazil Colombia Costa Rica Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela 1,353,183,480 458,336,340 29,100,720 11,640,288 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 lov* 27, 1943 tt a ff 180,402,035 83,342,496 1,696,911 1,716,157 2,664,122 7,341,998 938,025 2,510,843 1,379,318 460,324 9,362,423 500,406 307,300 4,850,381 ft 1,991,173 tt w tt ft t< f! ft ff ff ii Ron-signatory Countries? 51,653,778 1/ Quotas as established by action of the Inter-American Coffee Board on March 11, 1943* -oOo- TREASURY- DEPARTMENT Washington FOR IMMEDIATE RELEASE, Wednesday, December 8, 1943* Press Service No. 39-85 The Bureau of Customs announced today preliminaiy figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1, 1943, provided for in the InterAnerican Coffee Agreement, proclaimed by the President on April 15, 1941, as follows: Country of Production : : Quota Quantity :: Authorized for entry (Pounds) 1/ : for consumption : As of (Date) : (pounds) Signatory Countries: Brazil Colombia Costa Rica Cuba Pominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela Non-signatory Countries: 1/ 1,353,183,480 458,336,340 29,100,720 11,640,288 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 51,653,778 Npv. 27, 1943 tt il it it n ii it n it it n it it it 180,402,035 83,342,496 1,696,911 1,716,157 2,664,122 7,341,998 938,025 2,510,843 1,379,318 460,324 9,362,423 500,406 307,300 4,850,381 1,991,173 Quotas as established by action of the Inter-American Coffee Board on March 11, 1943. - A - result of a self-imposed rationing system inaugurated by distillers, combined ■with an order of the War Production Board restricting the use of bottles to 65 percent of the number used in certain base periods of 1942* ’’This reduction in withdrawals, together with increased purchasing power of the public, has created a large shortage of liquor, and has resulted in black market prices and the hoarding of stocks by some wholesalers and re tailers, and, to some extent, by preferred consumer customers. "This Unit has been conducting an extensive survey of the black market conditions, which has disclosed numerous violations of Internal Revenue laws and price ceiling violations on the part of wholesalers and retailers. These investigations are resulting in the seizure of liquors, the arrest of violators, the reporting of cases to United States Attorneys for prosecution, and the institution of proceedings to annul or revoke permits of wholesalers.” He said a survey ty the Unit indicated the bottle scarcity might be alleviated to considerable extent if bottlers shifted to quart packages instead of the various sizes used heretofore. 0O 0 - 3 - contain little or no Juniper flavoring — for gin under the standards of identity — product was made from inferior spirits. the essential flavoring material and that in many instances the The Bureau of Gustoms has been asked to withhold release of imported gin products until samples have been examined in Treasuiy laboratories. Similar difficulties have developed in connection with some ^whiskies’* in the import trade, and the Unit is withholding action on label applications until samples are analyzed. The so-called whiskies in some cases have been found to be cane spirits and flavoring, often bearing little resemblance to whisl^’. Steps are being taken to require age statements on products that are found to be whisljjr. Mr. Berkshire said the Unit would enforce the labelling regulations stringently on these imports, as the quality of much of the product examined is so inferior as to cause adverse consumer reaction. Recent weeks have seen several substantial seizures and arrests in connection with ^cutting* and bottling operations in New York, Pennsylvania, and New Jersey, with some cases also involving counterfeit revenue stamps and labels. This traffic in adulterated end mislabelled liquors constituted a serious enforcement problem/in prohibition days and in the early years following repeal. The isolated seizures of this type in November were the *yr\fryuis first of importance inyponths. it rate of approximately 65 percent of withdrawals during 1 9 ^ . This is the Failure of wholesalers to keep required Records of sa3.es and falsifi cation of these records have been among the most numerous violations discovered. The agents have been interested particularly in tracing large unit sales which might indicate a diversion into black market channels. Proceedings looking to revocation of permits to do business are being instituted in cases where regulations have been violated. Prosecutions for failure to obtain retail permits also are being instituted against some p e d d l e r s * o p e r a t i n g outside regular trade channels. Mr. Berkshire emphasized that the Alcohol Tax Unrt^s particular concern is the administering of the revenue laws as applied to alcoholic beverages and the maintenance of fair trade practices. In the revenue field, the drive against illicit distilling brought seizures of 507 stills in a four weeks1 period, an increase of 46 percent over the same four weeks last year when *5noonshining!*''was at the lowest level since the repeal of national prohibition. The amount of mash seized at these stills increased 106 percent over the 1942 period, indicating some increase i n the size of the plants captured. Sugar rationing and other war factors have helped to keep illicit distilling at extremely low levels despite the high level of federal taxes and the shortage of tax-paid liquor. The southeast Atlantic states continue to provide the bulk of still seizures, with a tendency in recent months toward an increase in such viola tions, compared with the autumn of 1942* Agents are giving close scrutiny to imports of gin from Cuba and Mexico. Mr. Berkshire said that it has been found that many such shipments of gin TO i Mr.Easton what do you "think of the wisdom of taking- some of the w r a p s off our activities against the liquor black market? I will clear with Revenue, of course. Mr,Berkshire goes up before the Van ¥uys committee on Friday,but plans to be available lust for questioning, without making a formal statement. Could we release some of this before the hearings? Coffelt Mr. Schwarz 31' Striking at the so-called Black Market in liquor r invoking Internal Revenue regulations set up to ^nsure fair trade practices in the industry, the Treasury’s Alcohol Tax Unit is conducting a nationwide investigation which hspB* result in numerous civil and criminal cases against violators^, it was revealed today* The Unit also moved vigorously against what has the appearance of an incipient mild revival of *^oonshiqSjig*^ and has ^Stepped ori* several isolated •butting* and false-labelling conspiracies. Bureau of Customs, the Unit has acted to halt Working with the importation of synthetic and substandard spirits where misClabelling is involved. The *fair trade*investigation, which is continuing, constitutes a new approach to the problems resulting from shortage of distilled spirits result ing from wartime conditions. Stewart Berkshire, head of the Alcohol Tax Unit of the Bureau of Internal Revenue, pointed out that violations of rationing orders primarily are a responsibility of state or local liquor control boards, and that vio lations of price ceilings primarily are matters for the Office of Price Adminis t rati on• However, a widespread probe many cases by Alcohol Tax agents has shown that in corollary violations of Internal Revenue laws and regulations have occi(re^which are subject to federal prosecution, or civil action. Unit is cooperating with the other agencies -where violations outside its immediate jurisdiction are uncovered The TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, F r i d a y , D e c e m b e r 10, 1 9 4 3 * 12-9-43 : Striking at the so-called Black Market Internal Revenue regulations insure fair t rade practices hol T a x U n i t resulting it w a s is Press Service No. 3 9 - 8 6 invoking set up to p r o t e c t t h e r e v e n u e an d in t h e industry, conducting a nationwide in n u m e r o u s in l i q u o r b y civil and criminal the Treasury*s A l c o investigation which cases against is violators, r e v e a l e d today, T h e U n i t also m o v e d v i g o r o u s l y a g a i n s t w h a t has t h e a p p e a r a n c e o f a n i n c i p i e n t m i l d r e v i v a l of m o o n s h i n i n g , a n d h a s s t e p p e d on s e v e r a l i s o l a t e d c u t t i n g a n d f a l s e - l a b e l l i n g c o n s p i r a c i e s * W o r k i n g w i t h t h e B u r e a u of Customs, t h e U n i t has a c t e d to h a l t i m p o r t a t i o n of s y n t h e t i c a n d s u b s t a n d a r d s p i r i t s w h e r e m i s l a b e l ling is i n v o l v e d . T h e f a i r t r a d e i n v e s t i g a t i o n , w h i c h is c o n t i n u i n g , c o n s t i tutes a n e w a p p r o a c h t o t h e p r o b l e m s r e s u l t i n g f r o m s h o r t a g e of distilled spirits resulting f r o m wartime conditions. S t e w a r t B e r k s h i r e , h e a d o f t h e A l c o h o l T a x U n i t of t h e Bureau of Internal Revenue, p o i n t e d out t hat v i o l a t i o n s of r a t i o n ing o r d e r s p r i m a r i l y a r e a r e s p o n s i b i l i t y o f s t a t e o r l o c a l l i q u o r control boards, a n d t h a t v i o l a t i o n s of p r i c e c e i l i n g s p r i m a r i l y are m a t t e r s f o r t h e O f f i c e o f P r i c e A d m i n i s t r a t i o n . , !. However, a w i d e s p r e a d probe b y A l c o h o l T a x agents has shown that in m a n y c a s e s c o r o l l a r y v i o l a t i o n s o f I n t e r n a l R e v e n u e l a w s and r e g u l a t i o n s h a v e o c c u r r e d w h i c h a r e s u b j e c t t o F e d e r a l p r o s e cution o r c i v i l a c t i o n . T h e U n i t is c o o p e r a t i n g w i t h t h e o t h e r a g e n c i e s w h e r e v i o l a t i o n s o u t s i d e its i m m e d i a t e j u r i s d i c t i o n a r e uncovered. F a i l u r e of w h o l e s a l e r s t o k e e p r e q u i r e d r e c o r d s o f s a l e s a n d falsification of t h e s e r e c o r d s h a v e been am o n g the most n u m e r o u s violations discovered. The agents have been interested p a r t i c u larly in t r a c i n g l a r g e u n i t s a l e s w h i c h m i g h t i n d i c a t e a d i v e r sion i n t o b l a c k m a r k e t c h a n n e l s ^ Proceedings looking to r e v o c a tion of p e r m i t s t o do b u s i n e s s a r e b e i n g i n s t i t u t e d in c a s e s 2 where regulations have been violated. Prosecutions for failure to obtain retail permits also are being instituted against some ped dlers operating outside regular trade channels. '&*• B e r k s h i r e e m p h a s i z e d t h a t t h e A l c o h o l T a x U n i t fs p a r t i c u l a r c o n c e r n is t h e a d m i n i s t e r i n g o f t h e r e v e n u e l a w s as a p p l i e d to a l c o h o l i c b e v e r a g e s a n d t h e m a i n t e n a n c e of f a i r t r a d e p r a c t i c e s . In the revenue field, the drive against illicit distilling brought seizures of 507 stills in a four weeks’ period, an in crease of 46 percent over the same four weeks last year when moonshining was at the lowest level since the repeal of national pro hibition. The amount of mash seized at these stills increased 106 percent over the 1942 period, indicating some increase in the size of the plants captured. Sugar rationing and other war factors have helped to keep illicit distilling at extremely low levels despite the high-level of Federal taxes and the shortage of taxpaid liquor. The southeast Atlantic continue to provide the bulk of s t i l l s e i z u r e s , w i t h a t a n i e n c y ih r e c e n t m o n t h s t o w a r d a n i n c r e a s e in s u c h v i o l a t i o n s , w i t h t h e a u t u m n of 1942, A g e n t s a r e g i v i n g c l o s e s c r u t in y t o i m p o r t s of g i n f r o m C u b a and Mexico. Mr, B e r k s h i r e s a i d t h a t it h a s b e e n f o u n d t h a t m a n y s u c h s h i p m e n t s of g i n c o n t a i n l i t t l e o r n o J u n i p e r f l a v o r i n g -the e s s e n t i a l f l a v o r i n g m a t e r i a l f o r g i n u n d e r t h e s t a n d a r d s of' i d e n t i t y -- a n d t h a t in m a n y i n s t a n c e s t h e p r o d u c t w a s m a d e f r o m inferior spirits. T h e B u r e a u of C u s t o m s h a s b e e n a s k e d t o w i t h hold r e l e a s e of i m p orted gin p r o d u c t s u n t i l samples h a v e b een examined in T r e a s u r y l a b o r a t o r i e s . S i m i l a r d i f f i c u l t i e s h a v e d e v e l o p e d in c o n n e c t i o n w i t h s o m e " w h i s k i e s 11 in t h e i m p o r t t r a d e , a n d t h e U n i t is w i t h h o l d i n g a c t i o n on l a b e l a p p l i c a t i o n s u n t i l s a m p l e s a r e a n a l y z e d . The so-called w h i s k i e s in s o m e c a s e s h a v e b e e n f o u n d t o b e c a n e s p i r i t s a n d flavoring, often b e a r i n g l i t t l e r e s e m b l a n c e to w h i skey. Steps are b e ing t a k e n t o r e q u i r e a g e s t a t e m e n t s on p r o d u c t s t h a t a r e f o u n d to b e whisk;ey. Mr*. B e r k s h i r e s a i d t h e U n i t w o u l d e n f o r c e t h e l a b e l l i n g r e g u l a t i o n s s t r i n g e n t l y on t h e s e i m p o r t s , as t h e q u a l i t y o f m u c h of the p r o d u c t e x a m i n e d is s o i n f e r i o r as t o c a u s e a d v e r s e c o n s u m e r reaction. Recent weeks have seen several substantial seizures and arrests in connection with cutting and bottling operations in Rew York, Pennsylvania, and Rew Jersey, with some cases also involving counterfeit revenue stamps and labels. This traffic in adulterated ** J :m and m i s l a b e l l e d liquors constituted a serious enforcement probl e m in p r o h i b i t i o n d a y s a n d in t h e e a r l y y e a r s f o l l o w i n g r e p e a l f T h e i s o l a t e d s e i z u r e s of t h i s t y p e in N o v e m b e r w e r e t h e f i r s t of i m p o r t a n c e in m a n y months. As to the g e n e r a l liquor situation, Mr* Berkshire said* ’’W i t h d r a w a l s o f d i s t i l l e d s p i r i t s f r o m b o n d f o r c o n s u m p t i o n f o r t h e p a s t s i x m o n t h s a r e at t h e r a t e o f a p p r o x i m a t e l y 65 p e r cent of w i t h d r a w a l s d u r i n g 1942* T h i s is t h e r e s u l t of a s e l f imposed rationing system inaugurated by distillers, combined w i t h a n o r d e r o f t h e W a r P r o d u c t i o n B o a r d r e s t r i c t i n g t h e u s e of b o t t l e s to 65 p e r c e n t o f t h e n u m b e r u s e d in c e r t a i n b a s e p e r i o d s of 1 9 4 2 . ’’T h i s r e d u c t i o n in w i t h d r a w a l s , t o g e t h e r w i t h i n c r e a s e d p u r c h a s i n g p o w e r o f t h e p u b l i c , h a s c r e a t e d a l a r g e s h o r t a g e of l i q u o r , a n d has r e s u l t e d in b l a c k m a r k e t p r i c e s a n d t h e h o a r d i n g ' of s t o c k s b y s o m e w h o l e s a l e r s a n d r e t a i l e r s , a nd, to s o m e extent, by p r e f e r r e d c o n s u m e r custo m e r s . ’’T h i s U n i t h a s b e e n c o n d u c t i n g a n e x t e n s i v e s u r v e y o f t h e black m a r k e t conditions, w h i c h has d i s c l o s e d num e r o u s v iolations of I n t e r n a l R e v e n u e laws a n d p r i c e c e i l i n g v i o l a t i o n s on the part of wholesalers and retailers, These investigations are r e s u l t i n g in t h e s e i z u r e o f l i q u o r s the arrest of violators, t h e r e p o r t i n g o f c a s e s t o U n i t e d S t a t e s Attornej^s f o r p r o s e c u tion, a n d t h e i n s t i t u t i o n o f p r o c e e d i n g s t o a n n u l o r r e v o k e p e r mits of w h o l e s a l e r s . ” He said a s u rvey by the U n i t indicated the bottle scarcity m i g h t b e a l l e v i a t e d t o c o n s i d e r a b l e e x t e n t if b o t t l e r s s h i f t e d to q u a r t p a c k a g e s i n s t e a d o f t h e v a r i o u s s i z e s u s e d h e r e t o f o r e . -0O 0- for such bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemntion at maturity during the taxable year for which the return is made, as •rdinary gain or loss. Treasury Department Circular No* 41&, as amended, and this notice, pre scribe the terms of the Treasury bills and govern the conditions of their issue. Copies of the circular may be obtained from any Federal Reserve Bank or Branch. Reserve Banks and Branches, following which public announcement will be made by the Secretary of the Treasury of the amount and urice range of accepted bids. Those submitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury exoressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final.] Subject to these reservations, tenders for $100,000 or less from any one bidder at I 99.905 entered on a fixed-price basis will be accepted in full. Payment of accepted tenders at the prices offered must be made or completed at the Federal Reserve Bank in cash or other immediately available funds on December l o , 1943 --------- ( T T ^ The income derived from Treasury bills, whether interest or gain from the sale or other disposition of the bills, shall not have any exemption, as such, and loss from the sale or other disoosition of Treasury bills shall not have any special treatment, as such, under Federal tax Acts now or hereafter enacted. The bills shall be subject to estate, inheritance, gift, ot other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority. For purposes of taxation the amount of discount at which Treasury bills are originally sold by the United States shall be considered to be interest. Under Sections 42 and 117 (a) (l) of the Internal Revenue Code, as amended by Section 115 of the Revenue Act of 1941* the amount of discount at which bills issued hereunder are sold shall not be considered to accrue until such bills shall be sold, redeemed or otherwise disposed of, and such bills are excluded from consideration as capital assets. Accordingly, the owner of Treasury bills (other than life insurance companies) issued hereunder need include in his income tax return only the difference between the price paid K$MX TREASURY -DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Friday, December 10, 1943 « The Secretary of the Treasury, by this public notice, invites tenders for $1,000,000,000- , or thereabouts, of 91 -day Treasury bills, to be issued on a discount basis under competitive and fixed—price bidding as hereinafter pro vided, The bills of this series will be dated March mature interest. 16, 1944 December 16, 1943 and will > when the face amount will be payable without 5S£ They will be issued in bearer form only, and in denominations of $1,000, $5,000, $10,000, $100,000, $ 500,000 , and $1,000,000 (maturity value). Tenders will be received at Federal Reserve Banks and Branches up to the closing hour, two o ’clock t>. m., Eastern War time, Monday, December 13, 1943— Tenders will, not be received at the Treasury Department, Washington. • Each tender must be for an even multiple of $1,000, and the price offered must be expressed on the basis of 100, with not.more than three decimals, e. g., 99.925. may not be used. Fractions It is urged that tenders be made on the printed forms and for warded in the special envelopes which will be supplied by Federal Reserve Banks or Branches on application therefor. Tenders will be received without deposit from incorporated banks and trust companies and from responsible and recognized dealers in investment securi ties. Tenders from others must be accompanied by payment of 2 percent rf the face amount of Treasury bills applied for, unless the tenders are accompanied by an express guaranty of payment by an incorporated bank or trust company. Immediately after the closing hour, tenders will be opened at the Federal TREASURY DEPARTMENT Washington F O R R E L E A S E , MORNING- N E W S P A P E R S , F r i d a y , D e c e m b e r IQ, 1943*______ 12-9-43 The Secretary of the Treasury, by this public notice, invites tenders for $1,000,000,000, or thereabouts, of 91-day Treasury bills, to.be issued on a discount basis under competi tive and fixed-price bidding as hereinafter provided. The bills of this series will be dated December 16, 1943, and will mature March 16, 1944, when the face amount will be payable without interest. They will be issued in bearer form only, and in denom- inations of $1,000,'$5,000, $10,000, $100,000, $500,000, and ■$1,000,000 (maturity value). Tenders will be received at Federal Reserve Banks and Branches up to the closing hour, two o ’clock p. m., Eastern War time, Monday, December l3» 1943* Tenders will not be received at the Treasury Department, Washington; Each tender must be for an even multiple of $l;000, and the price offered must be ex pressed on the basis of' 100, with not more than three decimals, e. g., 99.925. Fractions may not be used. It is urged that tenders be made on the printed forms and forwarded in the spe cial envelopes which will be supplied by Federal Reserve Banks or Branches on application therefor. Tenders will be received without deposit from incorporated banks and trust companies and from responsible and recognized dealers in investment securities. Tenders from others must be accompanied by payment of 2 percent of the face amount of Trea sury bills applied for, unless the tenders are accompanied by an express guaranty of payment by an incorporated bank or trust company. Immediately after the closing hour, tenders will be opened at the Federal Reserve Banks and Branches, following which pub lic announcement will be made by the Secretary of the Treasury of the amount and price range of accepted bids. Those sub-^ mitting tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final. 39-87 (Over) 2 S u b j e c t t o t h e s e r e s e r v a t i o n s , t e n d e r s f o r $ 1 0 0 , 0 0 0 or l e s s f r o m a n y o n e b i d d e r a t 9 9 * 9 0 5 e n t e r e d on a f i x e d - p r i c e b a s i s w i l l be a c c e p t e d in f u l l . P a y m e n t of a c c e p t e d t e n d e r s a t t h e p r i c e s o f f e r e d m u s t b e ' m a d e -or c o m p l e t e d a t t h e F e d e r a l R e s e r v e B a n k in c a s h o r o t h e r i m m e d i a t e l y a v a i l a b l e f u n d s on D e c e m b e r 16, 1943* s* » T h e i n c o m e d e r i v e d f r o m T r e a s u r y b i l l s , w h e t h e r i n t e r e s t or g a i n f r o m t h e s a l e d r o t h e r . ' d i s p o s i t i o n o f t h e b i l l s , s h a l l not h a v e a n y e x e m p t i o n , a s such, a n d l o s s f r o m t h e s a l e o r o t h e r d i s p o s i t i o n of T r e a s u r y b i l l s s h a l l n o t h a v e a n y s p e c i a l t r e a t m e nt, a s such, u n d e r F e d e r a l t a x A c t s n o w o r h e r e a f t e r enacted. T h e b i l l s s h a l l b e s u b j e c t t o est a t e , i n h e r i t a n c e , g i f t , or other exc i s e taxes, w h e t h e r F e d e r a l or State, but s h a l l be exempt from a l l t a x a t i o n n o w o r h e r e a f t e r i m p o s e d on t h e p r i n c i p a l o r i n t e r est t h e r e o f b y a n y S t a t e , o r a n y o f t h e p o s s e s s i o n s o f t h e U n i t e d S t a t e s , or b y a n y vl o c a l t a x i n g a u t h o r i t y . F o r p u r p o s e s of t a x a t i o n t h e a m o u n t ofv d i s c o u n t a t w h i c h T r e a s u r y b i l l s a r e ori g i n a l l y sold b y the U n i t e d States shall b e c o n s i d e r e d to be interest. U n d e r S e c t i o n s 42 a n d 1 1 1 (a) (1) O f t h e I n t e r n a l R e v e n u e Code, as a m e n d e d b y S e c t i o n 1 1 5 o f t h e R e v e n u e A c t o f 1941, t h e a m o u n t of d i s c o u n t a t w h i c h b i l l s i s s u e d h e r e u n d e r a r e s o l d s h a l l n o t be c o n s i d e r e d t o a c c r u e u n t i l s u c h b i l l s s h a l l b e sold, r e d e e m e d or o t h e r w i s e d i s p o s e d of, a n d s u c h b i l l s a r e e x c l u d e d f r o m c o n s i d e r a t i o n as c a p i t a l a s s e t s . A c c o r d i n g l y , t h e o w n e r of T r e a s u r y b i l l s ( o t h e r t h a n l i f e i n s u r a n c e c o m p a n i e s ) i s s u e d h e r e u n d e r need i n c l u d e in h i s i n c o m e t a x r e t u r n o n l y t h e d i f f e r e n c e b e t w e e n the p r i c e p a i d f o r s u c h b i l l s , w h e t h e r on o r i g i n a l _i s s u e _o r on s u b s e q u e n t p u r c hase, a n d t h e a m o u n t a c t u a l l y r e c e i v e d eith e r upon sale, o r r e d e m p t i o n a t m a t u r i t y .during t h e t a x a b l e y e a r f o r w h i c h t h e r e t u r n is mad e , as o r d i n a r y g a i n o r l o s s , T r e a s u r y D e p a r t m e n t C i r c u l a r D o . 418, as a m e n d e d , a n d this n o t i c e , p r e s c r i b e t h e t e r m s o f t h e T r e a s u r y b i l l s a n d g o v e r n the conditions of their issue. C o p i e s of the c i r c u l a r m a y be o b t a i n e d f rom a n y F e d e r a l R e s e r v e B a n k or Branch, -oOo 'i TREASURY DEPARTMENT Washington F O R IM E D I A T E R E L E A S E , F r i d a y . D e c e m b e r 10. 1 9 4 3 . V i n c e n t P. Callahan, Press Service No. 3 9 - 8 8 radio executive and former n e w s paperman, today resigned and Radio of t h e W a r F i n a n c e D i v i s i o n Department. He leaves as D i r e c t o r of Advertising, Press of t h e T r e a s u r y the Tre a s u r y to return to private business. In 1 9 4 1 , the Defe n s e Mr. C a l l a h a n was Savings of a l l a d v e r t i s i n g , promotion of the During the Staff, press sale appointed Chief Later he was p l a c e d and radio in h i s t o r y . for in c h a r g e in c o n n e c t i o n w i t h t h e of W a r B o n d s . current year the W ar Bond ported with more than $100,000,000 worth advertising of R a d i o in a l l m e d i a , prog r a m was sup of contributed the greatest promotion campaign TEKASUBT DKPASmKT Washington Press Service FOB BEUSA3S, w m sm ®SS®3PAPKBS, Monday» December 13. 1943* ^Secretary of the Treasury Morgenthau announced today that all outstand ing >-l/4 percent Treasury Bonds of 1944-46 are called for redemption 0® April 1$, 1944. Approximately H , 519,©GO,000 of these bonds are now out standing* ^JPhe text of the formal notice of call is as follows 1 BOEDS o r 1944-44 EOTICE OF d H FOE .IBMgglQM To Holders of >4/4 percent Treasury Bonds of 1944-46, and Others Concerned* X* Public notice is hereby given that all outstanding 3-1/4 percent Treasury Bonds of 1944-46, dated April 16, 1934, are hereby called for redemption on April 1$, 1944, on *hieh date interest on such bonds will cease* 2* Holders of these bonds nay, in advance of the redemption date, ibe offered the privilege of exchanging all or any part of their called ibonds for other interest-bearing obligations of the United States, in jwhich event public notice will hereafter be given and an official circular |governing the exchange offering will be issued* 3. Full information regarding the presentation and surrender of the _ A * for cash redemption under this call will b# found in Departnent Circular 1C T 66, dated duly 2 1 , 1941* Henry Morgenthau, dr*, Secretary of the Treasury* tmsmrnm, Washington, December 13, 1943* TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Monday, December 13, 1943* 12-11^43 Press Service •No. 39-89 Secretary of the Treasury Morgenthau announced today that all outstanding 3-1/4 percent Treasury Bonds of 1 9 4 4 - 4 6 are called for redemption on April 15, 1944. Approximately $1,519,000,000 of these bonds are now outstanding. The text of the formal notice of call is as follows? THREE AND ONE-QUARTER PERCENT TREASURY BONDS OP 1 9 4 4 - 4 6 NOTICE OF CALL FOR REDEMPTION To holders of 3-1/4 percent Treasury Bonds of 1 9 4 4 - 4 6 , and Others Concerned: 1, Public notice is hereby given that all out standing 3-1/4 percent Treasury Bonds of 1 9 4 4 -4 6 , dated April 16, 1934, are hereby called for redemption on April 15, 1944, on which date interest on such bonds will cease, 2* Holders of these bonds may, in advance of the redemption date, be offered the privilege of exchanging all or any part of their called bonds for other interestbearing obligations of the United States, in which event public notice will hereafter be given and an official circular governing the exchange offering will be issuedf 3. Pull information regarding the presentation and surrender of the bonds for cash redemption under this call will be found in Department Circular No. 666, dated July 21, 1941. Henry Morgenthau, Jr,, Secretary of the Treasury, . v •* ,■ , TREASURY DEPARTMENT, Washington, December 13, 1943. -0O 0- TREASURY DSPART1CTT Washington FOE RELEASE, MORS DIG NMSP A P K R S , Tuesday. December 16« 1943» Pr® 8® Service The Secretary of the Treasury announced last evening that the tenders for $ 1 ,0 0 0 ,0 0 0 , OCX), or thereabouts, of 91-day Treasury bills to b e dated December 16, 1943, and to mature March 16, 1946, which were offered on December 10, w ere op en ed at the Federal Reserve Banks on December 13. The details of this Issue are as follows: Total applied for - #1,816,956,000 Total accepted - 1,000,179,OCX) Average price (includes $65,767,000 entered on a fixedprice basis at 99.905 and accepted in full) - 99.905^Squivalent rate of discount approx. 0.375* P«r annum Range of accepted competitive bide: »igh L ciT - 99.925 Equivalent rate of discount approx. 0.297* per annua - 99.905 * * » « « 0.376* « ** (66 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for TfetaX Accented Boston Few York Philadelphia Cleveland fticbiRond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco $ $ 15,915,000 1 ,2 2 1 ,238,000 TGTA: w , 3 m ,o o o 605 ,210,000 54,467,000 58 ,400,000 22,364,000 18,418,OCX) 19 0 ,2 5 1,0 0 0 33,455,000 5,788,000 3 5 ,618 ,0 0 0 1 9 ,860,000 13 9 ,18 0 ,0 0 0 33,907,000 52,163, OuQ 1 9 ,475,000 12,660,000 114,543,000 20,490,000 5,724,000 26,978,000 13,982,000 84.667.000 31,814,954,000 n,000,179,000 TREASURY DEPARTMSRT Washington FOR RELEASE, MORNING NaTSPAPEBS, Tuesday. December lit. 19A3._____ Press Senrice ?o The Secretary of the Treasury announced last evening that the tenders for II ,000,300,000, or thereabouts, of 91-day Treasury bills to be dated December 16, 1943, and to mature March 16, 1944, which were offered on December 10, were opened at the Federal Reserve Banks on December 13* The details of this issue are as follows: Total applied for - $1,814,954,000 Total accepted - 1,000,179,000 Average price (includes 165,767,000 entered on a fixedprice basis at 99*905 and accepted in full) - 99. 905/ Equivalent rate of discount approx. 0.375$ per annum Range of accepted competitive bids: High Low - 99*925 Equivalent rate of discount approx. 0.297$ per annum - 99.905 * * * * • 0.376$ » " (46 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston Sew York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco 9 9 91,814,954,000 91,000,179,000 15,915,000 1,221,238,000 54,467,000 58,400,000 22,364,000 18,418,000 190,251,000 33,455,000 5,788,000 35,618,000 19,860,000 139.180.000 TOTA; 10,380,000 605,210,000 33,907,000 52,163,000 19,475,000 12,660,000 114,543,000 20,490,000 5,724,000 26,978,000 13,982,000 81,667.000 TREASURY DEPARTMENT Washington FOR RELEASE, MORNING- NEWSPAPERS, Tuesday, December 14, 1943* 12-13-43 Press Service No, 39-90 The Secretary of the Treasury announced last evening that the tenders for $1,000,000,000, or thereabouts, of 91~day Treas ury bills to be dated December 16, 1943, and to mature March 16, 1 9 4 4 , which were offered on December 10, were opened at the Fed eral Reserve Banks on December 13* The details of this issue are as follows; Total applied for - $1,814,954,000 Total accepted - 1,000,179,000 (includes $65,767,000 entered on a fixed-price basis at 99f905 and accepted in full) Average price - 99*905/Equivalent rate of discount approx 0*375?? per annum Range of accepted competitive bids: High Low - 99*925 Equivalent rate of discount approx 0.297?? per annum - 99*905 Equivalent rate of discount approx 0.376% per annum (46 percent of the amount bid for at the low price was accepted) Federal Reserve District Total Applied for Total Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St> Louis Minneapolis Kansas City Dallas San Francisco 1 $ TOTAL 15,9x5,000 1,221,238,000 54,467,000 58,400,000 22,364,000 18,418,000 190,251,000 33,455,000 5,788,000 35,618,000 19', 860,000 139,180,000 10, 380:, 000 605,210,000 33,907,000 52,163,000 19,475,000 12,660,000 114,543,000 20,490,000 5,724,000 26,978,000 13*982,000 84,667,000 $1,814,-954,000 $1,000,179,000 oOo- TREASURY DEPARTMENT Washington Press Service Ho. 3 I f - FOE IMMEDIATE RELEASE, Tuesday, Decamber lU, 19^3» The Treasury received today the sum of $233*9*5 * °6 from the Government of Finland, representing a payment of principal in the amount of $SH ,000 and the semiannual payment of interest in the amount of $136,220.00 under the Funding Agreement of May 1, 1923, and $ 1 3 ,695.06 as the sixth semiannual annuity due under the postponement agreement of May 1, 19^1 • | %his payment represents the entire amount due from the Government of Finland on December 15, 19^3 under these agreements. -oOo* TREASURY DEPARTMENT Washington FOR I M M E D I A T E RELEASE, T u e s d a y , D e c e m b e r 14, 1 9 4 3 * The Treasury received f r o m the G o v e r n m e n t of principal payment of in Funding Agreement the sixth agreement This o f M a y 1, payment the G o v e r n m e n t of the sum of $233,915.06 representing a payment of $ 8 4 , 0 0 0 and in the a m o u n t the semiannual today o f Finland, the a m o u n t interest Press Service No. 39-91 o f M a y 1, the semiannual of $136,220.00 under 1923, a n d $ 1 3 , 6 9 5 . 0 6 as a n n u i t y due u n d e r the p o s t p o n e m e n t 1941. represents Finland the entire on D e c e m b e r these agreements. oOo- amount 15, due from 1943 under s*femt 2 Iaoooo fufti vltlift Aieh H i« «#«xt«|mi for aanriod mom#!#* .to film (a) ooparato or {¥) Jolat rotarao axutar i . *. 3ft?, mM tag^ J fifSssteX iMMBBg ■«»»**— Is/ toaMsod mot laeowe ifypo of rotmra 1 Oa* dopondoat I fwo doposdosto t resulting la *• *«>•**•**• I I I l«c««f lit f TOO - #!,.{% $ 800 - *1,433 | 900 - fl.no i.<*5 - 4.T3J 1,433 - 3.0*3 1*P§ - 5.433 Or*r 4,733 « w 5,0«3 0 m 5,433 froooary Hofartaoat* #f fa* f m*ji»iL rv*mto *i •i *i WU S Joist toparato ®ooo»fcor 8, lft| i/ Bimioioa of Im o m feotmoon imsfcand oad vlft i n m H to t» omch that tho petootiol iAr«At«|t fxo» tt« moo of tiDitr tyj>« of rotors mill tt at a aasiarau !(, M iU I k Xm o m nwcsa irithln Vht*h It I* aftnatacMM <W* *«nrU* ««*»*•« *• filo («) or <%) J»lat wttonma aitor^l. 36*7, ■aTfpfa «to*<**k if Ktfrtll ootrolo - M M fjrp# #f wtttxm CoaHaod M t k « M ' '| .. . . . ■... ■■ .;... --* tmemm 41rid »4 * tm m * 4iTi&*A 1 la m m iiri&mA I g$ #UX$iM£ $M immmme tmx 3S s 3° $ goo - *1,0 7 1 * soo - 11,363 » * » • tt.309 1,0 7 1 - 5,16 7 1 ,3*3 - 5.55* Oror 5,167 (tor 5,558 k,30f - 5 .m ©toW 5,85* CM<M»r to p a rto m t. S ivtaion of fw t Kowwroh Jj im m Ii i d*pma«nt •»•«* tokM tor m nm **•* *Mto»to iMMtor 8, 19^3 nito !« « • » Iwmm. Q B* Consistency of Treasury position Although not a technical point there is one other statement in the Joint StaiT statement that oalls for comment. On page 3 It Is stated that the Treasury position before the House Ways and Means Committee was that "there was no better way of accomplishment" of the objective of taxing those now subject only to Tlctery tax than the integration plan now contained in the House Bill. This is not an adequate presentation of the position taken b y the Treasury before the Ways and Means Committee. The Treasury was asked its opinion of the plan with no advance knowledge of the plan. On the basis of a hasty review of the major points of the proposal ©vsr a few minutes n tentative reaction was given to the Committee that at the moment no bettor a l t o m a t l v e came to mind to accomplish the objective of keeping on the tax rolls ths 9,000,000 taxpayers at the bottom of the taxable Income scale. After the Treasury had had an opportunity to study the integration plan now in the House Bill, It stated unequivocally to the Committee on Ways and Means that the plan was "hopelessly complicated .* However, the Treasury was not afforded an opportunity to discuss its objsctlons in do tall boforo the Ways and Means Committee. It Is to bo noted that the Joint Staff statement failed to mention the later elarification of the Treasury position on the House Bill integration plan. P '-i'S 0. Kalatlonahln of ttfaaawnr i n U m t U n pgopoaal to rm m laA w of «>• memo.iMamtaai l a w . t « cmmaai Th« Joint Staff a t a t m a a t Indicate* (pp. 3 • H) that tha Svoamijr did not present an Integration proposal to the Committee on Ways and Means* The Treasury income tax proposals to the Congress thlsffall hare from the first contained the integration element. The proposal submitted to the Ways end Means Committee was designed not only to raise revenue hut to absorb the Victory tax burden Into the regular income tax structure. At that time* no need was seen for singling out ths lntagration features of the proposal for separate presentation* It was thought that lntagration would b o accomplished as part of a general Increase in Income tax rates together with other changes (such as lowered exemptions and repeal of the earned income credit)* and that a separate discussion of the Integration segment of the proposal would merely complicate the problems before the Ways and Means Committee* However, the Senate finance Committee was confronted with a specific integration proposal in the House Bill* Hopes for a general upward revision of income tax rates had not materialised* Therefore, to aid the Committee in the consideration o f matters before it* the integration segment of tho Treasury proposal was trsatsd separately to facilitate analysis and comparison with the integration provisions of the House Bill* S % ) 1. 0. *. .f • " “ ■ • M X * attributable to the returns of the $ million taxpayers eliminated under the treasury integration plan would not b e as great as the revenue that would be eolleeted from them* . T Quite aside from the (unte^rfble I implication that a tax is worthwhile if it does not ooet 100 peroent to oelleet is the feet that in fudging whether an administrative expenditure U worthwhile olt.rn.tiw. op.r.tio». ■*.« *. oon.id.rl. W a r as personnel is freed from tho administrative tasks involved In ths handling o f thoso millions of minor itsmsf increased attention mould be d e v o t e d . h te more adequate eolleetion from other more profitable areas of the tax bass with rssults that might bs expeeted to exceed the amount of rovei L \ lost by eliminating these small taxpayers* Moreover, any consideration o f the costs of maintaining these small accounts on ths tax rolls should \ I include the withholding burdens imposed upon employers and the taxpayers* I own tasks of compliance, as well as merely costs to ths Bursas of Internal Be venue. B. Estimated r e v e n u e ^ O n page 13 ths Joint Staff statement implies that the represented the yield of the minimum tax at |l6l,000,000, whereas ths || actual yield would b s mors* the treasury figure does not relate and was never intended to relate to the whole minimum tex* It Is the g Vv a i estimate of how much the $ million persons who would bs wholly relieved I # from income tax under ths treasury proposal would pay under the louse B 1 H « 'Ii merely of the application of ft 3 percent rate to the excess of the wages over ft uniform withholding exemption, for example, $12 for ft weekly payroll, regardless of the wage-earner** family status. Under the House Bill if he found that minimum tax withholding applied, hie computations would require use of a separate set o f exemptions that vary with family statue as do those for regular income-tax wlthholdlng^fun&er the treasury Integration proposal, withholding would he least complicated since there would ho only one set of exemptions and rates to apply. Under present law, payroll procedures are simplified by the fact that all wage earners subject merely to Victory tax withholding can ho treated uniformly. Under the House B U I , complications would he increased since differentiation according to family status would h e required for both minimum end regular taxes. If. Other point* on Integration A. Administrative problem under House B U I 1. the Joint Staff statement attempts to rebut the treasury** contentlen that the House Bill would unduly complicate the administrative process by stating (on page 12) that elimination of 2.b million returns "cannot be termed an addition to the problem of administration.11 this y fig g g t* truism does not constitute an answer to the evidence presented by the treasury to show that administrative burdens would he greatly increased under the House Bill, the benefits of eliminating 2.^ million returns would ho far mors than offset by the complexities o f the tax computations, the resultant large numbers of errors, and the necessity for furnishing the majority of taxpayers with assistance In determining the most advantageous method of filing under the House wiU be subject to two different taxes, with different exemptions and rates* will not ha at all rare under the House hill* Taking merely the ease eited in the Treasury*e statement* we see that with the husband*t 1noons at IJOD* he would he subject to the regular tax* while his wife would he subject to the aiainaa tax if her lneoae fell anywhere between $600 end $888. Two texee side by eide will he a'vssy real problem for nuaerous taxpayers* in . OMmiuatioB *y th* & sm S iU trm uHm stated that tha prortulon tha House »IU substituting varying minimum tax exemptions for the present fixed Victory tax exeaption would complicate withholding operations (Hearings* p. 28* 29) This eonelusion is attacked on page 13 of the Joint Staff etatenent. It is asserted that a table would ho provided froa which employer© could readily deteraine* in eaoh individual ease* whether withholding is to /ho computed by uso of the alniaua tax or tho regular inoona tax rates and exemptions# . This answer does not aeet the point in question for the many employers who uso the more accurate ’•precise* method of withholding* A table of /this p o rt would of course be provided* and is in fact in use under present law* The complication is introduced* however* la tho next step after |he employer has used mush a tabls to deteraine which of the alternative hates for withholding applies* Under present law if he finds that Victory tax withholding is appropriate* tho remaining oo^mtation consists A to im yinx *. (toiroa tw m « to »lda with tha tm gslur II. Sht CooalttM rtiff atotai on page k that, bawuat a table guiding taxpaysrs into either the minimum or the regular tan can he prepared, the treasury 1* wrong In asserting that there will he two alternative taxes# that ie* the minimum tan and the regular tan* aide hy elde under the Bouse hill, Aside from the disadvantage that the tabular guide will itselfn^ya devise new to Imorleen taxpayers* It le obvious that the preparation of mechanical gulden done not conjure the minimum tan out of enietenoe. Share are etlH two tunes (one of then entirely new) te he explained* two tanoe to he understood* and two taxes te he dealt wlth« Shoes who explain the tan hy written or spoken word will have to labor through both the minimum tan and the regular tax; no mechanical guide gan relieve then ef the task of explaining* nor the taxpayer from the taak of trying te understood* two different time with intricate^ Interrelations* for many married couples* moreover* the two taxes will setua&y he elde hy elde at a practical natter In tie course of their tan computations* Many couples filing separate returns will find that the husband le subject to the regular tan and the wife to the minima tan* cr vice versa* It i« to he noted that the £oint Committee staff did not dispute the example given in the Treasury** statement illustrating this point (page S6 of the Bearings)* the cases wh©re husband and wifs of the Joint Staff statement w o l d hold only under tho *>0-50 division of incomt which is implicitly assumed in ths table* If# for exaisple# a couple without dependents had somewhat so?i than ^ » 7 3 ^ (2 times $ 2 ,367 ) dividsd U 5 -5 5 instead of 5 0 -5 0 ns la table U# separate returns would not be desirable* ] J With a more uneven distribution o f income the incones at the breaking points Increase* On page 10 the Joint Staff statement asserts as an advantage of the House bill that it raises the amount of combined net income above which it is desirable for a married couple without dependents to file separate returns from $3,200 to $b,?33. At the same time it cites the lowering of this amount to $1,600 under tho Treasury proposal as a disadvantage* This argument entirely misses the essential point that# putting asideepiity questions and looking at the problem from the stand point of simplification or complexity# it makes no significant difference whether this point Is hi$h or low* The important thing for purpoees of simplification is that the point be clearly defined and readily determinable Under both the present law and the Treasury proposal the breaking-point is constant in terms o f surtax net income* and may be computed at a glance in terms of net income* Under the House bill the breaking-point is variable and difficult to determine# 1J If the split was U 5 - 5 5 * separate returns would result in a total tax of $062 as compared with $059 under a Joint return. An increase in the inequality of the division of income between husband and wife would increase the disadvantage o f separate returns at this combined net income level. complexity. ■;.4 As the number of such guide tables wa* increased, an $$$■ f■ increasing numbsr of taxpayers would come within the purview of one or more tables. She complexity of such a system of multiple guides would render thjm impracticable. An analystji of table U. page 10 of the statement of the Joint Committee Staff .fringe out d e a r l y the essential difference between the joint vs. separate returns problem in the regular Income tax area under the House bill ae compared with the problem under either the present law or the Treasury integration proposal. As the table shows, the amount of combined net Income above idiieh separate returns become advantageous varies under all threa tax methods with the number of dependents* That the table does not show is the fact that the point above which separate returns bscoms advantageous is fixsd in terms of surtax nst income under both present law and the Treasury pro posal. Under present law this point is at $3*000 of combined surtax net incomes under the Treasury proposal Involving a $500 first income bracket* this point would bs at $500 eomblntd surtax net income* These points are constant regardless of ths number of dependents and regardless of the division of income* By striking contrast* under the House bill this point varies in terms of surtax net Income with both the number of dependents and the percentage division of income* ~ Xn this connection* it should be noted that* just as in table 3# the breaking-points under ths House bill indicated in table page 10 nevertheless, ths advantage of joint returns for thin couple would exceed that of a coaple with the same Income, equally divided. With a HO -60 split the cowhined tax under •operate returns would he $868.87 ** compared with $ 858.67 under returns. An additional table would he necessary to guide the couple with the hO -60 split of Income. Separate additional tahlee would likewise he required for each different division of income if taxpayer* are to he guided to Joint or eeparate returns hy ths use of tahlee. %J Some of the variations in the ranges of advantage caused hy variations in the division of income are illustrated in * the attached Exhibit 1. It should he noted that, as the figures in table 3 th* statement indicate, the ranges of advantage vary with the number of dependents, fhis is further demonstrated in Exhibit 2. TOS from these examples and the tahlee here presented, it is de ar , as ths treasury previously pointed out, that both tha division of income and the number of dependents are important in determining the sense of advantage for one type of return or the other. Mo reaver, they bring into clear focus the important practical coneidaration that a number of tahlee like sample table 3 would he necessary to meet the hulk of taxpayer situations. Whese tables would have various maximum and minimum limits for t h ^ n « » ^ ^ each spouse for various dependency statuses. Such tahlee would tend to overlap, with a taxpayer finding himself on more than one table, thu s adding to the coafuslo$„.and / in addition to the defect« of the lower limits, admitted on page id of the statement of the Joint Committee Staff, thie analysis shows that the upper limits of t&bis 3 mre ambiguous. 1 not meet the condition! under which joint re torn* were advantageous, «1 nee the gfosa Income of one spouse was less than the minimum of $ 5 ^5 .85 . Actually, however, this couple should file joint returns since the liability under joint returns would h e $10.35 «* compared with $3 b. 3 h under separate returns. Again, taka the east of a eoople without dependante receiving a combined grots income equal to $5*®35-^6. their income wee divided equally each receiving $ 2 ,5 1 7 -7 3 *hey would be guided by the table into joint returns. 1/ If, however, they received the same combined gross Income, or $ 5 *0 35 -^*, divided unequally« Uo—bO, one would receive $2,0lh.lH; the other, $3,021.2$. offer no guide. *he table would It would in fact imply that joint returns would not be advantageous, since the income of one spouse exceeded the maximum allowed by the table. ^ T r~ It this Income level with a 50-50 split of income .heir liability would *8X be the same or $$5$.b7 under either joint or separate returns. However, the adequacy and usefulness of this type of table as a guide to the taxpayer is dubious and at best H a l t e d . Shore is no guidance for great numbers of taxpayers, for example, suppose the husband earns $2,b00(and the wife 11,000* If thsy have no dependents, table 3 would not guide them because the husband* s earnings would exceed the maximum income for one spouse to which the table would be applicable. If they have ® four dependents, table 3 would not answer their problems because the wife's Income would be lees than the minimum amount assumed for one spouse where there are food dependents* The table sets H a l t s within which joint returns give the low est tax. If it is to be a guide to the taxpayer, he wculd presumesbly have a right to expect that optside these limits joint returns would not give the lowest tax. is not the case, But in numerous situations this for example, suppose that a married couple with no dependents received a combined gross income of $ 1 ,1 1 1 *70 * i.e., two times $3$$.85* If their Income was divided equally, each receiving $555*^5, the table would guide them into joint returns. 1/ Suppose, however, they received the same gross income of $ 1 ,1 1 1 *7 0 , divided $700 and $bll.7Q. l/ This table in itself would imply that they did At this combined income level the liability under joint or separate returns would bdidtntical, 1. e*, $10*35* Point that perlexity is same on the 'short as it is on the long form At sevesal points, notably page 9 C bb enmi"*— S w p e W the ? Joint Staff statement suggests that couples using the short form (lOhOA) would avoid any laborous computations. .. i1■i*lll^ IWBWiA— — — ^ In fact, however, the fundamental perplexity with respect to the choice of joint or separate returns is hy no means limited to users of Form lOHO. It is practically the same whether the taxpayer uses or intends to use either 10U0 or lOUOA. The simplification of the arithmetic in the final computation does not affect the basic perplexity. Furthermore, even though to reach the smallest tax the taxpayer ultimately chooses the short form in the process of arriving at this decision he would in many cases have to make trial computations involving both long and short forms. C. Determination of income levels affected by complexity of choice the Joint Staff statement (page 9) denies the truth of assertion that because of variables in the possible division of income and dependents between husband and wife *no clear dividing lines or income zones can be established to guide taxpayers into one type of return or the other.® Table 3 9 Joint Staff statement appears to be offered ae a sample of the type of table which might be used to guide the taxpayer into the type of return verted to net Income by subtracting 6 percent for average deductions, l and are multiplied by two, they m ^ with the Treasury s figures for breaking points assuming a 50-50 division of income, given on page 2 2 of Appendix B of the Hoveaber 29* ifl® statement (page 5 / of Finance Committee Hearings). /3 similar dilemma* Under the Treasury proposal the choice between joint and separate returns would not only be clear-cut but would be the same as it is under present law, thus requiring no reappraisal of the most advantageous method of filing* I I A %he tax it hi® tie®# for® 10^K), while he may find the tax In a table for each alternative if **• usee Form 10^0-A. The Joint Staff statement (on page S) questions the Treasury assertion that the Houee hill will confront more than 10 million married couplee vith the choice between joint and separate return#. The figure of 10 million is, if anything, an understatement. Under the House hill, virtually every husband and wife, both receiving income, except those in relatively high brackets, will face the complex problem of choosing between joint and separate return#. The choice will, a# noted above, require the weighing of many complicated factor# not now involved in the tax law. While guides may be established to reduce the complexity for some taxpayers, they can at best cover only part of these married couples. With or without the guides, however, the problem will be confusing and often complex. The Joint Staff statement goes on to say (page 11) that even if the Treasury assertion is true, "it follows that the only possible reason that the Treasury proposal would not confront a good many more than 10 million couples with this dilemma Is that their proposal completely relieves 9 million persons of any tax whatsoever." It is not clear whether an implication is intended that the Treasury proposal would confront more than 10 million married couples with a // 3. Humber of taxpayers affected by the complexity It la asserted on page 3 of the Joint Staff statement that the cases where complications arise under the House bill are "limited to those persons who choose to file on the long fora of return with the hope that a few dollars of tax could be eared.* The quoted statement Implies that persons filing the long form to tare taxes should pay the penalty of suoh complexity. However, the fact that people in very large numbers compare liabilities when there is a Y o /& & r c c + t /~ chance of saving money( as Is Indicated by the fact that about half of v pUs> the persons eligible to use form IOHq a {normally filer)on form lQ^KjO makes the problestane of taxpayer understanding and convenience, not one of penalty. The further Implication that only persons seeking to save tax use the long form is contrary to the fact that many persona are required to file the long form because the sources or the site of their Incomes may bar XXI them from the use of the short form lOhOA.* \ Moreover, the complications In the choice between Joint and separate returns and In the division of dependents between spouses are not limited to form 10^0, the long form. Persons filing form 10*40-A, the short form, also have to make the choice by eomparlng liabilities under Joint and separate returns and various divisions of dependents. The only difference between forms 10*40 and 10*40-A is that for each of these possible divisions the taxpayer has to compute la* offer* no incentive for married couples with snail incomes to file separate returns, and on the other that it sokes no difference to such taxpayers which type of retuns they file, Flret of all, it should he said that there is no inherent contradiction between the two statements, ewen without qualifications. Second, the treasury's statement that under present law it is a natter of indifferenoe to married couples with surtax met income helow $2,000 whether they file separate or Joint returns d e a f l y applies only so long as no sxemptlon Is wasted. If the filing of separate returns results In unused exemptions under present law. It Is no longer a matter of Indifferences it Is simply irrational* waste and thereby reduce the exemption* crease In exemption* Filing separate returns may It cannot result in an in Therefore, while It may ho a matter of Indiffer ence whether joint or separate returns are filed (where no exemption is wasted), there cannot In any exeat he any incentive (in terms of rates and exemptions) to file separate returns* the Treasury's state ments are wholly consistent with each other* The points Just mads clearly Indicate the Irrelevancy of the assertions la the Joint Staff statement that there ie *absolutely no difference between the number of possible computations under the present lav and under the Reese bill *««* (Page 8} ether Assertion# on this subject require mention* One or two On page 8 it ie noted that in 4 of the 8 cases listed In the table prepared bp the treasury showing alternative computations, some of fee regal .jr income tan exemption was unused* assumption* this was said to bo a&*absar&* However, because of fee existence of fee minimum tax. It Is entirely possible to “waste" some of fee regular income tax exemption and yet obtain fee lowest combined tax liability In fee face of such wastage* therefore, lose of part of the regular exemption is no guarantee feat a given method of filing is disadvantageous* ‘ » farther point is made that "many of fee possible allocations lependeney credit would not bo permitted under the existing sh requires feat the taxpayer receiving dependency credit must 4 provide fee major support of fee dependent*11 (Rage 8} he a matter of pxmetleo, it is well known feat dependents are not in fact allocated according to the major rapport principle* would be well-nigh Impossible* To enforce felt principle The Bureau of Internal Revenue has not attempted to prevent taxpayers from allocating dependents in any maimer they see fit* On page 8 fee Joint Staff statement asserts th&t the Treasury’s testimony contradicts itself in raying on fee one hand feat present than $2,000 produces no tax advantage, and (2 } this Is a fact easily explained to and understood by taxpayers, the problem of alternative tax computations is, for all praetical purposes, non-existent under present lavs. tinder the louse bill, where (1) the amounts of the exemption o A-£_ 4rS different under joint and separate returns and under both the minimum tax and the regular tax, and (2 ) the rates may also differ ae between joint and separata returns and different allocations of dependents, the choice between joint and separate returns is anything but clear* The advantages do not run all in the direction of joint returns In one Income area and all in the direction of separate returns in another. There are several opposing factors and several different zones of advantages. Where husband and wife are subject to the minimum tax, separate returns result in a larger exemption than a joint return; where they are subject to the regular tax, separate returns result in a smaller exemption. In addition, tha credit for dependents varies as between the minimum tax and the regular tax* The combination of these factors mhkes the choice between joint and separata returns and different divisions of dependents a very real and very complex one under the House bill. in, part of the area where separate returns hare been preferable, joint r a torus will become advantageous* Therefore, there will not only he a problem of complexity in choosing the method of filing, there will also ha a shift to separate retorns for many persons now filing joint retorns, and vice versa. —» Under present law there is no incentive to file separate returns on form 10^0 as long as combined surtax net income does not exceed $2,000. It Is common knowledge that no advantage results from ths use of separate returns in this area. Conceivably, married couples can go through the motions of the alternative computations. It is entirely unrealistic to assume that they will do so, however, since the choice is entirely clear without such computations, filing separate returns^results in neither lower rates nor higher exemptions! in fact, the only possible change in liability by filing separate returns In the area under $2,000 Is an increase in liability resulting from loss of part of the personal exemption under the regular tax and a decrease in the amount of postwar credit under the Ylebory tax. Table 2 prepared by the «Toint Committee supports exactly this view. It is to bs noted that every one of the liabilities computed on separate returns it greater than the joint-return liability* Since (1) the filing of eeparato returns for combined surtax net incomes of less The whole point is that for the very taxpayer involved in the example separate returns would now he more advantageous than the joip^t return. More over the advantage lies in a particular division of dependents, to the hudand and one to the wife hut this advantage becomes known only after are made. ^ computations C co " it /file jointly, the regular tax if they file separately, or rice versa; the minimum tax may ap ly If dependents are allocated in one way, the regular tax, if another. Several alternative computations, often involving first the minimum and then the regular tax, will therefore he nec ssary In many cates to arrive at the filing combination Involving the smallest amount of tax. The statement questions the validity of the Treasuxy's example illustrating the series of alternative tax computations necessary under the Bouse bill to determine the lowest combined tax for a husband and wife both having income. reproduced on page 5 of statement.) (Bxample SBffciBX The «Tolnt Staff does not deny that IS tax determinations would be necessary under the Bouse bill. However, on pages 5 through S, the Committee XSX attempts to show that the same choices and alternative computations would be possible under present law. It is true that IS computations could he made under present law in the situation citid. The crux of the matter, however, is not that ^ h e computations are possible, but rC/ r: ___ ___*__ __ _____ -- that taxpayers would not find any point in making thern^i Under present law, the choice between joint and separate returns is perfectly clear and requires no alternative computations. Under the Mouse bill, the choice is not clear; In fact, In a considerable part of the area where joint returns have heretofore been clearly prefsrabla, separate returns will become advantageous . ( Likewise, x fhe points regarding complexity, raised by the Joint Committee Staff statement, are answered In the following discussion. I# The problem of the choice between joint and separate returns fhe Treasury and the Staff of the Joint Committee differ sharply on the complexity involved in the choice between joint and separate returns under the minimum tax. fhe chief points of t difference center on! (l) the nature and magnitude of the complexity under the House Ull and its comparison with present law; (2) the number of taxpayers affected by the complexity involved in the choice; (3 ) the income ranges in which the choice between joint and separate returns must be faced. A. fhe nature and magnitude of alternative tax computations On page 3 the Joint Staff states that *n© income taxpayers will have to compute two different taxes to determine their tax liability. This statement is in error. Although once the decision to use joint or separate returns has been made and the allocation of dependents decided upon, oily one tax — ■ either the regular or the minimum — will apply to each spouse^ jt k e process of choosing will itself frequently involve confusing switches between the regular and minimum Q/QS Many married couples where both spouses receive income will tax. have to compute both minimum and regular taxes in comparing the advantages of joint and separate returns and of different divisions of dependents between spouses, fhe minimum tax may apply if they Statement of Randolph E. Paul, General Counsel for the Treasury, before the Senate Finance Committee December 15, 1943 It was very kind of the Committee to give an opportunity to answer the statement of the Joint Staff made before the Committee yesterday. The time available has not been all I should have liked to have since some of the points involved are complicated §,nd require extensive analysis. However, I am presenting to the Committee at this time a general answer to the Joint Staff statement and I am also furnishing a detailed answer to all points in that statement* In m y answer I have endeavored to keep discussion on an objective basis and to avoid questioning the motives or the frankness of any person whose opinion may differ from mine. I think it clear that any other course is not in the interest of expeditious procedure or intelligent assistance to this Committee. It cannot be denied — and I see no denial in the Joint Staff state ment of December 14 —- that the Treasury’s integration proposal is far simpler than either the present law or the House bill. If simplicity is the controlling objective, the Treasury’s integration proposal is clearly the preferable method of integration. However, I pointed out in m y statement of November 29 that under this proposal 9 million taxpayers are relieved of income tax. These 9 million taxpayers would have paid only $161 million of tax under the House bill*Under the Treasury's proposal, the amount payable by these taxpayers would have been collected from other taxpayers. There would, therefore, have been no loss of revenue. It is generally agreed that real simplification cannot be achieved without dropping these 9 million taxpayers from the rolls. The removal of these taxpayers from the rolls is a question of policy for the Committee, The pertinent policy considerations on this point have been fully explored and there is no need to repeat them at this time. If the Committee desires to keep these 9 million taxpayers on the rolls even at the expense Of obvious complication of the tax structure, the question for the Committee then becomes, What type of income tax should be used to reach them? Eliminating the Treasury integration proposal, the alternatives are the present victory tax and the minimum tax contained in the House bill. The issue is not simply between the Treasury integration proposal and the minimum tax. If the Treasury proposal is rejected, the issue — and it is a vital issue — is between the victory tax and the minimum tax. The dropping of taxpayers from the rolls is not involved in this issue. 39-92 « 2 The Treasury and everybody else who recommended integration of the victory tax dxd so in the hope that integration would eliminate existing complications. Unless these complications are clearly and unmistakably re*moved by the minimum tax, there is absolutely no point in making this switch to another income tax method#- The Joint Staff has presented arguments in an attempt to prove that the House bill is less complicated than the victory tax. We are answering these arguments point by point later in this statement. We are convinced that the victory tax is less complicated than the minimum taxf .Both taxes are admittedly complex. In view of the sharp difference of opinion among the experts, your Committee must at least have reached the con clusion tnat it is debatable whether one is more complicated than the other* Under these circumstances every policy argument is against switching from the victory tax to the minimum tax. The taxpayer confusion and misunderstanding that would arise from a switch at this time is in itself an unanswerable argument against turning to the minimum tax. In the next few months the Treasury will be devoting every effort and cooperating with every educational facility to explain the victory tax so that millions will be enabled to fill out their March 15 returns.- . This education of taxpayers is necessary even if the victory tax is replaced by the minimum tax, since returns for 1943 to be filed in March, 1944, will still be based on the victory tax. This process of education under the victory tax will be difficult enough. But just as soon as it is achieved, the Treasury would have to turn around and go through the entire process of education all over again for the minimum tax. As a matter of fact it will be necessary to explain both the victory tax and the minimum tax at the same time to millions of taxpayers who would on March 15, 1944 file 1943 returns on the victory tax basis and 1944 declarations on the Ednimum tax basis. Satisfactory taxpayer education and compliance is impossible under these conditions. Adoption of the minimum tax would necessitate new withholding tables and new withholding exemptions, presumably to become effective on April 1, 1944. Retention of the victory tax, without other changes in the income tax rates, would make unnecessary any change in the withholding tables and exemptions. Consequently, in addition to all of the taxpayer confusion which a switch from trie victory tax to the minimum tax would involve, an added burden would be thrown on employers by the change in withholding necessitated by the minimum tax# -3This problem can only be approached from the standpoint of administration and taxpayer compliance* The Treasury Department through the Bureau of Internal Revenue must administer the income tax* In the opinion of the Commissioner of Internal Revenue both the victory tax and the minimum tax are a handicap to satisfactory administration* However, the Commissioner has stated his opinion that of the two the victory tax is the lesser evil* I quote from a letter the Commissioner of Internal Revenue sent to the head of the Joint Staff dated December 2, 19^3t * # * 111 should like to state at the outset that the minimum tax of the type proposed or any other tax separate from the regular income tax which will involve exemptions and credits for dependents different from those allowed for the regular income tax will be verydifficult of administration.” * # # ^Comparison with Victory Tax As between the minimum tax in H* R. 3687 a-fld the present Victory tax which includes the compulsory current use of post-’ ■war credit, the administrative burden would be less if the Victory tax were continued.” # * # ”* * * Especially in view of the change from one system to another, the minimum tax * * * would cause greater difficulties than those under the present law. In this regard, as I stated above, the Victory tax or any minimum tax necessarily adds serious administrative burdens to the regular income tax system and serious difficulties for the taxpayers.” It is earnestly urged upon the Committee that the judgment of the admin istrative agency having the burden of collecting the $17 billion under our existing income tax system is entitled to great weight when the question is one chiefly of administration* It is, in our opinion, a compelling reason against switching at this time from one complicated tax to another compli cated tax* It is possible within the framework of the Victory tax to take some steps in the direction of simplification. The Victory tax rate could be fixed at a flat Jfj> rate. This change would involve the least sacrifice in taxpayer education in respect to 19^-3 tax liability under the Victory tax. It would avoid the confusion involved in switching from a 3$ Victory tax with one set of concepts to a 31 ° minimum tax with a totally different set of con cepts, This suggestion was made to the Ways and Means Committee before that committee commenced its work on the Treasury proposals of October U, 19^3* - k As I have said, I am'replying point by point to the Joint S t a f f s criticism of my statement of Hovember 29» 19^3» At this stage, i would like to repeat the main arguments made in my statement: 1. The minimum tax involves the difficult problem of two alternative taxes and obliges taxpayers to decide which of the two taxes is applicable. 2. For millions of taxpayers it will necessitate a comparison of" tax liability under separate and joint returns that is not present today. 3* 1} will decrease the use of simplified form lOhOA, H* It will complicate the withholding process end place additional burdens on employers. 5* It will greatly increase the administrative burden upon the, Bureau of Internal Revenue. 6 . It unnecessarily reduces the present tax liability of about taxpayers. 26 million I said in my statementof November 29 » 19 ^3 > that the minimum tax in its proper perspective may jeopardize the whole income tax system* The recent statement of the Joint Staff does not face the reality of this possibility. It is necessary to the survival of a tax law affecting over'50 million people that the law be made understandable to those people. I see no hope of satis factorily explaining to millions of taxpayers over the radio, in the press, and through the mail two complicated taxes under which they must file at the same time returns for the year 19^3 and 'declarations for the year 19Uh. I therefore repeat what I said in my original statement that the minimum tax endangers the collection of more than §1J billion from over 50 million taxpayers throughout the income scale. I also repeat what I said in response to' a question asked during my testimony of November 29th that the Victory tax is the lesser of the two evils with which the Committee is confronted if it ■ decides as a matter o^ policy that it is essential to keep on the tax rolls 9 million taxpayers who pay a total tax of only $l 6l millions. o0o*r . - 5 The points regarding complexity, raised by the Joint Committee Staff statement, are answered in the following discussion. I. Tfo. Q Pr?folem of the choice between .joint and separate returns The Treasury and ihe Staff of the Joint Committee differ sharply on the complexity involved in the choice, between joint and separate returns under the minimum tax. The chief points of difference center on* (l) the nature and magnitude of the complexity under the House bill and its comparison with present law* (2) the number of taxpayers affected by the complexity involved m the choice^ (3) the income ranges in which the choice between joint and separate returns must be faced. A* The nature and magnitude of alternative tax conputations O11 P&ge 3 the Joint Staff states that ”no income taxpayers will have to ©ompute two different taxes to- determine their tax liability.” This statement is in error. Although once the decision to use joint or separate returns has been made and the allocation of dependents decided upon, only one tax — either the regular or the minimum — will apply to each spouse, the process of choosing will itself frequently involve confusing switches between the regular and minimum taxes. Many married couples where both spouses receive income will have to compute both minimum and regular taxes in comparing the advantages of O o m t and separate returns and of different divisions of dependents between tax may apply if they file jointly, the regular tax if y file separately, or vice versa* the minimum tax may apply if dependents are allocated in one way, the regular tax, if another. Several alternative computations, often involving first the minimum and then the regular tax, will therefore be necessary in many cases to arrive at the filing combination involv ing the smallest amount of tax. The statement questions the validity of the Treasury's example illustrating °f alternative tax computations necessary under the House bill to determine the lowest combined tax for a husband and wife both having income! (Exanple reproduced on page 5 of statement.) The Joint Staff does not deny hat 18 tax determinations would be necessary under the House bill. However al tern at *^ ^ t ?* th* Coimittee ^ t e m p t s to show that the same c h S aAd lternative computations would be possible under present law. It is true that Irv^Tt^Ztf t te made.under present law in the situation cited. T h f tf matter, however, is not that the computations are possible, but that taxpayers would not find any point in making them. Under present law the anerLtivr:od,0t^-and fact V ^ at;°n s * retUrnS iS perfeot^ Under the House bill, the choice is not clear: in been*clearlv°preferaMp ^ °f+tbe area where doint returns have heretofore S u H t a t f ? 1 ’ separate returns will become advantageous. The whole point is that for the very taxpayer involved in the example separate re+m-n^ would now be acre advantageous than the joint r e L n . " o r e o ^ h e ^ Wife b„? division of dependents, two to the husband and one to the separate returns for many persons now filing joint returns, and vice versa. Under present law there is no incentive to file separate returns on Form 1040 as long as combined surtax net income does not exceed $2,000. It is common knowledge that no advantage results from the use of separate returns in this ares* Conceivably, married couples can go through the motions of ohe alternative computations. Ityis entirely unrealistic to assume that they will do so,^ however, since the choice is entirely clear without such compu te o10ns. Filing separate returnst results in neither lower rates nor higher exemptions; in fact, the only possible change in liability by filing separate returns in the area under $2,000 i,s an increase in liability resulting from loss of part of the personal exemption under the regular tax and a decrease in the amount of postwar credit under the Victory tax. Table 2 prepared by the Joint Committee^supports exactly this view* It is to be noted that every one of the liabilities computed on separate returns is greater than the jointreturn liability. Since (l) the filing of separate returns for combined surtax net incomes of less than $2,000 produces no tax advantage, and *(2) this is a fact easily explained to and understood by taxpayers, the problem of alternative tax computations is, for all practical nurposes, non-existent under present laws. Under the House bill, where (l) the amounts of the exemption are different under joint and separate returns end under both the minimum tax and the regular tax, and (2) the rates may also differ as between joint and separate returns and different allocations,of dependents, the choice between joint and separate returns is anything but clesx, The advantages do not run all in the direction of joint returns in one income area and all in the direction of separate returns in another# There are several opposing factors and several different zones of advantages, Where husband and wife are subject to the minimum ta.x, separate returns result in a larger exemption than a joint return; where they are subject to the regular tax, separate returns result in a smaller exemption. In addition^ the credit for dependents varies as between the minimum tax and the regular tax. The combination of these factors’ makes the choice between joint and separate returns and different divisions of dependents a very real and very complex one under the House bill. The points just made clearly indicate the irrelevancy of the assertions in the Joint Staff statement that there is ’’absolutely no difference between the number of possible computations under the present law and under the House bill . (Page 8) One or two other assertions on this subject require mention. On page o it Is noted that in 4 of the 5 cases listed in the table prepared by the Treasury showing alternative computations, some of the regular income tax exemption was unused. This was said to be an ’’absurd” assumption, However, because of the existence oi the minimum tax, it is entirely nossible to ’’waste11 some of the regular income tax exemption and yet obtain the lowest combined tax liability in the face of such wastage. Therefore, loss ox part of the regular exemption is no guarantee that a given method of filing is disadvantageous. - 7 The further point is made that “man- of the possible allocations of the dependency credit -would not be permitted under the existing law which requires tnat the taxpayer receiving dependency credit must provide the major sunp’ort of the dependent (PageB) As a matter of practice it is well known that dependents are nothin fact allocated according to the major support orinclple To enforce this principle would be well-night impossible* The Bureau of Interna-. Revenue has not attempted to prevent taxpayers from allocating de pendents in any manner they see fit, On^page^o the Joint Staff statement asserts that the Treasury*s testimony conuradices itself in saying on the one hand that present law offers no incentive for married couples with small incomes to file separate returns ana on the other that it makes no difference to such taxpayers which type9of return they file. First of all, it should be said that there is no inherent ^1 on^^a<^^c^^on between the two statements, even without qualifications, Second the Treasury’s statement that under present law it is a matter of indifference to married couples with surtax net inccme below B2.000 whether they file separate or joint^returns clearly applies only so long as no exemption is ^as 6 f _^ filing of separate returns results in unused exemptions under present law, it is no longer a matter of indifference; it is simply irrational Filing separate returns may waste and thereby reduce the exemption. It canin an increase in exemption. Therefore, while it may be a matter of indifference whether joint or separate returns are filed (where no exemption is wasted) there cannot in any event be any incentive (in terms of rates and exemptions) to lile separate returns. The Treasury’s i tements are Y/holly consistent with each other. * Number of taxpayers affected by the complexity lb is asserted on page 3 of the Joint Staff statement that the cases where complications arise under the House bill are “limited to those persons who choose to file on the long form of return with the hope that a few dollars oi tax could be saved.” The quoted statement implies that persons filing the long form to save taxes should pay the penalty of such complexity. However the lact that people in very large numbers compare liabilities when there is a chance of. saving money (as is indicated by the fact that about 4-0 percent of the persons eligible to use Form 1040A filed on Form 1040 in ,1942) makes the problem one of-taxpayer understanding and convenience, not one of penalty, further implication that-only persons seeking to save tax use the long form is contrary to the fact that many persons are required to file the long form because the sources or the size of their incomes may bar them from the use of the short form 1040A. Moreover, the complications in the choice between joint and separate re turns and in the division of dependents between spouses are not limited to lorm 1040 the long form. Persons filing Form 1040A, the short form, also have to make the choice by comparing liabilities under joint and separate re turns and various divisions of dependents. The only difference between orms 1040 and f04OA is^that for each of these possible divisions the taxpayer + s to c ampu be ;ohe tax if he uses Form 1040, while he may find the tax in a table each alternative if he uses Form 1Q40A. x o r - 8 - .+ +?e ^01nt Staff statement (on page 8) questions the Treasury assertion tnat the House bill m i l confront more than IQ million-married couples tfith the choice between joint and separatevreturns. The figure of 10 million is if anything, an understatement. Under the House bill, virtually every * husband and wife, both deceiving income, except those in relatively* high brackets, will face the complex problem of choosing between joint and separate returns . The choice will, as noted above, .require the weighing of many complicated factors not now involved in the tax law. While guides may be estab lished to reduce the complexity for some taxpayers, they can at best, cover only part of these married couples. With or without the guides, however the problem m i l be confusing and often complex. ^ The Joint Staff statement goes on to say (page 11) that even if the Treasury assertion is true, "it follows that the only possible reason that the Treasury proposal would not confront a good many more than 10 million couples with this dilemma is that their proposal completely relieves 9 million persons of any tax whatsoever," It is not clear whether an implication is intended that the ^Treasury proposal would confront more than 10 million married couples with a similar dilemma. Under the Treasury proposal the choice between joint and separate returns would not only be clear-cut but would be the same as it is under present law, thus requiring no reappraisal of the most advantageous method of filing. At several points, notably page 9, the Joint Staff statement suggests that couples using the short form (1040A) would avoid any laborious oomputa- , lions• In^fact, however, the fundamental perplexity with respect to the Ciioiee df Joint or separate returns is by no means limited to users of f orm 104.0, It. is practically the same whether the taxpayer uses or intends to use either 1040 or 1040A, The simplification of the arithmetic in the final computation does not affect the basic perplexity. Furthermore ■even though^ wo reach the smallest tax the taxpayer ultimately chooses the short ■01m, m the process of arriving at this decision he would’ in many cases have to. make trial computations involving both long and'short forms. Determination of income levels affected bv complexity of choice v'"; , I°int Staff statement (page 9) denies the truth of the assertion that because of variables in the possible division of income and dependents, between husoand and wife "no clear dividing lines or income zones can be \ established J:o guide taxpayers into one type of return or the other," Table 3 on page 9 of the Joint. Staff statement appears to be offered as a sample of / tne type of table which might be used to guide the taxpayer into the type of re warn which w ould be advantageous for him tohise. This table is consistent with a table'previously submitted by Treasury; it difiers from the Treasury figures in that it is on a gross income basis rather than a net income basis and that by assuming maximum and minimum in comes for each spouse it makes certain limiting assumptions as to the division of income , If the gross income figures in Table 3 for a married couple with one dependent are converted to net income by subtracting 6 percent for average deductions, and are multiplied by two, they check with the Treasury’s figures for breaking points assuming a 50r-50 division of income, given on page 2 of Appendix B of the November 29, 1943 statement (page 58 of Finance Committee Hearings), However, the adequacy and usefulness of this type of table as a guide to the taxpayer is dubious and at best limited. There is no guidance for great . numbers of taxpayers. For example, suppose the husband earns ,,>2,600 and the wife $L,0QQ. If they have no dependents, table 3 would'not guide them because the husband’s earnings would exceed the maximum income for one spouse to which the table would be applicable. If they have four dependents, table 3 would not answer their problems because the w i f e ’s income would be less than the minimum amount assumed'for one spouse where there are four dependents * The table sets limits within which joint returns give the lowest tax. If it is to be a guide to the taxpayer, he would presumably have a right to expect that outside these limits joint returns would not give the lowest tax. But in numerous situations this is not the case. For example, suppose that a married couple with no dependents received a combined gross income of 91 ,1 11 ,70 , i.e., two times $555,85. If their income was divided equally, each receiving'$555. 85 , the table would guide them into joint returns, 1/ Suppose, however, they received the same gross income of $1,111.70, divided $700 and $411.70. This table in itself would imply that they did not meet the conditions under which joint returns were advantageous, since the gross income of one spouse was less than the minimum of $ 555 ,85 ^ Actually, however, this couple should file joint returns since the liability under joint returns would be $ 10,35 as compared with $36 ,34 under separate returns. Again, take the case of a couple without dependents receiving a combined gross income equal to $5,035*4$. If their income was divided equally each re ceiving $2,517.73 they would be guided by the table into joint returns, 2/ If, however, they received the same combined gross income, or $ 5 ,035.46 ""divided unequally, 40-60,^one would receive $2,014,18; the other, $3,021.28. The table would offer no guide , It would in fact imply that joint returns would not be advantageous, since the income of one spouse exceeded the maximum allowed by the t a ble. 1/ At this combined income level the liability under joint or separate returns would be identical, i.e,, $10.35, 2/ At this income level with a 50^50 split of income their liability would be the same or $ 858,67 under either joint or separate returns. - 10 - .Nevertheless, the advantage of joint returns for this couple would exceed that of a couple with the same income, equally divided* With a 4-0**60 split the combined pax under separate returns would be $868,37 as compared with $858,67 under joint returns,- An additional table would be necessary to guide the couple Tilth the 4-0-60 split of income. Separate additional tables would likewise be required for each different division of income if taxpayers are to be guided to joint or separate returns by the use of tables* . 1/ Some of the variations in' the ranges of advantage caused by variations I n the division of income are illustrated in the attached Exhibit 1* It should be noted that, as the figures in table 3 in the statement indicate, the ranges of advantage vary with the number of dependents. This is further demonstrated in Exhibit 2, * From these examples and the tables here presented, it is clear, as the Treasury previously pointed out, that both the division of income and the number of dependents are important in determining the zones of advantage for one type of return or the other. Moreover, they bring into clear focus the important practical consideration that a number of tables like sample table 3 would be necessary to meet the bulk of taxpayer situations. These tables would have various maximum and minimum limits for the income- of each spouse for various dependency statuses. Such tables would tend to overlap, with a taxpayer finding himself on more than one table, thus adding to the confusion and complexity. As the number of such guide tables was increased, an increase ing number of taxpayers would come within the purview of one or more tables, The complexity of such a system of multiple guides would render them imprac-^ ticable. An analysis of table 4-, page 10 of the statement of the Joint Committee Staff, brings out clearly the essential difference between the joint vs, separate returns problem in the regular income tax area under the House bill as compared with the problem under either the present law or the Treasury integration proposal. As the table shows, the amount of combined net income above which separate returns become advantageous varies under all three tax methods with the number of dependents, Vfhat the table docs not show is the fact that the point above which separate returns become advantageous is fixed in terms of surtax net income under both present law and the Treasury proposal. Under present law this point is at 32,000 of combined surtax net income $ under the Treasury proposal involving a- $500 first income bracket, this point would be $500 combined surtax net income, These points are constant regardless of the number of dependents ajid regardless of the division of income, By striking contrast, under the House bill this point varies in terms of surtax net income with both the number of dependents and the percentage division of income. 17 In addition to the defects' of the lower limit's ^ admitted on page 12 of the statement of the Joint Committee Staff, this analysis shows that the upper limits of table 3 are ambiguous. 11 In this connection, it should be noted that, just as in table 3, the breaking-points under the House bill indicated in table 4 / page 10 oi the Joint Staff statement would hold only under the 50-*50 division of income which is implicitly assumed in the table* If^ for example, a couple without dependents had somewhat more than $4*734 (2 times $2*367) divided 43-35 instead of 30^50 as in table 4, separate returns wonld not be desirable. y With a mere uneven distribution of income the incomes at the breaking points increase* On page 10 the Joint Staff statement asserts as an advantage of the House bil.3, that it raises the amount of combined net income above which it is desirable for a married couple without dependents to file separate returns from $3,200 to $4,733* -it the same time it cites the lowering of this amount to $1,600 under the Treasury proposal as a disadvantage* This argument entirely misses the es sential point that, putting aside equity questions and looking at the problem from the standpoint of simplification or complexity, it makes no significant difference whether this point is high or low# The important thing for purposes of simplification is that the point be clearly defined and readily determinable. Under both the present law and the Treasury proposal the breaking-point is constant in terms of surtax net income, and may be computed at a glance in terms of net income* Under the House bill the breaking-point is variable and difficult to determine# II• Complexity in having a minimum tax Side by side with the regular tax The Committee staff states on page 4 that, because a table guiding tax payers into either the minimum or the regular tax can be prepared, the Treasury is wrong in asserting that there will be two alternative taxes, that is, the minimum tax and the regular tax, side by side under the House bill. Aside from the disadvantage that the tabular guide will itself bo a device new to American taxpayers, it is obvious that the preparation of mechanical guides does not conjure the minimum tax out of existence# There are still two taxes (one of them entirely new) to be explained, two taxes to be understood, and two taxes to be dealt, with* Those who explain the tax by written or spoken work will have to labor through both the minimum tax and the regular tax; no mechanical guide can relieve them of the task of explaining, nor the taxpayer from the task of trying to understand, two different taxes with intricate interrelations* For many married couples, moreover, the two taxes will actually be side by side as a practical matter in the course of their tax computations# Many couples filing separate returns will find that the husband is subject to the regular tax and the wife to the minimum tax, or vice versa* It is to be noted that the Joint Committee staff did not dispute the example given in the Treasury’s state ment illustrating this point (page 26 of the Hearings)* The cases where husband and wife will be subject to two different taxes, with different exemptions and rates, will not be at all rare under the House bill* Taking merely the case cited in the Treasury’s statement, we see that with the husband’s income at $900, he would be subject to the regular tax, while his wife would be subject to the minimum tax if her income fell anywhere between $600 and $888* Two taxes side by side will be a very real problem for numerous taxpayers*____ ______________________ 1/ If the split was 45-r55, separate returns would result in a total tax of $862 as compared with $859 under a joint return* An increase in the inequality of the division of income between husband and wife would increase the disadvantage of separate returns at this combined net income level. III. Complication of withholding under House Bill The Treasury has stated that the provision of the House Bill substituting varying minimum tax exemptions for the present fixed Victory tax exemption would complicate withholding operations (Hearings, p. 28, 29), This conclu sion is attacked on page 13 of the Joint Staff statement* It is asserted that a table would be provided from which employers could readily determine, in each individual case, whether withholding is to be computed by use of the minimum tax or the regular income tax rates and exemptions. This answer does not meet the point in question for the many employers who use the more accurate ’’precise*1 method of withholding. A table of this sort would of course be provided, and is in fact in use under present law. The complication is introduced, however, in the next step after the employer has used such a table to determine which of the alternative bases for with holding applies. Under present law if ha finds that Victory tax withholding is appropriate, the remaining computation consists merely of the application of a 3 percent rate to the excess of the wages over a uniform withholding exemption, for example, $12 for a weekly payroll, regardless of the wageearner’s family status.. Under the House Bill if he found that minimum tax withholding applied, his computations would require use of a separate set of exemptions that vary with family status as do those for regular income-tax withholding. Under the Treasury integration proposal, withholding would be least complicated since there would be only one set of exemptions and rates to apply. Under present law, payroll procedures are simplified by the fact that all wage earners subject merely to Victory tax withholding can be treated uniformly. Under the House Bill, complications would be increased since differentiation according to family status would be required for both minimum and regular taxes. IV. Other points on integration A. Administrative problem under House Bill 1. The Joint Staff statement attempts to rebut the Treasury’s conten tion that the House Bill would unduly complicate the administrative process by stating (on page 12) that elimination of 2.4 million returns ’’cannot be termed an addition to the problem of administration.” This truism does not constitute an answer to the evidence presented by the Treasury to show that administrative burdens would be greatly increased under the House Bill. The benefits of elimi nating 2.4 million returns would be far more than offset by the complexities of the tax computations, the resultant large numbers of errors, and the necessity for furnishing the majority of taxpayers with assistance in determining the most advantageous method of filing under the House Bill. 2. On page 15 of the Joint Staff statement it is argued that the costs of administration attributable to the returns of the 9 million taxpayers eliminated under the Treasury integration plan would n o t be as great as the revenue that would be collected from them* Quite aside from the untenable implication that a tax is worthwhile if it does not cost 100 percent to collect is the fact that in judging whether an administrative expenditure is worthwhile alternative operations must be considered, Insofar as personnel is freed from the administrative tasks involved in the handling of these millions of minor items, increased attention could be devoted to more adequate collection from other more profitable areas of the tax base with results that might be expected to exceed the amount of revenue lost by eliminating these small taxpayers* Moreover, any consideration of the costs of maintaining these small accounts on the tax rolls should include the withholding burdens imposed upon employers and the taxpayers’ own tasks of compliance, as well as merely costs to the Bureau of Internal Revenue# B* Estimated revenue from the minimum tax On page 13 the Joint Staff statement implies that the Treasury represented the yield of the minimum tax at $161,000,000, whereas the actual yield would be more* The Treasury figure does not relate and was never intended to relate to the whole minimum tax* It is the estimate of how much the 9. million persons who would be wholly relieved from income tax under the Treasury proposal would pay under the House Bill* C. Relationship of Treasury integration proposal to remainder of the Treasury individual income tax proposal The Joint Staff statement indicates (pp» 4-) that the Treasury did not present an integration proposal to the Committee on Ways and Means. The Treasury income tax proposals to the Congress this Fall have from the first contained the integration element* The proposal submitted to the Ways and Means Committee was designed not only to raise revenue but to absorb the Victory tax burden into the regular income tax structure* At that time, no need was seen for signling out the integration features of the proposal for separate presentation* It was thought that integration would be accomplished as part of a general increase in income tax rates together with other changes (such as lowered exemptions and repeal of the earned income credit),ahd that a separate discussion of the integration segment of the proposal would merely complicate the problems before the Ways and Means Committee* However, the Senate Finance Committee was confronted with a specific integration proposal in the House Bill* Hopes for a general upward revision of income tax rates had not materialised. Therefore, to aid the Committee in the consideration of matters before it, the integration segment of the Treasury proposal was treated separately to facilitate analysis and comparison with the integration provisions of the House Bill* (Hearings, pp. 25*^32) - H D. - Consistency of Treasury position Although not a technical point there is one other statement in the Joint Staff statement that calls for comment. On page 3 it is stated that the Treasury position before the House Ways and Means Committee was that lfthere was no better way of accomplishment^ of the objective of taxing those now subject only to Fictory tax than the integration plan now contained in the House Bill. This is not an adequate presentation of the position taken by the Treasury before the Ways and Means Committee. The Treasury was asked its opinion of the plan with no advance knowledge of the plan. On the basis of a hasty review of the major points of the proposal over a few minutes a tentative reaction was given to the Committee that at the moment no better alternative came to mind to accomplish the objective of keeping on the tax rolls the 9j000,000 taxpayers at the bottom of the taxable income scale. After the Treasury had had an opportunity to study the integration plan now in the House Bill, it stated unequivocally to the Committee on Ways and Means that the plan was hopele s s l y complicated.11 However, the Treasury was not afforded an opportunity to discuss its objections in detail before the Ways and Means Committee. It is to be noted that the Joint Staff statement failed to mention the later clarification of the Treasury position on the House Bill integration plan# Exhibit 1 Income ranges within which it is advantageous for married couples to file (a) separate or (b) Joint returns under Ht R. 3687., assuming three different percentage divisions of income between ' husband and wife Married couple — one dependent 1/ Comb ined net income Type of return resulting in. Income divided : Income-divided : Income divided: lesser tax 60 - 40 ' 70 - 30 \ : ___ 5P - 50 $ 800 - $1,071 1,071 - «5,167 Over 5,167 $ 800 - $1,363 1,363 - $ 800 - $1,309 Separate 5,558 1,309 - 5,898 Joint Over 5,558 Over 5,898 Separate ispsl Treasury Department, Division of Tax Research December 8, 1943 1/ Assuming dependent credit takeh by-spouse with larger income. Exhibit 2 Income ranges within which it is advantageous for married couples to file (a) separate or (b) joint returns under H, Fu 3687, assigning three different dependency statuses 1/ . ______ No dependents $ 700 - ft* 045 Combined net i n c o m e _______ sType of return : One dependent sTwo dependents: resulting in • ______ j_______________; lesser tax $ BOO - ift, 433 $ 900 - $1,820 Separate 1,045 * 4/733 1,433 - 5,033 1,820 - 5,433 Joint Over 4,733 Over 5,083 Over 5,433 Separate Treasury Department, Divisible M Eeseardh December 8, 1943 1/ Division of income between husband and wife assumed to be such that the potential advantage from the use of either type of return will be at a maximum. - 3 - y. Gmmkt provisions 1. As fiscal agents of the United States, Federal Reserve Banks are authorised and requested to receive subscriptions, to make allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the Federal Reserve Banks of the respective Districts, to issue allotment notices, to receive payment for cer tificates allotted, to make delivery of certificates on full-paid subscriptions allotted, and they may issue interim receipts pending delivery of the definitive certificates. 2. The Secretary of the Treasury may at any time, or from time to time, pre scribe supplemental or amendatory rules and regulations governing the offering, which will be communicated promptly to the Federal Reserve Banka. KERRY MORGBHTHAU, JH., Secretary of the Treasury. tions of $1,000, $5,000, $10,000, $100,000 and $1,000,000. The certificate® will not be issued in registered form* 5. The certificates will be subject to the general regulations of the Treasury Department, now or hereafter prescribed, governing United States certificates. in. subscription Aim kuxymmt 1. Subscriptions will be received at the Federal Reserve Banka and Branches and at the Treasury Department, Washington. Commercial banks are requested not to pur chase and subscribers are requested not to trade in the securities allotted hereunder until after February 15, 1944. Banking institutions generally may submit subscrip tions for account of customers, but only the Federal Reserve Banks and the Treasury Department are authorised to act as official agencies. Others than banking institu tions will not be permitted to enter subscriptions except for their own account. Subscriptions must be accompanied by payment in full for the amount of certificates applied for. 2. The Secretary of the Treasury reserves the right to reject any subscription, in whole or in part, to allot less than the amount of certificates applied for, and to close the books as to any or all subscriptions at any time without notice; and any action he may take in these respects shall be final. all subscriptions will be allotted in full. Subject to these reservations, Allotment notices will be sent out prompt upon allotment• IV. PATUK8T 1. Payment at par and accrued interest, if any, for certificates allotted here under must be made on or before February 1, 1944, or on later allotment. accrued interest is $0,024 per $1,000. One day's Any qualified depositary will be permitted to make payment by credit for certificates allotted to its customers up to any amount for which it shall be qualified in excess of existing deposits, when so notified by the Federal Reserve Bank of its District. UNITED STATES OF AMERICA 7/8 Percent Treasury Certificates of Indebtedness of Series A-1945 Dated and bearing interest from February 1, 1944 1944 Department Circular No. 731 Due February 1, 1945 TREASUHT DEPARTMENT, Office of the Secretary, Washington, January 18, 1944. Fiscal Service Bureau of the Public Debt X. 1. OFFOTDBG OF CERTIFICATES The Secretary of the Treasury, pursuant to the authority of the Second liberty Bond Act, as amended, invites subscriptions, at par and accrued interest, from the people o f the United States for certificates of indebtedness of the United States, designated 7/8 percent Treasury Certificates of Indebtedness of Series A-1945. These certificates will not be available for subscription, for their own account, by commercial banks, which are defined for this purpose as banks accepting demand de posits. The amount of the offering is not specifically limited. II. 1. DESCRIPTION OF CERTIFICATES The certificates will be dated February 1, 1944, and will bear interest from that date a t the rate of 7/8 percent per annum, payable semiannually on August 1, 1944 end February 1, 1945. They will mature February 1, 1945, end will not be subject to call for redemption prior to maturity. 2. The Income derived from the certificates shall be subject to all Federal tax*. now or hereafter imposed. The certificates shall be subject to estate, inheritance, gift or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the poseesaions of the United States, or by any local taxing authority. > - 3. The certificates will be acceptable to secure deposits of public moneys. Thflf will not be acceptable in payment of taxes. 4. Bearer certificates with interest coupons attached will be issued in denosdna ■7 1. ?. GfflIBRAL PROVISIONS As fiscal agents of the United States, Federal Reserve Banks are authorised and requested to receive subscriptions, to sake allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the Federal Reserve Banks of the respective Districts, to issue allotment notices, to receive payment for h a n d b a l l © t t e d J to make delivery of bonds on full-paid subscriptions allotted, and they may issue interia receipts pending delivery of the definitive bonds* 2. The Secretary of the Treasury may at any time, or from time to time, prescribe supplemental or amendatory rules and regulations governing the offering, which will be communicated promptly to the Federal Reserve Banks. BSBHt MDRGSRTKAIJ, JR., Secretary of the Treasury. - 4 - M course by formal receipt from the Collector of internal Revenue. 6. Except as provided in the preceding paragraphs, the bonds will be subject to the general regulations of the Treasury Department, non or hereafter prescribed, governing United States bonds. III. 1. S0BSCRIPTIOH AND A I X O B O T T Subscriptions will be received at the Federal Reserve Banks and Branches and at the Treasury Department, Washington. Subscribers are requested not to trade in the securities allotted hereunder until after February 15, 1944. Banking Institutions generally nay submit subscriptions for account of customers, but only the Federal Re serve Banks and the Treasury Department are authorised to act as official agencies. Others than banking institutions will not be permitted to enter subscriptions except fop their own account. Subscriptions must be accompanied by payment in full for the amount of bonds applied for. 2. In whole The Secretary of the Treasury reserves the right to reject any subscription, op In part, to allot loss than the amount of bonds applied for, and to close the books as to any or all subscriptions at any time without notice; and any action he ■ay take in these respects shall be final. Subject to these reservations, and to the limitations on commercial bank subscriptions prescribed in Section I of this circular, all subscriptions will be allotted in full. Allotment notices will b e sent out promptly upon allotment. IF. 1. PAUfisBF Payment at par and accrued interest, if any, for bonds allotted hereunder must be made on or before February 1, 1944, or on later allotment. ( i s 10.062 per 11,000. One day's accrued inters! Any qualified depositary will b e permitted to make payment by credit for bonds allotted to it for itself and Its customers up to any amount for which it shall be qualified in excess of existing deposits, when so notified by the Federal Reserve Bank of Its District. 5. Any bond# issued hereunder which upon the death of the owner constitute part of his estate, will be redeemed at the option of the duly constituted representatives 1 of the deceased owner* s estate, at par and accrued interest to date of payment,— Pro vided: (a) that the bonds were actually owned by the decedent at the time of his death; and (b) that the Secretary of the Treasury be authorised to apply the entire proceeds of redemption to the payment of Federal estate taxes. Registered bonds submitted for redemption hereunder must be duly assigned to *?he Sec retary of the Treasury for redemption, the proceeds to be paid to the Collector of Internal Revenue at __ _ _ _ _ for credit on Federal estate taxes due from estate of .* Owing to the periodic closing of the transfer books and the impossibility of stopping payment of interest to the registered owner during the d o s e d period, registered bonds received after the closing of the books for payment dur ing such closed period will fee paid only at par with a deduction of interest from the 2[ti2ft km - date of payment to the next interest payment date;-* bonds received during the closed period for payment at a date after the books reopen will be paid at par plus accrued interest from the reopening of the books to the date of payment. In either case checks 7 for the full six months* interest due on the last day of the closed period will be for warded to the owner in due course. PD 1782,2 All bonds submitted must be accompanied by Form properly completed, signed and sworn to, and by a certificate of the appoint ment of the personal representatives, under seal of the court, dated not more than six months prior to the submission of the bonds, which shall show that at the date thereof the appointment was still in force and effect. Upon payment of the bonds appropriate memorandum receipt will be forwarded to the representatives, which will be followed in 1* An exact half-year* s interest is computed for each full half-year period i r r e specify of the actual number of days in the half year* For a fractional part of any half year, 1 computation is on the basis of the actual number of days in such naif year. 2. The transfer books are closed from February 16 to March 15, and from August 16 to "September 15 (both dates inclusive) in each year. 3. Copies of Form PD 1782 may be obtained from any Federal Reserve Bank or from the Treasury Department, Washington, D. C. - 2 - at the rate of 2-1/4 percent per annum, payable on a semiannual basis on September 15, 1944, and thereafter on March 15 and September 15 in each year until the principal amount becomes payable. They will mature September 15, 1959, but may be redeemed at th«] option of the United States on and after September 15, 1956, in whole or in part, at par| and accrued interest, on any interest day or days, on 4 months' notice of redemption given in such manner as the Secretary of the Treasury shall prescribe. In case of par tial redemption the bonds to be redeemed will be determined by such method as may be prescribed by the Secretary of the Treasury. From the date of redemption designated in any such notice, interest on the bonds called for redemption shall cease* Ill 2. The income derived from the bonds shall be subject to all Federal taxes, now or hereafter imposed. The bonds shall be subject to estate, inheritance, gift or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the pos sessions of the United States, or by any local taxing authority. 3. The bonds will be acceptable to secure deposits of public moneys. They will not be entitled to any privilege of conversion. 4. Bearer bonds with interest coupons attached, and bonds registered as to prin cipal and Interest, will be issued in denominations of $500, $1,000, $5,000, $10,000, $100,000 and $1,000,000. Provision will be made for the Interchange of bonds of dif ferent denominations and of coupon and registered bonds, and for the transfer of regis tered bonds, under rules and regulations prescribed by the Secretary of the Treasury. Except as provided in Section I of this circular, these bonds may not, before September 15, 1946, be transferred to o r be held by commercial banks, which are defined for this purpose as banks accepting demand deposits; however, the bonds may be pledged as collat-j eral for loans, including loans by commercial banks, but any such bank acquiring such bonds before September 15, 1946, because of the failure of such loans to b e paid at maturity will be required to dispose of them in the same manner as they dispose of ©the* assets not eligible to be owned by banks. QHITSD STATES OF AMERICA 2-1/4 PESCaif TR3ASWHT BCBDS OF 1956-59 Dated and bearing interest from February 1, 1944 Due September 15# 1959 REDEEMABLE AT THE OPTION OF THE UNITED STATES AT PAR AND ACCRUED INTEREST ON AND AFTER SEPTEMBER 15, 1956 Interest payable March 15 and September 15 TREASURY DEPARTMENT, Office of the Secretary, Washington, January IS, 1944. 1944 Department Circular No. 730 Fiscal Service Bureau of the Public Debt I. 1, OFFERING OF BONDS The Secretary of the Treasury, pursuant to the authority of the Second Liberty Bond Act, as amended, invites subscriptions, at par and accrued interest, from the people of the United States for bonds of the United States, designated 2-1/4 percent Treasury Bonds of 1956-59* 2. The amount of the offering is not specifically limited. These bonds will not be available for subscription, for their own account, by commercial banks, which are defined for this purpose as banks accepting demand deposits, except as follows: a commercial bank holding savings deposits as defined in Regulation of the Board of Governors of the Federal Reserve System may subscribe to the bonds of fered hereunder, to the 2-1/2 percent Treasury Bonds of 1965-70 offered simultaneously herewith under Treasury Department Circular No. 729# and to Series F-1944 and Series G-1944 United States Savings Bonds under Treasury Department Circular No. 654# Second Revision, but the amount of such subscriptions shall not exceed, in the aggregate, 10 pe cent of the savings deposits as shown on the bank1s books as of the date of the most recent call statement required by the supervising authorities prior to the date of sub scription for such bonds, or $200,000, whichever is less. No such bank shall hold more than $100 ,000 (issue price) of Series F and Series G Savings Bonds (Series 1944)# combin II. 1. DESCRIPTION OF BONDS The bonds will be dated February 1, 1944# and will bear interest from that dat« V. 1. GJ23SEAL PROVISIONS As fiscal agents of the United States, Federal Reserve Banks are authorised and requested to receive subscriptions, to make allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the Federal Reserve Banks of the respective Districts, to issue allotment notices, to receive payment for bonds allotted, to make delivery of bonds on full-paid subscriptions allotted, and they may issue in terim receipts pending delivery of the definitive bonds. 2. The Secretary of the Treasury may at any time, or from time to time, prescribe supplemental or amendatory rules and regulations governing the offering, which will be communicated promptly to the Federal Reserve Banks. h ©; r t k o r g s n t h a u , j r ., Secretary of the Treasury. memorandum receipt will be forwarded to the representatives, which will be followed in due course by formal receipt from the Collector of Internal Revenue. 6. Except as provided in the preceding paragraphs, the bonds will be subject to the general regulations of the Treasury Department, now or hereafter prescribed, govern ing United States bonds. III. 1. SUBSCRIPTION AND AlLOTMisHT Subscriptions will be received at the Federal Reserve Banks and Branches and 1 at the Treasury Department, Washington. Subscribers are requested not to trade in the securities allotted hereunder until after February 15, 1944. Banking institutions gen- ©rally may submit subscriptions for account of customers, but only the Federal Reserve Banks and the Treasury Department are authorized to act as official agencies. Others than banking institutions will not be peraitted to enter subscriptions except for their own account. Subscriptions must be accompanied by payment in full for the amount of bonds applied for. 2. The Secretary of the Treasury reserves the right to reject any subscription, in whole or in part, to allot less than the amount of bonds applied for, and to close the books as to any or all subscriptions at any time without notice; and any action he may take in these respects shall be final. Subject to these reservations, and to the limitations on commercial bank subscriptions prescribed in Section I of this circular, all subscriptions will be allotted in full. Allotment notices will be sent out promptly upon allotment. IV. 1. PAYMENT Payment at par and accrued interest, If any, for bonds allotted hereunder must be made on or before February 1 , 1 9 4 4 , or on later allotment. is 1 0 .0 6 9 per 1 1 ,0 0 0 . One day’s accrued interesj Any qualified depositary will be permitted to make payment by credit for bonds allotted to it for itself and its customers up to any amount for which it shall be qualified in excess of existing deposits, when so notified by the Federal Reserve Bank of its District. - 3 5. Any bonds issued hereunder which upon the death of the owner constitute part of his estate, will be redeemed at the option of the duly constituted representatives of the deceased owner* s estate, at par and accrued Interest to date of payment,"’* Pro vided: (a) that the bonds were actually owned by the decedent at the time of his death; and (b) that the Secretary of the Treasury be authorised to apply the entire proceeds of redemption to the payment of Federal estate taxes* Registered bonds submitted for redemption hereunder must be duly assigned to "The Sec retary of the Treasury for redemption, the proceeds to be paid to the Collector of Internal Revenue at ..... ... for credit on Federal estate taxes due from esta ^ *" Owing to the periodic closing of the transfer books and --- — ..... the impossibility of stopping payment of interest to the registered owner during the closed period, registered bonds received after the closing of the books for payment dur ing such closed period will be paid only at par with a deduction of interest from the * 2 date of payment to the next interest payment date;** bonds received during the closed period for payment at a date after the books reopen will be paid at par plus accrued interest from the reopening of the books to the date of payment. In either case checks for the full six months* interest due on the last day of the closed period will be for warded to the owner in due course* _ PD All bonds submitted must be accompanied by Form o properly completed, signed and sworn to, and by a certificate of the appoint ment of the personal representatives, under seal of the court, dated not more than six months prior to the submission of the bonds, which shall show that at the date thereof the appointment was still in force and effect. Upon payment o f the bonds appropriate i* exact half—year*s interest is computed for each full half-year period irrespectiT of the actual number of days in the half year. For a fractional part of any half year, computation is on the basis of the actual number of days in such half year. 2. The transfer books are closed from February 16 to March 15, and from August 16 to September 15 (both dates inclusive) in each year. 2 * Copies of Form PD 1782 may be obtained from any Federal Reserve Bank or from the Treasury Department, Washington, D. C. at the rate of 2-1/2 percent per annum, payable on a semiannual basis on September 15, 1944, and thereafter on March 15 and September 15 in each year until the principal amount becomes payable. They will mature March 15, 1970, but may be redeemed at the option o f the United States on and after March 15, 1965, in whole or t** part, at par and accrued interest, on any interest day or days, on 4 months' notice of redemption given in such manner as the Secretary of the Treasury shall prescribe. In case ©f partial re demption the bonds to be redeemed will be determined by such method as may be prescribe* by the Secretary of the Treasury* Fro® the date of redemption designated in any such notice, interest on the bonds called for redemption shall cease. 2. The income derived from the bonds shall be subject to all Federal taxes, now or hereafter imposed. The bonds shall be subject to estate, inheritance, gift or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the pos sessions of the United States, or by any local taxing authority. 3. The bonds will be acceptable to secure deposits of public moneys• They will not be entitled to any privilege of conversion. 4* pal and Bearer bonds with interest coupons attached, and bonds registered as to princi interest,(will beissued-in $100,000 and $1,000,000. denominations of $500, $1,000, $5,000, $10,000, j Provision will be made for the Interchange of bonds of differs denominations and of coupon and registered bonds, and for the transfer of registered bonds, under rules and regulations prescribed by the Secretary of the Treasury. Except 1 as provided in Section I of this circular, these bonds may not, before February 1, 1954#] be transferred to or bo held by commercial banks, which are defined for this purpose as 1 banks accepting demand deposits; however, the bonds may be pledged as collateral for loans, including loans by commercial banks, but any such bank acquiring such bonds befoij February 1, 1954, because of the failure of such loans to be paid at maturity will be required to dispose of them in the same manner as they dispose of other assets not eligi| to be owned by banks. UNITED STATES OF AMERICA 2-1/2 PERCENT TREASURY BONDS OF 1965-70 Dated and bearing interest fro© February 1, 1944 Due March 15, 1970 REDEEMABLE AT THE OPTION OF IBS UNITED STATES AT PAR AMD ACCRUED INTEREST ON AND AFTER MARCH 1$, 1965 Interest payable March 15 and September 15 1944 Department Circular No. 729 ____ TREASURY DEPARTMENT, Office of the Secretary, Washington, January 18, 1944. Fiscal Service Bureau of the Public Debt \ I. 1. OFFERING OF BONDS The Secretary of the Treasury, pursuant to the authority of the Second Liberty Bond Act, as amended, invites subscriptions, at par and accrued interest, from the people of the United States for bonds of the United states, designated 2-1/2 percent Treasury Bonds of 1965-70. 2. The amount of the offering is not specifically limited. These bonds will not be available for subscription, for their own account, by commercial banks, which are defined for this purpose as basks accepting demand deposits, except as follows: a commercial bank holding savings deposits as defined in Regulation of the Board of Governors of the Federal Reserve System may subscribe to the bonds of fered hereunder, to the 2-1/4 percent Treasury Bonds of 1956-59 offered simultaneously herewith under Treasury Department Circular No. 750, and to Series F-1944 and Series G-1944 United States Savings Bonds under Treasury Department Circular No. 654, Second Revision, but the amount of such subscriptions shall not exceed, in the aggregate, «**■ 10 percent of the savings deposits as shown on the bank’s books as of the date of the most recent call statement required by the supervising authorities prior to the date of subscription for such bonds, or 1200,000, whichever is less. No such bank shall hold more than $100,000 (issue price) of Series F and Series G Savings Bonds (Series 1944), combined. II. 1. DESCRIPTION OF BONDS The bonds will be dated February 1, 1944, and will bear interest from that date TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS, Storsday. M e m b e r 16. 1043. Press Service 39 - Secretary of the Treasury Morgenthau today released the official «!*• * ~ ~ Z ---------- 7 ^ * » —W W W W A M Q WUW * V M * UU WO*- M U H i l tfi'iVB bO %Qf d>4./,4 percent and the 2«*l/2 percent bonds* Such banks will also be permitted to subscribe to Series F and Series G savings bonds on and after January 1 l$4i The formula for commercial bank participation in these securities is that any bank holding savings deposits as defined in Regulation Q of the Board of Governors of the Federal Reserve System n a y subscribe to any or all of the four bonds in an amount not to exceed, in the aggregate, lOpereent of its savings deposits as shown on the bank*® books as of the date of the «ost recent call sta tement required by the supervising authorities prior to the date of subscribing for such bonds, or $200,000, whichever is less* Under no circumstances, however, will a bank be allowed to hold more than §100,000 (issue price) of Series F and Series G savings bonds (Series 1944)» combined*’, All subscriptions received from commercial banks under this formula are to be considered outside of the goal of $14,000,000,000 and will not be a part of any quotas* The texts of the official circulars followt TREASURY DEPARTMENT Washington FOR RELEASE, M O R N I N G N E W S P A P E R S , T h u r s d a y , D e c e m b e r 16, 1 9 4 5 . S e c r e t a r y of official circulars tions the of a n d the bonds the T r e a s u r y M o r g e n t h a u containing the 2-1/2 percent and 7/8 p e r c e n t which will be sol d , and Treasury Drive beginning Press No# Treasury today detailed Service 39-93 released terms a n d the condi 2-1/4 p e r c e n t T r e a s u r y bonds, certificates together with Series savings notes, during of E, the indebtedness, P and. G s a v i n g s Fourth War Loan J a n u a r y 18. The S e c r e t a r y a n n o u n c e d that com m e r c i a l banks h o l d i n g s a v i n g s d e p o s i t s w i l l be p e r m i t t e d to s u b s c r i b e d u r i n g t h e F o u r t h W'ar L o a n D r i v e to the 2 - 1 / 4 p e r c e n t a n d t h e 2 - 1 / 2 p e r c e n t bonds. S u c h b a n k s w i l l a l s o b e p e r m i t t e d to s u b s c r i b e to S e r ies F a n d S e r i e s G s a v i n g s b o n d s o n a n d a f t e r J a n u a r y 1, 1 9 4 4 # The formula for commercial b a n k p a r t i c i p a t i o n in these s e c u r i t i e s is t h a t a n y b a n k h o l d i n g .savings d e p o s i t s a s d e f i n e d in R e g u l a t i o n Q o f the B o a r d of G o v e r n o r s o f t h e F e d e r a l R e s e r v e S y s t e m m a y s u b s c r i b e to a n y o r a l l of the f o u r b o n d s in a n a m o u n t n o t to e x c e e d , in the a g g r e g a t e , 10 p e r c e n t o f its s a v i n g s d e p o s i t s as s h o w n o n the b a n k ’s b o o k s as of the d a t e o f the m o s t r e c e n t c a l l s t a t e m e n t r e q u i r e d b y the s u p e r v i s i n g a u t h o r i t i e s p r i o r to t h e d a t e o f s u b s c r i b i n g f o r s u c h b o n d s , o r J 2 0 0 , 0 0 0 , w h i c h e v e r is l e ss. U n d e r no circumstances, however, w i l l a b a n k b e a l l o w e d to h o l d m o r e t h a n $ 1 0 0 ,0 0 0 ( i s s u e p r i c e ) of S e r i e s F a n d S e r i e s savings bonds (Series 1944), combined# All subscriptions received from commercial banks this f o r m u l a a r e to b e c o n s i d e r e d o u t s i d e of the g o a l $ , 1 4 , 0 0 0 , 0 0 0 , 0 0 0 a n d w i l l n o t be a p a r t o f any q u o t a s , The texts of the official circulars under of follow; s UNITED STATES OF AMERICA 2—1/2 PERCENT TREASURE BONDS OF 1965-70 Dated and bearing interest from February X9 1944 Due March 15, 1970 REDEEMABLE AT TIE OPTION OF THE UNITED STATES AT PAR AND ACCRUED INTEREST ON AND A£TBR MARCH 15, 1965 Interest payable March 15 and September 15 TREASURY DEPARTMENT, Office of the Secretary, Washington, January IS, 1944o 194-4 Department Circular No© 729 Fiscal Service Bureau of the Public Debt I© OFFERER! OF BONDS 1. The Secretary of the Treasury, pursuant to the authority of the Second Liberty Bond Act, as amended, invites subscriptions, at par and accrued interest, from the people of the United States for bonds of the United States, designated 2- 1/2 percent Treasury Bonds of 1965-70. The amount of the offering is not specifically limited, 2, These bonds m i l not be available for subscription, for their own account by commercial banks, which are defined for this purpose as banks accepting demand deposits, except as follows? a commercial bank holding savings deposits as defined in Regulation Q of the Board of Governors of the Federal Reserve System may subscribe to the bonds offered hereunder, to the 2-1/4 percent Treasury . Bonds of 1956-59 offered simultaneously herewith under Treasury Department Circular No. 730, and to Series F-1944 and Series G-1944 United States Savings Bonds under Treasury Department Circular No. 654, Second Revision, but the amount of such subscriptions shall not exceed, in the aggregate, 10 percent of the savings deposits as shown on the bank’s books as of the date of the most recent call statement required by the supervising authorities prior to the date of subscription for such bonds, or $200,000, whichever is less, No such bank shall hold more than $100,000 (issue price) of Series F and Series G Savings Bonds (Series"1944)> combined, II. DESCRIPTION OF BONDS 1, The bonds will be dated February 1, 1944, and will bear interest from that date at the rate of 2— 1/2 percent per annum, payable on a semiannual basis on September 15, 1944, and thereafter on March 15 and September 15 in each year until the principal amount becomes payable. They will mature March 15, 1970, but may be redeemed at the option of the United States on and after March 15,1965, in whole or in part, at par and accrued interest, on any interest day or days, on 4 months’ notice of redemption given in such manner as the Secretary of the ~ 2 Treasury shall prescribe* In case of partial redemption the bonds to be redeemed will be determined by such method as may be prescribed by the Secretary of the Treasury. From the date of redemption designated in any such notice, interest on the bonds called for redemption shall cease. 2, The income derived fr&m the bonds shall be subject to all Federal taxes, now or hereafter imposed. The bonds shall be subject to estate, inherit*./: ance, gift or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by an local taxing authority. 3. The bonds will be acceptable to secure deposits of public moneys. will not be entitled to any privilege of conversion. They , 4* Bearer bonds with interest coupons attached, and bonds registed as to principal and interest, will be issued in denominations of $$ 00, $ 1 ,000, $ 5, 000, $ 10 , 000, $100,000 and $ 1 ,000, 000. Provision will be made for the interchange of bonds of different denominations and of coupon and registered bonds, and for the transfer of registered bonds, under rules and regulations prescribed by the Secretary of the Treasury, Except as provided in Section I of this circular, these bonds may not, before February 1 , 1954; be transferred to or be held by commercial banks, which are defined for this purpose as banks accepting demand deposits; however, the bonds may be pledged as collateral for loans, including loans by commercial banks, but any such bank acquiring such bonds before February 1 , 1954, because of the failure of such loans to be paid at maturity will be required to dispose of.them in the same manner as they dispose of other assets not eligible to be owned by banks, 5. Any bonds issued hereunder which upon the death of the owner constitute part of his^ estate, will be redeemed at the option of the duly constituted representatives of the deceased owner*s estate, at par and accrued interest to date of payment, A/ Provided; (a) that the bonds were actually owned by the decedent at the time of his death; and (b) that the Secretary of the Treasury be authorized to aPPly "the entire proceeds of redemption to the payment of Federal estate taxes. Registered bonds submitted for redemption hereunder must be duly assigned to "The Secretary of the Treasury for redemption, the proceeds to be paid to the Collector of Internal Revenue at . for credit on Federal estate taxes due from estate of _____ _____________ ,» Qv&ng to the periodic closing of the transfer books and the impossibility of stopping payment of interest to the registered owner during the closed period, registered bonds received after the closing of the books for payment during such closed period will be paid only at par with a deduction of interest from the date of payment to the next y An exact half-year’s interest is computed for each full half-year period irrespective of the actual number of days in the half year. For a frac4tional part of any half year, computation is on the basis of the actual number of days in such half year. - 3 interest payment date; 1/ bonds received during the closed period for payment at a date after the books reopen -will be paid at par plus accrued interest from the reopening of the books t o ‘.the date of payment*- In either case checks for the full six months 1 interest due on the last day of the closed period M i l be forwarded to the owner in due course•• All bonds submitted must be accompanied by Form PD 1782, 2/ properly completed, signed and sworn to, and by a certif icate of the appointment of the personal representatives, under seal of the court, dated not more than six months prior to the submission of the bonds, which shall show that at the date thereof the appointment was still in force and effect,' Upon payment of the bonds appropriate memorandum receipt will be forwarded to the representatives, which will be followed in due course by formal receipt from the Collector of:Internal Revenue,- 6 ,' Except as provided in.the preceding paragraphs,' the bonds will be - subject to the general regulations of the Treasury Department, now or hereafter prescribed, governing United States bonds, Ilf, SUBSCRIPTION AND A L I O T M T O 1, Subscriptions will be received at the Federal Reserve Banks and Branches and at the Treasury Department, Washington, Subscribers are requested not to trade in the securities allotted hereunder until after February 1 £, 19 44 . Banking institutions generally may submit subscriptions for account of customers, but only the Federal Reserve Banks and the Treasury Department are authorized to act as official agenciesf Others than banking institutions will not be permitted to enter subscriptions except for their own account.- Subscriptions must be accompanied by payment in full for the amount of bonds applied.for. 2. The Secretary of the Treasury reserves the right to reject any sub scription, in whole or in part, to allot less than the amount of bonds applied for, and to close the books as to any or all subscriptions at any time without notice; and any action he may take in these respects shall be final, Subject to these reservations, and to the limitations on commercial bank subscriptions prescribed in Section I of this circular, all subscriptions will be allotted in Allotment notices will be sent our promptly upon allotment. IV. PAYMENT 1. Payment at par and accrued interest, if any, for bonds allotted here under must be made on or before February 1 , 1944, or on later allotment. One day’s accrued interest is $>0*069 per $1,000. Any qualified depositary will be permitted to make payment by credit for bonds allotted to it for itself and its customers up to any amount for which it shall be qualified in excess of existing deposits, when so notified by the Federal Reserve Bank of its District. 1/ The transfer books are closed from February 16 to March 15, and from August 16 to September 1 $ (both dates inclusive) in each year. 2/ Copies of Form PD 1782 m a y be~ obtained from any Federal Reserve Bank or from the Treasury Department, Washington, D. C, i - 4V* GENERAL PROVISIONS If As fiscal agents of the United States, Federal Reserve Banks are authorized and requested to receive subscriptions, to make allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the federal Reserve Banks of the respective Districts, to issue allotment notices, to receive payment for bonds allotted, to make delivery of bonds on full-paid subscriptions allotted, and they m ay issue interim receipts pending delivery of the definitive bonds. J 2, The Secretary of the Treasury may at any time, or from time to time, prescribe supplemental or amendatory rules and regulations governing the ottering, which will be communicated promptly to the Federal Reserve Banks* HENRI MORGENTHAU, JR., Secretary of the Treasury. r UNITED STATES OF AMERICA 2-1/4 PERCENT TREASURY BONDS OF 1956-59 Dated and bearing interest from February 1, 1944 Due September 15* 1959 REDEEMABLE AT THE OPTION OF THE UNITED STATES AT PAR AND ACCRUED INTEREST ON AND AFTER SEPTEMBER 15, 1956 Interest payable March 15 and September 15 1944 Department Circular No. 730 TREASURY DEPARTMENT, Office of the Secretary, Washington, January IB, 1944* Fiscal Service Bureau of the Public Debt I, OFFERING O F BONDS 1| The Secretary of the Treasury, pursuant to the authority of the Second Liberty Bond Act, as amended, invites subscriptions, at par and accrued interest, from the people of the United State# for bends of the United States, designated 2-1/4 percent Treasury Bonds of 1956-59* The amount of the offering is not specifically limited» 2. These bonds will not be available for subscription, for their own account, by Commercial banks, which are defined for this purpose as banks accepting demand deposits, except as follows* a commercial bank holding savings deposits as defined in Regulation 1$ of the Board of Governors of the Federal Reserve System may sub scribe to the bonds offered hereunder, to the 2-1/2 percent Treasury Bonds of 1965-70 offered simultaneously herewith under Treasury Department Circular No. 729, and to Series F-1944 and Series G-1944 United States Savings Bonds under Treasury Department Circular No. 654, Second Revision, but the amount of such subscriptions shall not exceed, in the aggregate, 10 percent of the savings deposits as shown on the bank*s books as of the date of the most recent call statement required by the supervising authorities prior to the date of subscription for such bohds, Or •1200,000, whichever is less. No such bank shall hold more than $100,000 (issue price) of Series F and Series G Savings Bonds (Series 1944), combined. II. DESCRIPTION OF BONDS 1* The bonds will be dated February 1, 1944, and will bear interest from that date at the rate of 2-1/4 percent per annum, payable on a semiannual basis on September 15, 1944, and thereafter on March 15 and September 15 in each year until the principal amount becomes payable. They will mature September 15, 1959, but may be redeemed at the option of the United States oh and after September 15, 1956, in whole or in part, at par and accrued interest, on any interest day or days, on 4 months* notice of redemption given in such manner as the Secretary of the Treasury shall prescribe. In case of partial redemption the bonds to be re deemed will be determined by such method as may be prescribed by the Secretary of the Treasury, From the date of redemption designated in any such notice, interest on the bonds called for redemption shall cease, - 2 - 2. The income derived from the bonds shall be subject to all Federal taxes, now or herafter imposed. The bonds shall be subject to estate, inheritance, gift or other excise taxes, whether Federal or State, but shall be exempt from all taxation now or hereafter imposed on the principal or interest thereof by any State, or any of the possessions of the United States, or by any local taxing authority, 3• The bonds will be acceptable to secure deposits of public moneys. will not be entitled to any privilege of conversion, They 4* Bearer bonds with interest coupons attached, and bonds registered as to principal and interest, will be issued in denominations of $500, $1,000, $5,000, $10,000, $100,000 and $1,000,000, Provision will be made for the interchange of bonds of different denominations and of coupon and registered bonds, and for the transfer of registered bonds, under rules and regulations prescribed by the Secretary of the Treasury* "Fxcept as provided in Section I of this circular, these bonds may not, before September 15, 1946, be transferred to or be held by commercial banks, which are defined for this purpose as banks accepting demand deposits; however, the bonds may be pledged as collateral for loans, including loans by commercial banks, but any such bank acquiring such bonds before September 15, 1946, because of the failure of such loans to be paid at maturity will be required to dispose of them in the same manner as they dispose of other assets not eligible to be owned by banks# 5# Any bonds issued hereunder which upon the death of the owner constitute part of his estate, will be redeemed at the option of the duly constituted repre sentatives of the deceased ownerTs estate, at par and accrued interest to date of payment,!/ Provided: (a) that the bonds were actually owned b y the decedent at the time of his death; and (b) that the Secretary of the Treasury be authorized to apply the entire proceeds of redemption to the payment of Federal estate taxes# Registered bonds submitted for redemption hereunder must be duly assigned to nThe Secretary of the Treasury for redemption, the proceeds to be paid to the Collector of Internal Revenue at _______ i°r credit on Federal estate taxes due from estate of _____#” Owing to the periodic closing of the transfer books and the impossibility of stopping payment of interest to the regis tered owner during the closed period, registered bonds received after the closing of the books for payment during such closed period will be paid only at par with a deduction of interest from the date of payment to the next interest payment date;2/ bonds received during the closed period for payment at a date after the books reopen will be paid at par plus accrued interest from the reopening of the T7 An exact half-year*s interest is computed for each full half-year period irrespective of the actual number of days in the half year# For a fractional part of any half year, computation is on the basis of the actual number of days in such half year, 2/ The transfer books are closed from February 16 to March 15, and from August 16 to September 15 (both dates inclusive) in each year. books to the date of payment. In either case checks for the full six months' interest due on the last day of the closed period will be forwarded to the owner in due course. All bonds submitted must be accompanied by Form PT) 1782, l/ properly completed, signed and sworn to, and by a certificate of the appoint ment of the personal representatives, under seal of "the court, dated not more than six months prior to the submission of the bonds, which shall show that at the date theredf the appointment was still in force and effect. Upon payment of the bonds appropriate memorandum receipt will be forwarded to the representatives, which will be followed in due course by formal receipt from the Collector of Internal Revenue, 6, Except as provided in the preceding paragraphs, the bonds will be subject to the general regulations of the Treasury Department, how or hereafter prescribed governing United States bonds, III, SUBSCRIPTION AND ALLOTMENT 1, Subscriptions will be received at the Federal Reserve Banks and Branches and at the Treasury Department, Washington, Subscribers are requested not to trade in the securities allotted hereunder until after February 15, 1944* Banking institutions generally may submit subscriptions for account of customers, but only the Federal Reserve Banks and the Treasury Department are authorized to act as official agencies.: Others than banking institutions will not be permitted to enter subscriptions except for their own accounts Subscriptions must be ac companied by payment in full for the amount of bonds applied for, 2, The Secretary of the Treasury reserves the right to reject any subscrip tion, in whole or in part, to allot less than the amount of bonds applied for, and to close the books as to any or all subscriptions at any time without notice^ and any action he may take in these respects shall be final. Subject to these reservations, and to the limitations on commercial bank subscriptions prescribed in Section I of this circular', all subscriptions will be allotted in full. Allotment notices will be sent out promptly upon allotment, IV, PAYMENT 1, Payment at par and accrued interest, if any, for bonds allotted here under must be made on or before February 1, 1944, or on later allotment. One day's accrued interest i.s $0,062 per $1,000, Any qualified depositary will be permitted to make payment by credit for bonds allotted to it for itself and its customers up to any amount for which it shall be qualified in excess of existing deposits, when so notified by the Federal Reserve Bank of its District, V Copies of Form PD 1782 may be obtained from any Federal Reserve Bank or from the Treasury Department, Washington, D. C. V GENERAL PROVISIONS 1. As fiscal agents of the United States, Federal Reserve Banks are authorized and requested to receive subscriptions, to make allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the Federal Reserve Banks of the respective Districts, to issue allotment notices, to receive payment for bonds allotted,to make delivery of bonds on full-paid subscriptions allotted, and they may issue interim receipts pending delivery of the definitive bonds. 2. The Secretary of the Treasury may at any time, or from time to time, prescribe supplemental or amendatory rules and regulations governing -the ’Offering, which will be communicated promptly to the Federal Reserve Banks# HENRY MORGENTHAU, JR., Secretary of the Treasury# UNITED STATES OF AMERICA 7/8 Percent Treasury Certificates of Indebtedness of Series .A-1945 Dated and bearing interest from February 1, 1944 1944 Department Circular No, 731 Due February 1, 1945 TREASURY DEPARTMENT, Office of. the Secretary, Washington, January 18, 1944, Fiscal Service Bureau of the Public Debt I, OFFERING OF CERTIFICATES 1. The Secretary of the Treasury, pursuant to the authority of the Second Liberty "Bond Act, as amended, invites subscriptions, at par and accrued interest from the people ,of the United States for certificates of indebtedness of the United States, designated 7/8 percent Treasury Certificates of Indebtedness of , Series A-1945. These certificates will not be available for subscription, for their oim account, by commercial banks, which are defined for this purpose as banks accepting /demand deposits. The amount of the offering is not specifically limited II, DESCRIPTION OF CERTIFICATES !"• The certificates w i i r be dated February 1, 1944* and will bear interest from that date at the rate of 7/8 percent per annum, payable semiannually on August 1, 1944* and February 1,-1945* They will mature February 1, 1945* and will not be subject,to call for redemption prior to maturity. 2. The income derived from the certificates shall be subject to all Federal taxes, now or hereafter imposed. The certificates shall be subject to estate, inheritance,- gift or other excise taxes, whether Federal or State,, but shall be exempt from all taxation now or hereafter imposed on the principal,or interest thereof by any State, or any of the possessions o f ‘the United States, or by any local taxing authority. ( 3* The certificates will be acceptable to secure deposits of public moneys, They Trill not be acceptable in payment of taxes. 4* Bearer certificates with Interest coupons attached will be issued in denominations of $1,000, .§5,000,. $10,000, $100,000.and $1,000,000. The certifi cates will not be Issued in registered form.. 5* The certificates will be subject to the general regulations of.the Treasury Department, now or hereafter prescribed, governing United States certifi cates . III. SUBSCRIPTION AND ALLOTMENT 1, Subscriptions will be received at the Federal Reserve Banks and Branches and at the Treasury Department, "Washington, Commercial banks are requested not to purchase and subscribers are requested not to trade in the securities allotted hereunder until after February 15, 1944,, Banking institutions generally may - 2 - submit; Subscriptions for account of customers, but only the Federal Reserve Banks and the Treasury Department are authorized to act ad official agencies; Others than banking institutions m i l not be permitted to enter subscriptions except for their own account. Su d s cripuions must be accompanied by payment in full for the amount of certificates applied for;, 2 , The Secretary of the Treasury reserves the right to reject any subscription^ in whole or in part, to allot less than the amount of certificates applied lor? and to close the books as to any or all subscriptions at any time v&thout notice^ and any action he may take in these respects shall be final. Subject to these reservations, all subscriptions will be allotted in full. Allotment notices will be sent out promptly upon allotment, IV, PATMENT 1* Payment at par and accrued interest, if any, for certificates allotted hereunder must^be made on or before February 1, 1944, or on later allotment. One day's accrued interest is $0,024 per $1,000. Any qualified depositary will be permitted to make^payment by credit for certificates allotted to its customers up to any amount for which it shall be qualified in excess of existing deposits when so notified by the Federal Reserve Bank of its District, V. GENERAL PROVISIONS 1, As fiscal agents of the United States, Federal Reserve Banks are author ized and requested to receive subscriptions, to make allotments on the basis and up to the amounts indicated by the Secretary of the Treasury to the Federal Reserve Banks of, the respective Districts, to issue allotment notices, to receive payment for certificates allotted, to make delivery of certificates on full-paid subscriptions allotted, and they may issue interim receipts pending delivery of the definitive certificates, , * The Secretary of the Treasury may at any time, or from time to time, pre s e n c e supplemental or amendatory rules and regulations governing the offering which will be communicated promptly to the Federal Reserve Banks, HENRI MORGENTHAU, JR., Secretary of the Treasury. FOR IMMEDIATE EELS Igggaber im *. She Bureau of Customs announced today preliminary figures shoving the quantities of coffee authorised for entry for consumption under the quotas for the 12 souths commencing October 1* 1943, provided for in the Inter* American Coffee Agreement, proclaimed by the President on April 15, 1941, as follows: Country of Production : : Qpota Quantity t (Pounds) 1/ : e e 1 Authorised for entry * for consumption :/As of (Bate) : (Pounds) Signatory Countries: Brasil Colombia Costa Rica Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Tenesuela 1,352,183,480 458,886,840 28,100,720 U,640,288 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 2,910,072 69,114,210 26,373,202 3,637,590 61,111,612 Non-signatory Countrios: 51,653,778 Xf s 0 195,714,775 103,112,835 1,795,268 2,197,675 2,679,500 8,869,133 938,518 8,847,429 1,379,318 460,824 9,699,148 600,406 342,525 5,289,657 s 1,991,188 Bsc* 4, 1943 « s s s n N S « • H S Qiotas as established by aetlon of the Inter^Anerican Coffee Board cm March 11, 1943* TREASURE DEPARTMENT Washington POE IMMEDIATE EELEASE, Wednesday, December 15, 1943. Press Service No, 39-94 Tile Bureau of Customs announced today preliminary figures showing the quantities of coffee authorized for entry for consumption under the quotas for the 12 months commencing October 1, 1943, provided for in the InterAmerican Coffee Agreement, proclaimed by the President on April 15, 1941, as follows* Country of Production : Quota Quantity ? Authorized for entry i (pounds) 1/ : for consumntipn >■ ; As of (Date) ; (Pounds) Signatory Countries? Brazil Colombia Costa Bica • Cuba Dominican Republic Ecuador El Salvador Guatemala Haiti Honduras Mexico Nicaragua Peru Venezuela Non-signatory Countries^ 1/ 1,353,183,480 458,336,340 29,100,720 11,640,288 17,460,432 21,825,540 87,302,160 77,844,426 40,013,490 2,910,072 69,114,210 28,373,202 3,637,590 61,111,512 51,653,778 Dec, 4, 1943 n IT tl II If IT tl ft IT If It tr 195,714,775 103,112,835 1,795,258 2,197,675 2,679,500 8,869,133 938,518 3,847,429 1,379,318 460,324 9,699,148 500,406 342,525 5,239,657 tr 1,991,188 tf Quotas as established by action of the Inter-American Coffee Board on March 11, 1943, -oGO- I do not believe that the glory of America belongs only to the past. I believe that the real promise of America belongs to the future. Between the goal of securing maximum utilization of our resources and the goal of achieving a more equitable distribution of wealth, there need be no conflict. Our history has been testimony to that fact, and our future will be the record of its fulfillment. Perhaps for a long time to come* if the post-war period lives up to our hopes and expectations. But this would take me into new vistas beyond the scope of tonight1s address for I have no intention of discussing the broader phases of fiscal policy beyond the reconversion period. I would like to make, however, a few general observations. The war has opened the eyes of the American people to the tremendous productivity of industrial and agricultural America. The shortages of peacetime goods and services that exist now have not blinded us to the enormous potentialities for abundance inherent in our productive mechanism. It is precisely this unexampled capacity to produce upon which the future prosperity and welfare of our people ultimately depend. To help society achieve more fully the promise of abundance implicit in our capacity to produce; to help maintain output and employment at a level more nearly corresponding to our true productive potential; and to secure this at a price that a peaceful democracy can pay; — that will constitute the greatest task of economic statesmanship in the post-war world. rationing, should be kept in effect as long as necessary; and high income taxes, as long as possible. < Let me explain the difference between “necessary*1 and “possible11 in the statement which I hare just made. While I believe that we should keep the direct controls as long after the war as necessary, I do not believe that this will be very long. I feel certain that the last of them can be done away with as soon as the reconverted plants commence to pour their flood of consumers* goods on the market. I have said, however, that the high rates of taxation should be kept as long as possible. I think that the case here is very different. High personal taxes serve the anti-inflationary purpose of absorbing surplus purchasing power; and this may be very useful and necessary in the reconversion period. But they also serve the purpose of helping to pay off the national debt; and this purpose is also useful and necessary. It seems to me, therefore, that, while the criterion with respect to the removal of the controls should be “How soon can we remove them without risking inflation?*p the criterion with respect to wartime rates of taxation should be “How long can we keep them without risking unemployment?” - 26 fron wort in demobilising the war effort and reconverting private industry, but also the large liquid resources piled up during wartime, it is easy to conjure up the specter of a post-war inflation. Against this must be set the powerful force of human foresight and sobriety. The reconversion period is bound to be attended by considerable unemployment, and each individual will naturally ask himself how he is going to come out in the swirl of readjustments he sees around him. His natural tendency will be to "play it close to the chest!1 and handle his reserve funds as carefully as possible. This human tendency alone may maintain a high rate of saving during the reconversion period, and so forestall the possibility of a post-war inflation. Ie hope that this will be so; but counting on it would be as improvident as counting on an internal smash-up in Germany to win the war. He must consequently lay our plans to prevent a post-war inflation from occurring, but stand ready to adjust any such plans on short notice to conditions as they actually develop during the reconversion period. What should these plans be? It seems to me that the direct controls, such as price ceilings, priorities, and - 25 - which the Treasury has made recommendations to the Congressional committees ■— will be available to carry on the work of reconversion. In addition, there is provided in the present law a post-war refund, irrespective of future tax status, of ten per cent of the excess profits tax paid in the war period. For the reasons given, I do not believe that the adequacy of business funds for reconversion purposes will present a major problem. But I cannot speak with equal assurance with respect to the prospects for the control of individual spending during the reconversion period — the third post-war problea to be discussed. Immediately following the end of the actual fighting, we can probably expect a let-down in the willingness of people to submit from patriotic motives to a continued reduction in their consumption. There is likely to be a demand for an immediate end of the direct controls; and this demand may, to some extent, succeed. For some time, however, while industry is being reconverted and the war effort demobilized, there will be only a very gradual increase in the supply of consumers' goods. When it is considered that there will be available to be spent currently, in addition to the incomes being received for the production of^consumers*) goods, not merely the incomes - 2k - Second, in addition to their savings froa undistributed earnings, American corporations have piled up a large volume of liquid assets as a result of repayment of receivables, and in some cases reduction in inventories, and the general inability to expend depreciation and depletion reserves which has been brought about by wartime conditions. Reserve According to the estimates of the Federal Board, the demand deposits of nonfinaneial businesses including unincorporated Enterprises^ amounted to over 30 billion dollars at the end of last July; and, according to Treasury estimates, the holdings of Government securities payable for the most part on demand or at very short term — by nonfinaneial corporations alone, amount at the present time to about 20 billion dollars. Each of these figures is far above any peacetime precedent; but, to make the picture brighter, American business, during the same time it has been acquiring them, has reduced the amount of both its bank loans and its bonded debt. Third, generous carry-back and carry-forward provisions included in the corporation tax laws insure that corporation suffering losses during the reconversion period, or even earning incomes of less than their excess profits credit, will receive substantial refunds of the taxes paid in their prosperous years. These refunds — for the expediting of - 23 - My second point with respect to the reconversion period relates to the adequacy of corporate financial resources to carry on the work of reconversion. The adequacy of these resources is important, not merely or even principally from the point of view of the corporations involved, but fro* the point of view of the whole economic system. Me in the Treasury have given careful consideration to this matter, and believe that funds for the reconversion of war industry will be ample, provided that a prompt settlement is made of canceled war contracts. Our reasons for believing this are as follows: First, the wartime period has been a profitable one for American corporations as a whole. Set corporate profits, after taxes, have averaged about twice as much per year during the wartime period as they did in the years 1935 through 1939 (the base period for the FSB index of industriaj production); and, by and large, the greatest increases have gone to those firms whose problems of reconversion will be greatest. Corporate dividend ploicy, furthermore, has been so conservative that most of the increase in corporate earnings has been added to surplus. - 22 - Payments to contractors should be Just in accordance with a fixed standard of equity; that is, they should be enough to sake the contractors and their subcontractors I whole for the losses they have sustained as the result of the contract cancelations. It is important also, that payments to contractors should be prompt. This is not primarily for the benefit of the contractors themselves — that they will appreciate it — the country as a whole. although I have no doubt but for the benefit of A dollar paid out in the settlements of war contracts during the early reconversion period may — I in terms of national well being -- be worth several dollars ; paid out a year or so later. It is far more important, therefore, that the settlements be prompt than that they be accurate to the last dollar according to some accounting concept, which may itself be open to question. The settlement of war contracts along the lines which I I have Just outlined will involve a heavy outflow of funds from the Treasury in the few months immediately following the end of the war. ft are prepared for this outflow, and we feel that there will be few occasions when a disbursement! of funds may be made with so little real cost to the Government and so much benefit to the economy. - 21 - and material resources involved in making goods which we will never use; and, second, it gives the maximum stimulation to the men and management released from making such goods to seek employment in the production of goods for which there is a human need, and so hastens the process of reconversion. The(abrupt) cancelation of war contracts will give rise to two problems. These are: First, provision for the labor thrown out of employment; and second, compensation for the contractors. The first of these problems should be settled with liberality; the second, with the utmost of speed. A generous treatment of the labor displaced by contract cancelation is required, not merely by considerations of common humanity and fair dealing, but also by considerations of economy; for without it, we are unlikely to secure abrupt cancelation at all, and there is no form of relief more expensive than the production of unneeded tools of war. We should be sure, however, that the treatment accords labor displaced from war production is of such a character that it encourages, rather than slows down, its quest for peacetime employment. - 20 - carry on the work of reconversion; and, third, the control of individual spending daring the reconversion period. If the war should end today on all fronts, there would be outstanding ©ore than 75 billion dollars of war contracts on which deliveries had not yet been made. Much of the material covered by these contracts would be of no use to the Government if it were delivered after the immediate emergency of this war had passed. This is because there are no goods with respect to which obsolescence runs faster than it does for the goods of war; so the best preparation for future wars consists in maintaining the skills and plant capacity necessary for the development, production, and use of new war goods rather than in hoarding vast Quantities of old ones. Part of the undelivered contracts would still exist merely in blue-prints in the hands of the contractors, while part would be represented by goods in process, some of which in turn could be converted into peacetime goods. In my opinion, all war contracts should be canceled immediately upon the passing of the military need for the goods contracted for. reasons. this is desirable for two important First, it avoids the tremendous waste of human i - 19 - from a lack of demand for goods and inflation from a / / . . ..... shortage of goods* The unemployment of the reconversion period will be caused, however, not by a lack of demand for the finished products, but because the plants are not yet ready for mass reemployment, and so may go hand-in-hand with inflation* Once the period of reconversion is over and the tremendous potentialities off the American economy which have been demonstrated during the war period are directed to the production of the goods of peace, the main hazard of inflation will be over. The task of statesmanship in the period immediately following the war will be to hasten the reconversion process while mitigating its hardships and reducing its human costs. This task will, of course, be easier if a termination of the war on one front before the other should make it possible to complete part of the reconversion process under a wartime environment. But we must press for victory against Japan as well as Germany without regard for the economics of reconversion. This evening I shall discuss only three aspects of fiscal planning for the reconversion period, and these briefly. They are, first, the cancelation of war contracts; second, the adequacy of corporate financial resources to 18 - Immediately following the close of the war, we will be confronted with the problem of reconversion. fhe period of reconversion will be a time fraught with exceptional hazard to our economic structure. During normal times, most of our people are engaged in producing goods which they and their fellow workers can buy with their wages. During wartime, they are largely engaged in producing war goods which they cannot purchase with their incomes, but the excess purchasing power which is thereby created is held in check by direct controls, by personal taxation and by Government borrowing from individuals. The people are willing to accept and cooperate with these measures because of patriotism and the allpervading spirit of sacrifice which exists during wartimes. During the reconversion period, however, while the tools of production for peace goods are being made ready, purchasing power may outrun the goods available for purchase i while wartime measures of control may be relaxed if the people do not recognise the need for continued restraint. A price inflation is, consequently, one of the hazards of the reconversion period. Stalking hand-in-hand with it goes the hazard of unemployment, normally, these two are never seen together, since unemployment usually rises / T I think it can be fairly said of the United States, as the late Chancellor of the Exchequer, Sir Kingsley Wood recently said of Great Britain, that *. . . ve have revolutionised public opinion as to what are fair rates for Government war borrowing." I believe that this revolution in opinion has a sound basis in underlying economic realities, and is applicable to the coning times of peace also. I hope that the policies of the Government will be directed to this end. Financing the Post-War Readjustment I come now to the second major division of ay topic, that is, the problems of the post-war readjustment period. I approach this subject with some trepidation. Ho post-war plan will be of any value unless we win the war and are in a position to put it into effect. not yet in the bag. The war is Hitler’s post-war plan is slavery, and there will not be room for both his plan and our own. You all remember the recipe for rabbit stew which begins "First catch the rabbit." planning. So it is with post-war We must first win the war; and we must not let anything, even post-war planning, distract our minds from this for an instant. - 16 - investment of their demand deposits with time of issuance of over ten years. a maturity at The great majority of the securities sold to commercial banks have had maturities far shorter than this. Indeed, more than half of the total increase in the portfolios of commercial banks since Pearl Harbor has been in the form of three-month Treasury bills and one-year certificates of indebtedness. This concentration of sales to commercial banks in short securities insures that our banking system will be in a strong and liquid position to meet the problems of the post-war period. Finally, w© have financed this war at an average rate of slightly less than 1 - j A per cent. This compares with an average rate of about U-l/U per cent on the securities issued to finance the last World War. Interest rates have remained stable during the wartime period and confidence in the continuation of this stability has been and is widespread and well justified, and has caused investors to subscribe to new issues of Government securities in successive war loans without any sign of holding back in anticipation of higher rates. - 15 - Marketable securities, toy contrast, would be offered in small blocks, oftentimes through irregular channels where the original holders may not receive full value, and might dribble into the market in such a way as to keep it continually disturbed. They might not be fitted by coupon rate, maturity, or other characteristics for the predominant demand then existing in the market, but they would have been cast in whatever mold they were, once and for all, and the market would have to make the best of it. To the extent that the refunding of demand obligations would have been accomplished by the sale of securities to banks, so also would the marketable securities find their ultimate lodgment in banks, but only after a roundabout journey, probably involving both loss to their original purchasers and a higher interest cost to the Treasury. It seems clear, therefore, that the Treasury is in a much better position to refund the non-negotiable securities than the individual would be to refund negotiable securities through the market. The third of the principles governing our borrowing policy has been the maintenance of the liquidity of the banking system. We have laid down the policy that no securities will be offered to commercial banks for the - lb This problem is that the holders of these seeurities may dispose of them and spend the proceeds on consumers' goods at a time when the supply of such goods will be scarce; and the spending can result only in price rises. This problea would exist* however* whether the securities were payable on demand or were negotiable and payable at the close of a fixed tera* and will be somewhat less troublesoae for demand securities* because* as 1 have already pointed out* the liquidation of this type of security will never be precipitated by the fear of a fall in the price of the security itself. The other problems which will be caused by holdings of Government debt by snail investors in the post-war period are minor, relative to the major problem which 1 have just mentioned; and will be less serious with deaand obligations than with negotiable obligations of fixed tera. When savings bonds are presented for redemption to the Treasury and it is necessary to refund then* the Treasury offers the type and maturity of new securities best suited to the market at the time, and offers these securities for distribution through the regular channels of the Government security market. of savings bonds to a*all investors than it would be with the only practicable alternative to this course. This alternative would be the sale to snail investors of marketable securities payable by the Treasury only after the expiration of a fixed term of years. The fixing of a definite term on securities sold to small investors by no means insures that they will be held by these investors for the full term. By and large, the holders of marketable securities would sell then on the Baae occasions when holders of redeemable securities would redeem theirs. Indeed, there is one important occasion upon which marketable securities would be sold, but redeemable securities would not be redeemed — that is, the fear of a decline in price, from which the nonnegotiable securities are immune. Mow it may appear, at first glance, that while the Treasury{should jbe properly concerned with redemptions, it should not be concerned with market sales, since it must meet the redemptions out of its own pocket; while the market sales will be taken up by somebody else* This type of reasoning would suffice for a private borrower, but it is entirely inadequate for the Treasury since It overlooks the real problem which the holdings of Government securities-! whether redeemable or marketable — will present in the post-war period. by small investors - 12 - the banks to provide this necessary circulating medium, ■Jt even if adequate markets exist for them elsewhere. ^The amount of Government securities which would thus have to be sold to the banks in any event is substantial; but, in practice, I must admit that this haw^proved little of a problem, since it has taken care of Itself by the rapid expansion of the borrowing needs of the Federal Government and the slower development of nonbanking sources for Federal borrowing. For this reason, we have directed our main effort to the sale of securities to nonbanking investors. During the past year, we have sold to such investors, net after all # switches and redemptions, about forty billion dollars of Government securities, as compared with about thirty billions absorbed by the banks. Second, we have tried to make the securities sold to the small investor as riskless as possible. The Treasury has considered itself the trustee of the inexperienced investor. It is with this in view that the Department1s appeal to small investors has been confined to Series 1 bonds which are non-negotiable, payable on demand and hence are guaranteed against fluctuations in market values. The Treasury is less concerned with the large volume of demand obligations which is being built up by the sale - 11 - excises proposed by the Treasury this year and the spendings tax proposed last year are cases in point. The test should be rigid* however* and the considerations of public policy should be important before a tax is placed on the statute books* the burden of which is distributed in a manner other than that in which we would be willing to distribute the burdenl/of an increase irO the individual I turn now to our policies with respect to wartime borrowing. These have been dominated by the following considerations* First, we have tried to borrow as much as possible from investors other than commercial banks. must be stated subject to some qualification. This principle It would neither be possible nor desirable to do all of our borrowing outside of the banking system. I have already explained that one of the reasons for borrowing at all* rather than relying exclusively upon taxation* is that an expanding wartime economy needs — even at a constant price level — a greatly increased amount of currency and bank deposits. These can be obtained* under existing institutions and in wartime* only by a corresponding increase in the Government security holdings of commercial and Federal Reserve Ranks; and a sufficient amount of securities have to be sold to - 10 - to enter war plants in o r d e r ( t o ^ a r n incomes supplementary to those of their husbands. It would, therefore, aggravate the labor shortage. It would be very difficult to administer. This would be true, not only for the Treasury, but also for the taxpayers - as it would require the use of forms and questionnaires far more complex than any involved in the administration of the individual income tax. It seems to me that the basic problem of the taxation of j individuals in wartime is really not very complex. Aggregate individual income is higher, and the Government must tax a portion of it away. There may be a great deal of dispute as to which income brackets should be drawn upon the most heavily, but any reasonable pattern of withdrawal can be effected by means of the individual income tax. I think it is a good rule when any other tax is proposed, that you first express the distribution of its burden in terms of the individual income tax, and then ask yourself whether you would consider it reasonable that the burden of the individual income tax itself should be so altered. If the answer is *Mo,® then the other tax should be placed on the defensive and its proponents made to justify it by reasons of strong public policy. this can be done — Sometimes for example, I believe that the luxury hundred dollars for a single person, twelve hundred dollars for a married couple, and three hundred fifty dollars for each dependent. believe that I cannot accept this view; and I do not the advocates of the sales tax would, if they •i realized the full implications of their proposal. Third, it is often proposed that we should place a special tar on increases in individual incomes; that is, tax a man with an income of, say, three thousand dollars more heavily if he has recently come up from one thousand dollars than if he had been receiving three thousand dollars for some time. This proposal seems to me to be wrong on a number of counts* It is unfair. It seems to me that, consciously or unconsciously, it is based in part on the feudal concept that every man should stay in his place, and it strikes at the root of the principle that every man may rise according to his worth — a principle which has given so much life and hope to the American scene for generations past. It is uneconomic. It would undermine the incentive of workers to transfer to war industries located in inconvenient places and to work long hours at hard jobs. Particularly, it would strike at the incentive for wives 8 - taxes, for it means that we have acre dollars to spend than things to buy with the®. Second, the view is sometimes voiced that, while we have exhausted our ability to pay some kinds of taxes, such as income taxes, we have not exhausted our ability to pay other kinds of taxes, such as sales taxes, see no merit in this view. I can Ability to pay resides in persons, rather than in kinds of taxes — both income an# sales taxes must be met from the same pay envelopes; and if we have the ability to pay one, we have the ability to pay the other. The income tax can be adjusted, and is adjusted to the personal circumstances of those upon whom it is levied. Exemptions are granted commensurate with family status, so that the tax does not fall with merciless brutality upon those with small incomes and large families. Bo such adjustment mechanism is customary or practicable for the sales tax. The view that we have exhausted our ability to pay additional income taxes, but still have the ability to pay a sales tax, logically reduces itself to the view that the principal additional ability to pay in the economy resides in that portion of incomes falling within the exemptions from the individual income tax — that is, five Government is purchasing about one-half of the total volume of goods and services being produced, while the remaining 50 percent is being purchased for private nee. Federal taxes, however, are bringing in only about 20 percent of the gross income generated by production, leaving about 80 percent in private hands. There is, thus, a discrepancy equivalent to about 30 percent of the value of total output which makes up the Federal deficit on the one hand and the corresponding necessary private savings on the other hand. To the extent that total borrowing exceeds the-aggregate amount of savings consciously and intentionally undertaken, we are placing liquid assets in the hands of persons who may use them to put added pressure on price ceilings. It is to aid in immobilising such unstable accumulations, as well as for fiscal and equitable reasons, that the Treasury considers the need for additional taxes so urgent. £ do not desire to go into the matter of particular types of wartime taxes at any length this evening, but I should like to make some general observations. First, there can be no doubt of the ability of the people of the United States to pay taxes much higher than those now levied. itself is hard. Of course, it would be hard because war But the very fact that we are threatened with inflation is evidence of our ability to pay higher - 6 - enterprises were taxed away, there would be no economic incentive to call forth these exertions. ■ii The borrowing which is justified entirely by the I special considerations which I have just enumerated would have to take place for our wartime economy to operate smoothly, no matter how willing Congress might be to levy additional taxes or the people to bear them. This borrowing I alone would amount to a great deal of money by peacetime standards; but it would certainly be much less than the nearly fifty billion dollars a year which we should have to borrow even if the Treasury tax proposals were grunted in full. An additional amount of borrowing — over and above the minimum required on economic grounds — can also be accomplished without danger of inflation to the extent that individuals can be induced, for patriotic reasons, to increase their savings. This the Treasury is endeavoring I to do by means of the payroll savings plan and the War Loan campaigns. The volume of total savings required is dictated by the else of the deficit and may differ materially from the sum total of savings which would occur from economic and patriotic motives. At the present time the Federal 5 - than they are being replaced, and the depreciation reserves set aside to offset this wear and tear are piling up in cash. At the same time, the accounts receivable of these firms are running down, which results also in piling up cash. These funds are all available to be lent to the Government; but they are not available to be taxed since they represent capital, rather than income, of the firms possessing them, and represent very different proportions of the total capital of different firms, depending upon the type of business. A policy of borrowing these funds, rather than taxing them away, is, therefore, clearly indicated. In the third place, the great wartime expansion in the economy requires — even at a constant price level — a great increase in the available supply of currency and bank deposits; and this increase, under our existing institutions and under wartime conditions, can be supplied only by an increase in Government borrowing. Finally, it is necessary that some financial incentive be supplied to individuals to work long hours, and to corporations to operate with the utmost efficiency. If the whole of the extra incomes resulting from the overtime pay of individuals and the efficient management of business ! - H • been increased by the war to levels considerably above those required to meet their former standards of living, are ready and willing to lend a substantial proportion of their increased incomes to the Government in order to insure their future security. Ultimately, if the war should last long enough, these adjustments might be continued under a steadily increasing burden of taxation until each person’s standard of living and financial commitments had became adjusted to his place in the war economy, this is unlikely to occur, except in a very long war; and, in the meantime, a considerable proportion of the total war cost must be borrowed in order to avoid unnecessary disruption in the economy. In the next place, the magnitude of our war effort is fixed by our full gross product, rather than by our net national income. This means that during wartime replacement^| and repairs on plant and equipment must be postponed, as far as possible, so that the manpower and materials which they would otherwise have absorbed can be thrown into the war effort. Producers, as well as consumers, are asked by their Government to "Use it up. Wear it out, Hake it do, or Do without." This means that during the war period, the capital assets of most business firms are wearing out more rapidly reconmended to Congress that the whole cost of the war should be paid for out of current taxation. But it is these exceptions, and not the general rule, which need special justification; and I should like to explain to you tonight, not why the Treasury has reconaended to Congress additional taxes, which if enacted would only provide sufficient revenue to cover about one-half of total Federal expenditures, but rather why it has not asked for taxes to cover the full cost. The use of borrowing, to the extent that it is justified by special circtiastances. Bakes for a saoother working of our war economy than would the exclusive use of taxation. borrowing is What are these circuastances under which | , < i ; V ’I |? ^V'' ' ' thus the superior instrument of war finance? In the first place, the burden of a t a x — or of any other compulsory levy, even if it is subsequently reimburs able — must be levied according to fixed rules, these rules can take but little account of individual circumstances It requires considerable time for many individuals to adjust their living standards and commitments to the new and lower levels which would be dictated by all-out wartime taxation. While some individuals are revising their living standards downward, other individuals, whose incomes have larger extent, by postponing the replace®ant of capital goods wearing out during its course. With these exceptions, the whole physical cost of a war sust be paid for while it is being fought. What then, it may be asked, is the role of war borrowing The answer Bust be that war borrowing is a method of post poning, not the cost itself, but the final allocation of the total burden of the war to some future date, when the costs now paid for through the sale of bonds are finally assessed in the form of taxes — at which time it is ' \:' ,Jgk’'■../:. inevitable that a such larger portion of them will be paid by the persons now in the armed forces than if they were assessed today. When this fact is seen in its stark reality, it is clear that the money cost of the war should be met as far as possible by taxes, and so be paid for once and for all by today*s civilians at the same time that the men in the services are paying their much higher price in human cost on the fighting fronts. Exceptions fro® this rule should be permitted only when clearly justified by special circumstances. There are a number of these special circumstances, and it is because of the® that the Treasury Department has never | jsjeuj _ Financing the War and the Post-War Readjustment I welcome the opportunity to discuss with you this evening the problems of financing the war and the post-war readjustment. It is because we feel that these two problems are so closely tied together that I have chosen to discuss some aspects of each in the same address. War Finance It has come to be generally recognised that the real cost of a war must be paid for while it is being fought. This real cost consists in the labor put forth and the sacrifices endured in order to produce and to use the goods of war. Guns cannot be fired until they and their shells have been made, nor can they be fired with time borrowed from tomorrow, the labor and sacrifice involved in these things must be made today and cannot be postponed. There are, of course, some exceptions to this rule. k war may be fought, in small part, by the use of stocks of goods accumulated before it begins; and, to a much l TREASURY DEPARTIN' ITasM ngton FOR RELEASE, 8.30 P.M., E.W.T. Thursday 4 December 16. 19A3. (The following address by Daniel W, Bell, Under Secretary of the Treasury, before the Worcester ’ Economic Club at the Hotel Bancroft, Worcester, ^^Massachusetts, is scheduled for delivery at o,30 P,M,, E.W.T,. Thursday. December 16. 19A3, and is for release at that time,) 7 Press Service No, q f f 5” 2 TREASURY DEPARTMENT Washington Press Service No* 39-95 FOR RELEASE, 7:30 P.M., E.W.T* Thursday, December 16, 1943* (The*foilowing address b y Daniel W* Bell, Under Secretary of the Treasury, before the Worcester Economic Club at the Hotel Bancroft, Worcester, Massachusetts, is scheduled for delivery at 7:30 P*M*t E.W.T*, Thursday, December 16, 1943» and is for release at that time .) Financing the War and the Post-War Readjustment X welcome the opportunity to discuss with you this evening the problems of financing the war and the post—war readjustment* It is because we feel that these two problems are so closely tied together that I have chosen to discuss some aspects of each in the same address* War Finance It has come to be generally recognized that the real cost of a war must be paid for while it is being fought* This real cost consists in the labor put forth and the sacrifices endured in order to produce and to use the goods of lAfar* Guns cannot be fired until they and their shells have been made, nor can they be fired with time borrowed from tomorrow. The labor and sacrifice involved in these things must be made today and cannot be postponed. There are, of course, some exceptions to this rule* A war may be fought, in small part, by the use of stocks of goods accumulated before it begins; and, to a much larger extent, by postponing the replacement of capital goods wearing out during its course* With these exceptions, the whole physical cost of a war must be paid for while it is being fought. What then, it may be asked, is the role of war borrowing* The answer must be that war borrowing is a method of postponing, not the cost itself, but the final allocation of the total burden of the war to some future date, when the costs now paid for through the sale of bonds are finally assessed in the form of taxes r~- at which time it is inevitable that a much larger portion of them will be paid by the persons now in the armed forces than if they were assessed today. - 2 - When this.fact is seen in its stark reality, it is clear that the money cost of the war should be met as far as possible by taxes, and so be paid for once and for all by today’s civilians at the same time that the men in the services are paying their much higher price in human cost on the fighting fronts. Exceptions from this rule should be permitted only when clearly justified by special circumstances. There are a number of these special circumstances, and it is because of them that the Treasury Department has never recommended to Congress that the whole cost of the war should be paid for out of current taxation. But it is these exceptions, and not the general rule, which need special justification; and I should like to explain to you tonight, not why the Treasury has recommended to Congress additional taxes, which if enacted would only provide sufficient revenue to cover about one-half of total Federal expenditures, but rather why it has hot asked for taxes to cover the full cost. The use of borrowing, to the extent that it is justified by special circumstances, makes for a smoother working of our war economy than would the exclusive use of taxation. What are these circumstances under which borrowing is thus the superior instrument of war finance? In the first place, the burden of a tax — or of any other compulsory levy, even if it is subsequently reimbursable — must be levied according to fixed rules. These rules can. take but little account of individual circumstances. It requires considerable time for many individuals to adjust their living standards and commitments to the new and lower levels which would be dictated by all-out wartime taxation. While some individuals are revising their living standards downward, other individuals, whose incomes have been increased by the w;ar to levels considerably above those required to meet their former standards of living, are ready and willing to lend a substantial proportion of their increased incomes to the Government in order to insure their future security. Ultimately, if the war should last long enough, these adjustments might be continued under a steadily increasing burden of taxation until each person's standard of living and financial commitments had become adjusted to his place in the w/ar economy. This is unlikely to occur, except in a very long war; and, in the meantime, a considerable pro portion of the total war cost must be borrowed in order to avoid unneces sary disruption in the economy. In the next place, the magnitude of our war effort is fixed by our full gross product, rather than by our net national income. This means that during wartime replacements and repairs on plant and equipment must be postponed, as far as possible, so that the manpower and materials which they wrould otherwise have absorbed can be thrown into the war effort. Producers, as well as consumers, are asked by their Government to "Use it up, Wear it out, Make it do, or Do without.W This means that during the war period, the capital assets of most business firms are wearing out more rapidly than they are being replaced, and the depreciation reserves set aside to offset this wear and tear are piling up in cash^ At the same time, the accounts receivable of these firms are running down, which results also in piling up cash* These funds are all available to be lent to the Government; but they are not available to be taxed since they represent capital, rather than income, of the firms possessing them, and represent very different proportions of the total capital of different firms, depending upon the type of busi ness . A policy of borrowing these funds, rather than taxing them away, is, therefore, clearly indicated . In the third place, the great wartime expansion in the economy requires «*** even at a constant price level a great increase in the available supply of currency and bank deposits; and this increase, under our existing institutions and under wartime conditions, can be supplied only by an increase in Government borrowing. Finally, it is necessary that some financial incentive be supplied to individuals to work long hours, and to corporations to operate with the utmost efficiency. If the whole of the extra incomes resulting from the overtime pay of individuals and the efficient management of business enter prises were taxed away, there would be no economic incentive to call forth these exertions, The borrowing which is justified entirely by the special considerations which I have just enumerated would have to take place for our wartime economy to operate smoothly, no matter how willing Congress might be to levy additional taxes or the peop3,e to bear them, This borrowing alone would amount to a great deal of money by peacetime standards; but it would certainly be much less than the nearly fifty billion dollars a year which we should have to borrow even if the Treasury tax proposals were granted in full. An additional amount of borrowing — over and above the minumum re quired on economic grounds — can also be accomplished without danger of inflation to the extent that individuals can be induced, for patriotic reasons, to increase their savings ? This the Treasury is endeavoring to do by means of the payroll savings plan and the War Loan campaigns. The volume of total savings required is dictated by the size of the deficit and may differ materially from the sum total of savings which would occur from economic and patriotic motives, Ab the present time the Federal Government is purchasing about one-half of the total volume of goods and services being produced, ■while the remaining 50 percent is being purchased for private use. Federal taxes, however, are bringing in only about 20 percent of the gross income generated by production, leaving about 80 percent in private hands. There is, thus, a discrepancy equiva lent to about 30 percent of the value of total output which makes up the Federal deficit on the one hand and the corresponding necessary private savings on the other hand. - u - To the extent that total borrowing exceeds the aggregate amount of savings consciously and intentionally undertaken, we are placing liquid assets in the hands of persons who may use them to put added pressure on price ceilings. It is to aid in immobilizing such unstable accumulations, as well as for fiscal and equitable reasons, that the Treasury considers the need for additional taxes So urgent, I do not desire to go into the matter of particular types of wartime taxes at any length this evening, but I should like to make some general observations. First, there can be no doubt of the ability of the people of the United States to pay taxes much higher than those now levied. Of course, it would be hard because war itself is hard. But the very fact that we are threatened with inflation is evidence of our ability to pay higher taxes, for it means that we have more dollars to spend than things to buy with them. Second, the view is sometimes voiced that,, while we have exhausted our ability to pay 'Some kinds of taxes, such as income taxes, we have not exhausted our ability to pay other kinds of taxes, such as sales taxes, I can see no merit in this view. Ability to pay resides in per sons, rather than in.kinds of taxes — both income and sales taxes must be met from the same pay envelopes; and if we have the ability to pay one, we have the ability to pay the other. The income tax can be adjusted, and is adjusted to the personal circumstances of those upon whom it is levied. Exemptions are granted commensurate with family status, so that the tax does not fall with merci less brutality upon those with small incomes and large families. No such adjustment mechanism is customary or practicable for the sales tax. The view that, we have exhausted our ability to pay additional income taxes, out still have the ability to pay a sales tax, logically reduces itself to the view that the principal additional ability to pay in the economy resides in that portion of incomes falling within the exemptions from the individual income tax — that is, five hundred dollars for a single person, twelve hundred dollars for a married couple, and three hundred fifty dollars for each dependent. I cannot accept this view; and I do not be lieve that the advocates of the sales tax would, if they realized the full implications of their proposal. Third, it is often proposed that we should place a special tax on increases in individual incomes; that is, tax a man with an income of, say, three thousand dollars more heavily if he has recently come up from one thousand dollars than if he had been receiving three thousand dollars for some t i m e . This proposal seems to me to be wrong on a number of counts. It is unfairo It seems to me tjhatj consciously or unconsciously, it is based in part on the feudal concept that every man should stay in his place, and it strikes at the root of the principle that every man may rise according to his worth ***• a principle which has given so much life and hope to the American scene for generations past© It is uneconomic® It would undermine the incentive of workers to transfer to war industries located in inconvenient places and to work long hours at hard jobs0 Particularly^ it would strike at the incentive for wives to enter war plants in-order to earn incomes supplementary to those of their husbands® It would, therefore, aggravate the labor shortage® It would be very difficult to administer® This would be true, not only for the Treasury, but also for the taxpayers, as it would require the use of forms and questionnaires far more complex than any involved in the administration of the individual income tax© It seems to me that the basic problem of the taxation of individuals in wartime is really not very complex* Aggregate individual income is higher, and the Government must tax a portion of it away© There may be a great deal of dispute as to which income brackets should be drawn upon the most heavily, but any reasonable pattern of withdrawal can be effected by means of the individual income tax© I think it is a good rule when any other tax is proposed, that y o u first express the distribution of its burden in terms of the individual income tax, and then ask yourself whether y o u would consider it reasonable that the burden of the individual income tax itself should be so altered® If the answer is 11Ho,M then the other tax should be placed on the defensive and its proponents made to justify it by reasons of strong public policy® Sometimes this can be done for example, I believe that the luxury excises proposed by the Treasury this year and the spendings tax'proposed last year are cases in point0 The test should be rigid, hov/ever, and the considerations of public policy should be important before a tax is placed on the statute books, the burden of Yrhich is distributed in a manner other than that in which we would be willing to distribute the burden of ah-inci’ease in'the individual income tax® I turn new to our policies with respect toY/artime borrowing® have been dominated by the folloY/ing considerations© These First, we have tried to borroY«r as much as possible from investors other than commercial banks® This principle must be stated subject to some qualification® It Y/ould neither be possible nor desirable to do;-all of our borroYdng outside of the banking system® I have already explained that one of the reasons for borrovdng at all, rather than relying exclusively upon taxation, is that an expanding wartime economy needs r*r even at a con stant price level t **- a greatly increased amount of currency and bank deposits* These can be obtained, under existing institutions and in wartime, only by a corresponding increase in the Government security holdings of commercial and Federal Reserve Banksj and a sufficient amount of securities have to be sold to the banks to provide this necessary circulating medium, even if adequate markets exist for them elseY/here© ~ 6 — The amount of Government securities which would thus have to be sold to the banks in any event is substantial; but, in practice, I must admit that this has proved little of a problem, since rt has taken care of itself by the rapid expansion of the borrowing needs of the Federal Government and the slower development of nonbanking sources for Federal borrowing® For this reason, we have directed our main effort to the sale of securities to nonbanking investors® During the past year* we have sold to such investors, net after all switches and redemptions, about forty billion dollars of Government securities, as compared with about thirty billions absorbed try the banks® Second, we have tried to make the securities sold to the small investor as riskless as possible® The Treasury has considered itself the trustee of the inexperienced investor® It is with this in view that the Departments appeal to small investors has been confined $0 Series E bonds which are nonanegotiable, payable on demand and hence are guaranteed against fluctua tions in market values® The Treasury is less concerned With the large volume of demand obli«gations which is being built up by the sale of savings bonds to small investors than it would be with the only practicable alternative to this ' course® This alternative would be the sale to small investors of marketable securities payable by the treasury only after the expiration of a fixed term of years® The fixing of a definite term on securities sold to small investors by no means insures that they will be held by these investors for the full teririo 3y and large, the holders of marketable securities would sell them op the same occasions when holders of redeemable securities would redeem theirs® Indeed, there is one important Occasion upon which marketable securities would be sold, but redeemable securities would not be redeemed **» that is, the fear of a decline in price, from which the nonnegotiable securities are immune® Now it may appear, at first glance, that while the treasury should'be properly concerned with redemptions, it should not be concerned w ith market sales, since it must meet the redemptions out of its own pocket; while the market sales will be t-aken up by somebody else® This type of reasoning would suffice for a private borrower, but it is entirely inadequate for the Treasury since it overlooks the real problem which the holdings of government securities ^ whether redeemable or marketable by small investors m i l present in the post-war period® This problem is that the holders of these securities may dispose of of them and spend the proceeds o n .consumers1 goods at a time when the supply of such goods will be scarce; and the spending can result only in price riseso This problem would exist, however, whether the securities were payable on demand or were negotiable and payable at the close of a fixed term, and vnJLl be somewhat less troublesome for demand securities, because, as 1 have already pointed out, the liquidation of this type of security m i l never be precipitated by the fear of a fall in the price of the security itself® The other problems which will be caused try holdings of Government debt by small investors in the post-war period are minor, relative to the major problem w h i c h X have just mentioned; and will be less serious with demand obligations than with negotiable obligations of fixed term* When savings bonds are presented for redemption to the Treasury and it is necessary to refund them, the Treasury offers the type and maturity of new securities best suited to the market at the time, and offers these securities for distribution through the regular channels of the Government security market0 Marketable securities, by contrast, would be offered in small blocks, oftentimes through irregular channels where the original holders may not receive full value, and might dribble into the market in such a way as to keep it continually disturbed© They might not be fitted by coupon rate, maturity, or other characteristics for the predominant demand then existing in the market, but they would have been cast in whatever mold they were, once and for all, and the market would have to make the best of it© To the extent that the refunding of demand- obligations vrould have been accomplished by the sale of securities to banks, -so also would the marketable securities find their ultimate lodgment in banks, but only after a roundabout journey, probably involving both loss to their original purchasers and a higher interest cost to the Treasury© It seems clear, therefore, that the Treasury is in a much better position to refund the non-negotiable securities than the individual woiv..^ be to refund negotiable securities through the market© The third of the principles governing our borrowing policy has been the maintenance of the liquidity of the banking system® We have laid d own the policy that no securities will be offered to commercial banks for the investment of their demand deposits with’ a maturity at time of issuance of over ten years0 The great majority of the securities sold to commercial banks have had maturities far shorter than this© Indeed, more than half of the total increase in the portfolios of commercial banks since Pearl Harbor^has been in the form of three-month Treasury bills and one-year certificates of indebtedness* This concentration of sales to commercial banks in short securities insures that our banking system will be in a strong and liquid position to meet the problems of the post-war period0 Finally, we have financed this war at an average rate of slightly less than 1-3/4 pon cent© This compares with an average rate of about 4— 1/ 4. per cent on the securities issued to finance the last World War© ^Interest rates have remained stable during the wartime period and confidence in the continuation of this stability has been and is widespread and well justified, and has caused investors to subscribe to new issues of Government securities in successive war loans without any sign of holding back in anticipation of higher rates© a X think it can be fairly said of the United States, as the late Chancellor of the Exchequer, Sir Kingsley Wood, recently said of Great Britain, that ”, ♦ . we have revolutionized public opinion as to what are fair rates for Government war borrowing.” I believe that this revolution in opinion has a sound basis in underlying economic realities, and is applicable to the coming times of peace also# I hope that the policies of the Government will be directed to this end. Financing the Post-War Readjustment I come now to the second major division of my topio, that is, the prob lems of the post-war readjustment period. I approach this subject with some trepidation. Ho post-war plan will be of any value unless we win the war and are in a position to put it into effect. The war is not yet in the bag. Hitler»s post-war plan is slavery, and there will not be room for both his plan and our own, You all remember the recipe for rabbit stew which begins ”First catch the rabbit,” So it is with post-war planning. Tfe must first win the warj and we must not let anything, even post-war planning, distract our minds from this for an instant. Immediately following the close of the war, we will be confronted with the problem of reconversion. The period of reconversion will be a time fraught with exceptional hazard to our economic structure• During normal times, most pf pur people are engaged in producing goods which they and their fellow workers can buy with their wages. During wartime, they are largely engaged in producing war goods which they cannot purchase with their incomes, but the excess purchasing power which is thereby created is held in check by direct controls, by personal taxation and by Government borrowing from individuals^ The people are willing to accept and cooperate with these measures because of patriotism and the all-pervading spirit of sacrifice which exists during wartimes. During the reconversion period, however, While the tools of production for peace goods are being made ready, purchasing power may outrun the goods available for purchase, while wartime measures of control may be relaxed if the people do not recognize the need for continued restraint, A price inflation is, consequently, one of the hazards of the reconver sion period. Stalking hand-in-hand with it-goes the hazard of unemployment. Normally, these two are never seen together, since unemployment usually rises from a lack of demand for goods and inflation from a shortage of goods. The unemployment of the reconversion period will be caused, however, not by a lack of demand for the finished products, but because the plants are not yet ready for mass reemployment, and so may go hand-in-hand with inflation. One© the period of reconversion is over and the tremendous potentialities of the American economy which have been demonstrated during the war period are directed to the production of the goods of peace, the main hazard of inflation will be over, c - 9 - The task of statesmanship in the period immediately following the war will be to hasten the reconversion process while mitigating its hardships and reducing its human costs* This task will, of course, be easier if a termination of the war on one front before the other should make it possible to complete part of the reconversion process under a wartime environment. But we must press for victory against Japan as well as Germany without regard for the economics of reconversion. This evening I shall discuss only three aspects of fiscal planning for the reconversion period, and these briefly. They are, first,, the cancelation of war contracts; second, the adequacy of corporate financial resources to carry on the work of reconversion; and, third, the control of individual spending during the reconversion period. If the war should end today on all fronts, there would be outstanding more than 75 billion dollars of war contracts on which deliveries had not yet been made. Much of the material covered by these contracts would be of no use to the Government if it were delivered after the immediate emergency of this war had passed. This is because there are no goods with respect to which obsolescence runs faster than it does for the goods of war; so the best preparation for future Wars consists in maintaining the skills and plant capacity necessary for the development, production, and use of new war goods rather than in hoarding vast quantities, of old ones. Part of the undelivered contracts would still exist merely in blue-prints in the hands of the contractors, while part would be represented by goods in process, some of which in turn could be converted into peacetime goods. in my opinion, all war contracts should be canceled immediately upon the passing of the military need for the goods contracted for* This is de sirable for two important reasons. First, it avoids the tremendous waste of human and material resources involved in making goods which we will never use; and, second, it gives the maximum stimulation to the men and management released from making such goods to seek employment in the produc tion of goods for which there is a human need, and so hastens the process of reconversion. The abrupt cancelation of war contracts will give rise to two problems. These are: First, provision for the labor thrown out of employment; and second, compensation for the contractors. The first of these problems should be settled with liberality; the sec ond, with the utmost of speed. A generous treatment of the labor displaced by contract cancelation is required, not merely by considerations of common humanity and fair dealing, but also by considerations of economy; for without it,, we are unlikely to secure abrupt cancelation at all, and there is no form of relief more expen sive than the production of unneeded tools of war. We should be sure, how ever, that the treatment accorded labor displaced from war production is of such a character that it encourages, rather than slows down, its quest for peacetime employment, * 10 - Payments to contractors should be just in accordance with a fixed standard of equity* that is, they should be enough to make the contractors and their subcontractors whole for the losses they have sustained as the result of the contract cancelations* It is important also, that payments to contractors should be prompt. This is not primarily for the benefit of the contractors themselves — although I have no doubt that they will appreciate it — but for the benefit of the country as a whole. A dollar paid out in the settlement pf war con tracts during the early reconversion period may — in terms of national well being — * be worth several dollars paid out a year or so later, it is far more important, therefore, t hat the settlements be prompt than that they be accurate to the last dollar according to some accounting concept, which may itself be open to question* The settlement of war contracts along the lines which I have just out lined will involve a heavy outflow of funds from the Treasury in the few months immediately lollowing the end of the war. We are prepared for this outflow, and we feel that there, will be few occasions when a disbursement of funds may be made with so little real cost to the Government and so much benefit to the economy. My second point with respect to the reconversion period relates to the adequacy of corporate financial resources to carry on the work of reconversion. The adequacy of these resources is important, not merely or even principally from the point of view of the corporations involved, but from the point of view of the whole economic system. . • We in the Treasury have given careful consideration to this matter, and believe that funds for the reconversion of war industry will be ample, pro vided that a prompt settlement is made of canceled war contracts. Our reasons for believing this are as follows? First, the wartime period has been a profitable one for American corpo rations as a whole. Net corporate profits, after taxes, have averaged about twice as much per year during the wartime period as they did in the years 1935 through 1939 (the base period for the FEB index of industrial produc tion),* and, by and large, the greatest increases have gone to those firms whose problems of reconversion will be greatest. Corporate dividend policy, furthermore^ has been so conservative that most of the increase in corporate earnings has been added to surplus. Second, in addition to their savings from undistributed earnings, American corporations have piled up a large volume of liquid assets as a result of repayment of receivables, and in some cases reduction in inventories and the general inability to expend depreciation and depletion reserves which has been brought about by wartime conditions. According to the estimates of the Federal Reserve Board, the demand deposits of nonfinancial businesses, including unincorporated enterprises, amounted to over 30 billion dollars’at the end of last July,* and, according to Treasury estimates, the holdings of Government securities payable for the most part on demand or at very short term —— by nonfinancial corporations alone, amount at the present tim© to o m 11 about; 20 billion dollars. Each of these figures is far above any peacetime precedent; but, to make the picture brighter, American business, during the same time it has been acquiring them, has reduced the amount of both its bank loans and its bonded debt. Third, generous carry-back and carry-forward provisions included in the corporation tax laws insure that corporations suffering losses during the reconversion period, or even earning incomes of less than their excess profits credit, will receive substantial refunds of the taxes paid in their prosperous years. These refunds t - for the expediting of which the Treasury has made recommendations to the- Congressional committees — will be available to carry on the work of reconversion. In addition, there is provided in the present law a post-war refund, irrespective of future^ tax status, of ten per cent of the excess profits tax paid in the war period. For the reasons given, I do not believe that the adequacy of business funds for reconversion purposes will.present a major problem. But I cannot speak with equal assurance with respect to the■prospects for the control of individual spending during the reconversion period -- the third post-war problem to be discussed. Immediately fallowing the end of the actual fighting, we can probably expect a let-down in the willingness of people to submit from patriotic mo tives to a continued, reduction in their consumption. There is likely to be a demand for an immediate end of the direct controls; and this demand may, to some extent, succeed.. For some time, however, while industry is being reconverted and the war effort demobilized, there will be only a very gradual increase in the supply of consumers* goods. When it is considered that there will be available to be spent currently, in addition to the incomes being received for the production of consumers*goods, not merely the incomes from work in demobilizing the war effort and reconverting private industry, but also the large liquid resources piled up during wartime, it is easy to conjure up the specter of a post-war inflation. Against this must be set the povrerful force of human foresight and so briety. The reconversion period is bound to be attended by considerable un employment, and each individual will naturally ask himself how he is going to come out in the swirl of readjustments he sees around him. His natural tendency will be to ’’play it close to the chest” and handle his reserve funds as carefully as possible. This human tendency alone may maintain a high rate of saving during the reconversion period, and so forestall the possi bility of a post-war inflation. We hope that this will be so; but counting on it would be as improvident as counting on an internal smash-up in Germany to win the war, We must con sequently lay our plans to prevent a post-war inflation from occurring, but stand ready to adjust any such plans on short notice to conditions as they actually develop during the reconversion period, What should these plans be? It seems to me that the direct controls, such as price ceilings, priorities,, and rationing, should be kept in effect as long as necessary* and high income taxes, as long as possible. 12 - Let me explain the difference between "necessary" and "nossible" the statement which have just made. P m Ihile I believe that we should keep the direct controls as long after the war as necessary, :;l do not believe that this will be very long. I feel certain that the last *of them can be done away with as soon as the reconverted plants commence to pour* their flood of consumers’ goods on the market. I have said, however, that the high rates of taxation should be kept as long as possible. I think that the case here is very different. High per sonal taxes serve the anti-inflationary purpose of absorbing surplus purchas ing power 5 and this may be very useful and necessary in the reconversion period. But they also serve the purpose of helping to pay off the national debtj and this purpose is also useful and necessary. It seems to me, therefore, that, while the criterion with respect to e removal of the controls should be "How soon can we remove them without u inflation?"; the criterion with respect to wartime rates of taxation should be "How long can'we keep them without risking unemployment?" Perhaps for a long time to come, if the post-war period lives up to our hopes and expectations. r But this would take me into new vistas beyond the scope of tonight’s address for J have no intention of discussing the broader phases of fiscal policy beyond the reconversion period. I would like to make, however, a few general observations. The war has opened the eyes of the American people to the tremendous productivity of inustrial and agricultural America, The shortages of peacetime goods and services that exist now have not blinded us to the enormous potentialities for abundance inherent in our productive mechanism. It is precisely this unexampled capacity to produce upon which the future prosperity and welfare of our people ultimately depend. r e To help society achieve more fully the promise of abundance implicit m our capacity to produce; to help maintain output and employment at a leve more nearly corresponding to our true productive potential; and to secure is at a price that a peaceful democracy can pay; — that will constitute the greatest task of economic statesmanship in the post-war world. I do not believe that the glory of America belongs only to the past, I believe that the real promise of America belongs to the future. Between the goal of securing maximum utilization of our resources and the goal of achieving a more equitable distribution of wealth, there need be no conflict Our history has been testimony to that fact, and our future will be the record of its fulfillment. I TREASURY DEPARTMENT FISCAL SERV IC E BUREAU OF ACCOUNTS W A S H IN G TO N O F F IC E O F TH E CO M M ISSIO N E R December 7» 19 ^ 3 3 During the month of November, I9 L 3 , the following market transactions took place in direct and guaranteed securities of the Government: S a l e s ......... ..... ............. $5,000,000 P u r c h a s e s .......... ......... . ..... - Ket s a l e s .... ............. $5.000.000 ~ TREASURY DEPARTMENT Washington POR iMMBDIATE RELEASE, Wednesdaj, De.cember X5« 1945* Pitess Service No. 39-96 During the month of November, 1943, market transactions ih direct and guaranteed securi ties of the 0#f^rnment tor Treasury investment and other ac&$$$$£ $3,000,000, |n net sales of Morgenthau announced today, -oOOt sources of bogus money that for several years plagued the district Previously he had performed similar service in the Boston district He came to Washington as Supervising Agent in 1942, - 2 - At Newark and New York Mir* Maloney directed investigations which smashed major counterfeiting gangs operating in the area, and carried out many such as arranging for protection of the President and distinguished foreign visitors. He directed the protective detail that accompanied the King and Queen of England on their visit to the World*s Pair in 1939* He had charge of arrangements for the visit of Madam Chiang Kai-shek early this year, an assignment involving as great a variety of difficult situations as any protective operation ever undertaken by the Service. A v :/( o t all Treasury^Enf As ijjjiint District Coordinator,.^ Treasury Enforcement agencies from February, 1941, he played a prominent role in the organization of port protection and other wartime services of the Treasury and other cooperating Government and military authorities. Mr. Maloney served in the first World War as a private in the Army Air Force, with the Ninety-third Aerial Squadron at San Antonio, Texas, and in France. Mr. and Mrs. Maloney have taken residence at 2800 Ontario Road, N.W. Mr. McGrath, who succeeds Mr. Maloney in New York, is return ing to a familiar field. A veteran of 26 years with the Service, he headed, from 1938 to 1942, a special counterfeit detail working under Mr. Maloney in the New York area which smashed the major /• ( 2 — ^60 ^ 2 ^ i c ^ - P / ^Phw-g>g«ftfwaa»^today announced the appointment of James J* Maloney as Assistant Chief of the United States Secret Service, succeeding Joseph E. Murphy^who retired recently after 45 years in the organization, j^Mr. Maloney comes to Washington from New York City where he has been Supervising Agent of this key district since 1938* Chief Prank J, Wilson announced also that John J. McGrath has been trans ferred from the Capital, where he was Supervising Agent of the Washington district, to the New York City post; and has in turn been succeeded by Harry 3). Anheier^who formerly was Agent in Charge at New Orleans. Mr* Maloney is 47 years old. New York. He is a native of Bingham/ton, The new Assistant Chief was a law enforcement officer in southern New York for 12 years before his appointment to the Secret Service in 1931 as an operative at Detroit. In 1935 Mr. Maloney was transferred to Syracuse, New York, as Operative in Charge. In 1936 he was moved to Buffalo in the same capacity, and in December of that year became acting Supervising Agent of the Newark district. Mr. Maloney was designated Super vising Agent in 1938, and was transferred in the same year to the New York position. The New York district is considered the most important in the Secret Service field organization because of the range of activities and the scope of work the Service is. called upon to perform. TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, Thursday, December 16, 1943. Press Service No. 39-97 Secretary Morgenthau today announced the appointment of James J. Maloney as Assistant Chief of the United States Secret Service, succeeding Joseph E, Murpiy, who retired recently after 45 years in the organization. Mr. Maloney comes to Washington from New York City where he has been Supervising Agent of this key district since 1938. Chief Frank J. Wilson announced also that John J. McGrath has been transferred from the Capital, where he was Supervising Agent of the Washington district, to the New York City postj and has in turn been succeeded by Harry D. Anheier, who formerly was Agent in Charge at New Orleans* Mr, Maloney is 47 years old. He is a native of Binghamton, N e w York. The new Assistant Chief was a law enforcement officer in southern New York for 12 years before his appointment to the Secret Service in 1931 as an operative at Detroit. In 1935 Mr. Maloney was transferred to Syracuse, New York, as Operative in Charge. In 1936 he was moved to Buffalo in the same capacity, and in December of that year became acting Supervising Agent of the Newark district. Mr. Maloney was designated Supervising Agent in 1938, and was transferred in the same year to the New York position, The New York district is considered the most important in the Secret Service field organization because of the range of activities and the scope' of work the Service is called upon to perform, At Newark and New York Mr. Maloney directed investigations which smashed major counterfeiting gangs operating in the area, and carried out many other important assignments such as arranging for protection of the President and distinguished foreign visitors. He directed the protective detail that accompanied the King and Queen of England on their visit to the World's Fair in 1939. He had charge of arrangements for the visit of Madam Chiang Kai-shek early this year, an assignment involving" as great a variety of difficult situations as any protective operation ever undertaken by the Service. As District Coordinator in the states of New York and New Jersey of all Treasury Enforcement agencies from February, 1941, he played a prominent role in the organization of port protection and other wartime services of the Treasury and other cooperating Government and military authorities. Mr. Maloney served in the first world War as a private in the Army Air Force, with the Ninety-third Aerial Squadron at San Antonio, Texas, and in France. - 2 - Mr. and Mrs. Maloney have taken residence at 2300 Ontario Road, N. M Mr. McGrath, who succeeds Mr* Maloney in New York, is returning to A^veteran of 26 years with the Service, he headed, from tu t,° a sPec^^- counterfeit detail working under Mr. Maloney in the New York area which smashed the major sources of bogus money that for several years plagued the district. Previously he had perforated similar 1 ^ 1 9 4 2 in Boston district* He came to Washington as Supervising Agent oOo TREASURY DEPARTMENT Washington FOR IMMEDIATE RELEASE, Thursday, December 16, 1943* Press Service No. 39-97 Secretary Morgenthau today announced the appointment of James J. Maloney as Assistant Chief of the United States Secret Service, succeeding Joseph E, Murpl^r, who retired recently after 45 years in the organization. Mr. Maloney comes to Washington from New York City where he has been Supervising Agent of this key district since 1938. Chief Frank J. Wilson announced also that John J, McGrath has been transferred from the Capital, Y/here he was Supervising Agent of the Washington district, to the New York City post; and has in turn been succeeded by Harry D. Anheier, Yirho formerly was Agent in Charge at N e w Orleans. Mr, Maloney is 47 years old* He is a native of Binghamton, New York. The new Assistant Chief was a law enforcement officer in southern New York for 12 years before his appointment to the Secret Service in 1931 as an operative at Detroit. In 1935 Mr. Maloney was transferred to Syracuse, New York, as Operative in Charge. In 1936 he was moved to Buffalo in the same capacity, and in December of that year became acting Supervising Agent of the Newark district. Mr. Maloney was designated Supervising Agent in 1938, and was transferred in the same year to the New York position. The New York district is considered the most important in the Secret Service field organization because of the range of activities and the scope of work the Service is called upon to perform. At Newark and New York Mr, Maloney directed investigations which smashed major counterfeiting gangs operating in the area, and carried out many other important assignments such as arranging for protection of the President and distinguished foreign visitors. He directed the protective detail that accompanied the King and Queen of England on their visit to the World’s Fair in 1939. He had charge of arrangements for the visit of Madam Chiang Kai-shek early this year, an assignment involving as great a variety of difficult situations as any protective operation ever undertaken by the Service, As District Coordinator in the states of New York and New Jersey of all Treasury Enforcement agencies from February, 1941* he played a prominent role in the organization of port .protection and other Yrartime services of the Treasury and other cooperating Government and military authorities. Mr. Maloney served in the first world War as a private in the Army Air Force, Ydth the Ninety-third Aerial Squadron at San Antonio, Texas, and in France. - 2 ~ Mr. and Mrs. Maloney have taken residence at 2800 Ontario Road, N. W, Mr. McGrath, who succeeds Mr* Maloney in New York, is returning to a familiar field* A^veteran of 26 years with the Service, he headed, from 1933 to 1942, a special counterfeit detail working under Mr. Maloney in the Now York area which smashed the major sources of bogus money that for several years plagued the district; Previously he had performed similar service in the Boston district. He came to Washington as Supervising Agent oOo TREASURY DEPARTMENT Washington FOR RELEASE, MORNING NEWSPAPERS Monday, December 27, 1945 Press Service No. 39-98 Secretary of the Treasury Morgenthau today made public data from "Statistics of Income for 1941, Part 1,” compiled from indi vidual income tax returns and taxable fiduciary income tax returns filed during 1948. These .data are prepared under the direction of Commissioner of Internal Revenue Robert E. Hannegan. The total number of returns filed for the income year 1941 is 25,954,801 of which 15,617,209 are individual returns, Form 1040; 10,252,708 are the optional returns, Form 1040A* filed by individuals With certain gross income of $ 3,000 or less; and 84,884 are taxable fiduciary returns, Form 1041. As compared with the^previous year, the total number of returns increased 76 percent. The, increase is approximately 10 million taxable returns and 1 million nontaxable returns. The -total net income reported is $58,868,025,304, an increase of 61 percent. Included is $ 17,531,107,226 gross income reported on Form 104QA which does not provide for reporting the amount of net income. There are 17,587,768 taxable returns of which 17,587,471 show net income of $45,902,883,995, and '297 show deficit.of $ 7,573,471 owing to net long-term capital loss but disclose $2 ,326,475 alter native tax. Of the 8 ,367,033 nontaxable returns, 8 ,267,502 show net income of $ 12,965,141,399 — nontaxable because exemptions end credits exceed net income; and 99,531 show-a deficit of $ 284,449,222 — returns on which deductions equal, op exceed total income. The total tax liability amounts to $ 3 ,907,951,001 an increase of 161 percent over the,previous year. For taxable returns with net income, the average tax is $222 compared with $199 for 1940 and the effective tax rate is 8.5 percent compared with 6.4 percent for 1940. The amount and percent of increase or decrease in number of returns, net income, deficit, and taxes for 1941 over 1940 are as follows: , Individual returns and taxable fiduciary returns, 1941 and 1940* Number of returns, net income, deficit, and taxes (Money figures in thousands of dollars) 1941 Increase or decrease(-} 1941 over 1940 1940 Amount Total Individual and tax able fiduciary returns: Number of returns Net income Deficit Total tax Taxable individual and fiduciary returns* With net income* Number of returns Net income Tax Normal tax Surtax Alternative tax 3/ Defense ta x $ / Optional tax Individual returns with no net income* Number of returns Deficit Alternative tax Nontaxable individual returns * With net income 6/: Number of returns Net income With no net income 7/s Number of returns Deficit For footnotes, see p* 14 25,954,801 Percent 14,778,159 36,588,546 311,385 1,496,403 11,176,642 22,279,480 -19,362 2,411,548 76 61 -6 161 17,587,471 1/ 45,902,884 2/ 3,905,625 556,019 1,927,715 1,092,261 1,150 328,479 7,504,649 23,558,030 1,495*930 388,950 435,331 543,299 128,350 10,082,822 22,344,854 2,409,694 167,069 1,492,385 548,962 -127,200 328,479 134 95 161 43 543 101 -99 297 7,573 5/ 2,326 46 2,551 473 251 5,023 1,854 546 197 392 8,267,502 12,965,141 7,160,813 13,030,516 1,106,689 -65,374 15 -1 99,531 284,449 112,651 308,834 -13,120 24,385 -12 8 1 / 58,868,025 292,023 2/ 3,907,951 • - 3 The major changes in law affecting data on returns for the tax able year 1941, ares (l) Elimination of the defense tax; (2) imposi tion of surtax upon the entire surtax net income with an increase in the surtax rates; (3) provision for an optional tax on individuals with certain gross income of #3,000 or less, in.lieu of the normal tax and surtax; (4) reduction in the minimum amount of gross income for which a return is required to be filed from $2,000 to $1,500 for a married person living with husband or wife for the entire taxable year, and from $800 to $750 for a single person, a married person not living with husband or wife, an estate, and a trust; (5) reduc tion of the personal exemption from $2,000 to $1,500 for a married person living with husband or wife for the entire taxable year or a person who is head of a family, and from $800 to $750 for a single person, a married person not living with husband or wife, or an estate* and (6) disallowance of credit for one dependent when tax payer is head of a family only by reason of dependents for whom he would be entitled to credit. The Public Debt Act of 1941 provides for the taxation of inter est on obligations issued on and after March 1, 1941 by the United States or any agency or instrumentality thereof. The returns included in this report are those for the calendar year ended December 31, 1941; a fiscal year other than a calendar year, ending within the period July 1941 through June 1942; and a part year with the greater part of the accounting period in 1941. Returns from which data are tabulated are Forms 1040, 1040A, 1040B, and 1041. Tentative returns and amended returns are excluded* ' Statistics are taken from the returns as filed by the taxpayer, prior to revisions that may be made as a result of audit by the Bureau of Internal Revenue. Data for individual returns, Form 1040, with net income of $5,000 and qver, and for taxable fiduciary returns regardless of the amount of net income, are completely tabulated from each return* This procedure is followed also with respect to a portion of the individual returns, Form 1040, with net income under $5,000 while data for the remainder of such returns and for individual returns, Form 1040A, are estimated from samples. For the first time, data for individual returns, Form 1040A, are tabulated separately from data for returns, Form 1040. Return Form 1040A, is an optional return which may be used by individuals with gross income of $3,000 or less consisting wholly of salaries, wages, and compensation for personal services, and dividends, interest, rents, annuities, and royalties. Deductions and the amount of net income are not reported. Gross income is tabulated both as total income and net income and the optional tax, paid in lieu of normal tax and surtax, is tabulated as total tax. The amount of personal exemption shown in the tables is determined from the t a x p a y e r s status as indicated on the return. Earned income credit is computed as 10 percent of the gross income. 4 Five tables are presented in this release# Composite data for individual and taxable fiduciary returns are shown in tables 1, 2, and 3 whereas data for individual returns, exclusively, are shown in tables 2-A and 3-A, Data in table 1 are classified by States and Territories and those in the remaining 4 tables by net income classes. Since a classification of the returns, Form 1040A, cannot be made on the basis of net income, data from these returns are shown in aggre gate in the tables which present data tabulated by net income classes# ' Table 1. - Individual returns and taxable fiduciary returns, with net income, and individual returns wi t h no net income, 1941, b y States and Territories: Population, percent of population filing returns, total number of returns, and total tax; for returns with net income, number o f returns, net income, and tax; for returns with no net income, number of returns and deficit; for returns, Form 10404, number of returns, gross income, and tax STATES AN D TERRITORIES (1) Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware District of Columbia Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana Maine Maryland Massachusetts Michigan. Minnesota Mississippi Missouri Montana Nebraska Nevada Ne w Hampshire New Jersey Ne w Mexico New York North Carolina North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington . West Virginia Wisconsin Wyoming Total For footnotes, see pp. 14 and 15. Population April 1, 1940 (Sixteenth Census) (in thousands) (2) 2,835 73 499 1,949 6,907 1,123 1,709 267 663 1,897 3,124 423 525 7,897 3,428 2,538 1,801 2,846 2,364 847 1,821 4,317 5,256 2,792 2,184 3,785 559 1,316 no 492 4,160 532 13,479 3,572 642 6,908 2,356 1,090 9,900 715 1,900 643 2,916 6,415 550 359 2,678 1,756 1,902 3,138 251 132,165 Percent of population filing re turns (5) 7.41 35.58 15.39 5.12 29.97 16.04 34.69 24.19 37.86 12.75 8.27 23.49 14.39 26.45 20.00 17.15 14.27 9.24 9.82 16.99 27.95 27.39 26.10 18.36 4.24 15.76 19.05 13.95 35.37 21.13 29.44 9.90 25.87 7.79 13.84 24.54 9.17 ' 21.43 22.57 28.52 7.28 12.47 9.01 12.46 14*14 16.40 13.79 26.93 13.98 19.89 19.44 19.64 Total number of individual and taxable fiduciary re turns (col. 6 + 9 + 1 1 ) (4) 210,043 25,807 76,815 99,736 2,069,810 180,211 592,878 64,470 251,072 241,888 258,371 99,460 75,552 2,089,198 685,684 435,374 256,926 262,892 232,217 143,963 508,954 1,182,347 1,372,039 512,550 92,689 596,473 106,596 183,516 38,991 103,883 1,224,656 52,667 3,486,610 278,245 88,855 1,695,454 214,163 233,481 2,234,440 203,430 138,219 80,147 262,747 798,974 77,812 58,913 369,340 467,601 265,842 624,057 48.743 25,954,801 (Money figures in thousands of dollars) Individual returns ami taxable fiduciary returns 8/ w i t h net income, not includ ing returns. Form 104QA Total tax 2/ Number ox Net income 8/ Tax returns (5) 28,323 2,420 8,947 16,480 296,094 23,909 110,692 37,808 45,532 54,328 41,708 13,356 5,940 345,188 76,470 30,208 23,918 29,003 34,089 15,158 81,455 171,366 220,699 51,947 14,693 87,303 9,729 15,971 6,469 10,496 190,592 6,530 686,108 39,186 3,704 243,088 28,172 28,219 338,184 32,245 13,584 3,938 43,140 126,052 7,593 5,457 56,055 53,089 25,183 62,4 U 5,723 3,907,951 (6) (7) (8) 102,470 13,345 40,313 69,699 1,160,181 118,965 279,186 36,278 117,693 150,510 137,807 29,186 51,485 1,184,019 432,234 350,207 191,493 167,396 127,804 85,623277,106 634,200 782,708 365,536 58,676 414,182 67,388 131,169 17,109 57,914 756,409 33,227 2,331,967 164,138 76,763 1,043,219 154,467 141,071 1,256,497 116,548 74,476 63,597 145,537 528,218 47,936 38,603 197,518 232,019 116,496 400,001 31,676 296,998 34,881 104,403 192,871 3,126,641 288,802 863,285 149,883 377,571 460,178 415,369 106,175 112,052 3,325,464 1,036,323 672,947 414,388 407,212 356,092 203,636 833,821 1,707,677 2,245,774 795,449 165,695 1,034,435 160,023 281,162 50,976 133,417 2,104,681 85,370 6,372,005 417,619 132,633 2,757,968 376,410 354,360 3,345,229 305,562 184,009 113,772 420,128 1,378,671 116,947 82,930 566,408 592,278 506,749 890,208 79,381 26,418 fe,205 7,696 16,068 265,271 22,426 97,913 36,860 39,632 52,S6o 39,443 11,093 5,126 311,575 68,620 28,622 22,631 27,017 31,732 14,074 74,915 156,090 192,668 46,957 13,735 82,449 8,461 14,799 5,695 9,463 176,533 5,949 651,215 36,839 3,511 221,853 26,937 25,126 305,279 28,769 12,813 3,693 40,075 119,046 7,006 4,982 49,916 44,062 20,986 55,041 5,301 15,602,265 41,336,918 3,577,146 Individual returns with no net income 7/ Number of Deficit returns O) 699 105 714 472 13,124 1,582 1,274 140 118 2,869 1,504 34 637 7,350 2,273 3,119 1,881 785 1,287 1,344 875 4,775 761 1,918 427 2,717 826 1,973 80 634 2,864 649 16,606 248 636 3,792 1,653 1,296 4,494 83 603 868 591 6,027 7 19 679 1,910 <33 291 382 99,828 Individual returns, Form 1040A 9/ Gross income Number of returns (10) 1,523 297 1,616 1,233 36,374 2,595 4)626 1,899 982 9,020 4,970 171 866 17,599 5,695 3,943 3,330 1,737 3,470 2,252 3,173 12'649 7,347 2,948 807 6,168 1,361 2,694 238 910 9,221 1,061 75,634 708 721 11,021 3,793 2,986 16,343 933 1,033 '843 2,107 14,975 12 118 1,435 4,067 l)001 817 683 292,023 (ii) • 106,874 12'357 35,788 29,565 896,505 59,664 312,418 28'052 133,261 88,509 119,060 70,240 23,430 897,829 251,177 82,048 63,552 94,711 103,126 56,996 231,573 543) 372 588,570 145,096 33,586 179,574 38,382 50'374 21,802 45*335 465j383 18)791 1,138)037 113'859 11*456 648,443 58't)43 9i'ii4 973*449 86*799 63^140 15,682 116*619 264*729 29'869 20*291 171*143 233^672 148*913 (12) 175,170 18)400 64,058 47,119 1,475)559 98*400 5 4 1)0 74 46)301 220,299 143)420 189,619 116,488 40,871 1,545,760 '436)119 130)585/ 105)853 160,234 169,706 89,186 377*307 889)146 1,123)970 '249)107 58)744 309)311 66*252 79)968 16)685 37*018 71*975 790* 388 33*071 1,909*371 *187*105 18)047 1,137*040 99*965 150^879 1,731^721 *150*148 96*746 24^803 197*570 458)117 53* 770 33^689 300*106 402*618 270^883 379^301 28)751 10,252,708 17,531,107 223)765 Tax (13) 1,905 217 1,244 411 30,792 1,483 12*677 *794 5,891 l)731 2,257 2,263 813 33,507 7)842 1,587 1*273 1*981 2 )3 5 1 1)02 0 6*500 15*085 27*948 4*990 *959 4,822 1* 268 1*172 *773 1,032 14*032 *581 33,934 2*347 *193 21,116 1*235 3*094 32*786 3*396 *771 245 3,066 7*000 *587 475 6,107 9*012 4*198 7*288 '422 328,479 ftble 2. - Individual returns an d taxable fiduciary returns, w i t h net lucerne, 1941, b y taxable and nontaxable returns, b y ne t incone classes, and returns b y tyne of tax liability, also aggregates for taxable and n ^ t a x ^ l e individual returns wi t h no net Income i Number o f returns, ne t Income, personal exemption, credit for dependents, 5 earned income credit, total, tay. normal tar mtrtnr nlthw,nt4wa a... -------- j ■ < x _ » ... . . ? 9 Income classes a n d Me t income Jj/ classes JlL Taxable individual an d fiduciary returns , With net income, Fbrm 10404 (est.) jJ/ Forme 1 0 4 0 an d 1041, U n der .75 (est.) *75 u n d e r 1 (est.) 1 u n der 1. 5 (es$.) 1. 5 u n der 2 (est.) 2 u nder 2.5 (est.) 2.5 u n d e r 3 (est.) 3 u n d e r 4 (est.) 4 u n der 5 (est.) 5 under 6 6 under 7 7 under 8 8 under 9 9 under 10 1 0 under 11 11 under 12 12 under 13 13 u n d e r 14 14 u n der 15 15 under 20 20 under 25 25 u n der SO 30 under 40 40 under 50 50 under 60 60 under 70 70 u nder 80 80 under 90 90 under 100 100 u nder 150 150 under 200 200 under 250 250 u nder 300 300 u nder 400 400 under 500 500 u n der 750 750 under 1,000 1.000 u n der 1,500 1,500 under 2,000 2.000 under 3,000 3.000 under 4,000 4.000 under 5,000 5.000 and over Total, returns with net income With no net income, Fbrm 1040 jj/ Total, taxable returns (44+45) 49 SO SI 52 53 54 55 56 57 58 59 60 61 Nontaxable individual returns, With net income, 6/ Fbrm 10404 (est.) £ / Fbrm 1040, Under .75 (est.) -• .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 under 3 (est.) 3 under 4 4 under 5 Total, returns w i t h net income With no net income, Fbrm 1040 7/ Total, nontaxable returns (56+57) Humber of returns Net income 2 / (5) (8) exetot Credit for Personal dependents exemption 10/ (individual returns) - __ (£__ (♦> in-thousands of doil.-r.) Earned income credit JJJ (individual returns) Total t a x 2J -L?) ( 6) 6,199,542 10,560,017 6,135,612 382,554 1,056,002 598,479 67, £72 766,139 1,292,021 2,127,895 2,821,717 1,697,745 1,648,213 517,277 251,282 151,975 103,676 73,188 56,830 43,398 34,633 27,857 23,156 19,463 62,285 32,289 18,840 20,367 10,314 5,908 .3,660 2,405 1,656 1,223 2,784 969 434 217 244 125 114 55 84 5 25,950 676,559 1,588,178 3,752,174 5,204,885 4,650,648 5,598,869 2,290,184 1,370,260 982,494 774,381 620,596 538,784 454,595 397,750 347,673 312,292 281,887 1,070,515 718,862 514,245 699,970 459,187 322,397 236,467 179,249 140.215 115,678 333,998 166.215 96,903 59,316 84,447 55,318 68,295 47,366 41,633 8,324 23,068 22,545 5,306 561,457 953,529 2,656,488 3,212,804 2,380,151 2,255,750 681,702 328,874 196,212 133,399 93,728 72,479 55,037 43,991 35,044 29.160 24,683 78,620 40,517 23,413 25,058 12,631 7,274 4,513 2,921 2,047 1,469 5,367 1.160 510 266 293 148 131 60 40 5 112 1,576 66,914 157, 552 574,123 519,515 464,245 541,946 203,214 114,022 77,106 58,246 44,924 57,936 31,000 26, 555 22,690 2,118 9,190 54,471 86,205 138,501 160,197 262,196 146,720 104,702 87,507 78,120 69,665 66,504 61,238 67,909 54,495 59,999 50,983 999,565 184,467 153,378 940,347 180,499 138,445 108,503 85,957 70,450 59,488 181,958 95,945 55,971 35,343 51,147 39,659 49,796 99,964 26,117 4,882 14,346 14,292 10 6 10.519 17,587,471 45,902,884 ________ 297 14/7.575 17,587,768 15/45,895,311 11 7 289 20,057,936 509 24,534 99,461 410,122 491,775 567,668 186,886 98,576 60,067 40,139 29,281 22,271 17,047 13,527 11,101 9,067 7,785 24,539 12,585 7,319 7,846 3,939 2,194 1,497 883 600 467 1,015 336 173 64 87 43 36 16 9 20,022 17,525 57,220 30,507 18,065 19,976 10,511 6,271 5,937 2,618 '1,802 1,289 2,941 980 449 208 231 116 102 41 27 5 9 2 4 4 2,535,936 ________ 55 6 3,992,334 _______ 192 6.119 3,905,695 2.326 Number of returns Be turns wi t h normal ta x and surtax 12 / S x — --------— Tbtal (col. Normal tax U ♦ 12 ♦ 15 Net income £ / (8) (9) (10) 67,560 766,135 1,292,010 2,127,879 2,321,706 1,697,730 1,648,085 517,139 251,064 151,745 105,376 72,722 96,205 42,500 33,298 25,756 20,111 15,931 47,124 22,173 12,049 12,065 5,421 2,984 1,665 1,071 724 48 9 975 282 122 45 55 19 IS 8 6 1 3 26,947 676,534 1,588,160 3,752,146 5,204,861 4,650,608 5,598,409 2,289,559 1,369,328' 980,971 772,125 616,452 532,829 445,124 382,548 521,339 271,067 230,698 807,836 492,809 528,450 415,315 241,024 162,510 107,512 79,847 61,238 46,371 U S , 806 48,430 27,084 12,167 19,309 8,329 7,790 6,640 6,914 1,522 6,876 2,033 9,154 54,442 86,141 138,450 159,825 261,912 146,349 104,272 86,949 77,347 68,564 65,041 59,118 54,701 49,181 44,179 40,013 162,351 121,905 94,821 138,052 92,519 68,545 48,617 38,084 30,469 25,964 63,819 28,817 16,772 7,763 12,785 5,665 5,465 4,799 5,U7 1,145 5,268 766 2,245 17,995 26, 6 U 43,455 52,735 89,203 48,491 32,938 25,797 21,523 17,893 15,957 13,676 U,968 10,210 8,725 7,525 27,252 17,287 U,817 15,174 9,014 6,146 4,100 3,062 2,362 1,798 4,517 1,984 1,064 482 766 531 3U 264 276 61 275 1,267 6,9U 56,446 59,550 94,996 107,089 172,706 97,855 71'551 61,142 55,816 50,664 49,076 45,433 42,724 38,961 35,446 32,480 155,047 104,568 82,975 122,800 83,441 62,346 44,485 34,998 28,074 22,144 59,240 26,818 15,686 7,282 12,020 5,534 5,133 4,535 4,841 1,084 4,993 ----------Defense taxi/ (15) (15) 1 1 1 1 5 ’8 8 9 9 7 8 9 9 10 U U 52 48 SO 78 65 53 33 24 33 22 63 14 22 22 - 11,318,242 32,710,285 2,484,393 556,019 1,927,715 658 2,484,593 556,019 1,927,715 658 4,053,166 6,971,090 5,866,187 3,013,028 697,109 - - - * 858,155 284,504 1,309,494 1,024,992 553,386 149,629 33,119 1.0S9 8,267,502 99.531 475,829 250,850 1,722,470 1,809,312 1,223,291 400,356 107,404 4.540 12,965,141 14/284.449 798,008 377,929 1,913,678 1,531,475 829,455 224,616 49,678 1.603 11,592,629 (16) 55,681 68,789 242,609 605,394 536,762 213,351 67,907 5.338 4,806,858 (16) 3,241 1,748 12,911 14,744 9,935 3,302 569 ___ 97 743,578 — * — - _ - - - - - • - • «S» • «. - - - - m - m — - - - * * * - “ - _ _ 11,318,242 32,710,285 2,484,393 556,019 1,927,715 658 — * - M . - Grand total (46t58 o r 60 + 61) [ndiridual returns a n d taxable fiduciary returns wi t h net income (44tS6) [ndiridual returns w i t h no nst income (45+57) footnotes, see pp. 14 and 15, 25,854,978 99,828 58,868,025 24/292,025 31,650,275 (16) 7,342,794 (16) 4,755,912 3,905,625 11,318,242 32,710,285 2,484,393 556,019 1,927,715 658 (16) 2,326 * * “ - - - . f)+'1 Sable 2. - Individual returns and taxable fiduciary returns, w i t h ne t incase, 1941, b y taxable a n d returns, b y ne t lncose classes, an d taxable returns b y type of t ax liability) also aggregates for taxable a nd nontaxable individual returns w i t h no n et Incest I Nuaber of returns, ne t incone, personal exemption, credit for dependents, earned Income credit, total tax, normal tax, surtax, alternative tax, defense tax, average total tax, and effective tax rate - Continued Beturns w i t h alternative tax 5 / Net income 8 / classes 1 2 3 4 S 6 7 8 9 10 U 12 15 14 IS 16 17 18 19 20 21 22 25 24 25 26 27 28 29 30 31 32 33 34 3S 36 57 38 59 40 41 42 43 44 45 46 47 48 49 £0 51 52 55 54 55 56 57 58 (1) Taxable individual a n d fiduciary returns §/: W i t h net income! Form 10404 (est.) 9/ Fbrms 1040 and 1 0 4 1 i Under ,75 (est.) .75 u n d e r 1 (est. 1 under 1. 5 (est. 1.5 under 2 (est. 2 u n der 2.5 (est. 2.5 under 5 (est. 5 under 4 (est.) 4 u n der 5 (est.) 5 under 6 6 u n der 7 7 u n der 8 8 under 9 9 u n d e r 10 , 1 0 u n der 11 11 u n der 12 12 u n der 15 13 u n der 14 14 under 15 15 under 20 20 under 25 25 u n der SO 50 under 40 40 u n der SO 50 u n d e r 60 6 0 u n der 70 70 u n der 80 8 0 under 90 90 under 100 100 u nder 150 IS O under 200 200 u n der 250 250 u n der 300 300 under 400 400 under 500 500 under 750 750 u n der 1,000 1,000 under 1,500 1,500 under 2,000 2,000 under 3,000 3,000 u n der 4,000 4,000 under 5,000 5,000 an d ov e r Total, returns w i t h net income W i t h no ne t income, Fbrm 1 0 4 0 i _§/ Total, taxable returns (44+45) Vontaxable individual returns! W i t h net Incomei 6 / Fbrm 10404 (est.)- 9/ Fbrm 1 0 4 0 i U n d e r .75 (est«) •75 under 1 (est.) 1 under 1. 5 (est.) 1. 5 u n der 2 (est.) 2 u n der 2.6 (est.) 2.5 u n der 5 (est.) 3 u nder 4 . 4 under 5 Total, returns wi t h net income With no net income, Fbrm 1040 2/ Total, nontaxable returns (56+57) Number of returns Net incese 8/ Tbtal (col. 17 + 18) (14) (16) (15) 12 6 11 16 11 IS 128 138 168 232 800 466 625 898 1,535 2,101 3,045 3,532 15,161 10,116 6,791 8,302 4,893 2,924 1,995 1,552 952 734 1,809 687 512 17 2 189 104 101 47 28 4 7 6 — 2 69,687 297 69,984 Thx Alternative t ax (17) (18) 84 36 50 64 51 374 284 371 450 558 775 1,101 1,463 2,119 3,201 5,314 8,120 10,269 60,233 62,562 58,546 102,272 87,953 69,883 59,870 47,839 59,969 35,517 118,120 67,097 59,147. 27,580 38,522 26,919 37,261 24,434 20,959 3,737 9,078 14,205 .. se 10.519 2,652,SSL 14/7.575 6.119 1,092,753 2,526 6.119 1,092,261 2.326 492 1 5 / 2 r6 2 5 r008 1,095,060 1,094,587 492 .. • ,S - (20) (19)* 84 36 SO 64 61 574 284 371 430 558 775 1,101 1,465 2,119 3,201 5,314 8,120 10,269 60,284 62,564 SB, 556 102,295 87,973 69,899 59,885 47,872 59,981 55,524 118,158 67,128 39,200 27,580 38,361 26,968 57,261 24,466 21,000 3,737 9,078 14,292 3 5 IS 28 25 41 460 625 932 1,525 2,256 4,144 5,955 9,471 15,402 26,354 41,225 51,189 262,679 226,053 185,795 286,655 218,163 159,887 128,955 99,402 78,977 69,507 218,191 117,783 69,819 47,149 65,138 46,989 60,505 40,726 34,719 6,802 16,193 22,545 Effective t a x rate, percent (returns wi t h net (col. 7 i 3) Average total ta f (col. 7 - 2 ) Defense ta x 4/ • as es .S a. as • ms • • es se • - 1 2 11 25 20 . 16 16 53 12 7 19 30 52 • 39 49 a. 32 42 • 90 • a. s. 53 8.11 51 12 42 41 60 94 159 284 417 576 754 952 1,170 1,411 1,672 1,956 2,259 2,583 3,573 5,713 8,141 11,801 17,500 23,433 29,646 35,770 42,542 48,641 65,358 99,014 128,966 162,873 209,617 265,505 574,794 532,080 768,155 976,528 1,434,592 2,382,079 8.16 1.36 3.43 2.30 2.66 5.44 4.68 6.41 7.64 8.91 10.09 11.25 12.54 15.47 14.56 15.67 16.75 17.84 20.79 25.66 29.85 54.34 59.31 42.94 45.88 47.95 50.24 51.43 54.48 57,72 57,76 59,58 60.57 58.99 62.56 61.78 62.73 58.64 62.19 63.59 * _ 3.059.269 222 7.833 2221 58.17 8.51 8.51 _ — • •»es «e s. • «» me s. as as ■ es se _ — es • — ' - as s. es se - • - - .. .. a. as a. • as - •a (17) - as - 59 G rand total (46+58 o r 6 0 + 61) 69,984 15/2,625,006 1,095,080 1,094.587 492 60 individual returns a n d taxable fiduciary returns w i t h net income (44+56) individual returns w i t h n o n e t income (45+57) 69,687 2,632,581 1,092,755 1,092,261 492 151 6.65 297 14/7,573 2,526 2,526 - (17) - 61 Fo r footnotes, see pp. 14 an d 15, Table 2-A. - Individual returns wi t h ne t income, .1941, fey taxable and non taxable returns, b y n et income classes, and taxable returns b y type of tax liability; also aggregates for +«+° m . and individual returns w i t h n o net incomes Number of returns, net income, personal exemption, credit for dependents, earned income credit, total tax, normal tax, surtax, alternative tax, defense tax, average total tax, and effective tax rate (Net income classes and m o ney figures, except average total tax, in thousands of d o n »»»•«) Returns w i t h normal tax and surtax 12/ Ne t income classes fl) 1 2 S 4 5 6 7 8 9 10 11 12 IS 14 IS 16 17 18 19 20 21 22 25 24 25 26 27 28 29 50 51 52 55 54 35 56 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 55 54 55 56 57 58 59 60 61 Taxable individual returnss V i t h n e t incomes F o r m 104OA (est.) 9/ Fo r m 1040s Under .75 (est.) .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 u n der 5 (est.) 3 Tinder 4 (est.) 4 under 5 (est.) 5 under 6 6 under 7 7 under 8 8 under 9 9 under 10 10 under 11 1 1 under 12 12 under 15 13 under 14 14 under 15 15 under 20 20 under 25 25 under 30 30 under 40 40 under 50 50 under 60 60 under 70 70 under 80 80 under 90 90 under 100 100 under 150 150 under 200 200 under 250 250 under 500 300 under 400 400 under 500 500 under 750 750 under 1,000 1,000 under 1,500 1,500 under 2,000 2,000 under 3,000 3,000 under 4,000 4,000 under 5,000 5,000 and o v e r Total, returns w i t h n e t income Wi t h no net income, F o r m 1040 §/ Total, taxable returns (44+45) Nontaxable individual returns* With net incomes 6/~ Fo r m 1040A (est.) $J Form 1040: Under .75 (est.) .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 under 5 (est.) 3 under 4 4 under 5 Total, returns w i t h net income W i t h no net income, F a r m 1040 2 / Total, nontaxable returns (56+57) Grand total (46+58 or 60+61) Individual returns w i t h ne t income (44+56) Individual returns w i t h n o net Income (45+57) For footnotes, see pp, 1 4 an d 15. Number of returns Net Income 1/ (2) (5) Personal exemption 10/ (4) Credit for dependents (S) Earned income credit 2 3 / (6) 6,199,542 10,560,017 6,155,612 582,554 55,917 757,627 1,281,524 2,121,571 2,517,362 1,694,757 1,645,774 514,275 249,078 150,524 102,440 72,278 55,985 42,757 34,072 27,374 22,776 19,134 61,158 51,609 18,384 19,785 9,988 5,755 5,541 2,307 1,606 1,178 2,664 922 408 209 229 119 104 48 50 4 9 5 15,748 669,157 1,575,321 5,741,225 5,195,153 4,642,449 5,583,497 2,276,749 1,358,489 971,826 765,131 612,875 530,776 447,880 591,504 541,667 307,168 277,123 1,051,128 703,657 501,728 680,032 444,702 312,833 228,785 172,134 135,969 111,402 319,925 157,982 90,997 57,095 79,173 53,552 61,792 41,269 57,406 6,763 20,894 18,846 2,131 557,720 948,977 2,655,755 3,210,983 2,378,882 2,253,981 680,532 328,045 195,609 132,911 93,400 72,173 54,792 45,788 34,862 29,024 24,568 78,205 40,086 23,240 24,861 12,511 7,213 4,473 2,887 2,023 1,456 3,522 1,147 500 263 286 148 127 59 38 5 11 7 112 509 24,534 99,461 410,122 491,775 567,668 186,886 98,576 60,067 40,139 29,281 22,271 17,047 13,527 11,101 9,067 7,785 24,539 12,585 7,319 7,846 3,939 2,194 1,497 883 600 467 1,013 336 173 64 87 45 36 16 9 2 4 4 i 20,032,611 289 20,032,901 2,555,956 55 2,535,992 1 3,992,334 192 5.992,525 6,971,090 5,866,187 3,015,Q28 858,155 475,829 284,504 250,850 1,509,494 1,722,470 1,024,992 1,809,512 555,588 1,225,291 149,629 400,356 55,119 107,404 1.059 4,540 8*267,602 12,965,141 99.531 14/284.449 8,567,035 13/12, 680, 692 798,008 377,929 1,913,678 1,551,475 829,455 224,616 49,678 1.605 11,592,629 55,681 68,789 242,609 605,594 556,762 213,551 67,907 3.538 4,806,858 he) tw ________ ( M l (161 1,056,002 1,575 66,914 157,532 374,125 519,515 464,245 541,946. 205,214 114,022 77,106 58,246 44,924 37,936 31,000 26,555 22,620 20,022 17,525 57,220 30,507 18,065 19,976 10,511 6,271 3,937 2,618 1,802 1,289 2 ,941 980 449 208 231 116 102 41 27 5 9 6 4,055,166 _ Number of returns Net income (8) (9) (7) Tax 528,479 l ■ 1,427 «, 851 53,656 85,398 157,714 159,482 260,722 145,290 105,327 86,165 76,840 68,500 65,212 60;119 56,751 53,384 51,284 49,295 218,006 180,224 149,462 255,375 174,834 134,509 105,158 82,713 68,520 57,475 174,926 91,918 52,868 34,242 48,275 51,782 58,720 27,000 25,908 4,413 13,694 11,401 55,906 757,621 1,281,514 2,121,555 2,317,354 1,694,723 1,643,648 514,139 248,914 150,100 102,155 71,819 55,384 41,879 32,764 25,334 19,804 15,674 46,280 21,684 11,780 11,745 5,240 2,888 1,619 1,026 697 472 924 272 114 43 52 id 9 7 4 1 5 1 Total (col. 11+12+13) (10) 15,745' 669,132 1,575,510 3,741,198 5,195,135 4,642,411 5,583,044 2,276,142 1,557,579 970,354 762,990 608,790 525,047 438,619 376,215 316,098 266,926 226,979 793,550 481,916 521,064 402,375 232,983 157,251 104,535 76,509 58,964 44,753 109,869 46,766 25,511 11,621 18,256 8,329 5,220 5,797 4,764 1,522 6,876 1,343 8,795 55,627 85,334 137,664 159,109 260,459 144,929 102,911 85,618 76,112 67,443 65,827 58,047 55^650 48,225 45,374 39,264 159,038 118,944 92,515 134,257 89,339 66,297 47,241 56,475 29 j 355 23,111 6oj 545 27,842 15,667 7,414 12,071 5^665 3,659 4',188 5^531 l'l45 5,268 Normal tax (11) Surtax Defense tax 4/ (1ST (12) 495 2,102 17,674 26 j 291 45 j 146 52j463 88,674 48,016 32,506 25,405 21,185 17,604 15,663 13,429 11,735 10,011 8,S64 7,380 26,672 16,86711,527 14,746 8,697 5,941 3,982 2'950 2,272 1^733 4^281 918 ^995 460 725 351 . 208 250 190 61 275 848 6,693 35^952 59^043 94^ 518 106^646 17lj 763 96,910 70j397 60j206 54,919 49,833 48,157 44j611 41j887 58^206 54j800 5lj 873 132,322 102j 036 80 j 961 119,447 80 j 587 6 0 j316 43j230 35*529 27^ 034 21^356 56^ 215 25^924 14^650 6^ 954 11* 348 5*334 5^451 3^958 3*341 1* 084 4 ^993 (13) (is) (15) (15) (13) (15) 2 5 7 8 8 7 7 8 8 8 10 10 44 41 27 64 55 40 30 16 27 22 48 1 2 5 4 5 6 7 8 9 10 11 12 15 14 15 16 17 18 19 20 21 22 11,235,166 52,465,702 2,433,234 547,579 1,885,334 520 11,235.166 52,465,702 2,433,234 5 4 7.379 1.885.334 520 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 697,109 47 3,241 1,748 12,911 14,744 9,935 5,302 562 27 745,578 (16) (16) - - 48 49 50 51 52 55 54 55 56 57 58 — 2 10.519 17,502,587 45,562,076 297 14/7.575 17.502.884 15/45.554,502 Total ta? 2/ 6.119 5,815,415 2.326 5,817,741 22 _ - - - - - 25,869,917 LS/56,255,195 (16) (16) (16) 5,817,741 11,255,166 32,465,702 2,433,234 547,579 1,885,334 520 59 25,770,089 99,828 58,527,217 14/292,023 31,625,240 (16) 7,342,794 (16) 4,735,912 (16) 3,815,415 2,326 11,235,166 32,465,702 2,455,234 547,579 1, 885, 354 520 60 61 2-A. - Individual returns w i t h net income, 1941, b y taxable and nontaxable returns, by ne t Incase classes, and taxable returns b y type of tax liability; also aggregates for taxable and nontaxable individual returns w i t h no net income: Number of returns, ne t income, personal exemption, credit for dependents, earned income credit, total tax, normal tax, surtax alternative tax, defense tax, average total tax, and effective tax rate - Continued (Net income classes and m o n e y figures, except average total tax, in thousands of dollars) Returns wi t h alternative tax 3/ Net income classes (1) 1 z 3 4 5 6 7 3 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 26 27 28 29 50 31 32 53 34 55 36 57 58 39 40 41 42 45 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Taxable individual returns: With net income: Form 104OA (est.) 9/ Form 1040: Under .75 (est.) .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 under 3 (est.) 3 under 4 (est.) 4 under 5 (est.) 5 under 6 6 under 7 7 under 8 8 under 9 9 under 10 10 under 11 11 under 12 12 under 13 IS under 14 14 under 15 15 under 20 20 under 25 25 under 30 30 under 40 40 under 50 50 under 60 60 under 70 70 under 80 80 under 90 90 under 100 100 under 150 150 under 200 200 under 250 250 under .500 300 under 400 4 00 under 500 500 under 750 750 under 1,000 1,000 under 1,500 1,500 under 2,000 2,000 under 5,000 5,000 under 4,000 4,000 under 5,000 5,000 and over Total, returns wi t h ne t Income W i t h no ne t income, F o r m 1040 5/ Total, taxable returns (44+45) Nontaxable individual returns: W i t h net income: 6/ F o r m 104Q| (est.) £ / F o r m 1040: Under .75 (est.) .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 under 5 (est.) 5 under 4 4 under 5 Total, returns with net income W i t h no net Income, Form 1040 7/ Total, nontaxable returns (56+57) Grand total (46+58 or 60+61) Individual returns w i t h net income (44+56) Indj^ddual returns wi t h no net income (45+57) ' For footnotes, see pp. 14 and 15. Ne t income (14) (15) Total (col. 17 ♦ 18) Alternative tax Defense tax 4/ (16) (17) (18) (19) - u 2 67,879 297 68,176 3 5 11 28 18 38 455 606 910 1,472 2,142 4,083 5,729 9,261 15,090 25,566 40,242 50,144 257,798 221,720 180,664 277,656 211,719 155,585 124,253 95,625 / 77,004 66,648 210,056 111,217 65,686 45,475 60,937 45,204 56,572 35,471 32,642 5,241 14,018 18,846 — 10.519 2,536,357 14/7,578 15/27528,785 - - • ' - me — .— _ 6 ID 16 . 8 14 126 134 164 224 285 459 601 878 1,508 2,040 2,972 5,460 14,878 9,925 6,604 8,040 4,748 2,845 1,922 , 1,281 909 706 1,740 650 294 166 177 100 95 41 26 5 6 5 — 85 36 30 64 49 573 283 362 416 545 729 1,057 1,385 2,071 3,122 5,159 7,910 10,029 58,968 61,280 56,947 99,119 85,496 68,212 57,916 46,238 39,187 34,364 114,582 64,076 37,201 26,828 56,205 26,118 35,061 22,812 20,377 5,269 8,426 11,401 — 6.119 1,055,705 2.326 1,056,029 83 36 30 64 49 373 283 362 416 545 729 1,057 1,585 2,071 3,122 5,159 7,910 10,029 58,967 61,279 56,940 99,100 85,478 68,199 57,904 46,213 39,175 34,361 114,368 ' 64,059 37,16026,828 36,165 26,069 35,061 22,780 20,336 3,269 8,426 11,401 - • «• ... — • — — 1 2 7 18 18 13 12 25 12 4 14 17 41 _ 59 49 32 42 me.. - (20) S3 3.11 40 12 42 40 59 94 159 285 415 573 750 948 1,165 1,406 1,666 1,950 2,252 2,576 5,565 5,702 8,130 11,796 17,504 25,462 29,697 35,853 42,665 48,791 65,663 99,694 129,577 163,839 210,806 267,079 572,310 562,490 796,945 1,103,519 1,521,553 2,280,276 9.06 1.32 3.41 2.28 2.65 5.44 4.67 6.38 7.61 8.87 10.04 11.18 12.29 13.42 14.50 15.62 16.70 17.79 20.74 25.61 29.79 34.32 39.31 45.00 45.96 48.05 50.39 51.59 54.68 58.18 58.10 59.97 60.97 59.37 62.66 65.42 65.92 65.26 65.54 60.50 58.17 8.37 - 6.119 1,053,559 2.326 1.055.685 544 . 544 3.059.269 218 7.835 218 - - - me «• _ m — • — Effective tax rate, percent (returns with net income) (col. 7 i ! ) Average total tax (col. 7 * 2 ) Tax Number of returns - «. . me _ ... < - - - - - 15/2,528,785 1,056,029 1,055,685 344 (17) 2,536,557. 14/7,573 1,053,705 2,326 1,053,559 2,326 344 r - - 68,176 67,879 297 .. _ • - . - - 8.38 - r _ - _ 148 (17) — 6.52 - Table S,. - Individual returns and taxable fiduciary returns, w i t h net income, 1941, by taxable and nontaxable returns, and b y ne t income classes; also aggregates for taxable and nontaxable individual returns with no net income: Number of returns, sources of income and deductions, and net income __________________________________________(Net income classes and money figures in thousands of dollars)_______________ Sources of income Dividends Salaries Dividends Interest Capital gain 23/ Net gain and other from dom Bank on share ac AnnulGovernment from Shoi t-term 23/ Net compensa estic and deposits, counts in ties obligations Current long Net short Net short sales of Federal sav Rents and (indivi term capi term capi Partially Taxable Number of tion (in foreign notes, property Business year net term corpora mortgages, tax-exempt (subject ings and loan royalties dual dividual returns profit tal gain Short-term capital other tal loss of Net income 8/ classes. to nor tions 18/ corpora returns) associations (subject returns) (included 27/ gain capital preceding than (subject to tion bonds to surtax mal tax capital 22/ in total taxable year gain 25/ 23/ only) 19/ and sur surtax only) income) assets deducted 24 / tax) 20/ 21/ 2§/ 1 2 5 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 53 34 35 56 37 38 59 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Taxable individual and fiduciary returns 0/: W i t h net income: Form 10401 (est.) 9/ Forms 1040 and 1041: Under .75 (est.) .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 under 3 (est.) 3 under 4 (est.) 4 under 5 (est.) 5 under 6 6 under 7 7 under 8 8 under 9 9 under 10 10 under 11 11 under 12 12 under 13 13 under 14 14 under 15 15 under 20 20 under 25 25 under 30 30 under 40 40 under 50 50 under 60 60 under 70 70 under 80 80 under 90 90 under 100 100 under 150 150 under 200 200 under 250 250 under 300 300 under 400 4 00 under 500 500 under 750 750 under 1,000 1,000 under 1,500 1,500 under 2,000 2,000 under 3,000 3,000 under 4,000 4,000 under 5,000 5,000 and over Total, returns w i t h net income W i t h no net income, Form 1040 5/ Total, taxable returns X44+45) Nontaxable individual returns: W i t h net income 6/: F o r m 10404 (est.) 9/ Form 1040: Under .75 (est.) .75 under 1 (est.) 1 under 1.5 (est.) 1.5 under 2 (est.) 2 under 2.5 (est.) 2.5 under 3 (est.) 3 under 4 4 under 5 l Total, returns w i t h net income W i t h no net income, F o r m 1040 1] Total, nontaxable returns (56+57) 6,199,542 10,297,452 (35) (35) (35) (35) (55) (55) (35) - - - - 67,572 766,139 1,292,021 2,127,895 2,321,717 1,697,745 1,648,213 517,277 251,232 151,975 103,676 73,188 56,830 43,398 34,633 27,857 23,156 19,463 62,285 32,289 18,840 20,367 10,314 5,908 5,660 2,403 1,656 1,223 2,784 969 434 217 244 123 114 55 34 5 10 6 • 6,006 558,692 1,408,797 3,322,186 4,810,081 4,256,260 4,622,241 1,562,457 847,343 560,111 421,998 326,082 279,236 229,449 195,970 168,069 150,465 134,335 495,o n 318,706 216,801 275,460 169,269 115,901 78,230 57,252 39,846 54,109 82,369 33,590 18,406 7,721 9,856 5,633 3,425 1,616 865 122 606 163 70,121 47,661 95,927 136,563 139,742 137,347 260,672 190,685 124,587 105,325 94,451 80,532 74,887 67,122 60,743 56,573 51,847 47,409 198,477 154,855 121,401 184,496 136,994 99,142 78,931 61,441 50,778 43,188 139,162 73,760 41,351 28,931 42,070 23,658 39,166 25,828 20,141 3,199 11,245 20,719 - 33,867 32,303 57,845 86,132 79,951 64,872 110,843 67,934 38,303 30,292 24,681 20,147 17,442 15,358 13,592 11,894 10,455 9,036 36,747 23,454 16,465 21,460 13,058 8,564 5,897 4,569 2,882 2,440 7,595 3,553 1,840 1,372 1,198 659 1,446 396 481 50 81 65 - 4,275 2,560 5,022 6,784 6,148 5,464 10,067 6,894 3,813 3,099 2,779 2,331 2,087 1,972 2,000 1,639 1,477 1,275 5,252 3,961 2,425 4,266 2,779 1,507 913 865 605 556 1,609 741 522 192 327 54 62 65 52 (15) - 358 742 1,114 2,143 2,240 1,795 2,076 1,179 548 437 311 223 227 246 159 167 116 164 428 300 201 271 168 85 55 32 26 15 92 36 52 10 19 8 11 4 8 - 55 12 28 6 22 3 206 119 815 470 373 270 276 164 163 136 138 90 420 322 353 239 214 117 113 40 26 32 16 10 (13) (15) 10 (13) 226 8,511 15,650 19,748 15,367 13,092 16,757 9,475 4,122 3,055 2,471 2,121 1,583 1,282 1,045 980 1,041 680 2,844 1,943 1,186 1,528 1,344 520 895 407 300 262 5?5 249 92 171 241 21 19 45 62 — 1,617 1,277 2,791 4,462 4,514 4,682 11,890 8,492 6,802 6,046 5,217 4,089 3,936 3,425 2,913 2,810 2,395 2,301 8,686 6,220 3,820 6,673 4,381 2,885 2,080 2,581 1,307 635 2,705 1,829 919 469 629 644 82.6 13 1,040 4,058 2,288 .4,772 6,134 7,286 7,930 15,685 U,678 8,954 7,688 6,324 6,341 5,426 4,371 4,896 4,034 3,762 5,724 14,130 n,480 8,682 14,704 U,749 9,S77 7,695 7,451 5,010 6,283 20 ,s n 15,025 13,750 8,210 13,741 13,807 14,702 12,290 n.isi 3,125 •7,141 8,574 8.434 8 36,122,193 3,449,560 19.524 3.108 36.125.301 3.469.084 32 879,253 1.686 880.939 1 96,41? 253 96.670 1 16,069 31 16.099 33 3 13 8 6 9 88 77 257 142 189 134 136 247 135 105 no 146 373 354 232 229 146 106 77 100 16 55 222 91 53 27 20 18 7 10 1 1 • 1,650 1,280 2,804 4,470 4,520 4,691 U,979 8,569 7,060 6,189 5,406 4,225 4,072 5,672 3,048 2,915 2,505 2,447 9,059 6,574 4,052 6,902 4,527 2,991 2,157 2,682 1,324 690 2,925 1,920 972 496 649 663 353 24 1,041 1 _ 3 - 5705T 5f057 11,453 51,832 77,851 163,566 162,155 131,576 181,493 95,858 56,610 41,991 33,584 27,422 22,381 18,590 16,519 13,800 12,612 11,050 39,920 25,922 17,759 22,841 14,463 8,738 5,868 4,850 3,075 2,731 7,795 3,968 1,982 1,039 1,696 939 455 1,807 69 14 5 5 1,296,065 527 1,296,592 (55) 2 17,587,471 297 17.587.768 • - 4,053,166 6,868,982 (35) (35) (35) (35) 858,153 284,504 1,309,494 1,024,992 553,386 149,629 35,119 1.059 8,26?,502 99.531 8.367.035 231,524 113,076 996,689 1,366,496 988,702 312,427 80,078 2.256 10,9^0,210 54.275 11.014.483 61,742 12,692 50,817 17,096 7,815 2,361 619 51 153,193 66.838 220.031 42,820 8,709 40,755 10,059 4,931 1,037 237 14 108,559 18.305 126.864 4,398 958 5,883 1,191 557 191 40 4 11,222 1.823 15.045 - - - - - - - 47.139.784 3.689.115 1.007.803 109.715 47,082,405 3,602,753 987,812 19.991 Grand total (46+58 o r 60+61) 25.954.801 Individual returns and taxable fiduciary 25,854,973 returns w i t h net income (44+56) Individual returns wi t h no net income (45+57) 99.828 Fo r footnotes, see pp. 14 and IS. - (13) 57.382 86.362 64 • — 129,949 , 121 130,071 am mm 499 • 40 128,041 379 i28.4il _ 3,97? am. 8.977 a. (35) 11,415 2,810 13,023 3,066 941 540 100 4 31,901 2.035 55.936 2,092 663 2,635 1,445 749 369 84 • 5 8,042 4.122 12.163 16.09° 5.057 1.770.496 164.006 140.584 107,639 16,069 5,057 1,738,897 161,850 136,085 8.877 5,977 2.076 31 2.157 4.501 - • - - am, - - - - 51.598 • • • a. • am -J -1 4 17 •a 14 _ 2,092 663 2,635 1,445 749 369 84 3 8,042 4.122 12.163 4.533 - 1 552 10,785 22,074 53,s n 63,966 71,958 170,691 128,094 126,445 106,967 93,250 79,994 72,275 64,547 57,273 53,074 49,274 44,766 172,827 124,816 93,064 126,169 83,229 61,892 43,097 33,265 29,453 21,071 55,867 23,489 15,380 6,864 8,854 4,996 4,461 2,047 1,450 3 1 163 • - 2 3 4 5 • • 58,966 4,605,315 2,182,25$ 351 1.029 21 5 § V § 5 T 4,605,646 2,183,284 am 5,545 925 3,429 1,423 817 203 88 1 10,231 4.333 14.565 144.561 375.727 140,060 369,394 4.501 1,408 56,991 99,498 37.8,030 445,516 407,349 717,549 444,053 305,764 226,778 177,669 140,220 117,4 n 96,376 85,305 70,722 61,864 54,748 196,978 U3,830 74,938 97,150 57,189 34,614 27,108 18,749 13,803 9,421 32,365 14,887 6,308 6,419 5,593 2,918 1,871 2,169 1,751 3 • a. mm 40 5.245 132,018 359,163 am 579 13$,398 359,163 «• (55) 159,534 34,335 162,558 61,021 32,485 10,501 2,487 112 442,833 31.071 473.904 • «• 499 - 341 853 1,800 4,717 4,583 4,699 8,898 5,901. 3,867 3,023 2,255 2,123 1,630 1,467 1,202 977 1,097 872 2,957 1,339 833 941 587 440 274 346 252 87 272 155 85 19 32 6 • Part nership profit 28/ 6 7 8 9 10 11 12 13 14 IS 16 17 18 19 20 21 22 23 24 25 26 27 28. 29 30 31 32 33 34 35 36 37 38 39 40 41 42 45 44 45 46 - 47 12,486 5,032 29,085 35,187 19,273 6,591 2,244 108 no,oo? 11.549 121.555 70.755 S.474.818 2.304.859 68,539 6,455,95? 2,292,262 48 49 50 ma 1,730 179,740 610 129,592 3,476 668,294 1,775 485,170 1,386 266,068 267 95,048 122 26,517 7 2.2U 9,373 1,850,642 2,596 18.530 n . 7 6 8 1.869.172 2.417 18.861 12.577 51 S3 52 54 55 56 57 58 59 60 61 1 2 5 4 S 6 7 e 9 10 11 12 15 14 15 16 17 18 19 20 21 22 25 24 25 26 27 28 29 50 51 52 55 54 55 56 57 58 59 40 41 42 45 44 45 46 47 48 49 50 51 52 55 54 55 56 57 58 59 60 6J. Table 5* — Individual returns and taxable fiduciary returns, with net income, 1941, by taxable and nontaxable returns, and by net income classes; also aggregates for taxable and nontaxable individual returns with no net income: Humber of returns, sources of income and deductions, and net income - Continued ________________ _______ '_________ (Net Income classes and money figures in thousands of dollars) __________________________ Amount Source; a£ incoina - f!ont«d Income Net long Net loss Oontribudistrib Losses Bad from Other term Total from sales ions 51/ from fire, debts utable Total Other income fiduci income capital of prop Business Partner (individ Interest Taxes paid storm, 32/ deduc to bene Net income 8/ classes deduc 30/ aries loss erty other loss 27/ ship loss ual re etc. 32/ paid 32/ Tinditions tions ficiaries 2g/ 25/ th