On July 14th, the IRS held a public hearing for the debt-equity rule (section 385 of the IRS code) that the Treasury Department proposed last April. The hearing, which had as many as 16 speakers from various industries,...
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Effective Corporate Income Tax Rates and the Corporate Tax Yield
On the heels of numerous House Republican proposals to reduce corporate tax rates, there has been a trend among the fiscal policy punditry to claim that US corporate tax burdens are already minimal and that the economic burden of high marginal tax rates is exaggerated. Such was the nature of Tuesday's post by Bruce Bartlett in the Economix blog, which reported that US corporate tax revenue as a share of GDP was a meager 1.8% for 2008 (this according to the OECD; CBO reports 2.1% for the same year). But because this statistic was relayed amidst a discussion of "effective tax rates," it is important to clarify that 1.8% does not represent or approximate the average effective tax rate for US corporations.
The argument that low corporate tax revenue as a share of GDP directly indicates a low effective tax rate ignores that corporate earnings make up a minor share of GDP. Quite obviously, corporate profits-the base of corporate taxation-do not total the entirety of US GDP, and therefore 1.8% is not a figure that should be tossed around in the discussion of effective tax rates.
According to BEA data for years 2001-2008, corporate earnings as a share of GDP ranged from 7% to 13.7%, with a simple average of 10.1%. Using these figures alongside the OECD revenue data cited in the article, the chart below reveals that corporations paid an average effective tax rate of 24.1% for these years. (Because this rate is calculated with both OECD and BEA data, it should only serve as an approximation.) Employing BEA data for corporate tax revenue (as opposed to the OECD data) to keep sources consistent, the average effective rate for the same period was 25.7%.
US Corporate Income Tax Revenue as Shares of Corporate Activity and Gross
| ||2001||2002||2003||2004||2005||2006||2007||2008||Average (3)|
|Pre-Tax Corporate Earnings, $billions (1)||712.72||765.35||903.47||1,229.40||1,640.16||1,822.72||1,738.36||1,333.21|| |
|GDP, $billions (2)||10,234||10,590||11,089||11,812||12,580||13,336||14,011||14,369|| |
|Corporate Earnings as Percentage (%) of GDP||7.0||7.2||8.1||10.4||13.0||13.7||12.4||9.3||10.14|
|Corporate Tax Revenue as Percentage (%) of GDP (2)||1.9||1.7||2.1||2.5||3.1||3.4||3.0||1.8||2.44|
|Corporate Tax Revenue as Percentage (%) of Corporate Income (2)||27.3||23.5||25.8||24.0||23.8||24.9||24.2||19.4||24.10|
|BEA reported Corporate Tax Revenues, $billions (1)||203.3||192.3||243.8||306.1||412.4||473.3||445.5||308.4|| |
|Corporate Tax Revenue as Percentage (%) of Corporate Income (1)||28.5||25.1||27.0||24.9||25.1||26.0||25.6||23.1||25.67|
(1)Bureau of Economic Analysis
(2)Organization for Economic Cooperation and Development
(3)Average represents simple average rate across the eight years
These calculated averages generally reflect the findings of numerous recent analyses: In April, PricewaterhouseCoopers released its "Global Effective Tax Rates" report, which scored the US an average effective corporate tax rate of 27.7% for 2006-2009, sixth-highest in the world. Of the five countries with higher rates, three lowered their rates within or after the study, and one other, Japan, intends to in the near future.
PricewaterhouseCoopers Average Effective Corporate Tax Rates, 2006-2009
|Rank||Country||AETR|| ||Rank||Country||AETR|| ||Rank||Country||AETR|
|20||Philippines||24.0%||40||Peru||18.8%|| || || |
Source: PricewaterhouseCoopers, "Global Effective Tax Rates" Report, 2011
Similarly, in February the American Enterprise Institute reported the US average effective rate to be 29.0%, second only to Japan. And in 2008 GAO calculated the average effective tax rate for domestic corporate investment to be 25.2%, with the median at 31.8%. While there remain the highly publicized cases such as GE, the idea that US corporations pay little or no taxes is simply not the full story.
It may be a surprise to some that corporate earnings account for only roughly 10% of GDP. This is partially due to the dramatic decrease in the existence and activity of traditional C Corporations over the past decades. From 1981-2007, the C Corp share of business activity decreased from 87% to 64%, with a 10% decline since 1999 alone. The C Corp share of taxable income has fallen even more dramatically, from 70.6% in 1987 to 48.5% in 2004. More and more, businesses are electing to organize as "pass-through entities" (Subchapter S Corporations and Limited Liability Companies) where business income is reported on the individual level and not subject to the double-taxation of the current corporate tax system. The Tax Foundation reported in 2008 that with all such business forms included in the analysis, the historical average of total business tax revenues as a percentage of GDP increases from 2.2% to 3.3%.
With respect, Mr. Bartlett has done well to highlight the rather meager yield of the corporate income tax and some of the implications of maintaining a tax code riddled with special exemptions and preferences. The Tax Foundation recognizes that effective tax rates vary from statutory rates due to these preferences, and the complexity of the corporate tax code provides a strong argument for broadening the base through eliminating certain tax preferences and lowering the rate. But in sum, it is misleading to directly equate our low reliance on the corporate tax to the idea that all corporations pay low effective tax rates.
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