New York Fed Blog Post Understates Effective Corporate Tax Rates

Recently, an economist at the Federal Reserve Bank of New York released a blog post titled “TaxA tax is a mandatory payment or charge collected by local, state, and national governments from individuals or businesses to cover the costs of general government services, goods, and activities. Reform and U.S. Effective Profit Taxes: From Low to Lower.” This piece argues that prior to the Tax Cuts and Jobs Act (TCJA), the effective tax rate on corporations was low and that TCJA reduced it even more. As such, U.S. companies were already “competitive” relative to foreign firms. The piece calculates corporate effective tax rates in two ways: a marginal effective tax rate on investment and an average effective tax rate equal to taxes divided by profits. However, the piece makes errors that understate both effective tax rate measures. The piece also comes to conclusions that differ from other papers that compare U.S. effective tax rates to trading partners.

1. The Marginal Effective Tax Rate (METR)

The METR measures what the tax burden would be on an investment that just broke even in present value. It includes the effect of not just the statutory tax rate, but also the value of any investment credits and depreciationDepreciation is a measurement of the “useful life” of a business asset, such as machinery or a factory, to determine the multiyear period over which the cost of that asset can be deducted from taxable income. Instead of allowing businesses to deduct the cost of investments immediately (i.e., full expensing), depreciation requires deductions to be taken over time, reducing their value and discouraging investment. deductions. It is a useful measure because it tells us what the incentive is for companies to make new investments that would expand the capital stock and lead to a larger economy.

The piece estimates a METR for each country based on a weighted average of the METR for two assets: machinery and equipment, and business structures. The piece does this because different assets typically face different tax treatment. To get an overall METR for each country, it weighs each asset for each country by the amount of investment in machines and buildings. The result is that the U.S. METR in 2017 was 10.8 percent, below the average among survey countries. The TCJA resulted in the METR dropping to 3.6 percent in 2018, the second lowest among surveyed countries.

This methodology, however, understates the true METR for corporate capital in the U.S. (and other surveyed countries) and makes the U.S. seem more competitive before TCJA than it really was. The reason is that the author is weighing the METRs by investment. However, it is standard practice to weight by capital stock. The reason is because investment isn’t necessarily driven by the amount of a given asset in an economy. Investment is high in the case of machinery because companies need to replace machines frequently. In contrast, buildings have a low level of investment because they last a long time. In fact, the capital stock is comprised of twice as many buildings than machines (by value), according to Bureau of Economic Analysis (BEA) data, even though they account for a low share of investment.

If you were to use standard weighting (by capital stock), the pre-TCJA U.S. METR moves from below average and in the bottom half of surveyed countries to above average and among the top half of surveyed countries (Table 1). In fact, using a standard weighting tells a slightly different story than what the original piece told: before reform, the U.S. METR was slightly above average and after reform, the METR dropped to being in a more competitive position relative to survey countries.

Table 1: Marginal Effective Tax Rate (METR)

Investment Weight (original)		Capital Weight (corrected)
	METR		METR
Brazil	25.1	Japan	20.8
India	24.1	Germany	19.3
Germany	23.2	Brazil	19.3
Japan	22.2	United States 2027	17.9
Mexico	20.9	United Kingdom	17.9
Indonesia	20.5	Turkey	17.9
China	17.2	United States 2017	15.8
Spain	17.1	India	15.2
United Kingdom	16.9	Spain	14.9
Turkey	16.9	Mexico	14.8
United States 2027	16.4	Indonesia	14.1
France	14.5	Australia	12.6
Australia	14	China	12.3
United States 2017	10.8	France	11.8
Saudi Arabia	10.7	Saudi Arabia	10.8
Russia	8.7	United States 2018	9.9
Switzerland	7.9	Netherlands	8.6
Korea	4.8	Russia	7.3
Canada	4.7	Switzerland	6.8
Netherlands	3.8	Canada	6.5
United States 2018	3.6	Korea	5.5
Italy	-10.3	Italy	-7.0

2. The Average Effective Tax Rate

The average effective tax rate tries to capture the overall burden placed on companies that operate in a jurisdiction. It is a useful measure because it can tell us whether it is attractive, or not, for a company to enter and start producing in a specific jurisdiction.

To calculate each country’s effective tax rate, the piece used BEA, Congressional Budget Office (CBO), and Organisation for Economic Co-operation and Development (OECD) data on corporate profits and corporate tax revenue. Each country’s average effective tax rate is simply corporate tax revenue divided by corporate profits. The piece finds that the U.S.’s pre-reform average effective tax rate was 20.5 percent, which was in the middle of the pack and below the average (28 percent) among survey countries.

While the method for calculating the average effective tax rate is straightforward, there is an issue with the BEA data that leads this type of analysis to understate the effective corporate tax rate. The reason has to do with how the BEA and CBO data are organized. The measure of profits for “corporations” includes both the profits for C corporations and the profits for S corporations. In contrast, the measure of “corporate” tax revenue from BEA and CBO only includes the taxes paid by traditional C corporations—leaving out income taxes paid by S corporations.

The combination of C corporation and S corporationAn S corporation is a business entity which elects to pass business income and losses through to its shareholders. The shareholders are then responsible for paying individual income taxes on this income. Unlike subchapter C corporations, an S corporation (S corp) is not subject to the corporate income tax (CIT). profits in BEA and CBO data is very important in the United States. Pass-through businesses, including S corporations, make up a very large share of business profits in the United States. Previous research shows that aggregate pass-through profits exceed corporate profits.

If BEA data is used, S corporate profits should be removed. One very rough way to do this is to use IRS integrated business data. According to this data 21 percent of corporate net income was S corporate net income in 2013. If we use this share to reestimate the average effective tax rate before and after TCJA, we find that the effective rate is higher than the piece estimated.

I estimate that the pre-TCJA effective tax rate on C corporations increases from 20.5 percent to 26 percent and the 2018, post-reform effective tax rate rises from 15.3 percent to 19.4 percent. This still places the U.S. slightly below average before reform, but closer to the mean among survey countries of 28 percent. However, it also shows that after reform, tax payments as a share of profits won’t necessarily improve the U.S.’s ranking significantly among the surveyed counties.

3. Other Effective Tax Rate Studies

To emphasize how important methodological choices are, it is worth pointing out that other researchers that have measured effective tax rates typically come to different conclusions than the fed blog.

The CBO released a comparison of U.S. and foreign METRs and average effective tax rates in early 2017. This report found that for both measures, the U.S. tax rate was above average and near the top among survey countries before the TCJA (2012) (Table 2). Jack Mintz, a fellow at the University of Calgary, surveyed the METRs of more than twenty countries in 2017. His research found that even accounting for other taxes on capital such as sales taxes on inputs, the U.S. METR was much higher than average and among the top among surveyed countries.

Table 2: G20 Corporate Tax Rates, 2012

Source: CBO
Top Statutory Corporate Tax Rate		Average Effective Corporate Tax Rate		Marginal Effective Corporate Tax Rate
Country	Rate	Country	Rate	Country	Rate
United States	39.1%	Argentina	37.3%	Argentina	22.6%
Japan	37.0%	Indonesia	36.4%	Japan	21.7%
Argentina	35.0%	United States	29.0%	United Kingdom	18.7%
South Africa	34.6%	Japan	27.9%	United States	18.6%
France	34.4%	Italy	26.8%	Brazil	17.0%
Brazil	34.0%	India	25.6%	Germany	15.5%
India	32.5%	South Africa	23.5%	India	13.6%
Italy	31.4%	Brazil	22.3%	Mexico	11.9%
Germany	30.2%	Russia	21.3%	Indonesia	11.8%
Australia	30.0%	South Korea	20.4%	France	11.2%
Mexico	30.0%	Mexico	20.3%	Australia	10.4%
Canada	26.1%	France	20.0%	China	10.0%
China	25.0%	Turkey	19.5%	South Africa	9.0%
Indonesia	25.0%	China	19.1%	Canada	8.5%
South Korea	24.2%	Australia	17.0%	Saudi Arabia	8.4%
United Kingdom	24.0%	Canada	16.2%	Turkey	6.1%
Russia	20.0%	Germany	14.5%	Russia	4.4%
Saudi Arabia	20.0%	United Kingdom	10.1%	South Korea	4.1%
Turkey	20.0%			Italy	-23.5%

Using effective tax rates to analyze tax policy is important. It can tell us important things about how a tax code impacts taxpayers’ behavior and can provide a good measure of the true burden of the tax code. It is also usually the case that the effective tax rate can differ, sometimes significantly, from the statutory tax rate.

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