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The Challenges of Corporate-Only Revenue Neutral Tax Reform

18 min readBy: Scott Hodge

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Key Findings:

  • Policymakers are currently focused on corporate 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 to bring down the high statutory corporate income taxA corporate income tax (CIT) is levied by federal and state governments on business profits. Many companies are not subject to the CIT because they are taxed as pass-through businesses, with income reportable under the individual income tax. rate from 35 percent to 25 percent.
  • A pure 25 percent corporate tax cut would increase the size of the economy by at least 2 percent.
  • However, many lawmakers want to reduce the corporate income tax rate in a revenue neutral manner.
  • There are not enough corporate-only tax expenditures that could be eliminated to pay for a full corporate income tax cut to 25 percent.
  • Many corporate tax expenditures are also used by pass-through businesses. Eliminating them will increase taxes on pass-through businesses without giving them a lower tax rate.
  • According to the Tax Foundation Taxes and Growth Dynamic Model, eliminating corporate tax expenditures in order to pay for a lower corporate rate would fully negate the expected growth from the rate cut itself.


There is universal recognition in Washington that the 35 percent federal corporate tax rate is out of step with our global competitors and should be lowered in order to improve U.S. competitiveness and economic growth, with a common target of 25 percent. And while there is a need for comprehensive tax reform, many have suggested that lawmakers move forward with corporate-only reform, provided that it be accomplished in a revenue neutral manner by broadening the corporate tax baseThe tax base is the total amount of income, property, assets, consumption, transactions, or other economic activity subject to taxation by a tax authority. A narrow tax base is non-neutral and inefficient. A broad tax base reduces tax administration costs and allows more revenue to be raised at lower rates. .

While corporate-only tax reform may appear to be less complicated and more expeditious than comprehensive reform, there are reasons to believe that the goal of revenue neutrality and economic growth are at odds with each other. For example:

  1. People overestimate the number of “loopholes” in the corporate tax code. The static cost of cutting the corporate tax rate to 25 percent averages about $126 billion per year over ten years. However, the total amount of corporate tax expenditures averages about $180 billion per year, $80 billion of which is the cost of deferral—which ought to be reserved for international tax reform, not used for reforming the domestic corporate code. Thus, the numbers suggest that to cut the corporate rate to 25 percent in a statically measured, revenue neutral manner would require eliminating every other corporate tax expenditureTax expenditures are a departure from the “normal” tax code that lower the tax burden of individuals or businesses, through an exemption, deduction, credit, or preferential rate. Expenditures can result in significant revenue losses to the government and include provisions such as the earned income tax credit (EITC), child tax credit (CTC), deduction for employer health-care contributions, and tax-advantaged savings plans. —good and bad.
  2. Many corporate tax expenditures are also available to pass-through businesses such as S-corporations and partnerships. Eliminating these provisions to finance corporate-only reform would effectively raise taxes on pass-through firms without any corresponding reduction in their tax rates. Even if lawmakers were to attempt to hold pass-throughs harmless, it would require complicating the code by creating one set of rules for C-corporations and another for pass-throughs.
  3. Cutting the corporate tax rate to 25 percent would certainly boost economic growth—by at least 2 percent over the next decade or so according to the Tax Foundation’s TAG model. However, our model also shows that the negative economic effects of eliminating many of these corporate tax preferences would negate all of the growth generated by the rate cut.

Considering these issues, lawmakers would do well to rethink the self-imposed restriction of revenue neutrality, and focus on creating the maximum amount of economic growth, even if that comes at the expense of federal revenues. While there are certainly some base broadeners within the corporate code that won’t dampen the growth effects of the rate cut, there are not nearly enough of these to fund a rate cut on a static basis.

On the other hand, lawmakers could take into account the long-run effects on tax revenues from the additional growth generated by the corporate rate cut. Simply cutting the corporate tax rate would generate enough economic growth to eliminate much of the long-run revenue loss. Any short-term deficits could be covered by eliminating the least harmful tax expenditures or spending cuts.

So, lawmakers have a choice: they can eliminate most corporate tax expenditures and risk eliminating the growth effects of the rate cut; they can find offsets outside of the corporate code to maintain overall budget neutrality; or, they can relax the constraint of revenue neutrality and either accept a transitory deficit or look to spending restraint to cover the revenue gap. Given these choices, growth should always win out.

Corporate Tax Expenditures in Context

The corporate tax code is not riddled with as many “loopholes” as conventional wisdom would have it. According to the latest federal budget, there are roughly 80 corporate tax expenditures that have a total budgetary value in 2015 of $118 billion. By contrast, there are roughly 100 tax expenditures in the individual income taxAn individual income tax (or personal income tax) is levied on the wages, salaries, investments, or other forms of income an individual or household earns. The U.S. imposes a progressive income tax where rates increase with income. The Federal Income Tax was established in 1913 with the ratification of the 16th Amendment. Though barely 100 years old, individual income taxes are the largest source of tax revenue in the U.S. code with a total budgetary value of $1.1 trillion.

Furthermore, the majority of these corporate provisions perform important functions, such as ameliorating double taxationDouble taxation is when taxes are paid twice on the same dollar of income, regardless of whether that’s corporate or individual income. , correcting what would otherwise be an overstatement of income, or moving the code toward a less distorting tax base. Examples include: the deferral of income from controlled foreign corporations; accelerated 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. (known as MACRS, the Modified Accelerated Cost RecoveryCost recovery is the ability of businesses to recover (deduct) the costs of their investments. It plays an important role in defining a business’ tax base and can impact investment decisions. When businesses cannot fully deduct capital expenditures, they spend less on capital, which reduces worker’s productivity and wages. System); expensing of research and experimentation (R&E) expenditures; and excess of percentage over cost depletion.

Provisions such as these promote economic growth by reducing the cost of capital and, thus, encouraging more investment and the efficient use of business resources. As we will see below, the economic effects of eliminating these provisions can cancel out the positive effects of reducing the corporate tax rate.

Chart 1 shows the mathematical challenge of eliminating corporate tax preferences in order to offset the static cost of cutting the corporate tax rate. The bars illustrate the value and composition of tax expenditures in each of the next ten years, as is projected in the 2016 Federal Budget, while the line illustrates the approximate cost of cutting the corporate tax rate to 25 percent.

In 2015, corporate tax expenditures purportedly “cost” the Treasury $118 billion, a cost which is projected to grow to $239 billion by 2024. Over the next ten years, the total budgetary cost of all corporate tax expenditures is $1.8 trillion, an average of roughly $180 billion per year.

As the chart illustrates, the two biggest factors in the growth of corporate tax expenditures are the projected cost of deferral and the cost of accelerated depreciation. Deferral is the largest single corporate tax expenditure, with a total ten-year cost of $800 billion. Accelerated depreciation is the next largest, with a ten-year cost of $194 billion, followed by the Section 199 manufacturing deduction at $140 billion. The R&E tax creditA tax credit is a provision that reduces a taxpayer’s final tax bill, dollar-for-dollar. A tax credit differs from deductions and exemptions, which reduce taxable income, rather than the taxpayer’s tax bill directly. has a ten-year budgetary cost of $18 billion (compared to the $70 billion cost of the R&E expensing provision). That leaves the cost of all other provisions at $674 billion.

In contrast to this menu of available base broadeners, the ten-year cost of cutting the corporate tax rate to 25 percent is roughly $1.26 trillion ($1.32 trillion including the elimination of the corporate AMT), or $126 billion per year.[1] As is illustrated here, the cost of an immediate rate cut would start at $94 billion in the first year and gradually grow to $140 billion annually by the end of the decade.

It is also very clear from the chart that offsetting the cost of the rate cut would require eliminating every corporate tax expenditure except for deferral. Indeed, the value of all tax expenditures aside from deferral is roughly $1.1 trillion over ten years—nearly $200 billion short of offsetting the $1.26 trillion cost of cutting the corporate tax rate to 25 percent.

Since there is a very strong case to be made that any changes to deferral should be reserved for international tax reform, the math would seem to indicate that lawmakers will have to reach out beyond the corporate tax system if they intend to enact revenue neutral, or even budget neutral, corporate-only tax reform.

Corporate Tax Expenditures Are Shared with Pass-Throughs

Another complicating factor in attempting to broaden the corporate tax base to finance corporate-only tax reform is the fact that non-corporate businesses, such as S-corporations and partnerships, can also take advantage of many of the same tax expenditures as traditional C-corporations.

Chart 2 shows that 59 of the 79 corporate tax expenditures also benefit pass-through businesses. These provisions include a wide variety of items such as the R&E tax credit, the Section 199 manufacturing deduction, accelerated depreciation, the tax credit for low-income housing, and the charitable deduction. The value to C-corporations of these widely available provisions is $43 billion, whereas the value to pass-throughs of those same provisions is $92 billion,[2] more than twice as much.

Considering the disparity in how much each sector benefits from these provisions, it seems impossible for lawmakers to broaden the corporate tax base and not have pass-throughs suffer some collateral damage. Indeed, doing so would create two vastly different tax codes for corporations and noncorporations, resulting in an even more complicated tax code.

By contrast, only 20 provisions apply solely to C-corporations and they have a total budgetary value of $76 billion in 2015. As Chart 2 indicates, deferral comprises 85 percent of the total budgetary cost of these 20 provisions. The rest, including inventory sales source rules, the exemption of credit unions from tax, and the lower graduated income tax rates for corporations, total just $11 billion. Therefore, even if lawmakers were to repeal all of these items in an attempt to broaden the corporate tax base in a way that didn’t affect pass-throughs, there is still not enough savings here to offset the full cost of a 10 percentage point reduction in the corporate tax rate.

The Economic Effects of Corporate Base BroadeningBase broadening is the expansion of the amount of economic activity subject to tax, usually by eliminating exemptions, exclusions, deductions, credits, and other preferences. Narrow tax bases are non-neutral, favoring one product or industry over another, and can undermine revenue stability.

Setting aside the challenging static mathematics of broadening the corporate tax base in order to finance a rate cut, it is even more important for lawmakers to understand the different economic effects of eliminating various corporate tax expenditures as offsets. As we’ll see, exchanging some tax expenditures for rate cuts can have a positive effect on economic growth while trading other provisions for rate cuts can negate any of the economic growth generated by the lower rates.

In order to establish a benchmark, we used the Tax Foundation’s TAG model to first simulate the economic effects of cutting the corporate tax rate with no offsets to see how much growth a “pure” policy would generate. We cut the corporate income tax to 26.3 percent, which is as far as the corporate rate can be cut with the elimination of available corporate-only tax expenditures.[3] As Chart 3 indicates, cutting the corporate rate to 26.3 percent with no offsets can boost the level of GDP by 2 percent over roughly a decade. The challenge to those who insist that corporate tax reform be revenue neutral is to find offsets that don’t diminish the growth potential of a pure rate cut.

Rather than model the economic effects of all 79 different corporate tax expenditures, we instead separated them into four groups based on their characteristics, then used the model to estimate what the economic effects would be if these provisions were eliminated and the static savings was used to lower the corporate rate by an equivalent amount.

There are certainly many different ways to group these very different provisions, but we’ve chosen to split them along these main characteristics (the full list is included in the appendix):

Group 1: Provisions that move toward a cash flow base or prevent double taxation. This group includes deferral—which is intended to prevent the double taxation of foreign profits—and 15 provisions that offer firms a fuller, more accurate measure of their costs of production, including expensing, accelerated depreciation, or the proper treatment of inventories (such as LIFO—Last In, First Out). Eliminating them would raise the cost of capital by more than the corresponding tax rate reduction would reduce it.

Group 2: Provisions that affect business activity at the margin but don’t move toward a cash flow base. The main component of this group is the Section 199 manufacturing deduction. This measure does impact a targeted sector of businesses at the margin, effectively lowering their corporate tax rate, but does not move the system toward a consumption base. Eliminating these provisions is the equivalent of a rate increase.

Group 3: Provisions that have social policy objectives and those that have minimal economic effects. There are more than 20 provisions that can generally be considered social policy in nature, but which don’t distort the market. These include the special Blue Cross/Blue Shield deduction, the deductibility of charitable contributions, the work opportunity tax credit, and the credit for low-income housing investments. Repealing these provisions would have little impact on economic activity.

Group 4: Provisions that involve subsidies or those which distort the market in some fashion. There are more than 30 provisions that are generally intended to benefit a specific sector, industry, or policy objective. What makes these different from Group 3 is that these can be considered more of a direct subsidy to an industry or tend to distort the market in some way. These items include the exclusion of interest on public purpose State and local bonds, the exemption of credit union income from tax, the energy production credit, the new markets credit, and the credit for energy efficient appliances. Repealing these provisions would eliminate the distortions caused by them and would add to economic efficiency and growth.

Simulation Results

Group 1 Simulations:

The tax expenditures in Group 1 have a ten-year budgetary value of roughly $1.2 trillion, or an average of about $120 billion per year. However, deferral is the largest component of this group with a ten-year value of $812 billion and, for the purposes of this simulation, we are assuming deferral is reserved for any reform of the international tax system. MACRS has the second-highest value at roughly $200 billion over ten years and the remaining provisions have a value of $161 billion over ten years.[4]

For illustrative purposes, we simulated MACRS and the remaining expensing provisions separately:

Simulation 1: Change from MACRS to the Alternative Depreciation System (ADS).

In Simulation 1, we modeled a change in the depreciation regime from MACRS to ADS. As Chart 3 shows, this lowered the level of GDP by 1.46 percent by the end of the adjustment period. The main cause of the decline in GDP is the fact that the policy increases the cost of capital (the “service price”) by 2.7 percent. Moreover, the policy reduces business stocks by 4.1 percent and the wage rate by 1.2 percent.

Simulation 2: Eliminate LIFO and the remaining expensing provisions.

As with the move from MACRS to ADS, eliminating these provisions also increases the cost of capital and affects businesses’ investment decisions at the margin. As a result, the net effect of these changes reduces GDP by 0.49 percent.

Group 2 Simulation:

The elimination of the Section 199 manufacturing deduction is also at the margin. As a result, this trade has a net negative economic effect. GDP is reduced by 0.4 percent.

Group 3 Simulation:

As stated above, provisions in Group 3 are social policy provisions that do not impact investment decisions at the margin. When we enter the elimination of these expenditures into the model we find that it does not impact aggregate economic activity. There is no change to GDP.

Group 4 Simulation:

Group 4 provisions are considered corporate subsidies and also do not impact aggregate economic activity. As is shown in Chart 3, when we enter the elimination of these expenditures into the model we find that it has no long-term impact on GDP.

Final Simulation:

For the final simulation, we entered into the model all of the rate changes afforded by the elimination of these provisions, as well as the change in depreciation schedules.

As Chart 3 illustrates, the result of this summary simulation shows that the effect of broadening the corporate tax base completely negates the economic growth generated by the pure rate cut. The net effect of cutting the corporate tax rate to 26.3 percent while eliminating every corporate tax expenditure (except for deferral) decreases GDP by 0.05 percent over the adjustment period.

Indeed, no growth means no added investment or jobs, and no long-term recovery of federal revenue. It means that all the political pain of broadening the corporate tax base is for naught.


Lowering the 35 percent federal corporate tax rate is essential to making the U.S. more competitive and boosting long-term economic growth. Indeed, the Tax Foundation’s TAG model finds that a rate cut to 26.3 percent with no offsets would increase the level of GDP by more than 2 percent over the next decade and, over the long-term, would also recover much of the static revenue loss.

However, while there is a strong desire among many lawmakers to offset a rate cut with a broadening of the corporate tax base, there are both practical and economic challenges with such a tradeoff.

First, if we set aside deferral, there simply are not enough “loopholes” in the corporate tax code to fully offset the ten year cost of cutting the corporate tax rate to 25 percent. Moreover, the majority of corporate tax provisions are shared with pass-through businessA pass-through business is a sole proprietorship, partnership, or S corporation that is not subject to the corporate income tax; instead, this business reports its income on the individual income tax returns of the owners and is taxed at individual income tax rates. es such as S-corporations and LLCs. Eliminating these tax breaks indiscriminately would inadvertently increase the effective tax rates born by these noncorporation businesses with no corresponding reduction in their marginal tax rateThe marginal tax rate is the amount of additional tax paid for every additional dollar earned as income. The average tax rate is the total tax paid divided by total income earned. A 10 percent marginal tax rate means that 10 cents of every next dollar earned would be taken as tax. s. This should clearly be avoided.

Finally, our TAG model shows that the economic effects of broadening the corporate tax base fully negates the positive growth resulting from the rate cut itself. These results are consistent with similar exercises performed by economists at the Joint Committee on Taxation[5] and others at Rice University.[6]

The lesson from this is that lawmakers would do well to put a priority on generating economic growth and improving U.S. competitiveness rather than maintaining static revenue neutrality.

Corporate Income Tax Expenditures For Fiscal Years 2014-2024

In millions of dollars, based on assumptions from the Mid-Session Review of the 2015 Budget.


Group 1: Provisions that move toward a consumption base or prevent double taxation

Deferral of income from controlled
foreign corporations (normal tax method)


Accelerated depreciation of
machinery and equipment
(normal tax method)


Expensing of research and
experimentation expenditures (normal tax method)


Inventory property sales source rules


Excess of percentage over cost
depletion, fuels


Last In, First Out


Excess of percentage over cost
depletion, nonfuel minerals


Accelerated depreciation on rental
housing (normal tax method)


Expensing of exploration and
development costs, fuels


Expensing of multiperiod timber
growing costs


Natural gas distribution pipelines
treated as 15-year property


Amortize all geological and
geophysical expenditures over 2


Expensing of certain small
investments (normal tax method)


Expensing of certain multiperiod
production costs


Expensing of reforestation


Expensing of certain capital outlays


Expensing of exploration and
development costs, nonfuel


Total =


Total minus deferral & MACRS


Group 2: Provisions at the margin, but not toward a consumption base

Deduction for US production activities


Tonnage tax




Group 3: Provisions with nominal economic effects

Credit for low-income housing


Exclusion of interest on life insurance


Tax credit for orphan drug research


Graduated corporate income tax rate
(normal tax method)


Deductibility of charitable
contributions, other than education
and health


Deductibility of charitable contributions


Tax incentives for preservation of
historic structures


Exclusion of interest on rental housing


Special Blue Cross/Blue Shield


Deductibility of charitable contributions


Exclusion of interest on student-loan


Credit to holders of Gulf Tax Credit


Credit for employee health insurance
expenses of small business


Work opportunity tax credit


Small life insurance company


Tribal Economic Development Bonds


Special alternative tax on small
property and casualty insurance


Credit for disabled access



Deduction for endangered species
recovery expenditures


Employer-provided child care credit


Empowerment zones


Indian employment credit


Total =


Group 4: Targeted provisions with distortionary economic effects

Exclusion of interest on public
purpose State and local bonds


Exemption of credit union income


Special ESOP rules


Credit for increasing research


Exclusion of interest on hospital
construction bonds


Energy production credit


Exclusion of interest on bonds for
private nonprofit educational


Tax exemption of certain insurance
companies owned by tax-exempt


Exclusion of interest on owner-
occupied mortgage subsidy bonds


Advanced nuclear power production


New markets tax credit


Exclusion of interest for airport, dock,
and similar bonds


Energy investment credit


Exclusion of interest on bonds for
water, sewage, and hazardous
waste facilities


Qualified school construction bonds


Exemption of certain mutuals’ and
cooperatives’ income


Credit for holders of zone academy


Tax credits for clean-fuel burning
vehicles and refueling property


Exclusion of interest on small issue


Credit for investment in clean coal


Recovery Zone Bonds


Industrial CO2 capture and
sequestration tax credit


Exclusion of interest on bonds for
Highway Projects and rail-truck
transfer facilities


Exclusion of utility conservation


Credit for energy efficient appliances


Deferral of gain on sale of farm


Credit for holding clean renewable
energy bonds


Special rules for certain film and TV


Exclusion of interest on energy facility


Qualified energy conservation bonds


Investment credit for rehabilitation of
structures (other than historic)


Exclusion of interest on veterans
housing bonds


Credit for construction of new energy
efficient homes


Bio-Diesel and small agri-biodiesel
producer tax credits


Total =


[1] Tax Foundation Taxes and Growth Model and Joint Committee on Taxation.

[2] Much of the $92 billion available to pass-through businesses is also available to individuals with nonbusiness income.

[3] For simplicity, we assumed a revenue loss of $12.6 billion for every 1 point reduction in the corporate rate. This is based on the roughly $1.26 trillion ten-year cost of cutting the corporate rate to 25 percent, or $126 billion per year. The $1.1 trillion in corporate-only tax expenditures (excluding) deferral allows for an 8.7 percent corporate tax rate cut.

[4] Office of Management and Budget, Fiscal Year 2016 Budget of the U.S. Government, Feb. 2, 2015,

[5] Nicholas Bull, Tim Dowd, and Pamela Moomau, Corporate Tax Reform: A Macroeconomic Perspective, 64 (4), 923-942, National Tax Journal, Dec. 2011,

[6] John W. Diamond, Thomas S. Neubig, and George R. Zodrow, The Dynamic Economic Effects of a US Corporate Income Tax Rate Reduction, Oxford University Centre for Business Taxation, June 17, 2011.