Double Taxation
The release of Mitt Romney's tax returns has drawn attention yet again to the disparity between the rates paid on ordinary income and those paid on capital gains. It is being argued in some quarters that the 15% rate on capital gains vastly underestimates the effective tax rate paid by those whose income comes largely from financial investments, on the grounds that corporations pay a rate of 35% on profits. Were it not for this tax, it is argued, dividends and capital gains would be higher, and so would the after-tax receipts of those who derive the bulk of their income from such sources.
Romney himself has made this argument recently, claiming that his effective tax rate is closer to 50%:
One of the reasons why we have a lower tax rate on capital gains is because capital gains are also being taxed at the corporate level. So as businesses earn profits, that's taxed at 35 percent. Then as they distribute those profits in dividends, that's taxed at 15 percent more. So all total, the tax rate is really closer to 45 or 50 percent.
The absurdity of this claim is clearly revealed if one considers capital gains that accrue to short sellers, who pay rather than receive dividends while their positions are open. Following the logic of the argument, one would be forced to conclude that short sellers are taxed at an effective rate of negative 20%, thereby receiving a significant subsidy due to the existence of the corporate tax. The flaw in this reasoning is apparent when one recognizes that asset prices are lower (relative to the zero corporate tax benchmark) not only when a short position is covered, but also when it is entered.
There is no doubt that the presence of the corporate tax depresses the price of equities, but it does so both at the time of purchase and at the time of sale. If there were no corporate tax, dividends and capital gains per share would certainly be higher, but an investor would have paid substantially more per share to acquire his assets in the first place. As a result he would be holding fewer shares for any given initial outlay, and his after-tax income (holding constant the rate paid on capital gains) would not be substantially different.
To see why, it is useful to think about what determines the price of equities. Three factors are especially important: the current earnings of a firm (after payment of interest and taxes), the rate at which these earnings are expected to grow, and the riskiness of the security, which itself is linked to the degree to which the firm's earnings are correlated with broader market movements. Securities that are riskier in this latter sense tend to appreciate faster on average because investors would otherwise avoid them, depressing their prices and raising their expected returns until such returns are viewed as adequate compensation for the greater risk of holding them. This risk is routinely expressed as a market capitalization rate, interpreted as the expected return that investors require in order to hold the security. Airline and automobile stocks, for instance, have higher market capitalization rates than do shares in utilities.
The manner in which these factors interact to influence prices may be illustrated by considering the simplest possible case of a firm with constant expected earnings growth and a fixed dividend payout ratio. In this case, for reasons discussed in any introductory finance textbook, the fundamental value of the security is given by the simple formula D/(k-g), where D is the current dividend forecast (a constant share of the earnings forecast), g is its expected rate of growth, and k is the market capitalization rate. Shares in a debt-free firm that pays 20% of its earnings as dividends, is currently earning $10 per share annually, is expected to grow at 10%, and has a market capitalization rate of 12% would then have a share price of $100. After a year (assuming no change in these parameters) the share price would be $110 and the dividend payout $2. An investor would have made $12 on a $100 investment, a percentage return precisely equal to the market capitalization rate. All this is with no corporate tax.
Now suppose that a 35% corporate tax is in place, so after-tax earnings per share are $6.50 instead, with no change in other specifications. Dividends are then $1.30 per share and the initial share price is $65. After a year this rises to $71.50. Adding dividends and capital gains, an investor makes $7.80 for each share purchased at $65, again earning precisely 12%. Each share results in lower revenues to the investor, but since more shares can be purchased at the outset, aggregate income is no different.
None of this should be in the least bit surprising. Note, however, that if the corporate tax were to be eliminated today, there would be a sharp rise in the price of equities and current asset holders would enjoy a windfall gain. Similar issues arise with respect to the mortgage interest deduction: eliminating this would result in an immediate decline in home values, severely punishing those who purchased recently at prices that reflected the anticipated tax savings over the duration of the mortgage.
This does not necessarily mean that eliminating the corporate tax while simultaneously raising the rate on capital gains is necessarily a bad idea, or that elimination of the mortgage interest deduction is necessarily bad policy. A case could be made for both initiatives. The corporate tax is not uniformly applied due to the broad range of loopholes and exemptions, and the mortgage deduction is regressive and inhibits both neighborhood integration and labor mobility. But any such changes will have major distributional effects that must be taken into account in any comprehensive evaluation of the policy. Doing so properly requires a clear distinction between stocks and flows, and an analysis that goes a little deeper than simple arithmetic.
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Update: Follow-up post here.