A theory of capital gains taxation and business turnover

We present a theory concerning the realization of capital gains where ownership and control are linked as in Holmes and Schmitz (J. Pol. Econ. 103: 1005–1038, 1995). The model developed is a version of a Lucas-tree economy in which the productivity of a technology depends on the ownership of the technology. The existence and uniqueness of equilibrium follow from the Contraction Mapping Theorem. The theory implies that impediments to asset trading, such as capital gains taxation, negatively affect production efficiency. Moreover, we calibrate the model economy to U.S. data on small-business turnover and find that indexing deductions for inflation is capable of increasing capital-gains tax revenues. We thank an anonymous referee for helpful comments, and well as Tom Holmes, Ed Prescott, Jim Schmitz and Neil Wallace for insightful conversations. Cavalcanti is grateful for financial support from CNPq, as well as the hospitality from the University of Toronto during his visiting appointment at the Department of Economics in 2006. Erosa acknowledges the support from the Institute for Policy Analysis at the University of Toronto and the Social Sciences and Humanities Research Council of Canada.     

The effect of capital gains taxation on small business transfers and start-ups

This paper studies the effect of capital gains taxation on small business transfers and business start-ups. We consider a model in which agents have different abilities to manage businesses and derive an agent's optimal choices as an owner or non-owner of a small business. Agents' optimal choices depend on their abilities. We also find that capital gains taxation has a negative effect on small business transfers but can encourage small business start-ups.     

Risky human capital and deferred capital income taxation

We study the structure of optimal wedges and capital taxes in a dynamic Mirrlees economy with endogenous distribution of skills. Human capital is a private, stochastic state variable that drives the skill process of each individual. Building on the findings of the labor literature, we construct a tractable life-cycle model of human capital evolution with risky investment and stochastic depreciation. In this setting, we demonstrate the optimality of (a) a human capital premium, i.e., an excess return on human capital relative to physical capital, (b) a large intertemporal wedge early in the life-cycle, and (c) a non-zero intratemporal wedge even at the top of the skill distribution at all dates except the last date in the life-cycle. The main implication for the structure of optimal linear capital taxes is the necessity of deferred taxation of physical capital. The average marginal tax rate on physical capital held in every period is zero in present value. However, expected capital tax payments do not equal zero in every period. Necessarily, agents face negative expected capital tax payments early in the life-cycle and positive expected capital tax payments late in the life-cycle.     

On optimal redistributive capital taxation

This paper addresses conflicting results regarding the optimal taxation of capital income. Judd proves that in a steady state, there should be no taxation of capital income. Lansing studies a logarithmic example of one of Judd's models and finds that the optimal steady‐state tax on capital income is not always zero—it is positive in some specifications and negative in some others. There appears to be a contradiction. However, I show that Lansing derives his result by relaxing the convergence hypotheses of Judd's theorem. With less restrictive hypotheses, a wider range of primitives (parameter values, initial condition, etc.) satisfy the hypotheses and because each specification of primitives generates its own optimal time path(s) for the model's variables, it follows that a wider range of time paths with a wider range of steady‐state properties is possible. This raises a question. What happens if the convergence hypotheses are weakened further so that they are satisfied by a wider yet range of primitives? I find that at any interior steady state for the model's optimal tax equilibrium, either the capital tax is zero or else the elasticity of marginal utility is unitary which is satisfied identically in Lansing's log example. In effect, Lansing's example illustrates the only way in which an interior steady state can violate the zero tax result.     

Risk sharing through capital gains

Abstract We estimate channels of international risk sharing between European Monetary Union (EMU), European Union, and other OECD countries, 1992–2007. We focus on risk sharing through savings, factor income flows, and capital gains. Risk sharing through factor income and capital gains was close to zero before 1999 but has increased since then. Risk sharing from capital gains, at about 6%, is higher than risk sharing from factor income flows for European Union countries and OECD countries. Risk sharing from factor income flows is higher for euro zone countries, at 14%, reflecting increased international asset and liability holdings in the euro area.     

Cross-base tax elasticity of capital gains

This paper studies the cross-base tax elasticity of capital gains realizations to labour income taxes when capital gains are taxed at a separate proportional tax rate. Using a longitudinal panel of over 265 000 individuals in Sweden, this paper shows in a regression kink design that labour income taxes affect capital gains realizations in two ways. An increase in the marginal labour income tax rate increases the likelihood of realizing capital gains and the amount of realized capital gains. One implication of this result is that labour income taxes have a lock-out effect but that the magnitude of this effect is smaller than the lock-in effect of the actual capital gains tax.     

Inflation and the taxation of capital income a note

Zusammenfassung In einem einfachen neoklassischen Modell hat Professor M. Feldstein gezeigt, daß die Inflation die Steuerbelastung von Kapitalerträgen erhöht und damit die Nettoertrags-rate des Sparens senkt. In der vorliegenden Note werden zuerst einige Modellannahmen Feldsteins in Frage gestellt. Insbesondere erscheinen seine langfristige Steady-state-Analyse und die Verwendung eines neoklassischen Wachstumsmodells mit investitionsunabhängiger Wachstumsrate problematisch. Mit Einschränkungen wird in Feldsteins Modell auch das Phänomen der Doppelbesteuerung (teilweise schon wegen der erwähnten Steady-state-Betrachtung) nicht adäquat erfaßt. Im letzten Abschnitt wird die Anwendbarkeit des Modells auf österreichische Verhältnisse untersucht. Das (De-facto-)Fehlen einer Kapitalzuwachssteuer und die steuerliche Investitionsförderung lassen die Auswirkungen der Inflation auf die Kapitalertragsbesteuerung in Österreich weniger dramatisch erscheinen.     

Corporate taxation and the efficiency gains of the 1986 Tax Reform Act

Summary The 1986 Tax Reform Act (TRA) had little effect on the overall U. S. effective capital income tax rate. However, TRA significantly reduced differences in effective taxation of corporate and noncorporate capital for a number of U. S. industries. The Mutual Production Model developed in Gravelle and Kotlikoff (1989) can be used to study the efficiency gains from the reduction in corporate tax wedges within industries. Unlike the Harberger Model, the Mutual Production Model permits both corporate and noncorporate firms to produce the same goods and, therefore, to coexist within a given industry.This paper develops an 11-industry-55-year dynamic life cycle version of the Mutual Production Model. We use this model to study the steady-state efficiency gains associated with the new law. While we do not simulate the economy's transition path, our steady-state welfare changes are those that arise from compensating transitional generations for the first-order redistribution of income associated with the Tax Reform.We find that the 1986 Tax Reform law reduces excess burden by 85 percent of our model's economy's present value of consumption. This efficiency gain reflects the Tax Reform's reduction in corporate-noncorporate tax wedges, particularly in those industries with significant noncorporate production. Measured as a flow the 1988 estimated efficiency gain from the Tax Reform Act is $31 billion.The opinions expressed in this paper are those of the authors and do not necessarily reflect the views of The Congressional Research Service of the Library of Congress, Boston University, or The National Bureau of Economic Research. We are particularly grateful to Alan Auerbach, Oldrich Kyn, and an anonymous referee for very extensive and critical comments. We also thank Don Fullerton, Yolanda Henderson, Tom Woodward, and a referee for their very helpful suggestions.     

On income fluctuations and capital gains

We consider the infinite time horizon problem of asymptotically maximizing the expected accumulated discounted utility in a one-good production economy. The available capital in a given period is given by the production of the previous period plus a random variable. The product of the discount and interest factors is either (1) greater than or (2) equal to one. Under (1) the optimal policy exists under certain conditions and always under (2). The optimal capital sequence almost surely goes to infinity. Under (1) with conditions on the utility one almost surely reaches a capital level above which the sequence is increasing.     

Merchant guilds,taxation and social capital

We develop a theory of the emergence of merchant guilds as an efficient mechanism to foster cooperation between merchants and rulers, building on the complementarity between merchant guilds’ ability to enforce monopoly over trade and their social capital. Unlike existing models, we focus on local merchant guilds, rather than alien guilds, accounting for the main observed features of their behavior, internal organization and relationship with rulers. Our model delivers novel predictions about the emergence, variation, functioning, and eventual decline of this highly successful historical form of network. Our theory reconciles previous explanations and the large body of historical evidence on medieval merchant guilds. In doing so, we also shed novel light on the role of the guilds’ social capital, and its importance for taxation, welfare, and the development of towns and their government in medieval Europe.     

Dynamic inconsistency and non-preferential taxation of foreign capital

When capital is sunk after it is invested, a host government facing heterogeneous foreign investors has a strong incentive to reduce preferential taxes over time in order to attract less eager investors while fully expropriating past investors. This induces investors to wait rather than invest in the initial period, and leads to loss of tax revenue. This dynamic inconsistency problem is resolved if the host government commits to non-preferential taxation in each period even if it does not commit to future tax rates.     

Constrained Pareto-optimal taxation of labour and capital incomes

With the Pareto principle as the sole normative criterion, necessary conditions for optimal tax rates on labour and capital incomes are established in an overlapping-generations model. The individuals in the economy have differing earning abilities and their labour supply is endogenous. The analysis focuses on intragenerational aspects and is restricted to linear taxation in steady state.     

Equilibrium capital taxation in open economies under commitment

This paper analyzes equilibrium capital taxation in open economies with strategic interaction in a neo-classical growth model. Under perfect commitment, I show that non-cooperative capital taxes are zero in the long run for a large open economy, thereby generalizing the result previously established only for the special cases of a closed and a small open economy. This does not represent a race to the bottom, though, since the result is independent of the degree of capital mobility, the number of countries, or a country׳s size relative to the rest of the world. Moreover, when countries cooperate, they still set capital taxes to zero in the long run. These outcomes are robust to different equilibrium specifications, the inclusion of endogenous government spending, and heterogeneous agents and non-linear labor income taxation. Governments find it optimal to implement the efficient capital allocation in the long run, both in a closed and an open economy; this trumps incentives to tax foreigners’ domestic capital holdings by raising capital taxes and attracting capital from abroad by lowering capital taxes.     

An analysis of capital gains tax-induced earnings management

Since 1974, there have been four changes in the corporate tax rate on net capital gains. In each instance a firm had an incentive to alter its capital gains taking in order to maximize its after-tax cash flows. This paper presents a longitudinal analysis of firms' responses to the four rate changes and in doing so provides additional evidence regarding tax-induced earnings management. Most studies analyze firms' responses to tax law change in one tax act (e.g., The Tax Reform Act of 1986), yet firm response to one act might not be the typical response. Results from this study confirm such a phenomenon. The results also provide additional evidence on the association of firm characteristics with tax-induced earnings management.     

Global capital markets,direct taxation and the redistribution of income

Standard fiscal theory suggests that taxation should be heaviest on the least mobile factors of production – for both efficiency and revenue reasons. A shift in tax burdens from capital to labour as economies become globally integrated is thus justified. This theoretical tradition (founded by Ramsay and continued by Mirrlees and Lucas) assumes by construction that profit taxes reduce investment and growth; and while sensitive to inter-generational equity, sidesteps the issue of income distribution within generations. In contrast, starting from Keynes’ critique of these assumptions and building on modern endogenous growth models, it can be shown that profit taxation is not necessarily injurious to productive investment. In practice, moreover, the effect of globalisation has not been to reduce tax rates on capital, but rather to erode the tax base itself (i.e. ‘tax evasion’). Improved information exchange between tax authorities, which is now being driven by fiscal insolvency in developed countries, would allow tax incidence to be shifted so as to improve income distribution within OECD countries. Such cooperation could also permit the replacement of the current discretionary system of fiscal transfers from rich to poor countries (‘development aid’) by equitable sharing of global capital tax revenue.     

The taxation of capital returns in overlapping generations models

This paper shows that in the Diamond (1965) overlapping generations economy with production and capital savings, there is a period-by-period balanced fiscal policy supporting a steady state allocation that Pareto-improves upon the laissez-faire competitive equilibrium steady state (whether dynamically inefficient or efficient) without resorting to intergenerational transfers. The policy consists of taxing linearly (or subsidizing, in the dynamically efficient case) the returns to capital, while balancing the budget period by period through a lump-sum transfer (or tax, respectively) in second period. This intervention grants every generation the highest steady state utility attainable through markets (i.e. remunerating factors by their marginal productivities and without transfers) which under laissez-faire is not a competitive equilibrium outcome. A transition from the competitive equilibrium steady state to this other steady state is also Pareto-improving when the former is dynamically inefficient. The result disentangles from redistributive considerations the impact of the taxation of capital returns on steady state welfare, and thus provides a rationale for the taxation of capital returns that is based on efficiency considerations and not on redistributive goals.     

Policy commitment and the welfare gains from capital market liberalization

This paper evaluates the quantitative impact of capital liberalization on the taxation structure and welfare of the liberalizing countries when governments conduct fiscal policy optimally but without commitment (time-consistent policies). The transition from a regime of capital autarky to a regime of free mobility leads to a decrease in the long-term tax rate on capital of 13 percent and an increase in the tax rate on labor of 2 percent. As a consequence of this taxation shift, welfare increases by about 1 percent. The reduction in capital taxation induced by capital market liberalization is welfare improving because, in the absence of capital mobility, the time-consistent policies over-tax capital.     

Start-ups, venture capitalists, and the capital gains tax

A model of start-up finance with double moral hazard is proposed. Entrepreneurs have ideas and technical competence, but lack own resources as well as commercial experience. Venture capitalists (VCs) provide start-up finance and managerial support. Both types of agents thus jointly contribute to the firm's success, but neither type's effort is verifiable. We find that the market equilibrium is biased towards inefficiently low entrepreneurial effort and venture capital support. In this situation, the capital gains tax is particularly harmful. The introduction of a small tax impairs effort and advice and leads to a first-order welfare loss. Several other policies towards venture capital and start-up entrepreneurship are also investigated.