Comment: Tax Evasion at the Top of the Income Distribution: Theory and Evidence

Gerald Auten and David Splinter, "Comment: Tax Evasion at the Top of the Income Distribution: Theory and Evidence," Working Paper, May 5, 2021, http://www.davidsplinter.com/AutenSplinter-TaxEvasion.pdf

Their takeaway, “…While some increase in high-income audit rates may be appropriate, additional enforcement resources could also help audit selection by better identifying returns with lower reported incomes but higher likelihood of evasion. The combined efforts and increased cooperation of IRS divisions could lead to improved methods of selecting returns for audit and help maintain high ROIs for enforcement activities…. We note in this comment, however,that estimates of evasion not detected in NRP audits using simple DCE multipliers and allocating in proportion to reported income are not distributionally consistent. Moreover, we believe these approaches tend to overstate true top incomes and underreporting rates. We suggest alternative methods that would be more distributionally consistent. These suggest substantially less impact of evasion on top income shares. We are aware that there is considerable additional sophisticated evasion by some high-income individuals not found in NRP audits….”

They make the case this overstates the top income share, “.. Two-thirds of the estimated increase in top income shares results from applying DCE multipliers. This approach causes exaggerated upward re-ranking of returns with large amounts of detected evasion,shifting estimated evasion from the bottom and middle to the top of the income distribution. The second largest increase in top shares results from allocating additional passthrough evasion by reported income. However, returns with business losses appear to be allocated little additional evasion despite accounting for over one third of evaded income….While offshore evasion has received considerable attention, it accounts for only a small portion of the total effect on top income shares….”
Bottomline, “…National accounts explicitly break out proprietor evasion (combined amount for sole proprietors and partnerships) of $561 billion and wage evasion of $75 billion when averaging 2006-2013 (at 2012 dollars). Auten and Splinter (2019a, online data Table T1) provide estimates of likely evasion in national accounts for other income sources. For 2006-2013, there is annual evasion of about $44 billion for farms, $43 billion for rents, and $80 billion for S corporations. To compare with GLRRZ, there are smaller amounts for dividends and interest evasion that should be added and non-filer portions that should be removed from the values above. If we assume the former is $50 billion and the latter is 10 percent,this suggests about $770 billion in filer evasion in national income. In comparison, GLRRZ add $1,304 in audit-based evasion in 2012 (Table A6, exam and DCE columns). But this amount includes capital gains realizations that are not in national income. Excluding $70 billion in added evaded capital gains (5.3 percent of total based on Table A1) suggests that GLRRZ add audit-based filer evasion comparable to national income definitions of about $1,230 versus about $770 billion in national income.11 Therefore, the GLRRZ filer evasion estimate appears to exceed amounts in national income by $460 billion, or more than one half.This represents an additional 3 percent of national income…”

They describe Zucman’s methodology, “…GLRRZ’s analysis has four steps. First, it uses audit study micro data to add detected evasion. Second, GLRRZ imputes undetected evasion using a set of multipliers developed from earlier audit data. These multipliers are from detection-controlled estimation (DCE) and can nearly quadruple the amount of evasion in audit studies.Third, it adds imputations of additional evasion from passthrough entities (including partnerships, S corporations, and certain other sources). The amounts already in the NRP audits are removed and then this assumed total passthrough evasion is allocated by reported income, such that essentially all goes to the top of the distribution. Fourth, GLRRZ estimates how income from offshore wealth affects income distributions... Combining the four components of estimated evasion, GLRRZ argue that top 1% fiscal income shares increase by 1.5 percentage points (pp). This includes a 0.5pp decrease from detected evasion, 1.1pp increase from undetected evasion using DCE multipliers, 0.6pp increase from additional business evasion, and 0.3pp increase from income of offshore wealth..”

Ben and I both read Auten and Splinter arguing Zucman and his fellow travelers are likely overstating tax evasion at the top. However they don’t have a quantification table in the paper so we can’t exactly draw out the calculation you were interested in. AS do note a directional answer in the text, “…this suggests about $770 billion in filer evasion in national income. In comparison, GLRRZ add $1,304 in audit-based evasion in 2012 (Table A6, exam and DCE columns). But this amount includes capital gains realizations that are not in national income. Excluding $70 billion in added evaded capital gains (5.3 percent of total based on Table A1) suggests that GLRRZ add audit-based filer evasion comparable to national income definitions of about $1,230 versus about $770 billion in national income.11 Therefore, the GLRRZ filer evasion estimate appears to exceed amounts in national income by $460 billion, or more than one half…”