International Burdens of the Corporate Income Tax
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Int’l corporate tax model: 30% domestic share of world output/wealth. Key finding: Smaller economies face larger excess tax burden due to capital reallocation. Perfect capital mobility drives tax incidence.

“…As with any simplified model, the analysis is silent about some potentially important issues - such as the effect of the corporate tax on savings, growth and other dynamics - that may also have important effects on corporate tax incidence..."Assumptions (these are the big two) 1. “…The application starts with an assumption that capital is perfectly mobile internationally…” 2. “…also assumes initially that the degree of international output substitutability does not matter because the corporate tradable sectors have equal output capital intensities…”NOTE both of the above assumptions are “relaxed later in the application”3. “…The world consists of two countries. In an initial equilibrium, both economies are identical except for size. For each economy, production is divided into five sectors that each produce goods or services using labor, capital and (for agriculture) land. All production technologies are characterized by constant returns to scale; production functions are twice-differentiable and concave; competition is perfect at the level of the producer. The first three sectors are corporate. Sector one produces internationally tradable outputs for which the foreign and domestic products are perfect demand substitutes. The output from that sector is the numeraire. Sector two produces internationally tradable outputs for which the foreign and domestic products are not perfect demand substitutes. Sector three produces non-internationally tradable outputs for which consumption must occur in the same country as production; examples include utilities and transportation services. Sectors four and five are noncorporate sectors. Sector four produces internationally tradeable agricultural products. Sector five produces outputs that are not internationally tradeable, such as residential housing and retail services..." 4. “…Labor is homogeneous and perfectly mobile within each country, but cannot move between countries. Thus, the wage rate is the same for every sector within a country, but can differ between countries. Individuals do not vary their amount of labor supplied to the market…” 5. “…The worldwide supply of capital is fixed but perfectly mobile between countries in that the geographic location of investment does not matter to a marginal investor…” 6. “…The marginal return to investment is the same everywhere in equilibrium, excluding producer-level taxes on capital income…” 7. “…Capital owners can own capital in either country, but cannot themselves relocate abroad. Each owns a fixed share of the world capital stock…” 8. “…Consumers have identical homothetic preferences and must consume where they live. They can choose from among the five types of outputs produced in their own country (or imported from the other country in the case of outputs from sectors one and four) and imports of the unique output from sector two of the other country. Initial consumer expenditures on the six types of goods and services are proportional to the initial shares of worldwide production…” 9. “…The domestic government collects taxes and makes lump-sum distributions. In order to isolate the effects of the corporate income tax, the government’s other policies are assumed to affect neither economic efficiency nor the distribution of income. With any available tax revenues, the domestic government purchases the six available varieties of consumer goods according to the same expenditure shares as domestic consumers. The government redistributes that bundle of commodities to domestic residents in proportion to their incomes. The foreign government does not respond to any tax policies chosen by the domestic government…” 10. "...assuming that the input substitution elasticities are identical in all sectors and countries...." 11. "...assumed here that the domestic country does not produce enough to affect the world price of output in that sector..." 12. "...The model can be applied based on very few assumptions about the economy. Share assumptions (Table 1) apply for the United States and are taken from Gravelle and Smetters (2006).21 The capital intensities of sectors one and two are initially equated for simplicity. When those capital intensities are equal, the incidence results are the same as if the first two sectors are combined into one sector for which the foreign and domestic outputs are perfect substitutes. In other words, the fact that sector two produces foreign and domestic outputs that are not perfect substitutes does not affect the incidence results when the first two sectors have the same capital intensities. A later part of the application examines how incidence changes when those capital intensities are different. The domestic economy accounts for 30 percent of world output. In addition, domestic residents are assumed to own 30 percent of world output, so the country is neither a net international lender nor a net international borrower. That assumption is also relaxed later in this study..." 13. "...The tax burden is not exported or imported in the aggregate because the initial domestic and foreign per capital wealth endowments are assumed to be equal, and because the corporate tax has no tariff-like effects when the first two sectors have the same capital intensities..." 14. "...The excess burden, measured as a share of revenue, is largest when the domestic economy is smallest. That excess arises because the corporate tax causes capital to be allocated inefficiently away from the domestic corporate sector and out of the domestic economy. Both sources of inefficiency become smaller relative to domestic revenue as the domestic economy is assumed to be relatively larger..." 15. "...the marginal investor is still assumed to be indifferent between domestic and foreign investments that pay the same rate of return, but only for investments in some of the countries - perhaps between the highly industrialized countries...." 16. "...However, the capital intensities and output shares can be specified in a way that is consistent with Harberger’s (1995) assumptions: that labor employed in the first two sectors accounts for one-fourth of the domestic labor force; that capital used in the first two sectors accounts for one-half of all capital used in the corporate sectors; and that domestic capital accounts for three-eighths of the world’s capital stock. Otherwise, the parameter values (Table A1) have been completed with share assumptions. Alternatively, the first three sectors can be assumed to have the same relative capital intensities as in Table 1, but the capital intensity of sector five must be much lower for the Harberger (1995) assumptions to be satisfied. Either way, those assumptions do not appear to be reasonable for the U.S. economy. Sector three includes utilities and transportation, both of which are more capital-intensive than the manufacturing in sectors one and two. Sector five includes housing and retail services, for which production is much more capital intensive than manufacturing. Under the assumptions in Table A1, the domestic consumer’s burden is -95.8 percent of the revenue, while the foreign consumer’s burden is -0.04 percent of the revenue made by Gravelle and Smetters (2006), most critical of which is the assumption that labor receives about 70 percent of the value of total output. Compared to the base case in this study (Table 1), the capital intensity is assumed to be higher in the first two sectors (manufacturing). Also, in contrast to the base case, sector three (utilities) is assumed to be less capital intensive than the first two sectors...." Randolph, William, “International Burdens of the Corporate Income Tax,” Congressional Budget Office, August 2006. Available at:http://www.cbo.gov/sites/default/files/cbofiles/ftpdocs/75xx/doc7503/2006-09.pdf







Ed Comment: Is suspect variable rate loans grew after the rate cut because the rate cut was greater than it should have been/than mr market thought it should be.