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110 IRET Byline 1 (1993)

handle is hein.taxfoundation/iretbyln0110 and id is 1 raw text is: March 31, 1993  No. 110
Clinton's ITC: Too Brief,
Too Small, and Too Strange
President Clinton has proposed two types of
investment tax credit (ITC) which he hopes will jump-
start the economy near-term and improve long-term
capital formation without costing much revenue. The
credits are severely reduced in
value by punitive offsets and other
restrictions.   For  the  large    The    total
businesses that account for 85
percent or more of the nation's    package    wd
investment, the credit is temporary  cost of capii
and would do nothing long term to  in no way
counter   Clinton's   proposed     Clinton pac,
permanent two percentage point     capital to p
increase in the corporate tax rate
for large firms. The credits are
likewise inadequate to counter the
proposed permanent increases in personal tax rates
affecting upper-income savers and investors who own
and finance a significant portion of large and small
corporations and unincorporated businesses.  All
businesses would  also  suffer from  energy tax
increases. The total Clinton tax package would raise
the cost of capital. The credits in no way transform
the Clinton package from anti-capital to pro-growth.
Small businesses (those with less than $5 million
in average annual gross receipts in the preceding three
tax years) would be allowed a permanent investment
tax credit that would apply to all of a firm's
investment in eligible types of property. Eligible
property would be the same types of assets, principally

IRET&

of their assets by
Clinton tax
ould raise the
al. The credits
transform the
kage from anti-
ro-growth.

the amount of the credit received.
That is, if the business received a
$7 investment tax credit on a $100
machine, the business could only
write off $93 under the normal
capital cost recovery provisions.
The higher taxes resulting from the
reduced write-offs would offset
roughly 30 percent of the value of
the credit. On 7-year property of
small corporations, for example, the
effective credit in 1993 after basis
adjustment would be 3.81 percent,

instead of 5.6 percent. (See Table.) This 100% basis
adjustment is the harshest in the history of the ITC.
The expanded ITC introduced in the Economic
Recovery Tax Act of 1981 had no such basis
adjustment. Even the viciously anti-investment Tax
Equity and Fiscal Responsibility Act of 1982 required
that only half of the ITC be subtracted from the tax
basis of the equipment.
For unincorporated businesses, over 92 percent of
the permanent 5 percent credit would be wiped out by
the basis adjustment and the increase in the owners'
marginal income tax rates. The rate hikes include the
explicit hike in the statutory rates plus the effect on
marginal rates from elimination of the Medicare tax

Institute for
Research on the
Economics of
Taxation

machinery and equipment, eligible under past credits
(section 38 property, consisting of property with 3-,
5-, 7-, and 10-year recovery periods and 15-year
public utility property). Used property, purchased
principally by small businesses, would not be eligible.
The basic credit would be 7% on assets bought
between December 3, 1992, and December 31, 1994,
and 5% thereafter. However, 3-year assets would
receive only one-third of the credit, 5-year assets two-
thirds, and 7-year assets four-fifths, with the full credit
reserved for 10- and 15-year assets. (See Table.) The
small business credit would be subject to an annual
cap to prevent abuse of the $5 million gross receipts
rule.
The value of the small business credit would be
sharply limited by a basis adjustment.  Small
businesses would have to reduce the depreciable basis

IRET is a non-profit, tax exempt 501(c)(3) economic policy research and educational organization devoted to informing the
public about policies that will promote economic growth and efficient operation of the free market economy.
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