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                                                                                                     August 2, 2017

Key Issues in Tax Reform: The Better Way House Plan


On June 24, 2016, House Speaker Paul Ryan released the
Better Way Tax Reform Task Force Blueprint, which
provides a revision of federal income taxes. (For an analysis
of the plan, see CRS Report R44823, The Better Way
House Tax Plan: An Economic Analysis, by Jane G.
Gravelle.) The plan does not specify all changes that might
broaden the base or any transition rules.


For the individual income tax, the plan would broaden the
base by disallowing itemized deductions except for
mortgage interest and charitable deductions, lower the rates
(with a top rate of 33% compared to 39.6% under current
law), and alter some of the elements related to family size
and structure by eliminating personal exemptions, allowing
a larger standard deduction, and adding a dependent credit.
The current earned income credit and child credit would not
be altered. Capital gains, dividends, and interest would be
taxed at 50% of ordinary rates; currently, capital gains and
dividends are subject to a top rate of 20% and interest is
taxed at ordinary rates.

For business income, the current income tax would be
replaced by a cash-flow tax, with a top rate of 20% for
corporations and 25% for individuals' (pass-through)
capital income. A cash-flow tax allows investments, such as
purchases of buildings and equipment, to be deducted when
incurred rather than through depreciation deductions over
time and results in a zero tax rate on new investment
returns. The cash-flow treatment would not apply to land
and apparently not to inventories. Interest would no longer
be deducted. The tax would be border-adjusted (imports
taxed and exports excluded), making domestic consumption
the tax base, although a recent announcement from
congressional leaders and administration officials has
indicated that a border adjustment would be dropped in any
future tax plan. The border adjustment may not be complete
because it would not allow a refund of the export deduction
when it creates an overall loss, but rather a carryover of
losses with interest. The system would also move to a
territorial tax in which foreign source income (except for
easily shifted income) would not be taxed. The proposal
would repeal the domestic production activities deduction
but retain the research tax credit.

The proposal would repeal estate and gift taxes. Although
the Affordable Care Act (ACA) taxes are not repealed in
the Better Way tax reform proposal, ACA taxes are
repealed in the House-passed American Health Care Act.

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One objective of tax reform is to increase output and
efficiency. The plan would achieve efficiency gains,
particularly in the allocation of capital by type and industry
and in the even treatment of debt and equity finance.


Current effective corporate tax rates on new equity
investments are negative or zero for investment in
intangibles, around 24% for equipment, and up to 36% on
some structures. Overall, including taxes on shareholders
and creditors, effective tax rates are around 22% for
corporate equity financed investments and a negative 44%
on debt financed investments; the new plan would result in
rates close to zero for both. Similar narrowing of tax
differentials would occur for unincorporated businesses.

The plan's estimated output effects appear to be limited in
size and possibly negative. The direct effect of lower
marginal tax rates on labor supply is limited because the
reduction in marginal tax rates is small and largely offset by
an increased base that increases effective marginal rates.
Capital income effects are also somewhat limited even with
the movement to a cash-flow tax (that generally imposes a
zero rate) because the current effective tax rate is low, due
to current accelerated depreciation and the negative tax rate
on debt-financed investment. Growth effects are also
limited because most empirical evidence does not support
large savings and labor supply responses. As currently
proposed, the plan loses significant revenue which,
according to some estimates, could more than offset the
supply responses because the increased government
borrowing would crowd out private capital investment.

The effect on international capital flows is ambiguous as
the cash-flow tax, while encouraging equity capital to move
from abroad, would discourage inflows of debt. The plan
would eliminate many distortions associated with
multinational firms, including eliminating the tax treatment
that discourages repatriation of foreign source income to the
United States and the incentive for firms to invert (shift
headquarters abroad) by merging. It would also largely
eliminate profit shifting to low-tax countries, although if
border adjustments are eliminated, the effect on profit
shifting is ambiguous. Although the disallowance of interest
deductions and lower tax rates would reduce profit shifting
incentives, a territorial tax tends to induce more profit
shifting through transfer pricing of intangibles. Without the
border adjustment, the incentive to invert would not be
entirely eliminated but would be substantially reduced.

Exchange rate adjustments (the dollar should appreciate by
25%) should eliminate any effect of the border adjustment
on imports and exports, although how quickly that
adjustment would occur is uncertain. If firms cannot merge
or otherwise find ways to deal with the lack of refundability
of the value of the deduction for exports, the measure
would reduce imports.


The proposal would have effects on vertical equity
(progressivity, or how the tax burden changes as income


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