2018년 3월 1일 목요일

발췌: W. Vickrey // Tax Simplification through Cumulative Averaging


출처: William Vickrey, "Tax Simplification through Cumulative Averaging," Law and Contemporary Problems, ......


※ 발췌 (excerpt):

Complications in the enactment and administration of income tax laws as they generally exist at present arise very largely from the need to answer four types of questions: (1) Is it income? (2) Whose income is it? (3) What kind of income is it? and (4) When is it income? A surprisingly large portion of the questions that arise and generate involuted legislation and complicated administrative rulings have to do with the last two of these questions, questins essentially have little to do with the basic philosophy of the income tax, and which fundamentally should be irrelevant to the assessment of a properly designed income tax.

The question as to the kind of income that an item represents has to do very largely with  the special favors extended to income designated as capital gains. This is not the place to attempt to answer all of the varied and intricate specious arguments advanced in favor of such special treatment.[주]1  Suffice it here to say that the one argument that has some semblance of substance in the context of a general income tax assessed annually at progressive rates, to wit, that gains accumulated over a long period and realized in a single year may subject the taxpayer to unreasonably high bracket rates if no allowance is made, is largely vitiated as soon as there is available an adequate averaging of income, so that the effective rate ultimately depends not on the income of a single year but on the general level of income over a period of several years.

The difficulty heretofore with such averaging devices has been that either they were not fully effective in overcoming the disadvantages of "lumpy" income, or they required extensive record keeping, or fairly elaborate computations, or gave undesirably capricious results in special cases.

Cumulative averaging, or perhaps more descriptively, cumulative assessment, is a method of averaging that is at once simple, complete, and free from capricious impacts, and its adoption should completely overcome whatever rational hesitation there may be to the elimination of capital gains as a special category of income, allowing receipts in this form to be treated on the same basis as any other.[주]2

[주]2. The basic concept of cumulative averaging was first developed in Vickrey, "Averaging of income for Income Tax Purpose," 47. ^Journal of Political Economcy^. 379 (1939). The scheme was developed further and described more fully in W. Vickrey, Agenda for Progressive Taxation, 172-95, 285-87, & 417-27 (1947).

The question as to when an item is income is one that in the long run has little if anything to do with a taxpayer's over-all ability to pay, and in any properly designed tax should be a matter in which neither the taxpayer nor the Treasury should have any substantial interests. The fact that under the present law the timing of income does so make a substantial difference is amply attested to by the multitude of rules, distinctions, accounting specifications, and the like that permeate the regulations, and the amount of contention that arises between taxpayer and Revenue Service over these matters. That even so the results are not always considered adequately equitable is evidenced by the fact that at long last limited and complicated forms of averaging have been introduced to take care of the more extreme cases of inequity. But what has been done here has hardly scratched the surface of what can be done through averaging to make the income tax more equitable, and, far from taking advantage of the potentials for simplificatin that inhere in averaging, the methods of averaging adopted have themselves been a source of added and excessive complication.

Cumulative averaging is a method of assessing the income tax on the basis of the aggregate income of an individual over a period extending from some fixed initial year to the current year, in such a way that any shifting of items of income or of deductions from one year to another within this over-all period will have no effect on the over-all tax burden borne by the individual. Provided only that checks are provided through a final valuation of assets at the end of the last year of the averaging period, as at the death of the taxpayer, and the bringing to account of accruals of income thus revealed, so that income may not be shifted into or out of the period as a whole, the taxpayer may be left free to carry on his accounting in any self-consistant way he sees fit, deciding for himself such matters as rates of depreciation or amortization, whether to expense of capitalize outlays, when to date transaxtion, whether to accrue discounts, and the like. More important, taxpayers will be free to enter transactions at any time without having to take into account any likelihood that the timing or nominal form of the transactions would have a significant effect on his ultimate over-all tax liability.

Cumulative assessments, coupled of course with full taxation of capital gains and full deductibility of losses, is thus a means of freeing the taxpayer completely from the pervasive balefule influence of the income tax as it exists currently. There will be no locks-ins, no need to cast transactions in unnatural forms, and no need to consult a tax expert before every important transactions!

One might think that in order to accomplish all this the assessment of tax on a cumulative basis would itself have be fairly complicated. In practice, however, cumulative assessment turns out to be a very simple computation insofar as the taxpayer is concerned. By making use of tax tables quite similar to those now used for the annual tax computation, the computations required of the individual taxpayer are far simpler, in fact, than those required to take advantage of most of the averaging provisions that have thus far been enacted. Indeed, these computations turn out to be so simple that taxpayers in the income classes which now generally itemize deductions would have no difficulty in applying the cumulative assessment procedure as a normal routine rather than as an exceptional or optional procedure. This in itself is an important further simlification in that it removes from the taxpayer the burden of having to decide whether he should attempt to use the averaging provisions for any particular year.

Conceptually, cumulative assessment amounts to considering all previous payments on account of income tax on income reported for years included in the cumulation period as interest-bearing deposits in a tax guarantee account. The interest at an appropriate rate credited to this account during the last year plus the net taxable income from other sources for the current year are then added to the cumulative taxable income as of the previous year to get the cumulated taxable income for the period to date. The total tax due on this total income for the period is then obtained from a tax table appropriate to the number of years covered by the period, in exactly the same way as a tax is now computed for a single year. The tax currently due is the amount necessary to bring the balance in the tax guarantee account, including accrued interest, up to the level of this total tax due.

The actual computations required of the taxpayer in a typical case can be set out as follows for a taxpayer's 1974 return with an averaging period beginning with 1970, for example: ( ... ... )


다른 출처: William Vickrey, "Averaging of Income for Income-Tax Purposes," Journal of Political Economy 47, no. 3 (Jun., 1939): 379-397.

※ 발췌 (excerpt):

It has long been considered one of the principal defects of the gradual individual income tax that fluctuating incomes are, on the whole, subjected to much heavier tax burdens than incomes of comparable average magnitude which are relatively steady from year to year. ( ... ... )

Two notable attempts have been made to remedy this situation by the introduction of an averaging process. In the state of Wisconsin from 1928 to 1932 the state income tax was assessed on the basis of the average income for the last three years, with certain adjustments at the transition years. However, legal difficulties ( ... ... )

The Commonwealth of Australia in 1921 enacted a provision that the rate of tax to be applied to the income of the current year was to be determined by reference to an average of the income for the last five years. ( ... ... )

( ... ... )

다른 출처: Abu N. M. Wahid, Frontiers of Economics: Nobel Laureates of the Twentieth Century, ABC-CLIO, 2002.

※ 발췌 (excerpt):

( ... ... ) Vickrey contended that intertemporal tax neutrality can be achieved if tax authorities regard all tax payments, beginning with a given year, as interest bearing deposits with the treasury in the taxpayer's name. [:]
  • The accrued amount on this account would then be counted as a credit against the current assessed tax, based on the cumulated total income (including interest earned on the tax-deposit account) for the entire period to date
  • The current tax due would be the difference between this assessed cumulative tax and the accumulated balance on the taxpayer's account with the treasury
According to Vickrey, treating taxes paid as an interest-bearing account removes the incentive for taxpayers to vary the timing of realization or reporting of all forms of income.
Cumulative averaging methof of tax assessment is a noble innovation in the economics of taxation. ( ... ... )

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