Updated October 2017
When most of us think of American corporate taxes, we often recall Corporate America's whinging about the 35 percent headline tax rate and how punitive it is to their businesses. Critics of the current corporate tax rate base much of their anti-35-percent argument on the fact that corporations are double-taxed; first paying the 35 percent rate and then, through their shareholders, paying up to 23.8 percent on both dividends and capital gains. A recent study by Steve Rosenthal and Lydia Austin at the Tax Policy Center finds that this argument is not based on reality.
When most of us think of American corporate taxes, we often recall Corporate America's whinging about the 35 percent headline tax rate and how punitive it is to their businesses. Critics of the current corporate tax rate base much of their anti-35-percent argument on the fact that corporations are double-taxed; first paying the 35 percent rate and then, through their shareholders, paying up to 23.8 percent on both dividends and capital gains. A recent study by Steve Rosenthal and Lydia Austin at the Tax Policy Center finds that this argument is not based on reality.
The study by Rosenthal and Austin suggest that the anticipated
increase in revenue may not be as substantial as expected for one key reason;
how America investors hold their equity investments compared to how they held equities in the past. When just using
Federal Reserve Flow of Funds data, it appears that households own a substantial portion of
the outstanding shares issued by U.S. corporations; in 2015, households
directly owned 37.3 percent of corporate equity and an additional 13 percent
indirectly through mutual funds for a total of 50.3 percent. Other
sources suggest that household equity ownership ranges from 44 percent to 68
percent. The authors suggest that the Federal Reserve's household share
ownership measurement is too broad and greatly overestimates the ownership of
U.S. stock in taxable accounts, a more meaningful measure. To
gain a more meaningful ownership level, the authors adjusted the Fed's data as
follows:
1.) Excluded foreign
equity held by U.S. residents.
2.) Measured only the
stock of corporations that are separately taxable under subchapter C and
ignored passthrough corporations like mutual funds, ETFs, CEFs and real estate
investment trusts.
These two steps isolate
the corporations that are subject to U.S. taxes and are potentially subjected
to double taxation.
3.) Excluded stock held
by non-profits.
4.) Excluded stocks held
by IRAs.
5.) Added back stock that
taxable individuals held beneficially through mutual funds, ETFs and CEFs (i.e.
the underlying portfolios of these passthrough corporations).
Step 5 combines indirect
ownership with direct ownership by taxable accounts.
Here is a table showing
the end result of their calculations:
In 2015, the outstanding
value of U.S. corporate stock was $22.8 trillion
Now, the authors
calculate what portion of the $22.8 trillion in U.S. corporate stock was held
inside and outside of taxable accounts as well as removing stock held by foreigners, pensions and non-profits as shown on this table:
In 2015, the total
holdings of taxable corporate stock held by U.S. taxpayers was $5.525 trillion
or 24.2 percent of the total outstanding value of U.S. corporate stock.
Now that we have the data
for 2015, let's take a journey back in time. Looking back to 1965, the
authors found that the percentage of U.S. corporate stock held inside of
retirement plans (both defined benefit and defined contribution pension plans
as well as IRAs) has grown substantially from around 5 percent in 1965 to 37
percent in 2015 as shown on this graph:
In addition to growing
stock ownership in tax-sheltered plans, ownership of U.S. corporate shares by
foreigners in both portfolios and direct investments has risen from 5 to 6
percent in 1982 to 21 to 26 percent in 2015 as shown on this graph:
Putting all of the data
together, the authors derived this graphic solution:
Over the last five
decades, U.S. corporate stock held in individual taxable accounts has fallen
from 83.6 percent in 1965 to 24.2 percent in 2015.
As you can see from this
research, there has been a substantial erosion in the taxable shareholder base.
Individuals are simply increasingly choosing to hold their
equity investments inside a tax-sheltered vehicle. This means that any proposals
to increase federal tax revenues by increasing taxes on both dividends and
capital gains may well be moot. It also means that any proposals to
reduce the so-called double-taxation on corporate earnings must take
into account the fact that a very substantial and increasing portion of U.S. stock is already outside
the grasp of the Internal Revenue Service.
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