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Haig–Simons income

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is necessary under an SHS tax because these expenditures are neither consumption nor additions to savings. Since business and investment outlays have no place in the base of either tax, intuition suggests that business and investment interest expenses would be treated identically under a cash-flow consumption tax and an SHS tax. But they are not. The SHS tax and the cash-flow consumption tax take different structural approaches to the treatment of business and investment interest outlays although both systems share the general objective of removing current business and investment costs from the tax base.
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complex cash-flow tax. See J. Clifton Fleming, Jr., Scoping Out the Uncertain Simplification (Complication?) Effects of VATs, BATs and Consumed Income Taxes, 2 Fla. Tax Rev. 390, 419-21 (1995). Thus, a cash-flow consumption tax is often understood as implying progressive rates. See Michael J. Graetz, Implementing a Progressive Consumption Tax, 92 Harv. L. Rev. 1575, 1579 (1979). Nevertheless, the cash-flow consumption tax examples in this article will all assume a flat-rate tax in order to simplify the analysis.
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and the Personal Consumption Tax, 35 Tax Law. 415, 416 (1982) at 416; Alvin C. Warren, Jr., Would a Consumption Tax Be Fairer Than an Income Tax?, 89 Yale L.J. 1081, 1084 (1980); U.S. Treas. Dep't, Blueprints for Basic Tax Reform 113-43 (1977), at 2, 113. "The income-versus-consumption tax debate is about the treatment of savings." Edward J. McCaffery, Tax Policy Under a Hybrid Income-Consumption Tax, 70 Tex. L. Rev. 1145, 1149-55 (1992) at 1155.
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not currently taxed since they were assessed in a prior year. Stated differently, the SHS tax base has two components—current consumption and current savings (including current appreciation accruing to earlier investments)—whereas a cash-flow consumption tax has only a single component—current consumption.
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Jerome Kurtz, The Interest Deduction Under Our Hybrid Tax System: Muddling Toward Accommodation, 50 Tax L. Rev. 153, 158-61 (1995) at 161; 1 U.S. Treas. Dep't, Tax Reform for Fairness, Simplicity and Economic Growth 191-93 (1984) at 191; ABA Section of Taxation Committee on Simplification, Complexity
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Some scholars resist these criticisms, to the extent they conceive of Haig–Simons as dependent on utility; Simons rejected utility as the basis of the ability-to-pay standard. Indeed, Simons rejected both the notion that humans are "equally efficient pleasure machines," and the idea that taxation can
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In spite of their differences, however, both a cash-flow consumption tax and an SHS tax require that dollars paid out as business or investment expenses be eliminated from the base. This is necessary under a cash-flow consumption tax because business and investment expenses are not consumption and it
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A flat-rate could be employed instead of progressive rates under a cash-flow tax. See Treasury I, supra note 1, at 191. But if a flat-rate consumption tax were desired, it would generally be much simpler to use a value added tax, which cannot practically employ progressive rates, instead of the more
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The Haig–Simons equation is different from the USA's individual income tax base calculations. For example, any employer contributions to employee health insurance are not included in taxable employee income. Under the Haig–Simons definition of income, such contributions would be included in income.
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See 1 U.S. Treas. Dep't, Tax Reform for Fairness, Simplicity and Economic Growth 191-93 (1984); U.S. Treas. Dep't, Blueprints for Basic Tax Reform 113-43 (1977). The leading explanation and defense of a cash-flow consumption tax is still William D. Andrews, A Consumption-Type or Cash Flow Personal
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By contrast, the base for a theoretically correct Schanz–Haig–Simons (SHS) income tax is each individual's annual consumption plus current additions to savings. Thus current receipts that are otherwise taxable remain in the tax base, even if they are saved, and withdrawals from earlier savings are
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is intended to confine the cash-flow tax burden to an individual's annual consumption and to remove nonconsumption expenses and current savings from the tax base. The base is calculated by combining the year's gross receipts and savings withdrawals, and then subtracting the year's business and
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take account of interpersonal utilities. Simons sought a measurable definition for income, but his solution is open to criticism for reifying troubling dichotomies; for example, the Haig–Simons definition depends on the distinction between market and non-market values.
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Alvin C. Warren, Jr., Accelerated Capital Recovery, Debt, and Tax Arbitrage, 38 Tax Law. 549, 557 (1985); Blueprints, supra note 1, at 3, 64, 133; Stanley S. Surrey, Pathways to Tax Reform 20-21, 259 (1973). See also Simons, supra note 5, at
116:"Personal income may be defined as "the algebraic sum of (1) the market value of rights exercised in consumption and (2) the change in the value of the store of property rights between the beginning and end of the period in question." 482:
See David F. Bradford, Untangling the Income Tax 94, 96 (1986); Blueprints, supra note 1, at 119-20; Andrews, supra note 1, at 1149, 1151. See also, Treasury I, supra note 1, at 191; ABA, Sec. of Tax'n, supra note 3, at
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See Joseph M. Dodge et al., Federal Income Tax: Doctrine, Structure and Policy 27, 33 (1995); William D. Andrews, A Consumption-Type or Cash Flow Personal Income Tax, 87 Harv. L. Rev. 1113 (1974) at 1116.
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See ABA Section of Taxation Committee on Simplification, Complexity and the Personal Consumption Tax, 35 Tax Law. 415, 416 (1982); U.S. Treas. Dep't, Blueprints for Basic Tax Reform 113-43 (1977) at 113,
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Haig defined personal income as "the money value of the net accretion to one's economic power between two points of time," a formulation that was intended to include the taxpayer's consumption.
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Such contributions might not be included in a Haig–Simons income tax base, however, if their exclusion reflected "an appropriate adjustment in measuring ability to pay."
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applies to purchases of goods and services on each level of exchange until it reaches the ultimate consumer. In the US, most states tax purchases of goods with a
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it is "little more than an accounting identity, a tautology: it tells us only that all income is either spent or not , which is obvious enough".
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The measure of the income tax base equal to the sum of consumption and change in net worth was first advocated by German legal scholar
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Consumption refers to the money spent on goods and services of any kind. From a perfect theory view, consumption does not include
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Overview of the Definition of Income Used by the Staff of the Joint Committee on Taxation in Distributional Analyses
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Nancy Staudt, The Political Economy of Taxation: A Critical Review of a Classic, 30 Law & SOC'Y REV. 651 (1996)
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In this concept, all inflows and outflows of resources are considered taxable income in a broad sense, including
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investment expenses and the year's additions to savings. Progressive rates are applied to the resulting sum.
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Henry C. Simons, Personal Income Taxation: The Definition Of Income As A Problem Of Fiscal Policy 50 (1938).
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Schanz, Georg von (1896). "Der Einkommensbegriff und die Einkommensteuergesetze".
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Personal Income Taxation: the Definition of Income as a Problem of Fiscal Policy
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See, e.g., Stephen Utz, Ability to Pay, 23 WHITTIER L. REV. 867, 915-17 (2002)
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Law in public finance studies: income as consumption plus change in net worth
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E.g., Tresch at 269; see also NICHOLAS KALDOR, AN EXPENDITURE TAX 53 (1955).
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That was thought by Simons to be interchangeable with his own formulation:
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Andrews, William D. (1972). "Personal Deductions in an Ideal Income Tax".
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Edward J. McCaffrey, Tax's Empire 85 GEO. L.J. 71, 77-82 (1996) at 78
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and most states in the USA employ a tax on Haig–Simons income with a
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RICHARD TRESCH, PUBLIC FINANCE: A NORMATIVE THEORY 267 (1981).
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Schoen, Wolfgang (2005). "Capital Gains Taxation in Germany".
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Some fault it for neutrality between savings and consumption.
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Others observe that it is "only a surrogate utility measure."
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Schanz–Haig–Simons income tax vs. cash-flow consumption tax
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to analyze economic well-being which defines income as
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SIMONS, PERSONAL INCOME TAXATION, supra note 1, at 11,
328:. New York: Columbia University Press. pp. 1–28. 95:. His concept was further developed by the American 606:(2). The Harvard Law Review Association: 309–385. 49:. It is represented by the mathematical formula: 345:. Chicago: University of Chicago Press. p.  242:Joint Committee on Taxation (February 8, 2012). 8: 444:Income Tax, 87 Harv. L. Rev. 1113 (1974). 234: 271:Washington Center for Equitable Growth 7: 265:Price, Carter C. (12 August 2014). 195:Some argue that the definition is 25: 79:, and the full spending would be 1: 37:is an income measure used by 191:Criticisms of the definition 179:. In the European Union, a 505:Rethinking Tax Expenditures 658: 360:Bittker, Boris I. (1967). 153:Tax on Haig–Simons income 138:cash-flow consumption tax 39:public finance economists 35:Schanz–Haig–Simons income 503:Shaviro, Daniel (2004). 320:Haig, Robert M. (1921). 106:in the 1920s and 1930s. 224:Flat tax on consumption 158:Tax on change in wealth 72:= change in net worth. 339:Simons, Henry (1938). 326:The Federal Income Tax 77:capital expenditures 68:= consumption and Δ 599:Harvard Law Review 412:British Tax Review 367:Harvard Law Review 167:Tax on consumption 31:Haig–Simons income 18:Haig-Simons income 16:(Redirected from 649: 623: 584: 579: 573: 570: 564: 561: 555: 552: 546: 543: 537: 534: 528: 525: 519: 518: 500: 494: 490: 484: 480: 474: 470: 464: 461: 455: 451: 445: 441: 435: 431: 425: 423: 407: 401: 398: 392: 391: 357: 351: 350: 336: 330: 329: 317: 311: 310: 288: 282: 281: 279: 277: 262: 256: 255: 253: 251: 239: 93:Georg von Schanz 21: 657: 656: 652: 651: 650: 648: 647: 646: 627: 626: 612:10.2307/1339894 595: 592: 590:Further reading 587: 580: 576: 571: 567: 562: 558: 553: 549: 544: 540: 535: 531: 526: 522: 515: 507:. p. 209. 502: 501: 497: 491: 487: 481: 477: 471: 467: 462: 458: 452: 448: 442: 438: 432: 428: 409: 408: 404: 399: 395: 380:10.2307/1339337 374:(5): 925–985 . 359: 358: 354: 338: 337: 333: 319: 318: 314: 290: 289: 285: 275: 273: 264: 263: 259: 249: 247: 241: 240: 236: 232: 220: 193: 181:value added tax 177:consumption tax 169: 160: 155: 134: 104:Henry C. Simons 89: 45:plus change in 28: 23: 22: 15: 12: 11: 5: 655: 653: 645: 644: 639: 629: 628: 625: 624: 591: 588: 586: 585: 574: 565: 556: 547: 538: 529: 520: 513: 495: 485: 475: 465: 456: 446: 436: 426: 414:(6): 620–627. 402: 393: 352: 331: 312: 283: 257: 233: 231: 228: 227: 226: 219: 216: 205: 204: 192: 189: 173:European Union 168: 165: 159: 156: 154: 151: 133: 130: 126:windfall gains 118: 117: 100:Robert M. Haig 88: 85: 62: 61: 26: 24: 14: 13: 10: 9: 6: 4: 3: 2: 654: 643: 640: 638: 635: 634: 632: 621: 617: 613: 609: 605: 601: 600: 594: 593: 589: 583: 578: 575: 569: 566: 560: 557: 551: 548: 542: 539: 533: 530: 524: 521: 516: 514:0-7167-8655-9 510: 506: 499: 496: 489: 486: 479: 476: 469: 466: 460: 457: 450: 447: 440: 437: 430: 427: 421: 417: 413: 406: 403: 397: 394: 389: 385: 381: 377: 373: 369: 368: 363: 356: 353: 348: 344: 343: 335: 332: 327: 323: 316: 313: 308: 304: 300: 296: 295: 287: 284: 272: 268: 261: 258: 250:September 13, 245: 238: 235: 229: 225: 222: 221: 217: 215: 211: 208: 202: 201: 200: 198: 190: 188: 186: 182: 178: 174: 166: 164: 157: 152: 150: 146: 142: 139: 131: 129: 127: 123: 115: 114: 113: 110: 107: 105: 101: 98: 94: 86: 84: 82: 78: 73: 71: 67: 60: 56: 52: 51: 50: 48: 44: 40: 36: 32: 19: 603: 597: 577: 568: 559: 550: 541: 532: 523: 504: 498: 488: 478: 468: 459: 449: 439: 429: 411: 405: 396: 371: 365: 355: 341: 334: 325: 315: 298: 294:FinanzArchiv 292: 286: 274:. Retrieved 270: 260: 248:. Retrieved 237: 212: 209: 206: 197:tautological 194: 170: 161: 147: 143: 135: 119: 111: 108: 90: 74: 69: 65: 63: 58: 54: 34: 30: 29: 424:See page 2. 43:consumption 631:Categories 230:References 97:economists 642:Equations 572:Id. at 5. 307:0015-2218 185:sales tax 122:donations 81:amortized 47:net worth 301:: 1–87. 246:(Report) 218:See also 620:1339894 420:1551347 388:1339337 276:12 July 87:History 637:Income 618:  511:  418:  386:  305:  64:where 616:JSTOR 384:JSTOR 509:ISBN 483:419. 434:135. 416:SSRN 303:ISSN 278:2017 252:2022 171:The 124:and 102:and 53:I = 608:doi 493:54. 376:doi 57:+ Δ 33:or 633:: 614:. 604:86 602:. 382:. 372:80 370:. 364:. 347:49 324:. 299:13 297:. 269:. 199:: 187:. 136:A 128:. 83:. 70:NW 59:NW 622:. 610:: 517:. 422:. 390:. 378:: 349:. 309:. 280:. 254:. 66:C 55:C 20:)

Index

Haig-Simons income
public finance economists
consumption
net worth
capital expenditures
amortized
Georg von Schanz
economists
Robert M. Haig
Henry C. Simons
donations
windfall gains
cash-flow consumption tax
European Union
consumption tax
value added tax
sales tax
tautological
Flat tax on consumption
Overview of the Definition of Income Used by the Staff of the Joint Committee on Taxation in Distributional Analyses
"Miscalculating the wealth of the rich reveals unintended biases"
FinanzArchiv
ISSN
0015-2218
"The Concept of Income—Economic and Legal Aspects"
Personal Income Taxation: the Definition of Income as a Problem of Fiscal Policy
49
"A 'Comprehensive Tax Base' as a Goal of Income Tax Reform"
Harvard Law Review
doi

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