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The Pitfalls of International Integration: A Comment on the Bush Proposal and Its Aftermath

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  • Reuven Avi-Yonah

    (University of Michigan)

Abstract

In January 2003, the Bus Administration proposed a new system for taxing corporate dividends, under which domestic shareholders in U.S. corporations would not be taxed on dividends they received, provided the corporation distributed these dividends out of after-tax earnings (the "Bush Proposal"). The Bush Proposal was introduced in Congress in February 27,2003. Ultimately, however, Congress balked at enacting full-fledged dividend exemption. Instead, in the Jobs and Growth Tax Relief Reconciliation Act of 2003 ("JGTRRA") as enacted on May 28, 2003, a lower rate of 15% was adopted for dividends paid by domestic and certain foreign corporations, and the capital gains rate was likewise reduced to 15%. Significantly, and in stark contrast to the original Bush proposal, under JGTRRA the lower ate for dividends and capital gains does not depend on any tax being paid at the corporate level. This comment will focus primarily on the international aspects of both the Bush Proposal and JGTRRA. I will not lay out the proposal or the law in any detail. Instead, I will ask whether either the Bush Proposal or JGTRRA make sense from an economic efficiency perspective when the international implications are taken into account. I will leave to others the question of whether either the Bush Proposal or JGTRRA are sensible ways to stimulate the economy (for discussion for the effect of the 2001 tax cuts see Shapiro and Slemrod, 2001,2002). I will also omit ay discussion of the distributive effects of either the Bush Proposal or JGTRRA, which have been extensively discussed elsewhere (e.g. Tax Policy Center, 2003; Burman, Gale and Orszag, 2003

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  • Reuven Avi-Yonah, "undated". "The Pitfalls of International Integration: A Comment on the Bush Proposal and Its Aftermath," University of Michigan John M. Olin Center for Law & Economics Working Paper Series umichlwps-1007, University of Michigan John M. Olin Center for Law & Economics.
    • Handle: RePEc:bep:uomlwp:umichlwps-1007
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    References listed on IDEAS

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    1. Desai, Mihir A. & Hines, James R. Jr., 2003. "Evaluating International Tax Reform," National Tax Journal, National Tax Association;National Tax Journal, vol. 56(3), pages 487-502, September.
    2. Boadway, Robin & Bruce, Neil, 1992. "Problems with integrating corporate and personal income taxes in an open economy," Journal of Public Economics, Elsevier, vol. 48(1), pages 39-66, June.
    3. Matthew D. Shapiro & Joel Slemrod, 2003. "Did the 2001 Tax Rebate Stimulate Spending? Evidence from Taxpayer Surveys," NBER Chapters, in: Tax Policy and the Economy, Volume 17, pages 83-110, National Bureau of Economic Research, Inc.
    4. Clemens Fuest & Bernd Huber, 2000. "The Optimal Taxation of Dividends in a Small Open Economy," CESifo Working Paper Series 348, CESifo.
    5. Mutti, John & Grubert, Harry, 1985. "The taxation of capital income in an open economy: the importance of resident-nonresident tax treatment," Journal of Public Economics, Elsevier, vol. 27(3), pages 291-309, August.
    6. Fullerton, Don & Metcalf, Gilbert E., 2002. "Tax incidence," Handbook of Public Economics, in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 4, chapter 26, pages 1787-1872, Elsevier.
    7. Austan Goolsbee, 2002. "The Impact and Inefficiency of the Corporate Income Tax: Evidence from State Organizational Form Data," NBER Working Papers 9141, National Bureau of Economic Research, Inc.
    8. Grieson, Ronald E., 1975. "The incidence of profits taxes in a neo-classical growth model," Journal of Public Economics, Elsevier, vol. 4(1), pages 75-85, February.
    9. Grubert, Harry & Mutti, John, 1994. "International Aspects of Corporate Tax Integration: The Contrasting Role of Debt and Equity Flows," National Tax Journal, National Tax Association;National Tax Journal, vol. 47(1), pages 111-133, March.
    10. Arnold C. Harberger, 1962. "The Incidence of the Corporation Income Tax," Journal of Political Economy, University of Chicago Press, vol. 70(3), pages 215-215.
    11. Grubert, Harry & Mutti, John, 1994. "International Aspects of Corporate Tax Integration: The Contrasting Role of Debt and Equity Flows," National Tax Journal, National Tax Association, vol. 47(1), pages 111-33, March.
    12. Martin S. Feldstein, 1974. "Tax Incidence in a Growing Economy with Variable Factor Supply," The Quarterly Journal of Economics, President and Fellows of Harvard College, vol. 88(4), pages 551-573.
    13. Martin Feldstein, 1974. "Incidence of a Capital Income Tax in a Growing Economy with Variable Savings Rates," The Review of Economic Studies, Review of Economic Studies Ltd, vol. 41(4), pages 505-513.
    14. Matthew D. Shapiro & Joel Slemrod, 2003. "Consumer Response to Tax Rebates," American Economic Review, American Economic Association, vol. 93(1), pages 381-396, March.
    15. Bradford, David F., 1981. "The incidence and allocation effects of a tax on corporate distributions," Journal of Public Economics, Elsevier, vol. 15(1), pages 1-22, February.
    16. Gravelle, Jane G & Kotlikoff, Laurence J, 1989. "The Incidence and Efficiency Costs of Corporate Taxation When Corporate and Noncorporate Firms Produce the Same Good," Journal of Political Economy, University of Chicago Press, vol. 97(4), pages 749-780, August.
    17. Stiglitz, Joseph E., 1973. "Taxation, corporate financial policy, and the cost of capital," Journal of Public Economics, Elsevier, vol. 2(1), pages 1-34, February.
    18. Homma, Masaaki, 1981. "A dynamic analysis of the differential incidence of capital and labour taxes in a two-class economy," Journal of Public Economics, Elsevier, vol. 15(3), pages 363-378, June.
    19. Casey B. Mulligan, 2002. "Capital Tax Incidence: First Impressions from the Time Series," NBER Working Papers 9374, National Bureau of Economic Research, Inc.
    20. Judd, Kenneth L., 1985. "Redistributive taxation in a simple perfect foresight model," Journal of Public Economics, Elsevier, vol. 28(1), pages 59-83, October.
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    Cited by:

    1. R. Hubbard, 2005. "Economic Effects of the 2003 Partial Integration Proposal in the United States," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 12(1), pages 97-108, January.

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