Big Business Share of Federal Taxes Lowest Since 2011

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By Jonathan Nicholson

Nov. 25 — U.S. taxes on big business made up less than 10 percent of overall federal revenue in 2016, their lowest level since 2011, potentially raising questions about the effort to overhaul the complex corporate tax system ahead.

Prospects for a tax revamp received a boost from the election of Donald Trump, as the issue is a high priority for congressional Republicans who have awaited a GOP White House to push for an overhaul. In the past, efforts have often foundered on divisions over whether a revamp should be phased in, with changes for individuals and companies made separately, and a rivalry between large corporations focused on easing international taxation eased and smaller domestic businesses who pay taxes at individual tax rates, so-called pass-through entities.

According to Treasury Department data, corporate tax revenue totaled $299.6 billion in fiscal year 2016, which ended Sept. 30, while overall revenue amounted to $3.267 trillion, making the share of revenue 9.17 percent, by Bloomberg BNA calculations. That was down from 10.58 percent in fiscal 2015 and the lowest since 7.86 percent in fiscal 2011.

Third-Largest Source

Historically, corporate tax receipts have been only the third-largest source of income for the government, trailing well behind individual income taxes and payroll taxes for Social Security and Medicare. However, they can vary widely as a share of revenue, depending on the health of the economy, companies’ bottom lines and the tax code. In 2009, they fell to 6.57 percent, reflecting the impact of the 2007-09 recession. On the other hand, in 2006, they hit 14.70 percent, the highest since the late 1970s.

The Treasury figures have a significant limitation, though: they count only taxes paid by C corporations, traditional large companies that are usually publicly traded and subject to federal accounting oversight. They don’t count taxes from businesses organized as passthroughs that pay taxes at individual rates, such as S corporations, limited liability corporations and partnerships—and those make up more than half of U.S. business income, some estimates show.

Matthew Gardner, a senior fellow with liberal-leaning Center for Tax Justice, said the Treasury data showing the focus on the 35 percent tax rate for C corporations in the tax overhaul debate is misguided. While Trump on the campaign trail pointed to the rate as evidence the U.S. tax system isn’t competitive internationally, Gardner said the declining share of federal taxes paid by C corporations and their ability to often avoid taxes by shifting assets on paper overseas show that the more important rate is the effective tax rate for all businesses, not the statutory rate.

“It say particularly clearly that the statutory tax rate is not really the rate that matters,” Gardner said. “There’s a huge gap between what they ought to be paying and what they are paying.”

$100 Billion Lost Revenue?

“Business in the United States: Who Owns It and How Much Tax Do They Pay?”—a paper published in September as part of the National Bureau for Economic Research’s “Tax Policy and the Economy” book series—estimated the rise in non-C corporations since the 1980s meant the overall federal tax rate on all types U.S. taxable businesses was 24.3 percent in 2011. That included an estimated 15.9 percent average tax rate on partnerships, a 25 percent rate on S corporations, a 13.6 percent tax rate on sole proprietorships as well as a 31.6 percent rate on C corporations, and was adjusted for the share of each type of company in the business sector.

“We estimate that, if 2011 business income had instead been earned along 1980-sector income shares, the average tax rate on US business income would have been 28.0%. Total business income in 2011 was $2.6 trillion, so an additional 3.8 percentage points would have generated an additional $100 billion in tax revenue,” wrote the authors, who included five Treasury Department staffers, two professors from the University of Chicago and an assistant professor from the University of California at Berkeley.

The trajectory of C corporate tax receipts is projected to continue downward. While they were almost 23 percent of federal revenue in 1966, the nonpartisan Congressional Budget Office projects them to fall to about 8.5 percent by 2026.

Shift in Feasibilty

Joseph Rosenberg, a senior research associate with the centrist Urban-Brookings Tax Policy Center at the Urban Institute, said the decline was due not only to the shift away from organizing as C corporations, but also to the ability of multinational companies to shift profits outside the U.S. and legislative changes, such as making some previously temporary tax breaks permanent.

“There has been a shift in terms of the feasibility of how you tax multinationals, where capital is increasingly mobile, globally speaking,” Rosenberg said.

Whether the U.S. should continue its effort to tax business profits globally or instead move to a more territorial system is one of the central questions in the corporate tax overhaul debate. But neither Rosenberg or Gardner said resolving that long-running debate would necessarily increase collections.

“You need to make changes in how we tax,” Rosenberg said. “The policies need to adapt to shifting realities.”

Gardner said a more pure form of a worldwide taxation would help with future revenue, but do little to resolve the question of profits that companies are now holding offshore in hopes of bringing home should U.S. lawmakers agree to tax them at a rate lower than the current 35 percent. “A move to worldwide would shut the barn door,” he said.

Gardner said C corporations’ ability to lower their tax bills by shifting assets means the tax burden is being shifted away from them over the long term. “Every million dollars that C corporations avoid is $1 million someone else will have to pay,” he said.

To contact the reporter on this story: Jonathan Nicholson in Washington at jnicholson@bna.com

To contact the editor responsible for this story: Paul Hendrie at pHendrie@bna.com

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