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 Richmans' Trade and Taxes Blog

Border Adjustable Tax
Jesse Richman, 2/17/2017

The Tax Foundation has put out an analysis of the House Border Adjustable Tax plan.  This highlights some of the key elements of the plan, but may be incomplete in particular ways.  The full analysis is available here: 

They make a number of valuable points about the plan.  However, some of the arguments made depend upon assumptions which may not necessarily be relevant in the current situation. 

One key assumption is that trade is balanced (at least in the longish run).

"Both an origin-based tax and a destination-based tax are trade-neutral and switching from one to another does not impact the trade balance. This is because exports and imports are two sides of the same coin. Exports are needed to pay for imports and imports are the returns to exports. As such, taxing exports ends up reducing imports and taxing imports ends up reducing exports."

If trade is balanced, then of course this is right.  On the other hand, the US has run a remarkably robust trade deficit since the Carter administration -- four decades.  In the context of a situation in which trade is not balanced, it is worth thinking about the effects of the particular proposal.  The current corporate tax system taxes exports but not imports.  This will tend to discourage exports.  The proposed change will tax imports but not exports.  This will tend to discourage imports.  If one assumes that trade is balanced, then of course a border adjustable tax will have no effect on the trade balance.  But if in fact a country is running a trade deficit, switching the incidence of corporate taxation in a way that taxes imports instead of exports is a prudential measure likely to improve the trade balance.  It switches from a tax code that taxes exports to a tax code that taxes imports.  This is a VERY GOOD IDEA likely to improve the trade balance.

The paper makes a number of good points about the benefits of the proposal.  

"There are actually some non-economic advantages that may make the switch to a destination-based tax worthwhile. Paired with other aspects of a DBCFT, the border adjustment would make many strategies of profit shifting under current law impossible. It would also be possible to lift some of the complex anti-base erosion provisions that typically come with origin-based tax systems. Lastly, a border adjustment in a DBCFT raises a significant amount of revenue in the budget window, which can be used to finance other important reforms such as full expensing and lower marginal tax rates."

Under the current tax system, multinational corporations engage in extensive tax shifting and tax shelter strategies.  I would argue that the presence of these strategies is bad for the economy in multiple ways...


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Four Ways to Balance the Budget and Boost the Economy by Taxing Foreigners - we're published in American Thinker this morning
Howard Richman, 12/22/2016

In the American Thinker this morning, we suggest four tax changes that Congress could enact to balance the budget and boost the economy at the same time by taxing foreigners:

  1. Close the foreign savings tax loophole.
  2. Tax foreign dollar reserves.
  3. Integrate the corporate and personal income taxes.
  4. Impose trade balancing tariffs.

Our ballpark estimate is that these four proposals would bring the government $465 billion in tax revenue the first year. To read our commentary, go to:


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Real Income Tax Reform Is Taxing Corporate Earnings As Personal Income
Raymond Richman, 10/11/2016

Although tax reforms have been proposed by all candidates for President in the primaries, they all fall far short of what most economists would propose. It is not tax reform to impose a flat tax as Sen. Cruz and others have proposed or to eliminate the estate tax as a number of Republicans have recommended. The proposals would simply eliminate all progressivity from the tax system. The personal income tax and the estate tax are the only taxes that reduce income inequality and wealth inequality in a free market system. It is not tax reform to propose a value-added tax as Pres. Obama once briefly suggested and his rival Romney said he was considering it. The VA tax, widely used in the Euro community and promoted by the IMF for every country in the world is not appropriate for countries with a federal system of government. It is a sales tax and nearly every one of the States in the U.S. imposes a sales tax. Sales taxes should be left to the States.

Real reform must call for abolition of the corporate income tax and taxing corporate earnings as personal income under the personal income tax. None of the candidates for President have proposed doing so. Instead they propose reforms that are not real reforms at all. ...


Comments: 1

Only Modest Tax Reforms Are Needed to Get Domestic Industry Growing Again
Raymond Richman, 12/24/2015

John H. Cochrane, senior fellow of Stanford University’s Hoover Institution and formerly of the Booth School of Business at the University of Chicago, writing in and op-ed in the WSJ, 12-23-2015, entitled “Here’s What Genuine Tax Reform Looks Like” states that,  “The first goal of taxation is to raise needed government revenue with minimum economic damage.”  No, the first goal of taxation is to distribute the burden of taxation equitably, i.e., fairly. Minimizing economic damage is a very important goal.

Another important goal is adequacy to fund the functions of government without causing an undesirable level of inflation. Governments may impose fees and taxes based on the so-called benefit principle, such as court fees, charges to record transfers and ownership of property, and taxes on motor vehicles to finance the construction and maintenance of roads and bridges. Minimizing economic damage also includes avoiding excessive disincentives to work, invest, and save. There is nothing in Cochranes’ writing to indicate that he is an expert in the economics of public finance.

He prescribes a number of reforms, some of which I agree with. First and foremost is his proposal to abolish the corporate income tax. He is correct that “With no corporate tax, arguments disappear over investment expensing versus depreciation, repatriation of profits, too much tax deductible debt, R&D deductions, and the vast array of energy deductions and credits.” He does not conclude that corporate earnings should be taxed, instead, under the personal income tax, as I have proposed in recent publications.

Instead, he proposes that “government should tax consumption, not wages, income or wealth”, not inheritances, nor capital gains. Doing so, he argues, would eliminate the need for the “complex web of shelters”, including IRAs, health savings accounts, life insurance exemptions, and the “panoply of trusts that wealthy individuals use to shelter their wealth and escape the estate tax”. He would reduce the progressivity of the personal income tax, eliminate “All the various deductions, credits, and exclusions”....


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Tax Corporate Income as Personal Income -- we're published in today's American Thinker
Howard Richman, 2/10/2015

Here's how we begin:

Countries around the word have been gradually reducing their corporate income tax rates in order to gain a competitive advantage over their trading partners. Those with lower tax rates attract factories and corporate headquarters, while those with higher rates send factories and headquarters abroad. This trend has been gradually reducing the percentage of income paid by the rich while shifting the tax burden to the middle class.

Both Democrats and Republicans in Washington have put proposals on the table that would reduce the U.S. federal corporate income tax rate. Neither proposal is very good. Both proposals would leave the U.S. tax rate relatively high and would come with riders that would actively destroy U.S. jobs.

To read the rest, go to:


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The Corporate Income Tax Is the Worst Tax; Repeal It and Tax Corporate Earnings under the Personal Income Tax
Raymond Richman, 12/26/2014

There are taxes which treat taxpayers fairly, are progressive in their effects, and have few bad economic effects. The corporate income tax is not one of them. The corporate income tax treats taxpayers unfairly, favors the very rich, and has bad economic effects. It is probably the worst major tax, vastly inferior to the personal income tax, sales taxes, death taxes, or any other major source of revenue.

So who bears the burden of the corporate income tax? As an artificial entity, corporations cannot bear any corporate tax burden. Only living individuals bear the burden of taxation whether it be the corporate income tax, the personal income tax, sales taxes, or excise taxes. Economists are not sure who bears the burden of the corporate income tax. The most common view is that most of the tax is borne by shareholders but some of the tax is shifted forward to consumers in the form of higher prices. The amount shifted depends on the structure of the particular industry. A monopolist has more control over the prices it charges than those in a highly competitive industry or one where much of the productive activity is conducted by proprietorships and partnerships which are not subject to the corporate income tax. (And many economists believe that the corporate income tax is borne by investors in general in the form of higher interest rates and by some special classes of employees, but we’ll ignore that in our analysis.) So shareholders in some corporations bear all or most of the burden and shareholders in others may bear a lesser share of the burden. Consumers of some products may bear much of the burden and consumers of others little of the burden. These considerations make the distribution of the burden of the corporate income tax very uncertain which is one reason that makes it desirable to eliminate it and tax corporate earnings as personal income.

As to economic effects, the corporate income tax penalizes exporters and its high rates encourage inversions (moving corporate headquarters abroad) and outsourcing of factories and jobs. Facing international competition, American exporters have little or no ability to shift the tax burden and the high rate of corporate income tax places them at a disadvantage.



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Taxing Corporations As Partnerships Solves the Problems of Inversions and Outsourcing
Raymond Richman, 9/24/2014

Treasury Secretary Jacob Lew announced tightened tax rules to deter U.S. companies from moving their headquarters overseas to lower-tax countries, a practice called an inversion. Inversions sometimes take place to avoid paying taxes on the acquired company’s income which before the inversion paid taxes only to the country in which it has its headquarters. An inversion is not to be confused with outsourcing, the practice of closing factories and operations at home and manufacturing products and parts overseas. Outsourcing not only affects tax   revenue but it also causes massive unemployment here at home, and worsens our balance of trade. Inversions do not. Hardly any jobs have been lost by inversions in contrast with the loss of hundreds of thousands of jobs lost by outsourcing. Oddly, the administration has taken no action on outsourcing.

Nearly all the leading American corporations engage in outsourcing, including Apple, Nike, Honeywell, Caterpillar, Hewlett-Packard, Motorola, IBM, NCR, Lev-Strauss, and many, many others. Most, like Apple, add insult to injury by importing the products they produce overseas, worsening the U.S. trade balance. Inversions have little effect on employment and no effect on the trade balance. Why the Administration’s silence about outsourcing? One might hazard a guess. The Treasury Secretary’s silence perhaps can be explained by domestic politics.  Many of the corporations, their owners, and their trade associations contribute to the Democratic Party and the US chamber of Commerce and the National Association of Manufacturers officially espouse free trade.

As an illustrative case, take Burger King’s inversion with Jim Hortons of Canada. It does not reduce U.S. revenues at all from Burger King’s and Tim Hortons’ operations in the U.S. All the Burger Kings and Tim Hortons in the U.S. will continue to pay U.S. and state corporate income taxes. Admittedly, the movement of Burger King’s headquarters will cost the U.S. tax revenue and Canada will gain some. Canada’s top general corporate tax rate is 28 percent (but see below) compared with the U.S. 35 percent, so Burger King would stand to lose from the merger if Tim Hortons’ income were taxed at the U.S. 35 percent rate. The real culprit is a foolish U.S. income tax system.



Comments: 1

Tax Inversions and "Factoryless Manufacturers"
Jesse Richman, 8/28/2014

Likely without intending to, Greg Mankiw's recent piece advocating corporate tax reform in the NYT makes the critical argument against the creation of a 'factoryless goods manufacturer' category in our national accounting. Mankiw writes:

A main feature of the modern multinational corporation is that it is, truly, multinational. It has employees, customers and shareholders around the world. Its place of legal domicile is almost irrelevant. A good tax system would focus more on the economic fundamentals and less on the legal determination of a company’s headquarters.

If indeed the multinational corporation is in essence multi-stated or perhaps beyond any corporate state-affiliation, then it makes truly no sense at all to count some of the profits that corporation earns from its overseas activities as American manufacturing. Such corporations are, in Mankiw's logic not American. And the manufacturing clearly doesn't happen in America.


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Inversion Deals -- Corporate Income Tax Flight Continues
Jesse Richman, 8/26/2014

The United States has noncompetitive corporate income tax rates which create powerful incentives for US companies, aided by hedge funds and Wall Street banks, to flee the country.  A recent story in Forbes highlights the developing trend, and some of the key players in the effort to get Burger King a Canadian passport. 

The U.S. corporate income tax rate is politically hard to touch because people like the idea of taxing big money corporations at high rates.  But it is economically unsustainable, and needs to be significantly replaced by a VAT or some other tax that is less readily avoided. The move of even Burger King to abandon its U.S. corporate citizenship suggests just how important it is to break this political stalemate and reform the tax code. 

U.S. corporate tax rates are quite high compared with the rest of the world.  Canada's tax rate is 15 percent versus the U.S. rate of 35 percent, hence the attraction of a move north for Burger King.  

High corporate tax rates exacerbate the U.S. trade deficit in multiple ways.  For instance: 

1. They make it hard for truly U.S. corporations to compete internationally.  U.S. producers are at a disadvantage relative to foreign concerns paying less tax, and their products are correspondingly either less profitable or less price-competitive...  


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Abolish the Corporate Income Tax; Tax Corporations Like Partnerships
Raymond Richman, 8/12/2013

Both the Democrats and Republicans have proposed tax reforms. By and large, the Democratic proposals simply deny the rich deductions the remaining taxpayers can take. Republicans on the other hand appear to be opposed to any but consumption taxes. Neither party seems to be aware that over the centuries economists have developed a set of principles of taxation to aid in determining what tax is best to finance a given set and level of expenditures.

Some accepted principles of taxation are the following:

  1. In selecting a tax, the cost of administration and compliance should be taken into account.
  2. Classes of taxpayers who receive specific benefits from government expenditures should ordinarily be charged for such services, e.g., this justifies registration fees for real estate and motor vehicles, and court costs of private litigation, taxes on motor fuels to pay the cost of building and maintaining roads and bridges, etc.
  3. Taxpayers in equal circumstances should be taxed equally.
  4. The economic effects of a tax must be taken into consideration, with the negative effects of taxes minimized.
  5. The tax burden should be distributed progressively subject to the qualification that the social benefits of reduced inequality of income should at the margin never exceed the costs of diminished incentives to save and invest.

Here is what the Democratic proposals look like. According to the Center for American Progress, a self-described progressive group, the President has proposed that the 2014 federal budget include:...


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A Proposal for a New Federal Tax Code Abolishing the Corporate Income Tax
Raymond Richman, 7/3/2013

Recently, in this space 5/23/13, we pointed out the urgent need for tax reform and proposed limiting the IRS to an income tax on wages and salaries. We proposed abolition of the corporate income tax and replacing it with a tax on the market value of corporations. Since then we have reconsidered our proposal and we want to share with you our thoughts about what tax reform is needed and the present status of the reform we are proposing.       

The history of the modern income tax is often traced to Pitt’s British income tax of 1798 which fell short of achieving its targeted revenue, the shortage being made up by voluntary contributions. But the succeeding Income and Property Tax Act of 1803 was a success. It was simply a reenactment of Britain’s Income and Property Taxes that date back to William of Orange at the end of the 17th century and even earlier to the taxes under the Tudors. What they all had in common was that they had different treatments of income from different sources. We’re suggesting something similar, taxing income from wages, salaries, and bonuses more or less as they are currently taxed but taxing corporations by a tax on the market value of shares of the corporation. They would be two schedules of a single tax. Briefly, what we are proposing is to abolish the corporate income tax and taxes on dividends and capital gains and replace them with a tax based on the market value of the corporation’s outstanding shares and in another schedule we would tax wages and salaries, interest income, and the income of unincorporated businesses, including partnerships not listed on the stock exchanges and proprietorships. The taxation of real estate would be in a third schedule and the revenue reserved to the states in which such real estate is located.


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Palin calls for elimination of corporate income tax
Howard Richman, 9/6/2011

In her speech in Iowa on September 3, which you can watch above, Governor Sarah Palin called for the complete elimination of the U.S. corporate income tax as a way to create jobs. She correctly pointed out that the corporate income tax sends American jobs abroad and that eliminating the tax would cause investment in America to surge.

At the same time that she would eliminate the corporate income tax, she would end corporate bailouts, corporate welfare and tax loopholes. She would do so partly as an anti-corruption measure. She argues that Obama is growing a corrupt system of "crony capitalism" in the United States.

She is correct about the self-destructive nature of the corporate income tax. We summarized the disadvantages of that tax with the following four points in our 2008 book Trading Away Our Future:...


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Milken Institute: Cutting Corporate Income Tax would raise GDP
Howard Richman, 1/31/2010

On January 26, the Milken Institute issued a research report entitled Jobs for America: Investments and Policies for Economic Growth and Competitiveness. They analyzed several proposals for enhancing the American economy, and concluded:

• Reducing U.S. corporate income tax rates to the current average of OECD countries (from the current 35 percent to 22 percent) stimulates growth. By 2019, real GDP rises by 2.2 percent (or $375.55 billion) and 2.13 million jobs are created.

• Increasing the R&D tax credit by 25 percent and making it permanent enhances American innovation. By 2019, real GDP rises by 1.2 percent (or $206.3 billion) and 316,000 manufacturing jobs are created.

• Modernizing export controls on commercially available technology products for some countries would allow U.S. firms to capture increased international market share. In this scenario, real exports of goods and services rise by 1.9 percent (or $56.6 billion), and 340,000 jobs are added by 2019 (160,000 of them in the manufacturing sector).

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  • [An] extensive argument for balanced trade, and a program to achieve balanced trade is presented in Trading Away Our Future, by Raymond Richman, Howard Richman and Jesse Richman. “A minimum standard for ensuring that trade does benefit all is that trade should be relatively in balance.” [Balanced Trade entry]

    Journal of Economic Literature:

  • [Trading Away Our Future] Examines the costs and benefits of U.S. trade and tax policies. Discusses why trade deficits matter; root of the trade deficit; the “ostrich” and “eagles” attitudes; how to balance trade; taxation of capital gains; the real estate tax; the corporate income tax; solving the low savings problem; how to protect one’s assets; and a program for a strong America....

    Atlantic Economic Journal:

  • In Trading Away Our Future   Richman ... advocates the immediate adoption of a set of public policy proposal designed to reduce the trade deficit and increase domestic savings.... the set of public policy proposals is a wake-up call... [February 17, 2009 review by T.H. Cate]