Tag Archives: Greg Mankiw

Carried Interest and Your Private Sweat Equity

30 Saturday Dec 2017

Posted by in Central Planning, Taxes

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Suppose your rich uncle buys an old house to do some fix-ups and hopes to resell it at a gain. He has the cash and is willing to split the profit 50-50 if you’re willing to handle a few restorations over the next year. Even better, under the partnership he’ll form with you, your profit will be taxed as a pass-through capital gain. You’ll be taxed at only 15% (or 20% if your income is already very high). You’ll provide the labor, but your cut won’t be taxed at ordinary income tax rates.

That’s Just Like Carried Interest

A similar example is provided by Greg Mankiw, along with several others, to illustrate the ambiguity of “capital gains” under our tax law. What might surprise you is that the tax treatment of the deal with your uncle is exactly the same as the tax benefit received by the general partner (GP) in a private equity fund. The GP is the “worker”, as it were, who manages the capital paid-in by the fund’s investors (or limited partners). The GP attempts to build the fund’s value in various ways. The investors, on the other hand, take the same role as your uncle. The GP earns fees as a cut of the investment gains; those fees are essentially treated as capital gains for tax purposes. In the case of the private equity GP, however, the income is called “carried interest”, but there is no real difference.

The tax treatment of carried interest has been a target of progressives and populist critics for many years. This article in The Hill derides the GOP’s failure to close the carried interest “loophole” in the Tax Cut and Jobs Act (TCJA) recently signed into law by President Trump. Of course, wealthy private-equity players have sought to protect the rule with generous campaign contributions to key politicians. However, as illustrated by the partnership with your uncle, pass-through business taxation combined with the treatment of capital gains provides the same benefits to any business-person who invests “sweat equity” into the improvement of an asset for ultimate resale, including the business itself.

Should “sweat equity” earned by a worker be taxed more lightly than the direct receipt of “sweat wages”? The worker does not “own” the asset in question prior to the work effort, a fundamental distinction from what we normally consider to be a capital gain. On the other hand, the worker shoulders risk that the asset’s value will fail to meet expectations. My view is that it is not appropriate for the tradeoff between private risk and return to be managed via the income tax code or by government generally. Nevertheless, the sweat-equity conversion of labor value into asset appreciation is treated by tax law as a capital gain and is taxed at a lower rate than wages (except at low levels of taxable income).

Equal Protection Under the Tax Law

The carried interest rule and relatively “light” taxation of returns on capital are not at the root of the problem here. Rather, it is the disparate treatment of different kinds of income for tax purposes and the high taxation of ordinary income, even in the wake of the the TCJA’s passage. Diane Furchtgott-Roth argues that the low carried-interest tax rate is necessary to encourage productive investment. Peter Wayrich agrees, but again, that is not a good rationale for disparate (and high) taxation of labor income. This note in the Economic Policy Journal contains a quote on Senator Ron Johnson’s proposal to tax all productive entities at the 20% carried-interest tax rate. The potential loss of revenue might require a higher rate, but the proposition that rates should be equal across all forms of business organizations is more sensible than the complex changes promulgated for pass-throughs under the TCJA. Moreover, the progressive premise that tax rates on capital income should be high is a prescription for low rates of saving, a diminished pool of investment capital, and ultimately low growth in labor productivity and wages.

Demonizing Private Equity

The private equity business is criticized for reasons other than carried interest, but mainly due to superstition that these firms routinely engage in plundering healthy enterprises to extract value and victimize helpless employees by reducing wages or leaving them without work. Simple economics reveals the shallow thinking underlying such claims. As a first approximation, private equity can be profitable only when target firms are under-performing or undervalued. A healthy market for business ownership is necessary to ensure that firms with untapped value survive. Weak performance might stem from any number of circumstances but must be addressable under new management. That includes a management shakeup itself, and it could include a capital infusion to upgrade facilities, elimination of unprofitable product lines, a spin-off from a neglectful parent company, or wage renegotiation to improve competitiveness (but never ask a leftist if wages are too high, even as the employer fails).

Interest Deductibility

The tax benefits of carried interest enhance private equity deals relative to traditional merger and acquisition activity. Again, that illustrates the oddity of having different tax rules for different firms. In the past, the gains from carried interest have been magnified by another unfortunate aspect of the tax code: the interest-deductibility of business debt. The TCJA doesn’t completely eliminate this economic peculiarity, but it places a severe restriction on its use (see #6 on the list at the link).

In general, interest deductibility has favored the use of debt in the capital structures of all businesses. That leverage increases financial risk and bids up the level of interest rates faced by all borrowers. Private equity firms have made liberal use of debt in structuring buyouts. Their borrowing capacity combined with carried interest and the debt subsidy has undoubtedly made deals more attractive at the margin.

The new restriction on interest deductibility is likely to reinforce an existing trend in private equity: gradually, GPs have been putting more “skin in the game“. That is, they are risking a bit more of their own capital. That is generally a good thing for investors. The article at the last link was written in March 2017, so the data shown for 2017 is almost meaningless. In 2016, however, the average GP commitment as a percentage of fund size was still less than 8% and the median was just 4%. These percentages should continue to increase with competition for deals and more restricted deductibility of interest expense.

Taxes and Value

If you want to encourage value-maximizing behavior, then don’t tax its makers (or its markers) heavily. Carried interest extends the tax treatment of “sweat equity” to those who “police” the private sector for unexploited value: private equity firms. By eliminating waste, resuscitating formerly productive enterprises, and exploiting new profit opportunities, their efforts are socially accretive. The popular narrative of an “evil” and “vulturous” private equity industry is both misleading and destructive. Beyond that, there is no reason to tax different forms of productive activity at different rates, but we do. The TCJA has lessened the tax disparities to some extent, but more equalization should be a priority. At least the business interest deduction has been restricted, which should lessen the artificial reliance on borrowed capital.

Labor Shares the Burden of the Corporate Income Tax

03 Friday Nov 2017

Posted by in Taxes

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As expected, a reduction of the corporate income tax rate from 35% to 20% is included in the GOP’s tax reform bill, a summary of which was released today. That rate cut would be a welcome development for workers, consumers, and corporate shareholders. It should be no surprise that the burden of the U.S. corporate income tax is not borne exclusively by owners of capital. In fact, it might hurt workers and consumers substantially while imposing relatively little burden on shareholders.

John Cochrane’s post on the incidence of the tax on corporate income is very interesting, though by turns it rambles and may be too technical for some tastes. He notes that the incidence of the corporate tax can fall on only three different groups: shareholders, workers and customers:

“As an accounting matter, every cent [of taxes] corporations pay comes from higher prices, lower wages, or lower payments to shareholders. The only question is which one.“

Cochrane quotes Lawrence Summers and Paul Krugman, both of whom are of the belief that the incidence of the corporate tax must fall primarily on capital and not on labor. That’s consistent with their view that a reduction in corporate taxes amounts to a gift to shareholders. But Cochrane isn’t at all convinced:

“The usual principle is that he or she bears the burden who can’t get out of the way. So, how much room do companies, as a whole, have to raise prices, lower wages, lower interest payments, or lower dividends?”

In fact, owners of capital can get out of the way. Capital is very mobile relative to labor. Here’s a counterfactual exercise Cochrane steps through in order to illustrate the implications of ownership bearing the incidence of the tax: if equity markets are efficient, share prices reflect all available information about the firm. If wages and product prices are unchanged after the imposition of the tax, then shareholders would suffer an immediate loss. Once the tax is discounted into share prices, there would be no further impact on current or future shareholders. Thus, future buyers of shares would escape the tax burden entirely. As a first approximation, the share price must fall to the point at which the ongoing return on the stock is restored to its value prior to imposition of the tax.

Cochrane notes that evidence on the reaction of stock prices to corporate tax changes is mixed at best, which implies that the incidence of corporate taxation falls more weakly on shareholders than many believe. That leaves consumers or workers to bear a significant part of the burden. Workers and consumers are mostly one and the same: economy-wide, higher prices mean lower real wages; lower wages also mean lower real wages. So I’ll continue to speak as if the incidence of the tax falls on either labor or capital, and we can leave aside consumers as a separate category. Cochrane says:

“It used to be thought that it was easy to lower payments to shareholders — ‘the supply of savings is inelastic’ — so that’s where the tax would come from. The newer consensus is that companies as a whole have very little power to pay less to investors, … so the corporate tax comes from lower wages or, equivalently, higher prices. Then, indirectly, reducing the corporate tax would increase capital, which would result in higher wages.”

Cochrane’s post and another on his blog were prompted by an earlier piece by Greg Mankiw showing that real wages, in an open economy, will have a strong negative response to a corporate tax increase. Here is the reasoning: the tax reduces the return earned from invested capital in the short run. Ideally, capital is deployed only up to the point at which its return no longer exceeds the opportunity cost needed to attract it. Given time to adjust, less capital must be deployed after the imposition of the tax in order to force the return on a marginal unit of capital back up to the given opportunity cost. That means less capital deployed per worker, and that, in turn, reduces labor productivity and wages.

Another issue addressed by Cochrane has to do with assertions that monopoly power in the corporate sector is a good rationale for a high tax on corporate income. You can easily convince me that the “average” firm in the corporate sector earns a positive margin over marginal cost. However, a microeconomic analysis of monopoly behavior by the entire corporate sector would be awkward, to say the least. Despite all that, Cochrane notes that monopolists have more power than firms in competitive sectors to raise prices, and monopsonists have more power to reduce wages. Therefore, the “tax the monopolists” line of argument does not suggest that labor will avoid a significant burden of a corporate tax. A safer bet is that firms in the U.S. corporate sector are price-takers in capital markets, but to some degree may be price-makers in product and labor markets.

Cochrane also emphasizes the inefficiency of the corporate tax as a redistributional mechanism, even if shareholders bear a significant share of its burden. It is still likely to harm workers via lost productivity, as discussed above. It is also true that many workers hold corporate equities in their retirement funds, so a corporate tax harms them directly in their dual role as owners of capital.

The cut in the corporate tax rate is but one element of many in the GOP bill, but a related provision is that so-called “pass-through” income, of the type earned via many privately-owned businesses, would be taxed at a maximum rate of 25%. These businesses generate more income than C-corporations. Currently, pass-through income is taxed as ordinary income, so capping the top rate at 25% represents a very large tax cut. As Alex Tabarrok points out at the last link, tax treatment should be neutral with respect to the form of business organization, but under the GOP bill, the effective gap between the top rate for pass-throughs versus corporate income would be even larger than it is now.

Critics of a reduction in corporate taxes should bear in mind that its incidence falls at least partly on labor, perhaps mainly on labor. The U.S. has the highest corporate tax rate in the industrialized world. That undermines U.S. competitiveness, as does the complexity of corporate tax rules. Tax planning and compliance burn up massive resources while drastically reducing the tax “take”, i.e., the revenue actually collected. The corporate income tax is something of a “show” tax that exists to appease populist and leftist elements in the electorate who consistently fail to recognize the unexpectedly nasty consequences of their own advocacy.

 

The Taxing Logic of Carbon Cost Guesswork

11 Saturday Mar 2017

Posted by in Environment, Taxes, Uncategorized

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An article by three prominent economists* in the New York Times this week summarized the Climate Leadership Council’s Conservative Case for Climate Action“. The “four pillars” of this climate plan include (1) a revenue-neutral tax on carbon emissions, which are used to fund… (2) quarterly “carbon dividend” payments to all Americans; (3) border tax adjustments to account for carbon emissions and carbon taxes abroad; (4) eliminating all other regulations on emissions of carbon. The “Case” is thus a shift from traditional environmental regulation to a policy based on tax incentives, then wrapped around a redistributive universal income mechanism.

I’ll dispense with the latter “feature” by referencing my recent post on the universal basic income: bad idea! The economists advocate for the carbon dividend sincerely, but also perhaps as a political inducement to the left and confused centrists.

The Limits of Our Knowledge

The most interesting aspect of the “Case” is how it demonstrates uncertainty around the wisdom of carbon restrictions of any kind: traditional regulations, market-oriented trading, or tax incentives. Those all involve assumptions about the extent to which carbon emissions should be restricted, and it’s not clear that any one form of restriction is more ham-handed than another. Traditional regulation may restrict output in various ways. For example, standards on fuel efficiency are an indirect way of restricting output. A carbon market, with private trading in assigned “rights” to emit carbon, is more economically efficient in the sense that a tradeoff is involved for any decision having carbon implications at the margin. However, the establishment of a carbon market ultimately means that a limit must be imposed on the total quantity of rights available for trading.

A carbon tax imputes a cost of carbon emissions to society. It also imposes tradeoffs, so it is similar to carbon trading in being more economically efficient than traditional regulation. A producer can attempt to adjust a production process such that it emits less carbon, and the incidence of the tax falls partly on final consumers, who adjust the carbon intensity of their behavior accordingly. For our purposes here, a tax is more illuminating in the sense that we can assess inputs to the cost imputation. Even a cursory examination shows that the cost estimate can vary widely given reasonable differences in the inputs. So, in a sense, a tax helps to reveal the weakness of the case against carbon and the carbon-based rationale for allowing a coercive environmental authority to sclerose the arteries of the market system.

The three economists propose an initial tax of $40 per metric ton of emitted carbon. The basis for that figure is the so-called “social cost of carbon” (SCC), a theoretical construct that is not readily measured. Economists have long subscribed to the theory of social costs, or negative externalities, and to the legitimacy of government action to force cost causers to internalize social costs via corrective taxation. However, the wisdom of allowing the state to intrude upon markets in this way depends on our ability to actually measure specific external costs.

Fatuous Forecasts

The SCC is based on the presumed long-run costs of an incremental ton of carbon in the environment. I do not use the word “presumed” lightly. The $40 estimate subsumes a variety of speculative assumptions about the climate’s response to carbon emissions, the future economic impact of that response, and the rate at which society should be willing to trade those future costs against present costs. The figure only counts costs, without considering the huge potential benefits of warming, should it actually occur.

Ronald Bailey at Reason illustrates the many controversies surrounding the calculation of the SCC. He notes the tremendous uncertainty surrounding an Obama Administration estimate of $36 a ton in 2007 dollars. It used an outdated climate sensitivity figure much higher than more recent estimates, which would bring the calculated SCC down to just $16.

A discount rate of 3% was applied to projected future carbon costs to produce an SCC in present value terms. The idea is that today’s “collective” would be indifferent between paying this cost today and suffering the burden of future costs inflicted by carbon emissions. This presumes that 3% is the expected return society can earn for the future by investing resources today. Unfortunately, the SCC is tremendously sensitive to the discount rate. Together with the more realistic estimate of climate sensitivity, a discount rate of 7% (the Office of Management and Budget’s regulatory guidance) would actually make the SCC negative!

Another U.S. regulatory standard, according to Bailey, is that calculations of social cost are confined to costs borne domestically. However, the SCC attempts to encompass global costs, inflating the estimate by a factor of 4 to 14 times. The justification for the global calculation is apparent righteousness in owning up to the costs we cause as a nation, and also for the example it sets for other countries in crafting their own carbon policies. Unfortunately, it also magnifies the great uncertainties inherent in this messy calculation.

Lack of Evidence

This guest essay on the Watts Up With That? web site by Paul Driessen and Roger Bezdek takes a less gracious view of the SCC than Bailey, if that is possible. As they note, in addition to climate sensitivity, the SCC must come to grips with the challenge of measuring the economic damage caused by each degree of warming. This includes factors far into the future that simply cannot be projected with any confidence. We are expected to place faith in distant cost estimates of heat-related deaths, widespread crop failures, severe storm damage, coastal flooding, and many other calamities that are little more than scare stories. For example, the widely reported connection between atmospheric carbon concentration and severe weather is demonstrably false, as are reports that Pacific islands have been swallowed by the sea due to global warming.

Ignoring the Benefits

The SCC makes no allowance for the real benefits of burning fossil fuels, which have been a powerful engine of economic growth and still hold the potential to lift the underdeveloped world out of poverty and environmental  distress. The benefits of carbon also include fewer cold-related deaths, higher agricultural output, and a greener environment. It isn’t surprising that these benefits are ignored in the SCC calculation, as any recognition of that promise would undermine the narrative that fossil fuels are unambiguously evil. Indeed, an effort to calculate only the net costs of carbon emissions would likely expose the entire exercise as a sham.

The “four pillars” of the Climate Leadership Council‘s case for climate action rest upon an incredibly flimsy foundation. Like anthropomorphic climate change itself, appropriate measurement of a social cost of carbon is an unsettled issue. Its magnitude is far too uncertain to use as a tool of public policy: as either a tax or a rationale for carbon regulation of any kind. And let’s face it, taxation and regulation are coercive acts that better be undertaken with respect for the distortions they create. In this case, it’s not even clear that carbon emissions should be treated as an external cost in many applications, as opposed to an external benefit. So much for the corrective wisdom of authorities. The government is not well-equipped to centrally plan the economy, let alone the environment.

  • The three economists are Martin Feldstein, Ted Halstead and Greg Mankiw.

Free Trade Lets You Make a Deal

29 Wednesday Apr 2015

Posted by in Free Trade

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“Economists have the least influence on policy where they know the most and are most agreed; they have the most influence on policy where they know the least and disagree most vehemently.”

And what a shame! That quote is Alan Blinder’s Murphy’s Law of economic policy, provided by Greg Mankiw in the New York Times. Mankiw’s article, “Economists Actually Agree on This: The Wisdom of Free Trade“, discusses the prospective Trans-Pacific Partnership (TPP), an agreement that would liberalize trade between the U.S. and a number of Asian nations. A bill is before Congress that would give President Obama “fast track” authority to negotiate the deal. Some provisions of TPP are settled in principle, such as reduced tariffs, free trade unions, a reduced role for the state in the economy, and more transparency. Admittedly, it feels odd to advocate for Barack Obama to negotiate over less government — not to mention transparency!

As Mankiw says, “Among economists, the issue is a no-brainer.” Just as individuals voluntarily engage in trade because it is mutually beneficial, nations should engage in trade when they can specialize in their areas of comparative advantage. Liberalized trade, including reductions in tariffs and removal of quotas and other obstructions, ultimately brings more goods at lower prices. And ultimately, trade liberalization is not really about nations trading with one another. Rather, it is about liberating individuals to trade freely with one another across international borders.

Passage of fast-track authority is not assured. A great deal of nonsense has been written about the agreement. Oddly, people have a big hang-up about imports, but Mankiw notes that this is precisely wrong:

“A nation benefits from imports, [Adam Smith] argued, because they expand its opportunities for consumption. Exports are necessary only because other nations have the temerity to want to be paid for the goods they provide.“

Again, economists across the idealogical spectrum agree with this perspective. Mankiw offers three reasons, attributed to Bryan Caplan, for the public’s ambivalence to free trade:

“The first is an anti-foreign bias. People tend to view their own country in competition with other nations and underestimate the benefits of dealing with foreigners. Yet economics teaches that international trade is not like war but can be win-win.

The second is an anti-market bias. People tend to underestimate the benefits of the market mechanism as a guide to allocating resources. Yet history has taught repeatedly that the alternative — a planned economy — works poorly.

The third is a make-work bias. People tend to underestimate the benefit from conserving on labor and thus worry that imports will destroy jobs in import-competing industries. Yet long-run economic progress comes from finding ways to reduce labor input and redeploying workers to new, growing industries.“

Tyler Cowan is enthusiastic about the prospects for some of the poorest Asian nations to benefit from TPP, especially Vietnam. I seem to recall that he likes the cuisine! Cowan says: “Do you get that, progressives? Poorest country = biggest gainer.“

Punitive Taxes Chase Off a Rational King

28 Thursday Aug 2014

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The counterproductive U.S. corporate tax code was a major incentive for Burger King’s prospective merger with the Canadian doughnut chain Tim Hortons. The merger will allow BK to change its domicile to Canada, thereby reducing its tax bill. This is known as a corporate “tax inversion.” Canada’s tax system is less punishing because its corporate tax rate is lower than in the U.S., and Canadian taxes are based on territorial earnings, rather than global earnings as in the U.S. Megan McArdle explains that the latter is the more important consideration: “If we’re worried about inversion, then the U.S. government should follow the lead of other developed countries, and move to territorial taxation.”

The corporate income tax represents double taxation of income paid out as dividends and imposes, at least partly, a double tax burden on shareholders even when earnings are retained. Greg Mankiw believes that the corporate income tax should be abolished.

“The burden of the corporate tax is ultimately borne by people — some combination of the companies’ employees, customers and shareholders. After recognizing that corporations are mere conduits, we can focus more directly on the people.”

On the topic of “economic patriotism” and so-called “corporate desertion,” Mankiw quotes Learned Hand:

“Anyone may arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which best pays the treasury. There is not even a patriotic duty to increase one’s taxes.”

Mankiw also proposes a consumption tax as a replacement for federal income taxation, which has great merit, but it is a very ambitious plan and probably at odds with current political realities.