Government revenue, private welfare, and tax reform in a small open economy

This paper examines the welfare and revenue effects of consumption and income taxes in a general equilibrium model with variable supply of labour and public goods. We derive the optimal consumption and income tax rates for such an economy. It is established that it is better to lower the income tax rate and increase the rate of consumption tax when this economy is in a downturn.

The tax treatment of employee stock options : generous to a fault

In the 2000 budgets, both the federal and Ontario governments introduced changes to the tax treatment of employee stock options for the explicit purpose of making their tax treatment in Canada similar to or more favourable than that in the United States. The federal budget added a deferral, similar to that currently applicable to options granted by Canadian-controlled private corporations, for up to $100,000 per year of public company stock options. The Ontario budget introduced an exemption from tax for employees involved in research and development on the first $100,000 per year of employee benefits arising on the exercise of qualified stock options or on eligible capital gains arising from the sale of shares acquired by the exercise of eligible stock options. These proposals reflect the apparent acceptance by the two governments that there is a “brain drain” from Canada to the United States of knowledge workers in the “new” economy and that reductions in Canadian taxes should stem this drain. In the author’s view, the tax treatment of employee stock options, even without these changes, is overly generous. Both the federal and provincial proposals ignore the fact that most employee stock options are taxed more favourably in Canada than in the United States in any event. In particular, most employee stock option benefits in Canada are taxed at capital gains tax rates, whereas in the United States most are taxed at full rates. While the US Internal Revenue Code does provide capital gains tax treatment for certain employee stock option benefits, a number of preconditions must be met. Most important, the shares acquired pursuant to the options must be held for a minimum of one year after the option is exercised. In addition, there are monetary limits on the amount of options that qualify for capital gains treatment. In Canada, there are generally no holding period requirements or monetary limits that apply in order for the option holder to benefit from capital gains tax rates. Empirical evidence indicates that the vast majority of employees in the United States exercise their options and immediately sell the shares acquired. These “cashless exercises” do not benefit from capital gains treatment in the United States, whereas similar cashless exercises in Canada generally do. This empirical evidence suggests not only that the 2000 budget proposals are unwarranted, but also that the existing treatment of employee stock options in Canada is already more generous than that in the United States. This article begins with a theoretical “benchmark” for the taxation of employee stock options. The author suggests that employee stock options should be treated in the same manner as other income from employment. In theory, the value of the benefit should be included in income when the option is granted or vests. However, owing to the practical difficulty of valuing employee stock options, the theoretical benchmark proposed is that the value of the benefit (the difference between the fair market value of the shares acquired and the strike price under the option) be taxed when the shares are acquired, and the employer be entitled to a corresponding deduction. The employee stock option rules in Canada and the United States are then compared and contrasted with each other and the benchmark treatment. The article then examines the arguments that have been made for favourable treatment of employee stock options. Included in this critique is a review of the recent empirical work on the Canadian brain drain. Empirical studies suggest that the brain drain—if it exists at all—is small and that, despite what many newspapers and right-wing think-tanks would have us believe, lower taxes in the United States are not the cause. One study, concluding that taxes do have an effect on migration, suggests that even if Canada adopted a tax system identical to that in the United States, the brain drain would be reduced by a mere 10 percent. Indeed, even if Canada eliminated income tax altogether, it would not stop the brain drain. If governments here want to spend money in order to stem the brain drain, they should focus on other areas. For example, Canada produces fewer university graduates in the fields of mathematics, sciences, and engineering than any other G7 country except Italy. The short supply of university graduates in these fields, the apparent loss of top-calibre academics to US
universities, and the consequent lower levels of university research in these areas (an important spawning ground for new ideas in the “new” knowledge-based economy) suggest that Canada may be better served by devoting more resources to its university institutions, particularly in post-graduate programs, rather than continuing the current trend of budget cuts that universities have endured and may further endure if taxes are reduced.
As far as employee stock options are concerned, if Canada does want to look to the United States for guidance on tax reform (which it seems to do with increasing frequency of late), it should adopt the US rules applicable to nonstatutory options, which are close to the proposed benchmark treatment. In the absence of preferential tax treatment, employee stock options would still be included in compensation packages provided that there were sound business reasons for their use. No persuasive evidence has been put forward that the use of stock options, in the absence of tax incentives, is suboptimal. Indeed, the US experience suggests quite the opposite.

Taming Complexity in Australian Income Tax

Taxpayers and tax authorities recognise that complex Australian income tax law is in need of simplification - during the past decade there have been two ineffective attempts at simplification of the tax law - first by redrafting the law in plain English without addressing structural issues - second by the proposed wholesale replacement of the legislation with a new foundation, incorporating most of the causes of the complexity in the current law - with tax law growing in size and complexity, new paths to simplification must be considered.

The taxpayers'€™ charter : a case study in tax administration

The Australian Taxpayers'€™ Charter was introduced in 1997 and a revised version in November 2003. This is therefore an appropriate time to review the contribution of this initiative. This article traces the development of such modern charters and then specifically the development of tax charters. The Australian Taxpayers' Charter and the Australian Tax Office'€™s ("€œATO"€) experience with it are then examined. Among other possible advantages, the Charter may be used as a measure of the ATO'€™s performance. Taxpayers’ views regarding the extent to which the ATO meets its obligations under the Taxpayers'€™ Charter, as expressed in two surveys of Australian voters (N = 2,040 and 2,374), are presented. Generally the taxpayers are supportive. The results of the survey also support the ATO'€™s view that the Charter fits in with compliance policy. Finally, the Charter demonstrates how initiatives in tax administration might he successfully achieved.

Capital and Consumption Tax Reforms in a Small Open Economy

The effects of a reform in capital and consumption taxes on private welfare and government tax revenue are examined for a small open, capital-importing economy. A trade-off between private welfare and tax revenue is encountered in maximizing social welfare. Nonetheless, lowering capital taxes and raising consumption taxes can increase both private welfare and tax revenue if the initial tax rates are not optimal. In addition, a tax reform by this fashion is a likely response to a rise in the foreign rate of return on capital.

Tariff and consumption tax reforms in a developing tourism economy

This paper examines the effects of a coordinated tax reform by replacing import tariffs with point-by-point increases in consumption taxes for a small-open developing tourism economy. Foreign tourists demand for the non-traded goods provided in the informal sector of the host economy, resulting in a tourism-induced terms-of-trade effect. The presence of inbound tourism lends a support to positive tariffs even for a small open economy. The indirect tax reform of this kind can increase residents’ welfare and government revenue when the initial tariffs are relatively larger to the consumption taxes.

Environmental impacts of tariff and tax reforms under origin and destination principles

The impacts of a point-by-point tariff/tax reform on the environment under the origin-based or destination-based tax principle are examined. The policy reform under the origin-based principle can raise the optimal pollution tax and, hence, improve the environment when the consumption demand and pollution are strongly substitutable, whereas the reform under the destination-based principle lowers the optimal pollution tax and, hence, worsens the environment. Nonetheless, when the consumption demand and pollution exhibit weak substitutes or even complements, the tariff/tax reform results in less environmental deterioration under the destination-based principle.

Tariff and environmental policies with product standards

For a small open economy with consumption-based pollution emissions, the first-best optimal policy prescription is free trade along with a Pigouvian tax on emissions. Therefore, a package of coordinated tax reform by replacing tariffs with emission taxes can lower pollution emissions and increase market access and hence improve residents’ welfare and government revenue, as long as the initial tariffs are relatively high. Numerical simulations confirm the results obtained.

Post-growth policy instruments

This paper proposes a framework to evaluate post-growth policy instruments which gauges their capacity to lessen the pressure for growth emanating from the labour market and the state’s contradictory legitimisation and accumulation imperatives, whilst increasing societal well-being and reducing the biophysical throughput of the economy. It is argued that the most effective policies to do this are measures to reduce average working hours, expand low productivity sectors and reduce inequality. Specific policies instruments include public sector expansion and the promotion of cooperatives, the introduction of citizens’ basic income schemes, environmental tax reform, the abolition of fossil fuel subsidies, reforms to monetary policy, financial regulatory reform and the introduction of alternative measures of progress to gross domestic product.

Exempt treatment of financial intermediation services under a value-added tax: an assessment of alternatives

Most countries with a value-added tax (VAT) exempt financial intermediation services from the tax. While exemption is generally perceived to be undesirable, it is also widely regarded as unavoidable because of technical difficulties in applying VAT to these services. This article reviews the standard rationale for exempt treatment and then considers the relative merits of two recent challenges raised in the tax literature. The first challenge involves the application of cash flow taxation to financial intermediation services in a manner that is consistent with an invoice/credit VAT (which is the dominant form). The second challenge proposes a comprehensive system of zero-rating of financial intermediation services, which is supported by a characterization of the household consumption of such services as non-taxable. The author argues that each of these alternatives to an exemption system suffers from both theoretical and practical implementation difficulties that make maintenance of exempt treatment the preferred approach, at least in the short term. There is, however, a simpler alternative to these fundamental reform options, involving modification of just one aspect of an exemption system to relieve some of its more problematic aspects. Many of the interpretative problems and associated inefficiencies that plague an exemption system arise from the need to distinguish between taxable and exempt financial services. The author argues that these difficulties can be eliminated, to a large extent, by basing the distinction on the form of prices. In support of this approach, he points out that it is consistent with the underlying reasons for the application of exempt treatment. The author considers a number of other possible modifications, but these are either rejected outright or viewed with a healthy skepticism. For example, the author is critical of the apparent rationale for the application of cash flow taxation to property and casualty insurers. He also rejects proposals that accept some looseness in the formulaic allocation by financial intermediaries of the costs of business inputs between exempt and taxable services for input credit purposes. In his view, an explicit reliance on pricing structures to draw the boundary between exempt and taxable services is preferable to the provision of relief for blocked input tax credits of financial intermediaries. Finally, the author is skeptical of the case for a policy response intended to address the tax bias under an exemption system for financial intermediaries to insource supplies.

Black fella land – white fella tax : changing the CGT implications of aboriginal/native title

The taxation of aboriginal/native title payments gives rise to a number of complex and difficult legal and policy issues. Reform measures announced on 13 February 1998 by the then Federal Treasurer and Attorney-General did not address the possible capital gains tax (‘CGT’) implications and even those relating to ordinary income under s 6-5 Income Tax Assessment Act 1997 (Cth) remain unimplemented. The much anticipated Report of the Native Title Payments Working group (6 February 2009), while primarily focusing on non-taxation issues, also recognises the need for taxation reform and makes some recommendations in regard to such. Most recently, on 18 May the Assistant Treasurer, Senator Nick Sherry, the Minister for Families, Housing, Community Services and Indigenous Affairs, Jenny Macklin, and the Attorney General, Robert McClelland, announced the commencement of a national consultation on the tax treatment of native title, including the interaction of native title, Indigenous economic development and the tax system. The Assistant Treasurer recognised the need for “greater clarity and increased certainty for native title holders on how the tax system and native title interact.” At the same time, they released a paper entitled Native Title, Indigenous Economic Development and Tax to guide the national consultation. The proposed measures considered in the paper, including exempting Native title payments and/or creating a new tax exempt Indigenous Community Fund, provide a welcome step towards reform in this area. This article is part of a broader research project that explores the CGT implications of aboriginal/native title. While these provisions impact on both Indigenous traditional owners and relevant payers, such as mining companies, the focus in the project is particularly on the CGT implications for the traditional owners. This first part of the project examines the status of aboriginal/native title and incidental/ ancillary rights as CGT assets. The broader research project will then build on this analysis in the context of relevant CGT events. As the preliminary findings in this article evidence the CGT implications of aboriginal/native title are far from certain. The application of CGT to aboriginal/native title raises more issues than it answers. The key reason is that the current law is entirely unsuitable to communally held inalienable aboriginal/native title. Nevertheless, it will be seen that it is arguable that aboriginal/native title and/or incidental rights are post-CGT assets and acts in relation to such could trigger a CGT event with tax implications for the traditional owners. It will be suggested that these current tax provisions provide a very pertinent example where the law operates as a blunt tool that does not appropriately promote justice and reconciliation. To tax Indigenous communities as a result of acts that extinguish or impair their traditional ownership is incongruous. A specific provision(s) should be included in the capital gains provisions to ensure any such payments are exempt from taxation. This is not only fair given the history of uncompensated extinguishment of aboriginal title Australia, but also promotes the ability of Indigenous communities to optimise the financial benefits stemming from aboriginal/native title agreements.

From tax expenditures to rebates: an 'output based equity' approach for Australia's retirement policies

Australia's retirement policies are geared to shifting reliance from the Age Pension to private superannuation, predominately via the use of tax expenditures. This article examines tax expenditures in this area and concludes that inequities and inefficiencies abound. Reform is required. It is argued that the functions of revenue collection and social support should be separated, and the use of tax expenditures in superannuation should be discarded. A rebate system1 or a spending initiative, is proposed. This 'output based equity' approach will address fairness and equity issues at the time of retirement - when full benefits are received.