Fiscal Policy

  • United States
     A Quick Word on the (Lack of) Revenue From the Senate’s Proposed International Tax Reform
    The Joint Committee on Tax has scored the Senate’s proposed international tax reform. I haven’t seen any reporting indicating that the conference committee has significantly changed these provisions—though it seems like the conference committee will get rid of the alternative minimum tax for corporations that the Senate introduced at the last minute. And the JCT score of the Senate bill is kind of interesting—as it shows how the Senate effectively chose not to broaden the U.S. tax base in a way that will raise significant future revenues from the globally untaxed profits U.S. firms now stash abroad. The JCT indicates that the international side of the reform should generate $260 billion of revenue over ten years. But that is purely a function of the $290 billion in revenue expected from the taxation of “legacy” tax-deferred profits (the infamous cash stash U.S. firms have kept abroad while waiting for a tax holiday). The other reforms on net cost $30 billion. In some sense that is a function of moving toward a territorial system where income “earned” abroad can be returned to the U.S. without incurring an additional tax liability. The quotes around “earned” are intentional. A lot of tax planning goes into moving profits abroad—it isn’t clear if the American tax residents of Bermuda, Ireland, and similar locations really are earning large sums abroad, or just attributing large sums to their offshore arms. But it is also a function of the choices made to limit the potential base erosion. There seem to be real provisions to limit profit stripping out of the U.S. operations of foreign firms operating in the U.S.—those provisions are expected to net almost $150 billion over ten years.* But, well, the provisions designed to tax the often largely untaxed profits U.S. firms now report abroad seem thin. U.S. firms abroad now report $200 billion in “reinvested” (so not repatriated and not currently taxed) profits in the seven main tax havens, or almost exactly a percentage point of GDP. That is just the funds in the main tax havens—which I am taking as a proxy for the offshore earnings of U.S. firms that right now no one globally is really taxing. If that share stays constant as a share of GDP, the annual flow of such profits over the next ten years should average about $250 billion. A 20 percent tax (imposed on a firm’s global profit, with no deferral) thus should collect about $500 billion over ten years (e.g. an average of about $50 billion a year), minus any taxes actually paid abroad. And even a 10 percent tax should net about $250 billion. The proposed 10 percent global minimum on intangible income though collects $135 billion (per the JCT) —partially because of the deduction for foreign taxes actually paid, and in part because firms get an automatic deduction equal to a 10 percent assumed return on any actual assets abroad, and in part because of the way the tax is calculated. That’s leaving a lot of money on the table compared to a reform that really sought to broaden the base, which has clearly been eroded by tax shifting. And a large part of the gains from a global minimum are offset by the special low tax on export earnings from intangible income retained by a U.S. firm. The 12.5 percent rate (counting the ability to move intangible assets that now held abroad back to the U.S. without a tax penalty) is estimated to cost about $100 billion over ten years. In other words, the tax reform doesn’t seem to generate any significant future revenue out of U.S firms that have gamed the current system by shifting profits to low tax jurisdictions abroad.  And of course the new rules themselves can be gamed. As a prominent group of tax experts have noted, the 10 percent rate abroad creates incentives to shift assets offshore and the 12.5 percent rate on the export of intangibles creates incentives to export more (and then find ways to sell the goods back to the U.S). As a result, I would not be surprised if the Senate’s proposed international reforms—if they are adopted by the conference and approved by both houses—actually end up reducing the amount of “international” tax revenue the U.S. generates going forward. I have read that the tax reform doesn’t deliver much of an additional benefit to large global multinationals. That’s only true because global multinationals already have found so many ways to reduce their tax. The proposed reform doesn’t really widen the tax base to cover profits that have been shifted to tax havens in any real way. One final, small point: the FT’s estimate of the gains to Apple from the tax reform seems to be too low.  The FT’s calculation only captured the gains on Apple’s legacy profits (the $250 billion in cash Apple has “offshore,” which can be returned at a 14.5 percent rate rather than a 35 percent rate).   It didn’t try to estimate Apple’s future tax savings, and those will also be significant. Right now roughly two thirds of Apple’s profit is reportedly earned offshore (the New York Times indicates that 70 percent of Apple’s profit comes from its international side). So Apple’s offshore (e.g. tax deferred under current U.S. law) profit is likely close to $40 billion. Apple reports that it pays about $2 billion in foreign tax right now—so something close to a 5 percent rate on its roughly $40 billion in offshore profit. Going forward, those earnings will either be taxed at somewhat under 10 percent (the global minimum on intangibles is 10, but Apple does have some tangible assets abroad) or at 12.5 percent (if Apple reorganizes itself as a U.S. exporter of intangible design and software and phases out its offshore subsidiaries). Either rate would be well below the 35 percent rate (minus deductions of taxes actually paid abroad) that theoretically should be paid under the current law—in fact both are below the 14.5 percent rate on legacy (e.g. tax deferred) profits in the Senate bill. ** And Apple here really is a metaphor for all the big technology and pharmaceutical companies with large offshore earnings in low tax jurisdictions, and large offshore cash holdings. * The new base erosion taxes on foreign multinationals operating in the U.S. (which report very few profits in the U.S. currently thanks to their own tax gaming) helps offset the revenue lost from the shift to territoriality—e.g. the $215 billion in lost revenue from the “participation exemption” on U.S. firms foreign income in the JCT’s score. ** Of course Apple doesn’t pay the 35 percent rate as offshore profits can be tax deferred. If the Senate bill becomes law, its de facto tax rate on its past profits will be 14.5 percent--and Apple’s going forward rate on the same offshore income streams will be even lower.
  • United States
    Tax Reform and the Trade Balance
    Warning: long, wonky, and not for the fainthearted. I try to assess how the international reforms will impact where firms book profits and thus the measured trade and income balance, not just the mechanical impact of a higher fiscal deficit.
  • Eurozone
    The Eurozone’s Fiscal Version of the Impossible Trinity?
    The eurozone member-states may never be able to run a fiscal policy that is optimal for the eurozone taken as a whole.
  • Japan
    Abenomics and the Long Legacy of the Consumption Tax Hike
    Abe's consumption tax hike stalled what until then had been a demand led recovery, leading to a three year period with no growth in domestic demand. 
  • Energy and Climate Policy
    Rebuttal: Oil Subsidies—More Material for Climate Change Than You Might Think
    This post is authored by Peter Erickson, a staff scientist at the Stockholm Environment Institute and a co-author of a new paper in Nature Energy that studies how much of U.S. oil reserves are economical to extract as a result of government subsidies that benefit the oil industry. This post is a response to a previous post, by Varun Sivaram, arguing that federal tax breaks for the oil industry do not, in fact, cause a globally significant increase in greenhouse gas emissions, citing a recent CFR paper authored by Dr. Gilbert Metcalf at Tufts University. Dr. Sivaram’s short response to Mr. Erickson’s rebuttal is included at the bottom of the post. As Congress moves towards tax reform, there is one industry that hasn’t yet come up: oil. While subsidies for renewable energy are often in the cross-hairs of tax discussions, the billions in federal tax subsidies for the oil industry rarely are; indeed, some subsidies are nearing their 100th birthday. And yet, removing oil subsidies would be good not only for taxpayers, but for the climate as well. The lack of attention on petroleum subsidies is not for lack of analysis. Congress’ own Joint Committee on Taxation values the subsidies at more than $2 billion annually.  (Other researchers have put the total much higher.) Just in the last year, two major studies have assessed in detail how these subsidies affect investment returns in the US oil industry. The two analyses—one published by the Council on Foreign Relations (CFR) and the other in Nature Energy (which I coauthored)—both show the majority of subsidy value goes directly to profits, not to new investment.   That inefficiency—both studies argue—is reason enough for Congress to end the subsidies to the oil industry. But oil subsidies also have another strike against them: oil is a major contributor to climate change. The burning of gasoline, diesel, and other petroleum products is responsible for one-third of global CO2 emissions. That climate impact is one of the reasons the Obama Administration had committed, with other nations in the G7, to end these subsidies by 2025. Both the CFR and Nature Energy analyses arrive at a similar figure as to the net climate impact. As CFR fellow Varun Sivaram notes in a previous post on this blog comparing the two studies, the CFR study finds that subsidy removal would reduce global oil consumption by about half a percent. Our analysis for the Nature Energy study also finds a reduction in global oil consumption of about half a percent. (You won’t find this result in our paper, but it is what our oil market model, described in the online Supplementary Information, implies.) The most critical place where the studies—or rather, authors—differ is how they put this amount of oil in context. (Our study also addresses many more subsidies, and in much more detail, than the CFR study, but that is not the point I wish to address here.) Sivaram refers to the half-percent decrease in global oil consumption as “measly…washed out by the ordinary volatility of oil prices and resulting changes in consumption…the nearly-undetectable change in global oil consumption means that the climate effects of U.S. tax breaks are negligible.” I would argue that this assertion confuses the effect of subsidies on oil consumption with our ability to measure the change. But before I get into it further, let me first describe how much oil and CO2 we are talking about. By the CFR paper’s estimates, removal of US oil subsidies would lead to a drop in global oil consumption of 300,000 to 500,000 barrels per day (corresponding to 0.3% to 0.5% of the global oil market). The sequential effects in their model are shown in the chart below, which I made based on their results. It shows their lower-end case, in which global oil consumption drops by 300,000 barrels per day (bpd). (This case is described in their paper as using EIA’s reference case oil price forecast and an upward-sloping OPEC supply curve.)  In their model, a drop of over 600,000 bpd in US supply from subsidy removal is partially replaced by other sources of U.S., OPEC, and other rest-of-world supply, yielding a net reduction in global consumption of roughly half as much (300,000 bpd, shown in the right column). (This ratio itself is also interesting and important. For each barrel of oil not developed because of subsidies, this case shows a drop in global oil consumption of 0.45 barrels. The CFR study’s other three cases show a drop of 0.51, 0.63, and 0.82 barrels of global consumption for each US barrel left undeveloped.) Each barrel of oil yields, conservatively, about 400 kg of CO2 once burned, per IPCC figures. So, the range of impacts on oil consumption in the CFR study (again, reductions of 300-500k bpd or 110 million to 200 million bbl annually) implies a drop in global CO2 emissions of about 40-70 million tons of CO annually. (The actual emissions decrease from subsidy removal could well be greater, because this estimate doesn’t count other gases released in the course of extracting a barrel of oil, such as methane or other CO2 from energy used on-site). From a policy perspective, 40 to 70 million tons of CO2 is not a trivial (measly) amount. Rather, it is comparable in scale to other U.S. government efforts to reduce greenhouse gas emissions. For example, President Obama’s Climate Action Plan contained a host of high-profile measures that, individually, would have reduced annual (domestic) greenhouse gas emissions by 5 million tons (limits on methane from oil and gas extraction on federal land), 60 million tons (efficiency standards for big trucks), and 200 million tons (efficiency standards for cars). The CFR authors don’t quantify their findings in CO2 terms, however, and Sivaram refers to oil market volatility as a way to discount CFR’s findings on reduced oil consumption, concluding that the effects are “undetectable” and “negligible.” The argument is essentially that because other changes in the oil market are bigger, and can mask the independent effect of subsidy removal, that subsidy removal has no effect on climate change. This line of argument conflates causality, scale and likelihood of impact (which in this case are either all known, or can be estimated) with ability to monitor, detect and attribute changes (which is rarely possible in any case, even for more traditional policies focused on oil consumption). By this logic, almost any climate policy could also be discounted as immaterial, because it is rare to be able to directly observe with confidence both the intended result of a policy and the counterfactual – what would have happened otherwise.  Rather, I would argue that if we are to meet the challenge of global climate change, we’ll need these 40 to 70 million tons of avoided CO2, and many more, even if there is uncertainty about exactly how big the impact will be. Concluding an action represents a small fraction of the climate problem is less a statement about that action than it is about the massive scale of the climate challenge. Indeed, as the Obama White House Council on Environmental Quality stated, such a comparison is “not an appropriate method for characterizing the potential impacts associated with a proposed action… because…[it] does not reveal anything beyond the nature of the climate change challenge itself.” So, I argue that subsidy removal is indeed material for the climate, even by the CFR report’s own math. And as Sivaram also notes, the CO2 emission reductions would multiply as other countries also phase out their subsidies. Lastly, I need to disagree with Sivaram’s statement that our study is “written in a misleading way”. He asserts this because in the Nature Energy article we focus on the entire CO2 emissions from each barrel, rather than apply an oil market economic model as described above that counts only the net, or incremental, global CO2. But the incremental analysis method above is not the only way to describe CO2 emissions. Indeed, comparing the possible CO2 emissions from a particular source to the global remaining carbon budget is a simple and established way to gauge magnitudes, and nicely complements the incremental analysis enabled by oil market models.   As another noted subsidy expert—Ron Steenblik of the OECD—commented separately in Nature Energy, our analytical approach provides an important advance because it enables “researchers to look at the combined effect of many individual subsidies flowing to specific projects and to use project-specific data to gauge eligibility and uptake.” Similar assessments of other countries, and other fossil fuels, would provide an important window on the distortionary impacts of these subsidies and their perverse impacts on global efforts to contain climate change. Sivaram Response to Erickson Rebuttal First of all, I am grateful to Peter Erickson for responding in this way to a blog post I wrote that was critical of his conclusions. His response was graceful and sophisticated—I think I largely agree with it, and he’s pointed out some holes in my post that I want to acknowledge. However, I do still stand by my headline, “No, Tax Breaks for U.S. Oil and Gas Companies Probably Don’t Materially Affect Climate Change.” In fact, I think the Erickson rebuttal above reinforces just that point. Tackling the overall thesis first: in his rebuttal, Erickson is willing to accept that a reasonable estimate for the carbon impact of U.S. tax breaks for oil and gas companies is 40–70 million tons of carbon dioxide emissions annually (there may be other greenhouse gas emissions, such as methane, that increase the climate impact). Erickson even compares the magnitude of this negative climate impact with the positive impact of President Obama’s efficiency standards for big trucks. I am absolutely willing to accept that removing U.S. tax breaks for oil companies would be about as big a deal, in terms of direct emissions reduction, as setting domestic efficiency standards for big trucks. Importantly, this direct impact is trivial on a global scale, which is the point that I made in my original post, reinforcing Dr. Metcalf’s conclusion in his CFR paper. I am, however, sympathetic to Erickson’s argument that the world needs a rollback of tax breaks, efficiency standards for big trucks, and a whole suite of other policies in the United States and other major economies to combat climate change. And there is certainly symbolic value to the United States rolling back its oil industry tax breaks, possibly making it easier to persuade other countries to follow suit. I also want to concede that Erickson very rightly called me out on unclearly discussing the relationship between oil price volatility and the effect on oil prices of removing tax breaks. We definitely know which direction removing subsidies would move prices (up) and global consumption (down). I should have been clearer that my comparison of the frequent swings in oil prices to the tiny price impact of removing subsidies was merely to provide a sense of magnitude, NOT to imply that measurement error washes out our ability to forecast the magnitude of tax reform’s price impact, ceteris paribus. Finally, Erickson took issue to my characterization of his paper as “misleading.” Indeed, I never meant to imply that he and his co-authors intended to mislead anybody. I still, however, stand by what I meant: that the paper might lead a casual reader to take away an erroneous conclusion by relegating the global oil market model to an appendix and only citing the increase in U.S. emissions in the main body. In my opinion, readers need to know that industry tax breaks have a very small effect on global greenhouse gas emissions, but there are other very important reasons to remove them. And yes, the United States absolutely should remove its tax breaks, as should other countries remove their fossil fuel subsidies. On that count, Erickson and I are in complete agreement.
  • United States
    Apple’s Exports Aren’t Missing: They Are in Ireland
    Goods made in China flow through Ireland before returning to China, and the many other ways tax influences the balance of payments.
  • Energy and Climate Policy
    No, Tax Breaks for U.S. Oil and Gas Companies Probably Don’t Materially Affect Climate Change
    Last week, the journal Nature Energy published an article from scholars at the Stockholm Environment Institute arguing that the tax breaks given to oil companies by the U.S. government could lead to carbon emissions that eat up 1 percent of the world’s remaining “carbon budget.” (The carbon budget is scientists’ best guess of how much more carbon dioxide the world can emit while still having a chance of limiting global warming to 2°C.) This is an enormous figure—few other national policies reach that level of climate impact. So, if true, this analysis provides a powerful argument in favor of ending preferential tax treatment for U.S. oil and gas firms (see Vox’s piece for an accessible discussion). But that conclusion flies in the face of the conclusion reached by a paper published here at the Council on Foreign Relations by energy economist Gilbert Metcalf. His paper concluded that tax breaks for oil companies modestly increase U.S. oil production, but, more importantly, global prices for and consumption of oil barely budge as a result, minimally affecting the climate. (The paper came to a similar conclusion about the climate impacts of tax breaks for U.S. natural gas production.) I was closely involved in the review and editing process for that paper, and I can attest that Professor Metcalf’s methodology was rigorously stress-tested. So who’s right? In a nutshell, I stand by the CFR paper’s conclusion that federal tax breaks for oil and gas companies aren’t a major contributor to climate change. The biggest reason is that both the Nature Energy and CFR papers are in agreement that the tax breaks barely alter global oil prices, which implies insignificant changes in global consumption of, and emissions from, oil. In fact, the Nature Energy authors do not dispute this, and they only explicitly say that tax breaks cause emissions from burning U.S. oil to increase. But their omission that those tax breaks likely cause emissions from burning other countries’ oil to decrease can easily mislead a casual reader to assume that they mean global emissions will increase as much as emissions from burning U.S. oil will.  The two papers also have some other quantitative disagreements, and the Nature Energy paper might have more up-to-date industry data than the CFR paper. Nevertheless, I don’t think those other disagreements justify overturning the CFR paper’s overall conclusion about the limited climate effects of the tax breaks. Finally, the two papers do agree on one thing: the tax breaks should go. The Nature Energy paper contends that ending the tax breaks would bring “substantial climate benefits.” Although the CFR paper concludes that emissions “would not change substantially,” the two papers agree that tax reform has symbolic value that would strengthen U.S. climate leadership; U.S. taxpayers would also benefit from a few billion dollars annually of recouped government revenue from oil companies. Back to Basics The two papers are in agreement that there are three major tax breaks that oil companies get from the federal government that promote more U.S. oil production. The first allows firms to immediately expense “intangible drilling costs” (IDCs), which account for the majority of drilling costs, rather than deducting them from their taxable income over several years. The second tax break, percentage depletion, allows some oil companies to deduct a fixed percentage of their taxable income as costs rather than deducting the value of their reserves as they are depleted. And the third tax break allows oil companies to write off a percentage of their income through the domestic manufacturing deduction. Together, these three tax breaks amount to around $4 billion in foregone government revenue annually. (The Nature Energy paper considers several other tax breaks but concludes that these three are the important ones.) Both papers then set out to quantify how much more oil U.S. firms produce as a result of the tax breaks. In general, the two papers go about this in a similar way. The Nature Energy paper uses real industry data on U.S. shale oil fields to calculate which fields are profitable to produce oil from with the tax breaks but aren’t worth drilling without those breaks. And the CFR paper uses a new theoretical tool along with empirical statistics to find the percentage of wells that tax breaks make profitable to drill. But the two papers differ in their bottom-line conclusions. The Nature Energy paper rings the alarm bells by concluding that the total amount of oil in the fields that tax breaks turn from unprofitable to profitable is between 13 and 37 percent of the total amount of profitable oil (depending on where oil prices are between $75 and $50 per barrel; higher prices mean that less oil becomes economic to produce as a result of tax breaks—see figure 1). As a result, the authors conclude, if all of the oil in the fields turned profitable by tax breaks were produced by 2050 (and burned), the world would emit 6–7 gigatons of carbon dioxide, roughly 1 percent of the remaining carbon budget. Figure 1: Nature Energy paper summary figure: “The impact of subsidies is highly sensitive to oil price. These charts shows how much oil is economic at price levels between US$30 and US$100 per barrel according to whether it is already producing; discovered and economic without subsidies; discovered and economic only because of subsidies (‘subsidy-dependent’); or not yet discovered. a, Results at the base, 10% discount rate. b, Results at an alternative discount rate of 15%. The subsidy-dependence of the not-yet-discovered fields was not assessed, as these quantities are speculative, based on Rystad Energy’s assessment. Still, should they prove as subsidy-dependent as the fields we do assess, the impact of subsidies at higher prices would be larger than we currently estimate.” The CFR paper finds that 9 percent of the wells that oil companies drill each year are induced by tax breaks. But most of the additional oil that the U.S. produces will be offset by reduced production elsewhere in the world. After using a simple model of global oil supply and demand, the paper concludes that increased U.S. production translates only to at most a 1 percent decrease in global oil prices, and a measly half a percent increase in global consumption of oil (see table 2, which projects the oil market impacts of taking away tax breaks). Such a small uptick is washed out by the ordinary volatility of oil prices and resulting changes in consumption. So the CFR paper concludes that the nearly-undetectable change in global oil consumption means that the climate effects of U.S. tax breaks are negligible. Table 2: CFR paper summary table: Table 2 presents the modeled equilibrium values of global oil price, supply, and demand in 2030. The first column lays out four ways that the global market could develop: two future oil price possibilities considered by the Energy Information Agency (EIA), and within each of those cases, the two scenarios for OPEC to be price-responsive or exhibit cartel behavior to maintain its market share. Within each of these four alternatives for how global markets might behave, the second column presents two options for domestic policy: the United States can maintain existing tax preferences (baseline), or it can repeal the three major preferences. The tax reform is assumed to shift the domestic oil supply curve by 5 percent. The remaining columns in table 2 report the equilibrium Brent oil price—the benchmark for most of the world’s oil—in 2012 dollars; supply, in million barrels of oil per day (mbd) from the United States, OPEC, and the rest of the world (ROW); and global demand. Table 2 shows that the long-run effects of U.S. tax reform are minimal under a wide range of input assumptions for how the future oil market behaves. The highlighted figures demonstrate that global prices and demand change by up to 1 percent, and U.S. production changes by less than 5 percent, regardless of the assumptions of future oil prices and how OPEC will respond. Although these changes are greater than those projected by previous studies, they are still small. An oil price increase of up to 1 percent would be over three hundred times smaller than price spikes in the 1970s and ten times smaller than the average annual increase in oil prices from 2009 to 2014. It would raise domestic gasoline prices by at most two pennies per gallon at the pump." I don’t think the Nature Energy paper makes any explicit errors, but I do think it’s written in a misleading way. The paper has a supplementary section in which it also runs a simple global oil supply and demand model, which produces a similarly small price change (a 2 percent increase) in response to U.S. tax breaks as the CFR paper reports. What the Nature Energy paper is really concluding is that tax breaks to U.S. oil companies increase the slice of the global emissions pie that is attributable to U.S. oil being burned, but they don’t commensurately increase the size of that pie. Remaining Quibbles Between the Papers Still, there is some legitimate disagreement between the papers even before running a global supply-and-demand model, suggesting that the CFR paper’s estimate of oil market impacts might have been understated. The Nature Energy paper finds that tax breaks convert 13–37 percent of reserves from uneconomic to economic to extract. It uses actual data on the size and extraction cost of reserves in different shale oil plays to make this conclusion, and the article implies that U.S. production could actually increase by 13–37 percent in the long run as a result of the tax breaks. By contrast, the CFR paper’s estimate of the long-run increase in U.S. supply is much smaller—less than 5 percent. As explained above, the CFR paper first finds that tax breaks account for 9 percent of domestic drilling. Then, the paper further diminishes its estimate of the impact of tax breaks. The difference between drilling rate and long-run supply arises because the CFR paper uses industry data to conclude that the fields that the tax breaks turn from uneconomic to economic to drill are smaller than the average field. Therefore, even though the tax breaks account for 9 percent of the new wells, those smaller wells produce less than 5 percent of U.S. oil supply. The CFR paper does use industry data—including a constant estimate of the elasticity of drilling with respect to price and a regression of well initial production against profitability—but my read is that the Nature Energy paper’s dataset might be more up-to-date. (There are a few other disagreements in assumptions, such as whether the hurdle rate for new investments is 10 or 15 percent and whether the future oil price will be closer to $50 or $75 per barrel. The Nature Energy paper, however, is careful to run a sensitivity analysis and copy the CFR paper’s assumptions to enable comparison.) As a result, the CFR paper’s estimate of the increase in U.S. supply as a result of tax breaks—less than 5 percent—might be a bit of a lowball. In some sense we are comparing apples and oranges by comparing the CFR paper’s estimate of annual U.S. production attributable to tax breaks to the Nature Energy paper’s estimate of total reserves converted from uneconomic to economic. But there is some reason to believe that the effect of tax breaks might be to induce greater than 5 percent of U.S. oil production. Even if that is true, however, it is unlikely that tax breaks materially affect global consumption of oil, mediated through price changes, because the United States accounts for less than 15 percent of global production. Therefore, the conclusion of the CFR paper—that tax breaks to the oil and gas industry are immaterial to climate change in terms of directly induced emissions—probably stands. That doesn’t mean the tax breaks are a good idea. In fact, both papers argue forcefully that the tax breaks should be abolished, at the very least because the United States in doing so can demonstrate leadership in the G20 and other forums where it urges other countries to eliminate fossil fuel subsidies. The effects of those subsidies, on a global scale rather than a national scale, are in fact material to climate change. The world would be better off if they were sharply curtailed.
  • Puerto Rico
    What Puerto Rico Tells Us About Global Trade
    Trade in tax often trumps trade in tasks.
  • Mexico
    Why U.S. Tax Reform Threatens Mexico's Financial Future
    While tweets and speeches may continue to cause consternation in Mexico and Canada, the existential threat to NAFTA seems to have passed. President Donald Trump is now talking about giving “renegotiation a good, strong shot” rather than rescinding the free trade agreement entirely. On the docket will be intellectual property, labor rights, e-commerce, rules of origin and the environment – issues Canada and Mexico are happy to upgrade, the outlines already defined within the ill-fated Trans-Pacific Partnership. More contentious issues could include “Buy American” clauses, border customs processes, sanitary measures, and import licenses, as well as specific grievances around the Canadian dairy and soft lumber industries, and regarding Mexican sugar imports. The process will undoubtedly be drawn out; the negotiations won’t begin in earnest until three months after the White House informs a still-waiting Congress. But for Mexico, there is another huge challenge to its economic future: U.S. tax reform. The most obvious and widely noticed threat is a border adjustment tax (BAT). As laid out in Speaker Paul Ryan’s tax reform “blueprint,” it would charge a 20 percent levy on all goods and services brought into the United States, and exempt U.S.-made exports from being taxed at all. Its proponents claim the dollar would appreciate the 25 percent necessary to call it an economic wash; others believe Mexico and other exporting nations would suffer. This pseudo-value added tax (VAT) is looking less and less likely, as it is opposed by Wal-Mart, Target and nearly every other major retailer, as well as by oil companies, car makers and others that depend on products from elsewhere to run their factories and businesses here. Even if it passes, it will face legal challenges in the World Trade Organization (WTO) for its non-VAT qualities, in particular allowing companies to deduct wages when calculating their BAT tax burden. A corporate tax cut is more likely to succeed, and could be as damaging for Mexico. Republicans across the board have long favored a reduction, and with the U.S.' current 35 percent tax rate ranking highest among OECD nations, they have an argument for it. Ryan talks of lowering the corporate rate to 20 percent, bringing the United States in line with the United Kingdom and Luxemburg. Trump’s more drastic 15 percent proposal would put the United States in the bottom 20 percent of chargers, beating out Germany and closing in on the “corporate tax haven” of Ireland. If the U.S. rate plummets, Mexico will be forced to follow suit. View full text of article, originally published in Americas Quarterly.
  • United States
    Just How Much Money Should the Border-Adjusted Tax Raise Be Expected To Raise?
    I have a new paper out with David Kamin of New York University Law School—it will be formally out in Tax Notes in a couple of weeks, but given that there is a live debate on the topic, we are posting it in draft form now—and the New York Times had a related editorial linking to it earlier this week. So this is a joint post with David Kamin. Our paper makes two arguments. 1) Even with fairly optimistic assumptions about long-term growth and long-term interest rates and the persistence of “excess returns” from U.S. direct investment abroad, the U.S. cannot sustain trade deficits of approaching 3 percent of GDP over the long-run. The CBO’s estimates for long-run growth and the long-run nominal interest rate on the U.S. debt stock imply a sustainable long-run trade deficit of about 1 percent of GDP. That would generate maybe 20 basis points of GDP in permanent revenue. If the excess returns (“dark matter”) on U.S. foreign direct investment go away, the U.S. would need to run a small trade surplus—and the border adjustment would lose revenue over the long-term. As a result, realistic projections of revenue from a border adjustment should show that revenue falling considerably and, possibly, entirely disappearing over the long-term. Remember the border adjustment acts as a tax on imports (imports are not deductible as a cost) and a subsidy for exports (a portion domestic wage and other content of exports is effectively rebated, as exports are not considered revenues while domestic wages are considered expenses, creating a tax loss). So it only generates revenue in net if the revenue collected on the border adjustment on imports exceeds the revenue lost on the export rebate. This is actually standard old school IMF external debt sustainability analysis.* The basic logic is simple. Sustained trade deficits over time lead to a build-up of external debt, and it is impossible to borrow forever both to run trade deficits—as over time you have to borrow both to finance the trade deficit and the interest on your accumulated debt. Countries can run modest current account deficits over time without rising external debt, but they cannot run trade deficits over time (well, technically, the non-interest current account, not the trade deficit) without an ever-rising stock of external debt to GDP. For those more familiar with fiscal sustainability, the trade deficit is roughly analogous to the primary fiscal balance. A modest headline fiscal deficit is often consistent with a stable debt to GDP ratio, but a large primary fiscal deficit generally is not. An obvious irony: a border adjustment is the only source of the long-term revenue Paul Ryan needs to make the tax reform permanent through the budget reconciliation process if the U.S. is projected to run permanent trade deficits. Or in the terms of Trump’s campaign, if the U.S. keeps losing at trade—an overall deficit means lots of bilateral deficits. 2) The actual revenues that the border adjustment will generate will be a function of how transfer price and similar tax games evolve, not just how the trade balance evolves—and current estimates fail to take into account the fact that the border adjustment will be avoided to some significant degree. To be sure, it might very well reduce the considerable tax gaming that we see in the current system—but not by 100 percent. Exempting exports from corporate income tax (and providing a rebate against domestic costs) while taxing imports removes the incentives for some tax games, but creates incentives for others. Especially if the U.S. alone adopts a destination-based cash flow tax. The border adjustment would remove the incentive for some existing tax games. That is a attractive feature of the proposal. Some firms try to shift profits made in the U.S. outside the U.S. through creative transfer pricing—say importing drugs invented in the U.S. from Ireland for example, and booking the profit on U.S. sales in Ireland. A destination based tax would help there. It also would end firms’ needs to game the U.S. system when it came to export of intellectual property—probably the largest distortion in the current system. Notably, though, it would do so by giving up U.S. taxes of the global export of U.S. intellectual property and possibly turning the United States into a tax shelter from other countries’ source-based tax systems. Right now, tech companies do not so much avoid tax on their U.S. profits as avoid tax on their global profits—Apple Ireland gets the rights to Apples IP for Europe, Asia, the Middle East, and Africa, and those profits are effectively untaxed (at least until the funds are repatriated back to the U.S). A destination-based cash flow tax would entirely exempt revenues from the exports of the intellectual property from tax, so it wouldn’t matter if the profit was booked in Ireland or California (and if Apple’s domestic cost exceeded its domestic revenues, it might even get a rebate). Only the destination would matter from the U.S. perspective. We consequently would expect that exports of intellectual property would rise sharply with the tax reform, bringing down the reported trade deficit—in part because companies will try to avoid remaining source-based taxation of other countries. After all, if Germany still taxes based on source of the profit and the United States does not, it makes all the sense in the world to report that profit in the United States! However, this new gaming would almost entirely affect the revenue bases of other countries, not the revenue base of the United States. But the incentive to export—and for businesses to avoid importing—would create new kinds of tax games that do affect the U.S. tax base and that revenue estimates we’ve seen don’t seem to take into account. Specifically, there would be—as David Hemel has noted—strong incentives to book U.S. sales as exports where possible. A firm would export to an offshore subsidiary and deduct its exports from revenues. And then sell directly from abroad to consumers, avoiding any business tax. More generally, firms that import would try to sell directly to consumers if the tax was entirely collected through businesses. In order for it to work, you actually have to have “VAT” style border enforcement to avoid leakage. Here is an example, one Brad got from his father, who brought back a German car as a souvenir while on sabbatical in the 1960s: Go on a vacation in Europe. Pick up a BMW in Munich. Spend a couple of weeks touring. Put your new car on a ship—and fly back to the U.S. Then pick up your (almost) new car at the nearest port. You pay the shipping, but not the 20 percent border-adjustment. Not if the border adjustment is imposed through business tax filings. Think that won’t happen? Think again. They way to stop it is to do actual adjustments for any goods at the border. But then it isn’t just a business income tax. And policing virtual borders is even harder. Realistically some leakage is inevitable—and needs to be factored into the revenue estimates. Simply taking the current trade deficit and multiplying it by 20 percent (or whatever the new tax rate is)—what some current estimates do—is almost sure to over-estimate actual revenues. And then there’s the fact that trade deficits should dissipate over the long-term. * New school IMF debt sustainability analysis focuses almost entirely on fiscal debt sustainability. Brad thinks that is a step backwards.
  • China
    How Serious Is the Threat to Global Financial Stability From a Border-Adjustment Tax?
    Neil Irwin’s column on the border-adjustment tax spurred an interesting debate. Irwin notes that a 25 percent rise in the dollar (or even a somewhat smaller rise) would have an impact outside the United States, as the dollar is a global currency. Dean Baker and Jared Bernstein note that the dollar moves around a lot without destroying the global economy. The projected moves in the dollar are no larger than the dollar’s 20 percent or so move over the last three years. Baker: "Movements of this size happen all the time. They certainly can cause problems, but the financial system generally deals with it." Fair enough.* I still worry though. There is a difference between a 20 percent move (off a long-term low) and a 30 or 40 percent move. And there is a difference between normal exchange rate volatility and large, sustained currency shifts. I would note that the 20 percent rise in the dollar in late 2014 and early 2015 contributed to the change in China’s currency regime—and China’s shift to managing against a basket roiled global markets from August 2015 to February 2016. The world survived, but it wasn’t totally smooth. Let me focus on two specific reasons for concern: One. Balance sheet mismatches in emerging economies.** Two. Dollar pegs, or basket pegs heavily weighted to the dollar. One. Balance sheet mismatches. These are the old bane of emerging economies. Countries over-borrow in foreign currency. Their currency depreciates. And the country cannot pay its debts back. This was a big part of the story of the Asian crisis. And of subsequent defaults in Ecuador, Russia, and Argentina. But things have changed since the 1990s. The governments of most large emerging economies have more foreign currency assets than foreign currency debts. Central bank foreign exchange reserves exceed foreign currency bonds issued by the government. This is the case in China’s central government—it has $3 trillion in foreign currency reserves and almost no foreign currency denominated bonds. And the governments of Brazil, Russia and India all also have more foreign currency reserves than foreign currency debt. The Saudis have issued a lot of dollar debt recently. But the Saudi government is still net long the dollar—foreign currency bonds are $17.5 billion (plus some loans), reserves are still $536 billion. The governments of big emerging markets are generally not big borrowers in dollars anymore. Even those with current account deficits. There are some (partial) exceptions. Turkey is an interesting case, though the government of Turkey has only a modest amount of foreign currency debt (roughly $30 billion). But it is close because Turkey really has very few reserves. Around $55 billion of the central banks $106 billion in reserves (foreign currency and gold) have in effect been borrowed from the banks (see Paul McNamara; or the footnotes in Turkey’s SDDS reserves disclosure), and thus aren’t a hedge for the government. Argentina too after its recent bond issue. Yet, in broad terms, emerging market governments are better positioned to withstand big foreign currency moves than in the past. (On the flip side, foreign investors have taken on more local currency risk—they are the ones who stand to lose.) As many have noted, the FX risks within emerging markets now largely lie on the corporate side. Emerging market firms stepped up their dollar borrowing even as emerging market governments stepped down. I wouldn’t assume that just because firms were able to withstand a twenty percent move in the dollar they can easily withstand a forty percent move—especially if U.S. rates move up. The actual risk though likely varies. A lot of the biggest emerging market corporate issuers of dollar denominated bonds likely have state backing—PEMEX ($100 billion in debt, not all in dollars), Petrobras (over $100 billion in debt), Rosneft, Gazprom, the Chinese state banks, the big Chinese airlines, and the like. And most of these countries hold enough reserves to cover the foreign currency debts of their big state companies as well as the direct foreign currency debts of the state. But that doesn’t mean that a further rise in the debt burden of state companies wouldn’t be painful. Those most exposed are countries where there are big, broader foreign currency mismatches throughout the corporate sector. Turkey for example. Any rise in the dollar effectively shifts wealth from Turkey’s firms to Turkey’s households—at least those with dollar deposits.*** At some point the strain will become too big, and the banks will have to restructure their corporate loan book and absorb losses. Turkey’s banks are already hurting from a decline in the lira, which reduces their equity buffers (the banks have big foreign currency balance sheets, but keep their equity in lira—so the equity base shrinks relative to their total liabilities as the currency weakens). And there are a set of countries and companies that are exposed not so much to the dollar’s value relative to other large exporters of manufactures (Japan, China, Korea and Europe) but to the dollar price of commodities. That though is a subject for another time. The impact of the border adjustment on global commodity prices (notably oil) is a hotly debated topic, and I am not convinced that it will be as mechanical as some have argued. The other risk comes from the world’s remaining dollar pegs. A stronger dollar pulls up the value of a lot of other currencies, as many countries still peg to the dollar -- even though a reasonable number of de facto dollar pegs have either broken or transformed into basket pegs over the last two and a half years (the Kazakh tenge for example, or the Nigerian naira) I will set aside the questions around the Saudi peg. A stronger real effective riyal would hinder the Saudis’ efforts to diversify their economy away from oil, but I never took those efforts all that seriously. What really matters for Saudi Arabia in my view is not so much the value of the dollar against the G-3, but the value of oil in Saudi riyals. Dollar/oil matters more than dollar/yen—or put differently, dollar/yen only matters to the extent it changes dollar/oil. The hardest questions involve China. It doesn’t float now. And strictly speaking it doesn’t manage its currency against the dollar. Rather it tightly manages its currency against a basket. China would have to decide how it wants to react to a border adjustment. It won’t happen automatically. And it is easy to see how this could be an important source of future instability. Consider the following. China could decide to maintain a basket peg, and thus let the renminbi adjust to the border adjustment in proportion to the global market adjustment (and specifically moves in the dollar/euro and dollar/Asia). Because of the weight of the dollar, the Hong Kong dollar and the Saudi riyal in China’s basket, the renminbi would move by say 2/3rds as much as the dollar moves against the major advanced economies (Mexico and China dominate the dollar basket versus emerging markets—and neither enters into China’s own basket—China for obvious reasons and Mexico because direct trade is limited). So if the dollar appreciated by about 15 percent against the majors, the mechanical operation of the basket would produce a roughly 10 percent appreciation in the renminbi against the dollar. That would offset less than half the border adjustment on China’s exports (a full offset of a 20 percent border-adjustment on imports, given the math, requires a 25 percent move). And other countries would also gain relative to China, as their currencies would depreciate more. Would the market—which in China, is primarily domestic institutions that can move funds across the border more easily than international investors—believe that China wouldn’t move by more? Or would it start to speculate that China ultimately would want a full adjustment? Would China’s controls be effective if domestic exporters and importers believed that a further depreciation was imminent? And if China did a full adjustment—a one off reset of the level of the basket—how would other currencies respond? Would China trigger even bigger depreciations elsewhere in Asia? It doesn’t seem to me all that hard to see how there is an overshoot in Asia, given the large role that China plays in Asian trade. I know that goes against the conventional wisdom that the border adjustment won’t be perfectly offset because capital flows exceed trade flows, which is true, but incomplete—as it doesn’t quite capture the dynamics around America’s largest single source of imported goods and the biggest single contributor to the dollar’s trade-weighted index. China’s currency is heavily influenced by trade flows, including financial outflows disguised as trade flows—and of course by expectations about the yuan’s future course against the dollar. Those would be destabilized by a border adjustment. China doesn’t have giant domestic foreign currency mismatches. There are a few (the airlines) but they are manageable in the big scheme of things. The risk to China comes from the potential impact of outflows (and the policies introduced to stem outflows) on domestic financial stability. And the risk to the world in turns comes from the trade impact from a complete break in China’s peg and a major depreciation of the renminbi. One that overwhelms any border adjustment. * Small aside on the border adjustment: a border adjustment eliminates the incentive to game the system by shifting profits offshore, but it does so by exempting profits on exports from any onshore tax. It basically abandons the notion of trying to tax the intellectual property (IP) rents on export income, or the economic rents from the export of natural resources for that matter. And it could create incentives for other kinds of gaming. I am convinced that the current system is heavily gamed in ways that hurt U.S. exports of IP and high-margin products (the active ingredient in pharmaceuticals for example), but the proposed border-adjustment gets rid of some of the games by in effect not taxing certain kinds of hard-to-tax income. ** I am assuming that large financial institutions in the advanced economies have matched books (whether directly, or through cross-currency swaps and similar hedges), and thus do not have any worrying balance sheet mismatches. That is also just an assumption. At the same time, the moves in the dollar/euro and dollar/yen have put balance sheets to test. *** Turkey’s central bank publishes data on the foreign currency book of its corporate sector. Others should too.
  • Corporate Governance
    Apple's European Tax Bill: Time to Pay Up and Play by the Rules
    Apple and its allies in the U.S. Treasury and Congress would have you believe that this week’s ruling by the European Commission that the company must pay some $14.5 billion in taxes owed to Ireland and other governments is an assault on one of America’s most innovative and successful companies. In fact, the case is not really about Apple at all – it is about Ireland and other governments, both national and local, that are willing and eager to offer whatever tax breaks and other subsidies are needed to attract corporate investment. That is the very definition of a global “race to the bottom.” and it is a big problem not just for Europe but for the United States and the world. The U.S. government should be standing with Europe on this issue, not against it. The background of the case is both complicated and simple. It is complicated because of the byzantine series of tax maneuvers that Apple undertook to ensure that it paid a tax rate on its European profits that, according the European Commission, fell from just 1 percent in 2003 to a mere 0.005 percent in 2014. Ireland eagerly facilitated these maneuvers in order to encourage investment by Apple, which has created about 6,000 jobs in the country. Disentangling Apple’s tax planning was no easy task – a Senate investigation in 2013 ran into hundreds of pages describing such exotic tax dodges as the “double Irish with a Dutch sandwich.” But it is also simple because Apple is doing what every other well-managed company in the world is doing – trying to maximize its returns by minimizing its tax bill through whatever legal means are available. The scofflaw here is not Apple, but rather Ireland. Its economic growth strategy is built around attracting investment by mobile multinational companies by offering rock-bottom corporate tax rates, and then aiding and abetting when companies scheme to lower their tax bills still further. The result of such behaviors by many governments is that corporate tax payments have been falling sharply around the world. Ireland’s headline tax rate of 12.5 percent is a fraction of the U.S. top rate of 35 percent, but corporate tax rates have been falling almost everywhere in the world. In the 1980s, the United States had one of the lowest statutory corporate tax rates among the advanced economies; today it has the highest. And the actual rates paid by companies are far lower. That leaves more of the bill for schools, roads, fire, police and the military to be picked up by individual taxpayers. For the United States, it has become extremely difficult for the government to tax the foreign profits of big corporations at all. As we showed in our recent book How America Stacks Up: Economic Competitiveness and U.S. Policy, roughly one-quarter of all foreign profits are reported in “tax haven” jurisdictions like Ireland. And U.S. tax law is structured so that no tax is paid to Uncle Sam as long as the profits are held offshore – Apple alone has currently parked more than $200 billion outside the United States, and U.S. corporations collectively are holding more than $2 trillion overseas. Where does the U.S. interest lie here? According to the U.S. Treasury, in a statement this week, the ruling “could threaten to undermine foreign investment, the business climate in Europe, and the important spirit of economic partnership between the U.S. and the EU.” It has pledged to flight the decision. Apple itself has accused the Commission of trying to “rewrite Apple’s history in Europe, ignore Ireland’s tax laws and upend the international tax system in the process." Both Apple and the Irish government are appealing the ruling. Certainly the U.S. government should be trying to encourage successful companies like Apple, and to advocate for them if they are faced with discriminatory practices abroad. But the Treasury is also responsible for the budget of the U.S. government, which means ensuring that all taxpayers – including U.S. corporations – are paying a reasonable share of tax. Apple’s maneuvers mean not just less tax paid to European governments, but less tax collected by the U.S. government as well. The issue is a classic collective action problem. All governments in the world (including many U.S. state governments which similarly lavish tax subsidies on big companies) would be better off with common rules that discouraged such practices. But in the absence of rules, each government has an incentive to try to cut its taxes ever lower and to offer special tax holiday in order to attract job-creating investment. That leaves corporations wealthier, while governments – and the public services they provide – grow poorer. As I argue in my forthcoming book Failure to Adjust: How Americans Fell Behind in Global Economic Competition, the absence of agreements restraining these sorts of investment subsidies is the biggest hole in global trade rules. The United States and other countries have negotiated all sorts of binding international arrangements – including the controversial Investor-State Dispute Settlement provisions – that prevent governments from discriminating against foreign investors. But there are essentially no rules to prevent governments from offering sweetheart tax deals and other subsidies to attract corporate investment, even though such subsidies violate free market principles and badly distort investment decisions. The European Union has done more than any other entity to try to enforce some common rules. Its “state aids code” spells outs clearly that member governments are forbidden from offering the sort of selective tax treatment that Apple appears to have received. The goal is to create a level playing field for all European countries that are similarly trying to attract investment. Those rules make it fairer for companies as well, especially small ones that lack Apple's ability to negotiate special deals.  As the Commission wrote in its ruling on the Apple case, the special treatment it received in Ireland “gives Apple a significant advantage over other businesses that are subject to the same national taxation rules.” Ireland is not alone in having violated those rules – the Commission has also gone after Luxembourg, Belgium and the Netherlands over tax breaks for companies such as Fiat and Starbucks. Instead of bashing Europe, the United States should be standing with the Commission in trying to build better global rules for tax competition – such as through the OECD’s Base Erosion and Profit Shifting (BEPS) initiative – and then ensuring those rules are vigorously enforced. As the global champion of free markets, the United States should be out in front in trying to ensure that investment goes to those places that offer the best opportunities for successful businesses rather than allowing companies to be lured by competition-distorting subsidies. There is a final irony in the U.S. position on the tax issue. The Obama administration – which is hoping to pass the new Trans-Pacific Partnership (TPP) trade agreement and to negotiate a similar deal with Europe – has been pushing back against the arguments of trade critics that such deals weaken national sovereignty and may endanger national consumer or product safety regulations. Certainly, global arrangements can tie the hands of national or state governments, sometimes in unwanted ways. Apple has seized on that argument by accusing the Commission of “striking a devastating blow to the sovereignty of EU members states over their own tax maters.” But what opponents of these trade deals and other international agreements miss is that they can also prevent governments from doing stupid things that harm the interests of their citizens – like eliminating taxes on wealthy corporations to attract investment or raising protectionist tariffs to serve some narrow corporate agenda. The EU ruling this week was a small blow against stupid, self-defeating government policies. The United States should be applauding. This article originally appeared on LinkedIn.com.
  • Corporate Governance
    Standard Deductions: U.S. Corporate Tax Policy
    Overview How America Stacks Up: Economic Competitiveness and U.S. Policy compiles all eight Progress Reports and Scorecards from CFR's Renewing America initiative in a single digital collection. Explore the book and download an enhanced ebook for your preferred device.  Nearly three decades after the last major tax overhaul, both Democratic and Republican parties and President Barack Obama agree that cutting the corporate tax rate and taxing foreign profits differently would move the tax system in the right direction. The outdated corporate tax system does not raise as much revenue as the systems of most other rich countries, even as U.S. corporate profits have reached record highs, according to a new progress report and scorecard from the Council on Foreign Relations' Renewing America initiative. "While the U.S. government has stood still on corporate tax reform, most advanced countries have been lowering corporate tax rates, reducing tax breaks, and changing how they tax foreign profits," write Renewing America Director Edward Alden and Associate Director Rebecca Strauss. The U.S. corporate tax rate is the highest in the developed world, at 39.1 percent, and has remained largely unchanged since the last major overhaul in the mid-1980s. However, due to tax breaks and taxes deferred on foreign profits that stay abroad, the effective tax rate paid by U.S. corporations is much lower. In 2008, it was at 27.1 percent compared to 27.7 percent for the rest of the OECD. The biggest tax break is for foreign profits, which have been increasing steadily as a share of corporate profits. The United States stands apart from most other developed countries in the way it handles other foreign profits. In practice, the U.S. tax is only levied if and when profits are repatriated to the United States. As a consequence, U.S. corporations keep most of their foreign profits abroad—as much as $2 trillion is currently retained offshore. Additionally, corporations pay highly uneven tax rates depending on whether they qualify for these tax breaks, with research-intensive multinational companies paying much lower rates, for example, than domestic retailers. Yet recent reform attempts have failed, including Republican Representative Dave Camp’s ambitious 2014 proposal. Comprehensive tax reform may have to wait until after the 2016 Presidential election. The general contours of a likely reform have been drawn—cutting corporate rates, evening out effective rates, and taxing foreign profits differently. Congressional leaders have said comprehensive tax reform is not possible until after the 2014 elections. The general contours of a likely reform have been drawn—cutting corporate rates, evening out effective rates, and taxing foreign profits differently. Read Alden and Strauss's op-ed on their report findings on Fortune.com. This scorecard is part of CFR's Renewing America initiative, which generates innovative policy recommendations on revitalizing the U.S. economy and replenishing the sources of American power abroad. Scorecards provide analysis and infographics assessing policy developments and U.S. performance in such areas as infrastructure, education, international trade, and government deficits. The initiative is supported in part by a generous grant from the Bernard and Irene Schwartz Foundation. Download the scorecard [PDF]. Table of Contents Click on a chapter title below to view and download each Progress Report and Scorecard.