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Taxation and Valuation

Leonid A. Levin

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Abstract: I explain the root of persistent failure of efforts to remove tax-induced distortions of economic incentives. It lies in FUNDAMENTAL IMPOSSIBILITY of objectively evaluating tax base. Distortions can be entirely avoided in the sector of publicly traded corporations. Evaluation can be bypassed by taxing it in shares (to be auctioned) rather than cash. Stock capital includes cost basis (B) and unrealized gains (G). Gains are presently tax-deferred until realized in divestment. The deferral is remedied by corporate income tax (rate t). i is the variable interest rate on special constant value "cv-bonds". The proposed system replaces (1) corporate income tax - with interest on the deferred G*t, and (2) divestment taxes - with interest on B*t. To collect both, IRS will periodically take to auction a fraction i*t of privately held publicly traded shares. Note: (2) is a neutral simplification: Investments can be split into B(1-t) stock and B*t in bond portfolios. Bond interest buys back the auctioned shares, and tax-free divestment matches the original yield. The i*t stock tax matches the income tax on cv-bond portfolios of equal value. The Treasury, too, could match its income (in bond sales) to the rate t tax on the full stock market return (without tempting price manipulation). It can vary i to keep the bond volume at a fraction t of market capitalization; then share auctions supply bond interest. Taxpayers, too, could unilaterally match their burden to such tax by keeping a fraction t of capital in bonds. The main feature is: nothing companies and investors do can change their tax (fraction i*t of shares), so business decisions would be exactly the same as without taxes. No longer would taxes on dividends and capital gains impede capital flow, companies would forget bewildering mazes of tax laws, regulations, precedents; Congress would still collect the same revenue it now does.

Date: 2000-12, Revised 2024-11
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Published in Tax Notes Federal, 164(7):1065-1067 (8/12/2019)

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