Laurence J. Kotlikoff

Jane Gravelle

An important deficiency in Harberger's (1962) model of corporate income taxation is its inability to consider both corporate and noncorporate production of the same good. This precludes analysis of within-industry substitution of noncorporate for corporate production in response to the tax. Such within-industry substitution has potentially major implications for both the excess burden and incidence of the corporate tax. In Gravelle and Kotlikoff (1988) we present a new model of the corporation income tax. The model has two key characteristics. First, corporate and noncorporate firms produce (with identical production functions) each of the model's goods both before and after corporate taxation is imposed, and second, the decision of entrepreneurs to establish unincorporated business is endogenous. Compared with the Harberger model, the new model predicts a very much larger excess burden from corporate income taxation. The incidence of the corporate tax can also differ dramatically in the two models. Several commentators on our approach suggested that while corporate and noncorporate fins produce goods that are close substitutes, they are not necessarily identical goods. Others questioned the extent to which our results hinged on the endogeneity of entrepreneurship. This paper is a response to those comments. It presents a Harberger-type model (with no entrepreneurs), but one in which each industry/sector contains corporate and noncorporate fins (with identical production functions) which produce goods that are close substitutes in demand. As in our earlier model, the scope for considerable within-industry substitution of noncorporate for corporate capital leads to a very much larger excess burden than that in the Harberger model. For example, using Harberger's original 195? data and assuming unitary substitution elasticities in production and in inter-sector demand, but substitution elasticities of 30 in intra-sector demand, the excess burden of the corporate income tax in the current model is 107 percent of tax revenue. This figure is quite close to the 123 percent figure reported in Cravelle and Kotlikoff (1988) for the case of unitary substitution elasticities in production and inter-industry demand. Both numbers are considerably larger than the 8 percent excess burden figure that arises in the traditional Harberger model with unitary substitution elasticities.

Another Model Says Yes

Does the Harberger Model Greatly Understate the Excess Burden of the Corporate Tax?

Joseph J. Cordes

Robert D. Ebel

"From adjusted gross income to zoning and property taxes, the second edition of The Encyclopedia of Taxation and Tax Policy offers the best and most complete guide to taxes and tax-related issues. More than 150 tax practitioners and administrators, policymakers, and academics have contributed. The result is a unique and authoritative reference that examines virtually all tax instruments used by governments (individual income, corporate income, sales and value-added, property, estate and gift, franchise, poll, and many variants of these taxes), as well as characteristics of a good tax system, budgetary issues, and many current federal, state, local, and international tax policy issues. The new edition has been completely revised, with 40 new topics and 200 articles reflecting six years of legislative changes. Each essay provides the generalist with a quick and reliable introduction to many topics but also gives tax specialists the benefit of other experts' best thinking, in a manner that makes the complex understandable. Reference lists point the reader to additional sources of information for each topic. The first edition of The Encyclopedia of Taxation and Tax Policy was selected as an Outstanding Academic Book of the Year (1999) by Choice magazine."--Publisher's website.

Jane Gravelle

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