April 10, 1941
Mr. Blough
Mr. Ecker-R. and Mr. Farioletti
Subject: Some considerations respecting the advantages
of increased and additional selective excise over a
general sales tax
The principal considerations which might be advanced
in support of more intensive use of selective excises, as
opposed to the introduction of a general sales tax, fall
into six general categories: (A) Public policy; (B)
Revenue; (C) Equity among producers; (D) Incidence; (E)
Tax compliance; and, (F) Tax administration.
A. WITH RESPECT TO PUBLIC POLICY
1. Insofar as the need for additional revenue is of an
emergency character, it can be met more successfully
through the use of selective excises than by a general
sales tax would require the creation of an elaborate
administrative structure entailing more time and expense
than a temporary tax warrants (assuming that the revenue
requirements do not necessitate the imposition of so
large a number of excises as to approach the general
sales tax in scope.)
2. The conflict between the Administration's declared
policy of avoiding regressive taxes and the imposition of
consumption taxes can be minimized by the use of taxes on
specific commodities selected with this objective in
view. By fitting the selective tax structure to the
peculiar characteristics of individual commodities,
regressivity can be kept to a minimum.
3. By employing the flexibility inherent in selective
excises, many of the economic dislocations consequent to
a general sales tax can be minimized.
4. The super-imposition of a general sales tax on
existing Federal excises would add to the complexity of
the Federal tax structure.
5. Should the defense program require the curtailment
of civilian consumption of specific commodities through
tax measures, the existence of an elaborate excise
structure would afford a flexible instrument for that
purpose.
6. The Federal-State fiscal conflict involved in the
imposition of a Federal sales tax in addition to existing
state and local sales taxes would in part be mitigated by
a more intensive and extensive use of selective excises.
7. The imposition of a Federal general sales tax in
addition to the existing State sales taxes would arouse
much public opposition, which in part could be avoided by
a greater use of selective excises, even if revenue
requirements necessitate substantial additions to the
present list.
B. WITH RESPECT TO REVENUES
1. Within limits, a given amount of revenue could be
raised more readily through the use of selective excises
imposed at higher rates than by a lower-rate general
sales tax.
2. While the potential revenue yield from a general
sales tax is higher than that from selective excises,
this potential yield cannot be readily achieved because
of (a) the administrative necessity for a low rate; (b)
the inevitable exemption of important articles of common
consumption; (c) the administrative requirement for a
minimum sales exemption; and, (d) the probability of less
effective administration.
3. The initial rate of a general sales tax would have
to be lower than that in the case of selective excises
because of (a) the lack of Federal experience with a
general sales tax and the necessity for developing a new
administrative structure; (b) the necessity for keeping
the rate low in order to minimize litigation; and (c) the
need for minimizing the unequal economic effects of a
general rate of tax applied to commodities in general.
The rate of the general sales tax has to be low to
minimize the disturbing effects of the tax in those cases
in which a larger tax cannot be passed on by the
taxpayer.
C. WITH RESPECT TO EQUITY AMONG PRODUCERS
1. Selective excises can be adapted to the supply
characteristics of individual commodities. By exploiting
this flexibility the competitive position of different
producers within the industry will be disturbed less than
under a general sales tax.
2. In selective excises uniformity of tax base can be
more readily achieved than under a general sales tax
because the taxpayers within one industry are more
homogeneous than taxpayers in all industries.
3. To the extent that homogeneity is lacking among
several producers in the same industry, it can be more
readily compensated for by special provision. As a
consequence, the revenue obtainable from selective
excises can be maximized without the undesirable economic
effects inherent in a similar attempt under a general
sales tax.
D. WITH RESPECT TO INCIDENCE
1. The use of selective excises enables the adaptation
of the taxes to the demand characteristics peculiar to
each commodity. The regressive character of commodity
taxation can be minimized by imposing the excises on
those articles for which the consumption expenditures are
relatively more important at the higher than at the lower
income levels.
2. Special exemption provisions with respect to each
article would permit the tax burden to be less regressive
than under a sales tax.
3. Since multiple taxation is likely to be only
incidental under selective excises, the tax burden with
respect to consumers would tend to be less regressive.
4. Pyramiding could be more readily controlled NBER
excise taxes than under a general sales tax;
consequently, the undesirable effects of pyramiding could
be more easily avoided.
E. WITH RESPECT TO TAX COMPLIANCE
1. The number of taxpayers under selective excises
would be substantially less than under a general sales
tax.
2. The imposition of a general sales tax, in addition
to the present excises would in the case of many
taxpayers necessitate the preparation of several tax
returns and the payment of several separate taxes with
respect to the same transaction. A more intensive use of
excises would minimize that possibility.
3. The use of selective excises would enable the
issuance of more specific tax regulations than would be
possible if a general sales ax were imposed. This, in
turn, would make for more certainty on the part of
taxpayers.
4. The more intensive use of selective excises would
mean that in many cases the additional revenue would be
collected form taxpayers already experienced in paying
the particular tax and in complying with the regulations.
The general sales tax on the other hand would require the
education of a vast number of new taxpayers.
F. WITH RESPECT TO TAX ADMINISTRATION
1. Within limits, a certain amount of tax revenue can
be raised with less administrative difficulty from higher
rates on existing excises and from new selective excises
than from a general sales tax.
2. In view of the complex and diverse character of the
several segments of American industry and the
impracticability of recognizing such diversities in
statutes and regulations, the administration of a general
sales tax would not be as effective as that of selective
excises. However, a greater delegation of discretionary
authority to tax administrators would be an offsetting
consideration.
3. Uniformity of tax base -- especially troublesome
because of important variations among taxpayers in the
character and degree of industrial integration sales
policies, and form of business organizations -- can be
more readily attained under the excises than under a
general sales tax because of greater opportunities of
fitting the tax on each commodity to the representative
situation (the ordinary course of trade) in each
industry.
4. The difficulties of "multiple taxation"
raised by a general sales tax can be avoided almost
entirely under selective excises.
5. The efficient administration of exemption
provisions can be accomplished more successfully under
selective excises.
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