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Testimony: 

Before the Committee on Finance, U.S. Senate: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 10:30 a.m. EDT: 

Thursday, August 3, 2006: 

Individual Income Tax Policy: 

Streamlining, Simplification, and Additional Reforms Are Desirable: 

Statement of David M. Walker Comptroller General of the United States: 

GAO-06-1028T: 

GAO Highlights: 

Highlights of GAO-06-1028T, a testimony before the Committee on 
Finance, U.S. Senate 

Why GAO Did This Study: 

The federal government currently relies heavily on the individual 
income tax and payroll taxes for about 80 percent of its total annual 
revenue. Long-range projections show that without some form of policy 
change, the gap between revenues and spending will increasingly widen. 
The debate about the future tax system is partly about whether the 
goals for the nation’s tax system can be best achieved by reforming the 
current income tax so that it has a broader base and flatter rate 
schedule, or switching to some form of consumption tax. 

This testimony reviews the revenue contribution of the current 
individual income tax as well as its complexity, economic efficiency, 
equity, and taxpayer compliance issues; discusses some common 
dimensions to compare tax proposals; and draws some conclusions for tax 
reform. 

This statement is based on previously published GAO work and reviews of 
relevant literature. 

What GAO Found: 

The United States faces a large and growing structural budget deficit 
as current projected revenues are not sufficient to fund projected 
spending. The individual income tax has long been the largest source of 
federal revenue—amounting to $927 billion (7.5 percent of Gross 
Domestic Product (GDP)) in 2005. (Total revenues that year amounted to 
17.5 percent of GDP.) Income tax policy, including existing tax 
expenditures, such as the exclusion of employer-provided health 
insurance from individual income, and enforcement approaches, need to 
be key elements of a multipronged approach that reexamines federal 
policies and approaches to address our nation’s large and growing long-
term fiscal imbalance. 

Concerns regarding the complexity, efficiency, and equity of the 
individual income tax have contributed to calls for a substantial 
restructuring of the individual income tax or its full or partial 
replacement with some form of consumption tax. The widely recognized 
complexity of the tax results in (1) significant compliance costs, 
frustration, and anxiety for taxpayers; (2) decreased voluntary 
compliance; (3) increased difficulties for the Internal Revenue Service 
(IRS) in administering the tax laws; and (4) reduced confidence in the 
fairness of the tax. The tax also causes taxpayers to change their 
work, savings, investment, and consumption behavior in ways that reduce 
economic efficiency and, thereby, taxpayers’ well-being. 

Taxpayer noncompliance with the current individual income tax is 
another factor that could motivate reform. For tax year 2001, IRS 
estimated that noncompliance with the individual income tax accounted 
for about 70 percent of the $345 billion gross tax gap, which is the 
difference between the taxes that should have been paid voluntarily and 
on time and what was actually paid. Reducing this gap can improve the 
nation’s fiscal stability, as each 1 percent reduction in the tax gap 
would likely yield about $3 billion annually. Reducing the tax gap 
within the current income tax structure will require exploring new and 
innovative administrative and legislative approaches. 

In moving forward on tax reform, policymakers may find it useful to 
compare alternative proposals along some common dimensions. These 
include, in part, whether proposed tax systems over time will generate 
enough revenue to fund expected expenditures, whether the base is as 
broad as possible so rates can be as low as possible, whether the 
system meets our future needs, and whether it has attributes that 
promote compliance. Our publication, Understanding the Tax Reform 
Debate (GAO-05-1009SP), provides background, criteria, and questions 
that policymakers may find useful. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO--06-1028T]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact James White at (202) 512-
9110 or whitej@gao.gov. 

[End of Section] 

Mr. Chairman and Members of the Committee: 

I appreciate this opportunity to contribute to your consideration of 
fundamental tax reform by discussing the individual income tax. 
Although the focus of my statement is the individual income tax, it 
clearly makes sense to consider a broader reform encompassing both the 
individual and corporate income taxes and much of my message is 
applicable to broad reforms.[Footnote 1] 

As the Committee is well aware, two fundamental objectives of a tax 
system are (1) to raise revenue sufficient to fund projected spending 
and (2) to do so in a manner that is fair, relatively easy to 
administer, and minimizes negative effects on the economy. 
Unfortunately, over time, the accumulated changes to our individual tax 
system have not been consistent with these objectives and, not 
surprisingly, there is a growing debate about the fundamental design of 
the current tax system. 

The debate about the future tax system is partly about whether the 
goals for the nation's tax system can be best achieved by reforming the 
current income tax so that it has a broader base and a flatter rate 
schedule, or switching in whole or in part to some form of a 
consumption tax. The President's Advisory Panel on Federal Tax Reform 
has taken a major step in beginning this debate.[Footnote 2] The Panel 
suggested two alternative proposals for coordinated reform of the 
individual and corporate income taxes and thereby advanced the public 
debate over how best to simplify these taxes and their proposals 
include the desirable combination of broader tax bases and lower tax 
rates. 

My statement reviews the revenue contribution of the current individual 
income tax as well as its complexity, economic efficiency, equity, and 
taxpayer compliance issues. It also draws some conclusions regarding 
the need for tax reform. My statement today makes the following points: 

* The debate about the fundamental design of the tax system is 
occurring at a time when the nation also faces a large and growing 
structural budget deficit, as under current policy, the gap between 
revenues and spending will widen over the next few decades. The 
individual income tax has long been the single largest source of 
federal tax revenue--amounting to $927 billion in 2005. Individual 
income tax policy, including existing tax expenditures and enforcement 
approaches, needs to be an element of a multipronged approach that 
reexamines existing federal policies and approaches to address the 
nation's large long-term fiscal imbalance. 

* Concerns regarding the complexity, economic efficiency, and overall 
equity of the individual income tax have contributed to calls for a 
substantial restructuring of the individual tax or its full or partial 
replacement with some form of consumption tax. The widely recognized 
complexity of the tax results in (1) significant compliance costs, 
frustration and anxiety for taxpayers; (2) decreased voluntary 
compliance; (3) increased difficulties for the Internal Revenue Service 
(IRS) in administering the tax laws; and (4) reduced confidence in the 
fairness of the tax. As discussed in our publication, Understanding the 
Tax Reform Debate[Footnote 3] the individual income tax also causes 
taxpayers to change their work, savings, investment, and consumption 
behavior in ways that reduce economic efficiency and taxpayers' well- 
being. 

* Taxpayer noncompliance with the current individual income tax is 
another factor that could motivate reform. For tax year 2001, IRS 
estimated that noncompliance with the individual income tax accounted 
for about 70 percent of the $345 billion gross tax gap, which is the 
difference between the taxes that should have been paid voluntarily and 
on time and what was actually paid. Reducing this gap can improve the 
nation's fiscal stability, as each 1 percent reduction in the tax gap 
would likely yield about $3 billion annually. Given its persistence and 
size, reducing the tax gap within the current income tax structure will 
require exploring new and innovative administrative and legislative 
approaches. 

* In moving forward on tax reform, policymakers may find it useful to 
compare alternative proposals along some common dimensions. Among these 
are whether a proposed tax system will generate sufficient revenue over 
time to fund whatever spending path is chosen, whether the base is as 
broad as possible so rates can be as low as possible, and whether it 
has attributes that promote compliance. Our publication, Understanding 
the Tax Reform Debate, provides background, criteria, and questions 
that policymakers should find useful.[Footnote 4] 

My statement today is drawn from previous GAO reports and testimonies, 
which were done in accordance with generally accepted government 
auditing standards, as well as reviews of relevant literature. 

Background: 

The base of the individual income tax covers income paid to 
individuals, such as wages, interest, dividends, realized net capital 
gains, various forms of business income, and income from pensions, 
annuities, trusts and estates. This tax base is reduced by personal 
exemptions for taxpayers and their spouses and children, as well as by 
numerous preferences--statutorily defined as tax expenditures--such as 
the deduction for mortgage interest, the earned income tax credit, and 
the exclusion of the value of employer-provided health insurance from 
individuals' taxable income and taxable wage base. The statutory rates 
of tax on net taxable income range from 10 percent to 35 percent. Lower 
rates (5 percent and 15 percent, depending on taxable income) apply to 
long-term capital gains and dividend income. 

Individuals may also pay tax under the alternative minimum tax (AMT). 
The base of this tax equals regular taxable income, plus the value of 
various tax items, including personal exemptions and certain itemized 
deductions that are added back into the base. This AMT income base is 
then reduced by a substantial exemption and then taxed at a rate of 26 
percent or 28 percent, depending on the taxpayer's income level. 
Taxpayers compare their AMT tax liabilities to their regular tax 
liabilities and pay the greater of the two. 

Although the income tax applies to all who have taxable income, nearly 
all workers pay social insurance taxes to fund retirement, disability 
and retiree health programs. According to Congressional Budget Office 
estimates, in 2000 over 40 percent of households paid more in just 
their portion of social insurance taxes than they paid in income taxes. 
Further, when both their contribution and their employers' is counted, 
over 70 percent of households paid more in social insurance taxes than 
they did in income taxes. The consensus among economists is that the 
employees ultimately bear the entire social insurance tax burden. In 
2005 workers paid a total of $794 billion in social insurance taxes to 
fund federal social insurance, retirement, disability, and retiree 
health programs. This amount was in addition to their income tax 
liabilities. From the taxpayers' view, these taxes may not appear 
significantly different than income taxes. They reduce the workers' 
take-home pay each pay period and, although the taxes are set aside in 
a separate account to fund specific benefits, the portion of these 
taxes not immediately needed for current beneficiaries goes to fund 
current government expenses just like income taxes. 

Three long-standing criteria--equity; economic efficiency; and a 
combination of simplicity, transparency, and administrability--are 
typically used to evaluate tax policy. These criteria are often in 
conflict with each other and, as a result, there are usually trade-offs 
to consider and people are likely to disagree about the relative 
importance of the criteria. 

To the extent that a tax is not simple and efficient, it imposes costs 
on taxpayers beyond the payments they make to the U.S. Treasury. As 
shown in figure 1, the total cost of any tax from a taxpayer's point of 
view is the sum of the tax liability, the cost of complying with the 
tax system, and the economic efficiency costs that the tax imposes. In 
deciding on the size of government, we balance the total cost of taxes 
with the benefits provided by government programs. 

Figure 1: Components of the Total Cost of a Tax to Taxpayers: 

[See PDF for image] 

Source: GAO. 

[End of figure] 

The United States Faces a Large and Growing Structural Budget Deficit: 

Over the long term, the United States faces a large and growing 
structural budget deficit primarily caused by known demographic trends 
and rising health care costs, and this deficit is exacerbated over time 
by growing interest on the ever larger federal debt. Continuing on this 
imprudent and unsustainable fiscal path will gradually erode, if not 
suddenly damage, our economy, our standard of living, and ultimately 
our national security. Addressing the nation's long-term fiscal 
imbalances constitutes a major transformational challenge that may take 
a generation or more to resolve. Fiscal necessity may prompt a 
fundamental review of major program and policy areas. Many current 
federal programs and policies--including tax policies--were designed 
decades ago to respond to trends and challenges that existed then but 
may no longer suit our 21st century needs. Clearly, the individual 
income, social insurance, and corporate income taxes, which have been 
the federal government's three largest sources of revenue, will need to 
be considered in any plan for addressing the nation's long-term fiscal 
imbalance. 

Revenues from the Current Tax System Are Not Sufficient to Fund 
Projected Spending: 

Over the next few decades, as the baby boom generation retires, federal 
spending on retirement and health programs, such as Social Security, 
Medicare, and Medicaid, will grow dramatically and bind the nation's 
fiscal future. Absent policy changes on the spending and/or revenue 
sides of the budget, a growing imbalance between federal spending and 
tax revenues will mean escalating and ultimately unsustainable federal 
deficits and debt. In simple terms, the gap between projected spending 
and expected revenues grows larger every year. For example, as figure 2 
indicates, if discretionary spending grows at the same rate as the 
economy, all expiring tax provisions are extended, and then federal 
revenues are held as a constant share of the economy, revenues could be 
adequate to cover little more than interest on the federal debt by 
2040. 

Figure 2: Composition of Federal Spending as a Share of GDP, Assuming 
Discretionary Spending Grows with GDP after 2006 and That Expiring Tax 
Provisions Are Extended: 

[See PDF for image] 

Source: GAO's May 2006 analysis. 

Note: The revenue projection in this figure includes certain tax 
provisions that expired at the end of 2005, such as the increased 
alternative minimum tax exemption amount. 

[End of figure] 

We cannot grow our way out of this long-term fiscal challenge because 
the imbalance between spending and revenue is so large. We will need to 
make tough choices using a multipronged approach: (1) revise budget 
processes and financial reporting requirements; (2) restructure 
entitlement programs; (3) reexamine the base of discretionary spending 
and other spending; and (4) review and revise tax policy, including tax 
expenditures and tax enforcement programs. Individual income tax 
policy, tax expenditures, and enforcement need to be key elements of 
the overall tax review. 

One promising--and perhaps necessary--approach to tackling both the tax 
and entitlements part of our long-term fiscal challenge is a credible, 
capable, and bipartisan Tax and Entitlements Reform Commission. Such an 
approach would help ensure that any decisions made on taxes and 
spending are well coordinated and will produce a sustainable fiscal 
system that meets agreed-upon objectives. 

The Individual Income Tax Is the Largest Single Source of Federal 
Revenues: 

The individual income tax has long been the single largest source of 
federal tax revenue. In 2005, individual taxpayers paid $927 billion in 
income taxes. Figure 3 shows the relative importance of federal taxes. 
Since 1962, the individual income tax has ranged between a low of 7 
percent (in 2004) and a high of 10.3 percent (in 2000) of gross 
domestic product (GDP). Over the same period, social insurance taxes 
have grown considerably in importance--from 3 percent of GDP in 1962 to 
6.5 percent of GDP (or $794 billion) in 2005. Revenue from the 
individual income tax has historically accounted for between 40 percent 
and 50 percent of total federal tax revenue. In contrast, in the early 
1960s, social insurance taxes accounted for less than 20 percent of the 
total; however, they have grown to represent 37.1 percent of revenue in 
2005. 

Figure 3: Federal Revenues as a Percentage of GDP, 1962 to 2005: 

[See PDF for image] 

Source: GAO representation of Office of Management and Budget (OMB) 
data. 

[End of figure] 

Individual Income Tax Complexity, Compliance, and Efficiency Costs and 
Equity Concerns Contribute to Calls for Reform: 

Concerns about the complexity, efficiency, and equity of the individual 
income tax have motivated calls for a substantial restructuring of the 
tax or its replacement with some form of consumption tax. The widely 
recognized complexity of the tax results in (1) significant compliance 
costs, frustration, and anxiety for taxpayers; (2) decreased voluntary 
compliance; (3) increased difficulties for IRS in administering the tax 
laws; and (4) reduced confidence in the fairness of the tax. The 
individual income tax also causes taxpayers to change their work, 
savings, investment, and consumption behavior in ways that reduce their 
well-being.[Footnote 5] These reductions in well-being, known to 
economists as efficiency costs, are likely to be large--perhaps on the 
order of 2 percent of GDP or more. The success of our tax system hinges 
very much on the public's perception of its fairness and transparency. 
There are differences of opinion about the overall fairness of the 
individual income tax and concerns have been expressed about the equity 
of many specific features of the tax. 

Important Sources of Complexity Are Income Documentation Requirements 
and Tax Expenditure Rules: 

If they are to take advantage of the many tax benefits in the tax code, 
virtually all taxpayers must familiarize themselves with, or pay 
someone to advise them on, the sometimes complex rules for determining 
whether they qualify (and, if so, to what extent). Moreover, in cases 
where multiple tax expenditures have similar purposes, taxpayers may 
have to devote considerable time to learn and plan in order to make 
optimal use of these tax benefits. For example, the IRS publication Tax 
Benefits for Education[Footnote 6] outlines 12 tax expenditures, 
including 4 different tax expenditures for educational saving. The use 
of one of these tax expenditures can affect whether (or how) a taxpayer 
is allowed to use the other tax expenditures. Adding to the taxpayer's 
challenge to select the best educational tax benefit, the use of one of 
these tax expenditures may affect a student's eligibility for other 
forms of federal assistance for higher education, such as Pell grants 
and subsidized loans.[Footnote 7] 

The tax benefits, or tax expenditures, available under the income tax 
are usually justified on the grounds that they promote certain social 
or economic goals. They grant special tax relief (through deductions, 
credits, exemptions, etc.) that encourages certain types of behavior by 
taxpayers or aids taxpayers in certain circumstances. Tax expenditures 
can promote a wide range of goals, like encouraging economic 
development in disadvantaged areas, financing postsecondary education, 
or stimulating research and development. For example, a wide range of 
tax provisions are intended to help individuals save for their 
retirement. These include traditional and Roth Individual Retirement 
Accounts (IRA) and various plans administered by employers or available 
to self-employed individuals. Again, individuals face complex choices 
to select the best options as well as complex rules to stay in 
compliance once they select a retirement savings option. From a public 
policy perspective, all of this complexity and the burden it imposes on 
taxpayers would most likely be worthwhile if the tax incentives are 
successful in achieving their intended purposes. However, in many cases 
this is questionable or unknown. Although research results vary, many 
studies suggest that IRAs result in little actual increase in 
retirement saving. One concern is that individuals can take a lump sum 
withdrawal and, depending on how the sum is used, the individual may 
not have a sufficient stream of income over his/her remaining lifetime. 

Tax Expenditures Have Been Growing: 

The sum of the revenue loss estimates associated with tax expenditures 
was more than $775 billion in 2005 and the vast majority of this loss 
was for tax expenditures provided to individuals, rather than to 
corporations.[Footnote 8] As the data in figure 4 indicate, revenue 
losses due to tax expenditures exceeded discretionary spending for half 
of the last decade. 

Figure 4: Trends in Spending and Tax Expenditure Revenue Losses, 1982- 
2005: 

[See PDF for image] 

Source: GAO analysis of OMB budget reports on tax expenditures, fiscal 
years 1976-2007. 

Note: Summing the individual tax expenditure estimates is useful for 
gauging the general magnitude of the federal revenue involved, but it 
does not take into account possible interactions between individual 
provisions. 

[End of figure] 

Much of the revenue loss due to individual income tax expenditures is 
attributable to a small number of large tax expenditures. The seven tax 
expenditures shown in figure 5--each with an annual revenue loss 
estimated at $36 billion or more--accounted for about half of the sum 
of revenue losses for all tax expenditures for fiscal year 2005. With 
revenue losses estimated at $4.9 billion, the earned income tax credit 
(EITC) does not appear on this list. The EITC has both revenue losses 
and outlays when a taxpayer's refund exceeds their tax liability. If 
$34.6 billion in associated outlays were included, this refundable 
credit would rank among the largest tax expenditures. 

Figure 5: Revenue Loss Estimates for the Seven Largest Reported Tax 
Expenditures for Individuals, Fiscal Year 2005: 

[See PDF for image] 

Source: OMB, Analytical Perspectives, Budget of the United States 
Government, Fiscal year 2007. 

[A] If the payroll tax exclusion were also counted here, the total tax 
expenditure for employer contributions for health insurance premiums 
would be about 50 percent higher or $177.6 billion. 

[B] This is the revenue loss and does not include associated outlays of 
$14.6 billion. 

[End of figure] 

Although Difficult to Measure, Compliance Burden Is Likely a 
Significant Cost to Taxpayers: 

The costs of complying with the individual income tax are large but 
unclear. IRS's most recent estimates suggest that these costs are 
roughly on the order of ½ to 1 percent of GDP. These costs include the 
time and money spent complying with the computational, reporting, 
planning, and recordkeeping requirements of the tax system. Estimates 
of compliance costs are uncertain because taxpayers generally do not 
keep relevant records documenting their time and money spent complying 
with the tax system and many important elements of the costs are 
difficult to measure because, among other things, federal tax 
requirements often overlap with recordkeeping and reporting that 
taxpayers do for other purposes. 

The available compliance cost estimates do not represent the potential 
cost savings to be gained by replacing the current federal individual 
income tax. Any replacement tax system will impose significant 
compliance costs of its own. Moreover, given that many state and local 
government income taxes depend upon the same compliance activities as 
the federal income tax does, taxpayers would still bear the costs of 
those activities unless those other governments replaced their own 
taxes to conform to the new federal system. In addition, if some of the 
subsidies, such as the earned income tax credit and child tax credit, 
which are provided by the current federal tax system, are replaced by 
spending programs under a reformed system, tax compliance costs may be 
reduced, but only as a result of their being shifted to those new 
programs. Similarly, if a replacement tax system no longer requires 
individuals to compute and document their incomes, individuals will 
still need to document their incomes for borrowing and other purposes, 
and government statistical agencies will incur expenses to replace the 
data that they currently obtain from income tax returns. 

Taxes Generally Reduce Economic Efficiency: 

Taxes impose efficiency costs by altering taxpayers' behavior, inducing 
them to shift resources from higher valued uses to lower valued uses in 
an effort to reduce tax liability. This change in behavior can cause a 
reduction in taxpayers' well-being that, for example, may include lost 
production (or income) and consumption opportunities. One important 
behavioral change attributable to the income tax arises from the fact 
that investment in housing is given more favorable treatment than 
investment in business activities. Economists generally agree that this 
differential tax treatment reduces the amount of money available to 
businesses for investment in productivity-enhancing technology. This in 
turn results in employees receiving lower wages because increases in 
wages are generally tied to increases in productivity. The tax 
exclusion for the exclusion of employer-provided health insurance from 
individuals' taxable income, discussed in text box 1, is another 
example of an income tax provision that clearly reduces economic 
efficiency. The exclusion encourages more extensive insurance coverage, 
but introduces a well-known problem with health insurance. Because much 
of the cost of medical treatment is paid for by the insurer, patients 
and doctors are generally unaware of, or disconnected from, the total 
costs of health care and have little incentive to economize on health 
care spending. 

Efficiency costs, along with the tax liability paid to the government 
and the costs of complying with tax laws, are part of the total cost of 
taxes to taxpayers. However, this does not mean that taxes are not 
worth paying. One reason people bear taxes is they desire the benefits 
of government programs and services. (The government does deliver some 
services effectively and often provides services that otherwise would 
not be available.) Taxpayers implicitly or explicitly balance the costs 
of taxes with the benefits of government. 

Nevertheless, minimizing efficiency costs is one criterion for a good 
tax. Economists agree that taxes with broad bases and low rates 
generally cause lower efficiency costs than do taxes with narrow bases 
and high rates. The goal of tax policy is to design a tax system that 
produces revenue needed to pay current bills and deliver on future 
promises while at the same time balancing economic efficiency with 
other objectives, such as equity, simplicity, transparency, and 
administrability. Moreover, as noted earlier, the failure to provide 
sufficient tax revenues to finance the level of spending we choose as a 
nation gives rise to deficits and debt. Large, sustained deficits could 
ultimately have a negative impact on economic growth, productivity, and 
potentially our national security. Large structural deficits also raise 
serious stewardship and intergenerational equity issues. 

Text Box 1: Tax Expenditure for Employer-Provided Medical Insurance 
Premiums and Medical Care: 

The current U.S. tax system excludes employer-provided health insurance 
from individuals' taxable income even though such insurance is a form 
of income (noncash compensation).  The Department of the Treasury 
estimates that the tax exclusion for employer-provided health insurance 
resulted in $118.4 billion in lost revenue during 2005, not including 
forgone social insurance taxes and state taxes.  Including forgone 
federal social insurance taxes, an estimated $177.6 billion in revenue 
was forgone due to this exclusion. 

The tax exclusion increases the proportion of the population covered by 
health insurance. In 2004, nearly 46 million Americans were without 
health insurance. The tax exclusion encourages employers to offer and 
employees to participate in health insurance plans, increasing the 
proportion of workers covered. Because individuals may be better able 
to anticipate their health care needs than insurers, health care plans 
may attract customers with higher risk of poor health, resulting in 
higher premiums. By encouraging the pooling of high-and low-risk 
individuals, the tax exclusion may help to reduce premiums below those 
that individuals would face if they purchased insurance on their own.

However, some question whether the tax subsidy for health insurance is 
the best way to increase health insurance coverage. For example, the 
tax exclusion provides the most assistance to taxpayers who have high 
marginal tax rates (those with high incomes)—the exclusion saves those 
taxpayers more in taxes owed than it saves those with lower marginal 
tax rates.

The tax exclusion for health insurance also contributes to higher 
health care costs. The exclusion, by lowering premiums, encourages more 
extensive insurance coverage, which compounds another well-known 
problem with health insurance. Because much of the cost of medical 
treatment is paid for by a third party (the insurer), patients and 
doctors are generally unaware of, or disconnected from, the total costs 
of health care and have little incentive to economize on health care 
spending.

Unlike the tax exclusion for employer-provided health insurance, an 
ideal health care payment system would foster the delivery of care that 
is both effective and efficient, resulting in better value for the 
dollars spent on health care. 

[End of Text Box] 

Efficiency Costs Resulting from the Individual Income Tax Are Likely to 
Be Large but Can Only Be Estimated with Considerable Uncertainty: 

Estimating the efficiency costs of the federal tax system is an 
enormous, complicated, and uncertain task, given the complexity of 
existing tax rules, the breadth and diversity of the U.S. economy and 
population, and the limited empirical evidence available on how 
individuals and businesses change their behavior in response to tax 
rules. In practice, researchers have not been able to obtain and 
analyze all of the detailed data they need to produce efficiency cost 
estimates that are free from a large degree of uncertainty. 

The two studies that have made the most comprehensive estimates of the 
efficiency costs arising from the individual income tax in the past two 
decades suggest that those costs are considerable. The first study, 
which examined the combined efficiency costs of the individual income 
and payroll taxes, estimated those costs to have been on the order of 2 
to 5 percent of GDP in 1994.[Footnote 9] Estimates from the second 
study indicate that the efficiency cost of the individual income tax 
was on the order of 2 percent of GDP in 1997.[Footnote 10] Efficiency 
cost estimates such as these are often quite sensitive to the assumed 
magnitude of key behavioral responses and those assumptions are often 
based on empirical research that continues to evolve over time or, in 
other cases, has yet to be undertaken. For example, the consensus of 
recent research is that individuals are less responsive to changes in 
taxes than the first study assumed them to be. 

The extent to which efficiency gains could be realized by switching to 
an alternative tax system depends critically on the detailed 
characteristics of the alternative. All of the alternative tax system 
proposals that have received serious consideration in recent decades 
would have imposed significant efficiency costs. Moreover, in assessing 
the potential efficiency gains from any tax reform proposal it is also 
important to consider compensating changes that may be made on the 
spending side of the federal budget. For example, if any tax 
expenditures in the current federal income taxes are replaced by 
grants, spending programs, regulations, or other forms of nontax 
subsidies, those subsidies can result in efficiency costs similar in 
magnitude to those associated with the tax expenditures they replaced. 

Perceptions of Inequities in the Tax System Can Undermine Its Success: 

The success of our tax system hinges very much on the public's 
perception of its fairness and transparency. The myriad of tax 
deductions, credits, special rates, and so forth cause taxpayers to 
doubt the fairness of the tax system because they do not know whether 
those with the same ability to pay actually pay the same amount of tax. 
Fairness is ultimately a matter of personal judgment about issues such 
as how progressive tax rates should be and what constitutes ability to 
pay. 

Public confidence in the nation's tax laws and tax administration is 
critical because we rely heavily on a system of voluntary compliance. 
If taxpayers do not believe that the tax system is credible, easy to 
understand, and treats everyone fairly, then voluntary compliance is 
likely to decline. The latest available IRS estimates indicate that 
about 84 percent of total taxes due for tax year 2001 were paid 
voluntarily and on time. Complexity and the lack of transparency it can 
create exacerbate doubts about the current tax system's fairness. 

There are differences of opinion about the fairness of the individual 
income tax. Likewise, concerns have been expressed about the equity of 
many specific features of the tax, such as: 

* marriage penalties (and bonuses) built into the tax under which the 
combined tax liabilities of two individuals differ, depending on 
whether or not those individuals are married; 

* the inconsistent treatment between taxable wages and salaries and 
other components of total employee compensation, such as employer- 
provided health benefits that are not taxed; 

* the fact that many low-income individuals face high effective 
marginal tax rates over certain income ranges as the benefits of tax 
preferences, such as the earned income tax credit, phase out; 

* the provision of certain tax benefits in the form of deductions, 
which are more valuable to taxpayers in higher income brackets, rather 
than as tax credits; 

* the requirement that a taxpayer must own a home in order to receive 
the significant advantage of tax-preferred borrowing; and: 

* the greater ease with which self-employed individuals can underreport 
income, compared to employees whose incomes are subject to withholding 
and third-party reporting. 

Judging the equity of the individual income tax can depend 
substantially on the frame of reference used. For example, for many, a 
progressive tax code is considered to be more equitable. When looked at 
in isolation, the individual income tax system is somewhat progressive. 
If the frame of reference is expanded, however, and payroll taxes are 
also taken into account, total progressivity drops.[Footnote 11] As 
mentioned earlier, more than 70 percent of taxpayers are estimated to 
pay more in payroll taxes than individual income taxes when the 
combined employee and employer shares are considered.[Footnote 12] 
These frames of reference, of course, look only at the payment of 
taxes. An even wider frame of reference would take into account the 
benefits taxpayers receive, which could alter yet again judgments about 
the equity of the tax system. In fact, it could be argued that the full 
effect of federal government policies on different groups of 
individuals can only be determined by examining the effects of all 
federal taxes, spending programs, and regulations. 

Ensuring Individual Taxpayer Compliance with the Tax Laws Is 
Challenging: 

The extent of individual taxpayer noncompliance with the current tax 
laws is another factor that could motivate calls for reform. Ensuring 
compliance with our nation's tax laws is a challenging process for both 
taxpayers and IRS. The difficulty in ensuring compliance is underscored 
by the tax gap--the difference between the taxes that should be paid 
voluntarily and on time and what is actually paid--that arises every 
year when taxpayers fail to comply fully with the tax laws. Most 
recently, IRS estimated the gross tax gap for tax year 2001 to be $345 
billion, including individual income, corporate income, employment, 
estate, and excise taxes. IRS estimated it would eventually recover 
about $55 billion of the gross tax gap through late payments and 
enforcement actions, resulting in a net tax gap of $290 
billion.[Footnote 13] 

About 70 percent of the gross tax gap for tax year 2001, or an 
estimated $244 billion, was attributed to the individual income tax. As 
shown in table 1, individual taxpayers that underreported their income, 
underpaid their taxes, or failed to file an individual tax return 
altogether or on time (nonfiling) accounted for $197 billion, $23 
billion, and $25 billion of the tax gap, respectively. 

Table 1: Individual Income Tax Portion of the Tax Year 2001 Gross Tax 
Gap Estimate: 

Type of noncompliance: Underreporting; 
Tax gap (dollars in billions): $197. 

Type of noncompliance: Underreporting: Business income; 
ax gap (dollars in billions): 109. 

Type of noncompliance: Underreporting: Business income: Nonfarm 
proprietor income; 
Tax gap (dollars in billions): 68. 

Type of noncompliance: Underreporting: Business income: Partnership, S-
Corp, estate and trust; 
Tax gap (dollars in billions): 22. 

Type of noncompliance: Underreporting: Business income: Rents & 
royalties; 
Tax gap (dollars in billions): 13. 

Type of noncompliance: Underreporting: Business income: Farm income; 
Tax gap (dollars in billions): 6. 

Type of noncompliance: Underreporting: Nonbusiness income; 
Tax gap (dollars in billions): 56. 

Type of noncompliance: Underreporting: Nonbusiness income: Capital 
gains; 
Tax gap (dollars in billions): 11. 

Type of noncompliance: Underreporting: Nonbusiness income: Wages, 
salaries, tips; 
Tax gap (dollars in billions): 10. 

Type of noncompliance: Underreporting: Nonbusiness income: Pensions and 
annuities; 
Tax gap (dollars in billions): 4. 

Type of noncompliance: Underreporting: Nonbusiness income: Interest and 
dividend income; 
Tax gap (dollars in billions): 3. 

Type of noncompliance: Underreporting: Nonbusiness income: Other; 
Tax gap (dollars in billions): 28. 

Type of noncompliance: Underreporting: Credits; 
Tax gap (dollars in billions): 17. 

Type of noncompliance: Underreporting: Deductions, exemptions, 
adjustments; 
Tax gap (dollars in billions): 15. 

Type of noncompliance: Underpayment; 
Tax gap (dollars in billions): 23. 

Type of noncompliance: Nonfiling; 
Tax gap (dollars in billions): 25. 

Type of noncompliance: Total; 
Tax gap (dollars in billions): $244. 

Source: IRS. 

Note: Figures may not sum to totals because of rounding. 

[End of table] 

Improving compliance and reducing the tax gap would help improve the 
nation's fiscal stability. Even modest progress would yield significant 
revenue; each 1 percent reduction would likely yield nearly $3 billion 
annually. However, the tax gap has been a persistent problem in spite 
of a myriad of congressional and IRS efforts to reduce it, as the rate 
at which taxpayers voluntarily comply with our tax laws has changed 
little over the past three decades. As such, we need to consider not 
only options that have been previously proposed but also explore new 
and innovative approaches to improving compliance including fundamental 
reform of the tax system as well as providing IRS with additional 
enforcement tools and ensuring that significant resources are devoted 
to enforcement. 

Fundamentally reforming our tax system has the potential to improve 
compliance, especially if a new system has few tax preferences or 
complex tax code provisions and if taxable transactions are transparent 
to tax administrators. One factor that some believe contributes to the 
difficulty of achieving compliance is the complexity of our tax system. 
The complexity of, and frequent revisions to, the tax system make it 
more difficult and costly for taxpayers who want to comply to do so and 
for IRS to explain and enforce tax laws. Complexity also creates a 
fertile ground for those intentionally seeking to evade taxes, and 
often trips others into unintentional noncompliance. Likewise, the 
complexity of the tax system challenges IRS in its ability to 
administer our tax laws. 

Whether under our current income tax system or a reformed one, 
enforcement tools, particularly information reporting[Footnote 14] and 
tax withholding,[Footnote 15] are key to high levels of compliance. The 
extent to which individual taxpayers accurately report the income they 
earn has been shown to be related to the extent to which the income is 
reported to them and IRS by third parties or taxes on the income are 
withheld, as shown in figure 6. Taxpayers tend to report income subject 
to tax withholding or information reporting with high levels of 
compliance because the income is transparent to the taxpayers as well 
as to IRS. For example, employers report most wages, salaries, and tip 
compensation to employees and IRS through Form W-2. Also, banks and 
other financial institutions provide information returns (Forms 1099) 
to account holders and IRS showing the taxpayers' annual income from 
some types of investments. Findings from IRS's recent study of 
individual tax compliance indicate that nearly 99 percent of these 
types of income are accurately reported on individual tax returns. For 
types of income for which there is little or no information reporting, 
individual taxpayers tend to misreport over half of their income. 

Figure 6: Individual Net Income Misreporting Categorized by the Extent 
of Income Subject to Withholding and Information Reporting: 

[See PDF for image] 

Source: IRS. 

[End of figure] 

Ensuring that significant resources are devoted to enforcement also has 
the potential to minimize the tax gap for our current income tax system 
as well as for reformed systems Congress may adopt. For the current 
system, devoting more resources has the potential to reduce the tax gap 
by billions of dollars in that IRS would be able to expand its 
enforcement efforts to reach a greater number of potentially 
noncompliant taxpayers. Importantly, expanded enforcement efforts could 
reduce the tax gap more than through direct tax revenue collection, as 
widespread agreement exists that IRS enforcement programs have an 
indirect effect through increases in voluntary tax compliance.[Footnote 
16] However, determining the appropriate level of enforcement resources 
to provide IRS requires taking into account many factors, such as how 
effectively and efficiently IRS is currently using its resources, how 
to strike the proper balance between IRS's taxpayer service and 
enforcement activities, and competing federal funding priorities. 

Generally, when holding IRS accountable for the use of resources, it is 
also desirable to focus on the outcomes achieved rather than on how IRS 
allocates the resources it receives. Results are really what counts. If 
IRS, or any other agency, can figure out how to more cost effectively 
achieve a result, then reallocation of resources to other problem areas 
could be an appropriate strategy, within the restrictions applying to 
appropriation accounts, for making the best use of limited resources. 
In sum, regardless of the tax system, Congress needs to assure itself 
that the revenue agency has sufficient resources and reasonable 
flexibility to achieve desired outcomes and hold the agency accountable 
for those outcomes. 

Comparing Proposals on Common Dimensions: 

In moving forward on tax reform, policymakers may find it useful to 
compare proposals on common dimensions. These comparisons can be 
helpful whether reform is of the individual income tax, the current tax 
system more broadly, or in considering new systems altogether. 

First, is the tax base as broad as possible? Broad-based tax systems 
with minimal exceptions have many advantages. Fewer exceptions 
generally means less complexity, less compliance cost, less economic 
efficiency loss, and by increasing transparency may improve equity or 
perceptions of equity. In terms of the individual income tax, this 
suggests that eliminating or consolidating the myriad of tax 
expenditures must be considered. We need to be sure that the benefits 
achieved from having these special provisions are worth the associated 
revenue losses just as we must ensure that outlay programs--which may 
be attempting to achieve the same purposes as tax expenditures--achieve 
outcomes commensurate with their costs. To the extent tax expenditures 
are retained, consideration should be given to whether they are better 
targeted to meet an identified need. Many tax expenditures are broadly 
available and, in fact, provide greater "assistance" to those that most 
would consider least in need. This is broadly true of any tax 
expenditure that is worth more to higher income taxpayers than to lower 
income taxpayers, like the exclusion for the value of employer-provided 
health insurance and the mortgage interest deduction. 

Broad based tax systems can yield the same revenue as more narrowly 
based systems at lower tax rates. The combination of less direct 
intervention in the marketplace from special tax preferences, and the 
lower rates possible from broad based systems, can have substantial 
benefits for economic efficiency. For instance, some economists 
estimate that the economic efficiency costs of tax increases rise 
proportionately faster than the tax rates. In other words, a 50 percent 
tax increase could more than double the economic efficiency costs of a 
tax system. 

Does the proposed system raise sufficient revenue over time to fund our 
expected expenditures? As I mentioned earlier, we will fall woefully 
short of achieving this end if current spending and/or revenue trends 
are not altered. The economic efficiency costs of our current tax 
system likely will become an even more important issue as we grapple 
with the nation's long-term fiscal challenges. Although we clearly must 
restructure major entitlement programs and the basis of other federal 
spending, it is unlikely that our long-term fiscal challenge will be 
resolved solely by cutting spending. If we must raise revenues, doing 
so from a broad base and a lower rate will help minimize economic 
efficiency costs. 

In this regard, the President's Advisory Panel on Tax Reform has taken 
a useful step forward for tax reform, helping, for example, to focus 
the debate on specific proposals. Those proposals incorporate broader 
bases, with lower rates. However, the Panel acted within the guidance 
it was given, and one result is that the proposed reforms, if 
implemented as proposed, appear to provide much less than the necessary 
revenue to fund expected government spending. Although we have not 
evaluated the revenue effects of these proposals, other respected 
analysts have and they point to future revenue yields that would worsen 
the already difficult fiscal challenges the nation faces. 

Does the proposal look to future needs? Like many spending programs, 
the current tax system was developed in a profoundly different time. We 
live now in a much more global economy, with highly mobile capital, and 
investment options available to ordinary citizens that were not even 
imagined decades ago. We have growing concentrations of income and 
wealth. More firms operate multi-nationally and willingly move 
operations and capital around the world as they see best for their 
firms. 

Do the revenues for the proposed system hold up in the future? As an 
adjunct to looking forward when making reforms, the revenue 
consequences of all major tax changes should be estimated well into the 
future. Such long-term projections undoubtedly will be subject to 
uncertainty, but at the very least we should have the best estimates 
possible of whether the revenue trend is likely to shift up or down 
over the long-term. 

Does the proposed system have attributes associated with high 
compliance rates? Because any tax system can be subject to tax gaps, 
the administrability of reformed systems should be considered as part 
of the debate for change. In general, a reformed system is most likely 
to have a small tax gap if the system has few tax preferences or 
complex provisions and taxable transactions are transparent. 
Transparency in the context of tax administration is best achieved when 
third parties report information both to the taxpayer and the tax 
administrator. 

What transition issues exist and have they been dealt with in an 
equitable fashion that minimizes additional complexity and any adverse 
effects on the benefits to be gained from the new tax system? Under the 
current individual income tax system, citizens have made fundamental 
life choices based at least in part on the incentives in the tax 
system. For many, the favorable tax treatment of owner-occupied housing 
has led to choices to invest disproportionately in housing. Others have 
made long-term investments in tax-favored college savings plans. Thus, 
changes to the tax system can materially affect citizens' futures. 
Still others make their livings advising taxpayers, helping them 
understand tax provisions and complete their tax returns, and helping 
them devise investment and other financial plans taking into account 
current tax rules. 

Our publication, Understanding the Tax Reform Debate: Background, 
Criteria, and Questions,[Footnote 17] may be useful in guiding 
policymakers as they consider tax reform proposals. It was designed to 
aid policymakers in thinking about how to develop tax policy for the 
21st century. While not designed to break new conceptual ground, this 
report brings together a number of topics that tax experts have 
identified as those that should be considered when evaluating tax 
policy. It attempts to provide information about these topics in a 
clear, concise, and easily understandable manner for a non-technical 
audience. 

Concluding Observations: 

The problems that I have reviewed today relating to the compliance 
costs, efficiency costs, equity and tax gap associated with the current 
individual income tax system--many of which arise from the complex 
accumulation of tax preferences in that system--would seem to make an 
overwhelming case for a comprehensive review and reform of our tax 
policy. Further, we live a world that is profoundly different than when 
the individual income tax and many of its provisions were adopted. 
Despite numerous and repeated calls for such reform, progress has been 
slow. One reason why reform is difficult to accomplish is that the 
provisions of the tax code that generate compliance costs, efficiency 
costs, the tax gap and inequities also benefit many taxpayers and the 
individuals and companies that advise taxpayers and help them with 
their tax filing obligations. Reform is also difficult because, even 
when there is agreement on the amount of revenue to raise, there are 
differing opinions on the appropriate balance among the often 
conflicting objectives of equity, efficiency, and administrability. 
This, in turn, leads to widely divergent views on even the basic 
direction of reform. 

Fiscal necessity, prompted by the nation's unsustainable fiscal path, 
will eventually force changes to our spending and tax policies. We must 
fundamentally rethink policies and everything must be on the table. 
Tough choices will have to be made about the appropriate degree of 
emphasis on cutting back federal programs versus increasing tax 
revenue. 

Tax reform, if it broadens the tax base, could reduce the costs of 
raising a given amount of revenue by reducing the associated efficiency 
costs. Such a reform also likely would reduce inequities, compliance 
burden, and administrative costs. The recent report of the President's 
Advisory Panel on Federal Tax Reform recommended two different tax 
reform plans. Although each plan provides for significant 
simplification, neither of them addresses the growing imbalance between 
federal spending and revenues that I highlighted earlier. One approach 
for getting the process of comprehensive fiscal reform started would be 
through the establishment of a credible, capable, and bipartisan 
commission, to examine options for a combination of entitlement and tax 
reform. 

As policymakers consider proposals to reform the current individual 
income tax, or the entire tax system, they may find it useful to 
compare the proposals on common dimensions. Our publication, 
Understanding the Tax Reform Debate, may be useful when making these 
comparisons. 

Mr. Chairman and Members of the Committee, this concludes my statement. 
I would be pleased to answer any questions you may have at this time. 

Contact and Acknowledgments: 

For further information on this testimony please contact James White on 
(202) 512-9110 or whitej@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this testimony. Individuals making key contributions to this 
testimony include Michael Brostek, Director; Kevin Daly and Jim Wozny, 
Assistant Directors; Jeff Arkin; Elizabeth Fan; Tom Gilbert; Don 
Marples; and Jeff Procak. 

FOOTNOTES 

[1] I addressed a number of issues relating to the corporate income tax 
in a statement before this committee several weeks ago. See GAO, Tax 
Compliance: Challenges to Corporate Tax Enforcement and Options to 
Improve Securities Basis Reporting, GAO-06-851T (Washington, D.C.: June 
13, 2006). 

[2] President's Advisory Panel on Federal Tax Reform, Simple, Fair, and 
Pro-Growth: Proposals to Fix America's Tax System, (Washington, D.C.: 
November 2005). 

[3] GAO, Understanding the Tax Reform Debate: Background, Criteria, & 
Questions, GAO-05-1009SP (Washington, D.C.: September 2005). 

[4] GAO-05-1009SP. 

[5] GAO-05-1009SP. 

[6] Department of the Treasury, IRS, Publication 970, Tax Benefits for 
Education, 2004. 

[7] Three of the tax incentives for saving--Coverdell Education Savings 
Accounts, Qualified Tuition Programs, and U.S. education savings bonds-
-differ across more than a dozen dimensions. Similarly, three other tax 
expenditures, all of which help students meet current costs--the Hope 
credit, Lifetime Learning credit, and the tuition deduction--differ in 
terms of eligibility criteria, benefit levels, and income-related phase-
outs. For a fuller discussion, including estimates of the number of 
taxpayers who made suboptimal choices in selecting among three tax 
provisions, see GAO, Student Aid and Postsecondary Tax Preferences: 
Limited Research Exists on Effectiveness of Tools to Assist Students 
and Families through Title IV Student Aid and Tax Preferences, GAO-05-
684 (Washington, D.C.: July 29, 2005). 

[8] Summing the individual tax expenditure estimates is useful for 
gauging the general magnitude of the federal revenue involved, but it 
does not take into account possible interactions between individual 
provisions. 

[9] Martin Feldstein, "Tax Avoidance and the Deadweight Loss of the 
Income Tax," The Review of Economics and Statistics (1999). 

[10] Dale Jorgenson and Kun-Young Yun, Investment Volume 3: Lifting the 
Burden: Tax Reform, the Cost of Capital, and U.S. Economic Growth 
(Cambridge, Ma.: MIT Press), 2001. 

[11] Although it makes sense to consider the significant additional 
burden of social insurance taxes when evaluating individual tax 
burdens, there is some disagreement regarding the proper way to analyze 
the two taxes jointly. Many economists consider the portion of payroll 
taxes that fund Old-Age and Survivors Insurance benefits to be 
materially different from other federal taxes because individuals 
receive future benefits that are directly related to the amount of tax 
they pay. In their view some account should be made of the 
redistributive nature of the social security benefits formula. (See, 
for example, Richard V. Burkhauser and John A. Turner, "Is the Social 
Security Payroll Tax a Tax?," 13 Public Finance Quarterly, (1985) and 
Andrew Mitrusi and James Poterba, "The Distribution of Payroll and 
Income Tax Burdens, 1979-99," National Tax Journal, Vol. 53 no. 3 Part 
2 (September 2000) pp. 765- 794.) Other observers assert that future 
benefits are an entitlement based on participation in the workforce, 
not on the payment of tax, and that all social insurance taxes should 
be treated the same as individual income taxes when analyzing the 
distribution of tax burdens. (See Patricia E. Dilley, "Taking Public 
Rights Private: The Rhetoric and Reality of Social Security 
Privatization," Boston College Law Review, 975 (2000) and Deborah A. 
Geier, "Integrating the Federal Tax Burden on Labor Income," Tax Notes, 
January 27, 2003), pp. 563-583.) 

[12] The Tax Policy Center, using its tax simulation model, has 
estimated that 96 percent of taxpayers pay more in payroll taxes than 
individual income taxes when both the employee and employer shares of 
taxes are considered. Economists widely agree that the employee bears 
the full amount of the payroll tax. 

[13] Unless otherwise noted, references to the tax gap refer to the 
gross tax gap. 

[14] Information reporting involves the filing of information returns 
with IRS and taxpayers that contain information on certain 
transactions, such as wage and salary information employers report to 
employees and IRS through Form W-2. 

[15] An example of tax withholding is when employers withhold taxes on 
the wages that employees earn and remit them to IRS. 

[16] Two types of indirect effect are (1) the increase in voluntary 
compliance in the larger population resulting from examinations or 
other enforcement and nonenforcement actions on targeted taxpayers, and 
(2) the increase in voluntary compliance of the targeted taxpayer in 
subsequent years. 

[17] GAO-05-1009SP. 

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