2018年-IMF国际货币组织全球_The_Tax_Cuts_and_Jobs_Act_An_Appraisal_48页_879kb

Summary of the IMF Working Paper: The Tax Cuts and Jobs Act: An Appraisal

Core Content

The Tax Cuts and Jobs Act (TCJA), enacted in December 2017, represents a major overhaul of the U.S. tax system, with significant implications for both domestic and international tax policies. This paper evaluates the TCJA from the perspective of the U.S. and the global economy, highlighting its key provisions, their economic effects, and potential spillovers.

Main Objectives of the TCJA

The U.S. administration aimed to achieve the following through the TCJA:

• Simplify the tax system.
• Make U.S. business tax competitive internationally.
• Provide tax relief to lower- and middle-income Americans.
• Avoid giving significant tax cuts to the wealthy.
• Lower statutory tax rates and broaden tax bases.
• Create a more equitable system by taxing households uniformly based on income.
• Achieve these goals without increasing the fiscal deficit.

However, independent estimates suggest the TCJA will significantly increase the U.S. fiscal deficit, with the Congressional Budget Office (CBO) estimating a $2.3 trillion increase over the next decade under static costing, and $1.9 trillion when macroeconomic feedbacks are considered.

Key Provisions and Their Impacts

A. Corporate Tax Reform

• Lower Statutory Corporate Income Tax (CIT) Rate: The CIT rate was reduced from 35% to 21%, bringing the U.S. closer to the OECD median rate. However, subnational taxes (state and local) still place the U.S. in the upper range of corporate tax rates globally.
• Elimination of Qualified Production Activities Deduction: This removes a previous incentive for profit shifting and reduces the complexity of the tax system.
• New Deduction for Foreign-Derived Income (FDII): This deduction may lower the effective tax rate on foreign sales, potentially influencing multinational firms' behavior.
• Impact on Profit Shifting: The lower CIT rate is expected to reduce profit shifting, but the overall revenue loss from the rate cut is substantial.

B. Investment and Finance

• Full Expensing of Capital Investments: The TCJA allows firms to fully expense new and used tangible property with a recovery period of under 20 years until 2022. This reduces the marginal effective tax rate (METR) on equity-financed investment to near zero, encouraging investment.
• Interest Deduction Caps: Interest deductions are capped at 30% of earnings before interest, tax, depreciation, amortization, depletion, and net operating loss (EBITDA) for 2018–2021, and at a more binding definition of earnings (EBIT) from 2022 onwards. This reduces the distortion in favor of debt financing and mitigates 'debt bias'.
• Procyclical Distortion: The interest deduction rules are more binding during periods of low earnings, potentially increasing financial instability for leveraged firms. This is compounded by the restriction on loss carry-forwards.

C. Repeal of the Corporate Alternative Minimum Tax (AMT)

• The corporate AMT was repealed, which reduces compliance costs for firms and simplifies the tax system. It had previously affected a small number of corporations, mostly in high-income sectors.

Changes to the Personal Income Tax (PIT)

A. Tax Rate Reductions

• Marginal PIT rates were reduced for married couples with income above $19,050 (individuals above $9,525), with the new brackets shown in Table 1. However, these changes are temporary and expire after 2025.

B. Deductions and Exemptions

• The standard deduction was increased from $13,000 to $24,000 for joint filers, and the individual exemption was eliminated.
• Itemized deductions were reduced, including for home equity loans, gambling losses, and work-related expenses.
• The mortgage interest deduction cap was lowered to $750,000 and state and local tax deductions capped at $10,000.
• Medical expenses above 10% of income remain deductible, though the 2018 threshold was set at 7.5%.

C. Tax Credits

• The child tax credit was increased from $1,000 to $2,000, with up to $1,400 of the credit being refundable.
• The income threshold for eligibility was raised to $400,000 for joint filers, broadening the credit's reach to higher-income households.

D. Personal AMT

• The personal AMT was modified to raise the exemption threshold from $86,200 to $109,400 for married couples and increase the phase-out threshold to $1 million.
• These changes reduce the number of taxpayers subject to the AMT and make the standard tax system more likely to be binding for most.

Macroeconomic Effects

• The TCJA is expected to reduce the average METR across all investment types, though the effect is modest.
• The reduction in tax rates and the changes to deductions and credits are likely to benefit higher-income households more than lower-income ones.
• The paper highlights that the TCJA may not achieve the stated objective of targeting middle-class tax relief, as the largest real income gains have accrued to those earning above 150% of the median income.

International Spillovers

• The TCJA’s international provisions, including the Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII), create both positive and negative spillovers.
• The reduction in the U.S. CIT rate may weaken the anchor for international tax rates, potentially leading to increased tax competition.
• The changes could reshape the global tax landscape, especially for multinational corporations, by reducing profit shifting and altering the tax treatment of cross-border income.

Conclusion

The TCJA is a significant and complex reform that brings several benefits, such as simplifying the tax system and reducing distortions in corporate taxation. However, it also poses substantial fiscal costs and may not fully align with the administration's stated goal of targeting middle-class relief. The paper emphasizes the need for further refinements to the tax system, particularly in the area of personal income tax, to make it more progressive and to better target relief to lower- and middle-income households. It also underscores the potential for international tax policy responses due to the TCJA's impact on global tax coordination.