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Notes on the Tax Treatment of Structures

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  • Roger H. Gordon
  • James R. Hines Jr.
  • Lawrence H. Summers

Abstract

More than three quarters of the United States tangible capital stock represents structures. Tax policies potentially have a major impact on both the level and composition of investment in structures and equipment. This point is explicitly recognized in most discussions of the effects of capital income taxation. Two aspects of the taxation of structures --the relative burden placed on structures as opposed to equipment investment and the non-taxation of owner occupied housing under the income tax -- have attracted substantial attention in recent years. This paper explores these two aspects of the taxation of structures investments. While the tax system may well have a potent impact on the level and composition of structures investment, this paper argues that conventional analyses of these effects are very misleading. We reach two main conclusions. First,under current tax law, certain types of structures investment are very highly tax favored. Structures can be transferred and therefore depreciated more than once, and structures may be readily financed with tax-favored debt. Overall, itis unlikely that a significant bias towards equipment and against structures exists under current law. Second, the conventional view that the tax system is biased in favor of homeownership is wrong. Because of the possibility of "tax arbitrage" between high bracket landlords and low bracket tenants, the tax system has long favored rental over ownership for most households. The 1981 reforms by reducing the top marginal tax rate reduced this bias somewhat.

Suggested Citation

  • Roger H. Gordon & James R. Hines Jr. & Lawrence H. Summers, 1986. "Notes on the Tax Treatment of Structures," NBER Working Papers 1896, National Bureau of Economic Research, Inc.
  • Handle: RePEc:nbr:nberwo:1896
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    References listed on IDEAS

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    14. Bulow, Jeremy I & Summers, Lawrence H, 1984. "The Taxation of Risky Assets," Journal of Political Economy, University of Chicago Press, vol. 92(1), pages 20-39, February.
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    Cited by:

    1. Alan J. Auerbach & James M. Poterba, 1987. "Tax Loss Carryforwards and Corporate Tax Incentives," NBER Chapters,in: The Effects of Taxation on Capital Accumulation, pages 305-342 National Bureau of Economic Research, Inc.
    2. Don Fullerton & Andrew B. Lyon, 1988. "Tax Neutrality and Intangible Capital," NBER Chapters,in: Tax Policy and the Economy: Volume 2, pages 63-88 National Bureau of Economic Research, Inc.
    3. Andrew Narwold, 2004. "Ownership of Residential Rental Property in Regional Housing Markets," ERSA conference papers ersa04p494, European Regional Science Association.
    4. Green, Richard K. & White, Michelle J., 1997. "Measuring the Benefits of Homeowning: Effects on Children," Journal of Urban Economics, Elsevier, vol. 41(3), pages 441-461, May.
    5. Lawrence H. Summers, 1987. "Investment Incentives and the Discounting of Depreciation Allowances," NBER Chapters,in: The Effects of Taxation on Capital Accumulation, pages 295-304 National Bureau of Economic Research, Inc.
    6. Roger Gordon & Laura Kalambokidis & Joel Slemrod, 2003. "A New Summary Measure of the Effective Tax Rate on Investment," NBER Working Papers 9535, National Bureau of Economic Research, Inc.
    7. Alan J. Auerbach & David Reishus, 1988. "The Effects of Taxation on the Merger Decision," NBER Chapters,in: Corporate Takeovers: Causes and Consequences, pages 157-190 National Bureau of Economic Research, Inc.
    8. Poterba, James M, 1987. "Tax Evasion and Capital Gains Taxation," American Economic Review, American Economic Association, vol. 77(2), pages 234-239, May.
    9. Hines, James Jr., 2004. "On the timeliness of tax reform," Journal of Public Economics, Elsevier, vol. 88(5), pages 1043-1059, April.
    10. Edwin S. Mills, 1987. "Has the United States Overinvested in Housing?," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 15(1), pages 601-616.
    11. Mihir A. Desai & William M. Gentry, 2004. "The Character and Determinants of Corporate Capital Gains," NBER Chapters,in: Tax Policy and the Economy, Volume 18, pages 1-36 National Bureau of Economic Research, Inc.
    12. Judith Yates, 2003. "'The more things change?' An overview of Australia's recent home ownership policies," International Journal of Housing Policy, Taylor & Francis Journals, vol. 3(1), pages 1-33.
    13. Fullerton, Don & Henderson, Yolanda Kodrzycki, 1989. "The Marginal Excess Burden of Different Capital Tax Instruments," The Review of Economics and Statistics, MIT Press, vol. 71(3), pages 435-442, August.
    14. Andrei Shleifer & Robert W. Vishny, 1987. "Management Buyouts as a Response to Market Pressure," NBER Chapters,in: Mergers and Acquisitions, pages 87-102 National Bureau of Economic Research, Inc.
    15. Jorgenson, Dale W. & Yun, Kun-Young, 1990. "Tax Reform and U.S. Economic Growth," Scholarly Articles 3403059, Harvard University Department of Economics.
    16. Wood, Gavin A., 2001. "Are There Tax Arbitrage Opportunities in Private Rental Housing Markets?," Journal of Housing Economics, Elsevier, vol. 10(1), pages 1-20, March.
    17. Andrew Coleman, 2008. "Tax, Credit Constraints, and the Big Costs of Small Inflation," Working Papers 08_14, Motu Economic and Public Policy Research.
    18. Bovenberg, A Lans & Goulder, Lawrence H, 1993. " Promoting Investment under International Capital Mobility: An Intertemporal General Equilibrium Analysis," Scandinavian Journal of Economics, Wiley Blackwell, vol. 95(2), pages 133-156.
    19. repec:bla:econpa:v:35:y:2016:i:4:p:332-346 is not listed on IDEAS
    20. Andrew B. Lyon, 1989. "Did ACRS Really Cause Stock Prices to Fall?," NBER Working Papers 2990, National Bureau of Economic Research, Inc.
    21. Lawrence H. Summers, 1987. "Should Tax Reform Level the Playing Field?," NBER Working Papers 2132, National Bureau of Economic Research, Inc.
    22. Fullerton, Don & Mackie, James B. III, 1989. "Economic Efficiency in Recent Tax Reform History: Policy Reversals or Consistent Improvements?," National Tax Journal, National Tax Association;National Tax Journal, vol. 42(1), pages 1-13, March.
    23. Skinner, Jonathan, 1989. "Housing wealth and aggregate saving," Regional Science and Urban Economics, Elsevier, vol. 19(2), pages 305-324, May.
    24. Roger H. Gordon & Joel Slemrod, 1988. "Do We Collect Any Revenue from Taxing Capital Income?," NBER Chapters,in: Tax Policy and the Economy: Volume 2, pages 89-130 National Bureau of Economic Research, Inc.

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