Issues in the Taxation of Capital Income in the United States
综述了资本所得税领域的最新研究成果，包括最优税收理论的应用、美国税制对资本与劳动收入的差异化处理，以及私人储蓄对税后实际收益率的反应，为政策制定者和研究者提供参考。
Few issues in public finance stir as much academic debate or public discussion as the appropriate taxation of income from capital. Prescriptions and practices in various countries range from heavier taxation of capital than labor income to subsidization of investment. A variety of features of the current U.S. tax system differentially tax capital income relative to labor income, and certain types of capital income relative to other types. Important examples include the separate corporate income tax, the maximum tax on earned income, the treatment of pensions and life insurance, and the nontaxation of imputed income. In recent years much insight has been gained into several important issues in analyzing capital income taxation. Applications of the theory of optimal taxation have helped clarify the determinants of the optimal taxation of capital income, new empirical results have questioned long-held beliefs about the effects of capital income taxation on private saving and investment, and careful study has elucidated the complex nature of the incentives involved in the various special features of our current tax laws. This paper presents a summary of some recent results in this area of public finance. Toward this end, Section I presents a heuristic discussion of the application of optimal tax theory to the taxation of capital income. We note that efficiency may require something other than a convex combination of income and consumption taxation. Optimality might imply heavier taxation of capital income than in an income tax, on the one hand, or an interest income subsidy, on the other. The key parameters in answering this question are the ownand cross-compensated current and forward price effects on consumption and leisure at different stages of the life cycle. Section II discusses a variety of features of the current U.S. tax system which deal with capital income. Of particular interest are the separate corporate tax, the lack of price level indexing, the deductability of interest payments and the marginal finance decision, and the opportunity to save in some forms free of personal taxes. We conclude that the U.S. tax system, while often taxing capital income quite heavily, is in many respects a hybrid of an income and expenditure tax. Section III reviews some recent empirical research which suggests that private saving may be somewhat more responsive to the real after-tax rate of return than previously conjectured, and Section IV offers a brief conclusion and discusses (in light of the analysis in the paper) some policy issues and options currently under serious consideration.