Apropos of our earlier discussions around reforming taxation.  An interesting 
alternative (supplement?) to a stock-based tax.

E

http://www.brookings.edu/papers/2007/06corporatetaxes_kleinbard.aspx

Rehabilitating the Business Income Tax

Abstract 

This paper introduces the Business Enterprise Income Tax (BEIT), a 
comprehensive and detailed proposal for reforming business income taxation. 
Current law fails to tax all business income consistently and comprehensively. 
It distorts economic behavior and diverts managerial effort toward tax 
avoidance.
In contrast, the BEIT achieves comprehensive and consistent taxation of capital 
income and reduces tax-planning incentives. The BEIT integrates taxes at the 
corporate and the individual levels, ensuring that all income is taxed once and 
only once. 

The BEIT eliminates current law distinctions between debt and equity. Instead, 
the BEIT uses its cost of capital allowance (COCA) system to tax investors on 
the normal (risk-free) return to capital and to tax businesses only on risky 
returns and rents. Under the COCA system, businesses obtain a uniform deduction 
for a normal return on their capital and pay tax on the rest of their income; 
investors include an assumed normal return in their taxable incomes, whether or 
not received by them in cash. (Investors also pay a small tax on gains beyond 
normal returns for practical and ability-to-pay reasons). In practice, the COCA 
system functions as a business-level consumption tax plus an add-on investor 
tax on normal returns. 

The BEIT proposal also rationalizes the tax system by applying a single set of 
rules to all forms of business enterprises and business acquisitions. As a 
result, all business income is taxed identically and consistently, regardless 
of niceties of form.

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