Proposal for a “Dual‐​Rate Income Tax”

May 11, 2005 • Testimony

I am delighted that President Bush has established an advisory panel to study federal tax reform. The co‐​chairs of the panel, former senators Connie Mack of Florida and John Breaux of Louisiana, are the ideal leaders to tackle the ambitious task of overhauling the tax code to create greater fairness, opportunity, and economic growth.

President Bush has already made progress on incremental tax reforms. Income tax rates have been reduced, dividend and capital gains taxes have been cut, and the tax rules on retirement savings vehicles have been liberalized.

However, the tax system remains terribly complex and inefficient. The number of pages of federal tax rules has increased 48 percent in the past decade.1 The complex alternative minimum tax will hit about 35 million households by the end of the decade if not repealed. The high‐​rate U.S. corporate income tax is under growing pressure as global investment capital has become more mobile.

A number of tax reform plans would replace the income tax code with a consumption‐​based tax system. These plans include the Hall‐​Rabushka flat tax, a national retail sales tax, and a savings‐​exempt personal tax. There is no doubt that a consumption‐​based system would spur faster economic growth because of its more favorable treatment of savings and investment. Also, as former Princeton professor David Bradford stressed, consumption‐​based taxes are intrinsically simpler than income taxes.2

I support replacement of the income tax with a consumption‐​based system. But if policymakers do not want to make such a big reform jump all at once, the plan proposed here would be a big step toward a Hall‐​Rabushka flat tax. The “dual‐​rate income tax” is a good model for reform within the bounds of the current tax structure.

The dual‐​rate tax is a revenue‐​neutral option that would convert the individual income tax to a system with two rates, 15 and 27 percent. Most deductions and credits would be eliminated, but families would enjoy reduced marginal tax rates. To promote growth, the maximum individual rate on dividends, interest, and capital gains would be 15 percent. The corporate tax rate would be dropped to 15 percent. Such a reform would simplify the system, spur growth, and treat Americans more equally.

Details of the Dual‐​Rate Tax Plan
Under the plan, the individual income tax would be turned into a two‐​rate tax that eliminated most deductions and credits. Individuals would be taxed at a low 15 percent rate on income up to about $90,000 (singles) and $180,000 (married) and 27 percent above those thresholds. 3 (Currently, there are six income tax rates ranging from 10 to 35 percent). The vast majority of families — roughly 95 percent — would face a low 15 percent marginal income tax rate under the dual‐​rate plan. Under current law for 2005, singles with taxable income above $29,700 and couples with taxable income above $59,400 are in the 25 percent and higher tax brackets. The dual‐​rate plan would cut the marginal rate for most of those taxpayers to 15 percent. See Figure 1.

Table 1

The 27 percent rate would kick in at the wage threshold at which the 12.4 percent payroll tax that funds Social Security cuts out. The effect would be to create a consistent marginal tax rate of about 29 percent on earnings of all middle‐ and higher‐​income households, taking into account both the payroll and the income tax. That would be a big cut in the marginal rate for many middle‐​income families, who currently face a marginal rate of about 38 to 41 percent.4 See Figure 2. For example, single earners with wages between about $38,000 and $90,000 face a payroll tax rate of 15.3 percent and marginal income tax rates of 25 or 28 percent under current law.

Table 1

While marginal tax rates would fall under the dual‐​rate system, nearly all credits and deductions would be eliminated, such as the mortgage interest deduction. By dropping marginal rates and ending special breaks, the dual‐​rate tax would create a high degree of horizontal equity.

The dual‐​rate tax plan would retain the current law standard deduction, which is $5,000 for singles and $10,000 for married couples in 2005. The plan would also include an increased personal exemption, which would partly offset the elimination of the child tax credit. The exemption would be increased from $3,200 under current law in 2005 to $4,500. The plan would also retain the EITC, which reduces taxes for low‐​income workers.

The Dual‐​Rate Tax is Pro‐​Savings
The dual‐​rate tax would retain pro‐​savings features of the current tax code, including 401(k)s, IRAs, and Health Savings Accounts. Indeed, further steps to simplify and liberalize personal savings could be incorporated into the plan.5

In addition, a key goal of the dual‐​rate system is to reduce and equalize tax rates on income from savings. The maximum individual tax rate on dividends, interest, and capital gains would be 15 percent. (Interest is currently taxed up to the maximum individual rate of 35 percent). To match that change, the corporate tax rate would be cut to 15 percent and net interest deductions (interest receipts less interest deductions) excluded from the tax base.6 The result would be that interest and dividends would be taxed at both the corporate level and the individual level at 15 percent, for a net combined rate of 28 percent.7

Table 1 and Figure 3 show that the top combined marginal rates on wages, dividends, interest, and small business profits would be just under 30 percent in the dual‐​rate plan, compared to 35 to 45 percent under the current tax system.8 Wages would be taxed under the individual income tax and the existing payroll tax. Interest and dividends would be taxed under the individual and corporate income taxes.

Table 1

The dual‐​rate tax plan borrows from the “dual income tax” systems that have been implemented in a number of European countries. Those systems feature a lower flat rate on individual capital income (such as interest, dividends, and capital gains) and higher, graduated rates on labor income. Austria, Denmark, Finland, Netherlands, Norway, and Sweden have implemented such reforms. Capital income is taxed at a lower flat rate in order to reduce economic distortions and to respond to rising global capital mobility. If countries do not cut tax rates on capital income, tax competition will cause capital to flow abroad. For example, the Netherlands dropped its tax rate on dividends and capital gains to 25 percent from 52 percent in 2001 in order to reduce tax evasion.

Table 1

Lower Rates Instead of Special Breaks
The dual‐​rate tax plan ends special breaks under the current tax system in favor of lower rates in order to create a more fair and efficient tax system. Consider the advantage of eliminating the itemized deduction for state and local income and property taxes. This deduction encourages state and local governments to raise taxes because higher taxes are offset by the federal deduction. The deduction mutes beneficial tax competition between jurisdictions. Also, before the recent change that allows a federal deduction for state sales taxes, states were encouraged to favor income taxes over more pro‐​saving sales taxes.

Eliminating the deductibility of state and local taxes was discussed before the Tax Reform Act of 1986. President Ronald Reagan noted in June 1985: “Perhaps if the high‐​tax states didn’t have this federal crutch to prop up their big spending, they might have to cut taxes to stay competitive.“9 Indeed, a study at the time by Harvard’s Martin Feldstein and Gilbert Metcalf found that federal deductibility led to modestly higher state spending.10The dual‐​rate tax system would eliminate this pro‐​spending distortion.

The changes to the individual income tax under the proposed dual‐​rate system are estimated to be roughly revenue neutral on a static basis. Calculations were based on my analysis of IRS tax return data for 2002 and an estimate by the Tax Foundation for 2004 using their individual tax microsimulation model.11

Cutting the Corporate Tax Rate
While the United States led the world with a corporate tax rate cut in 1986, today it has the second‐​highest corporate tax rate in the 30‐​nation Organization for Economic Cooperation and Development. That creates a strong incentive for U.S. corporations to move their real investment and paper profits abroad. As much as $1 trillion in direct investment flows cross international borders each year, and research shows that these flows are increasingly sensitive to corporate taxes.12 Corporate tax reforms are urgently needed to tackle international tax competition head‐​on, and to attract these investment flows to our economy.

Table 1

The statutory U.S. corporate rate averages about 40 percent, including the 35 percent federal rate and the average state rate. By contrast, Figure 4 shows that the average rate in Asia, Europe, and Latin America is 30 percent or less. The average corporate tax rate in the OECD fell from 37.6 percent in 1996 to just 30.0 percent in 2004.13 The U.S. needs to catch up to tax reforms occurring abroad to ensure that American businesses remain competitive in global markets.

Under the dual‐​rate plan, the corporate tax rate would be cut sharply from 35 to 15 percent. To retain revenue‐​neutrality, a variety of tax base broadeners and spending cuts would be needed. A first step would be to end the deduction for net interest in order to create neutrality between corporate debt and equity.

The second step would be to end or limit the deduction for employer‐​paid health insurance benefits. Employer‐​paid benefits for health insurance are currently tax‐​free, creating distortions in the delivery of health care in the United States. An alternative to limiting the employer deduction would be to limit the individual exclusion for employer‐​provided benefits. At the same time, Health Savings Accounts could be expanded to shift the health care system toward individual coverage and control.14

Another corporate base broadener would be to eliminate the deduction for state and local taxes. That would create the benefit of increasing tax competition between the states. Without the federal deduction, businesses would be more sensitive to state taxes in their location decisions, thus providing a useful constraint on state and local fiscal policy.

The combination of these corporate tax changes (net interest, the health care deduction, and state and local taxes) would expand the corporate tax base by about 70 percent and offset more than half of the revenue loss from the rate cut.15 To get the corporate rate all the way down to 15 percent and retain revenue neutrality, corporate subsidies on the spending side of the federal budget could be cut.16

Also note that cutting the corporate tax rate would create macroeconomic feedback effects that would offset a substantial share of the revenue loss. Global investment flows would pour into the United States to take advantage of the 15 percent corporate rate, which would have the effect of boosting federal revenues.

The proposed corporate tax changes borrow from both the Hall‐​Rabushka flat tax and the “comprehensive business income tax” proposed in a 1992 Treasury study.17Both proposals would equalize the treatment of interest and dividends by excluding interest from the business tax base. Also, the flat tax would broaden the tax base by ending the deduction for employer‐​paid health benefits. The flat tax would also end the business deduction for federal payroll taxes. The dual‐​rate tax retains deductibility of federal payroll taxes but ends the deduction of state and local taxes to encourage interstate tax competition.

Under the dual‐​rate system, the corporate tax could be moved all the way to a Hall‐​Rabushka cash‐​flow business tax with four further steps. First, depreciation would be replaced by capital expensing. Second, accrual accounting would be replaced by cash accounting. Third, the “worldwide” tax system would be replaced by a “territorial” system that taxes firms on their domestic profits only. Territorial taxes are used by most industrial countries today because they are simpler and they allow firms to better compete in foreign markets.18 Fourth, the tax would be extended from corporations to all types of businesses.


The president’s call for tax reform creates both risks and opportunities for taxpayers and the economy. The risk stems from some policymakers who may view tax reform as an opportunity to increase revenues to fund entitlement programs and reduce the budget deficit. The president is right to reject that approach. There is no need for higher taxes when there are hundreds of inefficient federal programs that could be eliminated to save money.19

However, to support rising entitlement costs the economy needs pro‐​saving and pro‐​growth policies more than ever. The financial strains that will be caused by the retirement of the baby boomer generation will be easier to handle if the nation has a more efficient tax system. Tax reforms can help to increase personal saving to allow people to be better prepared for their future health care and retirement needs. And tax reforms can increase investment and productivity, enabling U.S. businesses to better tackle rising competition in global markets. The dual‐​rate tax plan would take a big step toward the simple, neutral, and pro‐​growth tax system that the United States needs to prosper in the coming decades.

View Powerpoint presentation (PPT, 102KB)

1. Page count of the CCH Inc. Standard Federal Tax Reporter.

2. See Chris Edwards, “Simplifying Federal Taxes: The Advantages of Consumption‐​Based Taxation,” Cato Institute Policy Analysis no. 416, October 17, 2001.

3. More precisely, the plan’s tax rates would be applied to taxable income, which would be adjusted gross income (as under current law) less the standard deduction and an expanded personal exemption. In 2005 the standard deduction is $5,000 for single and $10,000 for married filers, and the expanded personal exemption would be $4,500. Thus, the 27 percent bracket would begin at about $80,000 of taxable income for singles and about $160,000 of taxable income for married couples. (Dividends, interest, and capital gains would taxed at a maximum of 15 percent).

4. Calculations include the effect of the employer‐​paid payroll tax being deductible against the corporate income tax.

5. The administration has proposed adding lifetime savings accounts and simplifying the rules on current retirement plans. For a description, see U.S. Treasury, “General Explanation of the Administration’s FY2005 Revenue Proposals,” February 2004, www​.treas​.gov/​o​f​f​i​c​e​s​/​t​a​x​-​p​o​l​i​c​y​/​l​i​b​r​a​r​y​/​b​l​u​e​b​k​0​4.pdf.

6. Looking at IRS data for all nonfinancial C corporations for 2000 and 2001, the interest deduction is typically about $60 billion larger than interest income. Special rules would be required for the financial services industry. For corporate data, see IRS, Statistics of Income Division, Corporate Income Tax Returns 2001 (Washington: Government Printing Office, undated), Table 12.

7. Calculated as 15 + (1–0.15)*15.

8. For this proposal, I have assumed that the corporate income tax would be paid by C corporations, as under current law. Small businesses would continue to pay tax under the individual system. However, in the long run the tax code should be reformed to equalize the tax treatment of all businesses.

9. Ronald Reagan, Remarks during a White House Briefing on Tax Reform, June 7, 1985, www​.rea​gan​.utexas​.edu/​r​e​s​o​u​r​c​e​/​s​p​e​e​c​h​e​s​/​1​9​8​5​/​6​0​7​8​5​b.htm.

10. Martin Feldstein and Gilbert Metcalf, “The Effect of Federal Tax Deductibility on State and Local Taxes and Spending,” NBER Working Paper no. 1791, January 1986.

11. The Tax Foundation’s Individual Tax Simulation Model is based on the IRS, Statistics of Income, public use data file.

12. Chris Edwards and Veronique de Rugy, “International Tax Competition: A 21st‐​Century Restraint on Government,” Cato Institute Policy Analysis no. 431, April 12, 2002.

13. KPMG, “Corporate Tax Rates Survey,” January 2004.

14. See Michael Cannon, “Combining Tax Reform and Health Care Reform with Large HSAs,” Cato Institute Tax & Budget Bulletin no. 23, May, 2005.

15. Based on my calculations of aggregate IRS data for all nonfinancial C corporations in 2000 and 2001. The exclusion of interest income and deductions would expand the corporate tax base by about 10 percent; ending the health insurance deduction would expand the base by about 30 percent; and ending deductions for state and local taxes would expand the base by about 30 percent. Special rules would be needed for the financial services industry under such a tax plan. For corporate data, see IRS, Statistics of Income Division, Table 12.

16. Business subsidies, or “corporate welfare” on the spending side of the federal budget totals about $90 billion annually. See Chris Edwards and Tad DeHaven, “Corporate Welfare Update,” Cato Institute Tax & Budget Bulletin no. 7, May 2002.

17. U.S. Department of Treasury, Integration of the Individual and Corporate Tax Systems (Washington: Government Printing Office, January 1992).

18. For a discussion of international tax systems used in other countries, see Peter Merrill, PricewaterhouseCoopers, Testimony before the House Budget Committee on the “Competitiveness of the U.S. Tax Code,” July 22, 2004.

19. Chris Edwards, “Downsizing the Federal Government,” Cato Institute Policy Analysis no. 515, June 2, 2004.

About the Author
Chris Edwards
Director of Tax Policy Studies and editor of