Abstract
This study empirically investigates the extent of noncompliance with the tax code and examines the determinants of federal income tax evasion in the U.S. Employing a refined version of Feige’s (Staff Papers, International Monetary Fund 33(4):768–881, 1986, 1989) General Currency Ratio (GCR) model to estimate a time series of unreported income as our measure of tax evasion, we find that 18–23% of total reportable income may not properly be reported to the IRS. This gives rise to a 2009 “tax gap” in the range of $390–$540 billion. As regards the determinants of tax noncompliance, we find that federal income tax evasion is an increasing function of the average effective federal income tax rate, the unemployment rate, the nominal interest rate, and per capita real GDP, and a decreasing function of the IRS audit rate. Despite important refinements of the traditional currency ratio approach for estimating the aggregate size and growth of unreported economies, we conclude that the sensitivity of the results to different benchmarks, imperfect data sources and alternative specifying assumptions precludes obtaining results of sufficient accuracy and reliability to serve as effective policy guides.
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Notes
The IRS reported “that on average, for every dollar of income detected in (the Taxpayer Compliance Measurement Program) TCMP, another $2.28 went undetected.” Internal Revenue Service [43], p.A-31.
Internal Revenue Service [43].
This follows Feige’s [27] suggestion to “look for the footprints unwittingly left behind by the irregular economy in the macroeconomic data that are routinely calculated for other purposes.” P. 6.
The unreported economy as defined by Feige [30] “consists of those economic activities that circumvent or evade the institutionally established fiscal rules as codified in the tax code.”
The illegal economy as defined by Feige [30] “consists of the income produced by those activities pursued in violation of legal statues defining the scope of legitimate forms of commerce.”
The IRS defines the” tax gap” as “the difference between what taxpayers should have paid and what they actually paid on a timely basis.” The tax gap has three components –non-filing; underreporting of taxes owed and underpayment of taxes. It should be noted that the current IRS estimates of the tax gap do not include estimates for tax liabilities incurred from illegal activities since the IRS has not published measures the size of illegal activities since 1981.
These TCMP “audits from hell” were politically deemed to be overly intrusive and were discontinued. A less intrusive substitute for TCMP known as the National Research Program (NPR) was instituted in the 1990’s to estimate noncompliance.
Internal Revenue Service [43], Table D-17
Internal Revenue Service [42], Table VI-2
Unreported income is estimated as the gross tax gap divided by the National Bureau of Economic Research estimate of the marginal tax rate. See: http://www.nber.org/~taxsim/ally/ally.html. This method is likely to overstate legal source unreported income but does not include an estimate for illegal source income.
Often referred to as the “currency demand approach,” the GCR model is fully described in Appendix A along with the typical restrictive assumptions employed to obtain estimates of the relative size of the unreported economy. The relative size of the “unreported economy” is typically measured as Yu/ Yo = α. The “noncompliance rate” (η) is then measured as \( Yu/(\left( {Yu + Yo} \right) = \alpha /\left( {1 + \alpha } \right) \) .
Checkable deposits are defined as the sum of demand deposits and other “checkable deposits”.
The growth of plastic payment alternatives would also be expected to reduce the currency/deposit ratio over time. Failure to specifically account for this trend leads to an underestimate of the true noncompliance rate over time.
The 1988 benchmark includes TCMP estimates of unreported legal source income and projected unreported illegal source income. The 2010 benchmark excludes unreported illegal source income but may overstate unreported legal source income because it is based on the gross tax gap.
The Internal Revenue Service [41] citing underreporting of interest and dividend payments observes that “the unreported income problem extends beyond incomes paid in currency.” P.13
Internal Revenue Service [43], Table A-50.
The tax gap estimates reported diverge from those reported in earlier versions of this paper due to a recent revision of the marginal federal tax rate as estimated by the National Bureau of Economic Research.
The AET is the federal average tax rate from the NBER TAXSIM model. The AUDIT data were obtained from the Government Accounting Office ([39]: Table I.1), and the U.S. Census Bureau ([59]: Table 519, 1998: Table 550, 1999: Table 556, 2001: Table 546, 2010: Table 469). The TRA variable is a dummy variable; the Tax Reform Act of 1986 was actually signed into law by President Reagan in October of 1986. The data for the variables UN, INC, and i were obtained from the Council of Economic Advisors ([21], Tables B-42, B-41, B-73). The DIS data were obtained from the University of Michigan Institute for Social Research [58].The series adopted to measure income tax evasion, in this case represented by the variable U AGI /R AGI = Yu/Yo] were obtained from Feige [34], as described in Section 2. For the interested reader, descriptive statistics for each of the variables in each of the three study periods are found in Appendix B (Table B:1), and the actual U AGI /R AGI data are provided in Table B:2.
Note that the use of plastic payment methods reduces the demand for cash while increasing the demand for checking deposits, hence reducing the observed currency ratio over time.
The lower estimate is based on GCR (1988) while upper is based on GRM (1988) Ku = 4).
Similar concerns are expressed in Feige and Urban [35] in their investigation of estimates of the “unrecorded” economy in transition countries.
When the object of the analysis is to estimate” unrecorded” income, defined by Feige [30] as “the amount of income that should (under existing rules and conventions) be recorded in national income accounting systems but is not recorded,” the analysis should be based on a National Income and Product account (NIPA) aggregate that is properly adjusted for non-monetary imputations and for imputations already included in the recorded aggregate which accounts for omissions due to underreporting on tax source data. See Feige [29] and Feige and Urban [35].
In 1940, individual income taxes amounted to 14% of total government receipts.
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Appendices
Appendix A: The general currency ratio (GCR) model
The General Currency Ratio (GCR) model as described in Feige [28, 29] is a heuristic framework capable of representing a variety of common monetary approaches for obtaining time series estimates of the “unobserved” sector of the economy.
Let:
- o:
-
subscript to denote the observed sector
- u:
-
subscript to denote the unobserved sector
- C:
-
actual currency stock
- D:
-
actual stock of checkable deposits
- Yo :
-
observed income
- ko :
-
ratio of domestic currency to checkable deposits in the observed sector
- ku :
-
ratio of domestic currency to checkable deposits in the unobserved sector
- Vo :
-
observed sector income velocity
- Vu :
-
unobserved sector income velocity
When the object of analysis is to estimate unreported income on federal income tax returns, the empirical counterpart to observed income is the IRS measure of adjusted gross income (AGI). The unobserved sector now is measured by Yu, namely unreported adjusted gross income.Footnote 27 The GCR model specifies the following:
Equations (A:1) and (A: 2) decompose the actual stocks of currency and checkable deposits into their reported and unreported components. Equations (A: 3) and (A: 4) are definitions of the terms ko and ku which can be specified either as constants or functions. Similarly, (A: 5) and (A: 6) define income velocity in the two sectors. To solve the model for unreported income (Yu), we must evaluate (A: 6) in terms of the models observable variables namely, C, D and Yo. Repeated substitution and rearrangement of terms yields the general solution:
The most restrictive variants of the GCR model impose the following assumptionsFootnote 28:
-
a)
The entire stock of currency is held domestically.
-
b)
Currency is the exclusive medium of exchange for unreported transactions. (Du → 0; ku → ∞)
-
c)
The income velocities in the reported and unreported sectors are identical. (β = 1)
-
d)
The ratio of currency to checkable deposits in the observed sector is constant over time. (kot = constant for all t)
Imposing these assumptions on Eq. 8 yields the restrictive form of the GCR model,
Empirical estimates of unreported income (Y ut ) require an estimate of the parameter k o which Cagan [15] and Gutmann [40] assumed could be approximated as follows:
The 1940 benchmark assumption implied that prior to World War II, income tax evasion was zero.Footnote 29 The restrictive assumptions represented by (a….e) give rise to what is commonly known as the “simple currency ratio” model. Given a value of ko, obtained via assumption (e), Eq. A: 9 expresses the unknown unreported income as a simple function of observed variables.
In principle, any year t for which we have an independent estimate of both reported and unreported income can serve as “benchmark” year for estimating the GCR model. Given \( {\alpha_t} = \frac{{{Y_{{ut}}}}}{{{Y_{{ot}}}}} \), we can solve Eq. 9 for kot:
where ηt is the noncompliance rate. If kot = ko for all t, it is possible to generate a temporal path of the noncompliance rate from Eq. A: 9.
If we have independent knowledge concerning the values of the parameters, β and ku, assumptions (b) and (c) can be discarded and Eq. A: 8 can be employed to directly solve for Yut.
Appendix B
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Cebula, R.J., Feige, E.L. America’s unreported economy: measuring the size, growth and determinants of income tax evasion in the U.S.. Crime Law Soc Change 57, 265–285 (2012). https://doi.org/10.1007/s10611-011-9346-x
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DOI: https://doi.org/10.1007/s10611-011-9346-x