Frequently Asked Questions: Business Income Tax Loopholes

(SB3158Burchett/HB3182

Supplement to “Achieving a Broadly-Shared Prosperity in TN” www.fairtaxation.org/downloads/foodbizfairness.pdf

 

Q.        Why does Tennessee allow multi-state companies to take tax breaks that are not available to in-state companies?

A.        We can’t answer this question, but it seems to us that it’s time for the citizens and especially the business community of Tennessee to come together to demand that the General Assembly put an end to these tax breaks.

 

Q.        Why do you say the food tax is unfair?

A.        A Tennessee family earning in the lowest 20% spends over 20% of its income on food. A family in the top 20% spends only 4% of its income on food (even though the dollar amount is greater). Thus, the food tax hits the lower income family 5 times as hard as the affluent family.

 

Q.        Aren’t Food Stamps and WIC vouchers exempt from sales tax?

A.        Yes, but those are only supplements that do not provide full nutrition for a family. Also, many low and moderate-income families do not qualify for those programs.

 

Q.        Isn’t the food tax the most stable part of TN’s tax system?

A.        Stability is not the primary problem with Tennessee’s tax system. The lack of natural growth is. While the food tax is fairly resistant to short-term economic fluctuations, it is an extremely slow-growing revenue source over the long term. Because of its heavy reliance on sales and other consumption taxes that do not grow with the economy, Tennessee has a persistent structural deficit in its tax system. As time goes by and inflation increases the cost of government, TN must pass new laws to raise the rate of its consumption taxes; the current tax base does not grow with the economy.

 

Business taxes, by comparison, are fairly high-growth taxes over the long term. Substituting revenue generated by closing corporate tax loopholes for a portion of the food tax would help make Tennessee’s tax system more “elastic” or responsive to economic growth. 

 

Q.        Isn’t there a budget deficit this year that would make cutting the food tax difficult?

A.        Initially the administration stated its intention to meet the current budget shortfall by using savings that occur naturally from unfilled positions, programs that start later than expected or programs that run more efficiently. However, continuing shortfalls may necessitate budget cuts. While these are effective short-term solutions, the Food and Business Tax Fairness Act would help address the long-term budget challenges. It would replace a portion of the slow-growing food tax with business taxes that are far more responsive to economic growth. This approach would put our tax system on more solid fiscal ground as we move forward.

 

Q.        Would cutting the food tax make a TN personal income tax necessary?

A.        TFT believes that the creation of a balanced, common sense tax system will ultimately require a state income tax, as part of a comprehensive tax-restructuring package. The issue of a comprehensive tax package, however, is a much larger debate than whether or not we should cut the state food tax.

 

In practice, there is little connection between states that tax food and states that have an income tax. Of the 9 states without a broad-based income tax, only 2 tax food (Tennessee and South Dakota). Of the 41 states with a broad-based income tax, 12 tax food. The reason there is such little correlation between the two is that the food tax represents a very small, yet very unfair, portion of state revenue. In Tennessee, it represents less than 2% of the overall revenue, an amount that could easily be replaced, even without a state income tax.

 

Q.        How would the Food & Business Tax Fairness Act benefit Tennessee businesses?

A.         Small and medium-sized businesses that operate only in Tennessee (and perhaps a few multi-state businesses that voluntarily pay their full Tennessee taxes) are subsidizing those multi-state businesses that avoid TN taxes.  Such businesses minimize their TN taxes through elaborate restructuring of their subsidiary businesses to take advantage of loopholes in Tennessee’s tax code.

 

If all multi-state corporations paid their full tax obligations, we could all pay less tax on our food, and future tax increases could be delayed or avoided altogether. Also, businesses that compete directly with large multi-state corporations might be able to compete more effectively when their competitors have the same tax obligations.

 

Q.        How do you plan to close the loopholes?

A.        There is a mechanism called “combined reporting” that is now the law in 21 of the 45 states that have a corporate income tax. Those 21 states represent more than 50% of U. S. economic activity. California was the first state to introduce “combined reporting” in 1937. Sixteen states have used this approach since 1983 or before. Since 2004, Vermont, Texas, West Virginia, New York and Michigan have joined the movement. The governors of Iowa, Massachusetts North Carolina and Pennsylvania have recommended “combined reporting” for their states. The Multistate Tax Commission, a collaborative effort of state departments of revenue, has advocated “combined reporting” and is distributing a model law it approved in August 2006.

 

Michael Mazerov of the Center on Budget and Policy Priorities (CBPP) and Dr. William F. Fox of the UT Center on Business and Economic Research have advocated “combined reporting” for years. Charles McLure, Senior Fellow at the Hoover Institution and Deputy Assistant Secretary of the Treasury during the Reagan Administration said, “Failure to require unitary combination is an open invitation to tax avoidance.  (Or  to the extent transfer prices are misstated  — is it tax evasion?)  The advent of electronic commerce exacerbates the potential problems of economic interdependence and manipulation of transfer prices.” Charles E. McClure. “The Nuttiness of State and Local Taxes and the Nuttiness of Responses Thereto”. State Tax Notes, September 11, 2002, p. 851.

 

The Supreme Court has twice upheld the fairness and constitutionality of “combined reporting”.

 

Q.        What is “combined reporting”? What loopholes will it close?

A.        “Combined reporting” is a comprehensive solution to plug most of the largest loopholes in state corporate income tax systems. It nullifies the benefit of “PICs”, “nowhere income”, “transfer pricing”, “captive REITs”, “captive insurance companies” and “stashing” income-earning assets in tax haven states.

 

See Michael Mazerov. State Corporate Tax Shelters and the Need for Combined Reporting.  Center on Budget and Policy Priorities. October 26, 2007.  For a detailed discussion of some of the major corporate tax shelters and tax-avoidance strategies to which states that have not adopted “combined reporting” are vulnerable, consult: http://www.cbpp.org/10-25-07sfp.pdf.

 

Q.        Didn’t Tennessee already close these loopholes a couple of years ago?

A.        Tennessee recently enacted legislation to eliminate certain tax benefits associated with captive real estate investment trusts (REITs). However, this particular loophole is only one of many that multi-state corporations take advantage of, and even it was not fully closed.

 

Instead of taking a piecemeal approach to closing corporate tax loopholes, “combined reporting” goes to the core of the problem with a simple, common sense solution. By requiring corporations to report all their related subsidiaries as one business for tax purposes, “combined reporting” nullifies all the loopholes that hinge on the ability to shift profits back and forth among subsidiaries.

 

Q.        How does “combined reporting” work?

A.        “Combined reporting” is the alternative to the current system, “separate entity reporting” for corporate income tax calculation in TN. Most multi-state businesses are organized as a “parent company” and multiple subsidiaries with defined functions. “Separate entity reporting” states require each separate entity (parent or subsidiary) that conducts business in the state to file its own income tax return. This type of reporting leaves the door open for businesses to transfer their income from one subsidiary in a state that would tax it to another subsidiary in a state that would not tax it or tax it at a lower rate.

 

“Combined reporting” states require businesses that operate in their state to file one tax return combining the income and expenses of the parent company and all its subsidiaries that operate in the same “unitary” business. The income is then apportioned among the states according to a formula that includes factors for payroll, real estate and sales.

 

Q.        What is a “unitary” business?

A.        A unitary business is an integrated economic enterprise. One example is a retail business with transportation, storage, real estate management and marketing subsidiaries. If that company also owns a subsidiary cattle ranch, with independent management and sales to outside buyers, the subsidiary would not be part of the unitary business. If the subsidiary sold its beef in the retail stores, however, it would be part of the unitary business.

 

Q.        Won’t clever lawyers and accountants just devise new schemes to avoid state taxes?

A.        They may, but “combined reporting” leaves less “wiggle room” and smaller amounts of income available for tax sheltering. Other loophole-closing approaches focus on one scheme at a time, and are subject to more court challenges. Since “combined reporting” has been around so long, has been upheld by the Supreme Court and is now supported by a model statute and model regulations promulgated by the Multistate Tax Commission, the lawyers and accountants will have to earn their fees.

 

Q.        What companies are most aggressive about sheltering their income from state taxes?

A.        Corporations consider their tax returns confidential, proprietary information. Thus, it is very difficult to get solid information about their tax reduction strategies. The information that is available comes from court cases between corporations and state departments of revenue trying to enforce their laws and collect taxes they believe were due. State Corporate Tax Shelters and the Need for Combined Reporting article cited above lists 49 companies known to have used “PICs”.

 

Another study reviewed 252 corporations and compared the total state and local income taxes corporations reported in their federal income tax filings. The study listed state income tax rates for the years 2001 to 2003. It found that 71 companies paid no state income taxes in at least one of those years. The aggregate effective tax rate paid over those three years was 2.6%, while the average rate, according to state laws, was 6.8%.

 

Five of those 252 companies were headquartered in Tennessee. The companies and their respective aggregate state taxes paid were: Dollar General, 2.4%; Autozone, 2.8%; FedEx, 3.2%; Caremark, 3.5% and HCA, 3.6%. Tennessee’s statutory corporate income tax rate is 6.5%.

See Robert S. McIntyre and T.D. Coo Nguyen, State Corporate Income Taxes 2001-2003, Citizens for Tax Justice. February 2005.  A detailed study of the low aggregate state corporate tax payments made by many of the largest corporations in the U.S. can be found at: http://www.ctj.org/pdf/corp0205an.pdf. 

 

Q.        Is it legal for these companies to dodge so much of their tax liability?

A.        Yes. Tennessee’s tax law is so lax that multi-state companies routinely exploit the 18-wheeler sized gaps in the tax code.

 

Q.        How much revenue would full “combined reporting” generate in Tennessee?

A.        Because corporations’ tax returns are treated as confidential, proprietary information, it is difficult to know with certainty how much revenue would be generated by “combined reporting” in Tennessee.

 

The most detailed study on revenue generated through “combined reporting”, prepared by the Pennsylvania Department of Revenue, received an award for best research by a state revenue department from the Federation of Tax Administrators. That study found that “combined reporting” would increase business income tax revenue by 24%. Based on the following table, TFT estimates additional business income tax revenue in the range of 12-25%. Tennessee’s projected business income tax revenue for 2008-9 is around $1.15 Billion. This figure suggests that “combined reporting” could result in additional revenue between $135 and $275 Million.

 

Earlier studies produced the following results for other states:

Projected Increase in Corporate Income Tax Revenue Due to Combined Reporting

Dollar increase (millions)

Percent Increase

Wisconsin

70

13.0

Iowa

25

13.5

Vermont

5

14.2

Maryland

85

19.6

Florida

238

24.8

Source: Massachusetts Budget and Policy Center, Setting the record Straight on Combined Reporting,

March 30, 2004, http://www.massbudget.org/recordoncr.pdf (data from respective state governments)

 

Q.        Are there other measures Tennessee should take to tighten up its tax laws?

A.        Yes. Tennessee needs to add a “throwback rule” section that states: "Sales of tangible personal property are in Tennessee if the property is shipped from an office, store, warehouse, factory, or other place in this State and the taxpayer is not taxable in the State of the purchaser". Tennessee should also define business income as "all income which is apportionable under the Constitution of the United States." Michael Mazerov, Center on Budget and Policy Priorities, “Closing Three Common Corporate Income Tax Loopholes Could Raise Additional Revenue for Many States,” May 23, 2003.

 

Q.        How do you respond to multi-state corporations’ assertions that “combined reporting” would hinder economic development?

A.        “Combined reporting” states are disproportionately among the most economically successful. From 1979 to 2000, when manufacturing employment peaked in the U.S., “combined reporting” states constituted: 4 of the top 5 states in manufacturing job growth, 7 of the top 10 states in manufacturing job growth, 10 of the 17 states with positive manufacturing job growth, and only 6 of the 33 states with zero or negative manufacturing job growth. This does not prove that “combined reporting” enhances economic development, but it makes a compelling case that it does not hinder growth.

 

Q.        How do you respond to multi-state corporations’ assertions that “combined reporting” is unworkable and has caused lots of litigation over definition of “unitary business”?

A.        There has been considerable litigation over what constitutes a “unitary” business because such litigation is about the only course available to businesses to protect their tax avoidance schemes. Now that the Multistate Tax Commission has prepared a model statute and clear, enforceable definitions and regulations, such litigation should become less common. In any case, there has been no more litigation about unitary businesses than about laws specifically targeting only “PICs”, “REITs” or other “tax planning strategies”.

 

Q:        Which states are the common tax haven states?

A:        Nevada and Delaware

 

Q:        How would the new revenue be used?

A:        To fund further reductions in Tennessee’s regressive food tax. However, we understand that whenever a new source of revenue is introduced, everyone wants a piece of it.

 

Q.        Doesn’t the Commissioner of Revenue have the authority to require “combined reporting”?

A.        Yes, but only on a case-by-case basis and when he has reason to believe the taxpayer has underreported income. Exercising that authority would almost surely lead to litigation and the cost-benefit ratio would be too high to make it worthwhile. Mandatory “combined reporting” would be much more efficient.

 

In an article in the prestigious National Tax Journal, Economists William F. Fox, Matthew N. Murray, and LeAnn Luna wrote: “[W]e argue for “combined reporting” in all states. This conclusion is based in part on economic considerations that are independent of any tax planning opportunities, such as the practical problems associated with measuring economies of scope across related firms. But “combined reporting” can also lessen tax planning distortions based only on corporate form that waste resources through avoidance and government oversight activities. William F. Fox, Matthew N. Murray, and LeAnn Luna. “How Should a Subnational Corporate Income Tax on Multistate Businesses Be Structured?” National Tax Journal. March 2005.