Who Pays the Corporate Tax?

Who Pays the Corporate Tax?

Updated September 29, 2021
Who Pays the Corporate Tax?
Among the issues surrounding tax reform is who bears the
noncorporate). It could slightly exceed 100% or slightly fall
burden of the corporate tax. The burden could fall on
short, but was always close to 100%.
stockholders, on capital owners in general, or on labor. This
question is important for characterizing the distributional
Economists then began applying the model to an open
effects of the tax. If the tax reduces the returns to capital, it
economy in which the tax could cause the capital stock to
falls largely on higher-income individuals who own
contract because capital could flow out to other countries.
relatively more of capital assets and is progressive (i.e., the
An important advantage of a model is that it can set the
tax rises as a share of income as income rises). If it reduces
limits of what might be expected. The first, simplest,
wages, it falls on workers and it is less likely to be
models suggested that significant taxes could fall on labor.
progressive.
In the case of a small open economy with one good and
A considerable amount of economic research has appeared,
with perfect capital mobility (i.e., investment flows to the
especially in the past 10 or 15 years, examining the
highest rate of return regardless of location) and where
incidence of the tax. That research is reviewed in detail in
foreign and domestic products are perfect substitutes, the
CRS Report RL34229, Corporate Tax Reform: Issues for
full burden of the tax falls on labor income. Capital flows
Congress, by Jane G. Gravelle. That review suggests that
out of the country to the rest of the world causing the pre-
the evidence supports most or all of the burden falling on
tax return to rise and because prices must remain fixed (due
capital.
to perfect product substitution) and capital owners must
earn their original after-tax return, only the wage rate
Sometimes claims are made that the tax falls on the
adjusts, falling enough to offset the rise in the pre-tax
corporation’s customers (and by implication on purchases
return.
in the economy). Only relative and not absolute prices
matter in determining burden and aggregate real prices
These are strict assumptions; as they are relaxed, the burden
cannot rise in the economy due to taxes. A corporate tax
is more likely to shift to capital. For example, applying the
would raise the prices of corporate goods but at the same
model to a larger economy causes part of the burden to fall
time lower the price of noncorporate goods, with the overal
on capital.
effect on prices zero. Therefore, economic research has
focused on which factor of production (labor or capital)
Empirical evidence also suggests that capital is not
bears the burden, which is the more important issue for
perfectly mobile (i.e., investing abroad is not a perfect
distributional issues.
substitute for investing at home). Relaxing that assumption
causes a larger share to fall on capital as capital cannot
This research reflects two different approaches to empirical
move as easily. Similarly, making foreign products
estimates of the burden: embedding behavioral responses in
imperfect substitutes for domestic products makes the
a general equilibrium model and reduced-form statistical
economy less open and, again, causes more of the burden to
estimates.
fall on capital. Overall, using values from the empirical
literature for the three major behavioral effects (how easily
Behavioral Responses in a General
substitutable capital is across jurisdictions, how easily
Equilibrium Model
substitutable foreign products are for domestic ones, and
how easily capital can be substituted for labor in
Since the 1960s, the standard approach to studying the
production), as well as how capital intensive the corporate-
corporate tax burden was through a general equilibrium
tradable sector is compared with the economy as a whole,
model. The model that prevailed for many years was one
labor appears to bear between 20% and 40% of the burden;
with a closed economy with a fixed capital stock. This
hence, the majority falls on capital.
model shows that the burden falls on capital. The corporate
tax causes the return in the corporate sector to fall, and
This analysis likely still places too much of the burden on
capital moves out of that sector and into the noncorporate
labor for several reasons. First, some share of the profit that
sector. The contraction of the capital stock in the corporate
generates taxes is in the form of rents with the burden borne
sector causes the rate of return before tax to rise, restoring
entirely by stockholders. Although little evidence is
some of the original after-tax return, whereas the abundance
available on the share of rent, that evidence suggests a share
in the noncorporate sector causes the rate of return to fall,
of 10% to 20%. This share suggests a range of 15% to 36%
spreading the burden to other capital income. It also causes
falling on labor.
prices to rise in the corporate sector and fall in the
noncorporate sector. With a reasonable set of empirical
Second, the analysis applies only to a fully source-based
assumptions, wages were largely unaffected and the burden
(territorial) tax in which the U.S. corporate tax applies only
fell around 100% on capital (both corporate and
to profits earned in the United States. U.S. taxes are
https://crsreports.congress.gov

Who Pays the Corporate Tax?
imposed on some foreign source income, so that when the
found smaller results, but they still implied a fall in labor
tax rate increases, the tax on foreign source income also
income of $13 for each $1 of tax. Most of these studies,
increases. This effect reduces some of the outflow of
when examined closely, have errors, rely on restrictive
capital, which is the cause of the tax falling on labor, thus
assumptions, or have results that disappear with reasonable
further reducing the share falling on labor income. Current
changes in specification.
tax proposals in the Build Back Better Act, which would
increase the corporate tax rate from 21% to 26.5%, would
Studies across states have two additional limitations when
also increase those taxes and further reduce the share (both
used to infer U.S. corporate tax incidence. First, the state
of the existing tax and the tax change) that fall on labor.
corporate taxes are themselves only a fraction of federal
corporate taxes and thus they appeal to an even smaller
Finally, and perhaps most importantly, the corporate tax
variable. Second, it is difficult to determine whether these
subsidizes debt, so lowering the corporate tax will bring in
results would apply to the U.S. corporate tax.
more equity capital but less debt. As estimated in a study of
this phenomenon, if debt is more substitutable across
There is also a body of studies, mostly prepared by
countries than equity, lowering the corporate tax could
European economists, that examine the share of rents that
cause a contraction of total capital and a fall in wages. The
labor receives using a bargaining framework. These studies
consideration of debt could reverse the findings, indicating
are often cited as evidence of the U.S. corporate tax burden.
that labor income falls when the corporate tax is reduced.
This effect may be relevant in countries where unions are
strong, such as the UK and Germany, but unions in the
Another issue to consider is whether other countries might
United States are much less important and have declined
react to the United States lowering or raising its tax rate, by
over time; less than 7% of workers in the private sector are
lowering or raising their own rates. Many countries lowered
unionized. Most of these studies suffer from the same
their tax rates following the reduction in the U.S. corporate
problems as the cross-country and cross-state studies, and
tax rate from 48% to 34% in 1986 and from 35% to 21% in
most find implausible effects, particularly as they should
2017. If other countries respond, those changes will reduce
capture only the share of rents that, themselves, are a small
the burden on labor that arises from equity flows.
share of profit. Ironically, the economic theory they use to
model and justify their regressions actually indicates that
Reduced-Form Statistical Estimates
while before tax profits would be shared in a bargaining
situation, the tax on the rent would not be. (The share of the
Over the years, numerous studies have appeared that try to
tax on normal profits born by labor cannot be uncovered by
estimate the effect on wages by statistical regression
these short-term estimates, since it depends on capital flows
techniques in which the change in wages (across countries,
that are held fixed.) Thus, these studies face a strong burden
or in some cases across states) is estimated based on a
of proof when they seek an effect contradicted by theory.
number of explanatory variables, including the corporate
tax rate.
Current Practices
Such estimates face many difficulties, among them that
Currently, the Congressional Budget Office and the Joint
using a small variable, corporate taxes, that is about 2% of
Committee on Taxation assign 25% of the burden of the
GDP, to explain labor income, which is about two-thirds of
corporate tax to labor when preparing distributional results.
GDP, is unlikely to be robust (i.e., estimates are sensitive to
The Department of Treasury assigns 20% to labor in its last
small changes in variables). In addition, many of these
distributional estimate.
studies have yielded implausible results. For example, one
cross-country study’s estimates indicated that labor income
Jane G. Gravelle, Senior Specialist in Economic Policy
falls by $22 for each $1 of tax, an outcome that is
theoretically impossible, as shown in the previous
IF10742
discussion. The authors later revised their estimates and

https://crsreports.congress.gov

Who Pays the Corporate Tax?

Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff to
congressional committees and Members of Congress. It operates solely at the behest of and under the direction of Congress.
Information in a CRS Report should not be relied upon for purposes other than public understanding of information that has
been provided by CRS to Members of Congress in connection with CRS’s institutional role. CRS Reports, as a work of the
United States Government, are not subject to copyright protection in the United States. Any CRS Report may be
reproduced and distributed in its entirety without permission from CRS. However, as a CRS Report may include
copyrighted images or material from a third party, you may need to obtain the permissio n of the copyright holder if you
wish to copy or otherwise use copyrighted material.

https://crsreports.congress.gov | IF10742 · VERSION 3 · UPDATED