A Progressive System of Mark-to-Market Taxation
David S. Miller
Cadwalader, Wickersham & Taft
October 19, 2010
This article proposes a progressive system of mark-to-market taxation.
Under the proposal, all public companies, all private companies with $50 million or more of net assets, and all individuals and married couples with $1.6 million of adjusted gross income or $5 million of publicly traded property - representing the top 0.1 percent of highest-earning and wealthiest individuals - would be required to mark to market their publicly traded property and derivatives.
Mark-to-market gains of corporations would be subject to tax at the current marginal rate of 35%. Mark-to-market losses of corporations would be fully deductible against ordinary income or capital gain. Mark-to-market gains (and qualified dividends) of individuals would be subject to tax at the long-term capital gains rate of 15 percent, and their interest and other ordinary income would remain subject to tax at the ordinary income rate of 35%.
Individuals’ mark-to-market losses would be fully deductible to the extent of prior mark-to-market gains, could then be used to offset capital gains, and then mark-to-market losses could offset 43 percent (15%/35%) of ordinary income or could be carried forward indefinitely.
By a conservative (but back-of-the-envelope) estimate, the proposal could generate between $490 billion and $750 billion of new revenue over a 10-year horizon.
Number of Pages in PDF File: 34
JEL Classification: H20, H21, H22, H23, H24, H25working papers series
Date posted: October 21, 2010 ; Last revised: November 12, 2010
© 2013 Social Science Electronic Publishing, Inc. All Rights Reserved.
This page was processed by apollo5 in 0.281 seconds