Owner-occupied housing taxation: an equity evaluation of the UK and US tax systems.

Abstract

This research identifies and quantifies horizontal and vertical inequities resulting from selected owner-occupied housing tax policies though micro-simulation. The simulations are spread sheet constructions underpinned by the respective UK and US tax systems. Within each country-specific simulation case families are established varying with regard to income levels and investment choices. The specific tax policies analysed are the acquisition taxes, property taxes, elements specific to housing affecting income taxes (i.e. mortgage interest relief) and capital gains taxes. In addition to the specific tax policies, the overall tax obligations (the sum of the four specific taxes) are considered. The time frame of the study is a twenty-year period from 1990 through 2009. A recurring theme in the literature is that homeowners ought to be taxed as investors in rental properties to ensure tenure neutrality or, alternatively, taxed as any other investor to ensure tax neutrality. This research considers the corresponding effects on horizontal and vertical equity by modifying the UK and US tax systems for increased levels of neutrality through further micro-simulation analysis. Finally, the respective owner-occupied housing tax policy changes and reforms that occurred within the twenty-year period studied are evaluated in terms of enhancements to or hindrances of horizontal and vertical equity. This is accomplished by simulating sixteen five-year periods within the twenty-year time frame and evaluating horizontal and vertical equity on a within-country and a cross- country basis. What appears to be lacking in the literature is an extensive comparative analysis of the specific owner-occupied housing tax policies and their interrelationship with respect to the complex overall tax system in which they are present. The aim of this research is to contribute to the middle/high range of comparative analytical work. The research is set within a comprehensive theoretical framework and systematically ii compares the two countries’ specific tax policies and their overall impact on the respective tax systems. The methodology used is consistent between the two countries, ensuring a robust dual-nation comparison. The US specific tax policies relevant to homeownership and the overall tax system were found to have greater inherent horizontal inequities when compared with the UK tax policies and tax system. Both countries’ specific tax systems were found to have varying inherent vertical inequities. The UK homeowner occupiers experience more vertical equity (progressivity) in the acquisition tax system when compared with the US investors. Conversely, the US homeowner occupiers experience more vertical equity (progressivity) in the property tax, income tax and capital gains tax systems. Overall, the US investors experience a more progressive tax system when compared directly with the UK investors. The abolition of the UK Mortgage Interest Relief at Source (MIRAS) resulted in a less progressive income tax system for homeowner occupiers but one that is more horizontally equitable with other investors. The erosion of the benefits realised from the US mortgage interest and real estate tax deductions has resulted in a more vertically and horizontally equitable income tax system for all but the most wealthy. Vertical equity was improved by the adoption of the UK council tax in that it is a less regressive form of property taxation when compared with its predecessor. The recent reforms to the UK stamp duty (land tax) have made the system of acquisition taxation more vertically equitable but have exacerbated the horizontal inequity of the system with respect to other capital investors. The US capital gains tax system as it relates to the homeowner occupier changed significantly with the Tax Reform Act of 1997, resulting in a simpler but less equitable system depending on circumstances. With regard to the equity of the overall tax systems of the two countries, the UK’s progressivity has decreased while the horizontal equity has improved during the twenty-year period, whereas the progressivity of the US system has remained relatively flat with an improvement in horizontal equity. iii The author concludes with a call for the gradual repeal of the mortgage interest relief in the US, a subsidy shown to be extremely vertically inequitable in this study and one that was estimated to cost the exchequer $79 million in lost tax revenue in 2010 by the US Office for Management and Budget. While a taxable imputed rental income may be theoretically optimal, the well-recognised administrative and compliance issues associated with such tax reform make it untenable. Therefore, the second best option and the one adopted by the UK and most other developed nations, is not to allow a deduction for a cost in generating untaxed income. This research contributes a unique synthesis of methodological techniques to the housing equity literature. The combined analyses of horizontal equity under the classical definition with the chosen structural and distributional techniques in evaluating vertical equity have never been done before. The analysis of the overall tax system comprising four specific tax systems is also original in this area of research and employs the Suits (1977) method for determining overall progressivity. There is an attempt within this research to replicate the results derived from the Suits indices by similarly extending the structural indices, thus testing the transferability of the methodology established by Suits. This is the first attempt to extend the structural indices established decades earlier to researcher’s knowledge. The results from two of the three structural measures are inconsistent with each other and the results from the Suits indices and therefore not believed to be informative. However, the results from the extended Liability Progression of both countries are indeed consistent with the results of Suits indices. This is an interesting research observation and may be indicative of the transferability of the Suits methodology. This area of research continues to be discussed by academics and policymakers given the conflicting underpinning theories and continued fiscal favouritism in many developed countries. This research area has become even more topical in the last few years given the recent financial crisis. The multi-layered, comparative micro-simulation technique employed within this research provides a solid platform from which to appraise conventional wisdoms and proposals for future policy with regard to owner-occupied housing taxation and beyond.