Most industrial and developing countries tax individual and corporate capital gains more lightly than does the United States, according to a survey of twenty-four industrialized and developing countries that the ACCF Center for Policy Research commissioned from Arthur Andersen LLP. The Center’s analysis shows that the United States taxes both short- and long-term capital gains more harshly than most other countries. High capital gains tax rates increase the bias against saving and investment, raise the cost of capital for new investment, and slow U.S. economic growth.
Both short- and long-term capital gains on equities are taxed at higher rates in the United States than in most of the other twenty-three countries surveyed. Short-term gains are taxed at 39.6 percent in the United States compared to an average of 19.4 for the sample as a whole (see comparison table, parts I & II, and accompanying notes [marked with asterisk]). Long-term gains face a tax rate of 20 percent in the United States versus an average of 15.9 for all the countries in the survey. Thus, U.S. individual taxpayers face tax rates on long-term gains that are 26 percent higher than those paid by the average investor in other countries. In addition, the United States is one of only five countries surveyed with a holding period requirement in order for the investment to qualify as a capital asset.
The reduction in individual capital gains tax rates in the Taxpayer Relief Act of 1997 lowered the cost of capital for new investment and thus will enhance U.S. productivity and economic growth. The 1997 reductions almost certainly contributed to the current budget surpluses. In addition, shortening the holding period for long-term capital gains from eighteen to twelve months, which was included in the IRS Restructuring and Reform Act of 1998, signed into law by President Clinton July 22, 1998, will be a further boost to investment.
Similarly, short- and long-term corporate capital gains tax rates are higher in the United States than in most other industrial and developing countries surveyed. Both short- and long-term gains are taxed at a rate of 35 percent in the United States, compared to an average of 22.8 percent for short-term gains and 19.6 percent for long-term gains in the sample as a whole. In other words, U.S. corporations face long-term capital gains tax rates almost 80 percent higher than those of their competitors in other countries. The U.S. tax rate on long-term corporate capital gains is higher than that of all but two of the other countries surveyed (Germany [45 percent] and Australia [36 percent], and Australia provides for indexing the cost of an asset). In addition, only four of the twenty-four countries surveyed impose a holding period in order to be eligible for preferential corporate capital gains tax rates.
Sound tax policy and economic considerations, as well as revenue consequences, argue for further reductions in U.S. individual capital gains taxes. In addition, the U.S. corporate capital gains tax rate of 35 percent should be reduced, thereby creating a meaningful differential between the tax rate on ordinary corporate income and on capital gains. This would reinstate the historical U.S. treatment of corporate capital gains: an alternative corporate capital gains tax was part of the Internal Revenue Code from 1942 until its repeal by the Tax Reform Act of 1986.
| PART I: COMPARISON OF CAPITAL GAINS TAX RATES FOR INDIVIDUALS | |||||
| Country | Gross Domestic Saving as a Percent of GDP | Maximum Individual Tax Rate | Individual Capital Gains: Max. Tax Rate on Equities | Individual Holding Period | |
|---|---|---|---|---|---|
| Short-term | Long-term | ||||
| Argentina | 18.0 | 33.0 | Exempt | Exempt | No |
| Australia | 21.0 | 48.5 | 48.5 | 48.5; asset cost is indexed | No |
| Belgium | 23.0 | 56.7 | Exempt | Exempt | No |
| Brazil | 18.0 | 27.5 | 15.0 | 15.0 | No |
| Canada | 21.0 | 31.3 | 23.5 | 23.5 | No |
| Chile | 26.0 | 45.0 | 45.0; annual exclusion of $6,600 | 45.0; annual exclusion of $6,600 | No |
| China | 44.0 | 45.0 | 20.0; shares traded on major exchange exempt | 20.0; shares traded on major exchange exempt | No |
| Denmark | 21.0 | 61.7 | 40.0 | 40.0; shares valued at less than $16,000 exempt if held 3+ years | Yes, 3 years* |
| France | 21.0 | 58.1 | 26.0; annual exclusion of $8,315 | 26.0; annual exclusion of $8,315 | No |
| Germany | 23.0 | 55.9 | 55.9 | Exempt | Yes, 6 months |
| Hong Kong | 31.0 | 20.0* | Exempt | Exempt | No |
| India | 24.0 | 30.0 | 30.0 | 20.0 | Yes, 1 year |
| Indonesia | 33.0 | 30.0 | 0.1 | 0.1 | No |
| Italy | 22.0 | 46.0 | 12.5 | 12.5 | No |
| Japan | 30.0 | 50.0 | 1.25% of sales price or 20% of net gain | 1.25% of sales price or 20% of net gain | No |
| Korea | 34.0 | 40.0 | 20.0; shares traded on major exchange exempt | 20.0; shares traded on major exchange exempt | No |
| Mexico | 23.0 | 35.0 | Exempt | Exempt | No |
| Netherlands | 26.0 | 60.0 | Exempt | Exempt | No |
| Poland | 18.0 | 40.0 | Exempt | Exempt | No |
| Singapore | 50.0 | 28.0 | Exempt | Exempt | No |
| Sweden | 22.0 | 57.0 | 30.0 | 30.0 | No |
| Taiwan | N/A | 40.0 | Exempt (local company shares) | Exempt (local company shares) | No |
| United Kingdom | 15.0 | 40.0 | 40.0; shares valued at less than $11,225 exempt | 40.0; shares valued at less than $11,225 exempt | Yes, 1 to 10 years* |
| United States | 16.0 | 39.6 | 39.6 | 20.0 | Yes, 1 year* |
| Average | 25.2 | 42.4 | 19.4 | 15.9 | 79.2% have no holding period |
| PART II: COMPARISON OF CAPITAL GAINS TAX RATES FOR CORPORATIONS | ||||
|---|---|---|---|---|
| Country | Maximum Corporate Income Tax Rate | Corporate Capital Gains: Maximum Tax Rate on Equities | Corporate Holding Period | |
| Short-term | Long-term | |||
| Argentina | 33.0 | 33.0 | 33.0 | No |
| Australia | 36.0 | 36.0 | 36.0; asset cost is indexed | No |
| Belgium | 40.2 | Exempt | Exempt | No |
| Brazil | 33.0 | 33.0 | 33.0 | No |
| Canada | 29.1 | 21.8 | 21.8 | No |
| Chile | 15.0 | 15.0 | 15.0; asset cost is indexed | No |
| China | 33.0 | 33.0; shares traded on major exchange exempt | 33.0; shares traded on major exchange exempt | No |
| Denmark | 34.0 | 34.0 | Exempt* | Yes, 3 years* |
| France | 41.7 | 41.7 | 23.8 | Yes, 2 years |
| Germany | 45.0 | 45.0 | 45.0 | No |
| Hong Kong | 16.0* | Exempt | Exempt | No |
| India | 35.0 | 35.0 | 20.0* | Yes, 1 year |
| Indonesia | 30.0 | 0.1* | 0.1* | No |
| Italy | 37.0 | 37.0 | 27.0* | Yes, 3 years |
| Japan | 34.5 | 34.5 | 34.5 | No |
| Korea | 28.0 | 20.0; shares traded on major exchange exempt | 20.0; shares traded on major exchange exempt | No |
| Mexico | 34.0 | 34.0 | 34.0 | No |
| Netherlands | 35.0 | Exempt | Exempt | No |
| Poland | 36.0* | Exempt | Exempt | No |
| Singapore | 26.0 | Exempt | Exempt | No |
| Sweden | 28.0 | 28.0 | 28.0 | No |
| Taiwan | 25.0 | Exempt (local company shares) | Exempt (local company shares) | No |
| United Kingdom | 31.0* | 31.0* | 31.0*; asset cost is indexed | No |
| United States | 35.0 | 35.0 | 35.0 | No |
| Average | 32.1 | 22.8; United States is 54% higher than average | 19.6; United States is 79% higher than average | 83% have no holding period |
| *Notes on Table/Parts I and II | |
|---|---|
| Maximum Individual Tax Rate | |
| Hong Kong | Maximum marginal tax rate is 20 percent for the assessment year 1997/1998 and 17 percent for 1998/1999. |
| Individual Capital Gains | |
| Denmark | Gains on shares held three or more years are tax exempt if taxpayer owns less than US $16,000 of the company’s shares. |
| U. Kingdom | Sliding scale of rates applies to 1 to 10 years of ownership through an exclusion that rises gradually to 75 percent for assets held 10 or more years. Thus, assets held 10 or more years face a top marginal rate of 10 percent. |
| United States | Shares held 12 months or more are taxed at a rate lower than that on ordinary income under the IRS Restructuring and Reform Act of 1998. |
| Maximum Corporate Income Tax Rates | |
| Hong Kong | Maximum corporate rate is 16 percent for the assessment year 1998/99 and 16.5 percent for 1997/98. |
| Poland | The corporate rate will be reduced to 34 percent in 1999 and to 32 percent for 2000 and beyond. |
| U. Kingdom | The corporate rate will be reduced to 30 percent effective from April 1999. |
| Corporate Capital Gains | |
| Denmark | For corporations, capital gains are tax exempt if the holding period is longer than three years. |
| India | Capital gains from sale of equity investments and securities listed on stock exchange and held for more than one year are taxed at 20 percent. |
| Indonesia | An additional tax of 0.5 percent applies to the disposition of founder shares (effective as of May 29, 1997). In this case, if the taxpayer does not want to use the facility of 0.5 percent, the normal progressive tax rate of 30 percent is applied. |
| Italy | For corporations, a substitute tax of 27 percent applies on capital gains arising from the transfer of shares held and accounted for as financial assets for at least three years. |
| U. Kingdom | The corporate rate will be reduced to 30 percent effective from April 1999. |