speeches · April 29, 1980
Speech
G. William Miller · Governor
jjf
OepartmentoftheTREASURY
WASHINGTON, D.C. 20220 TELEPHONE 566-2041
I
embargoed for release until delivery
Expected at 9:30 a.m.
STATEMENT OF
THE HONORABLE
G. WILLIAM MILLER
SECRETARY OF THE TREASURY
BEFORE THE
COMMITTEE ON WAYS AND MEANS
U.S. HOUSE OF REPRESENTATIVES
APRIL 30, 1980
Mr. Chairman and Members of the Committee:
I am pleased to be here today to discuss the President's
proposal for withholding on interest and dividends.
Underreporting of interest and dividend income is no
longer a problem that we can afford to ignore. In 1979
taxpayers underreported interest and dividend income by
about $16 billion and thereby underpaid their taxes by
approximately $3.6 billion. Other taxpayers bear the cost
of these lost revenues by paying a larger share of the tax
burden.
Balancing the budget is a national priority in the
fight against inflation. As we ask the American people to
accept fiscal discipline, with cuts in spending for important
economic and social programs, we must at the same time"’take
positive action to avoid needless loss to the Treasury of
billions of dollars due under present tax laws.
Withholding is not a new tax.
To combat this needless loss to the Treasury, the
President has proposed a system of withholding on interest
and dividends similar to the current system of withholding
on the wages of our nation's workforce, a system that has
served us well since 1943. Withholding benefits not only
M-459
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
2
the government, but also benefits taxpayers by providing
them with a gradual and systematic way to pay their taxes.
Let me emphasize that withholding is not a new tax. As
with wage withholding, withholding on interest and dividends
does not increase anyone’s tax liability; it only changes
the method by which the taxes are paid. The purposes of the
withholding program are simple — to collect taxes due on
interest and dividend income and to ensure that all tax
payers report the full amount of their income and pay their
fair share of taxes.
It has been strongly argued in recent years that the
tax system relies too heavily on taxing savings and invest
ment. This issue is being examined closely. But it cannot
plausibly be argued that the way to lighten the tax burden
on savings is to facilitate noncompliance with current tax
laws.
Compliance is a current problem.
Overall our system of income taxation works very
smoothly. It is administered with honesty and integrity and
with very low administrative and enforcement costs.
Nevertheless, a recent Internal Revenue Service report
on income unreported by individuals clearly indicates that
substantial numbers of individuals do not pay the full
amount of tax that they owe because they fail to report the
full amount of their investment income. The report presents
the findings of a year-long study by an Internal Revenue
Service task force appointed by the Commissioner to review
all available data for the purpose of developing the best
possible estimates of unreported income. The report determined
that the 1976 gap between taxable interest payments received
by individual taxpayers and taxable interest payments reported
on individual income tax returns ranges from $5.4 billion to
$9.4 billion. The 1976 gap between taxable dividend payments
received by individuals and those reported on tax returns is
estimated to range from $2.1 billion to $4.7 bilxion. While
individuals are estimated to underreport wage income by only
2 to 3 percent, they omit 9 to 16 percent of interest and
dividend income, a rate of noncompliance that is at least
300 percent greater.
As a result of continued substantial noncompliance in
the reporting of investment income, about $3.6 billion in
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
3
taxes that were lawfully due were not collected in 1979. It
is estimated that in calendar year 1981 this tax loss will
increase to approximately $3.9 billion.
Underreporting of investment income jeopardizes the
very cornerstone of our tax system — self-assessment. The
Internal Revenue Service now audits only about 2 percent of
individual returns filed each year. Withholding provides a
logical means to attain high compliance with low audit
coverage.
Information reporting alone is not enough.
Some have suggested that the existing system of informa
tion reporting — or an expanded system — would solve the
reporting problem if only the Internal Revenue Service would
do its job. In 1962 the Senate rejected the withholding
approach adopted by the House on the ground that improved
compliance should first be sought by expanding the infor
mation reporting requirements. This has been done.
The intervening eighteen years have provided an ample
test of information reporting alone as a compliance measure.
The results of the recent Internal Revenue Service report on
unreported income clearly indicate that, even with the
additional reporting requirements enacted in the Revenue Act
of 1962, taxpayers still fail to report and pay tax on
significant amounts of taxable dividends and interest for
which information reports are filed. Certainly the time has
come to reassess how tax should be collected on interest and
dividend income and why information reporting alone is not
sufficient.
The Internal Revenue Service now matches at least 72
percent of the information documents that it receives on
interest and dividends and uncovers several million discrepancies
Much of the nonreporting is apparently due to inadvertence,
forgetfulness and failure to keep records, particularly by
taxpayers who receive relatively small amounts of dividend
and interest income. Other nonreporting is due to nonfilers
who owe some tax but who are difficult to trace. Because of
the small amount of revenue to be gained from any one taxpayer,
the cost of following up the millions of discrepancies is
demonstrably uneconomical. Even extensive pursuit of tax
payers would not achieve full collection of unpaid taxes.
There would be many unfruitful investigations where taxpayers
cannot be reached by telephone or traced if they have moved.
Even after the taxes have been assessed, it would be impossible
or uneconomical to collect them.
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
. - 4- -
The present situation, then, is that the Internal
Revenue Service uncovers many more leads through its matching
program than it pays to pursue. To follow up on all of
these leads would require millions of telephone calls,
letters and visits, and audit efforts concentrated on
individuals. This would inevitably be regarded as harass
ment of ’’little people" and would require shifts in staffing
that would prevent the Service from directing its limited
resources towards auditing compliance areas that are not
susceptible to withholding.
Withholding is now necessary.
How will withholding help? A substantial portion of
the taxes that now go unpaid will be collected without
costly audit procedures. Hot only will withholding auto
matically collect much of the tax owed, but people will have
more incentive to pay the remainder of their taxes due if
part of their taxes have already been paid. The Service
will be able to channel its audit resources to those areas
where they are most needed and that best serve the public
the complicated returns of corporations, partnerships and
sophisticated high-bracket individuals.
The Administration expects that withholding will also
increase the accuracy of information being submitted to the
Internal Revenue Service, thereby reducing the cost of
reconciling discrepancies on returns. Since taxpayers will
receive credit for withheld tax, they will have a positive,
incentive to supply payors with better information. Likewise,
taxpayers will be less likely to lose or forget about their
dividend and interest reports if these reports must be
attached to the return in order to claim the credit.
Information reporting alone provides no such incentives.
The Internal Revenue Service estimates that more than 11
percent of information returns required to be filed by
payors (Form 1099’s) have inaccurate or missing Social
Security numbers (taxpayer identification numbers), making
accurate matching of documents in such cases extraordinarily
expensive. By comparison, the rate of error on information
returns for wages (Form W-2), where the taxpayer is entitled
to a credit for the taxes paid, is estimated to be about 3
percent.
Experience with wage withholding has proven that with
holding is the most effective means of ensuring compliance
in the reporting of income. Wage-earners now pay their
taxes on a regular basis through withholding. Information
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
5
reporting and the system of estimated tax payments simply
have not been as effective. There is no reason why recipients
of dividends and interest should not be held to the same
standards of withholding and compliance that are set for
wage-earners.
Summary of the proposal
Under the President’s proposal, 15 percent will be
withheld on taxable dividends and interest paid to indivi
duals with respect to deposits and securities of a type
generally offered to the public. Most dividend and interest
income is currently subject to information reporting; the
proposal builds primarily upon the system that is now in
place. The proposal also will extend withholding to instruments
with respect to which reporting is not currently required,
including obligations of the U.S. government, such as Treasury
bills, as well as corporate coupon bonds and government
agency issues.
Payments to corporations (including corporate nominees
and corporate trustees) and noncorporate securities dealers
will be exempt from withholding. This exemption simplifies
the withholding system administratively. Moreover, there
are other safeguards to prevent noncompliance by these
entities, such as normally higher audit coverage by the
Internal Revenue Service. Exempt recipients will include
banks and thrift institutions, regulated investment companies,
collective investment funds managed by banks, money market
funds and the like. All of these entities will, however, be
required to withhold upon the payment of dividends or
interest to their non-exempt customers, shareholders, or
certificate holders.
Exempt organizations and individuals who reasonably
believe they will owe no tax will not be subject to with
holding if they file exemption certificates with the with
holding agent. Furthermore, the proposal will be designed
to minimize overwithholding and the period during which a
taxpayer is owed a refund.
Under the proposal, it is estimated that tax collections
for calendar year 1981 will increase by $2.1 billion and $2.3
and $2.6 billion in 1982 and 1983, respectively.
A detailed description of the proposal will be provided
in a separate technical explanation.
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
6
This proposal is different from
the 1962 proposal.
The President’s proposal meets the objections that were
raised to the proposal offered in 1962.
Although any withholding system will have complexities,
the present proposal has been designed with simplicity and
administrative ease in mind. Much of the complexity of the
1962 proposal stemmed from the level at which withholding
was made. The present proposal designates as the withholding
agent the entity that has the best information to determine
the status of the recipient of the investment income. This
approach, although more decentralized, makes exemptions
easier to administer and more closely parallels the wage
withholding system.
Since 1962, the computer age has advanced us far along
the road to solving administrative problems. As with the
current information reporting system, taxpayers will receive
reports showing the amount of investment income payable to
them and the amount of tax withheld. They will not have to
determine for themselves, as they would have in 1962, whether
the amount of dividends and interest received was net of
withholding or not.
Perhaps, in retrospect, installing a reporting system,
was the expedient approach in 1962. But in 1980, withholding
is feasible and practical -- as well as useful in the
effort to balance the budget.
Criticisms of the proposal
Despite the advantages of withholding, the proposal has
been subject to some criticism. I would like to comment
briefly on the main objections that have been raised.
Cost to withholding agents
One objection is that withholding agents will incur
additional administrative costs. Eighty-seven percent of
the interest and dividends covered by the proposal is already
subject to information reporting. For these, withholding
agents need only add the amount of withheld tax to the
reporting statement, remit the withheld tax to the Internal
Revenue Service, and adjust the payments to the payee
accordingly. Although withholding will be extended to
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
7
instruments for which there is now no reporting, most of
» them are bearer securities held by corporations, and corporate
recipients are exempt under the proposal.
Naturally there will be some start-up costs associated
with adding withholding -- there are always costs when an
existing system is modified. But with a reporting system
largely in place, we do not anticipate high continuing costs
of the system to withholding agents.
The principal new cost will result from the exemption
system. In recognition of this, exemption certificates will
be permanent until they are revoked.
Overall, however, withholding is a far better way to
collect taxes than is an increase in the number of audits,
record checks, and collection attempts by the Internal
Revenue Service. All taxpayers would bear the cost of
increased audit coverage through the higher taxes needed to
pay for the personnel and equipment necessary to conduct
thorough examinations of more returns. Perhaps more impor
tantly, taxpayers would suffer the loss of privacy from more
frequent audits, record checks and requests for detailed
information. The success of the wage withholding system
indicates that taxpayers prefer withholding as a way to pay
their taxes.
Overwithholding
Some are worried that low-income taxpayers, particularly
certain senior citizens who depend on interest and dividend
income, will be overwithheld. The proposal will exempt
individuals if they reasonably expect that they will owe no
tax. This means that 70 percent of the senior population
will be entirely exempt.
To deal with other problems of overwithholding and to
contain the costs of instituting the withholding system within
reasonable bounds, the Secretary will be given authority to
provide additional individual exemptions by regulation. For
example, the regulations could provide an exemption for married
couples filing jointly who are at least age 65 and for whom,
in both the prior year and the current year, interest and
dividend income does not exceed a stated amount, such as
$15,000, and total tax liability does not exceed 10 percent
of their investment income.
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
a -
Other individuals who incur tax liability will be able
to reduce their estimated tax payments to take account of
the tax withheld on their interest and dividends, including
interest and dividends that are eligible for the exclusion
provided by the Crude Oil Windfall Profit Tax Act. Wage-
earners will be able to adjust for tax withheld on interest
and dividends that are eligible for the exclusion by reducing
the amount of tax withheld from their wages.
Depositary institutions will be permitted to withhold
once at the end of the year on passbook accounts so that a
taxpayer may apply for a refund shortly after the tax is
withheld.
Impact on savings
Withholding does not change savings incentives for
individuals who now comply with the tax laws. Any argument
that the tax system should encourage people to save by
offering them opportunities to underreport their income must
be rejected out-of-hand. Savings incentives in the form of
opportunities for evasion promote inequity, undermine the
integrity of the tax system, and are a grossly inefficient
means of encouraging savings.
Some argue that the proposal will discourage savings by
reducing the yield on savings. This argument confuses a
change in the method of paying taxes, such as through with
holding, with a change in the overall level of taxation.
If taxes are withheld, the amount withheld becomes a credit
that taxpayers can claim against their final tax liability.
Taxpayers may then adjust their estimated tax payments or
simply reduce the balance due at the time that they file
their returns.
Even if a taxpayer decides to make no adjustment during
the year, he or she will only lose interest on the amount
of tax that would not have been paid as early in the year if
there were no withholding. Since the withheld tax on interest
paid on a typical savings account averages less than one
percent of asset value over the course of the year, at worst
the "loss" of interest on the withheld tax would be less
than one-tenth of one percent of asset value. Moreover,
most of this loss will be avoided if withholding on passbook-
type accounts occurs only at year end, rather than quarterly.
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Federal Reserve Bank of St. Louis
9
Thus, the argument that savings will be adversely
affected by this proposal is grossly overstated. Inflationary
expectations and restricted yields on passbook savings have
been the principal savings disincentives in recent years.
Congress, with the full support of the Administration, has
already acted to lift interest ceilings through the phase
out of Regulation Q. Current economic problems should not
lead us to advocate lower compliance with the tax laws as a
policy for increasing savings.
Conclusion
Withholding on wages proves that withholding is the
most economical way to achieve high levels of compliance in
the payment of taxes. The Administration’s proposal for
withholding on interest and dividends will impose minimal
burdens on withholding agents. It will also protect individuals
with little or no tax liability.
Congress and the Administration have at all times a
joint responsibility to make certain that the Federal govern
ment collects all taxes due it. In this period of fiscal
austerity, we can ill afford the needless loss of billions
of dollars in taxes that are not being paid on interest and
dividends. Withholding on investment income is the most
sensible and effective answer to this major compliance
problem.
o 0 o
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
Department of theJREfl$URY |
WASHINGTON, O.C. 20220 TELEPHONE 566-2041
embargoed for release until delivery
Expected at 9:30 a.m.
STATEMENT OF
THE HONORABLE
G. WILLIAM MILLER
SECRETARY OF THE TREASURY
BEFORE THE
COMMITTEE ON WAYS AND MEANS
U.S. HOUSE OF REPRESENTATIVES
APRIL 30, 1980
Mr. Chairman and Members of the Committee:
I am pleased to be here today to discuss the President's
proposal for withholding on interest and dividends.
Underreporting of interest and dividend income is no
longer a problem that we can afford to ignore. In 1979
taxpayers underreported interest and dividend income by
about $16 billion and thereby underpaid their taxes by
approximately $3.6 billion. Other taxpayers bear the cost
of these lost revenues by paying a larger share of the tax
burden.
Balancing the budget is a national priority in the
fight against inflation. As we ask the American people to
accept fiscal discipline, with cuts in spending for important
economic and social programs, we must at the same time*take
positive action to avoid needless loss to the Treasury of
billions of dollars due under present tax laws.
Withholding is not a new tax.
To combat this needless loss to the Treasury, the
President has proposed a system of withholding on interest
and dividends similar to the current system of withholding
on the wages of our nation's workforce, a system that has
served us well since 1943. Withholding benefits not only
M-459
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
2
the government, but also benefits taxpayers by providing
them with a gradual and systematic way to pay their taxes.
Let me emphasize that withholding is not a new tax. As
with wage withholding, withholding on interest and dividends
does not increase anyone's tax liability; it only changes
the method by which the taxes are paid. The purposes of the
withholding program are simple — to collect taxes due on
interest and dividend income and to ensure that all tax
payers report the full amount of their income and pay their
fair share of taxes.
It has been strongly argued in recent years that the
tax system relies too heavily on taxing savings and invest
ment. This issue is being examined closely. But it cannot
plausibly be argued that the way to lighten the tax burden
on savings is to facilitate noncompliance with current tax
laws.
Compliance is a current problem.
Overall our system of income taxation works very
smoothly. It is administered with honesty and integrity and
with very low administrative and enforcement costs.
Nevertheless, a recent Internal Revenue Service report
on income unreported by individuals clearly indicates that
substantial numbers of individuals do not pay the full
amount of tax that they owe because they fail to report the
full amount of their investment income. The report presents
the findings of a year-long study by an Internal Revenue
Service task force appointed by the Commissioner to review
all available data for the purpose of developing the best
possible estimates of unreported income. The report determined
that the 1976 gap between taxable interest payments received
by individual taxpayers and taxable interest payments reported
on individual income tax returns ranges from $5.4 billion to
$9.4 billion. The 1976 gap between taxable dividend payments
received by individuals and those reported on tax returns is
estimated to range from $2.1 billion to $4.7 billion. While
individuals are estimated to underreport wage income by only
2 to 3 percent, they omit 9 to 16 percent of interest and
dividend income, a rate of noncompliance that is at least
300 percent greater.
As a result of continued substantial noncompliance in
the reporting of investment income, about $3.6 billion in
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
3
taxes that were lawfully due were not collected in 1979. It
is estimated that in calendar year 1981 this tax loss will
increase to approximately $3.9 billion.
Underreporting of investment income jeopardizes the
very cornerstone of our tax system -- self-assessment. The
Internal Revenue Service now audits only about 2 percent of
individual returns filed each year. Withholding provides a
logical means to attain high compliance with low audit
coverage.
Information reporting alone is not enough.
Some have suggested that the existing system of informa
tion reporting — or an expanded system — would solve the
reporting problem if only the Internal Revenue Service would
do its job. In 1962 the Senate rejected the withholding
approach adopted by the House on the ground that improved
compliance should first be sought by expanding the infor
mation reporting requirements. This has been done.
The intervening eighteen years have provided an ample
test of information reporting alone as a compliance measure.
The results of the recent Internal Revenue Service report on
unreported income clearly indicate that, even with the
additional reporting requirements enacted in the Revenue Act
of 1962, taxpayers still fail to report and pay tax on
significant amounts of taxable dividends and interest for
which information reports are filed. Certainly the time has
come to reassess how tax should be collected on interest and
dividend income and why information reporting alone is not
sufficient.
The Internal Revenue Service now matches at least 72
percent of the information documents that it receives on
interest and dividends and uncovers several million discrepancies
Much of the nonreporting is apparently due to inadvertence,
forgetfulness and failure to keep records, particularly by
taxpayers who receive relatively small amounts of dividend
and interest income. Other nonreporting is due to nonfilers
who owe some tax but who are difficult to trace. Because of
the small amount of revenue to be gained from any one taxpayer,
the cost of following up the millions of discrepancies is
demonstrably uneconomical. Even extensive pursuit of tax
payers would not achieve full collection of unpaid taxes.
There would be many unfruitful investigations where taxpayers
cannot be reached by telephone or traced if they have moved.
Even after the taxes have been assessed, it would be impossible
or uneconomical to collect them.
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
4
The present situation, then, is that the Internal
Revenue Service uncovers many more leads through its matching
program than it pays to pursue. To follow up on all of
these leads would require millions of telephone calls,
letters and visits, and audit efforts concentrated on
individuals. This would inevitably be regarded as harass
ment of "little people" and would require shifts in staffing
that would prevent the Service from directing its limited
resources towards auditing compliance areas that are not
susceptible to withholding.
Withholding is now necessary.
How will withholding help? A substantial portion of
the taxes that now go unpaid will be collected without
costly audit procedures. Mot only will withholding auto
matically collect much of the tax owed, but people will have
more incentive to pay the remainder of their taxes due if
part of their taxes have already been paid. The Service
will be able to channel its audit resources to those areas
where they are most needed and that best serve the public
the complicated returns of corporations, partnerships and
sophisticated high-bracket individuals.
The Administration expects that withholding will also
increase the accuracy of information being submitted to the
Internal Revenue Service, thereby reducing the cost of
reconciling discrepancies on returns. Since taxpayers will
receive credit for withheld tax, they will have a positive,
incentive to supply payors with better information. Likewise,
taxpayers will be less likely to lose or forget about their
dividend and interest reports if these reports must be
attached to the return in order to claim the credit.
Information reporting alone provides no such incentives.
The Internal Revenue Service estimates that more than 11
percent of information returns required to be filed by
payors (Form 1099’s) have inaccurate or missing Social
Security numbers (taxpayer identification numbers), making
accurate matching of documents in such cases extraordinarily
expensive. By comparison, the rate of error on information
returns for wages (Form W-2), where the taxpayer is entitled
to a credit for the taxes paid, is estimated to be about 3
percent.
Experience with wage withholding has proven that with
holding is the most effective means of ensuring compliance
in the reporting of income. Wage-earners now pay their
taxes on a regular basis through withholding. Information
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
5
reporting and the system of estimated tax payments simply
have not been as effective. There is no reason why recipients
of dividends and interest should not be held to the same
standards of withholding and compliance that are set for
wage-earners.
Summary of the proposal
Under the President's proposal, 15 percent will be
withheld on taxable dividends and interest paid to indivi
duals with respect to deposits and securities of a type
generally offered to the public. Most dividend and interest
income is currently subject to information reporting; the
proposal builds primarily upon the system that is now in
place. The proposal also will extend withholding to instruments
with respect to which reporting is not currently required,
including obligations of the U.S. government, such as Treasury
bills, as well as corporate coupon bonds and government
agency issues.
Payments to corporations (including corporate nominees
and corporate trustees) and noncorporate securities dealers
will be exempt from withholding. This exemption simplifies
the withholding system administratively. Moreover, there
are other safeguards to prevent noncompliance by these
entities, such as normally higher audit coverage by the
Internal Revenue Service. Exempt recipients will include
banks and thrift institutions, regulated investment companies,
collective investment funds managed by banks, money market
funds and the like. All of these entities will, however, be
required to withhold upon the payment of dividends or
interest to their non-exempt customers, shareholders, or
certificate holders.
Exempt organizations and individuals who reasonably
believe they will owe no tax will not be subject to with
holding if they file exemption certificates with the with
holding agent. Furthermore, the proposal will be designed
to minimize overwithholding and the period during which a
taxpayer is owed a refund.
Under the proposal, it is estimated that tax collections
for calendar year 1981 will increase by $2.1 billion and $2.3
and $2.6 billion in 1982 and 1983, respectively.
A detailed description of the proposal will be provided
in a separate technical explanation.
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
6
This proposal is different from
the 1962 proposal.
The President’s proposal meets the objections that were
raised to the proposal offered in 1962.
Although any withholding system will have complexities,
the present proposal has been designed with simplicity and
administrative ease in mind. Wuch of the complexity of the
1962 proposal stemmed from the level at which withholding
was made. The present proposal designates as the withholding
agent the entity that has the best information to determine
the status of the recipient of the investment income. This
approach, although more decentralized, makes exemptions
easier to administer and more closely parallels the wage
withholding system.
Since 1962, the computer age has advanced us far along
the road to solving administrative problems. As with the
current information reporting system, taxpayers will receive
reports showing the amount of investment income payable to
them and the amount of tax withheld. They will not have to
determine for themselves, as they would have in 1962, whether
the amount of dividends and interest received was net of
withholding or not.
Perhaps, in retrospect, installing a reporting system
was the expedient approach in 1962. But in 1980, withholding
is feasible and practical -- as well as useful in the
effort to balance the budget.
Criticisms of the proposal
Despite the advantages of withholding, the proposal has
been subject to some criticism. I would like to comment
briefly on the main objections that have been raised.
Cost to withholding agents
One objection is that withholding agents will incur
additional administrative costs. Eighty-seven percent of
the interest and dividends covered by the proposal is already
subject to information reporting. For these, withholding
agents need only add the amount of withheld tax to the
reporting statement, remit the withheld tax to the Internal
Revenue Service, and adjust the payments to the payee
accordingly. Although withholding will be extended to
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
7
instruments for which there is now no reporting, most of
them are bearer securities held by corporations, and corporate
recipients are exempt under the proposal.
Naturally there will be some start-up costs associated
with adding withholding — there are always costs when an
existing system is modified. But with a reporting system
largely in place, we do not anticipate high continuing costs
of the system to withholding agents.
The principal new cost will result from the exemption
system. In recognition of this, exemption certificates will
be permanent until they are revoked.
Overall, however, withholding is a far better way to
collect taxes than is an increase in the number of audits,
record checks, and collection attempts by the Internal
Revenue Service. All taxpayers would bear the cost of
increased audit coverage through the higher taxes needed to
pay for the personnel and equipment necessary to conduct
thorough examinations of more returns. Perhaps more impor
tantly, taxpayers would suffer the loss of privacy from more
frequent audits, record checks and requests for detailed
information. The success of the wage withholding system
indicates that taxpayers prefer withholding as a way to pay
their taxes.
Overwithholding
Some are worried that low-income taxpayers, particularly
certain senior citizens who depend on interest and dividend
income, will be overwithheld. The proposal will exempt
individuals if they reasonably expect that they will owe no
tax. This means that 70 percent of the senior population
will be entirely exempt.
To deal with other problems of overwithholding and to
contain the costs of instituting the withholding system within
reasonable bounds, the Secretary will be given authority to
provide additional individual exemptions by regulation. For
example, the regulations could provide an exemption for married
couples filing jointly who are at least age 65 and for whom,
in both the prior year and the current year, interest and
dividend income does not exceed a stated amount, such as
$15,000, and total tax liability does not exceed 10 percent
of their investment income.
Digitized for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
8
Other individuals who incur tax liability will be able
to reduce their estimated tax payments to take account of 7
the tax withheld on their interest and dividends, including
interest and dividends that are eligible for the exclusion
provided by the Crude Oil Windfall Profit Tax Act. Wage-
earners will be able to adjust for tax withheld on interest
and dividends that are eligible for the exclusion by reducing
the amount of tax withheld from their wages.
Depositary institutions will be permitted to withhold
once at the end of the year on passbook accounts so that a
taxpayer may apply for a refund shortly after the tax is
withheld.
Impact on savings
Withholding does not change savings incentives for
individuals who now comply with the tax laws. Any argument
that the tax system should encourage people to save by
offering them opportunities to underreport their income must
be rejected out—of-hand. Savings incentives in the form of
opportunities for evasion promote inequity, undermine the
integritv of the tax system, and are a grossly inefficient
means of encouraging savings.
Some argue that the proposal will discourage savings by
reducing the yield on savings. This argument confuses a
change in the method of paying taxes, such as through with
holding, with a change in the overall level of taxation.
If taxes are withheld, the amount withheld becomes a credit
that taxpayers can claim against their final tax liability,
taxpayers may then adjust their estimated tax payments or
simply reduce the balance due at the time that they file
their returns.
Even if a taxpayer decides to make no adjustment during
the year, he or she will only lose interest on the amount
of tax that would not have been paid as early in the year if
there were no withholding. Since the withheld tax on interest
paid on a typical savings account averages less than one
percent of asset value over the course of the year, at worst
the "loss" of interest on the withheld tax would be less
than one-tenth of one percent of asset value. Moreover,
most of this loss will be avoided if withholding on passbook-
type accounts occurs only at year end, rather than quarterly.
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9
Thus, the argument that savings will be adversely
affected by this proposal is grossly overstated. Inflationary
expectations and restricted yields on passbook, savings have
been the principal savings disincentives in recent years.
Congress, with the full support of the Administration, has
already acted to lift interest ceilings through the phase
out of Regulation Q. Current economic problems should not
lead us to advocate lower compliance with the tax laws as a
policy for increasing savings.
Conclusion
Withholding on wages proves that withholding is the
most economical way to achieve high levels of compliance in
the payment of taxes. The Administration’s proposal for
withholding on interest and dividends will impose minimal
burdens on withholding agents. It will also protect individuals
with little or no tax liability.
Congress and the Administration have at all times a
joint responsibility to make certain that the Federal govern
ment collects all taxes due it. In this period of fiscal
austerity, we can ill afford the needless loss of billions
°f dollars in taxes that are not being paid on interest and
dividends. Withholding on investment income is the most
sensible and effective answer to this major compliance
problem.
o 0 o
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Cite this document
APA
G. William Miller (1980, April 29). Speech. Speeches, Federal Reserve. https://whenthefedspeaks.com/doc/speech_19800430_miller
BibTeX
@misc{wtfs_speech_19800430_miller,
author = {G. William Miller},
title = {Speech},
year = {1980},
month = {Apr},
howpublished = {Speeches, Federal Reserve},
url = {https://whenthefedspeaks.com/doc/speech_19800430_miller},
note = {Retrieved via When the Fed Speaks corpus}
}