Will the US ever tax churches?

How injustice triumphed

More and more people are of the opinion that the economy in developed countries does not work for the benefit of the working class and, in some cases, for the benefit of the middle class as well. Nowhere is this view held so vehemently, and for good reasons, as in the United States - where working class incomes have stagnated since 1980, where life expectancy has fallen, where the ultra-rich pay less taxes than teachers and ordinary employees, and where the young Adults start their working lives with enormous debts.

But how did the government of a country that had for decades taxed high incomes at 90 percent the idea in the mid-1980s that 28 percent would be better instead? How did it come about that Ronald Reagan was able to put the Tax Reform Act into effect on October 22, 1986 with his signature, with which the USA, which for years had pioneered the quasi-confiscatory taxation of high incomes, immediately set the lowest top tax rate in the industrialized world would? And how did it come about that after three weeks of plenary debate, the Senate passed the bill with 97 votes to 3? Because the Democrats Ted Kennedy, Al Gore, John Kerry and Joe Biden all enthusiastically voted yes at the time.

The law was by no means particularly popular with the population. But it is difficult to exaggerate the enthusiasm it met with among the country's political and intellectual elites. For them it represented the triumph of reason - the victory of the common good over self-interest and the beginning of a new era of growth and prosperity. Meanwhile, however, the law is widely recognized as a major cause of the explosion in inequality. And yet those who were involved in its creation fondly think back to that moment to this day. For the partisans among economists at American universities, it is a professional obligation to point out the merits of the law. This fundamental U-turn in 1986 reflects in part the dramatic changes in politics and ideology that contributed to Reagan's election victory six years earlier - and which, to a large extent, continue to this day. By reactivating pre-Civil War anti-tax rhetoric and giving it a modern claim, the Republican Party had forged an alliance of high-income voters across the country and white southerners. The ideas of a lean state, embodied by the Mont Pèlerin Society since its inception in 1947, embodied in 1964 by presidential candidate Barry Goldwater and further disseminated in the 1970s through a network of conservative foundations, had found their way into the mainstream and became to the politically prevailing ideas.

The government protects property

According to this ideology, the primary task of governments is to protect property rights. The most important growth engine is the profit-maximizing companies that try to minimize their tax burden. According to this worldview, “there is no such thing as society. There are just individual men and women, ”said Reagan's most important colleague, British Prime Minister Margret Thatcher. [1] For the atomized individual, paying taxes means suffering a total loss equivalent to legalized robbery.

Indeed, during his address on the White House lawn, Reagan denounced a tax system that had become "un-American". His “steeply progressive character” has “hit the economic life of the individual in its core”. The new law, however, is "the best job creation program that has ever emerged from the United States Congress". [2]

But because of that alone, Reagan's tax reform would probably not have gotten through the Democratic-controlled Congress - let alone passed by such an overwhelming majority in the Senate. There was something else behind their triumphant advance. According to both Reagan and the Democrats, who welcomed the bill, the legislature had no choice. The income tax was a mess, the abuse had reached immense proportions. In this situation, the government allegedly had only one option: to cut tax rates while closing loopholes to make up for lower revenues. The Tax Reform Act of 1986 exemplifies how a system of progressive taxation dies. It does not perish democratically, it is not dismantled by the will of the electorate, but is deliberately destroyed. If you look at most of the largest withdrawals of progressive taxation, you will always come across a certain pattern: First, tax avoidance increases massively. Then comes the complaint from governments that taxing the rich has become impossible. Their tax rates are then reduced.

Understanding this spiral - how does tax avoidance come about? And why don't the governments stop it? - is crucial to understand the past history of taxes and to create a more tax-friendly future.

The price for a civilized society

In the simplistic world of economists, tax enforcement is a simple matter: To make sure people pay, all you have to do is threaten regular tax audits, punish tax evaders and establish a straightforward tax system with no loopholes. These things are undoubtedly important and necessary. If tax evaders are more likely to be discovered and face heavy fines, fewer people will cheat. If, on the other hand, tax legislation has numerous exceptions for special interests, then more and more people will try to bypass the tax authorities.

In the real world, however, it takes more than straightforward laws and conscientious auditors to make taxation work. What is needed is a system of shared beliefs: that collective action has merit (the notion that we are more prosperous if we pool our resources rather than act in isolation); that the state has a central role in organizing this collective action; and that democracy is valuable. When these beliefs dominate, even the most progressive tax system can survive. But if they don't prevail, the unleashed and legitimized forces of tax avoidance will bring even the most sophisticated tax authorities to their knees and undermine the best tax laws.

This story - first acceptance and finally abandonment of belief in collective action - is that of what is probably the most progressive tax system in world history, a legacy of the New Deal. It successfully taxed the rich for 30 years - not just on paper, but in fact. The 80 to 90 percent top income tax rates that applied from the 1930s to the 1970s deliberately affected only a few people. But when you add all taxes together, the effective tax rates for the very wealthy exceeded 50 percent. Tax evasion was under control.

In the 1930s, Franklin D. Roosevelt first developed the tax enforcement strategy that would keep tax evasion and avoidance in check for decades to come. He provided the IRS with the legal powers and financial resources necessary to enforce the spirit of tax legislation. More importantly, he took the time to explain to people why taxes were important. He appealed to morality and gave tax evaders the cold shoulder: “Judge Holmes [3] said, 'Taxes are what we pay for a civilized society' [those words above the entrance to the Internal Revenue Service headquarters in Washington , DC, emblazoned]. Too many, however, want civilization at a special price. ”This is how Roosevelt put it in his address to Congress on June 1, 1937: Civilization depended on the containment of tax evasion. And until the 1970s, social norms like these actually limited taxpayers' demand for dubious tricks and twists. Laws and regulations that made these standards explicit prevented most US citizens from exploiting loopholes in federal tax law.

The New Deal tax system was not perfect. The main weakness was that profits from private sales were taxed less than other types of income from the 1930s through 1986. Profits from private sales are always there when an asset - such as company shares - is sold more expensive than it was acquired. The resulting profit is added to taxable income in the USA, but tax-privileged. When the peak income tax rate exceeded 90 percent, profits from private sales were taxed at just 25 percent. [4] One can argue about the advantages and disadvantages of reduced tax rates on these profits. An obvious shortcoming of such a policy, however, is that it encourages the wealthy to generate income in the form of profits from private sales rather than dividends or labor income. It opens up opportunities for tax avoidance.

Given the high top tax rates in the post-war decades, it is of course reasonable to assume that tax avoidance got out of hand. The rich will certainly not have resisted the temptation to transform their highly taxed labor incomes and dividends into less taxed profits from private sales for tax reasons.

But let's look at the data: Since 1986, profits from private sales have accounted for 4.1 percent of the average national income annually. From 1930 to 1985, when the top tax rates for these profits were significantly lower than those for regular income - and therefore the incentives to redeclare regular income as profits from private sales transactions were much greater - the corresponding value was 2.2 percent. Despite massive tax breaks, profits from private sales were low in the decades after the war. Some wealthy taxpayers are sure to have reclassified their regular income into profits from private sales by then, but they did not do so on a large scale.

Why not? Because the governments wouldn't allow it. There are not an infinite number of ways that regular incomes can look like profits from private sales. The main strategy was share buybacks. When companies buy back shares in themselves, like the distribution of dividends, the effect is that cash from the companies flows into the pockets of the shareholders. The main difference between the two types of payouts is their tax implications: share buybacks generate profits from private sales transactions for the shareholders who sell their shares to companies. Before 1982, share buybacks were illegal. The social norm, as it had taken shape in law, was that companies should pay out profits to their owners in the form of dividends. And dividends were subject to progressive income taxation. [5]

The strategy of tax avoidance

Another way the wealthy could avoid taxes was to get income from their employers in the form of tax-free benefits in kind: corporate jets, luxurious offices, lavish dining, corporate "seminars" on Cape Cod or Aspen, and so on. These things are harder to quantify than profits from private sales. However, there is no evidence in contemporary reports of executive lifestyles in the 1940s, 1950s, and 1960s that such benefits in kind were particularly frequent or extensive. The economist Challis Hall studied executive pay shortly after World War II. He came to the conclusion that "expenditures that actually reduce the cost of executives and represent additional income are only covered to a negligible extent by large companies". [6] Well, today CEOs don't necessarily dine sparingly. They are also not particularly reluctant to use their own company jets. But until the 1980s, wasting corporate money was simply not a socially acceptable behavior for managers.

Tricks and tricks for tax avoidance came up regularly, but were quickly banned. In 1935, the Revenue Act raised the top income tax rate to 79 percent, the highest rate ever. After this law was passed, the rich looked for ways to avoid their new taxes. Following his speech to Congress in 1937, Roosevelt sent Parliament a letter from then Treasury Secretary Henry Morgenthau Jr. listing eight tax avoidance tools that had spread and should be banned immediately. The first of these was "the tax evasion method by setting up foreign personal holding companies in the Bahamas, Panama, Newfoundland, and other places where taxes are low and corporate law is lax". [7] By 1936, wealthy Americans had set up dozens of offshore mailbox companies to give ownership of their stock and bond portfolios. These letterbox companies then collected dividends and interest in lieu of their actual owners, thereby avoiding taxation in the United States. The government responded quickly with a change in the law expressly forbidding this practice. From 1937 onwards, all income generated by foreign holdings under the control of Americans became immediately taxable in the United States. Owning foreign holding companies for reasons of tax avoidance suddenly became pointless.

Similarly, by the 1960s, growing numbers of wealthy US citizens had used the law for their own benefit by making tax-deductible charitable donations to private foundations they controlled. However, these donations were not “charitable”: the foundations gave their founders, their families or friends their financial donations or gave politically motivated gifts. The Tax Reform Act of 1969 cracked down on such abusive practices and achieved immediate results: within just a few years, namely from 1968 to 1970, the number of newly established private foundations collapsed by 80 percent. As a result of this reform, the "charitable" donations by the rich fell permanently by 30 percent. [8]

Roosevelt's strategy worked as long as succeeding governments maintained the New Deal-era belief system. That changed in the early 1980s. "The government is not the solution to our problem, the government is the problem," said Reagan's famous saying in his inaugural address in January 1981. [9] If some are tempted to avoid the tax, they cannot be blamed, because the tax rates were high and therefore “un-American”. In the new ideology that took the United States by storm in the early 1980s, tax evasion became a patriotic and, since the revived libertarian creed that “taxation is robbery”, it also became a moral duty. By the 1970s, governments had fought the tax avoidance industry. After Reagan moved into the White House in 1981, she was able to act with state blessings. The madness with the tax-saving models could begin.

"Insanity" doesn't even begin to capture the extent of what happened. The industry saw explosive growth. A whole network of financial entrepreneurs, promoters and consultants stormed the market. Some providers asked their employees to have one new idea per week. [10] They were overflowing with creativity and pioneering tax evasion practices. For every particularly blatant procedure that was prohibited by the IRS, several new ones were created.Wall Street Journal " and advertised in the financial sections of leading newspapers like toothpaste. The magic of the market economy was completely unleashed; the competition caused the prices for such tax savings plans to tumble. And as with any other product in a market economy, its invention enriched both its manufacturers and consumers: financiers, promoters and consultants took in commissions, and tax evaders increased their net profits.In this way, large amounts of additional income were created, as economists call these profits. With a little catch, however, because this additional income was achieved dollar for dollar at the expense of the rest of society.

The big bang of tax avoidance

The iconic product of the Reagan era - the iPod of tax avoidance, if you will - was created as a tax-saver (tax shelter) known. It worked like this: Income tax allows taxpayers to offset business losses against any type of income. The tax avoidance industry therefore began to sell investments in companies whose only asset was that they were making losses. These companies were not regular companies but partnerships and as such were not subject to corporation tax. In a partnership, profits are shared between the investors (partners) each year and their own income is added to (or deducted in the event of a loss) and is subject to personal income tax. Whoever invested in these loss-making partnerships could claim a share of the loss. For example, a high-earning employee could take a 10 percent stake in a partnership that lost $ 1 million and deduct $ 100,000 from his earnings and cut his income tax accordingly. The same was true of a wealthy individual who got their income from interest or dividends.

Some of these partnerships were bogus companies with no economic activity. Their very existence consisted in recording fictitious book losses that could be carried over into their owners' tax returns. Others were real businesses that were actually profitable but generated tax losses due to certain clauses in tax law, such as generous depreciation rules for the oil, gas, and real estate sectors. The first tax law of the Reagan era, the Economic Recovery Tax Act of 1981, allowed companies to write off their assets more quickly, which greatly increased the effectiveness of this type of tax hedge.

While the tax-saving industry began a few years before Reagan took office, it didn't really boom until the early 1980s. Let's take a look at the numbers: In 1978, the sum of losses from partnerships reported on personal income tax returns was four percent of total pre-tax income, the top one percent. It rose slowly at first, then exponentially, and in 1986 it was the equivalent of twelve percent of the income of the top one percent - the highest level ever recorded in US income tax history. From 1982 to 1986, the notional losses reported by investors in tax-saving schemes exceeded the total profits generated by genuine partnerships across the country. [11] Yes, it is: the total of net income from partnerships reported on tax returns - profits minus losses - was negative, a truly unique phenomenon. It wasn't even during the Great Depression. 1982 was a year of recession, but from 1983 to 1986 the economy recovered and grew rapidly. Tax saving, on the other hand, had reached such enormous proportions that entire industries, from real estate to oil, were apparently making losses - book losses tax-deductible from the personal income of their owners.

The consequence: income from income tax collapsed. By the mid-1980s, federal income tax revenues - both personal and corporate - as a percentage of national income had reached their lowest level since the 1949 recession, one of the sharpest declines in modern US history. The US budget deficit rose to over five percent of national income between 1982 and 1986, the highest level since World War II.

This explosive increase in tax evasion ultimately strengthened Reagan's position in the 1986 Tax Reform Act negotiations. At that point, the deficit was so great that the Democrats insisted that changes to the bill should not add further burden to the budget. Reagan complied with the demand: tax rates were lowered, but because tax-saving models were banned at the same time, no further losses should arise. Gone were the days when a fictitious book loss of $ 100,000 could make real income of $ 100,000 disappear. From this point on, corporate losses could only be offset against corporate profits.

Given the magnitude of tax savings in the mid-1980s, plugging this loophole promised billions in revenue. And it actually worked. After the law came into force, the partnerships magically stopped making losses. The total loss from partnerships, which the top one percent recorded, fell from twelve percent of their pre-tax income to five percent in 1989 and three percent in 1992. By the early 1990s, tax cuts had disappeared.

Tax avoidance versus tax evasion - a misguided discussion

Markets are the most powerful institution ever invented for satisfying the myriad of human desires and the most efficient method of providing diverse products that respond to the changing needs of billions of individuals. But intrinsically they are completely free from any concern for the common good. The same markets that give us ever faster mobile phones and better tasting breakfast cereals can, without blinking an eye, also provide services with no or negative societal value - services that enrich one part of society and another, or even all of us collectively get poorer. The tax avoidance market is an example of this. It doesn't make a single dollar in value. He makes the rich richer at the expense of the state - and that means at the expense of all of us. Behind every tax avoidance epidemic is not a sudden aversion to being taxed in the population, but a creative surge in the market for tax tricks.

Of course, not all of the services that tax lawyers and tax advisory firms provide are worthless from a societal point of view. Some help individuals and businesses understand tax law, clear up any ambiguities, or, even easier, fill out tax forms on their behalf. These offers are all legitimate. But creating products that serve no other purpose than cutting taxes owed is not very different from selling tools for a break-in. In any case, before 1980 such activities were treated as follows: The tax trick market was considered repulsive; it was not allowed to grow and prosper. No market exists in a vacuum - governments decide which can and cannot exist, or at least which of them are strictly regulated. Tolerating tax avoidance is a decision that governments make. Which leads us to a number of interesting questions. The first question is, if tax avoidance is simply theft, how does the tax avoidance industry legitimize itself?

Only the state that leaves tax loopholes should be to blame

The rhetoric that approves of tax tricks goes back to the dawn of progressive taxation in the United States. In 1933 the "New York Times " publicly that J. P. Morgan - one of the titans of wealth in America - had paid no income tax for 1931 and 1932. The Senate Banking Committee targeted him, whereupon the financier grew increasingly indignant at the shaming of tax frauds by the Democrats and Roosevelt. [12] Their offense in his eyes? Lumping tax evasion and tax avoidance together. Tax evasion was against the law; everyone agreed that she was bad. But tax avoidance broke no law. It just consisted of using loopholes to keep more of your income. As he pointed out, there was no moral obligation to avoid tax loopholes. The government was responsible: if there were loopholes, then the politicians had to plug them. Until then, those who were smart enough to take advantage of them could not be blamed for anything. So it's no surprise that Morgan always insisted that he himself only avoided taxes but never evaded taxes.

This justification still underpins the defenses of the tax avoidance industry today. But it was wrong when J. P. Morgan used it, and it still is. Why?

Because US-American law - like that of most other countries - contains a series of regulations which are known as the "Economic Substance Doctrine" and declare illegal any transaction that has no other purpose than to reduce tax liability. Everyone knows that the tax ploy market will always stay one step ahead of governments because it is impossible to anticipate the myriad of ways in which highly paid and highly motivated tax accountants will attempt to circumvent the law. That is why the Economic Substance Doctrine precautionary declares transactions that do not serve any purpose other than tax avoidance invalid. Invest in bogus partnerships to generate tax-deductible book losses? Setting up mailbox companies in Bermuda with the sole aim of avoiding the tax? Even if such transactions are not expressly prohibited by law, they nevertheless violate the aforementioned principle and are, as such, illegal.

Of course, it can be difficult to determine why individual taxpayers undertake certain transactions. Sometimes actions that clearly look like tax tricks also serve a legitimate economic goal. Governments also use the tax system to encourage certain activities, such as investing in municipal bonds (whose interest payments are tax-free in the United States). Creating such incentives is often bad policy - because it reduces tax revenues for dubious reasons, often under pressure from interest groups - but taking advantage of them is not objectionable. In this respect, J. P. Morgan was right. The only problem is that a large part of the supposedly "perfectly legal" tax tricks, such as the establishment of letterbox companies on small tropical islands, obviously violates the Economic Substance Doctrine and therefore violates the law.

The policy and the limits of tax enforcement

Which brings us to the second fundamental question: if many transactions that reduce tax revenues by billions are in fact illegal, why are they not being problematized in court? What is preventing the state from enforcing the principle of economic substance?

To understand this conundrum we have to start with the fact that it is impossible for the tax authorities to investigate all suspicious transactions. So, first of all, there is a fundamental information problem: it takes time to familiarize yourself with the universe of tricks that are popping up everywhere, and the tax avoidance industry can easily overwhelm the IRS auditing capabilities. In 1980, there were 5,000 cases pending in the US Federal Tax Court; In 1982, when the tax evasion craze picked up speed, this number had tripled to 15,000 cases. [14] In a matter of months, the court had to familiarize itself with and judge the thousands of different tax frauds that had arisen - an impossible task.

There is also a resource problem. The most tax-averse US citizens spend billions of dollars annually on devising their tax optimization strategies, and the amount is growing. The human and monetary resources of the IRS are fewer and even shrinking. This not only makes it more difficult to uncover trickery, but also to investigate, prosecute and ultimately annul illegal transactions. Even if a dubious ploy is identified, well-heeled taxpayers can hire the best lawyers (including ex-politicians) to defend themselves. You can stretch the legal battle for years and massively increase your chances of winning in court.

In an ideal world, the IRS would rely on the forces of self-regulation within the tax planning industry. Tax attorneys and tax advisors would follow high ethical standards and see it as part of their professional duties to enforce the spirit of the law; they would not market tax tricks that run counter to the principle of economic substance. The problem, however, is that these lawyers and consultants are being paid by the sponsors and users of tax tricks and are thus faced with a serious conflict of interests.

The decisive factor is the political will

This problem can be illustrated well with a trade that has evolved since the 1980s. Aggressive tax tricks are sold along with written legal statements that determine their likely legality. These statements serve as a de facto insurance against fraud, which tax evaders use to protect themselves from a possible penalty if the methods they use are judged to be illegal by the IRS. Tax attorneys are bound by ethical guidelines (and their conscience) to make a fair legal assessment. However, in assessing whether a tax trick in a gray area is more likely to be located on the black or white edge, a large part of subjective opinion goes into, and if the monetary reward is large enough, then the temptation to make the "correct" assessment - so the one who clears the dirtiest plan - be overwhelming.

Finally, perhaps most importantly, there may also be a lack of political will to enforce taxes. The clearest case in this context is the gradual death of the estate tax. While income from estate and gift taxes amounted to 0.2 percent of net household wealth in the early 1970s, it has only reached 0.03 to 0.04 percent per year since 2010 - a decrease of more than a factor of five. Part of this reduction is due to the increase in tax exemptions and the lowering of the top tax rate (from 77 percent in 1976 to 40 percent today), but the vast majority is due to a collapse in tax enforcement. In 1975, the IRS audited 65 percent of the 29,000 largest estate tax returns filed the previous year. In 2018, only 8.6 percent of the 34,000 estate tax returns filed in 2017 were checked. [15]

If we relied on the asset information in the declarations of the last few years, we would have to get the impression that either there are virtually no rich people in the USA or that they never die, so comprehensive was the surrender of tax enforcement. If we believe this, then wealth in the United States is more evenly distributed today than in France, Denmark, and Sweden. [16] If a person dies on the "Forbes' list of the 400 richest Americans, the fortune reported as their estate averages only half that of "Forbes " estimated actual assets. [17]

So that society can finally benefit from taxes again

What happened here? Estate tax avoidance has always existed. But governments have approached the problem with varying degrees of enthusiasm, and since the 1980s efforts have been minimal, to put it mildly. Reviled as a "death tax" by opponents, the estate tax is the only federal tax levied on wealth. It is also the most progressive of all federal levies; since its inception, over 90 percent of the population has been exempted from it. [18] As such, it has been one of the main targets of the anti-egalitarian ideology that sacralizes property and that has shaped American politics since the 1980s. It is impossible to understand the success of today's estate tax planning industry - the proliferation of "charitable" trusts, the misuse of haircuts, let alone the well-documented examples of outright (and criminally unprosecuted) fraud [19] - regardless of this political context .

What follows from all of this? Politics determine the priorities of tax enforcement.And the most important of these decisions is whether you want to continue to tolerate transactions that only serve the purpose of reducing your own tax liability - or whether you want to reassert the Economic Substance Doctrine, so that finally the society of economic wealth transactions in the billions again - or millions benefit.

The contribution is based on the third chapter of “The Triumph of Injustice. Taxes and Inequality in the 21st Century ”, the new book by Emmanuel Saez and Gabriel Zucman, which has just been published by Suhrkamp Verlag. Translation from English: Frank Lachmann.

[3] This is Oliver Wendell Holmes Jr., Supreme Court Justice of the United States from 1902 to 1932; Note d. Trans.

[4] Since 1922, when the reduced rates of tax on profits from private sales were introduced, the highest tax rate on long-term such profits has always been below 40 percent. The maximum rate was 25 percent from 1942 to 1964, the era of quasi-confiscatory top rates for income tax.

[5] The economists, blind to this social norm, could not understand why companies paid dividends and called this the "dividend puzzle".

[6] See Challis A. Hall, Effects of Taxation on Executive Compensation and Retirement Plans, Vol. 3, Boston 1951, p. 54.

[7] Joint Committee on Tax Evasion and Avoidance, Report of the Joint Committee on Tax Evasion and Avoidance, p. 1.

[8] See Gabrielle Fack and Camille Landais (eds), Charitable Giving and Tax Policy. A Historical and Comparative Perspective, Oxford 2016, Figs. 4.5 and 4.7.

[10] Ben Wang, Supplying the Tax Shelter Industry. Contingent Fee Compensation for Accountants Spurs Production, in: "Southern California Law Review", 76/2002, pp. 1237-1273, here: p. 1252.

[11] These calculations were made by the authors using publicly available tax data published by the Internal Revenue Service (IRS) income statistics division.

[12] See Joseph J. Thorndike, Historical Perspective. Pecora Hearings Spark Tax Morality, Tax Reform Debate, in: “Tax Notes 101” (November 10, 2003).

[13] David Cay Johnston's book Perfectly Legal. The Covert Campaign to Rig Our Tax System to Benefit the Super Rich - and Cheat Everybody Else (New York 2003) depicts the increase in tax avoidance by the rich since the mid-1970s.

[14] See Dennis J. Ventry, Tax Shelter Opinions Threatened the Tax System in the 1970s, in: “Tax Notes” 111 (May 22, 2006), p. 947.

[16] It is possible to infer the distribution of wealth among the general population from inheritance tax statistics using the Estate Multiplier Method, in which wealth at the time of death is reciprocally multiplied by the mortality rate based on age, gender and wealth. For a detailed discussion and assessment of this procedure, see Emmanuel Saez and Gabriel Zucman, Wealth Inequality in the United States Since 1913. Evidence from Capitalized Income Tax Data, in: “Quarterly Journal of Economics”, 131/2 (2016), p. 519-578.

[17] See Brian Raub et al., A Comparison of Wealth Estimates for America’s Wealthiest Decedents Using Tax Data and Data from the Forbes 400, in: “Proceedings. Annual Conference on Taxation and Minutes of the Annual Meeting of the National Tax Association ”, 103rd Annual Conference on Taxation (2010), pp. 128-135.

[18] See Wojciech Kopczuk and Emmanuel Saez, Top Wealth Shares in the United Stares, 1916-2000. Evidence from Estate Tax Returns, in: "National Tax Journal", Part 2 (2004), pp. 445-487, Table 1, Column 2.

[19] Donald Trump is a vivid example of a case of estate tax evasion, as documented by the “New York Times” (cf. David Barstow et al., Trump Engaged in Suspect Tax Schemes as He Reaped Riches From His Father, in: “The New York Times ", October 2nd, 2018.).