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DONALD MARRON

Musings on Economics, Finance, and Life

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A NEW SOLUTION FOR TAXING CRYPTOCURRENCY STAKING

Taxing digital assets poses many tax policy puzzles. So many, in fact, that the
Senate Finance Committee recently asked for advice on how to do it.

I have a new solution for one puzzle: how to tax the income people earn by
staking crypto tokens. In a staking system, token holders pledge (i.e., stake)
their tokens so they can help process and validate blockchain transactions.
Stakers thus replace traditional intermediaries like banks or credit card
companies. In return, they get rewarded with additional tokens.

A good place to start the puzzle is to ask how we tax similar economic
activities. That benchmark is straightforward. Stakers provide a service
(validating blockchain transactions) in return for compensation (more tokens).
If we want to treat them like other service providers, we should tax them on
their net income. Stakers should pay ordinary income taxes on the rewards they
receive and get deductions for the expenses they incur.

Staked tokens should generate tax deductions

Some expenses involved in staking, e.g., the costs of running computers, are
obvious. But there is also a non-obvious expense: cost recovery. Staked tokens
are a type of intangible property used to generate income. Staked tokens should
therefore qualify for the same amortization deductions other intangibles, like
franchise rights, receive. 

Alternatively, policymakers could create a new tax deduction that reflects how
the economic capability of staked tokens depreciates over time.

The idea that staked tokens are intangible property worthy of tax deductions may
be surprising. People often discuss cryptocurrencies as though they are some
sort of financial asset. Not literally a currency for tax purposes, but still
financial property. 

With rare exceptions, financial assets don’t get amortization or depreciation
deductions. Nor should they. People buy and sell them, exchange them for goods
and services, offer them as collateral for loans, or simply hold them. But they
don’t use them to produce any goods or services.

Staking changes that. The owner gives up their right to use tokens for financial
transactions and in return gets to earn rewards by validating blockchain
transactions. Staking thus transforms tokens into productive, intangible assets.
In tax jargon, tokens are placed in service to produce income.

Bitcoin validates transactions with a proof-of-work mechanism. But many other
blockchains—Ethereum and Tezos, for example—do it using proof-of-stake, which
requires fewer resources and less electricity. 

The opportunity to validate transactions is shared across people based on how
many tokens they stake. When they validate transactions correctly, stakers get
newly-issued tokens as a reward. But if they validate transactions poorly, they
may lose some staked tokens as a penalty. These incentives encourage stakers to
operate the decentralized network securely.

Staked tokens are thus the blockchain equivalent of franchise rights or taxi
medallions. If you want to serve branded fast food, you need a franchise right.
If you want to collect cab fares in New York City, you need a medallion. And if
you want to validate transactions on a proof-of-stake blockchain, you need
staked tokens.

We have clear rules for cost recovery for franchise rights, taxi medallions, and
many other types of intangible property. Under Section 197, taxpayers can
amortize the original cost of those intangibles over 15 years.

The simplest way to handle staked tokens would be to treat them the same way.
Congress could add staked tokens to the list of Section 197 intangibles. Or the
IRS could recognize staked tokens as the blockchain version of a franchise
right. Either way, stakers would get amortization on par with other service
providers who use intangible property. But only as long as their tokens remain
staked. When a person retakes control of their tokens, the deduction would end.

Newly-created tokens compete with existing tokens for staking rewards

You might wonder whether staked tokens deserve this treatment. Does their
productive capacity decline over time? The answer is yes. The issuance of new
tokens causes staked tokens to depreciate. Each new token can itself be staked
to offer validation services. That competition reduces the economic capability
of existing tokens.

Suppose a blockchain increases its token supply by 5 percent each year. Tokens
that could validate 10 percent of transactions this year might be able to
validate only 9.5 percent next year. And only 9 percent the year after. And so
on. New staked tokens cause existing staked tokens to gradually become obsolete.
Without some unforeseen improvement in market conditions, a person who stakes
the same number of tokens each year would see their revenue decline.

Policymakers have the option of looking beyond the rough justice of Section 197
amortization. They could allow deductions that reflect the actual decline in
staked tokens’ economic capability. There are some technical details in how you
measure this. But the basic idea is simple. If token supply expands 5 percent
one year, stakers could get a deduction of 5 percent of the cost of their
tokens. If policymakers prefer a depletion-like approach, the deduction could be
5 percent of their staking revenue. 

These approaches would be more administratively complex than 15-year
amortization. But they would allow deductions to more closely track the
depreciation experienced by staked tokens.

Two other approaches have dominated public debate. Traditional tax experts
recommend taxing staking rewards as ordinary income at receipt
(e.g., here and here). But to my knowledge, they have not suggested options for
cost recovery. Senators Lummis and Gillibrand, along with some crypto proponents
(e.g., here and here), have recommended taxing staking rewards only when the
tokens are eventually sold.

Both approaches have the virtue of administrative simplicity. But neither is
consistent with the way we tax other service providers.

If consistency is a goal, policymakers should chart a middle course. Stakers
should be taxed on their net income, not their gross income. Stakers should pay
ordinary income tax on their staking rewards. And they should get cost-recovery
deductions for the staked tokens that made those rewards possible.

This post first appeared on TaxVox, the blog of the Urban-Brookings Tax Policy
Center.

Author DonaldPosted on August 1, 2023Categories Cryptocurrencies, TaxesTags
Cryptocurrencies, Taxes


THE WORST JOBS DAY EVER

Driven by the COVID-19 shutdown, April marked the greatest job loss in American
history. The unemployment rate skyrocketed to 14.7 percent, and employers cut
20.5 million jobs.

Those figures are heart-wrenching. But as awful as they are, they do not fully
capture workers’ hardships. To be counted as unemployed, people must be
available for work and actively seeking it. With schools closed, job
opportunities withering, and social distancing the new norm, many displaced
workers don’t satisfy those requirements. Instead, they officially show up as
having left the labor force.



From February to April, the labor force shrank by 8 million people. Add that to
the more than 17 million increase in unemployment, and 25 million Americans are
no longer employed. More than 61 percent of Americans had jobs in February. In
April, only 51 percent did, the lowest level since records began in 1948.

In addition, millions of Americans still have jobs but have seen their hours
cut. From February to April, the number of people reporting that they work
part-time for economic reasons rose by 6.6 million. That spike happened even
though part-time workers have lost jobs at a particularly sharp rate.
Unemployment among people who usually work part-time rose from 3.7 percent in
February to 24.5 percent in April, while unemployment for full-time workers rose
from 3.5 percent to 12.9 percent.

Americans from all walks of life are suffering in the great shutdown. But the
employment damage is not distributed equally. As often happens in downturns,
highly educated workers have fared better than those with less education. Among
workers with a college degree, unemployment increased from 1.9 percent in
February to 8.4 percent in April. High school graduates with no college
education, however, have seen unemployment spike from 3.6 percent to 17.3
percent.

Teenage unemployment is now almost 32 percent, far more than for older workers.
Unemployment among Hispanic workers has increased more than for white, black,
and Asian workers. Women experienced a larger increase than did men.

We are living through remarkable times. The United States has not experienced
unemployment at these levels since the Great Depression. The one bit of good
news is that many job losses may be temporary. Indeed, a record 78 percent of
unemployed workers report they are on temporary layoff.

Unfortunately, many jobs will be permanently lost. To date, policymakers have
rightly focused on economy-wide disaster relief. Keeping families and employers
financially afloat is essential for an eventual recovery.

When we start down the path to recovery, policymakers should assess how severe
the longer-term damage will be and consider policies that accelerate the return
to full employment.

This post originally appeared on the Urban Institute’s Urban Wire blog.

Author DonaldPosted on May 8, 2020Categories Economics, MacroeconomicsTags jobs,
unemployment1 Comment on The Worst Jobs Day Ever


IF WE GIVE EVERYBODY CASH, LET’S TAX IT

Giving people cash is a great way to soften COVID-19’s economic blow. But it’s
sparked a classic debate. Should the federal government give money to everyone?
Or target it to people with low incomes?

Targeting has the potential to deliver the biggest benefit per dollar spent. But
eligibility requirements add complexity and will inevitably screen out some
people who need help. Universality is simpler and recognizes that we are all in
this together.

Happily, we can combine the best features of both approaches: Let’s give cash to
everyone, and then tax it later. By distributing money today, we get the speed
and inclusiveness of universality. By taxing it later, we can recapture some of
the benefits from those who needed them least.

One approach is simply to tax the assistance just like any other income. A
person with little income this year would keep the full government payment of,
say, $1,000. But a billionaire in California would net only $500. At tax time
next year, Uncle Sam would get $370 back and California would get $130. The
billionaire would receive half as much as the person with little income. And
states with income taxes would get a much-needed boost in revenues.

Ben Ritz of the Progressive Policy Institute has proposed another approach:
structuring the money as a pre-paid tax credit and then clawing back some of it
at tax time. The clawback system could be designed to accomplish any
distributional and fiscal goal you want. For example, you might phase out the
credit entirely for folks earning more than $150,000. Another possibility would
be to link the credit amount to some measure of income loss, not just income
level, by comparing the income changes across tax years.

Any of these approaches would reduce the fiscal cost of the cash payments and
thus, for the same overall cost, allow them to be bigger for those who get them.
Taxing the payments as income, for example, might create a 11 percent offset in
new federal revenues. (That figure is based on a report Elaine Maag and I did on
carbon dividends, an idea for universal payments linked to a carbon tax.) A
taxable payment of $1,125 would then have the about same net fiscal cost as an
untaxed $1,000 payment. Under Ritz’s proposal, a more aggressive clawback
approach could allow even bigger payments for the same overall cost.

The payments described here should not be treated as income in determining
eligibility and benefits in safety net programs. They should be treated as
income if we were enacting universal payments in normal times. But times are
decidedly not normal. There is no reason for these temporary payments to reduce
the efficacy of the existing safety net.

I favor targeting assistance to people with low incomes or sudden income loss if
it’s easy to do so. There’s clearly more bang per buck in directing aid to those
who likely need it most. Australia has already enacted one program along those
lines. But if we go with universal payments, let’s make the payments taxable.


Author DonaldPosted on March 18, 2020Categories Macroeconomics, TaxesTags
Macroeconomics, Taxes


ECONOMIC POLICY IN THE TIME OF COVID-19

COVID-19 poses a severe threat not only to public health but also to the overall
US economy. The nation’s policy response should focus on four basic strategies.

First, we should embrace those economic losses that protect health. The steps
needed to combat the coronavirus will inevitably reduce economic activity. We
want risky activities to stop. Social distancing is in. Gatherings are out.
Reducing economic activity will reduce the overall size of the economy. But we
all know Gross Domestic Product is not a measure of social wellbeing. That’s
especially true today.


Second, we should help people get through this sudden financial shock. Millions
of workers will see their incomes fall from reduced work hours, furloughs, and
layoffs. Restaurants, bars, and many other small businesses will see their
revenues crater.

Expanding existing safety net programs—as the House-passed Families First
Coronavirus Response Act does for unemployment insurance, Medicaid, and food
assistance—is a good start. So is supporting paid sick leave. But those programs
miss many people.

That’s why we are seeing new proposals to get money out the door quickly. Making
direct payments to households—recently proposed by Jason Furman (former economic
advisor to President Obama), Greg Mankiw (former advisor to President Bush), and
now Senator Mitt Romney (R-UT)—is one approach. Targeting payments to low income
households, as Australia is doing, is another. Giving money to employers who
keep workers on their payrolls is a third. Whichever approach we take, a
priority is getting support out quickly to soften what may be an unprecedented
loss in income.

Third, we should protect our economy’s productive capacity so it can rebound
once the virus risk recedes. COVID-19 shouldn’t destroy otherwise healthy
businesses and nonprofits.

The Federal Reserve will play a role by ensuring smooth functioning of credit
markets. Adding liquidity to Treasury markets, as the Fed is doing, is a good
step. It may well take more steps in the days ahead. But that won’t be enough.

Congress and President Trump should help fundamentally healthy firms that are
facing sudden cash flow stress and lack good financing options. Lending to small
businesses is a natural first step. Trump has proposed expanding lending
authority by the Small Business Administration. Other nations have announced
similarly-focused programs. The United Kingdom, for example, has introduced new
business interruption loans.

What to do for larger businesses is a harder question. Many large businesses do
have private financing options. Or would if they had managed their balance
sheets better. Expect spirited debate about where to draw the line between good
and bad bailouts and, for that matter, about what constitutes a bailout. (I’ll
have more to say about that in another post.)

Fourth, we should make full use of our economy’s productive capacity once the
virus recedes. Rebounding supply will help only if demand keeps up.

The Fed has taken a first step to support demand by cutting its target interest
rate to effectively zero and expanding its purchases of Treasury bonds and
mortgage-backed securities. Those steps will soften the decline in consumer and
business spending.

Whether that will be enough is anyone’s guess. With effective actions now, the
economy may rebound quickly once the virus threat abates. Unfortunately, it’s
also possible that economic activity will lag. If that happens, fiscal policy
can help boost demand. The actions we take now to provide income support will
help and could be continued. We also have the usual arsenal of tax (e.g.,
lowering payroll taxes) and spending (e.g., aid to states) options.

In recent days, America has made great strides in the first strategy, embracing
the economic losses necessary to fight the virus. In coming days, the priority
will shift to the next two, helping people survive the resulting sudden income
loss and defending our productive capacity so it can rebound quickly.
Policymakers may also take initial steps to support demand to make full use of
that capacity. But the ultimate scope of those efforts will need to track the
still-unknown size of the longer-term challenge.


Author DonaldPosted on March 17, 2020Categories MacroeconomicsTags Credit,
Macroeconomics, Taxes


BRAINTEASERS FROM MY DAD

When my sister and I were little, our Dad would challenge us with riddles and
word games. I mentioned three in my eulogy for Dad:

1. Imagine a two-volume dictionary sitting on a shelf. Each volume has 500
pages. A bookworm is on the first page of letter A. It wants to eat its way to
the end of letter Z as fast as possible. How many pages does it need to eat?

2. Should you walk to work or bring your lunch?

3. Is it warmer in the summer or in England?

Dad used the first to show the perils of leaping to conclusions. The second
introduced basic economics. As far as I can tell, the third is just amusing; if
you see a deeper meaning, please let me know.

 

Author DonaldPosted on December 15, 2019December 20, 2019Categories LifeTags
Fun, Puzzle2 Comments on Brainteasers From My Dad


REMEMBERING MY DAD, DONALD MARRON, 1934 – 2019

My dad died unexpectedly last Friday. He lived a remarkable, generous life.
Obituaries in Bloomberg, NYT, and WSJ give a taste of his success in business,
charity, and the arts. He was truly a self-made man.

Some of my favorite memories, however, are of my dad’s rare failures. His
unsuccessful effort to hurdle my sister’s cello during a game of chase. That
time we got ejected from Yankee Stadium for throwing paper airplanes. The one
and only set of tennis I ever won from him.

It’s difficult to believe he’s gone. Dad brought such vigor and energy to life.
Indeed, it was only a few months ago that we rocked to Billy Joel at Madison
Square Garden. You should have heard him sing “Movin’ Out”. If I make it to my
80s, I’d be thrilled to have half his energy and sharpness.

Health issues brought me to New York City often this past year. They proved a
blessing in disguise. My sister Jennifer and I got to see much more of Dad than
usual. We hung out in his office, grabbed a few dinners, and celebrated both
Dad’s and my birthdays. We feel fortunate we had that time together.

Dad was an inspiration and a great deal of fun. It’s an honor to bear his name.

P.S. See some of his favorite brain teasers here.

Author DonaldPosted on December 9, 2019December 20, 2019Categories Life1 Comment
on Remembering My Dad, Donald Marron, 1934 – 2019


SHOULD CONGRESS USE THE INCOME TAX TO DISCOURAGE CONSUMER DRUG ADS?

Senator Jeanne Shaheen (D-NH) and a score of Democratic cosponsors want to use
the tax code to discourage direct-to-consumer advertising by drug companies.
Their bill, the End Taxpayer Subsidies for Drug Ads Act, would prohibit firms
from taking tax deductions for any consumer advertising of prescription drugs.

Limiting tax deductions is a blunt and arbitrary way of approaching a legitimate
concern. Consumer drug ads play an important role in debates about the costs of
prescription drugs, the risks of misuse and overuse of some medications, the
balance of authority between doctors and patients, the limits of commercial
speech, and a host of other issues. For overviews, see here, here, and here.

But the bill is not well crafted to address those issues. The problem starts
with the legislation’s name: Allowing drug companies to deduct advertising costs
is not a subsidy. Many other deductions are: The charitable deduction in the
personal income tax, for example, subsidizes charitable giving. And the mortgage
interest deduction subsidizes borrowing to buy a home.

But the business deduction for advertising costs is not a subsidy. Continue
reading “Should Congress Use The Income Tax To Discourage Consumer Drug Ads?”

Author DonaldPosted on January 28, 2019December 4, 2019Categories Health,
Regulation, TaxesTags Drugs, Health, Taxes2 Comments on Should Congress Use The
Income Tax To Discourage Consumer Drug Ads?


DESIGNING CARBON DIVIDENDS

Carbon dividends are the hottest idea in climate policy. A diverse mix of
progressive and conservative voices are backing the idea of returning carbon tax
revenues to households in the form of regular “dividend” payments. So are a
range of businesses and environmental groups. Two weeks ago, six House
members—three Democrats and three Republicans—introduced carbon dividend
legislation.

Here is the idea: A robust carbon tax would cut emissions of carbon dioxide and
other gases that are threatening our climate. It also would indirectly increase
taxes on consumers and raise significant revenue. Carbon dividends would
distribute that revenue back to households through regular payments, thus
softening the financial blow of the tax while still reducing emissions. (Of
course, the revenue also could be directed to other purposes.)

While the premise is simple, the details of implementing carbon dividends are
complex. Policymakers face a range of philosophical, political, and practical
issues. In a new report, How to Design Carbon Dividends, my Tax Policy Center
colleague Elaine Maag and I explore those issues. Our work was funded by the
Climate Leadership Council, an advocate for carbon dividends (full disclosure: I
am a senior research fellow with the organization).

Two distinct philosophic views animate carbon dividend proposals. One sees
dividends as shared income from a communal property right. Just as Alaskans
share in income from the state’s oil resources, so could Americans share in
income from use of atmospheric resources.

The second sees dividends as a way to rebate carbon tax revenues back to the
consumers who ultimately pay them.

Though these ideas can be complementary, they have different implications for
designing carbon dividends. Continue reading “Designing Carbon Dividends”

Author DonaldPosted on December 12, 2018December 4, 2019Categories Energy,
Environment, TaxesTags Carbon Tax, Climate Change, Energy, Environment


THREE THINGS YOU SHOULD KNOW ABOUT THE BUYBACK FUROR

Record stock buybacks—driven in part by the corporate tax changes in the Tax
Cuts and Jobs Act (TCJA)—have sparked a media and political furor.
Unfortunately, they’ve also created a great deal of confusion. To help elevate
the debate, here are three things you should know.

1. Repatriated overseas profits are the main way TCJA is boosting buybacks

By slashing corporate taxes, TCJA will boost after-tax profits and cash flow.
Companies will use some of that cash to buy back shares. But that is not the
main way TCJA is fueling today’s record buybacks.

The big reason is the “liberation” of around $3 trillion in overseas profits.
Our old system taxed the earnings of foreign affiliates only when the domestic
parent company made use of them. To avoid that tax, many companies left those
earnings in their affiliates. They could reinvest them in their foreign
operations or hold them in U.S. financial institutions and securities, but they
couldn’t use them for dividends to parent company shareholders or stock
buybacks.

By imposing a one-time tax on those accumulated profits, the TCJA freed
companies to use the money wherever they wanted, including in the United States.
And multinational firms are leaping at the chance. Cisco, for example, says they
are repatriating $67 billion and buying back more than $25 billion in stock.

Cisco’s response reflects a broader trend. Repatriated profits will account for
two-thirds of this year’s increase in stock buybacks, according to JP Morgan.
Stronger earnings, due to both improved before-tax profits and lower taxes, make
up only one-third.

2. Buybacks do not mechanically increase stock prices

Buybacks can help shareholders. But it’s not as simple as much commentary
suggests. Continue reading “Three Things You Should Know about the Buyback
Furor”

Author DonaldPosted on April 12, 2018December 4, 2019Categories Economics,
Finance, Politics, TaxesTags Buybacks, Finance, Taxes


TALKING MONEY, INFLATION, FIAT, & BITCOIN

For your weekend listening pleasure (?): I visit the ReConsider podcast to chat
money, inflation, fiat currencies, gold, Bitcoin, & Uncle Sam’s balance sheet.
Starts at 4:59.

https://app.stitcher.com/splayer/f/123218/53701811

Author DonaldPosted on March 23, 2018Categories Uncategorized


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RECENT POSTS

 * A New Solution for Taxing Cryptocurrency Staking
 * The Worst Jobs Day Ever
 * If We Give Everybody Cash, Let’s Tax It
 * Economic Policy in the Time of COVID-19
 * Brainteasers From My Dad
 * Remembering My Dad, Donald Marron, 1934 – 2019
 * Should Congress Use The Income Tax To Discourage Consumer Drug Ads?
 * Designing Carbon Dividends
 * Three Things You Should Know about the Buyback Furor
 * Talking Money, Inflation, Fiat, & Bitcoin
 * How Should Tax Reform Treat Employee Stock and Options?
 * Eight Thoughts on Business Tax Reform
 * The 3-2-1 on Economic Growth: Hope for 3, Plan for 2, Pray it isn’t 1
 * Outside Research Organizations Can’t Replace CBO’s Budget Team
 * Can Trump Make Mexico Pay for the Wall?


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