of distorting taxation is recognized, horizontal and vertical equity must be
more broadly deWned in terms of tax burdens, as we have done. Conversely,
equating tax payments with tax burdens must imply both a Wrst-best policy
environment and lump-sum taxation.
We will adopt a Wrst-best framework and equate tax payments with tax
burdens to focus strictly on the equity issues involved with the ability-to-pay
principles. This is at best an uneasy convenience, however. The problem is
that the ability-to-pay principles lead to choices of broad-based taxes that are
almost certainly not lump sum, so that it is impossible to ignore distortions
entirely. In particular, the federal personal income tax contains a number of
second-best distortions whose equity implications can only be understood in
terms of the broader tax-burden interpretation of horizontal and vertical
equity. Thus, we will occasionally stray from the Wrst-best assumptions.
HORIZONTAL EQUITY
From Horizontal Equity to the Ideal Tax Base
Mainstream public sector economists do not agree on which tax base best
satisWes the principle of horizontal equity. They do agree, however, on the
proper way to think about what the ideal tax base should be. The line of
reasoning from horizontal equity to the ideal tax base always relies on the
same three principles of tax design. The disagreement occurs in applying the
third principle, which describes the Wnal step to the tax base.
The Three Principles of Tax Design
People Bear the Tax Burden
The Wrst principle of tax design is that people ultimately bear the burden
of any tax no matter what is actually taxed. For example, corporate income
taxes and sales taxes are levied on business Wrms in the United States, but
the fact that a business Wrm pays $X million in taxes is of little consequence.
The interesting questions in terms of tax equity are which people Wnally
bear the burden of these taxes. Is some or all of the burden ``passed forward''
to the consumers of the Wnal product through higher prices, ``passed back'' to
labor employed by the Wrm through lower wages, borne by the stockholders
of the Wrm, or borne by third parties not directly associated with the Wrm?
Social well being is directly related to individuals' utility functions, not to
production relationships, and any tax eventually burdens people in their roles
as consumers or as suppliers of factors, or both.
Individuals Sacrifice Utility
The second principle of tax design is that individuals ultimately sacriWce
utility when they pay general taxes, so that the ideal tax base would be
11. APPLYING FIRST-BEST PRINCIPLES OF TAXATIONÐWHAT TO TAX AND HOW 337
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