Läuft die Besteuerung von Wertzuwächsen auf eine Doppelbelastung hinaus?

Abstract

Is Taxation of Capital Gains Tantamount to A Double Burden?

The essays takes issue with the thesis put forward by Haller in this journal, 6th year (1973) p. 255, that the taxation of capital gains - realized and unrealized - results in a double burden which is unjustified from the standpoint of taxation according to the ability to pay. Haller bases his arguments against taxation of capital gains, not on the very much more general (Hobbes- Mill-Kaldor) thesis of the double burden on savings by way of income tax; indeed he expressly rejects this general double-burden thesis. The present essay dissects Aaller’s statements into individual arguments and discusses them in detail. In particular, he distinguishes among four such arguments: (1) Value increments are not real income because they are not ‘disposable’ income (illiquidity argument). (2) Value increments are not economically realizable; even the taking up of credit to realize capital gains would merely amount to a ‘pseudo-realization’ with an inflationary effect (macroeconomic argument). (3) In the case of realized value increments taxation is not advisable at least when merely redeployment of assets is involved. A genuine - taxable - realization would be given only if the gain deriving from the value increment was used for consumption (argument of the significance of the use of realized capital gains). (4) The value increment of undeveloped land ought to be taxed because no yield other than capital gains is derived from such Jand (argument of the special character of purely speculative investment). Each of these arguments is rejected as untenable in the present essay. On the basis of his deliberations the author comes to the conclusion that there are at least no fundamental differences between capital gains and other income when considered from the standpoint of distribution policy, so that taxation of both realized and unrealized capital gains - apart from the technical difficulties involved - appears justified and desirable. However, there are cases - e.g. ownership of condominium flats and one-family houses - in which the pressure to realize gains caused by the taxation of value increments can be considered “unreasonable’ for reasons other than ability-to-pay considerations and should be prevented by appropriate exemption regulations.