Income Taxation and Asset Valuation (I): Economic Depreciation, Accrual Taxation, and the Samuelson Theorem

Authors

• Theodore S. Sims, Boston Univeristy School of LawFollow

Author granted license

Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International

Document Type

Article

Publication Date

Winter 2013

ISSN

0040-0041

Publisher

New York University School of Law

Language

en-US

Abstract

Samuelson (1964) showed that an income tax with an allowance for "economic" depreciation leads to asset valuations that are independent of their holders’ marginal rates of tax. The tax system is then "neutral," in the sense that assets have the same value to all, irrespective of whether or at what rate they are taxed. In this essay I illustrate and show formally that taxation of cash flow minus an allowance for economic depreciation leads to the taxation of value as it accrues. That is, economic depreciation and pure accrual taxation are exactly equivalent. I suggest also that the form of "depreciation" allowance that gives rise to this result has implications for neutral taxation of capital income that extend beyond depreciation as such, and may help to improve our understanding of some of the historically more vexing details of property income taxation.

Recommended Citation

Theodore S. Sims, Income Taxation and Asset Valuation (I): Economic Depreciation, Accrual Taxation, and the Samuelson Theorem , 66 Tax Law Review 217 (2013).
Available at: https://scholarship.law.bu.edu/faculty_scholarship/433