Proposals calling for the fundamental restructuring of the Federal income tax system have

increased awareness of the complexities and inefficiencies of the current

system. Promoters of such proposals

suggest that the best approach to

deal with these inadequacies is to

completely replace the current

income tax rather than to make

adjustments within the existing

framework. Under recent proposals,

some form of consumption tax

would replace both the individual

and corporate income taxes, as well

as the Federal estate tax. A consumption tax can be levied directly

on spending or on an income base

with deductions for savings and

investment. This report examines

two consumption tax proposals—a

flat tax on income net of investment

and returns to savings, and a Federal

retail sales tax.

Objectives of Fundamental 

Tax Reform

Interest in restructuring the tax code

stems from three primary objectives:

simplifying tax rules, improving efficiency, and increasing the level of

savings and investment.

Many Taxpayers Find Current

Tax Code Too Complex. Perhaps

the most compelling argument for

fundamentally reforming the tax system is the complexity of the current

Federal income tax. This complexity

has increased over the years as the

income tax has been used to support

a variety of social and economic

goals. Much of this complexity is due

to a variety of special provisions that

target benefits to specific groups or

activities. One indication of the level

of complexity is the number of taxpayers who hire professionals to prepare their returns. About 85 percent

of farm sole proprietors used a paid

preparer to file their annual Federal

income tax returns in 1994, according to IRS Individual Public Use Tax

File data. By contrast, 72 percent of

other self-employed individuals and

45 percent of all other taxpayers

used a paid preparer. 

While many of the current restructuring proposals could simplify the tax

system, it is not clear that they would

retain the promised level of simplicity

as they work their way through the

legislative process or are subsequently amended. The Tax Reform

Act of 1986 is a good example of

how potential simplification gains

can be eroded both during the legislative process and over time by

subsequent amendments to the tax

code. Although the reforms achieved

were diluted by legislative compromise, the 1986 Act achieved some

simplification by reducing the number of tax brackets and by eliminating some individual itemized and

other deductions. However, over the

decade following enactment, new tax

brackets were introduced in 1991

and 1993 and a number of new targeted deductions and credits were

added—especially in the Taxpayer

Relief Act of 1997. This experience

suggests that any permanent gains

in simplification will require a change

in attitude toward the role of the tax

code in implementing social and economic policy and a commitment not

only to simplify existing provisions

but also to avoid reintroducing complexity over the long term.

The transition from the current

income tax to a consumption tax

would introduce added complexity

and would require rules to avoid

penalizing individuals and businesses

who made long-term decisions or

investments based on existing tax

Policy Issues in Rural Development

Economic Research Service/USDA

POLICY ISSUES IN RURAL DEVELOPMENT

United States

Department of 

Agriculture

Agriculture

Information

Bulletin No. 751-01

April 1999

How Would Fundamental

Tax Reform Affect Farmers?

Proposals to replace the existing Federal income tax with either a flat tax

on income or a Federal retail sales tax would represent a dramatic shift in

Federal tax policy. Following a transition period, farmers would likely

experience a reduction in compliance costs due to reduced tax complexity.

However, a revenue neutral, single-rate consumption tax would likely be

less progressive than the current system, shifting the tax burden from

higher income to middle and lower income farmers. The indirect effects of

such a dramatic shift in tax policy on interest rates, asset values, and

incentives to invest in farming are likely to be of greater importance than

the impact on Federal tax payments for many farmers. 
rules. Depreciation of existing capital

equipment and the taxation of

income from existing savings are

particularly important transition

issues. These rules would add considerable complexity during the transition period which might extend for

several years. Thus, while simplification may be the end result of restructuring the Federal income tax, it is

not necessarily guaranteed—especially in the short run. Furthermore,

it is not clear that the same level of

simplification could not be achieved

within the existing system without

the added complexities associated

with transition issues.

Current Tax Code Reduces Efficiency. Another argument in support

of fundamental tax reform is economic efficiency. The economy could

be more efficient if a new tax system

causes less distortion in economic

choices or if it costs less to administer.

Decisions on whether to consume,

save, or borrow are frequently influenced by taxes, as are choices such

as whether to farm, what to produce,

or when to buy inputs or sell farm

products. If an alternative tax structure

causes fewer distortions, yet allows the

Government to raise sufficient revenue, the economy could produce

more with the same level of resources. 

Administrative efficiency could also

be improved. Total income tax compliance costs are estimated to have

exceeded $50 billion in 1989. With

nearly $454 billion collected in total

income tax revenue, the compliance

cost was about 10 cents for every

dollar collected. The compliance

costs for self-employed individuals,

such as farmers, are especially high.

Farmers spend an estimated 60

hours per year on average on Federal

income tax matters.

Savings and Investment Gains

from Reform are Uncertain. A

third argument for fundamental tax

reform is the desire to increase the

rate of savings and investment. The

U.S. savings rate is lower than in

many other countries. Some suggest

that the Federal income tax is a contributing factor. Proponents assert

that exempting savings from tax will

raise the after-tax rate of return,

increase total savings and investment, promote business expansion,

and ultimately benefit both savers

and nonsavers. Critics counter that

current tax-oriented saving incentives

for retirement and college have not

had a clear effect on the overall savings rate, and that savings could even

fall if employers dismantle some pension plans under a new tax system. In

terms of capital investment, some

reform proposals would allow business investments to be deducted

immediately. Many small businesses,

including farmers, can already immediately expense much of their capital

investment. Thus, for farms and other

small businesses, the gains in investment from shifting to a consumptionbased tax are not clear.

Taxation of Farm Income

Under the Current Federal

Income Tax Structure

Examining farmers’ taxation under

the current Federal income tax structure provides a base to compare the

farm effects of tax-restructuring proposals. Under the current tax structure, income from farming is taxed

more favorably than income from

many other businesses. Aspects of

the current Federal income tax system responsible for this reduced effective rate of taxation include the ability

to use the cash method of accounting, to immediately deduct certain

capital expenditures, and to report

income from certain assets used in

farming as a capital gain. These and

other provisions, many of which are

available to other businesses, reduce

the farm income tax base. 

This favorable tax treatment is

reflected in the size of farm profits

and losses reported for income tax

purposes. Since 1980, aggregate

farm losses have exceeded farm

profits and are used to offset taxes

on off-farm income. In 1996, the last

year for which detailed data are available, farm sole proprietors reported

over $107 billion in gross farm business receipts for tax purposes but

reported a net farm operating loss of

about $7.1 billion. Many of these

losses are reported by smaller farms

in which the operator’s primary

source of income is an off-farm job

or other nonfarm source. In fact, 75

percent of farm sole proprietors with

farm business receipts below

$25,000 reported a farm loss for tax

purposes, and the average loss

reported was about $8,100. These

farms averaged over $59,000 in offfarm income. In contrast, 62 percent

of farms with farm business receipts

over $25,000 reported a farm profit,

and the average profit was about

$21,000. Thus, while many commercial-size farmers pay taxes on their

farm income, farm sole proprietors

in the aggregate pay little in Federal

income tax on farm income.

In most years, farm partnerships and

Subchapter S1 corporations also

report low incomes for tax purposes

(see table). In 1994, the most recent

year with data for all types of farm

organizations, farm sole proprietors

reported an aggregate farm operating loss of $7.3 billion, similar to

1996. However, they also reported

over $5.9 billion in gains on the sale

of farm capital assets and about

$600 million in farm rental income.

Thus, farm sole proprietors reported

$850 million in combined net farm

losses in 1994. Farm partnerships

were more profitable, reporting a

farm profit of $1 billion, while small

farm business corporations (Subchapter S) reported a net loss of

about $450 million. Thus, the total

amount of farm income subject to

the individual income tax was a negative $250 million. Large nonfamily

farm corporations taxed under the

corporate income tax reported a

2

Policy Issues in Rural Development

Economic Research Service/USDA

1A small business corporation whose

shareholders have elected to have

income and losses passed through to 

the shareholders rather than being taxed

under the corporate income tax.
profit of $1.1 billion, resulting in total

net taxable farm income of only

about $860 million for 1994. 

Fundamental Tax Reform 

Proposals

Over the years there have been a

variety of proposals for replacing the

current income tax. Most recently,

much of the attention has focused on

two types of consumption tax proposals—a flat tax based on income

with preferences for investments and

income from savings, and a Federal

retail sales tax.

The Flat Tax

In general, a flat tax is a tax system

that taxes a broad measure of

income at a single tax rate. There are

two main approaches to determine

the tax base: a consumption

approach and a comprehensive

income approach. While both envision a broader base by reducing the

number of targeted deductions, the

consumption approach encourages

saving over spending by exempting

dividends and interest income from

taxes. Given the often-stated objectives of reform, it is not surprising

that many of the recent tax proposals

adopt a broad tax base while exempting the returns to savings and investment. H.R. 1040 introduced in the

106th Congress is an example of a

consumption-based flat tax proposal.

Under this proposal, the current

multi-rate individual income tax structure would be replaced with a flat 19-

percent (17 percent after 2 years) tax

on earned income. Thus, investment

income such as interest, dividends,

and capital gains would not be taxed

at the individual level. The proposal

would also include some currently

untaxed employer-provided fringe

benefits in income, eliminate many of

the itemized deductions currently

allowable, and significantly increase

the standard deduction and personal

exemption amounts. 

In addition to the changes in the individual income tax system, H.R. 1040

would also integrate business taxation

and individual taxation by applying a

consumption-based income tax to all

businesses at the same 19-percent

rate. All investment in capital assets

could be deducted immediately as a

business expense. Although integrated through the same tax rate,

separate business and personal

returns would be filed, as opposed to

the current combined return for sole

proprietors. Requiring separate

returns would limit farmers’ ability to

use business losses to offset nonfarm

wage and salary income.

Flat Tax Would Reduce Progressivity. Replacing the current multitier individual income tax rate

structure (with marginal rates of 15

to 39.6 percent) with a flat 19-percent tax rate would result in substantial reductions in marginal tax rates

for some high-income farmers. Under

the current tax structure, fewer than

one-fourth of all farmers have marginal tax rates exceeding 15 percent,

and only about 5 percent have marginal tax rates over 28 percent. A

number of lower income farmers currently in the 15-percent bracket

would also experience reductions in

their tax rate since the increased

standard deduction ($23,200 for a

joint return, up from $7,200 in 1999)

and dependent exemption amount

($5,200 up from $2,750) would

exceed their taxable income and

result in zero tax. The remaining

farmers currently in the 15-percent

bracket would see a slight increase in

their marginal tax rates.

If the earned income tax credit were

eliminated, some low-income farmers

would experience a substantial

increase in their marginal tax rates.

These farmers currently have a negative effective marginal tax rate as a

result of the refundable earned

income tax credit. While allowing a

substantial exemption makes the flat

tax somewhat progressive, a tax system with only one rate is likely to be

less progressive than the current tax

system. Unless the rate changes are

offset by changes to the tax base,

such a system would shift the tax

burden from higher income farmers

to middle and lower income farmers. 

Modified Individual Tax Base

Would Vary by Household. Most tax

restructuring proposals substantially

modify the individual income tax base.

For individual taxpayers, changes in

the amount and type of taxable

income could more than offset any

change in marginal tax rates. Under

H.R. 1040, changes to the tax base

include taxing certain employer-provided fringe benefits, eliminating itemized deductions, and excluding from

Policy Issues in Rural Development

Economic Research Service/USDA

3

Farm profit and loss by type of organization, 1994

Over half of all farmers report a loss for Federal income tax purposes

Type of Profit Loss Total

organization Number Amount Number Amount Number Amount

1,000 $ million 1,000 $ million 1,000 $ million

Sole proprietors 1 876 13,097 1,389 -13,951 2,265 -853

Partnerships 2 58 3,031 42 -1,990 100 1,041

Subchapter S 2 17 1,046 19 -1,498 37 -453

Corporations 3 30 2,186 19 -1,064 49 1,123

Total 981 19,360 1,469 -18,503 2,451 858

1

 Farm sole proprietors are taxpayers filing IRS Schedule F. Amounts include net Schedule F,

capital gains from selling business assets (Form 4797), and farm rental net income 

(Form 4835). 2 Farm partnerships and subchapter S corporations include the combined 

net farm income reported on such returns, prior to allocation and pass-through to the individual

partners or shareholders. 3

 Includes net income from corporate tax returns that list farming as

the primary activity.

Source: ERS estimates compiled from IRS data.
taxation interest income, dividends,

and capital gains. Farmers receive

fewer tax-free employer-provided benefits such as health insurance than

other taxpayers. Also, only about 12

percent of households with a majority

of income from farming currently

itemize deductions compared with 30

percent for all taxpayers. Thus, these

changes in the tax base would generally have a smaller impact on farmers

than on other taxpayers.

Excluding interest income, dividends,

and capital gains from the tax base

would favor high-income farmers and

other taxpayers who normally

receive a much larger share of their

income from such sources. Since

farmers report more capital gains

than other taxpayers, excluding capital gains from the individual income

tax base would appear to favor farmers relative to other taxpayers. However, a large portion of farmers’

capital gains are from assets used in

the trade or business (such as breeding and dairy livestock), which would

be subject to tax as business income

and not excluded with other capital

gains. In 1994, farmers reported over

$12 billion in capital gains. However,

nearly half of this amount represented gain from the sale of assets

used in farming, such as livestock

and farmland. For those whose

income is primarily from farming,

over 90 percent of their total capital

gain income was from farm assets. 

The Flat Tax Would Affect

Farm Business Income and

Investment 

Many of the proposals for fundamental reform go beyond the individual

income tax and extend the consumption tax concept to business income.

These changes to the business

income tax base could be of even

greater significance to farmers than

changes to the individual tax rates,

exclusions, and deductions. Provisions governing deductions for capital investment and interest expenses

are especially important to farmers.

Under the current Federal income

tax, expenditures to acquire or

develop business assets that produce

income beyond the current period

generally are not immediately

deductible. Businesses are allowed

an annual depreciation deduction for

a portion of the capital expenditure.

However, the tax code began to allow

small businesses to immediately

expense a limited amount of capital

investment in 1986. More recent legislation increased the amount of

depreciable capital that can be

expensed from $17,500 per year to

$25,000 by 2003. Based on investment levels in recent years, this

allows about two-thirds of all farm

investment to be written off in the

year of purchase. Only about 10 percent of all farms, primarily the

largest farms, are currently unable to

fully expense their investment in

depreciable property (see figure).

Under a consumption-based tax, the

full cost of capital purchases could

be expensed. The primary beneficiaries of this change would be the

largest farms that frequently make

capital investments in excess of the

current annual expensing limit.

Deduction for Farmland Purchases Would Affect Land

Market. Perhaps the most dramatic

change for farm businesses in the

proposed flat tax would be an immediate deduction for farmland purchases. Under the current tax system,

farmland cannot be depreciated or

expensed. Allowing deductions for

farmland purchases would increase

the demand for land by both farmers

and other potential investors with sufficient resources and taxable income

to use the large deductions that

would be associated with such a business purchase. Under H.R. 1040, 

taxable losses created by such purchases could not be used to offset

nonfarm wage and salary income

because of separate business and

personal returns, but such losses

could be carried forward with an interest adjustment to offset future business income. Since the purchase

could be completely expensed, the

entire future sales price would be a

taxable gain if sold. Assuming the

step-up in basis rule continues to

apply to inheritances, this would provide landowners a substantial incentive to retain ownership until death to

avoid paying tax on the entire sales

proceeds. The lock-in effect that

already encourages farmers and others to hold assets until death would

be strengthened, further reducing the

supply of land available for sale.

Loss of Business Interest Deduction Would Favor Farmers with

Equity. Another important issue of

fundamental tax reform is the impact

on the farm business’ borrowing

costs. H.R. 1040 would eliminate the

business interest deduction. Proponents claim that interest rates would

decrease because the elimination of

the business interest deduction would

be coupled with an exemption for

interest income. The net effect on

borrowing costs would depend upon

whether interest rates decline enough

to offset the effects of losing the

deduction. Farmers currently deduct

about $10 billion in business interest

expenses each year, so eliminating

this deduction would greatly expand

the farm business tax base. However,

the effect would not be uniform

across the farm sector. About half of

all farmers have no debt, but many

of these are smaller part-time farmers. Younger, less established farmers would be especially affected by

this change since over two-thirds of

farmers under 35 have debt while

only about one-third of all farmers

over age 65 have debt.

Clearly, farmers with the highest marginal tax rates would experience the

sharpest increase in after-tax borrowing costs. However, because business

interest is also deductible for selfemployment taxes, even a farmer in

the 15-percent income tax bracket

has a combined tax rate of about 30

percent. To maintain the same aftertax cost of borrowing after losing the

interest expense deduction, a prereform interest rate of 10 percent

would have to drop below 7 percent

4

Policy Issues in Rural Development

Economic Research Service/USDA
following the enactment of a consumption tax. Given competition in

international capital markets and the

fact that the current tax code contains

numerous underused saving incentives, few analysts expect the change

in interest rates to be this large. Thus,

even with lower interest rates, young

farmers may be less able to compete

with older farmers or other investors

when buying farmland. The reliance

on leased land could increase, contributing to the separation of farm

ownership and operation.

The Federal Retail Sales Tax

Another reform option that has

received increased attention is a Federal retail sales tax such as that contained in H.R. 2001 introduced in the

105th Congress. A retail sales tax is

another form of a consumption tax.

Under this type of tax, products would

be taxed only once when they are purchased for final consumption at the

retail level. Investment income and

new savings would not be taxed until

they are spent on consumption. The

Federal retail sales tax would be very

similar to the sales taxes which are

currently levied in most States, but the

Federal tax would be at a much higher

rate, with estimates ranging from 15 to

23 percent. To keep the Federal tax

rate as low as possible, the tax base

would need to be very broad and

include products often excluded from

State sales taxes such as food, housing, services, and medical care.

Enacting a retail sales tax would represent a dramatic change in Federal

tax policy. Under H.R. 2001, a 15-percent retail sales tax on nearly all 

private consumption would replace

individual and corporate income

taxes as well as the Federal estate

tax. Only businesses that make sales

at the retail level would be required to

collect and pay the tax, greatly reducing the filing burden for most taxpayers. Sales to businesses, including

sales of investment goods, would

generally be exempt from tax through

the use of exemption certificates. A

tax rebate equal to the tax rate times

the poverty level would be provided

to reduce regressive effects. However,

the rebate would not offset the loss of

the refundable portion of the earned

income tax credit, which exceeded

$160 million for farmers and $23 billion for all taxpayers in 1996.

For farmers, a Federal retail sales tax

would exempt purchases of farm

inputs such as seed, fertilizer, feed,

and equipment from the tax as intermediate goods. Sales beyond the

farm gate to processors would also

be exempt. Therefore, a Federal retail

sales tax would have little direct

effect on farmers as businesses, but

would affect them primarily as

household consumers—the same as

nonfarm households. Compliance

would be simpler because the tax

would be determined and collected

by the retailer, eliminating individual

filing burdens unless the farmer

makes retail sales. However, farms

with consistent operating losses may

have difficulty meeting requirements

for the legitimate business use of

purchases and could lose their

exemption certificate.

Individual farmers may also be

affected by transition rules. A Federal

retail sales tax would discontinue the

use of existing net operating losses to

offset income from both farm and

nonfarm activities. Farmers carried an

estimated $6.6 billion of farm net

operating losses into tax year 1994.

Without transition relief, some farmers

could pay higher taxes under a Federal retail sales tax depending on their

household consumption and the level

of carryover losses. In addition, households that saved after-tax dollars

under an income tax might be taxed

again when those savings are spent

under a Federal retail sales tax. This

devalues old wealth relative to wealth

created under a new tax system.

Demand for Food Could be

Affected. Collectively, farmers may

be affected by a Federal retail sales

tax if the tax affects the demand for

food. If a wide tax base is preserved

to avoid a higher tax rate, and food

purchased at the retail level is not

exempt, the quantity of farm products demanded could fall because of

higher retail food prices. Although

some specialty products may benefit

from greater demand by households

with higher after-tax incomes, the net

effect is expected to be negative. The

decrease in food sales may be relatively small, however, because the

quantity of food consumed is affected

less by changes in price than is the

case with other consumer goods

Policy Issues in Rural Development

Economic Research Service/USDA

5

Under 40 40-<100 100-<250 250-<500 500 and over

0

20

40

60

80

Business receipts ($1,000)

Farmers with investment exceeding expensing limit, 1996

Larger farms would be primary beneficiaries from full expensing of 

capital investment

Percent

Source: Economic Research Service estimates from Agricultural Resource Management Survey, 1996.
(inelastic demand). Without other

structural changes, the price received

by farmers should not decrease very

much since most of the tax incidence

will be passed on to consumers

because of the inelastic demand.

Nonetheless, total farm revenues

could decrease slightly.

Compliance is Uncertain. Noncompliance issues are also a major concern with a Federal sales tax.

Opportunities may exist for many

small businesses to purchase household consumption goods tax-free by

using the business exemption. The

incentive to evade a Federal sales tax

will be much greater than for existing

State sales taxes, because of the relatively high tax rate necessary for a Federal retail sales tax to be revenue

neutral. Recent studies suggest a Federal retail sales tax would need to be

between 15 and 23 percent in order to

raise the same Federal revenue as the

current income tax. This rate would

need to be even higher if certain items

such as food or housing are exempted,

a rebate is provided, or significant transition rules apply. Also, since a retail

sales tax has only one collection point,

the incentive to evade or avoid such a

tax is especially high. If the tax can be

avoided at that one point, no tax is collected on the product or service. High

rates of noncompliance could require

even higher tax rates to collect the

desired amount of revenue.

Conclusions

Replacing the existing Federal

income tax with a flat consumptionbased income tax or a Federal retail

sales tax would dramatically shift tax

policy and affect farming activities.

Farmers would likely benefit from

reduced compliance costs due to a

less complex tax system. Complexity

could remain, however, during a transition period containing rules to prevent taxpayers from losing benefits

from past investments. The burden

of taxes under each proposal may

increase or decrease depending on

individual circumstances.

A revenue-neutral flat tax would likely

be less progressive than the current

system, shifting the tax burden from

high-income to middle- and lowincome farmers. Expanding the tax

base by including some fringe benefits and eliminating certain itemized

deductions would not significantly

affect farmers whose primary source

of income is farming. For most farmers, indirect effects on interest rates,

asset values, and incentives to invest

in farming are likely to be of greater

importance than changes in Federal

tax payments. Farmland may be sold

less frequently, increasing the reliance

on lease arrangements. Farmers

using equity capital might have an

advantage over those relying on debt.

A Federal retail sales tax would likely

tax many items usually exempted

from existing State sales taxes or

require an even higher tax rate than

proposed. Farmers would be affected

primarily as household consumers

rather than as businesses, because

business inputs would be exempt

from the sales tax as intermediate

goods. Only the small number of

farmers who make retail sales would

be required to collect the tax. Farm

product demand and prices could

decrease slightly if retail food prices

increase because of the tax. 

Contacting the Authors

Ron Durst

(202) 694-5347

e-mail: RDURST@ECON.AG.GOV

James Monke

(202) 694-5358

e-mail: JMONKE@ECON.AG.GOV

National Agricultural Library 

Cataloging Record

Durst, Ron

How would fundamental tax reform

affect farmers?

(Agriculture information bulletin;

no. 751-1)

1. Farmers—Taxation—United

States. 

2. Agriculture—Taxation—United

States.

3. Fiscal policy—United States. I.

Monke, James. II. Title.HD1443.U6 

Further Reading

Duncan, M., W. Koo, and R. Taylor.

“Overhauling the Federal Tax System: Do Farmers Gain?” Choices.

Vol. 12, no. 2 (1997): 28-31.

National Tax Journal, Symposium

Proceedings. “What Do We Mean

by Taxpayer Relief,” Vol. 51, no. 3

(Sept. 1998), p. 569-78, 621-35.

U.S. General Accounting Office. Tax

Administration: Potential Impact

of Alternative Taxes on Taxpayers

and Administrators. GAO/GGD-98-

37, Jan. 1998, 200 pp.

Policy Issues in 

Rural Development

The Food and Rural Economics

Division of ERS/USDA designed

this series of policy-oriented, timely

publications to provide background

and analysis for decisionmakers

and others.

U.S. Department of Agriculture

Economic Research Service

1800 M Street, NW

Washington, DC 20036-5831

6

Policy Issues in Rural Development

Economic Research Service/USDA

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