Office of Tax Analysis Working Papers and Technical Papers

The OTA Working Papers Series presents original research by the staff of the Office of Tax Analysis. The OTA Technical Papers Series presents documentation of the models, datasets, and methods developed by staff and used for policy analysis and estimates. The papers are intended to generate discussion and critical comment while informing and improving the quality of the analysis conducted by the Office. The papers are works in progress and subject to revision. Views and opinions expressed are those of the authors and do not necessarily represent official Treasury positions or policy. Comments are welcome, as are suggestions for improvements, and should be directed to the authors. OTA Papers may be quoted without additional permission.

Date​Paper

January 2025

127: Quantifying the 100% Exclusion of Capital Gains on Small Business Stock Zahrah Abdulrauf, Gerald Auten, Paul R. Organ, & Quinton White

November 2024

126: Taxing S Corporations as C Corporations Lucas Goodman, Quinton White, Andrew Whitten
June 2024125: Barriers to Claiming Education Tax Credits for Low-Income Students  Julie-Anne Cronin & Joseph Gray-Hancuch
January 2024124: Marriage Penalties and Bonuses by Race and Ethnicity: An Application of Race and Ethnicity Imputation Rachel Costello, Portia DeFilippes, Robin Fisher, Ben Klemens, & Emily Lin
July 2023123: Use of the Opportunity Zone Tax Incentive: What the Data Tell Us David Coyne & Craig Johnson
May 2023TP12: U.S. Treasury Individual Income Tax Model Robert Gillette et al.
January 2023122: Tax Expenditures by Race and Hispanic Ethnicity: An Application of the U.S. Treasury Department's Race and Hispanic Ethnicity Imputation Julie-Anne Cronin, Portia DeFilippes, & Robin Fisher
January 2023TP11: Estimation of Race and Ethnicity by Re-Weighting Tax Data Robin Fisher
May 2022TP10: U.S. Cost of Capital Model Methodology Tracy Foertsch
May 2022TP9: 2021 Effective Tax Rates on New Investment for OECD Countries  Tracy Foertsch
May 2022TP8: U.S. Distributional Analysis Methodology  Julie-Anne Cronin
November 2021121: Take-Up of Payroll Tax-Based Subsidies During the COVID-19 Pandemic  Lucas Goodman
​January 2020​120: Social Welfare Considerations of EI​TC Qualifying Child Noncompliance​ Kara Leibel, Emily Y. Lin, & Janet McCubbin​
​May 2019​119: Tax Support for Families under Current Law, 2019​ Deena Ackerman & Michael Cooper
​May 2019​118: Simulating the 199A Deduction for Pass-through Owners Lucas Goodman, Katherine Lim, Bruce Sacerdote, & Andrew Whitten
​February 2019​117: Health Insurance Coverage from Administrative Tax Data Ithai Lurie & James Pearce
June 2018TP7: A Note on the Correlation between Income and Wealth for Taxable Estates Julie-Anne Cronin & John Eiler
​January 2017​116: What Would a Cash Flow Tax Look Like For U.S. Companies? Lessons from a Historical Panel Elena Patel & John McClelland
​January 2017​115: Methodology for Analyzing a Carbon Tax John Horowitz, Julie-Anne Cronin, Hannah Hawkins, Laura Konda, & Alex Yuskavage
​January 2017​114: The Rise of Alternative Work Arrangements: Evidence and Implications for Tax Filing and Benefit Coverage Emilie Jackson, Adam Looney & Shanthi Ramnath (Tables only)
November 2016TP4 (updated): Methodology for Identifying Small Businesses and their Owners Matthew Knittel, Susan Nelson, Jason DeBacker, John Kitchen, James Pearce, & Richard Prisinzano (Tables 2007, 2010, 2014)
​November 2016​113: Tax Expenditures for Education Nicholas Turner
​November 2016​112: Tax Support for Families with Children: Key Tax Benefits, Their Impact on Marginal and Average Tax Rates, and an Approach to Simplification 2017 Law Deena Ackerman, Michael Cooper, Rachel Costello, & Patricia Tong
​November 2016​111: Have Excess Returns To Corporations Been Increasing Over Time? Austin Frerick & Laura Power
​October 2016​110: Business Use of Section 179 Expensing and Bonus Depreciation, 2002-2014 John Kitchen & Matthew Knittel
​September 2016​109: Using a Reconciliation of NIPA Personal Income and IRS AGI to Analyze Tax Expenditures Tracy Foertsch
​August 2016​108: Joint Filing by Same-Sex Couples after Windsor: Characteristics of Married Tax Filers in 2013 and 2014 Robin Fisher, Geof Gee, & Adam Looney
​August 2016​107: Paying Themselves: S Corporation Owners and Trends in S Corporation Income, 1980-2013 Susan C. Nelson
​July 2016​106: What Can Tax Data Tell Us About the Uninsured? Evidence from 2014 Ithai Z. Lurie & Janet McCubbin
​January 2016​105: The Devil is in the Details: A Comparison of the Corporate Average Effective Tax Rate Calculations Used by Government Agencies Laura Power
​October 2015104: ​Business in the United States: Who Owns It and How Much Tax Do They Pay? Michael Cooper, John McClelland, James Pearce, Richard Prisinzano, Joseph Sullivan, Danny Yagan, Owen Zidar, & Eric Zwick
June 2015TP6: Re-weighting to Produce State-Level Tax Microsimulation Estimates Robin Fisher & Emily Y. Lin
​February 2013​​81 (updated tables): Revenue Effects of Major Tax Bills Jerry Tempalski
May 2012TP5:  Distributing the US Corporate Income Tax: Revised US Treasury Methodology Julie-Anne Cronin, Emily Y. Lin, Laura Power & Michael Cooper
​February 2012103: ​Foreign Taxes and the Growing Share of U.S. Multinational Company Income Abroad: Profits, Not Sales, are Being Globalized Harry Grubert
August 2011TP4: Methodology for Identifying Small Businesses and their Owners Matthew Knittel, Susan Nelson, Jason DeBacker, John Kitchen, James Pearce, & Richard Prisinzano
​March 2011​​102: ​The Dividend Clientele Hypothesis: Evidence from the 2003 Tax Act Laura Kawano
July 2008TP3: Treasury's Panel Model for Tax Analysis James R. Nunns, Deena Ackerman, James Cilke, Julie-Anne Cronin, Janet Holtzblatt, Gillian Hunter, Emily Lin, & Janet McCubbin 
July 2008TP2: Income shifting from Transfer Pricing: Further Evidence from Tax Return Data  Michael McDonald
July 2008TP1: Debt and the Profitability of Foreign-Controlled Domestic Corporations in the United States  Harry Grubert
​December 2007​101: A Review of the Evidence on the Incidence of the Corporate Income Tax William M. Gentry
​November 200710​0: The Federal Gift Tax: History, Law, and EconomicsDavid Joulfaian
May 2007​99: Income Mobility In The U.S.: Evidence From Income Tax Returns For 1987 And 1996 Gerald E. Auten & Geoffrey Gee
​May 2007​98: Corporate Response to Accelerated Tax Depreciation: Bonus Depreciation for Tax Years 2002-2004 Matthew Knittel
October 2006​97: Measuring a Company's Foreign Tax Credit Position Henry Louie, Gerald Silverstein, & Donald J. Rousslang
​​September 2006​81 (revised): Revenue Effects of Major Tax Bills Jerry Tempalski
​November 2005​96: The Behavioral Response Of Wealth Accumulation To Estate Taxation: Time Series Evidence  David Joulfaian
​June 2005​95: Basic Facts On Charitable Giving David Joulfaian
June 200594: The Effect of the 2001 Recession and Recent Tax Changes on the Corporate Alternative Minimum TaxCurtis P. Carlson
June 200593: The Corporate Alternative Minimum Tax, Aggregate Historical TrendsCurtis P. Carlson
March 200592: Estate Taxes and Charitable Bequests: Evidence from Two Tax Regimes David Joulfaian
​​December 2004​91: Introduction of Roths, and IRA Participation Warren B. Hrung
​December 2004​90: Optimal Tax Enforcement: A Review of the Literature and Practical Implications Janet G. McCubbin
March 200389: Recent Trends in Stock Options Scott Jaquette, Matthew Knittel, & Karl Russo
August 200188: Regional Differences in the Utilization of the Mortgage Interest Deduction Peter Brady, Julie-Anne Cronin, & Scott Houser
June 200087: Who Pays the Individual AMT? Robert Rebelein & Jerry Tempalski
​May 2000​86: Choosing Between Gifts and Bequests: How Taxes Affect the Timing of Wealth Transfers David Joulfaian
September 199985: U.S. Treasury Distributional Methodology Julie-Anne Cronin
July 199984: The Effect of Tax-Based Savings Incentives on the Self-Employed Laura Power & Mark Rider
April 199983:Using the Experience in the U.S. States to Evaluate Issues in Implementing Formula Apportionment at the International LevelJoann Weiner
November 199982: Defining and Measuring Marriage Penalties and Bonuses Nicholas Bull, Janet Holtzblatt, James R. Nunns & Robert Rebelein
December 199880: The Federal Estate and Gift Tax: Description, Profile of Taxpayers, and Economic Consequences David Joulfaian
November 199879: Do Taxpayers Really Respond to Changes in Tax Rates? Evidence from the 1993 Tax Act Robert Carroll
July 199878: A Profile of Non-Filers James Cilke
June 199877: Tax Evasion by Small Business David Joulfaian and Mark Rider
June 199876: Does Strategic Behavior Automatically Negate Ricardian Equivalence? Robert Rebelein
March 199875: The Effect of Income Taxes on Household Income Gerald Auten & Robert Carroll
October 199774: Another Look at the Low Taxable Income of Foreign-Controlled Companies in the United States Harry Grubert
October 199773: Taxes and Corporate Choice of Organizational Form Robert Carroll & David Joulfaian
February 199672: Charitable Contributions and Intergenerational Transfers Gerald Auten & David Joulfaian
August 199471: The Distribution and Division of Bequests: Evidence From the Collation Study David Joulfaian
August 199470: Do Repatriation Taxes Matter? Evidence From the Tax Returns of U.S. Multinationals Rosanne Altshuler, T. Scott Newlon, & William C. Randolph
August 199469: Dynamic Income, Progressive Taxes, and the Timing of Charitable Contributions William C. Randolph
August 199468: Measuring Permanent Responses to Capital Gains Changes in Panel Data Leonard E. Burman & William C. Randolph
​May 1989​67: Estimation and Interpretation of Capital Gains Realization Behavior: Evidence from Panel Data  Gerald E. Auten, Leonard E. Burman, & William C. Randolph
​May 1989​66: New Estimates of Capital Gains Realization Behavior: Evidence From Pooled Cross-Section Data Robert Gillingham, John S. Greenless, & Kimberly D. Zieschang
​May 1989​65: An Analysis of Aggregate Time Series Capital Gains Equations Jonathan D. Jones
​May 1989​64: A History of Federal Tax Depreciation Policy David W. Brazell, Lowell Dworin, & Michael Walsh
​May 1989​63: Master Limited Partnerships: A View From Their 1986 Tax Returns Susan C. Nelson & Joann Martens
​February 1989​62: Measures of Goodness of Fit for Extrapolations: Initial Results Using the Individual Tax Model Database Robert E. Gillette
​November 1988​61: Recent Issues in Transfer Pricing Barbara L. Rollinson & Daniel J. Frisch
​October 1988​60: The Tax Expenditure Budget Before and After the Tax Reform Act of 1986 Thomas S. Neubig & David Joulfaian
​May 1988​59: Noncorporate Business Taxation Before and After the Tax Reform Act of 1986 Susan C. Nelson 
​October 1987​58: Government Forecasts and Budget Projections: An Analysis of Recent History George A. Plesko
​October 1987​57: Taxation of Foreign Exchange Gains and Losses Jenny Bourne Wahl
​April 1987​56: A Reexamination of the Use of Ability To Pay Taxes by Local Governments Timothy J. Goodspeed
​March 1984​55: Corporate and Personal Taxation of Capital Income in an Open Economy John Mutti & Harry Grubert
​February 1983​54: Housing Tenure, Uncertainty and Taxation Harvey S. Rosen, Kenneth T. Rosen & Douglas Holtz-Eakin​
​January 1984​53: The Taxation of Income Flowing Through Life Insurance Companies Thomas Neubig & C. Eugene Steuerle
​September 1983​52: The Taxation of Income Flowing Through Financial Institutions: General Framework and Summary of Tax Issues Thomas Neubig & C. Eugene Steuerle
​December 1982​51: A Primer on the Efficient Valuation of Fringe Benefits C. Eugene Steuerle
​December 1982​50: The Relationship Between Realized Income and Wealth: Report From a Select Sample of Estates Containing Farms or Businesses C. Eugene Steuerle
​June 1981​49: Taxation and the Sectoral Allocation of Capital in the U.S. Joseph J. Cordes & Steven M. Sheffrin
​April 1981​48: Individual Income Taxation 1947-79 Eugene Steuerle & Michael Hartzmark
​January 1981​47: The Effects of Tax Parameters on the Investment Equations in Macroeconomic Econometric Models Robert S. Chirinko & Robert Eisner
​January 1981​46: The Effects of Tax Policies on Investment in Macroeconometric Models: Full Model Simulations Robert S. Chirinko & Robert Eisner
​January 1981​45: Tax Policy Toward Research and Development George N. Carlson
​December 1980​44: Modelling Revenue and Allocation Effects of the Use of Tax-Exempt Bonds for Private Purposes Harvey Galper & Eric Toder
​December 1980​43: The Tax Treatment of Research and Development (R&D) Expenditures by Multinational Corporations: The Impact of Regulations Anita M. Benvignati
​October 1980​42: Is Income From Capital Subject to Individual Income Taxation? C. Eugene Steuerle
​September 1980​41: Can Tax Revenues Go Up When Tax Rates Go Down? Don Fullerton
​July 1980​40: International Aspects of Corporate-Shareholder Tax Integration George N. Carlson
​July 1980​39: Equity and the Taxation of Wealth Transfers C. Eugene Steuerle
June197938: Tax Expenditures for Health Care Eugene Steuerle & Ronald Hoffman
March 197937: Adjusting Depreciation for Price Changes Eugene Steuerle
April 197936: Effects of Potential Tax Reforms on Stock Market YieldsLarry L. Dildine & Eric J. Toder
October 197835: Distributional Aspects of Tax Reform During the Past Fifteen Years Benjamin A. Okner
September 197834: Simplification and Comprehensive Tax Reform Harvey Galper & Michael Kaufman
October 197833: The American Presence Abroad and U.S. Exports John Mutti
July 197832: The Treasury Personal Individual Income Tax Simulation Model Roy A. Wyscarver
July 197831: Self-Insurance: Economics and Tax Treatment Seymour Fiekowsky
August 197730: The Incidence and Allocation Effects of a Tax on Corporate Distributions David F. Bradford
August 197729: Preferential Taxation and Portfolio Choice: Some Empirical Evidence Harvey Galper & Dennis Zimmerman
February 197728: Economic Depreciation and the Taxation of Structures in U.S. Manufacturing Industries: An Empirical Analysis Frank C. Wykoff & Charles R. Hulten
May 197727: Accounting for Tax Subsidies With Special Reference to Cost of Service, or 'Fair Rate of Return,' Utility Regulation Seymour Fiekowsky
August 197726: The Cash Flow Version of an Expenditure Tax Peter Mieszkowski
March 197725: State Corporate Income Tax: Lambs in Wolves' Clothing? Charles E. McLure, Jr.
​August 1977​24: Income Averaging: Evidence on Benefits and Utilization Eugene Steuerle, Richard McHugh, & Emil Sunley
July 197723: Pitfalls in the Computation of 'Effective Tax Rates' Paid by Corporations Seymour Fiekowsky
March 197422: The Effect on U.S. Foreign Direct Investment of the Integration of the Corporate and Personal Income TaxesJames A. Griffin
November 197621: Applications of Optimal Tax Theory to Problems in Taxing Families and Individuals Harvey S. Rosen
November 197620: Destination Principle Border Tax Adjustments for the Corporate Income and Social Security Taxes G.N. Carlson, G.C. Hufbauer, & M.B. Krauss
November 197719: U.S Experience on Inflation and the Tax Structure Harvey Galper & John Mendenhall
September 197618: Border Tax Adjustments on Commodities and Income M.B. Krauss & G.C. Hufbauer
September 197617: Incomes Under Low and High Tax Rate Systems: 1929 vs. 1973Gabriel G. Rudney
November 197616: Tax Barriers to Technology Transfers G.N. Carlson & G.C. Hufbauer
August 197615: The Taxation of Income from Option Writing by Nonresidents David E. Short
August 197614: Estimation of a Simultaneous System of Equations When the Sample is Under-Sized K.R. Kadiyala & James R. Nunns
May 197613: Taxation of Western Enterprise in Selected European Socialist Countries Paul Jonas
May 197612: Distribution Requirements for Foundations Eugene Steuerle
April 197611: Taxation, Saving and the Rate of Interest Michael J. Boskin
February 197610: Tax Neutrality Between Capital Services Provided by Long-Lived and Short-Lived Assets Emil M. Sunley, Jr.
February 19769: The Policy Uses of a Computational General Equilibrium Algorithm John B. Shoven
December 19758: The Optimal Taxation of Commodities and Income David F. Bradford & Harvey S. Rosen
October 19757: Reducing and Merging Microdata Files J. Scott Turner & Gary B. Gilliam
December 19756: Statistical Problems of Merged Data Files Joseph B. Kadane
August 19755: Financial Data for Tax-Exempt Charitable Organizations John Copeland
April 19754: Measuring the Cost of Capital Services T. Nicolaus Tideman
​April 1975​3: Depreciation, Profits, and Rates of Return in Manufacturing IndustriesRobert M. Coen
September 1974​2: Issues in the Taxation of Petroleum and Natural Gas Income Seymour Fiekowsky
May 1974​1: The Effects of the Asset Depreciation Range System on Depreciation Practices Thomas Vasquez