The Efficiency-Equity Tradeoff of the Corporate Income Tax:
Evidence from the Tax Cuts and Jobs Act
Patrick J. Kennedy
Berkeley and JCT
(Job Market Paper)
Christine Dobridge
FRB
Paul Landefeld
JCT
Jacob Mortenson
JCT
(Click for latest version)
October 31, 2022
Abstract
This paper studies the effects of an historically large federal corporate income tax cut on U.S.
firms and workers, leveraging quasi-experimental policy variation from the 2017 law known as
the Tax Cuts and Jobs Act. To identify causal effects, we use employer-employee matched
federal tax records and an event study design comparing similarly-sized firms in the same
industry that faced divergent tax changes due to their pre-existing legal status. Reductions
in marginal income tax rates cause increases in sales, profits, investment, and employment,
with responses driven by firms in capital-intensive industries. Workers’ earnings gains are
concentrated in executive pay and in the top 10% of the within-firm income distribution, while
workers in the bottom 90% of the distribution see no change in earnings. Interpreted through
the lens of a stylized model, our estimates imply that a $1 marginal reduction in corporate tax
revenue generates an additional $0.10 in output, with 78% of gains flowing to the top 10% of
the income distribution. Overall, the results imply that corporate tax cuts improve aggregate
efficiency but exacerbate inequality.
Eric Heiser provided outstanding research assistance. We thank Alan Auerbach, Nano Barahona, Tom Barthold,
David Card, Benjamin Faber, Pablo Fajgelbaum, Penelopi Goldberg, Amit Khandelwal, Patrick Kline, Michael Love,
Emi Nakamura, Cristóbal Otero, Andrés Rodríguez-Clare, Jesse Rothstein, Nina Roussille, Emmanuel Saez, Benjamin
Schoefer, David Sraer, Jón Steinnson, Damián Vergara, Danny Yagan, Gabriel Zucman, and seminar participants at
Berkeley and the 2022 NBER Conference on Business Taxation at Stanford for constructive comments and suggestions.
Kennedy acknowledges financial support from the National Science Foundation Graduate Research Fellowship
Program. This research embodies work undertaken for the staff of the Joint Committee on Taxation, but as members of
both parties and both houses of Congress comprise the Joint Committee on Taxation, this work should not be construed
to represent the position of any member of the Committee. The views and opinions expressed here are the authors
own. They are not necessarily those of the Board of Governors of the Federal Reserve System, its members, or its staff.
Corresponding author: [email protected], [email protected]
1 Introduction
We study the effects of corporate income tax cuts on firms and workers in the United States,
where in 2017 Congress enacted the most sweeping and significant legislation on American federal
business taxation in a generation. Commonly known as the Tax Cuts and Jobs Act (TCJA), the
legislation introduced reforms to corporate marginal income tax rates, investment incentives,
and taxation of foreign income, among several other provisions of the tax code. Collectively,
the breadth of these provisions and the magnitude of the tax rate changes constitute the largest
overhaul of American business taxation since the Tax Reform Act of 1986, providing a rare and
sharp natural experiment to shed light on contemporary research and policy debates.
Even as governments around the globe have dramatically reduced corporate income tax rates
over the past half-century — from an unweighted average country worldwide statutory tax rate of
40% in 1980 to just 23% in 2021 (Tax Foundation 2021) policymakers and researchers today
fiercely debate the costs and benefits of declining corporate tax burdens. Advocates for tax
cuts argue that lower rates increase investment, growth, and workers’ living standards, while
opponents argue they do little to boost growth and primarily benefit the wealthy.
In this paper we bring new evidence to these debates. Our empirical analysis specifically
studies the core provisions of TCJA affecting firms’ statutory marginal income tax rates, using
a rich employer-employee matched panel dataset constructed from large random samples of
firm- and worker-level federal tax records. The data allow us to observe a holistic set of firm
outcomes such as sales, profits, shareholder payouts, and investment and to merge them
with worker-level data on employment and annual labor earnings.
Our main empirical strategy leverages an event study design to compare the outcomes of
similarly-sized firms in the same industry that faced divergent changes in their tax treatment.
In particular, TCJA cut the top marginal tax rate for a legal entity type of firms known as
C-corporations from 35% to 21% (a 40% reduction). At the same time, TCJA cut the implied top
marginal tax rate for a separate legal entity type of firms known as S-corporations from 39.6%
to 37% (a 6% reduction), and also introduced a new tax deduction that, for many of these firms,
further reduced the top marginal rate to 29.6% (for a cumulative 25% reduction).
1
C-corporations
and S-corporations operate in the same industries, overlap in their firm size distributions, and
faced broadly similar tax burdens prior to TCJA, inviting a natural comparison.
We exploit the fact that the average C-corp received a significantly larger tax cut than the
average S-corp to provide the first exhaustive evidence of these corporate tax changes on firms’
sales, profits, shareholder payouts, investment, and employment, as well as on workers’ annual
1
The top marginal tax rate for S-Corporations is implied because, unlike for C-Corporations, it must be computed as
a weighted average of the marginal tax rates faced by each firms’ individual owners and cannot be directly inferred from
firms’ tax records. The newly introduced tax deduction for S-corporations is known as the Qualified Business Income
(QBI) deduction. We discuss both points in greater detail in Sections 2 and 3. As we will describe, the main differences
between the firm types are that C-corporations may have unlimited shareholders and pay taxes directly to the federal
government, whereas S-corporations face greater shareholder restrictions and pay taxes indirectly to the government
via the individual tax filings of their shareholders.
1
earnings. As in Yagan (2015), the identifying assumption of our research design is not random
assignment of C or S status; rather, it is that outcomes for C- and S-corps would have trended
similarly in the absence of the tax cuts. Event studies indicate that outcomes of comparable C-
and S-corps were on similar trends prior to TCJA, and we further implement a series of robustness
checks to validate that our causal estimates are driven by changes in top marginal tax rates rather
than other features of the law, superficial tax shifting behaviors, or unrelated economic forces
differentially affecting C- and S-corps at the same time as TCJA.
Our benchmark regression specifications, which compare trends in outcomes of C- versus
S-corps controlling for firm and industry-size-year fixed effects, indicate that corporate income
tax cuts cause economically and statistically significant increases in firms’ sales, profits, payouts
to shareholders, employment, and real investment in capital goods. Responses are concentrated
in capital intensive industries, and are not larger for smaller or cash-constrained firms, suggesting
that effects are driven by a reduction in the cost of capital rather than by liquidity effects.
Our benchmark estimate of the federal corporate elasticity of taxable income, a key parameter
for measuring the magnitude of tax distortions, is 0.38 (s.e.=0.13). This elasticity is smaller than
most comparable estimates generated from variation in state and local corporate taxes, but larger
than most estimates on personal income taxes. Since businesses are less mobile at the federal level
than at the state or local level, and since a large literature documents that personal labor supply
elasticities are small, we interpret this evidence as consistent with the common economic intuition
that tax distortions vary proportionally with factor mobility.
Moving to the worker-level evidence, quantile regressions show that annual earnings do not
change for workers in the bottom 90% of the within-firm distribution, but do increase for workers
in the top 10%, and increase particularly sharply for firm managers and executives. Unlike other
outcomes such as employment and investment, we find that executive earnings increase in both
capital and non-capital intensive industries. Moreover, executive pay increases are only weakly
correlated with changes in firm sales, profits, or sales growth relative to other firms in the same
industry. Synthesizing this evidence, we estimate that approximately 10% of the executive pay
bump is driven by improved firm performance, while the remaining 90% is plausibly attributable
to rent-sharing or executive capture.
Descriptively, relative to the population of workers in our sample, the executives and workers
in the top 10% who benefit from higher earnings are typically older, have longer employment
tenures at the firm, and are more likely to be men. However, we find little evidence that earnings
effects vary heterogeneously by gender, age, or tenure after controlling for workers’ place in the
within-firm earnings distribution.
To evaluate the effects of corporate tax cuts on tax revenue and output, we combine the
reduced-form elasticities from the empirical analysis with a stylized model of firm owners and
workers. Using the model, we estimate that a $1 marginal reduction in the tax rate generates
an additional $0.10 increase in output. Corporate tax revenues decline by $0.87, with behavioral
responses of firms and workers modestly blunting mechanical revenue losses, and consistent with
2
the notion that contemporary top corporate marginal income tax rates in the US are below the
revenue-maximizing rate.
To evaluate distributional impacts, we estimate the short-run incidence of corporate tax cuts
on several factor groups firm owners, executives, and high- and low-paid workers as the
share of total output gains accruing to each factor. Combining our reduced form elasticities
with moments from the tax data, we find that approximately 56% of gains flow to firm owners,
12% flow to executives, 32% flow to high-paid workers, and 0% flow to low-paid workers. We
then go beyond factor incidence to estimate effects across the income distribution, accounting for
the empirical fact that many workers are also firm owners (that is, they hold equity portfolios)
and many firm owners also work. Using data on the distribution of capital ownership, we find
that approximately 78% of the gains from tax cuts accrue to the top 10% of earners, and 22% of
gains flow to the bottom 90%. Leveraging the empirically observable geographic distribution of
workers and income, we further find that these benefits are disproportionately concentrated in the
Northeastern and Western regions of the United States, and particularly among workers in large
and high-income cities.
This paper builds on a large body of research that studies the effects of corporate taxes on
profits, investment, shareholder payouts, employment, wages, and executive compensation.
2
Early seminal studies use aggregate or firm-level panel data and estimate two-way fixed effect
models to study policy variation across countries or industries (Hall and Jorgenson 1967;
Cummins, Hassett, and Hubbard 1994; Cummins, Hassett, and Hubbard 1996; Goolsbee 1998;
Hassett and Hubbard 2002). More recent contributions use detailed administrative microdata and
modern econometric methods to exploit geographic policy variation (Link, Menkhoff, Peichl, and
Schüle 2022; Duan and Moon 2022; Garrett, Ohrn, and Suárez Serrato 2020; Giroud and Rauh
2019; Fuest, Peichl, and Siegloch 2018; Suárez Serrato and Zidar 2016; Becker, Jacob, and Jacob
2013), industry-level variation in exposure to tax deductions or credits (Curtis, Garrett, Ohrn,
Roberts, and Serrato 2021; Ohrn 2022; Dobridge, Landefeld, and Mortenson 2021; Ohrn 2018;
Zwick and Mahon 2017; House and Shapiro 2008), and firm-level policy variation induced by
plausibly arbitrary legal or circumstancial distinctions (e.g., Boissel and Matray 2022; Moon 2022;
Carbonnier, Malgouyres, Py, and Urvoy 2022; Bachas and Soto 2021; Risch 2021; Alstadsæter,
Jacob, and Michaely 2017; Patel, Seegert, and Smith 2017; Yagan 2015; Devereux, Liu, and Loretz
2014).
Despite major advances in recent research, there are natural reasons to question whether
existing evidence is generalizable to understanding the effects of corporate tax cuts in the context
of TCJA. Evidence from subnational governments, small developing countries, or small firms may
2
Other outcomes studied in the literature include: establishment counts (e.g., Suárez Serrato and Zidar 2016; Giroud
and Rauh 2019); consumer prices (Baker, Sun, and Yannelis 2020); innovation and the mobility of inventors (Akcigit,
Grigsby, Nicholas, and Stantcheva 2021); international tax competition (Devereux, Lockwood, and Redoano 2008); the
location and investment decisions of multinational firms (Becker, Fuest, and Riedel 2012; Devereux and Griffith 2003);
tax avoidance and profit shifting (Garcia-Bernardo, Jansk
`
y, and Zucman 2022; Desai and Dharmapala 2009; Auerbach
and Slemrod 1997; Slemrod 1995; Hines and Rice 1994); and macroeconomic performance (Cloyne, Martinez, Mumtaz,
and Surico 2022; Zidar 2019; Romer and Romer 2010, Lee and Gordon 2005). These outcomes are beyond the scope of
this paper.
3
have limited applicability to major reforms in a large advanced economy such as the United States
(Auerbach 2018). This concern is especially salient with respect to the U.S. federal corporate
income tax, where the tax base is broader, top tax rates are higher, revenues are orders of
magnitude larger, and factors of production are considerably less mobile. Moreover, economic
theory predicts that alternate tax instruments such as dividend taxes, capital gains taxes, or
narrowly targeted corporate tax deductions and credits have very different effects than the
corporate income tax (Auerbach 2002; Hassett and Hubbard 2002). In this light, it is not surprising
that, due to differences in both normative and empirical worldviews, debates over the effects of
TCJA remain hotly contested by researchers and policymakers (Barro and Furman 2018).
Well-identified evidence on the federal corporate income tax has remained scarce for three
reasons. First, federal tax reforms are rare historical events, leaving limited policy variation for
researchers to study. Second, digitized administrative microdata was previously unavailable
to researchers, constraining the scope and precision of empirical analyses. Third, even when
countries do change their tax rates, it is difficult for researchers to identify credible counterfactuals
for causal inference, particularly as the parallel trends assumption underlying cross-country
difference-in-difference analyses are challenging to defend in disparate socioeconomic and
institutional settings.
This paper overcomes these limitations to provide clear and transparent evidence on the effects
of corporate tax cuts on firms and workers. In doing so, we make four main contributions to the
literature.
First, we study a rare policy change that generated historically large within-country variation in
federal corporate income tax rates, and moreover generated variation even across similarly sized
firms in the same industry. As a share of GDP, the TCJA tax cut is orders of magnitude larger
than previous studies that focus, for example, on changes in state or local corporate taxes, which
tend to have lower rates and a smaller tax base (e.g., Giroud and Rauh 2019; Fuest, Peichl, and
Siegloch 2018; Suárez Serrato and Zidar 2016). The large magnitude of the tax cut is relevant on
both theoretical grounds (according to the conventional view that tax distortions are proportional
to the square of the tax rate, as in Harberger 1964) and on purely empirical grounds (since ex-ante
it is unclear whether existing evidence can be extrapolated to the case of an outlier).
Second, we complement the large shock with detailed employer-employee matched tax records
that allow us to observe an unusually holistic set of firm- and worker-level outcomes. We build
on frontier research that uses employee-level data to provide a nuanced account of corporate tax
incidence on different types of workers (Carbonnier, Malgouyres, Py, and Urvoy 2022; Risch 2021;
Dobridge, Landefeld, and Mortenson 2021; Fuest, Peichl, and Siegloch 2018), and extend existing
work by empirically estimating geospatial incidence and incidence on firm owners. In contrast
to studies that do not directly observe profits (e.g., Suárez Serrato and Zidar 2016), the richness
of our data allows us to estimate incidence using fewer assumptions than are typically required
when data availability are more limited.
Third, we contribute to a growing literature that seeks to understand the effects of TCJA on
4
the U.S. economy. Researchers have studied impacts on macroeconomic performance (Gale and
Haldeman 2021; Gale, Gelfond, Krupkin, Mazur, and Toder 2019; Kumar 2019; Barro and Furman
2018; Mertens 2018), international and intertemporal profit shifting (Garcia-Bernardo, Jansk
`
y,
and Zucman 2022; Dowd, Giosa, and Willingham 2020; Clausing 2020), pass-through businesses
(Goodman, Lim, Sacerdote, and Whitten 2021), executive compensation (De Simone, McClure,
and Stomberg 2022), capital structures (Carrizosa, Gaertner, and Lynch 2020), and regional or local
economic outcomes (Kennedy and Wheeler 2022; Altig, Auerbach, Higgins, Koehler, Kotlikoff,
Terry, and Ye 2020). Our study differs from existing research in that we specifically study the
effects of TCJA’s marginal corporate income tax cuts on firm- and worker-level outcomes using
rich admistrative microdata and a quasi-experimental research design leveraging cross-firm policy
variation.
Finally, we contextualize our findings from this historical episode in broader debates about
efficiency and equity in national tax and transfer systems (Carbonnier, Malgouyres, Py, and
Urvoy 2022; Bachas and Soto 2021; Risch 2021; Hendren and Sprung-Keyser 2020; Fuest,
Peichl, and Siegloch 2018; Suárez Serrato and Zidar 2016; Devereux, Liu, and Loretz 2014;
Arulampalam, Devereux, and Maffini 2012; Gruber and Rauh 2007). With respect to efficiency,
our model-based estimates of the marginal output gains from cutting the federal corporate income
tax are approximately 1.5 to 2 times as large as the literature-implied marginal gains from cutting
personal income or payroll taxes. With respect to equity, our results contrast with much existing
research in that we find the incidence of the corporate falls heavily on capital and highly-paid
workers. Assessing incidence across the income distribution, we estimate that corporate income
tax cuts are similarly regressive relative to personal income tax cuts, but markedly less progressive
than payroll tax cuts. We note that our results capture short-run responses and do not account
for potential changes in government spending or after-tax redistribution, which are important
considerations for policymakers but beyond the scope of this research.
The rest of the paper proceeds as follows. Section 2 summarizes key features of the Tax Cuts
and Jobs Act, including its legislative history, institutional context, and major policy changes.
Section 3 describes data sources and variable definitions. Section 4 details our empirical strategy
and presents results. Section 5 presents a stylized model that we use to estimate the revenue
impacts, excess burden, and incidence of TCJA’s corporate tax cuts. Section 6 concludes with a
discussion of the results.
2 Institutional Setting: The Tax Cuts and Jobs Act
2.1 Legislative History
In 2017 Congress took on the task of reforming federal business tax policy, with the stated aims
of increasing capital investment, economic growth, and international competitiveness.
3
Following
3
The policy reforms were first proposed in a blueprint document released by Republicans in the House of
Representatives in June 2016, available here.
5
several months of political negotiations and policy proposals, in December 2017 Congress and
the President enacted Public Law 115-97, more commonly known as the Tax Cuts and Jobs Act,
or TCJA. The law included provisions affecting many aspects of the federal business tax code,
including corporate income tax rates, investment incentives, and taxation of foreign income. Most
policy changes were implemented beginning in tax year 2018, although some provisions, such as
the investment incentives that we will later discuss, were applied to tax year 2017. Our aim below
is not to exhaustively detail TCJA’s numerous reforms for reviews of significant provisions
see Auerbach (2018) and Joint Committee on Taxation (2018) but rather to illuminate the key
institutional details and policy variation that we leverage in our empirical analysis.
2.2 C-Corporations vs. S-Corporations
At the heart of TCJA was an overhaul of the income tax schedules facing two legally distinctive
types of businesses, known as C-Corporations and S-Corporations. Combined, C- and S-corps
account for approximately 70% of total U.S. employment and 74% of total payrolls, with
government, non-profits, and non-corporate private businesses comprising the remainder (Census
Bureau 2019). Our analysis focuses exclusively on the corporate sector, as other entity types face
different tax and regulatory regimes, and are beyond the scope of this paper. Below we describe
salient legal differences between C- and S-corps.
C-Corporations
C-corps are required to pay income taxes directly to the federal government, may be private or
public, and are subject to both corporate income taxes (paid on corporate profits) and dividend
taxes (paid by shareholders on profits distributed as dividends). Prior to TCJA, C-corps faced a
progressive tax schedule with eight income brackets and a top marginal rate of 35%. After TCJA,
these brackets collapsed to a single uniform 21% tax rate. Appendix A.1 documents the evolution
of top marginal income tax rates for C-corps in the United States since 1909, illustrating the historic
nature of this large and rare tax cut, and Appendix A.2 details the collapse of the progressive
corporate income brackets following TCJA. Appendix A.3 puts the U.S. corporate tax in a global
perspective, and Appendix A.4 benchmarks the magnitude of the TCJA corporate tax cut against
other recent studies in the literature.
S-Corporations
S-corps do not pay taxes directly to the federal government. Rather, the firms’ profits are
distributed to the individual owners of the firm, who pay taxes on profits as ordinary income and
can deduct any losses. S-corps may have up to 100 shareholders, all of whom must be U.S. citizens
and not businesses or institutional investors, and are not permitted to sell shares on publicly
traded stock exchanges. Unlike C-corps, S-corps do not face corporate income taxes, nor are their
distributed profits subject to the dividend tax.
6
Prior to 2018, owners of S-corps faced a top marginal income tax rate of 39.6%. TJCA then
provided two distinct types of tax relief to owners of S-corps. First, it reduced the top personal
income tax rate from 39.6% to 37%. Second, it introduced a 20% tax deduction on qualified business
income that further reduced the effective marginal tax rate on S-Corp income for most high-income
tax-payers from 37% to 29.6%. This tax deduction known as the Qualified Business Income
(“QBI”) deduction, or as “Section 199A after the applicable section of the internval revenue code
is claimable by most but not all owners of S-corps. Since the QBI limitations are complex and
not crucial for our empirical analysis, we abstract from details here and provide more details in
Appendix A.5.
Entity Type Choice and Switching
Firms must elect either C or S status upon incorporating. The decision to choose one corporate
form over the other may reflect a variety of considerations, including access to capital (recall that
S-corps may not be publicly traded) and tax planning (recall that C-corps must pay entity-level
taxes and are subject to dividend taxes on distributed profits). After electing C or S status,
switching entity types is costly, rare, and subject to regulatory restrictions. Thus, a firm’s entity
type prior to TCJA is strongly related to the tax rate change it faced after TCJA, and endogenous
switching is not a concern for our analysis.
2.3 Policy Variation in Marginal Income Tax Rates
Figure 1 shows the evolution of marginal income tax rates and tax burdens for C- and S-corps
in the years before and after TCJA. Panel A shows the sharp reduction in top statutory marginal
income tax rates for C-corps, as well as the change in implied top statutory marginal income tax
rates for S-corps depending on whether or not they are eligble for the QBI deduction.
Panel B shows the change in observed marginal tax rates from our analysis sample of large
firms with at least 100 employees. Entity-level tax rates and taxes paid are imputed for S-corps by
linking to returns of S-corp owners, as we will describe in detail in the following section. Observed
average marginal tax rates are lower than top statutory rates for several reasons. First, in any
given year some firms will have non-positive taxable income (for example, if they earn zero or
negative profits) and thus face a marginal tax rate of zero. Second, C-corps prior to TCJA faced a
graduated tax rate schedule. Third, our measure of the marginal tax rate for S-corps is computed
as a weighted-average of the tax rates faced by their owners, some of whom may not be in the top
tax bracket.
Panel C underscores the economic significance of the tax cuts in dollar terms, documenting the
observed average change in corporate taxes per worker for C- and S-corps. The panel shows that
average taxes per worker declined from 2016 to 2019 by approximately $1,600 per worker (28%)
for C-corps, and by approximately $800 per worker (13%) for S-corps.
Most importantly, all three panels show that, on average, C-corps received a significantly larger
tax cut than S-corps due to TCJA, illustrating the key policy variation that we use in our empirical
analysis to identify causal effects.
7
FIGURE 1: MARGINAL INCOME TAX RATES AND TAXES PER WORKER
Panel A: Top MTR (Statutory) Panel B: Average MTR (Observed)
S Corps
C Corps
W/out QBI
W/ QBI
(%)
10
20
30
40
50
2013 2014 2015 2016 2017 2018 2019
Top Marginal Income Tax Rates
.1
.15
.2
.25
.3
2013 2014 2015 2016 2017 2018 2019
S Corps C Corps
Marginal Tax Rate
Panel C: Taxes Per Worker (Observed)
S Corps
C Corps
Taxes/Worker ($)
3,000
4,000
5,000
6,000
7,000
2013 2014 2015 2016 2017 2018 2019
Notes: Panel A shows top statutory marginal income tax rates for C and S Corporations before and after enactment of
TCJA. Panel B shows the average MTRs observed in our data analysis sample of large firms with at least 100
employees; we discuss the data construction and variable definitions in Section 3. Panel C shows the change in taxes
per worker paid by C- and S- corps observed in the data over the sample period.
8
3 Data
We use a panel of employer-employee matched annual federal tax records from tax years 2013
to 2019. We begin the sample period in 2013, allowing us to compare trends in the outcomes
of C- and S-corps several years before TCJA, and end the sample in 2019, prior to the onset of
the COVID-19 pandemic in 2020. Below we describe the data sources and sample construction,
provide variable definitions, and present descriptive statistics. We provide additional details about
the data cleaning procedures in Appendix B.
3.1 Corporate Tax Returns
We study firms in the corporate Statistics of Income (SOI) files produced by the U.S. Internal
Revenue Service (IRS). The corporate SOI files include stratified random samples of corporate tax
returns from both C-corps (from IRS Form 1120) and S -corps (from IRS Form 1120S). IRS produces
and cleans these random samples to estimate aggregate statistics and to provide government
agencies with essential data for development of legislation and policy analysis. The corporate
tax returns allow us to observe firms’ domestic sales, costs, profits, investment, and taxes paid, as
well as their year of incorporation and industry. The IRS over-samples large firms with known
probability weights, and the samples are designed as rolling panels so as to allow for longitudinal
analyses.
4
We impose the following two sample restrictions on the SOI panel, yielding an analysis sample
of approximately 11,600 unique firms and 81,000 distinct firm-year observations.
First, we restrict the sample to large firms, defined as those with at least 100 employees and $1
million in sales in every year of our pre-treatment period from 2013 to 2016. There are two reasons
for restricting the sample to large firms. Large firms account for the lion’s share of corporate
economic activity, comprising approximately 90% of corporate sales, 70% of corporate taxes, and
67% of corporate employment.
5
Moreover, many small C-corps faced tax increases (rather than
tax cuts) after TCJA due to the flattening of corporate income tax brackets to a uniform 21% rate.
Including smaller firms would thus require significantly complicating our empirical design, which
simply compares outcomes of similar C- and S-corps over time. The large firm restriction both
allows us to study the most economically significant firms and to employ a more transparent and
credible research design.
Second, we balance the panel and drop firms that ever switch entity types from C to S or from
S to C over the course of our sample period. Balancing the panel ensures that our results are
not driven by the changing composition of firms in the SOI samples. Because entity-switching is
rare, dropping switchers from our sample excludes only approximately 4% of firms, collectively
comprising less than 0.5% of corporate sales or profits.
4
For additional details on construction of the SOI samples, see documentation provided by the IRS here.
5
Authors’ calculations using IRS SOI data.
9
3.2 Individual Tax Returns
We complement the sample of corporate tax records with several sources of individual-level
administrative records.
First, we merge the sample of corporate tax returns with the universe of worker-level filings of
IRS Form W-2, which provides information on workers’ annual wage earnings from each of their
employers. Employers are required each year to share copies of form W-2 both with their workers
and with the IRS, allowing us to observe the earnings of all workers even if they had no federal tax
liability or did not file a personal income tax return.
Second, we collect information about the owners of S-corps in our sample from the universe
of filings of IRS Form 1099-K1, which provides data on the income received by owners of
S-corps from each of their pass-through businesses each year, including pass-through income from
non-corporate partnerships. As we will describe below, we complement this information with data
from IRS Forms 1040 to compute implied marginal income tax rates and federal taxes paid for S
corporations.
Finally, we observe individuals’ age and gender from the Master Database maintained by the
Social Security Administration (SSA). We also observe their residential location using data from
Kennedy and Wheeler (2022).
3.3 Variable Definitions and Measurement
Our empirical analysis uses information on firm-level tax rates, taxes paid, sales, profits,
investment, employment, and shareholder payouts. We also use data on workers’ employment
and annual wage and salary earnings. We take care to measure these variables consistently
over time, such that our outcomes are not affected, for example, by changes in the tax base or
in reporting requirements on tax forms. We provide additional details on variable definitions,
including specific forms and line item numbers, in Appendix B.
Marginal Tax Rates
Our primary explanatory variable of interest is the marginal income tax rate paid by firms. For
C-corps, we observe taxable income and directly infer each firm’s marginal income tax rate using
the federal corporate income tax schedules reproduced in Appendix Table A.1. For S-corps, we
observe each owner’s taxable income from their personal tax returns, and directly infer their
personal marginal income tax rate using the federal personal income tax schedules as reproduced
in Appendix Table A.1. We then compute the implied corporate marginal tax rate for the firm as a
weighted average of the marginal personal income tax rates faced by the firms’ owners, where the
weights are given by the share of ordinary business income distributed to each owner from that
firm. For example, if an S-corp has two owners who receive an equal share of that firm’s business
income, facing marginal tax rates on their individual income of 25% and 35%, respectively, then
we compute the implied corporate marginal tax rate as (.5 .25) + (.5 .35) = 30%. Appendix
10
Figure B.1 shows the sample distribution of corporate MTRs for both S- and C-corps before and
after TCJA.
Taxes Paid
For C-corps, we directly observe total tax payments to the federal government on Form 1120. For
S-corps, which do not pay entity-level taxes, we must estimate tax payments using information
from the individual-level tax records of the firms’ owners. To do so, we first compute each owner’s
average tax rate from Form 1040 as total federal tax divided by taxable income. We also record each
owner’s total net ordinary business income from Form 1040 Schedule E, and estimate total business
taxes paid on this income by multiplying it by the owner’s average tax rate. We bottom code
total business taxes at zero, ensuring in our calculations that owners do not pay tax on business
losses. For each owner, we allocate her total business tax payments to each firm that she owns
in proportion to the share of ordinary business income received from that business. Finally, we
sum up the total tax payments of each firm’s owners to record an estimate of total firm-level tax
payments. We provide additional details about these computations in Appendix B.
Sales, Costs, and Profits
We measure firm sales as gross receipts. Pre-tax profits are defined as sales minus cost of goods
sold, which includes both material and labor inputs. An advantage of this profit measure is that
it is simple, transparent, consistent over time, and invariant to tax law and corporate form. As
a robustness check, we also construct a harmonized measure of earnings before interest, taxes,
depreciation, and amoritization (EBITDA), described in B. After-tax profits are equal to pre-tax
profits minus taxes paid.
Dividends, Share Buybacks, and Total Payouts
Dividends are defined as total cash and property payments to shareholders. Share buybacks are
defined as non-negative changes in treasury stock, and total payouts are measured as the sum of
dividends and share buybacks.
Investment
Net investment is defined as the change in the dollar value of capital assets, where capital assets are
equal to the book value of tangible investment minus capital asset retirements and accumulated
book depreciation. We also report results on new investment, defined as the sum of capital
expenditures reported on IRS Form 4562. These tax forms include information on firms’ purchases
of new capital assets such as machinery, computers, vehicles, office furniture, and structures. Firms
report these investments according to the lifespan of the investment, which affects the horizon
of capital tax deductions available to the firm. We decompose new investment into “short-life”
equipment with depreciation schedules of less than or equal to 10 years (such as light machinery,
11
computers, and vehicles), “long-life” equipment with longer depreciation schedules (such as
heavy machinery), and structures (such as new factories or office buildings).
Employment, Earnings, and Executive Compensation
We measure firm employment as the total number of unique individuals with a W-2 issued by
the firm. Firms with complex ownership structures often use multiple employer identification
numbers, and we use crosswalks to improve the linkage between W-2s and their ultimate parent
companies (see Joint Committee on Taxation 2022). Workers’ annual earnings are defined as
Medicare wages from the W-2, which capture wage, tip, and salary income even if it is not taxable.
Total firm payrolls are the sum of workers’ annual earnings. Because employment, earnings, and
payrolls are always strictly positive in our sample, we take logs of these outcomes in the empirical
analyses.
Firms report compensation of officers on Forms 1120 and 1120s, which we use to measure
executive pay. Officer designations are determined by state tax law, and reported compensation
captures several but not all components of executive pay, including: wage, salary, and bonus
income; stock options and grants, when exercised; and non-qualified deferred compensation.
However, this measure does not capture stock options or grants before they are exercised, and
does not include qualified incentive-based compenstion plans.
6
The measure thus represents a
lower bound on executive compensation.
We also construct an alternate proxy measure of executive compensation as the combined
annual W-2 earnings of the top five highest paid workers at the firm. This measure captures
compensation of high-ranking employees who may not qualify as officers for tax purposes.
Additional Firm Characteristics
We group firms into four time-invariant size bins with approximately comparable numbers of
observations based on their average employment in the pre-period years prior to 2017, where the
bins are: 100-199 employees; 200-499 employees; 500-999 employees; and 1000+ employees. We
also classify firms into time-variant industries using the NAICS-3 codes they report on Forms 1120
and 1120s. In the resulting data we observe 86 distinct industries and 280 distinct industry-size
bins.
Firm age is inferred from the firm’s year of incorporation, reported on the 1120. Firms are
classified as multinationals if their foreign sales share is greater than 1%, where foreign sales are
defined as the sum of gross receipts from all Controlled Foreign Corporations (that is, foreign
subsidiaries) reported on Form 5471. We measure capital intensivity at the industry level as capital
6
Designation of officers is detemined by the laws of the state or country where the firm is incorporated. Qualifed
deferred compensation plans include 401(k) and similar investment vehicles; these plans are subject to contribution
limits and regulatory restrictions, and investments are generally risk-free to workers. Non-qualified deferred
compensation plans are not subject to contribution limits and in principle are at risk if the firm declares bankruptcy,
although such losses are empirically rare. Qualified incentive-based compensation plans have a maximum deferral of
$100,000 per year and are taxed as long-term capital gains, and thus are not reported on the W-2.
12
assets divided by sales. Firms are classified as capital intensive if the mean of this ratio in the
pre-period is greater than the sample median, and others are classified as non-capital intensive.
Appendix B.3 shows that capital intensive firms are approximately equally distributed across the
firm size bins, and are not exclusively manufacturing firms.
Data Processing
We scale several outcomes taxes, sales, costs, and profits by firm sales in 2016, our baseline
year prior to the passage of TCJA. While it is common in economic research to estimate elasticities
by transforming regression outcomes using natural logs, doing so in our case is problematic
because taxes and profits are often zero or negative in a given year. Scaling firm variables
by baseline sales permits a natural economic interpretation of the regression coefficients in our
empirical analyses, allows us to study a range of outcomes such that they can be consistently and
easily compared, and is standard in the literature. In accordance with economic theory and prior
research, investment results are scaled by lagged capital, although for consistency across results
we also report results scaled by baseline sales in the Appendix. We also follow the literature in
winsorizing the top and bottom 0.1% of the scaled outcomes separately for C- and S-corps in each
year. Winsorizing ensures that our results are not driven by outliers or by measurement error,
and improves statistical precision. We also show that the empirical results are robust to alternate
winsorizing thresholds.
3.4 Descriptive Statistics
Panels A and B of Figure 2 show the distributions of log firm sales and log firm employment in our
sample, and illustrate broad overlap in the size distributions of C- and S-corps. The panels make
clear that the firm size distributions are strongly right-skewed, and that this skewness is more
pronounced for C-corps than S-corps. In robustness checks, we show that our empirical results are
insensitive to the inclusion or exclusion of very large C-corps; since they are qualitatively irrelevant
to the results, we include them in the main analysis sample.
Panel C of Figure 2 shows the NAICS-2 industry composition of the sample, and again reveals
broad overlap of C- and S-corps. Most industries have comparable shares of C- and S-corps. Some
sectors, such as management and professional services, have a relatively higher proportion of C-
than S-corps, while the reverse is true for others, such as construction and retail trade. Because
our event study analysis will use industry-size-year fixed effects to compare C- and S-corps in the
same industry and employment size bin, the observed sectoral overlap in the sample is more than
sufficient for our empirical design. In robustness checks, we show that results are insensitive to
the exclusion of industries in which the firm share of C-corps or S-corps exceeds 80%.
Table 1 presents descriptive statistics for our analysis sample from 2016. The mean firm in
the sample has annual sales of $1,046.9 million, earns pre-tax profits of $385.0 million, pays
$18.1 million in federal taxes, and makes real investments of $49.6 million per year. Mean firm
employment is 2,968 workers, and the average worker earns approximately $63,700 per year.
13
Consistent with Figure 2, columns 3-10 again underscore the right-skewness of firm size, especially
of C-corps, such that mean outcomes are significantly higher than medians and outcomes for
C-corps are higher and more variable than for S-corps.
7
FIGURE 2: FIRM SIZE DISTRIBUTIONS AND INDUSTRY COMPOSITION
Panel A: 2016 Sales Panel B: 2016 Employment
S-Corps
C-Corps
Density
0
.1
.2
.3
.4
$1mil $10mil $100mil $1bil $10bil $100bil
2016 Log Firm Sales
S-Corps
C-Corps
Density
0
.1
.2
.3
.4
.5
100 1K 10K 100K 1mil
2016 Log Firm Employment
Panel C: Industry Composition
Share of Firms
0
.05
.1
.15
.2
.25
.3
.35
Administration
Agriculture
Construction
Education
Entertainment
Finance
Food and Hotels
Health Care
Information
Management
Manufacturing
Mining
Other Services
Professional
Real Estate
Retail Trade
Transportation
Utilities
Wholesale Trade
C S
Notes: Panels A and B show the distribution of 2016 log firm sales and employment, respectively, for C- and S-corps in
the analysis sample. Panel C shows the NAICS-2 industry composition of firms in the sample.
7
All medians and other quantile statistics reported in this paper are fuzzed to protect taxpayer privacy; see
Appendix B for details.
14
TABLE 1: SUMMARY STATISTICS
All Firms C Corporations S Corporations
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)
Mean SD Mean SD p50 p90 Mean SD p50 p90
Taxes
Marginal Tax Rate 0.248 0.161 0.215 0.168 0.340 0.350 0.310 0.124 0.380 0.396
Federal Tax (mil) 18.1 164.7 26.1 202.7 0.6 24.7 2.9 13.1 0.6 6.8
Federal Tax Per Worker 6,050 11,503 6,382 12,480 1,229 17,567 5,415 9,326 1,669 15,187
Sales and Profits
Sales (mil) 1,046.9 5,976.2 1,467.0 7,327.1 152.7 2,276.4 244.4 636.3 117.6 463.5
Costs (mil) 654.5 4,667.9 905.8 5,733.4 69.5 1,130.1 174.5 521.9 72.5 345.3
Pre-Tax Profit (mil) 385.0 1,902.1 549.9 2,325.6 55.2 937.6 69.9 216.8 31.9 134.0
After-Tax Profit (mil) 366.9 1,799.7 523.8 2,199.9 52.2 906.3 67.0 211.7 30.2 127.1
EBITDA (mil) 155.9 1,240.2 227.0 1,525.2 11.6 273.0 20.1 64.4 8.1 38.6
Shareholder Payouts
Dividends (mil) 34.6 444.8 47.6 548.1 0.0 14.6 9.8 33.8 2.9 20.5
Share Buybacks (mil) 19.4 351.2 29.5 433.2 0.0 0.8 0.3 4.6 0.0 0.0
Total Payouts (mil) 56.5 708.4 80.8 873.0 0.0 24.9 10.1 34.1 3.0 20.9
Real Investment
Net Investment (mil) 17.9 404.4 26.6 498.8 0.0 23.3 1.3 15.0 0.0 5.3
Net Investment / Lagged Capital 0.16 1.36 0.15 1.26 0.01 0.39 0.18 1.53 0.01 0.42
New Investment (mil) 66.7 1,650.6 98.2 2,036.5 3.2 73.0 6.5 36.5 1.2 12.4
Employment and Earnings
Employment 2,968 21,533 4,041 26,241 510 5,986 918 5,262 340 1,454
Payroll (mil) 173 975 242 1,192 31 402 39 146 18 70
Mean Annual Earnings (thous) 63.7 59.2 68.2 62.8 56.5 111.3 55.1 50.3 49.0 80.9
Median Annual Earnings (thous) 46.2 25.4 49.6 28.0 42.9 84.8 39.7 17.7 37.6 60.2
Executive Pay
Executives’ Earnings (thous) 5,606 26,572 7,319 32,077 1,651 13,654 2,334 8,555 988 4,806
Mean Top 5 Earnings (thous) 1,187 3,329 1,496 3,950 458 3,203 596 1,388 341 1,059
Firm Characteristics
Firm Age 35 23 33 24 28 64 40 21 37 67
Multinational 0.24 0.32 0.10
Private 0.84 0.76 1.00
Capital Intensive 0.50 0.55 0.41
N Firms 11,647 7,645 4,002
Notes: Table shows summary statistics from 2016 for firms in the analysis sample. Medians and centile statistics are fuzzed to
protect taxpayer privacy. For data sources and variable definitions see Section 3.
15
4 Empirical Analysis
4.1 Empirical Strategy
We implement a transparent research design comparing trends in outcomes of C- and S-corps in
the same industry-size bin before and after TCJA. Our event study specification is given by:
y
ft
=
t6=2016
β
t
C
f
1(year = t) + γ
f
+ α
is(f ),t
+
ft
(1)
where y
ft
is an outcome for firm f in year t; C
f
is a binary variable equal to 1 if firm f is a C-corp
or 0 if it is an S-corp; γ
f
is a firm fixed effect; and α
is(f ),t
is an industry-size-year fixed effect, where
the industry-size bins are constructed as described in Section 3.3. The coefficients of interest, β
t
,
capture the average differences in outcomes between C- and S-corps in the same industry-size
bin in year t. We use 2016 as the reference year, allowing us to compare C- and S-corp trends for
several years prior to TCJA and also to observe any potential anticipatory tax-shifting behaviors
beginning in 2017. Standard errors are clustered by firm.
The key identifying assumption permitting a causal interpretation of the β
t
coefficients is that
the outcomes of C- and S-corps would have trended similarly in the absence of TCJA’s changes to
firms’ marginal income tax rates. While this assumption is not directly empircally testable, there
are several reasons that parallel trends is likely to hold in our setting. First, Congressional passage
of TCJA was widely unexpected prior to the 2016 federal elections, and so firms had limited
scope to anticipate the reform and to adjust their behavior endogenously to the policy changes.
Second, our narrowly defined industry-size-year fixed effects imply that we make comparisons
among C- and S-corps that that compete in similar product markets and are subject to the same
industry-by-size specific supply and demand shocks. Third, Yagan (2015) finds that C- and S-corp
trends in real outcomes were statistically indistinguishable for all years in his sample period from
1996-2008, implying that C- and S-corps have historically responded similarly to macroeconomic
shocks and trends. Fourth, as we will show, our event studies show parallel trends in the outcomes
of C- and S-corps in the years directly prior to the policy reform. Lastly, in Section 4.8, we carefully
consider additional identification threats, and present a series of robustness checks to ensure that
our causal estimates are not driven by non-MTR features of the law, anticipation effects, superficial
tax-shifting behaviors, or unrelated economic shocks differentially affecting C- and S-corps at the
same time as TCJA.
Our goal of assesssing the efficiency impacts and distributional effects of TCJA’s corporate tax
cuts will require that we obtain elasticities of profits, investment, and earnings with respect to
the net-of-tax rate. To estimate these key elasticities, we pool outcomes in the post-period and
use two-stage least squares. The reduced form, first-stage, and structural equations are given,
respectively, by:
16
y
ft
= λC
f
P ost
t
+ γ
f
+ α
is(f ),t
+
ft
(2)
ln(1 τ
f
) P ost
t
= δC
f
P ost + γ
f
+ α
is(f ),t
+
ft
(3)
y
ft
= ε ln(1 τ
f
) P ost
t
+ γ
f
+ α
is(f ),t
+
ft
(4)
where τ
f
is the 2016 to 2019 change in the marginal income tax rate for firm f , P ost
t
is
an indicator equal to 1 for years after 2018, and the fixed effects are the same as in equation 1.
Intuitively, we instrument for firms’ net-of-tax change using their pre-existing entity type status as
a C-or S-corps. The identifying assumptions underlying this empirical strategy are well known:
exogeneity, relevance, monotoncity, and exclusion. We do not claim strict exogeneity in our setting
that is, we do not claim there is random assignment of C or S status but rather rely on the
weaker claim of parallel trends in the outcome absent the changes in the tax rate (see Conley,
Hansen, and Rossi 2012). We examine the relevance and monotoncity conditions below, and return
to a discussion of the exclusion restriction when we evaluate mechanisms.
We begin the empirical analysis with a presentation of average responses, and then turn to
heterogeneity tests and robustness checks. We conclude the empirical analysis with a discussion
of mechanisms, where the focus is naturally related to the task of disentangling the impacts of
TCJA’s marginal tax rate cuts from other concurrent policy changes. First, however, our goal is
more modest: to provide clear evidence on how TCJA differentially affected C- and S-corps.
4.2 Marginal Tax Rates and Taxes Paid
Figure 3 plots the β
t
coefficients and 95% confidence intervals from estimating equation 1, using
the firms’ marginal tax rates and taxes paid as outcomes. We scale taxes paid (and other outcomes
that we will report below) by the firm’s baseline 2016 sales for the reasons discussed in Section 3.3.
In the bottom of each left panel we also report the 2016 sample outcome mean to contextualize the
economic scale and significance of the estimated coefficients.
Panel A of Figure 3 shows that the observed marginal tax rates of C- and S-corps trended
similarly prior to TCJA, but diverged sharply thereafter. On average, the marginal tax rate of
C-corps fell by approximately -5.2 percentage points (s.e.=0.2) compared to S-corps in the sample;
relative to the 2016 outcome mean in levels of 0.25, this represents a -5.2/0.25 20.8% decline in
the marginal tax rate facing C-corps relative to S-corps. The panel also makes clear that firms’ tax
burdens began to decline in 2017, even though the bulk of TCJA’s provisions did not take effect
until 2018. This pattern provides suggestive evidence that firms engaged in intertemporal shifting
behaviors to minimize tax liability, such as reporting costs in 2017 rather than 2018 so that those
costs could be deducted at a higher tax rate. We discuss shifting behaviors in greater detail later in
Section 4.8.
Panel B of Figure 3 shows an analogous version of Panel A, where the outcome is transformed
as the log net-of-tax rate, (1-τ
MT R
f
). We show this transformation because economic theory predicts
17
FIGURE 3: EVENT STUDIES: MARGINAL TAX RATES AND TAXES PAID
Panel A: Marginal Tax Rate Panel B: Log Net-of-Tax Rate
-.06
-.04
-.02
0
.02
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.25
Marginal Tax Rate
Difference Between C-Corps and S-Corps Over Time
0
.02
.04
.06
.08
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: -0.31
Log Net-of-Tax Rate
Difference Between C-Corps and S-Corps Over Time
Panel C: Tax / 2016 Sales Panel D: Tax Per Worker
-.02
-.01
0
.01
.02
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.06
Federal Tax
Difference Between C-Corps and S-Corps Over Time
($)
-4,000
-3,000
-2,000
-1,000
0
1,000
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 6,045
Tax Per Worker
Difference Between C-Corps and S-Corps Over Time
Notes: The unit of analysis is a firm-year. The panels plot the β
t
coefficients estimated from equation 1. These coefficients capture
average differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects.
Standard errors are clustered by firm and error bands show 95% confidence intervals. The outcome in Panel A is the firm’s marginal
tax rate, τ
MT R
f
, and the outcome in Panel B is the log net-of-tax rate, ln(1 τ
MT R
f
). The outcome in Panel C is tax per worker,
reported in dollars, and the outcome in Panel D is tax scaled by the firms’ baseline 2016 sales. Marginal tax rates for S-corps are
defined as the weighted average of the shareholders’ individual marginal tax rates, where the weights are given by the ownership
shares. See Section 3 for details on the measurement of tax payments for S-corps. For data sources and variable definitions see Section
3.
18
that firms respond to the net-of-tax rate when optimizing profits. The figure shows that, on
average, C-corps saw their net-of-tax rate increase by approximately 6.8% (s.e.=0.2) relative to
S-corps following TCJA. Below, we use this result to scale other reduced form effects, allowing us
to estimate elasticities of key outcomes with respect to changes in the log net-of-tax rate.
Panel C of Figure 3 shows that the differences in tax cuts also translated into differences in
taxes paid, with C-corps paying approximately -1.0 percentage points (15.0%; s.e.=0.3) less in
federal tax in 2019 relative to their baseline sales when compared to S-corps. Panel D illustrates
that the magnitude of this effect is economically large: on average, C-corps paid approximately
$2,200 (s.e.=$436) less in tax per worker than comparable S-corps following TCJA.
Columns 1 to 4 of Table 2 report the C × P ost estimates produced from estimating equation
2. Similar to the event studies, these coefficients capture the average difference between
C- and S-corps in the pre- and post-periods for each outcome after controlling for firm and
industry-size-year fixed effects.
TABLE 2: MARGINAL TAX RATES AND TAXES PAID
(1) (2) (3) (4)
τ
MT R
f
ln(1 τ
MT R
f
) Tax Per Worker Tax/Sales
2016
C × Post -0.052
∗∗∗
0.068
∗∗∗
-2203
∗∗∗
-0.010
∗∗∗
(0.002) (0.002) (436) (0.003)
2016 Outcome Mean 0.25 -0.31 6,045 0.06
Firm FE Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes
R2 0.72 0.73 0.59 0.83
N 81,529 81,529 81,529 81,529
N Firms 11,647 11,647 11,647 11,647
Notes: The unit of analysis is a firm-year. The table shows the C × P ost coefficients from
equation 2. These coefficients estimate average differential changes in outcomes between
C- and S-corps before and after TCJA, controlling for firm and industry-size-year fixed
effects. The outcome in column 1 is the firm’s marginal tax rate, τ
MT R
f
, and the outcome
in column 2 is the log net-of-tax rate, ln(1 τ
MT R
f
). The outcome in column 3 is tax
per worker, reported in nominal dollars, and the outcome in column 4 is tax scaled by
the firms’ baseline 2016 sales. Marginal tax rates for S-corps are defined as the weighted
average of the shareholders’ individual marginal tax rates, where the weights are given by
the ownership shares. See Section 3 for details on the measurement of tax payments for
S-corps. Standard errors are clustered by firm.
The results in Figure 3 and Table 2 provide evidence of a strong first stage, demonstrating
an economically meaningful and statistically powerful differential effect of TCJA on the tax rates
and tax payments of C-corps versus S- corps. These results also show that the relevance and
monotoncity assumptions underlying equation 3 are satisfied in this setting.
19
4.3 Sales, Costs, Pre-Tax Profits, and EBITDA
Figure 4 plots the results from estimating equation 1 to assess trends in the sales, costs, and pre-tax
profits, and EBITDA of C- and S-corps over time. The figure shows trends in these outcomes
were statistically similar before TCJA, again lending support to the parallel trends assumption
underlying the identification strategy. After TCJA, however, C-corps’ sales increased markedly
relative to S-corps, by approximately 3.6 percentage points (s.e.=1.5) by 2019. The effect is precisely
estimated and economically significant: using values from Table 1, the coefficient implies that the
average C-corp increased its sales by approximately $40 million relative to comparable S-corps.
C-corps also faced higher costs, as shown in Panel B, although the magnitude of the cost
increase is smaller than for sales and, on average, is not statistically significant. Later we show
that this average effect masks important heterogeneity, with both sales and costs increasing
predominantly in capital intensive industries.
Given sharply increasing sales and only modestly increasing costs, Panel C shows that the
average pre-tax profits of C-corps also increased relative to S-corps, by 2.6 percentage points
(s.e.=0.9). Panel D shows an alternate measure of pre-tax profits, using the harmonized EBITDA
measure, and again reveals a clear increase in the profits of C-corps relative to S-corps. These
results provide initial evidence that firms expanded in response to tax cuts, consistent with the
standard notion that taxes induce economic distortions and may generate deadweight loss.
Columns 1 to 4 of Table 3 show the C × P ost coefficients associated with the event studies in
Figure 4. In column 5, we estimate the elasticity of pre-tax profits with respect to the net-of-tax rate
using equation 4. Scaling the reduced form estimate in column 3 by the first-stage estimate from
column 2 of Table 2 yields an elasticity of 0.38 (s.e.= 0.13).
This elasticity – known as the elasticity of the tax base, or alternately as the elasticity of taxable
income (ETI) is a key parameter in the analysis. As shown by Feldstein (1999) and reviewed by
Saez, Slemrod, and Giertz (2012), under plausible assumptions it is a sufficient statistic that can be
used to estimate the welfare impacts and efficiency costs of tax changes. In general, a larger taxable
income elasticity implies greater deadweight loss, since it implies a larger distortion of economic
activity resulting from the tax.
Our estimate of the federal corporate ETI, 0.38, is on the lower end of corporate elasticities
identified from policy variation in small open economies. For example, Giroud and Rauh (2019)
estimate an elasticity of establishment growth (a proxy for the tax base) of approximately 0.50
with respect to state corporate taxes in the United States; Suárez Serrato and Zidar (2016) estimate
an elasticity of establishment growth of aproximately 0.9 for U.S. state corporate taxes over
an analogous time horizon to ours; and Bachas and Soto (2021) estimate large taxable income
elasticities of 3.0-5.0 for small firms in Costa Rica. On the other hand, our estimate of the corporate
ETI is on the higher end of most existing estimates of the ETI for personal incomes, which Saez,
Slemrod, and Giertz (2012) find in a literature review ranges from approximately 0.14 to 0.40, with
a central estimate of 0.25.
Viewed in the context of other research, we view our corporate ETI estimate as consistent with
20
FIGURE 4: EVENT STUDY: FIRM SALES, COSTS, AND PRE-TAX PROFITS
Panel A: Sales Panel B: Costs
-.02
0
.02
.04
.06
.08
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 1.00
Sales / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
-.02
-.01
0
.01
.02
.03
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.53
Costs / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Panel C: Pre-Tax Profits Panel D: EBITDA
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.47
Pre-Tax Profits / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
-.05
0
.05
.1
.15
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.29
EBITDA / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients estimated from equation 1. These coefficients capture average
differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects. Standard
errors are clustered by firm, and error bands show 95% confidence intervals. Sales are gross receipts. Costs are equal to cost of goods
sold, including both material and labor costs. Pre-tax profits are sales minus costs. EBITDA is a harmonized measure of earnings
before interest, taxes, depreciation, and amoritization; see Section 3 and Appendix B for details.
21
the common economic intuition that tax distortions vary with factor mobility. Firms and workers
are less mobile at the federal level than at the state and local level, mitigating distortions from
the federal corporate tax relative to the state and local corporate tax. However, many forms of
capital are internationally mobile relative to workers (Kotlikoff and Summers 1987), suggesting
that federal taxes on labor income, the primary source of personal income tax revenue, may be less
distorative than the federal corporate tax.
In Section 4.8 we perform extensive robustness checks on our ETI estimate, and in Section 6 we
discuss its significance in the context of the broader national tax and transfer system.
TABLE 3: SALES, COSTS, AND PRE-TAX PROFITS
(1) (2) (3) (4) (5)
Sales Costs Pre-tax π EBITDA Pre-tax π
C × Post 0.036
∗∗
0.010 0.026
∗∗∗
0.080
∗∗∗
(0.015) (0.009) (0.009) (0.011)
ln(1 τ
f
)× Post 0.379
∗∗∗
(0.127)
2016 Outcome Mean 1.00 0.53 0.47 0.29 0.47
Firm FE Yes Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes Yes
R2 0.40 0.65 0.62 0.84 n.a.
N 81,529 81,529 81,529 81,529 81,529
N Firms 11,647 11,647 11,647 11,647 11,647
First-Stage F 409.5
Notes: The unit of analysis is a firm-year. Columns 1-4 show the C × P ost
coefficients from equation 2. These coefficients estimate average differential
changes in outcomes between C- and S-corps before and after TCJA, controlling
for firm and industry-size-year fixed effects. All outcomes are scaled by 2016
baseline sales. Sales are gross receipts. Costs are equal to cost of goods sold,
including both material and labor costs. Pre-tax profits are sales minus costs.
EBITDA is a harmonized measure of earnings before interest, taxes, depreciation,
and amoritization. Column 5 reports the elasticity of pre-tax profits with respect
to the net-of-tax rate, computed by scaling the reduced form outcome in column
3 by the first stage coefficient from column 2 of Table 2. Standard errors are
clustered by firm. For additional information on data sources and variable
definitions see Section 3 and Appendix B.
4.4 After-Tax Profits and Shareholder Payouts
We use the same empirical strategy to evaluate trends in firms’ after-tax profits and payouts to
shareholders. Consistent with the increases in pre-tax profits and decline in tax liability, Panel A of
Figure 5, and Column 1 of Table 4, shows that the after-tax profits of C-corps increased relative to
S-corps following TCJA, by 3.6 percentage points (10.7%; s.e.=0.9). The magnitude of this effect is
22
economically and statistically signficiant, and underscores that tax cuts are highly lucrative to firm
owners. The elasticity of after-tax profits with respect to the net-of-tax rate, estimated in column
4 of Table 4 using equation 4, is 0.52 (s.e.= 0.13). Later, we leverage this elasticity to assess the
incidence of TCJA’s tax cuts on firm owners.
We also find that firms returned some of these excess profits to their shareholders via dividends
and share buybacks, the sum of which we refer to as total shareholders payouts. Because
shareholder payouts are infrequent events (approximately half of the payout observations in our
sample are zero), we study both the extensive and intensive margins. The outcome in Panel B of
Figure 5 is equal to one if total payouts are greater than zero (that is, the extensive margin), and
shows an increase of 4.0 percentage points (s.e.=0.8) in the payout probability of C-corps relative
to S-corps following TCJA. In Panel C we show the intensive margin, where the outcome is log
total payouts, and find that payouts of C-corps relative to S-corps increase by 21.9% (s.e.=5.0).
Consistent with this increase in shareholder payouts, in Appendix C.1 we find that C-corps do not
increase their issuance of equity or debt relative to S-corps after TCJA. The results are consistent
because, if firms need external financing to fund operations, they generally do not simulatenously
distribute cash to shareholders.
Overall, the results from Figure 5 and Table 4 provide evidence that firm owners bear a
substantial portion of the short-run economic incidence of the corporate income tax.
4.5 Labor Market Outcomes and Executive Pay
We again use equation 1 to examine the labor market outcomes of workers at C- and S-corps
before and after TCJA. Figure 6 shows the results from estimating equation 1 to assess trends in
log employment, total payroll, and annual earnings for selected groups of workers.
Figure 6 shows that the labor market outcomes of C- and S-corps followed similar trends prior
to TCJA. After TCJA, employment in C-corps increased modestly relative to S-corps, by 0.4%
(s.e.=0.8) on average, but the difference is not statistically distinguishable from zero. Total payrolls,
shown in Panel B, also increased modestly in C-corps relative to S-corps, by 1.2% (s.e.=0.8), and
again the difference is not statistically significant. However, later we show that these average
effects mask important heterogeneity across firms.
Panels C and D move beyond total payrolls to shed light on the distributional impacts of TCJA
on workers’ earnings. Panel C shows that the earnings of the median worker at the firm evolved
similarly for both C- and S-corps over the entire sample period, and implies that corporate tax
cuts did not have a statistically significant effect on earnings for the typical worker. By contrast,
Panels D shows that the earnings of higher-income C-corp workers increased sharply relative to
their counterparts in S-corps.
To more comprehensively evaluate the effects of TCJA on the distribution of workers’ earnings,
we estimate quantile regression specifications of equation 1, where the outcome y
ft
(p) is log annual
earnings of workers in firm f and year t at centile p. For example, y
ft
(p = 50) uses log median
earnings as the outcome, as shown in Panel C of Figure 6, and y
ft
(p = 99) uses the 99th percentile
23
FIGURE 5: EVENT STUDY: AFTER-TAX PROFITS AND SHAREHOLDER PAYOUTS
Panel A: After-Tax Profits
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.41
After-Tax Profits / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Panel B: Shareholder Payouts (Extensive Margin)
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.54
Shareholder Payouts (0/1)
Difference Between C-Corps and S-Corps Over Time
Panel C: Shareholder Payouts (Intensive Margin)
-.1
0
.1
.2
.3
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 1.45
Log Shareholder Payouts
Difference Between C-Corps and S-Corps Over Time
Notes: The unit of analysis is a firm-year. The panels plot the β
t
coefficients estimated from equation 1. These coefficients capture
average differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects.
Standard errors are clustered by firm and error bands show 95% confidence intervals. In Panel A, after-tax profits are defined as
pre-tax profits minus tax, and are scaled by 2016 baseline sales. In Panel B, the outcome is an indicator equal to 1 if shareholder
payouts are positive (i.e., the extensive margin), where payouts are defined as the sum of cash and property distributions to
shareholders. In Panel C, the outcome is log shareholder payouts (i.e., the intensive margin). For additional information on data
sources and variable definitions see Section 3 and Appendix B.
24
TABLE 4: AFTER-TAX PROFITS AND SHAREHOLDER PAYOUTS
(1) (2) (3) (4)
Post-Tax π Payouts (0/1) Log Payouts Post-Tax π
C × Post 0.036
∗∗∗
0.034
∗∗∗
0.246
∗∗∗
(0.009) (0.006) (0.034)
ln(1 τ
f
)× Post 0.521
∗∗∗
(0.129)
2016 Outcome Mean 0.41 0.54 1.45 0.41
Firm FE Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes
R2 0.69 0.76 0.86 n.a.
N 81,529 81,529 81,529 81,529
N Firms 11,647 11,647 11,647 11,647
First-Stage F 409.5
Notes: The unit of analysis is firm-year. Columns 1-3 show the C × P ost
coefficients from equation 2. These coefficients estimate average differential changes
in outcomes between C- and S-corps before and after TCJA, controlling for firm and
industry-size-year fixed effects. After-tax profits are defined as pre-tax profits minus
tax, and are scaled by 2016 baseline sales. In column 2, the outcome is an indicator
equal to 1 if shareholder payouts are positive (i.e., the extensive margin), where
payouts are defined as the sum of cash and property distributions to shareholders. In
column 3 the outcome is log shareholder payouts (i.e., the intensive margin). Column
4 reports the elasticity of after-tax profits with respect to the net-of-tax rate, computed
as in equation 4. Standard errors are clustered by firm. For additional information on
data sources and variable definitions see Section 3 and Appendix B.
25
of log worker earnings as the outcome, as in Panel D.
Figure 7 plots the β
2019
coefficients from these quantile regressions along with their
corresponding 95% confidence invervals. The figure shows that the relative earnings of workers
in C- and S-corps below the 90th percentile are statistically identical following TCJA; we cannot
reject that the coefficients are statistically distinguishable from zero.
However, Figure 7 reveals a very different pattern for workers in the top 10% of the earnings
distribution. Workers in C-corps at the 90th percentile of the within-firm distribution see their
relative earnings increase by 1.0% (s.e.=0.3), and these impacts grow steadily larger and statistically
sharper further up the distribution. At the 95th percentile, we estimate a relative earnings increase
of 1.2% (s.e.=0.4) for C-corp workers, and this magnitude climbs to 4.5% (s.e.=0.8) at the 99th
percentile.
We further assess the impacts of MTR cuts on executive pay. Figure 8 estimates equation 1 using
as outcomes log officer compensation (observed on IRS Forms 1120 and 1120s) and a proxy variable
constructed as the log mean earnings of the top five highest-paid workers at the firm (observed
from IRS Form W2). In Panel A, we estimate that the relative earnings of executives increased
by 4.6% (s.e.=1.2) at C-corps relative to S-corps, and in Panel B we estimate a quantitatively
comparable effect for the earnings of the top 5 highest paid workers at the firm of 4.0% (s.e.=0.8).
Because the tax data do not allow us to observe all components of executive compensation, such
as awarded bu unvested stock grants, these estimates likely represent a lower bound on the effects
of TCJA on executive pay. The fact that executive earnings increase in 2017, before TCJA fully took
effect, is consistent with firms intertemporally shifting forward executive compensation, perhaps
in the form of bonuses, so that these costs could be deducted at a higher tax rate prior to the
corporate rate cut beginning in 2018.
Panel A of Table 5 reports the C × P ost coefficients from equation 2, as well as the dependent
variable means in the baseline year and implied elaticities with respect to the net-of-tax rate. For
workers at the 95th percentile, we estimate an earnings elasticity of 0.18% (s.e.=0.05), and for
executives we estimate a larger earnings elasticity of 0.64% (s.e.=0.17). The mean baseline earnings
of these workers and executives are high: the average worker in the sample at the 95th percentile
of the within-firm distribution earns $157,639 per year, the average worker in the top five earns
$1,186,758 per year, and the average annual combined earnings of firm executives is $6,283,969.
Applying the baseline sample levels, the average firm net-of-tax-rate change in the sample, and
the estimated net-of-tax elasticity, the results imply that average combined executive earnings
increased by approximately $270,000 per year. Similar computations yield that average earnings
for workers at the 95th percentile increased by approximately $1,900 per year, and that earnings
changes for workers below the 90th percentile are statistically indistinguishable from zero.
What drives the sharp increases in executive pay? The coinciding increases in the sales, pre-tax
and after-tax profits, and investment of C-corps compared to S-corps suggest there is plausible
scope for managerial decisionmaking and effort to drive increased firm productivity. Moreover, in
some cases firm owners may incentivize managerial effort by explicitly compensating executives
26
FIGURE 6: EVENT STUDIES: LABOR MARKET OUTCOMES
Panel A: Log Employment Panel B: Log Payroll
-.02
-.01
0
.01
.02
.03
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 2,969
Difference Between C-Corps and S-Corps Over Time
-.04
-.02
0
.02
.04
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 173
Difference Between C-Corps and S-Corps Over Time
Panel C: Log Median Earnings Panel D: Log 99th Centile Earnings
-.03
-.02
-.01
0
.01
.02
.03
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 46,278
Difference Between C-Corps and S-Corps Over Time
-.04
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 371,861
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients estimated from equation 1. These coefficients capture average
differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects. Standard
errors are clustered by firm and error bands show 95% confidence intervals. Employment, payrolls, and annual earnings are
computed by matching worker-level W-2’s with firm-level tax returns. For additional details on data sources and variable definitions
see Section 3.
27
FIGURE 7: EARNINGS QUANTILE REGRESSIONS
β
2019
-.02
0
.02
.04
.06
.08
20 40 60 80 100
Firm Wage Centile
Notes: Unit of analysis is firm-year. Figure plots the β
2019
coefficients from equation 1, where the outcomes are centiles of the
distribution of workers’ wages within the firm. For example, centile 50 measures the annual earnings of the median worker within
the firm, and centile 90 captures the annual earnings of the worker at the 90th percentile of the within-firm earnings distribution. For
additional details on data sources and variable definitions, see Section 3. Standard errors are clustered by firm and error bands show
95% confidence intervals.
28
FIGURE 8: EVENT STUDIES: EXECUTIVE PAY
Panel A: Log Officer Compensation
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 6,283,969
Difference Between C-Corps and S-Corps Over Time
Panel B: Log Top 5 Earnings
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 1,186,758
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients estimated from equation 1. These coefficients capture average
differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects. Standard
errors are clustered by firm and error bands show 95% confidence intervals. The right panels are constructed such that the distance
between the C-corp and S-corp lines in each year is equal to the corresponding β
t
coefficient in the left panel, and such that the
observation-weighted average of the two lines is equal to the unweighted sample average of the outcome in each year. For data
sources and variable definitions see Section 3.
29
TABLE 5: LABOR MARKET OUTCOMES
Panel A: Labor Market Outcomes
(1) (2) (3) (4) (5) (6) (7) (8)
Emp Payroll p50 p90 p95 p99 Top5 Executives
C × Post 0.004 0.012 -0.000 0.010
∗∗∗
0.012
∗∗∗
0.045
∗∗∗
0.040
∗∗∗
0.046
∗∗∗
(0.008) (0.008) (0.004) (0.003) (0.004) (0.008) (0.008) (0.012)
2016 Outcome Mean 2,969 173 46,278 113,848 157,639 371,861 1,186,758 6,283,969
ε
NT R
0.05 0.18 -0.00 0.14 0.18 0.64 0.59 0.64
s.e. 0.12 0.11 0.05 0.05 0.05 0.12 0.12 0.17
Firm FE Yes Yes Yes Yes Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes Yes Yes Yes Yes
R2 0.97 0.97 0.95 0.96 0.95 0.88 0.92 0.92
N 81,529 81,529 81,529 81,529 81,529 81,529 81,529 72,400
N Firms 11,647 11,647 11,647 11,647 11,647 11,647 11,647 10,680
Panel B: Executive Compensation
Outcome is log executive pay
Controls for:
Benchmark Sales Profits Relative Sales
C × Post 0.046
∗∗∗
0.041
∗∗∗
0.041
∗∗∗
0.042
∗∗∗
(0.012) (0.012) (0.012) (0.012)
Firm FE Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes
R2 0.92 0.92 0.92 0.92
N 72,400 72,400 72,400 72,198
NF 10,680 10,680 10,680 10,678
Panel C: Worker Characteristics
Bottom 90% Top 10% Executives
Mean Wage (2016) 39,688 175,957 1,063,511
Female (Share) 0.45 0.30 0.12
Age (Years) 39.5 46.7 53.5
Firm Tenure (Years) 4.2 5.7 6.0
N Workers 32,386,875 3,924,113 72,117
Notes: Unit of analysis is firm-year. Panel A reports results the C × P ost coefficients obtained from estimating equation 2, where the
outcomes are log employment, log payroll, log annual earnings of workers at various centiles of the within-firm income distribution,
log mean earnings of the top 5 highest paid workers at the firm, and log executive compensation. These coefficients estimate average
differential changes in outcomes between C- and S-corps before and after TCJA, controlling for firm and industry-size-year fixed
effects. Panel B estimates variations of equation 2 where the outcome is log executive compensation, and adds time-varying controls
for several measures of firm performance. Standard errors in Panels A and B are clustered by firm. Panel C presents descriptive
statistics for the individual characteristics of workers in the bottom 90% of the distribution, in the top 10%, and of the top five highest
paid workers, where we use the latter as a proxy for executives.
30
on the basis of firm performance metrics (e.g., Bebchuk and Fried 2003; Murphy 1999; Jensen and
Murphy 1990). On the other hand, to the extent that executives have significant bargaining power
vis-a-vis shareholders, they may be in a position to extract a portion of after-tax profits even in the
absence of improvements in managerial productivity.
In Panel B of Table 5 we perform a series of empirical tests developed by Ohrn (2022) to evaluate
the relevance of these competing mechanisms, which are not necessarily mutually exclusive. The
outcome in all columns is log officer compensation as reported on Forms 1120 and 1120s. The
first column shows the benchmark specification given by equation 2. In the remaining columns,
we respectively add controls for three measures of firm performance: sales growth, profit growth,
and sales growth relative to other firms in the same industry.
8
To the extent that executive pay is
correlated with these performance metrics, we may expect the C × P ost coefficient to shrink as we
add the controls.
The results in columns 2-4 show that the C × P ost coefficient on executive pay shrinks only
modestly as we add controls for the firm performance metrics. The benchmark estimate of 4.6%
declines to a minimum of 4.1% when we add controls for sales growth, and shrinks by a similar
amount when controlling for profit growth or sales growth relative to other firms in the same
industry. Taken at face value, a plausible estimate is that 1-(4.1/4.6)10% of the increase in
executive pay is plausibly attributable to improved firm performance, while the remaining 90%
may reflect rent-sharing mechanisms. The results are similar when we use our proxy measure of
executive pay, reported in Appendix C.2.
These tests are not dispositive the econometric problems with conditioning on
post-treatment outcomes are well-known (e.g., Imbens 2020), and increasing managerial
productivity may not be fully reflected in the firm performance metrics over our limited time
horizon but they are suggestive, and give an approximate sense of plausible orders of
magnitude. The results are consistent with empirical evidence from Ohrn (2022), who finds that
executive pay in publicly traded firms is highly responsive to narrowly targeted corporate tax
breaks, and that pay increases are driven by rent-sharing rather than a higher marginal product
of labor. The results are also consistent with Bertrand and Mullainathan (2001), who find that
executives are often rewarded for positive shocks to the firm even if those shocks are clearly
beyond the manager’s control.
To provide additional insight into the distributional impacts of corporate tax cuts on workers’
earnings, Panel C of Table 5 presents descriptive statistics on the individual characteristics of
workers in the bottom 90% of the firm wage distribution, in the top 10% of the firm wage
distribution, and in the group of top five highest paid workers at the firm, which we use a proxy
for identifying executives (we do not directly observe which individuals are executives from Form
W-2). In our sample, 88% of executives are men, and on average these workers are 53 years old,
have worked for their employer for 6 years, and earn over $1 million in annual labor income. By
contrast, just 55% of workers in the bottom 90% of the distribution are men, and these workers on
8
As in Ohrn (2022), another natural performance metric would be earnings per share; however, we do not observe
this information for S-corporations or for private C-corporations.
31
average are 39 years old, have worked for their employer for 4 years, and earn less than $40,000 in
annual labor income.
Collectively, the findings from Table 5 imply that the short-run effects of corporate tax cuts
are regressive, increasing earnings only for workers at the top of the within-firm distribution.
The results also demonstrate that the distributional impacts of corporate tax cuts do not affect all
demographic groups equally; rather, the beneficiares of the tax cuts are disproportionately likely
to be men, to be older, and to have longer tenures at their current employer.
Our results are consistent with a group of studies finding evidence of rent-sharing with
high-income workers in response to tax or producticity shocks (Ohrn 2022; Carbonnier,
Malgouyres, Py, and Urvoy 2022; Dobridge, Landefeld, and Mortenson 2021; Kline, Petkova,
Williams, and Zidar 2019), but are in tension with another group of studies finding that the
incidence of the corporate tax is borne primarily by low-income and marginally attached workers
(Risch 2021; Fuest, Peichl, and Siegloch 2018). Notably, all the former studies finding gains for
high-income workers are identified from tax cuts, whereas the latter studies finding that costs
are borne by low-income workers are identified from tax increases. A plausible reconciliation of
the literature is that tax cuts and tax hikes may have asymmetric labor market effects (see also
discussion in Fuest, Peichl, and Siegloch 2018); we view this hypothesis as a fruitful area for future
research.
In Appendix C.3, we we study whether causal effects vary by demographic characteristics,
and find no evidence of heterogeneous effects after controlling for workers’ initial place in the
income distribution. We will explore additional aspects of heterogeneity in Section 4.7, and return
to broader issues of assesssing the incidence of the corporate income tax in Section 5.
4.6 Investment
Figure 9 shows the results from estimating equation 1 to assess relative trends in real net
investment of C- and S-corps. As with shareholder payouts, investment is a statistically volatile
outcome, and so we investigate both the extensive and intensive margin responses. In Panel A, the
outcome is an indicator equal to one if net investment is positive (that is, the extensive margin),
where net investment is defined as the change in book value of depreciable capital assets less
accumulated book depreciation. In any given year, net investment is negative for approximately
half the firms in our sample. The figure shows that C- and S-corps have similar trends in this
outcome over the pre-period, but after TCJA positive net investment among C-corps increases by
approximately 2.2 percentage points (s.e.=0.9) relative to S-corps.
On the intensive margin, Panel B of Figure 9 shows trends in the investment rate, defined as
net investment scaled by the lagged capital stock. We find that C-corps increase net investment
by 3.5% (s.e.=0.9) relative to S-corps after TCJA. For consistency with other previously reported
outcomes, in Panel C we also show net investment scaled by baseline 2016 sales. The figure again
shows that investment of C-corps increases relative to S-corps, by approximately 0.8 percentage
points (s.e.=0.5). In Appendix C.3, we provide additional results on investment using alternate
32
measures.
The elasticity of investment may have implications for economic growth (e.g., Romer and
Romer 2010) and, in our setting, has direct implications for assessing the incidence of the corporate
tax on capital suppliers (e.g., as in Goolsbee 1998). In column 4 of Table 6, we estimate an
investment elasticity of 0.52 (s.e.=0.08), implying that a 1% increase in the net-of-tax rate causes an
approximately 0.52% increase in investment. Later, we also estimate the elasticity of investment
with respect to the cost of capital. Before doing so, however we must first investigate whether
changes in investment are driven by changes in the cost of capital, as in a standard model, or
by others channels such as liquidity effects. We thus turn now to a battery of heterogeneity and
robustness tests, and then turn to an explicit discussion of mechanisms.
4.7 Firm Heterogeneity
Figure 10 presents our benchmark difference-in-difference estimates (i.e., the C × P ost coefficients
and 95% confidence intervals from equation 2) across several dimensions of firm heterogeneity,
focusing on the following outcomes: pre-tax profits, costs, employment, payroll, and net
investment. We focus on these outcomes due to their natural relevance in assessing whether our
estimates are driven by changes real economic activity or by tax and profit shifting behaviors by
firms; we also present results on other outcomes in Appendix C.5.
Existing research has emphasized that the effects of tax changes may vary by firm size (where
smaller firms may be better able to engage in tax shifting, as in Giroud and Rauh 2019); by liquidity
(where low-cash firms may face borrowing constraints and thus respond more elastically to tax
changes, as in Zwick and Mahon 2017 and Saez, Schoefer, and Seim 2019); by factor intensity
(where capital-intensive firms may be most responsive to a shock, as in Acemoglu and Guerrieri
2008); by firm profitability (where highly profitable firms may be managed more effectively, as
suggested by Bloom and Van Reenen 2007); by unionization rates (where highly unionized firms
may reduce firms’ profits and investment, as studied in Card, Devicienti, and Maida 2014); and by
industry concentration (where highly concentrated firms may be better able to pass the costs of tax
increases to their input suppliers, as in Fuest, Peichl, and Siegloch 2018 and Juarez 2022).
Here we focus on heterogeneity across the first three of these characteristics firm size,
liquidity, and capital intensity and report additional heterogeneity tests in Appendix C.5. Firm
size is defined using the the pre-TCJA employment bins used in our main analysis, although here
we exclude very large firms (defined as those with greater than $1 billion in sales or greater 10,000
employees in 2016) to ensure that results in the largest firm size bin are not driven by C-corps with
no comparably sized S-corps. We measure cash as the sum of the firm’s liquid assets, and classify
firms as high-cash if their average cash-to-assets ratio in the pre-period is greater than the median
value for the sample. Capital intensity is defined as in Section 3.3.
When we test for heterogeneity across firm size we include only industry-year fixed effects in
our regression specifications; for all other specifications we include industry-size-year fixed effects.
To obtain the point estimates in Figure 10 we run the model separately for each subsample of firms.
33
FIGURE 9: EVENT STUDIES: NET INVESTMENT
Panel A: Positive Net Investment (0/1)
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.52
Positive Net Investment (0/1)
Difference Between C-Corps and S-Corps Over Time
Panel B: Net Investment / Lagged Capital
-.02
0
.02
.04
.06
.08
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.06
Net Investment / Lagged Capital
Difference Between C-Corps and S-Corps Over Time
Panel C: Net Investment / 2016 Sales
-.01
0
.01
.02
2013 2014 2015 2016 2017 2018 2019
2016 Outcome Mean: 0.01
Net Investment / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The figure plots the β
t
coefficients estimated from equation 1. These coefficients capture average
differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects. Standard
errors are clustered by firm and error bands show 95% confidence intervals. Net investment is defined as the change in book value of
depreciable capital assets minus accumulated book depreciation. The outcome in Panel A is an indicator equal to 1 if net investment
is positive. The outcomes in Panels B and C, are net investment scaled by lagged capital and by baseline 2016 sales, respectively. For
data sources and variable definitions see Section 3.
34
TABLE 6: NET INVESTMENT
(1) (2) (3) (4)
I
t
> 0 I
t
/K
t1
I
t
/Sales
2016
I
t
/K
t1
C × Post 0.022
∗∗
0.035
∗∗∗
0.008
∗∗∗
(0.009) (0.005) (0.003)
ln(1 τ
f
)× Post 0.515
∗∗∗
(0.082)
2016 Outcome Mean 0.52 0.06 0.01 0.06
Firm FE Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes
R2 0.29 0.22 0.26 n.a.
N 81,529 81,529 81,529 81,529
N Firms 11,647 11,647 11,647 11,647
First-Stage F 403.8
Notes: The unit of analysis is a firm-year. Columns 1-3 report the C ×
P ost coefficients from equation 2. These coefficients estimate average
differential changes in outcomes between C- and S-corps before and after
TCJA, controlling for firm and industry-size-year fixed effects. Standard
errors are clustered by firm. Net investment is defined as the change
in book value of depreciable capital assets minus accumulated book
depreciation. The outcome in column 1 is an indicator equal to 1 if net
investment is positive. The outcomes in columns 2 and 3 are net investment
scaled by lagged capital and by baseline 2016 sales, respectively. Column
4 reports the elasticity of net investment with respect to the net-of-tax rate,
computed from equation 4.
35
FIGURE 10: FIRM HETEROGENEITY
Panel A Panel B
All
100-199 Emp
200-499 Emp
500-999 Emp
1K-10K Emp
Low Cash
High Cash
Capital Intensive
Not Capital Intensive
Firm Size
Liquidity
Production
-.05 0 .05 .1
Pre-Tax Profits
All
100-199 Emp
200-499 Emp
500-999 Emp
1K-10K Emp
Low Cash
High Cash
Capital Intensive
Not Capital Intensive
Firm Size
Liquidity
Production
-.1 -.05 0 .05 .1
Costs
Panel C Panel D
All
100-199 Emp
200-499 Emp
500-999 Emp
1K-10K Emp
Low Cash
High Cash
Capital Intensive
Not Capital Intensive
Firm Size
Liquidity
Production
-.05 0 .05 .1
Log Employment
All
100-199 Emp
200-499 Emp
500-999 Emp
1K-10K Emp
Low Cash
High Cash
Capital Intensive
Not Capital Intensive
Firm Size
Liquidity
Production
-.05 0 .05 .1
Log Payroll
Panel E Panel F
All
100-199 Emp
200-499 Emp
500-999 Emp
1K-10K Emp
Low Cash
High Cash
Capital Intensive
Not Capital Intensive
Firm Size
Liquidity
Production
-.05 0 .05 .1
Positive Net Investment (0/1)
All
100-199 Emp
200-499 Emp
500-999 Emp
1K-10K Emp
Low Cash
High Cash
Capital Intensive
Not Capital Intensive
Firm Size
Liquidity
Production
0 .02 .04 .06 .08
Net Investment / Lagged Capital
Notes: The unit of analysis is a firm-year. The table shows the C × P ost coefficients from equation 2. These coefficients estimate
average differential changes in outcomes between C- and S-corps before and after TCJA, controlling for firm and industry-size-year
fixed effects. Standard errors are clustered by firm.
36
Looking across the outcomes in Figure 10, we find no clear pattern with respect to firm size.
With respect to liquidity, we similarly do not find statistically significant differences between high-
and low-cash firms; although, taking the point estimates at face value, the results suggest that
high-cash firms are if anything weakly more responsive than low-cash firms in our sample. These
results contrast with Zwick and Mahon (2017), who find that small and financially-constrained
firms are most likely to increase investment and payrolls in response to bonus depreciation
incentives. While we find that smaller firms have larger point estimates than larger firms, these
differences are not statistically significant.
Several factors may explain why our findings differ from Zwick and Mahon (2017). First,
Zwick and Mahon study countercyclical policies enacted during U.S. recessions, when financial
constraints are most likely to be binding. By contrast, TCJA was enacted during a long
macroeconomic expansion with low interest rates and favorable financial conditions. Second,
Zwick and Mahon find that responses are largest for the smallest firms in their sample. By
contrast, our sample includes only medium-to-large sized firms. Finally, Zwick and Mahon use
an identification strategy that exploits cross-industry exposure to bonus depreciation incentives.
By contrast, our identification strategy exploits within-industry variation in tax policy, and as such
our industry-size-year fixed effects may absorb any time-varying policy impacts that affect both
C- and S-corps similarly.
Although policy impacts do not appear to vary with firm size or liquidity, Figure 10 shows
evidence that they do appear to vary with capital intensity. C-corps in capital intensive industries
are much more likely than comparable S-corps to increase their pre-tax profits, costs, employment,
and total payrolls in the years following TCJA, and the differences are both economically and
statistically significant. The evidence also suggests that capital-intensive C-corps are somewhat
more likely than comparable S-corps to increase investment, although the differences are not
statistically significant. The fact that the investment responses for these firms are similar, even
while the profit and cost elasticities are larger, suggests that the elasticity of output with respect to
capital inputs is likely larger in capital intensive industries, as in Acemoglu and Guerrieri (2008).
In Appendix C.5 we show the full event studies separately for capital-intensive and
non-capital-intensive firms, and present additional heterogeneity tests. In general, we do not
find clear evidence that policy effects vary with firm profitability, unionization rates, or market
concentration.
4.8 Robustness
Having presented the main results, we turn now to assessing their robustness and to addressing
potential threats to our identification strategy. The identifiying assumption underlying our
elasticity estimation strategy is that the outcomes of C- and S-corps would have trended similarly
in the absence of TCJA’s marginal income tax rate cuts. While this assumption is not directly
testable, the event studies above show that C- and S-corps followed broadly similar trends prior
to TCJA, lending support to its plausibility. However, if the differential tax cuts affecting C-
37
and S-corps following TCJA are correlated with simultaneous supply or demand shocks for
example, due to other provisions of the legislation or external events differentially affecting C-
and S-corps then our causal estimates would be biased. To address concerns about robustness
and identification, we present specifications with alternate controls and samples, and explicitly
consider how other provisions of TCJA, unrelated external events, anticipation effects, and
tax-shifting behaviors may affect our analysis.
Alternate Specifications
Row 1 of Table 7 reports the key net-of-tax elasticities obtained from estimating equation 1
using our benchmark specification. We focus on the outcomes that will serve as key inputs
into the model quantification: pre- and after-tax profits; the earnings of executive and high- and
low-paid workers; and net investment. In the remaining rows, we examine the sensitivity of these
estimates to alternate modeling choices. Unless otherwise noted, all specifications include firm
and industry-size-year fixed effects.
In row 2 we control for cohort-by-year fixed effects, where cohorts are defined using the
firms’ year of incorporation. This specification implies that the elasticities are identified from
comparisons of C- and S-corps that are the same age.
In row 3 we controls for state-by-year fixed effects, where a firm’s state is defined using the
address reported on Form 1120 or 1120s. In practice, the operations of large or exporting firms may
span many states. Therefore, this specification controls for location-specific trends to the extent
that firm performance is influenced by time-varying shocks associated with the firm’s reported tax
address.
Although we do not observe any systematic evidence that C- and S-corps were on different
trends prior to TCJA, in row 4 we nevertheless probe the sensitivity of the estimates to adding
pre-trend controls. Specifically, we control for lagged outcomes in 2013, 2014, 2015, and 2016, and
interact each of the lagged outcomes with year indicators.
In row 5 we show the results using a log transformation of the outcome. These specifications
implicity exclude observations in which the outcome is zero or negative. For outcomes where the
benchmark specificaiton was already logged, the results are the same as in row 1.
In column 6, we winsorize the outcomes at the 5th and 95th percentiles. These specifications
provide information about the extent to which the estimates are driven by changes in outcomes at
the tails of the outcome distribution.
In general, the elasticity estimates across all specifications and outcomes are stable and within
the 95% confidence interval of the benchmark specification in row 1.
38
TABLE 7: ROBUSTNESS TO ALTERNATE SPECIFICATIONS
(1) (2) (3) (4) (5) (6)
ε
B
ε
π
ε
w
p50
ε
w
p95
ε
w
exec
ε
I
Specification Pre-Tax π After-Tax π p50 w p95 w Exec w I
t
/K
t1
1. Benchmark 0.379 0.521 -0.001 0.176 0.639 0.515
(0.127) (0.129) (0.052) (0.053) (0.169) (0.082)
2. Age Controls 0.247 0.397 -0.010 0.150 0.468 0.519
(0.119) (0.122) (0.050) (0.050) (0.161) (0.078)
3. Location Controls 0.361 0.502 -0.016 0.165 0.685 0.486
(0.130) (0.132) (0.052) (0.053) (0.168) (0.081)
4. Pre-Trend Controls 0.434 0.471 0.091 0.262 1.103 0.535
(0.117) (0.121) (0.048) (0.050) (0.172) (0.075)
5. Log Outcome 0.234 0.372 -0.001 0.176 0.639 0.790
(0.136) (0.137) (0.052) (0.053) (0.169) (0.452)
6. Winsorize 5-95 0.257 0.279 -0.009 0.148 0.761 0.302
(0.051) (0.050) (0.041) (0.043) (0.150) (0.066)
The table shows net-of-tax elasticities for key outcomes estimated from variations on equation 4. Unless otherwise
indicated, all specifications include firm and industry-size-year fixed effects. The outcomes in columns 1 and 2 are
scaled by baseline 2016 sales, the outcomes in columns 3-5 are logged, and the outcome in column 6 is scaled by lagged
capital. Row 1 shows the benchmark specification. Row 2 controls for firm age by including cohort-by-year effects,
where cohorts are defined as the firms’ year of incorporation. Row 3 controls for state-by-year fixed effects, using the
firm’s reported address on its tax return. Row 4 controls for pre-trends, interacting the lagged pre-TJCA outcomes with
year indicators. Row 5 shows a log transformation of the outcome rather than scaling by baseline sales; four columns
3-5, the results are the same as in row 1. Row 6 winsorizes the outcomes at the 5th and 95th percentiles. Standard
errors clustered by firm.
Alternate Samples
Table 7 shows robustness results for the same key elasticities using alternate samples. Row 2
excludes firms with 2016 sales greater than $1 billion or 2016 employment greater than 10,000.
This sample restriction effectively excludes C-corps that are larger than the largest S-corps. Row 3
excludes “mismatched” industries, defined as those in which C-corps account for greater than 80%
or less than 20% of the firms in the sample. Row 4 excludes manufacturing firms, which may have
been more affected, for example, by the US-China trade war that ocurred during our sample period
(Fajgelbaum, Goldberg, Kennedy, and Khandelwal 2020). In all the samples, the magnitudes are
broadly similar to the benchmark specification.
39
Other Provisions of TCJA
Beyond reducing marginal corporate income tax rates, TCJA also introduced several new policies
affecting various business tax deductions, the taxation of foreign business income, and capital
investment incentives. To assess the extent to which our estimates may be driven by these policy
changes rather than by the rate cuts, below we briefly summarize the major provisions of TCJA
affecting corporations, and then present several additional robustness checks. For more details on
these reforms, see Auerbach (2018) and Joint Committee on Taxation (2018).
Net Operating Loss (NOL) Deductions: TCJA limited NOL deductions to 80% of a
corporation’s taxable income, eliminated NOL carrybacks, and allowed indefinite NOL
carryforwards.
Domestic Production Activities Deduction (DPAD): TCJA repealed DPAD, which provided
a tax deduction to corporations that produce manufactured goods within the United States.
Alternative Minimum Tax (AMT): TCJA repealed the corporate AMT, which imposed
a minimum tax of 20% on corporations’ relevant taxable income in excess of a $40,000
exemption threshold, excluding the firm’s AMT foreign tax credit.
Interest Deductions: TCJA limited the interest payment deductions to 30% of adjusted
taxable income.
Bonus Depreciation: TCJA temporarily allowed corporations to immediately deduct 100%
of the cost of newly purchased eligible capital investments (known as “full expensing”), an
increase from 50% prior to TCJA, but scheduled to phase out beginning in 2023.
Taxation of Foreign Income: TCJA introduced several changes to taxation of corporations’
income earned abroad. The most significant changes include: (a) a one-time tax on
previously accumulated foreign income and an elimination of tax on repatriated income;
(b) a minimum tax on foreign income above a threshold return on tangible assets (known
as Global Intangible Low-Taxed Income, or GILTI); (c) a minimum tax on deductible
related-party transactions to U.S. subsidiaries known as the Base Erosion and Anti-Abuse
Tax, or BEAT); and (d) a lower tax rate on income earned from foreign sales, known as
Foreign Derived Intangible Income, or FDII).
Ex-ante, it may seem unlikely that these other provisions would drive our results, for two
reasons. First, because TCJA’s non-rate policy changes broadly applied to both C- and S-Corps,
our difference-in-difference design implicitly controls for them to the extent that C- and S-corps
were similarly affected. Second, the legislative budget scoring report by the Congressional Joint
Committee on Taxation (2017) projected that the rate cuts would do more than any other business
tax provision of TCJA to reduce tax revenues, making those rate cuts natural suspects.
Neverthless, these considerations do not rule out that other provisions of TCJA may affect our
estimates. For example, if C- and S-corps were differentially exposed to these policy changes for
40
example, perhaps because C-corps are more likely to earn foreign income than S-corps and thus
more likely to be affected by the international provisions — then our net-of-tax elasticities may be
biased. In the case of bonus depreciation, theory suggests that the effect of the tax rate may interact
with the expensing rate; we discuss this possibility in greater detail in Section 4.9.
To assess the sensitivity of our estimates to alternate policy changes, in rows 5 to 9 of Table
8 we implement a series of additional robustness tests in which we exclude the firms most likely
to be affected by each respective provision of TCJA. In row 5, we exclude industries where net
operating losses are most common, defined as those where the share of firms reporting a loss
in the pre-period is greater than the sample median. We similarly define and exclude industries
where firms were most likely to claim the DPAD deduction (row 6) or exceed the interest limitation
threshold (row 7). In row 8 we exclude industries where firms were most exposed to changes in
bonus depreciation, defined as those where the ratio of bonus-eligible investment to sales is greater
than the sample median in the pre-period, and in row 9 we exclude the multinational firms in our
sample. Across the different samples, the results remain within the confidence interval of the
benchmark estimates in row 1.
Anticipation Effects
If businesses expected the federal government to cut corporate taxes long before TCJA was
formally enacted, they may have adjusted their behavior in anticipation of actual policy changes.
In that case, a naive empirical strategy that compares outcomes of firms before and after TCJA
risks underestimating the absolute magnitude of treatment effects, since a portion of the treatment
effects would be captured in the pre-period data.
However, a careful consideration of the legislative history of TCJA suggests that anticipation
effects are unlikely to bias our elasticity estimates. Pre-election polling and betting market spreads,
as well as post-election stock market responses and media coverage, indicated that the November
2016 federal election outcome was difficult to predict and largely unexpected by the public.
9
Because members of the two major U.S. political parties generally have different preferences
over business tax policy, the fact that the election was widely unexpected implies that firms and
workers could not have significantly adjusted their behavior long in advance of TCJA. While it is
possible that our empirical results may capture some anticipations effects during 2017 while policy
negotiations were ongoing, in Appendix C.7 we report elasticity esimates based on changes in
outcomes between 2016 and 2019 where the former is long before the legislative details of TCJA
were promulgated and the results are similar. Moreover, because our difference-in-difference
design compares relative changes in the trends of C- and S-corps, any anticipatory responses prior
to 2017 affecting all firms are absorbed in our industry-size-year fixed effects.
9
For pre-election polling, see a composite of surveys compiled by Real Clear Politics here. For betting spreads, see
time series data from PredictIt here. For examples of media coverage, see here. For stock market responses, see here.
41
TABLE 8: ROBUSTNESS TO ALTERNATE SAMPLES
(1) (2) (3) (4) (5) (6)
ε
B
ε
π
ε
w
p50
ε
w
p95
ε
w
exec
ε
I
Sample Pre-Tax π After-Tax π p50 w p95 w Exec w I
t
/K
t1
1. All Firms 0.379 0.521 -0.001 0.177 0.645 0.516
(0.127) (0.129) (0.052) (0.053) (0.169) (0.082)
2. Exclude Large C-Corps 0.376 0.540 0.021 0.207 0.778 0.547
(0.142) (0.144) (0.056) (0.058) (0.178) (0.089)
3. Exclude Mismatch Industries 0.277 0.435 0.002 0.149 0.529 0.523
(0.132) (0.134) (0.054) (0.053) (0.173) (0.085)
4. Exclude Mfg Industries 0.344 0.545 0.093 0.245 0.814 0.618
(0.149) (0.152) (0.069) (0.068) (0.222) (0.109)
5. Exclude NOL Industries 0.213 0.390 -0.023 0.097 0.353 0.319
(0.138) (0.143) (0.051) (0.056) (0.176) (0.083)
6. Exclude DPAD Industries 0.244 0.495 0.123 0.170 0.640 0.608
(0.168) (0.173) (0.076) (0.074) (0.238) (0.119)
7. Exclude High-Debt Industries 0.789 1.120 0.077 0.474 0.918 0.813
(0.243) (0.252) (0.090) (0.106) (0.309) (0.166)
8. Exclude Bonus Industries 0.320 0.364 0.078 0.208 0.697 0.559
(0.135) (0.134) (0.071) (0.074) (0.241) (0.119)
9. Exclude Multinationals 0.221 0.406 0.012 0.217 0.773 0.575
(0.116) (0.118) (0.056) (0.059) (0.187) (0.093)
10. Exclude Small Firms 0.442 0.601 0.022 0.186 0.644 0.452
(0.163) (0.165) (0.062) (0.060) (0.203) (0.093)
11. Exclude Single-Owner S-Corps 0.378 0.478 0.008 0.162 0.640 0.477
(0.122) (0.124) (0.050) (0.052) (0.162) (0.079)
The table shows net-of-tax elasticities for key outcomes estimated from equation 4 using alternate samples. All
specifications include firm and industry-size-year fixed effects. The outcomes in columns 1 and 2 are scaled by baseline
2016 sales, the outcomes in columns 3-5 are logged, and the outcome in column 6 is scaled by lagged capital. Row 1
shows the benchmark specification. Row 2 excludes firms with 2016 employment of greater than 10,000 or 2016 sales
greater than $1 billion. Row 3 excludes industries where the firm share of C-corps is less than 20% or greater than 80%.
Row 4 excludes manufacturing industries. Row 5 excludes industries where net operating losses are most common in
the pre-period. Row 6 excludes industries most likely to claim the Domestic Production Activities Deduction in the
pre-period. Row 7 excludes industries where firms are highly leveraged. Row 8 excludes industries most likely to
claim bonus depreciation. Row 9 excludes multinational firms. Row 10 excludes firms with fewer than 199 employees,
in our smallest firm-size bin. Row 11 excludes S-corps with only a single owner.
42
Tax Shifting and Evasion
Tax-shifting behaviors are strategies employed by firms to minimize their tax burdens without
significantly altering their broader economic behavior. Recent research emphasizes that taxable
income elasticities must be interpreted with caution to the extent that firms engage in tax-shifting
behaviors (e.g., Gorry, Hubbard, and Mathur 2021; Saez, Slemrod, and Giertz 2012). These
behaviors may include intertemporal shifting (e.g., firms accelerate deductions or delay income
in the years directly before and after a tax cut to minimize their tax burdens, for example as in
Dowd, Giosa, and Willingham 2020) or shifting across tax bases (e.g., when owners of pass-through
firms shift income between the corporate and individual sectors, for example as in Auerbach and
Slemrod 1997 and Slemrod 1995).
Estimation strategies that do not account for shifting may yield misleading elasticities. In
the case of intertemporal shifting, if revenue leakage in one year is offset by revenue gains in
subsequent years (or vice versa), the choice of measurement years may materially impact the
elasticity magnitudes. In the case of shifting across tax bases in essence, a form of fiscal
externality — elasticities that measure only a single tax base may exaggerate the decline in taxable
income resulting from a tax incease (or vice versa for a tax cut).
The elasticites that we report in Tables 3, 6, and 5 compare the relative changes in outcomes
of C- and S-corps before and after TCJA. To assess the sensitivity of these estimates to shifting
behaviors, in Appendix C.7 we show results where the elasticities are estimated from the
differential change in C- and S-corps from 2016 to 2019. These specifications avoid capturing
intertemporal tax-shifting behaviors in 2017 and 2018, the years where intertemporal shifting is
likely to be most significant. The results are statistically similar to the benchmark results from
equation 2.
In principle, shifting across tax bases is possible across several different margins. For example,
firms may change their entity-type, switching from C to S status or vice versa. S-corps owners
may choose to reclassify their wages as profits to maximize the value of the QBI deduction. The
incentive to reclassify wages in this way is strongest for S-corps with just one owner: because wage
costs are deductible, in firms with more than one owner, this form of shifting comes at the expense
of the other owners, who are unlikely to approve of it. Multinational firms may have incentives
to book their profits domestically rather than abroad in response to the new international tax
provisions. Finally, to the extent that tax cuts reduce incentives for tax evasion (that is, illegal
misreporting of income), this is most likely to be true among small firms, which are least likely to
be audited.
To evaluate the extent of entity-type switching, Figure 11 shows the profit-weighted share
of entity-type switchers in each year of our sample both before and after TCJA. The combined
switching rate of both C and S corps prior to TCJA was less than 0.3%, and this share increased only
trivially after TCJA to less than 0.4%. Thus, although we document a clear increase in entity-type
switching after TCJA, this form of tax shifting does not bias our elasticities.
43
FIGURE 11: CORPORATE ENTITY-TYPE SWITCHING, 2013-2019
Switcher Profits / All Profits
0
.001
.002
.003
2014 2015 2016 2017 2018 2019
S to C C to S
Notes: Figure shows the profit-weighted share of firms that switch their legal entity type from C-to-S or from S-to-C over our sample
period. Entity switching is very rare, and increased only modestly after TCJA.
To further assess the sensitivity of our estimates to firms with potentially high shifting
or evasion propensities, in Table 8 we run our benchmark specification from equation 4 on
samples that: exclude multinational firms (row 6); exclude small firms (row 10); and exclude
S-corps with only one owner (row 11). The point estimates are statistically indistinguishable
from the benchmark specification and do not suggest that income shifting across tax bases is
a significant concern in our setting. These findings are also consistent with contemporaneous
research. With respect to S-corps, Goodman, Lim, Sacerdote, and Whitten (2021) study a large
sample of de-identified tax returns of pass-through businesses and find that S-corps mostly
did not engage in wage-to-profit shifting in response to the QBI deduction. With respect to
multinationals, Garcia-Bernardo, Jansk
`
y, and Zucman (2022) find only small changes in the share
of US multinational profits booked abroad following TCJA.
4.9 Mechanisms and the Cost of Capital
In Section 4.7 we provided evidence that our empirical results are unlikely to be driven by income
or liquidity effects. In this section we argue that our findings are consistent with standard theories
in which permanent reductions in the cost of capital cause firms to increase their scale and profits.
To illuminate these mechanisms, we first introduce a stylized model of the corporate income tax.
Suppose firms optimize after-tax profits π:
π = F (K, L)(1 τ ) wL(1 τ) rK(1 θτ ) (5)
44
where τ is the corporate income tax rate, and θ [0, 1] is an expensing parameter capturing the
share of production costs that are tax deductible. These costs may include fully deductible capital
purchases (such as durable equipment eligible for bonus depreciation), partially deductible capital
purchases (such as structures), and non-deductible costs (such as managerial effort, to the extent
that it is not reflected in cost-deductible compensation). We assume that F (K, L) varies across
firms due to heterogeneous productivities, such that some firms are able to produce greater output
than others with a fixed set of inputs. The first-order condition for profit maximization with respect
to capital yields:
F
K
|{z}
MRPK
=
(1 θτ )
1 τ
r
| {z }
cost of capital
φ (6)
where the left side of the equation is the marginal revenue product of capital, and the right
side expression is defined as the user cost of capital, φ. The expression shows that, in general,
either decreasing the tax rate τ or increasing the expensing parameter θ lowers the cost of capital
φ. However, if all production costs are tax deductible (corresponding to the “full expensing” case
where θ = 1), then the tax rate does not affect the cost of capital, and thus does not affect capital
demand.
In our setting, TCJA both permanently cut the corporate tax rate and also temporarily increased
the effective expensing rate, due to the bonus depreciation incentives discussed in Section 4.8.
In response to this reduced cost of capital, standard models predict that firms will demand
more capital (that is, invest more), demand more labor (to the extent that capital and labor are
complements), and increase their scale (in part because a higher capital stock may make the firm
more productive).
How should we make sense of the simultaneous changes in the tax rate and expensing policy
in our setting? Which policy instrument is driving the results? Equation 6 implies that, if θ
pre
< 1
and θ
post
= 1, the relative change in the cost of capital wedge for C- versus S-corps is given by the
following expression:
φ
C
post
φ
C
pre
φ
S
post
φ
S
pre
=
(1 θτ
C
pre
)
1 τ
C
pre
(1 θτ
S
pre
)
1 τ
S
pre
(7)
In this expression, the change in the cost of capital wedge is affected only by the initial levels of
the tax rates, τ
C
pre
and τ
S
pre
, and is not affected by the changes in tax rates or by the levels of the rates
in the post-period. Because initial marginal income tax rates in our sample are higher for S-corps
than for C-corps — that is, because τ
S
pre
> τ
C
pre
— equation 7 implies that, at least for capital assets
eligible for bonus depreciation, S-corps faced a larger reduction in the cost of capital than C-corps
following TCJA. As a result, the model would predict that S-corps should increase investment,
employment, and sales relative to C-corps – the exact opposite of our empirical findings.
45
The fact that the qualitative predictions from this simple model differ so sharply from our
empirical results suggests that the simple model does not fully capture economic reality. In
practice, some capital expenditures, such as structures, do not qualify for bonus deprecitation.
Moreover, existing studies show that a large fraction of firms do not claim bonus depreciation
even when eligible to do so (Kitchen and Knittel 2016; see also Joint Committee on Taxation 2021),
suggesting the corporate rate change may remain relevant for firm behavior.
A complementary plausible reconciliation of evidence and theory in our setting appeals to
models that incorporate expectations and dynamics, as in Auerbach and Hassett (1992). In these
models, the combination of the permanent reduction in the tax rate and the tempoary change in
the expensing rate generates two offsetting effects. On the one hand, the temporary change in
expensing leads firms to engage in intertemporal substitution, pulling forward investment from
the future to the present. This effect is larger for S-corporations, since they face a higher tax rate
than C-corps both before and after TCJA.
On the other hand, expiration of full expensing leads firms to heed the permanent change in
the long-run tax rate. If current and future capital costs are complementary for example, due
to convex adjustment costs, multi-year investment projects, or complementary costs that are not
fully deductible this leads to a dampening of current investment. Intuitively, if firms know
that increasing investment today will commit them to higher costs in the future, and if those
future costs are sufficiently high (or the discount rate sufficiently low), then they will restrain their
investment today. This dampening effect is also larger for S-corps, since they faced a smaller rate
cut relative to C-corps.
Our empirical results are consistent with models in which the latter effect outweighs the
former: that is, our results suggest that firms were more responsive to the permanent change
in the long-run tax rate than to the temporary change in expensing policy. This interpretation also
aligns with the empirical evidence we have presented in Section 4.8 showing that the differential
responses of C-corps relative to S-corps do not appear to be statistically larger or smaller in
industries that are most exposed to bonus depreciation.
Consistent with this view, in Appendix C.8 we estimate cost-of-capital elasticities under the
assumption that firms are responsive to the permanent change in the corporate income tax rate
rather than the temporary change in the expensing rate.
10
To do so, we parameterize equation 6
using θ = 0.5, which is equal to the expensing rate prior to TCJA as well the level to which it is
scheduled to reset after the expiration of full expensing. In general, across outcomes our estimates
of the cost-of-capital elasticity are within the plausible range of estimates in the literature, and are
statistically indistinguishable from our corresponding estimates of the net-of-tax elasticity. In the
quantification exercise below, we use the net-of-tax elasticities since they are more transparently
estimated and yield a more natural interpretation for policy analysis.
10
In ongoing work, we estimate elasticities that account for both the temporary and permanent tax changes.
46
5 Revenue Impacts, Excess Burden, and Incidence
In this section we leverage the reduced form elasticities estimated in Section 4 to evaluate the
short-run revenue impacts, excess burden, and incidence of TCJA’s corporate tax cuts. We adopt
a transparent framework in the style of Feldstein (1999), such that elasticities of key outcomes
with respect to the net-of-tax rate are sufficient to estimate the aggregate welfare consequences of
changes in tax policy. As discussed in Saez, Slemrod, and Giertz (2012), the empirical validity of
this approach rests on two key assumptions: (a) neglible tax shifting, and (b) neglible income
effects. In Section 4.8 we presented several empirical tests suggesting that shifting behaviors
are unlikely to drive our estimate of the corporate taxable income elasticity. Moreover, our
heterogeneity tests in Section 4.7 showed that high- and low-liquidity firms responded similarly
to corproate tax cuts, suggesting income effects are indeed neglible in our setting.
For clarity and to facilitate comparison with existing literature, when interpreting the results
we focus only on the core provisions of TCJA relating to firms’ marginal income tax rates, and
abstract from issues relating to changes in personal income taxes, deficit financing, public goods
provision, consumer prices, and dynamics.
Revenue Impacts
Starting from the firm problem in equation 5, let the corporate tax base B be defined as firm
revenues less deductible costs:
B = F (K, L) wL θrK (8)
Total corporate tax revenues T are the product of the tax base B and the corporate tax rate τ :
T = τB (9)
In the absence of behavioral responses, mechanical changes in tax revenue from a change in
the corporate net-of-tax rate 1 τ are given by holding the tax base constant:
dM = Bd(1 τ) (10)
The additional change in tax revenue generated by behavioral responses is given by:
dB =
ε
B
Bτ
1 τ
(11)
where ε
B
=
B/B
(1τ )/(1τ )
is the elasticity of taxable income with respect to the net-of-tax rate,
equivalently called the elasticity of pre-tax profits or the elasticity of the corporate income tax base.
Intuitively, the extent to which revenue losses from tax cuts are offset by an expanding tax base is
directly proportional to the taxable income elasticity ε
B
. The total change in tax revenue is given
by:
47
dT dM + dB = dM
1
τε
B
1 τ
(12)
where dT is the sum of the mechanical and behavioral reponses.
11
Welfare and Excess Burden
Define aggregate welfare W as the sum of after-tax private income Y and public tax revenues T :
W = Y + T (13)
where taxes are defined as in equation 9, and Y is the sum of private income received by firm
owners (π
K
) and different groups of workers (π
L
j
), indexed by j:
Y = π
K
+
j
π
L
j
(14)
We use this defintion of welfare, which corresponds approximately to GDP or total output,
because it is transparent, can be objectively measured in the data, and can be easily compared with
existing estimates in the literature. In general, however, changes in output and welfare will not be
equivalent if, for example, there is curvature in individuals’ utility functions. Rather than welfare,
an alternate interpreation of W is that it quantifies the market value of the output distortion from
the corporate tax.
Guided by our empirical results, we classify three groups of workers: low-paid workers,
high-paid workers, and executives. Low-paid workers are defined as those in the bottom 90%
of the within-firm wage distribution, and high-paid workers as those in top 10%. Workers and
executives optimize consumption C
L
= w
j
L
j
, where w
j
is the wage for workers of type j and
L
j
is labor supply. The indirect utility function for workers is given by U
j
(w
j
) = w
j
L
j
, and the
change in utility from a change in wages is given by:
dU
j
(w
j
) = L
j
dw
j
= w
j
L
j
ε
L
j
d( 1 τ) (15)
where ε
L
j
is the elasticity of earnings for workers of type j with respect to the net-of-tax rate.
Because firm owners are assumed to optimize their demands for factor inputs, by application of
the envelope theorem the change in firm owners’ profits is given by:
K
= B
j
(1 τ )(dw
j
L
j
) (16)
The first term B implies that a reduction in the tax rate increases profits. The second term
j
(1 τ )(dw
j
L
j
) captures the effects of factor price adjustments: while higher wages improve
welfare for workers, they reduce welfare for firm owners, whose production costs increase. In
11
For simplicity, here we abstract from the effects of corporate tax changes on personal income tax revenues.
48
practice, these offsetting adjustments are implicitly embedded in the elasticity of after-tax profits
to the net-of-tax rate, which we have estimated in the empirical analysis. We can thus compute the
change in welfare for firm owners as:
K
= π
K
ε
π
d( 1 τ) (17)
where ε
π
is the elasticity of after-tax profits with respect to the net-of-tax rate, and π represents
after-tax profits in the baseline year. The total change in welfare is given by:
dW = dY + dT (18)
=
K
+
j
dU
j
+ dT
We combine the elasticites estimated in Section 4 with moments from the tax data to compute
the total change in welfare as expressed in equation 18. Finally, the marginal excess burden from
the corporate tax cut is given by:
dW
dT
=
dT +
K
+
j
dU
j
dT
(19)
which expresses the marginal welfare loss from raising an additional dollar of corporate tax
revenue— or, in our setting, the marginal welfare gain from an additional dollar of foregone tax
revenue.
Incidence
To assess distributional impacts of TCJA’s corporate tax changes, we adapt the framework
developed in Suárez Serrato and Zidar (2016) and Fuest, Peichl, and Siegloch (2018) to estimate
the share of productive factors in the total corporate tax burden. Our analysis differs from these
studies in two respects. First, the detailed microdata used in this study allows us to observe returns
to firm owners, and thus allow us to empirically estimate how these returns are affected by changes
in the corporate tax rate. Second, we are able to estimate the effects of corporate tax changes on the
full distribution of workers’ earnings. Using these two sets of estimates, we are able to evaluate
the incidence of corporate taxes using weaker assumptions than are required when these outcomes
are not empirically observable.
We are also able to extend our analysis to assess corporate tax incidence not only on factors
of production that is, on firm owners and workers, as is standard in the literature but also
to approximate incidence over the income distribution, taking account of the empirical fact that
many low-income workers own capital and most capital owners also work. Doing so allows us to
speak directly to research and policy debates about the progressivity of the corporate income tax.
Because we observe workers’ locations, we are also able to evaluate the geographic incidence of
49
corporate income tax cuts.
12
In evaluating incidence, we make the standard assumptions of a representative consumer and
equal redistribution of tax revenues to all citizens. The former assumption rules out distributional
impacts through changes in consumer prices, which are unobservable in our data. The latter
assumption, while strong, allows us to avoid making even stronger alternative assumptions about
the future path of fiscal policy. TCJA’s corporate tax cuts were deficit financed, and the future
trajectory of federal tax policy is always uncertain in a democracy.
Accounting for changes in factor prices, the change in welfare for firm owners is given by:
K
= B
j
(1 τ )(dw
j
L
j
) (20)
The first term B implies that a reduction in the tax rate increases profits. The remaining
terms capture the effects of factor price adjustments: while higher wages and capital costs may
improve welfare for workers and the suppliers of productive capital, they reduce welfare for firm
owners, whose production costs increase. These offsetting adjustments, however, are implicitly
embedded in the elasticity of after-tax profits to the net-of-tax rate, which we have estimated in the
empirical analysis. We can thus compute the change in welfare for firm owners as:
I
F
=
K
K
+
j
dU
j
(21)
Similarly, the share of workers in the total tax burden, I
L
j
, is given by replacing the numerator
in equation 21 with dU
j
.
We expand on the traditional analysis of factor incidence in two extensions. First, we
evaluate incidence with respect to the population distribution of income. Estimating distributional
incidence allows us to account for the empirical fact that many workers are also firm owners
(because they may hold equity portfolios, as emphasized in Auerbach 2006) and that many firm
owners also earn labor income (as documented in Smith, Yagan, Zidar, and Zwick 2019). We
assume that everyone works, and ascribe firm and capital ownership to workers using data on
the distribution of equity and wealth ownership from the Distributional Financial Accounts (DFA)
produced by the Federal Reserve Board (2018). We assume that executives are in the top 1% of
the distriubtion, that high-paid workers are in the 90-99th percentiles, and that low-paid workers
comprise the bottom 90%. Letting ω
j
represent the capital ownership share of workers of type j,
we have:
I
L
j
=
dU
j
+ ω
j
K
+
j
dU
j
(22)
12
In the incidence analysis of Fuest, Peichl, and Siegloch (2018) studying workers’ wages, the effects of corporate
tax changes on returns to firm owners are unobservable, and changes in rental rates are assumed to be negligible. This
assumption is likely to be appropriate in their analysis of tax changes in German municipalities, which they characterize
as small open economies. In the incidence analysis of Suárez Serrato and Zidar (2016), returns to firm owners are
unobservable but inferred via structural estimation. These studies evaluate impacts of corporate tax changes on median
and mean worker wages, respectively, but do not directly assess impacts over the earnings distribution.
50
which measures incidence across the income distribution for all workers, inclusive of both labor
and capital income.
Second, we combine the distributional estimates from equation 22 with the observed locations
of workers, inferred from zip codes reported on IRS Form W-2, to estimate the geographic
incidence of corporate income tax cuts across Census regions and commuting zones. Letting
ρ
j(r)
represent the share of workers of type j living in region r, and N
r
represent the region’s
population, we compute:
dY
r
N
r
=
j
ρ
j(r)
(dU
j
+ ω
j
K
)
N
r
(23)
which provides an estimate of the effect of federal corporate tax changes on per capita income
in region r. To the extent that firm ownership and employment are unequally spatially distributed
across the country, the gains from corporate tax cuts are likely to be unequally geographically
distributed as well.
5.1 Quantification Moments and Parameters
Table 9 summarizes the key inputs that we use to quantify the welfare and incidence implications
of TCJA’s corporate income tax cuts. Panel A includes information on the empirically observed
average tax rates and changes faced by C- and S-corps in our sample, and Panel B shows their
aggregate 2016 levels of tax liabilities, after-tax profits, and payrolls for different groups of workers.
Panel C reports the distribution of capital ownership as observed in the Distributional Financial
Accounts data, and Panel D reviews the key net-of-tax elasticities we have estimated in the
empirical analysis.
5.2 Revenue, Income, and Welfare Impacts
Panel A of Table 10 shows our estimates of the impacts of corporate income tax cuts on government
tax revenues. To generate these estimates, we use the empirically estimated elasticities and key
moments from our sample of tax returns. We show estimates of the mechanical effects on tax
revenue (that is, holding the tax base constant), as well as estimates of the total effects (taking
account of behavioral responses). We present the estimates as dollar values, percentage changes,
and as a share of 2016 GDP.
Panel A of Table 9 shows that, on average, TCJA reduced the marginal tax rate by 10 percentage
points for C-corps and by 4 percentage points for S-corps. In the absense of behavioral responses,
Panel A of Table 10 shows that this would lead to a $101 billion (34%) reduction in corporate tax
revenues, corresponding to approximately 0.47% of 2016 GDP. However, because firms respond to
the tax cut by expanding their operations and increasing pre-tax profits, the total reduction in tax
revenue is modestly attenuated, instead $88 billion (30%), or 0.41% of GDP.
Panel B of Table 10 shows our estimates of the change in private income from TCJA’s
corporate tax changes. We estimate that private income increases by $97 billion, or 0.46% of GDP.
51
TABLE 9: QUANTIFICATION MOMENTS AND PARAMETERS
All Corps C-Corps S-Corps
Panel A: MTRs (Sales-Weighted)
Mean 2016 τ 0.25 0.24 0.31
Mean τ -0.09 -0.10 -0.04
Mean τ /τ
t1
-0.33 -0.47 0.34
Mean ln(1 τ ) 0.13 0.14 0.06
Panel B: Firm Aggregates (bil)
Tax 299 255 44
Taxable Income 1,163 914 250
After-Tax Profit 882 658 224
Executive Payroll 151 105 47
Top 10 Payroll 767 673 94
Bottom 90 Payroll 1,403 1,211 192
Panel C: Distribution of Capital
Top 1% 0.27
91-99% 0.34
Bottom 90% 0.39
Panel D: Net-of-Tax Elasticities
Pre-Tax Profit 0.38
After-Tax Profit 0.52
Executive Pay 0.65
Top 10 Earnings 0.32
Bottom 90 Earnings 0.00
Table shows the inputs that we use to quantify the revenue, income, and welfare imapcts of TCJA’s corporate tax cuts.
Data in Panels A and B are directly observed in our sample of tax records, and data in Panel C are from the 2018 Federal
Reserve Board Distributional Financial Accounts. The parameters in Panel E are estimated in the empirical analysis.
52
TABLE 10: REVENUE AND WELFARE ESTIMATES
bil % % GDP
Panel A: Tax Revenues
Mechanical, dM -101.2 -33.8 -0.47
Total, dT -88.4 -29.5 -0.41
Panel B: After-Tax Private Income
Total Income, dY 97.3 3.0 0.46
Capital Income,
K
54.5 6.2 0.25
Labor Income,
L
42.9 1.8 0.20
Panel C: Welfare and Excess Burden
Welfare, dW 8.9 0.04 0.04
Marginal Excess Burden, dW /dT -10.1
This table shows estimated revenue, income, and welfare impacts from TCJA’s changes in marginal corporate income
tax rates. Outcomes are scaled in billions of dollars in column 1. The denominators for percentage changes in tax
revenues are: 2016 federal corporate tax revenues in Panel A; 2016 private income of corporate firm owners and
employees in Panel B; and 2016 GDP in Panel C. Outcomes in column 3 are scaled as a percent of GDP. The marginal
excess burden is defined as the ratio of the change in welfare to the change in tax revenues. See Section 5 for details.
53
Approximately $54 billion of these gains accrue to firm owners and $43 billion accrue to workers.
Panel C shows our estimates our welfare and the marginal excess burden of the corporate
tax. In our stylized framework, welfare increases linearly in private income and public revenues.
Private income gains of $97 billion combined with revenue losses of $88 billion imply a net increase
in total welfare of $9 billion, or 0.04% of 2016 GDP. Our estimate is of a similar order of magnitude
to Barro and Furman 2018, who structurally simulate the effects of TCJA on GDP using a fully
parameterized Ramsey model.
Panel C provides our estimate of the marginal excess burden of the corporate income tax,
dW
dT
.
We find that a marginal dollar of foregone revenue from corporate income tax cuts generates an
additional $0.10 in output. Viewed through the lens of the model, the results thus imply substantial
efficiency gains from corporate tax cuts. However, as we show below, these aggregate gains mask
significant distributional effects.
5.3 Incidence
Panel A of Table 11 shows our estimates of changes in private income for firm owners, executives,
and high- and low-paid workers. Combining our reduced form elasticities from Section 4 with the
moments from the tax data, we find that approximately 56% of the gains from TCJA’s corporate
tax cuts flow to firm owners; 12% flow to executives; 32% flow to high-paid workers; and 0% of the
gains flow to low-paid workers.
Panel B reports our estimates of incidence over the income distribution. When we allocate the
gains of firm owners to workers using data from the Distributional Financial Accounts, we find
that approximately 27% of the gains from corporate tax cuts accrue to the top 1% of the earnings
distribution; 51% accrue to the 90-99th percentiles; and 22% accrue to the bottom 90%. These
results highlight the importance of considering the joint impacts of changes on both capital and
labor income when assessing the distributional effects of corporate tax changes.
Panel C of Table 11 reports our estimates of geographic incidence across Census regions,
produced from equation 23.
13
Because firm owners and highly-paid workers are relatively highly
concentrated in the Northeast and West Coast regions of the United States, we find that gains from
the corporate tax cuts disproportionately accrue to those regions. For example, our estimate of the
per capita income gain for residents of the Northeast ($33) is approximately 77% larger than for
residents of the South ($19).
Panel A of Figure 12 maps the variation in our estimates of geographic incidence across
commuting zones. Beyond the regional patterns highlighted in Table 11, the map highlights
substantial within-region variation, with larger and higher-income commuting zones generally
seeing larger gains from the corporate tax cuts. The patterns are most clearly illustrated in Panel B,
which plots the estimated change in income against the 2016 average earnings of corporate-sector
employees, and where the bubbles are proportional in size to each commuting zone’s population.
13
We classify states into regions using the definitions from the U.S. Census, provided here, with the minor modifation
of classifying Delaware, DC, and Maryland as belonging to the Northeast rather than to the South.
54
Relative to the median commuting zone gain of approximately $120 per capita, we estimate that
gains are approximately 4 times larger in Houston or New York City; 6-7 times larger in Seattle; and
roughly 10 times larger in the San Francisco Bay Area. The results imply that corporate income tax
cuts not only increase income inequality across workers, but also contribute to growing inequality
across regions and commuting zones (Gaubert, Kline, Vergara, and Yagan 2021).
5.4 The Efficiency-Equity Tradeoff of the Corporate Income Tax
Our estimate of corporate taxable income elasticity a key parameter in the literature for
measuring the distortion of a tax implies substantial efficiency gains from cutting corporate
taxes (or, equivalently, implies substantial losses from increasing the corporate tax rate). However,
we also find that corporate tax cuts disproportionately benefit those with high incomes, with 78%
of the gains flowing to just 10% of the population. These results imply that policymakers face an
efficiency-equity tradeoff when setting corporate tax policy.
Given that the federal government must raise some level of revenue to finance its operations,
how should we interpret our results on the corporate income tax in the context of the broader
national tax and transfer system? In Figure 13, we benchmark our findings against estimates from
the literature on personal income and payroll taxes the two other largest sources of federal tax
revenues in the United States. The X-axis shows ε
B
, where ε
B
is the elasticity of the tax base to
an increase in the net-of-tax rate for each policy instrument. A larger magnitude of ε
B
implies a
larger distortion from the tax. The Y-axis shows the share of tax burden borne by the top 10% of
the income distribution, where higher shares imply that the tax is more progressive.
The estimates of ε
B
for the personal income tax (0.25) and payroll tax (0.21) are from Saez,
Slemrod, and Giertz (2012) and Saez, Schoefer, and Seim (2019), respectively. The former is based
on a comprehensive literature review of the voluminous empirical evidence on personal income
taxes, while the latter is, less satisfyingly, based on evidence of employment effects from a payroll
tax reform in Sweden. However, it is, to our knowledge, the best available estimate for payroll
taxes in the literature. We compute estimates for the share of personal and payroll tax burdens
borne by the top 10% and top 1% of the income distribution using data from the Congressional
Budget Office.
Viewed in the context of the literature, the results in Figure 13 suggest that the corporate income
tax is approximately 1.5 times less efficient than the personal income tax. In Panel A, where our
measure of equity is the share of the tax burden borne by the top 10%, the corporate income tax is
similarly progressive to the personal income tax. In Appendix Figure C.11, we use a more extreme
measure of equity, the share of the tax burden borne by the top 1%, and find that the corporate
income tax is both less efficient and less progressive than the personal income tax. In either case,
the corporate tax appears 3-4 times more progressive than the payroll tax, although it is twice as
inefficient.
55
TABLE 11: INCIDENCE ESTIMATES
$ % Change % Incidence
Panel A: Factors ($ bil)
Firm Owners 54.5 6.2 56
Executives 11.3 7.5 12
High-Paid Workers 31.6 4.1 32
Low-Paid Workers 0.0 0.0 0
Panel B: Distributional ($ bil)
Top 1% 26.0 6.7 27
91-99th% 50.1 4.7 51
Bottom 90% 21.2 1.2 22
Panel C: Geographic ($ per capita)
Northeast 423 0.7 33
Midwest 263 0.5 21
South 239 0.5 19
West 346 0.6 27
Table shows the estimated incidence of corporate tax cuts on firm owners, executives, and high- and low-paid workers.
To compute distributional incidence, we allocate gains of firm owners to workers using data on capital ownership from
the Federal Reserve Distributional Financial Accounts. The denominators for percent change shown in column 2 are:
2016 private income of corporate firm owners and employees in Panel A; private labor and corporate capital income in
Panel B; and real mean personal income by Census region according to the 2016 Census American Community Survey
in Panel C.
56
FIGURE 12: GEOGRAPHIC INCIDENCE
Panel A: Change in Per Capita Income across Commuting Zones
p1: <$10 p.c. p50: ~$120 p.c. p99: up to $1,340 p.c.
Panel B: Change in Per Capita Income vs. Initial Worker Earnings
New York
Houston
San Francisco
San Jose
Seattle
$ per capita
Median CZ
120
500
1,000
1,500
30,000 50,000 70,000 90,000 110,000 130,000
Mean Worker Earnings, 2016 $
The unit of analysis is a commuting zone. Panel A illustrates geographic variation in our estimates of changes in per
capita private income due to the corporate tax cuts, generated from equation 23. Income gains are proportional to color
intensity in the map, with darker colors representing larger gains. Panel B plots the estimated change in income for
each commuting zone against the 2016 average earnings of corporate-sector workers. The size of the bubbles is
proportional to each commuting zone’s 2016 population.
57
FIGURE 13: THE EFFICIENCY-EQUITY TRADEOFF IN CONTEXT
Corp Income Tax
Personal Income Tax
Payroll Tax
Top 10% Share
of Tax Burden
(This paper)
(Saez et al. 2012; CBO 2018)
(Saez et al. 2019; CBO 2018)
More Efficient >>>
0
.2
.4
.6
.8
1
More Progressive >>
-.6 -.5 -.4 -.3 -.2 -.1 0
-1 * Elasticity of Taxable Income
The figure contextualizes our results on the corporate income tax, compared here with the personal income and payroll
taxes, the two other largest sources of federal tax revenue in the United States. The elasticity of taxable income, shown
on the X-axis, is a key parameter for measuring tax distortions. The share of the tax burden borne by the top 10% of the
income distribution, shown on the Y-axis, is a measure of progressivity.
6 Conclusion
This paper analyzes the short-run impacts of historically large federal corporate income tax cuts on
large U.S. firms and their workers. Exploiting tax policy variation that allows us to compare trends
in outcomes of similarly sized firms operating in the same industry, we find that tax cuts cause
firms to increase their sales, profits, employment, payrolls, and investment. These responses are
predominantly concentrated in capital-intensive industries. Labor earnings increase for workers in
the top 10% of the within-firm earnings distribution, and rise particularly sharply for executives,
but do not change for workers in the bottom 90%. We do not find evidence that firms’ responses are
driven by liquidity or income effects, and interpret the results as consistent with standard models
in which firms are responsive to long-run changes in the cost of capital.
We empirically estimate key elasticites of firm- and worker-level outcomes, and combine these
elasticities with a stylized model to estimate the revenue impacts, welfare gains, and incidence
of TCJA’s corporate tax changes. We find that private incomes increase by $97 billion and tax
revenues decline by $88 billion, implying a net aggregate output gain of $9 billion, equivalent to
approximtely 0.04% of GDP. In the the model, reducing corporate tax revenues by $1 generates an
additional $0.10 in output, implying substantial efficiency gains from corporate tax cuts.
We also find that the gains from corporate tax cuts disproportionately flow to those with high
58
incomes. We estimate that approximately 56% of the gains accrue to firm owners, 12% accrue to
executives, 32% accrue to high-paid workers, and 0% flow to low-paid workers. When we adjust
these calculations to allow for the empirical fact that many workers hold equity portfolios, we
estimate that 78% of the gains flow to the top 10% of the earnings distribution, and 22% flow to the
bottom 90%.
In a benchmarking excercise, we find that the efficiency gains from corporate tax cuts are 1.5
to 2 times as large as personal income or payroll tax cuts, even while the distributional effects are
similarly regressive. Holding all else equal, the results imply that, on the margin, adjusting the
composition of federal revenues toward a larger share of personal income taxes and a lower share
of corporate income taxes may yield significant efficiency gains without sacrificing progressivity.
We conclude with important caveats. Our results do not capture a range of potentially
important channels through which corporate tax cuts may affect welfare. For example, in the
long-run, higher investment may increase productivity and broadly increase workers’ wages.
While we do not find clear effects of tax cuts on productivity in our data (see Appendix C.6),
and estimate zero effect on low-income workers’ earnings, it is possible that such gains may
materialize over a longer time horizon. On the other hand, reductions in tax revenues may lead
to a deterioration in the provision of public services (such as education, health, or infrastructure
spending), or reduce redistributive transfers, with potentially adverse implications for equity and
efficiency. We believe these are important topics for future research.
59
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65
Appendix Figures and Tables
A Appendix to Section 2: Setting and Institutional Details
A.1 Historical Statutory Federal Top Marginal Income Tax Rates
FIGURE A.1: TOP MARGINAL INCOME TAX RATES IN HISTORICAL CONTEXT
Panel A: Top Marginal Tax Rate for C-Corporations
TCJA
%
0
10
20
30
40
50
60
1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010 2020
Top US Marginal Income Tax Rate for C-Corporations
1909-present
Panel B: Implied Top Marginal Tax Rate for S-Corporations
TCJA
%
w/out QBI
w/ QBI
0
10
20
30
40
50
60
70
80
90
100
1960 1970 1980 1990 2000 2010 2020
Implied Top Marginal Income Tax Rate for S-Corporations
1958-present
Notes: Data from the Tax Foundation. Panel A shows the evolution of the top statutory marginal corporate income tax rate facing
C-Corporations throughout U.S. history. Panel B shows the implied top statutory marginal income tax rate facing S-corporations,
which equal to the top rate facing individuals.
A.2 Marginal Income Tax Rates and Brackets Before and After TCJA
TABLE A.1: MARGINAL INCOME TAX BRACKETS BEFORE AND AFTER TCJA
Panel A: Tax Brackets for C-Corporations
Income Upper Income Pre-TCJA Post-TCJA Firm Emp Sales
Bracket Threshold ($) MTR MTR Share Share Share
0 0 0 0 0.916 0.659 0.477
1 50,000 0.15 0.21 0.061 0.026 0.012
2 75,000 0.25 0.21 0.006 0.006 0.004
3 100,000 0.34 0.21 0.003 0.004 0.002
4 335,000 0.39 0.21 0.007 0.013 0.010
5 10,000,000 0.34 0.21 0.005 0.043 0.047
6 15,000,000 0.35 0.21 0.000 0.008 0.009
7 18,000,000 0.38 0.21 0.000 0.003 0.005
8 >18,000,000 0.35 0.21 0.001 0.240 0.433
Panel B: Implied Tax Brackets for S-Corporations (Married Joint Filers)
Income Upper Income 2017 Upper Income 2019
Bracket Threshold 2017 ($) MTR Threshold 2019 ($) MTR
1 18,650 .1 19,400 .1
2 75,900 .15 78,950 .12
3 153,100 .25 168,400 .22
4 233,350 .28 321,450 .24
5 416,700 .33 408,200 .32
6 470,700 .35 612,350 .35
7 >470,700 .396 >612,350 .37
Notes: Panel A reports the statutory marginal income tax brackets facing C-corps before and after TCJA. The firm, employment, and
sales shares are calculated in tax year 2016 using SOI data. Panel B illustrates an example of the implied statutory marginal income tax
brackets facing S-corp owners. This schedule varies depending on the taxpayer’s filing status. For illustrative purpsoes, the schedule
shown here is for married joint filers, although in practice we use the corresponding tax schedules for different filer types.
A.3 A Global Perspective on Corporate Income Taxes
FIGURE A.2: CORPORATE TAXES IN GLOBAL PERSPECTIVE
Panel A: Average Global Corporate Tax Rates
%
25
30
35
40
45
50
1980 1990 2000 2010 2020
(GDP-Weighted)
Global Average Top Statutory Corporate Tax Rate
Panel B: Average Corporate Income Taxes in OECD Countries as a Share of GDP
%
2.3
2.4
2.5
2.6
2.7
1990 2000 2010 2020
OECD Countries, GDP-Weighted
Corporate Income Tax Revenues / GDP
Notes: Panel A shows the GDP-weighted global average top statutory corporate income tax rate since 1980, using data from the Tax
Foundation. Panel B shows the lowess-smoothed GDP-weighted ratio of corporate income tax revenues to GDP since 1990 for OECD
countries, using data from the OECD tax database.
FIGURE A.3: CORPORATE TAX REVENUES IN OECD COUNTRIES, 2018
0 5 10 15 20
% of Total Revenue
United States
Italy
France
Germany
Greece
Finland
Austria
Denmark
Sweden
Iceland
United Kingdom
Turkey
Netherlands
Belgium
Czech Republic
Canada
Switzerland
Japan
Ireland
New Zealand
Korea
Luxembourg
Norway
Australia
Corporate Taxes as Share of Total Taxation
OECD Countries, 2018
Notes: This figure shows corporate tax revenues as a share of total taxation for OECD countries in 2018, using data from the OECD tax
database.
A.4 TCJA Tax Cut in the Context of Recent Literature
FIGURE A.4: TCJA TAX CHANGE VS. OTHER RECENT STUDIES
0 .05 .1 .15
Avg. Tax Change * Tax Base, as % of GDP
S-Seratto and Zidar 2016
(US State Corp Tax)
Giroud and Rauh 2019
(US State Corp Tax)
Fuest et al. 2019
(German Municipal Corp Tax)
This Paper
(US Federal Corp Tax)
Notes: This figure shows the average tax change studied in several recent papers, multiplied by the tax base and scaled by GDP. The
average tax change in Fuest et al. (2018) is 0.9 percentage points, and the LBT tax base is approximately 1.6% of GDP (see
OECD/UCLG 2019). The average tax change in Suárez Serrato and Zidar (2016) and Giroud and Rauh (2019) is 1.0 percentage point,
and the state corporate tax base is approximately 0.25% of GDP (Census 2019). The average tax change in this study is 9.0 percentage
points, and the 2016 federal corporate tax base is approximately 1.6% of GDP (OMB 2022).
A.5 Tax Rates for S-Corporations and Details of the QBI Deduction
TABLE A.2: PREDICTORS OF TAKE-UP OF THE QBI DEDUCTION FOR S-CORPS
(1) (2) (3)
2018 2019 Pooled
ω
T I
f
-0.801
∗∗∗
-0.834
∗∗∗
-0.817
∗∗∗
(0.012) (0.011) (0.009)
SSTB (0/1) -0.110
∗∗∗
-0.068
∗∗∗
-0.090
∗∗∗
(0.025) (0.021) (0.020)
Profits <=0 (0/1) -0.311
∗∗∗
-0.174
∗∗∗
-0.241
∗∗∗
(0.077) (0.059) (0.050)
Log Sales -0.014
∗∗∗
-0.008
∗∗
-0.011
∗∗∗
(0.004) (0.003) (0.003)
Outcome Mean 0.66 0.67 0.67
Year FE No No Yes
R2 0.59 0.67 0.63
N Firms 3,623 3,407 7,030
Notes: Table shows predictors of QBI takeup among
S-corporations.
A.6 Entity-Type Switching
TABLE A.3: ENTITY-TYPE SWITCHING
(1) (2)
S to C C to S
Log Lagged Sales × Post 0.000 0.004
(0.000) (0.002)
Firm Age × Post -0.000 -0.000
(0.000) (0.001)
Multinational (0/1) × Post 0.026
∗∗∗
-0.023
∗∗
(0.008) (0.010)
SSTB Industry × Post -0.001 0.016
(0.002) (0.026)
R2 0.00 0.02
N Firms 47,860 94,159
Notes: Table shows predictors of entity-type
switching after TCJA.
B Appendix to Section 3: Data Sources and Variable Definitions
B.1 Variable Definitions
Taxes Paid
Taxes paid are defined for C-corporations as Form 1120: Schedule L, line 31. For S corps, taxes
paid are measured using the following methodology:
1. Match S-corp owners to their 1040s
2. Use 1040s to compute each owner’s average tax rate (ATR) and total taxes paid on pass-through income
(a) Calculate ATR for a tax unit: ATR = Taxes Paid / Taxable Income
(b) Record net ordinary business income: NET_OBI = Line 32 from 1040 (from schedule E)
(c) Compute taxes paid on business income: BIZ_TAX_PAID = min(max{ATR*(NET_OBI),0},total tax paid on
1040)
(d) Save table unique by TIN-year
3. Compute total non-negative pass-through income from 1120s and 1065s by owner
(a) Append all K1s and from 1120s and 1065s with positive OBI (drop K1s with OBI<$0)
(b) Sum up OBI by TIN-year; call the sum OBI_SUM
(c) Save table unique by TIN-year
4. Merge table 2 and 3 by TIN-year
5. Compute the OBI share of each pass-through business in the owner’s portfolio
(a) Append all K1s from 1120s with positive OBI
(b) Match m:1 by TIN with table 4; new table is unique by TIN-K1-year
(c) Compute share of each K1 in total OBI, call it W = OBI / OBI_SUM
(d) Allocate tax_paid in proportion to the shares: S_TAX = W*BIZ_TAX_PAID
(e) Sum up s_tax by firm-year, final table is unique by EIN-year
Sales, Costs, and Profits
Sales are defined for C- and S-corporations as Form 1120: line 1c and Form 1120-S: line 1c,
respectively.
Costs of goods sold are defined for C- and S- corporations as Form 1120: line 2 and Form 1120-S:
line 2, respectively.
Pre-tax gross profits are defined as sales minus costs of goods sold.
After-tax gross profits are defined as gross profits minus taxes paid.
Earnings before interest, taxes, depreciation, and amoritization (EBITDA) is defined as net
income plus net interest expense plus depreciation. Net income is defined for C-corporations as
Form 1120: line 28. For S-corporations, net income is defined as Form 1120-S: line 21 combined
with Form 1120-S Schedule K: lines 2 14. Depreciation is defined for C- and S-corporations as
Form 1120: line 20 and Form 1120-S: line 14, respectively. Net interest expense is defined for
C-corporations as the maximum of zero and Form 1120: line 18 minus line 5. For S-corporations,
net interest expense is defined as Form 1120-S: line 12 plus Form 1120-S Schedule K: line 12b minus
line 4.
Shareholder Payouts
Dividends are defined for C-corporations as Form 1120: Schedule M-2, line 5a plus line 5c. For
S-corporations, dividends are defined as Form 1120-S: Schedule K, line 17c.
Share buybacks are defined as the non-negative annual dollar change in the treasury stock;
treasury stock is defined for C- corporations as Form 1120: Schedule L, line 27(d) and for
S-corporations as Form 1120-S: Schedule L, line 26(d).
Total payouts are defined as dividends plus share buybacks.
Investment
Capital assets is defined for C- and S- corporations as buildings and other depreciable assets less
accumulated depreciation, as measured on Form 1120: Schedule L, line 10b(d) and Form 1120-S:
Schedule L, line 10b(d), respectively.
Net investment is defined as the annual dollar change in capital assets.
Short-life new investment is defined for C- and S-corporations as the sum of Form 4562: lines
19a(c) to 19c(c).
Long-life new investment is defined for C- and S-corporations as the sum of Form 4562 lines
19d(c) to 19i(c) plus the sum of lines 20a(c) to 20c(c) plus the sum of line 14, line 15, and line 16.
Total new investment is defined as short-life new investment plus long-life new investment.
Employment and Earnings
Employment for C- and S-corporations is defined as the total number of unique individuals with
a W-2 issued by the firm.
Worker earnings are measured for C- and S-corporation employees from Form W-2, box 5
(Medicare Wages).
Payroll is defined as the sum of workers’ annual earnings.
Executive compensation is defined for C-corporations as Form 1120: line 12 and for
S-corporations as Form 1120-S: line 7.
Top-5 compensation is defined for C- and S-corporations as the combined annual W-2 earnings
of the top five highest paid workers at the firm.
Other Firm Characteristics
Age is defined as tax year minus year of incorporation, where year of incorporation for
C-corporations and S-corporations is defined as Form 1120: box C and Form 1120-S: box E,
respectively.
Multinational firms are defined as those whose foreign sales share is greater than 1%, where
foreign sales are defined as the sum of gross receipts from all Controlled Foreign Corporations
(that is, foreign subsidiaries) reported for each foreign subsidiary on Form 5471 Schedule C: line
1c.
Capital intensity is defined at the industry level as total capital assets divided by total sales.
C- and S-corporations are classified as capital intensive if the mean of this ratio in the pre-period
(2013 to 2016) is greater than the sample median.
Industry is defined for C-corporations as the first three digits of Form 1120: Schedule K, line 2a
and for S-corporations as the first three digits of Form 1120-S: Schedule B, line 2a.
B.2 Sample Distribution of Firms’ Statutory Marginal Income Tax Rates Before and
After TCJA
FIGURE B.1: SAMPLE DISTRIBUTION OF C-CORP STATUTORY MTRS
Panel A: Marginal Tax Rates for C-Corporations
0
20
40
60
Percent
0 .1 .2 .3 .4
C-Corp Firm MTR
2016 2019
Panel B: Implied Marginal Tax Rates for S-Corporations
0
10
20
30
40
50
Percent
0 .1 .2 .3 .4
S-Corp Firm MTR
2016 2019
Notes: Table shows the sample distribution of statutory marginal income tax rates for C- and S-corps before and after TCJA.
B.3 Size Distribution of Capital-Intensive Industries
FIGURE B.2: SIZE DISTRIBUTIONS OF FIRMS, BY CAPITAL INTENSITY
Panel A: 2016 Sales
Density
0
.1
.2
.3
.4
$1mil $10mil $100mil $1bil $10bil $100bil
2016 Log Sales
Capital Intensive Not Capital Intensive
Panel B: 2016 Employment
Density
0
.1
.2
.3
.4
.5
100 1K 10K 100K 1mil
2016 Log Employment
Capital Intensive Not Capital Intensive
Notes: Panels A and B show the distribution of 2016 log firm sales and employment, respectively, for capital-intensive and
non-capital-intensive firms.
C Appendix to Section 4: Empirical Results
C.1 Equity and Debt Issuance
TABLE C.1: EQUITY AND DEBT ISSUANCE
Equity Debt
(1) (2) (3) (4)
New Issuance (0/1) Log Issuance New Issuance (0/1) Log Debt
C × Post -0.003 0.027 0.005 -0.002
(0.006) (0.115) (0.008) (0.011)
2016 Outcome Mean 0.30 1.38 0.61 4.13
Firm FE Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes
R2 81501 22633 81501 81299
N 11,647 4,950 11,647 11,639
Notes: Table shows result from estimating equation 2 to assess if TCJA caused increases in equity
or debt issuance of C-corps relative to S-corps. Columns 1 and 3 show the extensive margins, and
columns 2 and 4 show the intensive margins. We find no signficiant difference.
C.2 Top 5 Earnings
TABLE C.2: TOP 5 EARNINGS
Outcome is top 5 earnings
Controls for:
Benchmark Sales Profits Relative Sales
C × Post 0.040
∗∗∗
0.038
∗∗∗
0.038
∗∗∗
0.038
∗∗∗
(0.008) (0.008) (0.008) (0.008)
Firm FE Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes
R2 1 1 1 1
N 81501 81501 81501 81259
N Firms 11,643 11,643 11,643 11,643
Notes: Unit of analysis is firm-year. Table reports results from estimating variations of equation 2, where the outcome is log
compensation of the top 5 highest paid workers at the firm. Column 1 shows the benchmark specification, and columns 2-4 adds
time-varying controls for several measures of firm performance. Standard errors are clustered by firm.
C.3 Worker Heterogeneity
In Figure C.1 we explore whether the earnings effects of corporate statutory income tax cuts vary
across worker characteristics. Specifically, we test whether the annual earnings responses
estimated from equation 1 differ for men and women; for workers above and below the age of 40;
and for workers with above and below 5 years of work history with their employer in 2019. In
light of our previous evidence that earnings impacts vary across the within-firm earnings
distribution, we also condition on workers’ initial place in that distribution in 2016. For example,
in Panel A where the x-axis is 60, we estimate equation 1 separately for men and women who
were initially at the 60th percentile of the within-firm earnings distribution, and plot the resulting
β
2019
coefficients and associated 95% confidence intervals on the y-axis.
1
As can be seen from the
widely overlapping confidence intervals in Figure ??, we do not find compelling evidence that
treatment effects vary by gender, age, or employment tenure.
FIGURE C.1: WORKER HETEROGENEITY
Panel A: Gender Panel B: Age
β
2019
-.05
0
.05
.1
20 40 60 80 100
Firm Wage Centile
Men Women
β
2019
-.05
0
.05
.1
20 40 60 80 100
Firm Wage Centile
Age <40 Age>=40
Panel C: Tenure
β
2019
-.05
0
.05
.1
20 40 60 80 100
Firm Wage Centile
<=5 Years Tenure >5 Years Tenure
1
Conditioning on workers’ initial place in the within-firm distribution requires that our sample is comprised of
“stayers”, that is, employees who worked at the same firm in 2016 and 2019.
C.4 Additional Investment Results
TABLE C.3: INVESTMENT SCALED BY 2016 BASELINE SALES
(1) (2) (3) (4) (5)
NetI
t
/K
t1
NewI
t
/K
t1
Short-Life Long-Life Structures
C × Post 0.008
∗∗∗
0.004 0.003
∗∗
-0.000 0.001
(0.003) (0.002) (0.001) (0.000) (0.001)
2016 Outcome Mean 0.01 0.06 0.04 0.01 0.01
Firm FE Yes Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes Yes
R2 0.26 0.60 0.63 0.50 0.38
N 81,529 81,529 81,529 81,529 81,529
N Firms 11,647 11,647 11,647 11,647 11,647
Notes: Table shows results for new investment scaled by baseline sales. See Section 3 for variable
definitions.
C.5 Firm Heterogeneity
Event Studies for Capital Intensive vs. Non-Capital Intensive Industries
FIGURE C.2: SALES, COSTS, AND PRE-TAX PROFITS, BY CAPITAL INTENSITY
Panel A: Sales Panel B: Costs
-.05
0
.05
.1
.15
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 1.00
Sales / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.53
Costs / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Panel C: Pre-Tax Profits Panel D: EBITDA
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.47
Pre-Tax Profits / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
-.1
0
.1
.2
.3
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.29
EBITDA / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients from equation 1, estimated for all firms and separately for
capital-intensive and non-capital intensive industries. These coefficients capture average differences in outcomes between C- and
S-corps over time after controlling for firm and industry-size-year fixed effects. Standard errors are clustered by firm, and error bands
show 95% confidence intervals. Sales are gross receipts. Costs are equal to cost of goods sold, including both material and labor costs.
Pre-tax profits are sales minus costs. EBITDA is a harmonized measure of earnings before interest, taxes, depreciation, and
amoritization; see Section 3 and Appendix B for details.
FIGURE C.3: AFTER-TAX PROFITS AND SHAREHOLDER PAYOUTS, BY CAPITAL INTENSITY
Panel A: After-Tax Profits
-.05
0
.05
.1
.15
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.41
After-Tax Profits / 2016 Sales
Difference Between C-Corps and S-Corps Over Time
Panel B: Shareholder Payouts (Extensive Margin)
-.04
-.02
0
.02
.04
.06
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.54
Shareholder Payouts (0/1)
Difference Between C-Corps and S-Corps Over Time
Panel C: Shareholder Payouts (Intensive Margin)
-.2
0
.2
.4
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 1.45
Log Shareholder Payouts
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients from equation 1, estimated for all firms and separately for
capital-intensive and non-capital intensive industries. These coefficients capture average differences in outcomes between C- and
S-corps over time after controlling for firm and industry-size-year fixed effects. Standard errors are clustered by firm and error bands
show 95% confidence intervals. In Panel A, after-tax profits are defined as pre-tax profits minus tax, and are scaled by 2016 baseline
sales. In Panel B, the outcome is an indicator equal to 1 if shareholder payouts are positive (i.e., the extensive margin), where payouts
are defined as the sum of cash and property distributions to shareholders. In Panel C, the outcome is log shareholder payouts (i.e., the
intensive margin). For additional information on data sources and variable definitions see Section 3 and Appendix B.
FIGURE C.4: LABOR MARKET OUTCOMES, BY CAPITAL INTENSITY
Panel A: Log Employment Panel B: Log Payroll
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 2,969
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 173
Panel C: Log Median Earnings Panel D: Log 99th Centile Earnings
-.03
-.02
-.01
0
.01
.02
.03
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 46,278
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 371,861
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients from equation 1, estimated for all firms and separately for
capital-intensive and non-capital intensive industries. These coefficients capture average differences in outcomes between C- and
S-corps over time after controlling for firm and industry-size-year fixed effects. Standard errors are clustered by firm and error bands
show 95% confidence intervals. The right panels are constructed such that the distance between the C-corp and S-corp lines in each
year is equal to the corresponding β
t
coefficient in the left panel, and such that the observation-weighted average of the two lines is
equal to the unweighted sample average of the outcome in each year. For data sources and variable definitions see Section 3.
FIGURE C.5: EXECUTIVE PAY, BY CAPITAL INTENSITY
Panel A: Log Officer Compensation
-.1
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 6,283,969
Panel B: Log Top 5 Earnings
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 1,186,758
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients from equation 1, estimated for all firms and separately for
capital-intensive and non-capital intensive industries. These coefficients capture average differences in outcomes between C- and
S-corps over time after controlling for firm and industry-size-year fixed effects. Standard errors are clustered by firm and error bands
show 95% confidence intervals. For data sources and variable definitions see Section 3.
FIGURE C.6: INVESTMENT, BY CAPITAL INTENSITY
Panel A: Positive Net Investment (0/1)
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.52
Positive Net Investment (0/1)
Difference Between C-Corps and S-Corps Over Time
Panel B: Net Investment / Lagged Capital
-.05
0
.05
.1
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.06
Net Investment / Lagged Capital
Difference Between C-Corps and S-Corps Over Time
Panel C: New Investment / Lagged Capital
-.04
-.02
0
.02
.04
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: 0.25
New Investment / Lagged Capital
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The figure plots the β
t
coefficients estimated from equation 1. These coefficients capture average
differences in outcomes between C- and S-corps over time after controlling for firm and industry-size-year fixed effects. Standard
errors are clustered by firm and error bands show 95% confidence intervals. Net investment is defined as the change in book value of
depreciable capital assets minus accumulated book depreciation. New investment is measured as new capital expenditures; see
Section 3 for details. The outcome in Panel A is an indicator equal to 1 if net investment is positive. The outcomes in Panels B and C,
net and new investment, respectively, are scaled by lagged capital. For data sources and variable definitions see Section 3.
More Firm Heterogeneity
FIGURE C.7: FIRM HETEROGENEITY 1
Panel A Panel B
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1 .15
Sales
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.04 -.02 0 .02 .04 .06
Costs
Panel C Panel D
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1
Pre-Tax Profits
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1
After-Tax Profits
Notes: The unit of analysis is a firm-year. The table shows the C × P ost coefficients from equation 2. These coefficients
estimate average differential changes in outcomes between C- and S-corps before and after TCJA controlling for firm
and industry-size-year fixed effects (unless otherwise specified). Firm-size regressions include only industry-year fixed
effects, and unionization regressions include only size-year fixed effects. Standard errors are clustered by firm. Firms
are classified as high-cash if their mean ratio of liquid assets to assets in the pre-period is greater than the sample
median. Firms are classified as highly profitable if their mean ratio of value-added per worker in the pre-period is
greater than the sample median. Firms are classified as highly-concentrated if their market share in industry sales in
the pre-period is greater than the sample median. Unionization rates are measured at the industry-level from the 2016
Current Population Survey.
FIGURE C.8: FIRM HETEROGENEITY 2
Panel A Panel B
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.1 0 .1 .2 .3 .4
Log Shareholder Payouts
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.02 0 .02 .04 .06 .08
Net Investment / Lagged K
Panel C Panel D
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.1 -.05 0 .05 .1
Log Employment
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1
Log Payroll
FIGURE C.9: FIRM HETEROGENEITY 3
Panel A Panel B
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.03 -.02 -.01 0 .01 .02
Log Median Earnings
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1 .15
Log 99th Centile Earnings
Panel C Panel D
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1
Top 5 Earnings
All
100-199 Emp
200-400 Emp
500-999 Emp
1000+ Emp
Low VA/Worker
High VA/Worker
Low Cash
High Cash
<10%
>10%
High Market Share
Low Market Share
Firm Size
Profitability
Liquidity
Unionization
Concentration
-.05 0 .05 .1 .15
Executives' Compensation
C.6 Productivity
FIGURE C.10: PRODUCTIVITY
Panel A: Log Valued Added Per Worker
-.1
0
.1
.2
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: -3.74
Log Value Added Per Worker
Difference Between C-Corps and S-Corps Over Time
Panel B: Log Profit Margin
-.1
-.05
0
.05
.1
.15
2013 2014 2015 2016 2017 2018 2019
All Capital Intensive Not Capital Intensive
2016 Outcome Mean: -2.39
Log Profit Margin
Difference Between C-Corps and S-Corps Over Time
Notes: Unit of analysis is firm-year. The panels plot the β
t
coefficients from equation 1, estimated for all firms and separately for
capital-intensive and non-capital intensive industries. These coefficients capture average differences in outcomes between C- and
S-corps over time after controlling for firm and industry-size-year fixed effects. Standard errors are clustered by firm, and error bands
show 95% confidence intervals. Value added is defined as EBITDA per worker. Profit margin is defined as the ratio of EBITDA to
sales. Standard errors are clustered by firm and error bands show 95% confidence intervals.
C.7 2016-2019 Elasticities
TABLE C.4: ELASTICITIES ESTIMATED FROM TAX YEARS 2016-2019
(1) (2) (3) (4) (5) (6) (7)
Ln(1 τ
MT R
f
) Pre-tax π Post-tax π I
t
/K
t1
w
p50
w
p95
Executives
ln(1 τ
f
)× 2019 1.000
∗∗∗
0.508
∗∗∗
0.637
∗∗∗
0.927
∗∗∗
0.037 0.220
∗∗∗
0.701
∗∗∗
(0.000) (0.141) (0.150) (0.131) (0.071) (0.071) (0.214)
2016 Outcome Mean -0.31 0.47 0.41 0.06 46,278 157,639 6,283,969
Firm FE Yes Yes Yes Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes Yes Yes Yes
N 81,529 81,529 81,529 81,529 81,529 81,529 72,400
N Firms 11,647 11,647 11,647 11,647 11,647 11,647 10,680
Notes: Table shows elasticities estimated using changes in outcomes between C- and S-corps from 2016-2019. These
estimates are unaffected by potential intertemporal shifting in tax years 2017 and 2018, and are similar to our
benchmark estimates.
C.8 Cost of Capital Elasticities
TABLE C.5: COST OF CAPITAL ELASTICITIES
(1) (2) (3) (4) (5) (6)
Pre-tax π Post-tax π I
t
/K
t1
w
p50
w
p95
w
exec
φ
f
× Post -0.669
∗∗∗
-0.920
∗∗∗
-0.910
∗∗∗
0.002 -0.312
∗∗∗
-1.128
∗∗∗
(0.224) (0.228) (0.145) (0.092) (0.094) (0.298)
2016 Outcome Mean 0.47 0.41 0.06 46,278 157,639 6,283,969
Firm FE Yes Yes Yes Yes Yes Yes
Industry-Size-Year FE Yes Yes Yes Yes Yes Yes
R2 81,529 81,529 81,529 81,529 81,529 72,400
N 11,647 11,647 11,647 11,647 11,647 10,680
Notes: Table shows cost-of-capital elasticities.
FIGURE C.11: THE EFFICIENCY-EQUITY TRADEOFF IN CONTEXT
Corp Income Tax
Personal Income Tax
Payroll Tax
Top 1% Share
of Tax Burden
More Efficient >>>
0
.2
.4
.6
More Progressive >>
-.6 -.5 -.4 -.3 -.2 -.1 0
-1 * Elasticity of Taxable Income
Notes: The figure contextualized our results on the corporate income tax against the personal income and payroll taxes, the two other
largest sources of federal tax revenue in the United States. The elasticity of taxable income, shown on the X-axes, is a key parameter in
the literature for measuring tax distortions. The share of tax burden borne by the top of the income distribution is a measure of
progressivity.