distributional impacts of oil and gas tax reforms

Distributional impacts of oil and gas tax reforms

Adam Rose and Brandt Stevens

Tax preferences relating to exploration and production in the oil and gas industries received a great deal of attention during the enactment of the US Federal Tax Reform Act of 1986. One of the main arguments put forth in favour of the removal of these preferences was that they favoured higher income taxpayers, and, therefore, were inequitable. A multisector income distribution model is utilized to examine the direct, indirect and induced distributional impacts of the ensuing reforms. The results indicate that, while the direct impact of these reforms is an improvement in equity among those receiving income from the oil and gas industries, the overall impact throughout the economy is equity-neutral. The result stems from the secondary ej$ects of the tax, which lead to net reductions in production in the oil and gas industries and their direct and indirect suppliers. Keywords: Oil and gas industries; Tax incidence input-output analysis; Income

A significant part of recent federal tax reform legisla- tion applies to tax preferences for the oil and gas industries. The purpose of this paper is to examine the full equity implications of two of these provisions relating to the elimination of the percentage depletion allowance for various cost categories, and the reduction of the intangible drilling cost base eligible for investment expensing. These deductions have often been viewed as tax shelters for the well-to-do (see

Galper and Zimmerman [6] and Piet [lS]), and eliminating them is intended to close tax ‘loopholes’ and make the system more equitable. However, most analyses of this policy have been superficial, since they only consider direct impacts. Typically they neglect the loss ofjobs and income in the oil and gas industries

Adam Rose is Professor and Chairman of the Department of Mineral Resource Economics, West Virginia Univer- sity, Morgantown, WV 22506, USA. Brandt Stevens is an Assistant Professor, Department of Economics, Illinois State University, Normal, IL 61761, USA.

The authors are grateful to Professor John Yu for the use of financial data he compiled on the oil and gas industries. They also wish to

thank Lorna Waddell and Shih-Mo Lin for their research assistance.

Final manuscript received 10 January 1988.

due to the ensuing higher operating costs, as well as the multiplier effects arising from reduced indirect and induced input requirements. It is possible that once all of these general equilibrium effects are taken into account, the full incidence of the tax reforms may turn out to be inequitable.

Tax reform in the oil and gas industries

Investments in the oil and gas industries have long

been considered as excellent tax shelters because of several important ‘tax breaks’ available to partner-

ships and small corporations. One prime example is the percentage depletion allowance for independent producers, which is 15% of the yross income from the property. It can be applied even after the recovery of all acquisition and development expenses. A second example is the expensing of intangible drilling costs, which includes labour, fuels, repairs, site preparation and related costs. It permits a quick wFite-off for expenditures that apply to the life of the well.

Two polar positions on this preferential taxation are often espoused. One focuses on the strategic and economic importance of the oil and gas industries, which provide valuable products with few good substi- tutes. Proponents of this view express concern about

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Distrihurional impacts of oil and gas tas wfortns: A. Rose and B. Slevms

the adequacy of domestic reserves and claim that the social cost of oil should include both a scarcity and a security premium (see eg Hogan [9]). This provides a rationale for subsidizing the discovery of new reserves in the USA and their production. Moreover, given the uncertainty of exploratory drilling there is a risk premium which is used to justify a higher rate of return in the industry. Overall, the relatively higher rate of return is seen as evidence of the orderly functioning of markets in the short run, and the subsidies are viewed as necessary to overcome imperfections associated with externalities and myopia with respect to long-run supply considerations.

An opposing view emphasizes the concentration of

large firms in the oil and gas industries and the resultant wielding of market power. The profits reaped by the oil industry in the aftermath of the Arab oil embargo of 1973-74 and the OPEC price escalations of the late 1970s and early 1980s are considered pure windfalls at the consumers’ expense. Preferential tax provisions are viewed as further benefiting those who have already received sizeable windfalls, or benefiting the well-to-do in general. Holders of this viewpoint characterize the market as working poorly and the current tax preferences as exacerbating the situation.

Even more moderate assessments of oil and gas tax provisions are highly critical. A recent Treasury Department [ 183 study has offered several arguments in favour of revisions of the tax code. Primarily, the arguments are that many of the provisions per- taining to the oil and gas industries result in inefli-

ciencies and inequities. The Treasury noted that the percentage depletion allowance is a production subsidy since the deduction can be claimed even after all development costs have been recovered. Thus, the pre-1986 tax code encourages more production of oil

and natural gas than is economically justifiable on the basis of the costs of development. Also, through the provision for deduction of intangible drilling costs, it biases exploration in favour of drilling as opposed to methods such as seismic or satellite surveys. The

current tax code was viewed as inequitable since the study found most of the benefits accrue to upper income bracket taxpayers.

Various studies have been able to shed light on some of these issues, though not to resolve them completely. For example, Chapman [3] and others have found that the oil industry has been characterized by greater than average profits since the embargo, but significantly greater profits in only two years. Galper and Zimmerman [6] found that the benefits of preferential

‘The study that comes closest to the cast in point is Jorgenson and Slesnick’s [I I] general equilibrium analysis of the efficiency and equity implications of the wtndfall profits tax.

taxation in oil and gas were skewed more toward higher income groups than were similar tax breaks in any other sector. Overall, however, studies of the distributional implications of these fiscal incentives are rare and none to date have been done in the general equilibrium context.’

Several alternative tax reform plans were proposed during the last several years, the most notable including the US Department of the Treasury plans and the KempKasten (HR 6165, S 2948) and Bradley- Gephardt (S 1421, HR 3271) bills. These plans differed in emphasis but generally promised to have some effect on the oil and gas industries through modification of the percentage depletion allowance, expensing of intangible drilling costs, and the windfall profits tax on domestically produced crude oil.

The bill finally enacted is known as the Tax Reform Act of 1986 (Public Law 99-5 14) and came into effect on 1 January 1987. In the case of the oil and gas industries, it represents, somewhat, a compromise of alternative administration and congressional proposals. While many of the Act’s provisions are applicable to oil and gas, we will confine our attention to the unique provisions relating to special tax preferences ~ indirect drilling costs and the percentage depletion allowance’ ~ and to the equity issue.

In the case of IDC, the prior law allowed for the deduction of intangible costs, such as expenditures on dry wells, in the year incurred. Independents were allowed a full write-off, while integrated producers were allowed to deduct 80% of these costs and to amortize the remainder over the next three years.3 The reforms did not change this status of the IDC tax preference in the case of independents. However, for integrated producers the write-off base is reduced to

70% with the remainder to be amortized over 5 years. For the PDA, certain resource acquisition costs,

such as lease bonuses and advance royalty payments, were deductible up to 15% under the pre-reform tax code. The reform eliminated the deduction of advance royalties and lease bonuses for all categories of producers.

Methodology

In the context of the economics of taxation, it is possible that the direct ‘imposition’ of a tax (or tax reform) is likely to differ considerably from its ultimate

‘Thus we exclude the effects of provisions relating to the corporate income tax, depreciation and the investment tax credit. ‘An ‘independent’ producer is engaged almost exclusively in the exploration and extraction phases of the petroleum business, and refines less than 50000 barrels per day or has retail sales less than $5 million. A further distinction is made between small independents and large ones. where the dividing line is I Ooo barrels per day.

236 ENERGY ECONOMICS July 1988

Distributional imparts of‘ oil and gas tax reforms: A. Rose and B. Stevens

‘incidence’. While this situation has been acknow- ledged for years in the public finance literature (see eg

Musgrave [ 131 and Harberger [S]), the difficulty has been in finding an operational methodology by which to perform the analysis. More recently, inputoutput (eg Golladay and Haveman [7]) and computable general equilibrium models based on I-O data (eg Ballard et al [2]) have proven successful in this effort.

Specifically, we wish to examine the extent to which general equilibrium effects override the initial progres- sivity of tax reforms on the oil and gas industries. The issue is whether a policy designed, at least in part, to improve the distribution of income might in fact worsen it. A priori, one would expect that the indirect and induced effects would be more normally distributed than the imposition of a set of reforms intended to eliminate tax shelters, usually utilized by those in upper income brackets. If the linkage between the oil and gas industries, and their direct and indirect suppliers is such as to cause a relatively greater reduction in employment in lesser skilled occupations and a relatively greater reduction in capital related income among low and middle income groups, the direct egalitarian effects could be more than offset.

We will employ an input-output approach to income distribution analysis below. The model is the most comprehensive I-O based model constructed to date from survey-based data. It is disaggregated to the 2-digit Bureau of Economic Analysis classification level (81 sectors) and includes all types of personal income payments. The major feature of the model is that it is able to trace these payments to recipients divided into 10 income brackets. Also, the model is amenable to parametric change as production, income, or income distribution patterns are altered. For a complete discussion of the model, its construction, and other applications the reader is referred to Rose, Stevens and Davis [ 161.

Examination of the distributional impacts of eliminating the percentage depletion allowance and expensing of intangible drilling costs involves three steps. First, is an analysis of the direct impacts of tax reform on tax liabilities across income groups and the resulting reduction in income. Second, is an estimate of the direct output reduction in the oil and gas industries stemming from higher operating costs. Third, is the use of the output reduction estimates to ‘drive’ our I-O income distribution model in order to determine the overall impacts.

Direct effects

A recent US Treasury study ([ 181, pp 23 l-33) concludes that 90 000 investors with adjusted gross incomes over $75 000 garnered half the benefits from the percentage

ENERGY ECONOMICS July 1988

depletion allowance, averaging about $6 400 each; while half of the intangible drilling cost benefits went to just 31000 investors with adjusted gross incomes greater than $100000, averaging about $28000 per taxpayer. At first glance then it would appear that the benefits of the PDA are slightly less skewed than those of the IDC.

We utilize the Treasury Department analysis as the basis of our direct estimates of the 1986 tax reforms. First, assuming that exactly half the benefits from IDC expensing flows to income earners in the over $100 000 income bracket, and that each member of this bracket averages $28 000 in tax preferences, their total benefits are $868 million. The remaining $868 million write-off is distributed to the other income groups. In the case of PDA, the benefits to taxpayers with adjusted gross incomes above $75000 amount to $576 million. The equivalent remaining write-offs are assumed to flow to the lower income brackets.

Since the actual reforms do not call for the total elimination of either PDA or IDC, the total income reduction for investors in oil and gas due to tax reform will not be equivalent to the combined $2 888 million.

Based on a preliminary Treasury Department analysis and a cash flow model for the industry made available to the authors (see Yu et al [21]), we estimated the reduction of write-offs to be 15% of the maximum for each of the two tax preferences.

To estimate the overall distribution of the PDA and IDC we made use of data developed by Galper and Zimmerman [6] on the share of unincorporated business losses by marginal tax rates for oil and gas extraction. We justify the use of these data as a proxy for the distribution of tax write-offs for PDA and IDC since Galper and Zimmerman have stated that ‘. . . re- stricting their analysis to investors with gross losses may come closer to identifying the set of tax-motivated investors’ (p 390). Data associating adjusted gross income brackets with marginal tax rates from a study by Thompson and Hicks [17] enables us to distribute tax benefits (positive, or negative as in the context of reforms evaluated here) among investors according to their incomes.

Before presenting the results, we should point out one of the basic assumptions of tax reform analysis. That is, there is an ‘actual’ level of income from any activity, such as oil and gas investment, and that the ‘net’ income, following deductions, is simply a ‘paper’ amount. Elimination of tax preferences would other- wise appear to raise income, because there would be less to deduct. But the Treasury estimates cited above, in effect, refer to a lowering of tax deductions, thereby increasing the income subject to tax, and hence tax liability, and thus lowering the ‘actual’ after-tax income.

237

Distributional impacts qf oil and gas tax reforms: A. Rose and B. Stevens

Table 1. Direct income reductions from oil and gas tax preference reforms, 1987.

Income bracket ($) & 4999

5OOS 9999 10@0&14999 15OOG19999 20 00&24 999 25 00&34 999 35 OOS49 999 50 OOC74 999 7500&99 999 100000+

Total

Gini

a 1982 US $ x IOh.

Pre-reform income from oil and gas” 1071

2 422 3 507 3 687 3913 7 468 7441 2 998

825 3 463

36 795

0.4577

Reduction in income due to tax reform”

5.34 4.23 0.66 2.75 4.71

13.28 32.96 15.50 52.64

112.71

244.84

0.848 1

Percentage change 0.499 0.175 0.019 0.075 0.122 0.178 0.443 0.517 6.38 1 3.255

0.665

N/A

Our initial distribution of direct tax reform impacts

represents only the change in tax liability. A further adjustment is required to compute the post-reform after-tax income reduction. The computation is simpli- fied if we think of the situation directly as one in which a taxpayer can no longer shelter, say, $1000 of income. The after-tax reduction is the portion of the $1000 that is taxed away, The actual post-reform income reduction from the oil and gas sector is thus simply the change in tax liability times the marginal tax rate. The analysis assumes that the highest marginal tax rate for a given income group applies to the change

in tax liability. This assumption is reasonable since the change in tax liability is marginal income.

fall only very slightly, from a pre-reform 0.4577 to a post-reform 0.4551, because the tax reform affects such a small percentage of oil and gas sector income.

Modification of oil and gas tax preferences leads to higher production costs and subsequently to reduced industry production. This adjustment actually takes place through a complex process relating not only to current production but to effects on current exploration and hence additional pressure on future produc-

tion. We limit our analysis to the short run, and hence will view the outcome in terms of an increase in the

costs of operation through higher after-tax costs and

through the increased costs of obtaining external investment funds.

The post-reform reduction in income is shown in column 2 of Table 1. Column 1 of the table shows the level of net (after-tax) pre-reform income from the oil and gas sector, and column 3 shows the percent reduction from this baseline. As we would expect from a proposal intended to promote vertical equity, the direct burden of the tax reform is highly progressive, ranging from less than one-tenth of one percent of all

income received from the petroleum sector by some of the lowest brackets to 6.4% and 3.3%, respectively, by the two highest brackets, However, while the Gini coefficient of 0.84814 for the direct tax preference reduction is obviously highly skewed, it causes the post-tax Gini coefficient5 for the petroleum sector to

We determine the direct output reduction in the oil and gas industries by a combination of two related models. These include a cash flow model developed by Yu et al [21] and a simple micro-simulation model of production decisions developed by Waddell [20]. Simulations of the tax reform were performed for all three classes of oil and gas producers, with the resulting output reduction estimates being imperceptible for small independents, 0.6429% for large independents, and 3.123% for integrated companies. Because integrated firms make up more than 75% of the oil production market, and are the major gas producers in the nation as well, the influence of integrated firms is great in yielding the overall average of an annual 2.457% reduction petroleum production.

4The high Gini is ‘progressive’ in this case because it pertains to an income reducfion.

sNote that the income payments listed in column 1 of Table 1 represent net (after federal tax) income, which we consider the best context to evaluate tax reform. These were obtained by multiplying gross oil and gas sector income projected to 1987 by a set of average tax rates (IRS [lo]). The pre-tax Gini coefficient for the oil and gas sector combined is 0.4907. We assumed no change in this distribution for our base case projection.

The results are consistent with other estimates recently put forth, such as the Permian Basin Petroleum

Association [ 141 projected 2.0 to 3.0% reduction. For the sake of perspective it should also be noted that the oft proposed elimination of both the IDC and PDA provisions was estimated by the American Petroleum Institute [I] to result in a combined 10% reduction in drilling and output in the oil and gas industries.


Distributional impacts qf oil and ,gas tax reforms: A. Rose and B. Stevens

Table 2. Sectors most effected by oil and gas industry tax reforms.

sector” Direct requirements Real estate 0.087 Maintenance 0.054 Utilities 0.016 Business services 0.015 Finance 0.008 Petroleum refining 0.008 Trade 0.008 Restaurants’ 0.007 Mining machinery’ 0.005

Transport 0.005 Food and kindred” 0.004 Other servicesd 0.00 1

Total requiremen& 0.244 0.093 0.08 1 0.08 1 0.091 0.065 0.160 0.054 0.008 0.059 0.083 0.099

“Does not include ‘own-use’ of oil and gas by the petroleum sector. bReduction per dollar decrease in final demand for petroleum sector. ‘Among the top 10 sectors in terms of direct impacts only. dAmong the top IO sectors in terms of total impacts only.

Second-order effects

Basic computations

The simulation of the total distributional impacts of the tax reforms is a straightforward application of our model. First, a change in final demand for oil and gas extraction is multiplied by the closed Leontief inverse of the US input-ouput table (US Forest Service [ 191) to determine the gross output reductions stimulated in each of the other sectors of the economy.6 The ten sectors impacted most are presented in Table 2. Overall, there is a strong similarity between the results for those sectors impacted directly and those impacted through the totality of multiplier effects. Only two sectors that are not among the top ten in the direct requirements column appear in the total requirements column, and the rank order between the top sectors is reasonably close. Still, some sectors, such as maintenance and mining machinery, are stimulated primarily by the oil and gas industries themselves, while others, such as business services, are linked to oil and gas even more through various rounds of indirect suppliers, and still other sectors, such as food and

trade, are stimulated primarily by the induced effects of income payments and subsequent consumer pur- chases. Thus several sectors that would not appear to be significantly affected by the oil and gas tax reforms will, in fact, have a major influence on the overall change in income distribution.

Second, a vector of sectoral gross output changes are multiplied by our multisector income distribution matrix, adjusted to reflect after-tax income levels. The matrix also contains a modified oil and gas sector column to reflect the tax reforms themselves. This yields a vector of total income changes differentiated by income group. The results pertain to the first effective year of the reforms, though we have used a 1982 I-O table. This is possible because computations

were performed with the coefficients of the table, which represent the structure of the economy, and adjusted final demand, which accounts for different output levels for 1987. The structural coefficients of an I-O model are impervious to scale. As typically is the case due to lack of data, we have applied a table specified for one year to another year. Errors in the results arise to the extent that changes in production technology or input substitution are not reflected by the set of fixed coefficients. It is highly likely that eventually some substitution effects will arise from the shift of resources out of oil and gas into other sectors or that other fuels will be substituted for oil and gas. However,

these are not likely to be significant in the first year the reforms go into effect because substitution possi- bilities are so limited in the short run.

Results

The results of our income distribution analysis are displayed in Table 3, in terms of individual income bracket effects and the Gini coefficient. Column 1 of the table is the baseline income distribution of the US economy (all sectors) projected to 1987. Column 2 contains the distribution of the direct and indirect income reductions associated with the decrease in oil and gas output, and column 3 contains the percentage change.

bThere is one preliminary step to account for the oil and aas sector’s . . own use of iis output. The projected 2.457% reduction in gross output in the oil and gas sector amounts to a 2.098% change in final demand for the sector, after dividing it by the diagonal element (equal to 1.171) of the closed Leontief inverse of the US I-O Table To; 1982.

The entries in the income reduction column represent the combination of three effects: (i) the direct income reduction as a result of the tax reforms on those who receive payments from the oil and gas sector (see Table 1); (ii) the direct income reductions throughout the economy stemming from the reduced production in the oil and gas sector; and (iii) the indirect and induced multiplier effects of the output reduction. Together they total $3246 million ($245, $895 and $2 106 million, respectively). This means that the overall outcome is dominated by the first- and second- order output effects of the reform. The distribution of

these income reductions is similar to the baseline (post-tax) income distribution of the economy as a whole. It is the case that sectors with some of the most uneven distributions, such as real estate, are significant portions of the effects of the petroleum sector output reductions, but these are the exceptions rather than

ENERGY ECONOMICS July 1988 239

Distributional impacts of oil and gas tax reforms: A. Rose and B. Stevens

Table 3. Total impact of the oil and gas tax preference reforms on the US economy, 1987.

Income bracket ($) & 4999

sOO& 9999 1oOOCL14999 1500&19999 2000@24999 25 ooo-34 999 35 ooo-49 999 5oOoC74 999 75 m99 999 1oOWO+

Total

Gini

Pre-reform income Reduction in income economy-wide” due to tax reform”

42 0.065 162 0.218 214 0.313 217 0.328 231 0.358 437 0.688 433 0.677 198 0.326 62 0.06 1

133 0.213

2129 3.247

0.4493 0.4619

Percentage change 0.155 0.135 0.146 0.151 0.155 0.157 0.156 0.164 0.099 0.160

0.148

N/A

* 1982 US $ x 10’.

the rule. The Gini coefficient of the combination of impacts is 0.4619, meaning that the total income reductions are very modestly skewed toward high income groups (note the percentage reductions in column 3 of Table 3).

It is not surprising then that the overall Gini coefficient for the economy is not reduced at all from its original level at 0.4493. Thus, the general equilibrium effects of the oil and gas sector tax reforms are ‘income distribution neutral’. Or in terms of our initial

hypothesis, they do not have the opposite of the intended effect, ie they do not adversely affect low income groups in a disproportionate way. At the same time, we should reiterate that the second-order effects nullified most of the intended equalization.

While the impact of the reforms on the size distribution of personal income in the USA as a whole does

not raise a concern, it should be noted that the spatial distribution of the impacts may be troublesome. Any reduction in petroleum sector output is likely to be heavily concentrated in the Texas-Oklahoma, Central Gulf Coast, and Appalachian regions. The economies of these areas have already been hit hard by the sharp decline in oil prices, and further loss of income, either

absolute or relative, exacerbates the problem.

Conclusion

Few studies of the recent tax reform proposals on the oil and gas industries, or of any previous tax reform proposals in general, have evaluated impacts outside the industry directly impacted. In the case examined in this paper there are broader distributional implications of job losses in the oil and gas industries and of cutbacks in the purchase of drilling and operating supplies resulting from tax reform. Moreover, there

are income ‘multiplier’ effects relating to the reduction in indirect and induced input requirements. Thus, the full ‘incidence’ of the reforms can only be examined in a general equilibrium framework. If government policy-makers are serious about promoting equity, they must evaluate the incidence of their proposals to make sure the proposals do not have an effect opposite to that intended.

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2

7

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9

10

11

12

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Distributional impacts of oil and gas tax reforms: A. Rose and B. Stevens

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