FISCAL CAPACITY IN NEW YORK: THE CITY VERSUS THE REGION

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National Tax Journal
Vol 51 no. 3 (September 1998) pp. 531-40

                             FISCAL CAPACITY IN NEW YORK

                         FISCAL CAPACITY IN
                         NEW YORK: THE CITY
                         VERSUS THE REGION
                                                         *
                         HOWARD CHERNICK

                         Abstract - This paper addresses the                              public services, which is comparable in
                         difficulties in developing comparative                           quality to that of their suburban
                         measures of fiscal capacity for jurisdic-                        competitors, at a competitive price. A
                         tions with widely varying authority to                           key element in meeting this competitive
                         levy taxes, with particular reference to                         test is the fiscal capacity of the city. If a
                         New York City (NYC) and its region. It                           city’s fiscal capacity is weak or declining
                         compares income and property wealth                              relative to the region, it will be forced to
                         in the region and computes both                                  make fiscal choices along a politically
                         representative tax system and income-                            and economically unattractive frontier of
                         with-exporting measures of capacity. In                          low public services or high tax rates.
                         terms of both income and taxable                                 This paper presents initial estimates of
                         property wealth, NYC’s values per                                fiscal capacity for the largest city in the
                         household are low relative to the                                country and its surrounding region
                         region. However, taking account of the                           within New York State. The research is
                         City’s ability to export taxes to non-                           part of a larger project on fiscal equity in
                         residents, its fiscal capacity goes from 25                      the New York metropolitan area.
                         percent lower than the median jurisdic-
                         tion in the region to approximately 20                           The paper has three sections. The first
                         percent higher.                                                  discusses briefly the various measures of
                                                                                          fiscal capacity, with special attention to
                                                                                          the difficulty of applying these measures
                                                                                          to the nation’s largest city. The second
                                                                                          section applies the fiscal capacity
                         INTRODUCTION                                                     measures to New York City (NYC) and a
                                                                                          sample of jurisdictions in the New York
                         For central cities to remain competitive                         metropolitan area. The third section
                         with their surrounding regions, as places                        provides a brief conclusion.
                         both for residential location and for the
                         production of goods and services, they
                         must be able to provide a bundle of                              MEASURES OF FISCAL CAPACITY
                                                                                          Fiscal capacity can be defined as the
                         *
                         Department of Economics, Hunter College and the Graduate         ability of a governmental jurisdiction to
                         Center, City University of New York, New York, NY 10021.         translate economic activity within its

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                     geographic borders into public spend-              on firms through gross receipts taxes.
                     ing. The concept is both hypothetical              New York City has both a broad-based
                     and comparative, reflecting the differing          personal income tax and a separate
                     amounts of revenue jurisdictions could             business net income tax, the latter
                     raise, rather than what they actually              imposed both on corporate entities and
                     raise. Any definition of fiscal capacity           noncorporate firms. Adding an “other”
                     must start with a measure of economic              category to represent miscellaneous
                     activity, such as income produced,                 small taxes, the general expression for
                     income received by residents, or                   RTS in jurisdiction i is given by
                     property wealth. The ability to transform
                     the economic base into public revenues
                     depends both on the type of taxes that              1
                     are legally available and on the eco-
                     nomic constraints facing the jurisdiction.         RTCi = tPROP BPROP,i + tSALES BSALES,i

                     At the local level, both factors are very                + tEARN BEARN,i + tCORP BCORP,i
                     important. Localities are legal creatures                + tOTHER BOTHER,i
                     of their states, and taxing authority
                     varies both across and within states.
                     Ceteris paribus, the more restrictive the          In equation 1, the subscript PROP refers
                     set of revenue instruments, the lower              to the property tax, SALES to general
                     the fiscal capacity. Economic constraints          and selective sales taxes, EARN to
                     are measured by the elasticity of the              individual income or earnings taxes, and
                     jurisdiction’s tax base and depend on              CORP to business income taxes. The
                     the extent of interjurisdictional and              weight on each tax base is the average
                     interregional tax competition. If two              tax rate on that base. The average may
                     cities have equal economic bases, but              be across jurisdictions or it may be
                     one faces more perfect suburban                    weighted by the jurisdiction’s share of
                     locational substitutes than the other,             the total population. The RTS is based
                     then it will also have lower fiscal                upon the typical legal authority over tax
                     capacity. Measures of fiscal capacity              instruments and the average fiscal
                     should take into account both the                  behavior of the sample. The drawbacks
                     statutory framework that shapes the                of the RTS are well known (Ladd and
                     tax system and the economic base                   Yinger, 1991). If a particular jurisdiction
                     elasticity.                                        faces a more (or less) restrictive legal
                                                                        framework than the average—for
                     The two major approaches to measuring              example, is not allowed to use a
                     fiscal capacity are the representative tax         particular tax or faces a tight rate or levy
                     system (RTS) and income with export-               restriction—its reduced ability to raise
                     ing. Under RTS, fiscal capacity is defined         revenue will not be directly reflected in
                     as the weighted sum of the major tax               its RTS. The only effect will be small and
                     bases potentially available to the                 indirect, through its influence on the
                     jurisdictions being compared (Advisory             average tax rates used to compute each
                     Commission on Intergovernmental                    city’s RTS.1
                     Relations, 1981). At the local level, the
                     major taxes are the real property tax,             The RTS measure also fails to capture
                     general and selective retail sales taxes,          differences in the competitive fiscal
                     and the earnings or income tax. A small            environment or the political economy of
                     number of cities impose separate taxes             different jurisdictions. Thus, if the

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                         average tax rate on any given base were               tax instruments, we modify the RTS
                         imposed in a jurisdiction with a lower                concept by defining a restricted tax
                         than average rate on that base, the                   capacity for the subset of taxes that
                         higher rate might induce a greater than               are common to all jurisdictions. This
                         average reduction in the value of that                approach has the advantage of not
                         base. The RTS will not reflect such a                 requiring data on tax bases such as
                         constraint. The RTS also ignores                      business income, which are not available
                         distributional constraints, which may                 for small jurisdictions. Since the property
                         limit a city’s ability to tax. Cities with            tax is the only common tax in our
                         relatively unequal income distributions               sample, this measure is simply the
                         must take into account the distribu-                  average property tax rate in the region
                         tional effects of taxes as well as the                multiplied by each jurisdiction’s per
                         revenue productivity of different tax                 household property tax base. The
                         instruments (Inman, 1989). To summa-                  measure indicates the amount of
                         rize this critique of the RTS concept, the            revenue that NYC could raise if it had a
                         less homogeneous are the jurisdictions                tax authority similar to other jurisdic-
                         being compared, either in terms of tax                tions in the region.
                         enabling authority or competitive fiscal
                         environment, the less satisfactory is the             The income with exporting approach, as
                         RTS as a measure of fiscal capacity.                  developed by Bradbury, Ladd, and
                                                                               Yinger (Bradbury and Ladd, 1985; Ladd
                         How can one adjust the RTS measure to                 and Yinger, 1991), is based on the
                         take into account the fiscal capacity of              premise that fiscal capacity should
                         those jurisdictions that rely on a broader            reflect the amount of revenue that
                         menu of taxes than the typical jurisdic-              could be raised if each jurisdiction’s
                         tion? One way to do so is to use                      residents faced the same tax burden.
                         population-weighted average tax rates.                However, resident income is augmented
                         Because larger jurisdictions tend to have             by a jurisdiction’s ability to export a
                         more tax instruments available to them,               portion of the taxes to nonresidents.
                         using population-weighted averages will               Fiscal capacity is defined as
                         tend to give more weight to larger
                         jurisdictions in defining fiscal capacity. If
                         one were to apply this approach to                    2
                         jurisdictions within the New York region,
                         it would undoubtedly raise the mea-                   FC = K*Y(1 + e)
                         sured tax capacity of the city in relation
                         to its suburbs. However, it would also
                         raise inappropriately the absolute                    In equation 2, K* is a standardized tax
                         measure of tax capacity for smaller                   burden, usually defined as the average
                         jurisdictions. From both a political and              resident tax burden for all jurisdictions in
                         an economic point of view, it is highly               the study. Also, Y is per capita income
                         unlikely that other jurisdictions could               and e is the average export ratio. The
                         impose a tax resembling NYC’s corpora-                export ratio, defined as exported taxes/
                         tion income tax. Hence, including such a              local taxes, measures the revenue that
                         tax in the tax capacity calculation is not            comes from nonresidents per dollar of
                         very meaningful.                                      tax paid by residents. As shown in
                                                                               equation 2, exporting enhances fiscal
                         As a compromise way of dealing with                   capacity, because it allows a portion of
                         the problem of restrictions on available              the cost of public services to be paid by

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                     nonresidents. However, while exporting                Both the exporting concept and the
                     lowers the cost of public services for                revenue hill concept are conceptually
                     residents, for nonresidents, it raises the            superior to RTS in that they are more
                     cost of doing business in the jurisdic-               explicitly related to the economic
                     tion. Nonresidents may respond to this                environment faced by any particular
                     higher price by relocating firms, place of            jurisdiction. However, implementing
                     employment, or location for shopping. If              either of the two concepts requires
                     this relocation occurs, there could be a              more information than the RTS. To
                     decline in the jurisdiction’s fiscal base. In         determine the revenue maximizing point
                     choosing their tax structures, localities             under the revenue hill approach, one
                     must balance these opposing consider-                 must estimate an econometric relation-
                     ations. The observed value of e for any               ship between tax rates and tax bases.
                     particular jurisdiction is assumed to be              This estimation requires time-series data
                     the maximum export ratio that the city                on tax rates in both the central city and
                     can sustain, implying that localities                 the various suburban locations, and
                     structure their tax systems so as to                  raises the issue of correctly identifying
                     maximize tax exporting, subject to the                the causal relationship between tax
                     legal restrictions on taxation.                       rates and tax bases. This is difficult
                                                                           because the tax rate is usually defined
                     A third and less well-known concept of                as revenue/base. Therefore, the rate will
                     fiscal capacity is the maximum amount of              be negatively correlated with the error
                     revenue a jurisdiction could raise with its           term, thus biasing downward the
                     existing tax structure. Inman and others              estimated tax rate coefficient.
                     have shown the existence of a revenue
                     hill for Philadelphia and several other               To implement the tax exporting concept,
                     large cities (Inman, Craig, and Luce,                 one starts with an incidence model for
                     1994). At tax rates close to the summit of            the various taxes and assumes that
                     the revenue hill, the value of extra public           incidence is uniform across all jurisdic-
                     expenditures financed by a tax increase is            tions. For example, Ladd and Yinger
                     more than offset by the decline in the tax            assume that capital is perfectly mobile
                     base. If the majority of jurisdictions in the         across cities, while labor and land are
                     sample are taxing at rates that are far               immobile. As a result, capital is assumed
                     from their maximum taxable revenues,                  to bear none of the burden of local
                     then the revenue hill concept of fiscal               taxes.2 The incidence assumptions
                     capacity should give a larger number                  produce varying export ratios because of
                     than the other two concepts.                          differences across cities or metropolitan
                                                                           areas in the residential locations of
                     Our discussion of fiscal capacity has                 consumers, workers, and landowners,
                     ignored intergovernmental aid. How-                   the groups who bear the entire burden
                     ever, fiscal capacity from local sources              of local taxes.
                     should in principal be augmented by
                     intergovernmental grants. In making                   The income with exporting approach
                     this adjustment, it is necessary to take              has been applied mainly to comparisons
                     account of higher level tax burdens as                of central cities and states. However, the
                     well, since a state that has both higher              exporting assumptions that are appro-
                     taxes and higher state aid does not                   priate for most cities and for smaller
                     necessarily increase the fiscal capacity of           jurisdictions must be modified to reflect
                     its municipalities. Grants will be in-                the special circumstances of NYC. What
                     cluded in future work on this project.                stands out in New York are the scope

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                         and level of its taxes. In 1994, per capita         able to shift a portion of taxes forward
                         tax revenues in New York were $2,470                to consumers outside of the region.
                         per capita. This amount was almost two
                         or more times as high as any other city             In NYC, a relatively high proportion of
                         except Washington D.C. (U.S. Bureau of              output is produced in sectors with
                         the Census, 1994). Though this differ-              market power that extends beyond the
                         ence would be reduced if one were to                region. New York is a center of national
                         take account of differences in govern-              and world finance. The securities
                         mental organization—e.g., Los Angeles               industry dominates the national market,
                         has an independent school district,                 with almost 42 percent of national
                         whereas New York does not—and New                   output produced in New York.4 About 17
                         York’s unusually high level of responsi-            percent of wages and salaries in NYC
                         bility for welfare programs, taxes per              comes from the securities industry, versus
                         capita would still be high in NYC. The              only 4 percent of employment. About 38
                         city has a broad-based personal income              percent of revenues from the unincorpo-
                         tax, a local sales tax, a corporation               rated business tax and the general
                         income tax, an unincorporated business              corporation tax comes from the finance,
                         tax, a commercial rent tax, and a highly            insurance, and real estate sector.5
                         differentiated property tax.3 The RTS will
                         underestimate New York’s fiscal capac-              Under the income with exporting
                         ity, because the average tax rate is close          approach to fiscal capacity, it is also
                         to zero for a number of taxes used only             difficult to adjust for significant differ-
                         by New York. For example, in 1994,                  ences in tax authority. Following Ladd
                         13.5 percent of NYC tax revenue was                 and Yinger, define the average export
                         derived from the corporation income                 ratio for any jurisdiction as
                         tax, versus zero in all other cities except
                         Washington, D.C.
                                                                              3
                         The standard incidence and exporting

                                                                                  Σ ( REV) e
                         assumptions under the income with                         n
                                                                                        Revj
                         exporting concept will also underesti-              e=                 j
                                                                                  j=1
                         mate NYC’s fiscal capacity. In particular,
                         the assumption that all taxes on capital
                         are shifted backward to labor and land
                         within the region seems inappropriate.              where Revj is revenue from tax instru-
                         The traditional analysis of tax exporting           ment j, n is the number of separate tax
                         classifies firms according to whether               instruments available, REV is total tax
                         they produce for local markets or                   revenues and ej is the export ratio of
                         national markets (McLure, 1967;                     instrument j. Under a general or
                         Bradbury and Ladd, 1985). Firms                     unconstrained measure of income with
                         producing in local markets are assumed              exporting, n would include all taxes
                         to be able to raise prices to the extent            available to any of the jurisdictions,
                         that there are no untaxed alternatives.             while REV would be hypothetical total
                         Thus, property taxes on rental housing              revenue that could be raised if the
                         are shifted forward to tenants. Taxes on            jurisdiction used all n taxes. Empirically,
                         firms producing for competitive national            the problem is that such a hypothetical
                         markets cannot be shifted to consum-                revenue concept is by definition never
                         ers, so they are borne by labor and land.           observed, so it is difficult to construct an
                         Firms with national market power are                empirical correlate.

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                     If instead of hypothetical revenue one             individual income tax. The income
                     uses actual revenue, equation 3 will lead          concept is New York adjusted gross
                     to an underestimate of exporting in                income, which is reported at the school
                     jurisdictions with broad taxing authority.         district level.6 For population, we use the
                     To see this, consider a jurisdiction that          number of income tax filing units, which
                     can levy only a property tax, versus a             should be a good approximation to the
                     second jurisdiction that gets 75 percent           number of families in each jurisdiction.
                     of its tax revenues from the property tax          Unfortunately, school districts and
                     and 25 percent from an earnings tax.               towns are frequently not coterminous in
                     Suppose that both jurisdictions have an            New York State. For towns that contain
                     export ratio for the property tax equal to         more than one school district, we
                     1.0, while the second jurisdiction has a           aggregated the income and property tax
                     0.3 export ratio for its earnings tax.             data up to the town level. For school
                     Using actual revenues, e1 equals 1.0,              districts that overlapped more than one
                     whereas e2 equals the weighted sum of              town, we allocated the school district
                     0.75.1.0 and 0.25.0.3, or 0.825. It is             totals to their respective towns.7 We
                     counterintuitive that the city with                restrict our sample to towns and cities
                     broader taxing authority can export a              with at least 5,000 filing units.
                     smaller fraction of its tax burden.
                                                                        Table 1 shows income and property
                     To address the problem of outlier                  values for NYC and the region. As
                     jurisdictions with more taxing authority           shown in column (2) of Table 1, despite
                     than the rest of the sample, we first              the concentration of high-income
                     compute an intermediate case of tax                individuals in some neighborhoods of
                     capacity under income with exporting.              Manhattan, the data show that the
                     In this first step, we use only the                relative income of persons residing in
                     property tax, which is the only tax                NYC is low compared to the region.
                     common to all jurisdictions. To approxi-           NYC ranks 33rd out of 38 jurisdictions,
                     mate the exporting ratio for NYC, we               with a value equal to only 75 percent of
                     then compute a separate exporting ratio            the median for the sample. By contrast,
                     for those taxes that are unique to the             the richest jurisdiction in the sample,
                     city, and add this ratio to the property           Scarsdale, has a per filing unit income of
                     tax exporting ratio.                               $192,000, almost five times that of
                                                                        NYC.

                     RESULTS
                                                                        Given the concentration of high-rise
                     We base our analysis on NYC and                    office buildings in Manhattan, one
                     jurisdictions in the five counties that            would expect NYC’s property tax base to
                     make up the Metropolitan Transit                   be high relative to its resident income.
                     Authority region. The counties are                 Surprisingly, this is not the case. The real
                     Westchester, Nassau, Suffolk, Rockland,            property base is about 3.1 times larger
                     and Putnam. The jurisdictional unit is             than resident income in both NYC and
                     cities and towns. Data on market value             the median suburban jurisdiction.
                     and property tax revenues are compiled             Consequently, NYC’s property tax base
                     by the State Comptroller from surveys              is low, equal to only 76 percent of the
                     conducted by the Office of Real Property           median, ranking 34th in the region. The
                     Services (New York State Comptroller,              fourth and fifth columns of Table 1
                     1997). Data are from the 1995 fiscal               decompose the property tax base into
                     year. 1995 income data come from the               its two main components, residential

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                                                                         TABLE 1
                                                 1995 INCOME AND PROPERTY VALUES IN NYC AND THE REGIONa
                                                        (PER NEW YORK STATE INCOME TAX FILING UNIT)
                                                 (1)              (2)                (3)                    (4)                   (5)
                                              Number          New York           Market Value         Market Value          Market Value of
                                              of Filing        Adjusted            of Real            of Residential         Commercial
                                               Units         Gross Income         Propertyb              Property              Property
                         NYC                 2,771,154         $38,901             $122,074              $66,909c               $45,407

                         Median (of 38
                          jurisdictions)       506,178d          51,904             160,644              114,906                 29,556

                         NYC/median               —               0.75                0.76                 0.58                   1.54

                         NYC rank                 —               33rd                34th                  37th                      8th

                         Highest                  8,620        192,053              345,128              319,620                 10,893
                         Source: New York State Comptroller (1997).
                         a
                           Sample includes towns or cities with 5,000 or more filing units in NYC and Westchester, Nassau, Suffolk,
                         Rockland, and Putnam counties.
                         b
                           Excludes tax exempt property.
                         c
                          Calculated adjusting for undervaluation of Class 2 Cooperatives and Condominiums (see endnote 7).
                         d
                           Number of filing units in the rest of the sample.

                         and commercial.8 The importance of                           only about half of the RTS amount. The
                         Manhattan’s central business district is                     difference between actual and potential
                         shown in column (5), giving the city a                       revenues shows the extent to which
                         commercial tax base that is 54 percent                       NYC has substituted other taxes for the
                         higher than the median (per filing unit).                    property tax. The substitution reflects
                         However, as shown in column (4), NYC                         the combination of legal restrictions on
                         has a very low residential base relative                     property tax assessments in NYC and
                         to the suburbs. This difference is                           the fact that the city has much broader
                         probably correlated with the difference                      taxing authority than the suburbs.
                         in average income between NYC and
                         the other jurisdictions. Because the                         Columns (3) and (4) of Table 2 show
                         residential base is so much greater than                     fiscal capacity under the income with
                         the commercial base, the disparity in                        exporting approach. The export ratios
                         residential base dominates the overall                       used in calculating fiscal capacity, and
                         city-suburban comparison.                                    the rationale for the ratios chosen, are
                                                                                      shown in Table 3. Column (3) shows
                         Tax capacity results are shown in Table                      fiscal capacity with only the property tax
                         2. The first column shows actual tax                         assumed to be exported. To calculate the
                         revenues in NYC. Column (2) shows the                        standardized burden, we allocated the
                         restricted RTS measure, based on the                         county sales tax total back to individual
                         property tax alone. This measure can be                      jurisdictions in proportion to the
                         interpreted as the revenue NYC could                         jurisdiction’s share of county adjusted
                         raise if it had the same rules on taxing                     gross income.9 Because of its high
                         authority as the suburban jurisdictions.                     proportion of commercial property, NYC’s
                         Under this measure, NYC’s rank is 34                         fiscal capacity increases to $2,684 and its
                         out of 38, reflecting its relatively low                     rank moves up from 34th to 24th. How-
                         property wealth per filing unit. The                         ever, it is still below the median for the
                         number in parentheses shows actual                           region and is only 31 percent of the fiscal
                         property tax revenues in NYC, which are                      capacity in the richest jurisdiction.

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                                                                        TABLE 2
                                       1995 FISCAL CAPACITY IN THE NEW YORK REGION USING ALTERNATIVE MEASURES
                                                         (PER NEW YORK STATE TAX FILING UNIT)
                                                (1)                         (2)                    (3)                (4)             (5)
                                           Actual Tax                 Representative          Income Plus       Income Plus
                                          Revenue from                 Tax Capacity             Exporting        Exporting;
                                              All Tax               Property Tax Onlya        Property and      Export Ratio
                                             Sources                 (Actual Property           Sales Tax       for All Major     Maximum
                                              (1994)                   Tax Revenue)               Onlyb             Taxes)        Revenuec
                     NYC                   $6,529d                       $2,070                  $2,684            $3,757e          $7,095
                                                                          (1,074)              (e = 0.58)
                     Median (of 38
                      jurisdictions)        3,183f                         2,724                  3,132             3,132       not available
                                                                           (2,738)             (e = 0.38)

                     NYC/median              2.05                           0.76                 0.86                1.20             —

                     NYC rank                                               34th                 25th                15th             —

                     Highest                7,583   f
                                                                           5,853                     8,786          8,786       not available
                                                                          (5,329)
                     a
                       Calculated as (0.01695)*(property tax base per filing unit). 0.01695 was the average tax rate in the region.
                     b
                       Assumes that only the property tax is exported. Calculated as 0.0437*Y(1 + eprop). The scalar 0.0437 is the
                     average burden on residents of the property tax and the sales tax. eprop is the export ratio for the property tax.
                     c
                       Computed as the sum of estimated summits of NYC’s revenue hills for the personal income, sales, property, and
                     corporation income taxes (Haughwout, 1997).
                     d
                       Calculated by dividing NYC per capita tax revenue of $2,470 by 0.378, the ratio of tax filing units to population.
                     Per capita tax revenue comes from U.S. Census of Governments (1994).
                     e
                       Calculated as 0.0437*Y(1 + eNYC). eNYC is the average exporting ratio for NYC, assumed to equal 1.21.
                     f
                      Calculated as the sum of the local property tax plus the jurisdiction’s share of county sales tax revenues, allocated
                     in proportion to the jurisdiction’s share of county income.

                                                                              TABLE 3
                                                                          EXPORTING RATIOS
                                                Property Taxa                                                       NYC Specific Taxes
                     Commercial              Industrial property:            Residential property:              Personal income tax: 0.05b
                     property: 1.5                   2.0                            0.05                         Corporation income tax,
                                                                                                             unincorporated business tax: 2.0c
                                                                                                                     Sales tax: 0.42d
                                                                                                                 Commercial rent tax: 1.5e
                     a
                       These values are similar to those used by Bradbury and Ladd (1985).
                     b
                       Nonresidents comprise about 12 percent of taxable income and are taxed at a flat rate of 0.45 percent, versus an
                     average rate on residents of 3.5 percent.
                     c
                      Based on the degree of national and international market power of New York firms.
                     d
                       Based on an estimated 30 percent of taxable sales made to nonresidents.
                     e
                       Assumed to be the same as the exporting ratio for the property tax on commercial real estate.

                     Column (4) of Table 2 adds the average                              mated fiscal capacity now moves up to
                     exporting ratio for NYC’s unique taxes—                             a rank of 15th, 20 percent above the
                     business and personal income taxes and                              median. These results are of course
                     the commercial rent tax—to the                                      sensitive to the exact exporting assump-
                     property tax exporting ratio in column                              tions chosen. However, it is clear that
                     (3). The overall exporting ratio for the                            greater ability to export taxes raises the
                     city under this approach is 1.21,                                   City’s fiscal capacity substantially relative
                     implying that, for every $1of tax borne                             to the suburbs. Comparing columns (1)
                     by city residents, an additional $1.21 is                           and (4), actual tax revenues in NYC are
                     paid by nonresidents. The City’s esti-                              37 percent higher than they would be if

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                         New York imposed the region-wide                      assumptions in this paper. Given the big
                         average burden on its residents.                      difference between actual revenues and
                                                                               fiscal capacity so measured, the results
                         For comparative purposes, in column                   suggest that very high exporting ratios
                         (5), we also show maximum fiscal                      would be required to close the gap.
                         capacity under the revenue hill ap-                   Thus, it seems likely that the actual tax
                         proach, estimated at $7,095 per filing                burden on NYC residents substantially
                         unit for the four major taxes                         exceeds the standardized tax burden for
                         (Haughwout, 1997). While one should                   the region.
                         be skeptical about the exact numbers,
                         the revenue hill approach suggests that,              While the tax capacity results are
                         in 1995, New York was close to the                    suggestive, to assess more fully the fiscal
                         economic limits on its ability to tax.                competitiveness of NYC in its region, we
                                                                               must expand the sample to include
                         Conclusions                                           fiscal data for northern New Jersey and
                                                                               Connecticut. We must also take account
                         Despite the concentration of commercial               of state and federal aid, variations in
                         activity in Manhattan, as of 1995, NYC                expenditure responsibility, and variations
                         had a low level of economic resources—                in the cost of providing public services.
                         personal income and property wealth—                  The next stage of this project is devoted
                         relative to other jurisdictions in the                to this task.
                         region. Both its income and its property
                         wealth per filing unit are 25 percent less
                         than the median. While the City’s                     ENDNOTES
                         relative position has probably improved
                                                                                   This paper draws upon work done with the New
                         slightly since 1995, the long process of
                                                                                   York City Independent Budget Office. I thank David
                         urban decentralization has left the                       Belkin, George Sweeting, and Luan Lubuele for
                         largest city in the United States impover-                their considerable help with both data and
                         ished relative to the region.                             concepts, and Ronnie Lowenstein, chief economist
                                                                                   for the IBO, for encouraging me to consider the
                                                                                   issues. I would also like to thank Andy Reschovsky
                         When we translate economic resources                      for detailed and insightful comments on an earlier
                         into measures of revenue raising capacity,                draft. The views presented are those of the author
                         New York’s relative position improves                     and should not be attributed to the IBO.
                                                                               1
                         somewhat. Taking account of a                             If each of the n jurisdictions whose fiscal capacity is
                                                                                   being compared is weighted equally in computing
                         jurisdiction’s ability to export a portion of
                                                                                   the average tax rate to apply to a given base, then
                         the property tax on nonresidential real                   each jurisdiction’s influence on the average tax rate
                         estate, NYC’s fiscal capacity is 86 percent               will be proportional to 1/n. If jurisdictions are
                         of the median. When we allow for the                      weighted by their relative population in computing
                                                                                   average tax rates, then the effect will be
                         City’s additional ability to export a
                                                                                   proportional to popi / ∑ pop.
                         portion of taxes on business income,                  2
                                                                                   This assumption would seem to be inconsistent
                         estimated tax capacity is 20 percent                      with the Mieszkowski result that it is the
                         greater than the median. However, actual                  differential rate of taxation of capital that is borne
                         taxes in NYC were substantially higher                    by the locality (Mieszkowski, 1972).
                                                                               3
                                                                                   The NYC ratio of effective property tax rates on
                         than the level implied if NYC imposed a                   non-residential to residential property is on the
                         standardized burden on its residents.                     order of four to one, as opposed to a national
                                                                                   average differential of 1.15 to one (Chernick and
                                                                                   Reschovsky, 1997).
                         The income with exporting measure is                  4
                                                                                   The data source is the U.S. Department of Commerce,
                         of course sensitive to the exporting                      Bureau of Economic Analysis, CA05 Series, Regional
                         assumptions used. We have used middle                     Economic Information Series Data Base, 1994.

                                                                         539
National Tax Journal
Vol 51 no. 3 (September 1998) pp. 531-40

                                                                                            NATIONAL TAX JOURNAL VOL. LI NO. 3

                     5
                         The data source is the Executive Budget of the City            Bradbury, Katherine, and Helen Ladd.
                         of New York FY 1999: Message of the Mayor,                     “Changes in the Revenue-Raising Capacity of
                         pages 57 and 63.                                               U.S. Cities, 1970–82.” New England Economic
                     6
                         Because the tax-based income concept excludes                  Review (March–April, 1985): 20–37.
                         most transfer income, and the proportion of                    Chernick, Howard, and Andrew Reschovsky.
                         income from transfers is likely to be higher in                “Urban Fiscal Problems: Coordinating Actions
                         central cities than in suburban jurisdictions, the             among Governments.” In The Urban Crisis:
                         income measure probably undercounts income in                  Linking Research to Action, edited by Burton A.
                         NYC relative to the other jurisdictions.                       Weisbrod and James C. Worthy. Evanston:
                     7
                          The residential property value data for NYC were              Northwestern University Press, 1997.
                         adjusted to reflect the treatment of Class II
                         cooperatives and condominiums under New York’s                 Haughwout, Andrew.        “Taxes in New York
                         property classification law. Under Section 581 of the          City: An Examination of the Long Run
                         law, these types of residential property are valued at         Implications of Rate Increases for Bases and
                         the same rate as comparable rental units subject to            Revenues.” Princeton University. Mimeo,
                         rent regulation. Because rent regulation lowers the            preliminary version, 1997.
                         market value of a rental building, the rule makes              Inman, Robert. “The Local Decision to Tax:
                         the estimated market value of cooperatives and                 Evidence from Large U.S. Cities.” Regional
                         condominiums less than their true market value.                Science and Urban Economics 19 No. 3 (August,
                         The value of this reduction is substantial, with true          1989): 455–92.
                         market value ranging from 2.5 to 3 times the legal             Inman, Robert, Steven Craig, and Thomas
                         “market value” over the local business cycle. While            Luce. “The Fiscal Future for American Cities:
                         the state conducts an independent survey of                    Lessons from Three Cities.” Wharton Real Estate
                         properties to obtain an equalization rate, it uses the         Working Paper #189. Philadelphia: The
                         Section 581 values for coops and condos. Coops                 Wharton School of the University of Pennsylvania,
                         and condos comprised 43 percent of Class II                    1994.
                         assessed value, and our adjustment increases their
                         estimated market value by a factor of 2.5, from the            Ladd, Helen F., and John Yinger.      America’s
                         state estimate of $38 billion to $95 billion.                  Ailing Cities: Fiscal Health and the Design of
                     8
                         In the six county New York region, these two types             Urban Policy. Baltimore: The Johns Hopkins
                         of property comprise about 90 percent of total                 University Press, 1990.
                         market value.                                                  Mieszkowski, Peter.      “The Property Tax: An
                     9
                         However, because we had no data on nonresident                 Excise Tax or a Profits Tax?” Journal of Public
                         shopping patterns for the suburban jurisdictions,              Economics 1 No. 1 (April, 1972): 73–96.
                         we assume that the tax is not exported.
                                                                                        McLure, Charles E., Jr. “Tax Exporting in the
                                                                                        United States: Estimates for 1962.” National
                                                                                        Tax Journal 20 No. 1 (March, 1967): 49–77.
                     REFERENCES
                                                                                        New York State Comptroller.      Overlapping
                     Advisory Commission on Intergovernmental                           Real Property Taxes, Tax Levy and Tax Rate
                     Relations. Measuring the Fiscal Capacity and                       Statistics: New York State Local Governments,
                     Effort of State and Local Areas. Washington,                       Fiscal Year Ending in 1996. Albany, May,
                     D.C.: ACIR, 1981.                                                  1997.

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