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Working Paper 2007-1 How the Border Behaves as a Tax Application of the Marginal Effective Tax Rates (METR) methodology to issues of increased border security * David Gillen Centre for Transportation Studies Sauder School of Business University of British Columbia Vancouver, BC Email: [email protected] Alicja Gados Centre for Transportation Studies Sauder School of Business University of British Columbia Vancouver, BC Copyright © 2007 by Centre for Transportation Studies Introduction The METR is a powerful analytical concept and tool that measures the effectiveness of taxes at the margin. The government may wish to induce industry to invest in certain projects or technologies that may have economy-wide effects or positive externalities. They can induce the private sector to make these investments by altering tax policies, and they can use METR to measure their effectiveness. The impact of investment incentives can be discovered by computing how the METR is affected by each individual incentive. The benefit is that variables can be measured in isolation. Our argument is that the concept of marginal effectiveness can be applied to border policies. Since 9/11, the border has become a subject of stricter security controls and protocols and has effectively become a stronger barrier to trade. Problems are caused by constrained border resources and increased demand exhibited in increased delay time. It is causing inefficiencies for commercial vehicles (CVO). In addition strict security checks are causing even more congestion, and increased variability. This means that delay time has a high variance. This causes scheduling inefficiencies and prevents the industry from reaching equilibrium. The Marginal Effective Tax Rate The marginal effective tax rate, or METR measures the tax wedge at the margin for a given type of capital demand, or the extent to which the tax system affects the marginal rate of return from holding the asset. The METR provides a summary measure of the cumulative tax distortion on a marginal investment decision (McKenzie 1994). METR is the difference between the gross of tax rate of return to capital at the margin in the private sector and the rate of return received by savers after tax (Boadway, Bruce et al. 1984). Marginal effective tax rate (METR) calculations have been widely investigated by the World Bank. McKenzie and Mansour (1998), McKenzie et al (1997), McKenzie (1994), McKenzie et al (1992), Boadway et al (1984), Boadway et al (1987), Boadway and Shah (1992) and Chen (2000), have explored this area in detail. The METR is the effective tax rate on marginal revenue, or the revenue generated by the last unit, marginal cost, of capital invested (Chen 2000). It is evaluated as the effective tax cost as a share of MC, net of economic depreciation. Firms pay income tax on the revenue generated by their capital investment, but reduce cost by writing off the cost of debt, they also defer tax liabilities. The pre tax rate of return is the same as the pre tax cost of capital or the net of economic depreciation, and the METR is the ‘wedge’ between that rate of return and the post tax return on capital, expressed as a fraction of the pre tax return. The METR can be applied to depreciable and non -depreciable assets as well, such as land and inventory, where depreciation (economic and tax) is zero. The marginal involves measuring the before tax rate of return on savings. * Research funded by a grant from the Bureau of Intelligent Transportation Systems and Freight Security. 1 METR methodology has several limitations. They measure only the size of the impact of tax measures on rate of return, and not responsiveness of investment. This means the usefulness is limited to making qualitative judgments to compare alternate investments. The drawback arises from the lack of technique to empirically measure investment demand. The positive benefit of using METR is it isolates tax considerations completely from others (McKenzie 1994). METR comparisons are made to show tax distortions across asset types and industries within a tax regime, or to evaluate the competitiveness of tax regimes. The comparisons help investors allocate their capital in response to variations in tax burdens. As such, it helps policymakers revaluate distortions within their jurisdictions. When studying METRs key assumptions made are that markets are perfectly competitive, firms behave as profit maximizers, and capital is fully mobile. The tax comparisons are meaningful because a firm is free to enter and exit a market, taxes will affect the investment decision. Among all tax comparisons, only the METR matters because it alone bears on the decision making margin (Chen 2000). However it is only good for evaluating the tax factors that bear on capital allocation decisions. It tells a comparative story about tax systems but does not reveal other underlying factors that may be relevant, and non-tax factors may play a more important role in investment decisions. The information content of METRs is limited. While it shows the size of the incentive imposed on the margin on a particular sort of investment decision, it does not show the magnitude of response to the incentive, nor the tax revenue effects to public sector. While METR calculations will be useful for analyzing tax reform issues they will be less so for the positive analysis of the effect of incentives on economic activity (Chen 2000). Average or marginal tax rate? The average effective tax rate, AETR and the marginal effective tax rate, METR, are two very different methodologies not to be confused because they are very different indicators. The AETR is a numeric ration of total taxes to pre-tax return for a set of one or more investment projects; it is a number featured in an income statement but does not have much use economically. It is not useful in decision making or forecasting, but it is a historical representative and an ex ante variable. It is marginal, not average factors that drive investment decisions. In METR, the word effective emphasizes all tax provisions, tax allowances, inventory accounting methods, and so on. With an AETR, effective represents the taxes incurred, but does not account for non-tax features of the investments. The expected pre tax on capital income is the expected pretax rate of return on a new marginal investment, divided by the pretax rate of return. (Fullerton 1995). METR can account for detailed provisions of the tax law. The METR is a forward-looking measure that summarizes the incentives to invest in a particular asset as provided by complicated tax laws. It bears little relation to an average tax rate 1, because that measures averages over taxes on income from all past investment. Estimates of METR will depend on particular assumptions about equilibrium in capital markets, rate of discount, inflation, expectations, financing, risk, and dividends. The simplest example is drawn from a world with no uncertainty. 1 Actual tax paid in a year divided by the actual capital income in that year 2 METR: exploration of a concept There are many ways of encouraging investment. The effects can be measured with METR. First, reductions in tax rates, whether permanent or temporary, can affect the sign of METR. This can be either positive or negative depending on the generosity of deductions and credits for capital costs. In the absence of investment tax credits, a corporate income tax will be neutral if the present value of deductions for capital costs, interests and depreciation just equal the initial cost of capital (Chen 2000). If present value of deductions exceeds the initial capital cost, the METR is negative, et cetera. If the effective tax rate is already negative, reductions will make it less negative, thereby reducing the incentive that already exists for investment. This is the ambiguous effect of tax rate reductions is because tax rate applies to both deductions and revenues. Measures which apply only to deduction side would be expected to have unambiguous effects of the direction of change in incentive to invest (Chen 2000). Chen (2000) gives examples to explain METR. Suppose a firm wishes to diversify through capital investment, and the pretax return profile is the same across all sectors, the firm will chose the investment that offers the lowest effective tax rate on capital investment in Canada. Or suppose a manufacturer wishes to expand operations within NAFTA boundaries. The decision will be based on which country offers the most attractive net return on capital. This is not surprising, as any rational investor will allocate capital to maximize profit. In a market with free entry, profit from every dollar invested will grow as long as the revenue from the last dollar invested, or the marginal revenue is greater than the cost of that dollar invested, or the marginal cost. Neoclassical theory dictates that profit from the investment is maximized when marginal revenue equals marginal cost. (Chen 2000). Tax policy affects marginal revenue and cost: taxes reduce marginal revenue and tax allowances reduce marginal cost. At the profit maximizing point, where marginal revenue equals marginal cost, the combined effect on marginal revenue, or cost, is the METR. The METR is the wedge between the before tax and post tax rates of return on capital, expressed as a percentage. Given equal nontax considerations, a rational investor will invest in the sector where METR is lowest. To the extent taxes play in an investment decision, the only tax rate that matters for capital allocation is the METR (Chen 2000). Taxing Inputs The government wishes not to tax business inputs, but inherently does so via several tax structures, such as a through a retail sales tax (McKenzie, Mansour et al. 1998). To calculate METR on inputs, McKenzie records four types of tangible capital (structures, machinery, land and inventories) and two types of intangible capital and labour. When looking at the impacts of taxation, it is important to look at if they are marginal and incremental economic decisions. The decision to hire one additional worker, employ an additional unit of capital, increase output by an additional unit. The METR is the amount of tax arising from the decision of a firm to undertake one more unit of economic activity. In the case of capital, the activity is the employment of an incremental unit of capital, in the case of production it is the employment of additional increment of output, in the case of security it is the employment of an 3 additional unit of “protection” (however vaguely that may be measured, since an incremental increase in security is near impossible to quantify). The U.S. Department of Homeland Security (DHS) measures the level of security via a threat indicator; 2 this may be used as their baseline for calculating the level of security that needs to be increased at borders. Because incremental effects of an increase of one variable are estimated, a positive METR indicates that a certain activity is discouraged by a tax system. A negative METR indicates that the activity is encouraged by the tax. A zero indicates neutrality, so the activity generates no tax revenue at the margin but infra marginal units of the activity may generate tax revenue. Taxes imposed on capital can effect both the level and composition of an economy by distorting the return to an incremental unit of capital. The METR on capital is a summary of the size of the distortion. Empirical research reveals that taxes levied on capital discourage investment to some extent. Interasset distortions can arise as well. Differences in METRs across capital can create inter-industry distortions, and over time, across assets, among sectors and jurisdictions (McKenzie, Mansour et al. 1998). The METR can be distributed like a contagion throughout the firm. Impacts demonstrate the co movement in cross-market linkages. Close market trade linkages explain the mechanism of contagion (Gillen and Lall 2003). These capital distortions are important because it can lead to a reduction in level of goods and services produced, or efficiency costs of capital taxation. Also, taxes on capital may also effect the rate of growth of the economy through their impact on investment. McKenzie et al (1998) distinguishes between two basic types of METRs. The METR on inputs, tangible capital such as buildings, equipment, land and inventories, and intangibles like R&D, measure the taxes incremental unit of input consumed by a firm. The second is METR on costs, which measures the contribution of taxes levied on the various inputs to the cost of producing an incremental unit of output. Input METRs indicate the extent to which taxes impede on the incentive to employ these inputs, and the cost METRs (a function of input METRs) measure the impact of the taxes on competitiveness (McKenzie, Mansour et al. 1998). The approach taken by McKenzie for METR on costs incorporates the vertical linkages between input and output markets. The output market is connected to the input market by the fact that the aggregate supply curve is the horizontal sum of the marginal cost curves. The marginal cost of providing an additional unit of output hence reflects the user cost of the various inputs, reflecting supply and demand conditions in the input markets. Supply is a function of the vector of input prices. The connection of input and output markets is a key measure of the METR on costs of production. If the tax system causes costs to rise, the industry supply curve will rise. Under some conditions, input taxes do not affect marginal costs because they do not feed through to user costs. This happens when supply is perfectly inelastic and demand is perfectly elastic. The extent to which they will be reflected depends upon supply and demand conditions in the user markets. The marginal cost function will depend on level of output, productivity measures, input shares and degree of substitutability between factors (McKenzie, Mansour et al. 1998). His model shows that as elasticity of substitution increases, the effective tax rate on marginal costs decreases. As the degree of substitutability rises, firm is better able to respond to changes in 2 http://www.dhs.gov/xinfoshare/programs/Copy_of_press_release_0046.shtm 4 relative factor prices by changing the input mix. A tax induced increase in the relative price of an input as a lower impact on marginal costs, the higher the elasticity of substitution. Policy issues often turn to the overall tax burden faced by companies. There is evidence that the tax system, in general, rather than only taxes on capital may influence the location of production facilities across jurisdictions (McKenzie, Mintz et al. 1997). Tax burdens can be computed in several ways to analyze the effect. One way involves measuring the effect of corporate income and other taxes on the return to capital, and the second involves measuring the METR on capital, grasping the user cost of capital. However, some taxes other than those that tax capital could influence the decision of a business to operate in a particular jurisdiction. Border congestion and mandatory security programs could be such a tax that does not charge capital directly but influences a firm’s decisions, including output and productivity. Risk & uncertainty There are different types of capital assets that may be disrupted (positively or negatively) by a border tax (METR). The concept of risk and reversibility is explored in a paper by McKenzie (1994). In the paper he claims that the tax system may distort incentives in risky capital to a much greater extent than defined in previous research because the issue of irreversibility (McKenzie 1994). The METR on costs measures the contribution of various taxes levied on inputs to the marginal cost of production. Tax levies contribution to the marginal cost of production provides a measure of the extent to which the tax system impinges upon the cost of doing business. Risk can dramatically increase the METR on capital, implying that tax systems discourage firms from undertaking some risky types of investments (McKenzie, Mansour et al. 1998). Corporate taxes distort firms investing rules in two ways: the return on a marginal unit of capital is lowered because the operating income it generates is taxed, and the effective price of a unit of capital is decreased owing to the flow of depreciation deductions (McKenzie 1994). There is also the issue of irreversibility as analyzed by McKenzie (1994). The concept of the cost of capital is important when analyzing tax policy and investments. METRs are used regularly as an indication that the tax system may impinge on firms’ investment decisions. METRs are an important component for formulation of tax policy, used widely by governments and are calculated based on a partial equilibrium dynamic neoclassical investment model. Risk and uncertainty has been shown to dramatically increase the METR on capital, so some tax systems would discourage firms from undertaking some types of risky investments. In addition, there are capital investments that are essentially irreversible, and have no meaning in other types of production. The literature treats capital investments as fully and costlessly reversible which is inappropriate for certain types of capital. Some capital is so specialized it is only valuable in a certain type of production. The conversion to alternate use is very costly. Since most ITS investments are irreversible, and have no auxiliary use, would it discourage a firm from taking a ITS investment over an alternative firm building investment? The literature suggests that CVOs are skeptical about the new ITS technology, and adoption rates of ITS remain low. This is because the trucking industry is driven by immediate or short term requirements on ROI. ITS investment by 5 carriers must meet several requirements, including short term ROI, managemeble per unit costs, and ease of use to economize on labour and training costs. The objectives of the technology should be quantifiable benefits to operational efficiency, productivity and safety (Donath 2005). This issue raises the idea of investment decision under uncertainty. The results of McKenzie (1994) suggest that risk and irreversibility of different types of capital cannot be ignored because of serious alterations the measurement of tax distortions. The METR on irreversible capital is higher than on reversible capital, and the magnitude of the distortion depends on the type and level of risk. If capital is irreversible, METR depends on both systematic an unsystematic income and capital risk and is increasing in all four types of risk. The extent that capital is inflexible in use the tax system may discourage investment in risky capital more so than currently thought. In their model, capital is assumed on have value only if used in production, and is completely irreversible. The type of risk is important too, as demonstrated by Bulow and Summers, that different types of uncertainty are important as well as ex ante depreciation (Bulow and Summers 1984). McKenzie distinguishes between two types of risk, income and capital risk. Income risk involves the uncertainty with future income, and capital risk involves replacement value of a firms’ capital. Income risk is associated with unknown future demand (the uncertainty of the demand function). In his analysis, he used the risk free rate as the discount rate, which hides some effects that prove important in the analysis of tax distortions under uncertainty. For example, the CAPM 3 capital market equilibrium requires that the firm values its investment program as if preferences were risk neutral, which may not necessarily be the case. The user cost if irreversible capital differs in an important way from the expression for reversible capital, reflecting a cost for irreversibility. When capital is fully reversible, the neoclassical result shows the firm employs capital up to the point where the marginal unit earns just enough to cover it’s cost, which is the opportunity cost of financing the investment plus the physical rate of depreciation less capital gain plus a risk premium to compensate risk averse investors for bearing systematic capital risk, for that unit of capital. In conventional analysis, where capital is considered reversible, capital adjusts instantly to discrepancies equality between ROR and on a marginal unit of capital and the user cost is maintained at each instant (McKenzie 1994). In the case of irreversible capital, the firm cannot immediately lower its capital stock, but instead allows for depreciation. When this is the case, the ability to delay an incremental investment has value in a risky environment. Waiting to install a unit of capital is costly because it delays realization of operating profits, but beneficial because it delays payment of unit price allows one to learn more about behavior of the stochastic variables causing the distortion. To determine METR in Canada, a small open economy is a price taker on international markets and treats the required after tax ROR on equity as exogenous. This means that the risk free rate, and systematic risk are exogenous. Investments must yield the internationally determined risk free rate of interest net of corporate taxes, depreciation and risk. 3 Capital Asset Pricing Model 6 The case of irreversible capital also changes tax depreciation. Without uncertainty, the neutral tax depreciation rate is the physical rate of depreciation less the rate of capital gain on a unit of capital. But with certainty, an additional term must be added to reflect the cost of dealing with systematic capital risk. This is because depreciation calculations are made ex ante based upon the original purchase price of the capital, and do not fluctuate with changes in purchase price. Therefore, the government does not share in the firm’s capital risk therefore an explicit deduction must be made to account for it in the model. No adjustment is necessary when capital is reversible, because under this assumption the firm’s capital fluctuates with changes in income. Income risk is implicitly deducted under a full loss offset tax system, since the government fully shares in this type of risk through fluctuations in tax revenues. Therefore, the government has incentive to structure the tax rates favorably to firms. Via calculation of METRs McKenzie provides that the Canadian tax system is decidedly nonneutral. METRs range from a low in manufacturing to a high in services, differences among the sectors are due to variations in tax rates, tax depreciation and economic depreciation. On average, in Canada the METR is 41.5 per cent, about 10 percentage points higher than the risk free rate. It is greater in industries with a large risk premium (agriculture, forestry, fishing) and lower in those with small risk premiums (retail, services). Canada discriminates significantly against investments in capital risky assets compared to riskless assets. The conclusion is that an additional tax distortion imposed upon risky investments due to irreversibility can be very significant, and further, by ignoring consequences of irreversibility traditional METR estimates are under-represented by the distortion caused by corporate income tax (McKenzie 1994). Comparative statics can be applied to determine analytically how METR responds to different types of risk. There are four types: unsystematic capital, systematic capital, unsystematic income and systematic income risks. The results find though the magnitude is different for each type, the size of the tax distortion (METR) increases with all types of risk. Valuations of METR, which ignore uncertainty and irreversibility, understate the disincentive effects of corporate taxation. When taxes were lowered, 4 the failure to account for uncertainty in risk in METRs may explain why strong positive incentive effects were not observed. If they were correctly measured, they may actually have increased. There are two types of risk well characterized in the literature – income and capital risk. Income risk involves uncertainty about the future stream of net revenues, because things such as price, wage and demand are uncertain, and is reflected in fluctuations in taxable income (Chen 2000). Full loss offsetting is equivalent to allowing deductibitlity for income risk, but not sufficient to guarentee neutrality with respect to capital risk. Capital risk deals with uncertainty with deprectiation after the capital is in use. Depreciation schedules are predetermined at the time of investment, but not adjusted for with changes in actual depreciation rates (Chen 2000). In METR, the determination of financial structure is not well developed. Therefore, tax effects cannot form the basis for a postive analysis of the effects of taxes on the financial structure of firms (Chen 2000). The directions of tax incentives can be deducted as well as prescriptions for tax reform. Some studies view that only taxes matter in determining financial structures. By concentrating on tax explanations as determinants of financial structure tax policy arguments about how to avoid distortions of financing can be seen (Chen 2000). If financial decisions are separable 4 Canadian tax reform of 1987 7 from investment decisions, the optimizing choice of financial structure will give rise to different equilibrium values of the costs of different sources of finance used in METR calculations. Inducing investment METR can be used to measure the impact of investment incentives. Investment incentives are intended to induce firms to invest more by increasing the rate of return from holding assets. Firms decide how much of capital of various types to hold, when to acquire the capital, how durable the capital and how long to hold it. Boadway and Shah (1992) use the METR concept to measure investment incentives in developing countries. They find that investment incentive typically operate through the tax system either directly or indirectly. Often tax incentives are administered to encourage the economy, but the only way of measuring their effectiveness is via METR calculation. Incentives involve interfering with capital markets to encourage particular types of investment, which implies inefficiency in the way capital markets allocate investment. (Boadway and Shah 1992). It is important to measure effectiveness of investments to avoid market failure. There are several sources of market failure: • • • • • • • • • Capital income taxes: taxes can inevitably impose a distortion on investment Dynamic inefficiency: exists if it is possible to make someone better off without making someone worse off. Externalities or public goods: if each saver receives utility for saving for their children, saving will yield external benefits that are not taken into account by savers. This will lead to less saving, or a high market discount rate. Government intervention should promote increased saving. Externalities of growth: these involve externalities on the supply side, for example to firms other than those undertaking the investment. Investments, such as technological improvements can generate external benefits to other firms. Incomplete or imperfect capital markets: markets may not be perfectly functioning due to liquidity constraints, or incomplete risk markets, influencing saving and investment behavior of persons. Informational asymmetries: the profitability of investment or some firm is better known by certain people than by others. For example, managers know more than shareholders, causing differences in behavior than if everyone was perfectly informed. The two types of asymmetries are adverse selection and moral hazard. International tax competition, Distortions in other markets, such as labour or foreign exchange markets. Inconsistency of government policy, especially over time, and trying to tax old capital In their paper, Boadway et al (1992) look at investment incentives as vehicles to stimulate growth and investment in a country. Investment incentives can play a major role as policy instruments. If the corporate tax is used as a withholding device, it will impose a tax distortion on domestic investment. Investment incentives that apply at source to domestically owned capital will offset the corporate tax distortion. The investment incentive should take the form of reduced tax rates (Boadway and Shah 1992). Another consideration is for infant industry start-up, in which case incentives may be superior to tariff protection. Many of these firms are not in a good position to pay tax and may be involved in risky projects. They may be cash strapped because of asymmetric 8 information, and they cannot distinguish themselves as good or bad risks to lenders. Temporary investment tax credits may be a good option. One of the major reasons for encouraging investment is that investment generates benefits for the economy far over privately captured benefits. The similarities are much like economy-wide network improvements for nationwide freight movement (ICF Consulting, HLB Decision Economics et al. 2001; Mallett and Sedor 2004). In that case, there is a case for encouraging investment to be higher than it ordinarily would be. Smaller, growing firms who are short of internal finance and cannot self insure are sensible targets for investment incentives as well, since the corporate tax system may discriminate against them. Temporary tax incentives may be used by countries as signals of their quality as places for foreign investment. Tax incentives can also overcome time inconsistency problems, due to the unreliability of governments to commit to future tax policies. Using METR models are one of the common ways 5 to evaluate investment incentives. METR methodology is straightforward to use to determine the size of the incentives to encourage investment. One can calculate the METR in the presence and absence of incentives and see explicitly how much the incentive changes the marginal tax rate on investment decisions of various sorts (Chen 2000). Taxes can affect investment in other ways than simply the size of demand for capital, they can affect the path of accumulation of capital as well as durability of capital. Permanent incentives will affect the long run demand for capital and may affect the chosen durability of capital. The subsidy to replacement capital means firms will have the incentive to choose less durable, fasterdepreciating capital. In open economies, capital may move across borders in response to tax measures affecting investment. Tax measures such as investment incentives would affect investment side of the market but not the saving side. The ability of capital to flow in this fashion presents a number of other issues to be considered: incentives which reduce tax liabilities of foreign firms may have limited effect on incentive of these firms to invest, and may serve largely to transfer funds to home treasuries (Chen 2000). Applications to different sectors Boadway et al. (1992) does an empirical investigation of METRs facing a firm extracting a depletable asset. They also characterize the significant difference between the average and marginal tax rate. In mining for example (mining resources are depletable assets) one would expect the marginal to be lower than average due to the presence of economic rents, since an average tax rate includes the taxes generate on a marginal capital investment. This is important in industries with large rents (Boadway, Bruce et al. 1987). A tax on rents is neutral, since the values of economic costs of production are deducted from the tax base. Here the 5 There are five broad models, though not exhaustive, identified to model investment and incentives to invest. See Appendix A. 9 tax on marginal investment is zero, but the average tax rate is positive. In the mining sector, average tax rates were used as indicators on effect of the tax system on the incentives to invest, but because the sector shows large positive average tax rates, the rates could be misleading in defining incentive to invest. If marginal rates are negative, this suggests that the tax system is an inefficient collector of rents. Resource and manufacturing firms are different. Resource firms hold and exploit depletable assets, but in manufacturing, assets are all reproducible. Tax laws also differ for the two industries, mainly, costs of exploration and development are subject to write off. They also pay more to provinces in terms of profit taxes, royalties, and the like. In this paper, they find the federal and provincial 6 governments tax policies on mining distort decision-making and do a poor job of collecting rents. The METR is much lower for mining than other industries, at 16.6 per cent in Ontario and 55.6 per cent in Quebec. The taxes tend to distort the mining sector significantly. They encourage exploration and development but discourage extraction and other investment. If a tax were imposed on pure profits or rents, the METR would be zero rather than negative. The federal corporate income tax subsidizes marginal investment in the sense that companies can write off generous deductions against other sources of incomes. The size of the subsidy depends on the manner in which taxable losses can be used. The substantial range in METR on mining assets suggests that the tax policy can be improved to remove distortionary effects. A suggestion has been to use cash flow tax, which would allow expensing of investments and non-deductibility of interest costs. Such a tax would remove the distortion it creates to production and instead tax economic rents. Non tax factors naturally affect the METR when combined with tax effects. Non tax factors may cause allocative distortions that were not intended by policy makers (Chen 2000). This may be happening with security requirements across the border. Non tax factors that can cause unintended allocative distortions are: inflation, the debt to assets ratio, economic depreciation and capital structure. Inflation affects METR through cost deductions, mainly through three channels. First, since the tax of borrowing is deductible in income tax, the higher the inflation the lower the post tax real financing cost and hence the lower the METR. Second, a higher inflation rate implies a higher nominal discount rate for future tax allowances, and implies a lower present value for future tax depreciation allowances. This raises METR on depreciable assets. The third stems from the inventory accounting method. In Canada, the first-in-first-out (FIFO) inventory accounting method is used for tax purposes. Inflation may cause the reported income to be higher because current prices for replacement cost will be higher than historical prices. 7 Inflation has opposing effects on METR depending on the assets, so the impact overall on METR will depend on the capital structure in a given industry (Chen 2000). A higher debt to asset ratio may reduce METR, because the greater the ratio, the greater the potential benefit of tax deductibility for interest expenses. Economic depreciation rate and the tax depreciation allowance also play a role in METR calculation. A higher tax deprecation allowance generates more benefits through tax deferral. Therefore, the METR on capital will be lower where tax depreciation allowances are more generous. 6 7 mainly Ontario and Quebec, where most mining activities occurred in that period Inventory is written off at historical prices but replaced at higher current prices 10 It is fairly intuitive that capital structure will effect METR, since a capital investment usually involves both depreciable and non-depreciable assets, such as structures, machinery, inventory and land. An industry with a higher capital share in higher taxed assets is more exposed to higher METR in general (Chen 2000). The Canadian tax system METRs allow one to compare tax rates across different assets, business sectors and tax regimes. Variations indicate distortions in one tax regime being more advantageous than another. For instance, the Canadian tax system taxes inventory the highest, and machinery the least. If tax rates are the same across different assets and sectors, an allowance scheme that favors certain asset types can cause cross-sector or cross-asset distortion. This information is revealed by METR analysis. The METR is important because it guides firm in capital allocation and investment decisions. The government has recognized the extent that taxes play in attracting or repelling foreign capital. This has brought to attention which measure of tax rate is important in economic decision-making. The METR, and not the average tax rate (AETR) matters in capital allocation. The METR is the tax rate that bears an incremental dollar of income from investment (Chen 2000). Standard analysis finds that the labour intensive firm is taxed at a higher rate than the capital intensive firm and is disadvantaged by the tax system as a result. But in their analysis McKenzie et al (1997) propose a new method for aggregating taxes that focuses on production rather than on investment decisions, based on the theory that firms produce output until marginal revenue equals marginal cost. Taxes on outputs and inputs affect production decisions by increasing marginal cost of production, hence causing the supply curve to shift. McKenzie et al find that the labour intensive firm is in fact favored by the tax system because taxes lead to a lower percentage increase in costs of production. This is because the labour intensive firm relies more heavily on a factor of production that is taxed at a lower rate. Their measure of the METR on MC of production depends on the factor of production used by firms, types of taxes imposed and the incidence of these taxes. They provide a summary statistic of how taxes impose upon the cost of doing business. By computing tax rates on marginal production costs, speculation can be drawn on how the tax system may influence decisions of where a firm produces, but how the tax system as a whole, and not just the tax on capital may encourage or discourage certain types of production compared to others in a particular region. Their approach focuses on the linkages between input and output markets. The output market is connected to the input market via the aggregate supply curve, that is, the sum of marginal cost curves for the individual suppliers. The MC of producing an additional unit of output reflects the user cost of various inputs, which affects supply and demand conditions in the input markets. The net impact of imposing a tax regime is to increase marginal costs, but it’s possible that MC may decline if the METR on some of the inputs is negative or sufficiently negative (McKenzie, Mintz et al. 1997). 11 McKenzie et al (1997) aggregate effective tax rates in the presence of multiple inputs into a simple summary statistic. They measure METR on MC, an increase in MC of production due to imposition of various taxes on a firm’s inputs and outputs. They focus on the production decision of firms rather than the investment decision, and take account of firm technology and factor intensities. They suggest that the effective tax rate on labour is substantially lower than the tax on capital inputs, in all sectors and all provinces. Sectors, which are relatively labour intensive, with a large portion of labour expenses, are likely to face lower effective tax rates on their marginal costs. This will tend to favor service sectors. The tax rates on inventory tend to be very high suggesting that sectors with a high inventory share such as agriculture, forestry and fishing and construction, will face higher tax rates on their costs. In a cross-Canada comparison, they found that the manufacturing sector faces a lower tax rate on costs than other industries. The effective tax rate is quite low due to the lower rate imposed on manufacturing in general by both the federal and most provincial governments. The service sector in every province faces lower tax on production costs by about 10 percentage points. This occurs despite the taxes on all inputs are much higher in services. Because the service sector uses more of the lower taxed input, the METR on costs is much lower even though it faces much higher costs on each of it’s inputs (McKenzie, Mintz et al. 1997). The transportation industry faces higher effective tax rates than utilities, yet in every province the effective tax rate on costs is higher in utilities by about 8 percentage points. This is because the labour’s share of costs in transportation is much higher than other sectors. The share of taxes collected from structures is much lower in transportation, therefore the high effective tax rate does not have a significant impact on marginal cost. Corporate tax is largely a method for the government to share the risk of the corporation to smooth out stream of profits and reduce variance, hence reduce risk of the return to equity. Therefore METR may not be a distorting tax. However this is not to say that profits and losses are treated similarly by the tax system; there is far from perfect loss offsetting, which may increase the distortions (Boadway, Bruce et al. 1984). Distortions The analysis of METRs in Canada showed three types of distortions caused by the tax system: across firm sizes, production inputs and across industries. They find that small firms are treated more favorably than large firms, METR on tangible capital are appreciably higher than those on intangible capital and labour, and service industries are treated less favorably than non-services, such as agriculture, forestry, non-renewable resources and construction (Boadway, Bruce et al. 1984). Boadway et al. (1984) shows the distortion created by the Canadian tax system on capital markets in the period 1963-78. Corporate tax causes the gross marginal rate of return on capital to differ from the rate of return on funds that the firm must pay to the market. Tax can induce either a positive or negative distortion, it could cause the return to exceed or fall short of the market return depending upon the generosity of deductions or tax credits. If the present value of capital cost allowances, deductions (interest) and tax credits is less than the initial cost of the investment than 12 the distortion will be positive and investment will be discouraged. If it’s present value exceeds the initial cost, the tax subsidizes investment at the margin (Boadway, Bruce et al. 1984). The METR on capital means the income generated from that type of capital. Of the four types of capital - inventory, land, buildings and machinery – inventory is taxed most highly and machinery the least. This is because Canada’s income tax system encourages capital investment in machinery provides a generous capital cost allowance for those assets. The much higher METR on inventory is mainly as a result of the tax reporting requirement that the first-in-first-out accounting method. This may cause taxable income to be inflated when prices are rising. If the last in last out method were allowed, there would be no inflated income for tax related to inventory, so the METR on inventory would be as low as the METR for land (Chen 2000). The METR on buildings is higher than on machinery because the tax depreciation allowance for buildings, relative to their economic depreciation rate, is much less. The depreciation rate on buildings is closer to the actual economic depreciation rate while that for machinery exceeds economic depreciation. METRs vary across sectors due to different capital structures, rates and capital cost allowances. For example, the combined statutory rate for manufacturing than for other non-resource sectors is about 6 percent lower. Thus the manufacturing industry is the lowest taxed non-resource industry in Canada. However, METR is not much lower than it is for other sectors, which is surprising considering the huge gap in statutory tax rates, but this is because manufacturing places capital heavily on inventory, and inventory is the highest taxed class of assets. The METR is highest for construction among all industries – it is the highest taxed on it’s assets and it holds a significant share of capital in inventory. Chen (2000) also does a cross border comparison of METRs, and asks the question of if given a location option, in which NAFTA country should a Canadian manufacturer expand it’s business line. A cross border comparison of METRs shows that that it’s lowest in manufacturing in US, and lower yet in Mexico. If business taxes were the only distinguishing features of projects, the manufacturer would be better off investing in U.S. or Mexico production facilities. In addition, the gap between METR between manufacturing and services is much bigger in Canada than in the other two countries, indicating Canada displays a more severe inter-sectoral distortion. Inflation Boadway et al. (1984) analyze the impact of corporate and personal income taxes and inflation on the cost of investing in depreciable and inventory capital. Inflation affects the value of the firms’ write-offs from investments and thus affects the magnitude of the distortion. The distortion is not obvious: it could be positive or negative. Inflation could be stimulative at margin when combined with corporate tax. Their analysis disintegrates investments by type: depreciable versus nondepreciable capital. In measuring METR in Canada, they distinguished four different types of capital: land, buildings, machinery and inventories. The presence of inflation appears to lower the net return to savings. Taxation of inflationary capital income more than offsets the tendency for market real rates of return to rise with inflation. For nondepreciable capital, the rate of return falls considerably with inflation because of writing off of 13 nominal rather than real interest (Boadway, Bruce et al. 1984). But inventories appear to be very negatively affected by inflation. In addition, corporate taxing appears to tax inventories heavily. Inflation does not seem to significantly effect incentives to invest or the METR, except in the case of inventories. Also with the exception of holding inventories, the corporate tax structure itself does not affect the decision to invest. Since firms have been holding additional inventories since 9/11 (“hoarding”) this could also effect decisions and profitability even further. Most corporate taxes have little provision for inflation. Deductions tend to be on nominal interest rates and depreciation is calculated on historical rather than replacement terms – so inflation affects the real value of the tax base. The effect is ambiguous; inflation could increase or decrease the METR. Lack of replacement cost depreciation will reduce the size of the write off, whereby METR would increase, but ability to deduce nominal interest means at times of high inflation firms can write off a part of principal on their debt: and this tends to reduce the METR. The net effect will depend on the relative magnitude of the two forces (Chen 2000). Application to ITS and Security The analysis of METRs on the Canadian tax system reveals that significant distortions can be created by taxing inputs. The distortions would not be recognized if not for the METR methodology. In fact, the source of burden would be very difficult to identify. Since increased border regulations, especially after 9/11 are designed to promote national security interests, sectors that rely on crossing the border as part of their business model decipher the increased security as an additional tax on their business. The result is a possible disadvantage to firms that required either sourcing from cross border, access to customers cross border, or firms where their business is inherent to crossing the border, for example, transportation companies such as trucking firms, versus firms that operate exclusively in the domestic market. There is heavy literature dedicated to the relative disadvantage to industries that rely on crossing the border, due to increased security regulations, and most of the burden bore by the trucking industry (DAMF Consultants Inc. and LP Tardiff & Associates Inc. 2005). It is important to note however that there have not been very many empirical analysis of the allegations, much of the support for the argument is garnered by surveys on the trucking industry and intense speculation. A parallel can be drawn from environmental taxes as exemplified by Poterba and Rotemberg (1995). They analyze the dilemma posed with how to charge and environmental exise tax on goods when either an intermediate or final imported good is subject to some sort of environmental tax (due to it’s polluting qualities) when it crosses the border. Problems with environmental exise taxes are particularly complex because many of these taxes are levied on intermediate inputs, such as fossil fuels rather than on final goods. If the intermediate good produces pollution only where it is used, than the country that imposes the tax on domestic use of intermediate goods will experience a reduction in pollution as use of the intermediate good moves to the other country (Poterba and Rotemberg 1995). But if use of this good generates pollution that flows across the border and consequently affects residents of the 14 taxing nation, a shift in production may not be favorable. This is a situation of misaligned incentives and externalities. In their paper, Poterba and Rotemberg (1995) analyze the design of environmental taxes on imported final goods when policy makers seek to affect equal changes in the marginal costs of domestic and foreign producers. Identifying the taxes is important to ensure that they are being directed at the source of pollution – it is important to ensure that preventing exise taxes imposed on foreign producers so that environmental protection does not become an excuse for protectionism of national sectors. When it is possible to measure the amount of taxed intermediate good used to produce an imported final good, an import tax equal to the tax on the intermediate good times the amount of the intermediate good used in domestic production of the final good will raise the marginal cost of domestic and foreign producers by the same amount. When final goods are produced jointly, there is a negative result because the amount of intermediate good is not well defined, and it is not possible to prescribe the appropriate border taxes. These taxes to regulate and control environmental protection, can be security protection both try to prevent the seepage of risk, whether environmental pollution or terrorist threats, through the border. To raise the marginal cost of foreign and domestic producers by the same amount, the tax on imported good final goods must be based on the importance of the intermediate good in domestic production. Regulations that allow importers to pay taxes equal to the actual amount of intermediate good used in production, may not raise marginal cost of foreign and domestic producers by the same amount. Countries attempt to control polluters but taxing them. The polluter, or the person responsible for the pollution should be the one penalized for producing the pollution, to create accountability and create proper incentives to abate polluting. The problem arises when a good is produced using intermediate goods that come from abroad. How should intermediate goods that will be used as part of a final product, which emit pollution be structured? Where should the good be taxed? In addition, there is also a problem with externalities. This is a similar situation that is associated with national and economic security. A security threat may exist in one country and relies on permeability to advance it to the country it intends to attack. Tightening border vulnerabilities has become a policy objective in the U.S. since 9/11. Border security policies have inadvertently led to increased congestion at the border, causing supply chain disruptions and decreased reliability. Increased information requirements 8 have stressed the industry and acted like a ‘tax,’ which offer both benefits and costs, at the margin. Hence the marginal effectiveness of such policies must be addressed. The ‘taxes’ can produce externalities, both positive and negative for the economy and for the company that is being taxed. The role of border security can be broken down to benefits and costs as follows: Benefits: • Increased security (for the company) • Increased security (economy-wide improvements) • Scheduling and supply chain improvements in the long run (company) 8 in programs such as C-TPAT, designed to increase supply chain visibility 15 • Network improvements for the economy Costs: • Scheduling difficulties arising from congestion at border, depending on high or low variance. If variance is low, may allow an adjustment to equilibrium; if variance is high this is a more serious issue because the industry is constantly subject to low reliability and unpredictable, irregular disruption • The objectives can produce economy wide improvements, so placing responsibility on the company alone requires the company to bear much of the cost while the economy receives positive externalities • The company can redistribute costs to customers in the form of higher prices We wish to suggest the METR methodology should be applied to border crossings because increased congestion, commercial vehicle volume, 9 and service unreliability is a major problem plaguing the trucking industry (Taylor, Robideaux et al. 2004). A METR approach will reveal the marginal costs that affect the firms. Basically, the following events are occurring: • • • • • The border presents an interruption in the supply chain or queuing point / verification point Increased demand at border is causing congestion Congestion is costing the industry involved in cross border activities, mainly for commercial vehicles (CVO) Increased costs for CVO have upstream and downstream effects A deviation from variance in delay time is rendering the industry unable to return to equilibrium Data collected over several days at regular hours (total data points is 800 entries) 10 displays the statistical information collected from all the border crossings. The results show a very high standard deviation. Though this data set is limited, it, combined with literature dedicated to the subject, reveals that the border is in fact a contributor to scheduling problems and inefficiencies and preventing the industry to settle into equilibrium 11 Utilizing the METR concept METR are a concept of an input based cost that can measure output effects. METR taxes are parallel to concepts such as security and border control. Security and border control are not costless, neither for the public sector to administer nor for the private sector to comply with. They involve increased time and effort to induce compliance, and increased requirements for shippers and carriers cost them time and resources, including opportunity costs. The programs have costs and benefits. One of the major components of costs is waiting time at the border. When delays are high, a commercial vehicle operator (CVO) will face higher operating costs, and if in addition, variance in delay is high, will not be able to reach equilibrium in scheduling. Though at the Pacific Crossing in Blaine, Washington the volumes have slightly decreased since 2001 See Appendix B 11 This needs to be investigated in greater detail. There is a considerable lack of empirical work dedicated to border crossing issues in the literature, though there is ample documentation of the problems qualitatively. 9 10 16 These ‘taxes’ are inputs and are also costs. ITS may be able to contribute to this methodology, since we are interested in increasing reliability of variance. Currently, there is no sense of optimization with current strategies to manage the border, instead, there is a concern over how demand should be met given resources, and how to best allocate those resources to match the demand, and not how to manage the demand itself. Demand is taken as exogenous in the models, and we argue that it does not need to be so. Demand can be managed. For example, to improve efficiency, a strategy may induce motorists to make use of border resources at non-peak times by relaying information on border congestion. There are consequences of increasing input taxes. There is a need to measure the output effects of these measures. The concept of increased security and border control is essentially an input tax; the costs and benefits should be measured. Can ITS contribute to the methodology of increased security? Security is difficult to measure, and full security is essentially impossible. 12 We believe ITS can serve to improve the information so route decisions can be changed, plans can be altered due to access to timely and reliable information. The effect of security and border regulations on commerce is a natural extension of METR because policies can act as an ambiguous tax on the sector. Having proper policies in place to protect the country, and the economy by ‘taxing’ entities that engage in cross border activities. Trading gives access to a larger market, therefore generates benefits for the economy and the company, but also generates costs because of the country’s concern with border permeability increasing risk of terrorist threats. Measuring the extent to which the business tax regime impedes on marginal costs helps us to think about the implications of taxation for competitiveness. Governments identify the preservation of competitiveness of domestic producers with foreign producers as the relative marginal costs they each have to pay and as these taxes impinge on competitiveness (Poterba and Rotemberg 1995). Increasing marginal costs may reduce production, and hence the level of business activity in an economy. In a competitive economy, firms produce goods until marginal revenues equal marginal costs. The extent the government policies can influence the marginal costs of production they can influence the level of goods available in an economy. A regime that can generate tax-induced differences across producers within a market, jurisdictions, and industries is of particular concern. At border crossings, subject to strict security regulation has created a tax on the industry. In the case of border crossings, we may see disparities between different trucking companies based on firm size, or further upstream or downstream, such as a automotive manufacturer that sources parts from both countries (Ontario Chamber of Commerce Borders and Trade Development Committee 2004). An important issue is the extent to which taxes levied on firm inputs are reflected in their user costs (therefore marginal production costs) – in CVO, this translates to if the increased charges at the border are passed on to their customer via higher shipping prices. This is important to distinguish because taxes levied on inputs will not affect user costs at all and will not feed to marginal costs. For more information, see the exploratory working paper by Gillen and Gados (2005), titled: The Economics of Security. 12 17 The extent to which taxes will be reflected in user cost of inputs depends on the supply and demand conditions in the input markets. In determining METR for border and security costs including congestion, we must determine the fraction of this ‘tax’ on inputs, such as: • • • Increased drivers wages Scheduling effects Upstream and downstream scheduling inconsistencies. As discovered by McKenzie et al (1997) the labour’s share of costs in transportation is much higher than other sectors. The share of taxes collected from structures is much lower in transportation, therefore the high effective tax rate on structures does not have a significant impact on marginal cost. However we may think of the input costs for a transportation company: • Input tax: depends on type of input – capital or labour input? Driver, labour, inventories, truck and assets, trailers, onboard assets, depreciation, dispatch centre. • Labour in transportation sector – increase value of trucker’s time: value of time, opportunity cost of transportation workers There is also an issue of distortion with inventory. There is an issue created with a higher METR on inventory holdings. This may disadvantage businesses that hold a high level of inventory. This problem is even more superlative because border security protocols have caused inventory hoarding. There is evidence that inventory holdings have increased even more since 9/11. More inventory has been added to the supply chain as unreliability with border control and security has become pervasive. Inventory hoarding means that more product is being held and the firm is consequently being taxed more, in addition to the border “tax” we characterize associated with shipping cross border, exacerbating the problem. The demand for border appears to behave inelastically because though the literature documents very problematic conditions at the border, the demand has not fallen, and businesses do not appear to have changed their operations. There is evidence that an ITS investment is irreversible. Unlike a building, it is a highly specialized tool that may involve a high amount of risk. For example, there is no sense in investing money in in-truck ITS applications if the government does not make investments outside the truck, meaning, to foster the ITS investment. For example, a truck investing in weigh-in-motion RFID needs an reciprocal sensor at the weigh-in-motion stations to bypass the stations. Or, a free and secure trade (FAST) RFID card needs a reader at the border. There is an urgent need to measure the effectiveness of border control programs at the margin, and to promote investments in the industry of suitable solutions, such as ITS that involve coupling the of private and public sector. 18 Appendices Appendix A Five broad models identified by Chen (2000) to model investment and incentives, among one of which is METR. 1. The flexible capital stock adjustment model: tax incentives affect investment through changes in desired capital stock by reducing relative price of capital. 2. The Q theory: firm will invest as long as a dollar spent buying capital raises the market value of the firm by over a dollar. 3. General forward looking models 4. Effective tax rate / return over cost models, and; 5. METR models (Chen 2000). Appendix B Border Wait Times: Collected in November and October, 2006; Number of observations is 800. Delay time in minutes. Source data: http://apps.cbp.gov/bwt/ Mean: 8.202 Standard Deviation: 12.651 Variance: 160.06 Average Daytime Wait Times for Commercial Vehicles at Selected Border Gateways: 2003 and 2004, in Minutes 2003 2004 Port Huron-Bluewater Bridge, MI 26.8 25.2 Blaine-Pacific Highway, WA 18.7 15.0 14.8 Detroit-Ambassador Bridge, MI 16.1 Buffalo/Niagara Falls-Peace Bridge, NY 10.0 12.5 Champlain, NY 3.7 11.6 7.6 Sumas, WA 11.0 Buffalo/Niagara Falls-Lewiston Bridge, NY 12.1 7.2 Sweetgrass, MT 4.8 6.8 5.6 Derby Line, VT 6.1 Pembina, ND 5.6 5.4 Houlton, ME 3.3 5.3 Sault Ste. Marie, MI 6.7 5.1 4.6 Highgate Springs, VT 4.5 Detroit-Windsor Tunnel, MI 3.6 4.0 Calais-Ferry Point, ME 14.7 3.9 Jackman, ME 1.3 1.3 Source: U.S. Customs Border Protection website: http://www.cbp.gov/ Accessed: August, 2006. 19 References Boadway, R., N. Bruce, et al. (1987). "Marginal Effective Tax Rates for Capital in the Canadian Mining Industry." The Canadian Journal of Economics / Revue canadienne d'Economique 20(No. 1): (Feb 1987), pp. 1-16. Boadway, R., N. Bruce, et al. (1984). "Taxation, Inflation and the Effective Marginal Tax Rate on Capital in Canada." The Canadian Journal of Economics / Revue canadienne d'Economique 17(No. 1): (Feb 1984), pp. 62-79. Boadway, R. and A. Shah (1992). "How Tax Incentives Affect Decisions to Invest in Developing Countries." Policy Research Working Paper Series 1011, The World Bank. Bulow, J. I. and L. H. Summers (1984). "The Taxation of Risky Assets." The Journal of Political Economy 92(No. 1): 20-39 (Feb., 1984). Chen, D. (2000). "The Marginal Effective Tax Rate: The Only Rate that Matters in Capital Allocation." Backgrounder: C.D. Howe Institute. DAMF Consultants Inc. and LP Tardiff & Associates Inc. (2005). "The Cumulative Impact of US Import Compliance Programs at the Canada/US Land Border on the Canadian Trucking Industry: Final Report." Transport Canada: TP14402E. Donath, M. (2005). "Homeland Security and the Trucking Industry Final Report." International Truck & Engine Corporation, ITS Institute, Center for Transportation Studies, University of Minnesota. Fullerton, D. (1995). "Marginal effective tax rate." University of Texas. Gillen, D. and A. Lall (2003). "International transmission of shocks in the airline industry." Journal of Air Transport Management 9(2003): pp.37-49. ICF Consulting, HLB Decision Economics, et al. (2001). "Freight Benefit/Cost Study Capturing the Full benefits of Freight Transportation Improvements: A Non-Technical Review of Linkages and the Benefit-Cost Analysis Framework (Final Report)." Mallett, W. and J. Sedor (2004). "Freight Transportation Improvements and the Economy." Prepared for the Federal Highway Administration. McKenzie, K. J. (1994). "The Implications of Risk and Irreversibility for the Measurement of Marginal Effective Tax Rates on Capital." The Canadian Journal of Economics / Revue canadienne d'Economique 27(No. 3): (Aug 1994), pp. 604-619. McKenzie, K. J., M. Mansour, et al. (1998). "The Calculation of Marginal Effective Tax Rates." Working Paper 97-15 Prepared for the Technical committee on Business Taxation. 20 McKenzie, K. J., J. Mintz, et al. (1997). "Measuring Effective Tax Rates in the Presence of Multiple Inputs: A Production Based Approach." International Tax and Public Finance 4: pp. 337-359 (1997). Ontario Chamber of Commerce Borders and Trade Development Committee (2004). "Cost of Border Delays to Ontario." Poterba, J. M. and J. J. Rotemberg (1995). "Environmental Taxes on Intermediate and Final Goods When Both Can Be Imported." International Tax and Public Finance 2: pp. 221-228 (1995). Taylor, J. C., D. R. Robideaux, et al. (2004). "U.S.-Canada Transportation and Logistics: Border Impacts and Costs, Causes, and Possible Solutions." Transportation Journal 43(4): ABI Inform Global. pg 5. 21