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CRS DISCUSSES EXCISE TAXES AND RELATED TRUST FUNDS.

SEP. 25, 1990

90-458 E

DATED SEP. 25, 1990
DOCUMENT ATTRIBUTES
  • Authors
    Noto, Nonna A.
    Talley, Louis Alan
  • Institutional Authors
    Congressional Research Service
  • Subject Area/Tax Topics
  • Index Terms
    excise taxes
    trust funds
    trusts
    luxury tax
    user fee
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 90-7153
  • Tax Analysts Electronic Citation
    90 TNT 204-20
Citations: 90-458 E

Excise Taxes and Related Trust Funds: A Primer

                            Nonna A. Noto

 

                    Specialist in Public Finance

 

 

                          Louis Alan Talley

 

                    Research Analyst in Taxation

 

                         Economics Division

 

 

                         September 25, 1990

 

 

SUMMARY

President Bush has included among possible acceptable areas for excise taxes: proposals previously made during the Reagan years (such as motor fuel excise tax receipts from pleasure boats to pay for Coast Guard services), taxes with an expiration date (such as the telephone excise tax), tariffs, and user-type taxes or fees. The 1970s and 1980s have seen trust funds established at an increased pace and financed with excise taxes on related products. Only a few of the excise taxes that have been extended, increased, or added are not dedicated to specific trust funds. A number of the dedicated taxes were accompanied by revenue targets for the trust fund and were scheduled to expire once the revenue target is reached.

There are six common purposes of excise taxes. These selective, narrow-based taxes are used to accomplish more fine-tuned policy goals than general revenue raising -- by influencing the consumption of particular products. Excise taxes fall into the categories of (1) sumptuary taxes, (2) regulatory taxes, (3) a user fee or charge, (4) import duties for balance-of-payments considerations, (5) rationing taxes, and (6) luxury taxes. Levying an excise tax at the manufacturing level minimizes administrative costs and the opportunity for evasion of the tax but increases the statutory tax rate, creates an incentive to restructure the manufacturing process to avoid the tax, and ensnares tax-exempt organizations in the tax base. If the tax is placed at the point of sale, administrative costs are higher and the potential for evasion increases.

Arguments made for increased use of excise taxes are based on their current political acceptability when imposed as a user type tax. Often these taxes encounter little taxpayer opposition when the tax is seen as a user charge or the revenue is dedicated to a worthy cause, when introduced as a small incremental charge per unit of consumption. The Federal Government is not seen as having abused its access to excise tax receipts, because many of these taxes have rates which have not been adjusted for inflation and are low compared to foreign excises. Evidence suggests that increased Federal rates would not have much effect on State reliance on excise taxes as a source of revenues in the long run.

Opponents of increased Federal use of excise taxes note that moves to raise excise tax rates may be seen as an encroachment on State sources of revenues. Because excise taxes are levied on a narrow, selective base, the revenue potential is limited and the nuisance aspect of a tax on a single commodity may create taxpayer resistance. In general, excises are considered to be regressive. Tax increases can add to inflationary trends, changed production patterns, lowered consumption, and an increase in tax evasion.

                          TABLE OF CONTENTS

 

 

EXCISE TAX POLICY VIEWS BY THE ADMINISTRATION

 

 

LINKAGE OF EXCISE TAXES AND TRUST FUNDS

 

 

PURPOSES OF EXCISE TAXES

 

 

     SUMPTUARY TAXES

 

     REGULATORY TAXES

 

     USER FEES OR CHARGES

 

     BALANCE-OF-PAYMENTS CONSIDERATIONS

 

     RATIONING TAXES

 

     LUXURY TAXES

 

 

AT WHAT STAGE OF PRODUCTION SHOULD AN EXCISE TAX BE LEVIED?

 

 

     MANUFACTURING LEVEL

 

     POINT OF SALE

 

 

ARGUMENTS FOR AND AGAINST THE USE OF EXCISE TAXES VIS-A-VIS OTHER

 

  TYPES OF TAXES

 

 

     ARGUMENTS FOR

 

     ARGUMENTS AGAINST

 

 

USER TAXES AND EARMARKING

 

 

     FORMAL VERSUS INFORMAL EARMARKING

 

     GENERAL COMMENTS ON EARMARKING

 

 

* * * * *

The Reagan Administration endorsed user fees as an appropriate means of revenue collection, while it generally remained opposed to other types of tax increases. Similarly, President Bush in his FY90 budget endorsed most of the user fee proposals set forth in the departing Reagan Administration's FY90 budget. Numerous user fee proposals appeared again in the Bush Administration's FY91 budget.

EXCISE TAX POLICY VIEWS BY THE ADMINISTRATION

During the nomination hearings of Richard G. Darman for the position of Director of the Office of Management and Budget, various revenue raising alternatives were portrayed as not in violation of President Bush's pledge of "no new taxes." Included among possible acceptable alternatives were proposals previously made during the Reagan years, extension of taxes with an expiration date (such as the telephone excise tax), tariffs, and user fees. Cited within this section of the report are specific excise categories which were discussed during those nomination hearings and thus are based on the public record. However, unless otherwise identified, the specific examples offered are those of the authors of this report and should not be interpreted as the tax policy of the Bush Administration.

Excise tax proposals made during the Reagan Presidency, with which Mr. Bush (as Vice President) was associated, are considered not to be new taxes under the Bush Administration's criteria. "If the Vice President [referring to the period when Mr. Bush served as Vice President] has been associated with the prior proposal, I would say it would not be considered a new tax in the way in which I would interpret it. I emphasized before that I was not speaking for him (President Bush) on this point." 1 There have been several excise taxes which were proposed during the Reagan Administration but were not enacted into law in the form that the Reagan Administration had requested. Examples are proposals to use motor fuel excise tax receipts from pleasure boats to help pay for the services provided by the Coast Guard and the request that funds in the Airport and Airway Trust Fund be used to support operations costs rather than those services being paid from general Federal receipts.

Extending taxes scheduled to expire were not viewed as tax increases if the purpose of the expiration date is simply to allow congressional review. An example cited was the further extension of the telephone excise tax. 2

Richard Darman was asked how President-elect Bush might view an oil import fee. In a written response submitted for the hearing record, Mr. Darman wrote that while many items can raise revenues, "not all are always termed 'taxes.'" 3 He went on to write that an oil import fee might be construed as a tariff.

The Bush Administration has supported proposals that are considered user fees. Mr. Darman stated, "A fee charged to visit national parks should be considered a 'user fee' rather than a tax as long as the government is directly charging the beneficiary only for the cost of the service provided by the government. In some circumstances (depending on the application of funds), a gasoline tax might also be considered a user fee -- as might alcohol and tobacco excises." 4 While user-type fees have been supported by the Bush Administration, it has been considered critical that linkage between the fee and the use of monies collected should be direct.

Obviously, it is not known just what specific excise tax proposals might be acceptable to the current Administration. However, it appears a number of types of excises may be acceptable. Among those are increased user-type excise taxes such as those intended for the Airport and Airway Trust Fund with a broadened base of eligible expenditures from the trust fund; the telephone excise tax; excises collected on alcohol and tobacco; and various energy taxes such as an increased tariff on imported oil.

LINKAGE OF EXCISE TAXES AND TRUST FUNDS

Federal excise taxes have held varied places in the U.S. tax system. Large amounts of revenue have been raised from a multiple of excises during times of fiscal emergency, principally to pay for wars. Excises were the single largest source of internal revenue for the Federal Government from 1862 until supplanted by the income tax in World War I; in the Spanish-American War period, they were a larger source of Federal tax collections than even customs duties. Thus, a history of our excise tax system is often one that mirrors our wars, serving as an emergency source of funds. Except for sumptuary taxes on tobacco and liquor, excises seem to have been used extensively for the control of social costs and as user charges only in recent years.

Trust funds are not the exclusive purview of recent excise tax history. However, the 1970s and 1980s have seen the establishment of such trust funds at an increased pace. These trust funds have typically been financed with excise taxes on related products. Many of these trust funds have been established because of deficit reduction pressures brought about by the passage of Gramm-Rudman- Hollings law to balance the Federal budget and the desire to offset new or existing expenditure responsibilities. A brief summary of the trust funds established during the Reagan and Bush Administrations follows.

1. The Hazardous Substance Response Trust Fund, set up in 1980, is mainly supported by excise tax receipts on crude oil and taxable chemicals sold by a manufacturer, producer, or importer. The trust fund and related taxes expired and were reestablished by the Superfund Revenue Act of 1986 (P.L. 99- 499). Expenditures from this fund may be made for releases or threats of releases of hazardous substances into the environment. Also established under this Act was the Leaking Underground Storage Tank (LUST) Trust Fund, with taxes imposed on gasoline, diesel fuel, and other types of fuels. Fund receipts are designed to pay cleanup and related costs for sites and removal of tanks which pose a threat to human health or the environment.

2. The Aquatic Resources Trust Fund was established under the Deficit Reduction Act of 1984 (P.L. 96-369). The fund is composed of two accounts. One account provides for restoring and managing fish with material value for sport or recreation in the marine and fresh waters of the United States, while the second account finances boating safety programs. It is funded by excise taxes on sportfishing equipment, outboard motors, sonar devices, and special motor fuels and gasoline used in motor boats.

3. As part of the Water Resources Development Act of 1986 (P.L. 99-662) a new excise tax is imposed on the value of cargo loaded or unloaded from commercial cargo vessels. This tax funds the Harbor Maintenance Trust Fund designed to fund operations and maintenance costs of the Saint Lawrence Seaway and other harbors within the United States.

4. The Oil Spill Liability Trust Fund became effective under the Omnibus Budget Reconciliation Act of 1989 (P.L. 101-239). Not only are costs incurred by the Federal Government for oil spill removal paid from the fund but also damage claims, Federal administrative expenses and payment of contributions to the International Fund. The financing is obtained from an excise tax of 5 cents per barrel on domestic crude oil and imported petroleum products.

Only a few of the extended, increased, or new excise taxes enacted during the 1980s are not dedicated (for example, telephone, cigarettes, distilled spirits, and golden parachute excess payments). A number of the dedicated taxes were accompanied by revenue targets and were scheduled to expire once that revenue target is reached (e.g., SUPERFUND and LUST taxes).

PURPOSES OF EXCISE TAXES

By their very nature of being selective and narrow-based, excise taxes often are used to accomplish more fine-tuned policy goals than general revenue raising. These selective effects are likely to accompany the use of an excise tax, whether or not it was chosen to further that particular purpose. Consequently, the consideration of an excise tax as a revenue source should be made with due attention to its likely side effects in the market for the taxed product.

SUMPTUARY TAXES

Excise taxes are sometimes imposed in the name of discouraging the consumption of products which have a "moral taint." These are referred to colloquially as "sin" taxes. Excise taxes on cigarettes 5 and alcohol 6 fall into this category. The argument that excise taxes can discourage consumption on these products is in direct contrast to the argument that excise taxes on these items are likely to generate substantial revenue, without much decrease in the level of consumption, because demand for these products is so insensitive to price (that is, they are price inelastic).

Sin taxes also can be viewed as a penalty or charge to consumers for the external costs generated by consumption of the taxed product. Following that line of argument, it might be considered appropriate to dedicate cigarette and alcohol excise tax revenues to health programs associated with substance abuse.

REGULATORY TAXES

Excise taxes may be imposed as a method of trying to price externalities. An example is using taxes on pollution rather than regulation as a means of diminishing the amount of pollution. Taxes on the emissions of motor vehicles or the pollutant content of gasoline could be viewed in this context.

USER FEES OR CHARGES

Excise taxes are sometimes seen as a rough approximation of user charges or market prices. For example, the use tax on highway vehicles exceeding 26,000 pounds can be viewed as a proxy for road and highway wear-and-tear charges. This association has been used to justify earmarking this type of revenue for the Highway Trust Fund.

BALANCE-OF-PAYMENTS CONSIDERATIONS

Excise taxes -- similar or supplementary to import duties -- may be used to discourage the consumption of a product heavily dependent on imports. In this context, a tax on petroleum products could be viewed as a means of reducing U.S. imports, and consequently, of improving the balance of trade and the balance of payments.

RATIONING TAXES

In a wartime situation, excise taxes may be applied to discourage civilian consumption of a wide variety of items which are seen as competing with military requirements. Taxation of the rubber content of tires and tubes during World War II is an example. In an energy crisis situation, taxing fuel could be considered an alternative to rationing as a method of encouraging the conservation of energy resources.

LUXURY TAXES

Excise taxes are sometimes used to discourage the consumption of luxury or "nonessential" goods. Less developed countries frequently impose luxury taxes to discourage the rich from purchasing expensive consumer items such as automobiles, appliances, jewelry, and clothing. This indirectly encourages them to invest rather than consume. (To the extent that these items are imported, the luxury tax also serves a balance-of-payments function.)

Luxury taxes are also a progressive brand of excise taxation, since high-income people are more likely to consume the taxed product. No present Federal excise tax is defended on "ability-to- pay" grounds as a tax on higher-income consumers.

AT WHAT STAGE OF PRODUCTION SHOULD AN EXCISE TAX BE LEVIED? 7

This section provides a brief discussion of the economic implications of the level at which an excise tax is collected -- retail, wholesale, or manufacturing. In general, any choice brings benefits and costs. The usual three choices for the level at which to levy the tax are on the manufacturer when the good leaves the premises, on the wholesaler, or on sale of the good at the retail level. The issues involved can be illustrated by discussing taxes levied on the two extreme cases, the manufacturer and the retailer. (Wholesalers would fall somewhere between these two extremes.)

MANUFACTURING LEVEL

Levying the tax at the manufacturing level raises three problems. First, some manufactured goods have a long inventory life. A considerable time period may elapse between the date the tax is paid (when the good leaves the manufacturer's premises) and the date the good is actually sold. In effect, the manufacturer incurs an interest cost to borrow the money for payment of the excise tax. Thus, the effective tax rate is actually higher than the statutory tax rate. It was partly for this reason that the Federal truck excise tax was changed in 1983 from a tax on the manufacture of the truck to a tax at time of sale to the user.

Second, a tax levied at the manufacturing level creates an incentive to minimize the tax base by restricting the manufacturing process to the most basic product, and adding options or enhancements later on the trip to the ultimate purchaser. The excise tax on trucks again provides a good example of this problem. When the tax was levied on the manufacturer, dealers and direct purchasers had an incentive to order stripped-down models devoid of most options. The options desired were then added after receipt of the vehicle. Although it is, of course, possible to tax these options at the time they are added, an administratively simple excise tax on trucks would no longer exist. The truck excise tax was changed in 1983 to include add-ons in the tax base.

A third problem can arise when the tax is levied at the manufacturing level. Any nonprofit or other entities that are exempt from the tax will require some special treatment to avoid paying the tax. Administrative difficulty is unavoidable.

POINT OF SALE

Two related problems arise when the tax is levied at the point of sale to the final consumer. Both administrative costs (both to the Government and to individual businesses) and the potential for evasion increase as the number of collection sites increase and the size of the tax base at each of these sites becomes relatively small. The excise tax on gasoline suffered from these problems, and the point of collection for the excise tax had to be moved to the product as it left the refinery. This approach, however, makes it necessary to find ways to eliminate the tax for nonprofit organizations and uses otherwise exempt from the tax (such as on the farm).

As can be seen from the preceding discussion, levying the tax at either of these levels has its problems. Levying the tax at the manufacturing level minimizes administrative costs and the opportunity for evasion of the tax base. But it increases the effective tax rate, creates an incentive to restructure the manufacturing process to avoid the tax, and ensnares tax-exempt organizations in the tax base. If the tax is placed at the point of sale, administrative costs are higher and the potential for evasion increases.

ARGUMENTS FOR AND AGAINST THE USE OF EXCISE TAXES VIS-A-VIS OTHER TYPES OF TAXES

The advantages and disadvantages of using excise taxes are briefly outlined in this section. Some of the advantages and disadvantages contradict others, as might be expected in a presentation of opposing viewpoints. This discussion is followed by a presentation of problems typically associated with earmarking revenues for trust funds.

ARGUMENTS FOR

o In the current political environment excise taxes appear particularly attractive as a revenue-raising device because of their political acceptability. They do not conflict with the Bush Administration's policy of retaining low tax rates. Additionally, the Administration has embraced the imposition of user type taxes.

o By being introduced as a small incremental charge per unit of consumption, they may encounter relatively little taxpayer opposition (known as "fiscal illusion").

o Taxpayers may be more sympathetic if the resulting revenues are to be earmarked for a particular category that is (a) deemed to be a worthy cause -- such as the excise tax on sports equipment being dedicated to fish and wildlife restoration projects, or (b) corresponds to a service that is understandably related to the excise tax in its role as a user charge -- such as motor fuel taxes being dedicated to highway construction and maintenance or other transportation programs such as mass transit systems.

o Excise taxes have been decreasing in importance as a source of Federal revenue. Many of the individual excise taxes were repealed in 1965 and the rates of tax per unit of consumption on the remaining major sources have not been adjusted for inflation and are relatively low when compared with rates imposed in foreign countries. Thus, the Federal Government cannot be charged with having abused its access to excise tax revenues. The present excises are minor sources of Federal receipts, representing 3.4 percent of Federal receipts in FY 1989. Excise taxes are estimated to compose 3.4 percent of receipts in 1990; 3.2 percent in FY 1991; 3.1 percent in FY 1992 and 1993; 3.0 percent in FY 1994 and only 2.9 percent in FY 1995. 8 In dollar amounts, excise taxes will rise from $34.1 billion in FY 1989 to an estimated $36.2 billion in FY 1990 and over $37.6 billion in FY 1991. The estimates for FY 1992 to FY 1995 are respectively $39.2 billion; $40.8 billion; $42.2 billion; and $43.7 billion. 9

o Because the States also can levy taxes on these same excise bases, the Federal Government in some sense competes with the States for these revenue sources. The States, however, have a history of acting quite independently of the Federal Government in setting their excise tax rates. Although raising the Federal tax rate might discourage State increases in the short run, evidence from the past suggests that it would not have much effect on State reliance on these excise tax sources in the long run.

o If different States have widely different rates of excise tax on a product, this introduces incentives to bootleg (e.g., purchase from wholesalers in low tax States and resell illegally at the retail level in high tax States). If excise tax rates are to be increased, particularly on tobacco and alcohol products, it maybe preferable to have the increase imposed nationwide by the Federal Government, rather than introduced unevenly by the individual States.

ARGUMENTS AGAINST

o The Federal Government has been backing off in the area of excise taxation. Taxes on may individual items were eliminated by the Excise Tax Reduction Act of 1965 (Public Law 89-44), and subsequent legislation. As a consequence, the excise tax has been increasingly left to the States, which have raised rates intermittently. Both the Federal and State levels of government now levy excise taxes on gasoline, tobacco products, and alcohol. Consequently, Federal moves to raise excise tax rates on these products might be seen as an encroachment on sources States have used for revenue raising purposes.

o Excise taxes are levied on narrow, selective bases. They are very different in concept from a broad-based consumption tax, or even a general sales tax. Their revenue potential is limited by the narrow base and the nuisance aspect of a tax on a single commodity may create taxpayer resistance.

o Imposing an excise tax raises the price facing the consumer. (Note that the price may not rise by the full amount of the tax because some portion may be borne by the producer.) Raising an excise tax on an item that has recently increased in price may add pressure to inflationary trends. For example, in the current Middle-East situation, a higher tax on petroleum and other energy products might be considered inflationary. Additionally, changes in prices will affect consumption decisions and consequently will influence production patterns. Producers of the items proposed for new or higher taxation are likely to object to these taxes in order to protect their profits.

o Raising the overall level of excise taxation on a given product beyond the "breaking point" may encourage outright tax evasion. If much of the market for the product is driven into the underground economy, the tax base correspondingly may disappear from the records.

o Excise taxes tend to be levied on a per unit rather than an ad valorem (percentage of price basis). Thus, while revenue responds to the volume of sale, it does not respond to price inflation. During inflation, the levy per unit must actively be raised from time to time if the amount of the tax is to remain in approximately the same ratio to the price of the taxed product. Furthermore, if consumption of the commodity does not increase with rising income levels (is not income- elastic), then the tax source will not be very sensitive to real income growth either.

o Some excise taxes are likely to be regressive -- that is, to fall more heavily on low- than high-income persons. A system of excise taxation can be made more regressive or progressive, depending upon the products selected for taxation. The conventional wisdom concerning the regressivity of excise taxes has generally been based on the assumption that excise taxes are fully shifted forward to consumers. This leads to the conclusion that an examination of consumption patterns across income groups adequately answers the question of regressivity. A more comprehensive tax incidence analysis -- which takes into account that the producer is likely to bear some of the burden of the tax -- tends to find excise taxes to be less regressive than the conventional wisdom would suggest.

USER TAXES AND EARMARKING

According to strict economic and legal criteria, user fees have a narrow definition. The basic requirement to qualify as a user fee, rather than a tax, is that the monetary amount of the charge to the user be closely related to the costs incurred by the government in providing the service to that user. If a fee is levied such that an individual is also charged for services provided to the general public, it is considered inequitable as a fee, and the courts view that user fee as a tax. 10 Most Federal Government activities are not suited to user-fee financing, either because they benefit the public at large or because they subsidize individuals considered too poor to pay. 11

FORMAL VERSUS INFORMAL EARMARKING

Formal earmarking of revenues involves the creation of a special fund within the general fund, a separate trust fund, or a public enterprise revolving fund. But earmarking can also be informal, accomplished by rhetorical association (such as a "sense of the Congress") or coincidence of timing between the enactment of revenue increases and expenditure programs.

During the 1980s, under the deficit-reduction pressures of Gramm-Rudman-Hollings and resistance to general tax increases, first by President Reagan and subsequently by President Bush, the Congress was attracted to "pay-as-you-go" or "deficit-neutral" expenditure proposals which included their own revenue source. Some were formally earmarked through trust funds, but others were not.

GENERAL COMMENTS ON EARMARKING

o There are likely to be problems if the amount of funds raised from the particular tax source does not closely match expenditure needs for the designated function.

In a restrictive trust-fund type of arrangement, if revenues exceed standard expenditure commitments, then it is in the self-interest of the fund to finance more of its own type of projects, rather than turn excess revenues over to the general fund. Thus, if a highway trust fund were in surplus, more than the socially optimal amount of highways might be built. One social safety valve on this is expanding the mandate of the trust, such as including mass transit as an acceptable object of highway trust fund expenditures.

Oppositely, if revenues fall short of expenditure commitments, there may be little sympathy for bailing it out with use of revenues from the general fund.

o An excise tax placed on a commodity can be contradictory in trying to finance programs designed to transfer income and/or services to the poor if that tax is deemed to be regressive. Because of the redistributive nature and intent, social welfare expenditures may be more appropriately financed by taxes that are progressive.

o If excise tax revenues are to be earmarked, then some type of user fee relationship would have the most rational appeal. This reasoning suggests that tobacco and alcohol tax revenues might be earmarked for a variety of health programs -- such as preventive health, cancer research, and treatment of substance abuse. But these particular taxes do not have any obvious correspondence to general medical assistance for the poor (such as the Medicaid program), let alone general welfare (AFDC).

 

FOOTNOTES

 

 

1 U.S. Congress. Senate. Committee on Governmental Affairs. Nomination of Richard G. Darman, Nominee to be Director, Office of Management and Budget. Senate Hearings 101-46, 101st Cong., 1st Sess. Washington, U.S. Govt. Print. Off., January 19,23, 1989. p. 88.

2 Ibid. p. 181.

3 Ibid. p. 180.

4 Ibid.

5 U.S. Library of Congress. Congressional Research Service. Tobacco Excise Taxes. Issue Brief No. 90101, by Louis Alan Talley, Updated regularly. Washington, 1990.

6 U.S. Library of Congress. Congressional Research Service. Alcohol Excise Taxes on Beverages. Issue Brief No. 90059, by Louis Alan Talley, Updated regularly. Washington, 1990.

7 This section was written by Dennis Zimmerman, Specialist in Public Finance, Economics Division of the Congressional Research Service.

8 U.S. Office of Management and Budget. Budget of the United States Government, FY 1991. Jan. 1990. p. A-286.

9 Ibid. p. A-285.

10 U.S. Library of Congress. Congressional Research Service. Application of Constitutional Delegation Standards Based upon the "Fee" or "Tax" Dichotomy. A report from the American Law Division, by David R. Siddall. Washington, June 23, 1982.

11 For a more detailed discussion see: U.S. Library of Congress. Congressional Research Service. Federal User Fees: An Overview. Report No. 89-625 E, by Julius W. Allen. Washington, October 31, 1989.

DOCUMENT ATTRIBUTES
  • Authors
    Noto, Nonna A.
    Talley, Louis Alan
  • Institutional Authors
    Congressional Research Service
  • Subject Area/Tax Topics
  • Index Terms
    excise taxes
    trust funds
    trusts
    luxury tax
    user fee
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 90-7153
  • Tax Analysts Electronic Citation
    90 TNT 204-20
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