CRS Reviews Studies of Social Security Individual Accounts
CRS Reviews Studies of Social Security Individual Accounts
- AuthorsPurcell, PatrickNuschler, Dawn
- Institutional AuthorsCongressional Research Service
- Subject Area/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2004-22471
- Tax Analysts Electronic Citation2004 TNT 227-41
Congressional Research Service
Library of Congress
Memorandum
March 2004
FROM:
Patrick Purcell
Dawn Nuschler
Specialists in Social Legislation
Domestic Social Policy Division
SUBJECT:
Social Security Individual Accounts and Private Pensions
The Congressional Research Service (CRS) has reviewed a number of studies that have considered some of the possible interactions between Social Security individual accounts and the private pension system. In reviewing the literature on this subject, we focused on the ways that individual accounts might potentially overlap with employer-sponsored plans and how individual accounts might affect employers' administration of their pension plans. We also noted the authors' caveats about the ways that employers and employees might respond to individual accounts, particularly with respect to sponsorship of, and participation in, pensions and retirement savings plans.
The memorandum is structured as follows: Section I provides a brief overview of employer-sponsored pensions in the United States. Section II describes ways in which a system of individual accounts under Social Security might affect employers. This is followed by brief discussions in sections III and IV of possible employer and employee responses to Social Security individual accounts. Section V of the memorandum provides a side-by-side comparison of five bills that were introduced in the 108th Congress that would include individual accounts as an element of Social Security reform. These bills are H.R. 75, H.R. 3177, H.R. 3055, H.R. 3821, and S. 1878. The side-by-side table compares the bills in terms of whether participation in individual accounts (IAs) would be mandatory or voluntary; whether IA funding would be from current payroll taxes ("carve-out") or from new contributions ("add-on") and whether the processing of IA contributions would be centralized (as with current social security taxes) or decentralized (as with private-sector retirement plans). These aspects of IAs would have significant effects on the cost of the plans and also determine who would bear those costs.
We also have provided with this memorandum a bibliography of the sources that we consulted in our research.
I. Overview of Employer-sponsored Retirement Plan Coverage
Although more than half of the private-sector workforce is employed at firms with 100 or more employees, most employers in the U.S. are small employers. Most of these small employers do not offer a retirement plan to their employees. For example:
Of the 5.7 million firms in the United States in 2000, 3.4 million (60%) had fewer than five employees, and 5.0 million (89%) have fewer then 20 employees.1 (Table 1)
According to the Department of Labor, there were 733,000 employment-based retirement plans in the U.S. in 1999. Thus, no more than 13% of private-sector employers offered a retirement plan to their employees that year.1 (Some had multiple plans.)
According to the Census Bureau, slightly more than half of private-sector workers are employed at firms that offer some or all of their employees a retirement plan.
There were 118 million private-sector workers of all ages in 2002. (See Table 2)
Among all workers in the private sector, 52% worked for firms that offered a retirement plan to some or all of their workers in 2002. Of these employees, about 80% had a 401(k)-type plan.2
Among workers in firms with fewer than 100 employees, just 32.4% worked for firms that offered a retirement plan to some or all of their workers in 2002.
Employer-sponsored retirement plans generally exclude workers who do not meet age, tenure, and hourly work requirements. This reduces administrative costs.
Federal law allows companies to exclude workers under 21 years of age, those who work less than 1,000 hours per year, and those who have been employed by the firm for less than 12 months from participating in employer-sponsored retirement plans.
The majority of employers send payroll taxes and federal income taxes in lump-sum payments to Federal Reserve Banks or other authorized institutions. The reports indicate the aggregate amount of taxes withheld from workers' pay, but not the amount of income and payroll taxes paid by particular workers. Reconciliation of gross tax payments with individuals' earnings is done once yearly on the Form W-2.
At least quarterly, employers submit to the IRS, reports of their payroll and income tax deposits. Small employers are permitted to report to IRS on paper.
In the late 1990s, 85% of employers reported wages to the Social Security Administration on paper, and 90% of such firms had fewer than 25 employees.
Table 1. Firms, Establishments, and Company Payroll by Firm Size
in 2000
Firm size Number Percent
(in thousands)
Firms, total 5,653 100%
Under 5 employees 3,397 60.1
5 to 9 employees 1,021 18.1
10 to 19 employees 617 10.9
20 to 99 employees 516 9.1
100 to 499 employees 84 1.5
500 or more employees 17 0.3
Establishments, total 7,070 100%
Under 5 employees 3,406 48.2
5 to 9 employees 1,035 14.6
10 to 19 employees 652 9.2
20 to 99 employees 674 9.5
100 to 499 employees 312 4.4
500 or more employees 990 14.0
Total payroll Average payroll
(in billions of $) (in dollars)
Annual payroll $3,879 $686,184
Under 5 employees 186 54,754
5 to 9 employees 174 170,421
10 to 19 employees 231 374,392
20 to 99 employees 608 1,178,295
100 to 499 employees 528 6,285,174
500 or more employees 2,152 126,588,235
Source: Statistical Abstract of the United States:
2003, Table 747, p. 506.
Note: Excludes government employees, railroad employees, and
self-employed workers. A firm is a business under a single
management and may include one or more establishments.
Table 2. Employment at firms that offered a retirement plan in
2002
Does employer offer a retirement plan?a
Number of workers
(in thousands) Percent of workers
Yes No Yes No
Size of firm (employees)
Under 10 4,092 16,789 19.6% 80.4%
10 to 25 4,441 9,466 31.9 68.1
25 to 99 8,617 9,588 47.3 52.7
100 to 499 10,468 7,071 59.7 40.3
500 to 999 4,347 2,152 66.9 33.1
1,000 or more 29,655 11,460 72.1 27.9
Employee work scheduleb
Full-time employee 53,962 40,649 57.0% 43.0%
Part-time employee 7,658 15,877 32.5 67.5
Employee annual earnings
Under $10,000 5,865 16,904 5.8% 74.2%
$10,000 to $19,999 8,469 14,067 37.6 62.4
$20,000 to $39,000 21,839 15,960 57.8 42.2
$40,000 to $59,999 12,618 5,101 71.2 28.8
$60,000 to $79,000 5,988 2,109 74.0 26.0
$80,000 or more 6,840 2,386 74.1 25.9
Highest grade completed
Less than 12 years c 4,718 12,427 27.5 72.5
High school graduate 18,289 18,675 49.5 50.5
Some college 18,899 15,705 54.6 45.4
College graduate 19,714 9,719 67.0 33.0
All private-sector workers 61,620 56,526 52.2% 47.8%
Source: CRS analysis of the March 2003 Current Population
Survey.
FOOTNOTES TO TABLE
a Could offer either a defined benefit plan, a defined
contribution plan, or both types.
b Part-time means fewer than 35 hours per week.
c Includes 2.9 million children under age 18.
II. Possible Effects of Individual Accounts on Employers
In a 401(k) plan, employers deposit IA contributions directly with financial institutions. Employers that don't offer defined contribution plans do not have the administrative infrastructure in place to assist in the administration of individual accounts (IAs).
Employers that do not currently offer defined contribution retirement plans would incur additional costs to quickly deposit IA contributions with financial institutions.
Using the current system of remitting payroll taxes to a central intermediary would not result in new costs for employers.
If employers have to determine each employee's interest in participating in voluntary IAs, per-participant costs could be higher than a mandatory system.
Because Social Security covers many small employers with limited technology, mistakes routinely occur in wage reporting and tax collecting.
SSA generally ignores discrepancies of one wage credit or less ($900 in 2004) between the IRS Form 941 reports and the Social Security W-2 report totals.
SSA posts earnings credits to participants' records even if their employer has failed to send the attendant taxes, so long as proof of individual earnings is supplied.
Unless workers are "held harmless" in this way under an IA system, workers could lose contributions and investment earnings because of employer error or noncompliance. Being "held harmless," however, requires someone else (either the government or the employer) to contribute money to replace the lost funds.
Legislation would need to define the fiduciary responsibilities that employers would have for managing their workers' contributions in an IA system.
Implementing Social Security individual accounts would require educating the public about the new system. If these costs are shared by employers, it would represent a new cost to those that do not offer retirement plans or retirement plan education.
Legislation would need to define the extent to which an employer offering investment advice or investment education was taking on fiduciary responsibilities.
The 401(k) plans differ in both the services they offer and the diversity of available investment options. These differences could raise questions of fairness if the system became the foundation for a universal system of individual accounts.
Using existing plans as a basis for IAs might require imposing greater uniformity across the different plans that employers offer.
Reducing "float" -- the time between collecting contributions and posting them to individual accounts -- might require quarterly reporting of W-2 information.
Float periods would be reduced if employers sent contributions directly to investment providers, rather than to a single government clearinghouse. However, this approach likely would be the most burdensome for small employers.
Pensions and individual accounts could have very different rules for distributing benefits. Employers may have to coordinate their existing pensions with individual accounts.
A 401(k) account currently permits workers to take lump-sum distributions without penalty at age 59 1/2, while Social Security individual accounts might restrict distributions until the age of eligibility for Social Security (62 or later).
Section 72(t) of the Internal Revenue Code allows certain penalty-free distributions from individual retirement accounts (IRAs) and 401(k) plans before age 59 1/2. The President's Commission recommended that no such pre-retirement distributions should be permitted from IAs.
Addressing differences between IAs and 401(k) plans might change the structure of pension plans, possibly affecting employer sponsorship and employee participation. For example, individual accounts could cause some employers to change the type of pension integration they use.
The integration rules for defined contribution (DC) plans are tied solely to employer contributions and would not be affected by changes in promised benefits. If payroll taxes are not increased, employers likely would not change the method of integrating their DC plans because the IA plan would not increase employer contributions.
Employers with integrated defined benefit plans, on the other hand, might change the terms of their plans because the individual account would likely require a change in the integration rules for defined benefit plans.
Defined benefit pension plans that integrate through the offset method must estimate the participant's Social Security benefit to calculate the appropriate offset.
With IAs, estimating the benefit to determine the appropriate offset could be difficult. Some employers might abandon the offset method in favor of the step-rate excess method of integration in which they need only satisfy IRS regulations on the permitted disparity between contributions for workers whose earnings are less than the Social Security taxable maximum and those whose earnings are above the taxable maximum.
III. Possible Employer Responses to Individual Accounts
To the extent that individual accounts affect employer costs or workers' perceptions of risk and return, both employers' incentives to offer pension coverage and workers' incentives to participate in employer-sponsored plans could be affected.
Some pension actuaries expect that employers would see significant added costs from having to correct any errors that would occur in a system of IAs.
Employers might seek to offset any higher costs arising from individual accounts by reducing or restructuring the benefit packages they currently offer to employees.
For example, an increase in employer costs associated with Social Security individual accounts could cause some employers who offer 401(k) plans to cut back on their matching contributions.
If, because of new costs from administering IAs, employers cut back on matching contributions, employee participation in 401(k) plans would probably decline.
The ERISA Industry Committee (ERIC) has suggested that if administrative costs of IAs are significant, Social Security reform "could cause a shrinkage of pension sponsorship."
Costs to employers depend in part on whether the administration and record-keeping functions are centralized or decentralized.
A centralized system would build on the existing centralized record-keeping systems of SSA and IRS and would be most likely to maintain the current level of employers' costs and responsibilities.
A decentralized system would minimize direct government involvement, but economies of scale could be more difficult to achieve and costs to employers would likely increase.
Table 3. Centralized vs. Decentralized Administration
Centralized administration and Decentralized administration and
record keeping record keeping
Would build on existing government Would require expanded employer
systems at SSA and IRS. infrastructure, especially to
implement a "401(k)" model.
Could achieve economies of scale. Economies of scale would be
difficult to achieve.
Government would have a substantial Would minimize government role
role in managing individual account in managing an individual
system. account system, but government
oversight still would be needed.
Would likely maintain or marginally Could substantially increase
increase employers' costs and employers' costs and
responsibilities. responsibilities.
Source: GAO-99-122.
IV. Possible Employee Responses to Individual Accounts
Workers who expect that Social Security IAs would offer the same range of services that are typical of employers' 401(k) plans may be disappointed.
Individuals might not be able to switch investment options until their contributions are allocated to their accounts. Unlike a 401(k) plan, this could be as long as six to 24 months after taxes were withheld from each worker's paycheck.
The typical 401(k) account provides eight or more investment options. The federal Thrift Savings Plan provides five investment options.
It would be difficult to predict whether new Social Security accounts would diminish participation in employer-provided retirement plans, even in the case of substitute (carve-out) accounts. Social Security IAs could have an impact on the willingness of employees, (particularly lower-income employees), to contribute to 401(k) plans.
Even if there is no increase in the payroll tax, IAs could affect employees' willingness to contribute to 401(k) plans. If employees believe that a reduced Social Security benefit plus the IA balance would provide adequate retirement income, some might reduce their 401(k) contributions.
If lower-wage workers reduce their contributions to 401(k) plans, it could have implications for highly compensated employees. Section 401(a)(4) of the Internal Revenue Code prohibits contributions by highly-compensated employees in employer-sponsored retirement plans from exceeding the contributions of lower-paid employees by more than specific ratios.
Alternatively, increased investment risk could encourage employees to increase their contributions to 401(k) plans to offset some of this risk. Moreover, some employees who currently contribute little or nothing to 401(k) plans might increase their contributions as they gain knowledge and experience as investors.
IAs could have an impact on how employees choose to invest the assets in their employer-sponsored defined contribution plans. Specifically, some workers might invest their 401(k) plan assets more conservatively as they seek to reduce the increased investment risk resulting from replacing part of Social Security with IAs.
Uccello, (2001) suggests that by reducing guaranteed benefits, Social Security IAs could cause some workers to invest their 401(k) assets more conservatively.
Table 4 summarizes some of the challenges to implementing a system of individual accounts for Social Security that would be presented by particular employer and employee characteristics.
Table 4. Challenges of Particular Employer and Employee
Characteristics
Employer/employee Characteristic Challenge
Employer turnover About 650,000 employers go out of
business or start new businesses
each year. This would create challenges
in ensuring that contributions were made
and credited to individual accounts.
Once an employer went out of business,
making corrections to individual
accounts would be difficult.
Employer record keeping More than 4 million employers
have 10 or fewer employees. Small
firms have more record-keeping
problems, and their records
often have errors. According to
SSA, about 85% of employers still
submit forms on paper, requiring
additional administrative steps to
check and record the data.
Workers with more than one employer Many workers in the United States have
more than one job at any given time or
work for more than one employer during
the year. About 58 million workers
(40% of the total workforce) have
annual earnings reported to SSA from
more than one employer. This could
pose problems for administering and
monitoring compliance with individual
account requirements (such as
government matches for low-wage
workers) unless a mechanism is created
to consolidate the records, especially
at retirement.
Unique reporting structure used by There are approximately 12 to 15
self-employed million self-employed individuals
in the U.S. They do not file W-2s
directly with SSA but rather provide
information to only the IRS through
their annual tax filings. The IRS
then forwards this information to
SSA at a later date. About one-half
of the self-employed also work for
employers that send W-2s to SSA.
Ensuring the compliance of the
self-employed under a system of
individual accounts would require
some oversight mechanism.
Source: GAO-99-122.
V. Social Security reform proposals in the 108th Congress
IA Participation
Four proposals provide for voluntary individual accounts
One proposal provides for mandatory individual accounts
IA Funding
The proposals provide for carve-out funding of individual accounts through a redirection of payroll taxes or general revenue funding.
Processing of IA Contributions
The proposals provide for a centralized system of processing IA contributions, typically through the existing structure for payroll tax collections.
H.R. 75 (Shaw) and H.R. 3177 (DeMint):
Text excerpted from SSA actuarial memorandums
IA Participation
H.R. 75 (Shaw)
Voluntary
H.R. 3177 (DeMint)
Voluntary (automatic enrollment with option to disenroll within 18 months)
Text excerpted from SSA actuarial memorandums
IA Funding
H.R. 75 (Shaw)
IA credited with annual contribution from the general fund
H.R. 3177 (DeMint)
Carve-out
Text excerpted from SSA actuarial memorandums
Processing Employee IA Contributions
H.R. 75 (Shaw)
$ Centralized Administration
Notes:
Establishes the Social Security Guarantee Board (SSG Board)
Provides three investment options Requires assets to be held in a single fund, which may be changed at most once per year. Annual account credits would be pooled and transmitted to the mutual fund managers under regulations prescribed by the Treasury in consultation with the SSG Board. Account holders would receive annual notices of assets, investment performance, and administrative costs in their SS statements. Account balances would be collectively invested in qualified mutual funds, managed by certified account managers under contract with and regulation by the SSG Board.
Credits would be transferred from the general fund to the accounts as soon as practicable in the following calendar year (expected to be generally by October 15 for wages and salaries and by December 1 for self-employment earnings).
H.R. 3177 (DeMint)
$ Centralized Administration
Notes:
Workers would have a portion of their payroll taxes redirected from the SS trust funds to an IA. IA assets, once credited, would be automatically invested by workers through the Personal Savings Board.
IA balances would be maintained in the default portfolio with 65% in a specified broad index fund consisting of private equities for corporations based in the United States and 35% in long-term bonds issued by the federal government. (Initially, the bond portion of assets would be invested in special Social Security Transition Bonds.) Once the IA balance reaches a specified threshold, the worker would be able to choose among four investment funds. Annual changes in allocation would be allowed.
The IA assets and special annuity assets of all workers will be managed with a single entity, the Personal Savings Board, maintaining records and issuing periodic account statements. IA management would be based on the design of the federal TSP, with limited reporting requirements. Assets would be invested in bulk with large financial institutions.
IA contributions directed to the IA of a worker based on a year's earnings are not determinable until earnings are reported to and tabulated by the SSA. Because this reporting is made by employers annually after the end of the calendar year, amounts for individual workers are not determinable for somewhat over a year, on average, after the date on which earnings are paid. IA contributions would be credited to the accounts as soon as reporting permits, with amount increased by the actual yield on the default portfolio from June 30 of the year of earnings to the point of crediting to the workers account.
H.R. 3055 (Smith), H.R. 3821 (Kolbe-Stenholm) and S. 1878 (Graham)
Text Excerpted from SSA Actuarial Memorandums
IA Participation
H.R. 3055 (Smith)
Voluntary
H.R. 3821 (Kolbe-Stenholm)
Mandatory
S. 1878 (Graham)
Voluntary
Text Excerpted from SSA Actuarial Memorandums
IA Funding
H.R. 3055 (Smith)
Carve-out
(Additional voluntary contributions allowed. Worker could transfer money into IA as specified rollover contributions from other designated trusts and eligible retirement plans.)
H.R. 3821 (Kolbe-Stenholm)
Carve-out
S. 1878 (Graham)
Carve-out (Additional voluntary contributions would be allowed.)
Text Excerpted from SSA Actuarial Memorandums
Processing Employee IA Contributions
H.R. 3055 (Smith)
$ Centralized Administration
Notes:
Initial contributions would be deposited in an Interim Investment Fund (IIF) established in the Treasury. Each worker would choose from one of three investment accounts available in the IIF.
Once the IA balance reaches a specified threshold, the worker would be allowed to transfer his/her account into a Personal Retirement Savings Account (PRSA). The PRSA would offer a broad range of regulated investment-company mutual funds approved by the Secretary of the Treasury. IA contributions would be collected using the existing structure for SS payroll tax collections. IA contributions in both the IIF and the PRSA would be managed by a central authority in a manner similar to that of the TSP. The central authority would maintain IA records and would make account transactions in aggregate amounts when dealing with private investment firms.
H.R. 3821 (Kolbe-Stenholm)
$ Centralized Administration
Notes:
The federal government would collect all redirected amounts in the same manner as SS payroll taxes are collected currently.
Accounts would be managed and invested, under the direction of the worker, in a federally-administered individual security account similar to the federal TSP.
When the balance of an individual's federally-administered individual security account is at least equal to the minimum deposit amount, the individual would be eligible to designate one of a range of several individual security accounts, still centrally managed.
For both "tiers" the central authority would maintain IA records and would combine account transactions in aggregate amounts when dealing with private investment firms.
S. 1878 (Graham)
$ Centralized Administration
Notes:
The newly-created Personal Retirement Account Board would establish a federally-administered IA for each participant in the Personal Retirement Account Fund.
IA contributions would be collected using the existing structure for collecting SS payroll taxes. IA contributions would be managed by a central authority in a manner similar to that of the federal TSP.
Initially, available investment choices would be limited to a first tier of options that would include several broad index funds (equity, government bonds, and corporate and other bonds) plus several balanced funds.
After the worker's account balance reaches a specified threshold, the worker would have the option of investing in a second tier of funds. The second tier, still managed centrally, would offer a range of funds provided by approved private investment firms. The worker would select an investment firm and the funds offered by that firm.
For both tiers, the central authority would maintain IA records and would combine account transactions in aggregate amounts when dealing with private investment firms.
Sources of Information on Individual Accounts in the U.S.:
AARP, Individual Accounts: Lessons from Sweden, AARP Issue Brief Number 60, May 2003.
AARP. Feasibility of Social Security Individual Accounts. By Francis X. Cavanaugh AARP Issue Brief #2002-14 (September 2002).
American Academy of Actuaries. Social Security Individual Accounts: Design Questions (October 2003).
American Academy of Actuaries. Social Security Reform: Voluntary or Mandatory Individual Accounts (September 2002).
Bender, Keith A. "Pension Integration and Retirement Benefits." Monthly Labor Review, vol 124, no. 2 (February 2001).
Burke, Karen C. and Grayson McCouch. "Privatizing Social Security: Administration and Implementation." Washington and Lee Law Review, vol. 58, no. 4 (Fall 2001).
CRS Report RL31085, Pension Issues: Small Employer Plans, by Patrick Purcell and Paul Graney.
CRS Report RL30122, Pensions and Retirement Savings Plans: Sponsorship and Participation, by Patrick Purcell
Employee Benefit Research Institute. Individual Social Security Accounts: Administrative Issues. EBRI Issue Brief Number 236 (September 2001).
Employee Benefit Research Institute. "Are Individual Social Security Accounts Feasible?" By Stephen Blakely. EBRI Notes, vol. 20, no. 3 (March 1999).
Employee Benefit Research Institute. "Small Employer Survey on Social Security Account Administration" By Kelly Olsen and Dallas Salisbury. EBRI Notes, vol. 20, no. 4 (April 1999).
Employee Benefit Research Institute. Individual Social Security Accounts: Issues in Assessing Administrative Feasibility and Costs. EBRI Issue Brief Number 203 (November 1998.)
John, David C. "Improving Social Security by Adding Personal Retirement Accounts: A Model for Implementation." Journal of Financial Service Professionals, vol. 55, no. 6 (Nov. 2001).
Moore, Kathryn L. "The Effects of Partial Privatization of Social Security upon Private Pensions." Washington and Lee Law Review, vol. 58, no. 4 (fall 2001).
President's Commission to Strengthen Social Security: Final Report. Chapter 2: "Administration of Personal Accounts" (December 2002).
Schreitmueller, Dick. "Social Security Personal Accounts: How Would They Work?" Journal of Pension Benefits, vol. 10, no. 4 (summer 2003).
Slusher, Chuck. "Pension Integration and Social Security Reform." Social Security Bulletin, vol. 60, no. 3 (1998).
U.S. General Accounting Office. Social Security Reform: Information on Using a Voluntary Approach to Individual Accounts, GAO-03-309. (March 2003).
U.S. General Accounting Office. Social Security Reform: Implications for Private Pensions, GAO/HEHS-00-187. (September 2000).
U.S. General Accounting Office. Social Security Reform: Administrative Costs for Individual Accounts Depend on System Design, GAO/HEHS-99-131 (June 1999).
U.S. General Accounting Office. Social Security Reform: Implementation Issues for Individual Accounts. GAO/HEHS-99-122 (June 1999).
Sources of Information on the U.K. Social Security System
Blake, David. Pension Schemes and Pension Funds in the United Kingdom. New York, Oxford University Press (2003).
Emmerson, Carl. Pension Reform in the United Kingdom: Increasing the Role of Private Pension? Oxford Institute of Ageing, Working Paper Number WP 402, October 2002. [http://www.ageing.ox.ac.uk/publications/papers/4-Emmerson.pdf]
Government Actuary's Department (UK), Occupational Pension Schemes 2000, Eleventh Survey by the Government Actuary, April 2003. [www.gad.gov.uk/publications/docs/ opss2000_final_results_final_7april2003.pdf]
U.S. General Accounting Office, Social Security Reform: Information on Using a Voluntary Approach to Individual Accounts, GAO-03-309, March 2003.
FOOTNOTES
1 U.S. Department of Labor, Private Pension Plan Bulletin: Abstract of Form 5500 Reports.
2 The percentage with a 401(k)-type plan is based on a CRS analysis of the Federal Reserve Board's 2001 Survey of Consumer Finances.
END OF FOOTNOTES
- AuthorsPurcell, PatrickNuschler, Dawn
- Institutional AuthorsCongressional Research Service
- Subject Area/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2004-22471
- Tax Analysts Electronic Citation2004 TNT 227-41