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DIFFICULTIES OF VALUATION

People often say that a Capital Levy merely imagines everybody dying at the same time. This parallel is

wrong in degree when you are considering the ease of paying duty or of changing the market values by a glut

of shares, and it is still more wrong when you are thinking of ease of valuation. When a man is dead, he is

dead, and in estimating the death duty you have not to bother about how long he is going to live! But every

time you value a life interest and take a big slice of it for tax you are probably doing a double injustice. The

charge is incorrect for two taxpayers. On a flat rate of tax this difficulty might be made less, but the essence of

any effective levy is a progressive scale. Moreover, whether you are right or wrong about Robinson's tax, he

has nothing in hand with which to pay it. He has either to raise a mortgage on his expectation (on which he

pays annual interest) or pay you by instalments. So far as his burden is concerned, therefore, there is no

outright cut. You will be getting an annual figure over nearly the whole class of life interests and reversions. It

is difficult to see how one can escape making adjustments year after year for some time in the light of the

ascertained facts, until the expiry of, say, nine or ten years has reduced the disparities between the estimated

valuations and the facts of life to smaller proportions.

Next come those valuations which depend for their accuracy upon being the true mid−point of probabilities. A

given mine may last for five years in the view of some experts, or it may go on for fifteen in the view of

others, and you may take a mid−point, say ten, and collect your tax, but, shortly after, this valuation turns out

to be badly wrong, though all your valuations in the aggregate are correct. While the active procedure of

collecting the levy is in progress for a number of years these assessments will simply shout at you for

adjustment. There are other types of difficulty in assessment which involve annual adjustment, but you will

appreciate most the necessity for care in the collection. Enthusiastic advocates for the levy meet every hard

case put forward where it is difficult to raise money, such as a private ownership of an indivisible business, by

saying: "But that will be made in instalments, or the man can raise a mortgage." But the extent to which this is

done robs the levy of all the virtues attaching to outrightness, for each instalment becomes, as the years roll

on, different in its real content upon a shifting price level, and every payment of interest on the mortgage−−to

say nothing of the ultimate repayment of that mortgage−−falls to be met as if reckoned upon the original

currency level. Then those classes of wealth which are not easily realisable without putting down the market

price also require treatment by instalments, and those who wish to put forward a logical scheme also add a

special charge upon salary−earners for some years−−a pseudo−capitalisation of their earning power.

A really fair and practicable levy would certainly be honeycombed with annual adjustments and payments for

some period of years, and one must consider how far this would invalidate the economic case of the "outright

cut," and make it no better than a high income−tax; indeed far worse, for the high income−tax does at least

follow closely upon the annual facts as they change, or is not stereotyped by a valuation made in obsolete

conditions. Imagine three shipowners each with vessels valued at L200,000, and each called upon to pay 20

per cent., or L40,000. One owning five small ships might have sold one of them, and thus paid his bill; the

second, with one large ship, might have agreed to pay L8000 annually (plus interest) for five years; while the

third might have mortgaged his vessel for L40,000, having no other capital at disposal. At to−day's values

each might have been worth, say, L50,000, but for the tax. The first would actually have ships worth L40,000,

so he would have borne the correct duty of 20 per cent. The second would have L50,000, bringing in, say,

L5000 annually, and would be attempting to pay L8000 out of it, while the third would be paying L2000 a

year out of his income and still be faced with an 80 per cent. charge on his fortune! His assessment is  computed at one point of time, and liquidated at another, when its incidence is totally different.

If one cannot have a levy complete at the time of imposition, it clearly ought not to be launched at a time of

rapidly changing prices. But that is, perhaps, when the economic case for it is strongest.