Jvisory Commission on IntergOVCrnmcntal Relations Washington, u. C. 20575 APR 7 1969 honorable John 5. Hold House of Representa tives Hashington, D. C. 20515 Dear Congressman Hold: in response to your letter of March 28, 1969, let me first point out that it was never the intention of the Advisory Omission on Intergovernmental Relations to "point the finger" at any State-- either for merit or criticism. Rather. our intention was simply to provide a factual basis for determining the proportion of State and local taxes to personal income. In this regard, you will note that the heading of Table l avoids the phrase "tax burden" and simply says "State and Local Revenue as s Percent of State Personal Income. by State. 1957. 1962 and 1967." Similarly my statement in the accompanying news release was neutral on this point. Specifically. my remarks were "Tax collections ranged from a high of more than 12 percent of personal income in unwaii, Hyoming and New York to a low of less than 8 percent in Ohio and illinois. Whether we view this an index of tax effort or tax burden depends upon how we View the role of State and local gov- ernment in the American federal system." Let no further point out that the data presented in Table l are essentially similar to the series published by the Bureau of the Ceneus in their annual publication, Qggggggentsl tinances. Census presents several series of general revenue per $1,000 of personal income and one of their specific tabulations is total State and local taxes in relation to income. further, the series published in our report is similar to the data that is so frequently mentioned as the "tax effort" factor to distribute various proposed revenue-sharing plans. with regard to the measure Hr. Allen has proposed, it would seem necessary to exclude the State and local taxes that other States export before determining wyoming's relative position. It is not clear from your letter whether this has been done in reaching the conclusion that Nyoming would emerge 33rd or 32nd under this substitute measure. The reference that "Hyomins has some unique conditions" that vitiatc our approach makes me suspect that this was not done. Tax exporting, however, is not unique to Wyoming; virtually all States Honorable John 8. Hold 2 - do it to some extent. You may incidentally be interested in 0 anne- what dated study that appeared in the National Tax Journal. March 1967, pp. 49-77. in that study. Charles R. McLure, Jr., made estimates of the percentage of all State and local taxes that were exported (or 1962. Mia eatinates for abort-run exporting show that nine Stateal/ export acre of their St; e-local taxes than does Wyoming; in the long run. five ltste exceed Hyoming's rate of 23.3 percent. Perhaps of even greater significance is Mr. Nature's statement (p. 66) "However, the overall export rates for 1962 are fairly abnilar between atates. despite considerable differences in state economiea and tax structures. to the extent this observation is true, Wye-ing's tax exporting is not only not unique but not strikingly different from the practice of other States and. of course. roughly similar tax exporting ratios would lead to similar rankinga among States both in State and local "tax burden, or under the approach we took. As a second coauent on Mr. Allen's proposed measure. let me offer the suggeation that it the purpoae of the alternative series in to dietinguiah tax burdens among States. it should not only ex- clude State and local taxes exported by all States but it should include State and local taxes ilported by the reapective States since the latter are ultimately also paid by reaidents of a particu- lar State. I am not at all sure that Wyoming would emerge on a favorable basis it thia were done. Essentially the reasons Hr. Allen offers for "favorable tax exporting" in "yo-in3--i.e.. its extractive reaources--would he the basia for an "unfavorable tax inputting" situation--the relative lack of a Ianufacturing sec- tor. I do not. however. know of any nonparahle tax importing studies that have been done. The question of estimating tax burdens for residents of a particular State then can become a quite complex exerciae. It is for the reasons given here that the stat! of the Advisory Conndsaion choee to present the familiar State and local taxes as a percent of personal income in ita report. with these points in hind, let me again state that we felt we were publiahing useful and factual data regarding one of the many faceta of State-local finance. 1/ Theae states are: Arizona, Connecticut. Delaware, Louisiana, Hichigan. Nevada, North Carolina. South Carolina and Texas. A/ These Statea are: Arizona, Delaware. Louiaiana, Nevada and Texas. Honoreble John 8. Hold 3 - After having eeid all of this. 1 went to ehnre your concern et the we, the new. India heve handle! these date to the detriment of thoee Stetee that heve the higheet ;etio of State end locel tax receipte to totel peroonel intone. Speciticelly, 1 en etteching e letter to the Editor of the U. 1. Ref! and 22:15 lgggrt, telling hie ettention to the highly questioneh e terminology need to deecrlbo our State and local tax findingo. Sincerely yours. lerrie Bryant Chair-en lncloeure