Under the realization rule, accrued gains and losses generally are not taken into account for income tax purposes until a disposition occurs. Thus, the realization rule is responsible for tax deferral, which in turn likely leads to economic inefficiencies and inequities. The realization rule also contributes greatly to the complexity of the federal income tax system by necessitating numerous Internal Revenue Code provisions that address the many consequences arising from the decision to postpone taxation until a disposition occurs.
An alternative to the realization rule is accrual taxation - the inclusion in the tax base of annual increases and decreases in the value of property, regardless of disposition. Accrual taxation may improve economic efficiency and equity, and certainly would obviate a substantial portion of the Code. Yet, accrual taxation presents serious problems of its own - the difficulty of valuing assets and possible taxpayer illiquidity. For these reasons, few have supported such a system. And the rare proposals made are merely calls for partial accrual taxation.
This article considers and analyzes complete accrual taxation. Actually, like prior proposals, the system considered here also excludes certain assets as well as the imputed income on consumer items. However, this accrual system is more complete in that it seeks to value and tax on an annual basis what are likely the most difficult-to-value assets - nonmarketed business interests and collectibles. To value these assets, this article suggests the use of computer software, in particular, artificial intelligence.
The goal of this article is to demonstrate that complete accrual taxation is potentially beneficial and feasible, and that further research should be done to address these issues. Much of the remaining work should be left to those who are expert in the fields of economics, artificial intelligence, and valuation. While this research may be difficult and costly, the potential benefits of complete accrual taxation warrant the endeavor.
'Complete' Accrual Taxation, 33 San Diego Law Rev. 1559-1680 (1996).