David Duff (Toronto) presents Rethinking the Concept of Income in Tax Law and Policy at Michigan today as part of its Tax Policy Workshop Series. Here is part of the Introduction:
This paper reconsiders the Haig-Simons definition of income, critically examining the arguments that Haig and Simons themselves advanced in favour of this definition as well as the implications of each definition for the inclusion of imputed income, gifts and inheritances, and unrealized gains. Part II considers the grounds on which Haig and Simons supported their definitions of income, arguing that neither rationale provides a coherent and ethically appealing justification for the taxation of personal income. Part III examines the implications of each definition for the taxation of imputed income, gifts and inheritances and unrealized gains, arguing that these implications contradict our considered convictions about the appropriate scope of a tax on income. Part IV offers concluding observations on the concept of income for tax purposes and the rationale for income taxation more generally.



