Who Pays the Property Tax?

George Zodrow, Abril 1, 2006

A critical aspect of the property tax, but one that is rarely addressed in public debate, is its “economic incidence,” or who actually bears the burden of the tax, as opposed to its statutory incidence, or who literally pays the tax. For example, a landlord might pay a property tax bill, but if some of the tax is offset with a rent increase, then the tenant bears that part of the tax burden. Not surprisingly, estimates of the economic incidence of taxes depend on the relative responsiveness of supply and demand to tax-induced price changes—factors that explain the extent to which consumers and businesses can change their behavior to avoid the tax.

The economic incidence of a tax is also affected by the phenomenon of “capitalization”—changes in asset prices that reflect the discounted present values of the economic effects of future tax and/or public expenditure changes. For example, an increase in property taxes, holding expenditures constant, might be capitalized into land or house values. The prices of these assets might fall by the present value of the projected increase in future taxes, whereas increases in expenditures, holding property taxes constant, might have offsetting effects.

These capitalization effects should include the effects of other tax-induced price changes, such as changes in future housing or land rents. In principle, the economic incidence of all of these capitalization effects is on the owners of land and housing at the time of the imposition of the tax, when the effects are “capitalized” as one-time changes in the prices of these assets. These price changes also significantly affect the ultimate economic burden of the tax on subsequent purchasers.

Benefit Tax versus Capital Tax Views

The complexity of measuring all of these effects implies that determining the economic incidence of taxes is one of the most difficult problems in public finance, and the property tax is no exception. Indeed, the debate over the incidence of the residential property tax has raged for at least the last thirty years, and is still far from resolved. Professional opinion on the incidence of the tax is generally divided between the “benefit tax” view and the “new” or “capital tax” view (Zodrow 2001).

Under the benefit tax view, the property tax is considered a user charge for public services received. It thus serves the function of a local head tax or benefit tax as envisioned by Tiebout (1956) in his celebrated analysis of how interjurisdictional competition coupled with consumer mobility can lead to the efficient provision of local public services. The implications for taxpayers are threefold. First, as a benefit tax the property tax is simply a payment for public services received, analogous to purchases of goods and services for private markets. Second, because the property tax functions as a market price, its use implies that local public services are provided efficiently. Third, the property tax, like all benefit taxes, results in no redistribution of income across households and thus has no impact on the distribution of income.

By comparison, under the capital tax view derived by Mieszkowski (1972) and elaborated by Zodrow and Mieszkowski (1986b), the property tax is a tax on the use of capital and thus inefficiently distorts resource allocation by driving capital investment out of high tax jurisdictions and into low tax jurisdictions. The capital tax view divides the incidence of the property tax into two components. The national average tax burden is in effect a “profits tax” borne by all capital owners, including homeowners, businesses, and investors. The local or “excise tax” components of property tax rates that fall above or below the national average are borne locally through changes in land rents, wages, or housing prices.

The incidence effects of local taxes that are higher and lower than the national average tend to cancel one another in the aggregate. Therefore, the profits tax effect is the main factor determining the incidence and distributional effects of the property tax. From the perspective of any single taxing jurisdiction, however, the burden of local expenditures financed by the property tax tends to be borne primarily by local residents.

The capital tax view has different implications for taxpayers in all three of the areas noted above for the benefit tax view. First, the tax has some significant benefit aspects in that local tax increases tend to be borne by local residents. Second, the tax inefficiently distorts housing consumption decisions; moreover, use of the local property tax can also lead to inefficient underprovision of local public services if government officials, concerned about tax-induced loss of investment, then reduce the level of public services (Zodrow and Mieszkowski 1986a). Third, because the primary effect of nationwide use of the property tax is a reduction in after-tax returns to capital owners, it is a highly progressive tax. Nevertheless, from the perspective of a single taxing jurisdiction, the local tax is not borne by capital owners as a whole but rather by local residents and is a roughly proportional tax. (See Table 1 for a summary of these two views.)

Capitalization and the Incidence of the Property Tax

My recent research sponsored by the Lincoln Institute has focused on a single but critical aspect of this long-standing debate. Dating back to the seminal work of Oates (1969), empirical evidence of the interjurisdictional capitalization of the discounted values of local property taxes and public services into house prices has been interpreted as offering support for the idea that property taxes can be viewed as payments for local public services received, consistent with the benefit tax view.

This notion was extended to the case of intrajurisdictional capitalization in the pathbreaking work of Hamilton (1976). In this model, which is characterized by perfectly mobile households with heterogeneous demands for housing and fixed housing supplies, intrajurisdictional fiscal capitalization converts the local property tax into a pure benefit tax, even though all houses are not identical. Specifically, high-value homes sell at a discount that reflects the capitalized present value of their “fiscal differential”—the present value of the excess of future taxes paid relative to public services received.

Similarly, low-value homes should sell at a premium that reflects the capitalized present value of the extent to which future taxes paid are less than the value of public services received. As a result, all households “pay for what they get” in public services, and the property tax is an efficient benefit tax. Capitalization thus implies that it is futile to follow the conventional strategy of buying a low-value home in a high-value community in order to receive local services at relatively low cost.

In supporting the idea that the combination of strict zoning regulations and fiscal capitalization converts the property tax into a benefit tax, Fischel (2001) interprets the extensive literature on the capitalization of property taxes and public services as demonstrating that fiscal “capitalization is everywhere.” He concludes that empirical support of fiscal capitalization provides compelling evidence that the benefit tax view accurately describes the effects of the property tax. Fischel makes this argument in the context of a model in which local governments are analogous to municipal corporations that maximize the house values of “homeowner-voter shareholders” who strive to protect their housing investments.

The central result of my research is that even if empirical evidence of the phenomenon of fiscal capitalization implies that it is indeed “everywhere,” such evidence does not establish the validity of the benefit tax view. Rather, my model shows that if one adopts all of the admittedly stringent assumptions of the benefit tax view, complete intrajurisdictional land value fiscal capitalization is also entirely consistent with, and indeed predicted by, the capital tax view of the property tax.

When combined with earlier results that demonstrate that interjurisdictional capitalization is also consistent with the capital tax view, my research results imply that the widely observed phenomenon of property tax capitalization provides little if any grounds for distinguishing between the capital tax and benefit tax views. That is, capitalization does not tell us whether the property tax should be viewed primarily as a progressive tax on all capital that inefficiently distorts decisions regarding housing consumption (the capital tax view), or an efficient user charge that has no effects on the distribution of income (the benefit tax view).

A Reconstruction of the Benefit Tax View

My research begins by reconstructing the Tiebout-Hamilton benefit tax view within the context of a partial equilibrium version of the standard differential tax incidence model, which focuses on the effects of use of the property tax in a single taxing jurisdiction. This approach is necessary because the derivations of the benefit tax and capital tax views of the property tax are based on somewhat different theoretical approaches.

Hamilton’s benefit tax view model characterizes the properties of an economy in equilibrium, with local public services financed by residential property taxes rather than the head taxes assumed by Tiebout. In contrast, the derivations of the capital tax view, such as those in Mieszkowski (1972) and Zodrow and Mieszkowski (1986b), are based on the differential tax incidence analysis pioneered by Harberger (1962). Under this approach, the effects of the property tax are analyzed by first constructing an initial equilibrium with either no taxes or only nondistortionary lump-sum taxes, and then introducing property taxes and analyzing their effects.

To facilitate a comparison of the two views, my analysis begins by deriving all of the benefit tax view results obtained in Hamilton’s model of intrajurisdictional fiscal capitalization within the context of a differential tax incidence model, one that is typical of the capital tax view but nevertheless makes the essential—and admittedly rather stringent—assumptions characteristic of derivations of the benefit tax view. In particular, households are perfectly mobile across competing local jurisdictions with an exogenous source of income, and there are a sufficient number of jurisdictions to satisfy all tastes for local public services.

Following Hamilton, the model has two different types of households, one of which demands relatively larger houses. Initially, the local economy is assumed to be in a Tiebout equilibrium, with local public services as well as housing and the composite good provided at efficient levels, and with local public services being financed by uniform head taxes per household. The fixed supply of land within a jurisdiction is used either for large houses for “high demanders” or small houses for “low demanders.”

Property taxes on all land and capital within the jurisdiction are then introduced into the model, with the revenues used to reduce the level of head taxation while holding the level of public services per capita fixed. Zoning is also introduced, by assuming that the amounts of land used for large and small houses are fixed. This is a weak version of the approach followed by Hamilton, who assumes fully developed communities and thus precludes any change in land or capital allocated to the two types of housing. Indeed, some form of land use zoning is required for any capitalization to occur since, in the absence of zoning, all land within the jurisdiction would in the long run sell for the same price and there would be no capitalization (Ross and Yinger 1999). In this derivation of the benefit view, housing capital is also assumed to be fixed, as in Hamilton’s analysis.

The effects of introducing property taxes on both housing capital and land in this initial equilibrium are identical to those predicted by Hamilton. First, for large homes, which experience a disproportionately larger increase in property taxes, the resulting negative fiscal differential is fully capitalized into lower housing prices. Similarly, small houses sell at a premium that exactly reflects the negative fiscal differential between total property taxes paid and the associated benefits of the tax change as measured by the reduction in head taxes.

Second, the net change in land values due to capitalization in a heterogeneous jurisdiction is zero; that is, the aggregate amount of the discount in land prices for larger homes equals the aggregate amount of the premium in land prices for smaller homes. Third, the price of each type of housing rises by just enough to offset the cost of the public services that must be financed with property taxes.

To sum up, all of the benefit tax view results obtained by Hamilton are obtained within the context of a partial equilibrium differential tax incidence model of a single taxing jurisdiction that is comprised of households that are homogeneous with respect to demands for public services, but heterogeneous with respect to demands for housing. Once again, capitalization implies that the property tax is a benefit tax. Accordingly, the combination of property tax payments and capitalization effects implies that (1) taxpayers pay for all their local public services; (2) both housing and local public services are consumed at efficient levels; and (3) the property tax results in no redistribution of income.

Capitalization Under the Capital Tax View

Converting this model to accommodate a version of the capital tax view is straightforward. Recall, however, that this approach considers the effects of the property tax from the perspective of a single taxing jurisdiction, which is modeled as a small open economy that faces a perfectly elastic supply of capital. Since the net rate of return to capital is fixed by assumption, the effect of nationwide use of the property tax on the return to capital cannot be analyzed. Nevertheless, within the single taxing jurisdiction framework the effects of the property tax on the allocation of housing capital, as well as the effects of this tax-induced reallocation on all other variables, including the changes in land prices that are the focus of the analysis, can still be derived.

The key distinction between the benefit tax and capital tax views of the property tax is that under the latter approach the stocks of housing capital are not assumed to be fixed (although the zoning assumption of fixed land supplies for the two types of housing is maintained). That is, under the capital tax view, which clearly reflects a relatively long-run view of incidence, households can reduce their housing consumption in response to an increase in the property tax.

Given these assumptions, the implications of the capital tax version of the model are as follows. First, capital flows out of the production of large houses where property taxes are high relative to benefits received, and into the production of smaller homes where the property tax bill is low relative to benefits received. This reallocation of housing capital is an important factor in determining incidence—who ultimately pays the property tax. The analysis shows that land rents unambiguously increase for land used for small houses and decrease for land used for large houses, and it is these changes in land rents that are capitalized into land prices. The key result is that these land value capitalization effects under the capital tax view are precisely the same as those calculated previously under the benefit tax view. Thus, the existence of capitalization does not help resolve the critical issue of whether the benefit view or the capital tax view more accurately describes the incidence and economic effects of the property tax.

The other results derived in Hamilton’s model obtain in this capital tax model as well. The net effect of property tax capitalization on aggregate land value within the taxing jurisdiction is zero. Similarly, the effects of the property tax on housing prices—which rise by an amount just sufficient to offset the value of public services received—are also identical under the two models, implying that housing prices for smaller homes increase proportionately more than prices for larger homes.

Despite this distortion of the allocation of housing capital under the capital tax view, the local effects of use of the property tax still have some very important features that are characteristic of a benefit tax. For example, residents pay for net local public services received (those not financed with head taxes) in the form of higher housing prices. Simultaneously, fiscal differentials are capitalized into land values, so that the net effect of the property tax burden and land value capitalization is that future purchasers of both types of houses effectively pay for what they get in public services.

Thus, the essential difference between the two views of the property tax is that, under the capital tax view, land value capitalization occurs due to capital reallocations across housing types, implying inefficiency in the housing market. Under the benefit tax view, capitalization occurs with respect to fixed housing capital stocks, and there is no distortion of the allocation of housing capital. For example, if a local government finances an increase in public expenditures with additional property taxes, the resulting capitalization effects are the same under both views (and cause the same gains and losses at the time of implementation). However, the capital tax view implies that in the long run housing demands will decline, while housing consumption remains unchanged under the benefit tax view.

My model also shows that under the capital tax view per capita housing consumption declines unambiguously for both types of households, which is the standard result that the property tax causes an inefficient reduction in housing consumption. In addition, the number of households that purchase small houses unambiguously increases, while the net effect on the number of households that purchase large houses is theoretically ambiguous, and the total population in the jurisdiction increases.


This analysis shows that, within the context of a partial equilibrium analytical framework characterized by assumptions typical of the benefit view of the property tax, intrajurisdictional capitalization into land values of fiscal differentials is entirely consistent with, and indeed predicted by, the capital tax view of the property tax. Earlier results demonstrate that interjurisdictional capitalization is also consistent with the capital tax view (Kotlikoff and Summers 1987). Together, these results suggest, counter to the claims of benefit tax proponents, that empirical evidence supporting full capitalization of property taxes in land values—either within or across jurisdictions—provides little if any evidence that allows researchers to distinguish between the capital tax and benefit tax views.

Instead, the key issue is whether the zoning restrictions or other mechanisms stressed by proponents of the benefit tax view are sufficiently binding to preclude the long-run adjustments in housing capital predicted by the capital tax view. This issue promises to be a fertile topic for future research, which may help clarify the answer to the long-standing and critical question of who pays the residential property tax.


George R. Zodrow is professor of economics and Rice Scholar in the Tax and Expenditure Policy Program of the Baker Institute for Public Policy at Rice University in Houston, Texas.




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