Tax Reform & Deficits: Moderate? or Raise the Stakes?

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October 16, 2017 03:50 PM GMT US Public Policy Brief Tax Reform & Deficits: Moderate? or Raise the Stakes? Will tax reform blow out the deficit? We think not, given Senate constraints & risks to our base case skewed toward legislative failure. Yet while this base case isn't a gamechanger, we remain vigilant for certain signposts that, if seen, set up bond market drama: an 'all or none' deficit choice. MORGAN STANLEY & CO. LLC Michael D Zezas, CFA STRATEGIST Michael.Zezas@morganstanley.com Meredith M Pickett STRATEGIST Meredith.Pickett@morganstanley.com Mark T Schmidt, CFA STRATEGIST Mark.Schmidt1@morganstanley.com Matthew Hornbach STRATEGIST Matthew.Hornbach@morganstanley.com +1 212 761-8609 +1 212 296-8165 +1 212 296-8702 +1 212 761-1837 There appears to be understandable confusion over how much tax legislation could expand the US deficit. There's an increasing embrace of the idea of growthfinanced tax cuts as a permission narrative for deficit expansion by some Republicans who had been vocal deficit hawks during the Obama administration. That key administration officials have suggested $2-3T of revenue losses will be made up by growth only further fuels speculation that a bill which substantially increases deficits looms. The likely outcome is a moderated plan with limited deficit expansion, because the alternative is a higher risk of failure. The Senate is the key to understanding outcomes. Because of their budget rules and thin majority, you only need a handful of deficit hawk voices to force a bill whose expected deficit expansion is far more modest than levels implied by the recent tax blueprint. Hence, Cohn, Mnuchin, and conservative Republicans may continue to embrace their inner 'Laffer' and advocate for the idea that tax cuts will fund themselves through substantial growth. However, there likely is not sufficient faith in that view in the Senate to drive votes to change budget rules and/or adoption of similarly aggressive growth assumptions for the tax bill's scoring. Hence, the proposal either moderates or probabilities of tax legislation 'failure' begin to rise. If our base case of moderation doesn't develop, then likelihood of success falls. Higher stakes & a volatile moment could emerge for the bond market. Signposts of a moderated plan would include at least some of the following: smaller rate cuts, & new 'pay fors'. If we approach the end of the year without some of those details emerging, then the dynamic could shift to a higher stakes choice on deficits. Without lower rates or more pay fors, Senate Republican leadership could feel pressure to abandon their current 'hawk-friendly' approach, adopt aggressive dynamic scoring, and enable legislation with substantially higher potential deficits. While that would alienate key members, reducing the odds of passage, it would set up an 'all or none' style vote on deficits. Relative to our current base case, which is neutral for bond markets, this would risk a volatile, curve-steepening moment, before returning to trend, as investors consider potentially boosted GDP expectations and the Fed reaction function. Due to the nature of the fixed income market, the issuers or bonds of the issuers recommended or discussed in this report may not be continuously followed. Accordingly, investors must regard this report as providing stand-alone analysis and should not expect continuing analysis or additional reports relating to such issuers or bonds of the issuers. Morgan Stanley does and seeks to do business with companies covered in Morgan Stanley Research. As a result, investors should be aware that the firm may have a conflict of interest that could affect the objectivity of Morgan Stanley Research. Investors should consider Morgan Stanley Research as only a single factor in making their investment decision. For analyst certification and other important disclosures, refer to the Disclosure Section, located at the end of this report. 1

US Senate - A Deficit Downer A common question we're being asked: how much could tax reform legislation increase the US deficit next year? It's an important question as it helps define the potential for a GDP boost next year and, consequently, the Fed reaction. It is also a source of confusion given the increasing embrace of the idea of growth-financed tax cuts as a permission narrative for deficit expansion by some Republicans who had been visibly hawkish on deficits during the Obama administration. In our view, that key administration officials, like Gary Cohn and Steve Mnuchin, have suggested $2-3T of revenue losses will be made up by growth only further fuels the perception that a bill which substantially increases the 2018 deficit is in the offing. Given this confusion, we want to offer a deeper breakdown of our view that the Senate's budget rules and prevailing politics should restrain deficit expansion and, accordingly, near-term GDP effects. The punchline is this: Cohn, Mnuchin, and conservative Republicans may continue to believe and advocate for the idea that tax cuts will fund themselves through substantial growth. However, there likely is not sufficient faith in that view in the Senate to drive votes to change budget rules and/or adoption of similarly aggressive growth assumptions for the tax bill's scoring. Hence, we think either a more modest tax proposal emerges or probabilities of tax legislation 'failure' begin to rise. Exhibit 1: Key Tax Provisions Big 6 Framework Our Base Case Timing Q417 1H18 Deficit Expansion 1.1% GDP 0.5% GDP Corporate Corporate rate 20% Phase-in to 25% Interest Deduction Partially limited Phase-in reduction Capex Expensing Extend bonus depreciation for 5 years Extend bonus depreciation Repatriation International Taxation Territorial Territorial Corporate Integration X X Tax Extenders Individual Brackets Permanent Cut, Consolidate to 3 brackets Temporary Cut, Consolidate to 4 brackets SALT Deduction Full repeal Income-based phase-out Mortgage Deduction Income-based phase-out Other deductions? Income-based phase-out Income exclusions Increase Standard Deduction Reduce Personal Exemption Repeal AMT Eliminate Estate Tax Temporary cut Remove ACA Taxes Source: Morgan Stanley Research, Unified Framework for Fixing our Broken Tax Code, Committee for a Responsible Federal Budget Let's start by breaking down how the Senate's position helps define deficit expectations from tax reform. As you might be aware, the Senate Budget Committee passed a budget resolution permitting $1.5T of deficit expansion over 10 years in order to accommodate tax reform. This begged the question from some investors about whether this actually set the table for a much bigger deficit expansion and, consequently, a more meaningful boost to growth and inflation expectations. In particular, the theory of $1.5T as a deficit 'floor' went: 2

The Senate can change the budget rules to allow for dynamic scoring (currently Senate rules prohibit the use of more than one set of economic assumptions), and/or overrule the parliamentarian if she tells them a dynamic score cannot be used for rulings on points of order under the Byrd Rule. Then, the $1.5T can be deficit left over (after accounting for growth), risking actual deficits even higher if those dynamic effects don t work Potential deficits are further augmented if the Senate replaces the JCT (and its more conservative dynamic scoring approach) as official scorers of the tax legislation, something Senate Budget Chair Enzi appears to have the power to do While we recognize this 'floor' theory is hypothetically possible, we think it is more likely that $1.5T is actually a deficit 'ceiling'. Consider: Senate rules don t currently allow dynamic scoring for budget reconciliation compliance, so we think $1.5T has to be the most any bill can be scored to add to the deficit under any method. 1 The vote count to change those rules doesn't appear reliable when you consider the positions of deficits hawks (Corker, Enzi) and Senate process purists (McCain, Collins, Murkowski). Further, that a similar rule change was not considered to facilitate ACA repeal despite its political urgency tells us something about the chamber's reluctance to change its rules. To elaborate, Senator Corker has been vocal in his declarations about not supporting a tax action that increases the deficit. 2 We think that Corker's comments should be read as wanting dynamic scoring to be a pay-for that brings the cost of the bill down to 0, not to allow for increased deficits above $1.5 T that are brought back down to that level. Senator Todd Young has echoed these sentiments. 3 The Senate Budget Committee Chairman Mike Enzi has final say over a score, and according to the New York Times, thus far "does not appear inclined to make radical changes to the rules." 4 For what its worth, independent budget analysts with more direct experience than we, like Bill Hoagland of the Bipartisan Policy Center, have stated their agreement with the idea of $1.5T as a 'ceiling' 5 Yet, even if you agree more with the 'floor' than the 'ceiling' theory, deficit expansion expectations still appear consistent with our range of.5%-1% of GDP. If you assume the JCT stays the official scorer, then their recent history of scoring tax cuts would suggest they re likely to give credit for.5-1.5% GDP growth. 3

Exhibit 2: Dynamic revenue estimates likely to be relatively modest Source Tax Plan Model Name JCT Camp (2014) JCT Camp (2014) JCT Camp (2014) JCT HR 2510 on Bonus Depreciation (2015) Source: Morgan Stanley Research, Joint Committee on Taxation JCT Macroeconomic Equilibrium Growth Model, High Labor Elasticity, Neutral Fed JCT Macroeconomic Equilibrium Growth Model, Low Labor Elasticity, Aggressive Fed JCT Overlapping Generations Model, Reduced Intellectual Property Elasticities 10Y Increase in GDP Further, it appears that the JCT and CBO's dynamic scoring models assume a "crowdingout effect," which may dampen the benefit of any deficit-financed tax cut from a scoring perspective. For example, the CBO noted of its Life-Cycle Growth Model that: "the model requires specification of future fiscal policies that put federal debt on a sustainable path over the long run. Forward looking households would not hold government bonds if they expected that debt as [a] share of GDP would rise without limit." Said differently, the CBO noted that "When the deficit goes up by one dollar, private savings is estimated to rise by 43 cents (national savings falls by 57 cents), and net capital inflows rise by 24 cents, ultimately leaving a decline of 33 cents in investment." 6 Although the JCT, and not the CBO, scores tax legislation, the CBO's explanation appears similar to the JCT's Overlapping Generations (OLG) model. The JCT says of its OLG model that "perfect foresight means the model cannot solve if fiscal policy is not sustainable," though its MEG model may feature "myopic individuals and business" which in turn could "allow simulation of nonsustainable fiscal policy." 7 In a 2011 paper, three economists at the JCT discussed how to model a five percentage point reduction in the corporate income tax rate, financed entirely by deficits. The economists concluded that GDP would rise only 0.1-0.2%. They argued: "In the longer run, the accumulated capital stock supports higher employment and consumption, maintaining a 0.2% increase in GDP. But increasing interest rates due to increased government borrowing slows the build-up of the capital stock, reducing saving; as a result, the fiscal picture begins to deteriorate." 8 In brief: a deficit-financed tax cut to increase investment may end up having little effect on investment, and therefore on growth, if higher deficits lead to higher interest rates (which makes borrowing to invest more expensive). Now, it is worth noting that the relationship between debt and interest rates is a controversial topic. 9 Record-high deficits occurring concurrently with record-low interest rates remains a striking contrast to earlier quantitative studies from the mid-2000s. 10 But we do not think recent experience will cause the JCT and CBO to substantially re-work their dynamic models. Further, consider this simplified example of the degree to which deficit expansion could be enabled by growth assumptions in legislative scoring. We do not possess the information to replicate the dynamic scoring process of the JCT and others, but offer this simple, conservative approach to show how deficit expansion potential is limited. First, we start with the principle that the score's assumed growth in tax revenue is equal to the potential deficit growth in either absolute terms (ceiling) or in addition to the $1.5T Senate-approved deficit (floor). Said differently, assumed tax revenue growth is potential deficit growth should dynamic effects not materialize. We then add a fixed percent to current 10-year CBO baseline GDP to very roughly approximate how a dynamic score might change it. We then calculate the hypothetical score's assumed tax revenue growth by mutilplying incremental GDP by 17.9%, the current share of GDP that 0.5% 0.1% 1.6% JCT Macroeconomic Equilibrium Growth Model 0.2% 4

goes to federal tax revenues. Finally, we assume that the average of the annual implied tax revenue growth is year 1 deficit growth capacity. This 'straight line' approach is consistent with dynamic deficit scores for prior tax actions, given their phases in approach, which we assume will apply to this action. As the table below then shows, a.5-1% deficit expansion assumption covers most reasonable outcomes if you assume the range of JCT's growth assumptions will apply. Even if the deficit expansion is more front loaded - for example, twice the annual average extra deficit - the deficit growth is not substantially higher. In this instance, assuming that forecasted GDP growth of 1% is not realized, then the increase in deficits would be in a range between 0.5%-1.31%, versus 0.25-1.06%. Exhibit 3: Deficit Growth Potential as a % of GDP Dynamic Scoring Assumption (GDP step up %) 0 0.5 1 1.5 2 2.5 3 Ceiling 0.00% 0.12% 0.25% 0.37% 0.50% 0.62% 0.75% Floor 0.81% 0.94% 1.06% 1.19% 1.31% 1.44% 1.56% Source: Morgan Stanley Research Hence, a key takeaway from our admittedly simplified analysis is this: for deficits to expand in a more meaningful, impactful way, a narrative must develop that causes Republicans to see no other way forward but to battle Senate deficit hawks and their explicitly stated views and intentions. While certainly not our base case, we explore this possibility and signposts for it in the next section so investors can prepare for this possibility. 5

What Would Make Us Wrong? The High Pressure, Hail Mary Scenario The key vulnerabilities to our above analysis are: The power of the Senate Budget Chair Enzi to substitute a more aggressive dynamic score for the expected conservative score of the JCT, thereby increasing potential deficit expansion. For example, the Tax Foundation scored the House GOP Blueprint as increasing the level of GDP by 9%, which is at least four times greater than how the JCT scored the Tax Reform Act of 2014 (the Camp Plan). 11 The potential for a conferenced budget resolution that raises the deficit 'ceiling' above $1.5T or extends the budget window beyond 10 years Yet given the evidence above that such moves would risk alienating enough votes to imperil the bill, we would interpret such a move as a gambit on a bill whose prospects are waning. Said differently, it would be an attempt to force Republican Senators to register a public vote, expecting that they would not vote against party orthodoxy on tax cuts. This is similar to the dynamic that played out on ACA repeal/replace. So what would suggest that tax reform prospects are falling while this 'high pressure Hail Mary' approach is becoming more likely? We'd watch for the following signs that suggest the current framework can't be effectively moderated: 'Red lines' on key rates (ie. the 20% corporate rate proposal) fail to moderate Existing 'pay for' proposals, like elimination of SALT deduction and/or limitation of corporate interest deduction, are watered down or removed without commensurate reduction of proposed rate cuts Congress starts 2018 without making substantial progress on key tax debates, perhaps due to government shutdown and DACA deliberations in December. While this is not our central expectation, we think investors should be attuned to this narrative as it packs greater potential market impact than our base case (moderated tax bill) or bear case (tax failure). Our cross asset and equity strategy team continue to argue that risk assets in the US on a relative and absolute basis are not pricing in an expectation of a positive growth shock from tax-driven stimulus. Hence, we think our base case of modest expansion and bear case of tax failure would likely not change the current market dynamic. However, the 'high pressure Hail Mary' brings a different dynamic. As we argued earlier, a shift to this dynamic would likely skew the odds against tax reform happening. But, if it did happen, it would now likely come with substantial enough deficit expansion to matter. For example, a simple annual average of the revenue loss of the cost of the current framework without any pay-fors would suggest a potential deficit expansion in 2018 of around 3% of GDP. 12 Hence, the tax legislation vote would become a more meaningful 'all or none' event on deficits for markets. This would set up a dynamic where vote uncertainty causes the bond market to start 6

pricing in some meaningful fiscal stimulus and reactive tightening from the Fed. While this likely supports our rates strategy team's outlook for a continued bear flattening of the yield curve, it could become a more volatile ride to arrive there. Specifically, if the choice was looking like an all-or-nothing affair, we expect bond yields would rise led by longer maturities. A risk premium, both in real rate and inflation, for higher deficits and uncertainty would begin to price in. But investor skepticism would prevent a disorderly move at first, given the precedent of failure on healthcare reform. In the event of passage, the subsequent move higher in rates would depend on the size of the static increase in the deficit over the next few years. Investors would likely assume higher coupon issuance across the curve with the Treasury continuing its strategy of extending the weighted average maturity of issuance. The long end would initially suffer from speculation over an ultra-long issue resurfacing. Ultimately, the increased issuance likely would pressure intermediate maturity Treasuries more than other sectors of the curve. Intermediates would also suffer from related expectations of either a consequent faster pace of rate hikes and/or a speedier balance sheet normalization profile (depending on the inclinations of the next Fed Chair). Once the increased deficit was in the price, the yield curve would continue its flattening trend. 7

Endnotes 1 Tax Notes, September 21, 2017; BNA, October 2, 2017 2 Politico, October 4, 2017 3 Indianapolis Business Journal, October 11, 2017 4 New York Times, September 22, 2017 5 Washington Examiner, September 26, 2017. 6 Hall, K. "How CBO Will Implement Dynamic Scoring." June 17, 2015. 7 Macroeconomic Analysis at the Joint Committee on Taxation and the Mechanics of Its Implementation. January 2015. Publication X-3-15. 8 Bull, Dowd and Moomau. "Corporate Tax Reform: A Macroeconomic Perspective." National Tax Journal, December 2011. 9 Consider, for example, the 2013 dispute over Reinhart and Rogoff's 2010 paper. 10 Nelson and Buol. "Budget Deficits and Interest Rates: What is the Link?" Central Banker - Summer 2004. Federal Reserve Bank of St. Louis. 11 See: Pomerleau, K. Details and Analysis of the 2016 House Republican Tax Reform Plan. "According to the Tax Foundation s Taxes and Growth Model, the plan would significantly reduce marginal tax rates and the cost of capital, which would lead to 9.1 percent higher GDP over the long term, 7.7 percent higher wages, and an additional 1.7 million full-time equivalent jobs." 12 To determine this number we used a straight line average of the $5.8 trillion 10-year cost of the plan estimated by the Committee for a Responsible Federal Budget. 8

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