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Discussion Of Robert L. Brown's "Tax Assistance To Qualified Retirement Savings Plans: Deferral Or Waiver"*, Mark W. Campbell

Journal of Actuarial Practice (1993-2006)

In the paper entitled "Tax Assistance to Qualified Retirement Savings Plans: Deferral or Waiver," Robert L. Brown concludes that "the nontaxation of investment income on qualified funds until taken is a tax waiver or tax subsidy from the government to participants of qualified plans". I believe, however, that this conclusion is based on flawed assumptions pertaining to:

• The behavioral responses of taxpayers to the withdrawal of such tax assistance;

• The definition of an appropriate benchmark tax system against which to measure the cost of such tax assistance; and

• The appropriate basis of comparison of alternative government tax …