Here’s Why, Actually, The IRS $600 Bank Reporting Proposal Is Entirely Reasonable

Over the last several days, we’ve seen the Outrage Machine in action over a new Treasury proposal to require banks to report to the IRS new information on U.S. bank accounts, in addition to the existing reporting of interest payments. This proposal, as described at CBS News (among, of course, many other sites) would require banks to report the gross annual inflows and outflows in bank accounts, ostensibly to catch high-income tax-dodgers. Because the threshold for reporting was set at $600, skeptics are, well, skeptical of the assertion that this change would only affect, as the Biden administration claims, those earning over $400,000 per year.

At the Heritage Foundation, a commentary claims that this change would be “invading your privacy and putting more of your financial data at risk,” citing past leaks at and politicization of the IRS. A group of 40 banking/credit industry organizations likewise objected that Americans’ financial privacy was at risk and claimed that this new requirement would deter unbanked households from establishing accounts. And other politicians, as cited in fact checks, mischaracterizing the proposal, claim that it would result in the IRS examining the particulars of every $600 transaction. Whether the very low threshold is an indication that the administration is being dishonest in its claims that their objective is only to catch wealthy tax cheats when they are, in fact setting the stage for a wider pursuit, or whether this is more a matter of failing to think through the implications of such a low threshold, who can say.

But at the same time, the other day, while driving home, I listened to a fairly generic conservative radio talk show host angry about this proposal. He was not angry about privacy concerns, and certainly not about whether people at the margins would be deterred from opening bank accounts, nor about the cost to banks of compliance with the new regulations. No, what he was up in arms about was the fact that Americans would be obliged to pay tax on their moonlighting self-employment income.

So here’s the plain-and-simple reality: Americans owe FICA tax on all their income up to the ceiling, and are obligated to report all their income in calculating their income tax. There is no legal, moral, or ethical right to underreport just because your income came from some other source than a “real job.” A babysitter, an Ebay reseller, someone who picks up handyman jobs on the side — all these folks have an obligation to report their income. (As a parent and Band Mom, I’m personally learning the ropes here, as our group navigates sending Form 1099s to college students and local musicians who are hired periodically.)

And — without wishing to wade into the entirely separate issue of high-income tax cheats — the “shadow economy” in the United States is substantial. Estimates are hard to come by, but one guesstimate is that the underground economy amounted to 11 – 12% of US GDP in 2018. A 2012 survey indicated that 91% of nannies reported being paid under the table. Among all household workers, another estimate found rates of between 74% and 97%, depending on methodology. And of course, the under-the-table workforce extends far beyond household workers, though it gets harder to quantify when we’re talking about other sorts of self-employed people not reporting their income, or small employers paying under the table.


But consider this: some time ago I discussed a book, Downhill from Here by Katherine S. Newman, which lamented gaps in the retirement system, such as multiemployer pension insolvencies and the retirees of Detroit, whose pensions were cut modestly with the city’s bankruptcy. I didn’t place too much credence in her arguments, lamenting as she did, for example, that the city of Detroit did not, in fact, sell art from the Detroit Institute of Arts to preserve pensioners’ benefits in full.

But in addition to these stories, she featured profiles of Americans who were working well past traditional retirement age, including Leslie, who ran a home daycare “off the books” and built up so little official employment history that her Social Security benefit was “almost nothing,” and Marissa, who was mostly paid under the table for housecleaning work and likewise had no meaningful Social Security benefit. In case case, Newman implies that it is a matter of unjust Social Security plan design that these women have no/few benefits rather than acknowledging that it was an intentional decision not to report their income.

In the same way, there are periodic sympathetic news reports of women formerly employed as nannies or housecleaners who became unemployed in the wake of the pandemic — but it doesn’t occur to those journalists that, to the extent that those women were employed, rather than self-employed, they should have qualified for unemployment benefits, or would have, had they been paid on the books.

Yes it’s unpopular to talk about this. There’s a presumption that people working under the table are poor, so that it would be unfair to enforce the requirement to pay taxes. Certainly, many of these workers would have incomes low enough that they would not be obliged to pay income taxes, though payroll/FICA taxes apply to all income. But for others, this is a sideline, and in yet other cases, they are genuinely employed, not self-employed, and have an employer who profits from the ability to escape taxation on some of their payroll.

And it’s not just a matter of lost taxes, or lost Social Security benefits. There’s something more fundamental that’s lost in our society when we treat participating in taxation and social insurance systems as somehow optional.

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