Human Endowment Taxation

Michigan law prof David Hasen has an intriguing new article, "The Illiberality of Human Endowment Taxation."  Right now, only the abstract appears to be available:

Recent tax scholarship has embraced the idea of human endowment taxation, or taxation of human capabilities, as an approach to ideal tax theory. Under endowment taxation, individuals are taxed according to their native ability to command resources, rather than according to any actual index of goods or expenditures, such as income, consumption or wealth, that might otherwise be thought relevant to imposing tax burdens. This article argues that endowment taxation is generally incompatible with political theories that might broadly be described as "liberal," whether or not these theories are thought to authorize redistribution. The article also suggests that under a wide array of assumptions, lump-sum taxes such as endowment taxes are not optimally efficient and that, even where they represent the most efficient available alternative, lump-sum taxes generate undesirable costs.

I know nothing about tax law (I've even forgotten anything I learned about it in law school), but endowment taxation seems fairly provocative from the standpoint of Catholic legal theory.  The Church instructs that, "In the redistribution of resources, public spending must observe the principles of solidarity, equality, and making use of talents." (Compend. of Soc. Doctrine 355)  I'm not sure that "making use of talents" means that the state should ascribe a taxable value to those innate talents regardless of an individual's initiative, but I'd welcome the input of someone who has followed this debate in the literature.

(HT: Solum)

Rob

UPDATE: William & Mary tax law prof Eric Chason offers this helpful explanation:

The idea is that everyone is taxed according to their ability to earn income, rather than their actual income. Taxing actual income distorts the decisions one makes about work versus leisure. Knowing that the government takes a cut from the returns on your work efforts makes you less likely to work. Contrast this with a poll tax, where everyone pays the same amount. The poll tax does not distort your work decision, because you keep everything from your work efforts. But most people think that a poll tax is intolerable because of the burdens it would place on the poor.  An endowment tax is essentially a progressive poll tax. The amount you pay is calibrated to the amount you could earn--whether or not you could actually earn it.