This paper demonstrates that the optimal structure of taxation in a fe
deral system of governments is one in which only lower level governmen
ts are allowed to tax, and the higher level of government receives its
revenues as contributions from the lower level governments. The centr
al inefficiency created when multiple levels are allowed to tax is a r
evenue externality between governments that is analogous to a common p
ool problem. A federal system with multiple levels of taxing authority
results in combined tax rates higher than would be optimal, a higher
excess burden of taxation, and an inefficiency bias in government spen
ding.