In this article, Professor Michael Knell proposes replacing the curren
t corporate income tax with an accretion corporate tax, which would ta
x the change in the total market value of a corporation's outstanding
securities. Such a tax would more closely approximate the income ideal
and would be simpler to implement than the present system, which reli
es on unsatisfactory accrual accounting conventions. Most important, t
he accretion corporate tax would sharply reduce the cost of tax admini
stration, the burden of tax compliance, and the incentive to engage in
tax planning. Professor Knell also describes how to implement the acc
retion corporate tax, addressing such questions as the appropriate tax
base, the valuation of nontraded securities, and the adjustments nece
ssary to preserve special tax rules.