PB-240 988
AN EVALUATION  OF THE IMPACT OF DISCRIMINATORY
TAXATION ON THE USE OF PRIMARY AND SECONDARY
RAW MATERIALS
BOOZ-ALLEN AND HAMILTON, INCORPORATED
PREPARED FOR
ENVIRONMENTAL  PROTECTION AGENCY

1975
                        DISTRIBUTED BY:
                        KFOl
                        National Technical Information Service
                        U. S. DEPARTMENT OF COMMERCE

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1. Report No.
   EPA/530/SW-lOlc
                                                     2.
                 PB   240   986
 4. r:>> •!,(] Subtitle
    Ar. -.".valuation  of the Impact of  Discriminatory Taxation on>
    the Use of Primary and Secondary  Raw Materials
                  5. Report Date
                      1975
                  6.
 7.
    Scoz-Allen and  Hamilton
                  •8. Performing Organization Rep:
                    No.
 9. Pprtoiining Organization Name and Address
    booz-Allen & Hamilton
    1021J Connecticut Avenue, N.W.
    Washington, D. C.   20036
                  10. Project/Task/Work Unit No.
                  11. Contract/Grant No.

                     EPA-68-01-0792
MP. Sponsoring Organization Name and Address
i    U.S.  Environmental  Protection Agency
    Office of Solid  Waste Management  Programs
    Washington, D. C.   20460
                  13. Type of Report & Period
                    Covered
                    Final
                  14.
 IS. Supplementary Notes
 16. Abstracts
    This report attempts to describe  and quantify the  value of current  Federal tax
    policy as it relates to competition  between virgin  and secondary materials.  Tax
    incentives are quantified on a per ton basis both  at the raw material  and selected
    final  product stages.   A qualitative review of the  potential in.pact of removing
    virgin material  incentives on the use of secondary  materials if provided.  Seven
    materials are included (bauxite,  timber, sand, iron ore, coal, oil, natural gas)
    with an analysis  of how their taxes  impact on several  product categories (glass,
    steel, aluminum,  newsprint, paperboard, plastics and rubber).  The  tax benefits
    examined include  the depletion allowance, capital  gains, exploration and development
    expenditures, State and local taxes  and foreign taxes..
 17. Key Words and Document Analysis.  17o. Descriptors

   *  Tax policy
   *  Secondary materials
   *  Recycling
 17b. Identifiers/Open-Ended Terms
 17c. COSATI Field/Group
 18. Availability Statement
      19. Secuiity Class (This
         Repot)
      	in CL
                                                         21. No. of Pages
                                                                 iffi
                                                                  Cla
      20. Security Class (This
         Page
           UNCLASSIFIED
                                                                               22. Price
  ORM NTis-38 IREV. «o.7ai  ENDORSED BY ANSI AND UNESCO.
THIS FORM MAY BE REPRODUCED
                                                                               USCOMM-OC 8269-P74

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                               SUMMARY
      This is a summary which presents findings and conclusions
 developed at length in the body of this report.


 1.    THE PRIMARY PURPOSE OF THIS STUDY HAS BEEN TO
      IDENTIFY DISCRIMININATORY TAX TREATMENT AND
      ESTIMATE ITS IMPACT ON RAW MATERIALS COSTS
      IN SIX INDUSTRIES
      The primary purpose of this study has been to identify taxes and
tax shelters applicable on a discriminatory basis to virgin or secondary
raw materials and to estimate their impacts on raw materials costs for
the following industries:
                 Aluminum
                 Pulp and Paper
                 Glass
                 Steel
                 Plastics
                 Rubber
      As a secondary study objective,  an attempt has been made to
assess, on a qualitative basis, the extent to which discriminatory
taxation may influence relative virgin and secondary materials use
in the commodities of interest.
2.    DISCRIMINATORY TAXES AND TAX BENEFITS WERE
      IDENTIFIED
      For purposes of this study, discriminatory taxes and tax benefits
were defined as those which are incident to the use of either virgin or
secondary raw materials but not to both.  It should be  clearly under-
stood that the term "discriminatory" in this context implies no judg-
ment as to the equitv or utility of specific taxes or tax benefits but
merely relates to their incidence.

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            AN EVALUATION OF THE IMPACT OF
          DISCRIMINATORY TAXATION ON THE USE
        OF PRIMARY AND SECONDARY RAW MATERIALS

                     Final Report
     This report (SW-lOlc) on work performed under
Federal solid waste management contract no. 68-01-0792
    is reproduced as received from the contractor.
         U.S.  ENVIRONMENTAL PROTECTION AGENCY
                         1975

                           \\

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This report as submitted by the grantee or contractor has not been
technically reviewed by the U.S. Environmental Protection Agency (EPA).
Publication does not signify that the contents necessarily reflect the
views and policies of EPA, nor does mention of commercial products
constitute endorsement or recommendation for use by the U.S. Government.

An environmental protection publication (SW-lOlc) in the solid waste
management series.
                                 t s

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      The taxes and tax benefits identified as discriminatory were all
 found to be applicable to virgin raw materials.   No taxes or tax bene-
 fits were identified as applicable to secondary materials but not to
 virgin materials.

      Exhibit I, following this page,  summarizes the major discrimina-
 tory taxes and tax benefits identified and evaluated during the  study.
 Each of the elements of taxation shown are governed by complex defini-
 tions and limitations which are discussed in some detail in Chapter II
 of this  report.  The applicability of the taxes and tax incentives to the
 commodities of interest in the study and to the raw materials  required
 to produce them is indicated on Exhibit II.  The  relative importance of
 individual tax elements as they relate to specific commodities and raw
 materials is discussed in following sections of th*s Summary.
 3.    EQUIVALENT PRIMARY AND SECONDARY RAW MATERIALS
      WERE IDENTIFIED
      Virgin raw materials and substitute secondary raw materials
consumed in the manufacture of the six commodities of interest were
identified.   Production processes related to both primary and secondary
raw materials use were identified for each commodity of interest and
relative raw material input and output ratios wero developed to provide
a basis for estimating the dollar impact of discriminatory tax treatment
on an equivalent product basis.  Specific attention was given to the im-
pact of technology on primary and secondary material substitutability.

      The equivalent primary and secondary products selected for evalua-
tion are shown on Exhibit III. As indicated in the Comments column of
the Exhibit, in most cases perfect substitutability does not exist.  Both
process and product characteristics operate to limit substitutability.
In plastics,  for example, substitutability of secondary materials is
virtually zero using currently available technology.  For the other  >
commodities, the substitutability of secondary materials varies quite
widely.  This subject is touched upon in more detail in following sec-
tions of this Summary.
4.    THE IMPACT OF DISCRIMINATORY TAXATION ON VIRGIN
      RAW MATERIALS COSTS WAS COMPUTED
      Data required to estimate the impact of discriminatory taxes and
tax benefits on virgin raw materials costs were identified along with
                                  ii

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                                                                                                                           EXHIBIT I

                                                                                                             SUMMARY OF MAJOR DISCRIMINATORY
                                                                                                                    TAXES AND TAX BENEFITS
Tax/Tax Benefit

The Percentage
Depletion Allowance
Foreign Tax Credit
Expensing of Mine
Exploration and
Development
Expenditures
   Effect on Income

Reduces Federal Income Taxes
payable
Reduces Federal Income
Taxes payable
Defers Federal Income
Taxes payable
Expensing of Intangible     Defers Federal Income
Drilling and Development  Taxes payable
Costs
Capital Gains Treat-
ment of Income from
Timber Sales
Minimum Tax on
Tax Preferences
State and Local
Resource Taxes
Reduces Federal Income
Taxes payable
Increases Federal Income
Taxes payable
Increases total taxes
payable
         Measure of Impact

The amount of the reduction in Federal Income
Tax payable if percentage depletion is elected
in preference to cost depletion

The amount of the reduction in Federal
Income tax payable if taxes paid to foreign
governments are treated as credits against
income taxes payable rather than deductions
to taxable income.

The present value of the amount of Federal
Income Tax payments deferred to future
years if subject expenditures are treated as
current year expenses  in preference to
capitalization and amortization over
several years.

The present value of the amount of Federal
Income Tax payments deferred to future
years if the subject expenditures are
treated as current year expenses in pref-
erence to capitalization and amortization
over several years.

The amount of the reduction in Federal Taxes
payable if income from sales of harvested
timber treated  as capital gains as opposeJ
to ordinary income

The amount of the limitation on the reduction
in Federal Income Taxes payable which can
be obtained by use of "tax preference" items
such as percentage depletion or capital gains

The amount of the resources taxes payable
                                                           ii-a
     Applicability

Applicable to U. S.  and foreign
mineral extraction by companies
taxable in the U. S.

Applicable to the foreign taxes
paid by corporations subject to
the U.  S.  Income Tax.
Applicable to mining operations
of companies taxable in the U. S.
Not applicable to petroleum
production.
                                                                                     Applicable to petroleum and
                                                                                     natural gas drilling operations
                                                                                     of companies subject to the U. S.
                                                                                     Income Tax
Applicable to timber '*r-/«»sting
operations in the U.  ';.
Applicable to taxable *r,tities
using "tax preference  items
Applicable in some taxations to
mining, drilling and •ur.
operations.

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                                                                                                                        EXHIBIT II

                                                                                                                INCIDENCE OF SIGNIFICANT
                                                                                                       DISCRIMINATORY TAXES AND TAX BENEFITS
                                                                                                           FOR THE COMMODITIES OF INTEREST
Tax/Tax Benefit

Percentage Depletion

Foreign Tax Credit

Expensing of Mine
Exploration and Develop-
ment Expenditures

Expensing of Intangible
Drilling and Development
Costs

I'apital Gains Treatment
of Income from Timber
Sales

Minimum Tax on Tax
Preferences

State and Local
Resources Taxes
Aluminum
Bauxite
X
X
Pulp & Paper
Timber
-
X

Sand
X
_
Glass
Lime-
stone
X
_

Feld
spar
X
_

Iron
Ore
X
X
Steel
Coal
X
X

Lime-
stone
X
_
Plastics &
Petroleum
X
X
Rubber
Natural
Gas
X
X
X
X
                X
X
X
X
X
                                                                 X
                                                                                       X
                             X
                                                                  il-b

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                                                                                                                             EXHIBIT III

                                                                                                               EQUIVALENT PRIMARY AND SECONDARY
                                                                                                               PRODUCTS SELECTED FOR EVALUATION
Commodity

Aluminum


Pulp and Paper
Glass
Steel
Plastics
Rubber
 Primary Product

Primary Aluminum
Ingot

Primary Newsprint
Primary Paperboard
Primary Bottle
Quality Glass
Raw steel
Thermoplastics —
Polyethelene. PVC.
Polystyre.-e

Thermosetting plastics

SBR (Synthetic Rubber)
    Equivalent
 Secondary Product

Secondary Aluminum
Ingot

Secondary Newsprint
Secondary Paperboard
Secondary Bottle
Quality Glass
Raw steel
None



None

Reclaimed Rubber
                              Comments

Substitutability exists primarily in ingot for making aluminum caw tings
Secondary newsprint may be freely substituted for primary newsj/rint
in end uses.

Secondary and primary paperboard while substitutable in many applica-
tions, often have differing appearance and  strength characteristic* which
affect market acceptance.

Production of most products using a mix of primary and secondary
materials is possible, subject to limitations on the proportion of
secondary materials.  Limits vary from product to product.

Secondary glass (cullet) may be freely substituted for virgin mat«r/,als
for up to 100% of product  content if cullet is of the same grade an-:
color as the glass to be produced.

In most cases,  raw steel  made from scrap is fully substitutable !•,'
raw steel made from  virgin materials.

There are process limitations on the proportion of scrap which :• % ,
be used in the manufacture of steel.

Thermoplastics are not recycled due to problems of separating &-•,•.
matching specific waste plastics for use in making like formula \a v.ucts
Thermosetting plastics cannot be recycled using existing techno!'.^-

The proportion of reclaimed rubber which can be used in tires
(the principal rubber product) is limited by product performance
specifications.
                                                              ii-c

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 potential data sources.  The primary published data sources used
 included producer financial statements, SEC filings, IRS publications
 ai-d records,  as well as special tax studies. Congressional hearing
 records,  and industry association records.  In general, the major
 shortcomings of published data from all sources proved to be lack
 of specificity and inadequate disaggregation.  To obtain data not
 publicly available,  major producers of the commodities of interest
 were contacted directly or through their trade associations and re-
 quested to provide  data with the stipulation that any information con-
 sidered to be proprietary would be treated so that the source would
 not be disclosed to any parties other than the Booz, Allen & Hamilton
 staff.

      The level of producer cooperation varied from company to com-
 pany and within industries.  The primary reasons advanced for limit-
 ing cooperation by those contacted were company policy regarding
 disclosure, the applicability of data to ongoing litigation, the cost
 of putting data in a usable form,  and misgivings concerning potential
 Government use of the data.

      Due to limitations inherent in the data base for the reasons  dis-
 cussed above, it was necessary to develop impact estimates in spite
 of data gaps.  Accordingly, a methodology was  used which, in the
 absence of contrary data, produced estimates of maximum impacts.
 Thus,  the impact estimates developed during the study are weighted
 against understating the effect of discriminatory taxes and tax bene-
 fits on virgin raw materials costs.   A detailed explanation of the
 estimating procedures used for each commodity studied is provided
 in the individual commodity chapters of this report (Chapters III -
 VII).

      Estimates were prepared for the years 1970 through 1972 for
 all virgin raw materials except petroleum and natural gas used in the
 production of rubber and plastics.  The 1970-1972 period reflects
the operation of current rules governing the tax elements evaluated.
 In the case of petroleum and natural gas, estimates for the years
 1969 through 1971  were prepared to make use of specific data ele-
ments  available for those years which were not available for 1972
at the time the study was conducted.

      Exhibit IV,  following this page, shows the estimated impacts
of discriminatory taxes and tax benefits on the unit cost of producing
primary aluminum, newsprint, paperboard,  glass,  steel and petrol-
 eum and natural gas.  The  estimates shown are for  1972 with the
 exception of petroleum and natural gas for which 1971 estimates are
provided.   Unlike the other commodities indicated, petroleum and
                                  iii

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                                                                                                           MAXIMUM ESTIMATED IMPACT OF
                                                                                                      DISCRIMINATORY TAXES AND TAX BENEFITS
                                                                                                   ON THE COST OF SELECTED COMMODITIES - 1972
      Tax Element

 Percentage Depletion

 Foreign Tax Treatment

 Expensing of Mine
 Exploration & Development
 Expenditures

 Expensing of Intangible
 Drilling & Development
 Costs

 Capital Gains Treatment
 of Income From Timber
 Sales

 Minimum Tax on
 Preferences

 State and Local
 Resources Taxes

 Total (After Tax)
  % of Price
 Total (Before Tax)
  % of Price
Aluminum
 (S Per
 Ingot Ton)

 S 1.35

   1.51
   1.02
                                                        Pulp & Paper
 Newsprint
($ Per Ton)

  $ -
Paperboard
($ Per Ton)
                    1.14
                   2.48
   Glass

($ Per Ton)

  $0.20
   Steel
(5 Per Ton of
 Raw Steel)

  $0.90

    0.27
                                                   0.27
 Petroleum
($ per BBL)
 For 1971
                                                    $0.25

                                                     0.13
                                                                                     0.01
Natural Gas
($ per MCF)
 For 1971
                 $0.015
                                                                                    0.002
(0. 08)
$3.80
0.7
$7.92
1.5
-
$1.14
0.7
$2.28
1.4
-
$2.48
1.4 - 2.2
$4.96
2.8 - 4. 3
-
$0.20**
1.4
$0.40
2.7
(0. 19)
$1.25
1.7?
$2.60
3.5*
(0. 04)
(0. 06)
$0.29
9.8
$0.60
20.2
(0.002)
(0. 007)
$0. 008
4.4
$0.017
9.3
 *  Percent of estimated average cost of producing raw steel @ $75. 00 (ton)

**  Includes estimated percentage depletion for limestone, soda ash (a limestone derivative) and feldspar


Note:  Impacts are shown as tax savings associated with tax benefits (after tax basis).  Before tax impacts represent the amount
      that prices would have to be increased to fully affect the effects of the removal of tax benefits.
                                                                 iii-a

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 natural gas are raw materials used in making plastics and rubber. As
 is explained in Chapter VII. the procedures for estimating the tax
 element impacts on the cost of producing plastics and rubber differed
 somewhat from those used for estimating impacts for other commodities.
 Accordingly, a detailed impact estimate for each tax element was not
 prepared for plastics and rubber.   Estimated total impacts of discrim-
 inatory taxes and tax benefits on the cost producing selected plastic
 products and rubber for 1971 are summarized on Exhibit V. following_
 this page.

      Estimates for specific tax elements as they relate 10 specific
 commodities were not prepared in those cases where:
                 The tax element would not be applicable
                 (e.g.,  percentage depletion does not apply
                 to timber operations)

                 The tax element would not produce a significant
                 impact
      Because of the data limitations discussed above, the figures
shown on Exhibits IV and V represent order of magnitude estimates.
They are, however, sufficiently accurate to permit a general assess-
ment of their significance in terms of relative virgin versus secondary
raw materials usage.
5.    DISCRIMINATORY TAXES AND TAX BENEFITS ARE
      LIKELY TO HAVE SOME MARGINAL IMPACT ON
      RELATIVE RAW MATERIALS USE IN PRODUCING
      THE COMMODITIES OF INTEREST
      It can be stated conceptually that any measures to provide tax
treatment equalization to virgin and secondary materials would cause
the relative cost of using secondary materials to decrease at all levels
of use.  Accordingly, tax treatment equalization should produce some
increase in relative secondary materials use.

      The degree to which secondary materials use will increase will
depend upon the amount of the change in relative cost as it relates to
                                iv

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                                              EXHIBIT V

                               .ESTIMATED IMPACT OF DISCRIMINATORY
                                TAXES AND TAX BENEFITS ON THE COST
                                  OF PRODUCING SELECTED PLASTIC
                                    AND RUBBER PRODUCTS - 1971
                                            ($ PER POUND)
                           LOW
                                            HIGH
Products
After Tax
$ Price
Before Tax
%of
$ Price
After Tax
% of
$ Price
Before Tax
%of
$ Price
High Density
Polyethelene

Low Density
Polyethelene

Polyvinyl
Chloride

Polystyrene
0.0004  0.27    0.0008  0.54   0.0007  0.52    0.0014   1.04
0.0002  0.16    0.0004  0.32   0.0006  0.47    0.0012  0.54
 N/A   N/A

0.0004  0.25
 N/A   N/A   0.0003  0.^3

0.0008  0.50   0.0009  0.72
0.0006  0.46

0.0018  1.42
SBR (Synthetic
 Rubber)       0.0007  0.2     0.0014  0.4    0.0017  0.7     0.0034  1.4
 Note:  Impacts are shown as tax savings associated with tax benefits (after tax
       basis).  Before tax impacts represent the amount that prices would have
       to be increased to fully offset the effects of the removal of tax benefits.
                             iv-a

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the marginal cost of accessing and using additional secondary materials.
Estimating the marginal cost of secondary materials is beyond the scope
of this study; however,  the following points can be made:
                 The price behavior of the secondary materials used
                 to produce the commodities of interest (except
                 plastics where secondary materials are not used)
                 suggests that the marginal costs of bringing addi-
                 tional supplies into the market place are high in the
                 short run.

                 The long run marginal costs of the  secondary
                 materials of interest are not known; however, it
                 appears likely that a not insignificant cost com-
                 ponent relates to the market risk inherent in
                 developing secondary materials supplies which
                 is in turn a function of price volitility,  A potential
                 means of dealing with such costs is through the
                 development of municipal reclamation centers
                 which could  absorb market price fluctuations.
                 This could prove feasible particularly in areas
                 where such a scheme would provide cost advan-
                 tages over other means of waste disposal.

                 That the long run marginal cost of obtaining addi-
                 tional secondary materials may be  relatively high
                 is suggested by the fact that for all of the commod-
                 ities studied, significant increments to the market
                 supply of secondary materials must be developed
                 from the post consumer waste stream which is the
                 highest cost source of secondary materials  due to
                 the mixed character of the waste and the attendant
                 separation problems and the relatively dispersed
                 nature of the sources which imposes higher trans-
                 portation costs.  As above, the use of municipal
                 reclamation centers may provide a means of
                 adjusting costs,  if the costs of alternative dis-
                 posal techniques are built into the equation.  At
                 the present time, such cost offsets are not re-
                 flected in the marketplace.

                 In the short  run, limits to the US3 of secondary
                 materials are imposed by the characteristics
                 of manufacturing technology in use.  In the long
                 run,  technological change and the development
                 of new manufacturing capacity capable of using

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                 secondary materials could significantly reduce
                 these barriers.

                 In general, the use of secondary materials requires
                 less energy than does the use of primary materials.
                 The manufacturing capacity to produce equivalent
                 output also requires less  capital investment in
                 many cases,  particularly for aluminum, pulp and
                 paper, and steel.  In view of the current energy
                 shortage and the capital squeeze faced by producers,
                 these factors should operate in favor of increased
                 secondary materials use over the long term.
      In view of the uncertainties outlined above, no conclusive state-
ments can be made regarding the impact of discriminatory taxation
on relative raw materials use.   Given the magnitude of the impacts
indicated on Exhibits IV and V and the indications that the marginal
cost of increased secondary materials use may be relatively high,
the best that can be said is that tax treatment equalization alone
may cause some marginal increase in secondary materials utiliza-
tion.  It should be kept in mind,  however, that there are additional
forces in operation which may beneficially influence secondary
materials usage.

      Specific commodity impacts are discussed below:
      (1)   Tax Treatment Equalization May Have Some
           Marginal Impact on Relative Use of Aluminum
           Scrat
           The substitutability of secondary aluminum for primary
      aluminum is limited by the following:
                 Primary and secondary ingot manufacturing
                 processes are not compatible thus increased
                 scrap usage will require secondary aluminum
                 capacity expansion.

                 Secondary ingot competes  with primary ingot at
                 present only in casting applications. Were
                 secondary ingot to capture a 100% share of the
                                VI

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            casting market output could be increased up to
            12. 5%.  Additional secondary ingot substitution
            would require advances in technology and changes
            in the alloy content of secondary ingot.
      At the present time, soaring foreign aluminum prices
 have caused strong aluminum scrap export demand which has
 caused scrap prices to increase to a point where domestic
 producers are faced with a scrap shortage.  They cannot
 outbid foreign producers for available supplies in the face
 of controlled product prices.  Thus,  while scrap market
 supplies may be increasing due to large price increases,
 domestic producers are faced with decreasing supplies.
 This situation should correct itself upon price decontrol;
 however, there is unlikely to be any secondary capacity
 expansion as long as the situation persists.

      The energy crisis and the capacity squeeze faced by
 aluminum producers tend to auger well for secondary pro-
 duction increases  over the long term as secondary produc-
 tion requires less than 10% of the energy and about 10% of
 the capital required for equivalent primary output.

      As with other commodities,  the marginal cost of alumi-
 num scrap is not known; however, given the fact that readily
 accessable supplies are in use and the limitations on substi-
 tution discussed above, it appears that  tax treatment equali-
 zation would have  at best a marginal impact on secondary
 output.  In the long run, the factors discussed above may
 lead to increased secondary output, although the degree to
 which such output  is likely to increase cannot be estimated
 at this time.
(2)    The Ultimate Impact Tax Treatment Equalization
      on Waste Paper Usage Is Indeterminate
      Potential for increased use of waste paper in paper
manufacturing does exist with the degree  of substitution
feasible varying by product.  Indeed,  there is evidence that
some mills are increasing the proportion of waste paper in
their products due to a shortage of virgin fibers related to
difficulties and costs of obtaining labor for lumbering opera-
tions.  The ultimate degree of substitution will, of course.
                           vn

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 depend on the marginal cost of wastepaper and the technological
 limits to substitution for specific products.

      The above notwithstanding,  history indicates that waste -
 paper market supplies are relatively insensitive to price in the
 short term indicating that an adjustment of relative wastepaper
 and virgin fibre costs of the order indicated on Exhibit IV would
 produce only marginal short term increases in secondary fibre
 usage.

      In the long run,  the impact  of tax treatment equalization is
 indeterminate as the long run marginal cost of secondary fibre
 is not known. As with other waste materials, however, addi-
 tional market supplies would have to be drawn from the post
 consumer waste stream which leads  to the conclusions that such
 costs may be relatively high.  Nevertheless, the American Paper
 Institute has extimated that use of old corrugated boxes, from
 commercial sources, may increase by as rruch as 34% over the
 next three years.
(3)   Tax Treatment Equalization Is Likely to Have Only
      a Marginal Impact on the Relative Use of Scrap Glass
      At the present time, industrial source cullet (scrap glass)
is fully utilized.  While cullet recovery from post consumer
waste is in limited practice, the economics of collection separa-
tion and transportation are unfavorable.   While precise quanti-
tative data are not available, it appears unlikely that an adjust-
ment in materials costs up to a maximum of $0. 40 per ton
(See Exhibit IV) would be  sufficient to offset such costs.

      Were municipalities to absorb collection and separation
costs in reclamation centers, the economics of recycling
could potentially be improved.
(4)    Tax Treatment Equalization May Cause Some
      Marginal Increase in Steel Scrap Usage
      At the present time,  about 18% of steel output is
accounted for by electric furnaces consuming scrap. Any
change in  relative materials costs in favor of scrap would
                         van

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tend to make electric furnace production more attractive.
Some limited increase in scrap utilization in other steel-
making processes may also be expected,  subject to techno-
logical limitations on substitution.

      The major barrier to the development of additional
electric furnace capacity is the potential shortage of electrical
power in both the long and the short term.

      During 1973,  a scrap shortage developed as export
buyers outbid domestic purchasers for available supplies.
This situation developed as foreign steel prices increased
at a much faster rate than domestic prices which are sub-
ject to price controls. With a return to a  free market, this
situation should correct itself.  While the  domestic-foreign
price imbalance exists, however, scrap for domestic pro-
ducers should remain in short supply, subject, of course,
to the extension of scrap export limitations. Accordingly,
in the short run tax treatment equalization should have
little,  if any. usage impact.

      In the long run, the degree to  which  scrap utilization
increases will depend on the  marginal cost of bringing addi-
tional quantities of scrap into the market place.  Such costs
will undoubtedly include some discounting  of market risk.
Definitive statements as  to the effectiveness of tax treat-
ment equalization are not possible as neither the short nor
the long run marginal costs of additional scrap are known.
As indicated in preceding sections, however,  the establish-
ment of mechanisms such as municipal reclamation centers,
if they prove feasible, can provide a means of accommodat-
ing market risk.

      It should be pointed out, however, that readily  access-
able sources of steel  scrap are currently in use thus addi-
tional market supplies will have to be drawn from higher cost
sources.
(5)    Tax Treatment Equalization is Unlikely to Influence
      the Relative Use of Secondary Materials in the
      Manufacture of Plastics and Rubber
      Thermosetting plastics cannot be remelted and reused
in any currently available process, thus tax treatment equali-
zation should have no impact.

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      Thermoplastics would require sorting by grade for reuse
in making plastics.  Given that there are many grades and types
of thermoplastics, the cost of sorting and grading from a mixed
waste stream would be prohibitive.  A change in relative mater-
ials costs of the order indicated on Exhibit V should not be suf-
ficient to offset the other costs of recycling.

      The use of reclaimed rubber,  principally from tires has
been declining for two reasons:
                 Product (tire) performance specifications
                 which limit the proportion a reclaimed
                 rubber which can be used

                 Increased costs of reclaiming rubber from
                 old tires caused by increased use non-
                 rubber tire components (e. g.,  steel and nylon
                 belts)
      Given changes in relative materials costs through tax
treatment equalization of the order indicated on Exhibit V,
it is unlikely that tax equalization alone would be sufficient
to cause producers to consider any significant increases in
their use of reclaimed rubber.

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               TABLE   OF   CONTENTS
                                                          Page
                                                        Number
       LETTER OF TRANSMITTAL


       EXECUTIVE SUMMARY                                i


  I.    INTRODUCTION                                       1


 II.    TAXES AND TAX INCENTIVES                          7


III.    THE ALUMINUM INDUSTRY                           22


IV.    THE PULP AND PAPER INDUSTRY                     36


 V.    THE GLASS INDUSTRY                                48


VI.    THE STEEL INDUSTRY                               53


VII.    THE RUBBER AND PLASTICS INDUSTRIES               68



                       APPENDIXES
                            xi

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               INDEX   OF  EXHIBITS
                                                  Following
                                                    Page
   I.    SUMMARY OF MAJOR DISCRIMINATORY
        TAXES AND TAX BENEFITS                      2

  II.    INCIDENCE OF SIGNIFICANT
        DISCRIMINATORY TAXES AND TAX
        BENEFITS FOR THE COMMODITIES                2
        OF INTEREST

 III.    EQUIVALENT PRIMARY AND SECONDARY
        PRODUCTS SELECTED FOR EVALUATION          2

 .IV.    MAXIMUM ESTIMATED IMPACT OF
        DISCRIMINATORY TAXES AND TAX
        BENEFITS ON THE COST OF SELECTED
        COMMODITIES -  1972                            5

  V.    ESTIMATED IMPACT OF DISCRIMINATORY
        TAXES AND TAX BENEFITS ON THE COST
        OF PRODUCING SELECTED PLASTIC AND
        RUBBER PRODUCTS - 1971 ($ PER POUND)         5

 VI.    PERCENTAGE DEPLETION RULES                8

 VII.    REGULATIONS PERTAINING TO FOREIGN
        TAX CREDITS                                 12

VIII.    SUMMARY OF FOREIGN TAXES OF
        COUNTRIES THAT HOST IMPORTANT
        EXTRACTIVE INDUSTRIES                       14

 IX.    RELATIVE TAX ADVANTAGES OF USE
        OF WESTERN HEMISPHERE  TRADE
        CORPORATION                                 15

  X.    STATE AND LOCAL TAX LAWS
        APPLICABLE TO CERTAIN RAW
        MATERIALS                                   17
                             xii

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  XI.    STATE TAX LAWS APPLICABLE TO
         TIMBER OPERATIONS

  XII.    IMPACT OF SELECTED TAXES AND TAX
         BENEFITS ON THE COST OF PRODUCING
         PRIMARY ALUMINUM INGOT  1970 - 1972

 XIII.    IMPACT OF SELECTED TAXES AND
         TAX BENEFITS ON THE COST OF
         PRODUCING PULP AND PAPER 1970-1972

 XIV.    WOOD PULP AND WASTEPAPER
         CONSUMPTION AND PRICE INDICES
         1964 - 1972

  XV.    YEARLY PRICE CHANGES FOR NO.  1
         WASTE NEWSPRINT 1968 - 1973

 XVI.    YEARLY PRICE CHANGES FOR WASTE
         PAPER 1968 - 1973

 XVII.    IMPACT OF THE  PERCENTAGE
         DEPLETION ALLOWANCE ON THE COST
         OF PRODUCING SAND AND GLASS 1970-1972

XVIII.    IMPACT OF SELECTED TAXES AND TAX
         INCENTIVES ON COST OF RAW INTEGRATED
         IRON ORE PRODUCTION 1970-1972

 XIX.    IMPACT OF SELECTED TAX BENEFITS ON
         THE COST OF INTEGRATED METALLURGICAL
         COAL PRODUCTS 1970-1972

  XX.    IMPACT OF SELECTED TAXES AND TAX
         BENEFITS ON THE  COST OF INTEGRATED
         RAW STEEL PRODUCTION 1970-1972

 XXI.    THERMOSETTING PLASTICS

 XXII.    THERMOPLASTICS

XXIII.    SIMPLIFIED FLOWCHART FOR SBR
         (SYNTHETIC RUBBER)
                                                       Following
                                                         Page
17



29



41



45


46


46



51



61



62



62

69

69


73
                          xlii

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                                                      Following
                                                        Page
 XXIV.    SIMPLIFIED FLOWCHART FOR
         SELECTED PLASTIC RESINS                       73

 XXV.    IMPACT OF SELECTED TAXES AND TAX
         BENEFITS ON THE COST OF PRODUCING
         CRUDE OIL AND NATURAL GAS                    76

 XXVI.    IMPACT OF SELECTED TAXES AND TAX
         BENEFITS ON THE COST OF PRODUCING
         SBR RUBBER - 1971                               76

XXVII.    IMPACT OF SELECTED TAXES AND TAX
         BENEFITS ON THE COST OF PRODUCING
         SELECTED PLASTICS RESINS - 1971                 77
         APPENDIXES
                          xiv

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                  I.  INTRODUCTION
      The Resource Recovery Division of the EPA, Office of
 Solid Waste Management is responsible for evaluating alternative
 means of encouraging secondary materials recovery and reuse.
 In connection with this responsibility,  the Resource Recovery Div-
 ision is examining the influence of discriminatory taxation on the
 relative use of virgin and secondary raw materials in the manu-
 facturing process.  The purpose of this study has been to quantify
the tax impact and to assess the influence of discriminatory taxa-
tion on the relative use of virgin and secondary raw materials in
the manufacture of the following products:
                 Aluminum
                 Pulp and Paper
                 Glass
                 Steel
                 Plastics
                 Rubber

 1.    THE PRIMARY STUDY OBJECTIVE HAS BEEN TO IDENTIFY
      DISCRIMINATORY TAX TREATMENT AND ESTIMATE ITS
      IMPACT ON RAW MATERIALS COSTS
      The primary objective of the study has been to identify taxes
 and tax benefits applicable on a discriminatory basis to virgin or
 secondary materials use and to estimate their impacts on raw mater-
 ials costs.  A secondary study objective has been, on a qualitative
 basis, to assess the degree to which discriminatory taxation may be
 expected to influence the relative use of virgin and secondary raw
 materials in the manufacture of the six products identified above.

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      The major tasks completed in conducting the study were as
follows:
                 Identification of discriminatory elements of tax-
                 ation.

                 The identification and matching of virgin raw
                 materials and their equivalent secondary mat-
                 erials substitutes; and the establishment of
                 equivalent material input and output ratios.

                 Identification of tax data needs and accessible
                 data sources.

                 Tax data collection and evaluation.

                 Computation of tax impacts on relative materials
                 costs.

                 Assessment of the significance of tax related
                 material cost differentials in terms of relative
                 virgin  and secondary raw materials use.
2.    DISCRIMINATORY TAXES AND TAX BENEFITS WERE IDENT-
      EFIED
      Discriminatory taxes and tax benefits were identified through ex-
tensive research of Federal, state,  and Local tax regulations and a
comprehensive review of related tax literature including specialized
tax journals.  The applicability of discriminatory tax elements which
is summarized on Exhibit I and II, following this page, and the rules
governing their application are discussed in detail in Chapter I! of
this report.

3.    EQUIVALENT PRIMARY AND SECONDARY MATERIALS WERE
      IDENTIFIED
      Virgin raw materials and substitute secondary raw materials
consumed in the manufacture of the six products were identified.  They
are summarized on Exhibit III,  following Exhibit II.  Production proc-
esses related to both secondary and primary raw materials use were
analyzed for each product of interest and relative raw materials

                              -2-

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                                                                                                                           EXHIBIT I

                                                                                                            SUMMARY OF MAJOR DISCRIMINATORY
                                                                                                                   TAXES AND TAX BENEFITS
Tax/Tax Benefit

The Percentage
Depletion Allowance
Foreign Tax Credit
Expensing of Mine
Exploration and
Development
Expenditures
   Effect on Income

Reduces Federal Income Taxes
payable
Reduces Federal Income
Taxes payable
Defers Federal Income
Taxes payable
Expensing of Intangible     Defers Federal Income
Drilling and Development   Taxes payable
Costs
Capital Gains Treat-
ment of Income from
Timber Sales
Minimum Tax on
Tax Preferences
State and Local
Resource Taxes
Reduces Federal Income
Taxes payable
Increases Federal Inco>-t<
Taxes payable
Increases total taxes
payable
         Measure of Impact

The amount of the reduction in Federal Income
Tax payable if percentage depletion is elected
in preference to cost depletion

The amount of the reduction in Federal
Income tax payable if taxes paid to foreign
governments are treated as  credits against
income taxes payable rather than deductions
to taxable income.

The present value of the amount of Federal
Income Tax payments deferred to future
years if subject expenditures are treated as
current year expenses  in preference to
capitalization and amortization over
several years.

The present value of the amount of Federal
Income Tax payments deferred to future
years if the subject expenditures are
treated as current year expenses in pref-
erence to capitalization and  amortization
over several years.

The amount of the reduction in Federal Taxes
payable if income from sales of harvested
timber treated  as capital gains as opposed
to ordinary income

The amount of the limitation on the  reduction
in Federal Income Taxes payable which can
be obtained by use of "tax preference" items
such as percentage depletion or capital gains

The amount of the resources taxes payable
     Applicability

Applicable to U. S.  and foreign
mineral extraction by companies
taxable in the U. S.

Applicable to the foreign taxes
paid by corporations subject to
the U.  S.  Income Tax.
Applicable to mining operations
of companies taxable in the U. S.
Not applicable to petroleum
production.
                                                                                    Applicable to petroleum and
                                                                                    natural gas drilling operations
                                                                                    of companies subject to the U. S.
                                                                                    Income Tax
Applicable to timber harvesting
operations in the U.  S.
Applicable to taxable entities
using "tax preference" items
Applicable in some locations to
mining, drilling and timber
operations.
                                                             2-a

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                                                                                                                       EXHIBIT II

                                                                                                                INCIDENCE OF SIGNIFICANT
                                                                                                       DISCRIMINATORY TAXES AND TAX BENEFITS
                                                                                                          FOR THE COMMODITIES OF INTEREST
                               Aluminum
Tax/Tax Benefit

Percentage Depletion

Foreign Tax Credit

Expensing of Mine
Exploration and Develop-
ment Expenditures

Expensing of Intangible
Drilling and Development
Costs

Capital Gains Treatment
of Inconne from Timber
Sales

Minjmum Tax on Tax
Preferences

State and Locai
Resources Taxes
X
X
           Pulp & Paper

             Timber



                X
                  Glass
                                    Steel
X
           Sand
            X
                            X
X
        LJme-
        stone
Feld
spar
  X
                               X
Iron
Ore

 X

 X
 X
                            X
Coal

 X

 X
 X
                   X
                                                          X
                                                                          X
X
                   X
           Plastics & Rubber
                       Natural
                         Gas
                                                      Petroleum

                                                          X

                                                          X
                                                                                      X
X
                                                      X

                                                      X
X
                                                                     2-b

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                                                                                                                           EXHIBIT III

                                                                                                              EQUIVALENT PRIMARY AND SECONDARY
                                                                                                              PRODUCTS SELECTED FOR EVALUATION
Commodity

Aluminum


Pulp and Paper
Glass
Steel
Plastics
Rubber
  Primary Product

Primary Aluminum
Ingot

Primary Newsprint
Primary Paperboard
Primary Bottle
Quality Ola.--&
Raw steel
Thermoplastic?--
Polyethelene.  PVC.
Polystyrene

Thermosettmg plastics

SBR (Synthetic Rubber)
   Equivalent
 Secondary Product

Secondary Aluminum
Ingot

Secondary Newsprint
Secondary Paperboard
Secondary Bottle
Quality Glass
Raw steel
None



None

Reclaimed Rubber
                              Comments

Substitutability exists primarily in ingot for making aluminum castings
Secondary newsprint may be freely substituted for primary newsprint
iii end uses.

Secondary and primary paperboard while substitutable in many applica-
tions, often have differing appearance and strength characteristics which
affect market acceptance.

Production of most products using a mix of primary and secondary
materials is possible, subject to limitations on the proportion of
secondary materials. Limits vary from product to product.

Secondary glass (cullet) may be freely substituted for virgin materials
for up to 100% of product content if cullet is of the same grade and
color as the glass  to be  produced.

In most cases,  raw steel made from scrap is fully substitutable for
raw steel made from virgin materials.

There are process limitations on the proportion of scrap which may
be used in the manufacture of steel.

Thermoplastics are not recycled due to problems of separating and
mniching specific  waste plastics for use in making like formula products
Thermosettmg plastics cannot be recycled using existing technology

The proportion of reclaimed rubber which can be used in tires
'the principal rubber product) is limited by product performance
specifications.
                                                                  2-c

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input and output ratios were developed to provide a basis for estimating
the dollar impacts of discriminatory tax treatment on equivalent pro-
duct costs.

     In conducting this analysis specific attention was given to ident-
ifying and assessing technological and economic barriers to the sub-
stitution of secondary raw materials for virgin raw materials.
4.    TAX DATA REQUIREMENTS AND SOURCES WERE IDENTIFIED
      AND DATA WAS COLLECTED
      The data required to compute the impact of identified discrim-
inatory taxes and tax benefits were identified along with potential
data sources.  Initial efforts were directed at identifying and acquiring
of publically available  data including:
                 Producer financial statements

                 SEC filings

                 Internal Revenue Service publications and records

                 Records  of court cases

                 Other sources, including Congressional hearing
                 records, tax studies, industry tax publications,
                 and publications of various government agencies
      Useful data were obtained from producer financial statements and
SEC filings, particularly for 1972 as a result of more complete inform-
ation disclosure than in prior years.  IRS data proved to be of limited
value due to age (up to ten years out of date) and levels of aggregation.
Such data proved to be useful when  it was up to date and related to in-
dustries when integration and diversification are limited.  Court cases
provided little useful data as available decisions were in settlement of
litigation regarding tax returns filed up to fifteen years in the past.
                               -3-

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Data from various other sources was found to be useful, although
the adequacy of data from all public sources was limited by lack
of specificity and inadequate disaggregation.

      To obtain required data which were not publicly available major
producers of the  products covered by the study were contacted directly
or through their trade associations and requested to provide data.
The following rules governing the handling of company data were
stressed:
                 Company data would be treated in confidence

                      Access would be restricted to Booz,
                      Allen & Hamilton, Inc. staff

                      Data would be used only for this study

                      Data would be presented in the final re-
                      port so as not to be attributable to a
                      specific producer.

                 The names of companies contacted and providing
                 data would not be disclosed.
      The level of producer cooperation obtained varied from company-
to-company and from industry-to-industry.  Data for two industries
was provided in aggregated form through the industry trade associations.
Data of this type proved to be highly useful.  In other cases, data of
varying degrees of usability was provided.  The results of producer
contacts have produced the following conclusions:
                 Producers are extremely reluctant to release any
                 unpublished data related to tax matters.

                      Release normally requires the consent of
                      the board of directors or the chief exec-
                      utive officer.

                      Obtaining consent is time consuming and re-
                      quires repeated personal contacts at the
                      senior executive level.

-------
                 Delivery of specific tax data requires a sig-
                 nificant producer clerical effort which must
                 be delivered on a spare time basis.
      Those producers which declined to provide data most frequently
 expressed the following reasons:
                 Company policy regarding the release of propri-
                 etary data

                 The pertinence of data to ongoing tax litigation

                 Lack of staff available to gather and summarize
                 the data

                 The high cost of gathering and summarizing the
                 data

                 Misgivings regarding Government use of the data
      The data obtained from producers and from published
sources, however, were sufficient to permit the development of
reasonably accurate tax impact estimates.
5.    THE IMPACT OF DISCRIMINATORY TAXATION ON
      RELATIVE MATERIALS COSTS WAS COMPUTED
      The impact of discriminatory taxation on relative materials
costs was computed using best available data.  Where specific tax
data were limited, a synthesis approach was used which was
weighted against understating possible tax impacts.  The methods
used to compute tax impacts for each product of interest are ex-
plained in detail in Chapters III-VII of this report.  Impacts are
summarized on Exhibits IV and V. following this page.
6.    THE SIGNIFICANCE OF COST DIFFERENTIALS RELATED
      TO DISCRIMINATORY TAXATION WAS ASSESSED IN
      TERMS OF RAW MATERIALS CHOICES


      The significance of raw material cost differentials related to
discriminatory taxation was assessad for each product of interest
                             •5-

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                                                                                                            MAXIMUM ESTIMATED IMPAC1 O!"
                                                                                                       DISCRIMINATORY TAXES AND TAX BENEFITS
                                                                                                    "JN THE COST OF SELECTED COMMODITIES - 1972
       Tax Element

 Percentage Depletion

 Foreign Tax Treatment

 Expensing of Mine
 Exploration & Development
 Expenditures

 Expensing of Intangible
 Drilling & Development
 Costs

 Capital Gains Treatment
 of Incomt Prom Timber
 Sales

 Minimum Tax on
 Preferences

 State and Local
 Resources Taxes

 Total (After Tax)
  % of Price
 Total (Before Tax)
  % of Price
Aluminum
(S Per
Ingot Ton)
S 1.35
1.51
1.0?
-
-
-
(0. 08)
33.30
0.7
S7.92
1.5
Pulp i Paper Glass Steel
Newsprint Paperboard (S Per Ton of
(S Per Ton) ($ Per Ton) (S Per Ton) Raw Steel)
S - S - $0.20 $0.90
0.27
0.27
-
1.14 2.48
-
(0.19)
SI. 14 $2.48 $0.20— $1.25
0.7 1.4 - 2. 2 1.4 1.7*
$2.28 $4.96 $0.40 $2.60
1.4 2.8-4.3 2.7 3.5*
Petroleum
($ per BBL)
For 1971
$0.25
0. 13
-
0.01
-
(0. 04)
(0. 06)
$0.29
9.8
$0.60
20.2
Natural Gas
($ per MCF)
For 1971
$0.015
-
-
0.002
-
(0.002)
(0.007)
$0.008
4.4
$0.017
9.3
 *  Percent of estimated average cost of producing raw steel @ $7b. CO (ton)

**  Includes estimated percentage depletion for hmesione,  sorla ash (a limestone derivative) and feldspar


Note:  Impacts are shown as tax savings associated with tax benefits (after tax basis).  Before tax impacts represent the amount
      that prices would nave to be increased to fully affect the effects  of the removal of tax benefits.
                                                                         5-a

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                                              EXHIBIT V

                                ESTIMATED IMPACT OF DISCRIMINATORY
                                TAXES AND TAX BENEFITS ON THE COST
                                  OF PRODUCING SELECTED PLASTIC
                                     AND RUBBER PRODUCTS  - 1971
                                            ($ PER POUND)
                           LOW
                                            HIGH
Products
After Tax
%of
$ Price
Before Tax
%of
$ Price
After Tax
% of
$ Price
Before Tax
%of
$ Price
High Density
Polyethelene

Low Density
Polyethelene

Polyvinyl
Chloride

Polystyrene
0.0004'  0.27


0.0002  0.16


 N/A   N/A

0.0004  0.25
0.0008  0.54   0.0007  0.52    0.0014  1.04
0.0004  0.32   0.0006  0.47    0.0012  0.54
 N/A   N/A   0.0003  0.23

0.0008  0.50   0.0009  0.72
0.0006  0.46

0.0018  1.42
SBR (Synthetic
 Rubber)       0.0007  0.2     0.0014  0.4    0.0017  0.7     0.0034   1.4
 Note:  Impacts are shown as tax savings associated with tax benefits (after tax
       basis).  Before tax impacts represent the amount that prices would have
       to be increased to fully offset the effects of the removal of tax benefits.
                               5-b

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in terms of their possible influence on raw materials choices.  The
following specific factors were considered in each case:
                 Cost differentials
                 The market availability of'secondary materials
                 Technological aspects of secondary materials use
      The following chapter discusses taxes and tax incentives found
to be discriminatory.
                           -6-

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             II.    TAXES AND TAX INCENTIVES
      There are no unique taxes or tax incentives applicable to
the users of secondary raw materials which are not also applicable
to users of virgin raw materials.  Taxes and tax incentives appli-
cable only to producers and users of primary raw materials are
identified and discussed in the balance of this chapter.  The follow-
ing topics are included:
            Depletion

            Minimum Tax on Tax Preferences

            U. S. Tax treatment of taxes paid to foreign
            governments

            State and local taxes

            Tax treatment  of mine exploration   intangible
            drilling and development costs

            Tax treatment  of capital gains
      A discussion of the relationships among certain tax incen-
tives is provided in the last section of the chanter.
1.    DEPLETION
      Depletion isthe exhaustion of mineral resources as a result of
extraction.  A deduction is allowed on tax returns in order to com-
pensate mineral producers for capital consumed  in the process of
extraction.  The depletion tax deduction may be computed on the basis
of cost (cost depletion} or on the basis of a percentage (percentage
depletion) of the gross income from mining,  whichever results in
the greater tax deduction.
                            .7-

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                                                                                                                               EXHIBIT VI

                                                                                                                     PERCENTAGE DEPLETION RULES
Mineral
Iron Ore
Percent
U.S.
Foreign
15%
14%
Mining Process*
Extraction from the Ground
Transportation to the plant or mills for other mining processing
Sorting ) When applied for purpose of
Concentrating) bringing to shipping grade
Sintering ) and form
Loading for shipment

if within 50 miles
Coal
Bauxite
Anorthosite
Clay
Latente
                        U. S.      10%           .     Extraction from the ground
                                                     Transportation to the plant or rmlls for other mining processing if within 50 miles
                                                     Cleaning
                                                     Breaking
                                                     Sizing
                                                     Dust Allaying
                                                     Treating to prevent freezing
                                                     Loading for shipment
U.S.
Foreign
22%
14%
For Ores Customarily Sold in the Form o* a Crude Mineral Product:
      Extraction from  the ground
      Transportation to the plant or mills for other mining processing if within 50 miles
      Sorting       )           When applied for purpose of
      Concentrating)            bringing to shipping grade
      Sintering     )            and form
      LOP ding for shipment
For Ores Not Customarily Sold in the Form of a Crude Mineral Product:
      Extraction
      Transportation to the pLint or mills for other mining process if within 50 miles
      Crushing
      Grinding
      Beneficiating
      Cyamdation
      Leaching
      Crystalizatioii
      Precipitation (excluding electrolytic deposition,  roasting, thermal or electric
       smelting or refining)
      Equipment processes
Limestone
Quartzsand
Quart zite
Nepheline Syenite
Feldspar
Lithium (Foreign)
U.S.
14%
      Extraction
      Transportation to the plant or mills for other mining process if within 50 miles
      Crushing and grinding (not fine  pulverization)
      Size classification
      Drying to remove free water (not to change physical or chemical identity or composition
      Washing or cleaning (not to activate or change the physical or chemical structure)
Natural Gas
and oil
U. S. &
Foreign
                                  22%
                    Extraction at the well before conversion or transportation
   Processes included for purposes of computing gross income
                                          7-a.

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      The basis for cost depletion is the total value of a mineral
deposit,  with value defined as the cost to the producer of the mineral
deposit,  (land, mineral rights, cost of developing the deposit,  etc.)
divided by the total estimated recoverable mineral units (e. g., tons
of coal) in the deposit.  The quotient provides the unit basis for cost
depletion.  Cost depletion for a given period is computed by multi-
plying the number of mineral units extracted during that period times
the unit depletion basis.

      Percentage depletion is measured by applying the percentage
provided in the Internal Revenue Code for the particular mineral
to the gross income (defined below) from its extraction.   Exhibit VI.
following this page, lists  the various minerals covered by this study
and the applicable percentage depletion rates.  The Exhibit also
shows the point in the processing of the mineral at which a price
is applied to  determine the gross income for computing percentage
depletion.
      (I)   Depletion Allowances in Excess of Cost Were Initially
           Allowed to Encourage Development of Mineral Sources
           The depletion allowance,  specifically percentage deple-
      tion, is an extention of the discovery value concept originating
      during the gold rush days of 1849.  Under this concept,  the
      fair market value of a mine (its discovery value) could be sub-
      stantially greater than the cost of mine development.  In 1918
      Congress recognized the discovery value concept by allowing
      depletion to be taken on the fair market value of the property
      at the time of the discovery or within 30 days thereafter.
      Because the regulations governing depletion on the basis of
      fair market value were difficult to administer,  percentage
      depletion was adopted in 1926 for oil and gas and in 1932 for
      coal, metals, and sulphur.  The 1964 Internal Revenue Code
      extended the percentage depletion allowance to almost all
      metallic and nonmetallic minerals.
     (2)   The Measure of the Tax Benefit Provided by Depletion
           is the Reduction in Taxes Payable Associated With Using
           Percentage Depletion in Preference to Cost Depletion
           The deduction for cost depletion is limited to actual pro-
     ducer costs; the deduction for percentage depletion, however.

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is available even though producer investment has been fully
recovered.  The deduction for percentage depletion can
exceed the original cost of the property.   Therefore, per-
centage depletion,  to the extent that it exceeds cost depletion,
is considered to provide a discriminatory tax benefit for pur-
poses of this study.
 (3)   The Tax Rules Pertaining to Percentage Depletion
      Include  Precise Definitions and Income Limitations
      The amount of the percentage depletion deduction is de-
pendent not only on the depletion precentage used but also
on the following three factors:
           A precise definition of "gross income" to which
           the depletion precentage is applied and from which
           taxable income is calculated

           A maximum limit on the amount of percentage
           depletion which can be claimed of 50% of the taxable
           income from mining properties

           There are a multitude of definitions for "mining
           properties".   A mining  property  is generally defined
           as each separate interest owned by a taxpayer in each
           mineral deposit in each separate tract or parcel of
           land.  Under the tax code, certain mineral interests
           may be aggregated  in computing depletion and
           taxable income.   Thus,  if the amount of taxable
           income from a property does not permit the full
           amount of available depletion to be taken, due to
           the 50% limitation,  then the combination  of income
           from that property with income from other properties
           which have taxable income in excess of the 50%
           limit, may permit the full amount of the depletion
           deduction taken to be increased.  The rules governing
           aggregation are extremely complex.
      The definition of gross income and the 50% limit on
taxable income for percentage depletion are presented below.
                      -9-

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 Definition of Gross Income
      Gross income is defined separately for oil and gas pro-
 ducers and for mining operations.  Oil and gas gross income
 is determined by the amount for which the oil or gas is sold
 at the well head or near the vicinity of the well. If the oil or
 gas is not sold at the well head and other production,  trans-
 portation,  or manufacturing costs are incurred by the extractor,
 then gross income is computed by using the representative mar-
 ket or field price at the well head.

      Gross income for mining operations is not limited to the
 sales value at the mine but is extended to include the value of
 certain treatment processes and transportation costs to the
 treatment plant.  The treatment process are listed in the tax
 code (see Exhibit I).  If the  minerals are not sold after the
 allowable treatment which would determine gross income, a
 representative market or field price must be used to calculate
 gross  income.

      Representative field prices are determined for an ore
 or mineral of a like kind or grade.  The  weighted average of
 competitive selling prices is an important factor in deter-
 mining the field prices.  Prices estaolished in  a transaction
 between divisions of an integrated producer cannot be used.
Taxable Income Limitations
      The total amount of percentage depletion which can be
claimed is limited to 50% of the taxable income from a mining
property. The taxable income from a mining property is cal-
culated by deducting from gross income the development ex-
penses deducted in computing taxable income,  costs of exploiting
the natural resource including the maintenance of geological
and land  departments,  interest on money borrowed to develop
mines, state income taxes,  and a fair share allocation of over-
head items.   The depletion deduction itself and charitable
contributions are not deducted from gross income in arriving
at the taxable income for the 50% limit computation.
                       -10-

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2.    MINIMUM TAX ON TAX PREFERENCES
      Under the Tax Reform Act of 1969, Congress imposed a 10%
tax, effective for years ending after 1969.  on items designated as
preference items.  Preference items were identified as those items
in the tax code  which, while available to all taxpayers, are advan-
tageous primarily to high income taxpayers, and the application of
which results in the reduction of a taxpayers effective tax rate.
The excess of allowable percentage depletion, over the adjusted
cost of a mineral property is defined as a tax preference item.
Also, for a corporation in the 48% tax rate bracket, 3/8 of total
capital gains claimed is a tax preference item.

      The tax on preferences is levied primarily on domestic source
income.  The tax is imposed on the total amount of tax preferences
less the following amounts:
                 A $30, 000 annual exemption per corporation

                 The income taxes paid for the taxable year,
                 excluding income taxes on accumulated earn-
                 ings and personal holding companies.
If the $30, 000 exemption plus the regular income tax liability is
in excess of the total amount of tax preferences available, the
excess amount may be carried forward for seven years and used
to offset the preference items in the following years.

      The tax reduces the effective tax benefit of percentage deple-
tions and capital gains.  Accordingly, the minimum tax on pref-
erences mitigates the benefits provided by certain tax incentives.
For the oil and gas  companies this reduction has been estimated
to be from 2. 5 to 4  percent of the percentage depletion benefit.
The impact of the minimum tax on preferences on the other
materials considered in the study is lower.
3.     U. S. TREATMENT OF TAXES PAID TO FOREIGN
      GOVERNMENTS
     The regulations governing foreign taxes are applicable to all
foreign operations of U. S. companies.  For purposes of this study.
                           -11-

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however, the impact of the tax rules are treated as applying to pri-
mary material users and not to secondary material users due to
the almost non-existent imports of secondary -materials,  'and the
fact that U. S.  companies do not process post-consumer waste
overseas.

      The gross taxable income of corporations operating inter-
nationally can vary widely, depending upon international transfer
pricing policies, corporate organization structure,  the degree of
integration of operations,  and other factors.
      (1)   U. S. Companies That Pay Foreign Income Taxes Can
           Generally Credit Such Taxes Against Their U. S. Tax
           Liability
           The United States taxes its citizens on their worldwide
     income. A U. S.  company thus could be taxed on the same
     income by the U. S. government and also by a foreign govern-
     ment.   Internal Revenue Service Code Section 901 allows a
     credit for the amount of income taxes imposed by foreign
     countries.  The credit is intended to pla-ie foreign  and
     domestic source income on an equal footing insofar as the
     United States income tax is concerned and is also designed
     to facilitate overseas investment.

           Regulations pertaining to foreign tax credits are shown
     in Exhibit VII,  following this page.
     (2)   The Measure of the Tax Benefit Associated With the
           Foreign Tax Credit is the Reduction in Taxes Payable
           Obtained by Treating Foreign Taxes Paid as a Credit
           Rather than as a Deduction
           The magnitude of the benefit provided by foreign tax
     credits varies with the effective tax rate of the foreign coun-
     tries imposing taxes and the treatment of the taxes paid on
     U. S.  tax returns.  Taken as a credit, foreign taxes are
     subtracted directly from the U. S. tax liability.  Taken as
     a deduction, foreign income taxes reduce taxable income.
     The taxpayer has the option of treating foreign taxes paid
     as either a credit or a Deduction.  However,  all  foreign
     taxes must be treated uniformly.
                            -12-

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                                            EXHIBIT VII


                         REGULATIONS PERTAINING TO FOREIGN TAX CREDITS
 1.    A taxpayer who pays taxes to a foreign country may be entitled to
      a tax credit if his foreign source income is subject to U. S.  income
      tax.

 2.    Limits on the Credit
      There are two alternative methods on computing the foreign tax
      credit—the "per country method" and the "overall' method... In
      neither case can the credit  exceed the actual amount of foreign
      tax paid. (Refer to text for explanation)

3.    Who Gets the Credit

      The credit is allowed to all citizens and corporations as to both
      taxes paid to a foreign country or a  possession of the United States.

4.    Special Rule for Foreign Mineral Operations

      A domestic mining company operating in a foreign country pays foreign
      taxes on its mineral income.  It must also include its foreign mineral
      income, along with its other foreign income, in its U. S. tax base.
      Effective for tax years after 1969, the excess of foreign tax credits
      resulting from the allowance of a  percentage depletion deduction on
      foreign mineral income cannot be used in determining the tax credit
      limit under the "overall" country method.  A country by country cal-
      culation must be made of the effect of percentage depletion on U.S.
      taxes on foreign mineral income. The amount of foreign income taxes
      paid which can be included in determining the tax credit limit under the
      "overall" method must be reduced by the amount that the foreign in-
      come tax exceeds the amount of U.S. tax calculated after application of
      the depletion deduction.  Any excess of foreign tax credits resulting
      from high foreign tax rates  may,  however, be included  in determining
      the "overall" tax credit limit.

5.    Credit of Domestic Corporation for Taxes of a Foreign  Subsidiary

      A domestic corporation which owns  10% or more 01 the  voting stock
      in a foreign corporation  is entitled to a credit for a proportion,
      based on dividends  received, of ihe taxes paid by the foreign corp-
      oration to a foreign country of United Sxates possession.  A credit
      is also allowed to a domestic corporation for foreign taxes paid  by
      a subsidiary of a foreign corporation described in the preceding sent-
      ence.  In such a case, however, in order for the credit to be avail-
      able,  the foreign corporation must own 50% or more of the foreign
      subsidiary's voting stock.

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      Where the effective tax rate of a foreign country is
higher than the U. S.  rate, a company may by using an
"overall" limitation, claim a credit for the total taxes that
it has paid to all foreign countries.  The company's credit
using the "overall" method is limited.  The limit is deter-
mined by calculating the U. S. tax on all income, from all
sources, including foreign and multiplying this amount by
a fraction, the numerator of which is the total foreign
taxable income and the denominator of which is  total
foreign and domestic income.  For example, assume the
following operating results  for a company with operations
in the U. S.  and two foreign countries:

                       Taxable
                        Income

      Country A         $1,000
      Country B          1,000
      U.  S.               1,000
          Total         $3,000

      If income were to be taxed separately in each country,
      the applicable taxes would be:

                       Taxable      Tax
                        Income       Rate       Tax

      Country A         $1,000       40%       $400
      Country B          1,000       60%        600
      U.  S.               1,000       48%        480

      If all income,  regardless of source,  were subject
      to U.  S. taxes, the applicable U.  S. tax would be:

                        Taxable      Tax
                        Income      Rate        Tax
     U. S.              $3.000       48%      $1,440

     Under the "overall' method, the maximum foreign
     tax credit would be  computed as follows:

     $2, OOP (Total Foreign Taxable Income)   $.  44Q _ $g6Q
     $3.000 (Total Taxable Income)           *  '    " *

     Thus,  while the company paid $1, 000 ($400 + $600) in
     foreign taxes, the allowable 'tax credit under the "overall"
     method is limited to $960.
                       -13-

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      If the allowable tax credit were computed on a "per
      country" basis, it would be limited to $880 as follows:

           $1.000
                   x $1,440  =  $480
      Since the tax paid in Country A was $400. the allowable
      tax credit is limited to $400 as the tax credit cannot
      exceed the tax paid in each country.  The allowable
      tax credit for taxes paid in Country B, however, is
      limited to $480 by the above formula even though
      $600 in taxes were actually paid.

           Exhibit VIII, following this page, summarizes
      relevant tax legislation of Venezuela, Canada, and
      Jamaica. These countries host important U. S.
      mineral operations.
(3)    United States Law Provides Several Other Methods
      of Sheltering Earnings of Foreign Operations From
      the full Effect of U. S.  Taxation
      Under U. S. tax regulations,  a corporation engaged in
foreign trade can organize and conduct operations in such a
way as to minimize the effects of the U. S. tax burden on
overseas enterprises.  The regulations are numerous and the
provisions extremely complex.   The more important means
of managing foreign operations to achieve maximum tax
savings are presented below.
           Western Hemisphere Trade Corporations

           U. S. corporations controlling foreign based
           mining enterprises can operate as "Western
           Hemisphere Trade Corporations" (WHTC).

           They can do so by incorporating a domestic
           subsidiary which controls overseas operations.
           A subsidiary can qualify as an WHTC if:

                Its entire business,  other than incidental
                purchases, is carried on in the Western
                Hemisphere.
                      -14-

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                                                                                                                              EXHIBIT Vin

                                                                                                             SUMMARY OF FOREIGN TAXES OF COUNTRIES
                                                                                                           THAT HOST IMPORTANT EXTRACTIVE INDUSTRIES
The Range of Foreign Taxes and Their Impact Upon Gross and Taxable Income Varies Widely.  Depending Upon International Transfer Pricing Policies.
Corporate Organizational Structure and Degree of Integration of Operations.  Below is a Summary of Relevant Tax Legislation of Three Countries that Host
Important U. S. -Owned Extractive Industries	
              VENEZUELA (1)

Corporations, partnerships and joint ventures
which are engaged in the exploitation of mines.
hydrocarbons and related activities are subject
to a tax for all their income.  Their gross income
comprises the amount of sales.  Exports of petrol-
eum and iron are. whether procured or not.  con-
sidered as sales.  The National Executive  establishes
basis for export prices.   When the reference prices
exceed realized prices, an extra income tax payment
will be made for the tax on t!.e difference between
th° taxable income f i om the books and that using the
reference prices. Depletion,  depreciation anc"
amorti7ation of assets are allowed.

   Depreciation--The cost ol UIP concession is
   considered to be its purchase price and related
   expenses  plus the initial -xploitation and ell
   exploration taxes.

   Depletion—Is calculated in the  unit of production
   basis, taking into consideration the unamortized
   cost, 'he  proven  reserves for the area  and the
   production of ih-  field.

Exploration expenses, tangiole and intengible
drilling coata are also allowed-

The /nrnme tax  rate for income from oil and mining
activities 10  a flat 60%. but the following adiustments
to the tax may be applicable:

   .  Credit for  new investment
   .  Credit for  increase in export sales
   .  Credit for  losses
   .  30-50 tax  (discussed below)

SO-SO iflx-coi-iparues engaged In the extraction of
petroleum or n-.irung are subject to an additional
tax (50-50 tax).  The tax is calculated by subtract-
ing from the net after-tax income the total taxi's
incurred during the  year, any excess is taxed at SOft.

In addition, other provisions of Venezuelan Law
may be  applicable to a particular company's
activities.
                 CANADA (2)
The following provisions of Canadian law apply
to mining and petroleum.  Otherwise, mining and
petroleum companies operating in Canada are
subject to the same rules that apply to all Cana-
dian corporations.  The corporate tax rate in
Canada for 1972 is 50%.

.  Taxpayers whose principal business is not
   mining or petroleum are allowed* deductions
   for Canadian exploration and development
   expenses.

.  All taxpayers are allowed deductions for foreign
   exploration and development expenses.

.  Acquisition of mining properties and royalty
   interests treated as exploration and develop-
   ment expenses, end proceeds on disposals
   of such properties are fully taxable subject
   to transitional rules for those owned at
   December 31. 1971.

.  Three year tax exemption for new mines are to
   be withdrawn after 1975 and replaced by an
   accelerated  writeoff of capital equipment and
   on-site facilities, including townsite facilities
   such as sewage plants, roads, hospitals and
   schools.  The accelerated writeoff also applies
   to a major expansion of an existing mine
   where capacity 19 increased by at least 25%.

.  The present system of automatic percentage
   depletion for operators (33%) and nonoperators
   C5%> will continue until 1976.  However, af.er
   1976, depletion will be based on amounts ex-
   pended on eligible expenditures since Novem-
   ber 7. 1969. Taxpayers will be allowed $1 of
   of depletion  for each $3 of eligible expenditures
   with a limit  of 33-1/3% of production profits
   per year. For this purpose, royalty income
   will be deemed to be production profits.

   A Federal corporate tax abatement on mining
   profitb of 15 percentage points was also intro-
   duced. This abatement which  commences in
   1977 will also apply in the Yukon and Northwest
   Territories.
             JAMAICA (3)
Mining companies are subject to the same
regulations governing all corporations
operating in Jamaica.  All companies pay a
basic company"profits tax and an "additional"
company profits tax.  The rate depends
upon the class of company (agricultural.
open, intermediate or close) and it ranges
from 25% to 35%.  The rate of additional
company profits tax is 15%.

In addition,  there are certain import duties.
tonnage taxes, excise taxes applicable to
all companies,  and preferential legislation
has been enacted to cover various industries.
No such legislation exists for bauxite opera-
tions although special concessions have
occasionally been granted to attract foreign
capital into the island.
(1)   Petroleum and iron ore
(2)   Principally Iron ore
(3)   Bauxite
                                                                 14-a

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            Its gross income for the current taxable
            year and the two preceding taxable years
            was derived:

                 95% or more from sources outside
                 the United States

                 90% or more from the active conduct
                 of a trade or business
      A WHTC is allowed, as a deduction in computing
the amount of income subject to tax,  an amount equal
to a fraction of its taxable income as computed without
this deduction.  For 1971 and subsequent years,  the
deduction is 14/48 or approximately 29.17%—a reduc-
tion of close to one third in the amount of U. S. tax
otherwise payable.  Other advantages of the WHTC are
discussed in Exhibit IX, following this page.  As indi-
cated in the Exhibit, the second main  advantage of a
WHTC is that domestic shareholders are not taxed on
dividends until they are received and corporate share-
holders,  in addition, are not taxed on 85%-100% of divi-
dends received.   Without the WHTC benefit, dividends
from a foreign corporation wculd be taxed not as re-
ceived, but as earned and the exemption of 85%-100%
of dividends received from taxation would not apply.

Less Developed Country Corporations (LDCC)

      Special tax treatment is also available to Less
Development Country Corporations (LDCC). An
LDCC is a corporation operating in a  less developed
country as designated by the President of the United
States which derives at least 80% of its gross income
in the less developed country,  and has at  least 80%
of its  assets invested in such a country.

      The tax benefit associated with an LDCC involves
the regulations cohering the  taxation of dividends re-
ceived from a foreign corporation. Normally, dividends
received from a foreign corporation are taxed  on the
full amount of the dividend declared,  regardless of the
amount of tax paid on that dividend to  a foreign govern-
ment.  U.S. taxes ov. dividends received from an LDCC
may be computed on the net amount of dividends received,
after deducting taxes paid to foreign governments.

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                                                                                                                        •   EXHIBIT IX

                                                                                                            RELATIVE TAX ADVANTACCS OF USE OF
                                                                                                        WESTERN HEMISPHERE TRADE CORPORATION
THE GREATEST ADVANTAGE OF USING A WHTC TO CONDUCT FOREIGN OPERATIONS IS THAT. AS A4I*. CORPORATION. THE DOMESTIC SHAREHOLDERS ARE NOT TAXABLE ON IMAGINARY
DIVIDENDS NOT ACTUALLY RECEIVED FROM IT. ADDITIONALLY. CORPORATE SHAREHOLDERS ARE ALLOWED THE DIVIDENDS RECEIVED DEDUCTION (100% OR 8SK) FOR DIVIDENDS RECEIVED
FROM A WHTC
OTHER VALUABLE ADVANTAGES OF A WHTC INCLUDE

• THE INCOME OF A WHTC IS SUBJECT TO U i TAX AT 34/48THS (OR 70.8%) OF THE FULL
  CORPORATION TAX RATE. WHEREAS INCOME OF THt FOREIGN CORPORATION IS
  TAXABLE TO ITS UJ SHAREHOLDERS AT THE FULL CORPORATION OR INDIVIDUAL
  TAX RATE. Ei lilFR WHERE ACTUALLY DISTRIBUTED TP THEM OR WHERE REQUIRED
  TO BE REPOHTCP BY THEM AS IMAGINARY DIVIDENDS.

• IT Ib POSSIBLE 10 TRANSFER Phl'PER1Y TO A WHTC IN EXCHANGE FOR SHARES OF
  I fS STOCK TAX-FREE (WITHOUT CAPITAL GAIN) ON THE 01 HER HAND. TRANSFERS
  OF PROPERTY TO A FOREIGN CORPORATION IN EXCHANGE FOR ITS STOCK REQUIRE
  CLEARANCE FROM THE INTfcRN/.L REVENUE SERVICE.

• THE DOMESTIC PAREUT COMPANY OF A WHTC IS TAXABLF ON NOT MORE THAN 15%
  OF DIVIDENDS ACTUALLY RECEIVED FROM THE WHTC. IS TAXED AT THE CAPITAL
  GAIN KATE ON GAINS REALIZED ON A SALE OF STOCK OF A tf.lll.. ANO CAN LIQUIDATE
  THE CORPORATION TAX FREE-TH^T is. WITIiaUl RECOGNITION OF GAIN ?N1HE
  OTHLR HAND, THE DOMES'! iC PARENT OF A CFC (CONTROLLED FOREIGN CORPORATION)
  NOW IS TAXABLE AT THE FULL CORPORATION TAX RATE (4854 OF ALL OVER $25.000)
  WITHOUT ALLOWANCE OF THE DIVIDENDS RECEIVED DEDUCTION.ON ALL EARNINGS
  OF A FOREIGN CORPORATION EITHER (1) WHEN EARNED BY THE FOREIGN
  CORPORATION. BEFORE BEING DISTRIBUTED BY IT. OR (2) PRIOR TO DISTRIBUTION OF
  SUCH EARNINGS.
• UNITED STATES SHAREHOLDERS OF A CFC ARE REQUIRED. IN MANY INSTANCES. TO PAY
  DOMESTIC TAXES ON ITS FOREIGN-EARNED INCOME BEFORE SUCH INCOME IS ACTUALLY
  DISTRIBUTEOTO THEM. WHEREAS A WHTC IS SUBJECT TO UNITED STATES TAX CURRENTLY

• A UNITED STATES CORPORATION THAT IS A SHAREHOLDER OF A WHTC CAN GET CAPITAL
  GAIN TREATMENT OF GAIN ON A SALE TO IT OF A PATENT. INVENTION. OR SIMILAR
  PROPERTY. WHEREAS GAIN ON A SIMILAR SALE TO A FOREIGN CORPORATION CONTROLLED
  BY THE DOMESTIC CORPORATION IS DENIED CAPITAL GAIN TREATMENT AND TAXED AS
  ORDINARY INCOME

• THF INCOME OF A WHTC CAN BE INCLUDED IN A UNITED STATES CONSOLIDATED INCOME
  TAX RETURN. WITHOUT LOSS OF THE SPECIAL WHTC DEDUCTION

• A WHTC CAN OBTAIN THE BENEFITS OF TAX TREATIES OF THE UNITED STATES WITH OTHER
  COUNTRIES.

• THE WHTC AND ITS SHAREHOLDERS ARE SPARED THE HEAVY BURDEN OF INCREASED ACCOUNTING
  AND REPORTING REQUIREMENTS IMPOSED BY THE UNITED STATES ON SHAREHOLDERS OF A CFC.
                                                                15-a

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      The tax benefit associated with an LDCC is some-
what limited by the provisions governing foreign tax
credits.  For non LDCC's a credit can be taken for the
full amount of foreign taxes paid on dividends received.
The amount of the  credit which can be taken for foreign
taxes paid on dividends received from an LDCC is limited
to the effective foreign tax  rate applied to the cash divi-
dend actually received (dividend declared, less foreign
taxes paid).

U.S. Corporation in a U.S. Possession

      A U.S.  domestic corporation that receives 80%
or more of gross income for three years from sources
in U.S. possessions, and 50%  of its gross income is
from trade or business (as  opposed to interest) in the
possession, may qualify  income for exemption from
taxation.  The applicable U.S. possessions are specif-
ically defined in the tax code; they include the Panama
Canal Zone, Wake and Midway Islands,  but do not include
the Virgin Islands  or Puerto Rico.


Controlled Foreign Corporations

      A controlled foreign  corporation (CFC) is  the
least advantageous means of operating a business a-
broad.  If an CFC  is established, it should be operated
and organized in such a way as net to allow dividends
tc be taxable to its U.S.  shareholders as imagninary
dividends under Subsection F.   Income exempt from
such treatment includes:

      Income from producing goods abroad

      Income from sales of goods for use, con-
      sumption,  or depreciaxion with the country
      of incorporation.

      The timing of the repatriation of profits and the
exclusion of Controlled Foreign Corporation can also
impact U.S. tax liabilities.

      When profits of U.S.  owned foreign operations
      are declared to the permanently reinvested.
      U.S. taxes do not need to be paid or accrued.
             -16-

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                       When imaginary dividends are declared,  a
                       company merely accrues U.S. taxes on its  books.
                       Such taxes are paid when dividends are actually
                       repatriated.

            Tax aspects of each form of organization vary, but adequate
      tax planning allows U.S.  enterprises to reduce their income tax
      liability.
4.    STATE AND LOCAL TAXES
      Various states impose severance,  occupation and modified property
and local jurisdictions taxes on timber lands, mines and wells.  These
taxes tend to act as a disincentive to production of virgin materials.

      Taxes are identified in Exhibit X, following this page, for certain
important virgin raw material producing states.  As the Exhibit shows,
these taxes vary substantially in amount, rate, and form of application.

      State taxes pertaining to forest lands are discussed in Exhibit XI.
These taxes, tax rates, and their applicability also vary greatly from
state to state.  Some act of incentives, some as disincentives.
5.     MINE EXPLORATION AND DEVELOPMENT EXPENDITURES
      AND INTANGIBLE DRILLING AND DEVELOPMENT COSTS
      Both miners and oil and gas producers may elect for tax pur-
poses to expense certain exploration and development expenditures.
      (I)   Under Certain Circumstances,  Mine Exploration and
           Development Expenditures May Be Deducted Currently
           Domestic mining companies (excluding oil and gas pro-
      ducers) may expense all miae exploration expenditures pro-
      vided that the amount expensed is recaptured once the mine
      reaches production or is sold.  Recapture is accomplished
      as previously deducted exploration expenditures are included
      in income or if the mining company reduces the amount of
      depletion claimed.
                             -17-

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                                 EXHIBIT X

                          STATE AND LOCAL TAX LAWS
                   APPLICABLE TO CERTAIN RAW MATFRIALS
Major Type
Commodoty Producing State of Tax Tax Rate
Iron Ore

Bauxite
Petroleum
Gas
Coal
Sand and Gravel
Minnesota



Michigan
Arkansas
Te»as
Louisiana
Califori'i:
Oklahoma
Wxas
Louisiana
California
New Mexico
West Virginia
Kentucky
California
Missouri
New Jersey
Illinois
Occupational Tax on Mining

Royalty Tax
Occupational Tax on Production o!
Taconites. Iron Sulphates and Derived
Concentrates
Production Tax

Severance Tax
Prodjction Tax
Petroleum Tax
Pi eduction Ttx
Production Tax
Production Tax
Production Tax
Srverancp Tax
Production Tax
Ad Valorem Tax
Conservation Tax
Emergency School Tax
Natural Gas Processors Tax
S» verance Tax
Production I'qi ipnicnt Tax
Pnvilegc Tax
^pocisl local taxes on production of
iirtural resources
Spvrinncp TJX
None
None
Nunc
None
15i% of value of iron ore at the mine less credits for labor on low grade ores lesearch and
exploration (reducing rate to about 14%)
15% of value of Taconites. Semi-Taconites and Iron Sulphides
154% for permission to explore and mine (gross value of mining is reduced by loyally tax to
avoid duplication of tax)
lli% per gross ton plus I/ IOC per ton for each lit iron content in excess of 55% (higher rate
applies if price index is over 110)
Added tax on production (per gross ton)-
1971 - 4C 1972 - ?C 1973 - 9; 1974 - 9C 1975 - IOC 1976 - IOC 1977 - 12« 1978 - 12{
Low grade iron ore is taxed during mine construction at 17o of annual capacity multiplied by
percentage of completion of construction after construction tax rate is 2% of annual average
production
Underground bcneficiated and agglomerated tax iron ore is taxed at 2% to 3% of property
depending upon annual shipments and process involved
liC per ton
Oil production tax is 4 60 per 42 gallon ban el of oil 'if value exceeds $1 per barrel, tax is 4.67i
of market value)
C rude petrnleum tax is 3/16C per 42 gallon barrel
1BC to 26C per 42 gallon harrel depending upon gravity
Hale per barrel is determined annually depending upon the amount requited to support the
division of oil and gas Hate has been running at 003 'iC per 42 gallon barrel
5% of gross value of production on the first $150 monthly gross if producing under 3 barrels
ilailv anil 7% on the balance
7J% of market value (condcnsates are taxed at lower oil rate)
2 1C per MCI~ (effective .lulv I. IS74. 1 1 i7o of value at severance)
See Pott oleum Hate has been running at about .0015C per 10.000 cu ft of gas
Ad Valorem Production tax based on assessed value of 150% of product value (less royalties
and trucking) times assessment ratio which i.s certified locally
14% of severed value
2 55% of severed value
45/100% of product value
2{% of severed value
27% ('% prior to M.iy ri. I'i72) of pimlurl value times assessment ratio levied on production
i-qiiipinent for scvernrt c. treatment or storage
Uusmess and occupational tax • 3 5% of gioss proceeds or gross income
Local taxes range from 1/2% to 1% of gross income
4% of sales, minimum 30? per ton strip mines are nlsn under special license




17-a

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                                                                                                                               EXHIBIT XI

                                                                                                     STATE TAX LAVS APPLICABLE TO TIMBER OPERATIONS
TIMBER
         STATE TAX LAWS APPLICABLE TO FOREST LANDS GENERALIY FALL INTO FOUR GROUPS-

         ID EXL1SPTIOH A'lO REBATE LAWS. (2) MODIFIED PROPERTY TAX LAWS. (31 YIELD TAX LAWS. (4) SEVERANCE TAX LAWS. MODIFIED
         PROPERTY TAX LAWS IN TURN FALL UNDEH THREE SUBGROUPS-  (1) MODIFIED ASSESSMENT. 12) MODIFIED RATE. (3) DEFERRED PAYMENT.
                   AKO BmAI b TAXES'
         ALABAMA.CALII un.'HA. CO; ORAOO.HAWAII.IDAHO.IOWA,
         NL.VHA.-Pil!,HE. fJCWJERStv. NORTH CAROLINA.PUERTO RICO.
         HHOntlflA,;0
        I
        I Mmifi
                       nTY TAX LAIVS*
         ALABAMA. .".oK.ViSts. MIMECTICUT. FLORIDA. HAWAII. IDAHO,
         InlOIA'JA. 13'.'A. LOUISIANA. MAINE. MARYLAND. MASSACHUSETTS.
         V..CIUI-.Arl .liril.'CSOTA, MISSISSIPPI. MISSOURI. MEW HAMPSHIRE,
         NLIV JEISSEY. N:'.V. EXICO. NOW YORK. NORTH DAKOTA. OHIO. OREGON.
         !>E':NSYLV£N:A. PUERTO RICO. RHODE ISLAND. VIRGINIA.WASHINGTON.
         WlblO.'lSIN
          Al ADAMA LUM .CCHCUT. HAWAII. IDAHO. LOUISIANA. MASSACHUSETTS.
          MICHIGAN. l.lir.'I.ESJTA. MISSISSIPPI. MISSOURI, NEW HAMPSHIRE. NEW
          YORK. ORF COM. WASHINGTON. WISCONSIN
          ALABAMA. ARKANSAS. I OUISIANA, NEW MEXICO, OREGON. VIRGINIA
REMOVES FOREST LANDS AND TIMBER OR TIMBER ALONE FROM
THE I-ROPERTY TAX ROLLS EITHER FOR A TERM OF YEARS OR.
INSC IE CASES. INDEFINITELY TO QUALIFY FOR EXEMPTION.
FOREST TRACTS MAY NEED TO COMPLY WITH CERTAIN FOREST
MANAGEMENT REQUIREMENTS REBATE LAWS PERMIT LANDOWNER
TO MPLY FOR ABATEMENT OF TAXES LEVIED
UNDER THE MODIFIED PROPERTY TAX LAVA OF THE MODIFIED ASSESSMENT
TYPE A FIXED ASSESSMENT PER ACRE MAY DE PROVIDED THE MODIFIED RATE
LAAS ARE VARIED BUT HAVE IN COMMON THE USE OF A TAX RATE THAT
DIFFI RS FROM THE MILLAGE RATE APPLICABLE TO REAL PROPERTY IN
GENERAL
YIEL" TAX LAWS ARE DESIGNED TO AID FORESTRY BY RELIEVING TIMBER
FROM PAYMENT OF ANNUAL PROPERTY TAXES AND IMPOSING INSTEAD A
TAX AT THE TIME OF TIMBER HARVEST
SEVERANCE TAXES ARE SIMILAR IN SOME RESPECTS TO YIELD TAXES BUT
IMPOSED SOLELY FOR REVENUE PURPOSES
 • TAX RATES AND APPLICABILITY VARY WIDELY FROM STATE TO STATE

 SUURCE:   TIMBER TAX JOURNAL. 1972
          FOREST INDUSTRIES COMMITTEE ON TIMBER VALUATION AND TAXATION
          WASHINGTON. DC
                                                                   17-b

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            Mine development expenditures may be expensed as
      incurred up to the point where the mine reaches full pro-
      duction.  Depreciable property,  such as trucks 'or buildings.
      however, must be capitalized.  In addition, expenditures
      for the purpose of decreasing operating costs may not be
      expensed.

            Once full production is reached,  expenditures to
      maintain the established production as  the working face
      of the mine recedes  may be expensed.
      (2)   Intangible Drilling and Development Costs
           May Be Expensed as Incurred
           Oil and gas producers may expense intangible drill-
      ing and development costs as they are incurred.  Such costs
      include labor, fuel, power, materials and supplies, rentals
      and other expenditures necessary to locate and develop a
      well.  Expenditures for tangible or salvageable assets may
      not be expensed, however,  as they may be reused in other
      locations.
      (3)   The Tax Benefits Associated With Current Write-Offs
           Depend on the Amount and Timing of the Tax Defer-
           ment and the Taxpayer's Opportunity Cost of Capital
           The benefit derived from the write-off of certain
      costs as expenses rather than as depreciation can be
      measured by the present value the deferred tax payments.
6.    CAPITAL GAINS
      Under Federal tax regulations,  gains from the sale or
exchange of certain capital assets held for more than six months
are provided preferential tax treatment.  The gains from such a
sale are taxed at a lower effective rate than are normal operating
profits. The basis for this preferential tax treatment is that
capital gains accumulate ovtr the period (often an extended
period) that assets are held but are realized when the assets
are sold or exchanged.
                          -18-

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      Timber is particularly affected by capital gains since timber
producers may treat the cutting of timber for sale or use as a
capital gain.  Prior to 1944,  capital gains treatment was available
only for the sale of a timber tract.  In 1944 capital gains treatment
was extended to cover timber harvesting.   Similar treatment is
available to companies disposing of coal or domestic iron ore
under royalty contracts.
      (t)   Proceeds From the Sale or Exchange of Timber Are
           Subject to Capital Gains Treatment
           Capital gains from timber disposal may result from
     the following:
                 Sale of standing timber
                 Disposal of timber under a cutting contract
                 (includes  Federal and privately owned lands)
                 Cutting by the taxpayer
     In each case,  the timber must be held for six or more months.
     Each of the above means of disposal is discussed below:
                Sale of standing timber.  Capital gains on the
                sale of standing timber are computed as the
                difference between the sales price and the ad-
                justed cost of the timber to the seller.

                Disposal under a cutting contract.  The excess
                of the payments received under a cutting contract
                over the adjusted cost of the timber may be
                treated as a capital gain. A cutting contract is
                a lease with payments based on the amount of
                timber cut.  To qualify for capital gains under
                a cutting contract, the trees need not be cut into
                lumber:   Christmas treesr  cordwood and pulp-
                wood also quaLty.  This  is applicable on both
                Federal and private lands.

                Timber cut by owner,  A taxpayer (individual or
                corporate) cutting owned timber for sale or own
                              -If-

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                 use, may elect capital gains treatment.  Capital
                 gains, however, must be taken on the amount of
                 timber cut in a given taxable year, whether it is
                 sold or not.

                 The capital gains election is binding and applies to
                 all timber owned by the taxpayer cut  in subsequent
                 years.  IRS permission is needed for any change.

                 If a capital gain election is not made, no gain or
                 loss is recognized when the timber is cut, but
                 income is recognized when the timber is sold in
                 the form of logs, pulpwood, or firewood and is
                 taxed as  ordinary income.
      (2)    Capital Gains Treatment is Available to Taxpayers
            Disposing of Coal or Domestic Iron Ore Under
            Royalty Contracts
           If a producer disposes of coal or iron ore which has
      been held for six months or more under a contract retaining
      an economic interest in the coal or iron ore (a royalty con-
      tract) he may elect capital gains treatment.
7.    IF PARTICULAR TAX INCENTIVES ARE ELIMINATED.
      ALTERNATIVE TAX TREATMENTS MAY BENEFICIALLY
      BE USED
      As indicated in the previous sections, differential tax rates
and tax treatment of some deductions and credits provide a tax
advantage to selected groups of taxpayers.  If the tax treatment
resulting in special benefits is eliminated, alternative tax treat-
ments are still available.  Some of these alternative treatments
have been discussed in defining the tax benefits, specifically for
depletion, foreign tax credits,  Western Hemisphere Trade Cor-
porations, and capital gains taxes; for example, cost depletion
would be taken in lieu of percentage depletion,  and foreign taxes
could be taken as a deduction instead  of a credit.

      If producers were not permitted to deduct exploration, and
intangible drilling costs currently,  an alternative to capitalization'
                             -20-

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and depreciation would be an abandonment loss deduction.  A
depreciable asset which  loses its usefulness ana is abandoned
is allowed a retirement loss deduction.  Therefore, while it may
be necessary to capitalize exploration and other  costs initially,
it will not be necessary to carry the costs if the  drilling or mine
explorations prove unsuccessful.

      Therefore, the maximum impact of eliminating tax incen-
tives would only occur if all tax options are closed.  Since this
is not likely to occur, any maximum impact analysis,  such as
those which follow, probably overstate the dollar impact  of tax
removal.
      The following chapter discusses the impact of discriminatory
taxation on the aluminum industry.
                            -21-

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                    III.  THE ALUMINUM INDUSTRY
      This chapter addresses the impact of discriminatory taxes and
tax benefits on the relative use of virgin and secondary materials in
the production of aluminum.
 1.    THE ALUMINUM INDUSTRY IS COMPOSED OF TWO
      DISTINCT SUB-INDUSTRIES. PRIMARY ALUMINUM AND
      SECONDARY ALUMINUM
      The primary and secondary aluminum industries are related
but largely separate in terms of production processes used and mar-
kets served.

      Primary aluminum producers can remelt industrial process
aluminum scrap which is compatible in alloy content and purity with
their primary products.  Aluminum fabricators also remelt internally
generated scrap. Neither primary producers nor fabricators are able
to make extensive use of scrap of mixed alloy content.

      Secondary aluminum smelters, which consume about 80% of the
total aluminum scrap supply are capable of making use of most types
of mixed alloy post-consumer scrap. About 90 percent of secondary
aluminum output is marketed to the aluminum casting industry with the
balance consumed in the production of steel.

      While secondary aluminum may not  be substituted for primary
aluminum in most primary aluminum end  uses, primary aluminum
may be substituted for secondary aluminum in casting.  At the present
time about 20 percent  of the  aluminum consumed by the casting indus-
try is obtained from primary producers.

      For purposes of this analysis, secondary aluminum has been
defined as functionally equivalent to primary aluminum at the alumi-
num ingot stage of production,  subject to the limits on cross  substi-
tution mentioned above.  Equivalency does not exist prior to the ingot
stage as primary and secondary aluminum processing techniques  are
not compatible.

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      The secondary aluminum industry cannot make extensive use
of recycled beverage cans due to their high magnesium content.
Primary producers manufacturing can stock may remelt old beverage
cans for reuse as can stock.  While this is currently being done by
several major primary producers the economics of this practice on
a large scale are undefined.  However, there may be difficulty in
obtaining an expanded supply of old cans.
2.    THERE ARE SEVERAL TAX BENEFITS AVAILABLE TO
      PRIMARY ALUMINUM PRODUCERS WHICH ARE UNAVAILABLE
      TO SECONDARY PRODUCERS
      There are no identifiable taxes or tax benefits applicable to
secondary aluminum production which are not also applicable to
primary production.  There are several elements of taxation.
however, which are unique to primary production.  They are as
follows:
                 Regulations providing tax benefits

                      The percentage depletion allowance on
                      bauxite

                      The foreign tax credit

                      Western Hemisphere Trade Corporation
                      allowances

                      Tax treatment of mine exploration and
                      development costs

                 State taxes applicable to bauxite mining
                                -23-

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3.    THE IMPACT OF EACH ELEMENT OF TAXATION
      ON THE COST OF PRODUCING PRIMARY ALUMINUM
      INGOT HAS BEEN COMPUTED
      The impact of the taxes and tax benefits discussed above on
the cost of producing primary aluminum ingot were computed for the
period 1970-1972. The analysis covered producers accounting for
approximately 70 percent of domestic bauxite consumption.   The
primary sources  of data used in estimating tax impacts were financial
statements and statistical data published by producers and the Alumi-
num Association, and copies of Form 10K filed by producers with
the SEC.

      Primary aluminum producers contacted, for the most part,
were unwilling to provide tax data beyond that publicly available.
One producer, however, did provide proprietary tax data which was
used to verify impact estimates based upon analysis of published
data. The analytical procedures used in preparing impact estimates
are discussed below.
      (1)   Raw Materials Conversion Ratios Were Developed
           for Primary and Secondary Aluminum Manufacturing
           To provide a basis for estimating tax impacts on a per
     unit of output basis, the following materials conversion ratios
     were developed:
                        Material Inputs to Produce
                         1 Ingot Ton of Primary
                            Aluminum Ingot
                Material                  Quantity

                Bauxite                   4. 0 tons
                Baked Caroon             0. 6 tons
                Cryolite                  0. 03 tonr-
                Aluminum Fluoride        0.04 tons
                                -54-

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      Analysis of tax impacts was limited to those associated
with bauxite production.  The impact of discriminatory taxa-
tion on the cost of the other materials listed above is not
significant.

      On the basis of discussions with industry sources, it was
assumed that aluminum scrap would be converted to secondary
ingot essentially on a ton for ton basis.
 (2)   Dollar Tax Impacts Per Ton of Bauxite Produced
      Were Computed for the Years 1970-1972
      The dollar impact of each element of taxation on the cost
per ton of bauxite mined was computed for each primary pro-
ducer evaluated. Separate estimates were prepared for each year
over the period 1970 - 1972.  Analytical procedures used were
as follows:
           Depletion Tax Benefits

           The procedures used in estimating unit depletion
           tax benefits were as follows:

                 Annual bauxite production quantities were
                 obtained from published producer statistics.
                 Adjustments were made where required to
                 eliminate purchased bauxite from aggregate
                 statistics.

                 The amount of cost  depletion claimed annually
                 by each producer was estimated on the basis
                 of depletion entries  on SEC Form 10K.

                 Percentage depletion was computed by
                 applying the allowable percentage depletion
                 rate for bauxita to the quantity of bauxite
                 mined by each producer in a given year
                 tim.es a cut off price per ton of bauxite
                 supplied by an industry source.   Computa-
                 tions were based primarily upon foreign source
                 bauxite as domestic bauxite production is only
                 10% of the total.
                           -25-

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The excess of percentage over cost deple-
tion was obtained by subtracting estimated
cost depletion from estimated percentage
depletion.

The net tax benefit was derived by multiplying
the excess of percentage depletion over cost
by 0.48.

To  evaluate the impact of ',he 50 percent limi-
nation on percentage depletion  (see Chapter
II) which would not be  reflected in the above
computations, a separate estimate of the
reduction in each producer's tax liability
attributable to depletion was developed using
a process of elimination.  Essentially,  re-
ductions in taxes payable attributable to all
non-depletion items including accelerated
depreciation, foreign tax credits,  the invest-
ment credit and other  items were  estimated
with the balance considered to be attributable
tc depletion. Data sources  included SEC
filings, notes to financial statements,
supplemented in some cases by data made
available by producers.

Estimated tax benefits derived using both
above methods  were compared and the lesser
indicated benefit was used for subsequent
analysis.  The lesser indicated benefit was
used to reflect the operation of the 50 percent
depletion limitation where possible.  Tf thp
first above  procedure  produced the lesser
indicated benefit, then the 50% percent limita-
tion would not be reflected.  If the second pro-
cedure used (process of elimination)  produced
the lesser indicated benefit, the difference in
benefits  was assumed to approximate the im-
pact on benefits of the 50 percent  limitation.
Care was taken not to  overestimate the magni-
tude of non-depletion itens  therefore weighting
the analysis toward understating rather than
overstating the reduction in benefits imposed
by the 50 percent limitation.
         -26-

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As indicated above, the estimating procedures may
be expected to overstate rather than understate the
tax benefit associated with the  percentage depletion
allowance.

Foreign Tax Credits

The procedures used  in estimating tax benefits
derived from foreign  tax credits were as follows:

      Foreign revenue from bauxite production
      was estimated by applying average bauxite
      prices, provided by industry sources,  to
      bauxite production.  Pre  tax profits were
      estimated to be equal to 11 percent of revenue
      on the basis of published  data (Fortunes 500)
      regarding the profitability of foreign mining
      operations.

      Foreign taxes paid were computed by applying
      a 30 percent tax rate to estimated pre-tax
      profits.  The tax rate used is that prevailing
      in major bauxite producing countries.

      The full amount of foreign taxes paid was
      assumed to be  creditable against U. S. taxes.
      The tax benefit associated with the foreign
      tax credit was  computed as  48 percent of
      the foreign taxes paid.  This procedure
      assumes that tax benefits can be maximized.
      i

Western Hemisphere Trade  Corporations (WHTC)

WHTC tax benefits were computed as follows:

      U.  S. tax liabilities without the WHTC option
      and prior to the application of the foreign tax
      credit were computed  as 48 percent of pre-
      tax income from bauxite mining.

      The WHTC option reduces the U. S. tax liability
      Dy 34 percent.   Thus the WHTC tax benefit was
      computed as 34  percent of the U. S. tax liability
      estimated  above (before application of the foreign
      tax credit).

-------
                 The procedures used in estimating WHTC and foreign
                 tax credit benefits are based upon the assumption that
                 maximum advantage can be taken of both benefits.
                 The tax code states that the foreign tax credit which
                 which may be taken by a WHTC is limited to the
                 effective WHTC tax rate which is 34 percent.  Since
                 the foreign tax rate assumed is 30 percent, this
                 limitation would not affect the computations.

                 Tax Treatment of Exploration and Development Costs

                 Benefits associated with the expensing of mine explora-
                 tion and development costs were estimated primarily
                 from analysis of expense accounts on producer
                 financial statements.  Adjustments were made
                 where required to isolate development expenses
                 attributable to mining activities.  The basis for
                 estimating the tax benefit in each year was com-
                 puted as the net reduction in the current years
                 tax liability achieved through treating such costs
                 as expenses rather than capital investments.   The
                 dollar value of the tax benefits was considered to
                 be the time value of the deferred tax liability dis-
                 counted at 6.5 percent over an average period of
                 12. 5 years.  The discount rate used reflects a
                 ronsej:yative_estimate of cost borrowing while the
                 cutoff point (12. 5 years) reflects an estimated
                 amortization period, were costs capitalized.

                 State Taxes

                 The impact of state taxes on production costs  was
                 estimated by applying Arkansas  state  tax rates
                 ($0.15 per ton of bauxite.)

      The estimating procedures described above  may be considered
conservative in that they are weighted against understating benefits.
                                 -28-

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       PERCENTAGE DEPLETION.  FOREIGN TAX TREATMENT.
       AND THE TAX TREATMENT OF EXPLORATION AND
       DEVELOPMENT EXPENSES HAVE NEARLY EQUAL  •
       IMPACTS ON THE COST OF PRIMARY ALUMINUM
       PRODUCTION
      The impacts -of applicable taxes and tax benefits on the cost of
 producing bauxite and primary aluminum ingot for the period 1970-
 1972 are shown on Exhibit XII, following this page.  The estimates
 shown cover approximately 70 percent of U. S.  owned bauxite ship-
 ments, and consequently may be expected to be generally represen-
 tative of industry operations.

      The table below summarizes the estimated net after tax reduction
in the cost of producing aluminum ingot in 1972 attiibutable to dis-
criminatory taxes and tax benefits, assuming 4. 0 tons of bauxite ore
are required per ton of aluminum ingot.
                                         Per Ton Basis
                                         $
             Depletion                $1.35         35.5

             Foreign tax credit         0. 78         20. 5

             WHTC                    0.73         19.2
             Exploration and
              development expenses     1.02

             State Taxes               (0.08)
                Total                 $3.80
  As indicated, percentage depletion is the largest single item contri-
  buting to cost reduction, although foreign tax regulations and explora-
  tion and development cost ;ax treatment combined account for about
  67 percent of total cost reduction.  The impact of state taxes as
  might be expected is negligible.

       The largest computed net tax benefit, $4. 36 per ingot ton in
  1970, would be equal to about 0. 9 percent of the current price of
  aluminum ingot ($500 per ton).  On & pretax basis the net tax benefit
  would be $8. 72 per ton, equal to about 1. 8 percent of the price of
  aluminum ingot.

                                  -29-

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                                                                                                                          i.xnmi i  x>i
                                                                                                             IMI'AC'I <•>'• SIJI I (.TEH I'AX) '! .\V|)  r/\x
                                                                                                             ijr.Ni:' irs ON mr COST 01  IMU-III-   .r
                                                                                                              1'RIMAHY ALUMINl.M INC.OT I "70 !!.•  ; •*

US TAX TREATMENT


nEPLETION

TAXES PAID OR DEEMEU
PAID TO FOREIGN GOVERNMENT
WESTERN HEMISPHERL
TPADF CORPORATION (WHTCl
EXPLORATION AND
DEVELOPMENT EXPENSES
STATE TAXES
DOLLARS PER TON ft PERCENT OF PRICE 0
BAUXITE
1972 1971 1970
t X S % S K
0317

0195

0182

OJV)

(00201
2.4-3 «

1420

13-18

182S

01-0.2
0264

0195

0182

0280

(0 020)
1826

1420

13-18

2.028

01-02
0360

0191

0179

0380

(0 020)
2.5-3 6

1413

I.31J

2733

01-02
ALUMINUM INGOT ©
1972 1971 1970
S % S % S K
121-1.35

0 70 0 78

0 664 7}

031 1 02

(007-008)
LESS
THAN 1
LESS
TNANI
LESS
THAN1
LESS
THAN 1
LESS
THAN1
09S10S

0 70-0 78

0 G6-0 73

100-1 12

(007-008)
LESS
THAN1
LESS
THANI
LESS
THAN 1
LESS
THAN 1
LESS
THAN 1
130144

069-076

064472

1 36-1 52

(007-008)
LESS
THANI
LESS
THANI
LESS
THAN 1
LESS
THAN 1
LESS
THAN 1
TOTAL IMPACT @ ©
348
6.895
301
649P
1090
73-103
341-380
LESS
THANI
3.24360
LESS
THAN 1
3324 36
LESS
THAN 1
PRICE LATA FOR BAUXITE AND ALUMINUM INGOT
    BAUXITE     137(1-S10S14 LONG 9RY TON
                1971 - J1C t1'LJ,.G OHV TON
                1972 - SIO $14 LONG DRY TON

    COMPANIES RESPONDING SHOWED AN AVERAGF PRICE
    OF SI3 00 IN 1972. SI300 IN 1971 AND SI2 80 IN 1970 THE S10-S14
    FIGURE COVERS A LARGER PCRCtNTAGE OF PRODUCTION
    ALUMINUM INGOT
                      1972  SO 26 IB
                      1971  SO 25 IB
                      1970  SO 27 IB
TOTAL IMPACT DOES NOT INCLUDE SIMILAR BENEFITS THAT MAY BE DERIVED FROM
CARBON. CRYOLITE OR ALUMINUM FLUORIDE. SUCH BENEFITS ARE NOT MATERIAL.
BENEFITS ASSOCIATED WITH THE EXCLUSION OF GROSS UP ON DIVIDENDS
OF LESS DEVELOPED COUNTRY CORPORATIONS AND WITH THE EXCLUSION
OF CONTROLLCU FOIIEILN SUBSIUIAKIFS WCIIt NOT FOJNU TO BC MATERIAL
                                                                             MATERIAL REQUIREMENTS FOR ONE TON OF ALUMINUM INGOT
36 -4 0 TONS OF BAUXITE
 6     TONS OF BAKED CARBON
 D3    TONS OF CRYOLITE
 04    TONS OF ALUMINUM FLUORIDE
*  Note   Impacts arc shown on an after tax basis
                                                                              APPROXIMATELY 70KOF US-OWNED BAUXITE SHIPMENTS ARE
                                                                              COVERED IN THIS EXHIBIT
NOTt  WHILE DATA USED IN THESE EXHIBITS WERE OBTAINED FROM
RELIABLE SOURCES. THE SCOPE OF THE BOOZ. ALLEN ASSIGNMENT
DID NOT INCLUDE AN AUDIT OR INDEPENDENT VERIFICATION OF
Tiirsr DATA
                                                                   29-a

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 5.    THE INFLUENCE OF DIFFERENTIAL TAXATION ON RAW
      MATERIALS USE MUST BE EVALUATED IN LIGHT OF
      INDUSTRY CHARACTERISTICS AND THE CURRENT
      INDUSTRY SITUATION
      As indicated previously in this chapter, the technology of
primary aluminum production limits the substitution of aluminum
scrap for primary raw materials in the primary aluminum produc-
tion process.  In the marketplace, however, secondary aluminum
may be substituted for primary aluminum.  Approximately 20 per-
cent of the aluminum consumed by the casting industry, the major
consumer of secondary aluminum, is supplied by primary producers.
This market, which in total is equal  to about 13 percent of secondary
production, provides the greatest potential for increasing secondary
producers' share of total output.

      Lesser potential exists, in the near term  at least, for substi-
tuting secondary aluminum in uses traditionally limited to primary
aluminum.  The primary barrier to substitution,  ovher than avail-
ability,  is provided by the fact that the alloy content and purity of
primary aluminum required for many uses cannot economically be
duplicated in secondary aluminum production.  Nevertheless,  some
substitutability undoubtedly does exist although its extent  has not
been investigated within the scope of this study.
      (1)   There Are Several Factors Currently Favorable
           to Prospects for Expanded Secondary Aluminum
           Production
           There are several elements of the current economic
     and energy situations which appear to be favorable to expanded
     secondary aluminum production:
                Primary aluminum processes arp highly energy
                intensive which make both current output and
                new capacity sensitive to energy shortages and
                costs.
                      25 percent or more of primary aluminum
                      ingot costs are accounted for by electrical
                      energy
                                -30-

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                 Significant expansion of domestic aluminum
                 production will require concurrent availability
                 of electric power generating capacity

                 Primary aluminum output has recently been
                 adversely affected by electric power shortages,
                 especially in the Pacific Northwest

            Secondary aluminum production, on a per unit basis,
            requires less than 10 percent of the energy consumed
            in primary production.

            At the present time, worldwide aluminum capacity,
            with some energy constrained exceptions, is vir-
            tually fully in use. Capacity must be expanded in
            the near term.  Secondary capacity, on an equiva-
            lent tonnage basis, requires slightly more than 10
            percent of the capital required for primary capacity
            and can be developed more rapidly.

            The Arab oil embargo has fostered concern regard-
            ing the potential export policies of bauxite and
            alumina  exporting countries most  of which are in
            the LDC category. While no overt actions have
            been taken, the possibility of action raises a new
            element  of risk regarding the accessibility and cost
            of raw materials.
      These factors may be viewed both singly and in combina-
tion as favorable to an expanded role for secondary aluminum
production.
(2)    Both Price Levels and Price Stability WiR Affect
      Prospects for the Increased Use of Aluminum Scrap
      At the present time,  available prompt industrial aluminum
scrap is virtually fully committed,  either 1o domestic or export
markets.  Thus,  the only source of additional market supplies
is post-consumer waste.  This scrap component is the most costly
to use due to the costs associated with scrap separation, con-
centration and transportation.  The extent to which the market
supply of scrap from this source will expand is a function of
the price of scrap and price stability,
                           -31-

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      The current aluminum scrap and secondary aluminum
 price situation is peculiar as domestic secondary aluminum
 producers are faced with a shortage of scrap.  This situation
 has resulted from the following influences:
            Worldwide aluminum prices, reflecting surging
            demand, have increased by more than 50 percent
            over 1972 levels.  This magnitude of increase
            has been applicable to both primary and secondary
            aluminum.

            Domestic primary and secondary aluminum prices,
            which are controlled, are currently about 20 percent
            lower than world prices.

            Aluminum scrap prices move very closely with
            secondary aluminum prices.  As a consequence,
            export scrap demand has caused scrap prices
            which are not controlled to increase to the point
            where domestic secondary producers cannot
            profitably compete for incremental  scrap
            supplies.
      Were price controls on aluminum to be removed, domestic
aluminum prices would undoubtedly adjust to eliminate this situa-
tion.  At the present time,  the situation can be described as
positive from the point of view of expansion of the market supply
of scrap but negative in terms of domestic secondary producer
market access and capacity expansion.  Assuming that alumi-
num prices are decontrolled, however, the outlook for in-
creased secondary aluminum production should be favorable.

      The volatility of the price of aluminum scrap presents a
risk related barrier to the investment in collection and separa-
tion equipment needed to  increase the market supply of old
aluminum scrap in the long run.   The degree of price volitility
can be seen in the behavior of the price of aluminum clippings
between 1969 and 1971.  In 1969,  with strong demand, prices
reached $295 per ton while, by the end of 1£71, reflecting
slack demand, prices had decreased by $145 per ton or 50
percent.  Similar volitility in terms of price increases has
been demonstrated during the recent demand surge. A large
component of the volitility of aluminum scrap prices is

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      directly attributable to the volitility of alumirum ingot prices
      on world markets.  Thus, a sharp change in the quantity of alumi-
      num demanded in the marketplace will be reflected in aluminum
      prices and in turn in scrap prices.  As a consequence, stabiliza-
      tion of scrap prices would require stabilization of  aluminum
      capacity and demand relationships into a reasonably predictable
      pattern, something  which has never been achieved.  At the
      present time, demand for aluminum has exceeded  or is on the
      verge of exceeding worldwide production capacity.  A cyclical
      downturn in  future demand could, however, send prices into a
      downward spiral.

            Significant expansion of secondary production in the long
      run,  then, may require that some mechanism be developed to
      accommodate the risks associated with scrap price instability.
      One such mechanism could be developed through the  establish-
      ment of municipal reclamation centers which would provide
      aluminum scrap to dealers at adjustable prices designed  to pro-
      vide  them with a reasonable profit in the face of fluctuating
      market prices.   The feasibility of this type of arrangement
      would depend, of course, on the expected net cost  to munici-
      palities or regional governments in relation \o the costs  of other
      disposal alternatives such as land fill, The basis  for such an
      arrangement would involve internalizing disposal costs not now
      reflected in  the cost and price of scrap.

            Stabilizing the market supply of post consumer aluminum
      scrap and internalizing disposal costs, which may permit the base
      market price of scrap to  be reduced,  could provide the basis for
      increasing the share of aluminum output by secondary producers.
      This is applicable both to general scrap and aluminum cans.

            Whether such an arrangement is practical will depend,  as
      indicated above,  on the relative net cost of reclamation as
      opposed to alternative disposal options.
7.    TAX TREATMENT EQUALIZATION MAY HAVE SOME
      MARGINAL IMPACT ON RELATIVE USE OF ALUMINUM SCRAP
      If the tax treatment of primary and secondary materials is
equalized by providing equivalent benefits to scrap processors , the
aluminum scrap supply curve will shift but the shape of the
supply curve will not be altered.  The degree to which the supply
curve shifts, as well as its shape, will determine the amount of
                                 -33-

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 additional scrap to be placed on the market at any given price.  The
 greater the slope of the supply curve, the larger will be the incre-
 mental market supply of scrap.

      The relatively small changes in the market supply of scrap
 accompanying very large changes in price suggests that the short run
 supply curve is relatively flat (i. e.,  supply is relatively inelastic to
 price) and that, consequently,  only marginal changes in the market
 supply of scrap would result from tax treatment equalization.

      Of more importance,  however, is the shape of the long run scrap
 supply curve.  The shape of this curve is not known; however, the
 following observations are possible:
                 The shape of the supply curve will depend in the
                 long run on marginal cost of scrap, which will
                 include a risk component related to price
                 instability.

                 Tax treatment equalization, because scrap price
                 instability is related to product demand patterns,
                 will have at best a marginal price stabilizing
                 influence.

                 If the long run marginal cost of scrap includes a
                 substantial risk component, it is likely that the
                 long run supply curve would be flat and the supply
                 impact of tax equalization marginal.   If,  on the
                 other hand,  the municipal reclamation program
                 were adopted, the risk would be minimized  and the
                 slope of the  long run supply curve steepened which
                 would cause tax equalization or any reduction  in net
                 cost to have a greater  impact or. market  supplies.

                 The long run marginal cost of scrap,  exclusive of
                 risk,  is also of paramount importance in assessing
                 impacts. The magnitude of such costs in relation to
                 the benefits  provided by tax equalization  will be a
                 key determinant ol changes in the market supply of
                 scrap.  Such costs are not,  however,  known.
      The short and the long run demand curves for snrap must also be
considered in evaluating the impact of tar equalization. The shape and
location of the short run scrap demand curve is determined by the
                                 -34-

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 short run demand curve for secondary aluminum ingot, but becomes
 vertical when the point on the curve is reached which represents
 limits of current secondary aluminum smelter and remelt furnace
 capacity.  At the present time, as noted above,  price controls have
 created a domestic scrap shortage.  In a free market, however, it
 is probable that secondary smelters would be operating at close to
 capacity thus allowing for minimal,  if any,  short run impact of tax
 equalization.

      The long run demand curve for aluminum scrap is dominated
 by several elements:
                 The long run aluminum ingot demand curve

                 The relative cost of scrap vs. primary raw
                 materials

                 The substitutability of scrap for primary materials
                 in end product applications
      An increase in the cost of virgin materials relative to secondary
materials would cause the demand curve to shift to the right thus
theoretically increasing the quantity of scrap demanded at any given
price.  The extent of the shift will be controlled by the relative change
in the cost of scrap vs. secondary materials and the degree that scrap
may be substituted for primary materials in end uses.  The degree of
substitutability is limited given the present state of the art,  as has
been pointed out previously.  In the long run, however,  technological
change may permit increased substitutions.

      In the short run, then, the impact on scrap demand of any tax
equalization  action which increases the cost of virgin raw material
is likely to be minimal,  The long run consequences of such an action
will depend on aluminum ingot demand as well as cost and technological
factors  described above which cannot be evaluated within the scope of
this study.

      The impact of tax equalization on scrap consumption both in the
short and  the long run depends  on both the supply and  demand factors
discussed above.
      The following chapter addresses the impact of discriminatory
taxation on the pulp and paper industry.
                               -35-

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                 IV.  THE PULP AND PAPER INDUSTRY
      This chapter addresses the impact of discriminatory taxes and
 tax benefits on the relative use of virgin and secondary materials in
 the pulp and paper industry.
 1.    PULP AND PAPER PRODUCTS MADE FROM VIRGIN AND
      SECONDARY MATERIALS COMPETE IN THE MARKET PLACE
      Pulp and paper products made from virgin and secondary materials
are substitutable for the most part in the market place.  Accordingly,
the point at which virgin and secondary materials are subject to substitu-
tion is in the final product stage (e.g., combination box board is a sub-
stitute for folding box board produced from virgin materials) for purposes
of this analysis.  It  should be pointed out, however, that secondary fibre
may be substituted for virgin  fibre to a limited degree during processing.

      The specific pulp and paper  products selected for analysis in this
study were newsprint and paperboard (folding box board).  Both of these
products are produced from virgin and secondary materials and compete
in the market place.  Although the specific properties of products pro-
duced from virgin and secondary materials  differ,  in some cases signi-
ficantly, they are mutually substitutable in many end uses.
2.    CAPITAL GAINS TREATMENT OF TIMBER PROFITS IS THE
      BASIS FOR DISCRIMINATORY TAXATION IN THE PRODUCTION
      OF PULP AND PAPER
      As discussed in Chapter II,  timber operators are allowed to
treat profits from the cutting and sale of timber as capital gains.
This  option,  which is not available to secondary fibre collectors and
dealers, effectively reduced the net cost of harvesting timber for use
in the manufacture of pulp and paper.  The net cost reduction or tax
benefit associated with the capital gains option is measured as the net
reduction in a timber operators tax liability in comparison with the tax
liability had timber harvesting profits been treated as ordinary income.

      There are special  state and  local taxes applicable to timber lands
which are not assessed at. any stage of secondary fibre collection and use.
Because of the diverse nature of these taxes, some of which provide
                                 -36-

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 incentives,  some disincentives, no attempt was made to quantify them.
The analysis of discriminatory taxation in the production of pulp and
paper is focused entirely on the capital gains option.
 3.    THE IMPACT OF THE CAPITAL GAINS OPTION WAS
      COMPUTED FOR THE MANUFACTURE OF NEWSPRINT
      AND PAPERBOARD
      The impact of the capital gains option on unit output costs was
 computed at the following pulp and paper processing stages:
                 Roundwood - timber after harvesting

                 Groundwood pulp and newsprint

                 Chemical woodpulp and paperboard
      Timber operations of pulp and paper producers accounting for
approximately 56 percent of domestic production were analyzed for the
period 1970-1972.  The analytical data base used was primarily that
provided by producer published financial and statistical  data and
copies of Form 10 K on file with the Securities and Exchange Commission.
Data available in the public files of the Internal Revenue Service proved to be
of limited value due to the level of data aggregation.  Individual com-
pany tax returns could not be and were not reviewed.

      Producers contacted were unwilling to make available specific
information beyond that available publicly. Producers did, however,
provide assistance in interpreting data published by them, i'n confirm-
ing the validity and  reasonableness of data adjustments made, in quanti-
fying materials conversion ratios (quantities of raw materials required
to produce a final product) and in providing independent confirmation of
product price levels.
                               -37-

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  (1)   Raw Materials Conversion Ratios Were Developed
       for Newsprint and Paperboard Manufacturing
       To provide a basis for assessing the capital gains benefit
  on a unit of output basis at each major production step, the
  following materials conversion ratios were used:
    Product

 Groundwood
   Pulp

 Chemical
   Wbodpulp

 Newsprint
 Folding
   Boxboard
        Input

1. 0 cords* Round wood


1. 6 cords Roundwood
1. 0 tons Groundwood
        Pulp

1.0 tons Chemical
        Woodpulp
      Output

1.0 tons Groundwood
        Pulp

1. 0 tons Chemical
        Woodpulp

1. 0 tons Newsprint
1.0 tons Folding
        Boxboard
 * One cord equals approximately 1. 2 tons
** Newsprint normally is produced using 75-80% groundwood and
   20-25% semi bleached chemical fiber; however, the ratio of 1.1
  is sufficiently accurate for this analysis.


       Detailed process flow diagrams for manufacturing news-
 print and paperboard are provided in Appendix A to this report.


 (2)    Dollar Capital Gains Benefits  Per Unit of Timber
       Harvested Were Computed for the Years 1970  - 1973
       Capital gains benefits per unit of timber harvested were
 computed for those producers included in the  study. Data re-
 garding specific timber plots or the ultimate usage of specific
 timber harvested, were not available. Accordingly, it was
 necessary to use aggregate annual data regarding timber har-
 vested for each producer analyzed.

       Similarly, producers contacted were unwilling to make
 capital gains data available regarding specific timber lands and
 were unable because of the multiple uses of timber cut in a given
 location to provide capital gains data relating  to timber harvested
                            -38-

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for use specifically in manufacturing pulp and paper.  Because of
these data limitations, it was necessary to make use of aggregate
capital gains data covering all timber operations.

      To isolate capital gains applicable to timber operations,
those components of total capital gains for each producer analyzed.
which  were  allocable to non-timber operations (real estate, secur-
ities investment, special items, etc.) were identified and appro-
priate adjustments made.  Producers contacted during the study
were particularly helpful in confirming the reasonableness of these
adjustments.

      The tax benefit associated with the capital gains option was
estimated by computing the tax liability for capital gains at the 30
percent capital gains rate and the 48 percent corporate  rate for
ordinary income.  The difference in the tax liabilities so derived
was considered to be the measure of the capital gains tax benefit.
The aggregate annual capital gains benefit computed for each pro-
ducer  analyzed was divided by the total amount of timber harvested
to provide an estimate of the capital gains benefit on a per unit
basis.
(3)   The Impact of Capital Gains Benefits Was Estimated
      at Each Major Production Stage for Newsprint and
      Paperboard
      The raw materials conversion ratios discussed above were
applied to the capital gains benefits computed for harvested
timber to provide an estimate of the value of such benefits in
relation to the following intermediate and final products:
           Unbleached groundwood pulp

           Chemical woodpulp

           Newsprint

           Folding boxboard
      The values of the capital gains benefits have been computed
in terms of dollars per ton and as a percentage of the prevailing
                           -39-

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prices of the above products.  Dollar benefits and the relation-
ship of benefits to prevailing prices in each case are displayed
as a low-high range with the limits of the range defined as follows:
            The low end of the range represents the lowest
            per unit benefit computed in each year among the
            producers analyzed as applied to the highest price
            shown for the product of interest

            The high end of the range represents the largest
            per unit benefit computed among the producers
            analysed applied to the lowest price shown for the
            product of interest
(4)   The Methodology Used in Computing Capital Gains
      Benefits and the Available Data Base Have
      Limitations Which Must Be Recognized
      As discussed above,  capital gains benefits per unit of
timber harvested were computed on the basis of all timber har-
vested by the producers analyzed. Thus,  the benefits derived
represent an average of benefits derived from timber cut for
all uses including lumber.  Because trees cut for lumber are
normally several years older than those cut for pulp and paper
and have a higher value,  it is probable that the estimates of
capital gains benefits derived overstate to some extent the benefits
applicable to wood used in producing pulp and paper.

      The capital gains benefits computed  for timber harvested
during 1971 are effectively reduced by capital losses claimed
during that year resulting from various circumstances including
losses on real estate operations.  Available data, including that
gathered by direct producer contacts, did  not permit adjustments
for capital losses on non-timber operations to be made. Accord-
ingly, indicated 1971 capital gains benefits should not be regarded
as representative of normal operations. Producer contacts did
confirm, however,  that the impact of capital losses would have
no material effect on benefits computed for timber harvested
during 1970 and 1972.
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4.    THE IMPACT OF CAPITAL GAINS TAX BENEFITS VARIES
      DEPENDING ON THE GRADE AND QUALITY OF THE FINAL
      PRODUCT AND THE DOLLAR VALUE OF COMPUTED
      CAPITAL GAINS
      Exhibit XIII,  following this page,  contains estimates of capital
gains tax benefits for the years 1970 - 1972.

      As indicated on the Exhibit the magnitude of computed tax bene-
fits in relation to product prices varies widely.  The table below sum-
marizes the magnitude of capital gains benefits in relation to pulp and
paper product prices for the years 1970 and 1972:

                                          After Tax Benefit as
                                               % of  Price
                                           1970           1972
      Groundwood Pulp                  0. 8 - 2. 2       0.6-1.6
      Chemical Pulp                     0.8-1.8       0.6-1.1
      Newsprint                         0.5-1.0           *
      Folding Boxboard and
       Paperboard                      0. 7 - 2. 4       0. 5 - 1. 6

Figures for 1971  have  not been included in the table as the effect of
capital losses,  discussed above, make them non- representative.  The
variations in the magnitude of benefits shown result from two factors:
                   Differences in computed tax benefits

                   Differences in product prices
  Differences in product prices are most significant for paperboard.
  Depending on product grade and quality, the price of paperboard may
  vary by as  much as $60 per ton (1972).  For the other products
  analyzed, the primary differential in the magnitude of capital gains
  benefits in  relation tc price is caused by the range of the dollar
  values of computed capital gains.

        It should be noted that the relationships shown on Exhibit XIII
  and the above table have been developed on an after tax basis.
  Thus, if capital gains benefits were removed, producers at each
  stage of production, assuming no substitution, would require price
  increases of approximately double  the amounts and percentages
                                 -41-

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                                                                                                                                    EXHIBIT XIII

                                                                                                                          IMPACT OF SELECTED TAXES AND
                                                                                                                    TAX BENEFITS ON THE COST OF PRODUCING
                                                                                                                             PULP AND PAPER 1970-1972
                                                                     DOLLARS PER TON AND PERCENT OF PRICE
1972
1971
1970
U. S. Tax
Treatment
Capital Gains
Total Impact
Capital Gains
Total Impact
Capital Gains
Total Impact
Roundwood
($ per Cord)
$
High
1. 14
1. 14
0.32
0.32
1.55
l.!)5
$
Low
0.54
0.54
0.15
0.15
0.73
0. V3
Unbleached Groundwood
Pulp (1) (2)
$
High
1.14
1. 14
0.32
0.32
1.55
1.55
$
Low
0.54
0.54
0.15
0.15
0.73
0.73
% %
Range
0.6 = 1.6
0.6 - 1.6
Less than 1
Less than 1
0.8 - 2. 2
0.8-2.2
Newsprint (1)
$
High
1. 14
1. 14
0.32
1.55
1.55
$
Low
0.54
0.54
0.15
0.73
0.73
% %
Range
Less than 1
Less than 1
Less than 1
Less than 1
0.5-1.0
0. 5 - 1.0
Chemical
Woodpulp (1)(3)
$
High
1.82
1.82
0.51
0.51
2.48
2.48
$
Low
0.86
0.86
0.24
0.24
1. 17
I. 17
% %
Range
0.6-1.1
0.6 - 1. 1
Less than I
Less than 1
0.8-1.8
0.8-1.8
Folding Boxboard
and Paperboard
$
High
1.82
1.82
0.51
0.51
2.48
2.48
S
Low
0.86
0.86
0.24
0.24
1. 17
1. 17
% %
Range
0.5-1.6
0.5-1.6
Less than 1
Less than 1
0.7-2.4
0.7-2.4
                                                                                   Price Per Ton
U)      Groundwood Pulp (-inbleached)
        Newap' 'lit
        Ground wood Pulp (bleached!
        Chemical pulp (including suLfate, sulfite.  bleached.
          unbleached, or semi-bleached
        Paperboard including folding box board
        Nn'.e:  Price depends upon quality and location
1972
72 - 88
164
91 -102
145-154
115-175
1971
72 - 88
154
80 -100
145-165
108-174
1970
72 - 88
151
80 -100
139-162
105- 168
(2)      Material requirement for groundwood pulp used for newsprint
          1. 0 cords of pulpwood for 1. 0 tons of ground wood pulp
(3)      Material requirements and yield factors for one ton of chemical
        pulo used for kraft vary depending on a variety of factors.  This
        exhibit assumes 1.6 cords of roundwood. Also required: waste
        papers and other fibers,  sulfur, chlorine, sodium hydroxide.
        sodium sulfate,  lime and other chemicals
This exhibit covers approximately 56% of total
paper produced in the U. S.
(4)     The data for 1971 reflect investment losses which effectively reduced
       capital gains from timber operations.


Note:   While data were obtained from reliable sources, the scope of
        the Booz. Allen assignment did not include an audit or independent
       verification of these data.

Note:    Impacts are shown on an after-tax basis
                                                                                41-a

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shown to restore after tax profits to levels achieved with capital
gains benefits in force. For the lowest priced paperboard indicated,
for example, price increases of $3. 64 per ton or 3. 2 percent would
be required to bring after tax profits up to achieved  1972 levels, in
the absence of capital gains benefits. A price increase of only one
percent for high value  paperboard products would be required to
restore 1972 profits to levels actually achieved.  This assumes,
of course,  that increased net costs are passed through all produc-
tion stages to the consumer.

      The probable effect of capital gains benefits on pulp and paper
processors' raw materials choices is discussed below.
5.    THE IMPACT OF TAX TREATMENT EQUALIZATION ON
      RAW MATERIALS CHOICES WILL DEPEND ON SEVERAL
      SHORT AND LONG RUN VARIABLES WHICH INFLUENCE
      RELATIVE COSTS
      The influence of capital gains benefits on pulp and paper pro-
ducers' decisions to use virgin raw materials as opposed to second-
ary raw materials must be considered in the light of basic production
economics and the current industry situation.  These factors are dis-
cussed in detail below.
      (1)   Demand for Pulp and Paper Products is Balanced
           With Production Capacity
           During the 1960 "s, capacity to produce pulp, paper, and
      paperboard chronically exceeded demand, leading to low prices,
      underutilized capacity,  and low producer rates of return on
      investment.  During 1971,  industry profitability was at its
      lowest point since 1938, with profits averaging 2. 3% of sales
      and returns on stockholders equity averaging 4. 8%.  In 1972,
      reflecting sharply increased demand and firmer prices, profit
      margins increased to about 3. 8% of sales, and return on stock-
      holders equity  rose to about 8.5%.
                               -42-

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      At the present time,  demand in almost all product classi-
 fications is becoming balanced with production capacity with pro-
 ducer backlogs increasing monthly.  This situation is expected
 to continue,  at least for the next few years, because additional
 production capacity is not being installed at a rate sufficient to
 meet anticipated demand.  This lack of capacity development
 results from the following factors:
            Return on investment,  including that for 1972,  has
            not been sufficient to justify new capacity.

            Significant investments--an estimated $1.6 billion
            for the 1971-74 period are currently being under-
            taken for pollution control.  At the present time,
            the ability of the industry to attract significant
            additional capital for capacity expansion is limited.

            Producers, in light of the experience of the 1960's,
            are reviewing  capacity expansion plans with great
            caution to avoid the development of future excess
            capacity problems.

            Major capacity additions take about three years to
            bring on stream.  Thus commitments to expansion
            made currently will not have any near-term impact
            on output.

      Given current and anticipated capacity and demand relation-
ships and the absence of price controls, it is probable that rates
of return will increase to a point that would make new capacity
attractive.  Capital  requirements for pollution control will
probably remain  a factor,  however, limiting capacity expansion
into  1978, since development of 1978 capacity must begin by
1975--in less than two years.

      Current indications are that capacity will expand by about
3% per year through 1975 which provides some margin for
potential growth in wastepaper usage.
                           -43-

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(2)   Despite Logistical Barriers, Use of Secondary Fibres
      in Existing Pulp and Paper Plants Appears to Be
      Increasing
      Pulp and paper plants currently in existence are located
primarily in rural areas,  in proximity to virgin material
sources of supply.  The rural location of these plants puts
them far from large waste paper sources which are in large
densely populated urban areas creating logistical and cost bar-
riers to the maintenance of a steady flow of secondary fibres.

      Wastepaper originating in the converting segment of the
paper and paperboard industry is virtually 100% recovered at
the present time.  The recovery rate from commercial as
opposed to manufacturing sources (primarily used boxes and
cartons) although not known with precision has potential for
increase.

      The largest potential source of wastepaper recovery is
municipal waste.  The logistics of collecting and separating waste
in sufficient quantities to make recovery economical in the past
minimized recovery increases.  Ongoing activities for recovery
of such waste have taken place in the  production of secondary
newsprint and corrugated boxes in locations where available
supplies are sufficient to make secondary materials  use economical.

      The potential for increased usage of secondary fibres from
commercial sources is not known with precision at this time.  The
general practice currently prevailing is for users of boxes and
cartons to contract for disposal with private collectors who nor-
mally do not attempt any recycling. While the logistical barriers
discussed above would  apply in a somewhat more limited sense
to the increased use of secondary fibres from  commercial
sources, there are encouraging signs.  The American Paper
Institute has estimated that the use of old corrugated boxes may
increase by as much as 34% over the next three years.

      Recent developments indicate that the use of secondary
fibres in existing plants is increasing,  although the extent of the
increase is not clear.  Two major factors appear to account for
this increase:

           A developing shortage of virgin fibres related not to
           a shortage of wood, but to difficulties and costs of
           obtaining labor for lumbering operations.
                            -44-

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            The lower capital costs and shorter lead times
            required to expand secondary production.

            The energy shortage, which has made secondary
            fibres more attractive as their use appears to re-
            quire less energy than do virgin fibres.
 In essence, the above factors appear in combination to have
 altered the relative cost of using virgin and secondary mater-
 ials in some applications, especially paperboard manufacturing.
 The extent of the substitution will depend ultimately on the incre-
 mental costs of obtaining additional volumes of wastepaper in
 relation to the increased  cost of obtaining and using virgin fibres.
 (3)   The Market Supply of Secondary' Fibres Appears to Be
      Relatively Insensitive to Price in the Short Term
       The quantity of wastepaper generated from all sources
in any given time period is directly related to the quantity of paper
produced in that period.  Paper and paperboard are non-durable
products, thus the opportunity to recycle waste from prior years'
production, as, for example,  with metal scrap, does not exist.
In periods of rapidly increasing paper output, therefore, prices
for wastepaper tend to increase sharply,  as supplies from
accessable industrial and commercial sources tend to lag demand.
Conversely, when output growth tails off, wastepaper prices tend to
decline sharply in the face of excess market supplies.  Since only
a relatively small proportion of the wastepaper entering the  solid
waste is recycled,  wastepaper price behavior in  the face of
relatively small changes in consumption suggests that the short
run marginal cost of recycling additional proportions of the waste-
paper supply is high. This is supported by the fact that additional
recycling would require use of wastepaper from the commercial
and post consumer  waste  streams which,  as indicated previously,
are higher cost sources.

       Exhibit XIV,  following this page, compares consumption
and price behavior for wood pulp and wastepaper.  The  volitility
of wastepaper prices, reflecting the factors discussed above is
clearly evident.  From  1969 to 1971,  wastepaper prices declined
by 19. 3% reflecting sluggish paper  demand.  As paper demand
grew rapidly in 1972, wastepaper prices increased by 19. 7%.

      Reported wood pulp prices on the other hand have demonstrated
significant historical stability which indicates that market supplies
have been significantly more  responsive to demand than is the case

                            -45-

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Source: Consumption indices computed from American Paper Institute data

        Price indices—Bureau of Labor Statistics. Wholesale Price Index
                                                                                                                         EXHIBIT XIV
                                                                                                                  WOOD PULP AND WASTEPAPER
                                                                                                                 CONSUMPTION AND PRICE INDICES
                                                                                                                            1964 - 1972
Wood Pulp
Consumption

Year
1972
1971
1970
1969
1988
1967
1966
1965
1964

Index
126.2
119.5
116.8
1)8.9
111.6
100.0
99.7
91.9
86. 8
% Change
From Prior
Year
+ 5. 6
+ 2.3
- 1.8
^ 6.5
+ 11.6
+ 0.3
+ 8.5
+ 5.9
N/A
Wood Pulp
Prices
Wastepaper
Consumption
% Change
From Prior
Index
111.1
112.0
109.5
100.0
100.0
100.0
100.0
100.1
98.1
Year
-1.0
+2.3
+9.5
0.0
0.0
0.0
-0. 1
+2.0
N/A
Index
115.8
113.1
110.3
110.3
103.7
100.0
99.1
95.3
91.6
% Change
From Prior
Year
42.4
+2.5
0.0
+6.4
+3.7
+1.0
+4.0
+4.0
N/A
Wastepaper
Prices

Index
133.9
111.9
124.9
138.7
130.0
100.0
134.4
127.3
118.3
% Change
From Prior
Year
+19.7
-10.4
- 9.4
+ 6.7
+30.0
-25.6
+ 5.6
+ 7.6
N/A
                                                             45-a

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 with wastepaper both in the short and the long run.  As
 indicated previously, however, a shortage of wood pulp has
 developed due to labor  and energy factors. It is too early
 to judge, however, whether the factors causing the  short-
 age are of a temporary or a long term nature.

      The volatile nature of wastepaper prices is further demon-
 strated by the range of price fluctuation within given years as
 indicated on Exhibits XV and XVI following this page.  The
 pattern of fluctuations tends  to highlight the short term mar-
 ket supply rigidity discussed above.

      In the short run (1-2 years), therefore,  it is probable
 that tax treatment equalization would cause secondary fibre
 use to  increase only marginally, if at all.
 (4)   The Long Run Responsiveness of the Market Supply
      oT Wastepaper to Cost/Price Changes Depends on
      Several Indeterminate Factors
      If the cost of making wastepaper available in the market
place were to decrease, the quantity offered for sale at any
price should increase over the long run.  Similarly, if the cost
of using virgin fibre were to increase relative to the cost of
using secondary fibre,  the price producers would be willing to
pay for any given quantity of wastepaper should increase pro-
portionately.  The magnitude of demand and or market supply
expansion will depend both on the change in relative cost/
price relationships, the long run marginal cost of recycling
additional wastepaper and the degree to which available technology
permits the substitution of wastepaper for virgin fibre.

      As is the case with all scrap, the long run marginal cost
of recycling additional wastepaper probably has a significant
risk component related to market instability. The development
of municipal or regional reclamation, as discussed in Chapter III
could provide a means of risk accommodation. This,  in turn,
could reduce the marginal cost of recycling causing the market
supply of wastepaper to become more responsive to price.
Other elements of marginal cost are also major determinants
of the long run wastepaper supply function.  Such costs, however,
are indeterminate at this time.
                          -46-

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                                                EXHIBIT XV

                                         YEARLY PRICE CHANGES FOR
                                            NO. 1 WASTE NEWSPRINT
                                                    1968 - 1973
                                                  (dollars per ton)
Year
1973
1972
1971
1970
1969
1968
Low
Price
$17.00
17.80
16.30
16.69
18.90
19.81
High
Price
$26.00
21.50
20.59
19.89
23.20
24.89
Price Changes
(Low-High)
$9.00
3.70
4.29
3.20
4.30
5.08
Source: Derived from data supplied by the
        Bureau of Labor Statistics
                            46-a

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                                               EXHIBIT XVI
                                        YEARLY PRICE CHANGES
                                           FOR WASTE, PAPER
                                               1968-1973
                                            (dollars per ton)
Year
1973
1972
1971
1970
1969
1968
Low
Price
• $24.69
23.04
19.34
20.02
25.20
18.17
High
Price
$42.53
25.68
22.99
25.63
26.29
27.13
Price Changes
(Low-High)
$17.84
2.64
3.65
5.61
1.09
8.96
Source: Derived from data supplied by the
        Bureau of Labor Statistics
                        46-b

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      Concerning technological barriers to substitution, the
following situation exists.
            Wastepaper can be used for up to 100% of materials
            inputs for newsprint* semi-chemical pulp and com-
            bination board

            Limits for kraft paper range from 5% to 25%
            depending on type

            For office,  communications, and printing papers,
            limits range from 10% to 80% depending on product
            type and grade
      Within the limits of current technology, then,  potential
for increased use of wastepaper through substitution does exist.
The major long term barrier to substitution, subject to the
technological limitations discussed above, is cost.
(5)   The Impact of Tax Treatment Equalization on Relative
      Materials Use in the Long Run Is Indeterminate
      On a pretax basis, the relative change in the cost/price
relationship of virgin materials and wastepaper used in news-
print manufacturing,  using the highest computed capital gain
benefit, would be $3.  10 ($1. 55 x 2--see Exhibit XIII) per  ton in
favor of wastepaper.  with the  capital gains benefit removed.

      In the production of paperboard, the cost /price advantage
accruing to wastepaper would  be $4. 96 before taxes ($2. 48 x 2--
see Exhibit XIII) using the highest computed capital gains benefit.

      The impact of a change in relative cost/price relationships
of the order indicated above on long run relative materials usage
cannot be quantified as the long run marginal cost of recycling
wastepaper is not known.

      It is probable that some substitution will occur; however,
the degree of substitution will be limited by both out-of-pocket
and risk related marginal costs of recycling.
      The following chapter discusses the impact of discrimina-
tory taxation on the glass industry.
                            -47-

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                       V.  THE GLASS INDUSTRY
      This chapter addresses the impact of discriminatory taxes and
tax benefits on the relative use of virgin and secondary materials
in the production of glass.
1.    SCRAP GLASS, KNOWN AS GULLET. MA Y BE SUBSTITUTED
      FOR VIRGIN RAW MATERIALS IN THE PRODUCTION OF GLASS
      Cleaned and sorted cullet may be substituted for virgin raw
materials in the production of glass.   If the cullet used is compatible
in color and composition with the glass it is used to make, the final
product would be indistinguishable from glass produced using virgin
raw materials in characteristics and end use.

      The substitutability of cullet for virgin raw materials, primarily
sand, is limited in generally prevailing production processes by the
requirement for cullet of like color and composition.  The Glass Con-
tainer Manufacturers Institute estimates that about 13% of glass cur-
rently produced is cullet based.  However, the cullet used is virtually
all generated within the glass producing process. With the exception
of color and composition requirements, there are no significant
process constraints to substantial substitution of cullet for virgin
materials in the manufacture of glass.
2.    THE PERCENTAGE DEPLETION ALLOWANCE PROVIDES
      THE BASIS FOR DISCRIMINATORY TAX BENEFITS
      APPLICABLE TO THE PRODUCTION OF GLASS
      The basis for discriminatory tax benefits applicable to the
production of glass from virgin raw materials is provided by the
percentage depletion allowance which may be applied to the mining
of sand.  There are no taxes or tax benefits  applicable to secondary
materials processing which are not likewise applicable to virgin
raw materials process

      There are state taxes applicable to sand mining and mine
exploration and development cost may be treated as expenses for
                                -48-

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tax purposes,  however, the impact of these tax elements was found
to be so minor as to not war rent specific consideration.
3.    THE IMPACT OF THE PERCENTAGE DEPLETION ALLOWANCE
      ON THE COST OF PRODUCING SAND WAS COMPUTED
      The impact of percentage depletion on production costs for
sand and glass was computed.  The analytical procedures used in
preparing the computations are described below.
      (1)   Raw-Material Conversion Ratios Were Developed
           for Glass Production
           To provide a basis for estimating the percentage depletion
     impact in terms of units of output, the following material input
     relationship's per ton of glass produced were developed:

                Material                 Quantity
                                         (pounds)

                Sand                       1.299
                Soda Ash                     426
                Feldspar                     157
                Limestone                   358
                Gullet                       200
           The above malenal input relationships were developed
     from published data and confirmed by industry sources.  The
     input mix shown is  representative of that used in making bottle
     quality glass.

           Detailed analysis of tax effects was confined to sand.
     Preliminary estimates of the impact of percentage depletion
     tax benefits on the cost of limestone,  soda ash, and feldspar
     per ton of glass  were as follows:
                 While limestone and soda ash, which is a derivative
                 of limestone account for 32% by  weight of material
                                -49-

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             inputs per ton of glass, the maximum possible tax
             benefit per ton of glass attributable to the percent-
             age depletion allowance benefit available to limestone
             producers is $0. 015 after taxes and $0.03 before taxes
             based upon estimates for limestone contained in
             Chapter VI.

             For 1970, the average per ton value of feldspar ship-
             ments was  $13. 28.  If it is  asnumed that this price
             represented the cutoff price for computing percentage
             depletion, then the maximum amount of depletion
             claimed would be $1.86 per ton without regard to the
             50% limitation.   The total tax shelter provided by
             percentage depletion would  be $0.89 per ton of feld-
             spar or $0. 07 per ton of glass. The net percentage
             depletion tax benefit per ton of glass representing
             the difference between percentage and cost depletion
             net tax effects, while not computed due to lack of cost
             depletion data would, of course,  be less than 0. 07 per
             ton.  Since the computed percentage depletion benefits
             applicable to limestone and feldspar which are sub-
             stantially overstated represent less than 0. 5 percent
             (one-half of one percent) of the price per ton of bottle
             quality glass, no further attempts at refinement were
             considered warranted.
(2)    The Dollar Impact of Percentage Depletion Per
      Ton of Sand and Glass Produced Was Computed
      For the Period 1970-1972
      The impact of percentage depletion on the cost of producing
glass and sand was computed for the years 1970-1972. The analy-
sis covered producers accounting for approximately 10 percent
of domestic glass quality sand output.  The procedures used in
preparing the impact estimates were as follows:
           Production statistics for glass quality sand were
           obtained from producers

           The amount of cost depletion claimed annually by
           each producer was estimated on the basis of deple-
           tion entries on SEC Form 10K.
                           -50-

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                 Percentage depletion was computed by applying
                 the allowable percentage depletion rate for glass
                 quality sand mined by each producer annually
                 times cut off prices  supplied by producers.

                 The excess of percentage depletion over cost de-
                 pletion was derived by subtracting estimated cost
                 depletion from estimated percentage depletion.

                 The depletion tax benefit was computed by multiply-
                 ing the excess of percentage depletion over cost by
                 0.48.

                 To evaluate the impact of the 50 percent limitation
                 on percentage depletion (see Chapter II) which
                 would not be reflected in the above computations
                 a separate estimate of the reduction in each pro-
                 ducer's tax liability attributable to depletion was
                 developed using a process of elimination. Essen-
                 tially,  reductions in taxes payable attributable to
                 all non-depletion items were estimated with the
                 balance considered to be attributable to depletion.
                 Data sources  included SEC filings, notes to finan-
                 cial statements,  and other available data.

                 Estimated tax benefits derived using both above
                 methods were compared and the lesser indicated
                 benefit was used for  subsequent analysis
           It should be noted that the above estimating procedures
      may be expected to overstate rather than understate the tax
      benefit associated with the percentage depletion allowance as
      procedures for assessing the impact of the 50% depletion
      limitation were applied conservatively so as to understate
      rather than overstate potential tax benefit reductions.
4.    DEPLETION TAX BENEFITS PROBABLY HAVE ONLY A
      MARGINAL IMPACT ON PRODUCER MATERIALS CHOICES
      The estimated impact of the percentage depletion allowance on
the cost of producing sand and glass is shown on Exhibit XVII, follow-
ing this page.  On an after  tax basis, the maximum computed
                                 -51-

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                                                                                                                            EXHIBIT XVU

                                                                                                           IMPACT OF THE PERCENTAGE DEPLETIO.V
                                                                                                           ALLOWANCE ON THE COST OF PRODUCING
                                                                                                                    SAND AND GLASS 1970-1972
(IS TAX TREATMENT

DEPLETION
DOLLARS PER TOM & PErJCEMT C? PRICE ©
GIASS DUAL!!1- "4 3
is;?
S ! -,
017 51
1P7*.
S 1 1
0.17 | 51
:S79
! *
017 I SI
GLASS ©
1972
S
Oil
K
LESS THAN 1
1271
S I X
Oil LESS THAN 1
1370
$ X
0.11 LESS THAN 1
     PniCE DATA
 SAND $3 31 PER TON
 CLASS SU79-S15'.8PERTUM
 THIS EXHIBIT '.OVERS APPROXIMATELY 10% OF TOTAL GLASS-
 QUALITY SAND MINED IN THE U S
 NOTE. WHILE DATA WERE OBTAINED FROM RELIABLE SOURCES.
 THE SCOPE OF THE BOOZ. ALLEN ASSIGNMENT DID NOT INCLUDE
 AN AUDIT OR IHIOEPEM3EMT VERIFICATION OF THESE DATA.
»»"=RAGE MATERIAL REQUIREMENTS FOR ONE TON OF
GLASS (BOTTLE DUALITY)
        SAND
        SODA ASH
        FELDSPAR
        LIMESTONE
        CULLET
1.299    LBS.
 426    LBS.
 157    LBS.
 353    LBS.
 200    LBS.
OTHER MATERIALS (POTASSIUM, MAGNESIUM) MAY BE
ADDED. DEPENDING UPON QUALITY.
SOURCE  BOOZ. ALLEN 8 HAMILTON. INC
                                                                                                   Imparts jro &hnwn on :in s.ftrr-l.-i\ Uasis,
                                                             51-a

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percentage depletion benefit is $0.17 per ton for sand and $0.11 per
ton for glass.  If computed benefits applicable to limestone, soda ash
and feldspar, which admittedly are substantially overstated, are
included the  percentage depletion benefit would be approximately
$0.19 per ton after taxes and $0. 38 per ton before taxes.  Total
benefits  would be equal to approximately 1. 2% of the price of glass
after taxes and 2. 5% before taxes.

      Industrial source cullet is currently almost fully recovered.
Additional cullet use could require cullet recovery from post-
consumer waste, primarily from glass in bottles.  While  bottle
recovery for cullet is in limited practice, the  economies of collec-
tion, separation and transportation are unfavorable.   While precise
quantitative data are not available, it can be stated that an adjust-
ment of relative materials costs  up to a maximum of $0. 38 per ton
in favor  of cullet would likely be  insufficient to offset high collection,
separation and transportation costs.

      Were municipalities or regional governments to absorb collec-
tion and  separation costs in reclamation centers,  the economies of
recycling could potentially be improved.  The impact of such practices
on cullet usage will depend on the costs involved,  which are not known
at this time.
       The following chapter discusses the impact of discriminatory
taxation on the steel industry.
                                 -52-

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                      VI.  THE STEEL INDUSTRY
      This chapter presents findings and conclusions regarding the
impact of discriminatory taxes and tax benefits on the relative use
of virgin and secondary materials in the manufacturing of steel.
 1.    STEEL SCRAP MAY BE SUBSTITUTED FOR VIRGIN
      RAW MATERIALS IN THE STEELMAKING FURNACE
      In the manufacture of steel from virgin raw materials, coke,
iron ore,  and limestone are charges into a blast furnace to produce pig
iron which is in turn treated in a steel making furnace to produce
steel.  Steel scrap may be substituted for pig iron in the steelmaking
furnace.  Accordingly,  it may be said that steel scrap and pig iron
produced  from virgin materials are functionally equivalent at the
raw steelmaking stage of production. For most uses, steel produced
from scrap is indistinguishable from steel produced from virgin raw
materials.

      Limitations on the substitutability of scrap for pig iron are
related to the type of steelmaking process used.  The limitations
connected with each of the three primary steel making processes
are summarized briefly below:

                 The basic oxygen process is currently the most
                 widely used  steelmaking process accounting for
                 56 percent of 1972 raw steel production.  Current
                 practice limits scrap usage to 30 percent of the
                 basic  oxygen furnace (EOF) charge, the balance of
                 the charge being molten pig iron.  Scrap usage in
                 BOF's could be increased by installing facilities
                 to preheat scrap prior to charging the furnace.

                 The electric furnace which accounced for about
                 18 percent of 1972 raw steel output is designed
                 to accept a 100 percent scrap charge.
                                 -53-

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                 The open hearth furnace which is being rapidly
                 displaced by the basic oxygen furnace is normally
                 charged with about 44 percent scrap.  This method
                 of steelmaking, however, is expected to decrease
                 rapidly in use.
      THERE ARE SEVERAL ELEMENTS OF TAXATION
      APPLICABLE TO THE PRODUCTION OF VIRGIN RAW
      MATERIALS USED IN STEELMAKING WHICH ARE NOT
      APPLICABLE TO THE COLLECTION AND MARKETING
      OF STEEL SCRAP
     As indicated above, the virgin raw materials used in steel-
making are iron ore. coal (coke) and limestone.  There are several
elements of taxation applicable to the production of these materials
which are not applicable to the collection and marketing of steel
scrap.   These are summarized below:
                Iron Ore
                      The percentage depletion allowance

                      Tax treatment of mine exploration and
                      development costs

                      The foreign tax credit

                      Mineral related state taxes

                Coal

                      The percentage depletion allowance

                      Tax treatment of mine exploration and
                      development costs

                      Mineral related state taxes
                                  -54-

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                 Limestone

                       The percentage depletion allowance
There are no taxes or tax benefits applicable to the collection
and marketing of steel scrap which are not also applicable to
virgin raw material production.  The nature and applicability
of the taxes and tax benefits identified above are discussed in
Chapter II.
3.    THE COST IMPACT OF APPLICABLE TAXES AND
      TAX INCENTIVES WAS COMPUTED FOR THE
      MANUFACTURING OF RAW STEEL
      Virgin raw material used in manufacturing steel are produced
by both non-integrated raw material suppliers and integrated steel
producers.  To isolate any impact differentials possibly related to differ-
ing degrees  of integration,  impacts were separately computed cover-
ing the following production stages:
                 Non-integrated production of iron ore

                 Non-integrated production of coal

                 Integrated steel production including:

                      Iron ore, coal, and limestone production
                      by integrated producers

                      Raw steel production
      (1)   Raw Materials Conversion Ratios Were Developed
           for Steelmaking
           To provide a basis for developing estimates of tax
                              -55-

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impacts on a unit of output basis, the following raw material
inputs per ton of steel produced were used:

           Material                  Quantity
                                        (tons)

           Iron Ore                    1. 20
           Coal                        0.60
           Limestone                   0. 18
           Steel scrap                  0. 45

These input quantities represent a weighted average of
material currently used in open hearth and basic oxygen
furnaces*  Material usage in electric furnace steelrnaking
was excluded from consideration as virgin raw materials
are not used to any significant degree with this process.
(2)   Estimates Were Prepared of the Impacts of Applicable
      Taxes and Tax Benefits on the Cost of Iron Ore Produc-
      tion by Non-Integrated Mining Companies for the Period
      1970 -  1972
      The impact of applicable taxes and tax benefits on the
cost of iron ore production for the period 1970 - 1972 was
computed for U. S. producers accounting for approximately
34 percent of non-integrated iron ore output.  Specific taxes
and tax benefits included in  the analysis were  percentage
depletion, tax treatment of exploration and development expenses
and state taxes. The procedures used in preparing the impact
estimates are described below:
           Percentage Depletion

           Tax benefits associated with the excess of per-
           centage depletion over cost depletion were com-
           puted as follows:

                 Annual iron ore production quantities  were
                 obtained from producers
                         -56-

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      The amount of cost depletion claimed
      annually by each producer was estimated
      on the basis of depletion entries on SEC
      Form 10K.

      Percentage depletion was computed by apply-
      ing the allowable percentage depletion rate
      for iron ore mined by each producer annually
      times cut  off prices  supplied by producers.

      The excess of percentage depletion over
      cost depletion was derived by subtracting
      estimated cost depletion from estimated
      percentage depletion.

      The depletion tax benefit was computed by
      multiplying the excess  of percentage deple-
      tion over cost by 0. 48.

      To evaluate the impact of the 50 percent limit-
      ation on percentage depletion (see Chapter
      II) which would not be reflected in the above
      computations, a separate estimate of the
      reduction in each producer's tax liability
      attributable to depletion was developed using
      a process  of elimination.  Essentially, re-
      ductions in taxes payable attributable to all
      non-depletion items were estimated with the
      balance  considered to be attributable to
      depletion.   Data sources included SEC
      filings, and notes to financial statements,
      supplemented in some cases by data made
      available by producers.

      Estimated tax benefits  derived using both
      above methods were  compared and the lesser
      indicated benefit was used for subsequent
      analysis

It should be noted that the above estimating pro-
cedures may be  expected to overstate rather than
understate the tax benefit associated with the percen-
tage depletion allowance  as procedures used to
              -57-

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           estimate the impact on benefits of the 50%
           depletion limitation were applied conservatively
           to ensure against overstating the reduction in
           benefits attributable to the limitation.

           Tax Treatment of Exploration and Development
           Costs

           Benefits associated with the expensing of mine
           exploration and development costs were  estimated
           on the basis of data made available by producers
           and analysis of expense accounts on producers'
           financial statements.  Adjustments were made
           where required to isolate development expenses
           attributable to mining activities.  The basis for
           estimating the tax benefit in each year was com-
           puted as the net reduction in the current year's
           tax liability achieved through treating such costs
           as expenses rather than capital investments.

           The dollar value of the tax benefits was considered
           to be the time value of the deferred tax liability
           discounted at 8. 5 percent over an average period
           of 12.5 years.

           State Taxes

           The impact of state taxes on production costs was
           estimated by applying state tax rates to iron ore
           production values and /or quantities by geographic
           source.  The discount rate used represents a
           conservative estimate of the cost of borrowing
           while the time period used (12. 5 years) repre-
           sents an amortization period were expenditures
           capitalized.

(3)    The Impact of Applicable Tax Benefits on the Cost
      of Metallurgical  Grade Coal Production Was
      Computed for Non-Integrated Producers
      The tax benefits provided by the percentage depletion
allowance and the expensing of mine exploration and develop-
ment costs were computed for non-integrated coal producers
accounting for 20 percent of domestic metallurgical grade
coal production. "The period covered was 1970-1972.
Analytical procedures used were the same as those used in
the analysis of non-integrated iron ore production.
                         -58-

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(4)   The Impact of Applicable Taxes and Tax
      Benefits on the Cost of Integrated Raw Steel
      Production Was Separately Estimated
      Separate estimates were prepared of the impact of
applicable taxes and tax benefits on the cost of integrated
steel production for the period 1970-1972.  Estimates were
based on data covering producers accounting for about 54
percent of domestic steel shipments.  Analytical procedures
used were as follows:
           The Percentage Depletion Allowance

                 Domestic depletion benefits for coal,
                 limestone and iron ore were computed
                 on the basis of aggregated proprietary
                 tax data provided by several producers.

                 Foreign depletion tax benefits applicable to
                 iron ore for which data was not made  avail-
                 able by producers was estimated using the
                 procedures described above for non-integrated
                 iron ore production

           The Foreign Tax Credit

           Tax benefits associated with foreign tax credits
           applicable to iron ore mining operations were
           estimated as follows:

                 Revenues from foreign operations and for-
                 eign taxes paid were obtained from producer
                 financial  statements, SEC filings and,  to a
                 limited extent, from direct producer contacts.

                 Estimates were developed on the basis of
                 foreign iron ore production statistics and
                 iron ore cut-off prices supplied by producers
                 of that portion of total foreign revenues
                 attributable to iron ore mining operations.
                        -59-

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      Foreign taxes paid were estimated on the
      basis of the assumption that the share of
      total foreign taxes paid in a given year attri-
      butable to iron ore mining operations was
      proportional to the share of total foreign
      revenues attributable to such operations

      The foreign taxes paid  were assumed to
      be fully creditable against U. S. taxes

      The tax benefit associated with the foreign
      tax credit was estimated as 48  percent of
      the foreign tax credit taken (equal to foreign
      taxes paid). This represents the differential
      in tax liability resulting from the treatment
      of foreign taxes paid as a tax credit rather
      than  as a deduction.

Tax Treatment of Mine Exploration and
Development Costs

Exploration and development expenses were esti-
mated in aggregate for all integrated producer
mining operations as disaggregated data were not
available.  Estimating procedures used were
the same as those described previously for non-
integrated  iron ore and coal mining.

State Taxes
State Taxes applicable to integrated iron ore mining
were estimated using the same procedures as described
for non-integrated iron ore mining.  The impact of
state taxes on the unit cost of coal and limestone
production were evaluated and found not to be
material.
              -60-

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4.    THE PERCENTAGE DEPLETION ALLOWANCE IS THE MOST
      SIGNIFICANT TAX BENEFIT INFLUENCING THE COST OF
      NON-INTEGRATED IRON ORE PRODUCTION
      Exhibit XVIII, following this page, summarizes the impact of
applicable taxes and tax benefits on the cost of non-integrated iron
ore production over the period 1970-1973.  The range indicated in
each year represents the highest and lowest computed impacts for
those producers analyzed.

      Variations in computed depletion benefits can be attributed
to the influence of the 50 percent limitation (see Chapter II) on per-
centage depletion .which is in turn influenced by producers' profit-
ability.  The benefits associated with exploration and development
expenses will vary from producer to producer and from year to year
depending on the level of exploration and development activity.  The
costs attributable to state taxes vary depending on the location of
mines and, in some cases, the grade and type of iron ore produced.

      The range of computed tax impacts per ton of iron ore for
1972 is  summarized below.

                              High	       	Low
     Depletion           $0.66    113.8       $0.20    87.0
     Exploration and
     Development
     Expenses            0.10     17.2        0.08     34.8

     State Taxes          (0.18)   (31.0)      (0.05)   (21.8)
         Total           $0.58   100.0       $0.23    100.0
    The percentage depletion allowance has clearly the overriding
influence on production costs.  It may be said that state taxes and
the benefits of expensing exploration and development costs are
mutually offsetting in most cases.  (See Exhibit XVIII for 1970,  '71
data).
                                 -61-

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                                                                                                 EXHIBIT XVIII

                                                                            IMPACT OF SELECTED TAXES AND TAX INCENTIVES
                                                                          ON COST OF NON INTEGRATED IRON ORE  PRODUCTION
                                                                                                    1970-1972
U S TAXll'EATr/ENT

DflFTlCN
EX'IORATIC'I AND DEVELOPMENT
E/r -:ES
S1AIE IAVCS
DOLLARS PER TON 8 PERCENT OF IRON DIE PRICE ©
1972
s s s •• %
HIGH
055
CIO
(0181
MEDIAN
C27
009
(Oil)
IC.V
070
Ol'J
19 Oil
PAHCE
1 159
LESS
THAN 1
ILSS
THA'. 1
1971
S S S S *
HIGH
037
020
1021)
'.•ECIAN
027
013
10 IS)
LOW
on
010
10061
RANGE
0632
0618
LESS
THA1I
1970
: s s % »
IUGH
ICO
CM
(013)
VEOIAN
028
Oil
1009)
LOW
016
009
100)1
RANGE
0393
0513
021.2
                                                                                    s r.
10TAI IIJK'.Cr O'i3
02S 1 023
1 2 1 2 1 0 35
02S 015 1 0132
101 1 0 30
021
1.294
PRICE DATA FOR mm CUE
DCiis.snc
IRON ORE -NATURAL $
IRON ORE -PIUETS
NOTE THE PRICE OF NATURAL
OF THE ORE
THE PRICE Or PELLETS IS HIGI
OF A'JDItlONAL PREPARATION
THCIt ADDITIONAL COSTS ARI
1972
11 17 '2 82
1778
1911
II 42 12 7:
1775
19)0
KC1120I
16 '1C
1971
9S8
II 17
FOȣICH
IS7I 1970
398 993 •
11 17 1080
IRON ORE DEPENDS ON THE SOURCE AND CHEVICAl STRUCTURE
Efl THAN THAT OF NATURAL IRON ORE BECAUSE
COSTS TO OETIRVIME CROSS INCOVE FOR DEPLETION
INCLUUIO IN THE -F C S ""IE VALUE 'PRICE USED
OC'JEflTS ASSOCIATED WITH THE CAPITAL GAINS TREATMENT OF ROYALTIES OH IRON
WtHE EVA'.UAfFO AND WERE HOT FOUND TO BE MATERIAL
 ni'  nun r n/\rn M-.I i< m n,i >,F r 'n-nis1 nir nurAii:[i< rnc'.i in i I/.CIE
    .l^ nir i'.in't L>I  fin MI il/ AiiiN ASsiu'i-Eni uinrj'jT iMCLUUt A>:
                      rApiirr niv :I«IA
                                                                                APPROXIMATELY 3!KOF RON ORE MINED BY NOH
                                                                                INTEGRATED U S COMPANIES IS COVERED BY THIS
                                                                                EXHIBIT
                                                                                     •:  li ;.  c I  ci:c sli.i-
                                               61-a

-------
 5.    PERCENTAGE DEPLETION AND THE TAX TREATMENT
      ALLOWED FOR EXPLORATION AND DEVELOPMENT COSTS
      HAVE NEARLY EQUAL IMPACTS ON THE COST OF NON-
      INTEGRATED METALLURGICAL GRADE COAL PRODUCTION
      Exhibit XDC,  following this page, summarizes the impact of
percentage depletion and the tax treatment allowed for exploration
and development expenses on the cost  of non-integrated metalurgi-
cal grade coal production for the period 1970-1972. The  range of
impacts indicated in each year results from the following:
                • The operation of the 50 percent percentage
                 depletion limitation (see Chapter II) which
                 varies with profitability

                 The level of exploration and development
                 activity in each year by each producer
      As indicated on the Exhibit,  percentage depletion accounts for
the largest share of total impact, up to 70 percent in 1972 (low),
however,  in some cases, notably 1970 and 1971,  depending on the
behavior of the variables identified above,  the impact of tax trest-
ment allowed for exploration and development costs  nearly equals
that of percentage depletion.

      The maximum computed total tax benefit in any year is $0. 48
per ton in 1971 while the lowest computed benefit is  $0. 16 per ton
also in 1971.  The net cost reductions attributable to these benefits
were equal to  1.4 -4.0 percent of the 1971 price per ton of metal-
lurgical grade coal on an after tax basis.
6.    THE PERCENTAGE DEPLETION ALLOWANCE IS THE
      PRIMARY FACTOR INFLUENCING THE IMPACT OF
      APPLICABLE TAXES AND TAX BENEFITS ON THE
      COST OF INTEGRATED STEELMAKING
      Exhibit XX summarizes the impact of the applicable taxes and
tax benefits on the cost of integrated raw steel production for the
period 1970-1972.   The impacts indicated were computed independently
                              -62-

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                                                                                            EXHIBIT XIX

                                                                      IMPACT OF SELECTED TAX BENEFITS ON THE
                                                                      COST OF INTEGRATED METALLURGICAL COAL
                                                                                      PRODUCTS  1970-1972
U S TAX TREATMENT

DEPLETION
EXPLORATION AND
DEVELOPMENT EXPENSES
TOTAL IMPACT ©

t
HIGH
021
ffl6
037

1972
t
MEDIAN
019
Oil
010

t
LOW
Oil
007
024
OOLI
« *
RANGE
17 IS
OSI2
1227
ARSPERT
S
HIGH
012
01S
048
ON&PERC
1971
S
MEDIAN
021
Oil
012
ENTOFP
S
LOW
009
007
01S
MCE 0
% *
RANGE
0827
0614
1440

S
HIGH
0.20
OIS
016

1970
S
MEDIAN
017
Oil
028

S
LOW
Oil
0.07
OJO

% *
RANGE
1313
0715
1915
(ME
PRICE DATA FOR COAL
TALLURGICAL GRADE COAL)
rEAR PRICE
1972
1971
|57(l
S 1178
S 11 71
S 1017
SHORT TON
SHORT TON
SHORT TON
                                       o
APPROXIMATELY 20KOF THE METALLURGICAL GRADE
COAL MINED IN THE UNITED STATES IS COVERED BY
THIS EXHIBIT
NOTE WHILE DATA WERE OBTAINED FROM RELIABLE
SOURCES. THE SCOPE OF THE BOOZ. ALLEN
ASSIGNMENT 010 NOT INCLUDE AN AUDIT OR
INDEPENDENT VERIFICATION OF THESE DATA.
    BENEFITS ASSOCIATEDW1TH THE CAPITAL GAINS TREATMENT OF ROYALTIES ON COAL.WITH THE 5-YEAR AMORTIZATION OF
    COAL MINE SAFETY EOUIPVENT AND WITH THE PARTIAL EXEMPTION OF EXPORT INCOME (DISC) WERE EVALUATED AND
    WERE NOT FOUND TO BE -lAUdlAl
®
    STATE TAXES (PRINCIPALLY WEST VIRGINIA). AND LOCAL TAXES. (PRINCIPALLY COMMUNITIES
    IN WEST VIRGINIA) WERE EVALUATED AND NOT FOUND TO BE MATERIAL
   SOURCE  BOOZ ALLEN ft HAMILTON INC
                                     Note:  Impacts are shown on an after-tax basis

                                                    62-a

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                                                                                                                                    EXHIBIT XX

                                                                                                              IMPACT OF SELECTED TAXES AND TAX BENEFITS ON
                                                                                                              THE COST OF INTEGRATED  RAW STEEL PRODUCTION
                                                                                                                                       1&70-1972



0!. 11 .'I Bl'ltSTT
F'jHlKj'!
At'll'S.Lt
TA- •" 1 .-. U(l """SI!
Ft M , '!• . .• u1 IV IMj
I- .'.•!. ..-..• ®
..'1 •'.' I- I/ C .MS
SI ". • 'IS
DOLLARS PER TON & PERCENT OF PRICF
IPOKORE
1112 1371 1970
'. 7
•,.'
2M
•. i 57
', ' i '
1' 1 j
S
M
,.;
•71
i H8
5055
*S J
; in
i
1 Ijii
1 7
171 It
19
OJ1
5i?
/3i
1 JiJ
4*49
4310
2525

IIS2I
CCAL
1972 1971 1970
.23

"1
23
...
S.«2


33


4 VI



4 J



LIVESTONE
1972 1971. 1170
024
.._

M



024


ii



QJ5



24



RAWSTEEl ®
1972 1971 MN~
904
255
275
(192)
12
IESS
1HAH1
USS
THAN 1
IESS
IMA1: i
Kl
325
2(1
'2171
14
LESS
1HAII 1
LESS
THAN 1
USS
THAN 1
.924
341
29)
1112)
14
ITSS
IHAN 1
LESS
THAN 1
LESS
IHAN 1

; ii .. o


i
I













1 I2S2
17
1347
195
1371
209
O
C T 1 i i El UArORIIIIMOIf CUAI L—'SIR'.E A"D 1AVJ STEEL
I",'?
1' ,\0"l DI •.".>TT.I'JAH1HAIV S IIII1M7
1' pltl.t It iLIL'IINAlUHAll ?'li
11 M 13)6
l-'ESiniE 1 70
P /S'ttLirOSTI M07
1471
II 4211 S7
9 'U
1171
IS2
U"!
1910
1010 1095
991
1037
1 65
(573

        A.V.R.
       '(Mill
M'O'I PRTUIOf 2 THE AUGCAI.'J I OF CX»LORATIOM
•I'.T ExPLnsisrosPECini. TA  • ATERIALS
O
     I   It.ISA  HC.IArEOV.lJHW'brEflNHfl'.r'Hi IT TRADE CU.II"jnATIONi IV.IITCI.
     I   >l '  :i  I '  l"IOf '-'IVII ".nSOF I" 511' /Fl'llLDCOUTIlPY COUPOHATIOTIS
                II' H't I  ll»l I..M  .11" If I '. I U' hklAl III 1 IJI! I'J.VL A1H IM'JN
               I It I   II  I1.  ' U  l.ftL
                                                        ©
AVCPACE QUANTITIES OF 'IATEPIAIS CONSUMED IN TMI
VA-l'J'ACTUnE • OF ONE TO'I OF HWtSIEEL WEIGHTED AVERAGE)
1972
ma-JucE "NET IONS) 120
CCAI I'.t 1 TO'ISI SI
LIVCS'ir.E IMTTOMSI II
SCdAPrjET TONS) 44
1971
120
5»
II
4S
1970
170
SI
11
44
•OUtS NOT INCLUDE ELECTRIC FURNACE
NHTT V.'IILE DATA I'SED IN THESE EXHI9HS KAS OBTAINED FROM PELIASLE
SOU'fC[S THE SCOPE Of TIIEOOOZ ALLEN ASSIGNMENT DIO NOT INCLUDE AN
AULIi UP IN'JtrrJCE'lT VERIFICATION OF THESE DATA
                                                            Note:  Impacts are indicated on an after-tax basis
                                                                                          62-b
                                                                                                                                                APPROXIMATELY 54X OF U S STEEL SHIPMENTS ARE

-------
  of those shown for non-integrated iron ore and coal production.
  Because much of the data used in preparing the analysis was supplied
  on an aggregated basis by an industry source average impact rather
  than ranges are shown.  A comparison of the estimates developed for
  integrated production with those developed for non-integrated iron
  ore and coal production indicates, however, that the estimates pre-
  pared for integrated production fall generally within the range of
  those developed for non-integrated production.

       The impact of the applicable taxes and tax benefits (after-tax
  basis) on the cost of raw steel production is summarized below.
                         1972            1971              1970
                               %        $      %

 Depletion           $.904    72.2    $.958    71.1

 Foreign Tax Credit   .265    21.3     .325    24.1

 Tax Treatment of     .275    22.0     .281    20.9
                                     t
 Exploration and
 Development Costs

 State Taxes         (.192)   (15.4)   (.217)  (16.1)     (.182)   (13.2)

    Total           $1.252   100.0  $1.347   100.0    $1.377    100.0


As is apparent,  the percentage depletion allowance has the greatest
impact on costs amounting to about  70 percent of the net after tax
benefit per ton of raw steel produced.  Regarding the cost impact of
all tax benefits, the following are pertinent:
                 The highest computed impact,  $1. 377 per ton of
                 raw steel for 1970,  represents approximately 2.1%
                 of the cost of producing raw steel.   For finished
                 steel the impact would be equal to $1. 969 per ton,
                 assuming that 1. 43 tons of raw steel are required
                 to produce a ton of finished steel.  This would be
                 equal to about 0. 9% of current average finished
                 steel prices  ($228 per ton).

                 On a pre-tax basis, the impacts cited above would
                 be equal to $2.87 per raw steel ton, or about  4. 4%
                 of estimated 1970 raw steel production costs.   For
                 finished steel, the pre-tax impact would be $4.10
                 per ton, or about  1. 8% of current finished steel
                 prices.

                                 -63-

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 (1)   Low Cost Scrap Sources Are Almost Fully Utilized
      To obtain an understanding of the market for steel scrap,
 it is necessary to understand the three basic sources of scrap.
            Steel Mills--Between the production of steel ingot and
            the production of finished steel mill products,  about
            30% of the volume of ingot steel produced becomes
            scrap. In general,  steel mills are configured to
            recycle such scrap internally. Scrap of this type
            is referred to as "home scrap. " Home scrap is
            the least costly of steel scrap, for obvious reasons,
            and is, for practical purposes, 100% recycled.

            Steel Fabricators--Steel scrap is also generated in
            the production of products containing steel,  such
            as automobiles, appliances,  and  machinery.  This
            scrap is referred to as "prompt industrial scrap".
            Prompt industrial scrap is usually purchased by
            steel producers either  through scrap processors
            or directly from the scrap producers.  Most scrap
            from this source is currently recycled.

            Post-Consumer Scrap--Discarded products containing
            steel are the third source of scrap.  Specific products
            include automobiles, appliances, ships, machinery
            and containers. Appliances and containers are usually
            a part of the municipal  solid waste system.  Automo-
            biles  can move through several avenues such as from
            the owner to the wreckers or to scrap processors for
            sale through broker to steel producer.  Heavy mach-
            inery or ships generally move directly from owner
            to scrap processor.  Substantial quantities of readily
            accessable post-consumer scrap are currently
            recycled.
      Because of the above factors, increased demand for scrap
will have to be met through recovery from scrap sources which
are difficult and costly to use.
                           -64-

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 (2)   The Current Volatility of Scrap Prices Presents a
      Major Barrier to Its Increased Use
      Relatively minor changes in the demand for scrap are
 accompanied by very large fluctuations in the price paid by
 producers for scrap.  During the period from June  1972 to
 June 1973, the price of No. 1 heavy melting scrap increased
 from $35. 20 per ton to $55. 00 per ton, or 56 percent.  Over
 this period then,  the raw materials  cost of producing raw
 steel in electric furnaces, using 100% purchased scrap, has
 increased by approximately $19. 80 per ton before taxes and
 $9. 90 after taxes.  During the past five years the price of
 No.  1 heavy melting scrap has fluctuated an average of $9. 93
 per ton annually from  low to high, with a minimum annual
 fluctuation of $7. 83 per ton in 1968.
(3)   Virgin Raw Material Markets Are Significantly
      More Stable Than Scrap Markets
      Vertical integration into the extraction of iron ore, coal,
and limestone is common among the major domestic steel pro-
ducers.  About 70% of the iron ore consumed by U. S. producers
is produced domestically, with the balance imported, primarily
from  Canada and Venezuela. The coal and limestone consumed
in making steel is  produced domestically.

      The practice of vertical integration and the stability of
supply from the mines result in a  relatively stable producer
cost of raw materials with cost/price changes occurring grad-
ually  over time in  a manner that is somewhat easily forecasted.
Thus  virgin material users  are insulated from  the large short-
term  price fluctuations found by purchasers of  scrap.  Inte-
grated companies  also have  substantial investments in virgin
raw materials sources which will  act to  limit the degree to
which scrap will be substituted for virgin materials.
                           -65-

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(4)   There Are No Major Technological Barriers to
      Increased Scrap Usage
      The greatest potential for future increased scrap
usage in steelmaking lies in the development of new electric
furnace capacity.  As indicated previously, electric furnaces
can use up to 100% scrap.   Basic oxygen furnaces can accom-
modate small percentage increases in scrap usage without
modification.

      Additional scrap supplies, derived primarily from
post-consumer waste, would contain greater amounts of
impurities than scrap presently used.  If such scrap repre-
sented a relatively minor proportion of total furnace input,
however, the additional impurities could be handled in the
manufacture of inexpensive steels without extensive techno-
logical change.
(5)   Tax Treatment Equalization May Cause Some
      Marginal Increase in Scrap Usage
      At the present time, about 18% of steel output is
accounted for by electric furnaces consuming scrap. Any
change in relative materials costs in favor of scrap would
tend to make electric furnace production more attractive.
Some limited increase in scrap utilization in other steel-
making processes may also be expected,  subject to the
technological limitations mentioned above.

      During 1973, a scrap shortage  developed as export
buyers outbid domestic  purchasers for available supplies.
This situation developed as foreign steel prices increased
at a much faster rate than domestic prices which are sub-
ject to price controls.  With a return to a free market,
this situation should correct itself.  While the domestic-
foreign price imbalance exists, however, scrap for
domestic producers should remain in short supply,  subject
of course to the extension of scrap export limitations.

      In the long run, the degree to which scrap utilization
increases will depend on the marginal cost of bringing
additional quantities of scrap into the market place.  Such
                        -66-

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costs will undoubtedly include some discounting of market
risk. Definitive statements as to the effectiveness of tax
treatment equalization are not possible as neither the short
nor the  long run marginal costs of additional scrap are
known.  As indicated in preceding chapters,  however, the
establishment of mechanisms such as municipal reclama-
tion  centers, if they prove feasible, can provide a means
of accommodating market risk.
       The following chapter discusses the impact of dis-
 criminatory taxation on the rubber and plastics industries.
                       -67-

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         VII.  THE RUBBER AND PLASTICS INDUSTRIES
      This chapter addresses the impact of discriminatory taxation
 on the relative use of virgin and secondary materials in the produc-
 tion of rubber and plastics.
 1.    THE SUBSTITUTABILITY OF SECONDARY MATERIALS
      FOR VIRGIN RAW MATERIALS IN THE MANUFACTURE
      OF RUBBER AND PLASTICS IS LIMITED
      Both rubber (synthetic rubber) and plastics are petrochemical
based.  The basic materials used in producing both products are
crude petroleum and natural gas.  For both rubber and plastics the
substitution of secondary materials for virgin raw materials in the
production process is extremely limited under present industry prac-
tices.
      (1)   Reclaimed Rubber is a Substitute for Rubber Produced
           From Virgin Materials
           Reclaimed rubber is a substitute for rubber produced from
      virgin materials.  In many uses, the proportion of reclaimed
      rubber which can be used is  limited by product specification
      requirements.  For example, high speed tires (automobile tires)
      may contain only a limited proportion of reclaimed rubber for
      reasons of performance and  safety.  Lower speed tires such as
      those used on farm equipment may contain a higher  percentage
      of reclaimed rubber.  The use of reclaimed  rubber  has been
      declining in recent years for reasons which are discussed in
      following sections of this chapter.
                             -68-

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(2)   The Substitutability of Secondary Plastics For Virgin
      Plastics is Limited
      At the present time, the quantity of plastics which is re-
claimed is insignificant.  Thermosetting plastics may not be
remelted as they are produced by a molecular bonding process
and would be destroyed by heat.  In addition,  it is not possible
to reduce such plastics by chemical means.  Exhibit XXI, following
this page describes uses of the major thermosetting plastics.

      Thermoplastics, described in Exhibit XXII, compose the
bulk of plastics entering the solid waste stream.  Such plastics
may be  remelted and reused.  What remelting does take place,
however, is in practice, largely confined to in-plant scrap for
the following reasons:
             Plastics for remelting must normally be segregated
             by type and grade.  Separation of mixed plastic
             waste has proven to be  impractical using commer-
             cially available techniques.  As an indicator of the
             magnitude of the separation it may be noted that there
             are more than 700 grades  of polyethelene plastics
             alone.

             Degradation of resin properties occurs in the process
             of reclamation.
        Recycling of plastic waste is currently practiced to a
  limited extent.  The processes involved,  however, require that
  the plastic scrap be reprocessed into lower quality plastics for
  uses not  requiring exacting product performance properties.
  Some examples  include the reprocessing  of milk containers for
  use in making soil pipe and the manufacture of novelty items
  from  mixed scrap plastics.  It is apparent, however,  that such
  reprocessing does not produce large volume plastic products.

        For practical purposes thermosetting plastic scrap has no
  virgin raw material counterpart because  of the  limitations on reuse
                          -69-

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                                              EXHIBIT XXI

                                       THERMOSETTING PLASTICS
Type

Alkyds



Arninos



Epoxies



Phenolics
Polyesters
Silicones
Uses

Electrical insulation,  electronic com-
ponents, putty,  glass-reinforce parts,
paints

Molding compounds, adhesives, laminating
resins, paper coating,  textile treatments,
plywood dinnerware,  decorating structures

Laminates, adhesives, flooring,  linings,
propellers, surface coatings, filament-
wound structures (rocket cases)

Impregnating resins,  brake lining, rubber
resins, electrical components, structural
board, laminates, glues, adhesives, binders
molds

Construction,  auto-repair putty,  laminates,
skis, fishing rods, boats and aircraft com-
ponents, coatings,  decorative fixtures

Mold-release agents, rubbers, laminates
encapsulating resins, antifoaming agents,
water-resistant uses
                                    69-a

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                                        EXHIBIT XXII (1)
                                       THERMOPLASTICS
Type

Polycarbonates



Polyamides



Polyurethanes


Polyet.hers


Phenoxies


Polyethylene



Polypropylene
Fluorocarbons
Polyvinyl
Chloride
Uses

Replacement for metals,  safety helmets,
lenses, electrical components,  photographic
film, die casting, insulator

Unlubricated bearings, fibers, gears,  appli-
ances, sutures, fishing lines, tires, watch
straps, packaging bottles

Insulation, foam inner liners for clothing,
coatings, rocket fuel binders, elastomers

Coatings, pump gears, water-meter parts,
bearing surfaces, valves

Surface coats,  adhesives,  binders,  electronic
parts

Packaging films and sheets,  containers, wire
and cable insulation,  pipe, linings,  coatings,
molds, toys, housewares

Housewares, medical equipment (can be
sterilized),  appliances, toys, electronic
components, tubing.and pipe (can be welded),
fibers and filaments, coatings

Electrical insulation, mechanical seals, gas-
kets, linings for chemical equipment,  bear-
ings, frying-pan coatings, cryogenic appli-
cations

Pipe and tubing,  pipe fittings, adhesives,
raincoats and baby pants, building panels,
wastepaper  baskets, weather stripping,
shoes
                                     69-b

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                                          EXHIBIT XXII (2)
Type

Acrylics
Polystyrene
Cellulosics
Furanes
Uses

Decorative and structural panels, massive
glazing domes, automotive lens systems,
illuminated translucent floor tiles, windows
and canopies, signs,  coating, adhesives,
elastomers

Insulation, pipe,  foams, cooling towers,
thin-walled containers, appliances,  rubbers,
automotive instruments and panels

Textile and paper finishes, thickening agents,
magnetic tapes, packaging pipe

Laminates,  coatings, impregnants,  linings
for rocket fuels,  floor tiling,  abrasive
wheels
                                   69-c

-------
      discussed above.  In any event, such plastics account for a
      minor share of plastics entering the solid waste stream.
      Accordingly thermosetting plastics have not been considered
      in subsequent analysis.

           Thermoplastic scrap,  keeping in mind the limitations dis-
      cussed above, may  be regarded as functionally equivalent to
      virgin raw material based thermoplastic resins.
2.    THERE ARE SEVERAL ELEMENTS OF TAXATION APPLICABLE
      TO THE PRODUCTION OF VIRGIN RAW MATERIALS AND IN THE
      MANUFACTURE OF RUBBER AND PLASTICS WHICH ARE NOT
      APPLICABLE TO SCRAP COLLECTION AND REUSE.
      There are no taxes or tax benefits applicable to secondary rubber
and plastics collection and use  which are not applicable to virgin mater-
ials production.   There are,  however, several elements of taxation
unique to the production of petroleum  and natural gas,  the virgin raw
materials from which rubber and plastics are made.  They are as
follows:
                 Regulations providing tax benefits:

                      The percentage depletion allowance on
                      petroleum and natural gas

                      The foreign tax credit

                      Tax treatment of well exploration and dev-
                      elopment costs and intangible drilling costs
                              -70-

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                 Applicable taxes

                       State taxes  on petroleum and natural gas

                       Minimum tax on tax preferences (applic-
                       able to depletion)

                       Tax benefits associated with Western Hemi-
                       sphere Trade Corporations were excluded
                       from direct consideration as WHTC's play
                       only a minor role in the overall extraction
                       of petroleum and natural gas for U.S. con-
                       sumption.


3.    THE IMPACT OF THE APPLICABLE TAXES AND TAX BENEFITS
      ON THE COST OF PRODUCING RUBBER AND PLASTICS HAS
      BEEN COMPUTED
      The impacts of the taxes and tax benefits identified above on the
cost of producing SBR  synthetic rubber and selected plastic resins were
computed for the period 1969-1971.  The plastic resins included in this
analysis were as follows:
                 High and low density polyethelene
                 Polyvinyl chloride
                 Polystyrene
      These resins are in common use and represent a large proportion
of the plastics entering the solid waste stream.

      The primary sources of data used in estimating tax impacts were
as follows:
                 Consolidated tax data covering several major
                 petroleum and natural gas producers provided
                 by the American Petroleum Institute and the
                 Petroleum Industry Research Foundation, Inc.
                             -71-

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                 Published producer financial and production
                 statistics

                 SEC Form 10K

                 U.S. Department of the Interior, Bureau of Mines

                 Selected  tax and statistical data provided by several
                 of the producers of petroleum and natural gas contacted
                 during the study.
      Petroleum and natural gas, and petrochemical producers con-
tacted during the study, for the most part were unwilling to provide
proprietory tax data.   Producers contacted, however,  were quite
helpful in verifying data developed from the sources and developing
material balancing data and production cost flow estimates for the
production of petrochemical feedstocks and plastic  resins.

      The tax analysis performed covers petroleum and natural gas
producers accounting for approximately 60 percent of U.S. outputs.

      The analytical procedures used in preparing the  impact estimates
are described below.
      (1)   Materials Cost Flow Estimates Were Prepared For the
           Production of Synthetic Rubber and Plastics
           The dollar amounts of raw materials costs in the unit prices
      of selected  plastic resins and SBR rubber were computed to pro-
      vide a basis for estimating tax impacts on intermediate and final
      products.  Cost/price flows were developed for the feedstocks
      most commonly used in producing the plastic resins of interest
      and SBR rubber.  The cost/price components estimated at  each
      stage of production were materials, utilities, labor, overhead
      and capital  charges.  The  basic data used in preparing the  es-
      timates was obtained from a published source containing 1965
      data.  Current materials balancing and cost/price data provided
                              -72-

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by several petroleum chemical industry sources were used
to verify and update the published data.  While the cost/
price data finally used do not reflect some recent component
changes,  such as increased feedstock costs and some reduc-
tions in labor and overhead costs, total cost/price estimates
are in line with  1972 figures.

      Materials  and cost/price flow estimates for the produc-
tion of synthetic rubber are presented in Exhibit XXIII, follow-
ing this page. Similar flows are provided for the plastics of
interest in Exhibit XXIV.  Since the plastics and rubber indus-
tries make use of several common intermediate products,
some of the detailed cost price data provided in Exhibit XXIII,
covering SBR rubber production, is not duplicated in
Exhibit XXIV, covering plastics production.
(2)    Dollar Tax Impacts Per Barrel of Crude Petroleum
      and Per Thousand Cubic Feet of Natural Gas Were
      Computed for the Period 1969-1971
      The dollar impacts of each applicable element of taxation
on the unit costs of producing crude petrolium and natural gas
were computed annually for the period 1969-1971.  Estimates
for 1972 were not prepared as data for that year of the quality
obtained from industry sources for the period 1969-1971 were
not available. Analytical procedures used were as follows:
           Depletion Tax Benefits

           The procedures used in estimating unit depletion
           tax benefits were as follows:

                 Annual units of domestic and foreign pro-
                 duction were obtained from industry sources.
                 Adjustments were made to place foreign
                 production on the same basis as domestic
                 production, that is, to exclude production
                 not reflected in tax data.
                        -73-

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                                                                                                                                                                                          EXHIBIT XXIII

                                                                                                                                                                            SIMPLIFIED FLOWCHART FOR SBR
                                                                                                                                                                                     (SYNTHETIC RUBBER)
IOSTOCC COSH U'.TO '«»r.[ f KOI
I 10 I « THI CluDC OH v«icl Or
 s >-o. •>! r\rn AUO 9r VARIOUS
• ""AMI: vnoi i\i •  I ijAi^lA'j.co
•••:•••>  31-1 li Li'il In*  . Jl
 >i .'-LIS-. i •[ AMU <.iiou> vir
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                                                                                                                      73-a

-------
                                                                                                                                                                          EXHIBIT XXIV

                                                                                                                                                                 SIMPLIFIED  FLOWCHART
                                                                                                                                                            FOR SELECTED PLASTIC RESINS
                     MUOI on
                       01
                    OATUIAlCAl
   iiintRi coin of i n rei iiimiit
   MIUSO
     AVIIACIIA» »«Tf IIALI COtn IK III
     OllliruiMOISOLAIl IAICOOH
     v«il l» Of mill iniMTIO
     •Airman IOCOMJICTOI MOWII
     TO •HfllOSIOCKCOSn
•niMiocicomof I

r



CMIOIIOI *ei ["" "*1

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• IIIIAM- J
PRODUCT m com
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inmMiconui

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„„._„ ... II Of TOTAL
A,,,"!., .» — •» coro
«a m
CHLOIUHI in
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UUOP.AUniMf.AO 0101 »l
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OOUCIIO»UII> >OI»ODUCIIO»COSTIAIIOOTHIRCOI»Ilin
                                     INCIt ASfS IM FHDDIUTION COST ACCOUNT FOITMI OlffCHiKCISIEm EHflQOUCIION COSISANDISTIMICfS
                                                                                                                    I OICNIUESIMRMiJlJAirftfAlCOSTSAHa
                                                                                                      73-b

-------
      Annual cost and percentage depletion totals
      applicable to foreign and domestic production
      were provided by industry sources.  The excess
      of percentage depletion over cost reportedly
      attributable to petroleum and natural production
      was estimated on the basis of the asstnption that
      the amount of depletion claimed would be pro-
      portional to the well head value of the petroleum
      and natural gas produced in a given period.

      The depletion tax benefit was estimated by
      multiplying the excess of percentage depletion
      by 0.48, the corporate income tax rate.

      The depletion tax benefit used in estimating total
      tax impacts  represents a weighted average of dom-
      estic and foreign benefits.

Minimum  Tax On Tax Preference Items  (Depletion)

The procedures  used to estimate the tax impact of
the minimum tax related to  the depletion allowance
were as follows:

      The total amount of taxes paid on preference
      items was obtained from industry sources.
      (The minimum tax did not become  effective
      until 1970).  Deductions relating to specific
      preference items  were estimated and a
      proportionate share of the taxes paid was
      allocated to  each.

      The estimated minimum tax attributable to
      the depletion allowance was allocated between
      natural gas and crude petroleum output  on the
      same basis as the depletion allowance.
            -74-

-------
Foreign Tax Credits

The procedures used in estimating tax benefits
derived from foreign tax credits were as follows:

      The total amounts of foreign tax credits
      taken annually were obtained from industry
      sources

      Foreign tax credits attributable to crude
      petroleum and natural gas produced were
      estimated on the basis  of the assumption
      that such credits would be proportional
      to the share of total foreign revenues attri-
      butable to petroleum and natural gas pro-
      duction.

      The tax benefit provided by the foreign tax
      credit was computed as 48 percent of the
      credit taken.

Tax Treatment of Exploration and Development Costs

The benefits associated with the tax treatment  of ex-
ploration, intangible drilling,  and development costs
were estimated on the basis of data regarding actual
expenditures obtained from industry sources.  The
basis for computing the value of the tax benefit was
defined  as the net reduction in the current year's tax
liability achieved through treating such costs as ex-
penses as opposed to capital expenditures.  The dollar
value of the tax benefit was considered to be the time
value of the deferred tax liability discounted at 7 per-
cent over a period of ten years.  The discount  rate
used reflects the estimated cost of producer borrow-
ing while the time pariod used  (10 years) represents
the estimated amortization period were expenditures
capitalized.

State Taxes

The impact of state taxes on crude petroleum and
natural gas production costs was estimated on  the
basis of severance and production taxes actually
             .75-

-------
                 paid by those producers included in the study.
                 The taxes paid were allocated between natural
                 gas and crude petroleum output on the basis of
                 gross revenues attributable to each.  The net
                 tax impact was computed as 48 percent of the
                 taxes paid.
4.    ESTIMATED TAX BENEFITS ARE PROBABLY NOT
      SUFFICIENT TO INFLUENCE PRODUCER RAW
      MATERIAL CHOICES
      Exhibit XXV, following this page,  summarizes the impact
of the discriminatory taxes and tax benefits evaluated on the cost
of producing crude petroleum and natural gas for the period 1969-
1971.  As indicated on the Exhibit,  the percentage depletion allow-
ance accounts for most of the tax benefits obtained.  The maximum
net reduction in the cost per  barrel of crude petroleum computed
(weighted average basis) is $0. 318 after taxes for 1969, equal to
approximately 12 percent of the prevailing crude oil price.   On a
pretax basis, the maximum computed net cost reduction would be
$0. 636 per barrel, equal to about 24 percent of the prevailing
crude oil price. For natural gas, the maximum computed tax
benefit is $0.011 per MCF after taxes for 1969,  equal to about
6. 6 percent of the prevailing natural gas price.  On a pretax
basis the benefit would be $0. 022 per MCF, equal to about 13. 2
percent of the prevailing price.

      Exhibit XXVI summarizes the impacts of the computed tax
impacts on the  cost of producing SBR rubber in 1971 using a crude
petroleum base.  Note that the impact will vary depending on the
share of feedstock costs attributable to crude petroleum costs.
Estimates of the share of crude petroleum costs in feedstock
costs ranged from 30 percent to 70 percent.  This wide range is
attributable mainly to differing methods of distributing  costs of
petroleum fractions and transportation costs.

      Assuming a 70 percent  cost share, the impact of  the taxes
and tax benefits on the cost of producing SBR rubber would be
0. 7 cents per pound, equal to 1. 4 percent of the  prevailing price
per pound of SBR rubber.
                            -76-

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                                                                                                 EXHIBIT XXV

                                                                                   IMPACT OF SELECTED TAXES AND
                                                                             TAX BENEFITS ON THE COST OF PRODUCING
                                                                                     CRUDE OIL AND NATURAL GAS
DOLLARS & PERCENT OF PRICE (1)
US TAX TREATMENT

DEPLETION' - DOMESTIC _
FOREIGN CD
WEIGHTED AVERAGE
MINIMUM TAX RELATED TO DEPLETION*
DOMESTIC
TAXES PAID OR DEEMED PAID TO FOREIGN
GOVERNMENTS
EXPLORATION AND DEVELOPMENT
EXPENSES' - DOMESTIC
FOREIGN
WEIGHTED AVERAGE
STATE TAXES
Oil (PER BARRED
1971
t X
0273 81
0211 75108
0249 79 90
OC42) 112)
oi28 46 66
0017 S
0010 4 S
OQI4 4 5
OOS60071H17 271
1970
t %
0258 81
0199 80108
0231 79 86
(00351 111)
0102 41 55
0013 6
QOI3 5- 7
0017 S
1005300681 117 27)
1969
S %
0 301 97
0317 I35IB1
0305 101 11 8
NOT APPLICABLE
0072 31 41
0021 7
0013 6 7
0018 fr '
(00510 069) 17 22
NATURAL GAS (MCF)
1971
t X
0.015 8 1
N/A
N/A
(OOU2I (III
N/A
0.002 1 t
N/A
N/A
(00060008)1 34-44)
1970
1 K
0014 12
N/A
N/A
'0 0021 1 1 21
N/A
0002 1.2
N/A
N/A
(00060008)1 35 471
1969
S «
0.015 90
N/A
N/A
NOT APPLICABLE
N/A
0002 12
N/A
N/A
(0006-0 0071 (3 M 21
TOTAL IMPACT
DOMESTIC
FOREIGN
0 252 0 261 t 0- 9 4
01120192 52 57
349 12 S 17 9
0.216 0 29S 96110
01740189 5559
314 126170
03070318 102123
02530271 82 88
402 171230
007 009 38 49
006-008 35 47
010 Oil 60- 66
    CRUDE OIL
     (PER BARREL)
    NATURAL GAS
      (PERHCF)
                       PRICE DATA
   DOMESTIC  FOREIGN AVERAGE

1972   3 39    2 00 2 90
1971   339    155 2 JO  277314
1970   3 IB    185250  270233
I9E9   3.09    1 75 2 35  2 59 3 02
                      1977     186
                      1971     182
                      1970     171
                      I9E9     167
iUUHU  BUUl ALLLNftllAMILlUN INI
                                                       76-a
                                                   US IMPORTS 1 TO S PERCENT OF THE NATURAL GAS SUPPLY
                                                   PRIMARILY FROM CANADA
Note:  Impacts are shown on an
       after-tax basis
                                                   APPROXIMATELY (0% OF US PRODUCTION OF CRUDE OIL IS
                                                   COVERED IN THIS EXHIBIT

-------
                                                                                                       EXHIBIT XXVI

                                                                                       IMPACT OF SELECTED TAXES AND TAX BENEFITS ON THE
                                                                                             COST OF PRODUCING SBR RUBBER - 1971
                                                                                                       (cents per pound)
 Percent of Feedstock Costs
 Atti ibutab e to Ciude Oil
 Cost i
SUR Synthetic
Rubber Price
pei- Pound
1071
Feedstock
Cost Per
Pound of
SBH
  Tax Impact
  Per Pound of
  SBR
                      Tax Impact
                      of Sim
                      Price	
After Tax Before Tax
                     After Tax Before Tax
         70%

          30",',,
    23.6

    23.6
  1.88

   .76
 .17

 .07
.34

.14
0.7

0.2
1.4

0.4
Note: Impacts are shown on an after-tax basis
                                                                76-b

-------
      Exhibit XXVII, following this page, summarizes the impact
of the tax elements analyzed on the cost of producing selected
plastic resins in 1971 from petroleum based feedstocks.  Again,
assuming a 70 percent share of crude petroleum costs in feed-
stock costs,  the pretax net cost reduction attributable to the
taxes and tax benefits evaluated is equal to about 1 percent of
prevailing resin prices.

      The tax impacts assuming use of natural gas based feed-
stocks or mixed based feedstocks are of the same order as those
discussed above.

      Because of the  significant technical barriers standing in the
way of increased secondary materials use in producing synthetic
rubber and plastics,  it can be concluded on a qualitative basis
that the incremental cost of using such materials would be very
high.  The magnitude of the tax benefits computed above, repre-
senting about one percent or less of rubber and resin prices
are not likely in themselves to be sufficient to  cause producers
to consider substitution of  reclaimed  rubber or plastics for
virgin or raw materials.
                             -77-

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                                                                                                                  EXHIBIT XXVH

                                                                                            IMPACT OF SELECTED TAXES AND TAX BEN R KITS
                                                                                   ON THE COST OF PRODUCING SELECTED PLASTICS RKSINS - 1971
                                                                                                                 (cents per pound)
 Plastic Rosins


High Density Polyethelene


Low Density Polyethelene


Polyvinyl Chloride

Pnlyslrene
                                 Percent of Feedstock Costs
                                 Allnb liable to Crude Oil
                                 Costs
30?o

7 (To
30%
                                         707.
                                         30%
                              1971 Resin
                              Trice
13  4
13.4

12  8
12.8

13.2
                                 13.8
                                 13.8
Estimated Feedstock
Cost
Per Pound of Resin

     .80
     .40

     .64
     .26

     .31

     I.50
     i. OU
      .3!)
                                        Tax [iipact
                                        Per Pound ot Rc^m
                                        After lax Before Tax
                                                                                                    'I •"  Impact
.07
.04

.06
.02

.03

 14
.O'J
.04
0.14
0.08

0. 12
0.04

0.06

o. •>;:
o :.'.
0.08
                           "•
                           i'r
                                ->f
                                                                                                             Hefnre lax
                                                                                                    '. '.2
1.04
0.54

0 34
0.32

0.46
                                                                               1.42
                                                                               O.SO
Note:  Impacts are shown on an after-tax basis
                                                                    77-a

-------
                                                                                                                         APPENDIX A (1)
                                          ALUMINUM MANUFACTURING
                                         UTILIZING VIRGIN MATERIALS
    CLAY AND SILICA
BAUXITE
 MINES
              BENEFICATEO
              BAUXITE ORES
      BAUXITE ORES ARE PROCESSED AT THE
      MINES OR ARE ALSO SHIPPED FOR
      PROCESSING ELSEWHERE
                                                                                                  HAY ADD
                                                                                                 ALLOYING
                                                                                                 MATERIALS
©
 2 TONS OF BAUXITE ORE FOR I TON OF ALUMINA
 2 TONS OF COAL FOR 1 TON OF ALUMINA
 1 TONS OF FUEL OIL FOR 1 TON OF ALUMINA
 2 TONS OF SODA FOR I TON OF ALUMINA
OS TONS OF LIME FOR I TON OF ALUMINA
      SOURCE ALUMIMUH. McGRAW-HILL. INC . 1969
       2 TONS OF ALUMINA FOR I TON OF ALUMINUM
       6 TONS OF BAKED CARBON FOR 1 TON OF ALUMINUM
      03 TONS OF CRYOLITE FOR 1 TON OF ALUMINUM
      04 TONS OF ALUMINUM FLUORIDE FOR 1 TON OF ALUMINUM
      SOURCE ALUMINUM. McGRAW HILL.INC . 1969
      S = SHIPPED

-------
                                                                                                                                       APPENDIX A (2)
                                           SECONDARY ALUMINUM MANUFACTURING
                                                      ALUMINUM DIE CASTING
       SECONDARY ALUMINUM SOURCES
  A    NEW SCRAP 82%
  ~ APPROX 17% BORINGS AND TURNINGS
    APPROX 51% CLIPPINGS AND FORCINGS
    APPKOX 14% RESIDUES
  B    OLD SCRAP 18%
    APPROX 11 5% OBSOLETE ALUMINUM BEARING PRODUCTS
    APPROX 6 5% SWEATED PIG ALUMINUM
  C BUNDLES WHERE POSSIBLE. ARE SHIPPED
  ~ ACCORDING TO ALLOY CONTENT

  D BOTH PRIMARY AND SECONDARY SMELTERS
  - PRODUCE PURE ELECTROLYTIC TYPE ALUMINUM.
    BUT SUCH OUTPUT IS OF MINOR IMPORTANCE TO
    THE SECONDARY INDUSTRY ALLOYS ARE ALMOST
    ALWAYS ADDED IF NOT ALREADY PRESENT IN
    ALUMINUM SCRAP IN CORRECT QUANTITIES
  E 87% OF SECONDARY SMLLTCR OUTPUT GOES TO FOUNDRIES.
  ~ OVER 60% OF OUTPUT IS USED IN DIE CASTING APPLICATIONS
  F  OEALER/PROCCSSOnS PFIOCFSS APPROXIMATELY 70% OF
  ~  HE CYCltn ALUMINUM
o
uitrcrn

•lOUIICE US UUIILAUUI MINI j

-------
                                                                                                                              APPENDIX A (3)
                                             SECONDARY ALUMINUM MANUFACTURING
                                                     ALUMINUM CAN RECYCLING
                                 ALUMINUM CAN
                                 RECLAMATION
                                 CENTERS
ALUMINUM CAN
MANUFACTURING
PLANTS
                                                                                                      USED ALUMINUM CANS
                                                                                                              ALUMINUM
                                                                                                              CAN MANU-
                                                                                                              FACTURING
                                                                                                              PROCESSES
                                                          FERROUS METALS
                                                          AND OTHER
                                                          FOREIGN
                                                          MATERIALS
IN 1971 APPROXIMATELY 12* OF ALL ALUMINUM CANS WERE
RECYCLED (770 MILLION CANS. OR 24.062 5 TONS OF ALUMINUM

32.000 CANS/PER TON

SOURCr Al UMINUM ASSOCIATION

-------
                                                                                                                      APPENDIX A (4)
                                         NEWSPRINT MANUFACTURING UTILIZING
                                                VIRGIN GROUNDWOOO PULP
 A) - USUALLY BALSAM OR SPRUCE

 S)- SHIPPLO
SOURCL  ALVAOb r.'ARKET. EPA. 197]
      MIDWEST RESEARCH INSTITUTE
                                    MATERIAL REQUIREMENTS

                                    1  CORD ROUNDWOOD (1 2 TONS)
                                       PER TON OF NEWSPRINT
NOTE   NEWSPRINT NORMALLY IS PRODUCED USING 75-80% GROUNDWOOD AND 20-25% SEMI-BLEACHED FIBER
       HOWEVER ASSUMING THE ABOVE MATERIAL REQUIREMENTS PROVIDES SUFFICIENT ACCURACY FOR
       THIS ANALYSIS

-------
PROCESSORIOEALER PAPERMILL
                                                                                                                            APPENDIX A (5)
                                              NEWSPRINT MANUFACTURING
                                           UTILIZING SECONDARY MATERIALS
                                                       OLD NEWS
                                                       PAPER STOCK
PAPER STOCK
PULP FIBERS
                                                                                                                90% RECYCLED NEWSPRINT
         MATERIAL REQUIREMENTS 1 19TONS
         OF PAPERSTOCK FOR 1 TON OF NEWSPRINT
          SOURCE CHEMICAL PROCESS INDUSTRIES. McGRAW HILL. 1971

          SOURCE REPORTS TO COUNCIL ON ENVIRONMENTAL QUALITY
                MIDWEST RESEARCH INSTITUTE. 1971
         [Si- SHIPPED

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                                                                                                                                    APPENDIX A (6)
                                                    INTEGRATED KRAFT PAPER
                                                   MANUFACTURING UTILIZING
                                                        VIRGIN MATERIALS
                                                     ADDITIVES
                                                     - "WHITE LIQUOR"
                                                       (SODIUM SULFIDE
                                                       AND CAUSTIC SODA)
                                                                                                                          O
F                                                                                                                      THICKENED
                                                                                                                        KRAFT
                                                                                                           SCREENING  \ __ PULP
                                                                                                          ILTERINGANO
                                                                                                          THICKENING
                        ADDITIVES
                        - BLEACHES
                        - FILLERS
                        - SIZERS
                        - COLORING
                        - OTHER PULPS
                        - WET STRENGTH RESINS
                                 PAPER
                                 MAKING
                               MACHINERY
                                                                        SPENT
                                                                       COOKING
                                                                       LIQUOR
                                                                    "BLACK LIQUOR-
                                                                                                                           KRAFT PAPER
                                                                                                        MATERIAL REQUIREMENTS PER
                                                                                                        TON OR KRAFT
                                                                                                        1 6 CORDS (2 TONS) ROUNDWOOD
                                                                                                        25 TONS LIME
                                                                                                        125 TONS SODA ASH      	
                                                                                                     — I LIQUOR IS USED AGAIN AS
                                                                                                       I COOKING AGENT
SOURCE   CHCUICAL PROCESS INDUSTRIES. McGRAW HILL. 1971. p 637
        SALVAGE MARKETS. U S EPA. 1972

8 • SHIPPED
6V PRODUCT EXTRACTS ARE IMPORTANT
FACTOR IN ECONOMICS OF VIRGIN
PULP PRODUCTION         	

-------
                                                                                                                                         APPENDIX A (7)
                                                     RECYCLED PAPER STOCK/PAPERBOARD
                                                          MANUFACTURING UTILIZING
                                                             SECONDARY MATERIALS
                                                                        ADDITIVES
                                                                          - WATER
                                              SORTING
                                            AND DECONTA-
                                             MINATING TO
                                            SPECIFICATION
                                                                                     PAPERBOARD '
                                                                                       MAKING
                                                                                      CYLINDER
                                                                                       BOARD
                                                                                      MACHINE
     FOLDING  /->.
    BOXBOARD (C j
   PAPERBOARD. V-X
"COMBINATION BOARD"
                                                                                                                                         PAPERBOARD
                                                                                                                                          BOXING
                                                                                                                                         MATERIALS
                                                                                                                                  PAPER8OARO
                                                                                                                                    FORMING
                                                                                                                                    PROCESS
                                                                                                                                   CONVERTER
                 OLD CORRUGATED. MIXED PAPERS AND HIGH-GRADE
                 "OE INKING" STOCK ONLY HIGH-GRADE "OE INKING"
                 STOCK CAN BE USED FOR RECYCLED PAPER PRODUCTS
                 UP TO 50% RESIDUALS IS USUAL EXPERIENCE
                 RESIDUALS INCLUDE CONTAMINANTS. CLAYS. SOMETIMES
                 INKS
                  MATERIAL REQUIREMENTS
                  1 34 TONS OF PAPER STOCK
                  FOR FOLDING BOXBOARD
                                                                                                                                    PROOUCTS
"=-
SOURCE  MRI. COMBINATION 1472

S - SHIPPED

-------
                                                                                                                                      APPENDIX A (8)
                                                          STEEL PRODUCTION
                                                           USING VIRGIN AND
                                                        SECONDARY MATERIAL
                                                     CHEMICAL BY-PRODUCTS
                                                      COKE OVEN GAS (HEAT SOURCE)
                                                                                             STEEIMAKING
                                                                                               FURNACES
                                                                                           (OPEN-HEARTH. BASIC
                                                                                              OXYGEN AND
                                                                                               ELECTRIC)
 CRUSHING.
SCREENING
                                                  HIGH GRADE
                                                 IRON BEARING
                                                  UATERIALS
                                                (AGGLOMERATE)
B IRON-ORE \
ENEFICIATING  )
  PLANTS   /
                                                                                                  STEEL
                                                                                                  USERS
                                                                                                ENERATO
MOLTEN STEEL
                ©
                                                                                                                                       INGOTS
MATERIAL REQUIREMENTS
MATERIAL REQUIREMENTS PER
TON OR PRIMARY RAW STEEL
IRON ORE
COAL
LIMESTONE
SCRAP
HP
060
018
04S
                                                        OPEN HEARTH-29 5% OF 1971 PRODUCTION

                                                        BASIC OXYGEN - S3 IK OF 1971 PRODUCTION

                                                        ELECTRIC - 174KOF 1971 PRODUCTION
SOURCE  MINERAL YEARBOOK. (IS. BUREAU OF MINES. 1971

S • SHIPPED

-------
                                                                                                                                        APPENDIX A (9)
                                                     GLASS MANUFACTURING UTILIZING
                                                    VIRGIN AND SECONDARY MATERIALS
SODA ASH.
FELDSPAR
LIMESTONE
                                                                              COHTAIHERS '
                                                                                                            CRUSHERS
                                                                               CULLET
                                                                                     RECYCLED GLASS
                                                                                   (SMALL PERCENTAGE)
      1.299 LBS OF SILICA FOR 1 TON OF GLASS
       126 LBS OF SODA ASH FOR 1 TON OF GLASS
       157 LBS OF FELDSPAR FOR I TON OF GLASS
       358 LBS OF LIMESTONE FOR 1 TON OF GLASS
AFTER PROCESSING. CONTENT IS
I.4GO LBS OF SILICA IN I TON OF GLASS
 276 LBS OF SODA ASH IN 1 TON OF GLASS
  26 LBS OF FELDSPAR IN 1 TON OF GLASS
 704 LBS OF LIMESTONE IN I TON OF GLASS
   11   CULLET MAKES UP 10  I5SS
      OF AVERAGE BATCH THAT GOES
        INTO MELTING FURNACE
     -OURCE GLASS INDUSTRY

-------
                                                                                              APPENDIX B(l)
                    SOURCES OF BAUXITE, ALUMINA AND ALUMINUM
                                 FOB THE U.S. MARKET
                          mm comma
                                                    •MEtf CONVERTED
                                                      TOAiawmm
                                                     SROAOIWUSTMAI
                                                    MO COMHNKR MMET
  ARKANSAS
nnmooucnm-
 MAMMA MO
   GEORGIA
HIIPRODUCTION •
  mm TQM
 ununton
     IM9OTUC
ifnuj.iwoim»
  AUHMUA
  nvLiwow
  tajHTOU
   ARRAMSM
    TCKAS
   AOSTIAUA
                                                     MIITNCAnLWA
                                                       •fWVOIK
                                                        TEXAS
                                                                                  CHICAGO.
                                                                                  lunton
 nnv«.swnv
  OftAUUTt*
miax*
  wu
  UHJMTOBI
                                                      UIUMTOM
  OVMAH t* mm. «x osn. or TW WTIMOO

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                                                                                                                                 AfTENDIXB(2)
                                                SOURCES OF TIMBER FOR THE U. S. MARKET
    DOMESTIC PRODUCTION OF WOOD PULP - 197(
                                           NEW ENGLAND  MID-ATLANTIC  E. NO. CENTRAL  W.NQ. CENTRAL SO. ATLANTIC E. SO. CENTRAL  W. SO. CENTRAL
                                                                                                              MOUNTAIN AND'
                                                                                                                 PACIFIC
47.743.000
2.796.000
TONS
1.461.000
TONS
3280.000
TONS
OBO.OOO
TONS
14.981.000
TONS
7.880.000
TONS
7.299.000
TONS
9J037.000
TONS
IMPORTED WOOD PULP AND OTHER FIBROUS MATERIALS
    CANADA
    OTHERS
-  153.053 TONS
-  138.34STONS
   ©  PRINCIPAL PRODUCERS
    •   TIMBER IS CONVERTED TO WOOD PULP
       FROM WHICH PAPER IS MADE

    SOURCE: MONTHLY STATISTICAL SUMMARIES
           AMERICAN PAPER INSTITUTE

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                                                                                                                                     APPENDIX B<3)
                       SOURCES OF  IRON/STEEL FOR THE U. S. MARKET
 MAJOR
 SOURCES
WHERE CONVERTED TO
  MOLTEN PIC IRON
WHERE CONVERTED
 TO MOLTEN STEEL
BROAD INDUSTRIAL
 AND CONSUMER
    MARKETS
IMPORTED
IRON ORE
1110 US
IUPORTS
10.299 TONS
VENEZUELA
1910 Uj
IMPORTS
4376 TONS-
CANADA
1910 US
IMPORTS
1.6)7 TONS'
DOMESTIC
IRON ORE
19)0 U S
PRODUCTION •
95 893 TONS
COAL
1970 U4
PRODUCTION •
612 661
LIMESTONE
1970 (IS
PRODUCTION •
19.14? TONS
MINNESOTA
1970
PRODUCTION •
SO 170 TONS
PENNSYLVANIA
1910
PRODUCTION •
90 220 TONS
NEST VIRGINIA
19)0
PRODUCTION •
144 072 TONS
KENTUCKY
1910
PRODUCTION'
125 305 TONS
ILLINOIS
1970
PRODUCTION •
65 119 TOM
OHIO
19)0
PRODUCTION •
MSI TONS
PENNSYLVANIA
1910 PRODUCTION
1 Ml TONS
MISSOURI
NOT AVAILAILE
                                                                                  (THOUSANDS OF
                                                                                   SHORT TONS)
                                                PENNSYLVANIA
                                                    1911
                                                   IBJI9
                                                    OHIO
                                                    1971

                                                    13 719
                                                   INDIANA
                                                    1971

                                                    12.740
                                                  ILLINOIS
                                                    1971

                                                   6.466
                                                  ALABAMA
                                                    1971

                                                    U62
                                              1971
                                          PENNSYLVANIA
                                             27.65S
                                              1971
                                              OHIO
                                             20.064
                                              1971
                                            INDIANA
                                              17 JO 7
                                              1971
                                            ILLINOIS
                                             10.07
                                              1971
                                            MICHIGAN
                                              9.069
                                                                                                                                  CHICAGO
                                                                                                                                  NEW YORK
                                           TOTAL 1971 U.S PRODUCTION
                                                   •1.332
                                     TOTAL 1971 US PRODUCTION
                                             120.441
                     •EXCLUDE! IMPORTS USED FOR MAKING AGGLOMERATES
                     IOURCC.
                             IIUMWOITEEL.U.S OEPT OF INTERIOR
                             MINERALS YEARBOOK. US OEPT OF INTERIOR. 1970

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                                                               APPENDIX B (4)
                     CRUDE PETROLEUM AND
                   REFINING PRODUCTION - 1972
                     (MILLIONS OF BARRELS)
DOMESTIC
CRUDE PRODUCTION
TOTAL:
TEXAS
LA.
CAL.
OK LA.
WYO.
N.MEX.
ALASKA
KANS.
MISS.
OTHER
3.459
1.302
896
347
207
141
110
74
74
61
247

FOREIGN CRUDE



REFINERY
INPUT
3.474
i

    807
NATURAL GAS
  LIQUIDS
    313
                                                   TOTAL OUTPUT
                                                       4.593
                                                     GASOLINE
                                                       2.316
                                                    DISTILLATE
                                                     FUEL OIL
                                                       962
                                                     RESIDUAL
                                                     FUEL OIL
                                                        293
                                                     JET FUEL
                                                       310
                                                  PETROCHEMICAL
                                                    FEEDSTOCKS
124
                                                     OTHER
                                                    PRODUCTS
                                                       730
                                                    SHORTAGE
                                                       (142)
                                                     IMPORTED
                                                     REFINED
                                                     PRODUCTS
                                                       819
                                                     (FOR 1971)

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               NATURAL GAS PRODUCTION
                AND DISPOSITION - 1971
                (BILLIONS OF CUBIC FEET)
   TOTAL
 PRODUCTION
    22,493
    TEXAS
    8.551
  LOUISIANA
    8.082
 OKLAHOMA
    1.684
 NEW MEXICO
    1.168
   KANSAS
     885
 CALIFORNIA
     613
  WYOMING
     380
OTHER STATES
    1.130
                        IMPORTS
                          935
 WITHDRAWN
FROM STORAGE
                          1.508
DOMESTIC
CONSUMPTION
TOTAL:
RES.
COMML
IND.
22.677
4,972
2,173
15.532
                                               EXPORTS
                                                  80
                                                STORED
                                                 1.839
                                                LOST IN
                                             TRANSMISSION
                                                 339
                                      f/

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                                                      APPENDIX C (1)
                  COMBUSTIBLE WASTE AS AN
                ALTERNATIVE TO FOSSIL FUELS
      This Appendix discusses the impact of tax benefits applicable
to fossil fuels (petroleum, natural gas and coal) on their cost relative
to the cost of combustible solid waste used as a fuel.  It has been
prepared as a supplement to the basic report contained in this volume
at the request of the Office of Solid Waste Management.
 1.    FOSSIL FUEL COSTS
      Exhibit C-I, following this page,  shows estimated 1973 fossil
fuel costs per million BTU's delivered to users.  It should be noted
that actual fuel costs can vary greatly, depending primarily on  origin
and sulphur content.
                 The price of coal is sensitive to sulphur content
                 as well as to the cost of mining with strip mined
                 coal,  the least expensive.  Costs to users can
                 vary from $0. 20 per million BTU's for accessible
                 high sulphur coal to more than $0. 75  per million
                 BTU's (mid-year 1973 prices) for low sulphur coal.

                 The price of No.  6 fuel oil,  as indicated on the
                 Exhibit, is subject to wide variation depending
                 on sulphur content and location of sale.  As an
                 example. No. 6 fuel oil in mid-197 3 was selling
                 in Chicago for up to $5. 88 per BBL and in
                 Oklahoma for $2. 60 per BBL.
      Because of the fuel price variability discussed above, it is
apparent that any truly valid evaluation of the relative advantages
of using combustible solid waste as an alternative to fossil fuels
must be made on a case-by-case basis.

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                                                     EXHIBIT C-I

                                                 FOSSIL FUEL PRICES
                                              PER MILLION BTU's (1973)
 Natural Gas

 Bituminous Coal
  & Lignite

 Fuel Oil (No.  8~
  National Average)
                         Units
MCF
TON
BBL
           Price
$ 0.509
 BTU's
Per Unit

1,040,000
 12.24**     22,000,000
  4.26***     5,800,000
 Price
   per
 Million
  BTU

$0.489*
                 0.556
                 0.734
   *  Estimated average rates charged to industrial users for 1973,
     Source:  "Analysis of the American Petroleum Institute - Foster
     Associates Study of the Impact of Deregulation on Natural Gas
     Prices"  Congressional Research Service, 1973.
     Note:  Data on price per million BTU's for 1972 adjusted by +9%
           to reflect estimated 1973  prices.

 **  Source:  Unpublished manuscript by Leonard W.  Westerstrom
     of the  Bureau of Mines.  Estimated 1973 bituminous coal price
     of $8. 16 per  ton adjusted by +50% to reflect transportation costs
     to user.

***  Source:  Federal Power Commission
                            (Da

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                                                   APPENDIX C (2)
 2.    EXPECTED FOSSIL FUEL COST INCREASES
      As is well known,  the price of fossil fuels is increasing and is
 expected to continue to increase for the foreseeable future.
                 Crude oil prices are expected to increase to $7. 00 -
                 $8. 00 per BBL in 1974.  Assuming that the price of
                 No. 6 fuel oil (N. Y.  Contract) averages out at $0. 75
                 per BBL above that of crude oil, costs to users
                 could increase to as much as $1.51 per million
                 BTU's.

                 If the well head price of natural gas is deregulated,
                 then substantial gas price increases could  occur,
                 depending on the manner in  which deregulation is
                 applied and producer success in renegotiating
                 prices on long term contracts.

                 Coal prices,  especially for  low sulphur coal, may
                 also be expected to increase as the fuel shortage
                 continues.
      Increases in the price of fossil fuels will, of course, tend to
make combustible solid waste a more attractive alternative fuel
source.
3.    THE COST OF COMBUSTIBLE WASTE AS A FUEL
      High and low estimates of the fuel costs of combustible solid
waste are contained in Exhibit C-II,  following this page.  The esti-
mates shown are based upon data contained in "Energy Recovery
from  Waste", published by the  Environmental Protection Agency
in 1973.

      The variability in cost is  a function of economies of scale and
transportation cost differentials.   The costs shown,  at $0. 48 to $1. 39
per million BTU's, do not include  the capital or operating costs for
combustion equipment adapted to burning combustible solid waste.

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                                        EXHIBIT C-H

                             ESTIMATED COSTS OF COMBUSTIBLE
                                  WASTE USED AS A FUEL
                                Low              High
                                Cost              Cost

Capital Costs                   $0.80            $  1.80

Operating Cost                   3.50              6.00

Transportation Cost              0.50              6.00

Total Cost Per Ton              $4.80            $13. 90
Cost per million BTU @
 10 million BTU/Ton           $0.48            $1.39
                      (2)a

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                                                  APPENDIX C (3)
4.    THE IMPACT OF TAX INCENTIVES ON FUEL COSTS
      Exhibit C-III, following this page shows the incremental cost
per BTU for fossil fuels if the applicable tax benefits detailed in the
body of this report were repealed.  The incremental cost shown is
equal to the highest computed total tax benefit for each fuel converted
to dollars per BTU on a pre-tax basis.  Price increases required to
recover income lost if the tax benefits were repealed would range
from  about 4% for natural gas to 15% for oil.

      To develop any  conclusions regarding the degree to which such
an increase in fossil fuel costs  would stimulate use of combustible
waste, the relative cost of burning each type of fuel must be con-
sidered.   Evaluation of such  costs (equipment and operating costs)
is beyond the scope of this effort.  Given, however, that the cost
of fossil fuels falls within the range of combustible waste costs, it
may be stated that tax treatment equalization as summarized on
Exhibit C-III could cause some marginal increase in the use of com-
bustible waste over the  long term.

      Of much greater significance to the future of combustible waste,
however,  is the very  rapid increase in the  cost of fossil fuels,  as
well as their limited  availability.  Both high costs and lack of supply
may provide a significant stimulus to increased combustible waste
usage.

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                                        EXHIBIT C-III

                                THE IMPACT OF TAX BENEFITS
                                    ON FOSSIL FUEL COSTS
                                     ($ per million BTU's)
Natural Gas

Coal

Fuel Oil
 Price

$0.489

 0.556

 0.734
Incremental
Costs if Tax
 Benefits
 Repealed

 $0.020

  0.046

  0.111
 New
 Price

$0.509

 0.602

 0.845
                      (3);
                                               ya!078

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