Home mortgage interest deduction
A home mortgage interest deduction allows taxpayers who own their homes to reduce their taxable income by the amount of interest paid on the loan which is secured by their principal residence. Most developed countries do not allow a deduction for interest on personal loans, so countries that allow a home mortgage interest deduction have created an exception to those rules. The Netherlands, Switzerland, the United States, Belgium, Denmark, and Ireland allow some form of the deduction.
Status in countries
Canada
Canadian federal income tax does not allow a deduction from taxable income for interest on loans secured by the taxpayer's personal residence, but homes used in businesses as a landlord who owns a rental residential property can deduct interest as any other reasonable business expense. The difference being the deduction is allowed only when the property is not used for the taxpayer's personal use but is used as in any other type of business. However, there may be additional exclusions for passive activity losses.An indirect method, known as the Smith Manoeuvre, for making interest on mortgage for personal residence tax deductible in Canada is through an asset swap, whereby the homebuyer sells his existing investments, purchases a house in full or in part by the sale, gets a mortgage on the house, and finally, buys back his investments with the money from the mortgage. The Supreme Court of Canada has ruled in 2001 in the Singleton v. Canada case that transactions in the asset swap are to be regarded as distinct, thus rendering the interest on home mortgage acquired as part of the asset swap tax deductible.
The home ownership rate in Canada was about the same as in the United States in 2008 despite the difference in tax policy.
Denmark
In Denmark part of the interest is deductible. In 1987 it was 73%. In 1993 it was 50% and in 1998 it was 46%. From 1998 to 2001 it was reduced to 32%. It is the plan that in 2019 it will be 25.5%.France
France does not allow a home mortgage interest deduction. In 2007, newly elected President Nicolas Sarkozy proposed creating the deduction as part of his legislative plan for sparking the French economy. In August 2007, the Constitutional Council, the highest court in France, struck down the mortgage interest deduction as unconstitutionally creating a tax advantage that goes far beyond its stated goal of encouraging non-homeowners to buy homes. The Court noted that the deduction would apply to people who already own homes.India
Home loan interest portion is deductible up to 150 000 rupees in a tax year for acquiring or constructing a property. The deduction is available only when the construction is complete or you have possession of the property. Interest of pre-construction period is deductible in five equal installments. The first installment is deductible in the year in which construction of property is completed or property acquired. The principal is deductible under section 80C, which has a limit of 150 000 rupees.Netherlands
In the Netherlands, a part of the interest payments can be deducted for a maximum period of 30 years. The deduction percentage is based on a person's income. However, before deduction the taxable income is increased by a percentage of the property value with the reasoning that the property has a potential income-generating purpose.Still in place currently, the mortgage interest tax deduction is subject to fierce debate, and a political issue during most recent elections. Although largely an emotional point of discussion with the Dutch electorate, and described by many as "political suicide", most Dutch people believe that the mortgage interest tax deduction will eventually be reformed. Many reasons for abolishment have been identified, often fuelled by a political ideology.
As it stands now, Dutch politicians and other organisations research possible strategies to end interest payments tax deduction and are fuelling public debate to prepare the Dutch public for eventual abolishment. Only 18% of the Dutch public support eliminating the mortgage interest deduction entirely.
Norway
Norway considers any interest paid, whether it is for a home mortgage or other debt, as a deductible expense. The result is a reduction of the tax bill of 25% of all interest paid. The fact that the government in effect subsidises 25% of the interest bill has made home ownership highly beneficial in Norway, and critics argue that the deduction has increased the cost of real estate. The Center Party has proposed reducing the deduction.Sweden
A tax credit of 30% of interest up until 100,000 SEK, and 21% over that amount. The amount was about 10,000 SEK per taxpaying person with debts.United Kingdom
The United Kingdom introduced a scheme called MIRAS in 1983 to allow mortgage interest to be tax deductible. It was abolished in 2000.United States
Prior to the Tax Reform Act of 1986, the interest on all personal loans was deductible. TRA86 eliminated that broad deduction, but left the narrower home mortgage interest deduction. While some Americans may believe that Congress created the home mortgage interest deduction as a way to encourage home ownership, historians point out that this was never the case, as explained in a New York Times article that notes that, in 1913, when interest deductions started, Congress "certainly wasn't thinking of the interest deduction as a stepping-stone to middle-class home ownership, because the tax excluded the first $3,000 of income; less than 1 percent of the population earned more than that;" moreover, during that era, most people who purchased homes paid upfront rather than taking out a mortgage. Rather, the reason for the deduction was that in a nation of small proprietors, it was more difficult to separate business and personal expenses, and so it was simpler to just allow deduction of all interest.Under of the Internal Revenue Code, the United States allows a home mortgage interest deduction, with several limitations. First, the taxpayer must elect to itemize deductions, and the total itemized deductions must exceed the standard deduction. Second, the deduction is limited to interest on debts secured by a principal residence or a second home. Third, interest is deductible on only the first $1 million of debt used for acquiring, constructing, or substantially improving the residence, or the first $100,000 of home equity debt regardless of the purpose or use of the loan. The cost to the federal government of the mortgage interest deductions in 2018 was approximately $25 billion, down from $60 billion for 2017 as a result of the Tax Cuts and Jobs Act of 2017.
In the United States, there are additional tax incentives for home ownership. For example, taxpayers are allowed an exclusion of up to $250,000 of capital gains on the sale of real property if the owner used it as primary residence for two of the five years before the date of sale. Economists have demonstrated that high-cost high-income areas receive most of the tax benefit. For example, San Francisco, California receives $26,385 per home while El Paso, Texas receives $2,153 per home, a 1,225% difference. The five highest income metros receive 87% of tax inflows, with over half going into California alone.
Controversy
The standard justification for the deduction is that it gives an incentive for home ownership, but most economists believe the deduction is bad policy and is counterproductive. They note that it increases inequality, is an unnecessary market distortion, and contributes to housing unaffordability.The National Association of Realtors strongly opposes eliminating the mortgage interest deduction, claiming, "Housing is the engine that drives the economy, and to even mention reducing the tax benefits of home ownership could endanger property values. Home prices, particularly in high cost areas, could decline 15 percent if recommendations to convert the mortgage interest deduction to a tax credit are implemented."
The Tax Foundation argues that few low- and middle-income taxpayers benefit, calling it a subsidy for the real estate industry. Alan Mallach, a senior fellow at the Center for Community Progress and a visiting scholar at the Federal Reserve Bank of Philadelphia, argues that the deduction artificially inflates home prices. Critics in the United States also estimate that it contributes between $70 billion and $100 billion annually to the federal budget deficit.
Economist Edward Glaeser remarked in The New York Times that the policy "is public paternalism at its worst" and wrongfully "encourages people to leave urban areas" as well as to borrow as much as possible to bet on housing.
On 9 March 2012, PBS aired an episode of its show Need to Know in which a bipartisan panel discussed tax reform. The panel, which consisted of former Democratic politician Eliot Spitzer, tax law professor Dorothy A. Brown, Reagan domestic policy advisor Bruce Bartlett, and libertarian economist Daniel J. Mitchell, unanimously opposed the federal mortgage interest deduction.