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Comment by p4bl0 | Hacker News Reader

When I read stuff like this I'm so glad to live in a country (France) that doesn't let people without any money when they're fired or have serious medical issues. Nation-wide solidarity costs little to each person but gives a lot to those who need it. So sad that our public unemployment and health systems are getting destroyed piece by piece by successive governments (the current one is particularly agressive).

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>Nation-wide solidarity costs little to each person

Federal income tax in France is greater than 45%[1]. There's nothing cheap about that. I much prefer the freedom of saving my own money, especially when working in something as lucrative as tech.

1.https://tradingeconomics.com/france/personal-income-tax-rate

Wow, that's actually a great deal. The top marginal tax rate in the state of California this year is roughly 65% (and that's excluding employer contributions).

13.3% of all income (State) +

39.6% of all income (Federal) +

5.3% of all income (Federal double tax on State Tax - thanks, Donny) +

6.2% of all income (Social Security - Individual)

=====

64.4%

Then of course your employer pays another 6.2% of gross earnings on your behalf for social security too. And of course, in tech, your employer has to pay for your healthcare too, an average of $19,616, which also actually comes out of your paycheck. [1] Feel free to work out what percentage of your gross earnings that amounts to and tack that on top also. Good thing we've got the freedom to save the remaining ~33% while people go without basic health cover and social services.

In years I earn a lot, I'd actually be better off in Canada.

[1] https://www.kff.org/health-costs/report/2018-employer-health...

You're double counting the "Federal double tax." Also, the marginal Social Security tax is $0, since it phases out long before you hit those marginal rates.

That being said, the reason France can offer robust services while California cannot, even though tech worker taxes are similar between the two countries, is because France taxes everyone that way. In France, the 41% tax bracket (just a little lower than the top bracket of 45%) kicks in at 71,000 Euros (about $80,000). The U.S. federal rate in that bracket is 25%. Then there is the 20% VAT paid by even the lowest income people.

Yep, you're absolutely right, I did double-count the double-tax. Your comment had me re-run the numbers, and this is what I came up with. You are correct that Social Security goes down to $0.

Medicare contributions have no cap, and are 1.45% by both the employer and employee and the 0.9% Obamacare surcharges on the employee only portion (until 2035) kicks in over $250,000 also. Therefore, social insurance contributes a marginal 3.79%

So, the numbers to the best of my knowledge should have been:

13.3% of all income (State) +

39.6% of all income (Federal, including the Donny double-tax) +

2.34% of all income (Medicare, Obamacare - Employee Contributions) +

1.45% of all income (Medicare - Employer Contributions)

=====

56.69%

Then you still have to deal with the fixed portions, the $19,616 [1] in healthcare premiums, the $7,347 you'd have paid in social security tax and the $7,347 your employer would have paid in social security tax. [2]

[1] https://www.kff.org/health-costs/report/2018-employer-health...

[2] https://www.bizfilings.com/toolkit/research-topics/managing-...

None of that is on all income; base Medicare is only on labor income, the Medicare surtax is on either (specifically, the lesser of) labor income or net investment income above certain thresholds, and the rest is on “normally taxed” income (but not, e.g., long-term capital gains, or gifts and inheritances—which, even when beyond the enormous exempt quantities, aren't taxed as normal income for the recipient, but to the giver or estate, and in California at a lower combined maximum state and federal rate than normal income tax, 40% federal and no state.)

And NSO stock options, which is likely very relevant to this audience.

> France can offer robust services while California cannot,

France offers much more social security than whole US.

Most of the US has much lower taxes than California.

The top marginal tax bracket in CA is for single people making $1M+, and higher if married. That's a lot, even for software engineers.

A more realistic total combined tax for most people is well under 50%.

For the UK with the NHS that figure would be 32% for most single people and less for those with kids.

You've excluded employers national insurance contributions here, which is 13.8% of total pay. That makes the true "main" marginal rate c.44% (20% tax + 12% employee national insurance + 13.8% employers NI / 113.8%).

Most higher earners in e.g. tech or professions will be in the 40% band at least, where the true marginal rate is c.49% (40%+2%+13.8% / 113.8%).

The "top" marginal rate is c.53% (45% tax+2% employee NI+13.8% employer NI / 113.8%) although the highest marginal rate comes between £100k and c.£123k as the personal allowance (bottom 0% band) gets withdrawn making the effective rate (40%+50%x40%+2%+13.8% / 113.8%) = c.65%. (And at the very low end of the scale, as benefits get withdrawn the marginal combined rate of tax and benefit withdrawal is also extremely high).

We don't allow joint filing for married couples which is a significant benefit, especially for single earner couples with high earnings, in the USA.

Then we have mandatory minimum private pension contributions (given these all go into a defined contribution scheme, it's just pay by another name), the apprenticeship levy, etc etc.

Overall, I'd say the UK and "high-tax" parts of the USA (California, New York etc) are similarly taxed at least as far as income is concerned.

Adding the employers contribution to calculate marginal rates for employees is not how its calculated.

Do you think any employer in the uk would magically give you the 13.8 if employers ni went away.

And most STEM jobs including tech don't get into the higher band at 46,350 I think you ignored the tax free band.

Yes I do think it would be likely to end up in employees pockets for many actually, over time (but probably only for a few overnight). This is what has largely happened with employer pension contributions which were capped first via the lifetime allowance and then the taper down from 40k to 10k for income over 150k. Most employers now offer a cash (ie salary increase) alternative at neutral cost to the employer.

Not including employers contribution when comparing countries is just non-sense to me: the only number that matters is the total cost per added employee for a business, and on the other side for the employee the after-tax money that remains after everything is deducted. And then you can put the services you get for the money (i.e. yes taxes are higher in France for instance, but the state provides also much more).

Withdrawal of child benefit puts a 60% or more marginal rate from £50k to £60k (plus the 12% employer ni)

The professionals in the UK work on a b2b basis because with current salaries and taxes it makes no sense to be an employee. Still you get taxed highly, but it is slightly better. Sadly the Tories are turning left and they look into taxing professionals too. I would be looking into leaving the country if they do.

And it's the third biggest economy in the world. My conclusion is that having a huge healthy educated talent pool is more important to companies than taxes.

I agree completely.

California is an outlier!

After taxes, insurance and maxing out my 401k (i.e. all the stuff that comes out of my paycheck) I take home 56% on the East coast (in a high tax state no less). I also pay less sales tax and transportation costs than I would in CA and I can afford a house with less than six figures (gross) household income.

You make paying 45% for France's system sound like a deal for a lifetime.

45% is only the (higher bracket) "federal taxes" (France isn't a federal country) that don't include all the welfare contributions which are taken from your salary (22% IIRC) and also the higher employer contributions.

Edit, FYI: - 14% from 9 964 € to 27 519 € - 30% from 27 519 € to 73 779 € - 41% from 73 779 € to 156 244 € - 45% beyond 156 244 €

And the table here for the social contribution that are taken out of your pay before the taxes above are applied: https://fr.wikipedia.org/wiki/Cotisations_sociales_en_France...

I left those out of my headline numbers too though.

Yeah I just clarified because of the part that said "for France's system", this part of the tax is not what's paying for the welfare part of the "system". According to https://argent.boursier.com/impots/analyses/ou-va-largent-de...

- 23.5% for tax credit for other people (i.e. think about solar panels, etc.)

- 15.7% for primary/secondary education (i.e. from kindergarten to 12th)

- 13.6% for counties and other local / regional structures.

- 11.5% for interest on the debt.

- 9.35% for the Defense budget.

- 6.35% for Universities (education and research) => This is paying for ~ free education!! Probably the best deal in the French system compared to the USA.

- 5% for Europe

- 4.3% Police

- 1.9% Judiciary

You aren’t paying the top marginal rate unless you make over $600k as a couple or $500k as a single.

Also the top marginal rate is 37%, not 39.5 (Thanks Donny.)

And SALT? Rather than “thanking” Donnie for the reduced deductibility, perhaps complain that they are so high as to exceed the allowable cap in the first place?

This is simply wrong. Income tax percentage depends on how much money you make, and it goes from 0% to 45%.

You pay 0% up to 9807€ of income. Anything above that and under 27086€ you pay 14% on it. Then between that and 72617€ you pay 30% on it. And then between that and 153783€ you pay 41% on it.

Finally, you pay 45% only if you make more than 153783€ per year and again, only on euros that you earn above this threshold.

As an associate professor early in my career my income tax amounts to around 12% of my salary I think.

Just to make things clear, income tax is indeed progressive, and 45% is the maximum income tax and very few get to that level.

However, it is far from the whole story: when you get paid, the employer pays taxes, then the employees pays taxes, and only then, you have your income, which is taxed again.

In the end, you get around half of what your employer pays. It means the "more than 45%" is spot on. It works a bit differently for those who are self employed but the numbers are similar.

It is different for civil servants, and as an associate professor, you are probably one. They are taxed much less, which makes sense since they are paid with tax money.

No, this is right, you have wrong. You have your gross salary (brut) on which you and your employer pay taxes (routhly 30%). And then on top of that you pay the tax you describe with a progressive tax rate up to 45%. So on average, 45% seems good to me.

If you speak in gross rather than in net, then it is even a lot more than what you're saying. But then it is not income tax, which is the percentage of what was discussed.

If you want to account for everything that is removed from your salary between gross cost for the employer and your net after taxes, it will surely be between 50% and 60% in average. But then we can talk about the benefit of all this.

I don't know for you but I strongly prefer that and the ability for everyone to get an education, health, unemployment, retirement, infrastructures, etc. than doubling or even more my own salary. Viruses won't stop spreading if you have money. Health is a social and political issue, not a personal one. I like being able to drive everywhere and not just in cities where people are rich enough to pay for roads. I like that when a friend is fired from their job they can keep their appartement until they find a new job. I like teaching to everyone who wants to learn rather than to the children of people rich enough to pay for tuition fees. I like that my parents will get a retirement salary and won't be in my charge when I may also have kids to take care of.

Now of course our system is not perfect and I largely idealized it here. But it is far better than if everyone would get their gross salary, paid no taxes, and would be able to care only for themselves.

> But then it is not income tax, which is the percentage of what was discussed.

On the contrary, this matches what is "Income tax" in the US.

> If you want to account for everything that is removed from your salary between gross cost for the employer and your net after taxes, it will surely be between 50% and 60% in average. But then we can talk about the benefit of all this.

But that is the discussion, I don't think anyone considered that there are higher taxes in France without any benefit for it.

Yes if all you think about is yourself then that works well.

Personal attacks aren't ok here. Please don't post like this, regardless of how wrong you think another commenter is. It degrades discussion considerably.

https://news.ycombinator.com/newsguidelines.html

Note the if. But you’re welcome to s/you/someone. It’s ment as a general statement without going into the details as to why a welfare system might be a good idea. Also you’re judging that only thinking about yourself is a negative thing.

> Yes if all you think about is yourself

How does saving your own money preclude you from thinking about others?

It was implied in he commment, since commenter didn't add in a factor to cover donations to others.

Implied in which comment? Where?

> Federal income tax

1. France is not a federal state.

2. Income tax doesn't pay (directly) for health insurance. Income tax also doesn't pay for social security. You're comparing apples to oranges.

France also has a 20% VAT.

Like a lot of European countries. For Germany the (very) rough rule of thumb is net salary equals 50% of gross salary (please refer to your German tax adiver or accountant for more details). That is after taxes, social security, health insurance and unemployment insurance.

In the U.S. that's true for high income professionals in high-cost states. For more typical salaries, even good ones in big cities, it's more like take home is 75% of gross.

Do those systems really work? Civil servants always find a way to deny support because you miss X or Z (I am talking mostly about the UK). I learned that it is best to take care yourself of yourself and don't depend on the state. I view the extra tax for the stuff I can't use as a theft.

> Nation-wide solidarity costs little to each person but gives a lot to those who need it.

The money I save from French taxes (I left this year) I can easily afford all manner of insurance plus I get paid a heck of a lot more to save quite a bit of money.

French employment is over 10% and the economy is stagnant. Could it be if you incentivize unemployment you get more of it? It sure seems like that in France. Chronic and intentional unemployment is not unusual in France. And everyone gets to pay for it. Disposable income in France is also significantly less than in the US.

The reasons for high unemployment in France are, I would suggest, more to do with how hard it is to fire people in France than taxes. If you know you'll be stuck with someone forever, you take the decision to hire much more seriously and you'd much rather ask an existing employee who's a known quantity to do more work instead (potentially even if you pay them more in raises than it would have cost to hire someone else).

Contrast that to e.g. Denmark where taxes are arguably higher but making redundancies/reducing workforce is not anything close to as hard or expensive for the employer.

Fair point; the French labor code is the problem, however taxes are related; the high cost of being stuck with someone is higher due to social charges and taxes. Reforming the labor code and lowering taxes would both make the employment market more liquid.

I'd water that most adults in the US know one or more hard-working people who are in financial dire straits due to medical bills. It's reasonable that you don't want a single-payer system in the US but why in Earth would you boast about our current healthcare system?

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