Blaine G. Saito

Document Type



Taxation-Federal | Tax Law


A great deal of scholarship focuses on whether we should place social safety net and redistribution programs within the tax sphere and under the responsibility of the IRS. But much of this literature misses a key point. These programs are here, and they are unlikely to leave the tax sphere. But little is said about how to approach administering them.

This Article suggests the IRS administer these programs under a new framework called contextualized purpose. The idea is that these tax programs should be organized and managed in a way that comports with the broader context of the social safety net and redistribution in which they exist. In applying this approach, the IRS would discern the various purposes, values, and goals of these programs and note how they interrelate with other purposes, values, and goals within the tax system and the broader social safety net. To that end, contextualized purpose often requires that the IRS coordinate with other agencies to avoid administrative cross-purposes and that the agencies iteratively grow through learning by doing.

The Article uses contextualized purpose to examine and suggest administrative changes to key income support programs like the earned income tax credit (EITC), the child tax credit (CTC), and the pandemic economic impact payments (EIP). It then discusses some of the advantages and concerns with this approach and how this approach fills the gap left by traditional discussions of tax programs to effectuate social policy.