An Investment Management Methodology for Publicly Held Property/Casualty Insurers

Investment officers of publicly held property/casualty companies wrestle with the question of how best to contribute to shareholder value. Should they view themselves as managers of a closed‐end investment company that happens to be funded by insurance underwriting? Or should they instead be investing funds primarily to defease the firm's liabilities and thus support the operations of a company whose principal value derives from its insurance activities? The authors of this article suggest that the investment policy of most insurance companies should have two primary objectives: (1) immunizing insurance reserves with a fixed‐income portfolio and (2) earning “abnormal returns” on surplus in “a responsible and disciplined” way. The latter means adhering to an asset allocation approach that takes account of the risk‐reward tradeoffs presented by a broad variety of investment types as well as the accounting treatment of investment income. Both accounting and economic considerations lead the authors to suggest that after‐tax net investment income (“NII”), as defined by U.S. GAAP, is the best benchmark of performance. While focusing mainly on the fixed income part of the portfolio, the authors suggest active management and portfolio approaches that aim to produce a growing, but relatively stable NII. Consistent with GAAP's treatment of NII (which includes interest income but excludes most capital gains) as “recurring income,” the authors argue that the market appears to assign significantly higher multiples to NII than to other sources of reported income.     

A SIMPLER CONSUMPTION-BASED ALTERNATIVE TO THE INCOME TAX FOR SOCIALIST ECONOMIES IN TRANSITION

The tax systems of socialist economies in transition will distortresource allocation, create inequities, and cause administrativeheadaches if not reformed. These countries have weak tax administrations,lack experience with mass taxes based on voluntary compliance,and need to encourage domestic saving and foreign investment.This article suggests an alternative to the conventional incometax that is more suited to these conditions. Attempting to tax real economic income raises complicated timingissues (when to recognize income and allow deductions) and mayrequire complex adjustments for inflation. The simplified alternativetax (SAT) avoids these complications and provides a generalincentive for saving and investment less subject to abuse ordistortions than tax holidays and other tax gimmicks in voguein countries emerging from socialism. The key elements of the SAT are separate taxes on income fromlabor and capital, immediate deduction for all business expenditures,no deduction for interest, and no taxation of interest or dividends.(Interest could be treated as under an income tax, at some cost.)Although the marginal effective tax rate is zero, the governmentshares in extraordinary returns to investment. The article discussespotential problems (including distributional implications, taxlosses, and foreign tax credits) as well as advantages of theSAT.      

Corporate flat tax reforms and businesses’ investment decisions: evidence from Switzerland

This paper focuses on the effects of a corporate income flat tax reform on businesses’ investment decisions. Since 1990, several Swiss states (cantons) have been switching from a graduated to a flat tax rate scheme on profits. The paper assesses the effects of such a reform both on the number of establishments (i.e. extensive margin of investment) and on the number of employees (i.e. intensive margin) in a given jurisdiction by computing a difference-in-differences estimation. Our results suggest that the introduction of a flat tax reform on corporate income taxes has a negative and statistically significant impact on both margins of investment. Moreover, the effect is considerably larger for riskier firms, suggesting that progressive taxation acts as an insurance effect for risk-averse entrepreneurs.     

企业所得税优惠政策研究

本文从免税收入、免征减征企业所得税和降低税率三个方面,对国债利息收入、权益性投资收益、非营利组织收入、农林牧渔业项目所得、国家重点扶持的公共基础设施项目投资经营所得、环境保护节能节水项目所得、技术转让所得以及小型微利企业、高新技术企业的企业所得税优惠政策进行了分析,提出了若干实施和完善企业所得税优惠政策的建议。     

Voluntary disclosure of operating income

This study investigates whether New Zealand firms’ voluntary disclosure of operating income, which is also known as earnings before interest and tax, in the income statement is related to the investment opportunity set. New Zealand provides an ideal setting to examine this because New Zealand generally accepted accounting principles do not require the disclosure of operating income as an intermediate income number in arriving at net income (earnings) in the income statement. We hypothesize and find evidence that firms with high assets‐in‐place and high leverage are more likely to voluntarily disclose operating income/earnings before interest and tax. However, the assets‐in‐place finding is sensitive to alternative measures of the investment opportunity set.     

保险公司资产组合与最优投资比例研究

保险公司收益主要来源于承保利润和投资收益,其中承保利润受政策变动、市场条件等外部环境的影响较大,而投资收益则更多地取决于保险公司的投资能力,因此保险公司如何构建资产组合、如何确定最优投资比例就是获取投资收益最大化的重要因素。本文通过理论推导得出了保险公司的资产组合模型并运用非线性规划求解出最优投资比例,进而根据保险公司的投资数据进行了实证研究,为我国保险公司的资产组合及最优投资比例提供了一个可借鉴的思路。     

Direct evidence of dividend tax clienteles

The paper is the first to evaluate the dividend tax clientele hypothesis using a data set of all domestic stock portfolios in the market. We find that investment funds that face a higher effective tax rate on dividend income than on capital gains tilt their portfolios away from dividend-paying stocks. These investors consequently earn a dividend yield that is about 35 basis points lower than that of investors who are tax neutral between dividends and capital gains (pension funds, unit-linked insurance, life insurance). Consistent with tax rules and charter provisions, we also find that private corporations prefer growth stocks, that foundations exhibit strong dividend preferences, and that partnerships rarely hold stocks portfolios.     

《企业所得税法》源泉扣缴上的几大变化

本文对"两法合并"后所得税源泉扣缴政策的重大变化进行了归纳总结:预提所得税减按10%征收;法定扣缴日期由五日变为七日;对税务机关指定扣缴新设定了三种情形;新增特定情况下的欠税追缴;非居民企业取得权益性投资收益不再免税;利息所得的免税范围有变化;转让财产所得减除项目由"原值"变为"净值"等。     

Taxation and the optimal constraint on corporate debt finance: why a comprehensive business income tax is suboptimal

The tax bias in favour of debt finance under the corporate income tax means that corporate debt ratios exceed the socially optimal level. This creates a rationale for a general thin capitalization rule limiting the amount of debt that qualifies for interest deductibility. This paper sets up a model of corporate finance and investment in a small open economy to identify the optimal constraint on tax-favoured debt finance, assuming that a given amount of revenue has to be raised from the corporate income tax. For plausible parameter values, the socially optimal debt-asset ratio is 2–3% points below the average corporate debt level currently observed. Driving the actual debt ratio down to this level through limitations on interest deductibility would generate a total welfare gain of about 5% of corporate tax revenue. The welfare gain would arise mainly from a fall in the social risks associated with corporate investment, but also from the cut in the corporate tax rate made possible by a broader corporate tax base.     

美国税收递延型企业年金分析及对我国的启示

随着人口老龄化日趋严重,税收递延企业年金已成为各界关注的焦点。以美国税收递延企业年金为研究对象,运用序数效用理论和消费者均衡,结合风险因子、工资、缴费期限等因素,分析其微观经济效应;进而根据美国的所得税率,测量各模式的收入积累效应,以及对工资、投资收益、缴费参数进行敏感性分析,对比度量各参数值对个人积累值的影响。结果显示：美国现行的免除企业和个人所得税的 EET 税延方式是最优的,参加税延型企业年金计划可增加个人积累;缴费年限对退休后积累值的敏感性最高,投资收益率、工资依次次之,缴费率不敏感。由此,结合我国情况建议采取 EET 模式,延长缴费年限,降低门槛和放宽投资,建立法律审查机制。     

Redistribution as Social Insurance and Capital Market Integration

In this paper we claim that enhanced economic integration can call for an increase in redistribution among workers. When individuals are risk averse and no human capital insurance is available, the share of workers who choose to invest in specific human capital will be inefficiently low. Redistribution among workers plays the role of the missing insurance market by making the investment in the specific skills more attractive. Capital market integration has two different effects. On the one hand it makes labour income taxation more distortionary, therefore reducing the optimal tax rate on labour. On the other hand, it increases the variance of specific labour wage and widens the scope for risk protection of specific human capital through the redistribution implemented by a labour income tax. We show that the insurance effect of redistribution can be stronger than the distortionary effect, so that the optimal tax rate on labour income can increase when capital markets become more integrated.     

我国保险公司税收制度的完善

我国保险公司税制存在诸多弊端 ,如 :中外资保险公司所得税待遇不同 ,营业税负担过重等 ,阻碍了保险业的发展。笔者建议在考虑政策目标 ,税收原则 ,最终纳税人等相关因素的前提下 ,改革现行保险公司税制。如 :统一中外资保险公司所得税税率 ,降低营业税率并实行差别税率等。     

税收优惠的国际竞争与影响

税收优惠竞争具有促进自由竞争、保障发展中国家的利益、保障外国投资者利益、对征税权力的约束的正面影响,也具有破坏生产效率、损害税收公平与社会福利、侵蚀其它地区的税基、破坏所得税的累进效果等负面影响。我国在新时期的税收优惠调整中,应该根据税收优惠竞争的正、负面影响综合考虑吸引投资与全民福利最大化双重因素。     

Reinsurance and corporate taxation in the United Kingdom life insurance industry

There are two main tax-related arguments regarding the use of reinsurance – the income volatility reduction and the income level enhancement arguments. The income volatility reduction argument contends that firms facing convex tax schedules have incentives to hedge in order to reduce the volatility of their annual taxable income and thereby lower expected tax liabilities [Smith, C.W., Stulz, R.M., 1985. Optimal hedging policies. Journal of Financial and Quantitative Analysis 19, 127–140]. The income level enhancement argument, advanced by Adiel [Adiel, R., 1996. Reinsurance and the management of regulatory ratios and taxes in the property–casualty insurance industry. Journal of Accounting and Economics 22, 207–240], is more specific to hedging via reinsurance. This perspective holds that reinsurance enhances current reported earnings via the receipt of reinsurance commissions and so increases tax liabilities. Consequently, insurance firms with high marginal tax rates should use less reinsurance than those with low marginal tax rates if tax matters. Prior studies using data on financial derivatives have produced mixed results on the validity of the first argument, while Adiel (1996) finds the second argument insignificant in his study of the use of reinsurance by a sample of United States (US) property–liability insurance firms. This study tests the two tax-related arguments using 1992–2001 data for a sample of United Kingdom (UK) life insurance firms. We find that UK life insurers with low before-planning marginal tax rates tend to use more reinsurance; in contrast, tax convexity is found to have no significant impact on the purchase of reinsurance and so the volatility-reduction argument is not supported.     

A hybrid consumption-based direct tax proposed for Bolivia

In 1994 the authors designed a consumption-based direct tax for the government of Bolivia. The proposal combined yield exemption treatment (exemption of interest income and no deduction for interest expense) of individuals with consumed income tax treatment (taxation or deduction of the net proceeds of borrowing and lending, as well as interest income and expense) of business. This article explains why taxation based on cash flow has administrative and economic advantages over a conventional income tax and why the hybrid system proposed is preferable to either pure form of consumption-based tax.     

中国保险业税收的制度、效应及完善机制探析

保险是现代经济的核心组成部分和经济发展的促进因素之一.当前,中国保险业的税收负担偏重,而各种税收影响保险需求方的功能较弱.实证分析表明,保险公司的实际税率对其盈利水平具有显著负效应,税收可以通过影响保险消费者的收入、保险价格进而影响保险需求.基于减轻保险业税收负担、刺激保险供求的基本原则,把结构性减税和整体性减税结合起...     

How Firms Make Capital Expenditure Decisions: Financial Signals, Internal Cash Flows, Income Taxes and the Tax Reform Act of 1986

This paper empirically assesses the determinants of future net capital expenditures for a broad cross-section of COMPUSTAT firms from 1973 to 1989. We explore three general categories of factors expected to affect investment: (1) external equity financing, (2) internally generated accounting information, and (3) tax incentives. We find that external financing and information plays a role in that both positive stock returns and equity issuances indicate future increases in investment. The results suggest that high stock prices not only lower the cost of capital, but also signal good investment opportunities. Accounting information about internal sources and uses of funds are also important in the investment decision. In particular, net income and depreciation are positive indicators of future investment while there is a tradeoff between the payment of dividends and investment. Further, positive changes in available cash liquidity also motivate future investment. While taxes are not important in the investment decision on average, we find that firms with previously higher income taxes invested substantially more in 1985 and 1986. This coincides with the repeal of the investment tax credit and the accelerated depreciation schedules in the Tax Reform Act of 1986. We view this as evidence that federal tax policy in the 1980's induced firms with high income tax obligations to accelerate capital expenditures just before the favorable tax treatment of capital expenditures was eliminated.     

Social long-term care insurance and redistribution

We study the role of social long-term care (LTC) insurance when income taxation and private insurance markets are imperfect. Policy instruments include public provision of LTC as well as a subsidy on private insurance. The subsidy scheme may be linear or nonlinear. For the linear part we consider an arbitrary number of types, characterized by earnings and survival probabilities. In the nonlinear part, society consists of three types: poor, middle class and rich. The first type is too poor to provide for dependence; the middle class type purchases private insurance and the high income type is self-insured. The main questions are at what level LTC should be provided to the poor and whether it is desirable to subsidize private LTC for the middle class. Interestingly, the results are not totally similar under both linear and nonlinear schemes. First, whereas in the linear case a subsidy of private LTC insurance is desirable, it is not in the nonlinear case (at least at the margin). Second, the desirability of public provision of LTC services depends on the way the income tax is restricted. In the linear case, it may be desirable only if no demogrant (uniform lump-sum transfer) is available. In the nonlinear case, public provision is desirable when the income tax is sufficiently restricted. Specifically, this is the case when the income is subject only to a proportional payroll tax while the LTC reimbursement policy can be nonlinear.     

U.S. tax policy and health insurance demand: Can a regressive policy improve welfare?

The U.S. tax policy on health insurance is regressive because it subsidizes only those offered group insurance through their employers, who also tend to have a relatively high income. Moreover, the subsidy takes the form of deductions from the progressive income tax system giving high income earners a larger subsidy. To understand the effect of the policy, we construct a dynamic general equilibrium model with heterogenous agents and an endogenous demand for health insurance. A complete removal of the subsidy may lead to a partial collapse of the group insurance market, reduce the insurance coverage and deteriorate welfare. There is, however, room for improving the coverage and welfare by extending a refundable credit to the individual insurance market.     

境外投资所得税收管理存在的问题与解决措施

本文分析了当前我国境外投资税收管理存在的主要问题,如境外投资的现行税收政策不够完善、税收管理权限不明确等,并就如何加强境外投资所得税收管理提出了相应对策。