Onesource Corporate Consulting,Inc.: Tax and financial reporting considerations

This case places you in the role of a new staff accountant at a public accounting firm who is asked to research financial accounting and tax issues for a client engagement. The client, Onesource Corporate Consulting, Inc. is a large, rapidly growing and successful consulting firm that specializes in corporate restructuring work, forensic investigations, litigation consulting, strategic communications consulting, economic consulting, and technology development. You must research issues affecting the company’s financial statements and tax reporting, including: contingent debt, forgivable loans issued to employees, revenue recognition for various types of contracts, and lease incentives. You will likely find this case challenging. However, this case is based on a real company and the research and analysis required in this case is reflective of issues and assignments you may encounter early in your career.     

Regal Hair Salon: Tax and financial reporting of gift cards

Regal Hair Salons Inc., an owner and operator of hair salons across the United States, has enhanced its brand recognition through gift cards and promotions. Using authoritative tax literature, you have to determine the amount and timing of its federal income tax liability for the gift cards of other retailers that Regal has sold, gift cards for its own products and services, and the gift cards that it has issued during a special promotion. You also have an opportunity to determine whether Regal’s financial reporting policies with respect to gift cards are consistent with Generally Accepted Accounting Principles (GAAPs), using FASB Accounting Standards Codification. Finally, based on your review of book-tax differences, you are to determine the appropriate current and deferred tax provision. The case provides an opportunity to examine several issues in a real-world setting, strengthen your tax and accounting research capabilities, and develop your critical thinking skills.     

Barbados Spirits Inc.

This case focuses on the audit of a subsidiary in Barbados of a Multi‐National Entity (“MNE”), a distiller in Toronto. The MNE is a large and important international client to the accounting firm. The firm provides both tax advisory and audit services to the MNE. The MNE, following advice of the accounting firm, has utilized an offshore related party to structure transactions that avoid taxes in Barbados. These related party transactions are a detriment to the interests of critical users of the financial statements, namely the minority shareholders and the tax authorities of Barbados. The auditor is now faced with evaluating the adequacy of the related party note disclosure and the completeness of the income tax provision. Independence issues of a self‐interest threat (importance of the client) and self‐review threat (evaluating the adequacy of the income tax provision based on tax advice provided by the firm) are explored.     

Currency Denomination of Intercompany Debt and Multinational Taxes

For multinational companies (MNCs) with foreign subsidiaries, the currency denomination of intercompany debt can have important effects on both taxes and financial statements. This paper analyzes the choice between an intercompany loan denominated in the home currency and one denominated in the subsidiary's functional currency. Using U.S. rules for financial accounting and taxes, the author demonstrates the expected impact of the loan's currency denomination on the expected level and variability of an MNCs overall taxes in the case where it has excess foreign tax credits.
The author's analysis shows that the foreign currency loan denomination leads to lower expected tax if the foreign withholding tax rate on interest is higher than the parent's home income tax rate. At the same time, the parent currency denomination leads to lower expected taxes if the parent's home income tax rate is higher than the foreign withholding tax rate on interest. Moreover, if an MNCs excess foreign tax credits are attributable to the subsidiary, the foreign currency loan denomination leads to lower variability in overall taxes. But in cases where the excess foreign tax credits arise from other foreign operations, the parent currency denomination leads to lower variability of overall tax.     

Converging to International Accounting Standards: Views from Japan

Many countries, including the European Union member states and Australia, adopted international accounting standards in 2005. This year was also critical in Japan for convergence activities. Based on a review of 2005 financial statements and a survey of securities analysts, this study identifies key issues for convergence of Japanese and international accounting standards. We find that accounting requirements relating to fair value measurement, comprehensive income items, leases and business combinations are relevant to Japanese firms. A survey of 974 members of the Security Analysts Association of Japan about these issues indicated support for convergence and the use of fair value measurement, disclosure of comprehensive income, recognition of leases and use of the purchase method for consolidation. We report support for several positions favoured by the International Accounting Standards Board (IASB), a positive signal for achieving convergence goals in Japan, which will be of interest to capital market participants in Japan and other countries .     

Real Effects of Accounting Rules: Evidence from Multinational Firms’ Investment Location and Profit Repatriation Decisions

We analyze survey responses from nearly 600 tax executives to better understand corporate decisions about real investment location and profit repatriation. Our evidence indicates that avoiding financial accounting income tax expense is as important as avoiding cash income taxes when corporations decide where to locate operations and whether to repatriate foreign earnings. This result is important in light of the recent research about whether financial accounting affects investment and in light of the decades of research on foreign investment that examines the role of cash income taxes but heretofore has not investigated the importance of financial reporting effects. Our analysis suggests that financial reporting is an important factor to be considered in the policy debates focused on bringing investment to the United States.     

Using Financial Accounting Data to Examine the Effect of Foreign Operations Located in Tax Havens and Other Countries on U.S. Multinational Firms' Tax Rates

This paper investigates the effect tax havens and other foreign jurisdictions have on the income tax rates of multinational firms based in the United States. We develop a new regression methodology using financial accounting data to estimate the average worldwide, federal, and foreign tax rates on worldwide, federal, and foreign pretax book income for a large sample of U.S. firms with and without tax haven operations. We find that on average U.S. firms that disclosed material operations in at least one tax haven country have a worldwide tax burden on worldwide income that is approximately 1.5 percentage points lower than firms without operations in at least one tax haven country. Our results also show that U.S. firms face a 4.4% current federal tax rate on foreign income whether or not they have tax haven operations. Finally, we find that U.S. firms with operations in some tax haven countries have higher federal tax rates on foreign income than other firms. This result suggests that in some cases, tax haven operations may increase U.S. tax collections at the expense of foreign country tax collections.     

Great Galway Goslings: Organizational Context of Managerial Accounting*

This case seeks to enhance student understanding of the relationship between accounting information and the order fulfllment and production activities of a manufacturing frm, Great Galway Goslings. Great Galway Goslings manufactures goose sculptures and has been suffering losses in recent years. Students draw on the skills they learned in financial accounting to analyze the company's order fulfllment activities, identify economic transactions, and prepare journal entries. The case provides a link to managerial accounting topics as students use segment financial statements to create contribution margin income statements, perform break‐even analyses, and recommend whether Great Galway Goslings should keep its retail business segment. Students will become familiar with the key features of business process management (BPM) and the extensive, real‐world activities that a manufacturing entity engages in to fll an order. Students will analyze the company's existing order fulfllment process and apply their knowledge of BPM to recommend process improvements for Great Galway. This case contributes to the accounting case literature by serving as a bridge from financial accounting to managerial accounting, intertwining many topics from managerial accounting into one cohesive case, and providing real‐world business process knowledge. Student feedback indicates that, overall, the case met its stated learning objectives. Great Galway Goslings is appropriate for an undergraduate introductory managerial accounting course but can be adapted to the equivalent graduate‐level course or an accounting information systems course.     

企业境外所得税收抵免政策解析

税收管辖权的重叠必然导致国际间重复课税。抵免法是各国推荐的消除重复课税的方法。本文在介绍国际税收抵免相关概念和原理的基础上,就我国企业境外所得税收抵免有关问题进行了分析解读,并比较了新旧政策的主要变化。     

新会计准则对企业所得税的影响

2007年1月1日,我国上市公司率先实行新的会计准则,不久的将来则有更多的非上市公司也将实行新的会计准则。这套新会计准则体系起点高、范围大、创新多,标志着我国的会计准则与国际会计准则实现了实质性的趋同。新会计准则的实施,不仅影响企业的财务状况和经营成果,而且对企业的申报纳税也产生重大影响。本文以现行税法和新会计准则体系为依据,重点研究探讨新会计准则对企业所得税的影响。     

论我国所得税会计处理方法的选择——基于所得税会计准则的国际比较研究

会计制度与税收制度之间差异的协调在相当长一段时间内都将是会计理论界与实务界的热点问题。当前,国际会计准则的制定,更多受到了英美等发达市场经济国家的影响,会计信息更强调反映企业的长期盈利能力,而非限于企业短期盈利状况;相应地,其会计报告的概念基础不再采用“收入费用观”,而是转向了“资产负债观”,在所得税会计处理方法上,也强调采用资产负债表债务法。我国新发布的所得税会计准则的一个突出变化是,强调采用资产负债表债务法,是我国所得税会计准则国际趋同的一个重要体现。     

居民企业境外所得税收抵免的计算

当居民企业取得境外所得时,通常已经在所得来源地按照当地的相关法律缴纳过所得税。如何按照我国税法规定正确计算可抵免的境外所得税额是每个有涉外业务的居民企业面临的难题。本文介绍了居民企业境外所得税收抵免相关项目的计算,并以案例的方式进一步加以分析。     

Boxing and Martial Arts Company,A Tax Case

A tax case is developed examining a private Canadian sports company. This case simulates a real‐world start‐up company in the area of Canadian Controlled Private Corporation taxation. The client, Boxing and Martial Arts Co., is a medium‐sized, rapidly growing sports promotion business. It operates in an environment where cash payments are common, especially towards foreign workers. Students must research issues involving tax deductions and revenue recognition. The learning objectives include: reinforcing taxation concepts that most students learn in introductory courses (i.e., revenue recognition, allowable business expenses) as well as improving students’ tax research skills for more complex issues (e.g., international tax treaties).     

新旧会计准则下所得税会计核算的比较研究

为与国际惯例趋同,我国对会计准则体系进行了修订,2006年财政部颁布了新企业会计准则。与旧准则相比,新会计准则变化很大,如所得税会计核算,需要根据新会计准则重新设置会计科目进行会计核算,进一步明确了所得税会计信息的披露内容,以最大限度地满足会计信息使用者的需求。     

Accounting for deferred tax in Japanese Banks and the consequences for their international operations

In recent years, financial reporting has changed in Japan towards the requirements of internationally recognized accounting standards. At the same time, banks suffered significant bad debts on their loans and it became difficult to maintain capital adequacy ratios at the level required for international operations. In this context, using as case studies the five major banking groups in Japan from 2002 to 2004, we address four related research questions concerned with the importance of deferred tax for the maintenance of regulatory capital. The responses of the government, regulatory agencies and auditors to problems with deferred tax accounting are also considered. We find that, without deferred tax assets, the five major banking groups would not have been allowed to operate internationally. We also suggest implications, and conclude that the solutions to these problems lie not just with the accounting profession but also with the government and regulatory agencies, as part of wider financial, rather than accounting, reform.     

The incentive to locate a multinational firm: The effect of tax reforms in the United Kingdom

The advent of the single European market has focused attention on the structure of international tax incentives for the location of multinational business. Multinationals that channel foreign income through the United Kingdom have been likely to suffer double taxation in the form of surplus advance corporation tax when they subsequently distribute the income to a foreign parent. This paper shows that the 1993 U.K. tax reforms create a significant reduction in the tax cost of locating in the United Kingdom, relative to traditionally favorable tax regimes such as the Netherlands.     

Capital Mobility and Source-Based Taxation of Capital Income in Small Open Economies

This paper examines the taxation of capital income in a small open economy that faces a highly elastic supply of internationally mobile capital and increasing tax competition. The analysis considers a wide variety of additional factors that affect the determination of capital income taxation policy, including the desire to tax economic rents earned by foreign and domestic firms, the desire to take advantage of any treasury transfer effects, the role played by transfer pricing and other financial accounting manipulations by foreign multinationals, the need for a backstop to the personal income tax and various political concerns. The paper evaluates several potential income and consumption-based tax reforms in this context. JEL Code: H21, H25, H87     

Accounting and Legal Implications of the Interposed Unit Trust Instrument

The application of a unit trust, within a complex group structure, to transact business and to hold other dependent operating instruments such as subordinate trusts, proprietary companies and investments in joint arrangements, raises issues touching the laws of trusts, income taxation and companies and exposes deficiencies in current accounting theory, practice and financial reporting. The use of unit trusts has off-balance sheet effects as both the trust itself and all subordinate instruments within its constellation may be effectively partitioned from those group results reported under traditional consolidation principles. The consequences of this partitioning distort the consolidation process and financial statements may then misrepresent a group's financial position. As yet, there is neither legislation nor accounting regulation providing direction in this complex area.     

关于加强涉外税收征管的研究和思考

目前,我国涉外税收征管中存在许多问题,表现在对违章处理不严、税收稽查面过窄、境外所得基本失控、漏征漏管户数多等,造成这些问题存在的根本原因是内外资两套企业所得税法并存、执法与引资对立的观念作祟和税务机关本身存在的一些问题。为此,我们必须大力贯彻科学发展观,正确对待外资,提高税务干部素质,加强国、地税之间的沟通和协作,借鉴国外征管经验,加强国际税收协调,全面改进涉外税收征管。     

Development of and student reactions to an international consolidation case problem

Use of case problems is a well established pedagogy for enhancing student learning. This paper describes development of an international consolidation case problem and reports how students responded to its assignment. The case problem could be effectively used in accounting classes such as international accounting and advanced accounting. Further, the case could be used to introduce professional accountants, who may not have previously faced this issue, with a basic overview of the international consolidation process. The issue of consolidation is typically covered in advanced accounting courses, and international financial reporting is covered in international accounting or intermediate accounting courses. The international consolidation case described in this paper makes a unique contribution by incorporating both consolidation accounting and international financial reporting (specifically, foreign currency translated financial statements) into one comprehensive case problem. When a subsidiary corporation is located in a different country from the parent corporation, the difficulty of consolidating the financial statements becomes more complex than for a strictly domestic company, as a result of different GAAPs and different currencies. The case problem has been used in two southwestern US universities. Student feedback indicates that the problem was well received and benefited student learning.