Beta Geared and Ungeared: Further Analysis of the Case of Active Debt Management

This paper extends previous work by Appleyard and Strong (1989) concerned with the implications of an active debt management policy (ADMP) for de-gearing a geared firm's equity beta. First, alternative derivations of the ADMP beta de-gearing formulae for an MM perfect capital market with corporation tax and for a world with corporation and personal taxes are presented. These derivations do not require the assumption of level perpetuity expected cash flows and therefore indicate a broader basis for the ADMP beta de-gearing formulae than previously demonstrated. Secondly, possible investor valuation errors from use of a PDMP (passive debt management policy) valuation methodology to value firms pursuing an ADMP are analysed in the context of an MM perfect capital market with corporation tax. Given constant (or zero) growth in the firm's expected unlevered cash flows, this analysis indicates that degearing errors from use of the PDMP beta de-gearing formula will only be associated with valuation errors if there is a change in the firm's target debt ratio and that the significance of such valuation errors will be largely dependent on the expected growth rate.     

Beta Geared and Ungeared: The Case of Active Debt Management

This paper extends the results of Buckley (1981) and Schnabel (1983) on the relationship between geared and ungeared betas. We contrast a passive debt management policy with an active debt management policy and derive the relevant beta degearing formulae for the case of an MM perfect capital market with corporation tax. We also extend these results to a world with personal taxes and debt related costs.     

中国产业投资基金组织形式探讨

产业投资基金(也称私募股权基金或股权投资企业)已经成为全球资本市场的重要参与者,但在我国尚处于起步阶段.在我国现行法律制度下,产业投资基金可能采取的组织形式分别为公司制、有限合伙制及信托制.本文针对投资者权利、税收地位、激励机制、资金筹集、资本退出、承诺出资制度及监督机制等方而对三种产业投资基金进行了分析比较,认为公司制和有限合伙制提供了较为完备的制度规范和税收优势,应成为未来我国产业投资基金的主要组织形式.     

Do government preferences matter for tax competition?

This paper explores how government preferences affect capital tax decisions of a country. We develop a model in which governments, differentiating in their preferences for economic development and income equality, compete for mobile capital over corporation taxes. The key prediction of the model, borne out in data from OECD countries over the years 1990–2012, is that an increase in government preferences for pursuing economic development relative to income equality makes countries’ horizontal tax reactions stronger. Unlike the existing studies, our result contributes to the tax competition literature by highlighting the importance of government preferences in determining the extent of tax competition among countries and so offering a novel explanation for the widely observed heterogeneous tax policies across countries.     

Tax, Corporate Behaviour and the Foreign Income Dividend Scheme

A model is derived which considers the interactions of corporation tax, advance corporation tax (ACT) and capital gains tax and their impact on UK corporate behaviour. It is shown that the recent changes to the ACT system, in the form of the Foreign Income Dividend (FID) scheme, will increase the gearing ratios of those firms affected by the changes. Debt will become more attractive, since it no longer increases irrecoverable ACT by reducing taxable profits. Furthermore, retention rates will fall, since retentions no longer serve as an ACT shield.     

Fundamental Tax Reform in The Netherlands

The Netherlands has abolished the tax on actual personal capital income and has replaced it by a presumptive capital income tax, which is in fact a net wealth tax. This paper contrasts this wealth tax with a conventional realization-based capital gains tax, a retrospective capital gains tax with interest on the deferred tax, and a mark-to-market tax which taxes capital gains as they accrue. We conclude that the effective and neutral taxation of capital income can best be ensured through a combination of (a) a mark-to-market tax to capture the returns on easy-to-value financial products, and (b) a capital gains tax with interest to tax the returns on hard-to-value real estate and small businesses.     

THE COST OF CAPITAL OF A COMPANY UNDER AN IMPUTATION TAX SYSTEM

One of the issues arising out of the introduction of an imputation tax for companies in Australia is the effect it is likely to have on the definition and measurement of a company's cost of capital. Insofar as there is a difference between the value of a dollar of franked relative to unfranked dividends, conventional definitions for the cost of capital are inappropriate and new definitions are required. This has implications for the measurement of a company's cost of capital and for the definition of net cash flows that are used in conjunction with the cost of capital. This paper sets out these definitions and an approach for measuring the cost of capital. The new definition of the cost of capital replaces the effective company tax rate T with T(l - γ) where γ is the value of personal tax credits. Further, the definition of the risk premium in the capital asset pricing model requires an adjustment for the capitalized value of personal tax credits to maintain consistency between the cost of capital and cash flows which are defined on an after-company tax but before-personal tax basis.     

A Comment on the Viability of the Allowance for Corporate Equity

This article, acknowledging the potentially important general attractions of the allowance for corporate equity (ACE), looks at some of its more specific implications. On corporate taxes, the article looks at questions about the implied revenue-neutral rate of corporation tax (and redistribution of the tax burden); the effects on cash flow of both government and companies; and what would become a crucially important charge on capital gains. On income tax, the article comments on the implications for self-employed earnings (and also, potentially, employees); for investment income and the logically accompanying EXPEP (extended personal equity plan); and therefore for inheritance tax. For international investment, the article notes that unless and until other countries adopt an ACE as the basis for harmonisation, the interaction of the ACE and existing taxes would not always be helpful for outward investment; and on some inward investment, if the most optimistic assumptions are not borne out, the effects could be rather bleak. JEL classification: H25, K34.     

Post-Tax Capital Investment Appraisal: Plant and Machinery

Tax considerations are important for companies which are no longer tax exhausted. Taxation has a major impact upon project yield and net present value (NPV) for capital investment in plant and machinery. This paper uses the weighted average cost of capital model to demonstrate that the impact of corporate taxation upon NPV need not be in the same direction as the impact upon yield. The NPV is reduced by the nominal 35% rate of corporation tax only when the pre-tax yield is very high; for low yielding projects the post-tax NPV can range from less than zero per cent to over 100% of the pre-tax NPV depending upon the gearing. The tax deductibility of the costs of the debt finance component of capital expenditure has a major and subtle interaction with other parameters which always favours high gearing.     

The perceived instability of tax legislation and its effect on consumption-investment decisions

During the past decade, there appears to have been an alarming decline in the flow of investment capital into ventures with uncertain returns. One factor which may have contributed to investor aversion to such investments is an increase in the perceived instability of the tax laws. This study examines the effect which this increase in the perceived instability of the tax laws may have on the two representative consumption-investment decisions of an owner-manager of a closely held corporation, namely: 1) the optimal periodic salary to draw from the corporation, and 2) the optimal time horizon for planning corporate affairs. These decisions are analyzed in the context of multiperiod optimization models. The study reveals that: 1) under certain conditions, increased tax rate uncertainty causes an increase in salary, and 2) increased tax rate uncertainty may cause a decrease in the time horizon for planning corporate affairs.     

Personal taxes,cost of insurer equity capital,and the case of offshore hedge fund reinsurers

Insurer investment returns are taxed in the United States at the corporate level and at the personal level when they are distributed to shareholders. This paper examines the implications of personal taxes for the tax cost on insurers equity capital and how these tax costs have varied over time under different tax regimes and with different asset portfolios. The paper also discusses how personal taxes provide tax incentives to form offshore hedge fund reinsurers, which provide an interesting case study illustrating the relevance of personal taxes. Finally, the paper discusses the tax treatment of alternative capital arrangements, such as collateralized reinsurance and sidecars.     

The classical tax system,imputation tax and capital budgeting

Differences in the taxation systems in Britain, France, and some other European countries (which use the imputation system) compared with the USA and the Netherlands, among others (which use the classical tax system), mean that the cost of equity capital should be specified, using a capital asset pricing model methodology, in different ways. Under the imputation system its value should be net of personal taxes; under the classical tax system, it should be gross of personal taxes. Similarly the value of the tax shield on debt for input into adjusted present value calculations differs, being significantly greater under the classical tax system. Formulae are set out to enable the calculation of the magnitude of the tax shield readily to be undertaken.     

Tax‐efficient irregular payout methods: The case of B share schemes and capital repayments via a court‐approved scheme of arrangement

Advance corporation tax (ACT) increased the tax cost to UK firms of distributing cash to shareholders. We demonstrate how the tax cost arising from ACT payments affected the channels through which UK firms returned capital to shareholders. In particular, we document and describe two unconventional irregular payout methods that enabled firms to avoid paying ACT. Firms choosing these methods are associated with significantly greater ACT problems than a control sample of firms that opted for conventional self‐tender offers and special dividends. Event study tests indicate that the decision to adopt tax‐efficient payout methods created significant additional value for shareholders beyond the basic cash distribution decision.     

权衡中的创新——双元所得税评介

双元所得税是与综合所得税、单一税并列的一种个人所得税的主要模式,其特征为双元税基、双元税率和限制优惠。双元所得税的优点是兼顾了税收收入和国际竞争力、兼顾了效率和一定程度的收入再分配、避免了对资本的重复课税、降低了由于通货膨胀带来的对资本所得的过度课税、简化了税制。双元所得税契合了北欧各国社会经济状况对税制的要求,因此,成为北欧国家个人所得税的首选模式。     

Personal Taxation in Firm Market Valuation: Theory and Test*

In this paper, I extend Ohlson's 1995 firm market valuation model to incorporate personal taxes: the taxes on dividends and the taxes on capital gains. Without personal taxes, firm market value can be expressed as the present value of future benefits received by the shareholders (dividends, in this case). With personal taxes, the benefits received by the shareholders should be classified into three categories (due to their different tax treatments): dividends, share repurchases, and new share issues (i.e., contributed capital). The extended model shows the effects of personal taxation on firm market valuation: retained earnings are valued less than contributed stocks, both dividends taxes and capital gains taxes affect retained earnings valuation and firm market value, and firms choose cash distribution methods (paying dividends and repurchasing shares) to increase their retained earnings valuation, therefore increasing their market value. An empirical test using a sample from the Disclosure Select Canada and Financial Post Card data bases for the years 1995‐98 supports these personal tax effects.     

Taxes, Leverage, and the Cost of Equity Capital

We examine the associations among leverage, corporate and investor level taxes, and the firm's implied cost of equity capital. Expanding on Modigliani and Miller [1958, 1963] , the cost of equity capital can be expressed as a function of leverage and corporate and investor level taxes. Based on this expression, we predict that the cost of equity is increasing in leverage, and that corporate taxes mitigate this leverage‐related risk premium, while the personal tax disadvantage of debt increases this premium. We empirically test these predictions using implied cost of equity estimates and proxies for the firm's corporate tax rate and the personal tax disadvantage of debt. Our results suggest that the equity risk premium associated with leverage is decreasing in the corporate tax benefit from debt. We find some evidence that the equity risk premium from leverage is increasing in the personal tax penalty associated with debt.     

Cost of capital equations under the Australian imputation tax system

Since the introduction of the Australian imputation tax system, there have been problems both in the measurement of the market value of franking (imputation tax) credits and in their application to estimating cash flows and the cost of capital. In the present paper, we provide a convenient and robust resolution to the above problems in the context of an internally consistent set of equations for the cost of capital, asset valuation and the capital asset pricing model (CAPM). The equations apply under both classical and imputation tax systems and under differential taxation of dividends, capital gains and interest. The simple form of the CAPM presented here is shown to encompass more complex versions of the CAPM, which attempt to accommodate the effect of personal taxes. The valuation equations require an estimate of the market value of $1 of the firm's dividends, within which is embedded the market value of the imputation tax credits. Separate estimates of the value of imputation tax credits, or Officer's gamma factor, are not required.     

Why Has the UK Corporation Tax Raised So Much Revenue?

We analyse a puzzle in the UK corporation tax: by both historic and international standards, corporation tax revenues have been high while the statutory rate has been reduced. We consider explanations based on changes in the tax law and in economic factors. Changes in the tax law, such as base‐broadening measures through reductions in capital allowances, can explain only part of the puzzle. Among the economic explanations, an increase in the size of the corporate sector, mainly caused by expansion of the service sector and improvements in profitability of the financial sector, seems the most likely. To the extent that higher profits, particularly financial sector profits, may have led to high revenues, there are doubts as to whether revenues will continue to be so strong.     

“十四五”时期的个人所得税改革展望

个人所得税在调节收入分配、实现社会公平方面具有重要作用。“十四五”时期的改革部署中明确提出了健全直接税体系,提高直接税比重的要求。因此,“十四五”时期个人所得税改革的重点在于提高个人所得税收入占税收总收入的比重,同时实现税收公平目标。对比近两年国外个人所得税发展趋势,发现我国个人所得税存在收入占比较低、劳动所得税负较重等问题。可以从多方面入手解决问题。一是将资本所得纳入综合所得计税范围,同时推进现代化税收征管,避免税收流失,以提高个人所得税收入占税收总收入的比重。二是通过完善专项附加扣除政策,进一步降低中低收入群体的税收负担,实现税收公平。三是优化高端人才税收优惠政策,提高人力资本积累对高质量发展的贡献。     

Do investors care about corporate taxes?

This paper conducts a comprehensive examination of the link between corporation tax payment and financial performance in the UK. We find no discernible link between tax rates and stock returns for the UK, no matter how tax payment is measured. This is true throughout the sample period and for both customer-facing and non-customer-facing companies. However, allowing for industry norms and a host of firm characteristics, companies with lower effective tax rates have significantly higher levels of stock market risk. Firms that are reported in the newspapers in a negative way in relation to their level of corporation tax payment experience small negative stock returns, which are partially reversed within a month. However, the initial negative effects and subsequent rebound are both more pronounced for smaller companies. News announcements of the potential involvement of a firm in a corporate inversion (expatriation) result in steeper and much longer-lasting falls in share prices, whereas news stories of a more general nature relating to a firm's tax avoidance or tax payments have little noticeable effect.