Dividend valuation,trading and transactions costs: the 1997 partial abolition of dividend tax credit repayments

Although UK resident tax-exempt shareholders lost the right to repayment of tax credits on dividends paid by UK resident companies in July 1997, they could continue to receive tax credit repayments in respect of dividends received from Irish resident companies until December 1998. In July 1997 the rate of tax credit on Irish companies' dividends was 21%, and this was reduced to 11% in December 1997. We obtain insights into the incentives and behaviour of UK tax-exempt investors in response to these changes in the relative ‘tax attractiveness’ of investments in Irish resident companies. We find that only at its highest rate, 21%, was the level of dividend tax credit on Irish companies' dividends sufficient to induce changes in UK tax-exempt shareholders' investment strategies; and that the propensity for dividend capture by tax-exempt investors is heightened when the dividend tax credit yield is of the order of 0.8 or more and dividend yield is of the order of 2.6% or more.     

Gold mining companies and the price of gold

This paper studies the exposure of Australian gold mining firms to changes in the gold price. We use a theoretical framework to formulate testable hypotheses regarding the gold exposure of gold mining firms. The empirical analysis based on all gold mining firms in the S&;P/ASX All Ordinaries Gold Index for the period from January 1980 to December 2010 finds that the average gold beta is around one but varies significantly through time. The relatively low average gold beta is attributed to the hedging and diversification of gold mining firms. We further find an asymmetric effect in gold betas, i.e. the gold exposure increases with positive gold price changes and decreases with negative gold price changes consistent with gold mining companies exercising real options on gold.     

Gold loans in the Australian gold mining industry: Do gold loans allow gold producers to increase leverage?

This paper tests the hypothesis that gold producers exhibit greater leverage where gold loans are used. As the choice of gold producers and the study period essentially avoids debt tax shield effects, the paper focuses on information asymmetry and agency costs explanations for leverage. Theory suggests hedging can reduce the cost of debt but it has little impact if management is not committed to adopting the promised hedging policy. The implicit hedge in gold loans commits management to hedging and so greater leverage is expected for producers adopting gold loans. Results from the analysis are consistent with this hypothesis.     

Tax-Induced Intra-Year Patterns in Bonds Yields

The ratio of the yields on short-term tax-exempt and taxable bonds exhibits a sawtooth pattern that is consistent with the impacts of tax deferments from dates on which interest payments are received to dates on which the resulting tax payments are paid. The effect of the tax deferment at turns of calendar years does not differ appreciably from the effect at the turn of any other tax quarter. Investors with tax payment schedules that differ from that of the investor that is indifferent between investing in taxable and tax-exempt bonds may benefit from tax-related timing strategies for investing in these bonds. Issuers may benefit from tax-related timing strategies for scheduling interest payments.     

Was the Tax-Exempt Bond Market Inefficient or Were Future Expected Tax Rates Negative?

This paper shows that the sharp narrowing with maturity of the spread between taxable and tax-exempt yields leaves room for tax arbitrage. At times, tax-exempt forward rates have exceeded taxable forward rates. At such times, only expectations of higher taxes on Treasury than on municipal bonds would eliminate profit opportunities. The authors develop the idea of forward tax rates and compute forward tax rates for 1955 through 1984. They also outline tax-arbitrage mechanisms involving private forward sale of long municipal bonds or the use of the Municipal Bond Futures Contract and show the potential profits.     

The Pricing of Tax-Exempt Bonds and the Miller Hypothesis

This paper reports a new test of two competing theories of the relation between tax-exempt and taxable interest rates. The Miller hypothesis predicts that the tax-exempt rate is 52 percent of the taxable rate, while the institutional demand hypothesis predicts a volatile relationship. The tests in this paper employ a random intercept model to control for the risk of average interest rates. The results favor the Miller hypothesis. Marginal tax rates are found to be close to Miller's predicted 48 percent. The relationship is not influenced by relative demand or supply and the marginal tax rate appears stable over time.     

Tax-Exempt Debt and the Capital Structure of Nonprofit Organizations: An Application to Hospitals

The availability of tax-exempt financing provides nonprofit (NP) organizations with their own tax-based incentives to issue debt. In this article, we develop a theoretical model in which NPs gain an indirect arbitrage from tax-exempt debt issuance, constrained by: 1) the requirement that fixed investment exceed tax-exempt debt flows (the project financing constraint), and 2) the constraint against share issuance. These constraints cause them to impute tax benefits to projects that afford access to the tax-exempt bond market. Empirical tests indicate that NP hospitals behave as if they have target levels of tax-exempt debt. Debt targeting is constrained by the availability of capital projects, while excess debt capacity stimulates investment.     

The market premium for the option to close: evidence from Australian gold mining firms

This study shows the market value of gold mining firms contains a premium for the option to close. The sample uses 41 gold mining producers listed on the Australian Stock Exchange from 1987 to 2013. The premium of the market price over the present value of cash flows is isolated and a pooled cross‐sectional regression tests the degree of association between that premium and theoretical option premiums. The results show market prices incorporate a premium reflecting the option to temporarily close operations. The magnitude of the option premium to close depends on whether firms are out or in the money options.     

世界黄金期货市场、工具与法规政策环境的比较分析

本文比较了世界主要黄金期货市场、投资工具与各国黄金市场法规政策环境,分析了不同的市场条件、法规政策环境对本国黄金期货市场发展产生的影响,探讨了成为国际性黄金期货市场应具备的基本要素:现货市场发展程度、市场规模、现货商影响力对黄金衍生工具的发展产生重要影响;外汇管制政策和进出口政策对确定本国黄金期货市场是国际性市场还是区域性市场起到关键性作用;黄金市场流通、增值税、监管政策对确定本国各类黄金市场交易的活跃度产生关键性作用。     

Trafficking in foreign tax credits: A case study of Compaq Computer Corporation

This paper describes a complex tax sham perpetrated by Compaq Computer Corporation and presumably many other U.S. firms during the 1990s. Using a novel trading strategy designed to exploit the tax code and accounting regulations, Compaq purchased what would otherwise be unusable foreign tax credits held by tax-exempt institutions, likely pension funds that held American Depository Receipts (ADRs) for international diversification. These tax-exempt institutions were paid for selling their foreign tax credits occasioned by foreign withholding taxes on dividend income. Obscure trading regulations promulgated by the Securities and Exchange Commission and the New York Stock Exchange (NYSE) facilitated the trading strategy. In 1999, a U.S. Federal District Tax Court ruled that Compaq's strategy lacked economic substance and was a sham. Compaq has appealed the ruling. A similar lower court ruling against IES Industries was overruled in 2001 by the U.S. Appeals Court for the Eighth Circuit in St. Louis. In September 2001, The Wall Street Journal reported that the U.S. Supreme Court may hear the matter depending on the disposition of the Compaq appeal. Recent changes to the Internal Revenue Code presumably preclude this type of trading strategy from being implemented in the future.     

Banks,firms and the relative pricing of tax-exempt and taxable bonds

The traditional analysis of the relative pricing of tax-exempt and taxable debt is a habitat theory of the term structure of interest rates. In the traditional analysis the preferences of investors for particular maturities of debt lead to unique pricing relations at every point on the yield curve which are indicative of investor marginal tax brackets. Recent work by Fama (1977) suggests that banks are potential arbitrageurs across tax-exempt and taxable bond markets which force a particular equilibrium on the pricing of short-term bonds. Miller (1977) suggests that the choice of debt or equity financing by firms in the aggregate forces a similar equilibrium on the pricing of all tax-exempt and taxable bonds. This paper exploits the institution of Regulation Q and its effects on the banking system to bring evidence to bear on the predictions of these three models.     

Credit unions and earnings management to mitigate political scrutiny over tax-exempt status

In this paper, we examine whether credit unions manage earnings to mitigate political scrutiny. In particular, we study whether credit unions increased loan loss provisions to decrease earnings around a 2005 congressional hearing on the efficacy of credit unions’ tax-exempt status. On average, we find evidence consistent with credit unions managing earnings downward via the loan loss provision in the quarters leading up to and surrounding the congressional hearing. In addition, we find that credit unions with higher earnings before the loan loss provision engaged in more downward earnings management than credit unions with lower earnings before provision. Our findings contribute to the literature examining the use of downward earnings management to avoid political scrutiny and the banking literature. Likewise, our results inform the continued debate as to whether credit unions should be tax-exempt.     

Seasonal Patterns in Money Market Mutual Funds

This study analyzes seasonal patterns in tax-exempt and taxable money market mutual fund yields. We document a significant increase in tax-exempt and taxable yields during the last three weeks of December, followed by a significant decrease in yields during the first three weeks of January. The yield changes are associated with a corresponding outflow of fund assets at the end of the year and inflow of assets in the beginning of the year. We also find that tax-exempt yields change systematically around the 15th of April, June and September, which are key individual income tax dates. These results are consistent with liquidity effects associated with year-end wages, dividends, and bonus payments and tax-effects. We also find that institution window dressing contributes to the year-end movements in taxable and tax-exempt fund yields. One implication is that municipalities planning to issue short-term notes and investors in these funds can time their actions to take advantage of these systematic yield changes.     

Tax-subsidized underpricing: The market for Build America Bonds

Build America Bonds (BABs) were issued by municipalities for 20 months as a part of the 2009 fiscal package. Unlike traditional tax-exempt municipals, BABs are taxable to the holder, but the Treasury rebates 35% of the coupon to the issuer. The stated purpose was to provide municipalities access to a more liquid market including foreign, tax-exempt, and tax-deferred investors. We find BABs do not exhibit greater liquidity than traditional municipals. BABs are more underpriced initially, particularly for interdealer trades. BABs also show a substitution from underwriter fees toward more underpricing, suggesting that the underpricing is a strategic response to the tax subsidy.     

The value of a flow-through entity in an integrated corporate tax system

In an integrated corporate tax system, resident shareholders receive a tax credit for corporate tax paid that can be used to offset personal tax on dividend income. Nonresident and tax-exempt (pension plan) investors cannot use the tax credit on corporate dividends and thus prefer to invest in flow-through entities. We estimate the value of the flow-through entity to nonresident and pension plan investors by examining the price change around the date of an unexpected announcement of a change in tax law related to Canadian publicly traded income trusts units creating an entity-level tax that makes them no longer tax-favored to these investors.     

Do non-profit hospitals provide more charity care when faced with a mandatory minimum standard? Evidence from Texas

Policymakers often question whether not-for-profit (NFP) hospitals provide enough charity care to justify tax advantages. In 1993, Texas enacted legislation requiring NFP hospitals to provide certain community benefits at levels set forth in specific criteria to retain tax-exempt status; this paper focuses on the effect of the legislation’s requirement that NFP hospitals spend a minimum of 4% of net patient revenue on charity care. We also study a modification of the law passed in 1995, which allows the deduction of bad debts expense when calculating net patient revenue. This change effectively lowers required charity care spending, and our study considers whether Texas hospitals responded by reducing charity care spending.     

The benefits of expediting government gold sales

Additional gold can be made available either by mining at high cost (approximately $250 per ounce in 1997 dollars) or by mobilizing government stocks at zero cost. Governments own massive above-ground stocks but loan out only a small percentage of these stocks. Making all government gold available for private uses immediately through some combination of sales and loans maximizes total welfare from private uses, a consequence of the first welfare theorem. We simulate a calibrated version of our model to quantify the effects of liquidating government stocks on alternative dates. If governments sell immediately rather than never, total welfare increases by $340 billion; if they make an unanticipated sale in 20 years, $105 billion of that amount is lost. By depressing prices, such sales benefit depletion and service users but injure private owners of stocks above and below-ground. However, the injury to above-ground stock owners is more than offset by the benefits to service users—often the same individuals. Mine owners would be the principal losers; however, they could be compensated (twice over) from government sales revenue without any need for tax increases.     

Changes to Income Trust Taxation in Canada: Investor Reaction and Dividend Clientele Theory

Abstract:  This paper explores the relationship between tax-induced dividend clientele theory and the recent changes to the taxation of income trusts in Canada. On October 31, 2006, the Canadian government announced the Tax Fairness Plan ( TFP ) calling for the elimination of the considerable tax advantage enjoyed by income trusts. Generally, distributions from income trusts are now taxed at rates comparable to those imposed on corporate dividends. We examine market reaction to the  TFP  to address three issues: first, whether the valuation effect of a dividend tax increase is consistent with the traditional or the new view of dividend taxation; secondly, whether the market reaction to tax increases has a differential impact on firm value that is related to the tax preferences of taxable, tax-exempt, and foreign investor tax clienteles; and thirdly, whether firms change their dividend policies in response to the preference of institutional investors (tax-based dividend policy effect) or whether institutional investors are sorting themselves across firms based on their dividend policies (investor sorting effect). Our results provide strong evidence as follows. First, the valuation effect in reaction to the  TFP  announcement is consistent with the traditional view of dividend taxation – i.e. that taxes on dividends reduce the net return to investors, increase the firm's cost of capital and lower the firm's ability to access capital markets, thereby discouraging investment and savings. Secondly, we saw that trusts with a larger percentage of their units held by tax-exempt, low-tax, and foreign investors had a higher decline in value when compared with trusts held mostly by ordinary taxable investors. These results support dividend tax clientele theory. Finally, we observed changes in institutional investor clienteles consistent with the investor sorting effect.     

The individual's tax-exempt bond portfolio decision under income uncertainty

In this article, an individual's tax-exempt bond portfolio decision is investigated. A model capturing the relationship between income uncertainty and optimal portfolio choice is defined when an individual decision-maker has the opportunity to hold higher yielding private-activity bonds. The findings in this article show that in most cases risk-averse individuals will maximize the expected utility of after-tax income by holding a large proportion of private-activity bonds in their portfolio even under income uncertainty and the risk of a minimum tax liability. Those individuals who would benefit from holding private-activity bonds in a tax-exempt portfolio are identified and the magnitude of the benefit is quantified.     

Cross-Border Investing with Tax Arbitrage: The Case of German Dividend Tax Credits

German dividends typically carry a tax credit which makes thedividend worth 42.86% more to a taxable German shareholder thanto a tax-exempt or foreign shareholder. This results in a penaltyfor foreign investors who buy and hold German dividend-payingstocks. I document that, as a result of the credit, the ex-daydrop exceeds the dividend by more than one-half of the tax credit,and show that futures and option prices embed more than one-halfof the tax credit. The existence of the credit creates opportunitiesfor cross-border tax arbitrage—in which foreign holdersof German stock transfer the dividend to German shareholders—andimplies that it is tax efficient for foreign investors to holdderivatives rather than investing directly in German stocks.The empirical findings are consistent with costly tax arbitrageactivity by German investors, who face tax risk due to antiarbitragerules. Since dividend tax credits exist in many other countries,the findings are potentially of broad interest.