Endogenous choice on tax instruments in a tax competition model: unit tax versus ad valorem tax

This paper analyzes an endogenous choice problem with regard to tax instruments in a capital tax competition model. Using a symmetric and two-region model of tax competition, where each region is allowed to choose either a unit or an ad valorem tax, we show that selecting a unit tax as a policy instrument is the dominant strategy.     

Applications of computer-assisted tax research in academic tax programs

The use of computer-assisted tax research by students and faculty has begun to increase rapidly after being available for over 15 years. Factors contributing to this increased usage include accessibility to the data bases by microcomputers, transmission technology improvements, the emergence of new competitors, and the growth of specialized tax programs. The purpose of this research was to determine the nature and extent of the use of computer-assisted tax research in academic tax programs. A survey was conducted of all schools with American Taxation Association members, AACSB accreditation, and/or graduate tax programs. Current users project increased use while the 71% of respondents who are nonusers overwhelmingly cite cost constraints as the deterrent, with pessimism about the possibility of adopting CATR in the near future.     

Asymmetric capital tax competition and choice of tax rate

This article provides an alternative mechanism that explains differences in capital tax rates, which applies to small jurisdictions. In the framework of standard capital tax competition models, regions have to be large, in the sense of having market power, otherwise they will tax capital, a mobile factor, at the same rate. In this paper, we consider a second mobile factor, labor, which is mobile only within metropolitan areas. We will show that this spatially limited mobile factor may explain the capital tax rate differences levied on the global mobile factor as long as no source-based wage tax is available. In addition to the theoretical treatment, numerical simulations also confirm this result and show a significant tax differential.     

The ability of deferred tax to predict future tax

We examine the usefulness of tax allocation accounting (deferred tax) for predicting future tax paid and future tax expense. Deferred taxes increase the explanatory power (R²) of regression models where future taxes paid or future tax expense is the dependent variable. However, the mean out‐of‐sample forecast errors for tax paid (future tax expense) is 30 (45.5) percent. Deferred tax increases predictive ability on pooled data, but is inconsistent on a year‐by‐year basis. We examine three explanations for poor predictive ability: losses, tax changes and asset growth. We discuss the policy and practical implications of our findings.     

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.     

Optimal tax depreciation

Currently, solutions to the choice of depreciation methods for tax purposes are obtained through numerical simulation. This paper presents a simple capital budgeting technique which, in conjunction with Descartes' rule of signs, analytically derives the optimal regular depreciation method under the existing U.S. tax code. This technique is then used to determine the optimal depreciable life for short-lived assets and, finally, the analysis is extented to cover the choice of depreciation methods under the Class Life Asset Depreciation Range System.     

Corporate tax avoidance: is tax transparency the solution?

Corporate tax avoidance has been a matter of considerable public attention, particularly since the 2008 global financial crisis. The nature of calls for tax reform and increased regulation, advocated most prominently by tax activists and NGOs, has revolved around transparency as a possible corrective to unacceptable tax avoidance, although there is no consensus as to what the term tax avoidance encompasses and when it becomes unacceptable. We examine two responses to calls for increased transparency about the tax affairs of multinational entities: firstly, country by country reporting that provides information to tax authorities, and secondly the UK requirement for publication of tax strategies, whereby large companies put information into the public domain. We find considerable misunderstanding about the benefits of transparency in this setting. By failing to consider the limits of transparency initiatives there is a risk of dysfunctional consequences, for example additional costs in providing and processing additional information, the prospect of increased disputes as new information generates new misinterpretations and uncertainty in determining the final tax position. There is a risk that greater disclosure will not effectively address concerns about unacceptable corporate tax avoidance.     

From the global income tax to the dual income tax: Recent tax reforms in the Nordic countries

The paper discusses the recent drive toward a system of dual income taxation (DIT) in the Nordic countries. The pure version of this system combines progressive taxation of labor and transfer incomes with a proportional tax on income from capital at a level equal to the corporate income tax rate. The paper considers the motives for the introduction of this new income tax system, ranging from abstract theoretical arguments to very pragmatic considerations. While the Nordic DIT system violates the principles of the conventional personal income tax, it is argued that it may in fact be more in line with the philosophy of a true Haig-Simons comprehensive income tax. It is also suggested that the DIT system may cause fewer distortions to resource allocation than the conventional income tax. On the debit side, the paper points out several practical problems of taxing income from small enterprises under the differentiated income tax.     

Corporation tax asymmetries: effective tax rates and profit shifting

This paper examines the way in which the asymmetric treatment of losses within corporate tax codes can be expected to affect behavioural responses to changes in tax rates. The paper uses the concept of an equivalent tax function, raising the same present value of tax payments as the actual function, in which the effective rate on losses in any period, and thus the degree of asymmetry, is explicit. The influence on the elasticity of tax revenue with respect to the tax rate of this effective rate is then examined, where ‘loss-shifting’ occurs. Results suggest that estimates of the behavioural effect on tax revenues of changes in tax rates can be expected in general to be smaller in regimes which involve greater asymmetries in the tax treatment of losses. Importantly, as losses vary over the economic cycle, the model predicts that the asymmetric tax treatment generates effects on tax revenues that are non-linear between above-trend and below-trend parts of the cycle.     

Relationship between tax compliance internationally and selected determinants of tax morale

Tax compliance has been studied by analyzing the individual decision of a representative person between planning and evading taxes. A neglected aspect of tax compliance is the impact of a social contract on tax morale. Such implicit contract between the individual and the state guaranteeing a high level of economic freedom, effective competition laws, an important equity market and high moral norms, is hypothesized to have a positive impact on tax compliance. In this paper, empirical evidence based on data from 30 countries indicate that tax compliance internationally is positively related to the level of economic freedom, the level of importance of the equity market and the effectiveness of competition laws and high moral norms.     

Organizing tax instruction: Evidence regarding how students organize tax knowledge

An important part of accounting curriculum reform is a movement away from traditional methods of organizing accounting courses toward improved organization schemes. Two basic approaches to organizing the content of tax courses are a transaction-based scheme and an entity-based scheme. This paper reports the results of an experiment that investigates which scheme is more consistent with how incoming masters in tax students organize tax knowledge and how different schemes affect the manner in which graduating students organize tax knowledge. Ninety students drawn from two full-time masters in taxation programs participated in the study. Subjects individually completed three separate tasks that measured how they organize tax knowledge at both the start of their degree program and three semesters later at or near the end of their program. The results for all three tasks indicate that incoming tax students organize tax knowledge around the type of transaction involved. The results for two of the three tasks indicate that the students' transaction focus did not change during their graduate tax program, whereas the results for the third task indicate that the students' transaction focus increased during their graduate tax experience. The implications of these findings for improving tax instruction are discussed.     

The effects of standardized tax rates,average tax rates,and the distribution of income on tax progressivity

This study examines the changes in US individual income tax progressivity over the 1986–2003 period using the indexes developed by [Kakwani, N.C., 1976. Measurement of tax progressivity: An international comparison. Economic Journal 87(March), 71–80]. Although progressivity over this time frame has generally been studied in the literature, we provide additional insights by decomposing the changes in index values to account for the effects of concurrent changes in the standardized tax rates, average tax rates, and the income distribution. The decomposition should prove to be particularly useful when different summary indexes lead to conflicting conclusions about progressivity changes, as is often the case. From a policy standpoint, we show that it is the standardized tax rates, a derivative of the legislated tax rates, which need to be monitored and managed to offset the negative progressivity effects of increasing before-tax income inequality.     

企业所得税视同销售业务的会计处理与纳税调整

视同销售是指企业发生特定的提供商品或劳务行为后,会计上对此一般不作为销售业务核算,不确认会计收入,而税法却规定视同销售实现,要求计算销售(营业)额并计算应交税金.本文只就自产产品视同销售的一般情况加以阐释.     

Implementing problematic tax regulation: Hysteresis and bureaucratic revolutionaries within tax administrations

Worldwide emerging demands for additional and more sophisticated regulation are triggering regulatory changes at the national level that not all tax authorities are prepared to implement effectively. We examine this phenomenon through a single case study concerned with the implementation of the problematic transfer pricing rule by the Chilean tax authority. Drawing on semi-structured interviews, other qualitative sources, and inspired by the lesser used Bourdieusian constructs of hysteresis and bureaucratic revolutionaries, we unravel the emergence, persistence and resolution of hysteresis, i.e., a misalignment between tax administration practices and the expectations imposed on that organisation within the broader tax field. The paper finds that attempts to internationalise the tax system when regulators were inexperienced gave rise to hysteresis. It also explores how the standard of the rule, in conjunction with other structural conditions, influenced the decisions of senior tax officials, thus contributing to the persistence of hysteresis within the tax authority. Finally, it illustrates how one very senior tax official, with an interest in the regulation, acted as a bureaucratic revolutionary to resolve hysteresis and make the rule work in practice.     

Valuation of tax expense

As tax expense reflects value lost to taxes paid, it should be negatively associated with value, provided nontax, value-relevant information is controlled for. However, valuation regressions estimated in prior research—using contemporaneous tax expense and nontax variables—document substantial variation in the coefficients on tax expense, ranging from significant negative to significant positive values. We show this variation is (a) caused by the omission of expected future profitability, and (b) explained by many factors that cause variation in the correlations among included variables and omitted future profitability. Unfortunately, difficulties associated with separating the impact of individual factors hampers tax research investigating determinants of the value relevance of tax expense.     

节税三策

2010年,吉利成功收购沃尔沃100％的股权,成为中国汽车企业成功收购国外豪华汽车企业和品牌的第一宗案例,吉利汽车因此成为了国内外学术界及实务界关注的焦点。然而,民营企业在快速发展的过程中并没有得到国家特殊的倾斜性税收优惠,因此企业自身只有主动地进行有效的税务筹划,才能实现企业价值最大化。     

Assessing professional ethics in tax: A case on uncertain tax positions

We develop and present an ethics case dealing with an uncertain tax position. The case can be used to assess professional ethics as part of an assurance-of-learning (AOL) plan as well as a component of a course grade. We present data on student performance on this case over a 5-year period. Students consider existing ethical frameworks to identify and frame the potential ethical “dilemmas” they might face in addressing whether to countenance a client’s suggested treatment and disclosure of an uncertain tax position. In addition, students evaluate the AICPA guidance and U.S. Treasury standards on taking and reporting uncertain tax positions in the tax return and the FASB and PCAOB standards on reporting and auditing uncertain tax positions in the financial statements. The case allows faculty to assess students’ ability to frame potential ethical dilemmas when clients engage in aggressive tax behavior, to recognize with whom and with what professional reference documents they should consult when an uncertain tax position arises, and to choose among alternative actions when faced with client/preparer conflicts.