论个人所得税的二元课税模式

由于综合个人所得税制在理论基础和实际征管方面都存在着难以克服的困难,发端于北欧国家的对劳动所得适用累进税率而对资本所得适用比例税率的二元个人所得税制就成为一种较为现实而理想的模式,在国际上正得到日益广泛的支持。我国近年提出的综合与分类相结合的个人所得税制模式近似于二元所得税制,应当作为个人所得税改革的长远目标,但还需对具体制度安排进行恰当的设计。     

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.     

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.     

Tax treatment of dividends and capital gains and the dividend decision under dual income tax

The paper analyses efficiency aspects of a dual income tax system with a higher tax on capital gains than dividends. It argues that apart from the distortions to investments claimed in earlier literature, the system puts even more emphasis in creating incentives for entrepreneurs to participate in tax planning. The paper suggests that the owner of a closely held company can avoid all personal taxes on entrepreneurial income by two tax-planning strategies. The first is the avoidance of distributions, which would be taxed at the tax rate on labour income. These funds would instead be invested in the financial markets. The second strategy is a distribute and call-back policy, converting retained profits into new equity capital. Interestingly, the outcome is that investment in real capital is not distorted in the long-run equilibrium. Empirical evidence using microdata is also provided.      

Taxes

This is a compendium of notes on taxes. Section 2 presents a general tax scheme. It is a tax on value added by labour and capital that does not favour one or the other. Section 3 contrasts taxation of business income for pass-through entities and corporations. Section 4 discusses property taxes as taxes on housing services and so a form of income tax. Section 5 turns to wealth taxes. The closing Section 6 attempts to explain why people donate to nonprofits but minimise tax payments to governments, even though governments and nonprofits engage in many of the same activities.     

Organizational forms and investment decisions

This paper analyzes investment rules for various organizational forms that are distinguished by the characteristics of their residual claims. Different restrictions on residual claims lead to different decision rules. The analysis indicates that the investment decisions of open corporations, financial mutuals and non-profits can be modeled by the value maximization rule. However, the decisions of proprietorships, partnerships, and closed corporations cannot in general be modeled by the market value rule.     

Slowing Fossil Fuel Extraction: A Role for Taxation of Exports,Capital Gains and Interest Income

This paper develops a model of a growing open economy rich in non‐renewable resources, the extraction of which negatively impacts domestic productivity and whose sector competes with final production for capital. We analyse how tax rates on capital gains and interest income and the time trend of an export revenue tax rate could slow the extraction of resources for export. We find that taxing capital gains and interest income at the same rate and setting an export revenue tax rate to decline at the marginal social cost of extraction would defer extraction. An export revenue tax rate need not fall over time to curb depletion if capital gains are taxed at a lower rate than interest income, which is second best to taxing asset returns at the same rate when the resources sector competes for capital.     

Taxes and production: The case of Pakistan

This paper investigates the effectiveness of investment incentives and corporate income taxes in influencing production and investment decisions in the Pakistani wearing apparel and leather products industries. Three tax instruments are considered: the corporate income tax (CIT), the investment tax credit (ITC), and the capital cost allowance (CCA).The results show that since there are significant capital adjustment costs, it is important to distinguish between the short, intermediate, and long-run effects associated with the tax instruments. Production decisions are relatively more responsive to changes in the ITC rate compared to changes in either CCA or CIT rates in each run. However, only in the long run for the apparel industry are the ITC and CCA rates cost effective in stimulating investment. The CIT is never cost effective. Thus targeted instruments outperform the general CIT instrument. In addition, although the incentive to invest is enhanced, there is little effect on output. Therefore, tax incentives essentially make production techniques more capital intensive.     

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.     

Distinguishing closely held companies for taxation purposes: The Australian experience 1930-1972

Early in the life of Australia's income tax, the government, sensitive to loss of taxation revenue through artificial arrangements to divert taxable profits from individuals to companies where they would be taxed more lightly, saw fit to provide a special taxation regime for closely held companies. From the first attempts by the government to distinguish closely held companies for tax purposes in 1930, until the final legislative changes in 1972, there arose a highly unsatisfactory situation in which taxpayers sought, through increasingly artificial means, to subvert the legislative purpose with the aim of tax avoidance. The government's response throughout was inadequate in a number of respects, and fuelled the fires of tax avoidance through inept drafting of the relevant legislation and delayed treatment of perceived abuses by taxpayers.     

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。     

QFII内地股票投资——免税的大餐?

合格境外机构投资者(Qualified Foreign Institutional Investors,以下简称"QFII")在内地股票投资的收益在国内法上负有向内地政府缴纳10%预提所得税的义务,但由于一部分中外税收协定对此的特殊规定以及公开证券市场交易的特殊性等原因,此类业务在事实上一直享受着"免税大餐"。本文建议内地税务机关委托内地资金托管银行代征QFII在内地的应纳税款。     

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     

The Impact of the 1986 Tax Reform Act on Income Shifting from Corporate to Shareholder Tax Bases: Evidence from the Motor Carrier Industry

Using a sample of privately held C corporations and S corporations from the motor carrier industry during 1984–92, we assess the effect of the 1986 Tax Reform Act on the amount of corporate income shareholders of privately held C corporations shifted to their personal tax bases. We estimate that the C corporations shifted a mean of $130,587 taxable income each year to shareholders (representing 29% of their mean accounting earnings before income shifting) after the 1986 tax law change. The C corporations used deductible managerial compensation and rent expense, but not interest expense, to shift income to shareholders.     

Dividend taxes,employment, and firm productivity

The paper examines the effect of dividend taxation on employment and productivity. I exploit a dividend tax cut of 10 percentage points for closely held private corporations in Sweden. Using data on all closely held Swedish firms with exact information on employees and their wages, I find that firms with limited internal funds increase productivity and wages relative to firms with sufficient internal funds whose investment decisions are less affected by dividend taxes. My findings indicate that dividend taxes constrain firms in investing efficiently. Lower taxes can result in higher capital and labor input and, thus, in higher productivity.     

Prospects for Co-ordination of Corporate Taxation and the Taxation of Interest Income in the EU

This paper evaluates the recent proposals for a co-ordinated capital tax policy in the European Union, focusing on an EU-wide minimum withholding tax on interest income and alternative ways to increase the effective tax rate on corporate profits. The analysis draws on current theoretical and empirical research and views the recent capital tax reforms undertaken by individual member countries as rational adjustments to changing conditions in capital markets. Special emphasis is placed on the constraints for EU tax policy imposed by the possibility of shifting capital income to third countries. The paper concludes that some aggregate efficiency gains can be expected from the EU co-ordination proposals, but additional tax collections will be limited largely to the group of small savers while highly mobile large-scale investors are likely to avoid the EU tax.     

Neutral Taxation of Shareholder Income

A Norwegian tax reform committee recently proposed a personal tax on the realized income from shares after deduction for an imputed risk-free rate of return. This paper describes the design of the proposed shareholder income tax and shows that it will be neutral with respect to investment and financing decisions and decisions to realize capital gains, provided that full loss offsets are granted. Thus the tax allows some non-distortionary double taxation of corporate equity income. With an appropriate choice of tax rates, it also solves the problem of income shifting under a dual income tax. JEL Code: H24, H25     

Capital Structure Determinants for Tax‐Exempt Organisations: Evidence from the UK

Abstract: This study looks into the determinants of capital structure in the absence of tax incentives. I find that attributes normally associated with debt use for taxable corporations are likewise correlated with debt use in the tax‐exempt sector. These include the organisation's age, asset tangibility, governance structure, industry grouping, liquidity, profitability, and size. Tax‐exempt sector‐specific findings indicate that debt use is also related to the size of the organisation's endowment and the amount of voluntary income. This study also demonstrates the portability of the theory of capital structure by extending the findings in Smith (2010) beyond the United States.     

One-Way Treaty with the World: The U.S. Withholding Tax and the Netherlands Antilles

This paper chronicles the experiences of the U.S. withholding tax on interest income. In 1984, the U.S. repealed its 30 percent withholding tax on interest income paid to foreign persons or corporations. While the tax raised little revenue, it had imposed substantial implicit costs on U.S. corporate borrowers. Since, prior to repeal, domestically issued bonds were subject either to withholding or strict information requirements, many U.S. multinationals raised funds through foreign finance subsidiaries, primarily in the Netherlands Antilles, to avoid the tax. Although the withholding tax rate was effectively reduced to zero in the U.S., this paper demonstrates that interest flows were highly sensitive to their after-tax cost.     

On syndicate sharing rules for unanimous project rankings

This paper extends the notion of individual certainty equivalent to group certainty equivalent, in order to derive sharing rules that ensure unanimity on project rankings within a syndicate. A constrained maximization problem is set up with optimal project-specific sharing rules as the solution. It is shown that the group certainty equivalent construct allows for experimental derivation of a syndicate's preference function from a procedure parallel to that presently employed for deriving preference functions of individuals. The analysis potentially has a role in examining the nature of optimal compensation systems (sharing rules) for closely held (non-traded) corporations and partnerships.