平均税率、标准税率与收入分布对个人所得税累进性的影响

运用中间累进性指标将个人所得税累进性的变化分解为标准税率的影响及收入分布的影响,对再分配效应变化也做了类似的分解,实证分析了我国2005~2011年个人所得税累进性及再分配效应的变化。结果显示,收入分布改变对于累进性的变化发挥主导作用,平均税率对于再分配效应的变化非常关键。因此,个人所得税的改革首先需要在分析居民收入分布的基础上进行,另外在累进性提高的同时也需十分关注税收规模的变化。     

The tax benefit of income smoothing

A worker can reduce tax liability by contributing to a private pension plan when marginal tax rates are high and withdraw pension benefits when marginal tax rates are low. We quantify the tax benefit of income smoothing through the private retirement system and find that it is negligible. This conclusion is important to households, investment advisers, tax policymakers, and scholars engaged in financial retirement planning.     

Evidence of the effect of domicile on corporate average effective tax rates in the European Union

We estimate (worldwide) corporate average effective tax rates (ETRs) from financial statements for companies domiciled in European Union (EU) member states during 7 years from 1990 to 1996. Our objective is to compare the tax rate effectively experienced by each company with the corporate statutory tax rate (STR) in the EU country in which each company is domiciled. The difference between the corporate statutory tax rate and the financial statement-based corporate average effective tax rate provides information on the magnitude of tax incentives provided by governments within the EU. These tax incentives come on top of the directly observable differences in statutory tax rates between EU member states. We find (1) that the use of tax incentives, over and above differences in STRs, differs substantially between EU member states (corporate domiciles) and (2) that the provision of tax incentives does not have the effect of equalizing corporate ETRs between EU member states (corporate domiciles).     

Corporate domicile and average effective tax rates: The cases of Canada,Japan, the United Kingdom,and the United States

We use financial statement information to estimate three alterantive average effective tax rates for firms domiciled in Canada, Japan, the United Kingdom, and the United States during the period 1982 to 1991. While many of the firms we examine operate worldwide, we use the termdomicile to refer to the legal residence or site of incorporation of the parent company. Our objective is to determine themarginal impact of a company's domicile on its worldwide tax burden, with controls for industry and year. We find both among domestic-only companies and among multinational companies the domiciles are consistently ranked in descending order by average effective tax rates as Japan, the United Kingdom, the United States, and Canada. In comparing domestic-only companies and multinationals domiciled in the same jurisdiction, only U.S. multinationals consistently face a greater tax burden than their domestic counterparts.     

Federal income tax laws that cause individuals’ marginal and statutory tax rates to differ

This article presents a “phaseouts table” as a tax educational tool. The table compiles and summarizes the phaseouts of and limitations on deductions, credits, exclusions from income, and allowed contributions for individual U.S. federal income taxpayers in 2013. Phaseouts can cause individual taxpayers’ marginal tax rate (MTR) to be higher than their statutory tax rate (STR) (i.e., “bracket” based on taxable income). For each phaseout, the table includes how the phaseout works, the adjusted gross income (AGI) range for the phaseout, and the related formula to compute MTR, given STR. The table is appropriate for any course that covers either U.S. federal income taxation of individuals or tax planning. (The phaseouts table is updated annually and is available upon request from the author.) The remainder of the article is a teaching resource, explaining how to compute the specific impact on MTR of each of several example phaseouts. Together, the phaseouts table and article enable U.S. tax instructors to assist students in learning about phaseouts in an integrated, comprehensive manner.     

Progression and revenue effects of income tax reform

Usually, only initial revenue effects of personal income tax reforms are considered. However, a tax reform characterized by base broadening in exchange for rate reduction can reduce the income elasticity of tax revenue. In that case, the increase in revenue after income growth will be relatively smaller: the tax reform has a negative effect on revenue in the second period. Using the microtax model of the Central Planning Bureau we simulated the effects of the Dutch Oort reform 1990 on revenue elasticities and, consequently, on tax revenue. The income tax revenue elasticity declined by 17 percent which caused an additional revenue loss of 0.6 percent in 1990, rising to 3.8 percent in 1993.     

新企业所得税法对证券市场的影响及配套法规的完善

本文在分析《中华人民共和国企业所得税法》(以下简称"新企业所得税法")的实施对证券市场影响的基础上,对新企业所得税法在规范证券市场所得课税方面存在的不足予以剖析,指出为实现证券市场所得课税的有效性,应针对其特殊性而制定相应的配套法规。     

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.      

Determinants of the variability in corporate effective tax rates and tax reform: Evidence from Australia

This study examines the determinants of the variability in corporate effective tax rates in Australia spanning the Ralph Review of Business Taxation reform. Our results indicate that corporate effective tax rates are associated with several major firm-specific characteristics, including firm size, capital structure (leverage) and asset mix (capital intensity, inventory intensity and R&D intensity). While the Ralph Review tax reform had a significant impact on many of these associations, corporate effective tax rates continue to be associated with firm size, capital structure and asset mix after the tax reform.     

Spillover effects of VAT Self-enforcement properties: Evidence based on the replacement of business tax with VAT reform

In accordance with the purchasing tax-deduction method and the receipt-based value added tax (VAT) system, the same transaction can be recorded by two firms, which creates self-enforcement properties, thereby restraining tax avoidance. Using the Replacement of Business Tax with VAT reform in China, this paper adopts a difference-in-differences design to investigate the spillover effects of VAT self-enforcement properties on corporate income tax avoidance by manually collating information about suppliers/clients of listed firms. As the listed firms' suppliers/clients switch from paying business tax to paying VAT, there is a striking decline in their corporate income tax avoidance behavior. This effect is pronounced in firms with closer upstream and downstream correlations, higher information complexity and stronger incentives for tax avoidance.     

The intoxicating brew of black liquor and son of black liquor: Deciphering the tax planning,research, policy and financial statement implications of tax credits via financial reporting income tax disclosures

In 2007, a change in the law regarding the alternative fuel mixture credit opened the door for paper mills to qualify a byproduct of paper manufacturing, black liquor, as a fuel eligible for the credit. The credit is a refundable credit of $0.50 per gallon. Paper mills can produce hundreds of millions of gallons of black liquor per year and qualified for the credit in 2009. In addition, in 2010 the IRS determined that these firms qualified for the cellulosic biofuels producer credit. Paper mill companies could amend their 2009 tax returns and swap their alternative fuel mixture credits for cellulosic biofuels producer credits worth $1.01 per gallon. The catch was that the alternative fuels mixture credit was refundable; the cellulosic biofuels producer credit was nonrefundable.     

中日韩非居民企业股息等所得税收政策比较与分析

本文首先比较了中国与日本、韩国对非居民企业在股息、利息和财产收益所得方面的税收政策和税收管理措施,在此基础上分析了当前我国在非居民企业税收政策制定和税收管理中存在的问题,并就进一步完善我国非居民企业税收政策,逐步建立科学、有效的非居民企业税收征管模式提出了建议。     

The role of political elites in income tax system design and tax fairness

Given the importance of fairness in the public acceptance of tax systems (Mirrlees et al., 2011), understanding the role of political elites in the tax design process and how this impacts fairness is important. In this paper, we use an interpretative approach to examine the design and ultimate rejection of the Kansas tax policy experiment that ran from May 2012 to June 2017. The central design element of this experiment was the fundamental disruption of the long-standing principle of horizontal equity (fairness), in which non-wage business income was relieved of income tax, while wage income was taxed. By interpreting this experiment through a Bourdieusian lens, we identify five key themes that are helpful in understanding income tax design, tax fairness, and the role played by political elites. Overall, we contribute to the literature by highlighting the way in which cultural capital may be used by political elites to reformulate groups of taxpayers in order to justify unequal treatment of equal taxpayers, which represents a violation of the notion of horizontal equity (fairness). We also highlight that although such violations of fairness in income tax system design may be sustainable in the short run, over the longer term, notions of fairness are so deeply embedded in the habitus of individual taxpayers that a return to the status quo is likely.     

Limits of tax regulation: Evidence from strategic R&D classification and the R&D tax credit

We investigate a tax avoidance strategy where firms use the ambiguity inherent in tax reporting to classify indirect costs as research and development (R&D) expenditures to take advantage of the R&D tax credit. We label this tax practice “strategic R&D classification”. We find a one standard deviation increase in strategic R&D classification leads, on average, to a 1.7% (1.5%) reduction in GAAP (cash) effective tax rates, suggesting this practice provides significant tax savings. However, we also find strategic R&D classification is related to both the level and changes in uncertain tax benefit liabilities required to be recognized under FIN 48, suggesting this practice comes with financial reporting costs. Our study contributes to the literature by documenting some of the costs and benefits associated with a previously unexplored tax strategy, and highlights the limitations faced by tax authorities in monitoring firms’ R&D tax credit.     

Meta-analysis categorization of EU countries in the context of corporate income tax

The corporate income tax is a corporate tax which aggregates economic, political and social aspects. The paper focuses on identification, analysis and assessment of homogenous EU countries groups, which show the common characteristics in the field of corporate taxation based on the selected segmentation criteria. Within the statistical meta-analysis in this paper some several methodical approaches were used: variants of agglomerative hierarchical cluster analysis, k-means method and fuzzy c-means and also multidimensional scaling method are implemented and compared. The purpose of this research is, in the context of theoretical implication to provide a synthesis of knowledge and empirical evidence about selected determinants of corporate taxation, and to verify the applicability of the clustering methods when gaining knowledge in the field of taxation. In the context of practical implication is the main purpose of this research the categorization of European countries into economically meaningful clusters, based on their similarity in corporate taxation, and to assess the convergence of European countries in corporate taxation. Results of provided cluster analysis are five groups of multidimensional objects with distinctive characteristics: nominal and effective corporate tax rate, economic performance and the level of debt.     

Effective tax rates and the “industrial policy” hypothesis: evidence from Malaysia

Studies on effective tax rates (ETR) and firm size in the non-U.S. context are next to non-existent, with the Kim and Limpaphayom study (1998) being the sole exception. Moreover, no detailed analysis has been performed to study the link between industrial sectors and ETR. Based on a hand-gathered sample of Malaysian firms trading in the Kuala Lumpur Stock Exchange in 1990-1999, this paper examines the association between ETR and a set of possible factors using a regression analysis. There is evidence to suggest that manufacturing firms and hotels pay significant lower effective tax in Malaysia between 1990-1999. In addition, it appears that large Malaysian firms do not suffer a “political cost” as indicated by a negative and significant relation between firm size and ETR. Finally, more efficient Malaysian firms pay lower effective tax. The results are consistent with the “industrial policy” hypothesis developed in this paper based on an examination of the Malaysian context. These results from a large developing country (e.g., Malaysia) can be used to compare with existing results from a large developed country (e.g., U.S.).     

浅析我国衍生金融工具所得性质、数量、时间的认定

衍生金融工具所得课税问题是一个国际难题。本文分别从衍生金融工具所得性质的认定、所得数量的认定、所得时间的认定三个方面展开阐述,分析了国际通行的做法,并联系我国实际对衍生金融工具所得课税进行了探讨。     

流转税和所得税的产业结构调整效应分析

以1994~2009年数据资料为基础构建VAR模型,运用协整检验分析方法、脉冲响应分析方法和方差分解分析方法对流转税和所得税影响产业结构的效应进行了研究。研究发现:从长期来说,流转税对产业结构调整的影响比较显著,而所得税相对弱些;从短期来看,所得税对产业结构调整的影响比较显著,而流转税相对较弱,但二者对产业结构调整的影响都具有滞后效应。因此,分时期区别利用流转税和所得税政策影响产业结构是必要的。     

The roles of book‐tax conformity and tax enforcement in regulating tax reporting behaviour following International Financial Reporting Standards adoption

This study investigates whether increasing the level of tax enforcement can potentially offset the primary cost of a reduction in the level of book‐tax conformity (BTC) following International Financial Reporting Standards (IFRS) adoption – increased tax avoidance. We find that after the decrease in BTC and the concomitant increase in tax enforcement that followed IFRS adoption in Israel, tax avoidance declined significantly. Our results imply that one of the primary costs of reducing BTC can be avoided. Moreover, the results suggest that rather than one strict regulatory approach to deal with reporting manipulations, a combination of trust and control is more effective and less radical.     

The impact of tax enforcement on corporate investment efficiency: evidence from the tax administration information system

Information technology is essential in tax enforcement. This study found that stronger tax enforcement after the tax administration information system reform improved corporate investment efficiency by reducing excessive investment expenditures. The effect is more significant under higher local government fiscal pressure, poorer external information environments, weaker external corporate governance, and stronger tax avoidance motivation. The main mechanism is based on the quality of the accounting information. This study enriches the literature on the economic consequences of tax enforcement and adds investment efficiency as an influential factor, which provides implications for international governments to use information technology to strengthen tax enforcement.