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 In 1984, the U.S. repealed its 30 percent withholding tax on interest income paid to foreign persons or corporations.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.     

How Did the Elimination of the US Earnings Test above the Normal Retirement Age Affect Labour Supply Expectations?*

We look at the effect of the 2000 repeal of the earnings test above the normal retirement age on retirement expectations of workers in the Health and Retirement Study, aged 51 to 61 in 1992. For men, we find that those whose marginal wage rate increased when the earnings test was repealed, had the largest increase in the probability to work full-time past normal retirement age. We do not find significant evidence of effects of the repeal of the earnings test on the probability to work past age 62 or the expected claiming age. On the other hand, for those reaching the normal retirement age, deviations between the age at which Social Security benefits are actually claimed and the previously reported expected age are more negative in 2000 than in 1998. Since our calculations show that the tax introduced by the earnings test was small when accounting for actuarial benefit adjustments and differential mortality, our results suggest that although male workers form expectations in a way consistent with forward-looking behavior, they misperceive the complicated rules of the earnings test. Results for females suggest similar patterns but estimates are imprecise.     

Economic Instruments to Improve UK Home Energy Efficiency without Negative Social Impacts*

The research examined how to use economic instruments to reduce carbon emissions from the UK housing sector without causing negative impacts on the poorest households. Carbon taxes would worsen the problem of fuel poverty. Compensation mechanisms involving the tax and benefit system were examined, but found not to be entirely effective because of the enormous range in the existing energy efficiency of homes. Exemptions for low‐income households were examined, but found impractical to target. It was concluded that the best way to use economic instruments was through a scheme involving energy audits and surcharges to council tax and stamp duty for homeowners who failed to make cost‐effective energy efficiency improvements within a specified time, with grants and loans to assist low‐income households. After the implementation of such a scheme for 10 years, it would be practical to introduce a targeted carbon tax.     

证券流转税:现状分析、国际趋势与改革思路

我国目前的证券税制以证券交易印花税为主体税种。从长远来看,我国应逐步完善证券流转税制,实行证券交易税和印花税兼征制度。改革我国的证券流转税,在证券交易环节用证券交易税代替印花税,不能仅限于更名,而应有实质性的改变。     

税收调控房地产的正当性及其必要限度——房产税改革试点的税法原则反思

法律是秩序与正义的综合体,房产税改革试点的合法性评价,既要关注相关制度的形式结构,即形式合法性问题,也要关注相关制度的正义价值,即实质正当性问题。就正当性而言,开征房产税是要逐渐地、持续地纠正住房市场化改革以来住房分配中效率与公平的失衡,体现分配正义;就形式结构而言,房产税改革必须遵循法治原则。而高房价盛行和收入差距扩大化背景下的沪渝两市房产税改革试点被赋予了过多的社会功能,有违税收法定原则;以户籍界分征收对象与减免标准有违税收公平原则;以房产交易价格为计税依据使税收适度原则难以落实。房产税改革应当回归税收法治轨道,以确保政府恪守其调控权运行的必要限度,保护纳税人权利,防止过高税收影响社会经济发展。     

印花税调整对股票价格影响的实证研究

印花税下调在短期内对大盘股指产生显著影响,但这种影响随时间的推移而逐渐减弱;税率下调对沪市和深市单只股票具有冲击效应,个股产生正的超额收益;税率下调对两市的大盘波动性产生显著影响,刺激了"噪声交易者",在短期内产生了噪声效应。目前印花税仍然存在一些不足,建议:拓宽税基,改双向征税为单向征税,尽快开征股票交易税。     

After the Supreme Court decision: what's next for reform

A Republican sweep in the November elections could lead to repeal of most of the Affordable Care Act, to be replaced with legislation to achieve limited coverage expansion. A Romney victory and split Congress would likely result in Republicans using their administrative authority to modify or disrupt implementation of the act, with provisions altered or repealed where bipartisan agreement exists. An Obama victory and split Congress would likely result in continued implementation of the act but with a delay to some elements.     

我国证券市场税收政策浅析

我国现行以证券交易印花税为主体的证券税制,在组织财政收入、调节证券市场、抑制过度投机等方面发挥了一定作用,但还存在一些不足之处。建议:进一步调整证券交易印花税的征收办法;建立一套系统、健全的证券税制;消除对公司和股东个人股、红利的重复征税;统一上市公司的企业所得税政策。     

欧共体法院判例对成员国个人所得税扣除制度的推进

《欧共体条约》中没有对直接税的具体规定,欧共体①立法机关也没有对直接税进行立法。但是,欧共体法院②通过案例判决,间接地发展了个人所得税的扣除制度,明确了相关的税收处理办法:应退还临时居民纳税人超额缴纳的工薪所得税;对非居民应按扣除商业费用后的净所得征税;"狭隘"归集抵免制因阻碍成员国间的资本自由流动而被废止。     

Universal Banking Under Bilateral Information Asymmetry

The Gramm–Leach–Bliley (GLB) Act of 1999 repealed many provisions of the Glass–Steagall Act that curtailed competition between banks and commercial firms. Significantly, however, the GLB Act did not repeal the constraint on banks from owning equity in commercial firms (“universal banking”). Should banks be allowed to hold equity in corporate borrowers? If allowed, would banks optimally choose to do so? Despite its relevance from a policy perspective, there are surprisingly few theoretical analyses of this issue of “universal banking”. We develop a model in which the bank's advisory role as an “inside” shareholder hinges on its equity stake. The optimal capital structure and the bank's and entrepreneur's equity stakes are endogenously determined in a world with potential double-sided moral hazard. In certain scenarios, the bank may prefer not to hold any equity. Our analysis indicates that allowing optimal bank equity participation may foster improved corporate performance. This benefit of universal banking should be considered in policy debates.     

Analysts’ earnings forecasting behavior surrounding uncertain regulatory events: evidence from the Tax Reform Act of 1986

This study examines analysts’ forecasting behaviour in the presence of significant tax policy uncertainty. The Tax Reform Act of 1986 (TRA86) was preceded by a lengthy debate, allowing us to investigate how tax policy uncertainty evolves over time. Our results are generally consistent with the intuition that uncertainty precedes the enactment of a proposed tax law while complexity manifests afterwards. Using the repeal of the investment tax credit to identify highly impacted firms, we find that the onset of disagreement among analysts during the debate occurred sooner for highly impacted firms than other firms. We also find that disagreement among analysts was concentrated among highly impacted firms before and after enactment. Given that our sample period precedes Regulation Fair Disclosure, our evidence suggests that analysts relied on private information from management to resolve the uncertainty associated with TRA86 but only for highly impacted firms.     

Conduit Entities: Implications of Indirect Tax-Efficient Financing Structures for Real Investment

As well known, companies shift income from high to low tax jurisdictions. Typically, profit shifting is achieved by direct financing structures whereby companies use debt finance in the high tax entity and equity finance in the low tax entity. However, certain tax policies can lead to indirect financing structures whereby a conduit entity provides an opportunity to achieve at least two deductions for interest expenses for an investment made in the host country. The effect of direct and indirect financing structures on real investment is compared.     

The trade war's impact on the financial market: Observations from the historical global trade war - the Smoot Hawley Tariff Act

This study examines financial market reactions to political events that led to the passage and repeal of the Smoot–Hawley Tariff Act (SHTA) from the perspective of political uncertainty. The events were a series of debates and votes held by the U.S. House and Senate before the SHTA was signed into law in 1930 and repealed in 1934. These events increase political uncertainty about trade policy, thereby creating a unique setting to measure the impact of political uncertainty on financial market reactions. We find that each event resulted in an average loss of 3.6% in the U.S. aggregate stock market over a [−1, +1] three-day window. Such negative returns were observed at the firm level. Moreover, we find that firms with higher tariff protection performed significantly better than firms with lower tariff protection on nonevent dates. Furthermore, we discovered that trading volumes were significantly higher on event dates than on nonevent dates. Stock return volatility was significantly higher during the entire debating and voting period than during the 12 months preceding its inception and 6 months following the SHTA's passage into law. However, higher tariff protection was associated with lower return volatility outside the event window. Our findings show that political uncertainty events commanded the risk premium.     

Adjustment of the Stamp Duty on Stock Transactions and Its Effect on the Chinese Stock Market

This paper studies how the last three adjustments of the stamp duty on stock transactions (SDST) have affected trading behavior on the Chinese stock market. To exclude other shocks from our event study, we focus only on the SDST's short-term effects. Based on an interval autoregressive (IAR) model, we find that the SDST's effects on interval return are trivial; moreover, its ability to influence market volatility and trading volume is cast into doubt. Our empirical evidence lends support to the view that in China the SDST is not an effective policy tool.     

A two-state analysis of estate taxes and charitable bequests from the most generous decedents

This study uses Censored Quantile Regression (CQR) and probate records for the years 2000–2005 to analyze charitable bequests of the most generous decedents from two states, Virginia and Louisiana. We focus on the most generous decedents because they account for a large portion of total charitable bequests. The most generous decedents' charitable bequest tax price (i.e., one minus the marginal tax rate) elasticity is not significantly greater than one in both our full sample and the subsample of the decedents filing federal estate tax returns. Our finding suggests that allowing charitable bequests to be deductible is not a treasury efficient policy for the most generous decedents. We also find that the tax price and wealth effects for the most generous decedents are overestimated by the Tobit model that has been traditionally utilized by prior studies. Furthermore, filers' charitable bequests are predicted to decrease if the estate tax is repealed.     

税收竞争理论发展综述

上世纪80年代中后期以来,税收竞争理论研究已经成为公共经济学领域研究的重要课题之一。近年来,国外对税收竞争的研究取得了众多的研究成果。而我国的研究起步较晚,仍处于介绍与评析国外理论阶段。随着全球化进程的加快,跨国公司活动的日益活跃,国家与国家之间的联系日益密切,如何充分运用税收竞争理论完善我国涉外税收制度、维护我国在对外经济交往中的税收利益、促进我国国内经济的发展将成为以后重要的研究方向。     

税收竞争是当代税收鼓励经济发展的基本形式

经济全球化推动税收竞争。20世纪80年代中后期世界范围内的大规模税制改革标志着税收竞争成为当代税收鼓励经济发展的基本形式;90年代中后期的税制调整是80年代中后期税收竞争的继续,是更加完善的税收竞争形式。公司所得税和关税占各国税收总收入的比重不断下降的趋势是税收竞争的显著结果;避税地税制模式是税收竞争的彻底表现。     

Alcohol taxes,tax revenues and the Single European Market

This paper addresses the issue of whether tax revenue from alcohol lost through cross-border shopping could be recouped by cutting excise duties. This in turn depends on the elasticity of demand for alcohol. We use data from the Family Expenditure Survey 1978–96 to estimate own- and cross-price elasticities of demand for beer, wine and spirits before and after completion of the Single Market. We find no evidence of a significant change in elasticities after the Single Market. The tax rates on beer and wine are currently below their revenue-maximising rates, implying that a cut in the duty rate on beer or wine would lead to a decrease in indirect tax revenue from alcohol. We cannot reject that the current tax rate on spirits is at the revenue-maximising rate, implying that further increases in the duty on spirits are likely to cause indirect tax revenue to fall.     

How Firms Make Capital Expenditure Decisions: Financial Signals, Internal Cash Flows, Income Taxes and the Tax Reform Act of 1986

This paper empirically assesses the determinants of future net capital expenditures for a broad cross-section of COMPUSTAT firms from 1973 to 1989. We explore three general categories of factors expected to affect investment: (1) external equity financing, (2) internally generated accounting information, and (3) tax incentives. We find that external financing and information plays a role in that both positive stock returns and equity issuances indicate future increases in investment. The results suggest that high stock prices not only lower the cost of capital, but also signal good investment opportunities. Accounting information about internal sources and uses of funds are also important in the investment decision. In particular, net income and depreciation are positive indicators of future investment while there is a tradeoff between the payment of dividends and investment. Further, positive changes in available cash liquidity also motivate future investment. While taxes are not important in the investment decision on average, we find that firms with previously higher income taxes invested substantially more in 1985 and 1986. This coincides with the repeal of the investment tax credit and the accelerated depreciation schedules in the Tax Reform Act of 1986. We view this as evidence that federal tax policy in the 1980's induced firms with high income tax obligations to accelerate capital expenditures just before the favorable tax treatment of capital expenditures was eliminated.     

解析公共税收的收入职能

税收的收入职能在人类社会不同历史发展阶段的具体表现是不同的,我们对税收收入职能的认识应该持有历史的、发展变化的观点。如何认识公共税收的收入职能,是我国公共税收建设中一个很重要的问题,因此,建议从公共税收收入职能的动因、职责范围及评判标准等方面进行全面剖析。