提高企业所得税征管质量和效率的探讨

目前在企业所得税征管方面还存在许多问题.提高企业所得税征管质量和效率的措施包括:加强企业所得税日常管理工作;加大对税务人员的培训力度;加大对纳税人关联企业交易往来的监控;严格审核纳税人申报的财产损失;提高税务稽查选案的准确率;保证税务稽查有的放矢,提高税务稽查的质量和效率.     

International tax arbitrage via corporate income splitting

Abstract

If capital for corporate finance was available from a common global pool and at zero transaction cost, then does after-tax arbitrage require harmonization of income tax rates across jurisdictions? This paper shows that the answer is in the negative. When a corporation has the choice of deciding the fraction of income that it distributes as dividends with the remainder held for future capitalization, then such choice brings about arbitrage in after-tax rates of return to investors facing a common pre-tax return but different rates of income taxes. Policy implications are drawn from this result.     

Economic Effects of Making the 2001 and 2003 Tax Cuts Permanent

All of the provisions of the landmark tax cuts enacted in 2001 and 2003 are scheduled to expire by the end of 2010. This paper analyzes the economic effects of making the tax cuts permanent. We describe the recent tax cuts and the proposals to make them permanent, and explore the consequences of making the tax cuts permanent with regard to the fiscal status of the government, the distribution of after-tax income, and prospects for long-term economic growth.JEL Code: H24     

工薪所得税筹划与企业创新

本文结合我国工薪所得税税负较重及实施创新驱动发展战略的现实背景,探讨工薪所得税筹划是否以及如何对企业创新产生影响。研究发现:(1)工薪所得税筹划程度与企业创新显著正相关;(2)员工应税压力越大,二者正相关关系越显著,且2011年个人所得税税制改革会抑制二者之间的正向关系,表明纳税筹划主要通过降低工薪税负的不利影响,强化薪酬的激励效应,进而促进企业创新;(3)当公司为国有企业或公司处在税收征管强度较大的地区时,二者的正向关系更强;(4)当企业人均薪酬波动较大时,二者的正向关系削弱;(5)当创新员工更有可能是避税行为的受益者时,二者的正相关关系更强。本研究对于降低工薪阶层税负,以及如何提高企业创新意愿,实现创新驱动发展战略,具有重要的理论和现实意义。     

Income repatriation decision for multinational corporations: Tax issues

This paper analyzes the existing asymmetry in the US corporate tax law governing the determination of foreign tax credits earned by US firms with foreign subsidiaries. The existing asymmetry results in the US government de facto holding foreign currency put options against US firms with foreign subsidiaries. Combined with the exchange rate volatility, this tax law asymmetry reduces the effective foreign after-tax rate of return and, thus, makes it profitable for US firms to repatriate their foreign source income earlier even when the foreign after-tax rate of return is higher than the domestic rate. Although this paper identifies this asymmetry in the tax law and analyzes its potential effect on the timing of foreign source income repatriation, it is an open question as to the economic significance of this tax code feature provided the firms’ ability to curry the unused tax credit forward for up to 10 years.     

Effects of Progressive Taxes under Decentralized Bargaining and Heterogeneous Labor

We consider changes in income tax progressivity in an economy where workers' productivities differ and workers and firms bargain individually over wages. With given employment a pure increase in tax progressivity reduces wages by reducing workers' relative bargaining power. When average taxes also increase, after-tax wages are unambiguously reduced, while the effects on gross wages and firm profitability are ambiguous. We next endogenize employment and firm entry under a uniform worker productivity distribution and the government's only policy instrument is a linear income tax. While a first-best solution then is ruled out, a second-best solution can be implemented using a family of linear tax functions, where a more progressive tax implies a higher tax revenue to the government. We show that the government can increase its tax revenue, and reduce after-tax income differences, without any additional disturbance to allocation.     

The use of information technology for international transfer pricing in multinational enterprises

This paper studies the degree to which multinational enterprises (MNEs) use information technology for managing international transfer pricing (ITP). Based on 21 interviews conducted with in-house accounting and tax professionals in MNEs, we observed limited use of information technology for ITP management. However, some degree of ITP automation was observed in workflow management to produce transfer pricing documentation. The limited degree of automation observed was driven by both system- and individual-level barriers. Overall, we found that management accountants and information technology experts dominate the enterprise resource planning system design agenda, and the tax departments’ ITP tax compliance objective plays a relatively limited role. This reduces the ability for ITP automation partly because the data segmentation that is prioritized for management reporting does not support the tax departments’ needs for legal-entity data segmentation to document tax compliance.     

Cost of capital and valuation in the public and private sectors: Tax,risk and debt capacity

Cost of capital and valuation differ in the private and public sectors, because taxes are a cost to the private sector but are only a transfer to the public sector. We show how to transform the after-tax private sector cost of capital into its pre-tax equivalent, for comparison with the public sector cost of capital. We establish the existence of a tax induced wedge between these two costs of capital. The wedge introduces a preference on the part of the private sector for assets with rapid tax depreciation, high debt capacity and low risk. We show that, in circumstances where an asset has identical public and private sector valuation in the absence of taxes, the tax induced difference in valuation is identical to the change in government tax receipts that results from having the asset owned by the private rather than the public sector. We provide some examples of distortions that result from failure to adjust for changes in tax revenues, and show how to effect such adjustment.     

物业税改革对地区间税收分配差距的影响

本文通过对地区间税收分配差距指标的分析,认为开征物业税很可能会扩大我国地区间税收分配差距。在当前物业税改革过程中,需要充分重视该问题的研究。建议将土地出让金制度和财政转移支付制度改革,作为物业税改革总体规划的重要配套措施,统筹设计相关制度,以有效防止地区间税收分配差距的不合理扩大,促进地区间经济协调、平衡发展。     

论国际税收竞争的法律调节

国际税收竞争正在成为经济全球化时代各国最大化本国经济利益的重要方式,它具有广泛的域外负外部效应,需要国际法规范予以调节.随着经济全球化的推进,wTO将成为调节国际税收政策的主要机构.我们必须降低现行企业所得税税率,以应对外国的税收竞争政策,同时,应成立专门工作小组,就国际税收竞争对我国的影响进行理论分析与实证研究,为我国参与wTO关于国际税收竞争问题的谈判提供政策建议.     

Strategic Subsidiary Disclosure

Although subsidiary disclosures in firms’ filings with the Securities and Exchanges Commission (SEC; Exhibit 21) represent the most granular required public disclosure of a firm's geographic footprint, little is understood about the quality of the disclosure, and anecdotal evidence suggests firms may not fully comply with the disclosure requirements. We use data provided by multinational firms to the Internal Revenue Service regarding their foreign subsidiary locations to explore the accuracy of public subsidiary disclosures on Exhibit 21 of Form 10-K per SEC rules. The overall incidence of nondisclosure is low, suggesting that most firms comply with Exhibit 21 disclosure rules, and that for most applications, Exhibit 21 disclosures provide a reasonable proxy for locations of significant subsidiaries. Nevertheless, there is some evidence of nondisclosure, particularly when subsidiaries are in tax havens, when the firm is more highly scrutinized in the media, or when the firm has other characteristics consistent with low-quality disclosures such as SEC comment letters.     

Does Fiscal Decentralization Promote Fiscal Discipline?

We investigate the efficiency and equity implications of a redistributive rule that takes into account both local tax collection efforts and deviation of local incomes from respective targets under alternative fiscal mechanisms. We show that, if the general budget constraint is binding, the proposed transfer rule leads to higher fiscal discipline under fiscal decentralization (FD) than under centralized redistribution. Although the centralized decision yields better income distribution than FD, FD also improves income distribution unambiguously when equalization across regions is targeted explicitly. When localities act strategically, the private sector’s utility weight enhances the disciplinary effect of decentralization.     

关于新一轮个人所得税调整的思考——工资薪金改革角度的探讨

近些年以来,个人所得税的改革一直都是大众所关心的话题。本文首先对此次新一轮个人所得税的改革做一个简单的回顾,通过较为详细的数据对比,分析了年终奖在缴纳个人所得税时,存在奖金增加反而税后收入减少的现象,然后以新、旧个人所得税法间的比较为出发点,对新个人所得税法可能产生的诸多影响进行简单的探讨。     

Dynamic Effects of Extending the 2001 and 2003 Income Tax Cuts

This paper focuses on the impact of permanently extending most of the provisions in EGTRRA and JGTRRA, coupled with potential legislative changes to the AMT, on the federal deficit, the distribution of after-tax income, and economic growth. The paper shows that including moderate behavioral responses offsets 16 percent of the static revenue loss estimate from 2005 to 2014. In addition, including behavioral responses implies that the percentage change in after-tax income from permanently extending the 2001 and 2003 income tax cuts would be largest for taxpayers with incomes ranging from $20,000 to $40,000. Finally, the simulation results suggest that extending the 2001 and 2003 income tax cuts and reducing the growth rate of government spending (excluding Social Security and Medicare), assuming that government expenditures are cut to avoid dramatic increases in government consumption relative to GDP in comparison to historical norms, would increase investment, employment, and output. However, postponing the implementation of tight spending controls would more than offset the positive benefits of lower tax rates on the size of the economy and leave future generations with fewer resources for private consumption and production.JEL Code: E62, H20, H30, H60The views expressed are those of the author and do not reflect those of the Baker Institute for Public Policy or any other organization. This paper was partially written while the author was employed by the Joint Committee on Taxation.     

政府财政激励、税收征管动机与企业盈余管理——以财政"省直管县"改革为自然实验的研究

政府对企业利润享有征税权,事实上是几乎所有企业的最大的中小股东,因此有动机对企业进行严格的税收征管,进而影响公司治理。本文以1998-2006年中国工业企业为样本,以财政“省直管县”改革为自然实验,从企业盈余管理的角度对此进行了考察。研究发现:财政“省直管县”改革能够显著抑制县辖区内企业的盈余管理行为,并且仅对具有征管权限的企业发挥作用;同时,当县级政府财政状况较差和税基较大时,财政“省直管县”对辖区内企业盈余管理行为的抑制作用更强,表明财政“省直管县”改革能够激励县级政府加强税收征管,进而改善辖区内企业盈余质量。更进一步地,本文还发现财政“省直管县”改革能够抑制企业逃税,提升县级政府财政收入。本文的研究不仅丰富了政府行为影响公司治理方面的文献,同时也为财政“省直管县”如何缓解县级政府财政困难提供了微观证据。     

加快经济发展方式转变的税收政策取向

为了加快经济发展方式的转变,保持经济平稳较快增长,有必要对提高财政收入占国民收入比重的政策、结构性减税政策实行调整。本文认为,完善税收政策的取向可确定为:稳定比重、调整结构、灵活应对、适时微调。从短期来看,税收政策主要是在稳定比重的前提下,灵活应对、适时微调;从中期来看,在稳定比重的前提下,着重进行税收制度的结构调整。对此,本文提出了政策取向的量化指标和具体内容。     

THE RELATIONSHIP BETWEEN BEFORE- AND AFTER-TAX YIELDS ON FINANCIAL ASSETS

In this research, the traditional approximation that after-tax yields equal before-tax yields times one minus the tax rate is shown in general to be incorrect. The traditional relationship holds only for one-year assets and perpetuities when a single tax rate applies to both ordinary income and capital gains. For all other multiperiod assets, the correct relationship is much more complex and is a function of the statutory tax rates on ordinary income and capital gains, the holding period, the dividend growth rate for common stocks, and any premium or discount on bonds. The direction of bond price changes is related inversely to the direction of the tax rate changes, but the direction of common stock price changes is related ambiguously to the direction of tax rate changes.     

Comparing in‐work benefits and the reward to work for families with children in the US and the UK

The income transfer systems for low‐income families in the US and the UK try both to reduce poverty and to encourage work. In‐work benefits are a key part of both countries' strategies through the earned income tax credit and the working families' tax credit (and predecessors) respectively. But tax credits are only one part of the whole tax and welfare system. In‐work benefits, taxes and welfare benefits combine in both countries to provide good financial incentives for lone parents to do minimum‐wage work, but poorer incentives to increase earnings further. But direct comparisons of budget constraints hide important points of detail. First, not enough is known about what determines take‐up of in‐work benefits. Second, the considerable differences in assessment and payment mechanisms and frequency between EITC and WFTC mean that low‐income families in the US and the UK may respond very differently to apparently similar financial incentives.     

INCORPORATION OF TAX CONSIDERATIONS INTO THE COMPUTATION OF DURATION

In this paper, the immunization process is extended to protect after-tax income, and the duration indices for after-tax immunization are derived. Selection of the appropriate index depends on individual investor differences in tax regulations. Attention is focused on the mutually exclusive decisions to amortize or not to amortize premia or discounts.     

An analysis of the tradeoff between tax deferred earnings in iras and preferential capital gains

This paper extends prior research in evaluating the decision of whether to invest in a mutual fund either outright or through one of the three available IRAs: the deductible IRA, the Roth IRA, and the nondeductible IRA. We provide mathematical models for after-tax accumulations for each of the investments that are a function of return, the percentage of the return currently taxable to the investor, the time horizon of the investment, the capital gain tax rate, and the ordinary income tax rate. The Roth IRA and the deductible IRA always dominate investments in the nondeductible IRA or through outright investment. However, in comparing the nondeductible IRA and outright investments, the outcome is dependent on the investment goals of the mutual fund and whether it generates substantial dividend distributions or capital gain distributions. Mutual funds with small dividend and capital gain distributions may accumulate larger amounts if held outright while mutual funds that pay substantial dividends or make substantial capital gain distributions accumulate larger after-tax amounts when invested in a nondeductible IRA.