Personal Taxation in Firm Market Valuation: Theory and Test*

In this paper, I extend Ohlson's 1995 firm market valuation model to incorporate personal taxes: the taxes on dividends and the taxes on capital gains. Without personal taxes, firm market value can be expressed as the present value of future benefits received by the shareholders (dividends, in this case). With personal taxes, the benefits received by the shareholders should be classified into three categories (due to their different tax treatments): dividends, share repurchases, and new share issues (i.e., contributed capital). The extended model shows the effects of personal taxation on firm market valuation: retained earnings are valued less than contributed stocks, both dividends taxes and capital gains taxes affect retained earnings valuation and firm market value, and firms choose cash distribution methods (paying dividends and repurchasing shares) to increase their retained earnings valuation, therefore increasing their market value. An empirical test using a sample from the Disclosure Select Canada and Financial Post Card data bases for the years 1995‐98 supports these personal tax effects.     

Corporate and personal income tax declarations

Decisions by firms and individuals on the extent of their tax payments have generally been treated as separate choices. Empirically, a positive relationship between corporate and personal income tax evasion can be observed. The theoretical analysis in this paper shows that a manager's decision on the firm's behaviour will be independent of his personal preferences if the gain from reducing corporate tax payments is certain, as in the case of tax avoidance. If, however, the firm evades taxes so that the manager's income depends on whether the firm's activities are detected or not, corporate and personal income tax evasion choices cannot be separated. Jel Code H 24 · H 25 · H 26     

Returns after personal tax on UK equity and gilts, 1919–1998

This paper investigates whether personal tax could help explain the size of the historic equity premium in the UK measured before personal tax. If there has been a higher tax burden on equity, some of the premium could be viewed as compensation for tax. It is estimated here that personal tax reduces the arithmetic mean nominal return on equity from 13.3% to 11.1% pa during the period 1919–1998, and the mean return on gilts from 7.1% to 5.6% pa. Thus, personal tax accounts for a slightly higher proportion of the before-tax return on gilts than on equity, implying that the equity premium is not a compensation for a higher tax burden on equity.     

企业年金缩小企业与机关事业单位职工养老金差距的政策仿真研究——工资异质性的视角

引入工资差异对企业职工企业年金缴费意愿的影响,采用仿真方法测量企业年金对企业与机关事业单位职工养老金差距的影响。首先,根据我国养老制度安排,构建了企业年金基金、基本养老金、退休金预测模型和养老金差距测量指标;其次,选取工资水平从社平工资的0．5倍～5．0倍的14类代表性职工,模拟了基准情境和提高企业年金税收优惠的四种情境——提高雇主缴费的企业所得税免税上限、降低雇主缴费计入个人账户部分的个人所得税税率、降低领取阶段的个人所得税税率、免征个人缴费的个人所得税,并进行了敏感性分析。仿真结果表明,企业年金及其税收优惠政策能够有效缩小企业与机关事业单位职工养老金差距,提高雇主缴费的企业所得税免税上限的作用最显著。企业年金投资收益率提高、企业年金管理费率降低、余寿减少、社平工资增长率提高和工作年限增加都会放大这种作用,反之亦然。工资越高企业职工从企业年金中获益越大,可能扩大企业职工内部养老金差距。     

Negative Effects of the Canadian GIS Clawback and Possible Mitigating Alternatives

Abstract

In Canada there are three main sources of government-provided retirement income: the Canada/Quebec Pension Plans (C/QPP), which have benefits and contributions based on earnings up to the Yearly Maximum Pensionable Earnings; Old Age Security (OAS), which is a fixed amount for most but does include a “clawback” of benefits for high-income individuals; and the Guaranteed Income Supplement (GIS), which is designed to supplement those persons with extremely low income. The annual GIS benefit is reduced, or clawed back, by 50 cents for every dollar of annual income the person has in retirement, including C/QPP and income from Registered Retirement Savings Plans (RRSPs) and other savings. OAS benefits are not included in determining the GIS clawback.

The result of this is that low-income individuals who attempt to enhance their retirement replacement ratio actually see a decrease in government-provided support the more they save for retirement. Savings in an RRSP can effectively be taxed at more than 100% through corresponding reductions in the GIS, social housing, home care, GAINS (Ontario’s Guaranteed Annual Income Supplement), and other benefits that are based on one’s personal retirement income.

This paper explores alternatives to the 50% GIS clawback, including a basic GIS exemption, a GIS clawback rate lower than 50%, and a combination of the two. The goal is to improve the fairness of the GIS and reduce the disincentive to save for retirement, without increasing the overall cost of the program significantly.     

The capitalization of taxes in bond prices: Evidence from the market for Government of Canada bonds

This paper provides estimates of the extent to which corporate and personal income taxes are capitalized in bond prices. The methodology yields estimates of the degree of tax capitalization, rather than an implied tax rate. This makes it straightforward to identify the marginal investor and test for changes in tax capitalization. The empirical approach also makes it unnecessary to jointly estimate the degree of tax capitalization and the entire yield curve. Corporate taxes are found to have been fully capitalized in pre-tax Government of Canada bond yields during the period 1986–1993. Since 1994, taxes have not been capitalized in yields. These results are consistent with the existence of a marginal investor, but the identity of the marginal investor changed from a financial sector firm to a non-taxed entity in the early 1990s.     

加拿大税收信用体系中的"自我遵从"和"失信惩戒"

加拿大是个高税负的国家,同时,它又是一个税法遵从度非常高的国家。加拿大的税收征管体制是建立在纳税人"自我遵从"的基础之上,这得益于其完善的税收信用管理体制。本文介绍了加拿大税收信用体系的基本情况,并探讨了其对我国税收信用体系建设的借鉴意义。     

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     

加拿大公司所得税制度与征管经验借鉴

加拿大的公司所得税制度体系完备,征管体系也较为合理,促进了经济的持续稳定发展。本文详细介绍了加拿大公司所得税制度及其征管体系,并提出我国在完善企业所得税制度时应借鉴其对公平与效率的兼顾以及加强税收征管的一些有效经验。     

Was the Tax-Exempt Bond Market Inefficient or Were Future Expected Tax Rates Negative?

This paper shows that the sharp narrowing with maturity of the spread between taxable and tax-exempt yields leaves room for tax arbitrage. At times, tax-exempt forward rates have exceeded taxable forward rates. At such times, only expectations of higher taxes on Treasury than on municipal bonds would eliminate profit opportunities. The authors develop the idea of forward tax rates and compute forward tax rates for 1955 through 1984. They also outline tax-arbitrage mechanisms involving private forward sale of long municipal bonds or the use of the Municipal Bond Futures Contract and show the potential profits.     

2000～2008年OECD成员国个人所得税变化及对我国的启示

本文通过对2000～2008年OECD成员国个人所得税变化的分析,得出OECD成员国低收入纳税人税负下降、高收入纳税人税负上升,个人所得税最高边际税率普遍下降、税率档次进一步减少、税收累进性提高等结论。借鉴OECD成员国经验并结合我国国情,认为我国个人所得税的功能应定位于调节收入分配,并就如何提高我国个人所得税累进性提出了相关政策建议。     

Do personal taxes affect capital structure? Evidence from the 2003 tax cut

Because the personal tax treatments of interest and dividend income likely affect the relative cost of debt and equity financing, a sharp change in tax treatment could affect firms' optimal leverage. This paper examines the effect of the 2003 equity income tax cut on firms' debt usage. Because this tax cut affected only individual investors, we can use a difference-in-differences method to identify the effect of personal tax on firms' leverage. Previous research has found that the 2003 tax cut encouraged dividend payouts and reduced the cost of equity, but it provides no link to equilibrium leverage ratios. We estimate that the tax cut causes the affected firms' leverage to decrease by about 5 percentage points. Furthermore, we show that the effects of the tax cut are stronger for firms with lower marginal corporate tax rates and for firms that are not financially constrained, consistent with our theoretical predictions. Overall, we find strong evidence that personal tax is an important determinant of firms' optimal leverage.     

The Evolution of the Tax Structure of a Reforming Transitional Economy: Hungary 1988–98

The paper analyses the revenue-raising, distributional and incentive effects of the personal tax system in Hungary from the start of the transitional tax reforms of 1988 to 1998, and shows that the tax structure has converged to an almost linear form similar to the more heavily taxed EU countries. The 1998 pension reform has reversed a trend increase in average and marginal tax rates but marginal rates still appear too high for a country wishing to encourage growth and employment creation.     

YIELD STRUCTURE OF TAXABLE VS. NONTAXABLE BONDS

In his 1976 presidential address to the American Finance Association, Miller shows that the equilibrium marginal personal tax rate on riskless bond income is equal to the marginal corporate tax rate. In the presence of risk, he and, subsequently, others suggest that the theoretical equilibrium occurs when the personal tax rate is less than the corporate tax rate. This study investigates empirically these relationships by examining the yield ratio of nontaxable to taxable debt at various risk levels. Both the riskless and risk propositions are confirmed.     

上市公司限售股转让税收政策研究

自2010年1月1日实施对个人转让限售股征收20％的个人所得税以来，通过法人转股给自然人进行避税的方式不再有效，但是各种新的避税方式仍层出不穷。对当前限售股转让的避税方式及其制度根源进行深入探讨，可以进一步完善当前税收政策的对策，使其充分发挥税收调节收入分配的职能。     

养老金计划与个人所得税政策

不同税制模式和个人所得税征税方式对养老金计划的影响不同,而养老金计划的个人所得税政策如何定位又主要取决于公共政策对储蓄以及不同储蓄形式的态度。比较国际实践,从税制模式、储蓄传统和长期资产管理来看,我国公共政策不需要鼓励养老金储蓄,但从金融体系的稳定和长远发展来看,又需要对养老金储蓄形式给予一定的鼓励。因此,我国个人所得税政策应该对其给予适当税收激励,但不需要很大力度。考虑到我国分类征收的个人所得税制,本文认为,我国个人所得税对养老金计划应该采取TEE模式(养老金缴款不允许税前扣除、对未支付的资本收益或资本利得不征税、对领取的全部养老金收入不征税)。     

Personal taxes,cost of insurer equity capital,and the case of offshore hedge fund reinsurers

Insurer investment returns are taxed in the United States at the corporate level and at the personal level when they are distributed to shareholders. This paper examines the implications of personal taxes for the tax cost on insurers equity capital and how these tax costs have varied over time under different tax regimes and with different asset portfolios. The paper also discusses how personal taxes provide tax incentives to form offshore hedge fund reinsurers, which provide an interesting case study illustrating the relevance of personal taxes. Finally, the paper discusses the tax treatment of alternative capital arrangements, such as collateralized reinsurance and sidecars.     

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。     

Tax Setting in a Federal System: The Case of Personal Income Taxation in Canada

In a decentralised tax system, the effects of tax policies enacted by one government are not confined to its own jurisdiction. First, if both the regional and the federal levels of government co-occupy the same fields of taxation, tax rate increases by one layer of government will reduce taxes collected by the other. Second, if the tax base is mobile, tax rate increases by one regional government will raise the amount of taxes collected by other regional governments. These sources of fiscal interdependence are called in the literature vertical and horizontal tax externalities, respectively. Third, as Smart (1998) shows, if equalisation transfers are present, an increase in the standard equalisation tax rate provides incentives to raise taxes to the receiving provinces. A way to check the empirical relevance of these hypotheses is to test for the existence of interactions between the regional tax rate, on the one hand, and the federal tax rate, the tax rate set by competing regions, and the standard equalisation tax rate, on the other hand. Following this approach, this paper estimates provincial tax setting functions with data on Canadian personal income taxation for the period 1982–1996. We find a significant positive response of provincial tax rates to changes in the federal income tax rate, the tax rates of competing provinces, and the standard equalisation rate (only for receiving provinces). We also find that the reaction to horizontal competition is stronger in the provinces that do not receive equalisation transfers.     

国内居民消费与经济自主性增长的持续动力

目前我国偏低的居民消费率不足以为经济自主性增长提供持续动力。本文认为,刺激居民消费需求,个人所得税改革不是关键,税收制度的进一步规范更为重要,宏观经济目标的实现与经济自主性增长机制的形成有赖于更长期的税收制度建设。