Marginal Tax Rates: Evidence from Nontaxable Corporate Bonds: A Note

This study offers an alternative method of calculating marginal personal tax rates through the pairing of nontaxable (industrial development and pollution control) and taxable corporate bonds. This procedure is shown to produce matched bond pairs that are comparable. Two hundred pairs of bonds are examined from the second quarter of 1973 through the second quarter of 1983. Testing of the marginal tax rate relationships indicates that the marginal personal tax rate is less than the corporate statutory tax rate.     

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.     

How do corporate tax bases change when corporate tax rates change? With implications for the tax rate elasticity of corporate tax revenues

We construct a new database of extensive margin changes to multiple aspects of corporate tax bases for OECD countries between 1980 and 2004. We use our data to systematically document the tendency of countries to implement policies that both lower the corporate tax rate and broaden the corporate tax base. This correlation informs our interpretation of previous estimates of the relationship between corporate tax rates and corporate tax revenues, which typically do not include comprehensive measures of the corporate tax base definition. We then re-examine the relationship between corporate tax rates and corporate tax revenues. We find that accounting for unobserved heterogeneity attenuates the relationship between corporate tax rates and corporate tax revenues, and increases the implied revenue-maximizing tax rate. Controlling for our new tax base measures does not substantively impact the magnitude of this relationship.     

Banks as Tax Planning Intermediaries

We provide the first large‐scale empirical evidence of banks functioning as tax planning intermediaries. We posit that some banks specialize in assisting corporate clients with tax planning. In this role, banks make use of their centrality in financial relationships; access to private information; and ability to structure, execute, and participate in tax planning transactions for clients. We measure bank‐client relationships using loan contracts and measure client tax planning using either the cash effective tax rate or the unrecognized tax benefit balance. Using a difference‐in‐differences design, we find that firms experience meaningful tax reductions when they begin a relationship with a bank whose existing clients engage in above‐median tax planning. The effects of pairing with such tax intermediary banks are concentrated in relationships with larger or longer maturity loans, clients with foreign income or greater credit risk, and when the bank is an industry specialist or has above‐median investment banking activities. Finally, we find that potential clients are more likely to choose tax intermediary banks than nontax intermediary banks, suggesting that tax intermediary banks benefit by attracting new business. Collectively, our results suggest that some banks act as tax planning intermediaries, a role beyond the traditional one of financial intermediary.     

Taxation and the optimal constraint on corporate debt finance: why a comprehensive business income tax is suboptimal

The tax bias in favour of debt finance under the corporate income tax means that corporate debt ratios exceed the socially optimal level. This creates a rationale for a general thin capitalization rule limiting the amount of debt that qualifies for interest deductibility. This paper sets up a model of corporate finance and investment in a small open economy to identify the optimal constraint on tax-favoured debt finance, assuming that a given amount of revenue has to be raised from the corporate income tax. For plausible parameter values, the socially optimal debt-asset ratio is 2–3% points below the average corporate debt level currently observed. Driving the actual debt ratio down to this level through limitations on interest deductibility would generate a total welfare gain of about 5% of corporate tax revenue. The welfare gain would arise mainly from a fall in the social risks associated with corporate investment, but also from the cut in the corporate tax rate made possible by a broader corporate tax base.     

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).     

Practitioners' perceptions of the importance of specific corporate tax knowledge of new hires working in tax

This study reports accounting practitioners' perceptions of the importance of new hires having certain tax knowledge normally addressed and developed in a corporate tax class. Variables related to the administration of a tax course are also examined.The results suggest that topics dealing with Subchapter S Corporations, determination of the corporate tax liability, and definition of the corporation are perceived as most important and should be covered in depth. Collapsible corporations and preferred stock bailouts are considered the least important topics.The survey results also are analyzed by firm size (large, medium, and small). Respondents from small firms place more importance on the accumulated earnings tax than the respondents from large firms. Respondents from large firms place more importance on reorganizations than respondents from medium or small firms.When asked about corporate tax course administration, respondents recommend the use of the Internal Revenue Code (IRC) and Regulations as a supplement to a standard textbook. They think it is important for any new hire to have at least one corporate tax course and be familiar with corporate tax forms. The only disagreement among the respondents from the different size firms is related to the number of courses students should complete. The respondents from the large firms indicate one course in corporate tax is not sufficient while the respondents from the medium and small firms indicate it is.The study also compares practitioners' recommendations concerning the amount of coverage for various corporate tax topics with the coverage of the topics in two corporate tax textbooks.These results have implications for accounting academicians who teach corporate tax. The results are useful in determining course coverage and in identifying topics that need additional attention as well as areas that need to be deemphasized or eliminated. The results also provide insight into the corporate tax course administration.     

Why Do Countries Mandate Accrual Accounting for Tax Purposes?

This study investigates why countries mandate accruals in the definition of corporate taxable income. Accruals alleviate timing and matching problems in cash flows, which smoothes taxable income and thus better aligns it with underlying economic performance. These accrual properties can be desirable in the tax setting as tax authorities seek more predictable corporate tax revenues. However, they can also make tax revenues procyclical by increasing the correlation between aggregate corporate tax revenues and aggregate economic activity. We argue that accruals shape the distribution of corporate tax revenues, which leads regulators to incorporate accruals into the definition of taxable income to balance the portfolio of government revenues and expenditures. Using a sample of 26 OECD countries, we find support for several theoretically motivated factors explaining the use of accruals in tax codes. We first provide evidence that corporate tax revenues are less volatile in high accrual countries, but high accrual countries collect relatively higher (lower) tax revenues when the corporate sector grows (contracts). Critically, we then show that accruals and smoother tax revenues are favored by countries with higher levels of government spending on public services and uncertain future expenditures, while countries with procyclical other tax collections favor cash rules and lower procyclicality of corporate tax revenues.     

Theft and taxes

This paper analyzes the interaction between corporate taxes and corporate governance. We show that the design of the corporate tax system affects the amount of private benefits extracted by company insiders and that the quality of the corporate governance system affects the sensitivity of tax revenues to tax changes. Analyses of a tax enforcement crackdown in Russia and cross-country data on tax changes support this two-way interaction between corporate governance and corporate taxation.     

一个有远见的税收制度应当关注未来的税基——特朗普新税法的成本分析及政策建议

20世纪50年代以来,美国企业所得税税率持续下降,政府税收收入也处于较低水平。2017年,特朗普新税法的实施大幅度降低了企业所得税税率,导致政府税收损失远超预期。然而,新税法实施后,美国企业投资和长期经济增长并没有明显改善。本文认为,一个国家经济效率主要取决于税基而非税率,美国政府应通过税收制度改革,增加对企业投资和研发投入的激励,从而扩大税基,实现经济的长期改善。     

Does recent empirical evidence support the existence of international corporate tax competition?

Recent reductions in institutional barriers to international investment have meant that the existence of international corporate tax differentials is now one of the most significant remaining causes of distortion to the optimum global allocation of resources, and hence to international trade. In the debate as to how to reduce such distortion, two main schools of thought have emerged. The first believes that this result can be achieved primarily through the international co-ordination of corporate taxes. To date, efforts in this direction have not made significant progress. The second contends that market forces, through tax competition, will spontaneously reduce international corporate tax differentials. In this article, an analysis of recent trends in corporate tax rates supports this second contention: statutory and effective corporate tax rates are continuing to decline and converge. However, recent tax revenue data give little support for the existence of tax competition; the expected shift in the tax burden from corporate profits onto less mobile factors such as labor has largely failed to materialize. Several explanations for these contrasting findings are outlined and analyzed.     

Financial leverage and corporate taxation: evidence from German corporate tax return data

To estimate the impact of profit taxation on the financial leverage of corporations, this study uses a pseudopanel constructed from comprehensive corporate tax return microdata for the period 1998–2001, which saw the introduction of major corporate tax reform in Germany. Financial leverage refers to the ratio of long-term debt to total capital. The endogeneity of the firm-specific marginal after-financing corporate income tax rate is controlled for by an instrumental variable approach. The instrument for the observed marginal tax rate is the counterfactual tax rate that a corporation would have faced in a particular period had there been no endogenous change, triggered by the tax reform, of its financial leverage and tax base. This counterfactual tax rate is derived from a detailed microsimulation model of the corporate sector, based on tax return microdata. The marginal tax rate has a statistically significant and relatively large positive effect on corporate leverage; for firms reporting positive profits, an increase of the marginal tax rate of 1 % would increase the financial leverage by approximately 0.7 %, on average. The debt ratio is less responsive to tax incentives for small corporations and firms facing high economic risks.     

Corporate site visit and tax avoidance: The effects of monitoring and tax knowledge dissemination

This study examines how institutional investors' corporate site visits affect tax avoidance. Using quantile regressions, we find that corporate site visits decrease tax avoidance for firms at high levels of tax avoidance and increase tax avoidance for firms at low levels. The effect of corporate site visits on tax avoidance is stronger for firms subject to a weaker information environment, which suggests that institutional investors acquire additional firm-specific information via corporate site visits and play a more effective monitoring role. We also find that visitors who visited low-tax firms in prior years share tax-planning knowledge with high-tax firms which they visit in the current year. The effect of tax knowledge transfer is more pronounced when the visitors are from incumbent institutional shareholders. This study identifies corporate site visits as a channel via which institutional investors serve as monitors to managers and as facilitators of tax knowledge transfer.     

Insiders’ perspectives of the effects of recent regulation on corporate taxation

Recent legislation and standard interpretations promulgated by governmental bodies and the Financial Accounting Standards Board (FASB) have attempted to address several issues related to corporate taxation. These issues include the lack of transparency regarding specific tax transactions, the difficulty in reconciling the corporate tax return with the corporate income statement, the relative lack of disclosure of tax contingencies in the financial statements, and the impact of internal control on the reliability of the corporate tax return. While the stated objectives of several recent regulations have included improvements in the areas of corporate tax compliance and transparency of financial statements, it is unclear whether these regulations have resulted in the desired effects. This study analyzes the perceptions of 223 corporate tax executives regarding the effects of Internal Revenue Announcement 2002-63, Schedule M-3 of IRS Form 1120, FASB Interpretation Number 48 (FIN 48), and Section 404 of the Sarbanes-Oxley Act. The findings indicate that the respondents perceive an overall increase in tax return transparency and corporate tax compliance as a result of Schedule M-3 and FIN 48; yet the ability of corporations to engage in tax planning has decreased as a result of FIN 48. The respondents also perceive that both FIN 48 and Section 404 of the Sarbanes-Oxley Act have increased their reliance on outside sources for tax compliance work.     

Taxing multi-nationals under union wage bargaining

This paper investigates corporate taxation under separate accounting (SA) and formula apportionment (FA) in a model with union wage bargaining and multi-national firms. Under SA, we find that increases in the corporate tax rate raise the wage level of domestic workers, while they lower the remuneration of foreign workers. The main insight emerging from a tax competition game is that the endogenous wage level gives rise to an ambiguous fiscal externality, which may dampen the race-to-the-bottom in corporate tax rates. A switch to a tax system with FA principles reverses the impact of corporate taxes on negotiated wages. While increases in the corporate tax rate reduce domestic wages, they raise the wage level of foreign workers. In a tax competition game, the endogenous wage level gives rise to a positive fiscal externality that enforces the race-to-the-bottom in corporate tax rates.     

The value of a flow-through entity in an integrated corporate tax system

In an integrated corporate tax system, resident shareholders receive a tax credit for corporate tax paid that can be used to offset personal tax on dividend income. Nonresident and tax-exempt (pension plan) investors cannot use the tax credit on corporate dividends and thus prefer to invest in flow-through entities. We estimate the value of the flow-through entity to nonresident and pension plan investors by examining the price change around the date of an unexpected announcement of a change in tax law related to Canadian publicly traded income trusts units creating an entity-level tax that makes them no longer tax-favored to these investors.     

Corporate income taxation in Lithuania in the context of the EU

This paper explores Lithuania's competitiveness in the area of corporate income taxation. In order to assess how much freedom of action the country has in designing its own corporate income tax policy, the process of EU tax harmonization is analyzed by evaluating justification for tax harmonization, the major developments and the main outcomes of this process. Lithuania's corporate income tax system is compared with the systems in the other EU countries. Following a macro backward-looking approach, the paper calculates the measures of effective profit tax burden. Effective tax burden measures are computed for the whole enlarged EU. Such calculations are still rare in the economic literature.     

Do corporate tax cuts increase investments?

This paper studies the effect of corporate taxes on investment. Since firms with a foreign parent have more cross-country profit shifting opportunities than domestically owned firms do, their effective tax rate and, consequently, their tax-induced costs to investment are lower. We therefore expect capital investment responses to a corporate tax cut to be heterogeneous across firms. Using firm-level data on German corporations, we exploit the 2008 tax reform, which substantially cut corporate taxes as an exogenous policy shock and expect domestically owned firms' investments to be more responsive to the reform. We show exactly this in a difference-in-differences setting. We find that the reduction in corporate tax payments led to a one-to-one increase in the real investments of domestic firms. The effect is stronger for domestic firms relying more on internal funds. Correspondingly, labor investment increased more for domestic firms, ensuring a constant mix of input factors. In addition, we show that domestic firms' sales grew faster after the tax cut than the sales of foreign-owned firms. Our results imply that corporate tax changes can increase corporate investment but that domestic firms benefit more than foreign-owned firms from a tax cut through higher investment responses resulting in greater sales growth.     

FDI determination and corporate tax competition in a volatile world

This paper investigates the impact of economic and political volatility on corporate tax rates on a large dataset of countries over the 1983–2003 period. Estimation of a dynamic tax rate equation supports the hypothesis that economic volatility negatively affects statutory corporate tax rates, while political volatility has no significant effect. In order to identify the channels through which volatility works, we estimate a structural model allowing for simultaneous determination of corporate tax rates and FDI inflows, and find that economic volatility affects the corporate tax setting process through its impact on FDI inflows.     

Corporate tax revenues in OECD countries

This paper studies variation among OECD countries in the size of corporate income tax revenues relative to GDP over the time period 1979–2002. A decomposition explains such variation as a function of the statutory tax rate, the breadth of the tax base, corporate profitability, and the share of the corporate sector in GDP. Empirical results indicate a parabolic relationship between tax rates and revenues, implying a revenue-maximizing corporate income tax rate of 33% for the whole sample. This revenue-maximizing rate is found to decrease as economies are smaller and more integrated with the world economy. JEL Classification H25, H87