Full Text Available After the ten years of work and discussion of the proposal the European Commission has published the proposal of CCCTB directive on 16th March, 2011. This proposal can be considered as unique, for the European Commission is suggesting totally new system of corporate taxation. The aim of the paper is to research the rules for consolidation and grouping suggested in the proposal of CCCTB directive, to identify the possible conflict situations and to suggest the possible solution. The focuses on the provisions regarding the conditions for consolidation and grouping, comprised in chapter IX, Art. 54–60. In that area has been identified, that even though the provisions seem to be clear, their practical application can in some situations lead to double interpretation, mainly with respect to the fact that individual member states are responsible for the implementation of the directive and also national tax administrators and national courts are going to interpret the provisions of the directive. Therefore even though the fact that suggested system is unique and addresses a lot of problems which are facing companies running business on the internal market, the provisions regarding the consolidation rules and rules for group formatting may still lead not to unified interpretation. In that respect, some of the rules should be more specific in order to ensure unified interpretation.
Full Text Available Transfer pricing mechanism is a tool commonly used to transfer the tax base in countries with high tax countries with lower taxation. In the European Union the financial operations generate tax revenue losses. In an attempt to limit manipulation by corporate tax systems, many public authorities have introduced transfer pricing rules, but these rules has shown limited efficacy, however, contribute to the increasing complexity of tax laws and the emergence of additional costs for companies. This paper deals with the concrete examples, the solution to solving the problem of transfer pricing in the European Union by the introduction of common consolidated corporate income tax.
Full Text Available In order to address some existing difficulties in corporate income taxation (CIT, the European Commission proposed the introduction of measures for coordination, a solution contested by some member states but supported by most professionals and many organizations representing the interests of European employers. Disputes in connection with the introduction of the Common Consolidated Corporate Tax Base (CCCTB are occasioned by the uncertainty regarding its effects. Since CIT makes an important contribution to the forming of central budget revenues, the CCCTB is a challenge for Romanian public authorities. The Romanian government has not made clear its options in this respect. In this paper we present the main points of view about the implications of introducing the CCCTB as seen by specialists and estimate the effects of the EU formula apportionment on CIT revenues in Romania.According to research results on a sample of companies in 2006-09, Romania will assume a loser position if the EU formula apportionment uses the payroll (although the loss of tax revenue would be lower than other researchers have estimated and a winner position if the EU formula apportionment does not use the payroll.
Full Text Available For solving the existing difficulties in corporate income taxation, the European Commission proposed the introduction of measures for coordination, solution contested by some Member States but supported by most professionals and many organizations representing the interests of European employers. Disputes in connection with the introduction of the “Common Consolidated Corporate Tax Base” system are determined by the uncertainty regarding its effects. In this context, we intend to present and analyze some effects of applying the EU formula apportionment.
Full Text Available As of 1 July 2013, i.e. with Croatia’s accession to the European Union, the number of Member States of the European Union rose to 28. The diversity of tax systems among the Member States causes interferences in cross-border activities of tax firms. That encourages transfer of income to countries with lower tax rates. The aim of this paper is to present the main points of view on the implications of the introduction of the Common Consolidated Corporate Tax Base (CCCTB in Croatia. This paper also estimates the effects of the prospective apportionment procedure on corporate group entities in Croatia. The acceptance of the CCCTB system will make Croatia attractive to foreign investors. It will also enable foreign multinational companies to do business in Croatia, which will contribute to its economic growth.
Ali, Eid Ashry Gaber
This thesis was submitted for the degree of Doctor of Philosophy and awarded by Brunel University. The thesis examines the international taxation rules of the Common Consolidated Corporate Tax Base (CCCTB) and their interaction with third-country corporate tax practice. The aim is to assess the effectiveness of the CCCTB vis-à-vis third countries, with Egypt as a practical example. The CCCTB has the potential to reduce corporate tax obstacles faced by businesses in the EU in having to comp...
This thesis "Tax planning in corporation" puts brain to legal entity income tax and it is looking for possible solutions in tax planning in corporation. The first part deals with the tax theory, the other part is the theory of tax planning, comparison of tax regimes and tax policy and tax revenue by optimizing both internationally and in the local aspect. The last part discusses options for optimizing tax
1 RESUMÉ Corporate Income Tax The aim of this diploma thesis on "Corporate Income Tax" is to outline the current legal background of the corporate income tax and asses and evaluate the most substantial changes regarding the Act no. 586/1992 Coll., Income Tax Act, as amended that have become effective as of January 1, 2014. The changes discussed in this thesis include especially, but are not limited to, the changes adopted in connection with the recodification of Czech Civil Law. This thesis c...
... 26 Internal Revenue 12 2010-04-01 2010-04-01 false Consolidated tax credits. 1.1502-3 Section 1... (CONTINUED) INCOME TAXES Consolidated Tax Liability § 1.1502-3 Consolidated tax credits. (a) Determination of...) Consolidated limitation based on amount of tax. (i) Notwithstanding the amount of the consolidated credit...
Kari, Seppo; Ylä-Liedenpoha, Jouko
Classical corporation tax entails double taxation of corporate income. The alternative practice of imputing corporation tax to the domestic recipients of dividends is shown, in the case of a company with international owners, to effectively convert the imputation system back to a classical corporation tax. It also requires complex rules for exempting flow-through dividends from equalization tax to avoid the cumulation of corporation tax internationally. In contrast, classical corporation tax ...
... 26 Internal Revenue 12 2010-04-01 2010-04-01 false Consolidated foreign tax credit. 1.1502-4... TAX (CONTINUED) INCOME TAXES Consolidated Tax Liability § 1.1502-4 Consolidated foreign tax credit. (a) In general. The credit under section 901 for taxes paid or accrued to any foreign country or...
Cornia, Gary; Edmiston, Kelly D.; Sjoquist, David L.; Wallace, Sally
This paper examines alternative explanations for the decline over the past two decades in state corporate income taxes relative to the state economy. We employ a survey of state tax administrators, individual tax returns from Georgia and Utah, and panel data to explore the importance of tax policy, tax planning, and economic factors on the trend in state corporate taxes. We find that corporate tax planning and economic factors account for much of the relative decline, and that state tax polic...
This paper deals with the impact of tax-aggressive strategies on corporate governance by adopting an agency perspective of the firm and discusses how certain corporate tax governance measures may limit these kinds of managerial actions. We first clarify a few basic concepts such as tax minimization, effective tax planning, tax avoidance, and tax evasion, which are important to understand in the discussion about aggressive tax behaviour. We further define the regulative concept of effective ta...
Contemporary populism is rooted in a crisis of legitimacy. Corporate taxavoidance by multinationals is one cause of that crisi s. Although states tend to beincreasingly formally committed to tackling avoidance, they do so in a system thatpromotes contradictory sets of behaviour. This tends to undermine attempts to solvethe problem of avoidance unless a more transformative collective approach is taken.Ironically, despite its own democratic deﬁcit, the European Comm ission has taken aleading ro...
Bružauskas, Valentinas; Stončiuvienė, Neringa
The article sets out the research results of existing Corporate Tax accounting in Lithuania. There is disclosed the link between financial and Corporate Tax accounting, and their coordination improvement. The authors think that, the closer link between financial and tax accounting is obligatory. The provisions of Corporate Tax calculation should be adjusted with requirements of financial accounting. Also there is specified the methods of Corporate Tax reform and their feasibility. In the arti...
My thesis investigates the association between CEO power, corporate tax avoidance and tax aggressiveness, using two organizational theory perspectives: self-interest and stewardship. I find that a powerful CEO engages in less corporate tax avoidance activities, which lends credence to the risk minimization motive of the stewardship perspective. My findings on the association between CEO power and tax aggressiveness show that powerful CEOs avoid risky tax avoidance strategies that expose a fir...
Blaufus, Kay; Möhlmann, Axel; Schwäbe, Alexander
Tax minimization strategies may lead to significant tax savings, which could, in turn, increase firm value. However, such strategies are also associated with significant costs, such as expected penalties and planning, agency, and reputation costs. The overall impact of firms' tax minimization strategies on firm value is, therefore, unclear. To investigate whether corporate tax minimization increases firm value, we analyze the stock price reaction to news concerning corporate tax avoidance or ...
Mahangila, Deogratius Ng'winula
Many governments are struggling with inadequate tax revenue and increasing tax gaps. Consequently, changing behaviour of non-compliant taxpayers as small and medium enterprises (SMEs) because of their tax revenue potential and non-compliance behaviour is essential. This thesis examined the impact of corporate income tax penalty incidence, retributive justice, procedural justice, the interaction between retributive and procedural justice on corporate income tax compliance behaviour. Also, the ...
My diploma thesis is focused on the optimization of corporate income tax. The thesis is divided into the theoretical and practical part. In the theoretical part are described terms such as taxpayers, subject of tax, tax base, tax calculation or when the tax is payable. The practical part begins with the characteristic of the company, followed by the calculation of the tax liability and the optimization of the corporate income tax. The aim of the thesis was to find the optimal variant of the c...
Stephen R. Richardson
Full Text Available There are both theoretical and practical tax policy considerations that favour a broad recognition for the value of corporate income tax losses-- including for businesses operated within corporate groups. Ideally, an equitable and economically efficient tax system could obviate the need for loss netting against income by providing for the tax value of losses from business to be refundable by tax authorities in cash to owners. This approach, however, involves many serious difficulties, including revenue cost to governments and potential for abuse by both domestic and foreign businesses. Accordingly, loss refundability tends to be provided for only sparingly, if at all; while many corporate income tax systems—such as in the U.S. the U.K., Japan and many other OECD countries--deal with loss netting within corporate groups through a formal system of tax loss transfer or tax consolidation. While Canadian policymakers have considered introduction of such a system over a long period of time, they have yet to come up with a satisfactory formal system for Canada. So, corporate groups in Canada have been left to make do with an informal self-help loss trading system that presents a number of problems compared to formal systems. As a federal country with substantial corporate taxation levied at the provincial level, Canada appears unusually constrained in what it can do to bring greater equity and efficiency to corporate group tax loss utilization. Moreover, the inefficiencies in the current system are small in aggregate terms, and the informal self-help system has a relatively generous threshold for access. Accordingly, while Canada’s current informal self-help corporate group loss system is far from ideal, it appears to remain as a workable approach. Alternatives to the status quo should be considered cautiously, as they have the potential to do more harm than good.
... 26 Internal Revenue 1 2010-04-01 2010-04-01 true Tax on corporations. 1.11-1 Section 1.11-1 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY INCOME TAX INCOME TAXES Tax on Corporations § 1.11-1 Tax on corporations. (a) Every corporation, foreign or domestic, is liable to the tax...
James Levinsohn; Joel Slemrod
In this paper we develop some simple models of optimal tax and tariff policy in the presence of global corporations that operate in an imperfectly competitive environment. The models emphasize two important differences in the practical application of tax and tariff policy - tax, but not tariff, policy can apply to offshore output and tariff, but not tax, policy can be industry-specific. Recognizing the multinationals' production decisions are endogenous to the tax and tariff policies they fac...
Friis Hansen, Søren; Nielsen, Jacob Graff
In terms of tax policy, tax harmonization or coordination of corporate taxation in the EU is usually considered from two complementary points of view: tax base and tax rate. These two perspectives structure the debate whether EU Member States, and more broadly States belonging to the same economic...... area, should harmonize or coordinate their policies in tax matters. However, little attention has been paid so far to a more basic question: who are corporate taxpayers? Are they defined in the same way over Europe? This may be explained by the fact that the vast majority of tax systems accept the same...... fundamental idea: while companies limited by shares and limited liability companies should be subject to corporate income tax (CIT), partnerships should be considered fully or partly transparent for tax purposes. This general statement is nevertheless an oversimplification of reality. Comparative law indeed...
One of the main objectives to be accomplished by the European Union law is to eliminate barriers to the functioning of domestic market and in particular improve the competitiveness of enterprises. After several years of efforts, the European Commission approved a proposal for the directive on a Common Consolidated Corporate Tax Base which is to remove obstacles to the functioning of internal market and increase tax harmonization. The article is aimed at presenting the essence of CCCTB in the ...
This thesis consists of four essays: The first essay entitled “Tax Effects on Asset Pricing – New Evidence from Tax Reform Announcements in Germany”, co-authored with Michael Overesch, Chair of Business Taxation at the University of Cologne, not only presents price effects for German shares given rumors about lowering the German corporate tax rate but also shows price effects for bonds following a substantial cut in the German personal interest tax rate. The second essay “Capital Inco...
Against the background of recovering growth and remaining fiscal consolidation needs, reforming tax expenditures may offer a promising avenue to raise revenue and, at the same time, improve efficiency of the tax systems. The workshop, held by DG ECFIN on 23 October 2013, addressed the economic and budgetary aspects of tax expenditures, including reporting practices, and discussed the rationale for business tax incentives and the distributional effects of tax reliefs in personal income taxatio...
Lourdes Jerez Barroso; Joaquín Texeira Quirós
Purpose: Due to its advantages in terms of neutrality and simplicity, the aim of this paper is to design a tax base for corporation cash flows, as well as to develop its practical implementation.Design/Methodology: The conceptual aspects and the background of tax on corporation tax flows are reviewed and a tax base that levies a charge on the corporation’s economical activities’ cash flow is then proposed. In order to carry this out, a methodological procedure is developed on the basis of the...
After the inheritance tax ruling by the German Federal Constitutional Court, legislators will have to limit the wide-ranging exemptions on company assets. In recent years, they have exempted half of all assets subject to inheritance tax. In particular, large transfers consisting mainly of corporate assets benefit from the favorable conditions. In 2012 and 2013, over half of all transfers of five million euros or more were tax exempt, and over 90 percent of transfers of 20 million euros or mor...
Nuralifmida Ayu Annisa
Full Text Available This study aims to find out how the influence of the corporate governance of tax avoidanceactivity in companies listed on Indonesia Stock Exchange in 2008. The samples are publiclytraded company listed on the Indonesia Stock Exchange in 2008 as many as 200 companies. Thisstudy uses data analysis and regression analysis of the elements of corporate governance and taxavoidance. The results of this study show that the elements of corporate governance that consist ofaudit quality and audit committee significantly influence the activity of tax avoidance as measuredusing proxy book tax gap. Other results show that the tax avoidance activity as measured withproxy book tax gap are not affected significantly by institutional ownership and board ofcommissioners. Limitation of this study is not to use each type of industries as control variable socan’t identify the direct effect from type of industry on tax avoidance. Another limitation of thisstudy is use corporate governance’s proxy separately, so it can’t capture the full effect ofcorporate governance. Keywords:corporate governance, ownership structure, board of commissioners, audit committee,tax avoidance, book tax gap.
Lourdes Jerez Barroso
Full Text Available Purpose: Due to its advantages in terms of neutrality and simplicity, the aim of this paper is to design a tax base for corporation cash flows, as well as to develop its practical implementation.Design/Methodology: The conceptual aspects and the background of tax on corporation tax flows are reviewed and a tax base that levies a charge on the corporation’s economical activities’ cash flow is then proposed. In order to carry this out, a methodological procedure is developed on the basis of the accounting documents that companies must present and through which the stock variables and the accounting documents’ work flow is transformed into cash flow.Findings: An implementation on the basis of the accounting documents that Spanish companies must present. Practical Implications: This paper defines the procedure to follow in order to determine the tax base of a cash flow corporate income tax on the basis of its accounts, which would allow an estimation of this tax figure’s revenue impact.Originality/ Value: The design of a tax base of cash flows for companies. The accounting approximation carried out to determine the cash flows justifies the fact that the tax base proposal is technically possible.
Full Text Available One of the main objectives to be accomplished by the European Union law is to eliminate barriers to the functioning of domestic market and in particular improve the competitiveness of enterprises. After several years of efforts, the European Commission approved a proposal for the directive on a Common Consolidated Corporate Tax Base which is to remove obstacles to the functioning of internal market and increase tax harmonization. The article is aimed at presenting the essence of CCCTB in the theory of corporate finance and its importance for enterprises, based on the survey of Polish and EU companies. The paper addresses issues relating to tax in corporate finance. Canons of taxation will be discussed and special emphasis will be placed on principles behind formulating fiscal law provisions (including the EU law. Furthermore, the article presents the results of surveys into the importance of taxation cannons for Polish and EU companies.
Tkachyk Lesya P.
Full Text Available The article identifies and reveals the essence of functional elements of corporate tax management, which are tax planning, tax analysis, tax accounting and reporting, tax control and tax monitoring. The article builds a functional model of corporate tax management that reflects interaction of its functional elements in the process of realisation of tax activity of economic subjects. Pursuant to this model, the corporate tax management is conducted in several stages, namely: development of alternative variants of tax activity, analysis of alternative variants of tax activity, selection of the optimal variant of tax activity, realisation of tax activity, control over realisation of tax activity and development of measures of increase of efficiency of tax management. Application of the functional model of corporate tax management, which envisages use of all instruments, allows optimisation of tax payments of economic subjects.
Full Text Available Worldwide crisis has made multinational companies that are engaged in corporate social responsibility actions to manage their businesses through the lens of various tax avoidance practices. The content of this paper is important due to the fact that tries to identify the impact in case of companies active in corporate social responsibility actions versus their tax structures orientation. Corporate social responsibility literature did not paid enough attention on the impact of the tax avoidance practices of companies. Tax, as a concept, brings in itself an important corporate financial impact with subsequent effects for the life of multiple citizens in countries where private entities are operating. Even though companies are usually expressing their ethical and responsible conduct in respect of the social environment, there are many cases when the business practices were not aligned with the declared corporate behavior. This paper seeks firstly to examine whether companies engaged in tax avoidance practices (ex. offshore tax havens consider that continue to act socially responsible. Secondly, the paper examines the influence on attending the stakeholdersâ€™ goals for those companies practicing tax avoidance and its implications on corporate social responsibility actions. Moreover, the paper focuses also on the aspects described before from the perspective of the corporate entities operating in Romania. This paperâ€™s intention is to use and to develop the results of previous research carried out by Lutz Preus (University of London and, subsequently, by Senators Levin, Coleman and Obama in their â€œStop Tax Haven Abuse Billâ€. The implications and the objectives of this material are to highlight, to identify and to spot clearly the relations and the influences of the tax haven practices of corporations versus their undertaken social responsibility actions. Moreover, this paper brings a fresh perspective of this topic from the
Bernstein, Jeffrey; Shah, Anwar
The authors provide an empirical framework for assessing the effects of tax policy on an array of producer decisions about output supplies and input demands in Mexico, Pakistan, and Turkey. They specify and estimate a dynamic production structure model with imperfect competition for selected industries in these countries. The model results suggest that tax policy affected production and investment and further that selective tax incentives such as investment tax credits, investment allowances,...
Annisa, Nuralifmida Ayu; Kurniasih, Lulus
This study aims to find out how the influence of the corporate governance of tax avoidanceactivity in companies listed on Indonesia Stock Exchange in 2008. The samples are publiclytraded company listed on the Indonesia Stock Exchange in 2008 as many as 200 companies. Thisstudy uses data analysis and regression analysis of the elements of corporate governance and taxavoidance. The results of this study show that the elements of corporate governance that consist ofaudit quality and audit commit...
... DEPARTMENT OF LABOR Employment and Training Administration [TA-W-73,579] Consolidated Glass and Mirror Corporation, a Subsidiary of Guardian Industries Corporation, Galax, VA; Notice of Affirmative... Consolidated Glass and Mirror Corporation, a Subsidiary of Guardian Industries Corporation, Galax, Virginia...
Full Text Available The interdependence between countries and the importance of the economic links between them has reached an extend unprecedented in history. In the context of globalization, the mobility of production factors may get pressure on governments to reduce taxes in order to remain attractive. In this way, differences between European Union member states will be intensifying, increasing national suzerainty limit controversies in direct tax domain and, especially, in corporate income taxes domain. It is acute the necessity of the coordination in tax domain in European Union, but it must not be neglected the fact that social preferences of each state imposes on independents in creating of national tax policy.
Full Text Available One of perspective directions of business development is creation of large companies (holdings, concerns, corporations, etc. that unite legally separate economic entities linked by organizational, economic and civil-law subordination. Increasing the efficiency of such companies and, on this basis, the growth of the national economy and its competitiveness in the world market is influenced by tax system of a group of interconnected companies. International experience has shown that these tax systems in different countries were created under the influence of a combination of various factors, most of which were due to both, historical development and mutual influence. The article presents the development of methodological approach to the improvement of Russian tax system for consolidated groups of taxpayers, which requires the integration of a number of scientific ideas and hypotheses of various schools and international experience in formation and development of the institution of consolidated tax reporting. This approach is based on the fact that consolidated group of taxpayers should be considered as an economic entity, which is a separate object of financial accounting and tax system. In present work with the help of such general scientific methods as system approach, comparison, method of data systematization and generalization, the conditions for creating consolidated group of taxpayers were studied; mechanism of consolidation and system of consolidated profitability reporting for the group of companies, their main content; the procedure for granting the right to set off losses, including losses incurred for the period preceding the year of consolidation of one company member of the group, against the profits of other members of the group.
The study examined the impact of corporate governance on tax planning of non- .... board characteristics on corporate tax avoidance (Minnick &Noga, 2010; Lanis ...... African economy; Journal of Business and Policy Research; 5(1), 110-122.
Thesis called "Corporate income tax and its impact on financial reporting" focuses on the problem of calculating the tax on corporate income of legal entity established for business purposes. The thesis deals with the issue of adjustment of profit in order to create the tax base and displays impact of this adjustment on due tax.
This article attempts to estimate the magnitude of corporate tax avoidance and personal tax evasion through offshore tax havens. US corporations book 20 percent of their profits in tax havens, a tenfold increase since the 1980; their effective tax rate has declined from 30 to 20 percent over the last 15 years, and about two-thirds of this decline can be attributed to increased international tax avoidance. Globally, 8 percent of the world's personal financial wealth is held offshore, costing m...
Drawing upon media agenda-setting theory and previous studies in organizational impression management, this paper empirically investigates the influence of tax avoidance news on corporate tax reporting. This study is based on the pronounced discontinuity in the amount of news articles related to tax avoidance in the United Kingdom over two periods (2010-2011 and 2012-2013). A difference-in-differences design is employed in order to enable a comparison of the media effects on those firms that ...
Full Text Available Recent trends towards a common European tax policy for the generalcorporate taxation aim at preventing the negative effects of tax competition, especially those ofthe national tax base “migration”, by moving corporate main offices in countries with moreadvantageous systems of taxation. The idea of harmonising corporate taxation constitutes oneof the most important debate topics on the agenda of the European Commission for the moment,and also within specialists’ theoretical approaches. The vast range of such approaches isparticularly relevant for the complexity of the problems that hindering the formula, even if it isonly at a theoretical level separated from the policy feasibility issues, and from widely sharedsolutions.
Gribnau, Hans; Salter, David; Oats, Lynne
Taxpayers have to plan their tax affairs to plan their life or develop their business strategy. Often tax planning is encouraged and intended by tax legislation. Tax incentives are often used to steer (corporate) citizens’ behaviour to achieve all kind of policy goals. In this way, the tax
Jaan Masso; Jaanika Meriküll
International tax competition had led to a lowering of corporate tax rates worldwide. Estonia was the first country to reduce the tax rate on retained earnings to zero, while distributed profits remained taxed at the pre-reform level. This paper seeks to analyse the effects of this unique tax reform implemented in year 2000. We apply a neoclassical exogenous growth general equilibrium model with an extension for endogenous corporate finance. Our findings indicate that the reform had a strong ...
The empirical literature shows that management incentives often reduce corporate tax aggressiveness. Focussing on the riskiness of tax aggressiveness this paper offers one explanation for the observed negative relation. Using an agency framework, I analyze the manager's choice of effort dedication in other tasks and her explicit choice of the firm's tax risk. I show that corporate tax aggressiveness may decrease with compensation incentives. By choosing the tax risk, the manager (partly) dete...
Full Text Available The possible ways of corporate tax base harmonization in the European Union are presented in the paper. Present situation when there are 27 different taxation systems used in the EU increases compliance costs of taxation to the companies and therefore decreases their competitiveness. It was proved, that there is negative correlation between the size of the company and the size of the compliance costs of taxation. Based on that, the European Commission has decided for twin-track strategy – to introduce home state taxation in the short term and common consolidated corporate tax base in the long term. In respect to the fact, that the pilot project in the frame of home state taxation system has not started yet, the attention has been turned to the common consolidated corporate tax base. The paper discusses the possible attitudes and methods of consolidated tax base allocation. Based on mentioned arguments the formulary apportionment with factors which generate the taxable income of the group (assets, payroll, turnover, etc. seems to be the best solution. Factors and their weight should become the subject of further discussion in the European Union. The aim of the paper is to present the possible harmonization models and further to discuss the methods which could be used for allocation of the consolidated tax base under CCCTB.
R.A. de Mooij (Ruud); G. Nicodè me
textabstractIn Europe, declining corporate tax rates have come along with rising tax-to-GDP ratios. This paper explores to what extent income shifting from the personal to the corporate tax base can explain these diverging developments. We exploit a panel of European data on firm births and legal
Full Text Available The majority of experts agree that taxes are distortionary in nature. This is relatively true for all of the different groups of taxes, but for the corporate taxes is exceptionallyobvious. The existence of the corporate tax system can affect the company’s behavior in number of ways and one of the most criticized is the ability for distortion of the choice of the sources of finance. In the following article, we explore the effects from corporate taxation on investment, through the methodological frame of the effective marginal tax rates. The objective is to analyze the investment decision in the case of isolated implementation of corporate taxes which means that the effects from the so-called “double taxation”, induced by the personal taxes are not taken in consideration. We hope to prove that these conditions generate “uneven” distribution of the burden across the projects covered with different sources of finance. Also, we intend to test and explore the properties of some alternative corporate tax systems which are widely known as neutral, such as: the comprehensive business income tax system (CBIT, the imputation corporate tax system (ICT, the full imputation corporate tax system (FICT, the allowance for corporate equity tax system (ACE and the split rate corporate tax system (SRCT. In addition, we support our findings with a practical example: the case study from the implementation of the split rate corporate tax system in Macedonia.
Boot, A.; Logue, D.; Spatt, C.
Corporate tax reform has been a controversial issue in the U.S. for several years, particularly as U.S. companies have accumulated cash in lower‐tax overseas subsidiaries, while some have used “inversions” to establish overseas corporate domiciles. Two features of U.S. corporate taxation stand out:
Full Text Available This paper analyzes the Common Corporate Tax Base (CCTB as an interim alternative to the proposal of a Council directive on a Common Consolidated Corporate Tax Base (CCCTB. The CCCTB concept does not only include common rules for determining the tax base like the CCTB but also the steps of consolidation and subsequent formula apportionment. Therefore, the paper starts by showing that particularly these second and third steps of the CCCTB project meet fierce political opposition from several Member States and do leave leeway for tax planning. Afterwards, the CCCTB proposal's approach to common rules for determining the tax base is evaluated, i.e. tested for its suitability as a point of departure for drafting a CCTB. Finally, various other aspects of the proposal are examined in light of a CCTB without consolidation.
In order to alleviate part of this double taxation of distributed profits the classical system was replaced in 1973 by the "imputation system". This new system of taxation gives shareholders tax credits for tax paid by the corporation. These tax credits may be used by shareholders to offset their income tax liability on the dividends they receive.
In addition to the ordinary corporate income tax, special purpose taxes are sometimes levied to extract abnormal profits arising from the use of natural resources. Such dual tax regimes exist in Norway for oil and hydropower, where the corresponding special purpose tax bases are unaffected by any derivatives payments. Dual tax firms with hedging programs therefore face the risk of potentially large discrepancies between the tax bases for corporate income tax and special purpose tax. I investigate how this tax base asymmetry influences the extent of hedging of value-maximizing firms facing hedgeable as well as unhedgeable risk. Dual tax firms facing deadweight costs in low-profit events generally demand less hedging than ordinary firms, but otherwise respond similarly to characteristics of the underlying risk exposures. The special purpose tax does not influence firms' hedge portfolios in the absence of deadweight cost. (author)
Frestad, Dennis [Department of Economics and Business Administration, University of Agder, Serviceboks 422, 4604 Kristiansand (Norway)
In addition to the ordinary corporate income tax, special purpose taxes are sometimes levied to extract abnormal profits arising from the use of natural resources. Such dual tax regimes exist in Norway for oil and hydropower, where the corresponding special purpose tax bases are unaffected by any derivatives payments. Dual tax firms with hedging programs therefore face the risk of potentially large discrepancies between the tax bases for corporate income tax and special purpose tax. I investigate how this tax base asymmetry influences the extent of hedging of value-maximizing firms facing hedgeable as well as unhedgeable risk. Dual tax firms facing deadweight costs in low-profit events generally demand less hedging than ordinary firms, but otherwise respond similarly to characteristics of the underlying risk exposures. The special purpose tax does not influence firms' hedge portfolios in the absence of deadweight cost. (author)
Policymakers worldwide try to hinder tax avoidance. In order to implement effective tax regulations, it is essential to completely understand why corporations avoid taxes and why some appear to be more effective than others. However, various challenges in identifying effects and determinants of corporate tax avoidance cause knowledge gaps. This thesis consists of three essays highlighting the necessity of refined identification strategies. The first essay “The Undersheltering Puzzle and its P...
... tax avoidance purposes, whether or not such corporation is engaged in trade or business in the United... TAX (CONTINUED) INCOME TAXES Foreign Corporations § 1.881-1 Manner of taxing foreign corporations. (a) Classes of foreign corporations. For purposes of the income tax, foreign corporations are divided into two...
Tax aggressiveness and corporate social responsibility fluidity in Nigerian firms. ... the nexus between shareholding and wider-spectrum stake-holding, where key ... to forge mutually expedient cash flow mechanisms for sustainable corporate ...
Muller, A.; Kolk, A.
Anecdotal evidence often suggests that multinational enterprises (MNEs) operating in developing countries "exploit their multinationality" to avoid paying taxes to host governments. This article explores the concept of "responsible tax" as a corporate social responsibility (CSR) issue for MNEs,
Jallai, Ave-Geidi; Gribnau, Hans
The purpose of this contribution is to explore the possibility of integrating tax with corporate social responsibility (CSR). Some corporate directors seem to argue that they do not have a choice with regard to tax planning, implying that a responsible tax planning strategy is not an option. This
Lai, Tat-kei; Ng, Travis
High dividend income tax in the U.S. can impede state competition in the market for corporate charters. We offer a model to formalize the mechanism through which dividend tax lowers the incentives for a state legislator to refrain from enacting takeover regulations. We test a key driver within...... the model, that dividend tax exacerbates agency conﬂicts between management and shareholders, making takeover regulations less consequential to the corporations that have their shareholders subject to the tax. The implication, that under a dividend tax cut, ﬁrms governed by fewer anti-takeover provisions...
Full Text Available The Job Growth and Taxpayer Relief Reconciliation Act of 2003 lowered dividend taxes to the same rate as capital gains taxes in the United States using the Pecking Order Theory as a framework. This paper develops a model that examines the effect the tax cut will have on corporate investment. The model finds that the dividend rate tax cut will increase the corporate cost of capital and lower investment. Therefore, any increase in the value of the stock market from this act will simply be a response to an increase in after tax returns and not from an increase in production.
... 26 Internal Revenue 2 2010-04-01 2010-04-01 false Taxes of shareholder paid by corporation. 1.164...) INCOME TAX (CONTINUED) INCOME TAXES (CONTINUED) Itemized Deductions for Individuals and Corporations § 1.164-7 Taxes of shareholder paid by corporation. Banks and other corporations paying taxes assessed...
Dahlia Sari; Christine Tjen
This study aims to examine the influence of the corporate taxpayers’ level of CSR disclosure and environmental performance on the level of tax aggressiveness. This study took a sample of non-financial companies listed on the Indonesian Stock Exchange during 2009-2012. This study shows that the corporate taxpayers’ level of CSR disclosure has significant negative effect towards the tax aggressiveness. It means the higher the level of the CSR disclosure, the lower the company’s tax aggressivene...
Full Text Available The main goal of this article is to discuss the mutual economic relations between personal and corporate income taxes. The article consists of three parts. The first is an introduction to these taxes and taxation. The second is the analysis in which the objective of the taxation is discussed. This part represents the trends in research on taxation and clarifies the aspects of taxes that should be considered in an optimal tax system construction. These include solutions which stimulate taxpayer behavior, the economically and socially oriented objectives of taxation, and guides needed for tax equalization. The conclusions are focused on the tax rates in personal and corporate income tax and their influence on economic behavior of firms and individuals. The authors show different points of view on tax rate equalization and discuss its consequences.
Full Text Available Despite of the factthat European Union economy is the subject to integrationprocess, there has been no harmonization of corporate income taxation. Nocompulsion to adapt to common tax law requirements makes that many,especially new member states of EU, tends to use corporate income tax to attractcapital flows. The tax competition often takes a form of so called “race to thebottom” and consists in reducing tax rates. At the same time fiscal authoritiesusually broaden their tax bases in favor to increase the neutrality of the corporateincome tax.The main goal of this article is to measure the combined effect ofreducing statutory tax rates and broadening of tax bases in selected MemberStates.
Telnova Hanna V.
Full Text Available The aim of the article is to reveal the relationship between the rates of corporate tax and personal income tax and the pace of economic development. The existence of the open financial market under conditions of globalization leaves its imprint on forming the vectors of development of the tax systems in the countries. Thus, the optimal corporate taxation creates a competitive and investment-attractive climate, facilitates encouraging foreign investments and locating economic activities. The study made it possible to establish the absence of a direct link between the tax rates and economic growth. At the same time, a linear relationship between the tax rates and the tax burden is revealed. On the basis of the presented mathematical expression, it can be concluded that an increase in the personal income tax causes an increase in the tax burden, and an increase in the corporate tax — its reduction. The cluster analysis of the corporate tax and the personal income tax in European countries allowed to justify the determinants of successful economic development presenting the formation of the vector of the tax policy in the aspect of moderate taxation of individuals and the need for low taxation of corporate profits.
Full Text Available This study aims to examine the influence of the corporate taxpayers’ level of CSR disclosure and environmental performance on the level of tax aggressiveness. This study took a sample of non-financial companies listed on the Indonesian Stock Exchange during 2009-2012. This study shows that the corporate taxpayers’ level of CSR disclosure has significant negative effect towards the tax aggressiveness. It means the higher the level of the CSR disclosure, the lower the company’s tax aggressiveness. This study also proves that good environmental performance will strengthen the negative effect of CSR disclosure on tax aggressiveness. The assessment of environmental performance is conducted by the Ministry of Environment as independent party. It means that the higher the score of company’s environmental performance, the higher the commitment to pay taxes. This study supports the view that more socially responsible corporations are likely to be less tax aggressive.
Antônio Paulo Machado Gomes
Full Text Available This article aimed to investigate whether corporate governance uses tax management to increase companies' performance. The objective was checking whether corporate governance characteristics, such as remuneration paid to the executive board, segregation between Chairman and CEO, and the independence and composition of the Board of Directors, influence tax management in Brazilian companies. At the same time, it aimed to identify whether the preceding tax management is reflected on the subsequent tax management. To do this, a sample of 355 Brazilian companies listed on the BM&FBOVESPA between 2008 and 2014 was used, in order to find out whether their corporate governance characteristics influenced tax management, something identified by calculating ETR, CashETR, and BTD. As a result, it was found (i that the remuneration paid to executives may be regarded as a characteristic influencing tax management in Brazilian firms, and (ii that the preceding tax management influences the future tax management. In addition, it was found that Brazilian companies do not rule out tax management benefits, since the average effective rate in the sample under analysis was 25%, and it is statistically lower than the nominal rate of taxes on earnings in Brazil, which is 34%.
Accepted version of an article in the journal: Energy Economics. Published version available on Science Direct: http://dx.doi.org/10.1016/j.eneco.2009.10.009 In addition to the ordinary corporate income tax, special purpose taxes are sometimes levied to extract abnormal profits arising from the use of natural resources. Such dual tax regimes exist in Norway for oil and hydropower, where the corresponding special purpose tax bases are unaffected by any derivatives payments. Dual tax firms w...
Full Text Available t This paper is focused on impact of corporate tax on wages and the number of employees. Since the main goal of businesses is profit and because wages are part of the costs it’s important to understand if businesses try to cut costs by reducing wages or through reducing the number of employees. In this paper, through the analysis is intend to understand whether there is a relation between changes in corporate tax rates, the growth rate of state revenues from corporate tax with the growth rate of wages. To achieve the purpose of this paper it will also be analyzed the relation between growth rates of corporate tax with the growth rate of employment. To reach the conclusion is analyzed the progress of wages, the progress rates of corporate tax and is presented a brief overview of the economy in general because the rate of its growth will affect businesses operating there and will affect all public because a part of them is employed in the private sector. By data analysis in this paper does not seem to pass the burden of corporate tax on employees through salary or number of employees.
MacKie-Mason, Jeffrey K
This paper provides clear evidence of substantial tax effects on the choice between issuing debt or equity; most studies fail to find significant effects. The relationship between tax shields and debt policy is clarified. Other papers miss the fact that most tax shields have a negligible effect on the marginal tax rate for most firms. New predictions are strongly supported by an empirical analysis; the method is to study incremental financing decisions using discrete choice analysis. Previous...
Sari, Dewi Kartika; Utama, Sidharta; Rossieta, Hilda
This study aims to investigate the relationship between tax avoidance, related party transactions and the corporate dividend policy. Furthermore, this study will also investigate the moderating effects of the implementation of Corporate Governance (CG) on the relationship between tax avoidance, Related Party Transactions (RPT) and corporate dividend policies. Our sample covers companies listed on the Indonesian Stock Exchange during 2011-2014. The results provide moderate support for the prop...
Full Text Available Canada is losing its appeal as a destination for business investment. Its ability to compete against other countries for investment slipped considerably this year in our global tax competitiveness ranking, down six spots among OECD countries, and down 11 spots among the 90 countries. While many governments around the world responded to the fallout of the global recession by significantly reducing corporate tax rates, certain policy moves in Canada have us headed in the opposite direction. Canada is in danger of repelling business investment, which can only worsen current economic and fiscal challenges. Canada’s fading advantage is the result of recent anti-competitive provincial tax policies that increased the cost of investment. This includes, most notably, British Columbia’s decision to reverse the harmonization of its provincial sales tax with the federal GST, as well as recent corporate income tax rate hikes in B.C. and New Brunswick. When economic calamity strikes, and workers and their families feel the pain of lost jobs and lost wealth, politicians know they can score populist points by targeting the corporate sector. After all, corporations do not vote and they do not have a human face. News stories about major multinational corporations using tax-avoidance techniques to minimize their tax bills, only feed the populism, leaving voters believing that companies are getting away without paying a “fair share” of taxes. But when the corporate sector is targeted, it is not only supposedly wealthy capitalists who pay, but also employees, through lost wages and jobs, and working-class people who have a stake in companies through pension plans and mutual funds. On a larger scale, it is the economy that suffers. The same profit-maximizing imperative that leads companies to seek ways to reduce their tax liabilities also motivates firms to redirect investment to competing, lower-tax jurisdictions. Populist policies aimed at squeezing
Vivi Adeyani Tandean
Full Text Available This study aims to examine empirically the effect of the application of GCG and the size of the company on tax avoidance. This study was performed on companies listed on the Stock Exchange 2010-2013. Variables used are institutional ownership, the independence of auditors, the audit committee, and the size of the company as an independent variable and tax avoidance as the dependent variable. The research sample 84 manufacturing companies. The sampling technique using judgment sampling. Testing data using multiple regression analysis. The test results showed that only affects the audit committee on tax avoidance. Keywords: Corporate governance, size, tax avoidance
Elena K. Vorobei
Full Text Available The article is focused on the issues of efficient use of different methods of tax accounting for the optimization of income tax expenses and their consolidation in corporate accounting policy. The article makes reasoned conclusions, concerning optimal selection of depreciation methods for tax and bookkeeping accounting and their consolidation in corporate accounting policy and consolidation of optimal methods of cost recovery in production, considering business environment. The impact of the selected methods on corporate income tax rates and corporate property tax rates was traced and tax recovery was estimated.
Full Text Available Although globalization has contributed immensely to growth and prosperity around the world, it is a growing challenge for tax policy makers. Globalization and greater mobility of tax bases increase the relative importance of taxes in corporations’ investment decisions. The combination of highly mobile capital, inadequacies in existing tax laws and a total change of international business environment have led to the fundamental problem in international tax law labeled by the OECD as the problem of BEPS (Base Erosion and Profit Shifting, along with severe competition among countries to attract investments and business activities. These challenges are the topic for the 2014 seminar of the Nordic Tax Research Council. Based on the Nordic national reports we discuss these challenges
Beyer, B. (Bianca)
Abstract The purpose of this thesis is to find evidence about national-scale economic instability (especially reflected in the impacts of the financial crisis) being present also on a business level, namely in the form of corporate tax avoidance. A broad strand of literature copes with the topic of corporate tax avoidance. The research stems mostly from companies located in the United States. This thesis combines the approa...
Limberg, Stephen T.; Robison, John R.; Schadewald, Michael S.
In 1996, Brazil adopted a worldwide income tax system for corporations. This system represents a fundamental change in how the Brazílian government treats multinational transactions and the tax minimizing strategies relevant to businesses. In this article, we describe the conceptual basis for worldwide tax systems and the problem of double taxation that they create. Responses to double taxation by both the governments and the priva te sector are considered. Namely, the imperfect mechanisms de...
retains current corporate income tax as a withholding mechanism for payment of the shareholder level tax, as a measure to ensure compliance, and as a...the burden of the corporate income tax will fall only on retained earnings." The immediate result of this method is more cash in hands of the...would convert the corporate income tax into a withholding mechanism for an ultimate tax on corporate source income at the shareholder level.9 Professor
... tax imposed by section 531 may apply if the avoidance is accomplished through the formation or use of... 26 Internal Revenue 7 2010-04-01 2010-04-01 true Corporations subject to accumulated earnings tax... (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES (CONTINUED) Corporations Used to Avoid Income Tax on...
... governments, international organizations, foreign tax-exempt corporations, or foreign private foundations, see... 26 Internal Revenue 12 2010-04-01 2010-04-01 false Withholding of tax on foreign corporations. 1... (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Withholding of Tax on Nonresident Aliens and Foreign...
Full Text Available This contribution examines the issues of measurement of corporate income tax effectiveness in the circumstances of the Czech Republic, referred to as the tax on income of legal persons. The tax on income of legal persons represents a significant part of the public budget revenue, with the volume of collection of CZK 128,002 million in 2012. The theoretical basis for this contribution is the principle of tax system effectiveness, which is one of the principles characterizing a good tax system and is related to costs inherent in a tax system. The contribution defines two existing types of costs expended on the collection of taxes, i. e. administrative costs (direct or indirect and in theory describes excessive tax burden. In this contribution we shall focus on the measurement of direct administrative costs. The measurement of effectiveness of corporation income tax is performed with the use of the full-time equivalent (FTE method, which is based on the classification of revenue authorities’ staff according to their jobs and on the determination of conversion coefficients in order to identify costs related to the collection of a particular tax.A separate part of the article deals with measurement of administrative costs performed by the Organisation for Economic Co-operation and Development on the timeline ranging from year 2009 to 2011. The author of this article performed his own measurements concerning the direct administrative costs related to the collection of tax on income of legal persons in the Czech Republic. Results achieved in the respective monitored years are lower by the average (in the Czech Republic 2 percentage of ca 1.66 percentage points in relation to the average value of direct administrative costs of the Czech tax system.
Bill B. Francis
Full Text Available We investigate whether tax avoidance substitutes for external financing. We exploit interstate banking deregulation as a quasi-external shock to examine whether firms engage in less tax avoidance after banking deregulation, because of cheaper and easier access to credit from banks. We find no empirical evidence to support this substitutive relation, even for firms with higher financial constraints or firms with higher external financing dependence.
Galindo, Arturo; Melendez, Marcela
This paper uses a yearly dataset of plant-level investment in Colombian firms during the period 1997 to 2007 to assess the impact of a tax incentive for firms that invest in fixed assets implemented in 2004. A positive and statistically significant correlation is found between the boom observed in investment and the adoption of the tax policy. However, the correlation vanishes when year-specific effects are controlled for. This result is robust to changes in the empirical specification, chang...
Full Text Available Raising taxes can come at a serious cost. Not just to the taxpayer, of course, but to the economy. Every tax hike naturally leads people or companies to reallocate resources in ways that are less productive, resulting in a loss of income-generating opportunities. At a certain point, raising taxes becomes manifestly counterproductive, with the revenue lost due to the negative economic effects outweighing any tax gains. In cases like that, a government would actually raise more money by lowering taxes, broadening the tax base, than it does by increasing taxes. In fact, an analysis of the tax-base elasticities of the provinces, using data from 1972 to 2010, reveals that this very phenomenon is what occurred in Saskatchewan, which raised corporate taxes to a point where it began to backfire, sabotaging the government’s goal of raising more revenue. It also occurred in New Brunswick, Newfoundland and Labrador, P.E.I., and Nova Scotia. In all these provinces, tax increases on corporate earnings actually ended up yielding less for the provinces than the provincial governments would have collected had they instead lowered corporate income taxes. In five other provinces, governments undermined their own provincial economies over the same period, raising corporate taxes when they would have been better off actually cutting the corporate income tax, and making up the difference with a revenue-neutral sales tax. Alberta, Ontario, British Columbia, Manitoba and Quebec all paid dearly for the decision to hit corporations with higher taxes, by sacrificing what could have been significant welfare gains had they sought to raise the same amount of revenue through higher sales taxes (or in the case of Alberta, a new sales tax. Quebec, at least, has lower tax-base elasticity than the others, however, possibly due to its unique cultural and linguistic characteristics, which may make it somewhat less likely for people and investors to leave the province. The
textabstractHow countries tax the profits of multinational enterprises has become hopelessly outdated. The recent OECD/G20 Base Erosion and Profit Shifting Project has left the existing international corporate taxation framework essentially intact. Perhaps it is time to consider a truly fundamental reform of corporate tax systems, i.e. Corporate Tax 2.0.
... 26 Internal Revenue 13 2010-04-01 2010-04-01 false Required use of magnetic media for corporate income tax returns. 1.6011-5 Section 1.6011-5 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Tax Returns Or Statements § 1.6011-5 Required use of magnetic media for corporate incom...
Pulido, Matilde; Barros, Victor
The aim of this paper is to study the longstanding relationship between corporate tax avoidance and ex ante equity cost of capital in Europe, taking into consideration country specific characteristics, which are essential in a context of corporate tax competition. We find that investors apprehend tax avoidance differently at distinct levels of tax avoidance. We provide strong evidence that as low tax avoidance firms engage in greater tax avoidance, the ex ante equity cost of capital decreases...
... DEPARTMENT OF TRANSPORTATION Surface Transportation Board [Docket No. FD 35398] BDB Company--Acquisition Exemption--Consolidated Rail Corporation BDB Company (BDB), a noncarrier, has filed a verified notice of exemption under 49 CFR 1150.31 to acquire from Consolidated Rail Corporation a parcel of land...
Dewi Kartika Sari
Full Text Available This study aims to investigate the relationship between tax avoidance, related party transactions and the corporate dividend policy. Furthermore, this study will also investigate the moderating effects of the implementation of Corporate Governance (CG on the relationship between tax avoidance, Related Party Transactions (RPT and corporate dividend policies. Our sample covers companies listed on the Indonesian Stock Exchange during 2011-2014. The results provide moderate support for the proposed hypotheses. First, the greater tax avoidance that a company makes will increase the size of the firm's RPT. Second, the higher that the company's RPT is, this will lower the company's cash dividend payout rate. Third, the greater the tax avoidance is, the lower the company's cash dividend payout rate will be, which is done through a related party transaction.Fourth, the impact of the implementation of strong CG will weaken the positive relationship between corporate tax avoidance and the company’s RPT size, strengthen the negative relationship between the RPT’s size and the cash dividend payout policy of the firm, and strengthen the negative relationship between the company’s tax avoidance and the company's cash dividend payout policy which is mediated by the company’s RPT. This study makes three contributions. First, this study shows an indirect relationship between tax avoidance and cash dividend payments, mediated by RPT. Second, this study tries to examine the effect of CG’s moderation on the relationship between tax avoidance and RPT, as well as the effect of CG’s moderation on the relationship between tax avoidance and cash dividend payments, mediated by RPT. Third, this study developed RPT measurements by looking at the RPT’s components more specifically (looking at components of transactions outside of the main business of the company - the "others" component.
Full Text Available This study aimed to examine the effect of good corporate Governance against tax avoidance peroxided by the book tax gap and corporate governance is peroxided by institutional ownership, managerial ownership, independent board, audit committee and audit quality. This study was performed on companies listed on the Stock Exchange on the observation period 2011-2014. The method used is purposive sampling and obtained a sample of 10 companies. The data used is secondary data that can be downloaded through www.idx.co.id and www.sahamok.com. The results showed that the variables of the board of managerial ownership, independent directors, audit committee, and audit quality effect on tax avoidance while institutional ownership variable has no effect on tax avoidance. It is suspected that institutional ownership as a monitoring tool in any decision taken by the manager does not support an optimal oversight of management performance related to tax evasion.DOI: 10.15408/etk.v15i2.3541
Alan J. Auerbach
This paper reviews recent empirical research studying the impact of the U.S. corporate income tax on the behavior of firms. Four areas are discussed:(1) The extent to which dividend taxation imposes a "double tax" on corporate source earnings;(2) The historical impact of tax incentives on the incentives to investand the value of corporate equity;(3) The effects of limited loss offset provisions on the incentives to invest in risky assets; and(4) The determinants of corporate leverage.
Full Text Available The Taiwanese government offers firms that invest in qualified projects in emerging high-tech industries two mutually exclusive tax incentives—a corporate 5-year tax exemption or shareholder investment tax credits. This study examines whether corporate managers take shareholder tax benefits into account in their corporate tax planning. The results show that privately held firms are more likely than listed firms to choose shareholder investment tax credits and forego corporate tax benefits. Listed firms with relatively high earnings response coefficients tend to choose a corporate 5-year tax exemption, as it can enhance reported after-tax earnings. Further, in the 5-year period following their choice of a particular tax incentive, firms choosing a corporate 5-year tax exemption exhibit significantly lower earnings persistence than those choosing shareholder investment tax credits. Taken together, these results suggest that stock market pressure has a significant effect on firms’ choices between corporate and shareholder tax benefits, and that the choice of tax incentives has an effect on future earnings quality.
Full Text Available The economic phenomena and process like the market evolution, the inflation and globalization have also triggered in accountancy the evolution from historical cost system to current cost. The corporal immobilization reassessment at the level of current cost must represent the real motivation to contribute to a truthful image of the patrimony and not a method of depreciating tax costs of economic operators.
Reilly, Robert F
The double taxation of C corporation income from operations and from the ultimate sale of its assets makes the C corporation an inefficient tax status for many health care entities. At the time of this writing, the changes in the federal tax law that are scheduled to take effect in 2013 will increase this level of double-taxation inefficiency. The owners of a C corporation practice can avoid the C corporation status tax inefficiency by converting the practice to either (1) S corporation status or (2) LLC status. The conversion of the health care C corporation to an S corporation may be accomplished without a current tax cost. However, the conversion of a health care C corporation to an LLC status can result in a current tax at both the corporation level and the shareholder level. Nonetheless, the current conversion tax cost may be less than the future tax cost (1) of operating the practice as a C corporation and incurring double taxation at what may be higher tax rates or (2) of incurring the higher tax cost (or reduced price) on the ultimate disposition of the practice assets and the attendant double taxation of the appreciation in the value of the practice assets. Since individual income tax rates on qualifying dividends from C corporations and on capital gains are currently at very low rates, this may be a good time for C corporation practice owners to consider the costs and benefits of a conversion to either S corporation status or LLC status. The practice owners should consult with their accounting, legal, and valuation advisors in order to consider all of the costs and benefits of a possible corporate tax status conversion. An estimation of both the costs and benefits of the corporate tax status conversion depends on the concluded fair market values of the medical practice, dental practice, or other health care entity assets. And, that practice asset appraisal should encompass all of the practice assets, both tangible assets and intangible assets.
Full Text Available This communiqué is based on the following paper: The Costliest Tax of All: Raising Revenue Through Corporate Tax Hikes can be Counter-Productive for the Provinces by Ergete Ferede and Bev Dahlby.
..., including any minority interests owned directly or indirectly by such shareholder in second-tier and third-tier corporations in the chain. A United States shareholder may elect to consolidate his interest in... corporation which ends in or with the subsequent taxable year of such shareholder, the shareholder's interest...
Jack M. Mintz
Full Text Available When a major corporation is found to be paying little or no taxes, public backlash and media furor over the issue may ensue. Some governments may well be just fine with it, while others like U.S. may take steps to ensure companies pay more tax. Sometimes, companies being in a non-taxpaying position properly reflects appropriate tax policy. That explanation, however, does not sell lattés, which is why in 2012, after the British public grew outraged over the discovery that Starbucks was paying no corporate taxes in the U.K., the coffee retailer actually volunteered to just write a cheque to the government. The reputational damage to Starbucks’ brand, the company calculated, was not worth the money it was saving in avoiding taxes, even if it was doing so perfectly legally. The fear of this kind of reputational damage can foil the very taxation policies that governments design specifically as a means to tax corporations fairly, efficiently and competitively. It may be good tax policy to allow corporations various deductions, or the ability to carry forward or carry back losses, but it can be politically vexatious. U.S. President Barack Obama demonstrated that explicitly when he suggested certain American companies using so-called tax inversions to relocate their headquarters to low-tax jurisdictions, were failing in their “economic patriotism.” Yet more multinationals than ever are legally and quite appropriately using tax strategies to minimize their taxes in various jurisdictions to the point where they are paying little to no corporate tax. For some corporations, the risk of public backlash is greater than it is for others: Starbucks and Facebook, being consumer-facing companies with a great deal of brand goodwill, have a lot more at risk than do Pfizer and Oracle. This risk makes the playing field for taxation less level, jeopardizing the fundamental tax principle of horizontal equity — that those of similar means should pay similar
Full Text Available The introduction of various tax expenditures by the tax authorities, mostly in corporate income taxation (CIT, in order to kick start development in areas affected by the war as well as in economically underdeveloped areas has been characteristic of the Croatian tax system since 2000. Although the purpose of such forms of state aid was to foster economic development and equalize the level over the entire country, at the same time they caused forgone tax revenues and it is therefore necessary to analyze their advantages and disadvantages and evaluate their possible positive or negative effects. This paper deals with the analysis of tax expenditures in the system of CIT in Croatia and it investigates their effect on the budget and the possible advantages brought by their introduction. The main purpose of the paper is to answer the questions as to whether the expenditures that have been introduced in CIT justify their purpose and the goal of their introduction and what can be done to improve the existing CIT expenditures system.
Richard M. Bird
Full Text Available Corporate tax reform has long been a contentious issue in Canada. Official commissions, academics and others have often proposed changes in the way we tax corporations. During the last 30 years, perhaps largely owing to concerns about international competitiveness, the corporate tax rate has been substantially reduced. Since revenues did not decline as a result, those concerned by increased inequality who believe that corporate taxes are paid mainly by the rich have suggested that corporate rates should be increased. Others, more persuaded by the increasing evidence that much of the burden of the corporate tax ultimately falls on workers and wages and that even to the extent it falls on capital the economic price paid in terms of reduced output and productivity for each corporate tax dollar collected is high have taken the opposite tack and argued that, if anything, corporate tax reform should be aimed at reducing even further the effective tax rate on corporate capital. Both the technical and the political aspects of corporate taxation are thus at play in the current discussion of possible corporate tax reform. After a brief review of the history, we consider what is now known about the relation between corporate rates and revenue, the surprisingly complex question of who ultimately pays the tax, and the largely undesirable economic effects of corporate income taxes. If all voters were economists and familiar with the evidence, it is unlikely any would favour big increases in corporate taxes. However, even economists who have read all the studies mentioned here (and more do not agree about the best way to reform the corporate income tax. We sketch three recent major reform proposals Canadian experts have recently put forward (1 replace the existing corporate tax by a tax on ‘rents’ (above-normal returns on capital, (2 replace both it and the current personal income tax by a ‘dual income tax’ with a flat rate on all capital income
Jallai, Ave-Geidi; Peeters, Bruno; Gribnau, Hans; Badisco, Jo
This contribution discusses the tax planning behaviour of big corporations and investigates Corporate Social Responsibility (CSR) as a tool to battle the issue. It will be argued that certain legal tax planning strategies of multinationals are not acceptable to local communities and the public in
Full Text Available As a developing country that accumulates its source of revenue to taxes, Indonesia is not spared from tax compliance issues. The low level of tax compliance indicates a different point of view between the government and the Taxpayer. The low level of tax compliance indicates a different point of view between the government and the Taxpayer. Taxpayers still consider the obligation to pay taxes as an expense that can reduce their income or profits. Therefore, the rational Taxpayer will try to minimize the tax burden. One of them is by doing Tax Evasion. Taxation management is more often done by the Taxpayer Agency, especially the Manufacturing company. This is because the company has a very high business risk. Tax Evasion can increase organizational complexity which in turn can reduce financial transparency. Therefore, companies are required to disclose more information and provide flexible reporting systems that facilitate stakeholders. This encourages companies in the world to take advantage of the development of information technology and interconnection networking through internet corporate reporting. Utilization of internet corporate reporting is expected to increase the value of the company. This study aims to analyze the relationship between the concept of Tax Evasion, the level of internet corporate reporting disclosure, and the firm value. The results showed that the three hypotheses in this study were accepted. Tax Evasion affects the level of internet corporate reporting disclosure. In addition, Tax Evasion also directly or indirectly influence the firm value through the level disclosure of internet corporate reporting.
Full Text Available Within the framework of micro-backward looking methodology, the paper computes the effective corporate income tax rate for Bucharest Stock Exchange non-financial companies for 2000 - 2009 period, using data from companies financial reports. We find that effective tax rate computed as profit tax/pre-tax income ratio was below the statutory tax rate, throughout the period, except for the year 2009 (when an alternative minimum tax was introduced and the differences have diminished since the flat tax was adopted (2005. When applying a correlation analysis, we find that the difference between this effective tax rate and the statutory tax rate presents a strong negative correlation with the return on assets ratio (ROA. Also, we have find that commerce is enjoying the most favourable tax regime, while energy is the most heavily taxed.
In the presence of international-capital mobility foreign direct investment is influenced by corporate income taxation and the rules how taxes paid in the host country are treated at home. In this paper the exemption, credit and deduction method are considered as tax rules. First, it is shown that under the exemption method there exist tax rate combinations that lead to a reversal of capital flows compared to a free-trade situation. Second, the decision on the tax rule and the corporate tax r...
Sedmak, M. R.
The effects of the provisions of the existing corporate and personal income tax codes on solar investment decisions are analyzed. It is shown that the provisions of a tax code do not discriminate against investment in solar technologies if the present value of depreciation and interest expense tax deductions over the relevant decision period is equal to the present value of actual capital expenses. However, on the basis of a quantitative analyses, it is concluded that the existing corporate income tax code does discriminate against solar investments for the majority of corporations, although the 25 percent tax credit available to businesses for solar investments is sufficient to alleviate the distortion in most cases. In contrast, the provisions of the existing personal income tax code favor solar investments over investments in less capital intensive energy generating units, as the interest paid on loads used to finance solar investments made by individuals is tax deductible, while conventional fuel expenses are not deductible.
The primary aims of this study are to identify whether there is any relationship between corporate tax avoidance and the cost of debt, and whether the level of institutional ownership moderates this relationship, with two hypotheses tests on sample of 110 listed firms in the main board of Bursa Malaysia during the year 2005 - 2009. This study supports prior papers with negative relationship between tax avoidance and the cost of debt, suggesting corporate tax avoidance activity can reduce the ...
Dahlia Sari; Christine Tjen
This study aims to examine the influence of the corporate taxpayers’ level of CSR disclosure and environmental performance on the level of tax aggressiveness. This study took a sample of non-financial companies listed on the Indonesian Stock Exchange during 2009-2012. This study shows that the corporate taxpayers’ level of CSR disclosure has significant negative effect towards the tax aggressiveness. It means the higher the level of the CSR disclosure, the lower the company’s tax aggressivene...
Riedel, Nadine; Fuest, Clemens; Maffini, Giorgia
Using a rich panel data base for firms in Asian countries, we assess the effect of public sector corruption on corporate assets investment and tax payments. Our findings suggest that public sector corruption does not deter investment activities of national firms while asset investment of multinational corporations is significantly reduced in corrupt environments. Moreover, the findings indicate that corruption exerts a quantitatively large negative effect on corporate tax payments, especially...
... taxes” means income, war profits, and excess profits taxes, and taxes included in the term “income, war... a foreign corporation for any taxable year shall be determined after reduction by any income, war... amounts so determined into United States dollars or other foreign currency shall be made at the proper...
Taxpayers have to plan their tax affairs to plan their life or develop their business strategy. Often tax planning is encouraged and intended by tax legislation, but sometimes it is not. By way of tax incentives the tax legislator often tries to steer citizens’ behaviour to achieve all kind of
National Education Association, Washington, DC. Research Div.
This report describes a study aimed to help education advocates protect public schools and services from the effects of certain types of economic development subsidies. These subsidies include cutting companies' property taxes and granting long-term diversions of certain districts' property taxes to corporations making investment in those…
The aim of this thesis is to research whether tax avoidance could be made illegal at an EU level and if so to what extent. The thesis will cover the main tax avoidance strategies and take a closer look at what measures EU has taken in the field of combatting tax avoidance. Corporate tax avoidance is a heavily debated topic with increasing importance. The difficulty with tax avoidance is that the line between when tax avoidance is unacceptable and when it is acceptable is very subjective. ...
Full Text Available The purpose of the article is to determine the trends of the functioning of the corporate income tax in the system of state revenue, assess its tax transformations, and determine the tax efficiency. On that basis, determining prospects of income tax in the national system of business entities taxation and developing proposals for improving the mechanism of taxation in Ukraine. Methodology. The theoretical and methodological base of scientific research of national and foreign scholars on the analysis of corporate income tax, official statistical data of the Ministry of Finance of Ukraine and State Fiscal Service of Ukraine. To ensure the authenticity and validity of the research results to the goal, the following methods are used: induction and deduction – during theoretical generalizations and conclusions; analogy method – when comparing the foreign experience of administration of corporate income tax; economics and statistics as methods of the macroeconomic situation of Ukraine analysing. Results. In the article, the corporate income tax is investigated. The macroeconomic situation in Ukraine is analysed. Reasonable steps for the further use of the European countries experience for Ukraine are founded. Practical implications. The results of this study can be used by state authorities in developing tax policy directions in Ukraine. Value/originality of the results is a complex theoretical and practical analysis of the corporate income tax in Ukraine. Further research should relate to the improvement of its own system of income taxation. In the process of its implementation, it is necessary to use the experience of European countries.
The purpose of this study was to identify the common consequences experienced by school corporations when closing or consolidating schools. The primary focus of the study was to identify the financial and political consequences experienced by school corporations when closing a school closing or consolidating schools. Specific questions regarding…
... Mirror Corporation, a Subsidiary of Guardian Industries Corporation, Galax, VA; Notice of Negative... and Mirror Corporation, a Subsidiary of Guardian Industries Corporation, Galax, Virginia (subject firm... firm, stated that the Galax, Virginia facility is owned by ``Guardian Industries, a [[Page 19473...
Full Text Available Subject. The influence of internationalization of tax law on Russian tax law enforcement in the area of corporate taxation is considered in the article.The purpose of the paper is to analyze influence of internationalization of tax law on Russian tax law enforcement in the area of corporate taxation.Methodology. The author uses methods of theoretical analysis, particularly the theory of integrative legal consciousness, as well as legal methods, including formal legal method and methods of comparative law.Results, scope of application. The development of Russian tax legislation is influenced by acts of international organizations, primarily the Action Plan aimed at combating base erosion and profit shifting (BEPS.Trends of regulation of corporate taxation in relationships with participation of a foreign element are considered in the article. The main issues of realization of norms in the area of corporate direct taxation are brought into light, and namely, taxation of royalties, intra-group expenses, thin capitalization rules and transfer pricing. Tax agreements concluded by the Russian Federation do not contain special rules aimed at combating abuses (in contrast, for example, from European anti-avoidance rules.In recent years Russian tax law introduced institutions that had been established and applied in the tax law of foreign countries. These processes are moving forward and are characterized by frequent changes of legislation, which indicates that the concept of deoffshorization and implementation of the BEPS plan is not always elaborated at the stage of adoption of bills.Conclusions. The author comes to the conclusion that the most relevant and most controversial issues are taxation of payment of royalties, debt financing and intra-group expenses. The practice of applying the CFC rules is just starts forming. In addition, there is a tendency to increase the quality and quantity of information sources used by tax authorities to collect
Ю. С. Шорохова
Full Text Available This article analyzes the scientific literature on issues relating to the historical aspects of the origin and formation of the corporate income tax. It is proved that the foundations of the modern mechanism of this tax were laid in ancient times, and therefore aim was already filling the state budget.
Bartelsman, E.J.; Beetsma, R.M.W.J.
This paper presents suggestive evidence of income shifting in response to differences in corporate tax rates for a large selection of OECD countries. We use a new method to disentangle the income shifting effects from the effects of tax rates on real activity. Our baseline estimates suggest that a
... this section, registration shall in all events be required with respect to any interests in the... claimed to be proprietary or exclusive to the tax shelter promoter or any party other than the offeree. (2... any tax advisor (including a tax advisor independent from all other entities involved in the...
Muhammad Irham Kurniawan
Full Text Available This study aims to examine the effect of corporate tax avoidance to the corporate cash holdings. Recent tax avoidance research found that tax avoidance is able to facilitate managerial rent extraction in the form of transfer of resources owned by the company. This study attempts to test how the relationship of tax avoidance with the amount of cash held by the company. The sample consists of 46 non-financial, non-property, non-real estate and non-construction companies from 2009-2016, with a total 368 observations. The study uses two different cash holdings measures to test the robustness of the research results. This study cannot find evidence that tax avoidance have a significant relationship to the level of cash holdings in public companies in Indonesia. Both measurements of cash holdings gave the same conclusions to the results of the study. This study provides an insight that agency theory in the context of tax avoidance and corporate cash holdings in developing countries such as Indonesia needs to be explored further as the agency conflict in Indonesia as a developing country is more principal-principal conflicts.
... Trade Act corporations. 1.6072-3 Section 1.6072-3 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT... Documents § 1.6072-3 Income tax due dates postponed in case of China Trade Act corporations. (a) With... tax return of any corporation organized under the China Trade Act of 1922 (15 U.S.C. ch. 4), as...
... Tax Accounting Elections on Behalf of Foreign Corporations AGENCY: Internal Revenue Service (IRS... change a method of accounting or taxable year on behalf of a foreign corporation. The regulations affect... with respect to the proposed amendments under section 964, which would provide a special definition of...
Eric J. Bartelsman; Roel Beetsma
This paper presents suggestive evidence of income shifting in response to differences in corporate tax rates for a large selection of OECD countries. We use a new method to disentangle the income shifting effects from the effects of tax rates on real activity. Our baseline estimates suggest that a substantial share of the revenues from a unilateral increase in the corporate tax rate is lost because of a decline in reported income.This discussion paper has resulted in a publication in the Jour...
Full Text Available This study aims to examine the influence of the corporate taxpayers’ level of CSR disclosure and environmental performance on the level of tax aggressiveness. This study took a sample of non-financial companies listed on the Indonesian Stock Exchange during 2009-2012. This study shows that the corporate taxpayers’ level of CSR disclosure has significant negative effect towards the tax aggressiveness. It means the higher the level of the CSR disclosure, the lower the company’s tax aggressiveness. This study also proves that good environmental performance will strengthen the negative effect of CSR disclosure on tax aggressiveness. The assessment of environmental performance is conducted by the Ministry of Environment as independent party. It means that the higher the score of company’s environmental performance, the higher the commitment to pay taxes. This study supports the view that more socially responsible corporations are likely to be less tax aggressive. Keywords: Corporate Social Responsibility Disclosure, Environmental Performance, Tax Aggressiveness
Full Text Available The paper addresses the problems of corporate taxation in a globalized world. It first considers recent trends in international practices and then reviews the literature on the effects of corporate taxes in closed and open economies. The paper emphasizes the severity of the problems caused by current international tax rules. It compares various national and international policy alternatives and considers two recent Nordic tax reform proposals as examples of national-level solutions. The problems of current international corporate taxation are fundamental. Introducing increasingly tight antiavoidance measures could serve as a medium-term approach but does not provide any promising long-term solution. There should be more research concerning initiatives that would reform the fundamental principles of the international tax system.
Full Text Available This paper empirically explores the effects of payroll taxes, value-added taxes and corporate income taxes on a variety of labor market outcomes such as participation, employment, informality, and wages. The results are based on nationallevel data of labor variables for 15 Latin American countries, and indicate that the effects of each tax are markedly different and may depend on several aspects of labor and tax institutions. Payroll taxes reduce employment and increase labor costs when their benefits are not valued by workers, but otherwise may increase labor participation and not raise labor costs. Value-added taxes increase informality and reduce skilled labor demand. In contrast, corporate income taxes may help reduce informality, especially among low education workers, but when tax enforcement capabilities are strong they may reduce labor participation and employment of medium- and high-education workers.
van de Streek, J.
The consolidation element is at the heart of the proposed Directive on a harmonized Common Consolidated Corporate Tax Base (CCCTB). In this article, the author examines the scope of the consolidation concept. When a company enters a consolidated group, conflicts of interest arise between Member
STĂNCULESCU SIMONA MARILENA
Full Text Available t The tax accounting system in Romania suffers many changes from one year to another. We assume that these changes occur in order to have a positive impact on the Romanian economy. One of the most important taxes collected by the state is the corporate tax. In this paper we aim to show the impact of the corporate tax on the economic development of Romania. We selected the period between 2003 and 2015. We provide an argument for the selection of the indicators which describe the economic development. For the period analyzed we described the changes in the regulations regarding the income tax, the impact on the economic development (assessed in terms of foreign direct investment and the correlation between the two.
Kenneth J. McKenzie
Full Text Available Who bears the burden, or incidence, of the corporate income tax (CIT? This is an important, if not somewhat contentious, policy issue. In this paper we provide a discussion of the existing research on the question, viewing it through a Canadian policy lens. We also use some new results from a companion technical paper, which undertakes one of the few empirical investigations of the issue using Canadian data, to discuss the implications of increases in corporate taxes for wages in Canadian provinces. While it is clear that people, not corporate entities, ultimately bear the burden of corporate taxes, a key question is which people? The answer to this question has important implications for the equity, or fairness, of the tax system. Much of the recent focus in policy discussions concerns the allocation of the burden of the CIT between owners of capital and labour. Since income from capital tends to be concentrated with wealthier individuals, if the burden of the CIT falls mostly on the owners of capital, it increases the progressivity of the tax system. On the other hand, if the tax is borne mostly by labour through lower wages, the CIT is less progressive. Much of the research into the incidence of the CIT has employed theoretical simulation models. Early models of this type, which were based on a closed economy with fixed supplies of labour and capital, suggested that most of the burden of the CIT would be borne by the owners of capital throughout the economy, and not just the shareholders of firms in the corporate sector. Subsequent extensions of those models into a small open economy setting, where capital and goods are highly mobile between jurisdictions (countries, provinces, predict that most of the burden of the CIT will be borne by other inputs that are relatively inelastic in supply, such as labour. These small open economy models are particularly relevant for Canada. Viewing the results of these models through a Canadian lens, we
Brian J. Arnold
Full Text Available Aggressive international tax planning by multinational corporations has lately fallen under intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid American taxes. More recently, politicians accused Burger King of being unpatriotic for its own purported “tax inversion” maneuver, in which it would acquire Canada’s Tim Hortons and shift the head office from Florida to Ontario, benefitting from the lower northern tax rates. The Chicago-based Walgreens pharmacy chain recently backed off a “tax inversion” plan to relocate to Switzerland (the former headquarters of Alliance Boots, a company acquired by Walgreens, apparently having assessed the political risk as too high. This sort of aggressive international tax planning by multinational corporations was what G20 members had committed to fighting against when they endorsed the OECD’s “action plan” against base erosion and profit shifting (BEPS. Canada has been vigilant about improving its tax framework to prevent non-resident corporations from eroding the Canadian tax base, having enacted thin-capitalization rules and, more recently, foreign-affiliate-dumping rules, as well as proposing anti-treaty-shopping measures. But despite Canada’s commitment to the OECD’s BEPS Action Plan, the Canadian government has been reluctant to follow through on implementing rules that might affect its own resident corporations and their international competitiveness. This is most notably visible in the generous participation exemption for dividends from foreign affiliates, the absence of rules restricting the deductibility of interest expenses incurred to earn exempt dividends from foreign affiliates. Canada may be reluctant to fully follow through on all aspects of the OECD’s BEPS Action Plan. As the examples of Apple, Amazon, Google and Starbucks demonstrate, the American
Ricardo Vinícius Dias Jordão
Full Text Available The objective of this paper was to investigate the use of corporate restructuring (CR practices as a tax management (TM strategy in Minas Gerais industrial companies. The research was carried out by means of a four comparative case study of qualitative and explanatory approach in industrial companies of Minas Gerais. Based on finance, accounting and taxes theories, it was concluded that the companies investigated have made CR processes, adopting corporate models different from those defined in its original organizational plans, doing it in a planned way aligned with the business strategy. It was possible to conclude that the tax planning consists of (i a means to reduce tax costs lawfully. It helps to maximize business performance, increasing competitiveness and sustainability thereof, and (ii consists in an important basis for the development of tax governance by adopting mechanisms to ensure compliance and promote the avoidance of taxes. Overall, it was found that (iii the effectiveness of these processes depends on a careful analysis of financial, legal, economic, financial, organizational and managerial aspects, and even if the tax planning through the CR (iv promoting the reduction, postponement and/or the elimination of tax costs, (v collaborating to increase in the TM efficiency and in the profits, (vi increasing thereby the value generation.
Full Text Available This research aims to study the market response to the aggressiveness of financial reporting and tax reporting conducted by the company. Investor’s response is reflected in the market value of the company's stock. This study is an explanatory research using quantitative approach. Research’s sample is a manufacturing company listed on the Indonesian stock exchanges from 2005 to 2015. The data were analyzed using multiple regression analysis. The data show that majority of sample companies’ fall into the category of middle tax aggressiveness. Research’s findings are both aggressive financial reporting and tax aggressiveness has a negative relationship with the market value of the company. However, only aggressive financial reporting that has a significant influence on the firm value. Based on these results it is concluded that tax aggressiveness does not directly affect the market in making decisions to assess the company's stock.
The current debate in corporate taxation is focusing on leveling the tax playing field within the European Union for companies operating across-countries. However, tax burdens could also vary with the size of companies within the same country, raising the question whether large companies pay their share of the burden. This paper uses firm-level data for 21 European countries between 1992 and 2004. The paper finds a robust negative correlation between the number of employees and the effective ...
Hietala, Harri; Kari, Seppo
This paper analyses the effects of the recent Finnish income tax reform on the behaviour of a closely held corporation (CHC) and its owners. The main elements of the reform are cuts in corporate and capital income tax rates and the replacement of the full imputation system by a partial double taxation of distributed profits. Considerable exemptions are applied to relieve the taxation of dividends from CHCs. The analysis indicates that the change in the CHC’s cost of capital depends on the mar...
Seppo Kari; Hietala; Harri
This paper analyses the effects of the recent Finnish income tax reform on the behaviour of a closely held corporation (CHC) and its owners. The main elements of the reform are cuts in corporate and capital income tax rates and the replacement of the current full imputation system by a partial double taxation of distributed profits. Considerable exemptions are applied to relieve the taxation of dividends from CHCs. The analysis indicates that the change in the CHC?s cost of capital depends on...
Grubert, Harry; Altshuler, Rosanne
Proposals for the reform of the taxation of cross-border income are evaluated within the general context of the corporate tax in an open economy. We focus on the various behavioral decisions that can be affected such as the location of income and its repatriation. The two income tax proposals considered are: (1) dividend exemption and (2) burden neutral worldwide taxation in which all foreign subsidiary income is included currently in the U.S. worldwide tax base, and at the same time the corp...
Schäfer, Anne; Spengel, Christoph
In this paper, an outline of the consequences of the increased use of ICT on international corporate taxation, namely on the tax attributes and the scope of taxation, is given. It is argued that the concept of capital export neutrality shall prevail, as it is deemed to be the most appropriate to the changed economic structure. With regard to the tax attributes in the source state, an enlargement of the notion of a permanent establishment in order to shift tax revenues to the source state is n...
... Tax Reform Act of 1969). (a) In general. The deduction by a corporation in any taxable year for... 26 Internal Revenue 3 2010-04-01 2010-04-01 false Contributions or gifts by corporations (before amendment by Tax Reform Act of 1969). 1.170-3 Section 1.170-3 Internal Revenue INTERNAL REVENUE SERVICE...
shareholders with long investment horizons because the tax cost saved from decreasing dividend payout ratios is an increasing function of shareholders’ investment horizon. The empirical tests support the hypothesis and show a negative relationship between the change in incremental tax costs and the change in dividend payout ratios for firms with long average investment horizons.
Tandean, Vivi Adeyani
Pemerintah mengharapkan wajib pajak membayar pajak sesuai kondisi sebenarnya sedangkan Perusahaanberusaha membayar pajak seminimal mungkin dengan melakukan manajemen pajak tanpa melanggar peraturan.Tuntutan bagi Perusahaan melakukan manajemen pajak yang harus diawasi menjadikan dibentuknya Corporategovernance. Penelitian ini bertujuan untuk menguji secara empiris pengaruh penerapan GCG dan ukuranperusahaan terhadap tax avoidance. Penelitian ini dilakukan pada Perusahaan manufaktur yang terdaf...
Full Text Available The paper deals with the problem of taxation and its potential impact on economic growth and presents some new empirical insights into this topic. The main aim of the paper is to verify an assumed nonlinear impact of corporate tax rates on economic growth. Based on the theory of public finance and taxation, we hypothesize that at relatively low tax rates it is possible that the impact of taxation on economic growth become slightly positive. On the other hand when the tax rates are higher a negative impact of taxation on economic growth could be expected. Despite the fact that the most of the existing studies find a negative linear relationship between these variables, we can also find strong support for a non-linear relationship from several theoretical models as well as some empirical studies. Based on panel data fixed-effects econometric models, we, as well, find empirical evidence for a non-linear relationship between nominal and effective corporate tax rates and economic growth. Our data consists of annual observations for the period 1999 to 2011 for EU Member States. Based on the results, we also estimated the optimal level of the corporate tax rate in terms of maximizing economic growth in the average of the EU countries.
Janský, Petr; Kokeš, O.
Roč. 27, č. 4 (2015), s. 537-546 ISSN 1463-1377 R&D Projects: GA TA ČR(CZ) TD020039; GA ČR GA15-24642S Institutional support: RVO:67985998 Keywords : corporate tax base erosion * Czech Republic * profit shifting Subject RIV: AH - Economics Impact factor: 0.548, year: 2015
S. Cnossen (Sijbren)
textabstractThis paper surveys and evaluates the corporation tax systems of the Member States of the European Union on the basis of a comprehensive taxonomy of actual and potential regimes, which have as their base either profits; profits, interest and royalties; or economic rents. The current
... 26 Internal Revenue 18 2010-04-01 2010-04-01 false Required use of magnetic media for corporate income tax returns. 301.6011-5 Section 301.6011-5 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) PROCEDURE AND ADMINISTRATION PROCEDURE AND ADMINISTRATION Information and Returns Returns and Records § 301.6011-5...
H. Schmittdiel (Heiner)
markdownabstract__Abstract__ In this paper, we test empirically whether there is a relationship between corporate income taxes and CEO bonus payments. Using Compustat and ExecuComp data from 1992 to 2010, we find mixed results. Looking at the whole sample, the average bonus contract rewards
Abrudan Leonard Calin
Full Text Available In this paper we will discuss about the implications of the corporate tax in the field of economical and social development. In the beginning we will present the results of the introduction of the new quota (16% as budgetary receipts and after that we wi
M.F. de Wilde (Maarten)
textabstractHow countries tax the profits of multinational enterprises has become hopelessly outdated. The recent OECD/G20 Base Erosion and Profit Shifting Project has left the existing international corporate taxation framework essentially intact. Perhaps it is time to consider a truly fundamental
Full Text Available Taxes are an integral part of human society, regardless of the economic, cultural and political disparities between the countries. Income taxes of legal entities represent significant part of the budget, what is the reason for their timeliness and public discussion. The aim of the paper is a classification of the EU countries into economic groups and an assessment of the grouping these EU member states based on common characteristics in the area of corporate income taxes. Common features are determined by the structure of selected macroeconomic indicators: public debt, government budget balance, the overall tax burden, economic performance, nominal and effective tax rate. The analysis compares a range of methodological approaches of hierarchical (Ward linkage and median linkage, and non‑hierarchical clustering (k-means clustering and fuzzy cluster analysis. The results of cluster analysis grouped the monitored countries into five clusters based on common characteristics as the corporate income tax rate, economics performance and the level of public debt. The result of the analysis shows that despite of ongoing there are still differences present, which are present in the ratios of countries’ development as well as in the economic policies of the particular countries.
Luciano Gomes dos Reis
Full Text Available The disclosure of tax incentives Culture is essential for external users to make full analysis of the benefits generated by them. In this sense, the aim of this study was to verify the consistency and form of disclosure of the information disclosed by the Corporation Publicly Traded in southern Brazil, from the perspective of reducing the tax burden and the amount allocated to the Culture. The sample consisted of 27 Corporate Capital Open in southern Brazil and analyzed its financial statements, accompanying notes and supplementary reports through pre-established keywords, characterizing the research as descriptive, with a qualitative approach. The results showed the importance of the Notes, the Management Report and additional reports as Social and Sustainability Report. These reports had relevant information and helpful research. However, many of them did not have clear information about the tax incentives for culture. Some companies released the tax incentive culture along with other incentives, such as the Workers Food Program - PAT, which did not allow detailed analysis of the data. We found cases of disagreement between the Ministry of Culture and information disclosed statements. In some cases, were observed lack of information about the tax incentives in the statements and supplementary reports. It was concluded that the disclosure is lower than necessary, because only four out of a total of twenty seven companies analyzed, reported consistent, complete and appropriate on tax incentives for culture.
Increasing knowledge of the climatological effects of CO 2 emissions have resulted in the concept of reducing energy consumption, and therefore also CO 2 emissions, by means of taxation. The concepts proposed for this are discussed in this article. It is shown that the concept of CO 2 energy taxes is based on a series of pseudo-plausibilities. The German gas industry's voluntary commitment is illustrated as the most suitable instrument for efficient reduction of CO 2 emissions. (orig.) [de
Full Text Available Society expects companies to take into account the economic, environmental, and social effects of their operations and activities. The concept of corporate social responsibility (CSR refers to the operations or actions of companies that are above or independent of the limits or minimum requirements set by legislation.
Kenneth J. McKenzie
Full Text Available Corporate income tax (CIT incidence is an important and contentious issue in tax policy discussions. Much of the focus in the recent literature and in policy discussions concerns the allocation of the burden of the CIT between owners of capital and labour. Since income from capital tends to be concentrated with wealthier individuals, if the burden of the CIT falls largely on capital it increases the tax system’s progressivity. On the other hand, if the tax is borne mostly by labour through lower wages, the CIT is less progressive. Despite the importance of this issue in policy discussions, empirical evidence is quite limited and the results are mixed; there is a particular dearth of empirical research on the incidence of corporate taxes in a Canadian setting. According to theoretical open economy general equilibrium models, the burden of the CIT may partly, and possibly largely, fall on labour. In these models, an increase in the CIT reduces the return to capital, causing capital to leave the jurisdiction, which lowers the marginal product of labour and ultimately wages. Thus, the CIT can have a negative indirect effect on wages through its impact on labour productivity by way of its impact on capital. However, the magnitude of this effect depends critically on several modelling assumptions and parameter values related to the size of the country, the degree of capital mobility, the nature of competition in the output market, etc. An emerging empirical literature investigates the effects of CIT on wages by way of this indirect transmission mechanism. Empirical studies in this vein include Hassett and Mathur (2006, 2015 for a cross-section of countries; Desai, Foley and Hines (2007 and Felix (2007, 2009 for the U.S. They all find evidence in support of the relevance of the indirect channel using national aggregate data. Other studies, such as Carroll (2009 and Felix (2009 for the U.S., examine corporate tax incidence at the subnational level
Full Text Available The article presents the taxation of the Corporate Income Tax of disposal of goods from deposit incorrect. The author indicates the moment of recognition of revenue from the operations of disposal of goods, which should be deferred until the completion of the possibilities of disposal of goods from deposit incorrect, when they are fixed costs of that income. Only at this point it will be possible to determine income.
Full Text Available This paper deals with researching negative consequences of allocation of economic (virtual gains made as a result of conventional accounting concept by facing current income with historical expenses and necessity to promote additional stimulating instruments that are at disposal by the state in order to eliminate these negative consequences. one of them is certainly protective interest as a relatively new active fiscal instrument of capital protection and recognition of price of invested owner's equity in business ventures, i.e. a specific form of compensation by the state for invested capital bearing in mind, that no source is free, including ones own sources. We also showed mechanisms of protective interest which, together with other measures of macroeconomic policy, should contribute to the protection of real purchasing power of company equity and increase of net gain, left on company's disposal for new investments, new work places, more money in the budget, protection of actual assets against taxing in the conditions of inflation, etc.
NewCo is the temporary name of the entity which combines all of the operations of AREVA related to the nuclear fuel cycle, whose legal name is New AREVA Holding. The NewCo capital increase reserved for the French State in the amount of 2.5 billion euro was completed on July 26, 2017. This operation resulted in AREVA SA's holding in NewCo's capital being reduced from 100% to 44.4% and, accordingly, led to the removal of the NewCo sub-group from the scope of the consolidated tax group initially created around AREVA SA. Consequently, and in order to establish the scope of the French tax consolidation group around NewCo from September 1, 2017, NewCo's Combined Shareholders' Meeting of July 27, 2017 resolved to temporarily modify the closing date of the fiscal year by setting an early closing of August 31, 2017 for the fiscal year opened January 1, 2017 (period lasting eight months), with a return to the closing date of 31 December as of the fiscal period starting September 1, 2017 (period lasting four months). In this context, NewCo has prepared the statutory and consolidated financial statements for the year opened January 1, 2017 and ended August 31, 2017. These financial statements were approved by NewCo's Board of Directors. At the closing on December 31, 2017, NewCo will draw up statutory and consolidated financial statements for the period from September 1, 2017 to December 31, 2017. Consolidated financial statements as of December 31, 2017 covering the full year 2017, i.e. a period of 12 months, will also be prepared on a voluntary basis. All the financial statements prepared by NewCo in respect of 2017 will be approved at a single General Meeting to be held in May 2018. A request to extend the deadline for the Annual Ordinary General Meeting called to approve NewCo's financial statements for the period ended August 31, 2017, will be made to the President of the Nanterre Commercial Court. NewCo's net income at August 31, 2017 was chiefly impacted, compared with
The first part of the paper presents the main causes for the divergence between the statutory and effective rate of the corporate income tax, based on the provisions of the Romanian Fiscal Code. The differences between the gross income and the taxable profit, which form the basis for calculating the income tax, are highlighted. The second part is devoted to the methodology for calculating the effective income tax rate and its analysis, based on data from the financial statements published in the post-crisis period by Romanian companies listed on BVB.
Full Text Available Withholding tax for non-resident taxpayers is a tax due to the Romanian state budget by taxpayers, the expense for the amount related to this tax playing a fiscal impact upon the fiscal result and, therefore, upon the corporate tax due within a fiscal period of time. Most of the times, in practice, a series of questions arise, such as: which is the entity having the obligation to compute and pay the tax, respectively the income payer or the one collecting it; is the transaction taxable from the point of view of the tax on non-resident taxpayers’ income, function of the nature and object of the transaction; which is the tax rate owed, in case the operation has a taxable feature; which is the fiscal treatment applicable in case of expenses incurred in the accounting records, with the amount of the tax owed on non-resident taxpayers income. Due to this reason, in practice there are several approaches which could generate fiscal risks, related to the fiscal treatment applicable in case of different types pf transactions concluded with non-resident tax payers, depending on the nature and scope of the respective transaction.
Full Text Available Depreciation and net results define the self-financing ability of an enterprise and any change in depreciations generates reverse effects upon a corporate tax. That is why the measurement and depreciation system of assets must be correlated with capital maintenance. In the event of depreciation, accounting policies may envisage the choice of one of the depreciation methods, for example straight-line, accelerated or degressive methods of depreciation. Choosing a method of depreciation involves an accounting option. The present article includes a comparative approach of depreciation methods and their implications upon the results and profit taxes, comprising own perspectives and opening new research prospects. The question can be “Which method is the best to use?”. The answer depends on enterprise objectives, on the “aggressiveness” used when it wants to approach fiscal management.
Marta de VICENTE LAMA
Full Text Available The consolidation perimeter of the public sector is the most important line between the micro and macro systems of government accounting. This paper focuses on the public sector boundary and assesses the potential impact on key reported figures – such as the ‘Maastricht’ deficit and debt ratios – that would result from moving public corporations inside the perimeter of the consolidated general government sector, public corporations that currently lie outside the general government sector. After examining 90 Spanish local governments with populations of over 50,000 during the 2010-2012 period, our results show that including public corporations within the general government sector perimeter leads to substantial differences in deficit and debt ratios, and that these differences significantly increase the number of municipalities in violation of fiscal limits imposed by the government. We also find that municipalities’ pre- and post-consolidation debt ratios are significantly different depending on the ruling party’s political ideology.
Szora Tamas Atila
Full Text Available The study is divided into four parts: in the introduction are presented the theoretical aspects of the consolidated financial statements and the consolidation methods. During the second part are shown the structure rates calculated prior and after the consolidation, and in the third are calculated the financial rates of return and the effective tax rates of fixed assets. The conclusion of this study presents that although the consolidated entity is not a tax, it presents the group effort without the internal flows between entities within the group. In terms of the world scientific research typology used by the authors, it refers to descriptive research, explanatory research and applied research. In terms of the novelties, brought by this study, it is specifically determined, based on the actual database, the evolution of structure indicators, indicators of balance, the financial profitability indicators of corporate companies prior to and after consolidation.
Would a specific tax regime that i) grants to companies formed under the European Company Statute the possibility to or ii) requires companies formed under the European Company Statute to establish the consolidated tax base for their EU wide activities according to one set of rules(either European or that of their ?home state?) and does not provide this possibility for companies which are run under a different legal form discriminate against these latter companies and/or provide state aid to ...
van de Streek, J.
Rules on exit taxation for the EU as a whole are under construction at European Council level. Formally, the work on this piece of EU tax legislation is part of the controversial Common Consolidated Corporate Tax Base (CCCTB). But it is also thinkable that even without a CCCTB being established in
Hansen, Rasmus Torpe
To this date, the tax-CSR-nexus has mainly been analysed through regression studies examining the global-level data of major multinational corporations and is currently not well documented in specific developing countries and regions. Based on the CSR disclosure and annual reports for the Sub-Saharan African subsidiaries of three major beverage companies, I analyse the connection between the companies’ CSR initiatives on the one side and their tax avoidance behaviour on the other. Globally, I...
Yussof, Salwa Hana
Tax expenditures are government indirect spending, hidden in the tax system, often used to support government’s social and economic objectives. Instead of directly allocating money for a particular objective, the government forgoes tax revenues from those who undertake activities that could achieve the objective. Therefore, tax expenditures should be analysed as government spending programs. Tax expenditure reporting and analysis has been a regular practice among many countries in the worl...
Poulsen, Martin; Hansen, Søren Jesper
Artiklen foretager en overordnet gennemgang af direktiv-forslaget om CCCTB og præsenterer i den forbindelse flere af de væsentligste muligheder og konsekvenser i relation til beskatning af selskaber inden for EU....
... (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Additions to the Tax, Additional Amounts, and Assessable... not include for such installment period the Federal income tax return as amended subsequent to the due... fourth installment date = $7,000 (ii) Addition to tax. Assuming that neither the annualized income...
Stanislav E. Kuzmin
Full Text Available The article outlines general characteristics of the sources of law, regulating relations associated with mergers, consolidations, acquisitions of joint stock companies in Russia and corporations in the United States respectively in the Russian legislation and the legislation of the United States and individual States. Both in Russia and in the USA there is a constitutional separation of powers between the Federal authorities and the Subjects of the Federation/States respectively. In both countries legal regulation of mergers and acquisitions of corporations is carried out first of all by a number of laws. These laws fall into three main groups: securities laws, antitrust (competition laws and civil and joint-stock legislation in Russia and corporate laws in the US. All the three groups are federal laws in Russia, while in the US the first two are federal too, but the last one is state laws. It is necessary to highlight the important role of judicial decisions in the United States on legal regulation of mergers, acquisitions, takeovers in comparison with Russia, which is due to the differences in the legal systems of the states in question. However, although Russia is not a state of case law, such legal acts as the resolution of the Plenum of the Supreme Commercial Court will undoubtedly have an impact on law enforcement practice and, consequently, on the regulation of relevant relations. Of particular importance are the findings of the Constitutional Court, whose decisions may cancel acts or their separate provisions provided they are recognized as unconstitutional. Such acts are repealed. Decisions of courts and other bodies based on acts or their separate provisions, recognized by the Constitutional Court of the Russian Federation unconstitutional, are not subject to execution and shall be revised in accordance with the Federal law. The US case law implies existence of a hierarchy of precedents according to which decisions adopted by the
Full Text Available Companies in Lithuania have to follow Business Accounting Standards (BAS when preparing their financial statements. Recording financial transactions according to BAS ensures that the information a company shares with potential lenders and investors gives a true and fair view of its business situation. However, the tax law prescribes its own set of accounting rules, which can result in a difference between what a business shows in financial statements and what it reports on its tax returns. This paper examines whether Lithuanian companies predominantly use tax accounting principles that migrate into their financial statements to create an inaccurate picture of business performance. The method of experts’ evaluation was chosen for that purpose. The results indicate that Lithuanian companies tend to heavily rely on accounting principles prescribed in corporate income tax law thus distorting information contained in financial statements. The paper contributes to the scarce literature on this issue of high relevance to both academics and practitioners.
Gupta, Sanjay; Mills, Lillian F.
Prior multistate tax research on differences in state tax rules, while investigating the effects on revenue, investment, and tax burden, is silent regarding the effect on compliance costs. We investigate factors that explain state income tax compliance costs for large firms. We find that state compliance costs increase in the number of filing states and entities (or in the number of state tax returns), firm size, and variables proxying for state tax complexity. Our evidence that multistate di...
Gravelle, Jane G.
The federal government loses both individual and corporate income tax revenue from the shifting of profits and income into low-tax countries, often referred to as tax havens. Tax havens are located around the world with concentrations in the Caribbean and Europe. Corporate profit shifting may cost up to $60 billion in revenue and remedies are likely to involve tax law changes. Individual income tax losses more often arise from tax evasion, and are facilitated by the lack of information report...
Full Text Available The subject. The article is devoted to the prerequisites of the emergence and essential characteristics of the institution of consolidated taxpayers’ groups in Russia and abroad, revealing of advantages and disadvantages of the legal regulation of the creation and operation of consolidated groups of payers of corporate profits tax, analyzing results and directions of the development of tax consolidation in Russian Federation.The purpose of the article is to identify positive and negative aspects of the functioning of the institution of consolidated taxpayers’ groups in Russia with the establishment of prospects of tax consolidation and the likely directions of its development.The description of the problem field. The development of the world economic system stimulates the emergence of new forms of management, characterized by the enlargement of busi-ness, the pooling of resources of individual enterprises into a single system in order to optimize entrepreneurial activity. These trends are reflected in the development of tax systems of various countries, that is expressed in the formation of institutions of consolidated taxpayers’ groups. Tax consolidation in Russia is a relatively new phenomenon, and it seems necessary to examine this institution from the law enforcement point of view, to evaluate its effectiveness.Methods and methodology. The authors used methods of analysis, synthesis, as well as formal-legal, comparative-legal, historical methods of investigation.Results and the scope of its application. The authors note that the institution of tax consolidation today is presented in the tax systems of most modern countries.The practice of applying the institution of consolidated taxpayers’ groups testifies to the existence of a significant number of advantages and disadvantages of tax consolidation in Russia. The moratorium on the creation of consolidated taxpayers’ groups, due to the contradictory nature of their influence on the
Köthenbürger, Marko; Stimmelmayr, Michael
if the corporate tax system exempts the normal return on investment from taxation. The optimal system may well use the full return on investment as a tax base. Hence, tax systems such as an Allowance for Corporate Equity (ACE) or a Cash-flow tax do not have the familiar efficiency-enhancing effects in the presence...
Antonio Lopo Martinez
Full Text Available A presente pesquisa tem como objetivo observar se a participação de empresas no Índice de Sustentabilidade Empresarial (ISE, listadas na BM&FBovespa, define alguma espécie de comportamento no tocante à agressividade tributária. As empresas listadas, ou não, no ISE foram avaliadas no período de 2010 a 2014 por meio de duas medidas de agressividade tributária: a taxa efetiva de tributação ETR (Effective tax Rate e a diferença entre os Lucros Contábeis e o Tributário (Book Tax Differences - BTD. Por hipóteses, especulava-se que as empresas listadas no índice seriam menos agressivas tributariamente, com o propósito de sinalizar um comportamento coerente com uma preocupação social. Entretanto, não foi encontrada uma teoria racional para justificar essa relação antecipada e, na verdade, sustentabilidade empresarial, em certa medida, poderia inclusive, estar relacionada com um planejamento tributário mais eficiente. A agressividade fiscal envolve o emprego de técnicas que privilegiam o planejamento tributário com vistas a reduzir a tributação explicita. Em certas circunstâncias empregam-se técnicas legais (elisão e outras ilegais, seja por sua abusividade na forma ou mesmo por ter caráter evasivo com vistas a reduzir a carga tributária. Os resultados documentados na pesquisa indicaram que as empresas que compõem o ISE tendem a ser menos agressivas tributariamente relativamente àquelas que não participam do ISE. Esse achado serve para antecipar o comportamento tributário de uma empresa em função dos valores que prestigia. The present research aims to observe whether the participation of companies in the Corporate Sustainability Index (ISE listed in BM & FBovespa defines behavior regarding tax aggressiveness. The companies listed or not in ISE were evaluated in the period from 2010 to 2014 through two measures of tax aggressiveness: the effective tax rate ETR (Effective tax Rate and the difference between Book Tax
The article analyzes the content of shadow economy through the prism of the tax administration. The author provides the limitations of the study and methodologically based relationship between the shadow economy and the tax revenue not to be received to the national consolidate budget. Country's tax losses (tax gap) is the amount of the tax revenue that is not received to the country's consolidated budget in the tax non-payment effects: tax avoidance and tax evasion. Tax losses (tax gap) is t...
Hansson, Åsa; Porter, Susan; Perry Williams, Susan
Economists and political scientists have long been interested in factors that affect the statutory tax rate on businesses set by federal governments. In this study, we examine the impact of political and economic factors on several measures of tax rates and tax incentives offered across 19 developed countries for the years 1979 through 2005. Our results indicate that while economic conditions such as openness, strategic interaction, budget constraints, economic downturns and an aging populati...
Cronin, Julie Anne; Lin, Emily Y.; Power, Laura; Cooper, Michael
The purpose of this analysis is to improve the U.S. Department of the Treasury’s distributional model and methodology by defining new model parameters. We compute the percentage of capital income attributable to normal versus supernormal return, the percentage of normal return attributable to the "cash flow tax" portion of the tax that does not impose a tax burden, and the portion of the burdensome tax on the normal return to capital borne by capital income versus labor income. In summary, 82...
Boll, Karen; Brehm Johansen, Mette
to wider international trends within tax administration, especially concerning the development of risk assessments and internal control in the corporations and a greater focus on monitoring of these elements by the tax authorities. Overall, the working paper concludes that Tax Governance as a model......This working paper presents an analysis of the experiences of Cooperative Compliance in Denmark. Cooperative Compliance denotes a specific kind of collaborative program for the regulation of large corporate taxpayers by the tax authorities. Cooperative Compliance programs have been implemented...... in several countries worldwide. In Denmark the program is called Tax Governance. Tax Governance has been studied using qualitative method and the analyses of the working paper build on an extensive base of in-depth interviews – primarily with tax directors from corporations participating in the program...
Full Text Available he purpose of this research is to know the influence of institutional ownership, independent commissioner, audit committee and audit quality to tax avoidance at mining company listed on BEI year 2014-2016. The population of this study is mining companies listed on the BEI 2014-2016 as many as 46 companies. Sampling used in this research purposive sampling method. Data source is secondary data obtained from company website and BEI website (www.idx.co.id. This study uses multiple regression analysis to analyze data with the help of SPSS 21 edition program. The results of this study indicate that the variables of institutional ownership, audit committee and audit quality have significant influence on tax avoidance, while independent commissioner variable has no significant effect on tax avoidance. The results of this study are expected to be an additional consideration of the management in conducting tax avoidance is correct and efficient without violating applicable tax laws, and can provide additional information for users of financial statements in investment decision making.
Full Text Available The primary objective of this research is to investigate the relationship between tax avoidance, income and cash held in companies listed on the Tehran Stock Exchange from 2009 to 2013. In this regard, avoidance of paying taxes is independent variables and criteria for evaluating financial performance; namely return on assets, return on average equities, economic value added, market value added, and the ratio of free cash flow are considered as dependent variables. Firm size and financial leverage are also considered as control variables. In general, the statistical method used in this research is correlation and regression. The results of the research showed that there was a significant and reverse relationship between avoidance of paying taxes and performance evaluation criteria, cash held.
Kevin A. Diehl
Full Text Available This research seeks to update and finally determine for the Fortune 500 whether the market values the inventory valuation choice of last-in, first-out (LIFO over first-in, first-out (FIFO as some signal of reporting and management quality. The market can adjust LIFO earnings to FIFO earnings. Thus, the only issue then is that companies choosing FIFO pay higher taxes, which shareowners should disfavor. Indeed, only 20 percent of the Fortune 500 utilize LIFO to value any inventory. However, after Spearman correlations and logistic regression, the research statistically significantly shows that investors are willing to give premiums on the price of stock for the choice of LIFO. Thus, companies should choose LIFO to reduce taxes and increase their stock prices.
Double taxation of dividends is a matter of great interest in the actual context of globalization and free movement of capital and persons. As the classical system is more and more abandoned, new solutions for the relief of double taxation are put into practice as a mean to reduce the fiscal burden on shareholders. With few exceptions, all these solutions are based on dividend tax relief. The paper aims at providing alternative solutions for double dividend taxation relief by taking some acti...
Roache, Sarah A; Gostin, Lawrence O
Globally, soda taxes are gaining momentum as powerful interventions to discourage sugar consumption and thereby reduce the growing burden of obesity and non-communicable diseases (NCDs). Evidence from early adopters including Mexico and Berkeley, California, confirms that soda taxes can disincentivize consumption through price increases and raise revenue to support government programs. The United Kingdom's new graduated levy on sweetened beverages is yielding yet another powerful impact: soda manufacturers are reformulating their beverages to significantly reduce the sugar content. Product reformulation - whether incentivized or mandatory - helps reduce overconsumption of sugars at the societal level, moving away from the long-standing notion of individual responsibility in favor of collective strategies to promote health. But as a matter of health equity, soda product reformulation should occur globally, especially in low- and middleincome countries (LMICs), which are increasingly targeted as emerging markets for soda and junk food and are disproportionately impacted by NCDs. As global momentum for sugar reduction increases, governments and public health advocates should harness the power of soda taxes to tackle the economic, social, and informational drivers of soda consumption, driving improvements in food environments and the public's health. © 2017 The Author(s); Published by Kerman University of Medical Sciences. This is an open-access article distributed under the terms of the Creative Commons Attribution License (http://creativecommons.org/licenses/by/4.0), which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
Sarah A. Roache
Full Text Available Globally, soda taxes are gaining momentum as powerful interventions to discourage sugar consumption and thereby reduce the growing burden of obesity and non-communicable diseases (NCDs. Evidence from early adopters including Mexico and Berkeley, California, confirms that soda taxes can disincentivize consumption through price increases and raise revenue to support government programs. The United Kingdom’s new graduated levy on sweetened beverages is yielding yet another powerful impact: soda manufacturers are reformulating their beverages to significantly reduce the sugar content. Product reformulation – whether incentivized or mandatory – helps reduce overconsumption of sugars at the societal level, moving away from the long-standing notion of individual responsibility in favor of collective strategies to promote health. But as a matter of health equity, soda product reformulation should occur globally, especially in low- and middleincome countries (LMICs, which are increasingly targeted as emerging markets for soda and junk food and are disproportionately impacted by NCDs. As global momentum for sugar reduction increases, governments and public health advocates should harness the power of soda taxes to tackle the economic, social, and informational drivers of soda consumption, driving improvements in food environments and the public’s health.
Full Text Available States, though in order to grasp taxable income have created legal infrastructure; with the reason of lack of efficient tax audit, they have been exposed to important tax losses due to transfer pricing.The amount of tax losses due to over invoiced imports and under invoiced exports that are determined as estimation; has shown that tax audit had not been efficient in transfer pricing. In order to minimize corporate tax losses that occured due to transfer pricing, it is required to take precautionary measures oriented in increasing efficiency in tax audit
Riskjell, Ole Kristian
This thesis seeks to answer what are the main distortions in the Norwegian tax system and to determine which of the ACE or CBIT systems that best could replace the current system. First, the thesis considers the current distortions in the Norwegian tax system. I find that the current tax system is distortive with regards to the tax-treatment of debt versus equity, as only cost of debt is deductible for tax purposes, while cost of equity is not. Moreover, the current system is d...
The purpose of this research project was to trace and locate 113 P- 38 Lightning Aircraft that were constructed by Consolidated-Vultee Aviation Corporation of Nashville-Tennessee. A determination as to where they were located at the end of World War II, along with their subsequent location, was attempted. This project utilized historical research with a qualitative approach where data was accumulated, evaluated and formulated based on events that happened 70 years ago. A triangulation practice is the process of collecting data, not from just one source, but from several sources. This process helps strengthen the individual data, compensated by others to create a complete picture of the phenomenon being researched. The research does not focus on pilots that flew the P-38's. However, a few pilot names may be mentioned that were involved in an accident the aircraft may have suffered. The Army Air Force requested 2000 P-38's Model " L " built by Consolidated-Vultee for the Lockheed Aircraft Corporation in Burbank, California. The War Department did not know at the time how long the present conflict of war might last.
Pope, Thomas R; Schwartz, Richard W
The development of tax reduction strategies is a critical aspect of both corporate and personal financial planning because taxes represent the largest annual expenditure for the majority of Americans. The categories of tax reduction strategies discussed include charitable-giving techniques, ways to maximize business deductions, shifting income to family members, education tax incentives, retirement planning, and small business tax considerations. One use for these tax savings is the enhancement of a corporation's capabilities to provide services to patients.
The rod consolidation demonstration involved pulling the fuel rods from five fuel assemblies from Unit 1 of RG and E's R.E. Ginna Nuclear Power Plant. Slow and careful rod pulling efforts were used for the first and second fuel assemblies. Rod pulling then proceeded smoothly and rapidly after some minor modifications were made to the UST and D consolidation equipment. The compaction ratios attained ranged from 1.85 to 2.00 (rods with collapsed cladding were replaced by dummy rods in one fuel assembly to demonstrate the 2:1 compaction ratio capability). This demonstration involved 895 PWR fuel rods, among which there were some known defective rods (over 50 had collapsed cladding); no rods were broken or dropped during the demonstration. However, one of the rods with collapsed cladding unexplainably broke during handling operations (i.e., reconfiguration in the failed fuel canister), subsequent to the rod consolidation demonstration. The broken rod created no facility problems; the pieces were encapsulated for subsequent storage. Another broken rod was found during postdemonstration cutting operations on the nonfuel-bearing structural components from the five assemblies; evidence indicates it was broken prior to any rod consolidation operations. During the demonstration, burnish-type lines or scratches were visible on the rods that were pulled; however, experience indicates that such lines are generally produced when rods are pulled (or pushed) through the spacer grids. Rods with collapsed cladding would not enter the funnel (the transition device between the fuel assembly and the canister that aids in obtaining high compaction ratios). Reforming of the flattened areas of the cladding on those rods was attempted to make the rod cross sections more nearly circular; some of the reformed rods passed through the funnel and into the canister
Deakin, John F.
The presentation deals with the North Sea fiscal regime, a modern system for corporation tax payments, transfer pricing, general anti-avoidance rule for direct taxes, treaty refunds, deductibility of interest for corporation tax, UK/US double taxation convention, and plain and simple tax legislation. Part of the background for the presentation was the fact that in England a new Labour Government had replaced the Conservatives and the new Chancellor had announced a review of the North Sea fiscal regime.
... follows: PART 1--INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read, in part... contains proposed amendments to 26 CFR part 1 concerning the allocation of earnings and profits in tax-free... the allocation of earnings and profits should conform to the rules for the allocation of other tax...
... only class of stock of M Corporation which in turn owns 100 percent of the only class of stock of N... controlled foreign corporations throughout the period here involved. (b) During 1963, N Corporation invests... for 1963 under section 951(a)(1)(B) by reason of his indirect ownership of the stock of N Corporation...
Guilherme Otávio Monteiro Guimarães
Full Text Available This study aimed to analyze the effective tax rate of public companies operating in stock market in Brazil over a period between 2003 and 2013, both to the total effective tax rate (ETRt as the curren (ETRc, seeking to verify evidence of the presence of tax management. This analysis consists of (i to assess whether average tax burden is upper, equal or less than the statutory rate of 34%; (ii verify that the ETR suffered influence of RTT adjustments arising from the introduction of IFRS; (iii identify proxies (size; profitability; inventory; properties, plants and equipment; debt; and deferred tax expenses which may explain the variation in ETR. The results showed that: (i companies have a significantly lower ETR than the statutory tax rate; (ii companies reported a lower ETR on the full adoption of IFRS period; (iii the ETR has relation to size (negative, debt (positive and components of assets (positive; and (iv there are deferral strategies considering the negative sign of deferred taxes in relation to the current ETR. The results confirm the practice of tax management and also demonstrate that the resulting RTT adjustments resulted in a lower tax burden, confirming previous studies that estimated less conservative earnings after the beginning of the convergence process. Finally, we observed that larger companies have a lower tax burden and that in general companies adopt choices that allow the deferral of taxes on income.
Shuchi Sharma; Rupendra Prakash Yadav.
Goods and Service Tax is a significant and logical step towards a comprehensive Indirect tax reform in India. This paper analyses the concept of Goods Service Tax and further discusses their impact on the various sectors in India. Brief description is given on Goods Service Tax background and Goods and Service Tax models helps to reduce tax burden. It aims at creating a single and unified market benefiting both corporate and economy because this is the only Indirect tax that directly affects ...
This diploma thesis deals with tax optimization of companies. The thesis is divided into two main parts - the theoretical and practical part. The introduction of the theoretical part describes the history of taxes, their basic characteristics and the importance of their collection for today's society. Subsequently, the tax system of the Czech Republic with a focus on value added tax and corporation tax is presented. The practical part deals with specific possibilities of optimization of the a...
Feller, Anna; Schanz, Deborah
The question of why some companies pay more taxes than others is a widely investigated topic of interest. One of the famous suspect explanations is a phenomenon called tax avoidance. We develop a holistic theoretical concept of influences on corporate tax planning through a series of 19 in-depth German tax expert interviews. Our findings show that three distinct hurdles in the tax planning process can explain different levels of tax expense across companies. Those three hurdles are which tax ...
Full Text Available The tax system of the Republic of Croatia contains a large number of very diverse kinds of tax expenditures whose the declared aim is to achieve certain social and economic objectives. This paper considers all the items that constitute tax expenditures in Croatia, within the systems of the personal income tax, corporate income tax, and real estate transfer tax and value added tax. The objective of the article is to determine the real level of tax expenditures per form of tax in the 2001-2004 period. We hypothesised that the tax expenditures in the analysed forms of tax are both high and growing, which was ultimately borne out, for almost all the analysed items in the tax forms considered are growing.
Dr.Sc. Skender Ahmeti; Dr.Sc. Muhamet Aliu; MSc. Alban Elshani; Yllka Ahmeti
This paper provides guidance for all those interested in research related to tax. In the study are included three main areas dealing with taxes and about taxes: (1) the role of information in corporation tax expenditures under the rules and laws of the country against financial statements according to international accounting standards, (2) case study PTK; how much effective tax and tax on extra profit has it paid (3) the impact of tax rules on investment decisions - the reasons and profits o...
Stallmann, Judith I.; Jones, Lonnie L.
This document is part of an educational series on Texas taxes. State and local taxes in Texas are compared with those of the fifty states and the District of Columbia. Taxes are compared per capita and per $1,000 of personal income. The taxes include: all state and local taxes, property taxes, sales and gross receipts taxes, personal income taxes, corporate income taxes and corporate franchise taxes. For each tax the national average, median, maximum and minimum are given along with the corre...
Alstadsæter, Annette; Jacob, Martin
This paper analyzes the sources of heterogeneity in legal tax avoidance strategies across individuals. Three conditions are required for a taxpayer to participate in tax avoidance: incentive, access, and awareness. Using rich Swedish administrative panel data with a unique link between corporate and individual tax returns, we analyze individual participation in legal tax planning around the 2006 Swedish tax reform. Our results suggest that closely held corporations are utilized to facilitate ...
... Corporation's Accounting and Financial Management Services Division will be the point of contact with the... when the Corporation: (1) Determines that an error has been made with respect to a debt that has been...
... 26 Internal Revenue 12 2010-04-01 2010-04-01 false Estimated tax. 1.1502-5 Section 1.1502-5 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Consolidated Tax Liability § 1.1502-5 Estimated tax. (a) General rule—(1) Consolidated...
This study also investigates whether individual U.K. companies respond to the 1997 abolition of tax-credit. The test results show that the majority of companies in the sample do not change their dividend policies after the abolition of tax credit. It is possible that companies are reluctant to cut their dividend payment since the existing dividend payout could be sustained in the long-run. They also avoid sending negative signals to the market. Thus, companies typically chose to keep a dividend level relatively stable following the tax change in 1997. Only the minority of the U.K. companies experience a decline in their dividend payment. This evidence supports the hypothesis that the abolition of tax credit on dividends results in a decrease in aggregate dividend payment in order to satisfy a tax clientele.
corporate income tax revenue and decrease personal income tax revenue and thus redistribute tax burdens. Our estimates would be affected accordingly...estimated $524 million in corporate income tax revenue for tax year 1983. However, the areas exempted or rebated another $2.35 billion of area income...Views Such exemptions and rebates, which the U .S. Code does not allow, account for much of the difference between estimated area corporate income tax collections
Full Text Available Tax expenditure analyses have been an important element in the supervision of reform processes linked to implementing different kinds of tax incentive and the management of a correct tax policy. The paper provides an evaluation of tax expenditure in Slovenia relating to personal income tax and corporate income tax. Four consecutive tax years were selected for the calculation of the tax expenditure on personal income tax (2006-09, while three consecutive years were selected for the corporate income tax calculation (2008-10. The tax expenditure calculated for personal income tax was highest in 2006 and reached 5.2% of GDP. After several changes in personal income tax, expenditures decreased to around 3% of GDP in the following three years. The tax expenditure calculated for corporate income tax was much lower as compared to GDP than for personal income tax, reaching around 0.2% of GDP.
Special Analysis G. 0 ...-..... . . . .~....... 677 777 ".47- śf . -2- Retained Earnings: The divergence of the individual from the corporate income tax rate...up to a 38.5 percent tax on S retained earnings. After paying corporate income tax on their income, firms may distribute their earnings to shareholders...months) over net short-term capital losses. They are taxed at the regular corporate income tax rate on the excess of net short-term capital gains over
Full Text Available In the Weighted Average Cost of Capital (WACC applied to the free cash flow (FCF, we assume that the cost of debt is the market, unsubsidized rate. With debt at the market rate and perfect capital markets, debt only creates value in the presence of taxes through the tax shield. In some cases, the firm may be able to obtain a loan at a rate that is below the market rate. With subsidized debt and taxes, there would be a benefit to debt financing, and the unleveraged and leveraged values of the cash flows would be unequal. The benefit of lower tax savings are offset by the benefit of the subsidy. These two benefits have to be introduced explicitly. In this paper we present the adjustments to the WACC with subsidized debt and taxes and the cost of leveraged equity for multiple periods. We demonstrate the analysis for both the WACC applied to the FCF and the WACC applied to the capital cash flow (CCF. We use the calculation of the Adjusted Present Value, APV, to consider both, the tax savings and the subsidy. We show how all the methods match.
Full Text Available The paper analyzes the cost of financing through financial and operational leasing due to the deductibility of depreciation and interest. The shareholders of any company aim to obtain profit and to increase their ownership equity. In order for this to happen, the company must have profit, for which a corporate tax must be paid. A good management translates into choosing the most advantageous means of financing, which will lead to paying a lower corporate tax. Leasing and the non-taxation of reinvested profits are two means through which companies can obtain significant fiscal advantages, by increasing the deductible expenses, or by paying lower taxes.
van 't Riet, Maarten; Lejour, Arjen
The international corporate tax system is considered as a network and, just like for transportation, ‘shortest’ paths are computed, minimizing tax payments for multinational enterprises when repatriating profits. We include corporate income tax rates, withholding taxes on dividends, double tax
... Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES (CONTINUED) Corporations Used to Avoid Income Tax on Shareholders § 1.531-1 Imposition of tax. Section 531 imposes (in addition to the other taxes imposed upon corporations by chapter 1 of the...
and household level in a coordi- investment takes place but also the mix of investment nated manner. A separate corporate income tax ap- in different...have studied the effects of assets. As another example, allowances for deprecia- the corporate income tax have concluded that it carries tion do not...types equal to over one-half of the tax revenues collected of investments more quickly than others. The result of from the corporate income tax .4 current
Sørensen, Peter Birch
This paper discusses the principles and practices of dual income taxation in the Nordic countries. The first part of the paper explains the rationale and the historical background for the introduction of the dual income tax and describes the current Nordic tax practices. The second part...... of the paper focuses on the problems of taxing income from small businesses and the issue of corporate-personal tax integration under the dual income tax, considering alternative ways of dealing with these challenges. In the third and final part of the paper, I briefly discuss whether introducing a dual income...
Varma, Vijaya Krushna Varma
All Direct and Indirect taxes accompanied by tax laws, accounting, auditing and tax returns, can be abolished if a new tax system called "TOP Tax system" is adopted and implemented by all nations. Ultimate economic reforms will relieve 7 billion people of the world from the cobweb of ambiguous and complex tax structures, plethora of tax laws, mandatory and cumbersome accounting, auditing, tax returns and consequent quagmire of all tax related cases. Taxation, tax collection, tax enforce...
... merge, consolidate, change form of organization (corporation, limited liability company, or limited partnership) or reorganize without the Secretary's prior written approval. Any such merger, consolidation, or...
Chongvilaivan, Aekapol; Jinjarak, Yothin
The scale dependence in firm growth (smaller firms grow faster) is systematically reflected in the size distribution. This paper studies whether taxes affect the equilibrium firm size distribution in a cross-country context. The main finding is that the empirical association between firm growth and corporate tax (VAT) is positive (negative), with notable differences in the response of manufacturing firms and that of the others. We draw implications for recent debate on the impact of taxes and...
Full Text Available REPUBLICANS REVEAL PROPOSED TAX OVERHAUL The White House and Congressional Republicans have revealed their much-anticipated proposal for reform of the U.S. personal and corporate tax systems. The proposal titled, “UNIFIED FRAMEWORK FOR FIXING OUR BROKEN TAX CODE” outlines a number of central policy changes, which will significantly alter the U.S. corporate tax system. The proposal includes a top federal marginal rate reduction for the sole proprietorships, partnerships and S corporation—small business equivalents— from 39.6% to 25% (state income tax rates would no longer be deductible. Large corporations would also see a meaningful federal rate reduction given the proposed drop in the federal corporate income tax rate from 35% to 20%. Additionally, the proposal includes a generous temporary measure intended to stimulate investment, full capital expensing for machinery with a partial limitation of interest deductions.
Peter Egger; Horst Raff
This paper argues that the large reduction in corporate tax rates and only gradual widening of tax bases in many countries over the last decades are consistent with tougher international competition for foreign direct investment (FDI). To make this point we develop a model in which governments compete for FDI using corporate tax rates and tax bases. The modelâ€™s predictions regarding the slope of policy reaction functions and the response of equilibrium tax parameters to trade costs and mark...
S. Kohlhase (Saskia)
textabstractUsing confidential corporate income tax return data, this paper investigates the association between book-tax non-conformity (measured as book-tax differences) and tax-loss carryforwards (TLCFs). I find that TLCFs are positively associated with temporary and permanent book-tax
Aziz Jaafar; John Thorton
We examine the impact of tax-haven operations on the effective corporate tax burdens of publicly listed and privately held firms domiciled in Europe. In particular, we consider how European firmsÕ tax haven operations interacts with factors such listing status and home-country tax reporting systems to determine the relative tax burdens of publicly listed and private firms. Our main empirical results show that tax haven operations is associated with lower effective tax rates for both private a...
Full Text Available Taxes have become an issue of corporate social responsibility (CSR, but the role of taxation is to some extent an ambiguous and controversial issue in the CSR framework. Similarly, another unclear question is what role investors who are committed to sustainable and responsible investment (SRI see taxes as having on their environmental, social, and governance (ESG agenda. Corporate taxes have an inverse relationship with the return of the investors: taxes paid directly affect what is left on the bottom line, reducing the return of investors. However, investors are now more aware of tax-related risks, which can include different forms of reputation risk. Corporate tax planning may increase the returns, but those increased returns are riskier. This study focuses particularly on the relationship between SRI and taxation. We find that tax matters are considered to be on the ESG agenda, but their role and significance in the ESG analysis is unclear.
Eggert, Wolfgang; Schjelderup, Guttorm
This paper compares property taxation to a corporate income tax based on formula apportionment in a model where identical countries compete to attract capital. We find that if countries can pair a residence-based capital tax with a property tax (source tax on capital) the tax equilibrium is efficient. In contrast, the use of a 2-factor FA scheme based on sales and capital combined with a residence-based capital tax leads to an inefficient outcome.
policies is a great challenge for governments; tax harmonization can be adopted for ... and the development trajectory of taxing state in diverse ways. For ... revenue is lost development opportunity.3 The existence of high corporate tax rate in a .... 26 This is levied pursuant to the Tertiary Education Trust Fund Tax Act 2011.
van 't Riet, Maarten; Lejour, Arjen
The international corporate tax system is considered as a network and, just like for transportation, ‘shortest’ paths are computed, minimizing tax payments for multinational enterprises when repatriating profits. We include corporate income tax rates, withholding taxes on dividends, double tax treaties and the double taxation relief methods. We find that treaty shopping leads to an average potential reduction of the tax burden on repatriated dividends of about 6 percentage points. Moreover, a...
Regulatory and institutional challenges of corporate governance in post banking consolidation Nigeria. ... PROMOTING ACCESS TO AFRICAN RESEARCH ... From a banking industry perspective, good corporate governance demands
... 26 Internal Revenue 10 2010-04-01 2010-04-01 false Foreign tax credit with respect to taxes paid... Controlled Foreign Corporations § 1.960-1 Foreign tax credit with respect to taxes paid on earnings and... foreign tax credit limitation under section 904(a) of the domestic corporation for the taxable year in...
Busato, Francesco; Chiarini, Bruno; Marchetti, Enrico
This paper shows under indeterminacy and tax evasion, an increase in corporate,labor or income tax rates pushes the economy into an expansionary pattern.These effects are reversed when the steady state is saddle-path stable.......This paper shows under indeterminacy and tax evasion, an increase in corporate,labor or income tax rates pushes the economy into an expansionary pattern.These effects are reversed when the steady state is saddle-path stable....
Revenue from corporation tax and taxes on capital income, net of revenue loss from deductibility of interest, as a percentage of the GDP has tripled in Finland over the past two decades. This is argued to result from greater openness of the economy as well as from simultaneous tax reforms towards neutrality of capital income taxation by combining tax-base broadening with tax-rate reductions. They implied improved efficiency of real investments, elimination of tax avoidance in entrepreneurial ...
Full Text Available 1990’s world was quite different from the world of 1950’s. Especially in the last twenty years, the increasing involvement of Japan in the world economy since the 1990s, in addition to the dominance of globalization and market economy throughout the world, the rapid spread of information resulting from the developments in IT-technology and the international competition emerging in the field of technology have all led to some significant developments in the world economy. Reduction of high mobility income and corporate tax rates due to tax competition may cause an unjust distribution of the tax burden. The fact that indirect taxation constitutes about 70% of the tax revenues obtained in Turkey can be taken as an indication of the unfairness in the distribution of tax burden in Turkey. In this study, following a definition of globalization and tax competition, classification of tax competition, reasons for increasing tax competition, benefits and losses of tax competition are explained, and changes introduced by various countries in their tax systems due to tax competition, the distribution of tax burden resulting from tax competition in Turkey and the effectiveness of the new income tax law in Turkey in terms of tax competition are analyzed.
Full Text Available The article analyzes the content of shadow economy through the prism of the tax administration. The author provides the limitations of the study and methodologically based relationship between the shadow economy and the tax revenue not to be received to the national consolidate budget. Country’s tax losses (tax gap is the amount of the tax revenue that is not received to the country's consolidated budget in the tax non-payment effects: tax avoidance and tax evasion. Tax losses (tax gap is treated as the difference between the amount of potential taxes and contributions that could be collected if the taxpayers correctly calculated and paid on time in accordance with the provisions of the legislation and actually paid taxes and contributions.Article in Lithuanian
... Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit AGENCY: Internal Revenue Service... purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that...
... Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit AGENCY: Internal Revenue Service... purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that...
... Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit AGENCY: Internal Revenue Service... purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that...
... TAX (CONTINUED) INCOME TAXES Domestic International Sales Corporations § 1.996-7 Carryover of DISC tax... 26 Internal Revenue 10 2010-04-01 2010-04-01 false Carryover of DISC tax attributes. 1.996-7... in nontaxable transactions shall be subject to rules generally applicable to other corporate tax...
because the windfall profit tax is deductible on both individual and corporate income tax returns and thus reduces the producer’s income tax liability...examinations generally are about 3 years more current than corporate income tax examinations, cross-tax-year coordina- - S . tion is needed to avoid...annual individual or corporate income tax return. In any case, taxpayers summarize the supporting net income limitation calculation on Form 6249
... regulations affect individuals and corporations that claim direct and indirect foreign tax credits. DATES... Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction AGENCY: Internal... determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address...
This thesis introduces the tax system of the Czech Republic. The corporate income tax in particular is specified in bigger detail. Its basic structural elements are described with the focus on the transformation of the accountable profit to the tax base. The practical part is divided into chapters, each of which deals with the optimization of the amount of the real tax liability. The content, instruments mentioned and methods for decreasing company tax liability applied suggest this work more...
Nicoleta Mihaela Florea
Full Text Available The study aims to analyze the dynamics of tax revenues in Romania in the period 2008 - 2013, following the installation of austerity caused by the global economic crisis. There are highlighted the earned revenues at the general consolidated budget by revenue category, according to the annual budget execution. The article deals mainly with the evolution of profit tax, income and salaries tax, value added tax and excise. .
Stephen Bond; Jing Xing
We present new empirical evidence that aggregate capital accumulation is strongly influenced by the user cost of capital and, in particular, by corporate tax incentives summarised in the tax-adjusted user cost. We use sectoral panel data for the USA, Japan, Australia and ten EU countries over the period 1982-2007. Our panel combines data on capital stocks, value-added and relative prices from the EU KLEMS database with measures of effective corporate tax rates from the Oxford University Centr...
The recent state aid investigations may be an incentive for the corporate boards and senior management of companies to have a closer look at their tax strategy and its implementation in the company's business and organization to avoid unexpected outcomes.
Reducing a national corporate tax rate and introducing numerous/ ample tax reliefs may have adverse effects on a country's reputation as it is perceived as being susceptible to unfair tax competition practices and prone to allowing the subsidiaries of foreign companies to enter the national market at any cost (even at the expense of preserving its natural assets). For this reason, it is essential to find the right balance between the need to attract foreign capital (on the one hand) and the p...
Beznoska, Martin; Hentze, Tobias
In the course of the 'Panama Papers' discussion, questions arise concerning the fiscal effects of international profit shifting and tax avoidance. A recent OECD study estimates the worldwide corporate tax losses to lie between 4 and 10 percent of the revenues. Applied to Germany, this would reflect between 3 and 7 billion Euro or maximum 1 percent of total tax revenues. However, the estimation underlies questionable assumptions and therefore severe uncertainties.
Indiana legislators are currently debating the merits of a proposal to adopt a statewide tuition scholarship tax credit program. The proposed program would make available $5 million in tax credits that businesses and individuals could claim by making donations to non-profit Scholarship Granting Organizations (SGOs). SGO donations would be matched…
Peter Egger; Simon Loretz; Michael Pfaffermayr; Hannes Winner
This paper assesses the impact of corporate taxation on multinational activity. A numerically solvable general equilibrium model of trade and multinational firms is used to incorporate the following components of corporate taxation: parent and host country statutory corporate tax rates, withholding tax rates, and parent and host country depreciation allowances. We account for their differential impact under alternative methods of double taxation relief (i.e., credit, exemption, and deduction)...
Accelerating the Worldwide Adoption of Sugar-Sweetened Beverage Taxes: Strengthening Commitment and Capacity Comment on "The Untapped Power of Soda Taxes: Incentivizing Consumers, Generating Revenue, and Altering Corporate Behavior".
Baker, Phillip; Jones, Alexandra; Thow, Anne Marie
In their recent article Roache and Gostin outline why governments and public health advocates should embrace soda taxes. The evidence is strong and continues to grow: such taxes can change consumer behavior, generate significant revenue and incentivize product reformulation. In essence, such taxes are an important and now well-established instrument of fiscal and public health policy. In this commentary we expand on their arguments by considering how the worldwide adoption of such taxes might be further accelerated. First, we identify where in the world taxes have been implemented to date and where the untapped potential remains greatest. Second, drawing upon recent case study research on country experiences we describe several conditions under which governments may be more likely to make taxation a political priority in the future. Third, we consider how to help strengthen the technical and legal capacities of governments to design and effectively administer taxes, with emphasis on low- and middle-income countries. We expect the findings to be most useful to public health advocates and policy-makers seeking to promote healthier diets and good nutrition. © 2018 The Author(s); Published by Kerman University of Medical Sciences. This is an open-access article distributed under the terms of the Creative Commons Attribution License (http://creativecommons.org/licenses/by/4.0), which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.
... THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Additions to the Tax, Additional Amounts.... (a) Notice and demand. (1) The Internal Revenue Service (IRS) shall issue to each tax return preparer... issued to the tax return preparer. (2) A tax return preparer may file one or more consolidated claims for...
Lai, Tat-kei; Ng, Travis
The agency model of Chetty and Saez (2010) predicts that firms with stronger corporate governance are more responsive to a dividend tax cut in their dividend and investment policies. We test these predictions by exploiting the sudden and significant dividend tax cut following the Jobs and Growth...... Tax Relief Reconciliation Act of 2003 and the pre-tax cut variation in corporate governance standards across firms. We find that firms with stronger corporate governance raise dividends and reduce investment in response to the tax cut significantly more than firms with weaker corporate governance...
Geiler, P.H.M.; Renneboog, L.D.R.
We study the tax regulations in relation to dividends and capital gains over the last two decades for the UK in order to determine whether changes in tax regimes affect corporate payout policy (dividends, share repurchases, or a combination). While we can identify investors’ tax-driven preferences
Hong, Qing; Smart, Michael
The multinationalization of corporate investment in recent years has given rise to a number of international tax avoidance schemes that may be eroding tax revenues in industrialized countries, but which may also reduce tax burdens on mobile capital and so facilitate investment. Both the welfare effects of and the optimal response to international tax planning are therefore ambiguous. Evaluating these factors in a simple general equilibrium model, we find that citizens of high-tax countries be...
Waples, Elaine; Darayseh, Musa
The corporate scandals of recent years have highlighted the failure of ethics, not only in corporate management, but also in the big accounting firms. For tax professionals, there is an inherent conflict of interest that makes studying ethics in the context of tax practice problematic. On the one hand, the tax professional is a client advocate…
Schaper, Marcel; Hage, Jaap; Waltermann, Antonia; Akkermans, Bram
Taxes are compulsory, unrequited payments to government. This chapter discusses the goals of taxation and provides an introduction to the most important taxes: taxes on income, taxes on goods and services, and taxes on property. Furthermore, the chapter offers insights to procedural issues of
Spain, H H
In a sand consolidation method in which there is injected a mixture of resin-forming liquids comprising an aryl-hydroxy low molecular weight compound, a water- soluble aldehyde, and a catalyst, an improvement is claimed which comprises diluting the resin-forming liquids with a diluent and with water so that the yield of the resin is sufficient to consolidate the sand particles with the minimum desirable pressure. The diluent may be mutually soluble in water and in the resin-forming liquids, and does not affect the setting time of the polymer. The aldehyde and the aryl-hydroxy compound may be in ratio of 5:1, and the diluent, methyl alcohol, is present in a ratio of 2:1 with reference to the water.
Renata Nogueira Braga
Full Text Available ABSTRACT This study investigates the association between mandatory International Financial Reporting Standards (IFRS adoption and corporate tax avoidance. In this study, tax avoidance is defined as a reduction in the effective corporate income tax rate through tax planning activities, whether these are legal, questionable, or even illegal. Three measures of tax avoidance are used and factors at the country and firm level (that have already been associated with tax avoidance in prior research are controlled. Using samples that range from 9,389 to 15,423 publicly-traded companies from 35 countries, covering 1999 to 2014, it is found that IFRS adoption is associated with higher levels of corporate tax avoidance, even when the level of book-tax conformity required in the countries and the volume of accruals are controlled, both of which are considered potential determinants of this relationship. Furthermore, the results suggest that after IFRS adoption, firms in higher book-tax conformity environments engage more in tax avoidance than firms in lower book-tax conformity environments. It is also identified that engagement in tax avoidance after IFRS adoption derives not only from accruals management, but also from practices that do not involve accruals. The main conclusion is that companies engage more in tax avoidance after mandatory IFRS adoption.
In Europe, a number of countries align tax accounts and parent-only accounts, while allowing companies to characterize consolidated profits to capital markets in a different way. Using parent-only (consolidated) accounts as a proxy for tax (book) accounts, this paper analyzes the role of reporting
Sureth, Caren; Langeleh, Dirk
This paper investigates the influence of different systems of current income and capital gains taxation on investor's decision to either carry out an investment in corporate shares or to invest funds alternatively on the capital market. Three basic tax systems are analyzed, a classical corporate tax system with double taxation of profits on corporate and personal level, a shareholder relief system, that reduces double taxation completely. It can be shown that general analytical solutions for ...
Dr.Sc. Skender Ahmeti
Full Text Available This paper provides guidance for all those interested in research related to tax. In the study are included three main areas dealing with taxes and about taxes: (1 the role of information in corporation tax expenditures under the rules and laws of the country against financial statements according to international accounting standards, (2 case study PTK; how much effective tax and tax on extra profit has it paid (3 the impact of tax rules on investment decisions - the reasons and profits of the company and the host country. We will try to summarize here the three areas of study and come to some conclusions on how to deal with fiscal policy in Kosovo. In addition, we will offer our opinion on some interesting and important questions for future research.
This essay in celebration of Grossman and Hart (GH) (Grossman, S., and H. Oliver. 1986. "The Costs and Benefits of Ownership: A Theory of Vertical and Lateral Integration," 94 Journal of Political Economy 691–719.) discusses how the introduction of incomplete contracts has fundamentally changed economists’ perspectives on corporate finance and control. Before GH, the dominant theory in corporate finance was the tradeoff theory pitting the tax advantages of debt (relative to equity) against ba...
Vermeulen, H.; Elink Schuurman, J.H.
In this article, the authors explain the amendments to Dutch tax law as a result of the recent implementation of the Alternative Investment Fund Managers Directive. Changes were made to the Dutch Corporate Income Tax Act, the Dutch Dividend Withholding Tax Act and the Dutch General Tax Act. Given
... tax exemption (determined under § 1.58-1) for such year. For purposes of section 56(c) and this... the acquiring corporation's minimum tax exemption for such year as the items of tax preference... intervening taxable years. If such method is used, the minimum tax liability of the intervening year is not...
Full Text Available The research’s first purpose is to analyze directly conservatism accounting influence towards book tax differences and tax avoidance. The second pusrpose is to analyze indirect influence of towards tax avoidance through book tax differences. The research is conducted to companies enlisted in Indonesian Stock Exchange and belongs to LQ45 during 2013 to 2015. The number of companies sample taken by purposive sampling is 23 corporations, therefore total observation is 69 observations. The acquired data analysed by path analysis. This research conclude that conservatism accounting practice significantly influence book tax difference practice but did not influence tax avoidance. Conservatism accounting practice is also has no influence towards tax avoidance committed by book tax differences. This book tax difference is only significantly influential to commit tax avoidance. This research can contribute in taxation field as input in tax planning formulation.
CATALINA SORIANA SITNIKOV
Full Text Available Corporations are at present operating in demanding and highly unsure periods, facing a mixture of increased macroeconomic need, competitive and capital market dangers, and in many cases, the prospect for significant technical and regulative gap. Throughout these demanding and highly unsure times, the corporations must pay particular attention to corporate strategy. In present times, corporate strategy must be perceived and used as a function of various fields, covers, and characters as well as a highly interactive system. For the corporation's strategy to become a competitive advantage is necessary to understand and also to integrate it in a holistic model to ensure sustainable progress of corporation activities under the optimum conditions of profitability. The model proposed in this paper is aimed at integrating the two strategic models, Hoshin Kanri and Integrated Strategy Model, as well as their consolidation with the principles of sound corporate governance set out by the OECD.
... 26 Internal Revenue 10 2010-04-01 2010-04-01 false Additional foreign tax credit in year of... Foreign Corporations § 1.960-4 Additional foreign tax credit in year of receipt of previously taxed... inclusion either chose to claim a foreign tax credit as provided in section 901 or did not pay or accrue any...
Full Text Available Periodically, tax systems need major reforms to remove the “barnacles” that accumulate under the short-term pressures of political expediency and to adapt to the long-term forces of technological and economic change. The current fiscal and economic problems that confront the provinces require an assessment of much-needed reforms. Raising tax revenue imposes large costs on our society, not only because of the administration and compliance costs of collecting taxes, but because taxes distort economic decisions in the private sector. This is especially true of provincial corporate income taxes. Taxing highly mobile corporate capital and corporate profits encourages firms to shift their investments and profits across provincial and international boundaries. The provinces would enjoy significant boosts to economic growth and efficiency gains by enacting a revenue-neutral switch from corporate to sales or personal income taxes. For Alberta, such a shift would yield up to $40 per dollar of tax revenue shifted from corporate to personal income taxes; for fiscal year 2011-12, this would amount to a percapita welfare gain of roughly $19,000. Other options for tax reform are also discussed in this paper, including the adoption of a penny tax to the GST to fund infrastructure spending by municipalities. However, we think this would saddle the private sector with significant compliance costs and create major economic distortions between neighbouring municipalities by creating an incentive to shop where the penny tax proposal was not adopted. In surveying the most pressing tax reform issues facing Canada, we offer policymakers a firm basis for coming to grips with them, so they can treat tax dollars with the care and foresight Canadians expect.
partly fall on investment and thus workers in the former country. This tax exporting mechanism introduces a scope for corporate taxes, which is not present in standard models of international taxation. Accounting for the internal capital markets of multinational firms thus represents a way to resolve......This paper develops a theoretical model of corporate taxation in the presence of financially integrated multinational firms. Under the assumption that multinational firms at least partly use internal loans to finance foreign investment, we find that the optimal corporate tax rate is positive from...... the perspective of a small, open economy. This finding contrasts the standard result that the optimal source based capital tax is zero. Intuitively, to the extent that multinational firms finance investment in country i with loans from affiliates in country j, the burden of corporate taxes in the latter country...
Bertinelli, Luisito; Bourgain, Arnaud
This paper contributes to measuring the influence of business (and tax) law reforms on sub-Saharan African countries tax mobilization ability. Relying on a new business law reform indicator, our results validate the significant impact of corporate law modernization on governmental revenue, and unearth a complementary effect between business and tax law reforms.
...--INCOME TAXES 0 Paragraph 1. The authority citation for part 1 continues to read, in part, as follows... proceeds and the standard for allocating net income and proceeds that are attributable to a prohibited tax... stock and purports to aid the S corporation and its shareholders in avoiding taxable income. The tax...
... 26 Internal Revenue 10 2010-04-01 2010-04-01 false Definition of controlled foreign corporation. 1...) INCOME TAX (CONTINUED) INCOME TAXES Controlled Foreign Corporations § 1.957-1 Definition of controlled foreign corporation. (a) In general. The term controlled foreign corporation means any foreign corporation...
Emilia Cornelia STOICA
Full Text Available Tax optimization, often called legal tax evasion is the use of methods and techniques that are within the law, in order to reduce or even cancel the tax liability. To achieve such an approach, the taxpayer or his advisers must know in depth the tax law - and by extension, the financial and administrative law - and, moreover, must be functional tax jurisdictions which allow the use of appropriate assemblies. The recent leasks, as WikiLeaks, LuxLeaks, SwissLeaks, Panama Papers etc. on financial flows to tax havens highlight the far-reaching unprecedented evasion and tax fraud, both in the amounts involved - trillions of dollars - and sophisticated assemblies used primarily by multinational companies to the detriment of the public finances of Member territory headquarters and branches which are located and, therefore, detrimental economic and social life of those countries. Tax evasion is based on legal mechanisms which, combined together in the montages of increasingly complex, allowing operators, mostly multinational legal entities to circumvent national tax law and not pay the taxes due. The border between tax optimization, tax evasion and fraud is very thin, optimization using various legal methods to reduce the tax owed, whereas tax evasion using illegal means, which covered crime. Tax evasion reveals either optimize or fraud. There is a significant international dimension of tax evasion because it is favored by multinational corporations operating conditions.
Full Text Available Tax planning is complex of measures,consisting in the reduction of tax payments under the law. Tax planning at the enterprise starts from the initial structuring of businesses and activities and can be carried out both at entity level (corporate and the individual (individual. Compared to tax evasion, tax planning is performed only under the law by avoiding taxes. Avoiding or reducing taxes is possible by organizing activities in such a way that the law allows reducing the tax base or tax rate. Optimization of tax payments is possible by organizing the work in such a way, so as the legislation avoids or reduces the tax base,tax rates and tax incentives application.
The consolidated financial statements of Saskatchewan Energy Holdings Ltd. (formerly Saskatchewan Energy Corporation) as of December 31, 1990, and the consolidated statements of earnings and retained earnings and changes in cash position for the year are presented. Data include an inventory of supplies, natural gas in storage, property, plant and equipment. Financial statements are also presented for the year ending December 31, 1989, with comparative figures for the seven months ending December 31, 1988.
The consolidated financial statements of Saskatchewan Energy Holdings Ltd. (formerly Saskatchewan Energy Corporation) as of December 31, 1990, and the consolidated statements of earnings and retained earnings and changes in cash position for the year are presented. Data include an inventory of supplies, natural gas in storage, property, plant and equipment. Financial statements are also presented for the year ending December 31, 1989, with comparative figures for the seven months ending December 31, 1988
This work provides basic information about consolidation and consolidated financial statements. In the beginning there are definisions of the members of the group under discussion and their relationship. Hereafter concepts of consolidation, accounting methods and methods of consolidation are discussed. It also compares approach of different accounting systems to consolidation.
Vesterø Jensen, Carsten; Nielsen, Søren Bo
of Greenland's tax system, the paper's special focus will be on the corporate tax systemand its interplay with personal taxation, as well on as the system of import duties. In particular, wecarry out computations of effective marginal and average corporate tax rates, as well as average effectivetax burdens...... on consumption, labour income and capital income, and compare these to similarmeasures for EU countries. In addition, we outline how Greenland's economic policy in other areasinterferes with tax policy. Especially fishery regulation, management of government-owned companies,and housing policy have major...
Jack M. Mintz
Full Text Available This paper addresses in depth the impact of both corporate taxes and royalties on the decision to invest in the oil and gas sector for British Columbia, Alberta, Saskatchewan, Nova Scotia and Newfoundland & Labrador and in comparison to Texas. Similar to Chen and Mintz (2009, we estimate the marginal effective tax rate on capital for the oil and gas sector, comparable to other sectors in the economy. In our assessment, we include federal and provincial corporate income taxes, sales taxes on capital purchases and other capital-related taxes in our assessment such as severance taxes and royalties. Except for oil and gas investments in Nova Scotia and Newfoundland & Labrador offshore developments, oil and gas investments bear a higher tax burden compared to other industries in Canada. In other words, oil and gas investments are generally not “subsidized” but bear a higher level of taxes and royalties on investment compared to other industries.
....537-3 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES (CONTINUED) Corporations Used to Avoid Income Tax on Shareholders § 1.537-3 Business... securities of another corporation is not, of itself, to be regarded as employment of the earnings and profits...
... the corporation for which the election is in effect. (2) Corporate level taxes. An S corporation is... recapture amounts. (b) Computation of corporate taxable income. The taxable income of an S corporation is... derived from an S corporation are made by the corporation. For example, elections of methods of accounting...
... 26 Internal Revenue 9 2010-04-01 2010-04-01 false Classification and manner of taxing alien... (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Nonresident Aliens and Foreign Corporations § 1.871-1 Classification and manner of taxing alien individuals. (a) Classes of aliens. For purposes of the income tax...
Tax havens have attracted increasing attention from policy-makers in recent years. This paper provides an overview of a growing body of research that analyses the consequences and determinants of the existence of tax-haven countries. For instance, recent evidence suggests that tax havens tend to have stronger governance institutions than comparable non-haven countries. Most importantly, tax havens provide opportunities for tax planning by multinational corporations. It is often argued that ta...
Adrian Mihai INCEU
Full Text Available In this study we make an analysis of the major aspects concerning the tax policy in the EU countries. For revealing a global image on tax policy within the EU we have to consider in our analysis the overall tax burden, the structure of tax revenues (direct taxation, indirect taxation, social contributions and the main types of taxes: corporate tax, personal tax, consumption tax. This article is based on a dynamic analysis of taxation using as a main tools descriptive and empirical analysis. The empirical study tries to determinate the correlation between tax burden and the implicit tax rate on capital and business income, consumption and labor through the panel methodology. This analysis is based the data delivered by the EUROSTAT. The main results obtained from the empirical study is that there are major differences concerning the correlation between total taxes as percentage of GDP and the implicit tax rate of profit, consumption and labor.
... business corporation among the shareholders of such corporation. Section 58(d)(2) provides rules for the... so computed are treated as items of tax preference of the shareholders of such corporation and not as... items of tax preference specified in section 57(a)(1) and § 1.57-1(a) (excess investment interest) and...
This report contains information on the effects of additional tax incentives for the petroleum production industry. It considers the effects of additional incentives on petroleum production and federal revenues, the federal tax burden on new domestic petroleum production investments under current law, and the comparative tax treatment of petroleum production investments in the United States and other nations
... also subject to the tax avoidance rules of § 1.897-6T(c). (b) Distributions by domestic corporations—(1... TAX (CONTINUED) INCOME TAXES Miscellaneous Provisions § 1.897-5T Corporate distributions (temporary...) Any U.S. tax paid by or on behalf of the distributee with respect to the distribution. (2...
Rossing, Christian Plesner; Riise Johansen, Thomas; Pearson, Thomas C.
-driven discipline to be dealt with by accounting and tax experts. Instead, MNEs face the task of establishing a complex fit with their environment beyond the typical stakeholders with transfer pricing, i.e. tax authorities. These include government officials, tax activists, and consumers who voice......This paper examines the case of Starbucks’ UK branch, which became subject to massive public criticism over alleged tax avoidance. Despite Starbucks arguing that its transfer pricing practices were in full compliance with regulatory requirements, public pressure for higher corporate tax payments...... led Starbucks to increase its UK tax payment on transfer pricing income beyond regulatory requirements. This case study suggests that MNE tax behavior on international transfer pricing is not strictly a matter of compliance with formal tax regulation. We demonstrate the way an MNE attempts to re...
Full Text Available Alberta enjoys a reputation as a fiercely competitive jurisdiction when it comes to tax rates. But the reality is that the province can do better with a tax mix that has greater emphasis on consumption, rather than income tax levies. While Alberta has a personal tax advantage compared to other Canadian jurisdictions — but not the United States — it relies most heavily on income taxes and non-resource revenues that impinges on investment and saving. Taxes on new investment in Alberta’s non-resource sectors are no better than average, compared to other countries in the Organization for Economic Cooperation and Development, or OECD, so it is not exceptionally attractive to many different kinds of investors. And Alberta’s corporate income tax rate is not much more competitive than the world average for manufacturing and service companies. By introducing the Harmonized Sales Tax with a provincial rate of 8 per cent (in addition to the federal 5 per cent rate, Alberta has the ability to make its tax system more competitive. An HST would even allow the province to entirely eliminate income tax for the majority of families. And because the HST would be easily administered using the same collection mechanisms that already exist for the GST, implementing a new Alberta HST could be done relatively smoothly and with minimal additional administration costs. Adopting an Alberta HST is the simplest, most efficient and fairest way to reform the provincial tax system, and will deliver noticeable benefits to Albertans, most visibly in the form of significant income tax relief. It would enable the province to raise the income-tax exemption from $17,593 to $57,250, making it possible for couples to earn up to $114,500 free of any provincial income taxes. In addition, the province could lower income tax rates for income over that amount from 10 to nine per cent. And with the revenue from the HST, Alberta would have the capacity to lower its general corporate
The objective of Phase 3 of the Prototypical Rod consolidation Demonstration Project (PRCDP) was to procure, fabricate, assemble, and test the Prototypical Rod consolidation System as described in the NUS Phase 2 Final Design Report. This effort required providing the materials, components, and fabricated parts which makes up all of the system equipment. In addition, it included the assembly, installation, and setup of this equipment at the Cold Test Facility. During the Phase 3 effort the system was tested on a component, subsystem, and system level. This volume 1, discusses the PRCDP Phase 3 Test Program that was conducted by the HALLIBURTON NUS Environmental Corporation under contract AC07-86ID12651 with the United States Department of Energy. This document, Volume 1, Book 2 discusses the following topics: Fuel Rod Extraction System Test Results and Analysis Reports and Clamping Table Test Results and Analysis Reports
The objective of Phase 3 of the Prototypical Rod consolidation Demonstration Project (PRCDP) was to procure, fabricate, assemble, and test the Prototypical Rod consolidation System as described in the NUS Phase 2 Final Design Report. This effort required providing the materials, components, and fabricated parts which makes up all of the system equipment. In addition, it included the assembly, installation, and setup of this equipment at the Cold Test Facility. During the Phase 3 effort the system was tested on a component, subsystem, and system level. This volume 1, discusses the PRCDP Phase 3 Test Program that was conducted by the HALLIBURTON NUS Environmental Corporation under contract AC07-86ID12651 with the United States Department of Energy. This document, Volume 1, Book 1 discusses the following topics: the background of the project; test program description; summary of tests and test results; problem evaluation; functional requirements confirmation; recommendations; and completed test documentation for tests performed in Phase 3
The objective of Phase 3 of the Prototypical Rod consolidation Demonstration Project (PRCDP) was to procure, fabricate, assemble, and test the Prototypical Rod consolidation System as described in the NUS Phase 2 Final Design Report. This effort required providing the materials, components, and fabricated parts which makes up all of the system equipment. In addition, it included the assembly, installation, and setup of this equipment at the Cold Test Facility. During the Phase 3 effort the system was tested on a component, subsystem, and system level. This volume 1, discusses the PRCDP Phase 3 Test Program that was conducted by the HALLIBURTON NUS Environmental Corporation under contract AC07-86ID12651 with the United States Department of Energy. This document, Volume 1, Book 9 discusses the following topics: Integrated System Normal Operations Test Results and Analysis Report; Integrated System Off-Normal Operations Test Results and Analysis Report; and Integrated System Maintenance Operations Test Results and Analysis Report
The objective of Phase 3 of the Prototypical Rod consolidation Demonstration Project (PRCDP) was to procure, fabricate, assemble, and test the Prototypical Rod consolidation System as described in the NUS Phase 2 Final Design Report. This effort required providing the materials, components, and fabricated parts which makes up all of the system equipment. In addition, it included the assembly, installation, and setup of this equipment at the Cold Test Facility. During the Phase 3 effort the system was tested on a component, subsystem, and system level. This volume 1, discusses the PRCDP Phase 3 Test Program that was conducted by the HALLIBURTON NUS Environmental Corporation under contract AC07-86ID12651 with the United States Department of Energy. This document, Volume 1, Book 8 discusses Control System SOT Tests Results and Analysis Report. This is a continuation of Book 7
King, Patricia H.; Morgan, Samuel D.
Surveys of community college graduates and of certified public accountants were made to determine employment relevance of the accounting curriculum. The article suggests topics from the study data which should be included in taxation courses, e.g., income tax accounting, corporate taxation accounting, and tax law. (MF)
The result of the global integration of the world economy are globally operating corporations. Multinational enterprises operate in different countries whose economic policies are different from each other. These differences have considerable impact on tax policy. Taxes are the subject of conflicting interests of the international business and tax policy. One of the current objectives of the MNEs is to reduce the total cost in order to achieving competitive advantage in the global market as w...
... 26 Internal Revenue 10 2010-04-01 2010-04-01 false Withholding by a China Trade Act corporation. 1...) INCOME TAX (CONTINUED) INCOME TAXES China Trade Act Corporations § 1.943-1 Withholding by a China Trade Act corporation. Dividends paid by a China Trade Act corporation to a nonresident alien individual...
... (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES China Trade Act Corporations § 1.941-1 Special deduction for China Trade Act corporations. In addition to the deductions from taxable income otherwise allowed such a corporation, a China Trade Act corporation is, under certain conditions, allowed an additional deduction in...
... 26 Internal Revenue 11 2010-04-01 2010-04-01 true Taxable year of S corporation. 1.1378-1 Section... TAX (CONTINUED) INCOME TAXES Small Business Corporations and Their Shareholders § 1.1378-1 Taxable year of S corporation. (a) In general. The taxable year of an S corporation must be a permitted year. A...
Full Text Available The recent financial crises has revealed the need to improve and ensure the stability of the financial sector to reduce negative externalities, to ensure fair and substantial contribution of the financial sector to the public finances and the need to consolidate public finance. All those needs represent substantial arguments for the discussion about the introduction of financial sector taxation. There are discussed in the paper two possible schemes of financial sector taxation – financial transaction tax and financial activities tax. The aim of the paper is to research the possibility of the introduction of financial sector taxation, to discuss the pros and cons of two major candidates on financial sector taxation – financial transaction tax and financial activities tax and to suggest the possible candidate suitable for the implementation on the EU level. Financial transaction tax represents the tool suitable mainly on global level, for only in that case enables generate sufficient financial resources. From EU point of view is considered as less suitable, for it bears the risk of reallocation. Therefore the introduction of financial activities tax on EU level is considered as a better solution for the financial sector taxation in the EU, for financial sector is exempted from value added tax. With respect to the fact, that the implementation would represent the innovative approach to the financial sector taxation, there are no empirical proves and therefore this could be the subject of further research.
Runcev, Nikolce; Krstev, Boris; Golomeova, Mirjana
In contemporary economic performance, corporate governance is considered an essential prerequisite in building a successful system for creating an attractive investment climate, which is characterized by competing companies oriented and efficient financial markets. Good corporate governance is based on principles of transparency, bias, efficiency, timeliness, completeness and accuracy of information at all levels of management. Companies with good corporate governance and afford easier acc...
... common carrier providing interstate rail service, primarily for Dura-Bond, without first obtaining... Industrial Railroad, Inc.--Acquisition and Operation Exemption--Consolidated Rail Corporation Turtle Creek... Consolidated Rail Corporation (Conrail) and to operate approximately 9.8 miles of rail line between milepost 0...
M.F. de Wilde (Maarten)
markdownabstract__Abstract__ The current international corporate tax regime for taxing the business proceeds of firms operates arbitrarily. The aggregates of the nation states’ international corporate tax systems seem to distort a global efficient allocation of resources. The current model of
Ewert, Ralf; Niemann, Rainer
We derive determinants of tax avoidance by means of a multi-task principal-agent model. We extend prevailing models by integrating both corporate and individual income taxation as well as by including tax planning effort in the agentâ€™s action portfolio. Our model shows novel and apparently paradoxical results regarding the impact of increased tax rates on efforts, risks, and incentive schemes. First, the principalâ€™s after-tax profit can increase with a higher corporate tax rate. Second, t...
Chamber of Commerce (1983) for data on differences in coverage by industry.) 1 Some versions of the tax cap would eliminate the ability of employers to deduct premium payments above the tax cap. While this would provide a more immediate stimulus to employers to change the fringe-benefit/wage mixture than the alternative, the long-run incidence would still remain on the employee. Further, since about 25 percent of all workers in the United States are employed either by government or by not-for-profit corporations who do not pay corporate taxes,
Waddock, Sandra; Rasche, Andreas
We define and discuss the concept of corporate responsibility. We suggest that corporate responsibility has some unique characteristics, which makes it different from earlier conceptions of corporate social responsibility. Our discussion further shows commonalities and differences between corporate...... responsibility and related concepts, such as corporate citizenship and business ethics. We also outline some ways in which corporations have implemented corporate responsibility in practice....
Tax compliance costs of consumption tax are relatively high. Tax compliance costs for self-assessment taxpayers are high, and for withholding income taxpayers, the compliance costs are small. That is to say, characteristics of tax compliance costs for income tax and consumption tax are various. And also characteristics of tax consciousness for income tax and consumption tax are many and various. The features of this paper are to clarify characteristics of tax compliance costs and tax consciou...
This article, acknowledging the potentially important general attractions of the allowance for corporate equity (ACE), looks at some of its more specific implications. On corporate taxes, the article looks at questions about the implied revenue-neutral rate of corporation tax (and redistribution of the tax burden); the effects on cash flow of both government and companies; and what would become a crucially important charge on capital gains. On income tax, the article comments on the implicati...
Florian Heider; Alexander Ljungqvist
We use a natural experiment in the form of 121 staggered changes in corporate income tax rates across U.S. states to show that tax considerations are a first-order determinant of firms' capital structure choices. Over the period 1990-2011, firms increase long-term leverage by 104 basis points on average (or $32.5 million in extra debt) in response to an average tax increase of 131 basis points. Contrary to static trade-off theory, the tax sensitivity of leverage is asymmetric: firms do not re...
... 26 Internal Revenue 13 2010-04-01 2010-04-01 false Acquiring corporation. 1.9002-6 Section 1.9002... (CONTINUED) INCOME TAXES General Actuarial Valuations § 1.9002-6 Acquiring corporation. Section 5(d) of the... corporation by another corporation in a distribution or transfer described in section 381(a) of the Code the...
Ekins, P.; Andersen, Mikael Skou; Vos, H.
EXECUTIVE SUMMARY1.Although the 5th Environmental Action Programme of the EU in 1992 recommended the greater use of economic instruments such as environmental taxes, there has been little progress in their use since then at the EU level. At Member State level, however, there has been a continuing...... increase in the use of environmental taxes over the last decade, which has accelerated in the last 5-6 years. This is primarily apparent in Scandinavia, but it is also noticeable in Austria, Belgium, France, Germany, The Netherlands and the United Kingdom.2.Evaluation studies of 16 environmental taxes have...... been identified and reviewed in this report. Within the limitations of the studies, it appears that these taxes have been environmentally effective (achieving their environmental objectives) and they seem to have achieved such objectives at reasonable cost. Examples of particularly successful taxes...
Deacon, R.; DeCanio, S.; Frech, H.E. III; Johnson, M.B.
In this book, the authors have produced an analysis of state energy taxation. Their factual findings are of particular relevance to California and other states in their consideration of severance taxes on oil production. It turns out, for example, that while California's tax burden on oil producers is slightly below average among the states, the combined revenues from taxes and royalties (expressed as a percent of the value of production) indicate that California is not easy on oil producers. In fact, California's oil tax system appears to be particularly well suited to its oil industry. Much of the production in the state is relatively high-cost and economically marginal. The state must tread carefully in taxing this production, lest it force it to be curtailed
Nielsen, Søren Bo
This paper attempts to place industrial foundations (IFs in the following; similar to trusts) in the tax system. An industrial foundation is a private foundation that holds a voting majority in a joint stock corporation. These IFs are probably more prevalent in Denmark than in any other country......? The paper explores the implications of treating IFs as high‐income earners (wealthy individuals) and draws the conclusion that in the current system, IFs are very leniently taxed relative to that benchmark. Lenient tax treatment relative to the norm is regularly interpreted as tax expenditures; the usual...
Spengel, Christoph; Heckemeyer, Jost Henrich; Nusser, Hannah; Klar, Oliver; Streif, Frank
[Introduction] The tax planning strategies of multinational corporations have been a key issue on the international policy agenda for some years now. Both the European Commission and the OECD are currently working on anti-avoidance measures to curb international profit shifting of multinational companies. These initiatives against so-called aggressive tax planning have mainly been pushed by anecdotal evidence on tax avoidance strategies of some of the currently most valuable and fast growing ...
There are two essential primary purposes for this thesis. The first has been to highlight the phenomena Tax Havens with its economical impact on other countries outlined in chapter two. Firstly the concept of tax havens is presented based on the OECD definition. Secondly the secrecy legislation, regulation and the corporate structures which tax havens offer to foreign investors and firms are given with their significance for other states. Thirdly, the ways tax havens are used b...
... amendments to the Income Tax Regulations (26 CFR part 1) under section 6012 relating to the returns of income... every person liable for income tax to make the returns required by regulation. Section 6012 requires... corporations to file a schedule disclosing uncertain tax positions related to the tax return as required by the...
... Section 1.534-3 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES (CONTINUED) Corporations Used to Avoid Income Tax on Shareholders § 1.534... to the Tax Court, if the taxpayer desires to submit such statement. See paragraph (b) of § 1.534-2...
This book is designed to be a quick reference work on California State taxes. With this in mind, the amount of detail is kept to a minimum by assuming that the reader has some knowledge of Federal taxes that are generally similar to the major California taxes (or that he has access to the wealth of information about Federal taxes that is readily available). The book explains the four major California taxes (personal income tax, tax on corporate income, inheritance tax, and gift tax), whenever possible, in terms of the comparable Federal taxes. Differences between the two laws are pointed out, and cross-references make it possible to trace from a given provision in one law to a comparable provision in the other. Special attention is given to subjects peculiar to the California law. In addition to the major State taxes, the book provides general information about other taxes levied by the State. Property taxes are also discussed briefly, because of their statewide impact, although they are imposed by local governmental units.
Full Text Available The aim of this work is structuring categorical-conceptual apparatus of the of the tax losses phenomenon in the state budgetary resources, namely clarification of the concepts of “tax gap”, “tax expenditures”, “tax losses”, as well as the quantification of tax losses of the Consolidated budget of Ukraine. Methodology. Most modern scholars interpret the tax gaps as the amount of taxes that were not received with the budget as a result of shadow economy, tax evasion and the existence of tax debt. However, considerable asymmetry of the tax component of the state budgetary resources also arises due to budget losses of all levels as a result of providing tax exemptions. In modern economic literature such losses are considered as tax expenditures. We consider tax losses a generalizing concept including potential amounts of tax revenues that the state and local budgets have not received as a result of the existence of the phenomenon of “tax gaps” and “tax expenditures”, and the amount of losses of the state budgetary resources in terms of their tax component is equal to the sum total of tax exemptions provided, unsettled tax debt of economic agents and the loss of tax revenue due to the operation of shadow economy. The study is based on the analysis of tax losses of budgetary resources of Ukraine during the period of time from 2004 to 2014. The results of the study showed enormous losses of budgetary resources in Ukraine due to the imperfection of the tax system, spread of undisclosed operations, tax evasion, and inefficient fiscal policy implementation. The Consolidated budget loses the amounts of monetary funds, equal to an average of 53.30% of actual revenue over the period studied. Total tax losses of the state budgetary resources in 2014 are equivalent to the total actual expenditures of the Consolidated budget of Ukraine on social protection and social security, defense, public order, security and judicial authorities. Even
markdownabstract__Abstract__ The current international corporate tax regime for taxing the business proceeds of firms operates arbitrarily. The aggregates of the nation states’ international corporate tax systems seem to distort a global efficient allocation of resources. The current model of corporate taxation finds its origins in the 1920s. It well suited the economic realities of the early days of international trade and commerce; the times when international business primarily revolved ar...
Kazuki Onji; David Vera
When positive and negative income are treated asymmetrically under a corporate income tax (CIT) without allowance for group taxation, a group of affi liated corporations may engage in tax avoidance by shifting income from profi table to unprofi table subsidiaries for the sole purpose of minimising the sum of tax liabilities of the group members. The aim of this paper is to offer systematic evidence on the behavioural response to a tax penalty that arises from doing business in multiple entiti...
... Trade Act corporations. 1.941-2 Section 1.941-2 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES China Trade Act Corporations § 1.941-2 Meaning of terms used in connection with China Trade Act corporations. (a) A China Trade Act corporation...
林旭; 苏宏通; 朱凯; 陈信元
文章分析了税负对公司投资决策的影响.与民营控股股东不同,作为国有企业的最终股东,政府不仅可以获得与股权投资相关的收益,而且可以获得独占性的税收,独占性的税收收入越高,政府控股的私有收益越大.因此,国有企业在投资决策时不仅考虑税后现金流量,而且会关注相关的预期税负,这提高了国有企业的投资?预期税负敏感性;政府对税收的需求越大,国有企业的投资?预期税负敏感性越高.实证结果表明:(1)与民营控股上市公司相比,国有控股上市公司的投资与预期税负之间的负相关关系更弱;(2)随着注册地基础设施投资回报率的增加,国有控股上市公司的投资与预期税负之间的负相关性显著下降.因此,最大化税收收入也是国有企业投资决策的重要考虑因素.文章为我国股权结构在公司财务决策中的作用提供了新的研究视角.%Based on the unique ownership structure of stated-owned enterprises(SOEs)in China,we examine the influence of expected tax burden on corporate investment decisions. Prior researches indicate that the efficiency of SOEs is lower than non-SOEs,which is proved in stock market as well(Wu,2012;Yao and Zhang,2001). There are two explanations for this phenomenon:property right view and policy burden view. The property right view believes that the main reason for the SOEs' low efficiency is unclear definition of property rights in SOEs(Zhang,1997). However,the policy burden view instead argues that excessive social responsibility and lack of reasonable market evaluation index lead to the low efficiency of SOEs(Lin et al, 1998). In this paper,we find that SOEs care tax when they make investment decisions,which is consistent with the policy burden view. We also indicate that the main reason for this phenomenon is a unique agency prob-lem caused by the fact that the state is the controller of SOEs,which is also consistent with the property
Lowering gasoline consumption is the quickest way to increase energy security and reduce emissions. Three policy initiatives designed to meet such goals are current contenders in Washington, DC: higher gasoline taxes; higher CAFE (Corporate Average Fuel Economy) standards; and an auto registration fee scheme with gas-guzzler taxes and gas-sipper subsidies. Any of these options will give us a more fuel-efficient auto fleet. The author feels, however, the gasoline tax holds several advantages: it is fair, flexible, smart, and honest. But he notes that he is proposing a substantial increase in the federal gasoline tax. Real commitment would translate into an additional 50 cents a gallon at the pump. While the concept of increasing taxes at the federal level is unpopular with voters and, thus, with elected officials, there are attractive ways to recycle the $50 billion in annual revenues that higher gas taxes would produce
the FTD system. These deposits included such tax receipts as withheld personal income tax, corporate income tax , and social security, excise...Greater than or 159,500 2,733 4.2 571,000 222,000 equal to $25,000 Total $1,279,000 Corporate Income Tax Payments Projected Sampling Average Number...than or 130,600 2,215 2.7 292,000 80,000 equal to $25,000 Total $779,000 Corporate Income Tax Payments Projected Sampling Average Number Average
This paper analyzes the effect of federal corporate income tax incentives on coal and nuclear power developments. It estimates (1) the magnitudes of tax incentives in relationship to utility costs, (2) the relative magnitude of benefits going to coal and nuclear facilities, and (3) the influence which the time paths of tax payments and after-tax net income have upon possible incentives for premature construction and excess capacity. Utility planners currently believe that nuclear power enjoys an after-tax competitive advantage over coal plants. Investigation of investment-related credits, deductions, and exclusions in the Internal Revenue Code shows that nuclear power enjoys a more favorable tax subsidy because of its greater capital intensity. In the absence of tax subsidies, no utility would prefer nuclear power to coal generation. Tax changes now under consideration could increase the tax benefits to both without disturbing the differential advantage held by nuclear power. 43 references, 2 figures, 4 tables
Full Text Available Canada is losing its edge in the competition for global capital. After a decade of remarkable progress in reducing the tax burden on business investment — moving from one of the least tax-competitive jurisdictions among its industrialized peers in 2000, to ranking in the middle of the pack by 2011 — Canada has slipped by largely standing still. As other countries in our peer group have continued to reform their business-tax regimes, they have surpassed Canada, which has slid from having the 19th-highest tax burden on investments by medium-sized and large corporations in 2012, to the 14th-highest among 34 OECD countries in 2014. Even more worrying is that Canada’s political currents are running the wrong way, with a few provinces having increased taxes on capital in recent years and a number of politicians today floating the possibility of even higher business taxes to help address budgetary strains. But the right approach to raising tax revenue and improving the economy is quite the opposite: lowering rates and broadening the tax base by making Canadian jurisdictions even more attractive to corporate investment. An important step towards that would be for federal and provincial governments to reduce targeted tax assistance and to level the tax field for all industries and sizes of businesses, ending the preferential treatment of favoured industries and small enterprises. In addition, those provinces that have yet to harmonize their sales tax with the federal GST should do so, or at least consider adopting a quasi-refund system that would relieve the provincial sales tax on capital inputs. Alberta, with no sales tax, could become more competitive by adopting an HST and using the proceeds to reduce personal and corporate taxes. Finally, Canada would do much better to mandate a uniform corporate tax rate, with an 11 per cent federal rate and a nine per cent average provincial rate. This would encourage capital investment and attract corporate
Lai, Tat-kei; Ng, Travis
The agency model of Chetty and Saez (2010) predicts that firms with stronger shareholder rights and a better market for corporate control are more responsive to a dividend tax cut in their dividend and investment policies. We test these predictions by exploiting the sudden and significant dividend...... tax cut following the Jobs and Growth Tax Relief Reconciliation Act of 2003 and the pre-tax cut variations in the firms’ governance indexes (the Corporate Governance Index constructed by Gompers, Ishii, and Metrick, 2003, and the Entrenchment Index constructed by Bebchuk, Cohen, and Ferrel, 2009). We...
... Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Additions to the Tax, Additional Amounts, and Assessable Penalties § 1.6655-4 Large... not to be taken into account and the taxable income of a corporation for any taxable year during the...
There are provisions in Income Tax Law No. 193 and Corporate Tax Law No. 5520 on the nature and taxation of income that real and legal persons acquire from real estate sales. There have been many changes in these provisions over time, but the changes made didnt meet the needs, and they distorted the systematic structure of the Laws. For these and similar reasons, the income tax law draft has been prepared based on Income Tax Law and Corporate Tax Law. With the draft, the Income Tax Law No. 19...
Mathur, Aparna; Morris, Adele C.
This paper analyzes the distributional implications of an illustrative $15 carbon tax imposed in 2010 on carbon in fossil fuels. We analyze its incidence across income classes and regions, both in isolation and when combined with measures that apply the carbon tax revenue to lowering other distortionary taxes in the economy. Consistent with earlier findings, we find that a carbon tax is regressive. Using tax swap simulations, we then subtract the burden of other taxes the carbon tax revenue could displace, and compute the net effect on households under three assumptions about how capital and labor income might be distributed. - Highlights: • Shows that a carbon tax by itself is regressive. • Burden of a carbon tax may be offset partly with a corporate tax swap. • Higher income households face negative tax rates under corporate tax swap. • Corporate tax swap results in wider regional variations in burden than labor tax swaps. • Adding sources side incidence of carbon tax makes tax less regressive
... (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Domestic International Sales Corporations § 1.993-5... international sales corporation described in paragraph (b) of this section, (ii) It is a real property holding...) Foreign international sales corporation—(1) In general. A foreign corporation is a foreign international...
... Jobs at RAND Media Resources Congressional Resources Doing Business with RAND Supporting RAND Educational Opportunities Alumni Association Follow RAND Corporation on Facebook RAND Corporation on Twitter RAND Corporation on LinkedIn ...
... paragraph (c)(5) of this section (relating to certain tax avoidance transactions), the nature of the assets... THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Taxable Year for Which Items of Gross... such liabilities (including any tax liabilities incurred by the corporation on the distribution), the...
Klijn, F.; Slikker, M.
We study a location-inventory model to analyze the impact of consolidation of distribution centers on facility and inventory costs. We introduce a cooperative game and show that when demand processes are i.i.d. the core is non-empty, i.e., consolidation allows for a stable division of the minimal
The objective of Phase 3 of the Prototypical Rod consolidation Demonstration Project (PRCDP) was to procure, fabricate, assemble, and test the Prototypical Rod consolidation System as described in the NUS Phase 2 Final Design Report. This effort required providing the materials, components, and fabricated parts which makes up all of the system equipment. In addition, it included the assembly, installation, and setup of this equipment at the Cold Test Facility. During the Phase 3 effort the system was tested on a component, subsystem, and system level. This volume 1, discusses the PRCDP Phase 3 Test Program that was conducted by the HALLIBURTON NUS Environmental Corporation under contract AC07-86ID12651 with the United States Department of Energy. This document, Volume 1, Book 4 discusses the following topics: Rod Compaction/Loading System Test Results and Analysis Report; Waste Collection System Test Results and Analysis Report; Waste Container Transfer Fixture Test Results and Analysis Report; Staging and Cutting Table Test Results and Analysis Report; and Upper Cutting System Test Results and Analysis Report
The objective of Phase 3 of the Prototypical Rod consolidation Demonstration Project (PRCDP) was to procure, fabricate, assemble, and test the Prototypical Rod consolidation System as described in the NUS Phase 2 Final Design Report. This effort required providing the materials, components, and fabricated parts which makes up all of the system equipment. In addition, it included the assembly, installation, and setup of this equipment at the Cold Test Facility. During the Phase 3 effort the system was tested on a component, subsystem, and system level. This volume 1, discusses the PRCDP Phase 3 Test Program that was conducted by the HALLIBURTON NUS Environmental Corporation under contract AC07-86ID12651 with the United States Department of Energy. This document, Volume 1, Book 5 discusses the following topics: Lower Cutting System Test Results and Analysis Report; NFBC Loading System Test Results and Analysis Report; Robotic Bridge Transporter Test Results and Analysis Report; RM-10A Remotec Manipulator Test Results and Analysis Report; and Manipulator Transporter Test Results and Analysis Report
... 12 Banks and Banking 6 2010-01-01 2010-01-01 false Farm Credit Leasing Services Corporation. 614... OPERATIONS Lending and Leasing Limits § 614.4356 Farm Credit Leasing Services Corporation. The Farm Credit Leasing Services Corporation may enter into a lease agreement with a lessee if the consolidated amount of...
Rochester Gas and Electric Corporation (RG ampersand E) has been involved in two separate fuel consolidation demonstration programs. One of those programs resulted in identifying some problems that may be resolved in consolidation hardware compaction and storage in order for consolidation to be attractive. In conjunction with the Electric Power Research Institute (EPRI), a study was recently performed on hardware compaction and storage. Consolidation is probably not a commercial alternative at this point in time because there are still several problems that must be resolved. There are some potential advantages of fuel consolidation. Consolidation has attractive economics and can minimize the institutional impacts of expanding spent fuel storage by internalizing spent fuel storage operations. The licensing effort is fairly simple. Consolidation may be less likely to have public intervention since the storage expansion will occur inside the plant. Consolidation can be subcontracted and the equipment is temporary. It can be used in conjunction with other storage expansion technologies such as dry storage. Fewer dry storage casks would be needed to store consolidated fuel than would be necessary for intact spent fuel
Burgers, I.J.J.; Mosquera, Valderrama I.J.
In their discussions on corporate income tax systems the International Organizations (IOs) OECD, UN, IMF and World Bank, Supranational Organizations (SOs), Non-Governmental Organizations (NGOs), associations of practitioners and Governments often refer to the concept of fairness without proper
Jul 26, 2012 ... the impact of tax incentives on corporate financial performance in Nigeria. The specific ..... many contemporary researchers in the field of financial/taxation accounting. .... The Principle of Personal Income Taxation in Nigeria.
Corporate branding has been seen as developing in “waves”. This chapter explores the links between corporate branding and corporate reputation as they emerge in the context of three waves of corporate branding. It highlights the way in which the two constructs have related to each other through o...... for corporate brands and corporate communication.......Corporate branding has been seen as developing in “waves”. This chapter explores the links between corporate branding and corporate reputation as they emerge in the context of three waves of corporate branding. It highlights the way in which the two constructs have related to each other through...... organizational culture and identity, and how, although characterized by parallel developments, new ideas and models from a “third” wave of corporate branding challenge prevailing assumptions of corporate reputation particularly in terms of the assumptions that reputations emerge from authentic and transparent...
..., DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES (CONTINUED) Corporations Used to Avoid Income Tax on Shareholders § 1.534-2 Burden of proof as to unreasonable accumulations in cases... a Tax Court proceeding with respect to an allegation that all or any part of the earnings and...
Schmidt, Peter Koerver
It is argued that the higher degree of economic integration across borders and the international trend towards a reduction of corporate income tax rates have had a significant impact on the Danish corporate tax regime in recent years. Accordingly, during the last ten years the Danish statutory...... corporate tax rate has been lowered further, while several government actions at the same time have been taken in order to combat international tax avoidance and evasion. As a result, new anti-avoidance provisions have been introduced and some of the older anti-avoidance provisions have been tightened...... party debt financing, transfer pricing and the effectiveness of anti-avoidance measures. However, the article concludes that these anti-avoidance provisions often suffer from being quite complex, very broad in scope and open to criticism from an EU law perspective....
Full Text Available In the paper are describing legal aspects of treatment of farming sector in the tax and social security system in Poland. Tax System in Polish Agriculture is an integral part of Polish Tax System. Most taxes paid by farmers are property taxes, which supplied the budget of main local authority in Poland (municipality. In some cases farmers pay also personal income tax and value added tax like those, who run specific agricultural production as well individual farmers who operate through a limited liability company are subject to corporate income tax. The social security fund for farmers (known as KRUS was speared in 1990 from the social security system (ZUS. Farmers receive similar benefits with regard to health care, education, and social welfare although the contributions into the farmers system are lower then under the ZUS system.
Full Text Available Reforms of environmental taxes in EU member states began to consolidate a strategic conceptual basis since the early '90s, when it was launched the idea of changing the tax burden from the tax factor of production, work to the environmental factors and use of environmental unfriendly activities and goods. The theoretical support of this view is represented by the corrective taxes Pigou situation justifying the optimal level of activity of producing goods and services from a social perspective, the collection of taxes imposed by the state of polluters, depending on the amount of damage and damage to third parties, the principle of 'polluter pays'. Despite the green fees start reforms of the EU member countries and their levels are not increased in recent years as a share of GDP. In the EU-27, 2008, revenues from environmental taxes represented a rate of about 2.8% of GDP and 6.1% of total revenues compared to 2.9% and 7.0% record share of GDP in 1999. Effects of environmental taxes on eco-efficiency must be seen not only in terms of their size or budget as income tax to GDP ratio, but also as a positive economic and social impact generated by larger beneficial effects of reducing pollution and preserving the quality natural resources and environmental factors.
Full Text Available Tax reliefs are optional, but a very important element of the taxation system. This element is used for different purposes by a country’s government institutions. Tax reliefs are a form of tax expenditure that helps to reduce budget revenues. Tax reliefs influence individual and corporate financial behaviour and can have positive or negative effects on the economic and social factors. In the last few years, expansion of tax relief has attracted worldwide attention because of the fact that, after the global financial crisis, many countries are still suffering from fiscal deficits, and expansion of tax relief has not contributed to solving this problem. Tax reliefs are presupposed to be a fiscal policy tool of significance in various subsystems of public finances. The main aim of this article is to examine the impact of personal income tax reliefs on Lithuanian public finances. To achieve this aim, statistical information was systemized; Monte Carlo method was used to group data by horizontal rows and logical links analysed, which helped to evaluate the influence of tax reliefs on public finances. In the simulations, the Monte Carlo method helped to simulate random samples, which were then examined by adapting the conclusions of the theory of probability and mathematical statistics methods.
... 26 Internal Revenue 18 2010-04-01 2010-04-01 false Signing of corporation returns. 301.6062-1 Section 301.6062-1 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED....6062-1 Signing of corporation returns. For provisions relating to the signing of corporation income tax...
... 27 Alcohol, Tobacco Products and Firearms 3 2010-04-01 2010-04-01 false Changes in corporation... CERTAIN OTHER FIREARMS Special (Occupational) Taxes Change of Ownership § 479.45 Changes in corporation... capital stock of a corporation if the laws of the State of incorporation provide for such change or...
Full Text Available The article substantiates the relevance of the study to ensure security of the state tax. Scientists studied different approaches to defining the essence of the concept of "security tax" on the key features that would satisfy the interests of all subjects of tax relations and the necessity of legal consolidation of this concept. Analyzed the economic, social and legal nature of the existence of the security tax, identified key indicators of fiscal security of Ukraine. To determine the effectiveness of the tax administration in the interests of the tax security highlights the main threats, tax security risks caused by external and internal factors, and propose measures for their elimination and prevent the possibility of their occurrence. The stages of tax risk management with effective building security tax, designed structurally-logic of the tax risk management security.
...) and any regulations thereunder. If any of the assets transferred are intangible assets, see section... 26 Internal Revenue 4 2010-04-01 2010-04-01 false Acquisition of foreign corporate stock or assets...) INCOME TAXES Effects on Corporation § 1.367(b)-4 Acquisition of foreign corporate stock or assets by a...
... of Accounting Used by Corporations That Acquire the Assets of Other Corporations; Correction AGENCY... describes corrections to final regulations (TD 9534) relating to the methods of accounting, including the... corporate reorganizations and tax-free liquidations. These regulations were published in the Federal...
... 26 Internal Revenue 9 2010-04-01 2010-04-01 false Taxation of foreign corporations engaged in U.S. business or of foreign corporations treated as having effectively connected income. 1.882-1 Section 1.882-1...) INCOME TAXES Foreign Corporations § 1.882-1 Taxation of foreign corporations engaged in U.S. business or...
This paper empirically highlights the role and significance of taxes for the capital structure decisions of banks. Using a difference-in-differences methodology, I show that an increase in the local U.S. state corporate tax rate affects both the banks' financing as well as their operating choices...
Carolina, Verani; Natalia, Maria; Debbianita, Debbianita
This research aimed to examine the influence of the executive characteristic on corporate tax avoidance. Risktaker’s executive tended to be more courageous and aggressive in taking decision related to the tax. On thecontrary, the risk averse executive tended to be carefully (Low, 2006). This research used leverage as interveningvariable. Therefore, there was an assumption that the executive characteristic determined the corporateleverage which then influenced their tax avoidance in the compan...
Nathalie V. Yurchenkova
Full Text Available Capacity of national tax systems isn’t fully revealed across all countries. Problems with tax administration, tax avoidance, leaving from the taxation of corporations and the leading financial organizations in the offshore confirm adaptation hypothesis stating that taxpayers adapt for changes in times quicker and more qualitatively than the state institutes. The leading role in formation of an evolutionary paradigm of the taxation belongs now to tools of evolutionary dynamics at social level.
James R. Hines, Jr.; Eric M. Rice
The offshore tax haven affiliates of American corporations account for more than a quarter of US foreign investment, an nearly a third of the foreign profits of US firms. This paper analyzes the origins of this tax haven activity and its implications for the US and foreign governments. Based on the behavior of US fins in 1982, it appears that American companies report extraordinarily high profit rates on both their real and their financial investments in tax havens. We calculate from this beh...
... Conviction and Tax Delinquent Status for Corporate Applicants and Awardees AGENCY: Office of the Chief... associated with Representations Regarding Felony Conviction and Tax Delinquent Status for Corporate... alternative means for communication (Braille, large print, audio tape, etc) should contact the USDA Target...
P. Quiry; Y. Le Fur; A. Salvi; M. Dallocchio; P. Vernimmen
Corporate Finance: Theory and Practice, 3rd Edition, the website www.vernimmen.com and the Vernimmen.com newsletter are all written and created by an author team who are both investment bankers/corporate financiers and academics. This book covers the theory and practice of Corporate Finance from a truly European perspective. It shows how to use financial theory to solve practical problems and is written for students of corporate finance and financial analysis and practising corporate financie...
As the world's biggest electricity generator, the EDF Group covers every sector of expertise, from generation to trading and transmission grids. EDF builds on the expertise of its people, its R and D and engineering skills, its experience as a leading industry operator and the attentive support of its customers to deliver competitive solutions that successfully reconcile economic growth with climate protection. This document presents the 2005 annual results and Consolidated financial statements of the Group at 31 December 2005: Consolidated income statements, consolidated balance sheets, consolidated cash flow statements, variation in consolidated equity, notes (group accounting policies, impact of first-time application of IFRs, transition to standards IAS 32 and 39 concerning financial instruments, summary of accounting and valuation methods, public distribution concessions in France, significant events and transactions of 2005, impact of the law of august 9, 2004 on comparability, changes in the scope of consolidation, segment reporting, sales, fuel and energy purchases, other external expenses, contractual obligations and commitments entered into in the course of business, personnel expenses, other operating income and expenses, other income and expenses, financial result, income taxes, basic earnings per share and diluted earnings per share, goodwill, other intangible assets, property, plant and equipment, investments in companies accounted for under the equity method, financial assets, inventories, including work-in-process, trade receivables, other receivables, cash and cash equivalents, available-for-sale assets and liabilities, equity, provisions, special concession liabilities, current and non-current financial liabilities, derivatives, other liabilities, related parties, greenhouse gas emission quotas, environment, subsequent events, scope of consolidation
National Aeronautics and Space Administration — The Consolidated Lunar Atlas is a collection of the best photographic images of the moon, including low-oblique photography, full-moon photography, and tabular and...
Svitlana Bychkova; Makarova Nadiya
Tax advising is strictly individual service requiring knowledge in the fields of law, tax and accounting. Tax advising includes not only advising on taxation models depending on the economic entity type of activity, but it also deals with issues of tax optimization. In the article the authors have offered their views on the concept of tax consulting in the area of tax optimization (tax planning). The subject matter has been a set of the most rational and important settings that allow you to u...
Full Text Available Agency conflict between minority and controlling shareholders in state owned firms has to be considered in order to examine the variability on effective tax rates. In China, state ownership helps the government to achieve its social objectives by optimizing corporate income tax. We provide a significant result to prove that state owned firms paid higher corporate income taxes than private firms. Our results also indicate that corporate effective tax rates are positively associated with firm sized and inventory intensity. However, we have no strong evidence to support the association with leverage, return on assets and capital intensity.
Kateryna Bornukova; Dzmitry Kruk; Gleb Shymanovich; Yuri Tserlukevich
This paper explores international experience of tax amnesties. Despite the popular use of tax amnesties, the results are mixed. The main advantage of the tax amnesty is the possibility to increase tax collections and improve tax compliance. However, it does not account for adverse effect of amnesties on tax compliance and high direct and indirect costs of amnesties. The success of the tax amnesty depends largely on the state of the economy. We have identified target groups and discussed a que...
... BUSINESS ADMINISTRATION NEW MARKETS VENTURE CAPITAL (âNMVCâ) PROGRAM Changes in Ownership, Structure, or Control Change in Structure of Nmvc Company § 108.470 SBA approval of merger, consolidation, or reorganization of NMVC Company. You may not merge, consolidate, change form of organization (corporation or...
... Preservation Certifications for Federal Income Tax Incentives AGENCY: National Park Service, Interior. ACTION... corporations must obtain these certifications to be eligible for tax credits from the Internal Revenue Service... containing the requirements for obtaining a tax credit; replaces references to NPS's regional offices with...
...-1 Evidence of purpose to avoid income tax. (a) In general. (1) The Commissioner's determination that a corporation was formed or availed of for the purpose of avoiding income tax with respect to... shall be determinative of the purpose to avoid the income tax with respect to shareholders unless the...
... corporations which claim the benefits of section 941 (relating to the special deduction for China Trade Act... 26 Internal Revenue 13 2010-04-01 2010-04-01 false Filing certain international income tax returns... certain international income tax returns. The following income tax returns shall be filed as directed in...
... 45 Public Welfare 4 2010-10-01 2010-10-01 false Tax sheltered annuities, retirement accounts and... SERVICES CORPORATION SUBGRANTS AND MEMBERSHIP FEES OR DUES § 1627.7 Tax sheltered annuities, retirement... recipient on behalf of its employees for the purpose of contributing to or funding a tax sheltered annuity...
We have seen a revival in interest in corporate law and corporate governance since the 1980s, as researchers applied the tools of the new institutional economics and modern corporate finance to analyze the new transactions emerging in the 1980s takeover wave. This article focuses on three mechanisms of corporate governance to illustrate the analytical usefulness of transaction cost economics for corporate law. They are the board of directors; relational investing, a form of block ownership in...
The success of tax planning can be converted into enterprise's productivity, tax planning strategy can maximize the desired effects and bring out its full play to tax planning. Taking new round of tax reform in 12th five-year-plan and the reformation of professional groups as the background, the author detailedly conceived a frame of corporate tax planning strategy for nuclear power enterprises of China National Nuclear Corporation at the forefront of reformation from an all-round comprehensive view and multi-angle stand. (author)
Lang, Michael; Owens, Jeffrey
The amount of taxes paid by multinational enterprises (MNEs) in host and home countries continues to make headline news. Corporate tax regimes, particularly those in many OECD countries, have never been more complex and the competition to attract and retain foreign direct investment (FDI) has perhaps never been so great. All of these political, legal, economic and competitive realities face countries at a time when they need additional budget revenues. At the June 2012 G-20 ...
Pursuant to paragraph 221(1)(d) of the Income Tax Act, payments made by federal Crown corporations (IDRC) under applicable service contracts (including contracts involving a mix of goods and services and services provided abroad) must be reported on a T1204 Government Service Contract Payment slip. To enable ...
problem that would be eliminated with the Hall and Rabushka’s flat tax rate proposal is double taxation of people who own shares in corporations...corporations would pay a 19 percent tax rate and income from dividends would not be taxed as personal income. This way, double taxation for...Rabushka’s method of counting all income as wages or salary regardless of the source significantly impacts Ashton. After Ashton deducts the allowances
Gili, J.A.; Poston, V.K.
This is the final report of the Prototypical Consolidation Demonstration Project, which was funded by the US Department of Energy's Office of Civilian Radioactive Waste Management. The project had two objectives: (a) to develop and demonstrate a prototype of production-scale equipment for the dry, horizontal consolidation and packaging of spent nuclear fuel rods from commercial boiling water reactor and pressurized water reactor fuel assemblies, and (b) to report the development and demonstration results to the US Department of Energy, Idaho Operations Office. This report summarizes the activities and conclusions of the project management contractor, EG ampersand G Idaho, Inc., and the fabrication and testing contractor, NUS Corporation (NUS). The report also presents EG ampersand G Idaho's assessments of the equipment and procedures developed by NUS
Brøchner, Jens; Jensen, Jesper; Svensson, Patrik
This study evaluates the economic effects of corporate tax coordination in the enlarged European Union (EU) using a computable general equilibrium model. Our main findings are as follows: (i) Corporate tax coordination can yield modest aggregate welfare gains. The 2004 enlargement of the EU has...... elaborate compensation mechanisms. (iii) The large and diverse country effects suggest that Enhanced Cooperation for a subset of the Member States may be the most likely route towards tax coordination. (iv) Identifying winners and losers from coordination for the purpose of a compensation mechanism may...
Nemir, David Charles (Inventor); Rubio, Edward S. (Inventor); Beck, Jan Bastian (Inventor)
Systems and methods for producing a dense, well bonded solid material from a powder may include consolidating the powder utilizing any suitable consolidation method, such as explosive shockwave consolidation. The systems and methods may also include a post-processing thermal treatment that exploits a mismatch between the coefficients of thermal expansion between the consolidated material and the container. Due to the mismatch in the coefficients, internal pressure on the consolidated material during the heat treatment may be increased.
Lade, Poul V.
The effect of consolidation stress state on the stress-strain and strength characteristics has been studied from experiments on undisturbed block samples of a natural, normally consolidated clay known as San Francisco Bay Mud. The results of experiments on K0-consolidated, hollow cylinder specimens...... and on isotropically consolidated, cubical specimens, both tested in triaxial compression and extension, clearly showed the influence of the undisturbed fabric as well as the effect of the initial consolidation stress states. While the K0-consolidated specimens appeared to retain their original fabric and exhibit...
Tse, Dorothy; Langston, Rosamund F; Kakeyama, Masaki; Bethus, Ingrid; Spooner, Patrick A; Wood, Emma R; Witter, Menno P; Morris, Richard G M
Memory encoding occurs rapidly, but the consolidation of memory in the neocortex has long been held to be a more gradual process. We now report, however, that systems consolidation can occur extremely quickly if an associative "schema" into which new information is incorporated has previously been created. In experiments using a hippocampal-dependent paired-associate task for rats, the memory of flavor-place associations became persistent over time as a putative neocortical schema gradually developed. New traces, trained for only one trial, then became assimilated and rapidly hippocampal-independent. Schemas also played a causal role in the creation of lasting associative memory representations during one-trial learning. The concept of neocortical schemas may unite psychological accounts of knowledge structures with neurobiological theories of systems memory consolidation.
Full Text Available The paper analyses Estonian tax structure changes during the last decade and critically assesses the current situation. The country’s tax mix is rather unique among EU countries – it has one of the highest proportions of consumption taxes in total taxes and the lowest level of capital and profit taxes. Such an unbalanced tax structure creates risks for public finances, limits revenue collection and distorts the business environment.
Herrick, F W; Brandstrom, R I
In this process for the formation of a consolidated aggregate, a mass of solid particles is combined with an aqueous alkaline consolidating compound which forms a gel. This gel consists principally of a mixture of the following: a vegetable polyphenolic material; one of the group of catechins; condensed tannins and extract of the bark of coniferous trees; with 1-10% by weight of formaldehyde; and a catalyst of the group of water-soluble salts of chromium, iron, and aluminum. This catalyst serves to catalyze the reaction of formation of the gel.
Full Text Available This research simulates the effect of imposing excise tax on plastic container of drinks towards economic performance of beverage industry in Indonesia and governmentâ˘A ´Zs tax revenue. The results showed that by imposing excise tax on plastic cups and plastic bottles the government would lose tax revenue from value added tax (PPN and corporate income tax (PPh badan more than they gain additional revenue from excise tax. Hence, imposing excise tax on drink containers should serve a clear purpose and an undeniable reason. This paper recommends the government to develop proper excise infrastructure to extend the goods or services to be taxed. This paper also recommends the required stages for extending the excise tax.
US Agency for International Development — The Collecting Taxes Database contains performance and structural indicators about national tax systems. The database contains quantitative revenue performance...
Full Text Available This paper explores the fiscal measures adopted in the transition European countries in order toencourage the foreign direct investment. There were analysed six countries: Albania, Macedonia,Moldova, Russian Federation, Union of Serbia and Muntenegro, Ukraine, based on the four criteria:corporate and capital gains tax rates, withholding taxes, tax incentives, foreign tax relief andtransfer pricing rules. Finally, the conclusion is that all the analysed countries offer favourable fiscalconditions for the foreign direct investment. Serbia, Muntenegro, Macedonia and Moldova haveattractive fiscal regimes, showing that the authorities from these countries count on the foreign directinvestment as a solution of solving the social and economic problems.
Bourgain, Arnaud; Pieretti, Patrice; Zanaj, Skerdilajda
The aim of this paper is to analyze within a simple model how a re- moval of bank secrecy can impact tax revenues and banks' profitability assuming that offshore centers are able to offer sophisticated but legal or not easily detectable tax planning. Two alternative regimes are considered. A first in which there is strict bank secrecy and a second where there is international information exchange for tax purposes. We show in particular that sharing tax information with onshore coun- tries can...
Full Text Available The offshore company, the emblem of the tax haven jurisdictions, is owned by non-residents and it conducts activities outside the island of incorporation in order to benefit from tax advantages. The purpose of this paper is to conduct a comparative analysis on the trends of constructing the offshore corporate structures at the level of five regions where tax havens have been identified: The Caribbean Sea and Central America; Europe; Asia; The Indian Ocean and The Pacific Ocean. Based on the tax and corporate legislations the analysis is focused on the main tax advantages offered by these entities, the incorporation and administration procedures as well as the costs involved. The results have shown that pure offshore corporate legislation is to be found at the level of only three geographic areas: The Caribbean Sea and Central America; The Indian Ocean and The Pacific Ocean and the offshore law is predominantly international, with only fine regional differences.
Full Text Available Traditional tax control has proven to be an insufficiently effective means of verifying the overall real economic power of large taxpayers (multinational corporations and wealthy individuals. As compared to the increasing mobility of taxpayers, tax administration activities are limited by the territorial jurisdiction of the fiscal sovereignty. The crisis of public finances has forced many countries to focus on the prevention of tax evasion and aggressive tax planning, particularly in international tax matters. In this sense, the traditional forms of tax control are supplemented by some additional strategies which are to provide tax authorities with more data on tax payers' business operations, profit, income, expenses and property. In practice, some developed tax administrations already apply a number of specific measures: the disclosure of information about aggressive tax planning schemes, advance pricing agreement, advance tax rulings, the use of financial intermediaries in data exchange processes, improved taxation relations, automatic exchange of tax information, etc. These specific measures are intended to help tax administrations to overcome the discrepancy between the information at their disposal and the information held by the taxpayers, which facilitates a more realistic assessment of tax liabilities. This will ensure a better management of tax risk and better tax compliance, which will ultimately contribute to a more efficient development of tax systems in the contemporary global business environment.
Nelson, J.D.; Wardwell, R.E.; Abt, S.R.; Staub, W.P.
The integrity of cover systems placed on tailings impoundments will be affected by the potential for differential settlement of the tailings surface. Settlement of the sand fraction will occur relatively rapidly. The slimes will take longer time for consolidation and will produce greater settlement. This report reviews the phenomenon of consolidation for saturated and unsaturated tailings. The effect of load application by cover placement and the extent to which dewatering of tailings will cause consolidation are considered. In addition, the feasibility of inducing consolidation by alternative means and the potential applicability of these methods to tailings impoundments reclamation are discussed. Differential settlement of the tailings will cause tensile strain to be developed in covers. This strain could be large enough to cause cracking within a relatively brittle compacted clay. Dewatering of tailings by drainage can cause settlement even greater than that by placement of a cover material. Dewatering of the tailings would also increase the stability of the tailings surface, thereby enhancing reclamation operations. Consequently, in view of the enhanced surface stability and the fact that a portion of the differential settlement can be accomplished prior to cover placement, dewatering of tailings impoundments during operations may have benefical effects
Wood, Marcia R.
This publication is designed to be a desktop reference and assist financial officers in both public and independent institutions of higher education in the preparation of consolidated financial statements. Chapter 1 covers generally accepted accounting principles and other accounting literature, and summarizes reporting rules of the Financial…
Full Text Available Environmental taxes should result in an improvement or prevention of deterioration of the environment. Although more advanced than previously existing Act on Excise Duty on Passenger Cars, Other Motor Vehicles, Vessels and Aircrafts from the 1997th year, the new law will hardly Croatia bring visible environmental benefit. Its application should not be expected to reduce the negative impacts of road traffic on air quality and greenhouse gas emissions until it does not clearly define how it will be at least part of the funds collected under this levy will be spent on measures to encourage the use of say hybrid or electric vehicles. Yet we should not neglect the fact that there is still need to work on educating people about the importance of environmental protection and any measures to be taken in the sphere of environmental protection should follow economic policies with a particular community or a country.
Jack M. Mintz
Full Text Available The federal Liberals and the NDP are right about this much: There is a more sensible way to tax the stock options that are granted as compensation by corporations than the approach the federal government takes now. But both parties are wrong about how much revenue an appropriate change in current tax policy will add to the treasury. Far from the half-billion dollars or more that both parties claim they will raise in federal tax revenue by changing the taxation of stock options, the appropriate reform will virtually raise no revenue. It could actually result in marginally lower tax revenue. As it stands, stock options are treated differently than salary and other forms of cash compensation when it comes to taxing an employee or director, in that they are subject to only half taxation, similar to capital gains. They are also treated differently than cash compensation for the corporation granting the options, in that they cannot be deducted from corporate income tax. The federal NDP and Liberals have both accepted the growing criticism, which only intensified in the aftermath of the 2008 financial crisis, that the lower tax rate is an unfair tax break for those employees who receive stock options. Both parties have proposed to change that, leaving an exemption for startup companies only, with the NDP proposing full personal taxation for all stock options except for start-up companies and the Liberals proposing it for options-based compensation exceeding $100,000. Treating stock options the same as cash compensation would indeed be more tax efficient, reducing the distortionary effect that can influence company compensation packages to give more weight to stock options and less to cash than they might otherwise. But the only way to ensure that efficiency is by treating both the personal tax side of the benefit, and the corporate tax side of the benefit, in the same way as other employee compensation. That is, applying full taxation to the recipient
Full Text Available The establishment of the European Union (EU has had a huge impact on Europe which has become a substantially different place as compared to what it used to be in some earlier times. In the field of taxation, the EU Member States are generally required to fully implement of the process of tax harmonization. In fiscal terms, harmonization implies the coordination of particular taxes, tax structures and tax policies among states. As the primary objective of the EU is to establish the common market, to prevent distortion and to eliminate obstacles hindering the free movement of goods, services, capital and people, the first step towards accomplishing these goals has been the harmonization of indirect taxes: the Value Added Tax and (partly excises. The results have been much more inconspicuous in the harmonization of direct taxes: the personal-income tax, the corporate tax, and property taxes. The harmonization of direct taxes in the EU is still a current issue, particularly in view of the unfair tax competition and the need to strengthen and promote the development of the European common market. However, in reality, EU Member States consistently keep protecting their tax sovereignty and putting off the full harmonization of their legislation on direct taxes for some other time. In the contemporary circumstances, the activities which deserve undivided attention are the efforts aimed at improving tax cooperation between EU Member States and their tax administrations. In this paper, the author analyses the characteristics of tax harmonization and tax competition. Further on, the author discusses the arguments for and against tax harmonization, as well as the pros and cons of tax competition. Bearing in mind the current state of affairs, the evident problems in the field of tax harmonization at the EU level and the willingness of Member States to improve their tax cooperation, the author suggests possible directions for the development of national tax
Ana Patricia HOMORODEAN (CSATLOS
Full Text Available In the context of globalization, sustainable development is the key to the development of contemporary society and future generations. Sustainability has become a key point for the debates in the political, economic, and academic environment. Therefore, today wehave reached the point when we speak of a country or company sustainability, of environmentalor agricultural sustainability, while speaking,at the same time, of fiscal policy sustainability. The purpose of this paper is to analyze the Romanian fiscal policy sustainability in terms of tax revenues. The methodology used in this research is bibliographical analysis of specialist literature and statistical analysis of data. Bibliographical analysis was used to define operating concepts: fiscal sustainability and tax revenues. Statistical analysis was used to analyze the evolution of tax revenues in Romania between2005and2013, as well as the share of tax revenues in the general consolidated budget of Romania. Statistical data were processed using Microsoft Excel and presented as evolution diagrams. The novelty and originality of the present work consist in the bibliographical study on Romanian fiscal policy sustainability, the statistical study on the evolution of tax revenues in Romania between 2005and2013, and the analysisof fiscal policy sustainability in Romania in terms of tax revenues.
... 26 Internal Revenue 10 2010-04-01 2010-04-01 false Taxation of a domestic international sales corporation. 1.991-1 Section 1.991-1 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Domestic International Sales Corporations § 1.991-1 Taxation...
This Saint Lucia Act revises and consolidates the law relating to income tax. It contains the following provisions, among others: 1) income accrued to a married woman is to be taxed in her own name; 2) the spousal deduction is set at $1500; and 3) the child deduction is set at $1000.
Zagler, Martin; Zanzottera, Cristiana
This paper analyzes the effects of legal uncertainty around corporate income taxation on foreign direct investment (FDI). Legal uncertainty can take many forms: double tax agreements, different types of legal systems and corruption. We test the effect of legal uncertainty on foreign direct investment with an international panel. We find that an increase in the ratio of the statutory corporate income tax rate of the destination relative to the source country exhibits a negati...
Full Text Available We study the development in the Danish corporate income tax base and the corporate income tax revenue in the period from 1990 until present. Measured in per cent of GDP the CIT base has out-paced the revenue due to parallel CIT rate cuts and base broadening reforms. We seek to explain the development in the CIT base and discuss whether this is threatened by base erosion and profit shifting.
VIJAYA KRUSHNA VARMA
TOP Tax system is a new tax system which can be used as a common tax system for all nations. This new tax system will be without present tax system’s all Direct and Indirect taxes accompanied by tax laws, tax exemptions, multiple tax collection departments to relieve 7 billion people of the world from the cobweb of ambiguous and complex tax structures, plethora of tax laws, mandatory and cumbersome accounting, auditing, tax returns and consequent quagmire of all tax related cases. Taxation, t...
Florida Progress Corporation is a utility holding company with assets of 5 billion dollars. Its principal subsidiary is the Florida Power Corporation; others are the Electric Fuels Corporation, the Mid-Continent Life Assurance Company, the Talquin Corporation, the Progress Credit Corporation and Advanced Separation Technologies Incorporated. The annual report describes achievements during the year. To meet growing energy demand Florida Power is building new peaking and base-load generating units, purchasing power from neighbouring utilities and cogenerators, and building more bulk power transmission line capacity in the state. Emphasis has been placed on meeting load growth by demand-site management. Attention is given to balancing energy needs with concerns for the environment, and there is an award-winning recycling program. The Electric Fuels Corporation major area of business is coal mining and transportation services. Advanced Separation Technologies has sold several of its patented ion separation machines. The report includes consolidated financial statements for the year ended 31 December 1991
As an alternative to taxation of capital income at the corporate level, countries could instead tax their individual residents on their worldwide capital income. Information exchange on individuals’ foreign investment income is absolutely necessary for this approach to be effective. The second part
Terra, B.J.M.; Wattel, P.J.
This book is intended as a reference book for tax law and EC law pratitioners, tax administrators, academics, the judiciary and tax or Community law policy makers. For students, an abridged student edition textbook is available. The book offers a systematic survey of the tax implications of the EC
De Waegenaere, A.M.B.; Wielhouwer, J.L.
The tax depreciation decision potentially has significant impact on the prof- itability of firms and projects. Indeed, the depreciation method chosen for tax purposes affects the timing of tax payments, and, as a consequence, it also affects the after-tax net present value of investment projects.
De Waegenaere, A.M.B.; Wielhouwer, J.L.
The tax depreciation decision potentially has significant impact on the profitability of firms and projects. Indeed, the depreciation method chosen for tax purposes affects the timing of tax payments, and, as a consequence, it also affects the after-tax net present value of investment projects.
Congressional Budget Office
In 1975, the first refundable tax credit—the earned income tax credit (EITC)—took effect. Since then, the number and cost of refundable tax credits—credits that can result in net payments from the government—have grown considerably. Those credits will cost $149 billion in 2013, CBO estimates, mostly for the EITC and the child tax credit.
... partnerships, see § 1.1446-4. For special rules applicable to tiered partnership structures, see § 1.1446-5... its 1446 tax), foreign corporation (which includes a foreign government pursuant to section 892(a)(3... partnership must generally pay 1446 tax on ECTI allocable to a foreign corporate partner that has made an...
Full Text Available This research aimed to examine the influence of the executive characteristic on corporate tax avoidance. Risktaker’s executive tended to be more courageous and aggressive in taking decision related to the tax. On thecontrary, the risk averse executive tended to be carefully (Low, 2006. This research used leverage as interveningvariable. Therefore, there was an assumption that the executive characteristic determined the corporateleverage which then influenced their tax avoidance in the company. Manufacturing companies which werelisted in Indonesia Stock Exchange during the period 2010-2012 were used as samples. This research usedpurposive sampling method to select the sample with the criteria as follows: they were listed in Indonesia StockExchange during the period of 2010-2012, they made a profit during the period of 2010-2012, and they usedrupiah as reporting currency. Data was processed using path analysis and the result showed that the executivecharacteristic had an impact on corporate tax avoidance with leverage as the intervening variable. The resultof this research could be used for the investors to assess the corporate tax avoidance before they made a decision,and also for the policy makers to detect the corporate tax avoidance.
@@ Tax planning is legal planning activities for tax savings, meaning tax payers make operation plans within the national policy framework and choose operation programs favorable to tax savings.Along with a maturing socialist market economy system in China, tax planning is becoming an integral part of enterprise management and operation.For a better tax planning, enterprises have to fully understand the meaning, get proficient at relevant strategies, and apply these methods to save taxes and realize the maximization of enterprise value while considering the actual situation.
... TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Pension, Profit-Sharing, Stock Bonus Plans, Etc... purpose of the ownership structure of an S corporation constitutes an avoidance or evasion of section 409..., as well as for purposes of section 4979A, which imposes an excise tax on certain events. (i) Deemed...
LaFrance, Julie; Lehmann, Martin
Predominantly since the 1992 Rio Summit, corporations have been increasingly pursuing partnerships with public institutions including governments, international organisations and NGOs that aim to contribute to sustainable development activities. Partnerships have become more common as corporation...... public-private partnerships. These theoretical perspectives are used to gain a deeper understanding of the corporate drivers that motivated TOTAL S.A. to approach UNESCO for cooperation on community development programs in Myanmar....
Full Text Available This paper aims to analyze nonlinear finite strain consolidation with secondary consolidation behavior. On the basis of some assumptions about the secondary consolidation behavior, the continuity equation of pore water in Gibson’s consolidation theory is modified. Taking the nonlinear compressibility and nonlinear permeability of soils into consideration, the governing equation for finite strain consolidation analysis is derived. Based on the experimental data of Hangzhou soft clay samples, the new governing equation is solved with the finite element method. Afterwards, the calculation results of this new method and other two methods are compared. It can be found that Gibson’s method may underestimate the excess pore water pressure during primary consolidation. The new method which takes the secondary consolidation behavior, the nonlinear compressibility, and nonlinear permeability of soils into consideration can precisely estimate the settlement rate and the final settlement of Hangzhou soft clay sample.
ANDREEA LAVINIA CAZACU (NEAMŢU
Full Text Available Transfer pricing are the prices at which a company transfers physical goods and intangible property or provides services to affiliated companies. Transfer pricing mechanism is the most frequently used instrument for the transfer of the tax base from countries with high tax to low tax countries. In the context of transfer pricing, all transactions should be made only respecting the principle of market value (Arm’s length principle. Under current conditions, we can say that globalization influences the transfer pricing, because it makes possible to transfer profits from one country to another, by removing state barriers. The expression "transfer pricing" is used as shorthand for multinational corporations to store profits in tax havens and to avoid tax evasion in developed countries. These two terms (transfer pricing and tax havens combined, make the benefits of affiliated groups to grow impressively.
Meldgaard, Henrik; Bundgaard, Jakob; Weber, Katja Dyppel
As a response to the increasing sophistication of tax planners in identifying and exploiting the legal arbitrage opportunities and the boundaries of acceptable tax planning, policy makers across OECD, G20 and EU countries have taken steps to ensure that taxation duly takes place where economic...... value is generated and where the economic activity is actually carried out. In this context, the European Commission sees a strong need to obtain increased knowledge of the tax laws and practices of Member States of the European Union, which may expose particular jurisdictions to aggressive tax planning...... (ATP). The present study was commissioned with the aim to: 1. Identify model ATP structures; 2. Identify ATP indicators which facilitate or allow ATP; 3. Review the corporate income tax systems of the EU Member States by means of the ATP indicators, in order to identify those tax rules and practices...
Full Text Available The process of globalisation has led, among other things, to harmful tax competition. This paper considers the efforts within the EU in combating harmful tax competition (Code of Conduct on Business Taxation and their effects when taking into account the EU regulations in relation to state aids. Considering a number of problems in the implementation of the Code, and the numerous criticisms with regard to the validity of the combat against harmful tax competition – it is difficult to give a final answer about its success. Croatian tax system, and the corporation tax in particular, are analysed in the light of the aforementioned problems. The advantages of the equal treatment of domestic and foreign investors, as well as the certain elements of state aids in tax benefits, are pointed out.
This article describes the argumentative structure of Hayek on the relationship between power to tax and the progressive tax. It is observed throughout its work giving special attention to two works: The Constitution of Liberty (1959) and Law, Legislation and Liberty, vol3; The Political Order of Free People, 1979) Hayek describes one of the arguments most complete information bout SFP progressive tax systems (progressive tax). According to the author the history of the tax progressive system...
Norwegian Government Commission on Capital Flight from Poor Countries
Tax havens harm both industrialised and developing countries, but the damaging impacts are largest in developing countries. This is partly because these countries are poor and thereby have more need to protect their national tax base, and partly because they generally have weaker institutions and thereby fewer opportunities for enforcing the laws and regulations they adopt. Tax treaties between tax havens and developing countries often contribute to a significant reduction in the tax base of...
Full Text Available The work is in the applied research line and aims to analyze the legal provisions on specific tax regarding the measure in which this tax would ensure an equal tax treatment in the economic environment that would comply with the principle of proportionality. The specific tax will take effect from January 1st, 2017 in Romania for the activities in tourism and hotels field, restaurants, bars and public food services. The research methods are based on analysis and comparison. The paper specifically follows the way in which the specific tax will influence the taxpayers, corporate tax payers currently operating in the areas listed above, as they are obliged to replace the corporate tax with a fixed tax until 2017. This tax influenced only by the entity's ability to produce income (useful surface of the location, commercial venue (area and location, category and seasonality of activities, it no longer takes into account the actual obtained profit. We believe that in those areas was rather necessary to establish a minimum tax, not a fixed tax. We welcome the calculation and substantiation mode of the specific tax depending on the national average set at the level of 2014 based on the tax data from NAFA and other institutes and business organizations in these areas, however, after the analysis, we believe that this tax, although is going to ensure more efficient collection of tax claims from a larger number of taxpayers and is going to facilitate the reduction of tax evasion level from certain taxpayers and it will also facilitate the large taxpayers who usually due a lower tax than the performed profit.
Full Text Available Given the dynamics of economic and financial globalization, national tax authorities often do not have adequate tools to effectively combat tax avoidance practices that exploit gaps in the existing tax rules. To address the global problem of tax base erosion and profit shifting (BEPS, the Organisation for Economic Co-operation and Development (OECD and the Group of 20 (G20 have consolidated their efforts on an equal footing. Their joint BEPS Action Plan allowed to involve more than 100 countries, both developing and advanced, in designing and implementing rules aimed at aligning the generation of profits and their taxation and increasing the predictability, transparency and flexibility of the international tax environment for business. This article examines the history of the BEPS project, emphasizing the mode of OECD-G20 engagement in global tax governance, describes the key recommendations made by international institutions to tackle BEPS and forecasts further developments in the area. The author pays special attention to the mechanisms designed to stimulate participation by non-OECD and non-G20 members in the BEPS project and the stance of business on the proposed reforms. He concludes that the work on BEPS is far from finished. Different interpretations of standards, risks of strengthening tax competition between countries and potentially excessive tax burdens on businesses should be addressed. In this regard, OECD and G20 should strengthen their efforts to ensure the participation of developing countries and the private sector, which would stimulate other reforms in international taxation to support global growth and development.
Two of the factors that need to be taken into account with rod consolidation are (1) the effects on rods from their removal from the fuel assembly and (2) the effects on rods as a result of the consolidation process. Potential components of both factors are described in the report. Discussed under (1) are scratches on the fuel rod surfaces, rod breakage, crud, extended burnup, and possible cladding embrittlement due to hydrogen injection at BWRs. Discussed under (2) are the increased water temperature (less than 10 0 C) because of closer packing of the rods, formation of crevices between rods in the close-packed mode, contact with dissimilar metals, and the potential for rapid heating of fuel rods following the loss of water from a spent fuel storage pool. Another factor that plays an important role in rod consolidation is the cost of disposal of the nonfuel-bearing components of the fuel assembly. Also, the dose rate from the components - especially Inconel spacer grids - can affect the handling procedures. Several licensing issues that exist are described. A list of recommendations is provided. 98 refs., 5 figs., 5 tabs
Full Text Available Small business tax compliance requires special attention. On the one hand small businesses are often incapable of rigorously fulfilling their tax obligations, more vulnerable to external risks and tempted to exploit opportunities to be non-compliant. On the other hand, unlike larger businesses, they are usually sole proprietors or owner-operated businesses, hence highly responsive to personal, social, cognitive and emotional factors. These attributes pave the way to a better use of measures designed to influence their behavior and choices. This paper discusses the role and effectiveness of tax penalties in enhancing tax compliance in small businesses. It argues that tax penalties, although indispensable for tax enforcement, may not be a first-choice tool in ensuring tax compliance. Too punitive a tax regime is an important barrier to business formalization and increasing severity of tax penalties does not produce the intended results. To be effective, tax penalties should deter and motivate taxpayers rather than exert repressive measures against them.
Givoly, Dan; Hayn, Carla
The authors examine the aggregate and distributional effects of the Tax Reform Act of 1986 on equity values of publicly traded corporations. The results show that the effect of the act on the aggregate equity value of corporations was consistent with the present value of the projected added tax collection from the corporate sector. The cross-sectional variation in the magnitude and direction of the stock price response to the Tax Reform Act of 1986 was a function of both the direct and indire...
... pays $3,000 social security taxes in connection with the erection of the hotel. B's election to... bind him to capitalize the social security taxes paid in erecting the hotel; he may deduct the $3,000 social security taxes paid in erecting the hotel. Example 4. In 1957, M Corporation began the erection of...
Full Text Available In the last few years, many countries Central and Eastern European countrieshave reduced their corporate income tax rates with the purpose of attractingmultinational companies. Various studies indicate the fact that the level of the corporateincome tax represents an important advantage that drives the decisions to place foreigndirect investments. Many European Union member states have initiated corporateincome tax reforms, in order to generate the increase in the competitiveness of nationaleconomies. In the case of the Central and Eastern European countries, where thedecrease in the corporate income taxes was higher, these reforms brought profoundchanges in the economic environment.
Irina P. Dovbiy
Full Text Available The article analyzes the tax benefits for the enterprises of Russia. Their analysis is carried out in the context of territorial affiliation of tax benefit. Tax benefits were granted as anti-crisis measures: promotion of entrepreneurship, reduction of informal employment, implementation of investment projects. Their granting was often characterized by haphazard nature. There were cases of abuse in the application of tax benefits. The entrepreneur must be ready to prove their right to benefits. Tax benefits have a triple effect: economic, fiscal-budgetary, social. The state tax policy allowed reducing the level of debt burden for 2016. Simultaneously, the increase in tax and non-tax revenues of the consolidated budgets was ensured. The authors analyze the regional and sectoral tax benefits. They are very diverse, especially for small businesses. This is due to socio-economic differentiation of regions. The magnitude of the regional tax burden is determined by the complex of factors: external and internal. The application of tax benefits is associated with big problems. First of all, this is a concealment of income. Secondly, there is a problem of “double” taxation. Difficulties are also associated with applying individual tax regimes: special economic zones, territories of advanced development. The problem of drawing “out of the shadow” of selfemployed citizens is very acute. There must be a special fee regime for them: there is no guarantee of employment for such citizens. The problems of regional taxation of entrepreneurial activity include, on the one hand, the availability and development of various benefits, and on the other hand, their nonsystem character, the impossibility of identifying and using various mechanisms in the aggregate, for example, the mechanisms for the development of entire industries and social directions in entrepreneurship. The authors emphasize that the conditions in which the modern economy of Russia is
Tax compliance denotes the act of reporting and paying taxes in accordance with the tax laws. Current social science scholarship on tax compliance can almost entirely be divided into behavioural psychology analyses and critical tax studies. This article, which presents two cases of how tax...... compliance is constructed, challenges the explanatory reaches of today's social science approaches, arguing that an alternative approach to understanding tax compliance is worthwhile exploring. This other choice of approach, inspired by actor–network theory (ANT), adopts a more practice-oriented focus...... that studies tax compliance where it takes place as well as what it is made of. Consequently, this article argues that tax compliance is a socio-material assemblage and that complying is a distributed action. The article concludes by highlighting how an ANT approach contributes to the further theoretical...
Ling, Lai Ming; Nawawi, Nurul Hidayah Ahamad
Purpose: This study aims to examine the ICT skills needed by a fresh accounting graduate when first joining a tax firm; to find out usage of electronic tax (e-tax) applications in tax practice; to assess the rating of senior tax practitioners on fresh graduates' ICT and e-tax applications skills; and to solicit tax practitioners' opinion regarding…
Lassen, Astrid Heidemann
Corporate entrepreneurship is often highlighted as being more relevant than ever, as a viable means for existing organizations to pursue creative new solutions to the complex challenges facing firms today. This includes continuously exploring and exploiting previously unexploited opportunities......, and thereby moving the organization to a new state of being. In spite of a general consensus on a strong interlinkage between the concepts of innovation and corporate entrepreneurship, the nature of this linkage is rarely addressed directly. This has made further research in the two areas problematic, mainly...... nature of corporate entrepreneurship and innovation by exploring the role played by innovation in corporate entrepreneurship. - Develop a framework of corporate entrepreneurial innovation which facilitates an understanding of challenges related hereto and practices applied to overcome these challenges...
Herlin, Heidi; Thusgaard Pedersen, Janni
action between business and NGOs through convening, translation, collaboration, and mediation. Our study provides valuable insights into the tri-part relationship of company foundation NGO by discussing the implications of corporate foundations taking an active role in the realm of corporate social...... responsibility (CSR). The paper hence illuminates the fascinating and overlooked role of corporate foundations as potential bridges between business and civil society. It also informs theory on boundary organizations by clarifying challenges and limits of such institutions.......This paper aims to explore the potential of Danish corporate foundations as boundary organizations facilitating relationships between their founding companies and non-governmental organizations (NGOs). Hitherto, research has been silent about the role of corporate foundations in relation to cross...
We analyze the impact of tax morality on progressive income (wage) taxation. We assume that transfers (cash-back) and public expenditures are financed from linear wage taxes. We derive the reported wages from individual utility maximization, when individuals obtain partial satisfaction from reporting wages (depending on their tax morality), and cannot be excluded from the use of public services. The government maximizes a utilitarian social welfare function, also taking into account the utili...
Rahimi, Fatemeh; Møller, Charles
multinational corporations. The ERP distribution decision in MNCs has been mainly associated with the corporate strategy and governance structure. As global ERP deployment benefits mainly come from business consolidation, and as there are significant costs and risks associated with centralized ERP...... to be more directly affected by the factors prohibiting further divergence, namely the corporate business process governance structure and the degree of similarity of its business models....
Gong, Di; Hu, Shiwei; Ligthart, J.E.
Corporate income taxation, by affecting the after-tax cost of funding, has implications for a bank’s incentive to securitize. Using a sample of OECD banks over the period 1999–2006, we find that corporate income taxation led to more securitization at banks that are constrained in funding markets,
Gong, D.; Ligthart, J.E.
Abstract: Corporate income taxation, by affecting the after-tax cost of funding, has implications for a bank's incentive to securitize. Using a sample of OECD banks over the period 1999-2006, we fi nd that corporate income taxation led to more securitization at banks that are constrained in funding
Purpose – The purpose of this paper is to analyse everyday reasoning in public administration. This is done by focusing on front line tax inspectors’ decisions about tax evasion. Design/methodology/approach – The paper presents ethnography of bureaucracy and field audits. The material stems from...... fieldwork conducted in the Central Customs and Tax Administration. Findings – The paper shows that the tax inspectors reason about tax evasion in a casuistic manner. They pay attention to similar cases and to particular circumstances of the individual cases. In deciding on tax evasion, the inspectors do...
This article shows a new form of regulation within a tax administration where tax administrators abate tax evasion by nudging and motivating consumers to only purchase services from tax compliant businesses. This indirectly closes or forces tax evading businesses to change their practices, because...... stakeholders, i.e. the consumers, in the regulatory craft. The study is based on a qualitative methodology and draws on a unique case of regulation in the cleaning sector. This sector is at high risk of tax evasion and human exploitation of vulnerable workers operating in the informal economy. The article has...
Gjedsted Nielsen, Mads
This paper is the first to consider a large scale natural experiment to estimate the effect of taxes on house prices. We find that a 1 percentage-point increase in income tax rates lead to a drop in house prices of at most 2.2%. This corresponds to a tax capitalization for the average household...... capitalization from earlier studies. Furthermore, we find no effect of property taxes on house prices. We attribute this to the low levels of Danish municipal property tax rates compared to income tax rates....
Schmidt Peter Koerver
Full Text Available It is argued th**at the higher degree of economic integration across borders and the international trend towards a reduction of corporate income tax rates have had a significant impact on the Danish corporate tax regime in recent years. Accordingly, during the last ten years the Danish statutory corporate tax rate has been lowered further, while several government actions at the same time have been taken in order to combat international tax avoidance and evasion. As a result, new anti-avoidance provisions have been introduced and some of the older anti-avoidance provisions have been tightened in order to prevent base erosion and profit shifting. Thus, to some extent Denmark has already tried to address a number of the key pressure areas mentioned in the recently published OECD BEPS report, such as international mismatches in entity and instrument characterization, the tax treatment of related party debt financing, transfer pricing and the effectiveness of anti-avoidance measures. However, the article concludes that these anti-avoidance provisions often suffer from being quite complex, very broad in scope and open to criticism from an EU law perspective.
A survey of electrochemical methods applications in fuel reprocessing was completed. A dummy fuel assembly shroud was cut using the remotely operated laser disassembly equipment. Operations and engineering efforts have continued to correct equipment operating, software, and procedural problems experienced during the previous uranium compaigns. Fuel cycle options were examined for the liquid metal reactor fuel cycle. In high temperature gas cooled reactor spent fuel studies, preconceptual designs were completed for the concrete storage cask and open field drywell storage concept. These and other tasks operating under the consolidated fuel reprocessing program are examined.
Kirchler, Erich; Wahl, Ingrid
Surveys on tax compliance and non-compliance often rely on ad hoc formulated items which lack standardization and empirical validation. We present an inventory to assess tax compliance and distinguish between different forms of compliance and non-compliance: voluntary versus enforced compliance, tax avoidance, and tax evasion. First, items to measure voluntary and enforced compliance, avoidance, and evasion were drawn up (collected from past research and newly developed), and tested empirically with the aim of producing four validated scales with a clear factorial structure. Second, findings from the first analyses were replicated and extended to validation on the basis of motivational postures. A standardized inventory is provided which can be used in surveys in order to collect data which are comparable across research focusing on self-reports. The inventory can be used in either of two ways: either in its entirety, or by applying the single scales independently, allowing an economical and fast assessment of different facets of tax compliance.
Full Text Available This article aims to describe the development in the field of corporate tax law in Iceland, from both legal and economic point of view, with a focus on measures taken to protect the tax base and in order to try to make Iceland an attractive place for investment and establishment companies. First, there will be a brief general description of the development of the corporate tax rate in Iceland since 2004 and an overview of new taxes that have been introduced for companies over the past ten years. Second, there will be an analysis of how the Icelandic legal framework provides for incentives for investment and establishment of companies in Iceland. Third, this discussion is to be followed by a section on the steps Iceland has taken in order to combat tax avoidance. Fourth, there is a general description of the economic development for the corporate taxation in Iceland since 1990 and fifth, there is brief discussion of the development of revenues from the corporate tax. Sixth, a short overview of the real investment in the Icelandic economy is given, and finally, the main conclusions of this article will be summed up with a short discussion on the main challenges Iceland is currently facing in the field of corporate taxation in today’s globalised economy.
A rod consolidation demonstration with irradiated pressurized water reactor fuel was recently conducted by personnel from Nuclear Assurance Corporation and West Valley Nuclear Services Company at the West Valley Demonstration Project in West Valley, New York. The rod consolidation demonstration involved pulling all of the fuel rods from six fuel Assemblies. In general, the rod pulling proceeded smoothly. The highest compaction ratio attained was 1:8:1. Among the total of 1074 fuel rods were some known degraded rods (they had collapsed cladding, a result of in-reactor fuel densification), but no rods were broken or dropped during the demonstration. One aim was to gather information on the effect of rod consolidation operations on the integrity of the fuel rods during subsequent handling and storage. Another goal was to collect information on the condition and handling of intact, damaged, and failed fuel that has been in storage for an extended period. 9 refs., 8 figs., 1 tab
This paper investigates the relationship between the disparity in tax base and tax collection. I address the tax collection problem with traditional industrial organization approach. Thus, I model the "tax minimization" industry where the supplier helps taxpayers to avoid their tax liability. I find that lower income inequality as well as a less progressive tax code may result in a smaller number of tax payers committing to their tax duties. Finally, I question the reduction in the highest ta...
... is preferable to disregarding options subject to an anti-avoidance rule. The IRS and the Treasury... rule only applies to foreign corporations and noted that avoidance concerns may equally be present with... though, for Federal tax purposes, the acquired stock no longer exists after the transaction. Thus, for...
Behaghel, Luc; Lorenceau, Adrien; Quantin, Simon
This paper uses regression discontinuity design to provide quasi-experimental estimates of the impact of a tax credit program targeted at rural areas in France, including corporate and payroll tax exemptions. We find no impact of the program on total employment or the number of businesses, and no impact of the different program components on targeted subsets of firms. Comparison with a contemporaneous urban scheme suggests ways the incentives of the rural program could be targeted more effect...
Full Text Available Taxation policy reforms has been done by the government with the issuance of Law No. 11 year 2016 about Tax Amnesty. The background of the issuance of this law : a there is still treasure the community both in the country and foreign who have not yet fully reported in the Annual Tax Income, b to increase state revenues and economic growth as well as awareness and compliance community in the implementation of tax obligations . Although the government wants tax amnesty� to secure tax revenue, but in general they wants it for the repatriation of capital. The goal is to increase the liquidity is getting tighter, so eventually bank deposits can be cheaper, bank lending rates fell and investment will� increase. In addition, the quality of economic growth will increase by decreasing of unemployment, inequality, and poverty. To obtain a Tax Amnesty, the tax payer must disclose truthfully how the property owned which have not paid or partially paid taxes in the Letter of Statement and pay the ransom that provisions stipulated in the Act, and not subject to administrative sanctions taxation and criminal sanctions in the area of taxation. The ransom money to be paid in full to the state treasury through the Bank Perception (Bank elected to hold funds Tax Amnesty. Institution Tax Amnesty container fund is 19 Banks, 19 securities firms, and 18 of the Investment Manager. Tax payers who intend to bring �funds owned to Indonesian territory, at least to invest of 3 years commencing from the funds transferred by the tax payer to the Special Account through the Bank Perception. Investment instruments include in the form of government securities of the Republic of Indonesia, the bonds of State BUMN, bond financing institution owned by the government, financial investments in the Bank's perception, bonds private companies whose trade is supervised by the Financial Services Authority, infrastructure investment through government cooperation with corporate
Full Text Available In the past decade, Canada has undertaken extensive business tax reform, with sharply lower corporate income tax rates, better capital cost allowances, sales tax harmonization, and the virtual elimination of capital tax on non-financial businesses. Further changes are in store by 2012 that will put Canada in the middle of the pack of a broad group of 80 countries. Over the past several years, however, Canada has lost some standing. In 2005, it was the fourth-highest-taxed country, and by 2007 it had improved to thirteenth highest; by 2009, though, it had worsened to tenth highest. Still, in that year, taking into account the reforms that had taken place, Canada’s business tax structure was better than that of the United States. Canada’s tax competitiveness among the Group-of-7 major industrialized countries has also improved, but still lags that of most other members of the Organisation for Economic Cooperation and Development (OECD. Additional reductions of business taxes by 2013 — particularly sales tax harmonization in Ontario and British Columbia and planned federal and provincial corporate tax rate reductions — will further improve Canada’s business tax competitiveness, crucially with respect to the emerging economies of Brazil, Russia, India, and China. Yet federal opposition parties are urging an end to further planned reductions of federal and provincial corporate income tax rates. Such a move would be seriously misguided. Not only would it put Canada’s tax competitiveness at a disadvantage among OECD countries, impairing productivity; it would also harm government revenues as businesses shifted their profits out of high-tax jurisdictions and into lower-tax one abroad.
Bauman, L J; Friedman, S B
Pediatricians differ on the optimal ways to discipline children. The major controversy surrounds the use of corporal punishment. In an effort to resolve this controversy, the American Academy of Pediatrics (AAP) cosponsored a conference entitled "The Short and Long-Term Consequences of Corporal Punishment" in February 1996. This article reviews scientific literature on corporal punishment and summarizes the proceedings from the conference. The authors conclude that, although the research data are inadequate to resolve the controversy, there are areas of consensus. Practitioners should assess the spanking practices of the parent they see and counsel parents to avoid those that are, by AAP consensus, dangerous, ineffective, or abusive.
Full Text Available Since 2000, Canada has been remarkably successful in building a more competitive corporate tax system, principally by lowering tax rates and broadening the tax base. Canada’s marginal effective tax rate (METR is now the lowest, and hence the most tax-competitive among the G-7, the 20th most tax-competitive in the 34-member OECD, and 57th among the 90 countries surveyed in this paper. The result has been greater investment and improved economic growth despite recessionary pressures. In particular, provincial sales tax harmonization with the GST has heightened Ontario’s competitiveness and promises to do the same for PEI, the latest convert to the cause. However, progress has not been uniform. Some provincial governments have lost focus by raising rates or introducing tax preferences that narrow the base, inevitably harming business efficiency. British Columbia’s decision to replace the new Harmonized Sales Tax with the old retail sales tax will cost it dearly, especially when it comes to public spending. On the other hand, corporate tax rate reductions of more than 30 percent (since 2000 have, contrary to the critics’ cries, failed to make an appreciable dent in tax revenues thanks to multinationals’ habit of shifting profits to Canada to take advantage of lower rates. This paper, in providing a candid snapshot of Canadian taxation measured against 89 other nations, serves as an invaluable foundation for understanding how far this country has come, and what its next steps should be.
This report briefly presents and comments the amount of environmental taxes which have been collected in France in 2008. These taxes comprise energy taxes (nearly 68 per cent), transport taxes (nearly 28 per cent) and pollution and resource taxes (less than 5 per cent), and represent 2 per cent of the French GDP and 5 per cent of mandatory contributions. The share of environmental taxes is compared among the European Union countries. This shows that France is close to the average. It also appears that these taxes evolve slower than the GDP. An indicator is built up and commented: it relates the rate between energy taxes and the GDP on the one hand, and energy consumption on the other hand. This indicator displays a slow but significant decrease since the end of the last century
Earth Data Analysis Center, University of New Mexico — This layer represents boundaries for New Mexico tax district "OUT" categories and incorporated/municipal "IN" categories as identified on the "Certificate of Tax...
The statistics presents statements of environmental taxes for the period 1991-2001 (and budget figure for 2002). Environmental taxes are a concept for pollution, energy, transportation and resource related taxes. Income of the government from environmental taxes have increased from 30,0 billions DDK in 1991 to 62,2 billions DDK in 2001 - a little more than a doubling. The environmental taxes' part of the total taxes' part og the total taxes has increased from 7,5% in 1991 to 9,4% in 2001. In 2001 the energy taxes are 57%, the transportation taxes 36% and the pollution and resource taxes 7% of the environmental taxes. (LN)
The purpose of this study is to discuss what kinds of information are demanded by the users of financial statements and what kinds of problems plague the companies using SPE (special purpose equity), while considering the actual situations of the consolidation and disclosure of SPE in Japan. At present, there is the trend of consolidating a broad range of SPE in Japan, etc., but some users of financial statements point out that it became difficult to understand consolidated financial stat...
Estelle P. Dauchy; Sebastien Bradley; Makoto Hasegawa
Despite an extensive literature on the normative implications of different international tax regimes and an empirical literature addressing individual specific predictions, there exists little evidence encompassing the broad range of effects of taxing corporations' foreign-source income on a worldwide or territorial basis. This paper takes a more comprehensive quantitative approach by examining stock market reactions surrounding three events over the course of which Japan's 2009 adoption of a...
Danehy, L J; Scutt, R C; Stonehill, E
Because the performance of shared service and tax-exempt status under Section 501(c)(3) of the Internal Revenue Code can be incompatible, hospitals planning to provide services to each other or to other organizations on a fee-for-service basis may wish to do so through a separate corporate entity. Using either a Section 501(e) shared service organization, a Sub-chapter T cooperative, or a taxable business corporation, a compromise can be reached between operational flexibility and tax benefits.
Full Text Available Tax policy is one of the most important policy in consideration of investment development in certain industry. Research by Newlon (1987, Swenson (1994 and Hines (1996 concluded that tax rate is one of the most important thing considered by investors in a foreign direct investment. One of tax policy could be used to attract foreign direct investment is income tax incentives. The attractiveness of income tax incentives to a foreign direct investment is as much as the attractiveness to a domestic investment (Anwar and Mulyadi, 2012. In this paper, we have conducted a study of income tax incentives in food and agriculture industry; where we conduct a thorough study of income tax incentives and corporate performance in Indonesian and Australian food and agriculture industry. Our research show that there is a significant influence of income tax incentives to corporate performance. Based on our study, we conclude that the significant influence of income tax incentives to Indonesian corporate performance somewhat in a higher degree than the Australian peers. We have also concluded that Indonesian government provide a relatively more interesting income tax incentives compare to Australian government. However, an average method of net income –a method applied in Australia– could be considered by Indonesian government to avoid a market price fluctuation in this industry.
Alan, Sule; Leth-Petersen, Søren; Munk-Nielsen, Anders
We estimate the effect of a Danish 1987 tax reform, which reduced the tax rate applied to interest deductions from 73% to 50% for households with high incomes, but less for households with middle or low incomes. Using high quality panel data we find that households responded to the reduced tax su...... subsidy by lowering interest payments and we find that the responsiveness to the tax subsidy varies by the initial level of interest payments....
De Waegenaere, A.M.B.; Wielhouwer, J.L.
The tax depreciation decision potentially has significant impact on the profitability of firms and projects. Indeed, the depreciation method chosen for tax purposes affects the timing of tax payments, and, as a consequence, it also affects the after-tax net present value of investment projects. Previous research focusses on the optimal choice of depreciation method under the assumption that the depreciation method has to be set ex ante and cannot be changed during the useful life of the asset...
Department of Veterans Affairs — The Consolidated Copayment Processing Center (CCPC) database contains Veteran patient contact and billing information in order to support the printing and mailing of...
Full Text Available The paper investigated the relationship between corporate tax optimization and the firm's value in the Tunisian context over an 11 year period. The empirical results revealed that tax optimization, accruals and investment increased the firm's value. After dividing the sample between listed and non-listed firms, we concluded that, compared to non-listed firms, the listed firms were better able to optimize tax through adopting a tax policy. Our findings help decision makers, researchers and practices to better understand the role of tax optimization in the management of firms and, also, in their performance.
Full Text Available Canada stands to lose a major competitive edge unless it responds to the challenges of the 2018 U.S. tax reforms by instituting reforms of its own. At 20.9 per cent, Canada’s tax burden on new investment (measured by the marginal effective tax rate or METR, is competitive when compared to countries in the Americas and Asia-Oceania, and it’s the second lowest among the G7 countries. However, the rules of the game are about to change with U.S. tax reform. Among the reforms the U.S. is bringing in are a drop in the federal corporate income tax rate from 35 per cent to 21 per cent, a ten-year window for full and partial expensing machinery and equipment, and other various rules that will incent companies to push profits into the U.S. and interest and other expenses into foreign jurisdictions. The result of this and other reforms will be a sharp drop in the U.S. METR by almost half – from 34. 6 per cent to 18.8 per cent. This means Canada will have a higher tax burden on capital than the U.S. Put simply, Canada and other countries will face a drop in revenue while the U.S. gains revenue. Alarm bells should be ringing among public policy-makers in Canada and elsewhere, since research shows that taxes are a significant factor in multinationals’ decisions on where to invest globally and how to finance it. The dramatic U.S. reforms will put Canada at a distinct disadvantage, dragged down further by its small market size, energy levies and regulatory burden. This paper examines the corporate tax-rate situation in 92 countries, with many either having reduced their rates recently or are planning to in the next few years. In Canada, the only movement has been in several provinces, entailing a small increase in British Columbia and small decreases in Saskatchewan and Quebec. And while the average METR among OECD countries has dropped in the past few years, Canada’s in 2017 was approximately the same as it was in 2010, climbing upward from a nadir
... return. Corporations that prepare financial statements are required by generally accepted accounting principles to identify and quantify all uncertain tax positions as described in Financial Accounting..., including International Financial Reporting Standards and country-specific generally accepted accounting...
Appeals to corporate responsibility often simply take for granted that businesses have ethical responsibilities that go beyond just respecting the law. This paper addresses arguments to the effect that businesses have no such responsibilities. The interesting claim is not that businesses have no ethical responsibility at all but that their primal responsibility is to increase their profits. The extent to which there is reason to take such arguments seriously delineates the limits of corporate...
Pedersen, Anders Branth; Nielsen, Helle Ørsted; Andersen, Mikael Skou
pesticide taxes on agriculture, which makes it interesting to analyze how effective they have been. Here the effects of the ad valorem tax (1996-2013) are analyzed. The case study demonstrates the challenges of choosing an optimal tax design in a complex political setting where, additionally, not all...
... 26 Internal Revenue 9 2010-04-01 2010-04-01 false Taxation of foreign corporations not engaged in U.S. business. 1.881-2 Section 1.881-2 Internal Revenue INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY (CONTINUED) INCOME TAX (CONTINUED) INCOME TAXES Foreign Corporations § 1.881-2 Taxation of foreign...
RTE's 2016 revenue stands at 4 446 million euro with a net income of 403 million euro. RTE continued its sustained investment programme with 1 519 million euro of investments aimed to reinforce electrical power supply security, develop cross-border capacities, accelerate digital transformation, and adapt the network to contribute to the success of energy transition. In 2016, favourable weather conditions were not sufficient to fully offset lower interconnection revenues resulting from narrowing electricity-price differentials with neighbouring countries and the strengthening of the tariff reduction policy for electricity-intensive customers. Effects of tariff reduction will be offset over the next financial years in accordance with the law on energy transition for green growth. In light of these factors, RTE's 2016 revenue of 4 446 million euro was down slightly compared to 2015 (-3%). 2016 net income of 403 million euro was up 6% compared to 2014 (379 million euro). 2015 net income (215 million euro) was exceptionally low due to the effect of the European Commission's decision dated 22 July 2015 regarding the tax treatment of provisions created between 1986 and 1997 for the renewal of the General Transmission Network ('RAG') facilities. 2016 net income was the result of good operating expense management and sustained revenue performance. 1 519 million euro of investments were made in 2016, 8% more than in 2015. As part of its industrial project launched in 2016, RTE strengthened its policy of adapting the network to the challenges of the energy transition and reoriented some investments in order to accelerate the implementation of digital technologies, with a view to ultimately having the top electrical and digital network in Europe. The level of investments in 2016 led to a slight increase in net debt (+3% for a net debt of 8 539 million euro at the end of 2016), which remains consistent with the maintenance of the company's financial balances. The strength of
Reinstein, A; Carmichael, B J; Spaulding, A D
The provisions of the Financial Accounting Standards Board (FASB) Statement No. 109, Accounting for Income Taxes, require all organizations that issue financial statements to shift the focus of their accounting for income taxes from the income statement to the balance sheet. This change can alter significantly a healthcare organization's financial position. The change also may affect the way in which investors, lenders, regulators, and other users of financial statements evaluate corporations in the healthcare industry. Hospitals and other healthcare organizations, particularly for-profit organizations, therefore, should review carefully their methods of accounting for such items as deferred tax assets and loss and expense reserves.
Maarten van 't Riet; Arjan Lejour
With a novel approach this paper sheds light on the international tax planning possibilities of multinationals. The international corporate tax system is considered a network, just like for transportation, and â€˜shortestâ€™ paths are computed, minimizing tax payments for the multinationals when repatriating profits. Read the accompanying press release and background document A and B . The network consists of 108 jurisdictions, and the â€˜shortestâ€™ paths are constructed from the rates of co...
Murray, Matthew N.
Argues that shifting to an indirect tax system (a national sales tax) will not necessarily reduce tax avoidance and tax evasion behavior by businesses and individuals, particularly if the tax rate is set high to maintain revenue neutrality. Lack of experience in administering a high-rate, indirect tax system precludes definitive statements regarding the likely extent of tax base erosion under a national sales tax.
M.Comm. (International Accounting) Recently, there has been a spate of reported cases of large corporate entities paying very little, or no income tax, despite the appearance of being profitable. Enron conducted a lot of business through special purpose vehicle (SPV) companies that were structured specifically for the purpose of paying very little, if any, corporate tax, without having to reduce reported book net profits to achieve this. A study in October 2012 of Starbucks by Reuters foun...
This report presented a brief comment on policy issues concerning taxes imposed on the resource industry. It was suggested that if the resource industry in Canada is to remain competitive beyond the current boom, the federal government should provide a more stable tax environment for investment in the longer run. With the current internationally competitive tax rates and high neutrality among energy sectors, there is presently a unique opportunity to settle this issue and to improve the tax system as a whole. It was suggested that the federal corporate income tax rate on resource profits should be reduced from 28 per cent to 21 per cent as it is in other sectors. It was also suggested that the resource allowance should be replaced with deductibility for resource royalties as payment for the cost of using provincially owned resources. This report also described other changes that could be implemented to improve the tax system and to enhance the competitiveness of the resource sector. It was noted that the changes could result in a single corporate income tax rate on all industrial activities by 2005
Kuban, D.P.; Noakes, M.W.; Bradley, E.C.
The Advanced Servomanipulator (ASM) System consists of three major components: the ASM slave, the dual arm master controller or master, and the control system. The ASM is a remotely maintainable force-reflecting servomanipulator developed at the Oak Ridge National Laboratory (ORNL) as part of the Consolidated Fuel Reprocessing Program of (CFRP). This new manipulator addresses requirements of advanced nuclear fuel reprocessing with emphasis on force reflection, remote maintainability, and reliability. It uses an all-gear force transmission system. The master arms were designed as a kinematic replica of ASM and use cable force transmission. Special digital control algorithms were developed to improve the system performance. The system is presently operational and undergoing evaluation. Preliminary testing has been completed and is reported. The system is now undergoing commercialization by transferring the technology to the private sector
Gyimóthy, Szilvia; Munar, Ana Maria; Larson, Mia
This study revisits and integrates the insights of recent studies on emergent social media strategies deployed by destination and event management organisations. In a comparative analysis Munar (2012) identified four generic approaches pursued by national tourism boards in the Nordic region, while...... Gyimóthy & Larson (2014) portrayed three digital value co-creation strategies deployed by festival social media. Both frameworks provided novel analytical typologies which identified a series of categories (mimetic, analytic, immersion, advertising and insourcing, crowdsourcing and community consolidation......). This paper discusses the complementary nature of these conceptual proposals and advances an integrated conceptual framework of social media strategies. Based on the empirical findings of a case study that revisits evolving digital and social media strategies of European DMOs this paper maps the dynamics...
Sautter, Robert L; Thomson, Richard B
The manner in which medical care is reimbursed in the United States has resulted in significant consolidation in the U.S. health care system. One of the consequences of this has been the development of centralized clinical microbiology laboratories that provide services to patients receiving care in multiple off-site, often remote, locations. Microbiology specimens are unique among clinical specimens in that optimal analysis may require the maintenance of viable organisms. Centralized laboratories may be located hours from patient care settings, and transport conditions need to be such that organism viability can be maintained under a variety of transport conditions. Further, since the provision of rapid results has been shown to enhance patient care, effective and timely means for generating and then reporting the results of clinical microbiology analyses must be in place. In addition, today, increasing numbers of patients are found to have infection caused by pathogens that were either very uncommon in the past or even completely unrecognized. As a result, infectious disease specialists, in particular, are more dependent than ever on access to high-quality diagnostic information from clinical microbiology laboratories. In this point-counterpoint discussion, Robert Sautter, who directs a Charlotte, NC, clinical microbiology laboratory that provides services for a 40-hospital system spread over 3 states in the southeastern United States explains how an integrated clinical microbiology laboratory service has been established in a multihospital system. Richard (Tom) Thomson of the NorthShore University HealthSystem in Evanston, IL, discusses some of the problems and pitfalls associated with large-scale laboratory consolidation. Copyright © 2015, American Society for Microbiology. All Rights Reserved.
Rasmussen, T.L.; Schoonen, D.H.; Feldman, E.M.; Fisher, M.W.
The Department of Energy's (DOE) Office of Civilian Radioactive Waste Management (OCRWM) is funding a program to consolidate commercial spent fuel for testing in dry storage casks and to develop technology that will be fed into other OCRWM programs, e.g., Prototypical Consolidation Demonstration Program (PCDP). The program is being conducted at the Idaho National Engineering Laboratory (INEL) by the INEL Operating Contractor EG and G Idaho, Inc. Hardware and software have been designed and fabricated for installation in a hot cell adjacent to the Test Area North (TAN) Hot Shop Facility. This equipment is used to perform dry consolidation of commercial spent fuel from the Virginia Power (VP) Cooperative Agreement Spent Fuel Storage Cask (SFSC) Demonstration Program and assemblies that had previously been stored at the Engine Maintenance and Disassembly (EMAD) facility in Nevada. Consolidation is accomplished by individual, horizontal rod pulling. A computerized semiautomatic control system with operator involvement is utilized to conduct consolidation operations. During consolidation operations, data is taken to characterize this technology. Still photo, video tape, and other documentation will be generated to make developed information available to interested parties. Cold checkout of the hardware and software was completed in September of 1986. Following installation in the hot cell, consolidation operations begins in May 1987. Resulting consolidated fuel will be utilized in the VP Cooperative Agreement SFSC Program
Rasmussen, T.L.; Schoonen, D.H.; Fisher, M.W.
The Department of Energy's (DOE) Office of Civilian Radioactive Waste Management (OCRWM) is funding a Program to consolidate commercial spent fuel for testing in dry storage casks and to develop technology that will be fed into other OCRWM Programs, e.g., Prototypical Consolidation Demonstration Program. The Program is being conducted at the Idaho National Engineering Laboratory (INEL) by the Operating Contractor, EGandG Idaho, Inc. Hardware and software have been designed and fabricated for installation in a hot cell adjacent to the Test Area North (TAN) Hot Shop Facility. This equipment will be used to perform dry consolidation of commercial spent fuel from the Virginia Power (VP) Cooperative Agreement Spent Fuel Storage Cask (SPSC) Demonstration Program and assemblies that had previously been stored at the Engine Maintenance and Disassembly (EMAD) facility in Nevada. Consolidation will be accomplished by individual, horizontal rod pulling. A computerized semi-automatic control system with operator involvement will be utilized to conduct consolidation operations. Special features have been incorporated in the design to allow crud collection and measurement of rod pulling forces. During consolidation operations, data will be taken to characterize this technology. Still photo, video tape, and other documentation will be generated to make developed information available to interested parties. Cold checkout of the hardware and software will complete in September of 1986. Following installation in the hot cell, consolidation operations will begin in January 1987. Resulting consolidated fuel will be utilized in the VP Cooperative Agreement SFSC Program
Streifel, James S.; And Others
Examination of 19 school district consolidations in 10 states, 1980-84, revealed that, of 6 expenditure categories, only administration showed significant savings 3 years after consolidation, when compared to changes in state average costs during that period. Changes in other expenditure categories varied widely among districts. Contains 22…
Department of Education, Washington, DC.
Intended for financial aid counselors, this document provides guidelines to the Federal Direct Consolidation Loan Program for borrowers who are in school, as well as those in repayment, or in default. An introductory section explains the basics of the consolidated loan program, loan categories, and interest rates. Next, standards for borrower…
District consolidation is a highly emotional process. One key to success is sticking to the facts. In Iowa, school districts facing financial difficulties or enrollment concerns do not have to move directly to consolidation. In many cases, districts begin by developing sharing agreements. These sharing agreements may start with simple sharing of…
Jack M. Mintz
Full Text Available The purpose of this report is to provide cost of capital formulae for assessing the effects of taxation on the incentive to invest in oil and gas industries in Canada. The analysis is based on the assumption that businesses invest in capital until the after-tax rate of return on capital is equal to the tax-adjusted cost of capital. The cost of capital in absence of taxation is the inflation-adjusted cost of finance. The after-tax rate of return on capital is the annualized profit earned on a project net of the taxes paid by the businesses. For this purpose, we include corporate income, sales and other capital-related taxes as applied to oil and gas investments. For oil and gas taxation, it is necessary to account for royalties in a special way. Royalties are payment made by businesses for the right to extract oil and gas from land owned by the property holder. The land is owned by the province so the royalties are a rental payment for the benefit received from extracting the product from provincial lands. Thus, provincial royalty payments are a cost to oil and gas companies for using public property. However, since the provincial government is responsible for the royalty regime and could use taxes like the corporate income tax to extract revenue, one might think of royalties as part of the overall fiscal regime to raise revenue. In principle, one should subtract the rental benefit received from oil and gas businesses from taxes and royalty payments to assess the overall fiscal impact. This is impossible to do without measuring some explicit rental rate for use of provincial property. Further, royalty payments may distort economic decisions unlike a payment based on the economic rents earned on oil and gas projects. Instead, for comparability across jurisdictions, one might calculate the aggregate tax and royalty effective tax rates (such as between Alberta and Texas.
The statistics presents statements of environmental taxes for the period 1991-2000 (and budget figure for 2001). Environmental taxes is a collective concept for pollution, energy, transportation and resource related taxes. Income of the government from environmental taxes have increased from 30,0 billions DDK in 1991 to 60,6 billions DDK in 2000 - a little more than a doubling. The environmental taxes' part of the total taxes has increased from 7,5% in 1991 to 9,7% in 2000. In 2000 the energy taxes are 55%, the transportation taxes 38% and the pollution and resource taxes 7% of the environmental taxes. (EHS)
Recent developments in China's oil market have reignited the interest of multinational oil and gas companies in China. New onshore and offshore blocks are being granted, and the Tarim basin has been opened to foreign participation for the first time. Foreign participation is also being sought in refining and other downstream areas. Though Chinese officials have long been viewed as difficult negotiators, the tax provisions applicable to oil and gas exploration and production in China are some of the more generous in the area. This article describes some of the relevant features of the system and some of the problem areas. The paper describes production sharing contracts, applicable taxes, gross income determination, taxable income, tax consolidation, overseas charges, and withholding taxes on payments to subcontractors and employees
As economic globalization proceeds, tax policies of one nation influence others more and greater pressures are imposed on tax systems and tax administrations．The possibility of tax avoidance will expand if cross-border transactions are abused．Specifically, tax system differentials among countries increase the opportunity for tax avoidance．Under some tax avoidance schemes, foreign entities which have no or little economic substance are used to create artificial losses, so that they can minimiz...
... 26 Internal Revenue 18 2010-04-01 2010-04-01 false Personal holding company tax. 301.6501(f)-1... Collection § 301.6501(f)-1 Personal holding company tax. If a corporation which is a personal holding company... time during the last half of such taxable year, more than 50 percent in value of the outstanding...
Using the universe of South African corporate tax returns for 2009–14, we estimate profit- and debt-shifting responses in South Africa. We find evidence that South African subsidiaries engage in profit shifting and that profit-shifting responses to tax incentives across all channels...
H. Gribnau (Hans)
textabstractThe international tax system is the result of the interaction of different actors who share the responsibility for its integrity. States and multinational corporations both enjoy to a certain extent freedom of choice with regard to their tax behaviour – which entails moral
The international tax system is the result of the interaction of different actors who share the responsibility for its integrity. States and multinational corporations both enjoy to a certain extent freedom of choice with regard to their tax behaviour – which entails moral responsibility. Making,
Full Text Available In the article an analysis of the impact of corruption, both administrative and state capture, on the tax structure is carried out. The authors established a negative correlation between the degree of corruption and the height of the effective tax burden, while isolating a simultaneous directly proportional impact of the nominal tax burden (which could reflect state intervention - the main corruption factor on the scope of corruption. The effects of corruption on the decrease of individual taxes' share in GDP are diversified, with impact on direct taxes as a whole being more observable. The mode of tax assessment significantly determines exposure of certain tax to the administrative corruption: it is generally larger in case of taxes assessed by the decision of the competent tax officials who are carrying out both assessment and audit, while in the case of self-assessment and withholding they just perform audits implying limited exposure to corruption. Corruptive state capture is present in the case of taxes which are important for influential corruptors. That is why in Serbia laws preventing taxation of capital gains or heavier taxation of dividends and other income paid to non-residents located in the tax havens were adopted, while by-laws which should have enabled implementation of prescribed lump sum taxation based on external signs of wealth have not been enacted. The authors concluded that the anti-corruption strategy should rely on the increasing role of self-assessment, which could reduce the room for administrative corruption. Unclear and imprecise formulations of the tax norms facilitate corruption, because they create room for arbitrariness in interpretation and implementation of the laws and by-laws. It is therefore necessary to surprises discretion, simplify tax procedure and diminish the number of tax relief's.
1 Abstract: The tax system and agreements on the avoidance of double taxation This diploma thesis "The tax system and agreements on the avoidance of double taxation" is focused on practical issues in the field of using international corporate structure in order to decrease the tax liability applicable on entrepreneurs. The diploma thesis includes the basic description of the legal rules applicable in the Czech Republic, such as acts and also international treaties. In the field of EU law, the...
Aim/purpose - Today, international capital flows play a leading role in shaping global economic relations and directly impact the budgets of many states. What is of major importance in this process are the differences and legal loopholes in tax systems of individual states, which allow profits to be taxed at the minimum percentage rate. Tax avoidance is particularly popular among corporations operating in global markets, which use various mechanisms for this purpose. The main aim of this arti...
Siemers, Lars-H. R.; Zöller, Daniel
Political economy aspects make progressive income taxation and taxation of capital income imperative in practise. International tax competition and profit shifting, in turn, put pressure on corporate and capital taxes. Hence, the scope for a politically feasible change-over to a status of improved taxation is little. We provide an extended dynamic general equilibrium model and analyze politically feasible recent reform proposals referring neutrality. We then propose an alternative tax reform ...
Full Text Available The purpose of this study is to analyze and understand the recently introduced form of managementof a company limited by shares. The Law no. 441/2006, which fundamentally amended Company Law,created this form of controlling the company, the corporate governance, but the legislation does not explicitlydefine what it wants to achieve through this instrument. This topic is recent in research as the theme ofgerman-roman commercial law systems (in French corporate governance system was introduced in 1966 andin Romania in 2006 but in terms of Anglo-Saxon law, the topic has been addressed years since 1776 (AdamSmith: The Wealth of Nations The concept of corporate governance would like, as a result, to establish somerules that companies must comply in order to achieve effective governance, transparent and beneficial forboth shareholders and for the minority. Corporate governance is a key element with an aim at improvingefficiency and economic growth in full accordance with the increase of investors’ confidence. Corporategovernance assumes a series of relationship between the company management, leadership, shareholders andthe other people concerned. Also corporate governance provides for that structure by means of which thecompany’s targets are set out and the means to achieve them and also the manner how to monitor such.
Zolotor, Adam J
Corporal punishment is used for discipline in most homes in the United States. It is also associated with a long list of adverse developmental, behavioral, and health-related consequences. Primary care providers, as trusted sources for parenting information, have an opportunity to engage parents in discussions about discipline as early as infancy. These discussions should focus on building parents' skills in the use of other behavioral techniques, limiting (or eliminating) the use of corporal punishment and identifying additional resources as needed. Copyright © 2014 Elsevier Inc. All rights reserved.
..., Accountants, Inc. and Accountant Temps Mountain View, CA; Amended Certification Regarding Eligibility To Apply... on-site leased workers from ATR International, Accountants, Inc., and Accountant Temps, Mountain View... a separate unemployment insurance (UI) tax account under the name Microsemi Corporation. Accordingly...
Full Text Available In the article the features of tax control in the system of taxes administration were investigated. The basic approaches to the determination of tax control were defined. Principles of tax control that must be kept were defined and it will ensure efficiency and effectiveness of tax control. Basic forms of tax control were characterized. An advantages of horizontal monitoring that is one of the form of tax controls were directed. Key words: tax control, tax control forms, horizontal monitoring, documentaries, desk and actual checks.
Ketchum, K; Lavigne, R.; Plummer, R.
The oil sands are a strategic Canadian resource for which federal and provincial governments provide financial incentives to develop and exploit. This report describes the Oil Sands Tax Expenditure Model (OSTEM) developed to estimate the size of the federal income tax expenditure attributed to the oil sands industry. Tax expenditures are tax concessions which are used as alternatives to direct government spending for achieving government policy objectives. The OSTEM was developed within the business Income Tax Division of Canada's Department of Finance. Data inputs for the model were obtained from oil sands developers and Natural Resources Canada. OSTEM calculates annual revenues, royalties and federal taxes at project levels using project-level projections of capital investment, operating expenses and production. OSTEM calculates tax expenditures by comparing taxes paid under different tax regimes. The model also estimates the foregone revenue as a percentage of capital investment. Total tax expenditures associated with investment in the oil sands are projected to total $820 million for the period from 1986 to 2030, representing 4.6 per cent of the total investment. 10 refs., 2 tabs., 7 figs
Balboni, John A.; Gokcen, Tahir; Hui, Frank C. L.; Graube, Peter; Morrissey, Patricia; Lewis, Ronald
The paper describes the consolidation of NASA's high powered arc-jet testing at a single location. The existing plasma arc-jet wind tunnels located at the Johnson Space Center were relocated to Ames Research Center while maintaining NASA's technical capability to ground-test thermal protection system materials under simulated atmospheric entry convective heating. The testing conditions at JSC were reproduced and successfully demonstrated at ARC through close collaboration between the two centers. New equipment was installed at Ames to provide test gases of pure nitrogen mixed with pure oxygen, and for future nitrogen-carbon dioxide mixtures. A new control system was custom designed, installed and tested. Tests demonstrated the capability of the 10 MW constricted-segmented arc heater at Ames meets the requirements of the major customer, NASA's Orion program. Solutions from an advanced computational fluid dynamics code were used to aid in characterizing the properties of the plasma stream and the surface environment on the calorimeters in the supersonic flow stream produced by the arc heater.
Diplomová práce se zabývá problematikou konsolidace účetní závěrky. Práce je členěna na dvě části. První část je zaměřena na sestavení konsolidované účetní závěrky za českou část skupiny podniků. Druhá část se zabývá analýzou výkonnosti sestavené konsolidované účetní závěrky a jednotlivých společností finančními ukazateli. Práce rovněž obsahuje návrhy na zlepšení ekonomické situace holdingu či jednotlivých společností. Master's thesis deals with the consolidation of the financial statement...
Schneider, Friedrich; Kirchler, Erich; Maciejovsky, Boris
Although from an economic point of view, legal considerations apart, tax avoidance, tax evasion and tax flight have similar effects, namely a reduction of revenue yields, and are based on the same desire to reduce the tax burden, it is likely that individuals perceive them as different and as unequally fair. Overall, 252 fiscal officers, business students, business lawyers, and entrepreneurs produced spontaneous associations to a scenario either describing tax avoidance, tax evasion, or tax f...
Arguments for eliminating the double taxation of dividends apply only to dividends paid by corporations to individuals. The double (and multiple) taxation of dividends paid by one firm to another intercorporate dividends - was explicitly included in the 1930s to eliminate pyramidal corporate groups. These structures exist elsewhere, and are associated with corporate governance problems, corporate tax avoidance, and a greater concentration of economic power than is currently possible in the Un...
Jurcau Anca Sabina
Full Text Available This paper is about how multinational enterprises choose transfer prices in the presence of differential corporate income tax rates. A transfer prince is a value placed on the goods which are traded between divisions of an organization. We review and exte
Full Text Available This paper puts a conceptual framework to outline research for corporate social responsibility (CSR audit based on the analysis of current CRS literature and audit models as implementation of CSR. It is intended to make clear the phenomena about the relationship between audit, implementation of business ethics principles and corporate governance. However, most studies do not take into account modify CSR audit. This paper reports part of a research we carried out on the theoretical interpretation of the corporate social responsibility audit. This paper examines the corporate social responsibility audit as a composition of four categories - management system audits, on-site audits, verbal probability expressions (VPE audits and technology audits. The paper concludes suggests to systematize multiple audits so that they can be conduct in three types of audits - environmental management audits covering in-house companies, environmental technology audits of products, and environmental audits of sites, including non-manufacturing sites and non-consolidated subsidiaries.
Corporate entreprenørskab kan blive svaret på, hvordan Danmark fremmer en mere videnintensiv produktion. Begrebet er blevet anvendt til at forklare forskellige organisatoriske fænomener alt fra strategi over ledelse i al almindelighed til innovation, hvilket har medført en mangfoldighed af begreb...
path of an entrepreneurial opportunity of the Danish corporate venture capitalist,Danfoss A/S. This paper distinguishes itself from previous research done on entrepreneurialopportunities by creating a holistic and conceptual framework, which broadens and expands theperception of the market participants...
LaFrance, Julie; Lehmann, Martin
Predominantly since the 1992 Rio Summit, corporations have been increasingly pursuing partnerships with public institutions including governments, international organisations and NGOs that aim to contribute to sustainable development activities. Both the business community and public organisation...... for cooperation on community development programs in Myanmar....
HARALAMBIE GEORGE ALIN
Full Text Available The economic downturn, affecting lately the states all over the world, imposed their governments to take measures in fiscal and budget plan in order to reduce the budget deficit, by reducing spending and increasing the revenue mobilized to the budget, especially tax revenues, by increasing the tax burden both for the individuals and legal entities. Reforming the tax system at European level involved widening the tax base both for the income earned by individual taxpayers and those made by companies to the detriment of effective tax rates increase. The share in GDP of mandatory levies is uneven across the EU. In the year 2012, it range from 30% in Lithuania with 50% to Denmark. Fiscal consolidation in the member states aimed reforms in the field of indirect taxation (by increasing VAT- 1% for the Czech Republic, Slovakia, Italy, Poland and Finland to 7% in Hungary with 5%, Romania, 4%, excise duties and environmental taxes and a downward trend in the rate of taxation in the case of direct taxes through progressive taxation of personal income, which led to increased revenue due compulsory levies in most countries of the European Union. 13 EU countries have acted to increase the VAT rate between 2010-2014.
Smith, Pamela C
Strategic tax planning issues are important to the nonprofit health care sector, despite its philanthropic mission. The consolidation of the industry has led management to fight for resources and develop alternative strategies for raising money. When management evaluates alternative collaborative structures to increase efficiency, the impact on governance structures must also be considered. The increased governmental scrutiny of joint ventures within the health care sector warrants management's attention as well. The financial incentives must be considered, along with the various tax policy implications of cross-sector collaborations.
Raimondos-Møller, Pascalis; Woodland, Alan D.
This paper introduces an index of tax optimality thatmeasures the distance of some current tax structure from the optimal taxstructure in the presence of public goods. In doing so, we derive a [0, 1]number that reveals immediately how far the current tax configurationis from the optimal one and......, thereby, the degree of efficiency of a taxsystem. We call this number the Tax Optimality Index. We show howthe basic method can be altered in order to derive a revenue equivalentuniform tax, which measures the size of the public sector. A numericalexample is used to illustrate the method developed.......JEL Code: H21, H41.Keywords: Tax optimality index, excess burden, distance function.Authors Affiliations: Raimondos-Møller: Copenhagen Business School, CEPR,CESifo, and EPRU. Woodland: University of Sydney....
Rossing, Christian Plesner
This paper examines how a functional tax strategy impacts the management control system (MCS) in a multinational enterprise (MNE) facing transfer pricing tax risks. Based on case study findings it is argued that the MCS in a multinational setting is contingent upon the MNE's response to its tax...... environment. Moreover, the paper extends existing contingency-based theory on MCS by illustrating the role of inter-organisational network collaboration across MNE transfer pricing tax experts. This collaboration, caused by a widely dispersed tax knowledge base, fuels the formal interactive control system...... and reduces tax uncertainty. The paper adopts an interdisciplinary approach for explaining findings, using contingency-based theory and network theory at the inter-organisational level....
Kirchler, Erich; Wahl, Ingrid
Surveys on tax compliance and non-compliance often rely on ad hoc formulated items which lack standardization and empirical validation. We present an inventory to assess tax compliance and distinguish between different forms of compliance and non-compliance: voluntary versus enforced compliance, tax avoidance, and tax evasion. First, items to measure voluntary and enforced compliance, avoidance, and evasion were drawn up (collected from past research and newly developed), and tested empirically with the aim of producing four validated scales with a clear factorial structure. Second, findings from the first analyses were replicated and extended to validation on the basis of motivational postures. A standardized inventory is provided which can be used in surveys in order to collect data which are comparable across research focusing on self-reports. The inventory can be used in either of two ways: either in its entirety, or by applying the single scales independently, allowing an economical and fast assessment of different facets of tax compliance. PMID:20502612
Philipp Doerrenberg; Andreas Peichl
As the link between tax compliance and tax morale is found to be robust, finding the determinants of tax morale can help to understand and fight tax evasion. In this paper we analyze the effect of progressive taxation on tax morale in a cross-country approach - which has not been investigated before. Our theoretical analysis leads to two testable predictions. First, an individual's tax morale is higher, the more progressive the tax schedule is. Second, the impact of tax progressivity on tax m...