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Accumulation of Tax-Loss Carryforwards: The Role of Book-Tax Non-Conformity 税收损失结转的积累:账面税收不符合的作用
Pub Date : 2016-06-13 DOI: 10.2139/ssrn.2794992
Saskia Kohlhase
Using 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 differences. Only firms with positive pre-tax book income and negative taxable income (double-picture firms) drive the positive association between TLCFs and temporary book-tax differences. Conversely, the positive association of TLCFs and permanent book-tax differences is present for double-picture firms and the remaining firms. The results suggest that double-picture firms, which feature high TLCFs compared to their size and to the remaining firms, use temporary book-tax differences to report a lower taxable income than pre-tax book income. Thus, this paper contributes to the understanding of the drivers of rising TLCFs. This is important, as offsetting TLCFs against future profits jeopardizes a country’s tax revenue.
本文利用保密的企业所得税申报数据,研究了账面税收不合规(以账面税收差异衡量)与税收损失结转(tlcf)之间的关系。我发现tlcf与暂时和永久的账面税差异呈正相关。只有税前账面收入为正、应税收入为负的公司(双图公司)才会推动tlcf与临时账面税收差异之间的正相关关系。相反,tlcf和永久账面税收差异的正相关存在于双重图景公司和剩余公司。结果表明,与规模和其他公司相比,具有高tlcf特征的双重图景公司使用临时账面税收差异来报告比税前账面收入更低的应税收入。因此,本文有助于理解tlcf上升的驱动因素。这一点很重要,因为用tlcf抵消未来利润会危及一个国家的税收。
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引用次数: 0
On the Timing and Pricing of Dividends: Reply 论股利的时机与定价:答
Pub Date : 2016-06-03 DOI: 10.2139/ssrn.2787713
Jules H. van Binsbergen, R. Koijen
Schulz (2016) replicates the findings of van Binsbergen, Brandt, and Koijen (2012)--henceforth, BBK--and agrees that the average pretax returns on short-term dividend strips are higher than those of the index, but argues that the after-tax returns are not. He thus provides a possible economic interpretation of the results in BBK: taxes. Schulz (2016) estimates the differential tax rates of dividends versus capital gains from ex-dividend day returns. We show that these estimated tax rates are suspect and imprecisely measured, peaking at over 100 percent in some periods. The results in BBK are robust to using tax rates from the literature (Sialm 2009). The arguments in Schulz (2016) thus crucially depend on implausibly large tax estimates. We further discuss two other financial market imperfections discussed in the literature and show that they are also unlikely to explain the results in BBK.
Schulz(2016)复制了van Binsbergen、Brandt和Koijen(2012)的研究结果,并同意短期股息条的平均税前回报率高于指数,但认为税后回报率并非如此。因此,他为BBK的结果提供了一个可能的经济解释:税收。Schulz(2016)估计股息与除息日回报的资本收益的差异税率。我们表明,这些估计的税率是可疑的,测量不精确,在某些时期达到100%以上的峰值。BBK的结果对使用文献中的税率是稳健的(Sialm 2009)。因此,舒尔茨(2016)的论点在很大程度上依赖于令人难以置信的巨额税收估计。我们进一步讨论了文献中讨论的另外两个金融市场缺陷,并表明它们也不太可能解释BBK的结果。
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引用次数: 12
Corporate Taxation and Location of Intangible Assets: Patents vs. Trademarks 企业税收与无形资产的定位:专利与商标
Pub Date : 2016-03-23 DOI: 10.2139/ssrn.2753656
O. Dudar, Johannes Voget
Numerous empirical studies have analysed the influence of corporate taxation on the location of intangible assets within a company group. However, the previous literature has rather focused on studying the impact of taxation on patent location choices assuming that these assets represent the rest of intangibles as well. This paper complements previous studies by estimating and comparing the tax elasticities of two different types of intangibles - patents and trademarks. We employ data on European and US patent and trademark applications in the period of 1996-2012 and estimate a multinomial logit model that incorporates various observed and unobserved factors of the intangible's location choice. According to our main findings, trademarks are more sensitive to changes in taxation as compared to patents. This implies that firms use trademarks more eagerly for tax planning purposes than patents.
大量实证研究分析了公司税对公司集团内无形资产位置的影响。然而,以前的文献更侧重于研究税收对专利地点选择的影响,假设这些资产也代表了其余的无形资产。本文通过估算和比较两种不同类型的无形资产——专利和商标的税收弹性来补充以往的研究。我们采用1996-2012年期间欧洲和美国专利和商标申请的数据,并估计了一个包含各种无形资产位置选择的观察和未观察因素的多项logit模型。根据我们的主要发现,与专利相比,商标对税收的变化更为敏感。这意味着企业在税收规划方面比专利更热衷于使用商标。
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引用次数: 20
CEO Severance Pay and Corporate Tax Planning 首席执行官遣散费和公司税收筹划
Pub Date : 2016-01-06 DOI: 10.2139/ssrn.2802426
J. Campbell, Jenny Xinjiao Guan, Oliver Zhen Li, Zhenlong Zheng
We examine the association between CEO severance pay (i.e., payment a CEO would receive if s/he is involuntarily terminated) and corporate tax planning activities. We find that CEO severance pay is positively associated with corporate tax planning, consistent with CEO severance pay providing contractual protection against managers' career concerns and thereby inducing otherwise risk-averse managers to engage in incremental levels of tax planning. This result holds under an instrumental variable approach and propensity score matching, and survives alternative measures of CEO severance pay and corporate tax planning. Finally, we find that severance pay provides stronger tax planning incentives in situations where managers are expected to face greater career concerns—when they are less experienced, when they face stronger shareholder monitoring, and when they manage firms with higher idiosyncratic volatility. Overall, our results suggest that CEO severance pay represents a form of efficient contracting with otherwise risk-averse managers.
我们考察了CEO离职补偿金(即CEO被非自愿解雇后将获得的补偿金)与公司税务筹划活动之间的关系。我们发现,CEO遣散费与企业税收筹划呈正相关,这与CEO遣散费提供契约保护,防止经理人的职业担忧,从而诱导原本厌恶风险的经理人参与增量水平的税收筹划是一致的。这一结果在工具变量方法和倾向得分匹配下成立,并且在CEO遣散费和企业税收筹划的替代措施下成立。最后,我们发现,在管理者面临更大的职业担忧的情况下,当他们经验不足、面临更强的股东监督、以及管理具有更高特质波动性的公司时,遣散费提供了更强的税收筹划激励。总体而言,我们的研究结果表明,首席执行官的遣散费代表了一种有效的合同形式,否则风险厌恶的经理。
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引用次数: 18
Book-Tax Conformity and Reporting Behavior – A Quasi-Experiment 书税一致性和报告行为——一个准实验
Pub Date : 2016-01-01 DOI: 10.2139/ssrn.2760323
Marcia Evers, Ina Meier, Katharina Finke
We examine how a comprehensive change in book-tax conformity affects firms' reporting behavior. To this end, we exploit a Reform Act as a quasi-natural experiment which implied a decrease in book-tax conformity in Germany in 2010. In particular, this reform allows firms to exercise tax accounting options independently from financial accounting. Our study builds on a unique dataset of linked individual financial statements and actual tax return data. It covers roughly 150 incorporated firms for the years 2008 to 2012. Exploiting the exceptional change in conformity, we contribute to the ongoing debate on the impact of booktax conformity. Our results show that profitable companies, which have a clear tax sheltering incentive, actually use the newly introduced reporting leeway to manage taxable income downwards. This is especially attributable to companies exploiting favorable tax depreciation rules. Moreover, we find larger opportunistic tax reporting responses for small companies with less complex and predominantly domestic group structures. In addition, we observe that a decrease in book-tax conformity induces a decrease in the general persistence of taxable income, but at the same time gives rise to higher financial earnings persistence. This corroborates our finding of increased tax sheltering activity in post reform years.
我们研究了帐面税一致性的全面变化如何影响公司的报告行为。为此,我们利用一项改革法案作为准自然实验,这意味着2010年德国书本税一致性的降低。特别是,这项改革允许企业独立于财务会计行使税务会计选择权。我们的研究建立在一个独特的数据集上,该数据集将个人财务报表和实际纳税申报数据联系在一起。它涵盖了2008年至2012年期间约150家注册公司。利用一致性的特殊变化,我们为正在进行的关于图书税一致性影响的辩论做出了贡献。我们的研究结果表明,具有明确避税激励的盈利公司实际上利用新引入的报告余地来向下管理应税收入。这主要是由于企业利用了优惠的税收折旧规则。此外,我们发现,对于那些不太复杂、主要是国内集团结构的小公司,机会主义的纳税报告反应更大。此外,我们观察到,账面税收一致性的降低会导致应税收入的总体持久性降低,但同时也会导致更高的财务收益持久性。这证实了我们的发现,即在改革后的几年里,避税活动有所增加。
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引用次数: 3
Tax Compliance with Strategic Auditors: An Experimental Study 战略审计师的税务遵从:一项实验研究
Pub Date : 2015-10-26 DOI: 10.2139/ssrn.2680463
Yutaro Murakami, S. Taguchi
The purpose of this study is to experimentally investigate an analytical model of tax compliance, assuming a game-theoretic situation between a taxpayer and a tax auditor. Specifically, we focus on the following three research questions. First, would the taxpayer’s behavior change if the tax auditor is a human or a computer, ceteris paribus? Second, how do changes of the tax rate affect the taxpayer’s and auditor’s behavior? Third, what influence does personality have on the tax compliance of taxpayers?The main results of this study are as follows. First, the taxpayer evades less when the tax auditor is a human than when it is a computer. Second, a decrease in the tax rate can increase the taxpayer’s tax compliance behavior. Third, the compliance rate increases among taxpayers who are younger, more trustworthy, and have lower levels of strategic reciprocity.
本研究的目的是在假设纳税人与税务稽核员之间的博弈情况下,对税收合规的分析模型进行实验研究。具体来说,我们主要关注以下三个研究问题。首先,如果税务审计员是人还是电脑,其他条件不变,纳税人的行为会改变吗?第二,税率的变化如何影响纳税人和审计师的行为?第三,人格对纳税人纳税合规性的影响是什么?本研究的主要结果如下:首先,当税务审计员是人的时候,纳税人的逃税行为要比当税务审计员是电脑的时候少。第二,降低税率可以增加纳税人的纳税合规行为。第三,在更年轻、更值得信赖、战略互惠水平较低的纳税人中,合规率上升。
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引用次数: 3
The Three Hurdles of Tax Planning: How Business Context, Aims of Tax Planning, and Tax Manager Power Affect Tax Expense 税收筹划的三个障碍:商业环境、税收筹划目标和税务经理权力如何影响税收支出
Pub Date : 2015-09-29 DOI: 10.2139/ssrn.2512177
Anna F. Feller, Deborah Schanz
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 planning methods are. available (defined by business context), desirable (given via aims of tax planning), and implementable (determined by tax manager power). A large part of previous research has estimated the influence of firm characteristics, which we define as part of the business context, on the tax expense, while the other influences that we identify have largely been left "out of the equation". In order to apply and operationalize the identified three-hurdle concept, we construct five short, real-world company case studies. In these case studies, we show how variation in two key constructs across companies leads to different levels of tax expense. First, companies vary widely in the aggressiveness of their aims of tax planning. Second, tax managers can assume very different levels of power in their organization, determining the ability to implement tax planning methods. In conclusion, we provide generalizable insights into the tax planning process of companies which help to explain the observed variation in tax expenses across firms.
为什么有些公司比其他公司交更多的税是一个被广泛研究的话题。一个著名的可疑解释是一种叫做避税的现象。我们通过对19位德国税务专家的一系列深入访谈,形成了对企业税收筹划影响的整体理论概念。我们的研究结果表明,税收筹划过程中的三个不同障碍可以解释不同公司的税收费用水平。这三个障碍就是税收筹划方法。可用(由业务环境定义),可取(通过税收规划的目标给出)和可实施(由税务经理权力决定)。之前的大部分研究都估计了企业特征(我们将其定义为商业环境的一部分)对税收支出的影响,而我们确定的其他影响在很大程度上被“排除在等式之外”。为了应用和操作确定的三障碍概念,我们构建了五个简短的,真实的公司案例研究。在这些案例研究中,我们展示了公司之间两个关键结构的差异如何导致不同水平的税收支出。首先,企业在税收筹划目标的激进程度上差别很大。其次,税务经理可以在其组织中承担非常不同级别的权力,这决定了实施税务筹划方法的能力。总之,我们对公司的税收筹划过程提供了概括性的见解,这有助于解释在公司之间观察到的税收费用差异。
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引用次数: 36
Small Business Owners' Attitudes Toward GST Compliance: A Preliminary Study 小企业主对商品及服务税合规的态度:初步研究
Pub Date : 2015-06-17 DOI: 10.2139/ssrn.2666317
L. Woodward, L. Tan
A significant body of research both internationally and in New Zealand has been devoted to understanding the factors that influence compliance with tax law. Early studies on compliance were primarily focused on individuals and income tax. Recent comprehensive reviews of the literature indicate that groups of taxpayers, such as small businesses, and compliance with other tax types, such as consumption taxes, remain under-explored.To contribute to the extant literature, this preliminary study extends prior work on the compliance attitudes or behaviour of small business owners (SBOs) by focusing on their tax attitudes toward New Zealand’s goods and services tax (GST) system. In particular, their perceptions of deterrence (eg chance of being audited or penalised), tax morale, social norms (eg other business taxpayer’s compliance attitudes), perception of the tax system (eg fairness, complexity, tax burden), and tax administration (eg trust in authority) are examined.The results show some evidence of “mental accounting” which is in line with Adams and Webley’s study. Not all SBOs perceived the GST system as being reasonably simple or easy to understand. Many owners also indicated that they relied on accounting software packages for recording their GST transactions and they appeared to assume their tax practitioners would pick up any errors they make. The results further indicate that tax penalty and tax audit are salient in the minds of SBOs. The majority of SBOs always tried to file a correct and timely tax return in view of the potential cost of incurring penalties for not doing so. Although the tax system was perceived as being reasonably simple, issues relating to internet transactions and GST on imports, and the burden of compliance cost of GST were particularly frustrating to SBOs. They also had different personal experiences in their dealings with Inland Revenue and different perceptions of Inland Revenue’s fairness. The SBOs’ GST morale with regards to proper invoicing and classification of goods and services was found to be positive. The majority would not feel good in falsifying invoices or misclassifying goods or services, although some suspected others did engage in such activities. Many are also aware of customers’ preference to pay cash to business owners to avoid GST and one-third of the sampled owners even admitted doing so themselves. These insights have several implications for tax authorities.
国际上和新西兰的一个重要研究机构一直致力于了解影响遵守税法的因素。早期关于合规的研究主要集中在个人和所得税方面。最近对文献的全面审查表明,纳税人群体,如小企业,以及遵守其他税收类型,如消费税,仍未得到充分探讨。为了对现有文献做出贡献,本初步研究通过关注小企业主(SBOs)对新西兰商品和服务税(GST)制度的税收态度,扩展了先前对小企业主(SBOs)的合规态度或行为的研究。特别是,他们对威慑力(如被审计或处罚的机会)、税收士气、社会规范(如其他企业纳税人的合规态度)、税收制度(如公平、复杂性、税收负担)和税收管理(如对当局的信任)的看法进行了审查。研究结果显示了一些“心理会计”的证据,这与亚当斯和韦伯利的研究一致。并非所有sbo都认为商品及服务税制度相当简单或容易理解。许多业主还表示,他们依靠会计软件包来记录他们的商品及服务税交易,他们似乎认为他们的税务从业人员会发现他们犯的任何错误。结果进一步表明,税务处罚和税务审计在SBOs的思想中是突出的。鉴于不这样做可能招致罚款的潜在成本,大多数sbo总是试图提交正确和及时的纳税申报表。虽然税收制度被认为相当简单,但与互联网交易和进口商品及服务税有关的问题,以及商品及服务税的合规成本负担,对sbo来说尤其令人沮丧。他们在与税务局打交道的过程中也有不同的个人经历,对税务局的公平也有不同的看法。sbo在商品和服务的正确发票和分类方面的GST士气被发现是积极的。大多数人对伪造发票或对商品或服务进行错误分类感到不舒服,尽管有些人怀疑其他人确实从事此类活动。许多人还意识到,客户倾向于向企业主支付现金以避免消费税,三分之一的抽样企业主甚至承认自己也这样做。这些见解对税务机关有几点启示。
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引用次数: 26
Voluntary Disclosure of Evaded Taxes -- Increasing Revenues, or Increasing Incentives to Evade? 自愿披露逃税——增加税收,还是增加逃税动机?
Pub Date : 2015-05-19 DOI: 10.1016/J.JPUBECO.2015.08.007
Dominika Langenmayr
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引用次数: 63
The Litigation of Tax Benefit Preservation Plans 税收利益保全计划之诉讼
Pub Date : 2015-04-01 DOI: 10.2139/SSRN.2438003
T. Boulton, Terry D. Nixon
We study the rise of shareholder right plans aimed at protecting a firm’s net operating loss carryforwards (tax benefit preservation plans). Traditional rights plans are designed to prevent hostile takeovers and have been found to entrench management at the expense of outside shareholders. Tax benefit preservation plans, however, have the potential to benefit shareholders by protecting a potentially valuable corporate asset. We find that entrenchment concerns tend to outweigh the protection of net operating loss carryforwards when firms adopt tax benefit preservation plans. Specifically, we find that abnormal returns are negative at the announcement of a new tax benefit preservation plan. However, the full impact of plan adoption on share prices is not evident until the Delaware Courts validated their use, which also had a negative impact on the firms most likely to consider adopting a plan.
我们研究了旨在保护公司净经营亏损结转的股东权利计划(税收优惠保留计划)的兴起。传统的权利计划旨在防止恶意收购,并被发现以牺牲外部股东的利益为代价巩固管理层。然而,税收优惠保留计划有可能通过保护潜在的有价值的公司资产而使股东受益。我们发现,当企业采用税收优惠保留计划时,堑壕问题往往超过对净经营损失结转的保护。具体而言,我们发现在新的税收优惠保留计划公告时,异常收益为负。然而,在特拉华州法院确认其使用之前,计划采用对股价的全面影响并不明显,这也对最有可能考虑采用计划的公司产生了负面影响。
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引用次数: 0
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Tax eJournal
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