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What Are Minimum Taxes, and Why Might One Favor or Disfavor Them? 什么是最低税,为什么人们会赞成或不赞成?
Pub Date : 2020-06-09 DOI: 10.2139/SSRN.3604328
Daniel N. Shaviro
Minimum taxes (including global minimum taxes) have serious drawbacks, and generally make sense, if at all, only if otherwise superior options must be ruled out for reasons of optics or political economy. Yet, given the “compared to what?” question that haunts all real-world tax policy-making, one cannot reasonably say that they should never be used. Still, any such use should generally be contingent, reluctant, and based on understanding their structural deficiencies.
最低税(包括全球最低税)有严重的缺点,通常只有在出于光学或政治经济学的原因必须排除其他更好的选择时,最低税才有意义。然而,考虑到“与什么相比?”这个问题困扰着所有现实世界的税收政策制定,人们不能合理地说它们永远不应该被使用。然而,任何这样的使用通常应该是偶然的,不情愿的,并基于对其结构缺陷的理解。
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引用次数: 10
How Durable is a Lockbox for Carbon Tax Revenue? 碳税收入的“锁箱”能持续多久?
Pub Date : 2020-04-13 DOI: 10.5195/taxreview.2019.107
J. Milne
Debates about carbon taxes in political and policy circles inevitably involve discussions about how to use the revenue from carbon taxes. Choices about revenue use will turn on the complex interaction of political strategies, the broader fiscal picture, equity and economic concerns, and environmental considerations. The ultimate choice will mold policymakers’ promises to constituents and the public as they describe and promote carbon taxes. Those promises become particularly important when they purport to dedicate the revenue to a specific purpose. Voters and stakeholders will wonder whether promises can and will be kept. Can the revenue actually be put into a secure lockbox to ensure that the revenue is used as promised? Will that lockbox endure over time?

This article considers the legal durability of promises to earmark carbon tax revenue. It focuses on three types of revenue dedication: revenue-neutral tax reform, revenue recycling through “dividends” or rebates, and dedication of revenue to spending on climate-related matters. It explores the legal design of these alternatives. It also analyzes how the legal context, such as budget rules and procedures, may influence whether promises are kept in the short and long terms. While drawing on examples of carbon pricing measures and proposals in North America, the article strives to identify issues that may apply in other countries as well. Regardless of jurisdiction, policymakers and carbon tax advocates should consider whether their rhetorical promises can translate into legally durable reality. The article does not advocate for specific policy or political choices about how to use carbon tax revenue. It seeks instead to help inform choices and future research.
政治和政策圈对碳税的争论不可避免地涉及到如何使用碳税收入的讨论。关于收入使用的选择,将取决于政治战略、更广泛的财政状况、公平和经济问题以及环境考虑之间复杂的相互作用。最终的选择将塑造决策者对选民和公众的承诺,因为他们描述和推动碳税。当这些承诺声称要将收入用于特定目的时,它们就变得尤为重要。选民和利益相关者会怀疑承诺是否能够兑现。收入是否真的可以放入一个安全的锁箱中,以确保收入按照承诺使用?这个上锁的盒子会经久不衰吗?本文考虑了碳税专款承诺的法律持久性。它侧重于三种类型的收入投入:收入中性的税制改革,通过“分红”或回扣回收收入,以及将收入用于气候相关事务的支出。它探讨了这些替代方案的法律设计。报告还分析了预算规则和程序等法律环境如何影响短期和长期承诺是否得到履行。本文在借鉴北美碳定价措施和建议的同时,努力找出可能适用于其他国家的问题。无论管辖权如何,政策制定者和碳税倡导者都应该考虑他们的口头承诺能否转化为法律上持久的现实。本文不主张就如何使用碳税收入进行具体的政策或政治选择。相反,它寻求帮助为选择和未来的研究提供信息。
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引用次数: 0
Perceptions of Tax Compliance by SMEs and Tax Practitioners in New Zealand: A Divergent View? 新西兰中小企业和税务从业人员对税务合规的看法:分歧的观点?
Pub Date : 2020-03-13 DOI: 10.2139/ssrn.3649856
Dr. Sue Yong, B. Freudenberg
Despite the economic importance of small and medium enterprises (SMEs), little is known about their tax compliance perceptions, which may influence their compliance behavior. This is particularly so in relation to comparing the tax perceptions of New Zealand SMEs and their tax practitioners. This article reports on a qualitative study which examined the tax compliance perceptions of New Zealand SMEs and their tax practitioners. The findings of this study reveal that SMEs’ perceptions of tax compliance are multifaceted and include legal factors, compliance costs, economic considerations and perceptions of “others”. On the other hand, tax practitioners generally have a narrow context focusing mainly on compliance cost and legal obligations. The tax policy implications from this study include that it can potentially assist tax authorities to design and implement strategies to influence SMEs’ compliance behaviors. Also, for tax practitioners it illustrates their important role in reducing the stress of their SME clients by assisting them through education, including how to use accounting reports for compliance and business control purposes.
尽管中小企业在经济上具有重要意义,但人们对其税收合规观念知之甚少,这可能会影响其合规行为。在比较新西兰中小企业及其税务从业人员的税收观念时尤其如此。本文报告了一项定性研究,该研究调查了新西兰中小企业及其税务从业人员的税务合规观念。本研究发现,中小企业对税收合规的认知是多方面的,包括法律因素、合规成本、经济考虑和对“他人”的认知。另一方面,税务从业人员通常有一个狭窄的背景,主要关注合规成本和法律义务。本研究的税收政策启示包括,它可以潜在地帮助税务机关设计和实施影响中小企业合规行为的策略。此外,对于税务从业人员来说,它说明了他们在减轻中小企业客户压力方面的重要作用,通过帮助他们进行教育,包括如何使用会计报告以达到合规和业务控制的目的。
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引用次数: 0
Time for a Tax Return Filing Fee 是时候交纳税申报费了
Pub Date : 2020-03-11 DOI: 10.2139/ssrn.3552675
Emily L. Cauble
The IRS faces the monumental task of verifying, to the extent possible, the tax consequences reported on the hundreds of millions of tax returns filed each year. It does so with meager and shrinking resources. Some taxpayers burden the filing system more than others. At one extreme, a taxpayer who earns only income that is subject to third-party reporting and withholding and who claims the standard deduction adds very little to the IRS’s burden. At the other end of the extreme, a large business engaged in numerous complex transactions the tax treatment of which are not free from doubt demands significant resources if that taxpayer’s claimed tax outcomes are fully examined. In light of this landscape, this Article makes the novel proposal that Congress require payment of a tax return filing fee by some taxpayers. The amount of the fee would vary based on some of the factors that make each taxpayer more or less difficult to audit, with carve-outs for difficult-to-audit items that are disproportionately claimed by lower-income individuals. The goals of the proposal are three: first, to make the system fairer, second, to raise additional revenue, and third, to improve efficiency by encouraging taxpayers to take into account the costs imposed on the tax administration system by their complex transactions.
美国国税局面临着一项艰巨的任务,即尽可能核实每年上亿份纳税申报单上报告的纳税后果。它是在资源贫乏和不断萎缩的情况下做到这一点的。一些纳税人比其他纳税人负担更重。在一种极端情况下,如果纳税人的收入只属于第三方报告和代扣代缴,并要求标准扣除额,那么他对国税局的负担就很少。在另一个极端,大型企业从事许多复杂的交易,这些交易的税收待遇并非毫无疑问,如果纳税人声称的税收结果得到充分审查,则需要大量资源。鉴于这种情况,本文提出了一个新颖的建议,即国会要求一些纳税人支付纳税申报表申请费。该费用的数额将根据使每个纳税人或多或少难以审计的一些因素而有所不同,对低收入个人要求的不成比例的难以审计的项目予以豁免。该提案的目标有三个:第一,使税收系统更加公平;第二,增加额外收入;第三,通过鼓励纳税人考虑复杂交易给税收管理系统带来的成本来提高效率。
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引用次数: 0
The Australian Tax Planning Playbook: Volume 1 澳大利亚税务筹划手册:第一卷
Pub Date : 2020-03-01 DOI: 10.2139/ssrn.3553095
Robert V. Breunig, T. Sainsbury
Has income tax become voluntary in Australia? It appears that for some, nil or very low tax bills are a very real prospect. Those with flexibility over how they earn income can use a range of legal means of ‘tax arbitrage’ to pay a lower marginal tax rate. Those highly motivated to achieve the lowest possible tax bill can structure their financial affairs so as to stream income through a mix of companies, trusts, property assets, superannuation funds and adult family members over time. This paper presents some of the simpler strategies that are part of the ‘Tax Planning Playbook’. In doing so, it shows how tax planning is available to people across the income distribution. It is not surprising that taxpayers make use of the opportunities available to them and respond to the incentives they face. However, a system that encourages tax planning is an affront to the commonly-held core principles of good tax design of fairness, efficiency and simplicity. It also raises questions about the longer-term sustainability of Australia’s tax system. Addressing tax planning requires a wholesale rethink about the design and role of income in Australia’s tax system.
在澳大利亚所得税是自愿的吗?对一些人来说,零税收或极低的税收似乎是一个非常现实的前景。那些在收入方式上有灵活性的人可以利用一系列合法的“税收套利”手段来支付较低的边际税率。那些强烈希望尽可能少交税的人,可以通过公司、信托、房地产资产、退休金基金和成年家庭成员的组合来安排他们的财务状况。本文提出了一些简单的策略,是“税收规划手册”的一部分。通过这样做,它显示了收入分配中的人们是如何进行税收规划的。纳税人利用他们可以获得的机会,并对他们面临的激励作出反应,这并不奇怪。然而,鼓励税收筹划的制度违背了公平、效率和简单等良好税收设计的普遍核心原则。这也引发了人们对澳大利亚税收制度长期可持续性的质疑。解决税收规划问题需要对澳大利亚税收体系中收入的设计和作用进行全面反思。
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引用次数: 4
Saving the Planet by Cutting Corporate Taxes: A Comparative Case Study Analysis 通过削减公司税拯救地球:一个比较案例研究分析
Pub Date : 2020-02-27 DOI: 10.5744/ftr.2020.1004
Roberta F. Mann, Fiona Martin, B. Butcher
This Article examines corporate tax trends in the context of the press­ing global issue of climate change. Multinational corporations play a huge role in the global economy. We argue that the role of for-profit corporations should not be limited to making short-term profits for their shareholders. If corporations benefit from corporate tax reduc­tions, some of that benefit should be shared with society. This Article explores the connection between climate change and corporate activity through a new lens: corporate tax policy. It expands the current inquiry about the impact of taxes on corporations by connecting that discussion to the impact of multinational corporate activity on the global environment. To date, while research has been done on the interaction between corporate tax avoidance and corporate social responsibility, no research has examined the connection between the global trend of corporate tax rate cuts and the increasingly important influence of corporate environmental social responsibility. This Article begins to fill that gap by making a qualitative inquiry into the interac­tion between effective corporate tax rates, corporate tax cuts, and cor­porate social responsibility.
本文考察了在气候变化这一紧迫的全球问题背景下的公司税趋势。跨国公司在全球经济中发挥着巨大的作用。我们认为,营利性公司的作用不应局限于为其股东创造短期利润。如果企业从公司税减免中受益,那么其中的一些好处应该与社会分享。本文通过企业税收政策这一新的视角探讨了气候变化与企业活动之间的联系。它通过将讨论与跨国公司活动对全球环境的影响联系起来,扩大了目前关于税收对公司影响的调查。到目前为止,虽然对企业避税与企业社会责任之间的相互作用进行了研究,但尚未有研究考察全球企业税率下调趋势与企业环境社会责任日益重要的影响之间的联系。本文通过对有效企业税率、企业减税和企业社会责任之间的相互作用进行定性调查,开始填补这一空白。
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引用次数: 3
Responsible Tax in Multinational Enterprises – Why and How? (Ansvarlig Skat I Multinationale Koncerner – Hvorfor Og Hvordan?)
Pub Date : 2020-02-27 DOI: 10.2139/ssrn.3545410
Peter Koerver Schmidt
In the first part of the paper, it is argued that multinational enterprises (MNEs) may benefit from including considerations of corporate responsibility when determining their tax planning behavior. The conclusion mainly rests on the fact that increased awareness of responsible tax behavior may shed useful light on the damaging effects aggressive tax planning may have on an MNE’s reputation. In addition, an increased focus on responsible tax behavior may assist the MNE’s management in maximizing shareholder welfare - and not only shareholder value. Against this background, the second part of the paper is devoted to an analysis of how MNEs actually can implement and design their own tax policy/strategy in responsible manner. Finally, in the third part of the paper, the author tries to take stock of the current endeavors of Danish-based MNEs with respect to implementation of responsible tax policies. In this context, and based on a review of publicly available information gathered from MNEs forming part of the OMX Copenhagen 25 Index, it is concluded that the largest Danish-based MNEs currently show solid appetite for implementing policies on responsible tax and that some of these policies actually make up good examples of how to design public tax policies/strategies.
在本文的第一部分,认为跨国企业(MNEs)可能受益于在确定其税收筹划行为时纳入企业责任的考虑。结论主要基于这样一个事实,即提高对负责任的税收行为的认识,可能有助于了解积极的税收筹划可能对跨国公司声誉产生的破坏性影响。此外,更加关注负责任的税收行为可能有助于跨国公司管理层最大化股东福利,而不仅仅是股东价值。在此背景下,本文的第二部分致力于分析跨国公司如何以负责任的方式实施和设计自己的税收政策/战略。最后,在论文的第三部分,作者试图对丹麦跨国公司在实施负责任的税收政策方面的当前努力进行评估。在此背景下,基于对从构成OMX哥本哈根25指数一部分的跨国公司收集的公开信息的审查,得出的结论是,目前最大的丹麦跨国公司对实施负责任税政策表现出强烈的兴趣,其中一些政策实际上构成了如何设计公共税收政策/战略的良好范例。
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引用次数: 0
Information Matters in Tax Enforcement 税务执法中的资讯事宜
Pub Date : 2019-12-21 DOI: 10.2139/SSRN.3325598
Leandra Lederman, J. Dugan
Most legal and economics scholars recognize both that the government needs information about taxpayers’ transactions in order to determine whether their reporting is honest, and that third-party reporting helps the government obtain that information. Given governments’ reliance on tax funds, it is risky to think that information or third-party reporting is not needed by tax agencies. However, a recent article by Professor Wei Cui asserts that “modern governments can practice ‘taxation without information.’” Professor Cui’s argument rests on two premises: (1) “giving governments effective access to taxpayer information through third parties does not explain the success of modern tax administration” because, he argues, some important taxes, such as the value added tax (VAT), do not involve information reporting; and (2) modern tax administration succeeds because business firms are “sites of social cooperation under the rule of law,” fostering compliance. As this Article explains, the literature demonstrates that both arguments are mistaken. That is, it shows that third-party information reporting is highly effective, information sharing is used to enforce VATs, and firms are not inherently compliant. In fact, where individuals report on firms, firms’ compliance increases, which supports the intuitive notion that third-party reporting increases tax compliance and that information accordingly matters in tax enforcement.
大多数法律和经济学学者都认识到,政府需要纳税人的交易信息,以确定他们的报告是否诚实,而第三方报告有助于政府获得这些信息。鉴于政府对税收资金的依赖,认为税务机构不需要信息或第三方报告是有风险的。然而,崔伟教授最近的一篇文章断言,“现代政府可以在没有信息的情况下征税”。崔教授的论点基于两个前提:(1)“让政府通过第三方有效获取纳税人信息并不能解释现代税收管理的成功”,因为他认为,一些重要的税收,如增值税(VAT),不涉及信息报告;(2)现代税务管理之所以成功,是因为企业是“法治下社会合作的场所”,促进了守法。正如本文所解释的,文献表明这两种观点都是错误的。也就是说,它表明第三方信息报告是非常有效的,信息共享被用来执行增值税,公司不是天生的合规。事实上,在个人报告公司的地方,公司的合规性会增加,这支持了第三方报告提高税收合规性的直觉观念,因此信息在税收执法中很重要。
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引用次数: 0
Institutional and Structural Legitimacy Deficits in the International Tax Regime 国际税收制度的制度性和结构性合法性赤字
Pub Date : 2019-12-18 DOI: 10.2139/SSRN.3545569
Ivan Ozai
Only the abstract, table of contents and introduction are available here. As the OECD and the G20 strengthen their central role in the international tax policy arena, scholars and commentators increasingly question their legitimacy to impose standards and norms worldwide. Calls for greater participation of developing countries led the OECD to introduce the Inclusive Framework. Despite questions about whether such initiative improved normative legitimacy or constituted mere rhetoric to circumvent calls for greater inclusiveness, it illustrates the attention given by policy leaders to the potential legitimacy deficits in the international tax regime. This article analyses the present international tax regime from the perspective of normative legitimacy and argues that despite the importance of improving participation of less powerful countries in international tax policy decisions, increased participation alone may not suffice in making these decisions responsive to interests and needs of developing countries. Structural shortcomings in the institutional design of the international tax regime may require a more in-depth discussion on what normative principles should guide overall reform of the international tax system in a way that produces a fairer allocation of rights and duties among different stakeholders.
这里只提供摘要、目录和介绍。随着经合组织和20国集团加强其在国际税收政策领域的核心作用,学者和评论员越来越多地质疑它们在全球范围内强加标准和规范的合法性。对发展中国家更多参与的呼吁促使经合组织推出了包容性框架。尽管有人质疑这样的倡议是提高了规范的合法性,还是仅仅是为了规避要求更大包容性的呼吁而采取的花言巧语,但它表明,政策领导人对国际税收制度中潜在的合法性缺陷给予了关注。本文从规范合法性的角度分析了目前的国际税收制度,并认为尽管提高实力较弱国家在国际税收政策决策中的参与很重要,但仅增加参与可能不足以使这些决策符合发展中国家的利益和需求。国际税收制度体制设计中的结构性缺陷可能需要更深入地讨论应以何种规范原则指导国际税收制度的全面改革,从而在不同利益攸关方之间更公平地分配权利和义务。
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引用次数: 3
Thinking Outside the Box (12): The Benefits of Increased Transparency in Employer-Sponsored Health Insurance for the 180 Million Insured 跳出框框思考(12):为1.8亿被保险人增加雇主赞助的医疗保险透明度的好处
Pub Date : 2019-12-11 DOI: 10.2139/ssrn.3498366
R. Herzlinger, Barak D Richman
Economists have long noted that the tax exclusion of employer-sponsored insurance (ESI) caused workers to purchase health plans that differ in price and other characteristics from those they would otherwise choose for themselves. We explore the short-term and long-term benefits of giving workers better control over ESI funds. To measure near-term benefits, we execute a simulation in which employees in large group plans capitalize on a new opportunity to use tax-advantaged Health Reimbursement Arrangements (HRAs) to control the full ESI contribution. Employees would deduct for income tax purposes the amount used for health insurance and, if they spend less than the amount of their ESI funds, take the remainder as taxed income. Our calculations adjust for adverse selection by providing a cross-subsidization holdback from the ESI funds. We find that employees increase annual after-tax household income between $101–$252 billion and that federal income tax revenues would increase by $39–$163 billion. Lower- and middle-income households gain proportionately more income. Long-term benefits include the increased take-up of new policies that reduce net spending, spillover benefits to governmental health care programs, and innovative educational and navigational services. We compares these results to those in nations with similar consumer–driven health care systems. The U.S. results rest on offering workers HRAs newly integrated with health plans, adequate plan choice, and transparency about plan actuarial values and ESI contributions. Our policy recommendations include expanded transparency in Box 12 of IRS Form W-2, currently the only required source of employee information about their ESI.
经济学家早就注意到,雇主赞助保险(ESI)的税收减免导致工人购买的健康计划在价格和其他特征上与他们自己选择的计划不同。我们探讨了让员工更好地控制ESI资金的短期和长期效益。为了衡量短期利益,我们执行了一个模拟,在这个模拟中,大型集团计划中的员工利用一个新的机会,使用税收优惠的健康报销安排(HRAs)来控制全部ESI贡献。雇员将扣除用于健康保险的金额作为所得税,如果他们的支出少于ESI基金的金额,则将剩余部分作为纳税收入。我们的计算通过提供ESI基金的交叉补贴阻力来调整逆向选择。我们发现,雇员每年使家庭税后收入增加1020亿至2520亿美元,联邦所得税收入将增加390亿至1630亿美元。中低收入家庭的收入相应增加。长期利益包括更多地采用减少净支出的新政策,对政府医疗保健计划的溢出效益,以及创新的教育和导航服务。我们将这些结果与拥有类似消费者驱动型医疗体系的国家进行了比较。美国的结果取决于为员工提供与健康计划新整合的人力资源评估,充分的计划选择,以及计划精算值和ESI贡献的透明度。我们的政策建议包括扩大美国国税局W-2表格第12栏的透明度,这是目前唯一需要的员工ESI信息来源。
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引用次数: 0
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