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Nontax Country Characteristics and Tax Avoidance 非税国家特征与避税
Pub Date : 2018-11-29 DOI: 10.2139/ssrn.3292703
J. Yoo, Y. Lee
This study tests the role of national culture in tax avoidance by multinational corporations (MNCs). Hofstede’s four cultural dimensions are used to measure cultural differences across countries: uncertainty avoidance, individualism, masculinity, and power distance. The level of tax avoidance is estimated based on the worldwide effective tax rate (ETR) of corporate groups. A sample of group years domiciled in 31 countries for the years 2008 to 2015 is used to test the association between culture and tax avoidance. The empirical results of the study imply that MNCs headquartered in countries with low uncertainty avoidance, low individualism, high masculinity, and low power distance engage in a higher level of tax avoidance than MNCs in countries with high uncertainty avoidance, high individualism, low masculinity, and high power distance. In addition, the cultural features of the parent company generally have a stronger influence on group-level tax avoidance than those of its subsidiaries. This study contributes to the literature by presenting empirical evidence of culture as a determinant of tax avoidance by MNCs. The study also suggests that policymakers consider cultural factors when setting anti-avoidance regulations for MNCs.
本研究检验了民族文化在跨国公司避税中的作用。Hofstede的四个文化维度被用来衡量不同国家的文化差异:不确定性规避、个人主义、男子气概和权力距离。避税水平是根据企业集团的全球有效税率(ETR)来估计的。本研究以2008年至2015年在31个国家注册的集团为样本,检验文化与避税之间的关系。研究的实证结果表明,总部设在不确定性规避、低个人主义、高男性化和低权力距离国家的跨国公司的避税水平高于总部设在不确定性规避、高个人主义、低男性化和高权力距离国家的跨国公司。此外,母公司的文化特征对集团层面避税的影响一般大于其子公司的文化特征。本研究通过提出文化是跨国公司避税的决定因素的经验证据,为文献做出了贡献。该研究还表明,政策制定者在制定跨国公司反避税法规时应考虑文化因素。
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引用次数: 0
Selfcure Economies and the E.U. Economy (Bonded Economies) 自保经济与欧盟经济(保税经济)
Pub Date : 2018-11-25 DOI: 10.2139/ssrn.3290231
Constantinos Challoumis Κωνσταντίνος Χαλλουμής
This paper analyzes issues about the attribute which have any economy to resettle the dysfunctions and the weaknesses, which come from structural economic problems of the public administration and the activities of the private section. The currency rate is the stabilizing factor of any economy, as will be shown to that scientific thesis. Then, this reasoning index that for the purposes of this work would be used paradigms from real countries’ cases and a theoretical analysis and therefore logical deductions. In other words, this work indicates that the secure economies are the economic immune system of these economic systems. These paper, finally, provides the two mainstream solutions for these economic conditions.
本文通过对具有经济属性的问题进行分析,以解决公共行政和私营部门活动的结构性经济问题所带来的功能失调和弱点。货币汇率是任何经济体的稳定因素,这将在那篇科学论文中得到证明。然后,这个推理指标,为本工作的目的,将使用范式从实际国家的案例和理论分析,因此逻辑推理。换句话说,这项工作表明,安全经济是这些经济体系的经济免疫系统。最后,本文提出了针对这些经济条件的两种主流解决方案。
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引用次数: 0
Tales from the Crypt - How to Regulate Initial Coin Offerings 地下室的故事-如何规范首次代币发行
Pub Date : 2018-11-21 DOI: 10.2139/ssrn.3288778
Thorsten V. Koeppl, Jeremy M. Kronick
Given the boom in, and media attention surrounding, Initial Coin Offerings (ICOs), this Commentary asks whether this new type of financing is one that fills a market gap in the financial sector, or is just a way of defrauding unsuspecting retail investors looking to invest in new startups. We set forth arguments showing that ICOs do indeed fill an essential gap in funding for entrepreneurs that have limited access to other forms of startup financing such as crowdfunding, venture capital or bank lending. We point out that for an ICO to be the efficient way of financing, the business venture needs to develop: i. a decentralized platform, usually based on blockchain technology; where ii. a coin gives digital access to the platform; and serves as iii. a means of payment for users that engage in decentralized, person-to-person (P2P) exchange in order to create and transfer value between them. If these features are fulfilled, using an ICO can be integral to the project’s success, and we label it simply a “fundamental ICO.” Based on such guidance, and very much in the spirit of “activity-based regulation,” we suggest that Canadian securities regulators develop specific regulations for ICOs that move beyond the question of whether an ICO is a security or not and take into account the special nature of such financing. Alternatively, or until new rules arrive, regulatory relief could still be granted for fundamental ICOs under the Canadian Securities Administrators (CSA) Sandbox. Our proposed test can also create guidelines for the right approach to taxation that is consistent with the value that is added by such financing. Tax rules can be based on the dual roles of the coins, which are both an investment stake and a currency. There is value in bringing together economic, regulatory and legal aspects to develop a specific framework for the regulation and taxation of ICOs in Canada. This can ensure an environment that reaps the benefits of the ongoing blockchain revolution for the Canadian economy without exposing investors unnecessarily to fraud.
鉴于首次代币发行(ico)的繁荣和媒体对其的关注,本文提出了一个问题,即这种新型融资是填补了金融领域的市场空白,还是只是欺骗希望投资新创业公司的毫无怀疑的散户投资者的一种方式。我们提出的论点表明,ico确实填补了企业家获得其他形式的创业融资(如众筹、风险投资或银行贷款)的资金缺口。我们指出,要使ICO成为一种有效的融资方式,企业需要发展:1 .一个分散的平台,通常基于区块链技术;二世。一枚硬币可以让用户以数字方式访问该平台;作为iii。为了在用户之间创造和转移价值,从事去中心化的个人对个人(P2P)交换的用户的一种支付手段。如果满足了这些特征,使用ICO可以成为项目成功不可或缺的一部分,我们将其称为“基础ICO”。基于这样的指导,并非常本着“基于活动的监管”的精神,我们建议加拿大证券监管机构为ICO制定具体的监管规定,这些规定超越了ICO是否是证券的问题,并考虑到此类融资的特殊性。或者,在新规则出台之前,加拿大证券管理局(CSA)沙盒下的基本ico仍可获得监管救济。我们提出的测试还可以为与此类融资所增加的价值相一致的正确征税方法制定指导方针。税收规则可以基于比特币的双重角色,它既是投资股份,也是货币。将经济、监管和法律方面结合起来,为加拿大的ico制定一个具体的监管和税收框架,是有价值的。这可以确保一个环境,使加拿大经济从正在进行的区块链革命中获益,而不会让投资者不必要地遭受欺诈。
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引用次数: 7
Macroprudential Margins: A New Countercyclical Tool? 宏观审慎边际:一个新的逆周期工具?
Pub Date : 2018-11-09 DOI: 10.2139/ssrn.3284418
Cian O'Neill, Nicholas Vause
We quantify the size of a fire-sale externality in the derivatives market in the absence of a macroprudential buffer on top of microprudential initial margin requirements. We show how this varies over the financial cycle with market volatility. We then assess the ability of a macroprudential buffer to reduce this externality. We find this depends critically on the release conditions of the buffer. A buffer could reduce or, if set appropriately, even eliminate the externality, as long as it was released when investors faced any significant collateral calls, regardless of whether these related to variation or initial margins. However, it could be harmful if it was released only with calls for additional initial margin. Predicated on ideal release conditions, we test the performance of macroprudential buffers based on ‘anti-procyclicality’ mechanisms in current regulations. These mechanisms can reduce the fire-sale externality in some market conditions, but not all. Conceptually, we devise alternative mechanismsthat eliminate the externality, although it may be difficult for policymakers to specify these in practice. Finally, as an alternative to quantity-based solutions, we investigate the ability of taxes to reduce the externality. We find that such a price-based solution could also eliminate the externality if set appropriately, but this would require a high tax rate and the redistribution of significant tax revenues.
我们量化了在微观审慎初始保证金要求之上缺乏宏观审慎缓冲的情况下衍生品市场贱卖外部性的规模。我们展示了这在金融周期中如何随着市场波动而变化。然后,我们评估宏观审慎缓冲减少这种外部性的能力。我们发现这主要取决于缓冲区的释放条件。如果设置得当,缓冲可以减少甚至消除外部性,只要在投资者面临重大抵押品要求时释放缓冲,无论这些要求是否与变动或初始保证金有关。然而,如果它只是在要求额外初始保证金的情况下发布,可能是有害的。基于理想的释放条件,我们测试了当前法规中基于“反顺周期性”机制的宏观审慎缓冲的性能。这些机制可以在某些市场条件下减少甩卖的外部性,但不是全部。从概念上讲,我们设计了消除外部性的替代机制,尽管政策制定者在实践中可能难以具体说明这些机制。最后,作为基于数量的解决方案的替代方案,我们研究了税收减少外部性的能力。我们发现,如果设置得当,这种基于价格的解决方案也可以消除外部性,但这将需要高税率和大量税收收入的再分配。
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引用次数: 6
Averting the Multiemployer Pension Solvency Crisis 避免多雇主养老金偿付危机
Pub Date : 2018-10-19 DOI: 10.2139/ssrn.3381914
Charles P. Blahous
The Pension Benefit Guaranty Corporation (PBGC) multiemployer pension insurance program faces projected insolvency, driven by systemic underfunding of multiemployer pension plans. To address this brewing crisis, Congress has established a joint select committee to develop multiemployer pension reforms. Primary causes of the crisis include lax funding rules and inaccurate valuations of pension assets and liabilities. Explanations frequently offered for underfunding, such as financial market downturns and the declining proportion of active workers, fail to account for the relative weakness of multiemployer pension finances. Reforms should establish accurate asset and liability measurements, safeguards against further deterioration of underfunded plans, improved incentives for plan trustees, stronger funding requirements, and risk-based premiums. Legislators may wish to consider authorizing the PBGC to relieve plans of so-called orphan liabilities, subject to strict requirements that any relief must reduce projected claims on pension insurance. Lawmakers must be firm in declaring that no taxpayer funds will be used to bail out multiemployer pensions.
由于多雇主养老金计划的系统性资金不足,养老金福利担保公司(PBGC)的多雇主养老金保险计划面临预计的破产。为了解决这一酝酿中的危机,国会成立了一个联合特别委员会,以制定多雇主养老金改革方案。这场危机的主要原因包括宽松的融资规则和对养老金资产和负债的不准确估值。对于资金不足,人们经常给出的解释,比如金融市场低迷和活跃工人比例下降,都无法解释多雇主养老金财务的相对疲弱。改革应建立准确的资产和负债衡量标准,防止资金不足的计划进一步恶化的保障措施,改进对计划受托人的激励措施,提高资金要求,并建立基于风险的保费。立法者可能希望考虑授权PBGC减轻所谓孤儿负债的计划,但有严格的要求,即任何救济必须减少养老金保险的预计索赔。议员们必须坚定地宣布,纳税人的资金不会被用于救助多雇主养老金。
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引用次数: 0
Distance and Decline: The Case of Petersburg, Virginia 距离与衰落:以弗吉尼亚州彼得堡为例
Pub Date : 2018-10-16 DOI: 10.21144/WP18-16
R. Owens, Santiago M. Pinto
Petersburg, Virginia, prospered over two centuries as a center of production and trade. However, the city experienced economic difficulties beginning in the 1980s as a large number of layoffs at production plants in the area coincided with an erosion of retail trade in the city. Prolonged economic decline followed. In contrast, somewhat similar shocks in other moderate-sized cities in Virginia were followed by gradual economic recovery. We examine these differing outcomes and offer an explanation that hinges on the proximity of Petersburg to its larger neighbor, the greater Richmond area. We find evidence suggesting that after the job declines, higher-skilled residents in Petersburg initially commuted to jobs nearer to Richmond, later relocating from Petersburg toward Richmond--an option not readily available in the other Virginia cities considered. We suggest that, as a result, Petersburg suffered a sharp decline in tax revenues and that municipal costs could not be proportionately scaled down, leading to severe fiscal stress.
弗吉尼亚州的彼得堡作为生产和贸易中心繁荣了两个世纪。然而,从20世纪80年代开始,该市经历了经济困难,因为该地区生产工厂大量裁员,同时该市的零售贸易受到侵蚀。随之而来的是长期的经济衰退。相比之下,弗吉尼亚州其他中等规模的城市受到类似的冲击后,经济逐渐复苏。我们研究了这些不同的结果,并提供了一种解释,这种解释取决于彼得堡与其更大的邻居——更大的里士满地区的接近程度。我们发现有证据表明,在就业下降后,彼得堡的高技能居民最初通勤到离里士满更近的地方工作,后来从彼得堡搬到里士满——这一选择在弗吉尼亚其他城市并不容易得到考虑。我们认为,因此,彼得堡的税收收入急剧下降,市政费用无法按比例减少,导致严重的财政压力。
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引用次数: 0
Cannabis Countdown: Estimating the Size of Illegal Markets and Lost Tax Revenue Post-Legalization 大麻倒计时:估计非法市场的规模和合法化后的税收损失
Pub Date : 2018-10-11 DOI: 10.2139/ssrn.3269989
Anindya Sen, Rosalie Wyonch
With Canada ending the legal prohibition of recreational marijuana as of October 17, 2018, governments across the country have been mobilizing to tackle the many policy challenges. But there has been a lack of policy discussion on whether supply from existing authorized producers will be sufficient to meet expected demand. This Commentary contributes to the literature by estimating the size of the marijuana black market during the first year of legalization, October 2018 – September 2019. These estimates take into account legal-illegal price differences as well as the gap between market demand and available legal supply. Our results show that both pricing and supply shortages will contribute to maintaining the black market, resulting in lost tax revenues and a continued need to spend significant resources on law enforcement activities related to the market. Our projections indicate the size of the black market, including legal supply shortages, will be about 380 tonnes, or at least $2.5 billion during the first year of legalization. This further suggests that forgone government revenues based on the coordinated excise tax framework and GST/HST/QST could be about $800 million. This loss can be attributed to a shifting mix of black market activity and legal market supply shortages, depending on the legal price and availability of supply. Using midpoint estimates for demand, our supply projections indicate that at $9 per gram, 87 percent of the resulting tax loss would be attributed to the black market and the remaining 13 percent to supply shortage in the legal market. There are various options that Canadian governments could employ to reduce this potential loss. Provinces should ensure regulations facilitate a competitive and convenient legal retail market. The federal government should focus on ensuring that it does not impede production more than is necessary to protect public health so there will be enough legal marijuana to supply these retail outlets. In addition, the federal government and Health Canada should develop regulations for edible and concentrated marijuana products. These products are already available on the black market, providing it a significant competitive advantage since they will not be part of the legal regime, at least at first. While our results predict initial shortages in legal supply, the market should be able to adjust as time goes on; Consumers' Interests and Protection;Provincial Taxation and Budgets; Health Policy; Provincial Comparisons
随着加拿大于2018年10月17日结束娱乐性大麻的法律禁令,全国各地的政府都在动员起来应对许多政策挑战。但对于现有授权生产商的供应是否足以满足预期需求,一直缺乏政策讨论。本评论通过估算大麻合法化第一年(2018年10月至2019年9月)大麻黑市的规模,为文献做出贡献。这些估计考虑了合法和非法价格差异,以及市场需求和现有合法供应之间的差距。我们的研究结果表明,定价和供应短缺都将有助于维持黑市,导致税收损失,并继续需要在与市场相关的执法活动上花费大量资源。我们的预测表明,包括合法供应短缺在内,黑市的规模将在合法化的第一年达到380吨左右,或至少25亿美元。这进一步表明,基于协调的消费税框架和GST/HST/QST的政府收入可能约为8亿美元。这种损失可归因于黑市活动和合法市场供应短缺的混合变化,这取决于合法价格和供应的可得性。使用需求的中点估计,我们的供应预测表明,以每克9美元计算,87%的税收损失将归因于黑市,剩下的13%归因于合法市场的供应短缺。加拿大政府可以采用多种方案来减少这一潜在损失。各省应确保法规促进竞争和便利的合法零售市场。联邦政府应该把重点放在确保它不会阻碍生产超过保护公众健康的必要程度上,这样就会有足够的合法大麻供应给这些零售店。此外,联邦政府和加拿大卫生部应该制定可食用和浓缩大麻产品的法规。这些产品已经可以在黑市上买到,这为它提供了一个显著的竞争优势,因为它们不会成为法律制度的一部分,至少在一开始是这样。虽然我们的研究结果预测合法供应最初会出现短缺,但随着时间的推移,市场应该能够进行调整;消费者利益与保护;省级税收与预算;卫生政策;省的比较
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引用次数: 9
Taxes, Governance, and Debt Maturity Structure: International Evidence 税收、治理和债务期限结构:国际证据
Pub Date : 2018-10-07 DOI: 10.2139/ssrn.3262779
Eilnaz Kashefi Pour, M. Lasfer
We provide a cross-country evidence on the impact of corporate and personal income taxes, and corporate governance systems on debt maturity structures and leverage using a comprehensive sample of 212,642 firm-year observations based on a sample of 19,573 firms from 24 OECD countries over the period 1990–2015. We find longer debt maturities, higher leverage, and, in a dynamic setting, a greater propensity to decrease short-term debt, in countries with high investor protection and where the potentials for debt tax shields and after-tax return of investors are high. Our results imply that when investors are protected, firms tend to have optimal debt maturities to maximise the gains from tax shields and minimise the tax cost of equity. In contrast, in low protection countries, investors prefer their firms to opt for low debt that is mainly short-term to mitigate the risk-shifting and debt overhang problems even if this entails forgoing the debt tax shields. Our results hold for various robustness checks including the hierarchical linear model specification, which corrects for a number of OLS biases.
我们对公司和个人所得税以及公司治理制度对债务期限结构和杠杆的影响提供了跨国证据,采用了1990年至2015年期间来自24个经合组织国家的19,573家公司样本的212,642家公司年度观察结果的综合样本。我们发现,在投资者保护程度高、债务税盾和投资者税后回报潜力高的国家,债务期限更长,杠杆率更高,在动态环境中,减少短期债务的倾向更大。我们的研究结果表明,当投资者受到保护时,企业倾向于选择最佳债务期限,以最大限度地提高税收保护的收益,并最大限度地降低股权的税收成本。相比之下,在低保护的国家,投资者更希望他们的公司选择低债务,主要是短期的,以减轻风险转移和债务积压问题,即使这需要放弃债务税盾。我们的结果适用于各种鲁棒性检查,包括层次线性模型规范,它纠正了许多OLS偏差。
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引用次数: 20
Sample Statistics as Convincing Evidence: A Tax Fraud Case 样本统计作为有力证据:一起税务欺诈案
Pub Date : 2018-09-25 DOI: 10.2139/ssrn.3272185
J. Lillestøl
This report deals with the analysis of data used by tax officers to support their claim of tax fraud at a pizzeria. The possibilities of embezzlement under study are overreporting of take-away sales and underreporting of cash payments. Several modelling approaches are explored, ranging from simple well-known methods to presumably more precise tools. More specifically, we contrast common methods based on normal assumptions and models based on Gamma-assumptions. For the latter, both maximum likelihood and Bayesian approaches are covered. Several criteria for the choice of method in practice are discussed, among them, how easy the method is to understand, justify and communicate to the parties. Some dilemmas present itself: the choice of statistical method, its role in building the evidence, the choice of risk factor, the application of legal principles like “clear and convincing evidence” and “beyond reasonable doubt”. The insights gained may be useful for both tax officers and defenders of the taxpayer, as well as for expert witnesses.
本报告涉及税务官员用来支持他们对披萨店税务欺诈指控的数据分析。正在研究的挪用公款的可能性包括虚报外卖销售额和少报现金支付。探讨了几种建模方法,从简单的众所周知的方法到可能更精确的工具。更具体地说,我们比较了基于正常假设的常见方法和基于伽马假设的模型。对于后者,涵盖了最大似然和贝叶斯方法。讨论了实践中选择方法的几个标准,其中包括该方法是否容易理解、证明和与当事人沟通。统计方法的选择、统计方法在证据构建中的作用、风险因素的选择、“证据明确、令人信服”和“排除合理怀疑”等法律原则的适用等方面存在一些困境。所获得的见解可能对税务官员和纳税人的辩护人以及专家证人都有用。
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引用次数: 0
Policy Forum: Equalization and Canada's Fiscal Constitution — The Tie That Binds? 政策论坛:平等与加拿大财政宪法——捆绑的纽带?
Pub Date : 2018-09-08 DOI: 10.2139/ssrn.3262830
R. Bird
Canada has had a fiscal equalization system since 1957, and equalization was formally embedded in the constitution in 1982. However, the rationale for equalization, how the concept is defined and applied, and what its effects are or should be are all issues that continue to be vigorously debated in both political and expert circles. This article reviews some of these issues and concludes that, on the whole, equalization has played a useful role in helping Canada to get through the last half-century as well as it has. However, the system could be improved by making it more transparent--for example, by fixing the amount to be distributed at (say) the present share of the federal budget (instead of indexing it to a moving average of nominal growth in the gross domestic product), and making the distributional formula less overtly political by establishing a quasi-independent board to examine the allocation formula from time to time and make ecommendations for change. Governments at both the federal and provincial levels would then be more accountable for their actions, as they should be in a democracy.
加拿大从1957年开始实行财政均等化制度,并于1982年正式写入宪法。但是,平等的理由、如何界定和应用这一概念以及它的影响是什么或应该是什么,都是政治和专家界继续激烈辩论的问题。本文回顾了其中的一些问题,并得出结论,总的来说,平等在帮助加拿大度过过去半个世纪方面发挥了有益的作用。然而,可以通过提高透明度来改进这一体系——例如,将分配金额固定在(比如说)联邦预算的当前份额上(而不是将其与国内生产总值(gdp)名义增长的移动平均值挂钩),并通过建立一个准独立的委员会,不时审查分配公式,并提出改革建议,从而使分配公式不那么明显地政治化。这样一来,联邦和省级政府就会对自己的行为更加负责,这是民主国家应该做的。
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引用次数: 2
期刊
Public Economics: Taxation
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