How Chevron, Texaco, and the Indonesian Government Structured Transactions to Avoid Billions in U.S. Income Taxes

2003 ◽  
Vol 17 (2) ◽  
pp. 107-122 ◽  
Author(s):  
Jeffrey D. Gramlich ◽  
James E. Wheeler
Keyword(s):  
Crude Oil ◽  
Income Tax ◽  
Income Taxes ◽  
Tax Credits ◽  
The Other ◽  
Production Sharing ◽  
Tax Returns ◽  
State Income ◽  
The Government ◽  
State Taxes

This paper explains the transactions, agreements, and accounting that Chevron, Texaco, and the Government of Indonesia used to structure transactions that avoided billions in U.S. income taxes. Although ChevronTexaco became a merged entity on October 9, 2001, for many years Chevron and Texaco operated as separate corporations, with each owning 50 percent of a group of primarily non-U.S. companies collectively known as Caltex. Transactions were structured such that Chevron and Texaco subsidiaries paid Caltex excessive prices for Indonesian crude oil, leading to excessive dividend income (with foreign tax credits) and cost of sales deductions on U.S. income tax returns. When one of the equal shareholders purchased more overpriced oil than the other, Caltex paid monthly “Special Dividends” to the “overlifter” that could be construed as cost rebates, not dividends. To compensate for the extra taxes it received, the Government of Indonesia provided Caltex with oil in excess of the amount called for under the formal production-sharing contract (PSC) with the Government of Indonesia. We estimate that this arrangement allowed Chevron and Texaco together to annually avoid paying some $220 million in federal income taxes and $11.1 million in state income taxes from 1964 to 2002. These estimates produce total federal and state taxes avoided of $8.6 billion and $433 million, respectively, for the combined company, ChevronTexaco.

Criminal Prosecution of Tax Return Preparers

2008 ◽  
Vol 6 (1) ◽  
pp. 24-42
Author(s):  
Nancy B. Nichols
Keyword(s):  
Income Tax ◽  
Tax Credits ◽  
Internal Revenue Service ◽  
Criminal Investigation ◽  
Criminal Prosecution ◽  
Earned Income ◽  
Financial Crimes ◽  
Tax Returns ◽  
The Government

Over 61 percent of individual taxpayers, accounting for more than 76 million returns, utilized the services of paid preparers in 2005. However, hiring a paid preparer does not assure the taxpayer or the government that the return will be prepared correctly. Tax return preparer fraud generally involves the preparation and filing of false income tax returns by preparers who claim inflated personal or business expenses, false deductions, unallowable credits or excessive exemptions on returns completed for their clients or fictitious taxpayers. Preparers may also manipulate income figures to fraudulently obtain tax credits, such as the earned income tax credit. The Criminal Investigation (CI) division of the Internal Revenue Service (IRS) prosecutes the most serious cases of preparers suspected of criminal or fraudulent behavior and other related financial crimes. This article investigates the role of CI in prosecuting tax return preparers and analyzes the results of 377 published tax return preparer criminal tax cases from 2000 through 2005. The paper also reviews various alternatives for discouraging fraudulent behavior, including registration of all paid preparers, automatic return preparation by the IRS, more stringent preparer penalties, and improved collection of assessed preparer penalties.

scholarly journals What Explains the Redistribution Achieved by the Italian Personal Income Tax? Evidence from Administrative Data

2016 ◽  
Vol 46 (1) ◽  
pp. 7-28 ◽  
Author(s):  
Gian Paolo Barbetta ◽  
Simone Pellegrino ◽  
Gilberto Turati
Keyword(s):  
Administrative Data ◽  
Income Tax ◽  
Personal Income ◽  
Tax Credits ◽  
Tax Credit ◽  
Tax Rates ◽  
Personal Income Tax ◽  
Tax Returns ◽  
The Government ◽  
Redistributive Effect

We analyze the Italian personal income tax (PIT) in the light of the different tools available to the government to achieve income redistribution. We focus in particular on three mechanisms: marginal tax rates, deductions, and tax credits. Exploiting an extended version of the standard Pfähler decomposition, we estimate the contribution of each of these three tools to the overall redistributive effect of the PIT using administrative data on more than 1.3 million individual tax returns. Our estimates suggest that more than half of the total PIT redistributive effect is due to the two most important tax credits (the tax credit for employment and the tax credit for retirement income), while the marginal rates schedule contribution is about 40 percent. On the contrary, most of the itemized expenditures do not show any sizable impact on redistribution.

A STUDY OF THE IMPACT OF SPECIAL INTEREST GROUPS ON MAJOR TAX REFORM: AGRICULTURE AND THE 1913 INCOME TAX LAW

2008 ◽  
Vol 35 (2) ◽  
pp. 71-100 ◽  
Author(s):  
Douglas K. Barney ◽  
Tonya K. Flesher
Keyword(s):  
Quantitative Analysis ◽  
Income Tax ◽  
Income Taxes ◽  
Tax Law ◽  
Special Interest Groups ◽  
Congressional Debates ◽  
Farm Population ◽  
Income Tax Law ◽  
State Income ◽  
The Impact

Farmers have benefited from unique tax treatment since the beginning of the income tax law. This paper explores agricultural influences on the passage of the income tax in 1913, using both qualitative and quantitative analysis. The results show that agricultural interests were influential in the development and passage of tax/tariff laws. The percentage of congressmen with agricultural ties explains the strong affection for agriculture. Discussion in congressional debates and in agricultural journals was passionate and patriotic in support of equity for farmers. The quantitative analysis reveals that the percentage farm population was a significant predictor of passage of the 16th Amendment by the states and of adoption of state income taxes in the 20th century.

Analisis Ekualisasi SPT Masa PPN Dengan SPT PPh Badan Terhadap Kewajiban Perpajakan PT. Adiyana Teknik Mandiri

2018 ◽  
Vol 6 (3) ◽  
pp. 117-122
Author(s):  
Irham Firdauza Pratama ◽  
Hadi Sutomo
Keyword(s):  
Income Tax ◽  
Value Added ◽  
Preventive Measure ◽  
Income Taxes ◽  
Financial Statement ◽  
Corporate Income Tax ◽  
Applicable Law ◽  
Tax Returns ◽  
Tax Audit ◽  
The Difference

Many cases are related to corrections caused by the occurrence of VAT and Income Tax equalization. The difference in reporting the circulation of business on the VAT SPT with the Corporate Income Tax Return is the object of the tax authorities' examination. Basically, equalization is not to find the same number of circulation businesses but to find the cause of the difference between the VAT Period of Income Tax and the Corporate Income Tax Return. These differences are often due to differences in provisions between Income Taxes and Value Added Taxes, such as tax objects, exchange rates, and so on. The purpose of this study was to find out how to report the circulation of business between the VAT Period of VAT and Corporate Income Tax Returns of PT. AdiyanaTeknikMandiri. To find out the process and analysis of equalization between VAT Period of VAT and Corporate Income Tax Returns at PT. AdiyanaTeknikMandiri. To find out the equalization benefits of the VAT Period SPT with Corporate Income Tax Returns for companies. This study uses a comparative descriptive method with qualitative and quantitative data, namely by analyzing and processing financial statement data and existing fiscal reports, then comparing the circulation of business to the results of calculations according to the VAT Period of VAT and Corporate Income Tax Returns, then processed further to provide an explanation of the difference in business circulation generated. The results of this study indicate that PT. AdiyanaTeknikMandiri that the company in reporting the circulation of its business has not been reported as it should, it is known after equalizing it is known that there is a number of business circulation that has not been reported in the VAT Period SPT report so that it causes a difference in the amount of business circulation between the VAT Period of Income Tax and the Corporate Income Tax Return. Equalization process is carried out by comparing the VAT Period report with the Corporate Income Tax Return, collecting data on business circulation in the ledger, comparing the data obtained, then analyzing the factors that cause the different reporting of business circulation. Equalization benefits for the company, which can be a preventive measure to face a tax audit by the tax authorities, so that the company can explain in accordance with the conditions that occur, equalization can also be a benchmark of compliance and increase the accuracy of taxpayers in reporting the amount of tax obligations in accordance with the applicable law .   Keywords: tax equalization, business circulation, corporate income tax return

scholarly journals The Impact of Federal and State Income Tax Liabilities on Timber Investments in the Midwest and Northeast

2007 ◽  
Vol 24 (4) ◽  
pp. 245-251 ◽  
Author(s):  
Nathan R. Smith ◽  
Philip Bailey ◽  
Harry Haney ◽  
Debra Salbador ◽  
John Greene
Keyword(s):  
Income Tax ◽  
Tax Planning ◽  
Income Taxes ◽  
Forest Landowners ◽  
Middle Income ◽  
State Tax ◽  
State Income Tax ◽  
State Income ◽  
Lower Peninsula ◽  
The Impact

Abstract Federal and state income taxes are calculated for hypothetical forest landowners in two income brackets across 23 states in the Midwest and Northeast to illustrate the effects of differential state tax treatment. The income tax liability is calculated in a year in which the timber owners harvest $200,000 worth of timber. State income taxes ranged from highs of $13,427 for middle-income landowners and $18,527 for high-income landowners in Maine to no tax burden in New Hampshire and South Dakota. Calculated state and federal income taxes are based on 2004 tax regulations and rates. After-tax land expectation values calculated for a forest landowner in the Northern Lower Peninsula of Michigan illustrate the importance of tax planning on returns to a timber investment. The results support the need for adequate tax accounting.

scholarly journals The Impact of Federal and State Income Tax Liabilities on Timber Investments in the West

2008 ◽  
Vol 23 (2) ◽  
pp. 121-126
Author(s):  
Nathan R. Smith ◽  
Phillip Bailey ◽  
Harry Haney ◽  
Debra Salbador ◽  
John Greene
Keyword(s):  
Income Tax ◽  
Tax Planning ◽  
Income Taxes ◽  
The West ◽  
Forest Landowners ◽  
Middle Income ◽  
State Tax ◽  
State Income Tax ◽  
State Income ◽  
The Impact

Abstract Federal and state income taxes are calculated for hypothetical forest landowners in two income brackets across 13 states in the West to illustrate the effects of differential state tax treatment. The income tax liability is calculated in a year in which the timber owners harvest $200,000 worth of timber. State income taxes range from highs of $19,693 for middle-income and $34,993 for high-income landowners in Oregon to no income tax in Alaska, Nevada, Washington and Wyoming. After-tax land expectation values for a forest landowner in Oregon are also calculated to illustrate the importance of tax planning on returns to a timber investment. The need for adequate tax accounting is supported by the results.

scholarly journals An economic analysis of Iranian petroleum contract

2020 ◽  
Vol 17 (5) ◽  
pp. 1451-1461 ◽  
Author(s):  
Fazel M. Farimani ◽  
Xiaoyi Mu ◽  
Hamed Sahebhonar ◽  
Ali Taherifard
Keyword(s):  
Sensitivity Analysis ◽  
Economic Analysis ◽  
Crude Oil ◽  
Technical Information ◽  
Oil Price ◽  
Economic Rent ◽  
Crude Oil Price ◽  
New Model ◽  
Production Sharing ◽  
The Government

Abstract Following three generations of buyback contracts, the new model of Iranian petroleum contracts (IPC) was introduced by the Iranian cabinet to incentivize investments in the country. This paper analyzes the fiscal terms of the contract with technical information from one of the candidate fields for licensing. The financial simulation shows that, in general, the IPC resembles more a service contract than a production sharing contract as the contractor’s take is relatively low—below 5% across different scenarios of crude oil price. Second, the IPC is progressive in that as the overall profitability of the project improves the government takes an increasing share of the economic rent. The results are confirmed in a sensitivity analysis of each party’s profitability and takes on oil price, CAPEX, OPEX and the fee.

scholarly journals The Impact of Federal and State Income Taxes on Timber Income in the Northeast and Midwest Following the 1986 Tax Reform Act

1996 ◽  
Vol 13 (1) ◽  
pp. 8-15 ◽  
Author(s):  
William C. Siegel ◽  
Harry L. Haney ◽  
Daniel M. Peters ◽  
Pete Bettinger ◽  
Debra S. Callihan
Keyword(s):  
New Hampshire ◽  
Income Tax ◽  
Income Level ◽  
Income Taxes ◽  
The State ◽  
High Income ◽  
Tax Rate ◽  
Income Levels ◽  
State Income Tax ◽  
State Income

Abstract The structure and provisions of state income taxes are detailed for timber owners in 19 states of the Northeast and Midwest. Using 1994 federal and state income tax rules, the tax liability for a hypothetical married couple with timber sale income was calculated for two federal income tax rate brackets (medium and high income levels) for states in the Northeast and Midwest that impose an income tax. At the medium income level, the state portion of the total income tax liability ranged from 12.7% in Pennsylvania to 25.6% in Delaware. At the high income level, the state portion ranged from 11.1% in Pennsylvania to 24.9% in Minnesota. For both income levels, New Hampshire had the lowest state portion of the total tax liability when considering their business profits tax (12% for the medium and 7% for the high income level). The provision most significantly affecting state income tax liability was the tax rate schedule. Installment sales provide an alternative tax planning strategy for those timber owners who qualify as investors rather than a business and who are in the lowest federal tax bracket. Several states also impose taxes other than an income tax when timber is harvested. For example, Minnesota and New Hampshire both impose a minimum 10% yield tax on the timber's stumpage value. These levies significantly affect the total tax liability on harvest income. North. J. Appl. For. 13(1):8-15.

scholarly journals The Jock Tax Contest: Professional Athletes Vs. The States - Background And Current Developments

2011 ◽  
Vol 20 (2) ◽  
Author(s):  
Elizabeth C. Ekmekjian ◽  
James C. Wilkerson ◽  
Robert W. Bing
Keyword(s):  
New York ◽  
Income Tax ◽  
Major League Baseball ◽  
Income Taxes ◽  
The State ◽  
Income Taxation ◽  
Professional Athletes ◽  
Baseball Player ◽  
National Anthem ◽  
State Income

Opening day of the Major League Baseball‟s 2<span>002 season fell on April 1 of that year. After the National Anthem was sung, the crowd applauded as the New York Mets took the field, and the umpire yelled, “play ball.” The State of New York also cheered. Why? New York, like a number of other states and localities, imposes an income tax on athletes that visit its borders. So, when Tex- as Rangers shortstop, Alex Rodriguez, the highest paid baseball player during the 2002 season with a salary of $22 million, played 4 regular season games in the Big Apple, he incurred a tax liability of approximately $34,250. This state income taxation of nonresident professional athletes is commonly referred to as “the jock tax.” This paper introduces the reader to the jock tax beginning with a brief explanation of state income taxes, continuing with a discussion of its complexi- ties and historical/current issues faced by athletes, teams and the states through implementation of the tax. The paper concludes with the broader implications of a state or local taxing jurisdiction's powers to tax its nonresident visitors. </span>

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