Smoothness and the Value Relevance of Taxable Income

2015 ◽  
Vol 37 (2) ◽  
pp. 141-167 ◽  
Author(s):  
Michael A. Mayberry ◽  
Sean T. McGuire ◽  
Thomas C. Omer
Keyword(s):  
Value Relevance ◽  
Tax Avoidance ◽  
Tax Planning ◽  
Additional Analysis ◽  
Taxable Income ◽  
Planning Strategy ◽  
Avoidance Strategy ◽  
Jel Classifications

ABSTRACT This study investigates whether the smoothness of estimated taxable income influences its value relevance. Contrary to research that finds that smoothness enhances the value relevance of book income, we find that smoothness reduces the value relevance of taxable income. We decompose the smoothness of taxable income into its innate and discretionary components and find that innate smoothness is not associated with the value relevance of taxable income. However, we find that discretionary smoothness is associated with a reduction in taxable income's value relevance, suggesting that discretionary smoothness either eliminates or reduces the information contained in taxable income. In additional analysis, we find that discretionary smoothness is also associated with higher levels of future tax avoidance, consistent with managers smoothing taxable income as part of their tax avoidance strategy. In combination, our results suggest that the reduced value relevance of estimated taxable income is a byproduct of managers' tax-planning strategy. JEL Classifications: G32; H25; H32; M41.

Do Investors Use Prior Tax Avoidance when Pricing Tax Loss Carryforwards?

2016 ◽  
Vol 38 (2) ◽  
pp. 27-49 ◽  
Author(s):  
Sean T. McGuire ◽  
Stevanie S. Neuman ◽  
Adam J. Olson ◽  
Thomas C. Omer
Keyword(s):  
Avoidance Behavior ◽  
Tax Avoidance ◽  
Tax Planning ◽  
High Variability ◽  
Data Availability ◽  
Taxable Income ◽  
Internal Revenue ◽  
Valuation Allowance ◽  
Tax Loss ◽  
Jel Classifications

ABSTRACT The Internal Revenue Code allows firms to carry excess tax losses forward to offset future taxable income and reduce taxes. Consistent with tax loss carryforwards (TLCFs) creating a significant asset, prior research finds that investors positively value TLCFs. However, investors face significant uncertainty about whether firms will have sufficient future taxable income to benefit from TLCFs. We hypothesize that investors' valuation of new TLCFs will vary with firms' prior tax avoidance behavior because it signals firms' abilities to generate taxable income to offset TLCFs through tax planning. We confirm that investors assign a positive value to new TLCFs and find that investors' valuation varies with firms' prior tax avoidance behavior. Investors positively value TLCFs when firms exhibit high variability in prior tax avoidance and high levels of prior tax avoidance. Our results are incremental to the effect of changes in the valuation allowance on investors' valuation of new TLCFs. JEL Classifications: M40; M41; M49. Data Availability: Data used in this study are available from public sources identified in the paper.

scholarly journals TAX HEAVENS PHENOMENON: TAX PLANNING STRATEGY OR TAX AVOIDANCE

2020 ◽  
Vol 4 (1) ◽  
pp. 1-24
Author(s):  
Dinik Fitri Rahajeng Pangestuti ◽  
Nisrina Sari ◽  
Ambar Lestari
Keyword(s):  
Data Exchange ◽  
Tax Avoidance ◽  
Tax Planning ◽  
The Other ◽  
Planning Strategy ◽  
Exchange Of Information ◽  
Small Countries ◽  
Negative Effect ◽  
The Government ◽  
Fiscal Authority

Abstract Tax planning is one example of the use of regulatory loopholes. On the other hand for the Fiscal Authority, carrying out tax avoidance practices as a form of tax planning will have a negative effect on the Government and, for this reason, the Government makes fiscal corrections as its remedial. Many also hide their assets in tax heavens countries. This is so that the assets they have are not taxed. Tax heavens countries are usually small countries that apply very low taxes, some even do not impose taxes at all. However, the government has prepared an Automatic Exchange of Information (AEoI) data exchange plan that occurs in 2018, certainly will make tax evaders unable to run away from the pursuit of the tax authorities, even if they have to flee to tax heavens countries (tax heavens). Keywords: tax heavens, tax planning, Automatic Exchange of Information (AEoI)   Abstrak Perencanaan pajak adalah salah satu contoh penggunaan celah peraturan. Pada sisi lain bagi Otoritas Fiskal, melakukan praktik penghindaran pajak sebagai bentuk perencanaan pajak akan membawa efek negatif bagi Pemerintah dan, untuk itulah, Pemerintah melakukan koreksi fiskal sebagai remedialnya. Banyak juga yang menyembunyikan asetnya di negara-negara tax heavens. Hal ini bertujuan agar aset yang mereka punya tidak terkena pajak. Negara tax heavens biasanya merupakan negara kecil yang menerapkan pajak yang sangat rendah, bahkan ada yang tidak mengenakan pajak sama sekali. Namun, pemerintah telah menyiapkan Rencana pertukaran informasi data perbankan secara otomatis (Automatic Exchange of Information/AEoI) yang terjadi pada 2018, dipastikan akan membuat para pengemplang pajak tidak akan bisa lari dari kejaran otoritas pajak, sekalipun mereka harus kabur ke negara surga pajak (tax heavens). Kata kunci: Tax Heavens, Tax Planning, Automatic Exchange of Information (AEoI)

Code Section 304: The Gift That Keeps on Giving

2019 ◽  
Vol 17 (1) ◽  
pp. 25-39
Author(s):  
Doron Narotzki ◽  
Melanie G. McCoskey
Keyword(s):  
Tax Avoidance ◽  
Tax Planning ◽  
Expected Loss ◽  
Legislative Change ◽  
Planning Tools ◽  
The Gift ◽  
Foreign Corporations ◽  
Jobs Act ◽  
The U.S ◽  
Jel Classifications

ABSTRACT The Tax Cuts and Jobs Act (TCJA) has created a unique opportunity to utilize Code Section 304 and Code Section 245A as powerful tax-planning tools. By utilizing the rules established for redemptions between related corporations under the anti-abuse provisions of Code Section 304 combined with the new 100 percent DRD of Code Section 245A, extracting earnings from affiliated foreign corporations tax-free has never been easier. This paper explains how these two code sections interact with each other and the resulting ability to extract certain foreign-sourced earnings tax-free. It also identifies incentives created by the TCJA to operate profitable businesses overseas and expected loss operations in the U.S. Finally, the paper offers a legislative change to close the tax avoidance loophole created by the TCJA. JEL Classifications: H2.

Consistency of Book-Tax Differences and the Information Content of Earnings

2012 ◽  
Vol 34 (2) ◽  
pp. 93-116 ◽  
Author(s):  
Linda H. Chen ◽  
Dan S. Dhaliwal ◽  
Mark A. Trombley
Keyword(s):  
Standard Deviation ◽  
Earnings Management ◽  
Information Content ◽  
Joint Effect ◽  
Tax Planning ◽  
Taxable Income ◽  
Incremental Effect ◽  
The Difference ◽  
Jel Classifications

ABSTRACT This paper examines the effect of tax planning and earnings management on the informativeness of book income and taxable income. We conduct two sets of tests documenting (1) the incremental effect of tax planning and earnings management on the informativeness of book and taxable income, and (2) the relation between the consistency of the book-tax difference and the informativeness of book and taxable income. The consistency of the book-tax difference depends on firm decisions regarding incremental earnings management and tax planning. Consistency of the book-tax difference is measured as the standard deviation of the discretionary component of the difference between book income and taxable income. Our results show that consistency of the book-tax difference, as a measure of the joint effect of earnings management and tax planning, is related to persistence of both book and tax income and has an incremental effect on information content of both book income and taxable income. JEL Classifications: G12; G32; H24; H25.

scholarly journals Good Tax Governance: A Matter of Moral Responsibility and Transparency

2017 ◽  
Vol 2017 (1) ◽  
pp. 70-88 ◽  
Author(s):  
Hans J.L.M. Gribnau ◽  
Ave-Geidi Jallai
Keyword(s):  
Multinational Corporations ◽  
Tax Evasion ◽  
Tax Avoidance ◽  
Tax Planning ◽  
Moral Leadership ◽  
Current Debate ◽  
Planning Strategy ◽  
The Difference ◽  
Mind Set ◽  
Corporate Social

Abstract Multinational corporations’ tax practices are hotly debated nowadays. Multinationals are accused of not paying their fair share of taxes. Apparently, acting within the limits set by law is not sufficient to qualify as morally responsible behavior anymore. This article offers ethical reflection on the current debate. The general public typically evaluates (aggressive) tax planning in moral terms rather than legal terms. Therefore, multinationals need to reflect on their tax planning strategy next to economic and legal terms also in ethical terms. This article addresses the relationship between society, morality and taxes. The concepts of tax planning, “aggressive tax planning”, “tax evasion” and “tax avoidance” are elaborated on to exemplify the difference between a purely legal and broader approach. In moral terms, aggressive tax planning may imply loss of integrity and trust which may entail certain costs for businesses, such as reputation damage. It will be argued that in order to improve corporate reputation and (moral) leadership, corporate social responsibility (CSR), endorsed by many corporations around the globe, is a helpful tool. Reflection on tax planning in the context of CSR - good tax governance - should foster a moral mind set and enhance accountability and transparency.

scholarly journals PLANEJAMENTO TRIBUTÁRIO EM UMA INDÚSTRIA DE CONFECÇÕES

2021 ◽  
pp. 77-92
Author(s):  
Andrey Araujo ◽  
Diones Kleinibing Bugalho ◽  
Francieli Morlin Bugalho ◽  
Januario José Monteiro
Keyword(s):  
Income Tax ◽  
Processing System ◽  
Tax Avoidance ◽  
Financial Statements ◽  
Tax Planning ◽  
Research Data ◽  
Clothing Industry ◽  
Data Processing System ◽  
Balance Sheets ◽  
Taxable Income

A presente pesquisa teve por objetivo identificar o regime tributário que fosse menos oneroso à uma indústria de confecções, ou seja, ocasionando a menor carga tributária. Com a finalidade de realizar o planejamento tributário, foram efetuadas diversas consultas em pesquisas existentes e nas legislações aplicáveis, para que tudo fosse praticado por meios legais, sendo caracterizada pela elisão fiscal, trata-se de uma pesquisa qualitativa, onde os dados da pesquisa foram coletados através do sistema eletrônico de processamento de dados, relatórios, balanços e demonstrações contábeis. O período analisado refere-se ao ano de 2018, pelo qual foram efetuados os cálculos pelo regime tributário Lucro Real o pela contabilidade responsável pela empresa. Foram comparados os valores dos tributos de PIS, COFINS, IRPJ, CSLL, ICMS, IPI e CPP, onde ocorreu os comparativos entre os regimes de tributação Lucro Real e Lucro Presumido, com a finalidade de demonstrar o melhor regime aplicável. Os resultados indicam que o melhor regime tributário para o período analisado foi o Lucro Real, identificando que está enquadrada na melhor forma de apuração. Palavras-Chave: Lucro Real. Lucro Presumido. Regime Tributário. Tributos.   Abstract: The present research aimed to identify the tax regime that would be less costly to a clothing industry, that is, causing the lowest tax burden. In order to carry out tax planning, several consultations were carried out in existing research and in the applicable legislation, so that everything could be practiced by legal means, being characterized by tax avoidance, it is a qualitative research, where the research data were collected through the electronic data processing system, reports, balance sheets and financial statements. The period analyzed refers to the year 2018, where calculations have already been made under the taxable profit regime by the accounting responsible for the company. The values ​​of the PIS, COFINS, IRPJ, CSLL, ICMS, IPI and CPP taxes were compared, where the comparisons between the taxable income tax system and the presumed income tax occurred, in order to demonstrate the best applicable regime. The results indicate that the best tax regime for the period analyzed is the Real Profit, identifying that it is framed in the best form of calculation. Keywords: Real Profit. Presumed profit. Tax regime. Taxes.

Brewing Up Controversy: A Case Exploring the Ethics of Corporate Tax Planning

2015 ◽  
Vol 30 (4) ◽  
pp. 311-327 ◽  
Author(s):  
Megan F. Hess ◽  
Raquel Meyer Alexander
Keyword(s):  
Real World ◽  
Ethical Issues ◽  
Tax Avoidance ◽  
Tax Planning ◽  
Learning Assessment ◽  
Class Discussion ◽  
Corporate Tax ◽  
Tax Havens ◽  
Multinational Organizations ◽  
The U.S

ABSTRACT This instructional case explores the ethical issues surrounding the corporate tax-planning and tax-avoidance strategies of multinational organizations. Drawing on the real-world experiences of SABMiller, one of the world's largest beverage companies, this case provides a launching point for students to consider the ethics of corporate tax planning. The ethics of multinational tax practices, especially the use of tax havens, has recently become the focus of media and legislative debate in both the U.S. and the U.K., and many well-respected companies, such as General Electric, Apple Inc., and Starbucks are now feeling the pressure to reform. In a post-case learning assessment, students demonstrated significant improvement in their understanding and indicated that they enjoyed discussing this controversial issue. The “Implementation Guidance” section and Teaching Notes offer guidance for in-class discussion of the ethical and tax issues in this case.

The Accrual Accounting Principle and its Implications for Portuguese Tax Courts Decisions

2020 ◽  
Vol 0 (0) ◽  
Author(s):  
Daniel Taborda ◽  
João Sousa
Keyword(s):  
Tax Avoidance ◽  
Case Law ◽  
Tax Law ◽  
Income Transfer ◽  
Legal Decisions ◽  
Taxable Income ◽  
Principle Of Justice ◽  
Legal Arguments ◽  
Accounting Principle ◽  
Flexible Application

AbstractTo the best of our knowledge, this is the first paper focusing on the interpretations issued by different Portuguese courts concerning the application of the accrual principle established in the Corporate Income Tax Code.This paper uses a database of the Portuguese tax courts’ decisions and employs a case law-based research methodology to address the following question: under which circumstances the principle of justice may affect the strict application of the accrual principle? After collecting twenty-four legal decisions related to the application of the accrual principle outlined in tax law, this paper summarises eleven, grouping them according to the different issues under dispute. This analysis also includes the confrontation of the assumptions used by the tax authority and the claims of the taxpayers, identifying and discussing the legal arguments to override the strict application of the accrual principle.The main conclusion is that Portuguese courts may summon the principle of justice in taxation when taxpayers violate the accrual principle, in order to prevent unfair corrections to taxable income performed in tax audits. This paper found that the tax authority typically demands a rigid use of the accrual principle while the taxpayers often argue for a more flexible application. This last perspective has been adopted by the tax courts in certain circumstances, in particular when taxable income transfer was not motivated by tax avoidance.

TAX PLANNING AND STATE AID UNDER THE EUROPEAN LAW

2021 ◽  
Vol 66 (05) ◽  
pp. 228-232
Author(s):  
Aygun Gunduz Guliyeva ◽  
Keyword(s):  
Key Words ◽  
Rule Of Law ◽  
Tax Avoidance ◽  
Tax Planning ◽  
State Aid ◽  
European Court Of Justice ◽  
European Law ◽  
The Rule Of Law ◽  
Court Of Justice ◽  
European Court

There is a strong link between funding criteria from government sources and the advantage and selectivity associated with classifying an event as government assistance. However, the selectivity criterion is very important when considering whether there is a banned state aid. Finally, the European Court of Justice no longer applies the rule of law and exclusion to selectivity. Instead, the selectivity review consists of two parts: whether a precaution is selective and whether preference is necessary and proportionate. Key words: EU, tax, tax avoidance, state aid, tax planning, competition

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