A Model of Dynamic Tax Planning with an Application to Estate Freezes
This paper develops a model of dynamic tax planning in which the implementation of a tax plan involves exercising an option to execute an irreversible investment or financing structure transaction. The model considers four aspects of such transactions and shows that transactions are deferred if the tax savings from the transaction are lower or if the time horizon over which the transaction can be executed is longer. Deferral is also increasing in cost of a future unfavorable event to which the irreversibility of the transaction limits one's ability to respond, but may increase or decrease with a change in the probability that an unfavorable event occurs. We apply the model to a common estate freeze tax plan in Canada. Undertaking an estate freeze requires a private company's owner-manager to choose how one's business assets are to be distributed at death. In contrast to the conventional wisdom regarding the timing of this strategy, we find that waiting to implement the strategy is often optimal. We test the model using data on family-owned businesses in Canada and find strong support for the model's predictions.