scholarly journals An Overview of Academic Tax Accounting Research Drawing on U.S. Multinational Taxation

2020 ◽  
Vol 19 (3) ◽  
pp. 9-17
Author(s):  
Terry Shevlin
Keyword(s):  
Tax Reform ◽  
Tax Planning ◽  
Rate Of Return ◽  
Global Approach ◽  
Tax Rate ◽  
Accounting Research ◽  
Tax Research ◽  
Multinational Taxation ◽  
Jobs Act ◽  
The U.S

ABSTRACT Economics-based tax research in accounting draws heavily on the Scholes-Wolfson framework. The framework develops a global approach to tax planning where all parties, all taxes, and all costs are to be considered in effective tax planning. Effective tax planning is distinct from tax minimization as the goal of the former is to maximize the after-tax rate of return. The first empirical applications of the framework followed the passage of the Tax Reform Act of 1986. Taxation of multinationals has long been of interest to accounting (and other) researchers and continues to be of interest. The Tax Cuts and Jobs Act of 2017 changed many tax laws including how the U.S. taxes U.S. multinationals. Research examining the ramifications of this latest Tax Act is already well under way.

A Model of Multinational Income Shifting and an Application to Tax Planning with E-Commerce

2014 ◽  
Vol 36 (2) ◽  
pp. 27-53 ◽  
Author(s):  
Kenneth J. Klassen ◽  
Stacie K. Laplante ◽  
Carla Carnaghan
Keyword(s):  
Tax Planning ◽  
Investment Model ◽  
Income Shifting ◽  
Tax Rates ◽  
Foreign Investments ◽  
Effective Tax Rates ◽  
Tax Rate ◽  
Foreign Earnings ◽  
Joint Consideration ◽  
The U.S

ABSTRACT: This manuscript develops an investment model that incorporates the joint consideration of income shifting by multinational parents to or from a foreign subsidiary and the decision to repatriate or reinvest foreign earnings. The model demonstrates that, while there is always an incentive to shift income into the U.S. from high-foreign-tax-rate subsidiaries, income shifting out of the U.S. to low-tax-rate countries occurs only under certain conditions. The model explicitly shows how the firms' required rate of return for foreign investments affects both repatriation and income shifting decisions. We show how the model can be used to refine extant research. We then apply it to a novel setting—using e-commerce for tax planning. We find firms in manufacturing industries with high levels of e-commerce have economically significant lower cash effective tax rates. This effect is magnified for firms that are less likely to have taxable repatriations. JEL Classifications: G38, H25, H32, M41.

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.

Income from Student Inventions and the Kiddie Tax

2012 ◽  
Vol 10 (2) ◽  
pp. 1-13
Author(s):  
Brigitte W. Muehlmann ◽  
Wanny Baez ◽  
Priscilla A. Burnaby
Keyword(s):  
Graduate Students ◽  
Tax Planning ◽  
Primary Sources ◽  
Tax Law ◽  
Full Time ◽  
Tax Rate ◽  
Scientific Revolutions ◽  
Unearned Income ◽  
Planning Strategies ◽  
The U.S

ABSTRACT Scientific revolutions, frequently led by the youngest scientists, are essential for the competitiveness of the U.S. economy. In 2008, the kiddie tax age limit was increased from 18 to 24 years, which expanded its coverage to full-time undergraduate and graduate students. Although Congress generally seeks to promote innovation, royalty income from student-created inventions is penalized because it is characterized as unearned income that is subject to the kiddie tax, a form of alternative minimum tax. The objective of the drafter of the kiddie tax was to cover income transferred from a parent's to a child's lower tax rate. Student inventors can employ tax planning strategies to avoid the kiddie tax on earnings from their patents provided they are aware of the kiddie tax provisions. The tax treatment of student inventor royalty income could not be discerned from primary sources of tax law or the JCT Bluebooks. It would be desirable for Congress to act and either eliminate the kiddie tax on the royalty income from student inventions or, at a minimum, disclose the legislative design of the provision and what it intends to accomplish so that those affected by it could plan accordingly.

The Tax Cuts and Jobs Act of 2017 and the Gig Economy: Why the Employee vs. Contractor Debate Matters More than Ever

2021 ◽  
pp. 088636872110602
Author(s):  
Stanley Veliotis ◽  
Balsam Steve
Keyword(s):  
Income Tax ◽  
Tax Reform ◽  
Point Of View ◽  
Tax Law ◽  
Court Cases ◽  
Independent Contractors ◽  
Gig Economy ◽  
Jobs Act ◽  
The U.S ◽  
Tax Cuts

The issue of whether workers are independent contractors or employees has become even more relevant with recently enacted and proposed legislation and court cases in many jurisdictions seeking to impose employee status on many Gig economy workforce participants, such as ride-share drivers. This article emphasizes that the U.S. income tax rules, especially after tax reform effective in 2018, makes employee status extremely tax-inefficient for these workers. This article explains the relevant tax law changes and provides various examples of typical settings to confirm that workers with even small relative work expenses are often better off as contractors from a tax point of view.

scholarly journals Policy Forum: Is Accelerated Depreciation Good or Misguided Tax Policy?

2019 ◽  
Vol 67 (1) ◽  
pp. 41-55
Author(s):  
Philip Bazel ◽  
Jack Mintz
Keyword(s):  
United States ◽  
Tax Reform ◽  
The United States ◽  
Tax Rates ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Accelerated Depreciation ◽  
The Government ◽  
Jobs Act

The authors examine the implications of Canada's response to the 2017 US tax reform. Canada's focus on accelerated tax depreciation will achieve lower marginal effective tax rates on capital for taxpaying companies, well below the US levels achieved with the Tax Cuts and Jobs Act that came into effect on January 1, 2018. By ignoring neutrality, the government offsets some of the potential gains by reducing the tax burden on capital, thereby failing to maximize efficiency gains from a better corporate tax system. Further, Canada's approach fails to respond to competitiveness effects of US reforms on corporate tax base erosion in Canada as companies shift profits to the United States. The low US tax rate on intangible income will draw certain functions to the United States. A more comprehensive approach to corporate tax reform, including some reduction in corporate income tax rates, would have been a preferable response.

Tax Reform and Tax Experts

2018 ◽  
Vol 40 (2) ◽  
pp. 83-88 ◽  
Author(s):  
Joel Slemrod
Keyword(s):  
Tax Reform ◽  
Natural Experiments ◽  
Tax Rate ◽  
Long Run ◽  
Normative Evaluation ◽  
Wide Range ◽  
Standard Deduction ◽  
Fiscal Imbalance ◽  
Tax Changes ◽  
Jobs Act

ABSTRACT The Tax Cuts and Jobs Act (TCJA), passed in 2017, represents the most comprehensive revision of the U.S. income tax since the Tax Reform Act of 1986 (TRA86). Although the TCJA shares many features with TRA86—corporate tax rate cuts, increasing the standard deduction, cutting back on deductions—it sharply differs in that it is neither revenue neutral nor distributionally neutral, both aspects of which are troubling in light of the large long-run federal fiscal imbalance and rising income inequality. Regardless of one's normative evaluation, the TCJA provides scores of natural experiments that can inform us about the consequences of tax changes on a wide range of economic behaviors.

Making Tax Havens Work: The Necessity of Tax Professionalism

2018 ◽  
Vol 18 (1) ◽  
pp. 53-80
Author(s):  
Martin T. Stuebs ◽  
Helen (Janie) Whiteaker-Poe
Keyword(s):  
Tax Policy ◽  
Tax Reform ◽  
Corporate Tax ◽  
Tax System ◽  
Tax Havens ◽  
Earned Income ◽  
Tax Professionals ◽  
Jobs Act ◽  
Influence Behavior ◽  
The U.S

ABSTRACT The Tax Cuts and Jobs Act of 2017 overhauled the U.S. corporate tax system, lowering the statutory rate, exempting foreign earned income, and strengthening anti-abuse provisions. However, opportunities and incentives for abuse remain. Therefore, while developing tax policy is helpful, this paper posits that developing tax professionalism—not only tax policy—is needed. Efforts to reform tax policy should be balanced with efforts to develop and guard tax professionalism. Implementing tax policies in a flourishing tax system requires flourishing tax professionals. We develop theoretical and moral analyses to assess tax policy and tax professionalism approaches to tax reform. By targeting processes in the tax system, the tax policy approach attempts to influence practitioner behavior by restricting opportunities and incentives for corporate tax aggression. The tax professionalism approach recognizes that beneath efforts to influence behavior is a deeper, fundamental challenge to develop and protect tax professionals as reflexive agents capable of responsibly handling tax system opportunities and incentives. The tax professionalism approach focuses on persons in the tax system—not processes. This paper draws attention to the limitations of the tax policy approach and to the complementary need for the tax professionalism approach and proposes practical approaches to developing tax professionalism.

Transocean and the History of Tax Inversions

2018 ◽  
Vol 34 (1) ◽  
pp. 1-12
Author(s):  
Susan M. Albring ◽  
Randal J. Elder ◽  
Mitchell A. Franklin
Keyword(s):  
Multinational Corporations ◽  
Economic Impacts ◽  
Income Taxes ◽  
Tax Rates ◽  
Corporate Tax ◽  
Corporate Income Taxes ◽  
History Of ◽  
Jobs Act ◽  
The U.S ◽  
Over Time

ABSTRACT The first tax inversion in 1983 was followed by small waves of subsequent inversion activity, including two inversions completed by Transocean. Significant media and political attention focused on transactions made by U.S. multinational corporations that were primarily designed to reduce U.S. corporate income taxes. As a result, the U.S. government took several actions to limit inversion activity. The Tax Cuts and Jobs Act of 2017 (TCJA) significantly lowered U.S. corporate tax rates and one expected impact of TCJA is a reduction of inversion activity. Students use the Transocean inversions to understand the reasons why companies complete a tax inversion and how the U.S. tax code affects inversion activity. Students also learn about the structure of inversion transactions and how they have changed over time as the U.S. government attempted to limit them. Students also assess the tax and economic impacts of inversion transactions to evaluate tax policy.

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.

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