Taxation Commons^™

Targets Tax Shelter Participation And Takeover Premiums, Travis Chow, Kenneth J. Klassen, Yanju Liu

Research Collection School Of Accountancy

This paper examines the effect of targets' participation in tax shelters on takeover premiums in mergers and acquisitions. Using a novel data set in which targets disclose that they have not participated in tax shelters, we find that targets that make this statement in their merger filings are associated with 4.6 percent higher takeover premiums, on average. These findings suggest that acquirers are concerned about the potential future liabilities when targets have engaged in tax sheltering. Consistent with this interpretation, the results also indicate that the positive association between targets' nonsheltering disclosure and acquisition premiums is stronger for less ...

Developing A Holistic Approach For Tackling Undeclared Work: Background Paper, Colin C. Williams

Colin C Williams

The Nominalistic Principle: A Legal Approach To Inflation, Deflation, Devaluation And Revaluation, Alain H. Sheer

Georgia Journal of International & Comparative Law

No abstract provided.

Taxation – Selection Of Exchange Rate For Translation Purposes -- Where Multiple Exchange Rates Exist For A Foreign Currency And The Underlying Transaction Is Financial In Nature, The Proper Rate For Translation Components Of Taxable Income Is The "Free" Market Rate (Durovic V. Commissioner Of Internal Revenue, 7th Cir. 1976), Tim J. Floyd

Georgia Journal of International & Comparative Law

No abstract provided.

Non-Exclusive Dynamic Contracts, Competition, And The Limits Of Insurance, Laurence Ales, Pricila Maziero

Finance Papers

We study how the presence of non-exclusive contracts limits the amount of insurance provided in a decentralized economy. We consider a dynamic Mirrleesian economy in which agents are privately informed about idiosyncratic labor productivity shocks. Agents sign privately observable insurance contracts with multiple firms (i.e., they are non-exclusive). Contracts specify both labor and savings requirements. Firms have no restriction on the contracts they can offer and interact strategically. In equilibrium, contrary to the case with exclusive contracts, a standard Euler equation holds, and the marginal rate of substitution between consumption and leisure is equated to the worker's marginal ...

Excessive State Debt: A New Approach To A Growing Problem, Vincent Buccola

Penn Wharton Public Policy Initiative

Economists and political observers agree state governments defaulting on their debt obligations is a growing concern. How best to aid struggling states, however, is a point of contention. This Issue Brief makes a case against ex post restructuring measures, specifically bankruptcy modeled on Chapter 9 of the U.S. Bankruptcy Code, and in favor of ex ante debt mitigation action. In particular, it introduces tax-credit borrowing (TCB) as a potential commitment device for states that would allow for the creation of super-priority, risk-free debt. TCB ensures that states internalize the risk of default and avoids the moral hazard problem of ...

Insurance Against Extreme Events: Pairing Short-Term Incentives With Long-Term Strategies, Howard Kunreuther

Penn Wharton Public Policy Initiative

Consumers tend to purchase too little insurance or purchase it too late. Consequently, taxpayers wind up bearing substantial burdens for paying reconstruction costs from extreme events. The 2005 and 2012 hurricane seasons alone cost taxpayers nearly $150 billion. There is much that can be done to better facilitate the role that insurance can play in addressing losses from extreme events, both natural and man-made.

En_Final_ Diagnostic Report On Undeclared Work In Greece.Pdf, Colin C. Williams

Colin C Williams

The Contemporary Tax Journal Volume 6, No. 1 – Summer/Fall 2016

The Contemporary Tax Journal

No abstract provided.

Gamers Beware: Level 99 Boss...Taxes!, Fenny Lei

The Contemporary Tax Journal

No abstract provided.

Employer Shared Responsibility Provisions Under The Affordable Care Act, Xuan Hong

The Contemporary Tax Journal

No abstract provided.

When Is A Transfer Of Assets To A Controlled Corporation By Related Parties A Sale Or Contribution Of Capital?, Ophelia Ding

The Contemporary Tax Journal

No abstract provided.

The Contemporary Tax Journal's Interview Of Dr. Susan Martin, Shilpa Balnadu

The Contemporary Tax Journal

No abstract provided.

Starbucks: Social Responsiblity And Tax Avoidance, Katherine Campbell, Duane Helleloid

Management Faculty Publications

This instructional case is designed to explore how accounting choices, and specifically tax minimization practices, should consider a company's overall strategy and positioning within multiple stakeholder groups. Starbucks had been successful in growing its stores and presence in the United Kingdom (UK), and described the profitable growth to investors as something it wanted to build on in other international markets. However, in its 15 years of operations in the UK, the company had paid UK corporate income taxes only once. Using a combination of legal tax avoidance practices (e.g., transfer prices, royalty payments, interest expense), Starbucks UK had ...

Impact Of Assurance Level And Tax Status On The Tendency Of Relatively Small Manufacturers To Manage Production And Earnings, Benjamin P. Foster, John M. Mueller, Trimbak Shastri

Faculty Scholarship

The number and importance of private companies in the United States indicates that reliable quality of financial accounting reports (QFAR) of private companies that are useful for decision making is likely to be important for economic growth. Most previous research examining QFAR addressed earnings management among publicly-traded companies. This study extends prior literature by examining whether abnormal production of public and private companies is impacted by (i) assurance type (PCAOB-audit, GAAS-audit, and SSARS-Review), (ii) tax status (separately taxed versus pass-through entity) of private companies, and (iii) relative size. An audit of financial statements provides a high degree of assurance, whereas ...

Who Will Brave The Third Rail?, Anthony J. Cataldo Ii, Peter F. Oehlers

Peter Oehlers

No abstract provided.

A Review And Critique Of Selected Problem Areas From The Tax Reform Act Of 1976, Neil E. Harl, Michael D. Boehlje

Neil E. Harl

Rarely has agriculture enjoyed the attention it received in the Tax Reform Act of 1976. In addition to various provisions narrowing the scope of tax shelter opportunities, Congressional attention was drawn to the federal estate tax concerns that were believed to be unique to agriculture and other small firms. As a result, legislation was enacted providing two new methods for valuing land, an expanded and more attractive installment option or paying the federal estate tax attributable to a qualifying business, a new rule for taxing post-1976 joint tenancies at death,— an opportunity to continue "Section 303" stock redemptions for the ...

"Use" Valuation Under The 1976 Tax Reform Act: Problems And Implications, Michael D. Boehlje, Neil E. Harl

Neil E. Harl

With the rapid rise in farmland*values during recent years, farmers and farm organizations have argued that land values have little relationship to agricultural productivity. The fact that farmers have been the dominant purchasers in the farm real estate market during this period of time would seem to discredit this argument to some degree, but public officials have been sympathetic to the farmers' arguments. Some state legislatures, particularly in areas o f the country where urban expansion has placed upward pressures on land values, have adopted procedures to value farmland based on its agricultural productivity for purposes of assessing property ...

Rich Have Responsibility To Give Back, Aaron W. Hughey

Aaron W. Hughey

No abstract provided.

The Marriage Tax: A Social And Fiscal Policy Reversal For U.S. Family Taxation, Anthony J. Cataldo Ii, Kevin E. Flynn, John S. Dejoy

Kevin Flynn

No abstract provided.