Taxation Commons^™

How To Reduce The Tax Bill Of A Multinational Technology Company?, Dimitrios V. Siskos

Dimitrios V. Siskos

It is said that nothing in this world is certain except for death and taxes. For those with clever accountants, however, the latter can be kept to a minimum. Particularly, companies seek to minimize their tax liability through "tax planning", adopting deductions, rebates, exemptions and other “legal” tools that the domestic tax system provides to them. However, while tax planning is considered to be quite logical in the terms of making profit, there is a grey area between this and "tax avoidance”. This paper suggests a legitimate tax plan for a multinational technology company that minimizes its tax obligations1, without …

Post-Jgtrra Dividend Planning, Danny A. Pannese, Paul N. Iannone

Danny Pannese

The JGTRRA reduced the tax rate on dividends for individuals and lowered the accumulated earnings and personal holding company taxes for corporations until 2008. This article reviews some of the planning techniques corporations and shareholders can use to take advantage of the temporarily lower rates. One of the key provisions of the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA), if not the prime emphasis of the legislation, is Section 302's reduction in the individual tax rate on corporate dividends received to 15% (5% for individuals in the 15% and 10% brackets). In an emerging trend, the lower …

Liberating Trapped Cash: A Case Study Of Trapped Cash At Apple And Microsoft, Russell P. Engel, Bridget M. Lyons, Danny A. Pannese

Danny Pannese

The topic of trapped cash, or cash permanently reinvested overseas to avoid tax upon repatriation, has become a hot topic in accounting, finance and policy circles over the past two years. This case study analyzes the activities of two major technology firms, Microsoft and Apple, to liberate enormous holdings of trapped cash. The case prompts a discussion of the topic of trapped cash, stakeholder considerations and tools available to manage cash balances held outside the United States. The focus is to examine the strategies available and those selected by Microsoft and Apple to meet or at least appease stakeholder demands …

Agency Activism As A New Way Of Life: Administrative Modification Of The Internal Revenue Code Through Limited Issue Focused Examinations, W Edward Afield

W. Edward "Ted" Afield

In the name of increasing efficiency and better utilizing limited resources, the IRS has begun to adopt audit policies that overly favor taxpayers and greatly hinder the IRS’s ability to perform thorough audits. Highlighting this trend is a relatively new audit technique used by the Large to Mid-Size Business Division (LMSB), known as the Limited Issue Focused Examination (LIFE) Process. Under LIFE, the LMSB has attempted to involve taxpayers in the audit process by sharing responsibility for timely completion of the audit and has attempted to streamline the audit by reducing the scope of issues examined and applying materiality thresholds …

A Study On R&D Tax Incentives: Final Report, Bas Straathof, Elina Gaillard Ladinska, Henk Lm Kox, Remco Mocking

Henk LM Kox

The Effect Of Taxes On Multinational Debt Location, Matteo Arena, Andrew Roper

Matteo P. Arena

We provide new evidence that differences in international tax rates and tax regimes affect multinational firms' debt location decisions. Our sample contains 8287 debt issues from 2437 firms headquartered in 23 different countries with debt-issuing subsidiaries in 59 countries. We analyze firms' marginal decisions of where to issue debt to investigate the influence of a comprehensive set of tax-related effects, including differences in personal and corporate tax rates, tax credit and exemption systems, and bi-lateral cross-country withholding taxes on interest and dividend payments. Our results show that differences in personal and corporate tax rates, the presence of dividend imputation or …