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Getting Serious About Corporate Tax Shelters
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Book Synopsis Getting Serious About Corporate Tax Shelters by : George K. Yin
Download or read book Getting Serious About Corporate Tax Shelters written by George K. Yin and published by . This book was released on 2014 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Assuming that the problem of corporate tax shelters is as serious as some claim, this article suggests searching for a solution with the same characteristics as section 469 of the Internal Revenue Code (the passive activity loss limitations) - a broad, reasonably clear, outcomes-oriented rule that is unaffected by taxpayer purpose or intent, or the other elements making up the taxpayer's transaction. One possible solution is enactment of an quot;anti-abusequot; rule which denies a particular tax result if no sensible legislator would have approved of the result at the time the statute was drafted. The uncertainty of such a rule, however, would likely undermine its ability to be an effective deterrent to corporate tax shelters. The other possible solution explored in this article, which deserves further consideration, is to tax public corporations on their income reported for financial accounting purposes, as adjusted by tax rules authorizing specific deviations from that base. This solution should eliminate an entire class of shelter transactions. It may also greatly simplify the law and provide much needed transparency to the process of determining corporate income tax liabilities.
Book Synopsis Corporate Tax Shelters by : United States. Congress. House. Committee on Ways and Means
Download or read book Corporate Tax Shelters written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 2001 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Corporate Tax Shelters by : United States. Congress. Senate. Committee on Finance
Download or read book Corporate Tax Shelters written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2002 with total page 122 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The New Market in Corporate Tax Shelters by : Joseph Bankman
Download or read book The New Market in Corporate Tax Shelters written by Joseph Bankman and published by . This book was released on 2000 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The term ?tax shelter? is ...
Book Synopsis Tax Shelters, a Guide for Investors and Their Advisors by : Robert E. Swanson
Download or read book Tax Shelters, a Guide for Investors and Their Advisors written by Robert E. Swanson and published by Irwin Professional Publishing. This book was released on 1982 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The (Uncertain) Future of Corporate Tax Shelters by : Joshua D. Blank
Download or read book The (Uncertain) Future of Corporate Tax Shelters written by Joshua D. Blank and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Corporations and their shareholders have always sought opportunities to avoid entity- and shareholder-level tax liabilities under the U.S. corporate tax system. In response to the tax shelter boom of the late 1990s, Congress adopted what can be described as an “activity-based” approach to corporate tax enforcement. The reportable transaction disclosure rules target specific corporate activities and transactions that may be abusive. Because corporate tax shelters are often difficult for the IRS to detect, US tax law mandates that taxpayers and their advisors disclose to the IRS instances in which they have participated in transactions that bear tax shelter traits. Every year, thousands of US taxpayers and their advisors mail special disclosure forms that may reveal potentially abusive tax strategies, including “listed transactions” and “transactions of interest,” to the IRS Office of Tax Shelter Analysis.Despite their potential tax enforcement benefits, the reportable transaction disclosure regime faces an uncertain future. Even though taxpayers and advisors must disclose potential tax shelters to the IRS using special forms, it is unclear whether the IRS has the resources necessary to review these disclosures and pursue audits and potential tax controversies. The IRS has also significantly curtailed its designation of tax strategies as listed transactions and transactions of interest. And in 2021, the US Supreme Court held that taxpayers and their advisors may seek pre-enforcement actions against the IRS's notices that designate tax strategies as reportable transactions without violating the Anti-Injunction Act.In this chapter, we introduce a new approach to tax enforcement against corporate tax shelters in the United States. We argue that the reportable transaction rules face significant limitations as the government's primary response to abusive corporate tax shelters today. As we argue, these rules are reactive in that they often apply to emerging tax avoidance schemes rather than as a means of preempting abusive corporate tax planning. In addition, these rules may fail to deliver information that the IRS can use to detect corporate tax abuse, including due to manipulation of the disclosed information by the taxpayer. Finally, the IRS is likely to face litigation hurdles in designating “listed transactions” and “transactions of interest” through preemptive taxpayer challenges under the Administrative Procedure Act. In response, we propose three policy reforms that would mandate preemptive disclosure of broader categories of information related to tax planning from corporate taxpayers, in addition to the specific information that the reportable transaction rules currently target.
Book Synopsis Tax Shelters by : United States. Congress. Senate. Committee on Finance
Download or read book Tax Shelters written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2004 with total page 380 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Problem of Corporate Tax Shelters by :
Download or read book The Problem of Corporate Tax Shelters written by and published by . This book was released on 1999 with total page 165 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Shelter in Business by : William J. Casey
Download or read book Tax Shelter in Business written by William J. Casey and published by . This book was released on 1953 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Corporate Response to Government Attacks on Tax Shelters by : Noel Brock
Download or read book The Corporate Response to Government Attacks on Tax Shelters written by Noel Brock and published by . This book was released on 2017 with total page 17 pages. Available in PDF, EPUB and Kindle. Book excerpt: We examine the effectiveness of four federal government actions, all of which were designed to curb the proliferation of corporate tax shelters dating back to the 1990s, at eliciting measurable changes in characteristics commonly associated with tax shelter firms. Our results suggest that the government's initial attacks on corporate tax shelters in the early 2000s elicited significant declines in book-tax differences, discretionary accruals, and the use of Big N audit firms, which contributed to gradual reductions in the estimated likelihood of tax sheltering for both multinational and purely domestic firms. Conversely, later attempts to discourage corporate tax shelters proved ineffective, likely due in part to the effectiveness of previous government attacks and a faltering economy. This study addresses calls from prior literature for a better understanding of factors determining corporate tax avoidance and offers new evidence of multi-faceted taxpayer reactions to corporate tax reform.
Book Synopsis The How and Why of the New Public Corporation Tax Shelter Compliance Norm by : Susan C. Morse
Download or read book The How and Why of the New Public Corporation Tax Shelter Compliance Norm written by Susan C. Morse and published by . This book was released on 2012 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the recent shift toward a stronger federal income tax compliance norm at public corporations, as evidenced by practitioner and government comments and survey results. The apparent demise of mass-marketed corporate tax shelters presents the clearest example of this new norm. The paper focuses on the organizational behavior of tax decisionmakers within public corporations as they respond to Sarbanes-Oxley, enforcement initiatives, and tax shelter regulation. The paper identifies three elements that have contributed to the development of a stronger tax compliance norm. First, Sarbanes-Oxley has resulted in the expansion and increased transparency of public corporation tax decisionmaking groups. Organizational behavior insights suggest that this should produce more considered decisions. Second, civil and criminal enforcement has resulted in real concerns about personal and firm liability among organization leaders. This causes organization hierarchies to encourage and reward compliance. Third, the government has clearly identified objectionable tax shelter transactions and plainly labeled them unacceptable and even fraudulent. In the tax shelter area, this substantially reduces the ethical or legal uncertainty that otherwise presents an obstacle to the development of compliance norms in organizations. The paper identifies elements of this story that do not fit neatly under the classic economic analysis of tax avoidance or evasion, including the importance of enforcement outside the tax context and the particular power of clear government rules. The conclusion also discusses what the government might do, in light of the organizational behavior influences identified by the paper, to preserve and expand the new public corporation tax compliance norm.
Book Synopsis Running for Shelter by : Richard Meyer
Download or read book Running for Shelter written by Richard Meyer and published by . This book was released on 1985 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Shelters and Corporate Debt Policy by : John R. Graham
Download or read book Tax Shelters and Corporate Debt Policy written by John R. Graham and published by . This book was released on 2005 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: We use a novel sample of 44 tax shelter cases involving public corporations to investigate which types of firms shelter, the magnitude of the tax shelters they use, and whether participating in a shelter affects corporate debt policy. The propensity to shelter increases with firm size, profitability, Ramp;D expenditures, foreign operations, and the market to book ratio. The average deduction produced by the shelters in our sample is very large, equaling approximately nine percent of asset value. This is about three times as large as interest deductions for comparable firms.Our results suggest that corporations substitute away from debt when using tax shelters. Seven years before they engage in sheltering activity, shelter firms have mean debt ratios of about 25 percent, roughly equivalent to matched firm debt ratios. By the year of the sheltering activity, shelter firm debt ratios have fallen to approximately 18 percent while matched firm debt ratios have not fallen. These results help explain why some firms appear to be under-levered when tax-sheltering activity is ignored, and also why corporate tax payments have fallen so precipitously in recent years.
Book Synopsis The Problem of Corporate Tax Shelters by : Department Of The Treasury
Download or read book The Problem of Corporate Tax Shelters written by Department Of The Treasury and published by . This book was released on 2013-06-25 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The proliferation of corporate tax shelters presents an unacceptable and growing level of tax avoidance behavior. Over the past several years, Congress and the Administration repeatedly have provided targeted responses to specific shelters as they have come to light. The Administration believes that a generic solution to curb the growth of corporate tax shelters must be fashioned, as opposed to the current after-the-fact, ad hoc approach. This, admittedly, is not an easy task. Unlike the individual tax shelters of the 1970s and 1980s, corporate tax shelters may take several forms and do not rely on any single Code section or regulation. For this reason, they are hard to define. Nonetheless, the Administration in its Fiscal Year 2000 Budget proposed several generic remedies, focused on certain identified common characteristics, to curb the growth of corporate tax shelters. As Deputy Secretary Lawrence Summers recently stated, the Administration's proposals are intended ...
Book Synopsis Corporate Tax Shelters by : Yoram Keinan
Download or read book Corporate Tax Shelters written by Yoram Keinan and published by . This book was released on 2002 with total page 142 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Corporate Tax Shelters and the IRS Large and Mid-Sized Business Division by : Federal Bar Association
Download or read book Corporate Tax Shelters and the IRS Large and Mid-Sized Business Division written by Federal Bar Association and published by . This book was released on 1982-12-01 with total page 23 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis An Examination of Corporate Tax Shelter Participants by : Ryan J. Wilson
Download or read book An Examination of Corporate Tax Shelter Participants written by Ryan J. Wilson and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Recent evidence suggests that corporate tax shelters have become important corporate instruments for reducing tax burden. Based on a sample of identified tax shelter participants, I develop a profile of the type of firm that likely engages in tax sheltering. The model detects tax shelter participants through the use of variables predicted to be either affected by or associated with tax sheltering. I find that firms actively engaged in tax sheltering exhibit larger ex post book-tax differences and more aggressive financial reporting practices. Using this model of tax shelter firm characteristics, I identify a broad sample of predicted tax shelter firms from the population of firms. I then examine whether tax sheltering is associated with wealth creation for shareholders or with managerial opportunism. I find that active tax shelter firms with strong corporate governance exhibit positive abnormal returns. This finding is consistent with tax sheltering being a tool for wealth creation in well-governed firms.
