Corporate Tax-Rate and Tax-Base Avoidance Trends of U.S. Domestic and U.S. Multinational Firms

2019 ◽  
Author(s):  
Terry J. Shevlin ◽  
Niklas Lampenius ◽  
Arthur Stenzel
Keyword(s):  
Multinational Firms ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate

scholarly journals Abuses and Penalties of a Corporate Tax Inversion

2019 ◽  
Vol 7 (1) ◽  
pp. 5
Author(s):  
James Yang ◽  
Leonard Lauricella ◽  
Frank Aquilino
Keyword(s):  
Multinational Corporations ◽  
International Taxation ◽  
Internal Revenue Service ◽  
Tax Law ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Tax Savings ◽  
Treasury Department ◽  
The U.S

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on foreign-sourced income until dividends are repatriated back to the U.S. As a result, it creates tax loopholes. This paper reveals six actual cases of corporate tax inversion. This practice has triggered the Congress to enact §7874, the Internal Revenue Service (IRS) to issue Notices IR 2014-52 and IR 2015-79, and the U.S. Treasury Department to promulgate TD 9761. This paper investigates some details of these penalties. This paper further demonstrates an example in determining the amount of tax savings by engaging in a corporate tax inversion. It also offers many strategies.

scholarly journals The international Challenges and Finnish Corporate Taxation

2014 ◽  
Vol 2014 (2) ◽  
pp. 132-148
Author(s):  
Juha Lindgren
Keyword(s):  
Corporate Taxation ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Cross Border ◽  
Exchange Of Information ◽  
The Cross ◽  
National Tax

Abstract One of the main trends in Finnish corporate taxation during the last ten years has been the lowering of the corporate tax rate. The decision to lower the corporate tax rate to 20% from the beginning of 2014 also changed the approach in reforming the corporate taxation as it was decided to stay on the grounds of a broad tax base and not to make loopholes in it with targeted exceptions. The Finnish corporate taxation contains also some provisions that act as incentives for investment and the establishment of companies. However, the focus has been lately on the rules with purpose to protect the national tax base. Therefore, article handles both the specific anti avoidance rules and the application of the general anti avoidance rule on the cross-border transactions. Some particular challenges and the exchange of information are also taken into account before the conclusion with some ideas and aspects on future reforms.

scholarly journals Comparison of Income Tax Base in Visegrad Countries

2021 ◽  
Vol 16 (2) ◽  
pp. 101-110
Author(s):  
Jana Hinke ◽  
Tomáš Rain ◽  
Barbora Hrabovská
Keyword(s):  
Literature Review ◽  
Income Tax ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
The Disabled ◽  
The Impact ◽  
Visegrád Countries ◽  
Calculation Procedures

Abstract The objective of the research was to compare the procedures for the calculation of income tax in the Visegrad Four (V4) countries. The statutory income tax calculation procedures are very similar in the V4 countries. Particular systems differ parametrically. Based on a literature review, synthesis of knowledge, comparison and simulation calculations, it can be stated that Hungary has the lowest corporate tax rate, and in the simulative calculations it also produced the lowest tax and highest profit after taxation for a fictitious entity in Hungary. Income tax in the V4 countries differs mainly in the possibility of applying the loss of previous years, in the impact of depreciation on the amount of the tax and in the income tax rebate linked to the employment of the disabled.

scholarly journals The Analysis of the Cross-border Corporate Profit’s Taxation

2019 ◽  
Vol 11 (2) ◽  
Author(s):  
Rita Koroseczné Pavlin ◽  
Diána Koponicsné Györke
Keyword(s):  
Special Focus ◽  
Corporate Tax ◽  
Tax Base ◽  
Member States ◽  
Tax Rate ◽  
Direct Taxation ◽  
Cross Border ◽  
The Common ◽  
The Given ◽  
A Company

Ensuring the same competition conditions for the companies in EU requires tax harmonization between Member States. In this paper, we review some elements of the harmonization efforts. We will discuss the OECD guidelines on direct taxation and the transfer price regulation as a way to regulate corporate tax optimization behaviour. Based on the Effective Average Tax Rate we introduce the differences in the taxation of profits between Member States. The Common Consolidated Corporate Tax Base is one of the key elements in the harmonization of cross-border corporate profit taxation, so our study has a special focus on the proposal. The undisputed advantage of the CCCTB would be the simplification of the taxation of transactions between Member States. However, it also raises the question of how it limits the ability of each Member State to attract capital and to what extent can assign the profit tax to the given country in proportion to the operation of a company and with this how to realize that the base of the corporate tax focuses on the place of activity.      

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.

scholarly journals Corporate taxation in Iceland and the international challenge

2014 ◽  
Vol 2014 (2) ◽  
pp. 149-172
Author(s):  
Fjóla Agnarsdóttir ◽  
Rakel Jensdóttir
Keyword(s):  
Tax Avoidance ◽  
Legal Framework ◽  
Corporate Taxation ◽  
Point Of View ◽  
General Description ◽  
Corporate Tax ◽  
Tax Base ◽  
Economic Point ◽  
Tax Rate ◽  
The Past

Abstract This article aims to describe the development in the field of corporate tax law in Iceland, from both legal and economic point of view, with a focus on measures taken to protect the tax base and in order to try to make Iceland an attractive place for investment and establishment companies. First, there will be a brief general description of the development of the corporate tax rate in Iceland since 2004 and an overview of new taxes that have been introduced for companies over the past ten years. Second, there will be an analysis of how the Icelandic legal framework provides for incentives for investment and establishment of companies in Iceland. Third, this discussion is to be followed by a section on the steps Iceland has taken in order to combat tax avoidance. Fourth, there is a general description of the economic development for the corporate taxation in Iceland since 1990 and fifth, there is brief discussion of the development of revenues from the corporate tax. Sixth, a short overview of the real investment in the Icelandic economy is given, and finally, the main conclusions of this article will be summed up with a short discussion on the main challenges Iceland is currently facing in the field of corporate taxation in today’s globalised economy.

scholarly journals TAX HARMONIZATION ASEAN MELALUI ASEAN TAX FORUM -PEMBELAJARAN DARI PROSES TAX HARMONIZATION UNI EROPA-

2015 ◽  
Vol 15 (1) ◽  
pp. 33
Author(s):  
Suska Suska ◽  
Yuventus Effendi
Keyword(s):  
Corporate Tax ◽  
Double Taxation ◽  
Tax Base ◽  
Member States ◽  
Tax Rate ◽  
Tax Harmonization ◽  
Harmonization Process ◽  
The Common ◽  
Asean Countries ◽  
Asean Economic Community

ASEAN Tax Forum was established in the ASEAN Minister of Finance meeting in Bali April 2011. The forum consists of tax authority among ASEAN countries intended for exchange of information on the tax regime and instruments among Member States as well as to work on the issues of avoidance of double taxation and addressing withholding tax to further support the building of a competitive ASEAN Economic Community. The tax harmonization process among member states of ASEAN needs several stages to be taken. Tax Treaty as the step to eliminate the double taxation still not implemented by all ASEAN members. Tax rate particularly corporate tax rate is varying among countries. Learning the lesson from European Union, the direction of tax harmonization is to establish the common tax base while tax rate still differentiate among member states.

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