Tax Planning

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Michael P Donohoe - One of the best experts on this subject based on the ideXlab platform.

  • the shareholder response to corporate Tax Planning advice regulation
    Social Science Research Network, 2021
    Co-Authors: Michael P Donohoe, Brian Gale, Michael A Mayberry
    Abstract:

    We examine the shareholder response to heightened regulation of corporate Tax Planning advice through the covered opinions rules under U.S. Treasury Department Circular No. 230. These rules imposed extensive due diligence obligations and drafting requirements on Tax professionals for a broad range of written Tax advice. Despite overwhelming criticism from Tax professionals, stock returns reveal a positive shareholder response to the promulgation of the rules, equating to a $12.33 billion aggregate increase in shareholder value. Consistent with shareholders believing that the benefits of the rules—deterrence of excessively risky Tax Planning and increased monitoring—would offset the burdens, we find that the shareholder response was more positive for firms with higher Tax risk, weaker monitoring, and higher Tax risk coupled with weaker monitoring. Overall, these findings provide new evidence that shareholders perceive regulations aiming to curtail risky Tax Planning as value enhancing when they target Tax professionals rather than Taxpayers.

  • the shareholder response to corporate Tax Planning advice regulation
    2020
    Co-Authors: Michael P Donohoe, Brian Gale, Michael A Mayberry
    Abstract:

    We examine the shareholder response to heightened regulation of corporate Tax Planning advice through the covered opinions rules under U.S. Treasury Department Circular No. 230. These rules imposed extensive due diligence obligations and drafting requirements on Tax professionals for a broad range of written Tax advice. Despite overwhelming criticism from Tax professionals, stock returns reveal a positive shareholder response to the promulgation of the rules, equating to a $12.33 billion increase in aggregate shareholder value. Consistent with shareholders believing that the benefits of the rules—deterrence of excessively risky Tax Planning and increased monitoring—would offset the burdens, we find that the shareholder response was more positive for firms with higher Tax risk, weaker monitoring, and higher Tax risk coupled with weaker monitoring. Overall, these findings provide new evidence that shareholders perceive regulations aiming to curtail risky Tax Planning differently depending on whether they target Tax professionals or Taxpayers.

  • the geometry of international Tax Planning after the Tax cuts and jobs act a riff on circles squares and triangles
    National Tax Journal, 2019
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for Tax Planning and compliance by U.S. multinational corporations (MNCs). The promised shift...

  • the geometry of international Tax Planning after the Tax cuts and jobs act a riff on circles squares and triangles
    Social Science Research Network, 2019
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for Tax Planning and compliance by U.S. multinational corporations (MNCs). The promised shift to a more territorial system actually results in a greater likelihood that more of a U.S. MNC’s foreign income is subject to current U.S. Taxation. The TCJA complicates effective Tax Planning for such firms, forcing them to reexamine their existing global structures and financial arrangements (i.e., the “geometry” of international Tax Planning). We briefly review international Tax Planning before the TCJA as well as some key international Tax provisions in the TCJA. We then provide a method to estimate the new Global Intangible Low-Taxed Income (GILTI) Tax from a U.S. MNC’s financial statements when such information is not publicly disclosed and illustrate the effective Tax rate (ETR) and GILTI Tax effects for a small sample of public firms after the TCJA. Finally, we discuss some likely changes in international Tax Planning going forward.

  • risky business the prosopography of corporate Tax Planning
    National Tax Journal, 2014
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    We trace the history of corporate Tax Planning from a compliance-focused activity to a profit-enhancing endeavor to a risk management center. Tax directors of U.S. multinational corporations face unprecedented global pressures from Taxing jurisdictions seeking to increase their share of the enterprise’s worldwide Taxes. Increasingly, corporations must consider the risks that a Tax strategy will impose on them, not only in terms of potential lost revenue, but also in terms of reputation and market share. We discuss the components of Tax risk management in today’s global environment and speculate how future corporate Tax Planning will change in light of the Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting project.

Edward L Maydew - One of the best experts on this subject based on the ideXlab platform.

  • is Tax Planning best done in private
    Social Science Research Network, 2020
    Co-Authors: Jeffrey L. Hoopes, Edward L Maydew, Patrick Langetieg, Michele Mullaney
    Abstract:

    We utilize extensive Internal Revenue Service data to investigate the Tax behavior of comparable privately-held and publicly-held corporations. Our findings paint a nuanced picture of private versus public firm Tax Planning. Consistent with prior research, we find that private firms are more willing to engage in Tax strategies that also decrease financial accounting income (conforming Tax Planning). Additionally, we find that private firms are more responsive to shareholder-level dividend Taxes. However, tests reveal that private firms engage in either the same or less of other types of Tax Planning than their public peers. These tests include general measures of nonconforming Tax Planning and aggressive Tax Planning, in addition to specific measures such as Tax haven usage and use of certain credits and deductions. Overall, our findings suggest that private firms have advantages over their public peers for some types of Tax Planning, but are not more active Tax planners otherwise.

  • banks as Tax Planning intermediaries
    Journal of Accounting Research, 2019
    Co-Authors: John Gallemore, Brandon Gipper, Edward L Maydew
    Abstract:

    We provide the first large‐scale empirical evidence of banks functioning as Tax Planning intermediaries. We posit that some banks specialize in assisting corporate clients with Tax Planning. In this role, banks make use of their centrality in financial relationships; access to private information; and ability to structure, execute, and participate in Tax Planning transactions for clients. We measure bank‐client relationships using loan contracts and measure client Tax Planning using either the cash effective Tax rate or the unrecognized Tax benefit balance. Using a difference‐in‐differences design, we find that firms experience meaningful Tax reductions when they begin a relationship with a bank whose existing clients engage in above‐median Tax Planning. The effects of pairing with such Tax intermediary banks are concentrated in relationships with larger or longer maturity loans, clients with foreign income or greater credit risk, and when the bank is an industry specialist or has above‐median investment banking activities. Finally, we find that potential clients are more likely to choose Tax intermediary banks than nonTax intermediary banks, suggesting that Tax intermediary banks benefit by attracting new business. Collectively, our results suggest that some banks act as Tax Planning intermediaries, a role beyond the traditional one of financial intermediary.

  • Tax Planning diffusion real effects and sharing of benefits
    Social Science Research Network, 2018
    Co-Authors: Ling Cen, Edward L Maydew, Liandong Zhang, Luo Zuo
    Abstract:

    We investigate the diffusion of Tax Planning across firms, and the real effects and sharing of benefits from such diffusion. Using supply chain relationships among firms as a possible diffusion channel, we find that Tax Planning spreads from principal customers to their dependent suppliers. We find that Tax Planning diffusion has real effects on product markets and that both parties to the Tax Planning diffusion share in the benefits. As Tax Planning diffuses to suppliers, suppliers share the Tax savings with their customers by reducing the mark-up on their products. Finally, we show that Tax Planning diffusion is more pronounced when the customer and the supplier share a common external auditor and when they are located in the same state, suggesting that these diffusion channels complement one another.

  • banks as Tax Planning intermediaries
    Social Science Research Network, 2016
    Co-Authors: John Gallemore, Brandon Gipper, Edward L Maydew
    Abstract:

    We provide the first large-sample evidence of banks playing an important role in facilitating Tax Planning by client firms. Banks could be associated with client Tax avoidance through two separate mechanisms. First, banks may act as Tax Planning intermediaries by developing and implementing Tax strategies for corporate clients or by spreading Tax strategies across clients. Second, banks may select borrowers in part based on their Tax avoidance. Capturing bank-client relationships using lending contracts, we find that a borrower’s own Tax avoidance is strongly associated with the average Tax avoidance of its bank’s other borrowers. Further tests are consistent with this result being driven in part by banks acting as Tax Planning intermediaries. Finally, we find that borrowers experience meaningful increases in Tax avoidance when they begin a new relationship with a bank whose existing borrowers are substantial Tax avoiders. Overall, our results suggest that banks, in addition to being financial intermediaries, also act as Tax Planning intermediaries in facilitating corporate Tax Planning.

  • the changing role of auditors in corporate Tax Planning
    National Bureau of Economic Research, 2005
    Co-Authors: Edward L Maydew, Douglas A Shackelford
    Abstract:

    This paper examines changes in the role that auditors play in corporate Tax Planning following recent events, including the well-known accounting scandals, passage of the Sarbanes-Oxley Act, and regulatory actions by the SEC and PCAOB. On the whole, these events have increased the sensitivity to and scrutiny of auditor independence. We examine the effects of these events on the market for Tax Planning, in particular the longstanding link between audit and Tax services. While the effects are recent, they are already being seen in the data. Specifically, there has already been a dramatic shift in the market for Tax Planning away from obtaining Tax Planning services from one's auditor. We estimate that the ratio of Tax fees to audit fees paid to the auditors of firms in the S&P 500 decline from approximately one in 2001 to one-fourth in 2004. At the same time, we find no evidence of a general decline in spending for Tax services. In sum, the evidence indicates a decoupling of the longstanding link between audit and Tax services, such that firms are shifting their purchase of Tax services away from their auditor and towards other providers.

Edmund Outslay - One of the best experts on this subject based on the ideXlab platform.

  • the geometry of international Tax Planning after the Tax cuts and jobs act a riff on circles squares and triangles
    National Tax Journal, 2019
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for Tax Planning and compliance by U.S. multinational corporations (MNCs). The promised shift...

  • the geometry of international Tax Planning after the Tax cuts and jobs act a riff on circles squares and triangles
    Social Science Research Network, 2019
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for Tax Planning and compliance by U.S. multinational corporations (MNCs). The promised shift to a more territorial system actually results in a greater likelihood that more of a U.S. MNC’s foreign income is subject to current U.S. Taxation. The TCJA complicates effective Tax Planning for such firms, forcing them to reexamine their existing global structures and financial arrangements (i.e., the “geometry” of international Tax Planning). We briefly review international Tax Planning before the TCJA as well as some key international Tax provisions in the TCJA. We then provide a method to estimate the new Global Intangible Low-Taxed Income (GILTI) Tax from a U.S. MNC’s financial statements when such information is not publicly disclosed and illustrate the effective Tax rate (ETR) and GILTI Tax effects for a small sample of public firms after the TCJA. Finally, we discuss some likely changes in international Tax Planning going forward.

  • risky business the prosopography of corporate Tax Planning
    National Tax Journal, 2014
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    We trace the history of corporate Tax Planning from a compliance-focused activity to a profit-enhancing endeavor to a risk management center. Tax directors of U.S. multinational corporations face unprecedented global pressures from Taxing jurisdictions seeking to increase their share of the enterprise’s worldwide Taxes. Increasingly, corporations must consider the risks that a Tax strategy will impose on them, not only in terms of potential lost revenue, but also in terms of reputation and market share. We discuss the components of Tax risk management in today’s global environment and speculate how future corporate Tax Planning will change in light of the Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting project.

  • risky business the prosopography of corporate Tax Planning
    National Tax Journal, 2014
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    We trace the history of corporate Tax Planning from a compliance-focused activity to a profit-enhancing endeavor to a risk management center. Tax directors of U.S. multinational corporations face u...

Michael A Mayberry - One of the best experts on this subject based on the ideXlab platform.

  • the shareholder response to corporate Tax Planning advice regulation
    Social Science Research Network, 2021
    Co-Authors: Michael P Donohoe, Brian Gale, Michael A Mayberry
    Abstract:

    We examine the shareholder response to heightened regulation of corporate Tax Planning advice through the covered opinions rules under U.S. Treasury Department Circular No. 230. These rules imposed extensive due diligence obligations and drafting requirements on Tax professionals for a broad range of written Tax advice. Despite overwhelming criticism from Tax professionals, stock returns reveal a positive shareholder response to the promulgation of the rules, equating to a $12.33 billion aggregate increase in shareholder value. Consistent with shareholders believing that the benefits of the rules—deterrence of excessively risky Tax Planning and increased monitoring—would offset the burdens, we find that the shareholder response was more positive for firms with higher Tax risk, weaker monitoring, and higher Tax risk coupled with weaker monitoring. Overall, these findings provide new evidence that shareholders perceive regulations aiming to curtail risky Tax Planning as value enhancing when they target Tax professionals rather than Taxpayers.

  • the shareholder response to corporate Tax Planning advice regulation
    2020
    Co-Authors: Michael P Donohoe, Brian Gale, Michael A Mayberry
    Abstract:

    We examine the shareholder response to heightened regulation of corporate Tax Planning advice through the covered opinions rules under U.S. Treasury Department Circular No. 230. These rules imposed extensive due diligence obligations and drafting requirements on Tax professionals for a broad range of written Tax advice. Despite overwhelming criticism from Tax professionals, stock returns reveal a positive shareholder response to the promulgation of the rules, equating to a $12.33 billion increase in aggregate shareholder value. Consistent with shareholders believing that the benefits of the rules—deterrence of excessively risky Tax Planning and increased monitoring—would offset the burdens, we find that the shareholder response was more positive for firms with higher Tax risk, weaker monitoring, and higher Tax risk coupled with weaker monitoring. Overall, these findings provide new evidence that shareholders perceive regulations aiming to curtail risky Tax Planning differently depending on whether they target Tax professionals or Taxpayers.

Gary A Mcgill - One of the best experts on this subject based on the ideXlab platform.

  • the geometry of international Tax Planning after the Tax cuts and jobs act a riff on circles squares and triangles
    National Tax Journal, 2019
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for Tax Planning and compliance by U.S. multinational corporations (MNCs). The promised shift...

  • the geometry of international Tax Planning after the Tax cuts and jobs act a riff on circles squares and triangles
    Social Science Research Network, 2019
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    The enactment of the so-called Tax Cuts and Jobs Act of 2017 (TCJA) significantly changes the landscape for Tax Planning and compliance by U.S. multinational corporations (MNCs). The promised shift to a more territorial system actually results in a greater likelihood that more of a U.S. MNC’s foreign income is subject to current U.S. Taxation. The TCJA complicates effective Tax Planning for such firms, forcing them to reexamine their existing global structures and financial arrangements (i.e., the “geometry” of international Tax Planning). We briefly review international Tax Planning before the TCJA as well as some key international Tax provisions in the TCJA. We then provide a method to estimate the new Global Intangible Low-Taxed Income (GILTI) Tax from a U.S. MNC’s financial statements when such information is not publicly disclosed and illustrate the effective Tax rate (ETR) and GILTI Tax effects for a small sample of public firms after the TCJA. Finally, we discuss some likely changes in international Tax Planning going forward.

  • risky business the prosopography of corporate Tax Planning
    National Tax Journal, 2014
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    We trace the history of corporate Tax Planning from a compliance-focused activity to a profit-enhancing endeavor to a risk management center. Tax directors of U.S. multinational corporations face unprecedented global pressures from Taxing jurisdictions seeking to increase their share of the enterprise’s worldwide Taxes. Increasingly, corporations must consider the risks that a Tax strategy will impose on them, not only in terms of potential lost revenue, but also in terms of reputation and market share. We discuss the components of Tax risk management in today’s global environment and speculate how future corporate Tax Planning will change in light of the Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting project.

  • risky business the prosopography of corporate Tax Planning
    National Tax Journal, 2014
    Co-Authors: Michael P Donohoe, Gary A Mcgill, Edmund Outslay
    Abstract:

    We trace the history of corporate Tax Planning from a compliance-focused activity to a profit-enhancing endeavor to a risk management center. Tax directors of U.S. multinational corporations face u...