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1、1,Chapter 17 The Corporation Tax,Public Economics,2,Introduction,A corporation is a form of business organization in which ownership is usually represented by transferable stock certificates Stockholders have limited liability Corporations are independent legal entities Can make contracts, hold prop
2、erty, incur debt, sue, and be sued,3,Why Tax Corporations?,Only real people can pay a tax, so why not just tax incomes of corporation owners via the personal income tax? Justification #1: Corporations are distinct entities, and ownership and control are separated Justification #2: Corporations recei
3、ve a number of special privileges, such as limited liability. Corporation tax simply a user fee. Justification #3: Corporation tax protects the integrity of the personal income tax. Cannot simply accumulate income within the corporation to defer tax payments.,4,Structure,Tax system can safely be pre
4、sented as a flat rate of 35% Statutory rate gives relatively little information about the effective burden, because we must know what deductions are allowed,5,Structure: Deductions,Employee compensation Interest payments, not dividends Depreciation No Investment Tax Credit Treatment of Dividends ver
5、sus Retained Earnings,6,Structure,Employee compensation Wages and benefits are excluded from taxable income,7,Structure,Interest payments, not dividends When corporations borrow, interest payments to lenders are excluded from taxable income. When corporations finance activities by issuing stock, div
6、idends are not deductible.,8,Structure,How should durable goods be treated in determining taxable income? Buying a drill press (that lasts for 10 years) is initially just an exchange of assets, not an economic cost. As it is used, it is subject to wear and tear, which decreases its value. This decre
7、ase in value, called economic depreciation, is an economic cost to the firm.,9,Structure,Each years worth of depreciation should be deductible from that years gross income. Difficult to measure true depreciation, or even the useful life of durable goods. Instead, the tax law specifies a tax life: Fo
8、r each asset, what proportion of its acquisition value can be depreciated each year, and over how many years.,10,Structure,To calculate the value of the depreciation allowances in the tax code, compute the present value of the stream of depreciation allowances. Generally, the present value of these
9、allowances for a $1 asset would be:,11,Structure,Thus, the presence of depreciation allowances lowers the effective price of acquiring durable assets from $q to $(1-)q. Tax savings depends on value of T and the function D(n). Tax benefits are more valuable the lower T is, and the more front-loaded D
10、(n) is.,12,Structure,Accelerated depreciation is a scheme to write off assets faster than true economic depreciation. Expensing allows a firm to deduct from current taxable income the assets full cost at the time of acquisition.,13,Structure,Under current law, T varies from 3 to 39 years. Racehorses
11、 are depreciated over 3 years Computers are depreciated over 5 years Nonresidential structures are depreciated over 31.5 years Generally tax lives are shorter than actual useful lives.,14,Structure,Intangible assets some spending, such as an advertising campaign, may increase sales over a number of
12、years. Computing appropriate depreciation is difficult.,15,Structure,No Investment Tax Credit (ITC) Prior to 1986, ITC permitted a firm to subtract some portion of the purchase price of an asset from its tax liability at the time the asset was acquired. ITC did not depend on corporate tax rate (in c
13、ontrast to depreciation allowances) Subtracted directly from tax liability, not taxable income,16,Structure,Discussion so far has focused on taxed directly paid by corporation. Another issue is the total tax rate on income generated by corporations. Corporate profits may either be retained by the fi
14、rm (retained earnings) or paid to stockholders (dividends) Dividends not deductible expense from corporations viewpoint, and taxed in the personal income tax code too.,17,Structure,Recent legislation has moved toward eliminating this double taxation of dividends. Maximum tax rate on dividends receiv
15、ed is now 15% at the individual level.,18,Structure,Retained earnings increase the value of the corporation, and this increase should be valued into the stock price. These increased capital gains are not taxed until those gains are realized. Thus, tax system creates incentives for firms to retain ea
16、rnings rather than pay them out in dividends.,19,Incidence and Excess Burden,Economic consequences of the corporation tax are very controversial. Not a consensus on just what kind of tax it is. Tax on Corporate Capital Tax on Economic Profits,20,Incidence and Excess Burden:Tax on Corporate Capital,F
17、irm is not allowed to deduct from taxable income the opportunity cost of capital supplied to shareholders. Therefore, the corporation tax is a partial factor tax. Tax leads to migration of capital from the corporate sector until the after-tax rates of return are equalized.,21,Incidence and Excess Bu
18、rden:Tax on Corporate Capital,As capital moves to the non-corporate sector, the rate of return on capital to all owners of capital is depressed. Reallocation also affects return to labor. Ultimate incidence depends on production technology and structure of consumers demands.,22,Incidence and Excess
19、Burden:Tax on Economic Profits,Alternative view is that corporation tax is tax on economic profits. Tax base = gross corporate income costs Incidence of profits tax is straightforward, no shifting of tax. Tax is borne by owners of firm, no misallocation of resources.,23,Incidence and Excess Burden:T
20、ax on Economic Profits,Problems: Base of pure profits tax is computed by subtracting from gross earnings the value of all inputs including the opportunity cost of the inputs supplied by the owners. Not the case here. Under certain circumstances, corporation tax is equivalent to profits tax (when cor
21、poration can deduct interest payments to creditors).,24,Effects on Behavior,Total Physical Investment Types of Asset Corporate Finance,25,Effects on Behavior:Total Physical Investment,Total Physical Investment Do features like accelerated depreciation and the investment tax credit stimulate investme
22、nt demand? Will discuss three types of models: Accelerator model Neoclassical model Cash flow model,26,Effects on Behavior:Total Physical Investment,Accelerator model Main determinant of the amount of investment is changes in the level of output demanded. Depreciation allowances and investment tax c
23、redits basically irrelevant,27,Effects on Behavior:Total Physical Investment,Neoclassical model Key variable is user cost of capital the cost the firm incurs as a consequence of owning an asset. Includes direct costs like depreciation and taxes Includes opportunity costs of forgoing other investment
24、s,28,Effects on Behavior:Total Physical Investment,An investment will only be undertaken if its return exceeds the user cost of capital. Define: r = return in capital market = depreciation = corporate tax rate t = personal tax rate,29,Effects on Behavior:Total Physical Investment,The user cost of ca
25、pital is then defined as:,Thus, a company would only undertake a project if the return where greater than C.,30,Effects on Behavior:Total Physical Investment,Previous equation did not account for depreciation allowances () or investment tax credits (k). User cost of capital becomes:,By taxing corpor
26、ate income, tax make capital investment more expensive, but depreciation allowances and ITCs lower the user cost.,31,Effects on Behavior:Total Physical Investment,How do user costs affect investment? If the neoclassical model is correct, investment does respond to depreciation allowances and ITCs. E
27、conometrically, role of policy expectations in the investment process is critical. Current investment depends on future values of the user cost of capital. Elasticity around 0.4 seems reasonable.,32,Effects on Behavior:Total Physical Investment,Cash Flow Model Cash flow is the difference between rev
28、enues and expenditures for inputs The more money on hand, the greater the capacity for investment In neoclassical model, internal funds and borrowed money had the same opportunity cost. In cash flow model, cost of internal funds is lower than external funds. For example, lenders may view a project a
29、s being more uncertain than the management.,33,Effects on Behavior:Types of Asset,Tax system encourages the purchase of certain types of assets, for example those with generous depreciation allowances. Table 17.1 shows that the Tax Reform Act of 1986 reduced the gap between tax rates on equipment an
30、d structures.,Table 17.1,35,Effects on Behavior:Corporate Finance,Owners must decide how to finance a firms operations, and whether to distribute or retain profits.,36,Effects on Behavior:Corporate Finance,Why do firms pay dividends? If outcomes of all investments are known in advance and there are
31、no taxes, then the owners of a firm are indifferent between a dollar of dividends or retained earnings. In reality, tax system is not neutral dividends are more highly taxed. Surprisingly, in a typical year, almost 79% of after-tax corporate profits are paid out as dividends.,37,Effects on Behavior:
32、Corporate Finance,Several explanations: Signal of firms financial strength Marginal tax rates of investors vary some firms “specialize” in attracting low marginal tax rate investors, known as the clientele effect.,38,Effects on Behavior:Corporate Finance,Several econometric studies have found that w
33、hen the opportunity cost of retained earnings decreases, dividend payments go down. Thus, tax system increases amount of retained earnings.,39,Effects on Behavior:Corporate Finance,In raising money, firm can either borrow money and pay interest (issue debt) or it can issues shares of stock and pay d
34、ividends (issue equity). U.S. tax system allows deductibility of interest payments, but not dividend payments. Thus, built in bias toward debt financing.,40,Effects on Behavior:Corporate Finance,In one econometric study, Gordon and Lee (2001) find that lowering the corporate rate by 10 percentage po
35、ints lowers the percentage of the firms assets financed by debt by 4 percent.,41,Effects on Behavior:Corporate Finance,Recent corporate scandals Number of firms, most notably Enron, used deceptive and fraudulent practices to inflate earnings and increase stock value. Is the tax system to blame? Dividend payments send a strong signal about the profitabilit
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