CHAPTER 19

1. CHAPTER 19 THE CORPORATION TAX

2. I’ll probably kick myself for having said this, but when are we going to have the courage to point out that in our tax structure, the corporation tax is very hard to justify? President Ronald W. Reagan

3. Corporations • Corporation – A state-chartered form of business organization, usually with limited liability for shareholders (owners) and an independent legal status • Limited liability • Corporations are “artificial legal persons”

4. Why Tax Corporations? • Only real people can pay a tax • Justifications • Corporations are distinct entities • Corporations receive special privileges from society • Protects integrity of personal income tax

5. Structure Revenue - Expenses incurred earning revenues Taxable Income * Tax rate (15% - 35%) Tax - Credits Total Tax Alternative Minimum Tax Treatment of Losses

6. Treatment of Dividends versus Retained Earnings • Double taxation

7. Effective Tax Rate on Corporate Capital • Statutory rate versus effective rate • Interest deductibility • Depreciation allowances • Inflation • Double taxation • Gravelle [2004] • Effective corporate rate = 32%; noncorporate rate = 18% • Sensitivity of estimate

8. Incidence and Excess Burden • A tax on corporate capital • Incidence in a general equilibrium model • Excess burden on a general equilibrium model • A tax on economic profits • Incidence and excess burden of a tax on economic profits • Actual corporate profits versus economic profits • Stiglitz [1973] model

9. Effects on Behavior – Total Physical Investment • Accelerator Model • Neoclassical Model • Cash Flow Model

10. Effects on Behavior-Type of Asset • Tax system encourages purchase of assets that receive relatively generous depreciation allowances

11. Effects on Behavior-Corporate Finance • Why do firms pay dividends? • Dividends as a signal of firm’s financial strength • Clientele effect • Effect of taxes on dividend policy • Empirical evidence – Chetty and Saez [2004] • Effect on savings • Debt versus Equity Finance • Did the tax system cause the corporate accounting scandals?

12. State Corporation Taxes • State taxes have similar incidence and efficiency problems as federal taxes • Variation of tax rates across state lines

13. Taxation of Multinational Corporations • Structure • U. S. corporations pay tax at standard rate on global taxable income • Credit for foreign taxes paid • Subsidiary status • Deferral of taxes on income from foreign enterprise • Repatriation • Income allocation • Arm’s length system • Transfer-pricing problem

14. Evaluation of Tax Treatment of Multinational Firms • Maximization of world income • Maximization of national income

15. Corporation Tax Reform • Full Integration (Partnership Method) • Issues • Nature of the corporation • Administrative feasibility • Effects on efficiency • Effects on saving • Effect on distribution of income

16. Dividend Relief • Allow corporation to deduct dividends • Exclude dividends from individual taxation • 2003 legislation – 15% maximal tax rate on dividends

17. Allowable Expenses • Employee Compensation • except compensation in excess of $1,000,000 • Options do not have to be included • Cost of Material Inputs • Taxes including employer contributions to Social Security • Repairs and advertising • Interest but not dividends • Depreciation • No investment tax credit

18. Depreciation • What is depreciation? • Tax life of an asset • 3, 5, 7, 10, 15, 20, 27.5, and 39 years • Most 5 years

19. Calculating the Value of Depreciation Allowances – Straight-Line Depreciation, 10 year tax life

20. Calculating the Value of Depreciation Allowances – Straight-Line Depreciation, 5 year tax life

21. Calculating the Value of Depreciation Allowances – Double Declining Balance Depreciation, 10 year tax life

22. General Analysis of Depreciation Tax Savings T = tax life D(n) = proportion of asset that can be written off against taxable income in nth year θ = corporate tax rate Present value of tax savings: ψ = θ * D(1) + θ * D(2) + … + θ * D(T) 1 + r (1 + r)2 (1 + r)T

23. More on Depreciation • Accelerated depreciation • Expensing • Intangible Assets

24. Investment Tax Credit k = investment tax credit q = acquisition price of asset (1 – k)q = effective price of asset

25. Stiglitz Model G = before-tax value of output produced by machine r = interest rate Firm buys machine if: G – r > 0 Assume corporate tax (1) net income taxed at rate θ (2) net income = G – r (1 – θ)(G – r) > 0

26. Neoclassical Model User cost of capital = (r + δ) After tax rate of return = (1 – θ) * (1 – t) (1 – θ) * (1 – t) * C = (r + δ) C = (r + δ) (1 – θ) * (1 – t) C = (r + δ) * (1 – ψ –k) (1 – θ) * (1 – t)

27. Effect of User Cost on Investment • Econometric problems • Role of expectations • Elasticity of supply curve of capital goods • Open economy problems

28. Cash Flow Model • What is cash flow? • Irrelevancy of cash flow in neoclassical model • Cost of internal versus external funds • Empirical results

29. Maximization of World Income rf = rUS (1 – tf)rf = (1 – tUS)rUS Full credit versus limited credit

30. Maximization of National Income this one (1 – tf)rf = rUS rf = rUS/(1 – tf) if tf < 1, then rUS < rUS/(1 – tf) Deduction of foreign tax payments from domestic income: rf(1 – tf)(1 – tUS) = rUS(1 – tUS) Note: this equation equivalent to …

31. Effects on Efficiency of Full Integration • Misallocation of resources between corporate and noncorporate sectors eliminated • Tax-induced distortions in savings decisions reduced • Remove incentive for “excessive” retained earnings • Reduce bias toward debt financing