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1
Tarrant, Greg. "The distinction between tax evasion, tax avoidance and tax planning." Thesis, Rhodes University, 2008. http://hdl.handle.net/10962/d1004549.
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Tax avoidance has been the subject of intense scrutiny lately by both the South African Revenue Service ("the SARS") and the media. This attention stems largely from the recent withdrawal of section 103(1) together with the introduction of section 80A to 80L of the South African Income Tax Act. However, this attention is not limited to South Africa. Revenue authorities worldwide have focused on the task of challenging tax avoidance. The approach of the SARS to tackling tax avoidance has been multi-faceted. In the Discussion Paper on Tax Avoidance and Section 103 (1) of the South African Income Tax Act they begin with a review of the distinction between tax evasion, tax avoidance and tax planning. Following a call for comment the SARS issued an Interim Response followed by the Revised Proposals which culminated in the withdrawal of the longstanding general anti-avoidance rules housed in section 103(1) and the introduction of new and more comprehensive anti-avoidance rules. In addition, the SARS has adopted an ongoing media campaign stressing the importance of paying tax in a country with a large development agenda like that of South Africa, the need for taxpayers to adopt a responsible attitude to the management of tax and the inclusion of responsible tax management as the greatest measure of a taxpayer's corporate and social investment. In tandem with this message the SARS have sought to vilify those taxpayers who engage in tax avoidance. The message is clear: tax avoidance carries reputational risks; those who engage in tax avoidance are unpatriotic or immoral and their actions simply result in an unfair shifting of the tax burden. The SARS is not alone in the above approach. Around the world tax authorities have been echoing the same message. The message appears to be working. Accounting firms speak of a "creeping conservatism" that has pervaded company boardrooms. What is not clear, however, is whether taxpayers, in becoming more conservative, are simply more fully aware of tax risks and are making informed decisions or whether they are simply responding to external events, such as the worldwide focus by revenue authorities and the media on tax avoidance. Whatever the reason, it is now critical, particularly in the case of corporate taxpayers, that their policies for tax and its attendant risks need to be as sophisticated, coherent and transparent as its policies in all other areas involving multiple stakeholders, such as suppliers, customers, staff and investors. How does a company begin to set its tax philosophy and strategic direction or to determine its appetite for risk? A starting point, it is submitted would be a review of the distinction between tax evasion, avoidance and planning with a heightened sensitivity to the unfamiliar ethical, moral and social risks. The goal of this thesis was to clearly define the distinction between tax evasion, tax avoidance and tax planning from a legal interpretive, ethical and historical perspective in order to develop a rudimentary framework for the responsible management of strategic tax decisions, in the light of the new South African general anti-avoidance legislation. The research methodology entails a qualitative research orientation consisting of a critical conceptual analysis of tax evasion and tax avoidance, with a view to establishing a basic framework to be used by taxpayers to make informed decisions on tax matters. The analysis of the distinction in this work culminated in a diagrammatic representation of the distinction between tax evasion, tax avoidance and tax planning emphasising the different types of tax avoidance from least aggressive to the most abusive and from the least objectionable to most objectionable. It is anticipated that a visual representation of the distinction, however flawed, would result in a far more pragmatic tool to taxpayers than a lengthy document. From a glance taxpayers can determine the following: That tax avoidance is legal; that different forms of tax avoidance exist, some forms being more aggressive than others; that aggressive forms of tax avoidance carry reputational risks; and that in certain circumstances aggressive tax avoidance schemes may border on tax evasion. This, it is envisaged, may prompt taxpayers to ask the right questions when faced with an external or in-house tax avoidance arrangement rather than simply blindly accepting or rejecting the arrangement.
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Amberger, Harald, Eva Eberhartinger, and Helmut Kasper. "Tax-Rate Biases in Tax-Planning Decisions: Experimental Evidence." WU Vienna University of Economics and Business, Universität Wien, 2016. http://epub.wu.ac.at/4897/1/SSRN%2Did2727680.pdf.
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Recent empirical findings suggest that firms might not always engage in economically optimal tax planning. We conduct a series of four laboratory experiments with 223 students and 62 tax professionals to examine whether decision biases offer a behavioral explanation for tax outcomes. We find that individuals overestimate the importance of tax rates relative to the tax base when facing time pressure in tax-planning decisions. This systematic decision bias results in suboptimal choices. In line with the theory of rational inattention, we observe that increasing tax-burden differences between two tax-planning strategies weakly mitigate the decision bias. However, tax-planning behavior is unaffected by the level of experience: students and highly experienced tax professionals are similarly prone to biased decision-making. Overall, our findings suggest that overestimating the implications of salient tax-rate information can cause decision biases and contribute to heterogeneity in tax outcomes.Series: WU International Taxation Research Paper Series
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Zetler, Hila. "International tax planning and anti-tax avoidance provisions - Hila Zetler." Bachelor's thesis, University of Cape Town, 2013. http://hdl.handle.net/11427/4579.
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Includes bibliographical references.'The avoidance of tax may be lawful, but it is not yet a virtue' – Lord Denning¹. The famous English judge, Lord Denning, explained that the avoidance of tax may be legal, but it is not necessarily ethical. By said words, Justice Denning implied that, when a taxpayer avoids paying taxes through legal tax planning, he may, despite the ostensible legality thereof, nevertheless harm society. Assuming that such action does, indeed, involve an immoral act, should the legislature intervene?
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Fatouros, Dimitrios Michael. "Mathematical modelling for international tax planning." Thesis, Imperial College London, 1998. http://hdl.handle.net/10044/1/7954.
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Myhrberg, André, and Johannes Harnesk. "SUSTAINABLE TAX PLANNING : Investigating the relationship between ESG and tax aggressiveness." Thesis, Umeå universitet, Företagsekonomi, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:umu:diva-160509.
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The footprint firms leave behind on this planet is widely discussed, and the topic of corporate social responsibility is constantly receiving additional attention. The gravity of working towards a more sustainable way of conducting business is illustrated by the incentivized tax system in various countries, where CSR can render tax deductions. It is widely debated if CSR and tax aggressiveness can live in symbiosis, and what relationship the two areas have. However, the literature investigating thisrelationship is scarce, which has left a research gap for the authors of this study to fill.This study does through a quantitative method investigate the relationship between CSR and tax aggressiveness of 3899 firms from 68 different countries, measuredat the end of 2018. By equivalating the level of social responsibility of a firm with the widely accepted ESG-score and the level of tax aggressiveness of a firm with the ETR-index created by the authors, the statistical testing of the relationship was enabled. Further, the control variables country, industry, leverage, beta, and size were included to account for variance in tax aggressiveness which is not captured by the ESG-score.To guide the authors through the establishment of hypothesis and statistical testing,a theoretical framework was established, concluding theories speaking for the implementation of tax aggressiveness, against it, and theories which reconciles the two contradicting views. The data was thereafter processed to investigate which statistical model to utilize. The robust OLS was found to be the best suited model, which was used to test the relationship between the aggregated ESG-score, as well as its components, relationship to the ETR-index.The statistical results in this study did not exhibit a significant relationship between the aggregated ESG-score, nor for the two components S and G, and the ETR-index. There is however a significant positive relationship between the E-score and the ETR-index, showing that environmentally friendly firms are less tax aggressive in general. This relationship could be explained by the stakeholder theory, which indicates that a firm's objective should be to maximize the value creation for all its stakeholders, as well as by the legitimacy theory, stating that firms seek to conduct proper business within socially constructed norms. Furthermore, the results show that tax aggressiveness depends on the country of headcounter, the industry, and the beta of a firm.
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Kamasa, R. E. "Tax system reform in Rwanda." Thesis, Stellenbosch : Stellenbosch University, 2002. http://hdl.handle.net/10019.1/53079.
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Thesis (MPA)--Stellenbosch University, 2002.ENGLISH ABSTRACT: The implementation of policy reforms in developing countries continues to be negatively influenced by factors such as difficulties with resource mobilization, the dominance of technocratic policy management advocated by donors, and the persistence of state centralism. Tax system reforms in Rwanda constitute institutional and policy reforms aimed at improving tax compliance and ultimately the contribution of tax revenue to the national GDP. But, because of implementation flaws, including among others the scant flow of technical and financial resources; the dominance of a narrow technocratic approach in implementation; and indeed the failure of the implementers to mobilize political resources and constituent support, the realization of the above objective became a less attainable goal. This research examines the institutional and policy reforms in the tax system and the dynamics of their implementation, through the manipulation of secondary, numerical and textual information/ data on tax system administration in Rwanda. Chapter one of the research deals with the development of the idea to research tax system reform and the formulation of the research problem, hypothesis and methodology. In addition to that, chapter one provides an overview of the tax system reform in Rwanda, a comparative insight into the implementation of reform policies in developing countries, and contemporary experiences in tax system reforms. Chapters two and three, which are formative chapters, focus respectively on the background situations that either influenced or affected tax system reform in Rwanda, and the normative requirements for tax systems. Chapter four evaluates the implementation of reform and how it concurs with problem situations and normatives. Chapter five is summative in that it provides an interpretation and recommendations, as well as a summary of the research findings.
AFRIKAANSE OPSOMMING: Die implementering van beleidshervorming in ontwikkelende lande word negatief beïnvloed deur faktore soos probleme met die mobilisering van hulpbronne, die oorheersing van die tipe tegnokratiese beleidsbestuur wat deur donateurs voorgestaan word, en 'n voortgesette sentralistiese staatsbestel. Belastinghervorming in Rwanda omsluit institusionele en beleidshervorming met die oog op verbeterde belastingbetaling, wat tot 'n uiteindelike verbetering in die bydrae van belastinginkomste tot die BNP moet lei. Teenspoed tydens die implementering van die hervormingspoging, onder meer as gevolg van 'n gebrek aan tegniese en finansiële hulpbronne, die bekrompenheid van die tegnokratiese benadering waardeur die implementeringspoging oorheers is, en inderdaad die feit dat die implementeerders nie die nodige politieke middele of die publiek se ondersteuning kon mobiliseer nie, het egter veroorsaak dat hierdie doelwitte moeilik bereikbaar geraak het. Hierdie navorsing stel ondersoek in na institusionele en beleidshervorming ten opsigte van die belastingstelsel, en kyk ook na die implementeringsdinamiek daarvan. Die ondersoek is gegrond op 'n ontleding van sekondêre numeriese en tekstuele inligting/data oor die administrasie van die belastingstelsel in Rwanda. Hoofstuk een dui aan hoe die gedagte ontstaan het om navorsing oor die hervorming van die belastingstelsel in Rwanda te doen, en stel die navorsingsprobleem, die -hipotese en -metodologie bekend. Hierbenewens bied hoofstuk een 'n oorsig oor die hervorming van die belastingstelsel in Rwanda, en vergelykende insigte in die implementering van hervormingsbeleid in ontwikkelende lande asook onlangse ervaring wat die hervorming van belastingstelsels betref. Hoofstuk twee en drie is formatief van aard. Hulle fokus onderskeidelik op die agtergrondomstandighede wat 'n invloed op belastinghervorming in Rwanda gehad het, en op die normatiewe vereistes wat aan belastingsisteme gestel word. Hoofstuk vier evalueer die implementering van hervorming en hoe dit met probleemsituasies en hervormingsnorme verband hou. Hoofstuk vyf is summatief van aard en bevat 'n vertolking en aanbevelings, sowel as 'n samevatting van die navorsingsbevindinge.
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Schwäbe, Alexander Norbert [Verfasser]. "Essays on corporate tax planning / Alexander Norbert Schwäbe." Hannover : Gottfried Wilhelm Leibniz Universität Hannover, 2018. http://d-nb.info/1176105140/34.
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Evers, Lisa Verfasser], and Christoph [Akademischer Betreuer] [Spengel. "Intellectual Property (IP) Box Regimes : Tax Planning, Effective Tax Burdens, and Tax Policy Options / Lisa Evers. Betreuer: Christoph Spengel." Mannheim : Universitätsbibliothek Mannheim, 2015. http://d-nb.info/1068460903/34.
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Evers, Lisa [Verfasser], and Christoph [Akademischer Betreuer] Spengel. "Intellectual Property (IP) Box Regimes : Tax Planning, Effective Tax Burdens, and Tax Policy Options / Lisa Evers. Betreuer: Christoph Spengel." Mannheim : Universitätsbibliothek Mannheim, 2015. http://d-nb.info/1068460903/34.
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Abdul, Wahab Nor Shaipah. "Tax planning and corporate governance : effects on shareholders' valuation." Thesis, University of Southampton, 2010. https://eprints.soton.ac.uk/162801/.
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Tax planning by large companies has been widely and publicly discussed due to its implications for the level of provision of public goods and more general social issues. In the U.K., tax avoidance, as estimated by Her Majesty’s Revenue and Customs’ anti-avoidance group, leads to several billion pounds of lost revenue each year. Consequently, the authorities implement tax investigation through risk classification assessments. The prospect of an adverse assessment may influence company directors when making tax planning decisions and similar risk concerns may influence shareholders in valuing tax planning activities. This study reports the results of an investigation of the relationship between firm value and tax planning whilst simultaneously considering corporate governance as a moderating influence. The sample of firms examined consists of non-financial London Stock Exchange-listed companies from 2005 to 2007. The results indicate a negative relationship between firm value and tax planning activities which is unconditional upon corporate governance conditions for both persistent and non-persistent profit-making companies. This relationship can be further explained as being related to the permanent differences component of tax saving where firm value is reported as negatively related to permanent differences. The findings of this study contribute to the body of knowledge since there is a general dearth of published research study from outside the U.S. that investigates these relationships.
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Tsang, Hin-mun Horatio. "The tax planning in Hong Kong and the popularity of its use among individuals in Hong Kong /." Hong Kong : University of Hong Kong, 1998. http://sunzi.lib.hku.hk/hkuto/record.jsp?B19878461.
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Wu, Rebecca Chieh. "A Study on the Appropriateness for Adopting ‘Universal’ Definitions for Tax Compliance and Non-Compliance: A New Zealand Case Study Approach." Thesis, University of Canterbury. Accounting and Taxation, 2012. http://hdl.handle.net/10092/7609.
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Issues and problems associated with the seriousness of tax non-compliance have increased dramatically over the years due to the widening tax gaps experienced by governments worldwide as a result of sophisticated transactions. To add to the severity of the situation are the concerns surrounding the difficulties associated with our abilities in defining what is meant by tax compliance, non-compliance and their relevant sub-categories. This study reviews both the international existing literature and New Zealand case law to examine how the concepts have (or have not) been defined over the years within particular studies and case law. The results are presented in the form of a critical literature review where the definitions (or descriptions) for the concepts are organized into tables, in order to compare how the definitions have (or have not) been ‘improved’ over the years. Lastly, this study discusses the implications regarding whether ‘universal’ definitions can or should be developed and attributed to each of the concepts in order to clear the murkiness between our understanding of the various concepts of tax compliance, non-compliance, and their sub-categories.
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Wu, Jenny Chiani. "NYC property tax exemption program : existing policies and future planning." Thesis, Massachusetts Institute of Technology, 2012. http://hdl.handle.net/1721.1/77130.
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Thesis (S.M. in Real Estate Development)--Massachusetts Institute of Technology, Program in Real Estate Development in Conjunction with the Center for Real Estate, 2012.Cataloged from department-submitted PDF version of thesis. This electronic version was submitted and approved by the author's academic department as part of an electronic thesis pilot project. The certified thesis is available in the Institute Archives and Special Collections.
Includes bibliographical references (p. 106-108).
New York City's tax expenditures relate to real property tax totaled $4.5 billion in fiscal year 2012. The largest expenditure relates to the "421-a" tax exemption program for new multi-family residential real estate development, which costs the New Yorkers nearly $1 billion in foregone tax revenue (Office of Tax Policy, FY 2012). The 421-a program was originally established in the 1970s to spur new multi-family developments. Initially, developers received full tax exemption on the assessed value of the new construction, which then decreased by a phase-out schedule where their property taxes were payable in full at the end of benefit period. As the private development market recovered, the city calibrated the program to (i) exclude certain neighborhoods from receiving benefits for strictly market-rate development and (ii) to spur affordable housing development by offering benefits of the program if a certain percentage of the total units constructed were affordable. Despite the success of the strategy in delivering 142,044 residential units in 2012 (Office of Tax Policy, FY 2012), the program has been subjected to increasing scrutiny as New York City's need for real estate tax revenue has increased. It is unclear how many of these units would have been built without the exemption. Many opponents have argued for the termination of the program because it has not produced benefits commensurate with the huge tax expenditures New York City has made, and that the beneficiaries had been landowners who captured the value of the abatements through higher land prices. As the program approaches its potential renewal in June 15, 2015, it is worthwhile to conduct a detailed analysis of the efficacy and cost of the current program. The thesis offers a thorough yet intelligible case study of a co-op building in Chelsea of how the property taxes would be calculated and the program's impact on the financial feasibility of the development. Different scenarios are created that follows each of the program reforms to understand the actual value of the property tax exemptions to developers and the ways in which such value is distributed. In the current environment where many New Yorkers find themselves facing a daunting housing market with decreased production and increased demand for affordable units, the program should strengthen its benefits to steer more developers towards creating affordable housing. Alternative financial models based on the case study suggest that the return of an improved negotiable certificate program can make the 421-a program a more effective affordable housing incentive without additional cost to the city.
by Jenny Chiani Wu.
S.M.in Real Estate Development
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Goosen, Chantelle. "International Tax Planning: The Concept of Place of Effective Management." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/4624.
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This dissertation will study certain aspects of the South African Income Tax Act2 such as residence-based concepts, with specific reference to place of effective management, which brings a taxpayer within the ambit of the South African Tax Law. It will also address issues regarding Double taxation agreements and the impact of all these issues on companies trading internationally. This paper is intended to raise an awareness of the current issues, general principles and practices to be taken into account when organizing a company's affairs to limit the tax liability in South Africa.
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Rivera-Torres, Leticia. "Tax exemption and industrial development in Puerto Rico." Thesis, Massachusetts Institute of Technology, 1989. http://hdl.handle.net/1721.1/69704.
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Fogelman, Catherine S. 1969. "The syndication of low-income housing tax credits." Thesis, Massachusetts Institute of Technology, 1998. http://hdl.handle.net/1721.1/66387.
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Thesis (S.M.)--Massachusetts Institute of Technology, Dept. of Urban Studies and Planning, 1998.Includes bibliographical references (leaf 47).
The low-income housing tax credit is the primary governmental incentive for the development of affordable housing. This public policy initiative has become attractive to investors because in exchange for an equity investment, they receive tax credits, which serve to reduce their federal income tax liability. Widely held C corporations, due to specifications of the tax code, can utilize tax credits better than any other investor class. Serving as financial intermediaries, syndicators complete the low-income housing tax credit market by bringing together developers, who sell tax credits, and corporations, who purchase these credits. This thesis addresses the role of the for-profit syndicator as the financial intermediary in this market. Syndicators add value by filling informational gaps, providing diversification, and managing risk for investors. In exchange for these and other services, investors pay syndicators a load, which covers fees and expenses. Boston Financial, one of the nation's largest syndicators, has provided information and data for this study. As a means of addressing the value of the syndicator, a performance analysis of Boston Financial's first ten tax credit funds has been performed. This analysis shows that these funds are returning impressive yields. Stated objectives are being met both in terms of yield and tax credit delivery. As this market has matured, pressure on syndicator loads has increased due to competition and falling yields. In such an environment, a syndicator's track record and reputation for delivering yield and managing risk gain importance. As the market continues to evolve, downward pressure on fees is expected to continue.
by Catherine S. Fogelman.
S.M.
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Afonso, Ana Catarina Duarte. "Determinantes do corporate tax avoidance e da utilização de tax havens." Master's thesis, Instituto Superior de Economia e Gestão, 2017. http://hdl.handle.net/10400.5/14487.
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Mestrado em Contabilidade, Fiscalidade e Finanças EmpresariaisEste trabalho de investigação tem como objetivo analisar os determinantes do corporate tax avoidance e da utilização de tax havens, isto é, em que medida certas características da empresa poderão afetar a sua prática de tax avoidance e influenciar a sua escolha na utilização de subsidiárias localizadas em tax havens. Para uma amostra de 321 empresas Europeias constatou-se que a dimensão da empresa, a sua rentabilidade e o grau de utilização de tax havens, determinam de forma positiva o nível de tax avoidance, enquanto que o facto de estarmos perante uma empresa familiar, afeta negativamente o nível praticado. Verificou-se também que a dimensão da empresa influencia negativamente a sua escolha na localização de subsidiárias em tax havens.
This research aims to analyse the determinants of corporate tax avoidance and the use of tax havens, to what extent certain aspects of the company may affect its practice of tax avoidance and influence its choice in the use of subsidiaries located in tax havens. In a selection of 321 European companies, it was found that the size of the company, its profitability, and its degree of use of tax havens, positively determine the level of tax avoidance, while when a family business is endangered, it affects the level practiced in a negative way. It was also found that the size of the company negatively influenced in its choice in the location of subsidiaries in tax havens.
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Tully, Jennifer Anne. "Tax breaks in U.S. agriculture : who benefits, who loses?" Thesis, Massachusetts Institute of Technology, 1986. http://hdl.handle.net/1721.1/78065.
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Thesis (M.C.P.)--Massachusetts Institute of Technology, Dept. of Urban Studies and Planning, 1986.MICROFICHE COPY AVAILABLE IN ARCHIVES AND ROTCH
Bibliography: leaves 54-56.
by Jennifer Anne Tully.
M.C.P.
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Villanueva, Gutiérrez Walker. "Aggressive Tax Planning, the new paradigm of the transfer pricing rule and the avoidance in the Tax Code." IUS ET VERITAS, 2017. http://repositorio.pucp.edu.pe/index/handle/123456789/123689.
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In this paper, the author analyzes the problematic of the aggressive tax planning, due to the lack of coherence between the tax rules of the different States and indicates the way in which the transfer pricing rule should be applied. Also, he analyzes the regulation of the anti-avoidance provision in the Tax Code and criticizes how the Supreme Court applies this anti-avoidance provision and the reasoning of the Tax Court to derive legal effects based on the economic content.En el presente artículo, el autor analiza la problemática de la planificación fiscal agresiva, debido a la falta de coherencia entre las normas tributarias de los distintos Estados y señala la manera en que debe aplicarse la norma de precios de transferencia. Asimismo, analiza la regulación de la norma anti-elusiva en el Código Tributario y realiza una crítica respecto a cómo la Corte Suprema aplica esta norma anti-elusiva y el razonamiento del Tribunal Fiscal para derivar efectos jurídicos sobre la base del contenido económico.
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McMonagle, Samantha. "Tax planning under the Jobs and Growth Tax Relief Reconciliation Act of 2003 is more important than ever. /." Staten Island, N.Y. : [s.n.], 2004. http://library.wagner.edu/theses/business/2004/thesis_bus_2004_mcmon_tax.pdf.
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Vergara, Domínguez Damián. "Business creation, income sheltering and individual tax planning: evidence from special tax regimes for small businesses in Chile." Tesis, Universidad de Chile, 2016. http://repositorio.uchile.cl/handle/2250/143987.
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Tesis para optar al grado de Magíster en EconomíaIn 2013, the Chilean tax system was characterized by the presence of several special tax regimes for small businesses (STRs). Given system’s complexity, the particularities of the different STRs raised concerns about their potential usage as tax avoidance channels for high income taxpayers. This paper addresses that issue by asking if those regimes were associated with a strategic tax planning decision at the individual level. Descriptive statistics account for three stylized facts about STRs usage who suggest the existence of a strategic behavior: STRs were massively used, were mainly used by high income taxpayers, and usage made by high income taxpayers appeared to be part of a businesses portfolio. After rationalizing the stylized facts with a simple analytic model, an econometric analysis is carried out in order to provide formal evidence about strategic behaviors regarding STRs usage. Results confirm model’s predictions: after a reform that made a special STR more restrictive, incomes from businesses subscribed to that STR reported at the individual level decreased, and income from alternative sources increased, resulting in higher taxable incomes given the more restrictive scenario for avoiding taxes. According to the model presented, evidence support the existence of strategic behaviors regarding tax planning at the individual level.
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Olligs, Pia [Verfasser], Michael [Gutachter] Overesch, and Carsten [Gutachter] Homburg. "Determinants of Tax Planning / Pia Olligs ; Gutachter: Michael Overesch, Carsten Homburg." Köln : Universitäts- und Stadtbibliothek Köln, 2016. http://d-nb.info/1123703744/34.
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Mulligan, Emer. "Tax planning in practice : a field study of US multinational corporations." Thesis, University of Warwick, 2008. http://wrap.warwick.ac.uk/1113/.
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The aim of this study is to achieve a better understanding of tax planning in practice, identifying and taking account of the multiple arenas within which it operates, and thereby highlighting its social and institutional dimensions. In the current rapidly changing business and regulatory environment, in which tax is an extremely important source of revenue for governments around the world, an enhanced understanding of tax planning in practice benefits and has implications for taxpayers and tax policymakers alike. The four research questions posed in this study address: the organisation and strategic alignment of the tax planning function in multinational corporations (MNCs); performance measurement of this function; tax risk management; the nature and impact of the relationship between the tax planning function within MNCs and the external environment within which it operates. Empirically this study focuses on US MNCs, primarily in respect of mainstream corporation tax planning. In line with the interpretive inductive methodological approach adopted, face-to-face interviews were conducted with senior tax executives in US MNCs, and tax advisors to such companies. A theoretical framework is developed which combines core themes and theoretical constructs within three strands of literature, namely, tax planning, new institutional sociology and endogeneity of law. This framework provides a powerful explanatory lens through which the findings are presented and interpreted. The role ofpower and powerful actors is an important and recurring theme, and partly explains prevailing tax planning practices through the intensity of professional and social interaction between tax executives. Increasingly tax risk management is more important and there is evidence that this may change the way in which the tax planning function is given strategic recognition and integrated operationally. with business units. The focus on tax risk management results in an isomorphic trend towards conservatism in tax planning, and competitor and peer company influence are significant in shaping tax risk management mechanisms. Measuring the performance of the tax planning function is found to be variable, although there was a view that the effective tax rate (ETR), although an important external measure of corporate performance, was inappropriate as an internal measure. Tax laws are often portrayed as exogenous factors, however this study has found that companies invest heavily in external affairs and direct lobbying to secure changes in the law to suit their purposes; evidencing its endogeneity. Networking costs, reputational risk management and lobbying costs therefore represent non-tax costs that are difficult to measure, but are important components of tax planning activities, overlooked in the current tax planning literature. In addition to the findings themselves this study contributes to knowledge through its interpretive methodological approach which provides a new and rich perspective on tax planning in practice, highlighting some shortcomings of the positivistic approach. It also develops a theoretical framework which uniquely combines theoretical constructs from three strands of literature.
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Horan, Cynthia L. "Empty coffers--tax reform politics in Boston and New York." Thesis, Massachusetts Institute of Technology, 1986. http://hdl.handle.net/1721.1/14889.
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Thesis (Ph. D.)--Massachusetts Institute of Technology, Dept. of Urban Studies and Planning, 1986.MICROFICHE COPY AVAILABLE IN ARCHIVES AND ROTCH
Bibliography: leaves 246-256.
by Cynthia L. Horan.
Ph.D.
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Walpole, Julie D. 1966. "Exploring the paired share REIT and quantifying its tax advantage." Thesis, Massachusetts Institute of Technology, 1998. http://hdl.handle.net/1721.1/70747.
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Thesis (S.M.)--Massachusetts Institute of Technology, Dept. of Urban Studies and Planning, 1998.Includes bibliographical references.
Real Estate Investment Trusts (REITs) were established in 1960 by Congress to open real estate investing to the small investor, in the same way that mutual funds have allowed small investors access to a diversified portfolio of stocks. As is the case with mutual funds, REITs enjoy a conduit status, allowing them to avoid corporate level taxation as long as they meet certain requirements. These requirements have been designed and legislated to ensure that REITs remains passive owners of real estate. As a passive owner of real estate, the traditional REIT vehicle is not ideally suited for an operationally intensive business, even those with a large real estate component (notably hotels, casinos, health care centers, and parking garages). Accordingly, variations of the REIT structure have emerged over time in an effort to benefit from the active business income generated through the operations of real estate holdings. One such variation is the Paired Share REIT. Conceived in 1977, and later banned from further formation in 1984, the structure has once again come under fire. Citing tax avoidance business practices that result in unfair competitive advantage, the Clinton Administration proposes to curb the use of the Paired Share structure on any new acquisitions by the five grandfathered Paired Share REITs that today still exist today. This thesis examines the Paired Share REIT structure and its perceived tax advantage. It concludes that while the Paired Share REIT structure can enjoy a tax advantage relative to a subchapter "C" corporation legislated REIT restrictions limit its financial flexibility. In addition, there are financial tactics available to the "C" corporation that can do much to mitigate these advantages. Two notable tactics are the use of the tax-shielding value of debt and the ability to retain earnings to fund growth. Further, it is concluded that the combined tax expense of the business entity and its shareholders does not differ significantly from the Paired Share REIT and the "C" corporation.
by Julie D. Walpole.
S.M.
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Green, Christopher Terrence. "An analysis of the use of limited real rights in tax planning." Thesis, Nelson Mandela Metropolitan University, 2008. http://hdl.handle.net/10948/809.
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The aim of this treatise is to provide an analysis of the tax implications of making use of limited real rights in tax planning. In order to understand the tax implications of making use of limited real rights it is necessary to understand the nature and legal form of these rights. The importance of this understanding lies in the determination of the tax legislation applicable to the right in question, and the subsequent tax implications. The next step in working through an analysis of the tax implications of making use of limited real rights is therefore to define the scope of applicable legislation. This required an analysis of the scoping provisions of our tax legislation. Once the scope of applicable legislation had been defined, it was then possible to move onto an analysis of the application of the legislation identified to the various “stages” of limited real rights. The conclusion from this analysis is that the tax implications of making use of limited real rights are spread fairly broadly across several different pieces of legislation, and need to be carefully and fully considered when making a decision to make use of limited real rights in a tax planning strategy. The conclusion on the analysis of certain selected tax planning strategies that make use of limited real rights is that it is possible to make fairly substantial cash flow savings when deciding to implement a particular strategy which makes use of limited real rights. But, that use of these strategies is not without risk. For example, SARS may examine a particular strategy in terms of the “new” GAAR. The financial implications of the successful application of the GAAR may be disastrous to the taxpayer, and the tax planner will need to have considered and advised on the possibility of such a challenge from SARS. In addition, in some of the strategies, there are risks associated with the anticipated life expectancy of parties to the tax plan being shorter than anticipated. The conclusion is that the use of limited real rights in tax planning can be effective and provide savings, but that the use of such a strategy requires, inter alia, a very careful consideration of the interaction and application of our tax legislation to the strategy.
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Ellis, Jason Brian. "The implications for tax planning of the general anti-avoidance provisions : part IVA of the Income Tax Assessment Act /." Title page, table of contents and introduction only, 1993. http://web4.library.adelaide.edu.au/theses/09C/09ce471.pdf.
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Bailey, Philip Donald. "The Impact of Federal and State Income Taxes on Forest Landowners: An Examination of Tax Liabilities and Tax Planning." Thesis, Virginia Tech, 1998. http://hdl.handle.net/10919/31701.
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Federal and state income tax laws pertaining to forest landowners are examined. Income tax liabilities are calculated for hypothetical forest landowners in two income brackets across the 41 states in the U.S. which impose a comprehensive income tax. The income tax liability is calculated to illustrate the effects of differential state tax treatment on a representative forest landowner with two different income levels ($50,000 and $110,000) who harvests $200,000 worth of timber in a given tax year. After-tax land expectation values for a forest landowner are also calculated to illustrate the effects of tax planning on returns to timber investment over time.
Twenty-eight states utilize the federal adjusted gross income (AGI) as their tax base. Thirty-three states provide a personal exemption in the form of a credit or deduction. A standard deduction is allowed in twenty-six states. The minimum tax rates range from zero percent in Delaware to six percent in Minnesota and North Carolina. Maximum rates range from 4.5 percent in Connecticut to 11 percent in Montana. Four states allow a capital gains exclusion while two others have maximum capital gains rates that are lower than the highest ordinary state tax rate.
In the South, landowners have the lowest state tax liability in Louisiana and the highest liability in North Carolina for both income levels. In the Midwest and Northeast, landowners in the medium income ($50,000) level have the lowest tax liability in North Dakota and the highest in Minnesota. Landowners in the high income level ($110,000) have the lowest tax liability in Pennsylvania and the highest liability in Minnesota. In the West, medium-income level Idaho and Montana landowners have the lowest and highest state tax liabilities, respectively. High level income landowners have the lowest liability in Arizona and the highest liability in Montana.
The effects of tax planning on a forest landowner's potential revenues are calculated using land expectation methodology. Six different scenarios are used to examine the effect of common omissions and mistakes made by a typical landowner. In each successive scenario, the landowners forego certain tax benefit(s) that, in turn, lower their LEV. Different representative state tax rates and discount rates are used as a sensitivity analysis to find a range of values that could potentially occur. The treatment of timber revenue as an ordinary
gain provides the largest decline in land expectation value in most cases.
Master of Science
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Kuok, Chi. "Anti-corruption campaign and tax avoidance :evidence from China." Thesis, University of Macau, 2018. http://umaclib3.umac.mo/record=b3959240.
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Hanson, Andrew R. "Essays on federal tax policy for housing and urban redevelopment." Related electronic resource: Current Research at SU : database of SU dissertations, recent titles available full text, 2008. http://wwwlib.umi.com/cr/syr/main.
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Battaglene, William M. "Australian promoter penalty laws: Their design, administration and commentary in Australian professional tax publications." Thesis, Queensland University of Technology, 2018. https://eprints.qut.edu.au/121484/2/William%20Battaglene%20Thesis.pdf.
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Responsive Regulation Theory is applied to an examination of the Promoter Penalty Laws, which are designed to deter the promotion of tax avoidance and tax evasion schemes. These laws are examined in terms of their legislative design, the way that the Australian Taxation Office applies them, and the views of them expressed in professional tax publications. Recommendations for potential improvements to the laws are made.
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Zamcheck, Abraham Moses. "Planning for a "sudden-death" inventory loss triggered by international tax competition." Thesis, Massachusetts Institute of Technology, 2016. http://hdl.handle.net/1721.1/107505.
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Thesis: M. Eng. in Logistics, Massachusetts Institute of Technology, Supply Chain Management Program, 2016.Cataloged from PDF version of thesis.
Includes bibliographical references (pages 50-51).
This study addresses a medical device company's need to relicense its products for export after declaring a new legal manufacturer. New license applications are approved at an unknown date with increasing probability within a finite time horizon. Approval results in the instantaneous obsolescence, or "sudden-death," of inventory bound for export. As a result, the company needs to re-align its supply chain strategy to avoid stock-outs or inventory obsolescence. This thesis develops a model that aids the organization in assessing the decisions and necessary information that can help navigate the transition. Potential responses include pushing inventory out of the system before obsolescence, or ramping down production in advance of the sudden-death event. Improved estimates of alternative distribution costs, shortage costs, salvage values, and production capacities will greatly aid the organization's ability to respond to the event scenario. Changing these factors suggest different optimal inventory policies. To illustrate this relationship, a dynamic programming model is derived based on a probability distributions for likely license approval times. The resulting model allows the organization to assess optimal inventory policies derived from various system assumptions. In the thesis, different product aggregations are used to assess inventory strategies for bulk-license application submission. Patterns are identified in the analysis of simulation runs, including the time period for starting alternative inventory ramp-up as well as ramp-down speed. The intent of the study is to provide an iterative method for experimenting with assumptions within the organization in order to drive a coordinated response to the sudden-death eVent. The method is intended to be useful to other organizations planning to transition in preparation-for events occurring with increasing likelihood within finite time horizons.
by Abraham Zamcheck.
M. Eng. in Logistics
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le, Roux Daniel Josua. "Retirement planning : could tax and financial literacy increase financial independence during retirement?" Diss., University of Pretoria, 2017. http://hdl.handle.net/2263/60503.
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Recent studies have indicated that only 6% of South African citizens can maintain their standard of living during retirement. This is of great concern to both the government and individuals. In an attempt to counter this dilemma, the government has implemented several new tax exemptions and deductions to encourage taxpayers to increase their retirement savings.
However, uncertainty exists regarding the effectiveness of these exemptions and deductions. For individuals to benefit from same, they will need to be informed on and understand the principles on which they are based. Above all, South African citizens need to grasp the importance of ensuring their financial security during retirement, which will hopefully create a culture of saving for that purpose. South Africans therefore need to increase their level of financial and tax literacy, either by informing themselves in that regard, or by consulting with professionals.
This study was conducted from a South African perspective and focused on the probability of financial and tax literacy increasing financial independence during retirement. The data presented in this study was collected by means of two questionnaires, which were emailed to a selection of participants. The purpose of this study was first to determine the financial and tax literacy of South Africans with regard to retirement planning and second, to determine whether financial and tax literacy could increase financial independence during retirement. This study is an empirical study since primary data was collected specifically for this research project.
Based on the data obtained by means of the questionnaires, it was concluded that the financial and tax literacy of the majority of South Africans is not sufficient to intentionally benefit from tax-beneficial retirement funds and investments. It was further concluded that although the majority of South Africans are not sufficiently financially literate to be able to optimise their retirement savings, they are willing to improve their level of financial and tax literacy and increase their savings towards retirement once they have been informed and have gained some understanding in this regard. Therefore, financial and tax literacy can potentially increase financial independence during retirement.Mini Dissertation (MCom)--University of Pretoria, 2017.
Taxation
MCom
Unrestricted
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Quinkler, Valentin Hermann Carl [Verfasser]. "Empirical essays on tax planning and transfer pricing / Valentin Hermann Carl Quinkler." Hannover : Gottfried Wilhelm Leibniz Universität Hannover, 2019. http://d-nb.info/1204458472/34.
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Ghebretsadk, A. F. (Abraham Fissehaye). "Semi-autonomous revenue authorities for successful implementation of tax administration reform." Thesis, Stellenbosch : Stellenbosch University, 2003. http://hdl.handle.net/10019.1/49786.
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Thesis (MPA)--University of Stellenbosch, 2003.ENGLISH ABSTRACT: There is a growing tendency towards the establishment of semi-autonomous revenue authorities to collect taxes on behalf of the government. This is necessary for the efficient tax collection by which the state finances its administrative organs. Tax administration as part of the general civil service has suffered due to budget restrictions, inefficiency and corruption resulting from the mere characteristics of the field of public administration. As a remedy, modern tax administrations are now introducing the principles and methods used in the private sector. The trend in public administration, thus, seems to be towards autonomy and professionalization. Strengthening tax administration is thus critical to the successful implementation of the whole tax system. Tax administration, to be successful, needs the simplification of tax policy, commitment at the political and managerial level, and the existence of a comprehensive set of strategies. There is evidence that the creation of semi-autonomous tax authorities has enabled some developing countries to dramatically increase tax revenue. These semi-autonomous revenue authorities are created with the aim of generating additional revenue, improving the tax system and ensuring more equitable taxation. The revenue authorities' model keeps the better employees by better compensation, is flexible in human resources management, integrates tax operations, and is flexibile in budget management. Despite their similarity in objective there are some variations of organizational design of revenue authorities from country to country, with differences in their legal foundation, governance structures, staffing, funding basis, and internal organization. However, there are arguments against semi-autonomous revenue authorities and that they are not a panacea of tax administration. The arguments against the revenue authorities' model are higher costs, discontent of the wider civil service (because of inequities of salary), risks involved in the autonomy, potential for corruption, sustainability and necessity. Nevertheless, the advantages of revenue authorities weigh more than the disadvantages. To overcome the disadvantages of semiautonomous revenue authorities, there should be a clearly defined relationship between the government and the revenue authorities, there should be an appropriate regulatory framework and public accountability, and the structure should be as simple as possible.
AFRIKAANSE OPSOMMING: Daar is 'n groeiende tendens na die totstandkoming van semi-outonome inkomste owerhede om belasting namens die regering in te vorder. Dit is nodig vir die doeltreffende invordering van belasting deur middel waarvan die staat sy administratiewe organe finansier. Belasting administrasie, as deel van die algemene staatsdiens het gely deur begrotingsbeperkings, ondoeltreffendheid en korrupsie wat voortvloei uit die blote kenmerke van die gebied van die openbare administrasie. As 'n remedie, is moderne belasting administrasies besig om die beginsels en metodiek wat in die privaat sector gebruik word in te voer. Die tendens in publieke administrasie is dus gerig op outonomiteit en professionalisme. Die versterking van belasting administrasie is dus krieties vir die suksesvolle implimentering van die hele belastingsisteem. Belasting administrasie, om suksesvol te wees, benodig die vereenvoudiging van belasting beleid, verbondenheid op politieke en bestuursvlak en die bestaan van 'n omvattende stel strategieë. Daar is getuienis dat die totstandkoming van semi-outonome belastingowerhede het sekere ontwikkelende lande in staat gestelom dramaties die belasting inkomste te vermeerder. Hierdie semi-outonome inkomste owerhede is tot stand gebring met die doelom addisionele inkomste te genereer, die belastingsisteem te verbeter en om meer billike belastingte verseker. Die belastingowerhede model behou die beter werknemers deur middel van beter kompensasie, is buigsaam t.o.v. menslike hulpbronbestuur, integreer belastingsprosesse en is buigsaam in begrotingsbestuur. Nieteenstaande hul eendersheid t.o.v die doelwitte, is daar wel variasies van organisasie ontwerp van belastingowerhede van land tot land, met verskille in hul regsgrondslag, "governance" strukture, personeelvoorsiening, basis van bevondsing en die interne organisasie. Daar is wel argumente teen semi-outonome belastingowerhede en dat hulle nie die wondermiddel vir belasting administrasie is nie. Die argumente teen die belastingowerhede model is dié van hoer kostes, ontevredenheid van die breë openbare administrasie (weens die onbillikheid van salarisse), die risko verbondce aan die outonomiteit, die potensiaal vir korrupsie, volhoubaarheid en noodsaaklikheid. Desnieteenstaande, die voordele van belastingowerhede weeg sterker as die nadele. Om die nadele te oorkom, moet daar 'n duidelike uiteengesette verhouding tussen die regering en die belastingowerhede wees, daar moet 'n toepaslike regulerende raamwerk en openbare toerekenbaarheid en die struktuuer moet so eenvoudig moontlik wees.
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Ibele, Mark Adams. "Tax limitations and municipal revenues and expenditures : Proposition 13 and its aftermath." Thesis, Massachusetts Institute of Technology, 1997. http://hdl.handle.net/1721.1/67506.
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Cassiem, Rehana. "The taxation of income and expenditure of Trusts in South Africa - are they still viable estate planning tools?" Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/12821.
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Includes bibliographical references.This research paper will explore the taxation of the income and expenditure in today’s day and age. We will have an in - depth look into the mechanics of trusts, to ascertain whether they still have a role to fulfil in estate planning. Therefore the paper will first explore the background in trusts in Section A, Section B will deal with how trusts are tax and Section C will try and answer why trusts are still popular amidst the unfavourable changes in recent legislation.
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Andrade, Leonardo Aguirra de. "Estruturação elusiva de atos e negócios jurídicos no direito tributário brasileiro: limites ao planejamento tributário." Universidade de São Paulo, 2014. http://www.teses.usp.br/teses/disponiveis/2/2133/tde-11022015-134547/.
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O presente estudo analisa os contornos da estruturação elusiva de atos e negócios jurídicos no Direito Tributário brasileiro. Inicialmente, busca-se definir o conceito de planejamento tributário, abordando as diferentes noções de elisão fiscal, elusão fiscal e evasão fiscal, bem como os critérios contemplados pela doutrina brasileira de Direito Tributário para distinguir as condutas oponíveis e inoponíveis ao Fisco. Para melhor compreensão dos limites da conduta elusiva, examinam-se os princípios constitucionais pertinentes à interpretação da lei tributária e à qualificação da materialidade tributável, as quais são estudadas com vistas à percepção da relação entre Direito Tributário e Direito Privado. Nessa seara, destacam-se os esforços para compreensão da importância dos artigos 109, 116, incisos I e I, e 118 do Código Tributário Nacional em matéria de aplicação da lei tributária, principalmente para entender as consequências da caracterização de determinados vícios ou defeitos, do ponto de vista formal e material, nos atos e negócios jurídicos realizados pelos contribuintes com objetivo de economia fiscal. Nesse particular, examinam-se as figuras da simulação, abuso do direito, fraude à lei e abuso de formas à luz da doutrina brasileira, a fim de verificar sua aplicabilidade em matéria de qualificação da materialidade tributável, bem como com a intenção de identificar pontos em comum entre elas. Analisa-se a pertinência da utilização do postulado da proporcionalidade como parâmetro de interpretação das regras e princípios aplicáveis à estruturação elusiva de atos e negócios realizados pelos contribuintes. Uma vez compreendido o cenário da doutrina brasileira, parte-se para o estudo das figuras do propósito negocial, abuso de formas, fraude à lei e abuso do direito, de acordo com as experiências do Direito estrangeiro, respectivamente, nos Estados Unidos, Alemanha, Espanha e França, igualmente, com o objetivo de encontrar pontos em comum entre tais figuras. Assim, testa-se o postulado da proporcionalidade como ferramenta de compreensão das referidas figuras de acordo com os ordenamentos jurídicos dos respectivos países maternos. Feito esse estudo, busca-se refletir sobre a importação dos conceitos estrangeiros para fins de tratamento da elusão no Brasil, bem como sobre a necessidade da edição de uma norma geral antielusiva no Brasil. Por fim, são examinados os critérios e conceitos adotados pelo Conselho Administrativo de Recursos Fiscais do Ministério da Fazenda para avaliar as condutas elusivas praticadas pelos contribuintes, à luz dos parâmetros selecionados ao longo do trabalho.This study examines the contours of the elusive structuring of acts and transactions according to the Brazilian Tax Law. Initially, it seeks to define the concept of tax planning, covering the different notions of tax avoidance, tax elusion and tax evasion, besides the criteria used by the Brazilian Tax Law doctrine to distinguish between conducts that may be or may be not enforceable against the Brazilian tax authorities. For a better understanding of the limits of an elusive conduct, this study examines the constitutional principles that are relevant to the interpretation of Tax Law and to the identification of taxable material facts, which are also analyzed in view of the relationship between Tax Law and Private Law. Regarding this subject, we highlight the efforts made to understand the importance of articles 109, 116, sections I and I, and 118 of the National Tax Code in regard to the enforcement of the Tax Law and, mainly, efforts made to understand the consequences of the characterization of certain formal or material defects or flaws in acts and transactions undertaken by taxpayers for the purpose of tax saving. In particular, we examine the discussions held by the Brazilian legal doctrine concerning simulation, abuse of law, fraus legis and abuse of forms in order to verify the applicability of those concepts to qualify taxable material facts and in order to identify similarities among them. This study also analyzes the appropriateness of using the postulate of proportionality as a parameter of interpretation of rules and principles applicable to the elusive structuring of acts and transactions conducted by taxpayers. Once the Brazilian doctrine is understood, we proceed to the study of the business purpose test, abuse of forms, fraus legis and abuse of law, respectively, according to the experiences in the United States, Germany, Spain and France. This analysis aims to find common ground between the referred figures. Thus, we test the postulate of proportionality as a tool to understand these figures pursuant to the legal systems of their respective countries of origin. Once this analysis is concluded, we try to reflect on the adoption of foreign concepts for treating tax elusion in Brazil, as well as on the need of editing a national general rule to avoid tax elusion. Finally, we examine the criteria and concepts adopted by the Administrative Board of Tax Appeals of the Ministry of Finance for assessing the elusive behaviors practiced by taxpayers in the light of the parameters selected throughout this study.
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Rademeyer, Conrad. "The impact of capital gains tax on estate planning : a practical decision making model for investing and estate planning." Thesis, Stellenbosch : Stellenbosch University, 2002. http://hdl.handle.net/10019.1/53122.
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Thesis (MBA)--Stellenbosch University, 2002.ENGLISH ABSTRACT: After many years of speculation about the possible introduction of a capital gains tax in South Africa, the tax is finally with us. Coming on top of the move to a residence basis of taxation, the introduction of the capital gains tax will impose a massive burden on the limited, skilled administrative recourses available to taxpayers and the SARS alike. Amongst investors and even some professional financial advisors such as auditors and attorneys there still is confusion and not a lack of knowledge on CGT. Appropriate planning and structuring is seldom performed. The potential CGT liability escalates every year depending on the growth rate of the particular asset. CGT will therefor be an unavoidable and growing problem for investors. Planning for the CGT goes hand in hand with estate planning and requires decisions to be taken now. The purpose is to position and structure your portfolio to avoid or reduce future tax liability (CGT and estate duty). In this study an Excel program was developed in order to calculate CGT. The model (Estate Advisor) also has a decision function and can calculate and predict future CGT liability. The purpose of the model is to test the result of a range of decisions and assumptions quickly and accurately. This enables the investor to decide on entities and structures that would best suit his situation given the assets under his control. The Estate Advisor is a tool for producing different scenarios of future situations regarding CGT and estate duty. It helps the investor to investigate and consider different options regarding his investments with regard to CGT.
AFRIKAANSE OPSOMMING: Na baie jare van onsekerheid en gissings omtrent die moontlike implementering van Kapitaalwinsbelasting in Suid-Afrika, is hierdie belasting finaal geïmplementeer deur die SAID. Die implementering van KWB val saam met die verskuiwing na "verblyf' as "bron" van inkomstebelasting. Tesame sal dit groot druk uitoefen op die beperkte administratiewe bronne wat aan die belasingbetaler en die SAID beskikbaar is. Tussen gewone beleggers en selfs ook tussen sommige professionele finansiële adviseurs (ouditeure en prokureurs) heers daar in 'n groot mate onsekerheid en onkundigheid met betrekking tot KWB. Die probleem is dat 'n ferm basis van kennis van KWB benodig word om in staat te wees om die berekeninge te doen. 'n Gevolg van hierdie situasie is dat dringend benodigde aandag nie altyd aan beleggers geskenk word nie. Die potensiële KWB aanspreeklikheid eskaleer elke jaar met die betrokke groeikoers van die onderliggende bate. KWB is dus 'n onafwendbare en groeiende realiteit vir beleggers. Die beplanning vir toekomstige KWB gaan hand aan hand met beplanning vir boedelbelasting doeleindes. Die doel is om die belegger se portefeulje te posisioneer en struktureer sodat toekomstige belastingaanspreeklikheid (KWB en boedelbelasting) beperk kan word. In hierdie tesis is 'n eenvoudige Excel model ontwerp om KWB en boedelbelasting te bereken. Die model doen al die berekeninge en haal dus die las van die belegger af om oor detail kennis van KWB te beskik. Die model (Estate Advisor) het ook 'n besluitnemingsfunksie waar die belegger verskillende opsies kan oorweeg en toets. Die model word gebruik om toekomstige KWB te voorspel en bereken. Dit stel die belegger in staat om besluite te maak omtrent entiteite en strukture wat in sy situasie die gepaste antwoord sal wees. Die model moet nie gesien word as 'n instrument om beleggingsbesluite te neem nie en dit kan nie keuses uitoefen tussen verskillende beleggingsbates nie. Die doel van die model is uitsluitlik om die effek van verskillende besluite en aannames te vinnig en akkuraat te bereken. Dit dien as hulpmiddel vir die beplan van KWB en boedelbelasting wat in die toekoms betaal moet word. Die Estate Advisor is 'n instrument vir die produsering van verskillende scenarios van toekomstige situasies met betrekking tot KWB en boedelbelasting. Dit help die belegger om verskillende opsies te oorweeg en die beste beleggingsbesluit te maak.
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Barber, Joel Raymond. "Tax effects and term structure measurement." Diss., The University of Arizona, 1989. http://hdl.handle.net/10150/184815.
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For investors in a given tax bracket, bonds with certain combinations of price and maturity may dominate other bonds. If markets are complete, S. M. Schaefer proved that a prohibition on short sales will give rise to tax-induced clienteles. Thus, bonds classified into groups by price and maturity may be held by investors in different tax brackets. Because of the tax advantages associated with discount bonds, there should be a tendency for high tax bracket investors to hold discount bonds and for low tax bracket investors to hold par and near-par bonds. An empirical consquence of this is that the after-tax term structure and implied tax rates may be different across different sets of bonds. The objective of this study is to test empirically for tax-induced clienteles in the market for government bonds with a regression methodology. Nonlinear least squares is used to simultaneously estimate the after-tax term structure and the corresponding implied tax rates. The estimation is performed on each group separately and on the entire sample. The null hypothesis is that the sets of parameters describing the after-tax term structure are equal across the groups. The alternative hypothesis, which will be termed the tax clientele hypothesis, is that sets of parameters are not equal across the groups.
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Катаева, К. Д., and K. D. Kataeva. "Применение методов налогового планирования в деятельности организации и оценка их эффективностиу : магистерская диссертация." Master's thesis, б. и, 2020. http://hdl.handle.net/10995/93993.
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Выпускная квалификационная работа (магистерская диссертация) посвящена исследованию налогового планирования и его методов; их применение в деятельности организации. Предметом исследования является налоговое планирование, виды и применение методов налогового планирования на практике. Основной целью магистерской диссертации является определение направлений налоговой политики актуальной для анализируемого предприятия и разработка мероприятий по их реализации. В заключении обозначены рекомендации по снижению налоговых рисков для исследуемого объекта и достижения оптимального баланса налоговой нагрузки.Final qualifying work (master's thesis) is devoted to the study organization activities. The subject of the study is tax planning, types and application of tax planning methods in practice. The main goal of the master's thesis is to identify areas of tax policy relevant to the analyzed enterprise and the development of measures for their implementation. In the conclusion, recommendations for reducing tax risks for the investigated object and achieving the optimal balance of the tax burden are outlined.
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Tarsitano, Alberto. "Illegitimate Tax Avoidance and Rule XVI of Preliminary Title of Tax Code." IUS ET VERITAS, 2014. http://repositorio.pucp.edu.pe/index/handle/123456789/123330.
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The author analyzes a very important issue such as illegitimate tax avoidance. He begins by explaining the content of the concept of illegitimate tax avoidance, and also he points out the differences with other concepts like tax evasion and tax planning. Then, he comments the debate on the use of legal figures which doesn’t belong to Tax Law, in order to solve issue of illegitimate tax avoidance. Finally, he explains the scope and the application of the Peruvian general anti-avoidance rule stipulated in the Peruvian Tax Code.El autor analiza un tema de suma importancia como es el de la elusión fiscal. Se comienza esclareciendo el contenido del concepto de elusión, diferenciándolo de otros conceptos como la evasión fiscal y la economía de opción. Luego, pasa a recoger y comentar el debate en torno al uso de figuras ajenas al Derecho Tributario para dar solución al problema de la elusión fiscal. Finalmente, pasa a explicar el alcance y aplicación de la cláusula general antielusiva peruana estipulada en la norma XVI del Título Preliminar del Código tributario.
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Kuo, Wen-wen, and 郭文文. "Personal Saving Tax Planning-The Case of Planning Inheritance Tax." Thesis, 2006. http://ndltd.ncl.edu.tw/handle/98384910391939463017.
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碩士義守大學
管理研究所碩士班
94
This study employs the case of planning inheritance tax to develop an appropriate personal saving tax planning. This study collects the relating inheritance laws and the recommends of Certified Public Accountant (CPA) and literature, and deliberates about realistic scenarios. In addition, this study also applies the case study to design the approach of inheritance tax planning and suggests the appropriate method for various scenarios. This study discusses the inheritance tax planning by two aspects: do planning and not planning. According to the characteristics of property, we develop a number of saving tax approaches and tools. Moreover, this study also discusses the timing and the effects of application. After considering the purposes of inheritance tax planning, the personal finance planner may follow this study to find a best way of saving tax.
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Cheng, Wen-Rong, and 鄭文榮. "Tax Planning for Income Tax Integration." Thesis, 1998. http://ndltd.ncl.edu.tw/handle/12877934755287021949.
Full textAbstract:
碩士國立臺灣大學
會計學系
86
As our country adopts income tax integration, individuals and enterprises should restructure their investment and financing decisions, accounting treatment, and strategies of tax planning. Among them, how tax planning should be changed to maximize the wealth of the related individuals or organizations is most concerned by accountants. Therefore the main purpose of this study is to explore tax planning strategies for income tax integration. This thesis first begins with the introduction and discussion of income tax integration adopted in Taiwan in 1998. And then the thesis discusses related papers and articles about tax planning. After reviewing the extant literature, the study uses many examples to demonstrate tax planning strategies for individuals and enterprises to cope with the new laws of tax integration.
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Pillay, Puvanasen Dayalan. "Tax consequences of estate planning." Thesis, 2004. http://hdl.handle.net/10413/1798.
Full textAbstract:
The primary objective of estate planning is to meet the short-term and long-term financial needs of the planner and to ensure a smooth transition of the planner's estate on passing on, in keeping with the needs and wishes of the individual. The implementation of an estate plan does hold many tax advantages and care should be taken to ensure that in the process of tax structuring, we do not lose sight of other important objectives and wishes of the client, as well not contravene any legislation which may render the tax benefits null and void. Estate Duty is levied on an estate at a flat rate of 20 % on the net value of an estate and the planner needs to ensure that his financial affairs are structured in a manner to take maximum advantage of the deductions and abatements available. This will ensure that the duty payable is kept to a minimum. In the process of estate planning the planner must always be aware of the other taxes that could reduce or negate the intended estate duty savings for example donations tax, capital gains tax and income tax. There are many estate planning techniques that can be implemented to meet the objective of a smooth transition of the estate as well as being tax efficient. The nature of everyone's affairs and potential estates vary considerably. As a result there are fairly simple techniques for planners with uncomplicated financial affairs. These would normally be appropriate to salaried employees and smaller business owner's who do not amass a large estate over their lifetime. For high net worth individuals the techniques can be fairly complex, integrating the setting up of companies and/or trusts in order to achieve the planner's objectives and tax efficiency. Due to the specialized and complex nature of certain entities specific estate planning techniques have been designed. With the relaxation of exchange control regulations many South African residents now have offshore assets which form part of their dutiable estate. Careful consideration has to be given to this area since it can be complex with different rules applying to different offshore centres. This is dependant on whether South Africa has a double taxation treaty with that country or not. Income tax and estate planning are inter-related and structures designed to reduce estate duty may have differing consequences from an income tax point of view. This occurs in particular when the use of trusts and donations are envisaged and care should be taken that cognizance of all the anti-avoidance provisions of the Income Tax Act are carefully considered. We can be certain of two things in life "death and taxes". The timing of one's death is an unknown mystery but tax is defined in terms of legislation. With careful planning one can take maximum advantage of the available "tax breaks" with the flexibility to react to changes in legislation, so that the plan can always meet the wishes of the planner irrespective when he/she may pass on (Personal Finance:2004)Thesis (M.Com.)-University of KwaZulu-Natal, 2004.
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Chao, Yi-Chun, and 趙苡均. "A Study on Tax Planning of Taiwan’s Alternative Minimum tax." Thesis, 2009. http://ndltd.ncl.edu.tw/handle/sauwq5.
Full textAbstract:
碩士銘傳大學
財務金融學系碩士在職專班
97
The Legislative Yuan has passed “The Enforcement Rules of the Income Basic Tax Act” (the so-called Alternative Minimum Tax) on 9th, December, 2007. This Act, which is the first tax-adding Act in recent 20 years, indicates a huge progress of taxation justice in Taiwan. The Ministry of Finance enforces The Alternative Minimum Tax mainly for the reason that some specific groups of people take advantage of special tax relief measures made by the government to achieve specific goals for a long time. It is difficult to resolve the unfairness of minorities merit from the tax relief measures because the regulations are separated among more than 30 laws and are hard to be amended in short-term. As a result, The Ministry of Finance refers to international experiences and make The Alternative Minimum Tax to make up the insufficiency of present tax system by collecting certain proportion of income tax to those individuals and companies who apply to the tax relief regulations and thus pay relatively low tax or even exempt from tax. Government levy taxes not only to raise incomes, but also to equalize wealth. Countries under free economies especially emphasize on taxation fairness to achieve this goal. Our government collects tax based on Territoriality Principle, however, under the Alternative Minimum Tax system, arguments about income receiver, income place, income categories, and actual taxpayers occurred during execution. Also further tax management problems have appeared. Such as the definition of taxable subjects, taxable range and territory; the tax collection methods, audit technique gap and the lost of taxable basis, etc. This study mainly discusses the impacts and influences that enforcing Alternative Minimum Tax would possess, especially on the aspects of tax payer, taxable range, and audit method. Through the study we try to find out the present development and taxation problems, and use computerized formula and statistic method to calculate the tax exemption under the original income and tax rate. Moreover, the study considers opinions from professionals of the industries, the authorities, and the academies to analyze the effect and solutions for tax payers to manage their tax planning and for government to make policies and to construct tax management strategies.
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Chu, Chiung-Fang, and 朱瓊芳. "International Tax Planning on Private Property." Thesis, 2007. http://ndltd.ncl.edu.tw/handle/78839517990590726887.
Full textAbstract:
碩士中興大學
會計學研究所
95
International tax planning has come a long way over the last couple of years and will continue to evolve. With an ongoing increase in globalization, legislation and practices regarding multination tax efficient solution are spring up. The Majority is specialized in jurical investors, and in particularly, this study extends to natural person. This study mainly explores the groundwork and motivation of international tax planning on individuals, and summaries the latest development and basic regulations with reference to estate tax and individual income tax that selected countries constituting. We delegate Taiwan, the United States, the United Kingdom, Singapore, the Republic of Korea, Japan, the People''s Republic of China, Hong Kong, the Netherlands, Cayman Islands to mainstream countries. Through assumptive demonstration of three elements of tax：“taxpayer, taxable income, and tax rate”, we interpret applicative tax regulations, analyze the benefit and risk, and compare the differences before and after. The purpose of these examples is to pull together the current thinking of the necessity of reformation in property taxes and the trend of competitive, proper levying policy. We look forward to making an effort to present some feasible and concrete suggestions for current taxation authority to regulate simplier policies and draw up more effective strategies for global investors.
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Chan, Shu-Wen, and 詹淑雯. "Tax Planning Methods for the Value-Added Tax of Mainland China." Thesis, 2005. http://ndltd.ncl.edu.tw/handle/dcg33c.
Full textAbstract:
碩士東吳大學
會計學系
93
This study is to provide useful tax planning methods for Mainland China’s Value-Added Tax, and to survey the actual applications of these tax-planning methods. This research is carried out with Likert Scale to measure opinions of questionnaire subjects, including CPAs and Taiwanese businessmen in Mainland China. In addition, five experts are interviewed to explain the results of the questionnaires. These five experts include two CPAs, two financial executives of Taiwanese enterprises, and one Professor specializing in tax affairs of Mainland China. The findings of the questionnaires and interviews are as follows: I.Both CPAs and Taiwanese businessmen are inclined to favor the seven tax-planning methods proposed by this study, and there is no significant differences in their agreement among different groups of subjects. II.In practice, recommending or adopting the tax-planning methods proposed in this study are as follows: i.In general, most frequently adopted or recommended methods are to increase procurement of input taxes for tax-planning, and to choose appropriate export operation and tax refund methods for exporting products. ii.It is related with the scales of CPA firms whether to recommend the tax-planning methods of choosing filing status such as ordinary taxpayers or small-scale taxpayers, choosing appropriate filing status of importers for importing products, and choosing appropriate export operation and tax refund methods for exporting products. iii.Whether to adopt the tax-planning method of increasing procurement of input taxes is related with the investment scale of Taiwanese enterprises in Mainland China. III.There is a strong correlation between the approval and the recommendation or adoption for the following tax-planning methods: choosing filing status such as ordinary taxpayers or small-scale taxpayers, increasing procurement of input taxes, choosing appropriate filing status of importers for importing products, and choosing appropriate export operation and tax refund methods for exporting products. Our empirical results indicate there exist multiple options and tax-planning methods due to the features of Mainland China’s value-added tax system; consequently, there are opportunities for taxpayers to make tax-planning plans. The contents and results of this study provide detailed explanations on these tax-planning methods and guidance for implementation. Therefore, professionals and Taiwan businessmen in China to smooth their operation and reduce tax costs may use this thesis as a useful reference. Keywords: Value-Added tax of Mainland China, Value-Added Taxes, Tax-planning methods, Taiwan businessmen
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Tsai, Chia-Ching, and 蔡佳靜. "International Tax Planning and Use of Tax Haven of Multinational Companies." Thesis, 1998. http://ndltd.ncl.edu.tw/handle/37988696821068632420.
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FU, YIN-JOU, and 傅銀柔. "Trust acts Tax Benefit and Tax Planning, Equity Research─To income tax, inheritance tax and gift tax laws as an example." Thesis, 2010. http://ndltd.ncl.edu.tw/handle/36478009239179151218.
Full textAbstract:
碩士逢甲大學
經營管理碩士在職專班
98
The Trust''s origin can be traced back to ancient Egypt. The ancient Egyptians, by way of testamentary trusts, transferred their own properties to their children and relatives.During the Roman era, Trust has become an indirect way to bequeath in ancient Roman’s legal legacy system. The modern Trust system was formed in the United Kingdom. The British Trust system is based on the medieval system of land-USE. It is a system that the trustee, based on the contents of Trust, manages the Trust on behalf of the beneficiaries. Because of the flexibility of such system, as well as additional functions such as financial management, social security maintenance, and social benefits, it has gradually developed all over the world. Great Britain, USA, and Japan are the three countries with the most developed Trust industries. Trust is a property management system that bases its core on capital, goods, and trust to manage the properties through trustee and delegate. Not only does it help people manage property, Trust also has the function of investment financial management. In addition, it can help high income people to enjoy tax management. In the past, the Trust industries in Taiwan were not as developed as other modern countries. With joint efforts form government authorities, Trust industries, and scholars, Taiwan’s Trust Act and Trust Industries Law were signed and implemented in January, 1996 and July, 2000 respectively. Other relevant laws were also subsequently implemented which not only makes Taiwan’s Trust regulating policies complete, but also enable Taiwan’s Trust industries to enjoy diversified developments. In recent years, Taiwan’s domestic capital market develops rapidly. People’s financial management concept has also greatly developed and matured in recent years. While pursuing the maximum return of investment, the tax risks must not be ignored. The scope of this study is to discuss the impact of income tax on inheritance and gift after the implementation of Trust tax. Begin with the Trust system of Great Britain, USA, Japan, and compare them to Taiwan’s Trust system. Using case studies, tax planning and benefits are then analyzed. Because Trust involves transfer of form and transfer of substance at different points, therefore the logic behind Trust tax law is uniquely different from the conventional tax law. The current inherence law and gift law have decreased the tax rate. The scope of this study will also examine whether there will be more room for tax saving, as well as the benefits and fairness of the tax law before and after the law change.