Elimination of double tax benefits for military homeowners.

Item 1005-C

Reporting Income Taxes in the Banking Sector In Angola - Accounting, Tax Regulation and Financial Reporting Evidences

This research provides an insight into income taxes reporting in Angola, based on hand collected data from the annual reports of banks. Empirical studies on Angolan companies are scarce, in part due to the limited access to data. The results show that income taxes’ reporting has improved over the years 2010-2013, becoming more reliable and understandable. The Angolan Government is boosting the economic growth through tax benefits in the investment in public debt, which cause a reduction in the banks’ effective tax rate. The new income tax law will reduce the statutory tax rate from 2015 onwards and change the taxable income, resulting in shifting the focus to promoting private investment.

The Rise of The Swiss Tax Haven in the Interwar Period: An International Comparison

The history of tax havens during the decades before World War II is still little known. To date, the studies that have focused on the 1920s and 1930s have presented either a very general perspective on the development of tax havens or a narrow national point of view. Based on unpublished historical archives of five countries (Switzerland, Great Britain, Belgium, France, Germany), this paper offers therefore a new comparative appraisal of international tax competition during this period in order to answer the following question: What was the specificity of the Swiss case - already considered a quintessential tax haven at the time - in comparison to other banking centres? The findings of this research study are twofold. First, the 1920s and 1930s appear as something of a golden age of opportunity for avoiding taxation through the relocation of assets. Most of the financial centres granted consistent tax benefits for imported capital, while the limited degree of international cooperation and the usual guarantee of banking secrecy in European countries prevented the taxation of exported assets. Second, within this general environment, the fiscal strategies of a tax haven like Switzerland differed from those of a great financial power like Great Britain. Whereas the Swiss administration readily placed itself at the service of the banking community, British policy was more balanced between the contradictory interests of the Board of Inland Revenue, the Treasury, and the English business circles.

The Rise of The Swiss Tax Haven in the Interwar Period: An International Comparison

The history of tax havens is still little known for the decades before World War II. Up to now the studies that have focused on the 1920s and 30s have presented either a very general perspective on the development of tax havens or a narrow national point of view. Based on unpublished historical archives of four countries, this paper offers therefore a new comparative look on international tax competition during this period in order to answer the following question: was the Swiss case - already considered as a quintessential tax haven at the time - specific in comparison to other banking centres? This research has two results. On the one hand, the 1920s and 30s appear as something of a golden age of opportunity for avoiding taxation through the relocation of assets. Actually, most of the financial centres granted consistent tax benefits for imported capital, while the extremely limited degree of international cooperation and the usual guarantee of banking secrecy in European countries prevented the taxation of exported assets. On the other hand, within this general balance sheet, the fiscal strategies of a tax haven like Switzerland differed from those of a great financial power like Great Britain. Whereas the Swiss administration readily placed itself at the service of the bankers, the British policy was more balanced between the contradictory interests of the Board of Inland Revenue, the Treasury and the English business circles.

Do brazilian states engage in the fiscal war of ports? An empiric study of tax competition and an analysis of a natural experiment: the brazilian senate resolution 13/2012

O fim do ano de 2014 marcou o segundo aniversário da Resolução 13/2012 (R13) do Senado brasileiro. Grosso modo, R13 constituiu-se de um normativo do Senado cujo objetivo era o de por um fim na Guerra Fiscal dos Portos (FWP), uma competição fiscal entre os estados que se dá através da concessão de benefícios fiscais sobre operações interestaduais com mercadorias importadas de modo a atrair empresas importadoras para o território do estado concedente. R13 diminuiu o nível da tributação sobre tais operações, esperando com isso diminuir os lucros auferidos e a propensão das firmas de aceitarem tais regimes especiais de incentivação fiscal. Nada obstante, R13 gerou uma grande discussão sobre se os benefícios da atração de investimentos para um estado em particular superariam ou não os custos que esse estado incorreria em renunciar receitas tributárias em razão concessão desses benefícios fiscais. O objetivo do presente trabalho é o de dar uma contribuição a essa discussão, testando se um comportamento de interação estratégica entre estados, tal como aquele que supostamente ocorre no contexto da FWP, de fato emerge dos dados de importação coletados de janeiro de 2010 a maio de 2015, e, também, testando se a R13 de fato afetou tal comportamento de interação estratégica. Utiliza-se aqui um modelo de econometria espacial, no qual se especifica uma matriz de pesos que agrega o nível de importação das jurisdições concorrentes, organizando os dados em um painel de efeitos fixos. Os resultados sugerem que existe um comportamento de interação estratégica entre os estados e que a R13 de fato impactou tal comportamento.

Tax-Optimal Step-Up and Imperfect Loss Offset

In the field of mergers and acquisitions, German and international tax law allow for several opportunities to step up a firm's assets, i.e., to revaluate the assets at fair market values. When a step-up is performed the taxpayer recognizes a taxable gain, but also obtains tax benefits in the form of higher future depreciation allowances associated with stepping up the tax base of the assets. This tax-planning problem is well known in taxation literature and can also be applied to firm valuation in the presence of taxation. However, the known models usually assume a perfect loss offset. If this assumption is abandoned, the depreciation allowances may lose value as they become tax effective at a later point in time, or even never if there are not enough cash flows to be offset against. This aspect is especiallyrelevant if future cash flows are assumed to be uncertain. This paper shows that a step-up may be disadvantageous or a firm overvalued if these aspects are not integrated into the basic calculus. Compared to the standard approach, assets should be stepped up only in a few cases and - under specific conditions - at a later point in time. Firm values may be considerably lower under imperfect loss offset.

The Optimal Capital Structure of Banks: Balancing Deposit Insurance, Capital Requirements and Tax-Advantaged Debt

The capital structure and regulation of financial intermediaries is an important topic for practitioners, regulators and academic researchers. In general, theory predicts that firms choose their capital structures by balancing the benefits of debt (e.g., tax and agency benefits) against its costs (e.g., bankruptcy costs). However, when traditional corporate finance models have been applied to insured financial institutions, the results have generally predicted corner solutions (all equity or all debt) to the capital structure problem. This paper studies the impact and interaction of deposit insurance, capital requirements and tax benefits on a bankÇs choice of optimal capital structure. Using a contingent claims model to value the firm and its associated claims, we find that there exists an interior optimal capital ratio in the presence of deposit insurance, taxes and a minimum fixed capital standard. Banks voluntarily choose to maintain capital in excess of the minimum required in order to balance the risks of insolvency (especially the loss of future tax benefits) against the benefits of additional debt. Because we derive a closed- form solution, our model provides useful insights on several current policy debates including revisions to the regulatory framework for GSEs, tax policy in general and the tax exemption for credit unions.

Charity care and community benefits by hospital type in Texas

Hospital care is the largest component of the health care sector. This industry is made up of for profit hospital (FPH) organizations, not for profit (NFP) hospitals, and government (GOV) run hospital facilities. Objectives of this analysis were: (a) to conduct a literature review on NFP hospital legislation at the state level in Texas and at the federal level in the broader U.S.; and (b) to describe the types of charity care and community benefits currently being provided: by NFP hospitals compared to FPH hospitals and GOV hospitals; by hospitals geographic proximity to the Texas-Mexico border; and by hospital community type (rural, suburban, and urban); and (c) propose specific policy changes that may be needed to improve the current Texas State statute. Methods. In describing the historical and current policy context of NFP hospital legislation in the United States, federal legislation was reviewed from 1913 to the present and Texas State legislation was reviewed from 1980 to the present. In describing the provision of charity care, data from the 2008 Annual Cooperative Hospital Survey were examined by hospital organizational type, size, proximity to the border, and community type using linear regression and chi-squared tests to assess differences in charity care and community benefits. Results. The data included 123 NFP hospitals, 114 GOV hospitals, and 123 FPH. Results. Small sized (p<0.001) and medium sized (p<0.001) NFP hospitals provide a greater percent of total charity care when compared to FPH hospitals and to both GOV and FPH hospitals respectively; however, no significant difference in total charity care was found among large sized NFP hospitals when compared to FPH hospitals alone (p=.345) and both GOV and FPH facilities (p=.214). The amount of charity care provided was not found to be different based on proximity to the border or community type. Community benefit planning and budgeting was found to be similar regardless of community type and proximity to the border. Conclusion. No differences in charity care in Texas were found for large sized NFP hospitals compared to FPH and GOV hospitals. Contrary to widely held beliefs, this study did not find the border region to provide a greater amount of charity care or bad debt. Charity care also did not vary by community type. These findings underscore the need for continued collection of transparent data from all hospitals in order to provide policy makers and consumers with information on utilization trends to ensure benefits are being provided to the community. Policy changes or revoking tax-benefits may occur as charity care utilization declines with the implementation of health reform in the next few years.^

Tax implications of dividend policy

This study examines the tax-arbitrage possibilities on the Budapest Stock Exchange between 1995 and 2007. The theoretical possibility for the arbitrage is the different taxation for different stockholders, for the private investors and for the institutions: the institutions had higher taxation on capital gain while private persons in the whole period had tax-benefits on capital gains. The dynamic clientele model shows, that there is a range of the price drops after dividend payouts which guarantees a risk-free profit for both parties. The research is based on the turnover data from 97 companies listed on the Budapest Stock Exchange. We have tested the significant turnovers around the dividend-dates. The study presents clear evidence that investors continuously did take advantages on the different taxation.

Property Exchange Rules Offer Tax Opportunities for Hotel Owners

One strategy often overlooked by hospitality owners in developing cost-saving strategies is the use of like-kind exchanges to acquire property. The author reviews some alternative methods of like-kind exchanges, which may not only provide new business opportunities for the hospitality owner, but lucrative tax benefits as well.

Model for facilities or vendors location in a global scale considering several echelons in the Chain

The facilities location problem for companies with global operations is very complex and not well explored in the literature. This work proposes a MILP model that solves the problem through minimization of the total logistic cost. Main contributions of the model are the pioneer carrying cost calculation, the treatment given to the take-or-pay costs and to the international tax benefits such as drawback and added value taxes in Brazil. The model was successfully applied to a real case of a chemical industry with industrial plants and sales all over the world. The model application recommended a totally new sourcing model for the company.

“Reforma fiscal: carro novo ou filhos e família”?

O art. 67º da Constituição é claro, quando afirma: “Incumbe, designadamente, ao Estado para protecção da família: § a) Promover a independência social e económica dos agregados familiares § f) Regular os impostos e os benefícios sociais, de harmonia com os encargos familiares”. Abstract: O art. 67º da Constituição é claro, quando afirma: “Incumbe, designadamente, ao Estado para protecção da família: § a) Promover a independência social e económica dos agregados familiares § f) Regular os impostos e os benefícios sociais, de harmonia com os encargos familiares”.

Gestão fiscal e benefícios fiscais

Dissertação de Mestrado apresentado ao Instituto de Contabilidade e Administração do Porto para a obtenção do grau de Mestre em Auditoria, sob orientação de Doutor José Campos Amorim

Impacto dos benefícios fiscais, em sede de IRS, em Portugal e a sua evolução no período de 2001-2010

Mestrado em Contabilidade

As deduções de IRS antes e depois do memorando da Troika

Mestrado em Fiscalidade