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1、美华管理人才学校美华管理人才学校 学学员用书员用书 电子教辅税电子教辅税收筹划原理收筹划原理Types of Taxes and the Jurisdictions That Use ThemnLearning ObjectivesDefine the terms tax,taxpayer,incidence,and jurisdiction.Express the relationship between tax base,rate,and revenue as a formula.Describe the taxes levied by local governments,state go
2、vernments,and the federal government.Explain why different jurisdictions compete for revenues from the same taxpayer.Identify the reasons why governments modify their tax systems.Describe the three primary sources of federal tax law.Types of Taxes and the Jurisdictions That Use ThemnSome Basic Termi
3、nologyTaxnA payment to support the cost of governmentTaxpayernAny person or organization required by law to pay a tax to a governmental authorityIncidencenThe ultimate economic burden represented by the tax.JurisdictionnThe right of a government to levy tax on a specific person or organizationTypes
4、of Taxes and the Jurisdictions That Use ThemnSome Basic TerminologyThe Relationship between Base,Rate and Revenue Tax(T)=Rate(r)Base(B)Types of Taxes and the Jurisdictions That Use ThemnSome Basic TerminologyTransaction or Activity-Based TaxesnA tax can be event or transaction based so that the tax
5、is triggered only when an event occurs or a transaction takes place.Earmarked TaxesnA tax can be described as activity based when it is imposed on the cumulative result of an ongoing activity.Types of Taxes and the Jurisdictions That Use ThemnThe Pervasive Nature of TaxationLocal TaxesnReal Property
6、 TaxesnPersonal Property TaxesState TaxesnRetail Sales,Uses,and Excise TaxesnPersonal Income TaxesnCorporate Income TaxesFederal TaxesnHistory of the Income TaxnEmployment and Unemployment TaxesnOther Federal TaxesTypes of Taxes and the Jurisdictions That Use ThemTypes of Taxes and the Jurisdictions
7、 That Use ThemnTaxes Imposed by Foreign JurisdictionsValue-added tax(VAT)nJurisdictional CompetitionExplain why different jurisdictions compete for revenues from the same taxpayerTypes of Taxes and the Jurisdictions That Use ThemnDynamic Nature of TaxationTax Base ChangesnLegalized GamblingnSales Ta
8、x ExpansionTax and the Political ProcessTypes of Taxes and the Jurisdictions That Use ThemnSources of Federal Tax LawStatutory AuthoritynInternal Revenue Code of 1986Administrative AuthoritynTreasury regulationsnInternal Revenue Service(IRS)nInternal Revenue Bulletins(IRBs)nCumulative Bulletins(CBs)
9、Judicial AuthorityTypes of Taxes and the Jurisdictions That Use ThemnConclusionChapter TWOTax Policy Issues:Standards for a Good TaxTax Policy Issues:Standards for a Good TaxnLearning ObjectivesExplain the concept of sufficiency of a good tax.Differentiate between the income effect and the substitut
10、ion effect.Describe the characteristics of a convenient tax.Contrast the classical and the modern concepts of tax efficiency.Define horizontal and vertical equity.Differentiate between a regressive,a proportionate,and a progressive rate structure.Explain the difference between marginal and average t
11、ax rates.Discuss distributive justice as a tax policy objective.Tax Policy Issues:Standards for a Good TaxnStandards for a Good TaxA good tax should be sufficient to raise the necessary government revenues.A good tax should be convenient for the government to administer and for people to pay.A good
12、tax should be efficient in economic terms.A good tax should be fair.Tax Policy Issues:Standards for a Good TaxnTaxes Should be SufficientA tax is sufficient if it generates enough funds to pay for the public goods and services provided by the government.Tax Policy Issues:Standards for a Good TaxnTax
13、es Should be SufficientThe National DebtHow to Increase Tax RevenuesStatic versus Dynamic ForecastingTax Policy Issues:Standards for a Good TaxnTaxes Should be SufficientBehavioral Responses to Rate ChangesnIncome EffectnSubstitution EffectnSupply-Side EconomicsTax Policy Issues:Standards for a Good
14、 TaxnTaxes Should Be ConvenientFrom the governments viewpoint,a good tax should be convenient to administer.From the taxpayers viewpoint,a good tax should be convenient to pay.Tax Policy Issues:Standards for a Good TaxnTaxes Should Be EfficientThe Classical Standard of EfficiencynAn efficient tax sh
15、all be neutral in its effect on the free market.Taxes as an Instrument of Fiscal PolicynIn the Keynesian schema,tax system is a primary tool of fiscal policy.Tax Policy Issues:Standards for a Good TaxnTaxes Should Be EfficientTaxes and Behavior ModificationnIncome Tax PreferencenThe Tax Expenditures
16、 BudgeTax Policy Issues:Standards for a Good TaxnTaxes Should Be FairAbility to PaynIn the tax policy literature,ability to pay refers to the economic resources under a persons control.Tax Policy Issues:Standards for a Good TaxnTaxes Should Be FairHorizontal EquitynIf a tax is designed so that perso
17、ns with the same ability to pay(as measured by the tax base)owe the same amount of tax,that system can be described as horizontally equitable.Tax Policy Issues:Standards for a Good TaxnTaxes Should Be FairHorizontal EquitynTaxable Income and Ability to PaynAnnual versus Lifetime Horizontal EquitynTa
18、x Preference and Horizontal EquityTax Policy Issues:Standards for a Good TaxnTaxes Should Be FairVertical EquitynA tax system is vertically equitable if persons with a greater ability to pay owe more tax than persons with a lesser ability to pay.Tax Policy Issues:Standards for a Good TaxnTaxes Shoul
19、d Be FairVertical EquitynRegressive TaxesnIncome Tax Rate StructuresnMarginal and Average Tax RatesTax Policy Issues:Standards for a Good TaxnTaxes Should Be FairDistributive JusticeTax Policy Issues:Standards for a Good TaxnTaxes Should Be FairMarginal rateAverage rate10Tax rates(percent)2050100Tax
20、able income（$000）Tax Policy Issues:Standards for a Good TaxnTaxes Should Be FairMarginal rateAverage rate5101612%Tax rates(percent)2050100Taxable income（$000）Tax Policy Issues:Standards for a Good TaxnTaxes Should Be FairThe Perception of InequityTax Policy Issues:Standards for a Good TaxnConclusion
21、Chapter ThreeTaxes as Transaction CostsTaxes as Transaction CostsnLearning ObjectivesCompute the tax cost of an income item and the tax savings from a deduction.Integrate tax costs and savings into NPV calculationsIdentify the uncertainties concerning future tax costs and savings.Explain why tax min
22、imization may not be the optimal business strategy.Explain why bilateral tax planning is important in private market transactions.Distinguish between arms-length and related party transactions.Taxes as Transaction CostsnThe Role of Net Present Value in Decision MakingQuantifying Cash FlowsTaxes as T
23、ransaction CostsnThe Role of Net Present Value in Decision MakingThe Concept of Present ValuenPresent ValuenPresent Value of an AnnuitynPresent Value Tables($1 for n periods)Taxes as Transaction CostsnThe Role of Net Present Value in Decision MakingThe Issues of RiskTaxes as Transaction CostsnThe Ro
24、le of Net Present Value in Decision MakingA Net Present Value ExampleTaxes as Transaction CostsEngagement1Engagement2Current year:Cash revenues$150,000$200,000 Cash expenses (90,000)(65,000)Net cash flow$60,000$135,000Next year:Cash revenues$150,000$125,000 Cash expenses(10,000)(65,000)Net cash flow
25、$140,000$60,000Present value of current year cash flow$60,000$135,000Present value of next year cash flow (cash flow.909 discount factor)127,260 54,540NPV$187,260$189,540Taxes as Transaction CostsnTaxes and Cash FlowsnTax CostsnTax SavingsThe Significance of Marginal Tax RateTaxes as Transaction Cos
26、tsnTaxes and Cash FlowsNet Present Value Example RevisitedTaxes as Transaction CostsEngagement1 Engagement2Current year:Taxable revenues$150,000$200,000 Deductible expenses (90,000)(65,000)Before-tax cash flow/taxable income$60,000$135,000 Income tax cost at 40%(24,000)(54,000)After-tax cash flow$36
27、,000$81,000Next year:Taxable revenues$150,000$125,000 Deductible expenses (10,000)(65,000)Before-tax cash flow/taxable income$140,000$60,000 Income tax cost at 40%(56,000)(24,000)After-tax cash flow$84,000$36,000Present value of current year cash flow$36,000$81,000Present value of next year cash flo
28、w (after-tax cash flow .909 discount factor)76,356 32,724NPV$112,356$113,724Taxes as Transaction CostsnTaxes and Cash FlowsNet Present Value Example RevisitednDifferent Tax Treatment across TransactionsnDifferent Tax Rates over TimeTaxes as Transaction CostsEngagement1 Engagement2Current year:Taxabl
29、e revenues$150,000$200,000 Deductible expenses(90,000)(48,750)Nondeductible expenses -0-(16,250)Before-tax cash flow$60,000$135,000 Income tax cost:Taxable income$60,000$151,250 .40 .40 Tax cost (24,000)(60,500)After-tax cash flow$36,000$74,500Next year:Taxable revenues$150,000$125,000 Deductible ex
30、penses(10,000)(48,750)Nondeductible expenses-0-(16,250)Before-tax cash flow$140,000$60,000 Income tax cost:Taxable income$140,000$76,250 .40 .40 Tax cost(56,000)(30,500)After-tax cash flow$84,000$29,500Present value of current year cash flow$36,000$74,500Present value of next year cash flow (after-t
31、ax cash flow .909 discount factor)76,356 26,816 NPV$112,356$101,316Taxes as Transaction CostsEngagement1 Engagement2Current year:Taxable revenues$150,000$200,000 Deductible expenses (90,000)(65,000)Before-tax cash flow/taxable income$60,000$135,000 Income tax cost at 40%(24,000)(54,000)After-tax cas
32、h flow$36,000$81,000Next year:Taxable revenues$150,000$125,000 Deductible expenses (10,000)(65,000)Before-tax cash flow/taxable income$140,000$60,000 Income tax cost at 25%(35,000)(15,000)After-tax cash flow$105,000$45,000Present value of current year cash flow$36,000$81,000Present value of next yea
33、r cash flow (after-tax cash flow .909 discount factor)95,445 40,905NPV$131,445$121,905Taxes as Transaction CostsnTaxes and Cash FlowsThe Uncertainty of Tax ConsequencesnAudit RisknTax Law UncertaintynMarginal Rate UncertaintyTaxes and Cash FlowsnStructuring Transactions to Reduce TaxesAn Important C
34、aveatTransactional MarketsnPrivate Market TransactionsnThe Arms-Length PresumptionnPublic Market TransactionsnFictitious Markets:Related Party TransactionsTaxes and Cash FlowsnConclusionChapter FourMaxims of Income Tax PlanningMaxims of Income Tax PlanningnLearning ObjectivesDifferentiate between ta
35、x avoidance and tax evasion.List the four variable that determine the tax consequences of a transaction.Explain why an income shift or a deduction shift can improve NPV.Identify the circumstances in which a tax deferral strategy may not improve NPV.Contrast the tax character of ordinary income and c
36、apital gain.Distinguish between an explicit tax and an implicit tax.Summarize the four tax planning maxims.Describe the three legal doctrines that the IRS uses to challenge tax planning strategies.Maxims of Income Tax PlanningnTax AvoidanceNot EvasionLegitimate means reducing taxes are described as
37、tax avoidance;Illegal means the same end constitute tax evasion.Maxims of Income Tax PlanningnWhat Makes Income Tax Planning Possible?1.The entity variable:Which entity undertakes the transaction?2.The time period variable:During which tax year or years does the transaction occur?3.The jurisdiction
38、variable:In which taxing jurisdiction does the transaction occur?4.The character variable:What is the tax character of the income from the transaction?Maxims of Income Tax PlanningnThe Entity VariableIncome ShiftingDeduction ShiftingConstraints on Income ShiftingnAssignment of Income DoctrineIncome
39、must be taxed to the entity that renders the service or owns the capital with respect to which the income is paid.Maxims of Income Tax PlanningnThe Time Period VariableMaxims of Income Tax PlanningYear 0Year 1Revenues$120$180Expenses (40)(80)Income tax cost:Taxable income$80$100 .35 .35 Tax cost (28
40、)(35)After-tax net cash flow$52$65Present value of year 0 cash flow$52Present value of year 1 cash flow（$65.893 discount factor）58NPV$110Maxims of Income Tax PlanningYear 0Year 1Revenues$120$180Expenses (40)(80)Income tax cost:Taxable income 0$180 .35 .35 Tax cost -0-(63)After-tax net cash flow$80$3
41、7Present value of year 0 cash flow$80Present value of year 1 cash flow（$65.893 discount factor）33NPV$113Maxims of Income Tax PlanningnThe Time Period VariableIncome Deferral and Opportunity CostsMaxims of Income Tax PlanningYear 0Year 1Revenues$40$260Expenses (40)(80)Income tax cost:Taxable income -
42、0-$180 .35 Tax cost -0-(63)After-tax net cash flow -0-$37Present value of year 0 cash flow -0-Present value of year 1 cash flow（$65.893 discount factor）104NPV$104Maxims of Income Tax PlanningYear 0Year 1Revenues$120$180Expenses (120)-0-Income tax cost:Taxable income -0-$180 .35 Tax cost -0-(63)After
43、-tax net cash flow -0-$117Present value of year 0 cash flow -0-Present value of year 1 cash flow（$65.893 discount factor）104NPV$104Maxims of Income Tax PlanningnThe Time Period VariableIncome Deferral and Rate ChangesMaxims of Income Tax PlanningYear 0 Year 1 Year 2 Year 3Without income Taxable inco
44、me$30,000 -0-0-0-Tax cost at 35%$10,500 -0-0-0-NPV of tax costs$10,500With deferral:Taxable income-0-$10,000$10,000$10,000 Tax cost at 35%-0-$3,500$3,500$3,500 Discount factors .917 .842 .772$3,210$2,947$2,702 NPV of tax costs$8,859Maxims of Income Tax PlanningYear 0 Year 1 Year 2 Year 3Taxable inco
45、me -0-$10,000$10,000$10,000Tax cost at 45%-0-$4,500$4,500$4,500Discount factors .917 .842 .772$4,127$3,789$3,474Actual NPV of tax costs$11,390Maxims of Income Tax PlanningActual NPV of tax costs$11,390NPV of tax cost without deferral （10，500）$890Maxims of Income Tax PlanningnThe Jurisdiction Variabl
46、eMaxims of Income Tax PlanningFirm Y Firm ZBefore-tax cash/income$5,000$5,000State income tax cost(200)(500)Federal taxable income$4,800$4,500Federal tax cost (Taxable income39%)(1,872)(1,755)After-tax cash flow$2,928$2,745Maxims of Income Tax PlanningnThe Character VariableMaxims of Income Tax Plan
47、ningOrdinary Capital Tax-Exempt Income Gain IncomeBefore-tax cash/income$1,000$1,000$1,000Tax cost (350)(150)-0-After-tax cash flow$650$850$1,000Maxims of Income Tax PlanningnThe Character VariableDetermining the Value of Preferential RatesMaxims of Income Tax PlanningOrdinary Income Capital GainBef
48、ore-tax cash/income$1,000$1,000Tax cost(28%regular rate)(280)(150)After-tax cash flow$720$850Maxims of Income Tax PlanningnThe Character VariableConstraints on ConversionImplicit TaxesMaxims of Income Tax PlanningCorporate Municipal Bond Interest Bond InterestBefore-tax cash/income$2,000$2,000Tax co
49、st(28%regular rate)(660)-0-After-tax cash flow$1,340$2,000Maxims of Income Tax PlanningCorporate Municipal Bond Interest Bond InterestBefore-tax cash/income$2,000$1,600Tax cost(660)-0-After-tax cash flow$1,340$1,600Maxims of Income Tax PlanningCorporate Municipal Bond Interest Bond InterestBefore-ta
50、x cash/income$2,000$1,300Tax cost(660)-0-After-tax cash flow$1,340$1,300Maxims of Income Tax PlanningnDeveloping Tax Planning StrategiesAdditional Strategic ConsiderationsTax Legal DoctrinesMaxims of Income Tax PlanningnConclusionChapter FiveTax ResearchTax ResearchnLearning ObjectivesUnderstand and