Wealth tax as alternative minimum tax? The impact of a wealth tax on business structure and strategy

An alternative minimum tax (AMT) is often regarded as desirable. We analyze a wealth tax at corporate and personal level that is designed as an AMT as proposed by the German Green Party. This wealth tax is imputable to profit taxes and is hence intended to prevent multiple (multistage) taxation. Referring to data from annual reports and the German Central Bank we model enterprises of different structure, industry, size and legal status. We show that companies in the service sector which generally maintain rather high gearing rates are more frequently subjected to the wealth tax than capital intensive industries. This result runs counter to well-known effects of a common wealth tax. Capital intensive firms, e.g. in the metal industry, are levied with definitive wealth tax only if they have large loss carry-forwards or extremely volatile profits. Furthermore, partnerships often enjoy wealth tax privileges due to uniform taxation at individual level whereas corporations may suffer from the wealth tax at corporate and personal level caused by imputation backlogs. Obviously, the underlying AMT influences corporate dividend policy evoking a push-out effect. We prove that this kind of wealth taxation usually favors financial rather than real investment and encourages outbound investment. Consequently, introducing an AMT discriminates against many firms and investment projects, especially if economic income is lower than taxable income. This proves that whenever income is taxed correctly, AMT is dispensable. --alternative minimum tax,business strategy,investment decisions,wealth tax

The impact of profit taxation on capitalized investment with options to delay and divest

In entrepreneurial decisions making uncertain future profits often are a main characteristics of real investment opportunities. If investors can react to uncertainty the degree of irreversibility and timing flexibility inherent in the available project should be integrated into the decision calculus. In this paper we investigate the interdependencies of effects from profit taxation and real options. We model an investment decision including an option to invest and an option to abandon. We show that increasing the tax rate can lead to paradoxical tax effects, i.e. may foster an investor's willingness to invest into a capitalized investment. Instead, if we abstract from the possibility to abandon the investment object such paradoxical effect cannot be identified. Determining the after-tax value of the option to enter the investment project with and without an abandonment option we receive a critical cash flow cutoff level. We find that the value of the option to abandon depends on the tax rate and the amount of periodical cash flows. The option value can be increasing or decreasing in the tax rate. We find scenarios with paradoxical tax effects and show that the observed paradoxical effects are due to the presence of the real abandonment option itself. This finding contributes to the stream of literature that explains potential sources of paradoxical tax effects. The generated decision rules are helpful for investors facing risky investment opportunities and for discussing the economic impact of tax reforms. Furthermore, we highlight the overwhelming importance of integrating taxes in typically applied valuation approaches. --investment decisions,real options,tax effects,timing flexibility,,uncertainty

Proposals for a European corporate taxation and their influence on multinationals' tax planning

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Income tax statistics analysis: A comparison of microsimulation versus group simulation

Microsimulation based on income tax statistics may be useful in tax reform discussions. Unfortunately, access to appropriate data is still rather restricted and expensive for ad-hoc analyses, and individual data is often even not available at all. In this paper we take Germany and its data situation as a proxy for many countries? restrictions in terms of tax data availability. Analyzing how much reliability and robustness of results we lose if we employ group simulation instead of microsimulation, we compare both methods. Investigating tax scale effects by the group model leads to very good results. Determining the financial effects of modified tax bases, the deviation from the microsimulation results increases, especially if tax base cuts vary between taxpayers. In addition, we take account of the class of taxpayers with a negative taxable income. Neglecting this class we identify a systematic underestimation of the financial consequences of a modified tax base with the group model assuming a progressive tax scale. If the group simulation data is not arranged according to the taxable income, but rather according to the total amount of income, we also find a tendency towards higher deviations from the microsimulation results. Quantifying the tax revenue effects of alternative tax settings the group simulation model represents a good compromise between the desire to capture the complex reality and the achievable accuracy when facing limited resources and data. Furthermore, for those cases in which group simulation is the appropriate tool, we provide a very simple method to interpolate a suitable income distribution and thereby the tax distribution within the classes. This interpolation makes future estimates of tax revenues a lot easier. We conclude that, although microsimulation in general is the superior approach, a group simulation model remains of interest, especially for analyses of rather old data and cross-country analyses, when sufficiently detailed data for micro analyses is missing.microsimulation; group simulation; tax revenue; personal income tax; tax statistics

Taxation under Uncertainty – Problems of Dynamic Programming and Contingent Claims Analysis in Real Option Theory

This article deals with the integration of taxes into real option-based investment models under risk neutrality and risk averison. It compares the possible approaches dynamic programming and contingent claims analysis to analyze their effects on the optimal investment rules before and after taxes. It can be shown that despite their different assumptions, dynamic programming and contingent claims analysis yield identical investment thresholds under risk neutrality. In contrast, under risk aversion, there are severe problems in determining an adequate risk-adjusted discount rate. The application of contingent claims analysis is restricted to cases with a dividend rate unaffected by risk. Therefore, only dynamic programming permits an explicit investment threshold without taxation. After taxes, both approaches fail to reach general solutions. Nevertheless, using a sufficient condition, it is possible to derive neutral tax systems under risk aversion as is demonstrated by using dynamic programming.

Investment effects of capital gains taxation under simultaneous investment and abandonment flexibility

The influence of capital gains taxes on investment decisions is a central issue of accounting and public finance research. However, the implications of capital gains taxes on investors' willingness to invest in irreversible projects with entry and exit flexibility have not yet been a focal issue. As a result, the effects of taxing capital gains on the interdependencies of investment and divestment decisions have to be identified, especially under timing flexibility. This paper closes this gap by simultaneously analyzing investment timing and abandonment decisions for risky irreversible investment projects with uncertain cash flows under differential tax rates for ordinary income and capital gains. We investigate whether capital gains taxes affect immediate and delayed investment asymmetrically. Furthermore, we investigate the impact of capital gains taxation on the optimal abandonment decision. Performing extensive numerical simulations we find that varying the liquidation proceeds affects the decision whether or not to postpone the investment decision. Higher cash flow volatility favors delayed investment. We find that the introduction of capital gains taxation tends to be harmful for immediate investment. Moreover, we show that taxing capital gains may induce a tax paradox for delayed investment. Depending on the pre-tax parameter setting the future value of delayed investment may even increase in absolute terms for increasing capital gains tax rates. For sufficiently high liquidation proceeds capital gains taxation tends to favor continuation of a project. We find taxing capital gains mainly induces other, but not necessarily less arbitrary distortions than exempting capital gains. --

The Impact of Differential Capital Income Taxation on the Value of Risky Projects

We analyze the impact of differential capital income taxation on the value of risky investment under irreversibility. Under a uniform tax rate, raising the tax rate can either increase or reduce the value of a risky project. Many countries have introduced a separate flat tax on capital income. In contrast to uniform taxation, differential capital income taxation crowds out risky real investment. This dysfunctional effect can neither be corrected by generous depreciation schedules nor by increasing the flat tax rate. This tax discrimination of risky real investment might have contributed to the current crisis.Capital Income Taxation, Flat tax, Risk-taking, Investment decisions, Uncertainty

Does capital tax uncertainty delay irreversible risky investment?

Tax uncertainty is often claimed to be harmful for investments. Capital taxes, such as property and wealth taxes, are particularly exposed to tax uncertainty. Capital tax uncertainty emerges from expected tax reforms, the unclear outcome of future tax audits, and simplified estimates of capital tax bases in investment models. Uncertain returns on investment as well as stochastic taxation contribute to overall uncertainty and may significantly affect investment decisions. Hitherto, it is unknown how capital tax uncertainty affects investment timing. However, it is well known that both uncertainty and capital tax may be harmful for investment and decelerate investment activities. We are the first to study the investment timing effects of stochastic capital taxes in a real options setting with risky investment opportunities. Our results indicate that even risk neutral investors are sensitive with respect to capital tax risk and may react in a surprising manner to a newly introduced stochastic capital tax. As an apparently paradoxical investment effect, we find that increased capital tax uncertainty can accelerate risky investment if such uncertainty is sufficiently low compared to cash .ow uncertainty. In contrast, high capital tax risk delays high-risk innovative investment projects. To reduce unintended consequences of uncertain tax policy, tax legislators and tax authorities should avoid high levels of capital tax uncertainty. Broadening the capital tax base or increasing the capital tax rate induces ambiguous timing effects. Furthermore, high-growth investments are likely to be postponed if they experience a capital tax cut. Since investment reactions upon tax reforms are well-known to affect income and wealth distribution, reliable estimations of the impact of taxes on economic decisions are necessary

Can the CCCTB Alleviate Tax Discrimination Against Loss-making European Multinational Groups?

In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By con-trast, we study the conditions under which one or the other tax system is preferable from the per-spective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves ad-vantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract)Series: WU International Taxation Research Paper Serie

Taxation of risky investment and paradoxical investor behavior

Under uncertainty and irreversibility, real option-based models are widely accepted for assessing investment projects. So far the existing post-tax analyses do not provide a general analytical description of investor reactions towards profit tax rate changes. This paper sets out to fill part of the void. We implement a simple tax system and focus on risky capital market investment and an option to wait. Taxes affect risk-free and risky capital market investment asymmetrically and hence cause distortions. We analytically identify a set of neutral tax rates (tax regimes) that preserve the critical post-tax investment threshold in case of tax rate changes as well as general normal and paradoxical settings. Unlike for other tax paradoxa neither depreciation rules nor loss offset restrictions are responsible for the observed paradoxical reaction. Identifying normal and paradoxical tax regimes can be regarded as a first step to a generalized description of tax effects under uncertainty, both for individual project evaluation as well as for understanding tax effects on an aggregate level. --investment decision,real options,tax paradox,uncertainty