Since its inception in 1969, the Alternative Minimum Tax (AMT) has been utilized to keep taxpayers with higher income from taking advantage of loopholes and paying little or no income tax. This project presents an outline of what the AMT is, how it is calculated, and its history; and also illustrates why the AMT is no longer viable today.

Fairness and justice are important goals and cores values for pursuing an effective taxation system. However, for certain economic and social purposes, our nation implements extensive and long period tax deductions causing constant doubt of the equality of taxation. The tax deduction policies may be equitable to the past, but with the change of the environment, should the government carefully examine whether the result of the tax deductions has affected the fairness, justice and fiscal of the nation. If these deductions have already impaired the welfare of the nation, it is necessary to revise the taxation system and reconstruct the public value. The Legislative Yuan has passed ¡§Fundamental Regulations of Income Tax¡¨ also named ¡§Alternative Minimum Taxation, AMT¡¨ by the end of 2005. It is the first tax regulations passed by the Legislative Yuan in the last two decades. These regulations limit the deductions and compensate the deficiency of unfairness. Thus, this research will focus on taxpayers¡¦ recognition and support of the tax reform after the regulations are executed. Should people promote more tax reforms if outdated deductions exist? Therefore, by combining the questionnaires with the empirical analysis, gathering related discoveries and opinions, this research leads to a practical suggestion and provides a reference with the tax authorities to amend the tax deduction policies. According to the result, the tax experts and professionals agree that AMT meets the needs of tax equality and justice. Besides, nearly 60% of the interviewees think AMT is beneficial to our nation¡¦s finance. However, people recognize that negative effects and problems with the implementation of AMT should be overcome. People also highly expect to modify the outdated tax deductions. In conclusion, our research provides the following suggestions: 1. To thoroughly review and revise the outdated tax deductions promptly. 2. To review and amend the extent of the income tax deductions. 3. The review of investment tax credit is the main purpose of our tax reforms. 4. To prevent the incentive of tax evasion and discuss regularly about the existence or abolition of the AMT.

政府為促進產業發展，採行各項租稅減免措施，導致租稅減免範圍擴增、稅基流失，且減免利益集中少數納稅義務人之租稅負擔不公平情形。自2006年1月1日起施行「所得基本稅額條例」，通稱「最低稅負制」，對於過度享有租稅減免優惠者，課徵一定比率最低稅負，以制衡現行課稅制度所存在的缺失。 本研究利用財政部臺灣省北區國稅局所轄之營利事業2004年至2007年所得稅結算申報資料進行相關分析：最低稅負制之稅收主要係來自享有較多租稅減免優惠之電子資訊業、半導體光電業，及具有較多證期交易所得之金融保險業，且多為大型企業及採會計師簽證申報案件者；實際受最低稅負制影響之營利事業僅約占總申報件數0.18％以下，產業間租稅負擔不公平情形稍獲得改善。最低稅負制實施之第一年，繳納最低稅負稅額主要係加回證期交易所得，且其適用投資抵減稅額之比例亦相當高；在第二年度，營利事業可能較具學習效果，而減少其出售證期交易之所得，並調整免稅所得及投資抵減稅額之適用。另透過實證模型，可知研發費用、出售土地所得及屬會計師簽證申報案件者與有效稅率為負向影響；總資產報酬率與有效稅率為正向影響，最低稅負制會隨著實施時間之久遠，有漸進提高有效稅率之顯著效果。此外，若最低稅負制之稅基納入出售土地所得後，估計2006年及2007年分別可增加稅收約0.41億元及1.08億元，有助提高財稅收入及符合租稅公平原則。 / For improving industrial development, R.O.C. government took various tax concession measures, which resulted in an increasing taxation relief category, a fading taxation basis, as well as the unfair tax burden which results in the tax concession was concentrated on a few specific taxpayers. The Income Basic Tax Act, effective on January 1st of 2006, is generally known as “the Alternative Minimum Tax ” (the AMT), which imposing a fixed-rated minimum tax on those who excessively apply preferential tax concessions, in order to rectify the current inadequacy of taxation system within. This study utilized the corporation income tax return forms data processed by the National Tax Administration of Northern Taiwan Province, Ministry of Finance, R.O.C., from year 2004 to 2007, in order to engage in relevant analysis content as following: The revenue from the AMT is mainly from those who applied more preferential tax concessions firms in, such as, electronics information industry, semiconductor and optoelectronics industry, as well as those firms of finance and insurance industry that high proportion of whose earning is composed from securities and futures capital gains, and most of these are large corporations and verified by CPAs. The percentage of firms actually impacted by the AMT is around 0.18% weak of all income tax return forms, so that the tax burden unfairness is slightly being improved. In the first effective year of the AMT, the minimum obligation tax amount mainly was by adding back the capital gains of securities and futures transactions, in which a high percentage to apply for investment tax credit category. In the second effective year, corporations might have higher learning efficiency, and they reduced their securities and futures capital gains as well as adjusted amounts on income tax concession and investment tax credit categories. Furthermore, by the demonstrated model, we knew that there is a negative correlation between Effective Tax Rate and—R&D expenses, gains on land transactions, and the income tax return forms verified by CPAs; there is a positive correlation between Effective Tax Rate and Totaled Assets Rate of Return. We also learned that the AMT would gradually increase the conspicuous impact on Effective Tax Rate as time goes by. In addition, it is assumed that the AMT subsumed gains on land transactions under the income tax basis, the tax revenue estimated may increase approximately 0.41 hundred million and 1.08 hundred million dollars in year 2006 and 2007 respectively, and this tax assumption may be beneficial for increasing tax revenue and on the fair taxation principle.

本研究探討美國最低稅負制與個人非現金捐贈行為的關係。1993年時美國對於最低稅負制做稅制上之修正，將非現金捐贈之扣抵稅額以購入成本計算修改為以公平市價計算；此一稅制上的改變，正提供一個相當適合研究的時機，可以對非現金捐贈部分進行深入了解。所以本研究以美國內地稅務局在1989年及1995年的橫斷面個人申報所得稅資料庫，並採用差異中的差異分析法，來探討最低稅負制度對於非現金捐贈行為的影響，並加入可能會影響非現金捐贈的解釋變數，包括：所得、財富、年齡、婚姻、扶養親屬人數等變數。 經實證結果發現，最低稅負制度對於非現金捐贈行為效果顯著且正向，即代表1993年美國稅制從以購入成本計算扣抵額修正為以公平市價計算扣抵額，此政策能夠誘發民眾對非現金捐贈金額增加，至於解釋變數上經實證結果發現，當所得及財富越高之納稅人，對非現金捐贈金額越高，在婚姻及年齡方面，已婚者及年齡較大者在捐贈金額上為多；至於扶養親屬人數方面，對於捐贈金額影響是不顯著的。 / This thesis is focus on the relation of the Alternative Minimum Tax (AMT) and Non-Cash Donations (NCD). The America amended the AMT in 1993. It changed the NCD-deduction calculation from cost to fair value. This revolution gave a good time for researching about NCD. So, this report took the individual tax database from Internal Revenue Service (IRS) in 1989 to 1995 for example. And used Differences-in-Differences (DID) way to discuss the infect of NCD from AMT. Besides, this research added some NCD variables including of income, wealth, age, marriage, numbers of dependent. The empirical result showed that the AMT had obvious and positive effect on NCD behavior. It represented that the AMT policy change in 1993 could cause the NCD increase. The more income and wealth had more NCD amount. People married and elderly people offered more donation than single and young. The numbers of dependent had no obvious effect on donation.

本研究主要目的，即在以迴歸模型量化依最低稅負制納稅企業的投資行為，比較我國依最低稅負制納稅及依一般稅率納稅企業的國內投資金額，進而分析政府在實施新稅制下課徵稅收，是否影響我國企業的投資意願，了解不同產業類別受最低稅負制之衝擊或影響程度。擬以Menzel(1990)研究所採用的模型及假設，以本國國內外企業為研究對象，結果顯示企業的資產或所得兩變數對國內投資有正向影響。其次探討最低稅負制對於企業投資所減少的幅度：於本研究假設下，並無顯著證據證明新稅制會使企業減少其國內投資金額；換言之，最低稅負制政策並不至於顯著影響企業的投資決策。 最後針對企業、政府等部門提出建議供參。首先，針對企業部門而言，無論是國內企業或是跨國投資企業，其對國內、外之投資都不因是否依新稅制納稅而有顯著的變化，表示新稅制並不會造成扭曲國內企業與跨國投資企業於國內投資之決策，當然也不至於影響國內資本的累積，企業於作投資決策的同時，毋須擔心適用不同的稅制是否產生不同的租稅負擔。而對政府部門而言，就本研究所設定的假設條件下，亦證實了最低稅負制不至於影響我國企業的投資決策，對國內投資的影響不大，此結果無疑為近年來國內所推動的新稅制，奠定了強而有力的基礎，政府藉由推行最低稅負制作為進行財政改革的短期方案之一，除可發揮一稅制所應具備的所得重分配效果，使各產業間租稅負擔更趨公平化，未來對於財政部所期望的「配合行政院財政改革方案之中、長期措施，逐步推動實施稅制改革方案，以期達成妥善調整稅制結構、追求稅收穩定與適足、租稅公平與效率」等目標而言，將有莫大的助益。 / The purpose of this dissertation is to document and quantify the impact of investment incentives under the alternative minimum tax (AMT) on domestic corporations’ investment decisions. On the one hand, this research addresses whether new domestic capital investment by AMT corporations is less than that of regular tax corporation; on the other hand, it also examines whether multinational AMT corporations invest less in Taiwan than domestic AMT corporations. With the same models and assumptions used by Mezel’s research method, I find that multinational AMT corporations, compared with multinational corporations paying with regular tax policy, do not exhibit significantly higher levels of foreign investment. This consequence shows that the AMT rules do not significantly influence multinational corporations either to invest less in Taiwan or to substitute foreign for domestic investment. In other words, there is weak evidence that the AMT rules do significantly influence the domestic corporations’investment decisions. The last part of my essay provides some suggestions for the domestic corporations and the relative departments of the government at the same time. First, since the results of this study indicate that, in general, the AMT rules do not affect the investment dicisions of AMT corporations by causing them to invest less in Taiwan, the domestic corporations are not worried about that new tax policy distorts the investment decisions. Further, the results do not indicate any evidence that corporations shift their investments overseas at the expense of domestic ones, which means the incentives described in the analytical research do not exist. Therefore, for the government, policymakers should carefully consider whether any new tax reforms are necessary, such as AMT rules, for pursuing the goals of taxiation stability and adquency in the long run.

本研究主要在探討最低稅負制實施後，對我國上市櫃電子業稅負影響情況為何。不同於以往文獻以營利事業所得稅申報資料來進行模擬分析，本研究以財務報表之所得稅附註資料進行模擬設算。不用營利事業所得稅申報資料進行模擬乃因該資料取得不易，並非一般投資大眾所能獲取之資料，本研究乃嘗試使用財務報表之所得稅附註資料進行模擬設算，希望能模擬出最低稅負制之實施對電子業之影響情形。此外，本研究利用模擬設算之基本稅額與一般所得稅額之差額當成依變數，建立一條迴歸式，希望能從中發現最低稅負制實施後，受影響之公司具有哪些特性，以供投資人在選擇投資標的時有所參考。 本研究經過篩選後，對我國上市櫃電子業的其中206家公司進行民國93年及94年的模擬設算。其設算結果為平均每年每家公司會增加1,000多萬元的稅負，而約有3成的公司將會受到影響。實證結果亦證實最低稅負制實施後，對於我國上市櫃電子業確實有明顯的租稅負擔。迴歸結果則發現，對於股東可扣抵稅額愈小、研發費用愈高、獲利能力愈佳及公司規模愈大之公司會有較明顯的租稅負擔。此種情形是否對這些公司之競爭力造成不利影響，非常值得關心。此外，電子業競爭相當激烈，必須投入相當多的研究發展費用與相關的重大投資，而經本研究結果也證實，研發費用愈高的公司，在最低稅負實施後，將補繳愈多的稅額，未來公司在從事這些支出時，應更加審慎評估。 / This study investigates the effects that the implementation of Alternative Minimum Tax (AMT) has on our electronic industries publicly listed in Taiwan Stock Exchange. Past studies often utilized the income tax reported by profit-seeking enterprises; nevertheless, these data are not accessible to the public. In view of this, the current study attempts to simulate calculating the appendix of income tax in financial statements, with an aim to simulating the impacts that implementation of AMT exerts on the electronic industries. Furthermore, as the difference between the simulated Basic tax and Regular tax is the dependent variable, established is a regression model, with which the characteristics of the companies influenced by the implementation of AMT can be identified, so that investors can refer to when they choose investing targets. After the sampling, the simulating calculation on two years, i.e. 2004 and 2005 has been conducted among 206 companies among the publicly listed electronic industries. The results of calculation demonstrate that each company would have more than ten million taxes each year and approximately thirty percent of the firms will be influenced by the implementation of AMT. Empirical results also confirm that there will be significant tax burdens after AMT takes effect. Moreover, the outcomes of regression analysis indicate that more salient tax burdens will be imposed upon the firms with larger size, smaller shareholder deductible tax, higher research funds, and more profitability.

本研究主要在探討近年來兩大租稅改革：兩稅合一制及最低稅負制之施行對上市公司外資持股比率之影響，是否降低外資持有我國上市公司股票之意願，影響我國企業的股權結構。 兩稅合一制施行後，消除股利所得之重複課稅，國內法人股東與自然人實質稅負減輕；但根據所得稅法第七十三條之二規定，非中華民國境內居住之個人、在中華民國境內無固定營業場所及營業代理人之營利事業，其獲配股利所含之稅額，不得扣抵其應納稅額，外資無法享受股東可扣抵稅額消除重複課稅的好處，外資在台投資實質總稅負仍維持為40%，較境內自然人股東之實質稅率6%~40%為高，股東可扣抵稅額比例愈高，外資損失越大。再者，最低稅負制施行主要影響對象為外資持股最多的電子業，且最低稅負制之施行對於公司補繳之稅負，外資股東也無法享受股利抵稅權。故可推論兩稅合一制、最低稅負制之施行及股東可扣抵稅額與上市公司外資持股比率應呈負向關係。 本研究之樣本為民國85年到民國95年及最低稅負制前、後之台灣上市公司。主要實證結果彙整如下： 1、兩稅合一制之施行及股東可扣抵稅額與上市公司外資持股比率呈負向關係，最低稅負制之施行與上市公司外資持股比率呈正向關係，但其效果應為股價指數之影響所致而非最低稅負制之施行；又最低稅負制施行後，外資仍偏好持有公司有效稅率低於10%之股票。 2、另外以民國93年到民國95年資料額外檢測，最低稅負制下限制投資抵減金額之效用，推論投資抵減金額在最低稅負制施行後與上市公司外資持股比率應呈負向關係，實證結果為負向關係但不顯著。 / The objective of this study is to examine whether the implementation of the Imputation Tax System and Alternative Minimum Tax System will affect the willing of foreign investors to invest in listed companies. The sample of this study consists of firms listed in the Taiwan Stock Exchange from 1996 through 2006. The empirical results in this research are summarized as follows: 1、 The implementation of the Imputation Tax System and a firms' imputation tax credit ratios have a negative impact on the percentage of foreign ownership in listed companies, but the implementation of Alternative Minimum Tax System has a positive impact on that. We conduct further examination and find the increasing effect of the percentage of foreign ownership is more rely on the effect of stock index than that of the implementation of Alternative Minimum Tax System. Further, foreign investors still prefer to invest in listed companies whose effect rates are lower than 10%. 2、With the implementation of Alternative Minimum Tax System, the use of investment tax credit was restricted. The empirical result of this study shows that after the implementation of Alternative Minimum Tax System, the investment tax credit has a negative but not significant impact on the percentage of foreign ownership in listed companies.

Personal Income Taxation in the United States of America on Federal and State Level The main aim of this thesis is to show the complexity of personal income taxation in the United States of America, by explaining the system of taxation and the main changes of the personal income taxation for the last ten years, under the influence of Economic Growth and Tax Relief Reconciliation Act, which was passed in year 2001. The system of this work is divided into four main parts. The role of the first part is to show the history of the taxation which led to the today's personal income taxation system, followed by second part with the explanation of system of the personal income tax of individuals, shown in details with the differentiated statuses of subjects, deductions, progressive tax brackets and tax credit for the taxpayers. The third part shortly describes personal income taxation system in the state of Maryland to show a different layer of the taxation system with its rules. The fourth part reflects the changes of the tax system in the last decade, which were brought by EGTRRA, with its affects on various groups of taxpayers and the effect on the economy of the country. These four parts together should create a picture of the system and its functioning of the personal income taxation in the United States of America.