Since 1982, 40 states and the District of Columbia have offered amnesty programs. In December 1990, the Multistate Tax Commission (MTC) established the National Nexus Program (NNP), a permanent tax amnesty program. Prior literature has focused on amnesty programs and has shown that these programs do little to increase tax revenues and compliance when increased future enforcement is absent. I examine the impact of the NNP on state corporate tax revenues. From 1991 through 2008, state corporate tax revenues are significantly lower than revenues from 1973 through 1990. Further, I find that states joining the NNP have a negative impact on state corporate tax revenues; however, the initial year impacts revenues differently than all other years. The implementation of Financial Interpretation No. 48 (FIN 48) provides another reason for firms to disclose in the NNP. Specifically, to reduce the FIN 48 liability on financial statements, firms may disclose in the NNP. The primary purpose of FIN 48 is to increase the comparability and transparency of financial reporting of income taxes through requiring consistent recording and disclosure across firms. Although FIN 48 has been replaced with the Accounting Standard Codification 740-10, I continue to refer to FIN 48 because of familiarity. I examine whether FIN 48 resulted in an increased number of firms entering the NNP by state. I also investigate whether FIN 48 impacted the dollar amount of NNP disclosures by state. Using aggregated proprietary data obtained from the NNP and matched with hand-collected data from 1994 through 2008, I find that FIN 48 has a positive effect on the number of NNP disclosures but has no impact on the dollar amount of disclosure. Rather, for states joining the NNP, the dollar amount of disclosure tends to be driven by the states adopting combined reporting requirements. In examining publicly-traded firms on an individual case basis, I find that economic presence and voluntary compliance initiatives predominately have a negative effect on the dollar amount of disclosure while FIN 48 has an insignificant impact.

In this study, I examine how firms change their tax avoidance and financial reporting following large tax settlements. I find that firms decrease tax avoidance following large settlements and this effect is concentrated among firms under-reserved for the settlement for financial accounting purposes. Additionally, my results suggest firms learn from tax examination resolutions in a way that affects their financial reporting over the tax account. Finally, I find that the effect of large settlements also spills over to firms within the same auditor network. This study provides context to the tax authority's efficacy in deterring tax avoidance and highlights its role in the financial reporting process.

This study examines the determinants of tax aggressiveness. I utilize the unrecognized tax benefits (UTB) disclosed by the adoption of Financial Interpretation No. 48, “Accounting for Uncertainty in Income Taxes” (FIN 48) to proxy for firms’ tax aggressiveness. I hand collect UTB disclosures for 562 calendar year-end firms in the S and P 1500. Controlling for firms’ incentives and abilities to engage in aggressive tax positions (tax factors) and firms’ discretion over recognizing the financial reporting benefits of aggressive tax positions, I examine whether firms’ level of aggressive tax positions is influenced by (1) financial reporting aggressiveness, (2) choice of auditor, (3) analyst coverage, and (4) corporate governance quality. Using ordinary least squares regression, I examine the determinants of firms total UTB and its permanent and temporary components. I find that UTB and its permanent component are positively associated with firm size, presence of foreign operations, research and development activity, selling, general and administrative activity, firm value, and the probability that the firm engages in tax shelter activity. However, the temporary component is only increasing in firm size. Also, I find that UTB and its permanent component are positively associated with firms engaging in financial reporting aggressiveness and increasing auditor provided tax services, but negatively associated with analyst coverage, while the temporary component is only positively associated with financial reporting aggressiveness. Finally, I split the sample based on firms’ use of discretion over recognizing the tax benefits of aggressive tax positions prior to FIN 48 adoption. I find that firms which aggressively recognize tax benefits prior to FIN 48 adoption (i.e. firms that increased UTBs at FIN 48 adoption) have UTBs that are positive and significantly associated with (1) the probability that a firm engages in tax shelter activity, (2) auditor provided tax services, and (3) their record of using last chance earnings management to meet or beat analyst forecasts. These associations are not significant for firms that did not aggressively recognize tax benefits prior to FIN 48 adoption, suggesting that firms’ financial reporting aggressiveness is positively associated with firms’ level of tax aggression.

abstract: This study examines determinants of the length of conflict between firms and the Internal Revenue Service (IRS). I hand collect firm disclosures of the number of years open for federal tax purposes to create a proxy for IRS conflict length. Using this proxy, I find evidence that larger firms, firms with more book-tax differences, and firms facing higher IRS attention and audit probabilities are associated with lengthier IRS conflicts. In contrast, firms with higher deferred tax assets, intangibles, return on assets, and firms disclosing participation in the Compliance Assurance Process program are associated with shorter IRS conflicts. Additional analyses show IRS conflict length is positively associated with manager risk preferences and poor tax accounting quality. I also find lengthier IRS conflicts are associated with higher future tax risk and higher audit fees. Tax controversy is becoming increasingly important for firms but remains relatively understudied. I provide empirical evidence on cross-sectional variation in IRS conflict length. / Dissertation/Thesis / Doctoral Dissertation Accountancy 2020