This dissertation contains two essays. The American Jobs Creation Act of 2004 was intended to stimulate the economy by expediting the repatriation of foreign earnings and requiring that those repatriations be invested in domestic operations. The first essay investigates (1) who repatriated foreign earnings under the provisions of the Act, (2) why firms repatriated and (3) what the firms did with the repatriated funds. The first essay identifies 364 firms that repatriated approximately $283 billion under the Act. The only significant increase in expenditures for the repatriating firms was for stock repurchases, an expenditure specifically prohibited under the Act. Firms appear to have repatriated foreign earnings to take advantage of the tax savings without achieving the Act‟s intended objective of increasing domestic investment. The second essay builds on recent research that evaluates the lock-out effect of the U.S. international tax system. The second essay studies the factors associated with the lock-out effect of the U.S. international tax system. Recent evidence suggests that firms that have reached their optimal level of investment in foreign operations will accumulate foreign earnings abroad in financial assets to avoid recording the associated U.S. tax liability. However, prior research has not disentangled the difference between firms that permanently reinvest their foreign earnings for reinvest into operations versus firms that classify their foreign earnings as permanently reinvest to indefinitely defer the recognition of the associated U.S. tax liability. Using a hand-collected sample of firms that repatriated under the one-time tax holiday, I find that the firms were classifying their foreign earnings as permanently reinvested to avoid recognizing the associated U.S. liability before and after the one-time tax holiday. Also, during the tax holiday firms brought back significant amounts of cash previously classified as permanently reinvested foreign earnings suggesting that the earnings were not retained abroad for foreign reinvestment. The results of essay two are consistent with theoretical predictions that firms repatriating under the Act classified their foreign earnings as permanently reinvested to avoid recognizing the associated U.S. tax liability.

This dissertation examines firms’ reactions to two changes in tax law intended to increase dividend payout and capital investment, the Job Creation and Worker Assistance Act (JCWAA) of 2002 and the Jobs Growth Tax Relief Reconciliation Act (JGTRRA) of 2003. Chapter IV assesses whether firms assuage agency conflicts between management and shareholders created by changes in individual-level taxes on dividends, focusing on the impact of board independence on changes in management compensation and dividend policies. Data analyses suggest that greater board independence mitigates the effects of both CEO stock and option holdings on dividend increases. Additionally, firms appear to implicitly dividend-protect options through increased cash compensation, effectively reimbursing CEOs for decreases in option value. Firms that did not increase dividends in the first year following the passage of JGTRRA decreased option grants to induce greater future dividend payouts. Chapter V examines the relation between contemporary dividend increases and future earnings around JGTRRA. Specifically, I investigate whether firms increase dividends in response to shareholder demands, and I examine the market reaction to preand post-JGTRRA dividend changes. In addition, I focus on the dividend policies of growth firms, testing between firm maturation (Grullon et al. 2002) and tax-based explanations. Results suggest that dividends are less explanatory as to future earnings in the post-JGTRRA period. Post-JGTRRA dividend increases by growth firms are consistent with tax motives rather than firm maturation because growth firms paying dividends have greater investment in the post-JGTRRA period. Chapter VI examines the effects of JCWAA and JGTRRA provisions enacted to increase business capital expenditures through increased depreciation allowances. I develop a model to predict what firms’ capital expenditures would have been in the absence of these acts, comparing the actual and predicted values. I find firms significantly increased purchases of qualified assets but decreased nonqualified asset purchases, netting only a marginal overall increase in capital expenditures. Finally, I examine the impact of these acts on leasing transactions, finding that low marginal tax rate firms significantly increased use of operating leases following the passage of JCWAA, whereas firms with higher MTRs decreased lease transactions.

Federal and state income tax laws pertaining to forest landowners are examined. Income tax liabilities are calculated for hypothetical forest landowners in two income brackets across the 41 states in the U.S. which impose a comprehensive income tax. The income tax liability is calculated to illustrate the effects of differential state tax treatment on a representative forest landowner with two different income levels ($50,000 and $110,000) who harvests $200,000 worth of timber in a given tax year. After-tax land expectation values for a forest landowner are also calculated to illustrate the effects of tax planning on returns to timber investment over time. Twenty-eight states utilize the federal adjusted gross income (AGI) as their tax base. Thirty-three states provide a personal exemption in the form of a credit or deduction. A standard deduction is allowed in twenty-six states. The minimum tax rates range from zero percent in Delaware to six percent in Minnesota and North Carolina. Maximum rates range from 4.5 percent in Connecticut to 11 percent in Montana. Four states allow a capital gains exclusion while two others have maximum capital gains rates that are lower than the highest ordinary state tax rate. In the South, landowners have the lowest state tax liability in Louisiana and the highest liability in North Carolina for both income levels. In the Midwest and Northeast, landowners in the medium income ($50,000) level have the lowest tax liability in North Dakota and the highest in Minnesota. Landowners in the high income level ($110,000) have the lowest tax liability in Pennsylvania and the highest liability in Minnesota. In the West, medium-income level Idaho and Montana landowners have the lowest and highest state tax liabilities, respectively. High level income landowners have the lowest liability in Arizona and the highest liability in Montana. The effects of tax planning on a forest landowner's potential revenues are calculated using land expectation methodology. Six different scenarios are used to examine the effect of common omissions and mistakes made by a typical landowner. In each successive scenario, the landowners forego certain tax benefit(s) that, in turn, lower their LEV. Different representative state tax rates and discount rates are used as a sensitivity analysis to find a range of values that could potentially occur. The treatment of timber revenue as an ordinary gain provides the largest decline in land expectation value in most cases. / Master of Science

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The purpose of this paper is to propose an alternative to the current U.S. corporate tax system. This paper analyzes the qualities of a “good” tax, theories of international neutrality, the two major international tax systems, and how the U.S. hybrid system falls short of these criteria. The current U.S. tax system is inefficient and overly complex. This paper will show that the U.S. tax system has major shortcomings, and will explore the popular proposals for reform. After demonstrating the strengths and weaknesses of the proposals, this paper concludes that a territorial income tax system with certain protections for income shifting is ideal for U.S. corporations.

1 Summary The topic of this diploma thesis is taxation of companies' income. The aim of the thesis is to describe and introduce question following from the application of income tax act to the companies. The accent is put on the taxation of dividends. Taxation of companies' income plays a vital role in decision making process of domestic as well as foreign investors where to invest their finances. The thesis is focused on the analysis of Czech tax legislation made through a comparison with the Slovak basic tax legislation. The first chapter deals with the delimitation of core concepts related to the taxation of incomes. It focuses on the income tax act, aspect of natural person's taxation and artificial person's taxation. The second chapter is concerned of characteristic related to taxation of personal companies and stock corporations. The third chapter presents basic terms of dividend's taxation on the domestic as well as on the international level such as the core concept of dividend or tax domicile. The fourth chapter examine the European tax legislation and harmonization of tax legislation within the European Union. The fifth chapter illustrates taxation of domestic payment of dividends and its characteristics related to the natural and artificial person as recipients of dividends. The sixth chapter...

The purpose of my thesis is to analyse tax legislation for sportsmen. The reason for my research is that sport in our era is not only leisure time activity, but also can be very significant source of income for athletes, sport institutions and other subjects, that must pay taxes. I have also very close relationship to sport, and sports enviroment, so it is consequent, that I choose to connect sport, and subject of my study, wich is law of course. The thesis is composed of seven chapters, each of them dealing with different aspects of tax legislation and sports enviroment. Chapter One is introductory and defines basic terminology used in the thesis, such as sportsman, sport, sports associations. It also contains subchapters wich deals with history, legal form of activity of athletes (point of view on professional athletes in individual sports and collective sports), and the comparison of this problematics with other european countries, and European Union. Chapter Two analyzes critical judgment of czech Supreme administration law court about legal form of activity of athletes. It concludes with suggestion, that professional athletes in collective sports could be besides employees also self-employed persons. Chapter Three is subdivided into four parts and provides an outline of taxation of athletes. Part one...

University of Technology, Sydney. Faculty of Engineering. / This research has analysed the economy-wide impacts of carbon tax as a policy option to reduce the rate of growth of carbon-dioxide emissions from the electricity sector in Australia. These impacts are analysed for energy and non energy sectors of the economy. An energy-oriented Input–Output framework, with ‘flexible’ production functions, based on Translog and Cobb-Douglas formulations, is employed for the analysis of various impacts. Further, two alternative conceptions of carbon tax are considered in this research, namely, based on Polluter Pays Principle (PPP) and Shared Responsibility Principle (SRP). In the first instance, the impacts are analysed, for the period 2005–2020, for tax levels of $10 and $20 per tonne of CO2, in a situation of no a-priori limit on CO2 emissions. The analysis shows that CO2 emissions from the electricity sector, when carbon tax is based on PPP, would be 211 and 152 Mt, for tax levels of $10 and $20, respectively (as compared to 250 Mt in the Base Case scenario, that is, the business-as-usual-case). The net economic costs, corresponding with these tax levels, expressed in present value terms, would be $27 and $49 billion, respectively, over the period 2005-2020. These economic costs are equivalent to 0.43 and 0.78 per cent of the estimated GDP of Australia. Further, most of the economic burden, in this instance, would fall on the electricity sector, particularly coal-fired electricity generators – large consumers of direct fossil fuel. On the other hand, in the case of a carbon tax based on SRP, CO2 emissions would be 172 and 116 Mt, for tax levels of $10 and $20, respectively. The corresponding net economic costs would be $47 (0.74 per cent of GDP) and $84 (1.34 per cent of GDP) billion, respectively, with significant burden felt by the commercial sector – large consumers of indirect energy and materials whose production would contribute to CO2 emissions. Next, the impacts are analysed by placing an a-priori limit on CO2 emissions from the electricity sector – equivalent to 108 per cent of the 1990 level (that is, 138 Mt), by the year 2020. Two cases are analysed, namely, early action (carbon tax introduced in 2005) and deferred action (carbon tax introduced in 2010). In the case of early action, the analysis suggests, carbon tax of $25 and $15, based on PPP and SRP, respectively, would be required to achieve the above noted emissions target. The corresponding tax levels in the case of deferred action are $51 and $26, respectively. This research also shows that the net economic costs, in the case of early action, would be $32 billion (for PPP) and $18 billion (for SRP) higher than those in the case of deferred action. However, this research has demonstrated, that this inference is largely due to the selection of particular indicator (that is, present value) and the relatively short time frame (that is, 2005–2020) for analysis. By extending the time frame of the analysis to the year 2040, the case for an early introduction of carbon tax strengthens. Overall, the analysis in this research suggests that an immediate introduction of carbon tax, based on SRP, is the most attractive approach to reduce the rate of growth of CO2 emissions from the electricity sector and to simultaneously meet economic and social objectives. If the decision to introduce such a tax is deferred, it would be rather difficult to achieve not only environmental objectives but economic and social objectives as well.