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This paper investigates the significant increase in S corporation banks converting to C corporations following the 2017 Tax Cuts and Jobs Act (TCJA) and the shift in motivations behind these conversions.

The paper uses bank-level panel data from Federal Deposit Insurance Corporation (FDIC) Call Reports to analyze the determinants of S bank conversions after the TCJA, comparing post-TCJA conversion trends with pre-TCJA trends utilizing an ordinary least squares (OLS) and logistics model.

The study finds that post-TCJA conversions are primarily driven by financially stable banks seeking improved tax conditions and relaxed shareholder restrictions as C corporations. This contrasts with pre-TCJA conversions, which were predominantly driven by financially distressed S corporation banks seeking new equity capital to maintain solvency.

The findings necessitate a comprehensive reconsideration of the Subchapter S status' sustained relevance for smaller institutions, especially in light of the comparative benefits now offered by the C corporation status post-TCJA. The results underscore the importance of ongoing academic investigation to deepen the understanding of the evolving fiscal landscape's effects on community banks, thereby contributing to the knowledge of the resilience and health of the US economy.

This research nudges policymakers and regulators to contemplate the ongoing relevance and advantages of the S corporation status. Given the substantial benefits conferred by the C corporation status in the post-TCJA environment, this study suggests that retaining the S corporation status may not offer the same appeal for smaller community banks as it once did.

This paper contributes to the broader understanding of the impact of tax policy on businesses' organizational choices, particularly in the banking industry and emphasizes the need for a comprehensive review of the S corporation status to assess its ongoing applicability in fostering small and community-focused financial institutions in light of the evolved corporate tax landscape.

The purpose of this paper is to empirically test legitimacy theory by comparing the corporate social responsibility (CSR) disclosures of tax aggressive corporations with those of non‐tax aggressive corporations in Australia.

A unique sample of 20 Australian corporations accused by the Australian Taxation Office of engaging in tax aggressive activities during the 2001‐2006 period was hand‐collected. These 20 tax aggressive corporations were then matched with 20 non‐tax aggressive corporations (based on industry classification, corporation size and time period). This process generated a choice‐based sample of 40 corporations for empirical analysis. Using content analysis techniques, financial accounting data were gathered from the Aspect‐Huntley database and CSR disclosures were individually measured for each corporation in the sample. Various statistical techniques were then used (e.g. paired sample statistics, Pearson correlation analysis and ordinary least squares regression analysis) to test legitimacy theory.

Overall, the empirical results consistently show a positive and statistically significant association between corporate tax aggressiveness and CSR disclosure, thereby confirming legitimacy theory in the context of corporate tax aggressiveness.

The paper provides empirical evidence in support of legitimacy theory as an explanation for why specific corporations disclose more CSR‐related information than others. Additionally, to the best of the authors' knowledge, the paper is one of the first to document an empirical association between corporate tax aggressiveness and CSR in the literature.

This paper suggests that the proliferation of highly sophisticated corporate tax shelters has been a major reason for the decline of corporate income tax as a percentage of GDP and of total Federal receipts. Many of these shelters have extended beyond solid tax planning and into the realm of subversion. The controversy surrounding possible remedies for these abuses is just as lively as the debates surrounding the tax shelters themselves. This article explores the nature of a variety of tax shelters in an effort to illustrate the insidious nature of the corporate tax shelter problem and then discusses solutions, both legislative and nonlegislative, designed to curb these abuses.

The purpose of this paper is to warn policymakers, by examining certain aspects of policy, possibly overlooked, against overestimating the power of corporate social responsibility (CSR) idea to inhibit tax avoidance by the multinationals.

By examining, with narrative and qualitative means, existing insights such as ones with regard to the inefficiency of the public sector.

Implication that the following three factors could not co-exist: promoting CSR activities, which include moral tax payment by the multinational corporations; requiring the multinationals to refrain from immorally reducing effective tax rates and keeping the current level of public utilities.

To sound an alarm to tax policymakers who are particularly addicted to the base erosion and profit shifting by multinational enterprises recently by this new implication mixing up with existing findings with regard to the CSR idea and cost-inefficiency character of the public sector activities.

From time to time we have had occasion to refer to earnings per share in terms of the new ‘imputation’ system of company taxation. This is a somewhat complex system and we have asked our Financial Correspondent to explain in some detail what is involved. In attempting an explanation, he has found it useful to compare the present system not only, as others have done, with the preceding corporation tax system inaugurated by Mr Callaghan in his 1965 Budget, but also with the earlier profits‐cum‐ income tax system. There are of course many other systems of company taxation, but for purposes of explanation a comparison of the three systems — profits‐plus‐income tax, the Callaghan‐type corporation tax, and the imputation system—is sufficient.

This paper is an effort to demystify tax havens – what they mean, what they offer and why they are harmful. It offers a detailed analysis of abusive tax planning by multinational corporations, involving the use of tax havens, shedding light on how corporations use “egregious” tax-sheltering techniques right from their incorporation to avoid payment of income taxes. The paper also discusses global efforts against the phenomenon and policy recommendations.

The paper brings together definitions from various sources to accurately define and identify tax haven economies. The key contribution of the paper is to diagrammatically explain the use of tax havens by MNCs right from the time they are incorporated. It explains how every big and small corporate decision is motivated by the desire to save taxes and how tax havens come in handy for such corporations.

This paper finds that base erosion and profit shifting (BEPS) is a pervasive phenomenon, largely due to the suppliers of tax haven operations. Here, corporate decisions are divided into strategic and operational and further subdivided into investing, operating and financing activities, and provide real-life corporate examples of how tax havens fit into almost every corporate decision. This is the key contribution of the paper.

This is a review paper that sums up knowledge about tax havens and their use by MNCs. It does not, however, use empirical data to corroborate its findings. It would be interesting to see empirically whether MNCs with greater tax haven operations actually have lower effective tax rates.

The paper can provide a framework for designing tax policies in a manner that geographical arbitrage can be minimized. It can enable formulation of the necessary incentive structures in the form of penalties, rewards and the like for both the users and providers of tax haven services to curb massive base and profit shifting out of high-tax countries.

The paper is one small step in the direction of bringing about equality in tax payments, i.e. to align real tax systems with the canon of equality that Adam Smith once dreamt of. Taxes should be progressive in nature, implying that the amount of taxes paid should increase with one’s income. However, with the advent of offshore financial centres and egregious tax planning techniques, only the smaller corporations and middle-class individuals end up paying taxes, while the rich and bigger corporations get away easily.

The paper explores in detail the manner in which MNCs use, rather exploit, regulatory loopholes in tax systems of different countries to save on tax payments. By shifting their tax base from one country to another, MNCs not only hamper Treasury collections but also breed disrespect for the global tax system. The paper can help in designing tax laws in tune with such corporate motives.

The purpose of this paper is to examine the profitability of different ownership forms of banks. The two ownership forms are corporations that elect to be taxed as a Subchapter S corporation (limited to 100 shareholders) as opposed to those corporations that do not make this election. The impact this election has on the dividends paid to the investors is examined.

This paper uses Call Report Data on Wisconsin banks as collected by SNL Securities as its database. The research methodology uses two measures of performance: dividend ratio and accounting return on assets (ROA). The dividend ratio is defined as dividends as a percentage of net income (dividends/net income). Accounting return on investment is net income as a percentage of total assets (net income/total assets) and is a measure of profitability. A number of regressions were created with these as the endogenenous variables and a heteroskedasticity‐corrected ordinary least squares (OLS) model was used.

Subchapter S banks were found to be more profitable (as measured by ROA). However, when taxes are taken into account, there is no practical difference in profitability between the two types of corporate structure.

By limiting the analysis to Wisconsin, a single state, confusion that may be caused by both state laws (personal and corporate) and local corporate cultures is avoided.

The practical implications of this research can guide the federal government in determining whether this form of stock ownership is a device that reduces or increases federal tax revenues. It can also provide insight to the stockholders of these banks into the differences in profitability these corporate forms offer.

While earlier literature has reviewed the concept of Subchapter S corporations and its theoretical impact, little research has been conducted that tests the actual results. Due to the private nature of the corporate form (these types of corporations are often not publicly traded and have no incentive to reveal private financial records), this original research is the result of the public nature of banks that provide a rich dataset for us to examine.

This paper addresses the role of corporate social responsibility (CSR) performance as a potential mechanism for reducing firms' likelihood of engaging in tax aggressiveness (TAG). The paper also contributes to the existing literature by addressing the moderating effect of national cultures on the link between CSR performance and corporate TAG.

The focus is placed on an unbalanced panel of 2,696 companies distributed in 30 countries and seven economic sectors over the period of 2002–2014.

The results provide support for those companies achieving high corporate social performance (CSP), corporate environmental performance (CEP) and corporate governance performance (CGP) being less likely to engage in aggressive tax practices. Finally, the results identify some national cultural dimensions moderating the link between disaggregated measures of CSR performance and firms' TAG.

The difficulty of accessing CSR and TAG data for non-listed companies could bias the data set towards a compliant company profile because of the higher visibility. In addition, the use of effective tax rates to examine firms' TAG should be interpreted with some caution.

The paper's findings provide unique and useful information for company stakeholders and managers aiming to address the factors that enhance firms' incentives to engage in aggressive tax practices.

This paper addresses the multidimensional nature of CSR performance by analysing the links between CSP, CEP and CGP and corporations' TAG. Furthermore, the research addresses the way in which national culture moderates the links between disaggregated measures of CSR performance and corporate TAG.

The purpose of this paper is to empirically test whether corporates, via publicly disclosed sentiment and in response to government initiatives such as domestic corporate tax reform measures that address transparency, are beginning to view tax as a fourth dimension of corporate social responsibility (CSR).

To determine whether corporate attitudes towards tax are changing, representations about the corporate entity by a variety of stakeholders and through numerous channels were analysed using Leximancer software. These representations were in response to four distinct Australian domestic tax reform measures instituted during and subsequent to the Australian Government Senate Inquiry into corporate tax avoidance. The use of Leximancer, a data-analysis and mapping software that automates the coding of document text, delineates concepts and identifies themes, is well suited to the nature and size of the data used (Lodhia and Martin, 2011) and ensures the validity and reliability of the results (Dumay, 2014).

This paper provides evidence on the efficacy of global and domestic tax-reform measures that target tax avoidance through transparency. This is demonstrated by a progressive change in corporate attitudes towards tax and suggests a transition, albeit nascent, from the aggregate view to the real entity view of a corporation. As such, this study provides evidence of the inception of a corporate conscience when it comes to tax, whereby tax is instituted as a fourth dimension of CSR.

Using a theoretical framework which adopts the historically accepted views of the firm, the authors argue that a shift from the aggregate view to the real entity view of a corporation will have the following implications: an expansion of the dimensional factors of CSR (economic, social, environmental and tax); a new standard or definition of corporate responsibility which encompasses both legal and moral considerations and has transparency at its core (Narotzki, 2016); and a new outlook where consumers realise that they have the power to influence and demand action from corporates.

This paper uses state-of-the-art software to empirically test the efficacy of global and domestic tax reform measures that target transparency, ultimately providing evidence supporting the adoption of these measures and the recognition of a new dimension of CSR, tax.

This paper aims to explore the potential use of a dividend capture strategy by individual investors. This strategy arises from the 2003 tax law changes which lowered tax rates on dividends received, while leaving the short‐term tax rates on capital losses unchanged. In addition, leverage can be used in combination with an aggressive call‐writing strategy to receive a multiple of the tax‐advantaged dividend yield without a corresponding increase in risk.

In addition to illustrating how the dividend capture strategy works, a new method of comparing returns between strategies is developed. This method does not rely on a particular risk‐return model, such as is used by the Sharpe ratio or Jensen's alpha methodologies. Finally, a formula is derived which computes the borrowing (margin loan) rate that makes the aggressive call‐writing strategy profitable.

The 2003 changes in US tax laws provide individuals with an opportunity to apply dividend capture techniques similar to those which have been available to corporations for many years. However, corporations use dividend capture techniques to lower risk, while individuals require risk exposure to keep the possibility for capital gains. Thus, a method is developed for capturing an enhanced tax refund on the drop in stock price caused by the stock going ex‐dividend without giving up the potential for capital gain. A byproduct of this method is a straightforward means to measure risk‐adjusted returns for the covered call strategy. The aggressive call‐writing strategy described in this paper is found to offer enhanced returns without an increase in risk for those in the top individual tax brackets.

The specific level of additional risk‐adjusted returns available depends on the tax rates and interest (margin loan) rates facing the investor.

Following the 2003 tax law changes, individuals can receive returns on stocks higher than implied by the statutory tax rate on dividends by employing a dividend capture strategy which involves writing call options on dividend‐paying stocks. This paper also demonstrates that the risk exposure necessary to obtain full capital gains potential can be maintained with an aggressive strategy. This strategy inherently provides a method to judge the extent of improvement without having to rely on questionable assumptions of any specific asset‐pricing model.

The paper provides an alternative to conventional covered call‐writing strategies which reduce exposure to capital gains. Individual investors and their advisors will find a method to maintain exposure to market risk and therefore the full potential for capital gains, while receiving preferential tax treatment on dividends received. Researchers will find a method to directly compute risk‐adjusted return for covered call‐writing strategies without having to rely on assumptions made in the asset‐pricing models underlying the Sharpe ratio and Jensen's alpha.