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We investigate the interaction of debt covenants and tax accounting on the adoption of Financial Interpretation No. 48 (FIN 48). We examine how firms respond to the potential tightening of covenant slack upon FIN 48 adoption and whether these actions are penalized by creditors and anticipated by equity markets. We find that upon FIN 48 adoption, the majority of sample corporate borrowers increase their tax reserves and reduce equity. Firms close to debt covenant violation were even more likely to increase tax reserves upon FIN 48 adoption; however, the size of the adjustment was relatively smaller, suggesting that the FIN 48 standards limited, but did not eliminate, firms use of discretion in reporting uncertain tax positions to avoid costly covenant violations. For firms near net worth debt covenant violation, the act of decreasing equity upon FIN 48 adoption imposes real economic costs, as the average cost of debt increased by 43 basis points. Finally, we extend prior research on the market response to FIN 48 by showing how the market response to FIN 48 adoption is a function of debt covenant slack and tax aggressiveness. Specifically, the cumulative abnormal return at the FIN 48 exposure draft release date is negative only for tax aggressive firms that are close to debt covenant violation.

We examine the relationship between tax-related accounting misstatements and changes in the uncertain tax benefits accrual account in the year of the disclosure of a misstatement. We find that the disclosure of a tax-related misstatement is associated with an increase in unrecognized tax benefits during that year. We show that the increase in unrecognized tax benefits in the year of disclosure is from uncertain tax positions taken in prior periods. Overall, this finding is consistent with increase in financial reporting conservatism upon disclosure of tax-related accounting misstatement.

To better detect potential audit issues, since 2010, the Internal Revenue Service has required firms to file a separate schedule individually disclosing each of their uncertain tax positions (UTPs). This study uses an experiment to examine how this increase in detection risk from the newly created IRS schedule influences both a firm’s tax reporting and financial reporting concurrently. We find that corporate tax professionals were more likely to recommend an UTP when their firm had a strong UTP reporting quality, regardless of the detection risk level of the reporting environment. However, we find an interaction effect for the recording of the tax reserve. In a low detection risk environment, corporate tax professionals recorded a higher (lower) tax reserve when their firm had a weak (strong) UTP reporting quality. However, in a high detection risk environment, corporate tax professionals recorded a lower (higher) tax reserve when their firm had a weak (strong) UTP reporting quality. Overall, the results provide insight into the dual nature of UTP reporting and the determinants that influence each reporting behavior.

Forty-five years ago, psychologist Stanley Milgram conducted a series of famous experiments on obedience and authority that tested individuals' willingness to administer electric shocks to a test subject under the direction of an authority figure. This paper discusses how Milgram's work on human psychological tendencies can be used to address subordination of judgment and other ethical issues in financial accounting and reporting, including accounting for income taxes. The teaching approach described relies on readings, videos, and mini-cases to give students an appreciation for the role of organizational influences on ethical decision making in today's accounting world. This teaching approach is innovative in its use of social psychological theories to address accounting ethical dilemmas, and its incorporation of contemporary international financial reporting standards and tax reporting issues into the ethics debate.

This paper examines the relationship between environmental uncertainty and tax avoidance at the firm level. We posit that managers faced with more uncertain environments are likely to engage in more tax avoidance activities. We find a significant and negative relationship between environmental uncertainty and effective tax rates, and our results persist through a battery of robust checks. We further find that managerial ability mitigates the above relationship. Moreover, we find that small, highly leveraged, and innovative firms operating in uncertain environments engage in more tax avoidance.

This research note investigates the relationship between the constructs of professional skepticism and client advocacy as they relate to accountants’ roles as auditors and tax professionals. Although Pinsker, Pennington, and Schafer (2009) implicitly treat advocacy and professional skepticism as opposing constructs, the purpose of this research note is to explicitly examine whether an accounting professional can be both a professional skeptic and a client advocate. Two hundred and six experienced accounting professionals with a mixture of accounting and tax backgrounds responded to a client advocacy scale (Pinsker et al., 2009) and a professional skepticism scale (Hurtt, 2010). Results indicate that while tax professionals have higher levels of client advocacy than auditors, both groups have similar levels of professional skepticism. Moreover, no correlation emerges between participants’ responses to the advocacy and the full professional skepticism scale or five of its six sub-scales. These results provide evidence that client advocacy is a separate and distinct construct from professional skepticism. These findings have implications for behavioral accounting researchers by demonstrating that these two constructs are not related; thus, it is important to separately measure client advocacy and professional skepticism when they are relevant to a research question.

Schedule UTP requires that firms disclose to the IRS the uncertain tax positions that comprise the federal portion of the tax reserve disclosed on their financial statements. To investigate whether Schedule UTP has been an effective audit tool to the IRS, we use financial statement disclosures of reductions in reserves due to a lapse in the statute of limitations (Lapse). We find that the probability of a Lapse is 3.4 percent lower after Schedule UTP. However, this result is driven by domestic firms; we do not find evidence that Schedule UTP has been effective in the audit of multinational firms.

The Compliance Assurance Process (CAP) is a federally funded IRS corporate audit program. The program’s goal is to determine the best tax treatment for complex transactions before a corporation files its tax return. The US Department of the Treasury has voiced concerns regarding resource constraints and whether the program enhances public (nonprofessional investor) and investor confidence. We conduct a behavioral experiment using 176 Master of Business Administration and Master of Accounting students as proxies for nonprofessional investors. In the experiment, we examine the effects of CAP participation and corporate tax risk profile on judgments about financial statement credibility. We use a 2 × 2 experimental design with corporate tax risk profile manipulated as high risk or low risk and participation in CAP manipulated as participatory or non-participatory. This research investigates whether CAP program participation and/or tax risk level influence nonprofessional investors’ perceptions of the certainty and accuracy of the provision for income taxes. The results suggest both CAP program participation and tax risk influence nonprofessional investors’ perceptions of the certainty of the income tax provision; and tax risk also influences nonprofessional investors’ perception of the accuracy of the income tax provision.

I examine patterns of making or deferring strategic repatriations that firms can use to either meet analysts' forecasts or defer to maintain future reported earnings flexibility. First, I examine the extent to which firms repatriate earnings from high foreign tax subsidiaries to decrease US tax expense, resulting in increased net income and lower cash taxes. Using federal tax return information, I find evidence that firms strategically repatriate these earnings to meet or beat current analysts' forecasts. Next, I find evidence that firms that are able to obtain current year tax reductions defer these repatriations in an attempt to build cookie-jar reserves. Lastly, I find that firms do not disclose high foreign tax repatriations (HTRs), even when required by SEC rules. This study contributes to the earnings management, tax avoidance, and disclosure literature by examining a discretionary tax planning strategy.