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Book part
Publication date: 9 November 2004

Ernest R. Larkins

With repeal of the extraterritorial income exclusion expected in 2004, many U.S. companies selling abroad must rethink tax strategies related to export profit. Many firms with net…

Abstract

With repeal of the extraterritorial income exclusion expected in 2004, many U.S. companies selling abroad must rethink tax strategies related to export profit. Many firms with net operating loss (NOL) carryforwards, foreign tax credit (FTC) carryforwards, and interest-charge domestic international sales corporations (ICDs) can reduce marginal tax rates (MTRs) below rates otherwise applying to domestic sales. This article provides several case examples illustrating how U.S. exporters can minimize the MTR applicable to export profit. MTRs often depend on the period over which the company expects to absorb its NOL or FTC carryforward, the firm’s discount rate, and, in the case of ICDs, the prevailing T-bill rate. Assuming a 34% corporate tax rate, exporters with NOL (FTC) carryforwards can reduce the MTR on export profit to zero (17%) in some cases. Also, over the range of variables this article examines, the ICD reduces the MTR on export profit to between 34 and 21%. The cases illustrate how NOL and FTC carryforwards and ICDs affect exporters’ MTRs and provide educators with useful tools for discussing the tax aspects of exporting.

Details

Advances in Taxation
Type: Book
ISBN: 978-0-76231-134-7

Book part
Publication date: 12 September 2022

Dawei Jin, Hao Shen, Haizhi Wang and Desheng Yin

This chapter investigates whether and to what extent tax benefits affect the likelihood of firms undertaking leveraged buyout (LBO) transactions.

Abstract

Purpose

This chapter investigates whether and to what extent tax benefits affect the likelihood of firms undertaking leveraged buyout (LBO) transactions.

Design/Methodology/Approach

With an identified sample of LBO firms and similar non-LBO counterparts, this chapter utilizes staggered changes in state corporate income tax rates as exogenous shocks and adopts a Logistic regression to analyze how these tax changes affect firms' probability of engaging in LBOs.

Findings

Firms are more likely to engage in LBOs after increases in corporate income tax rates. Specifically, the increase in the likelihood of firms undertaking LBOs following tax increases is between 6.9% and 12.9%. We also find that this positive relation is more pronounced for firms with higher levels of return on assets (ROA) and marginal tax rates (MTR). Finally, we report that the mean value of tax benefits accounts for between 28.5% and 170% of the premium paid to pre-buyout shareholders.

Originality/Value

This chapter provides strong evidence that tax benefits constitute an important source of value creation in LBOs and adds to the debate regarding the role of tax benefits in LBOs.

Details

Empirical Research in Banking and Corporate Finance
Type: Book
ISBN: 978-1-78973-397-6

Keywords

Book part
Publication date: 3 January 2015

Robert Todd Perdue and Christopher McCarty

The nexus where law, social movements, and organizations meet demands further explication. This research adds to our understandings of these dynamics by examining the case of the…

Abstract

The nexus where law, social movements, and organizations meet demands further explication. This research adds to our understandings of these dynamics by examining the case of the central Appalachian anti-strip mining movement. After developing a social network technique to analyze over thirty years of newspapers, we find a period of reduced movement activity following the passage of the Surface Mining Control and Reclamation Act of 1977. Conversely, we observe a reinvigoration of the movement following the passage of the Clean Air Amendments of 1990 and the perverse incentives they created for mountaintop removal mining. Finally, we see that joint participation in lawsuits is a primary tie that binds these groups together.

Details

Studies in Law, Politics, and Society
Type: Book
ISBN: 978-1-78441-568-6

Book part
Publication date: 1 July 2002

Gregory G. Geisler and Ernest R. Larkins

Many studies find that taxes influence capital location, income shifting, and capital structure decisions of multinational companies. So, reasonably estimating the marginal tax…

Abstract

Many studies find that taxes influence capital location, income shifting, and capital structure decisions of multinational companies. So, reasonably estimating the marginal tax effect of international business decisions is important. However, simple marginal tax rate (MTR) proxies, such as a foreign country's top statutory rate or a rate that assumes remittance of all foreign profits as current dividends, fail to capture many tax law complexities. This article develops an algebraic “mixed remittance” model for calculating a U.S. company's MTR on its foreign subsidiary's profits. In contrast to the simpler proxies, the mixed remittance model allows foreign profits to be remitted in different forms (i.e. not just as dividends) and across varying time periods (i.e. not just the current period[t Also, the mixed remittance model considers withholding taxes, tax deferrals from postponed dividends, and foreign tax credit positions. Paired t-tests show that the resulting MTR measure often differs significantly from the two simpler MTR proxies.

Details

Advances in Taxation
Type: Book
ISBN: 978-1-84950-158-3

Abstract

Details

Advanced Modeling for Transit Operations and Service Planning
Type: Book
ISBN: 978-0-585-47522-6

Book part
Publication date: 20 May 2003

James Davies, Michael Hoy and Tracy Lynch

The distributional impacts of replacing an income tax that has graduated marginal rates by a flat tax are complex. Typically the flat tax rate will be less than the top marginal…

Abstract

The distributional impacts of replacing an income tax that has graduated marginal rates by a flat tax are complex. Typically the flat tax rate will be less than the top marginal rate under the pre-existing tax, leading to gains for the wealthiest. On the other hand, real-world proposals generally combine this with increases in personal exemptions that benefit some of the lowest income taxpayers. The result is that flat tax proposals usually redistribute from the middle to the extremes.

Details

Fiscal Policy, Inequality and Welfare
Type: Book
ISBN: 978-1-84950-212-2

Book part
Publication date: 8 August 2022

John Armstrong

Of the three ‘pillars of sustainability’, railways’ initial focus was on the economic pillar, having been developed in the nineteenth century to enable economic development and

Abstract

Of the three ‘pillars of sustainability’, railways’ initial focus was on the economic pillar, having been developed in the nineteenth century to enable economic development and having struggled in the mid-twentieth century to maintain their economic sustainability in the face of competition from road and air transport. From the 1960s onwards, increased focus on and concern about social and environmental sustainability, together with rail’s comparatively high capacity and low environmental impact, has led to renewed interest in the role of rail in passenger and freight transport. Providing the necessary railway system capacity to enable a significant modal shift from air and (especially) road transport requires major investment, and there is a trade-off between the economic sustainability of these investments and the resulting social and environmental sustainability benefits. However, the railways should also benefit from the increased revenue resulting from improved services and could be supported by additional financial incentives to encourage modal shift. Similarly, there are different philosophies of and approaches to timetable planning and development, ranging from making the most economically sustainable use of resources to the provision of high-frequency, integrated ‘clockface’ timetables, providing passengers and freight users with an attractive range of travel and transport opportunities. Future sustainability, capacity, timetabling and other aspirations are set out in the Rail Safety and Standards Board’s Operational Philosophy for the GB Mainline Railway: these aspirations were developed in the context of Britain’s heavy rail system but are also more generally applicable.

Details

Sustainable Railway Engineering and Operations
Type: Book
ISBN: 978-1-83909-589-4

Keywords

Book part
Publication date: 20 January 2011

Priscilla Y.L. Chan

China represents around 20% of the world's population, and her economy is still performing well under economic crisis. Historical events have shaped different parts of China with…

Abstract

China represents around 20% of the world's population, and her economy is still performing well under economic crisis. Historical events have shaped different parts of China with different economic developments and cultural encounters. The most prominent difference is between Hong Kong and the Mainland. This chapter would like to examine the development and issues of fashion retailing in China. For better understanding, this chapter starts with a brief discussion on apparel industry development and fashion culture in Hong Kong and the Mainland, follows by historical development and then presents systems of fashion retailing in both Hong Kong and the Mainland. Desktop research and exploratory research techniques were employed. Stores of international fashion luxury brands in Hong Kong, Shanghai and Beijing were visited. Comparison of branding issues, particularly for luxury market in Hong Kong and the Mainland are discussed, so are future directions of fashion retailing in these places.

Details

International Marketing
Type: Book
ISBN: 978-0-85724-448-2

Keywords

Book part
Publication date: 16 January 2012

Haixiao PAN

Purpose – This chapter explores the functions of institutional setting, technical requirements and local city characteristics as they affect the implementation of sustainable…

Abstract

Purpose – This chapter explores the functions of institutional setting, technical requirements and local city characteristics as they affect the implementation of sustainable urban travel policies in China under the pressure of fast motorization and the constraints of energy and resource limitations.

Methodology – We reviewed the documents related to sustainable urban transport vision in China from central government and compared the motorization and urban transport policy at local city level in relation to social equity, urban transport finance, as well as the challenge of an ageing society.

Findings – The concept of sustainable development had been widely talked about in China but has not yet been effectively translated into actions in urban transport. There is a need to strengthen the synchronization of central government and local government strategies on sustainable transport in order to achieve less car-dependent cities.

Research limitations/implications – We need more research to understand the specific characteristics of the Chinese urban transport system and the constraints on the implementation of sustainable transport policy at a local level.

Practical and social implications – The achievement of a higher share of walking and cycling will greatly improve sustainable urban mobility, in terms of social equity, quality of urban life and also fossil energy consumption.

Originality – Current policy documents and implementation practice were analysed to provide the reader with a deep understanding of urban transport policy in China.

Details

Sustainable Transport for Chinese Cities
Type: Book
ISBN: 978-1-78190-476-3

Keywords

Book part
Publication date: 10 December 2015

Chun Kit Lok

Smart card-based E-payment systems are receiving increasing attention as the number of implementations is witnessed on the rise globally. Understanding of user adoption behavior…

Abstract

Smart card-based E-payment systems are receiving increasing attention as the number of implementations is witnessed on the rise globally. Understanding of user adoption behavior of E-payment systems that employ smart card technology becomes a research area that is of particular value and interest to both IS researchers and professionals. However, research interest focuses mostly on why a smart card-based E-payment system results in a failure or how the system could have grown into a success. This signals the fact that researchers have not had much opportunity to critically review a smart card-based E-payment system that has gained wide support and overcome the hurdle of critical mass adoption. The Octopus in Hong Kong has provided a rare opportunity for investigating smart card-based E-payment system because of its unprecedented success. This research seeks to thoroughly analyze the Octopus from technology adoption behavior perspectives.

Cultural impacts on adoption behavior are one of the key areas that this research posits to investigate. Since the present research is conducted in Hong Kong where a majority of population is Chinese ethnicity and yet is westernized in a number of aspects, assuming that users in Hong Kong are characterized by eastern or western culture is less useful. Explicit cultural characteristics at individual level are tapped into here instead of applying generalization of cultural beliefs to users to more accurately reflect cultural bias. In this vein, the technology acceptance model (TAM) is adapted, extended, and tested for its applicability cross-culturally in Hong Kong on the Octopus. Four cultural dimensions developed by Hofstede are included in this study, namely uncertainty avoidance, masculinity, individualism, and Confucian Dynamism (long-term orientation), to explore their influence on usage behavior through the mediation of perceived usefulness.

TAM is also integrated with the innovation diffusion theory (IDT) to borrow two constructs in relation to innovative characteristics, namely relative advantage and compatibility, in order to enhance the explanatory power of the proposed research model. Besides, the normative accountability of the research model is strengthened by embracing two social influences, namely subjective norm and image. As the last antecedent to perceived usefulness, prior experience serves to bring in the time variation factor to allow level of prior experience to exert both direct and moderating effects on perceived usefulness.

The resulting research model is analyzed by partial least squares (PLS)-based Structural Equation Modeling (SEM) approach. The research findings reveal that all cultural dimensions demonstrate direct effect on perceived usefulness though the influence of uncertainty avoidance is found marginally significant. Other constructs on innovative characteristics and social influences are validated to be significant as hypothesized. Prior experience does indeed significantly moderate the two influences that perceived usefulness receives from relative advantage and compatibility, respectively. The research model has demonstrated convincing explanatory power and so may be employed for further studies in other contexts. In particular, cultural effects play a key role in contributing to the uniqueness of the model, enabling it to be an effective tool to help critically understand increasingly internationalized IS system development and implementation efforts. This research also suggests several practical implications in view of the findings that could better inform managerial decisions for designing, implementing, or promoting smart card-based E-payment system.

Details

E-services Adoption: Processes by Firms in Developing Nations
Type: Book
ISBN: 978-1-78560-709-7

Keywords

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