In: Edgar, T.E., Farrar, J. and Mawani, A. "Foreign Direct Investment, Thin Capitalization, and the Interest Expense Deduction: A Policy Analysis" Canadian Tax Journal 2008, 56(4): 803-869
In: Canadian journal of economics and political science: the journal of the Canadian Political Science Association = Revue canadienne d'économique et de science politique, Band 27, Heft 2, S. 192-204
In view of the approaching revision of the Bank Act in 1964, it may now be appropriate to re-examine contemporary opinion and practice concerning commercial bank capital. It is tempting to inquire whether there is an optimum ratio of capital to assets towards which commercial banks should aim. The traditional economic function of capital accounts has been to protect bank depositors against loss caused by depreciation of bank assets. "Bank capital is in effect a first line of deposit guarantee. Any supervisory standard for measuring capital adequacy should be expressed in terms of the function of bank capital. The function of bank capital is to protect the bank creditors, mostly depositors, against ultimate loss."Taking a literal view of this function, supervisory authorities in the United States came to apply a standard ratio of capital to deposits of 10 per cent; "there appears to be no scientific basis for this particular ratio. It is simply a good round decimal, easy to calculate at a glance." Then, as the capital: asset ratio fell substantially with the increase of bank holdings of government securities, a capital: asset standard was suggested. Since losses result from asset depreciation, and bank assets do not all involve the same degree of risk, assets seemed a more relevant guide to capital requirements than deposits. Such an assets standard would not indicate a need for more capital until earning assets of some inherent risk were being acquired. Incidentally, if protection of assets were the accepted function of bank equity, it would only be that portion of capital funds in excess of fixed assets which would be relevant for the numerator.
In an environment of increasing government expenditures financed largely viii through taxes, including a relatively visible and large residential property tax, the issue of whether property taxes are capitalized into market values is increasingly important. Property tax capitalization is the reflection of property taxes in the value of real property. The capitalization of property tax does not necessarily pose a problem; rather, problems arise when homes identical to each other have different taxes and these differentials are then capitalized into market values. These capitalized tax differentials result in large capital gains and losses to owners of real estate. This study (1) reviews existing economic theory and empirical evidence on the capitalization of property taxes, (2) develops a model of property valuation inclusive of tax effects, and (3) estimates the parameters of this model using a comprehensive data set of over 334 home sales in the Logan, Utah area. The empirical results include an estimate of the tax capitalization effect. Two closely related issues are also addressed in the study. They include: (I) changes in real estate prices, including a suggested method for measuring such change and (2) a study of property tax equity, including two specific measures of tax fairness. The conclusions are (I) tax differentials are capitalized; (2) real estate prices in the study area increased approximately 10 percent per year from 1989 to 1992; and (3) there is significant variation in assessment ratios.
Dieser Beitrag untersucht die Wirkungen der Zinsbereinigung des Eigenkapitals auf das zu erwartende Steueraufkommen und auf den internationalen Steuerwettbewerb. Ausgangspunkt hierfür ist eine modelltheoretische Untersuchung des Zusammenhanges zwischen Kapitalmarktrenditen und Eigenkapitalrenditen. Hierbei treten Effekte auf, die dafür sorgen, dass der für die Zinsbereinigung maßgebende Eigenkapitalposten unerwartet gering ausfällt. Die Zinsbereinigung entfaltet im Ergebnis sehr starke Wirkungen auf die Finanzierungsstruktu-ren internationaler Konzerne, obwohl verhältnismäßig geringe Steuerausfälle mit dieser Wirkung einhergehen. Im Bezug auf Gewinnverlagerungen mittels Verrechnungspreisen kann die Zinsbereinigung hingegen keine Wirkungen entfalten, hier kann nur eine Tarifsenkung Abhilfe verschaffen. Die Tragweite der Ergebnisse für die reale Steuerpolitik wird anhand der Unternehmensbilanzstatistik der deutschen Bundesbank auch empirisch bestätigt. In der Zinsbereinigung kann insgesamt eine Alternative zum neuem § 8a KStG, der "Zinsschranke", gesehen werden. Abschließend ist in den geringen zu erwartenden Steuerausfällen ein weiterer Vorteil für die Zinsbereinigung gefunden, welche diese als Steuerreformoption attraktiver werden lässt. Dies ist auch deswegen von aktuellem Interesse, weil die Zinsbereinigung die negativen Auswirkungen der fehlenden Finanzierungs-neutralität nach Einführung der Abgeltungsteuer reduzieren kann. ; This paper investigates the impact of an Allowance for Corporate Equity (ACE) on the expected tax revenues and on the international tax competition. Beginning with an analysis of the relation between the rate of return on equity and the interest rate on the capital market, this paper figures out some effects which cause surprisingly low net assets used to calculate the ACE. This yields to a strong impact on the financial structure of multicorpo-rate enterprises although there is only a moderate decline in tax revenues. Focusing profit shifting via transfer prices, the ACE has no positive effect. Only a cut of the corporate tax rate is useful in this context. The relevance of these results is additionally affirmed by using the statistical data published by the "Deutsche Bundesbank", the central bank of Germany, which includes an aggregated corporate balance sheet. All in all, the ACE can be seen as an alternative to the new German thin capitalization rules applied in 2008 ("Zinsschranke"). Additionally, the low tax revenue losses constitute a new advantage for the ACE as a blueprint for corporate tax reforms. This is also interesting because an ACE could reduce the negative effects on the financial structure of firms which accompanies the implementation of a low withholding tax on interests.
In: Assael, Jérémi, Laurent Carlier, and Damien Challet. 2023. "Dissecting the Explanatory Power of ESG Features on Equity Returns by Sector, Capitalization, and Year with Interpretable Machine Learning" Journal of Risk and Financial Management 16, no. 3: 159. https://doi.org/10.3390/jrfm16030159
Abstract This paper investigates the spread of the Global Financial Crisis (GFC) and the Eurozone Sovereign Debt Crisis (ESDC) to different market capitalization segments across countries and regions. Specifically, it tests for capitalization-specific contagion across both crises and their phases by examining large, medium and small capitalization indices of G-20 equity markets. The analysis across stable and the two crisis periods shows the existence of a stronger largecap transmission channel for the majority of countries. On the other hand, the contagion dynamics across the phases of the two crises do not provide a clear pattern of a specific cap size-based contagion across all markets. However, there is evidence that the Pacific region and the three cap groups of some individual markets of different regions are less severely affected. Further, all three cap groups of developed markets are mostly affected during the last phase of the ESDC, while emerging and frontier markets show a more diverse pattern of contagion across the phases of both crises. Finally, the Lehman Brothers' collapse triggers a dramatic increase of the infection rate, while the ESDC seems to be more contagious than the GFC. JEL classifications: F30; G15 Keywords: Capitalization-specific contagion; global financial crisis; Eurozone debt crisis; dynamic conditional correlation; FIAPARCH
By granting intracompany loans to their foreign affiliates, multinational firms may reduce their tax liability abroad. Many countries have legislated thin-capitalization rules (TCRs) that limit the allowable levels of intracompany loans or restrict interest deductibility if certain thresholds are crossed. This paper empirically analyzes the effect of the German TCR on corporate policy. We find that tightening the regulations in 2001 had some limiting effect on leverage. Foreign affiliates reacted by reducing intracompany loans and increasing equity, with no significant evidence of reduced real investment. A possible reason for the limited impact of the TCR was that multinational firms had the option to work around the regulation by using holding company structures. Indeed, holding companies have been used to shift huge amounts of intracompany loans onto the books of German affiliates. At the same time, however, only part of these observed reorganizations seem to have been a reaction to TCR.
The contemporary significance of branding as a source of value is explored by situating the creation and valorization of brand equity within 'the full circuit of capital'. Conceived as a form of co-production occurring in the sphere of circulation (as well as production), brand-building is connected to: the surpluses generated by the labour of user-consumers as well as the designers and producers of branded products and services; the realization of surplus through control of revenues derived from sales of these products and services and the appropriation of surpluses, including the conversion of brand equity into brand value after deduction of costs. Contemporary investment in branding is related to the financialization of brands as intangibles that make a growing contribution to market capitalization. By attending to multiple facets of the circuit of capital, including the co-production brand equity by user-consumers, some pointers are proposed for developing a more 'joined-up' view of the 'bigger picture' of contemporary capitalist reproduction.
This thesis is directed towards the entrepreneur who is formulating a venture and is in search of a means of direction. A profile of entrepreneurs is illustrated along with a method of developing a business plan; a necessity in searching for capital. The performing of a market study and the preparation of financial data are presented to give the entrepreneur all the necessary data required in structuring the proposed offering. Financing methods through debt, equity and leasing are discussed in addition to their effects on the structuring of the venture. The sources of external financing, such as venture capitalists, banks, and government agencies are introduced and evaluated based on their criteria that must be met when acquiring funds. The study demonstrates that it is more feasible under certain economic conditions for a venture in the start-up stage to use venture capitalists as a source of funds as opposed to any other source of financing.