The Economic Effects of Special Purpose Entities on Corporate Tax Avoidance

• 成果类型: Article
• 署名作者: Demere, Paul; Donohoe, Michael P.; Lisowsky, Petro
• 署名单位: University System of Georgia; University of Georgia; University of Illinois System; University of Illinois Urbana-Champaign; Boston University
• 刊物名称: CONTEMPORARY ACCOUNTING RESEARCH
• ISSN/ISSBN: 0823-9150
• DOI: 10.1111/1911-3846.12580
• 发表日期: 2020
• 页码: 1562-1597
• 关键词: off-balance-sheet; debt; US; incentives; benefits; equity; liability; shelters; models; cost

摘要

This study provides the first large-sample evidence on the economic tax effects of special purpose entities (SPEs). These increasingly common organizational structures facilitate corporate tax savings by enabling sponsor firms to increase tax-advantaged activities and/or enhance their tax efficiency (i.e., relative tax savings of a given activity). Using path analysis, we find that SPEs facilitate greater tax avoidance such that an economically large amount of cash tax savings from research and development (R&D), depreciable assets, net operating loss carryforwards, intangible assets, foreign operations, and tax havens occur in conjunction with SPE use. We estimate that SPEs help generate over $330 billion of incremental cash tax savings, or roughly 6 percent of total U.S. federal corporate income tax collections during the sample period. Interaction analyses reveal that SPEs enhance the tax efficiency of intangibles and R&D by 61.5 percent to 87.5 percent. Overall, these findings provide economic insight into complex organizational structures supporting corporate tax avoidance.