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作者：McDonald, RL
作者单位：Northwestern University
摘要：It is common for firms to issue or purchase options on the firm's own stock. Examples include convertible bonds, warrants, call options as employee compensation, and the sale of put options as part of share repurchase programs. This paper shows that option positions with implicit borrowing - such as put sales and call purchases - are tax-disadvantaged relative to the equivalent synthetic option with explicit borrowing. Conversely, option positions with implicit lending - such as warrants - are...
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作者：Auerbach, AJ; Bradford, DF
作者单位：University of California System; University of California Berkeley; Princeton University
摘要：We show the unique form that must be taken by a tax system based entirely on realization accounting to implement a uniform capital income tax, or, equivalently, a uniform wealth tax. This system combines elements of an accrual based capital income tax and a traditional cash-flow tax, having many of the attributes of the latter while still imposing a tax burden on marginal capital income. Like the traditional cash-flow tax, this system may be integrated with a tax on labor income. We also show ...
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作者：Warren, AC Jr
作者单位：Harvard University
摘要：This paper discusses the response of the US federal income tax to financial innovation. Income taxation in the US and elsewhere has traditionally relied on distinctions, such as the difference between fixed and contingent returns, that can be undermined by new financial products. The principal tax law responses to innovative products have been: (1) transactional analysis, which aggregates or disaggregates new transactions to conform them to existing legal categories, (2) taxation of changes in...
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作者：Auerbach, AJ
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作者：Keuschnigg, C; Nielsen, SB
作者单位：University of St Gallen; Copenhagen Business School
摘要：A model of start-up finance with double moral hazard is proposed. Entrepreneurs have ideas and technical competence, but lack own resources as well as commercial experience. Venture capitalists (VCs) provide start-up finance and managerial support. Both types of agents thus jointly contribute to the firm's success, but neither type's effort is verifiable. We find that the market equilibrium is biased towards inefficiently low entrepreneurial effort and venture capital support. In this situatio...
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作者：Gordon, R; Kalambokidis, L; Slemrod, J
作者单位：University of California System; University of California San Diego; University of Minnesota System; University of Minnesota Twin Cities; University of Michigan System; University of Michigan
摘要：The U.S. income tax system has long been recognized as a hybrid of an income and consumption tax system, with elements that do not fit naturally into either pure system. What it actually is has important policy implications for, among other things, understanding the impact of moving closer to a pure consumption tax regime. In this paper, we examine the nature of the U.S. income tax system by calculating the revenue and distributional implications of switching from the current system to one for...
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作者：Hines, JR
作者单位：University of Michigan System; University of Michigan; National Bureau of Economic Research
摘要：This paper analyzes efficient government reactions to unanticipated tax avoidance. Quickly reforming tax laws to reduce the effectiveness of new tax avoidance techniques prevents widespread adoption, but indirectly encourages the rapid development of new avoidance methods if prior users are permitted to retain their tax benefits. Tax reforms that immediately prevent new avoidance mean that innovators need not fear imitation by competitors, and cannot rely on copying the innovations of others. ...
