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CHAPTER 15- TAXATION AND CORPORATE INCOME

May 30, 2018

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    1

    Chapter 15

    Taxation of CorporateIncome

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    2

    Forms of Business

    Sole Proprietorships

    Partnerships

    Corporations

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    3

    Corporations

    Corporations are granted the legalstatus of people.

    This means that they can own propertyand borrow money.

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    Corporate Ownership

    Corporations are owned by shareholders. Eachshare entitles its holder to a fraction of the

    dividends declared,votes at shareholders meetings that determine the

    operations of the corporation, and

    proceeds if the corporation were to dissolve.

    The fraction of all of the above that applies for eachshareholder is the number of shares held divided bythe total number of shares outstanding.

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    5

    Corporate Taxes

    Corporations are subject to a corporateincome tax in the U.S.

    Since the corporation is not really a person,the people who bear the burden of this taxdepend on the shifting of the tax.

    The tax could be shifted backwards toemployees, shifted forward to consumers orborne by the shareholders.

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    The Tax Base: Measuring Business Income Using the comprehensive definition of income,

    business income is receipts + net capital gains

    income labor, interest, material, and otherbusiness costs.

    In the U.S., only realized capital gains areincluded in net taxable income forcorporations.

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    Taxation of Owner-Supplied Inputs

    In small business settings, owners work forthemselves. The profit from the business iswhat each owner is paid.

    Some of this is normal profit; some iseconomic profit.

    Corporations feature no owner-supplied inputso all profit, normal and economic, is taxed.

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    Corporate Profits and Where They Go

    Corporate Profits = Corporate Taxes +Retained Earnings + Dividends

    Retained Earnings are the portion of after-taxcorporate profits that a company keeps toinvest in the business.

    Dividends are the portion of after-taxcorporate profits that are distributed toshareholders.

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    Economic Depreciation Economic Depreciation is the amount of

    value that an asset loses over time.

    When a business buys an expensive capitalasset, it cannot deduct from corporate profitsthe entire value of the asset.

    Because the asset will be productive for asubstantial period of time, companies canonly deduct a portion of the value of theasset.

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    Inflation and Depreciation

    If inflation is running at a significant pace,then the replacement cost for a capital

    asset can be higher than the valueremaining on the books.

    Depreciation is understated if firms areonly allowed to use historic costs.

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    Undistributed Corporate Profits,

    Dividends, And Interest Cost

    Some argue that a separate corporate income

    formula is necessary to reverse the tax preferencethat comes from the exclusion of all unrealizedcapital gains in calculating personal income tax.

    Others counter that because payment on corporatedebt (interest) is deductible to the corporation butpayment on equity (dividends) is not, a separatetax on corporate income is neutral.

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    Double Taxation of Corporate Income

    Corporate Income is considered to be double-taxed,because its income is taxed twice.

    The Corporation must pay taxes on the profits, then

    shareholders must pay taxes on the amount theyreceive in either dividends or capital gains.

    Under a comprehensive income tax this would nothappen. Corporate profits, either retained or paid individends, would enter individual income taxstructures according to the percentage of thecorporation owned by each shareholder.

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    Arguments in Favor of Double Taxing

    Corporate IncomeUnrealized Capital Gains and the Stepped-Up Basis:

    A major source of unrealized capital gains forindividuals is corporate stocks. If the businessprofit were not taxed at the corporate level, itmight never be taxed.

    Compensation for Bankruptcy Protection: Individuals are not liable for the bankruptcy of

    assets they hold in corporations, whereas theyare liable in cases of proprietorships andpartnerships. This poses a real advantage toinvesting in corporations over the other businessforms.

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    The Consequence of Double Taxation: A

    Bias Toward Debt Finance A corporation can raise money by borrowing (taking on

    debt), or it can raise money by selling stock.

    The corporation can deduct from its profits the amountit pays in interest to its bondholders.

    It cannot deduct the dividends it pays to itsstockholders. This encourages debt finance over

    equity finance.

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    Demonstrating the Bias toward Debt Finance

    Item All-Equity 50% Debt 50% Equity

    Balance Sheet

    Total Assets $1,000,000 $1,000,000

    Debt 0 $500,000Shareholders Equity $1,000,000 $500,000

    Income Statement

    Operating Income $150,000 $150,000

    Interest Expense 0 $50,000

    Taxable Income $150,000 $100,000

    Income Tax $51,000 $34,000

    Income afterCorporate Tax

    $99,000 $66,000

    Return on Equity 9.9% 13.2%

    Assumptions:10% interest;34% tax rate

    Conclusion: The taxation ofcorporate profits combinedwith the deductibility ofinterest raises the after-taxreturn on equity to firms ingreater debt, therebymotivating firms to increasetheir debt burdens to aninefficiently high level.

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    Tax Treatment of Multinational Corporations

    Large corporations with multinational operations haveforeign subsidiaries throughout the world.

    The foreign subsidiaries are incorporated under thelaws of a foreign nation and are legally separate fromthe parent corporation.

    There are two ways of taxing multinationals: Taxes only on repatriated profits. Computing worldwide income and granting a credit for tax

    payments made to other countries.

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    Rate StructureTaxable Income Average Tax

    Rate at theBeginningof theBracket

    MarginalTax Rate

    Less than $50,000 0% 15%

    $50K