关于信用卡债务的英文文献和翻译 第10页

Tax Planning as a Tax-Favored Activity
Tax planning itself is a tax-favored activity because money spent thereon is tax deductible and tax savings  arising from tax planning is effectively tax exempt because they reduce taxes payable and hence, more  tax-favored than tax-exemption. When PTROR (pre-tax rate of return) is equal to ATROR (after-tax rate  of return), then it is called tax exemption (a situation in which an asset escapes explicit taxation).
For example, there are two alternatives with marginal tax rate (MTR) of 15%: Alternative-1: Invest Tk. 10,000 in fully taxable corporate bonds for one year with a yield of 10% p.a. before taxes. And Alternative-2: Invest Tk. 10,000 in tax planning services to save Tk. 11,0000 in taxes in one year. PTROR (Pre-tax Return/Pre-tax Investment) for Alternative-1 will be 10% [= (Tk. 10,000x10%)/Tk.约瑟夫环-数据结构课程设计
10,000]. And PTROR for Alternative-2 will also be 10% [=(Tk. 11,000 – Tk. 10,000)/Tk. 10,000]. But   ATROR  (After-tax  Return/After-tax  Investment)  for  Alternative-1  will  be  8.5%  [={(Tk.
10,000x10%)(1 – 15%)}/Tk. 10,000]. And ATROR for Alternative-2 will be 11.76% [= {(Tk. 11,000
– Tk. 10,000) (1 – 0%)}/{Tk. 10,000(1 – 15%)}]. Thus, Alternative-2 (tax planning) yields higher
ATROR and hence, tax-favored.

A Brief Highlight on Scholes-Wolfson Tax Strategy

Scholes-Wolfson tax strategy depends on identification of tax clientele, which is based on implicit tax and also  the adoption of tax arbitrage. Implicit tax arises because the pre-tax investment returns available on  tax-favored assets are less than those available on tax-disfavored assets. Taxpayers wishing  to  obtain  the  tax-favored treatment  offered  by  the  investment  bid  up  the  price  of  the investment lowering the pre-tax return. Thus, a desperate effort to avoid tax might emphasize only to reduce explicit tax by adopting  tax-favored treatments, might reduce the after-tax return and hence there will be a decrease in after-tax return, which is nothing but an implicit tax. Implicit tax rate is the difference in pretax returns on a given asset,  and  the benchmark asset (usually, “fully taxable bonds” taken as benchmark asset). Say, pretax return on  fully taxable bond is 10%, and fully tax- exempted return on government security is 7%, then implicit tax  rate on government security 30% [=(10% – 7%)/10%]. Thus, paying tax at a rate of 30% on fully taxable bond would result in a return of  7%,  the  same  as  the  pretax  return  on  tax-exempt  government  security.  Taxpayers  who  are indifferent between purchasing two equally risky assets, the returns to which are taxed differently, are called the marginal investors. Taxpayers that prefer one investment over another are referred to as the tax clientele for the preferred investment. Unless investors correctly identify their proper tax clientele, they will not maximize their after-tax rates of return. Usually to identify the proper tax clientele, one way is to compute the implicit tax on tax-favored investment based on a fully taxable investment, then  clientele of the fully taxable investment will be the taxpayers having “marginal explicit tax rates” (METR) below the implicit tax found. For example, pretax return on fully taxable bond is assumed at 10%, and fully tax-exempted return on government security is 7%, then implicit tax rate on government security is 30% [=(10%–7%)/10%]. The clientele for fully taxable bond are taxpayers with METR below 30%. A taxpayer with 20% METR will earn 8% [=10%(1–20%)] after- tax by investing in fully taxable bond, 1% greater than in tax-exempt government security.
Tax arbitrage is the purchase of one asset (a “long” position) and the sale of another (a “short” position) to create a sure profit despite a zero level of net investment. Through tax arbitrage, one can maximize after tax return effectively without adopting easy and desperate tax-minimization strategies which might introduce significant nontax costs. There are two types of tax arbitrage: organizational- form arbitrage and clientele-based arbitrage. They can be briefly explained as follows:本文来自辣.文,论-文·网原文请找腾讯752018766

Arbitrage Type of taxpayers Long Position in Short Position in
Organizational- form All taxpayers An asset or productive activity through a favorably
taxed organizational form An asset or productive activity through an unfavorably taxed
organizational form
Clientele-based High-tax-rate
taxpayers A relatively tax-favored asset
(one that bears a relatively high implicit tax) A relatively tax-disfavored
asset (one that bears a relatively more explicit tax)
 Low-tax-rate
taxpayers A relatively tax-disfavored
asset A relatively tax-favored asset

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But tax arbitrage may be prevented by tax-rule restrictions and frictions. Tax-rule restrictions are the  restrictions imposed by the taxing authority, which prevent taxpayers from using certain tax arbitrage techniques to reduce taxes in socially undesirable way (e.g., placing limits by tax authority on taxpayer’s ability to deduct interest only from the income out of investment by the borrowing) and frictions are the direct  transaction costs. Although tax-rule restrictions and frictions may impede employment of tax arbitrage  technique, but it is these frictions and tax-rule restrictions that make potential returns to tax planning so high.

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