Financial Regulatory Forum

from Tales from the Trail:

The wishful thinking behind a repatriation tax holiday

By Ryan McCarthy

The opinions expressed are his own.

Big U.S. multinationals have a strange sense of timing: apparently, now is the ideal time to fight for a tax holiday. The New York Times on Monday had an in-depth look at the topic of a repatriation tax holiday, with lovely charts and a helpful video detailing the myriad ways corporations cut their tax bills by stashing profits overseas. Given the clamoring about lack of demand in the economy, the deficit talks and swollen corporate cash holdings, the lobbying push seems poorly timed at best.

New York Times' David Kocieniewski is rightly skeptical of the effort that’s currently backed by even tech titans like Apple and Google. He ferrets out an NBER study that excoriates the results of an abysmal 2004 dalliance with a repatriation tax holiday, which the study finds, led to little actual hiring and investment in the U.S. The appeal of a repatriation tax holiday is that large U.S.-based corporations could temporarily see much of their taxable income fall to 5.25 percent -- the rate often paid through overseas subsidiaries -- from 35 percent, the U.S. corporate rate. In theory, this windfall would temporarily prevent corporations from stashing profits overseas, bring in tax revenue, create jobs and spur investment.

And while Kocieniewski spends nearly 2,000 words on the issue, he doesn't mention specifics of the actual legislation in play, which make the latest tax repatriation push seem just as unpromising as its predecessor.

The "Freedom to Invest Act" -- a title that couldn't be more ironic given the state of corporate coffers -- makes at best only a cursory attempt to do better than its 2004 version. Introduced by Rep. Jim Brady (R-Texas), the bill has gained nine co-sponsors, including Democrats like Colorado's Jared Polis and Tennessee's Jim Cooper.

The key difference in the current version of the repatriation push seems to be a taxable income penalty of $25,000 that would be assessed to corporations that lay off employees within two years of the tax holiday. The penalty is meant to punish corporations that repatriate overseas profits, then simply pay that money to their shareholders and do little or no hiring.

COMMENT

If I had a fortune safely esconced in some other country with a low tax rate I would leave it there, rather than have some politician redistribute, confiscate or attach long term obligations to the “holiday”.

Posted by zotdoc | Report as abusive

from The Great Debate:

Taxing spoils of the financial sector

If you want less of something, tax it.

That truism is often used as an argument against a tax on profits, or health benefits, or employment, but in the case of the rents extracted from the economy by the financial services industry here's hoping it proves more of a promise than a threat.

The International Monetary Fund has put forward two new taxes on banks to pay the costs of future rescues, one of which is a fairly conventional "Financial Stability Contribution," with an initial flat levy on all banks, to be refined later into something with more precise institutional and systemic risk adjustments.

More interestingly, the IMF is also proposing a "Financial Activities Tax," (FAT) a tax on bank pay and profits which, if correctly designed, could serve as a tax on rents -- the unwarranted spoils -- of the financial sector.

In economics the concept of "rents", essentially the extra money a given individual or industry is able to extract from its clients above what it would if there were perfect competition, is central. If there is only one cable television provider in your neighborhood you will know what I am talking about.

In financial services, the evidence is that rents are huge, in part because of impaired competition and in part because increasingly complex financial services allow banks to sell clients products that they don't understand, may not need and will almost always be over-charged for. Bank employees in turn charge hefty rents to their bosses, boards and shareholders, each of whom, as you journey up the organizational chart, understand less about the complex services, and like clients, are then less able to defend their own interests.

Some of the best evidence forming the intellectual underpinning of this is provided by economists Thomas Philippon of New York University and Ariell Reshef of the University of Virginia, whose work found that about 30 to 50 percent of the extra pay bankers get as compared to similar professionals is attributable to rents. <http://people.virginia.edu/~ar7kf/paper s/pr_rev15_submitted.pdf>

COMMENT

As a long in the tooth former consultant to Central Banks & Commercial Banks, here is my “old fashioned” view.

Banks are the primary engine driving the world’s economy.

Tax the Banks and they will pass it on their customers.

More expensive money means Less economic dynamism & incidentally more unproductive public service costs to regulate.

Obama must have fools for advisers.

But what do I know, it is 20 years since I was advising governments of the world.

Posted by investeast | Report as abusive

Australia tax body may harden stand on private equity

   By Victoria Thieberger    MELBOURNE, April 21 (Reuters) – The Australian tax office has delayed two critical rulings on how private equity firms are taxed, in a move that tax experts say means the office is hardening its stance against private equity. (more…)

from MacroScope:

A “Greed Tax” on banks

Photo

The International Monetary Fund has done what it was bid by the G20  and come up with proposals for getting banks to pay for the government help they receive when they get in trouble.  You can read the actual wording here, but it comes down to this:

1) A "Financial Stability Contribution" which would be pooled into a fund that would use it to help weak banks, or just go into general government revenues.

2)  A "Financial Activities Tax" -- perhaps intentionally known as FAT -- to be levied on combined bank profits and remuneration (for which read "bonuses") and paid to governments.

The first is a kind of insurance policy. The second, however, looks decidedly like what might be called a Greed Tax -- government action on the kind of wealth that has infuriated taxpayers across the world.

The debate will be over whether this is simple kowtowing to populist sentiment or whether it is a reasonable limit on people being accused of knowing none.

U.S. government to enhance municipal market regulation

    WASHINGTON, March 2 (Reuters) – The Internal Revenue Service has agreed to work more closely with the Securities and Exchange Commission to regulate the U.S. municipal bond market, the IRS said on Tuesday, adding the two federal agencies had signed memorandum of understanding. (more…)

ANALYSIS-Private equity firms brace for tax battle

   By Megan Davies and Kim Dixon    NEW YORK/WASHINGTON, Feb 7 (Reuters) – Private equity firms are again being threatened with higher taxes, as a long-running debate over how to classify their profits again becomes a focus for governments desperate for cash. (more…)

Liechtenstein may sign other tax deals – paper

Photo

   ZURICH, Feb 5 (Reuters) – Liechtenstein may negotiate agreements with countries similar to the one it has with Britain, Crown Prince Alois was quoted as saying in a Swiss newspaper on Friday. (more…)

EU economy, tax nominees may face second grilling

Photo

By John O’Donnell

BRUSSELS, Jan 14 (Reuters) – One of the European Union’s top lawmakers has said she may demand a second hearing to quiz the bloc’s designated tax and economics chiefs before the committee she leads decides whether to approve their appointments.

The remarks by Sharon Bowles, who leads the influential economic and monetary affairs committee, cast uncertainty over the line-up of the next European Commission, in particular the would-be tax chief, who has already faced criticism.

“I would have liked more questioning time with him,” Bowles said of Algirdas Semeta, the Lithuanian candidate to take charge of EU taxation whose answers at a European Parliament hearing were described by socialists as unconvincing.

Commenting on Finland’s Olli Rehn, the candidate to become the 27-country bloc’s economic and monetary affairs chief, Bowles said: “On many things he was strong and interesting. On other things we would have liked more information.”

Bowles said she may seek a second hearing with both. She signalled this was more likely for Semeta than Rehn, who is already an EU commissioner and has faced little criticism following his appearance before lawmakers to win their approval.

“I’m not going to say no to that. We might,” she said when asked if she would request a second hearing. “If you want us to do a good and worthy appraisal you have to give us the time.”

Italy says considering further tax amnesty

    ROME, Dec 15 (Reuters) – Italy’s government is considering a further tax amnesty following this year’s amnesty, which is scheduled to expire on Tuesday and expected to raise up to 4.0 billion euros in windfall tax revenues. (more…)

Banks expected to swallow most of new UK bonus tax

Photo

By Steve Slater

LONDON, Dec 11 (Reuters) – Banks are likely to swallow the bulk of the cost of a shock UK tax on bonuses unveiled this week, rather than pass it on to staff or find loopholes, as more countries join the clampdown on payouts, industry experts and sources said.

Britain slapped a special 50 percent tax on bank bonuses on Wednesday, provoking outrage across the industry and raising fears that London will lose talented staff and business to rival financial centres.

But France looks set to follow with its own one-off tax and Germany and other countries may clamp down on the free-wheeling bonus culture that critics say fueled the financial crisis. If more follow, it could reduce the impact on London and also prompt banks to absorb most of the cost, experts said.

“The mood over the last 24 hours seems to be that most banks will swallow the pill,” said Neal Todd, corporate tax partner at law firm Berwin Leighton Paisner.

Banks are still assessing the impact of the tax, notably its scope in terms of whether it will stretch to asset management, private equity and other activities, and how far it applies to staff who spend just some of their time in Britain.

“Our feeling is the banks will take it on the chin, realise it’s punitive and a one-off and if they try to wiggle out of it then next time around the government will be even harsher,” said Benjamin Williamson, economist at the Centre for Economics and Business Research (CEBR).

  •