Ernest R. Larkins

On Compliance with Ethical Standards in Tax Return Preparation

The Statements on Responsibilities in Tax Practice (SRTPs) provide guidance to the CPA when making decisions in tax practice. Many of these decisions are ethical in nature and have implications for tax compliance. In this study, a survey methodology is used to test whether the SRTPs affect decisions that CPAs make. The findings suggest that a clear majority of CPAs follow the SRTPs when making ethical decisions relating to tax return preparation and that CPAs follow the SRTPs more often than unlicensed preparers on half the issues tested. However, a statistically significant number of CPAs do not follow the SRTPs and, CPAs do not follow the SRTPs any more often than unlicensed tax preparers on three issues.

Double Tax Relief for Foreign Income: A Comparative Study of Advanced Economies

This article involves a comparative analysis of tax laws providing unilateral relief that reduce or eliminate the double taxation of foreign income. Countries use two general methods to provide such relief: the exemption method and the foreign tax credit. This paper explores capital export neutrality and capital import neutrality as a method for evaluating international tax policies, and compares the double tax relief methods of seven advanced countries.

Marginal tax rates on foreign profits of U.S. multinationals

Many studies find that taxes influence capital location, income shifting, and capital structure decisions of multinational companies. So, reasonably estimating the marginal tax effect of international business decisions is important. However, simple marginal tax rate (MTR) proxies, such as a foreign countrys top statutory rate or a rate that assumes remittance of all foreign profits as current dividends, fail to capture many tax law complexities. This article develops an algebraic “mixed remittance” model for calculating a U.S. companys MTR on its foreign subsidiarys profits. In contrast to the simpler proxies, the mixed remittance model allows foreign profits to be remitted in different forms (i.e. not just as dividends) and across varying time periods (i.e. not just the current period[t Also, the mixed remittance model considers withholding taxes, tax deferrals from postponed dividends, and foreign tax credit positions. Paired t-tests show that the resulting MTR measure often differs significantly from the two simpler MTR proxies.