Jacco L. Wielhouwer

Optimal Tax Depreciation with Uncertain Future Cash-Flows

Abstract Since taxable income consists of cash-flows reduced with depreciation charges, the choice of the depreciation method affects taxable income in future periods. A manager can therefore try to minimize the present value of future tax payments by choosing a particular depreciation method among those that are accepted by the tax authorities. We focus here on the choice between the two most commonly used methods in practice, i.e. the straight line depreciation method (SDM) and an accelerated depreciation method (ADM), such as the double declining balance (DDB) method and the sum of the years–digits (SYD) method. We show how the optimal choice depends on the discount factor, the degree of uncertainty in future cash-flows, and the structure of the tax system.

Only the Carrot, Not the Stick: Incorporating Trust into the Enforcement of Regulation

New enforcement strategies allow agents to gain the regulator’s trust and consequently face a lower audit probability. Prior research suggests that, in order to prevent lower compliance, a reduction in the audit probability (the “carrot”) must be compensated with the introduction of a higher penalty for non-compliance (the “stick”). However, such carrot-and-stick strategies reflect neither the concept of trust nor the strategies observed in practice. In response to this, we define trust-based regulation as a strategy that incorporates rules that allow trust to develop, and using a generic (non-cooperative) game of tax compliance, we examine whether trust-based regulation is feasible (i.e., whether, in equilibrium, a reduction in the audit probability, without ever increasing the penalty for non-compliance, does not lead to reduced compliance). The model shows that trust-based regulation is feasible when the agent sufficiently values the future. In line with the concept of trust, this strategy is feasible when the regulator is uncertain about the agent’s intentions. Moreover, the model shows that (i) introducing higher penalties makes trust-based regulation less feasible, and (ii) combining trust and forgiveness can lead to a lower audit probability for both trusted and distrusted agents. Policy recommendations often point toward increasing deterrence. This model shows that the opposite can be optimal.

Financial Accounting Effects of Tax Aggressiveness: Contracting and Measurement

This study examines a setting in which a tax-reporting decision is delegated to a firms tax manager. Using financial accounting measures of tax expense to evaluate the tax manager allows the firm to efficiently attain the level of tax avoidance it prefers, despite the fact that the consequences of the tax-reporting decision will occur in the future. The study also examines how well two accounting measures of tax aggressiveness — cash taxes paid and the unrecognized tax benefit — distinguish between conservative and aggressive firms.

Using Bilateral Advance Pricing Agreements to Resolve Tax Transfer Pricing Disputes

We investigate the use of bilateral advance pricing agreements (BAPAs) to resolve transfer pricing disputes between a taxpayer and two tax authorities. BAPAs are designed to protect firms from double taxation while reducing expected compliance costs. We identify settings in which we expect BAPAs to arise and investigate the effect of the program on compliance costs. We show that agreements are more likely to arise when the amount of income potentially subject to double taxation is low and the difference in tax rates between the two countries is high. We also show that the BAPA program can increase compliance costs.

Optimal tax depreciation lives and charges under regulatory constraints

Abstract. Depreciation is not only a representation of the loss in asset-value over time. It is also a strategic tool for management and can be used to minimize tax payments. In this paper we derive the depreciation scheme that minimizes the expected value of the present value of future tax payments for two types of constraints on the depreciation method. We show how the optimal scheme depends on the discount factor and the cash flow distributions. Moreover, we find the somewhat surprising result that the way in which the optimum is affected by uncertainty depends crucially on the type of regulatory constraint.

Dynamic tax depreciation strategies

The tax depreciation decision potentially has significant impact on the profitability of firms and projects. Indeed, the depreciation method chosen for tax purposes affects the timing of tax payments, and, as a consequence, it also affects the after-tax net present value of investment projects. Previous research focusses on the optimal choice of depreciation method under the assumption that the depreciation method has to be set ex ante and cannot be changed during the useful life of the asset. However, several countries allow changes of depreciation method under certain circumstances. This paper develops a dynamic programming approach to determine the firm’s optimal choice with regard to the initial depreciation method, and whether changes of method are proposed in later periods.

A breakpoint search approach for convex resource allocation problems with bounded variables

We present an efficient approach to solve resource allocation problems with a single resource, a convex separable objective function, a convex separable resource-usage constraint, and variables that are bounded below and above. Through a combination of function evaluations and median searches, information on whether or not the upper- and lowerbounds are binding is obtained. Once this information is available for all upper and lower bounds, it remains to determine the optimum of a smaller problem with unbounded variables. This can be done through a multiplier search procedure. The information gathered allows for alternative approaches for the multiplier search which can reduce the complexity of this procedure.

On the steady state of the replicating portfolio: Accounting for a growth rate

Abstract. For the risk management and transfer pricing of non-maturity liabilities, banks in Europe often use a so-called replicating portfolio technique. A commonly used implementation is replication of a fixed investment rule every time period. This paper deals with the development of the portfolio in the long run, when using this methodology. Applying this replicating portfolio technique yields, after a while, a steady state. Besides the straightforward result when volume is constant, we solve the steady states for the case where the funds (volume) grow with a fixed rate (e.g. due to credited interest or growth in GDP). We therefore define a system growth process, alternative to the Markov process (when volume is constant). From a transfer pricing and risk-management point of view, the resulting portfolio should satisfy certain requirements concerning return and flexibility. Once the steady state can be calculated for given growth rates, the investment policy can be specified. The importance of taking account of a growth rate is illustrated. Growth in volume implies that a different rule will converge to the desired steady state. This is illustrated analytically and with numerical examples. The purpose of the paper is not to find the ideal hedge strategy for non-maturity liabilities, but to improve the existing risk management without any implementation costs for the banks. Given the currently used methodology, accounting for a growth rate can significantly improve the risk management of non-maturity liabilities.

Investment Decisions and Depreciation Choices Under a Discretionary Tax Depreciation Rule

Prior studies have shown limited impact of the US bonus depreciation rules on firm investments during economic downturns. In this article we study the effects of a set of more flexible rules – discretionary tax depreciation (DTD) – introduced in the Netherlands during the 2009–2011 economic crisis. Our simulation results show DTD, which allows firms to accelerate and also to postpone depreciation, to be much more effective than bonus depreciation in reducing the expected value of tax payments, especially in crisis periods. Using a sample of 325 clients of a single office of a Dutch accounting firm, we show that DTD has led to higher investments in assets qualifying for discretionary depreciation for firms that faced the highest marginal tax rate. For other firms, the additional investments crowd out investments in assets that do not qualify for DTD. Our analysis on the actual depreciation choices reveals that firms postpone depreciation when facing losses or loss carry forwards, or to smooth taxable income under the progressive tax system. Our results suggest that a fiscal policy that permits firms to postpone depreciation, as well as to accelerate, may stimulate investment.

Development cost capitalization during R&D races

We investigate the economic effects of capitalizing development costs during a race between two firms to discover and develop a new technology. Winning the race requires success in the research stage and success in the development stage. Development costs are expensed in some settings, but capitalized in others. Capitalization of development costs provides a credible signal regarding progress in the race, allowing the rival to make a more informed decision regarding whether to proceed with development. We study the effects of this signal on the firms’ investment decisions and social welfare. We show that if both firms capitalize instead of expense development costs, aggregate investment in research weakly increases but aggregate investment in development weakly decreases. We also characterize the accounting policies that the two rival firms would adopt if they could freely choose either an expensing policy or a capitalization policy.