Paper IJA
Tentar publicar numa revista académica internacional (com peer review) é um processo longo, com muitas contrariedades e desilusões pelo caminho.
Ao fim de algumas conferências e muitas alterações desde a proposta inicial, conseguimos finalmente a publicação.
Lamento não poder publicar a versão completa.
quarta-feira, 23 de setembro de 2009
domingo, 20 de setembro de 2009
Scott Dyreng
Foi adicionada na secção "Professores" a webpage de Scott Dyreng.
E os professores portugueses das áreas do conhecimento sobre que se debruça este blog? Por onde andam as webpages deles...
Para já ainda só encontrei a do Prof. Saldanha Sanches.
sábado, 19 de setembro de 2009
E em Portugal, como é?
Corporate manager aggressiveness in tax decision-making
by Zuber, Jill M., Ph.D., University of Arkansas, 2007 , 128 pages; AAT 3292662
Abstract (Summary)
"The Government Accountability Office has estimated that federal coffers have been deprived of $33 billion [in uncollected tax revenues] over the last 10 years by abusive tax shelters identified by the government" (Browning 2004, C-1). The Internal Revenue Services' approach of disallowing tax transactions is reactive, haphazard, and resource intensive. How much tax revenue has the U.S. government lost due to aggressive tax decision-making through potentially controversial tax choices not identified by the Internal Revenue Service (IRS)? The purpose of this research is to investigate the impact of (1) organizational culture, (2) commitment to the organization, and (3) risk and ambiguity on corporate manager aggressiveness in tax decision-making. Within the corporate environment, tax decisions are made on behalf and in the economic interest of the corporate taxpayer. Engaging in transactions or methods (tax shelters) that maximize after-tax returns, but are unintended by the law, illustrate aggressiveness in tax decisions. Tax choices can be classified as tax avoidance (legitimate means of reducing taxes that are specifically prescribed and endorsed by Congress), tax evasion (an illegal tax reducing method that is specifically disallowed by tax law, IRS regulations, or judicial precedent or the reporting of more deductions and/or less income than actually occurred), or as gray area choices. Tax choices exist in a gray area when they are not adequately described as either tax avoidance or tax evasion. For example, gray area choices are tax deductions that are not explicitly disallowed by tax law but are also not specifically allowed. For purposes of this study, gray area tax choices are defined as tax aggressiveness.
The purpose of the first study is to investigate the influence of organizational culture on corporate manager aggressiveness in tax decisions. Managers do not operate independently; they are affected by their environment, what others do, and their perceptions of what is acceptable by society, like minded professionals, other managers in the organization, and their organization's culture. The effect of organizational culture on tax decision-making is an important topic as pressure exists within corporate America to maximize after-tax profits and the IRS continues to disallow tax shelters taken by corporate taxpayers. Using an experimental task, 58 MBA students classified an asset for tax depreciation purposes. The results indicate that subjects assigned to an aggressive organizational culture make more aggressive tax choices than subjects assigned to a non-aggressive culture. Further, subjects in the non-aggressive culture treatment group consider their personal attitude towards taking risk in addition to the culture when making tax choices.
The purpose of the second study is to examine whether an individual's commitment (identification and attachment) to the organization amplifies or diminishes the effect of culture on aggressive tax decision-making. Theory suggests that individuals who are highly committed to the organization will make decisions that are aligned with the organizational culture. However, the results of this study indicate that individuals with low commitment make decisions aligned with their organization's culture. Regardless of their commitment to the organization, individuals in an aggressive culture make more aggressive tax decisions than those in a non-aggressive culture.
The purpose of the third study is to investigate the influence of environment ambiguity, risk, and tolerance of ambiguity on corporate manager aggressiveness in tax decision-making. Seventy-eight senior accounting students and graduate accounting students made a tax decision from three transfer pricing choices provided in an experimental task. Theory suggests individuals operating in ambiguous environments make conservative (unconservative) decisions because they overestimate (underestimate) the level of risk when it is low (high). The overall results of this study indicate that individuals are not impacted by ambiguity when making tax choices. However, the individual's assessment of risk is impacted by ambiguity when the risk of a particular tax choice is low. The tax choices and assessments of risk are not influenced by the individuals' tolerance of ambiguity. However, the importance of the magnitude of tax savings to individuals did differentiate those choosing the low risk tax choice from those choosing an aggressive tax choice. Finally, two new measures, intent of rules observance and tax aggressiveness as the norm, are developed and their influence on aggressive tax decision-making is explored.
This dissertation examines three potential causes, (1) organizational culture, (2) commitment to the organization, and (3) risk and ambiguity of corporate manager aggressiveness in tax decision-making. Collectively, this dissertation contributes to the literature by exploring antecedents and broadening our understanding of aggressive tax decisions made on behalf of corporate taxpayers.
by Zuber, Jill M., Ph.D., University of Arkansas, 2007 , 128 pages; AAT 3292662
Abstract (Summary)
"The Government Accountability Office has estimated that federal coffers have been deprived of $33 billion [in uncollected tax revenues] over the last 10 years by abusive tax shelters identified by the government" (Browning 2004, C-1). The Internal Revenue Services' approach of disallowing tax transactions is reactive, haphazard, and resource intensive. How much tax revenue has the U.S. government lost due to aggressive tax decision-making through potentially controversial tax choices not identified by the Internal Revenue Service (IRS)? The purpose of this research is to investigate the impact of (1) organizational culture, (2) commitment to the organization, and (3) risk and ambiguity on corporate manager aggressiveness in tax decision-making. Within the corporate environment, tax decisions are made on behalf and in the economic interest of the corporate taxpayer. Engaging in transactions or methods (tax shelters) that maximize after-tax returns, but are unintended by the law, illustrate aggressiveness in tax decisions. Tax choices can be classified as tax avoidance (legitimate means of reducing taxes that are specifically prescribed and endorsed by Congress), tax evasion (an illegal tax reducing method that is specifically disallowed by tax law, IRS regulations, or judicial precedent or the reporting of more deductions and/or less income than actually occurred), or as gray area choices. Tax choices exist in a gray area when they are not adequately described as either tax avoidance or tax evasion. For example, gray area choices are tax deductions that are not explicitly disallowed by tax law but are also not specifically allowed. For purposes of this study, gray area tax choices are defined as tax aggressiveness.
The purpose of the first study is to investigate the influence of organizational culture on corporate manager aggressiveness in tax decisions. Managers do not operate independently; they are affected by their environment, what others do, and their perceptions of what is acceptable by society, like minded professionals, other managers in the organization, and their organization's culture. The effect of organizational culture on tax decision-making is an important topic as pressure exists within corporate America to maximize after-tax profits and the IRS continues to disallow tax shelters taken by corporate taxpayers. Using an experimental task, 58 MBA students classified an asset for tax depreciation purposes. The results indicate that subjects assigned to an aggressive organizational culture make more aggressive tax choices than subjects assigned to a non-aggressive culture. Further, subjects in the non-aggressive culture treatment group consider their personal attitude towards taking risk in addition to the culture when making tax choices.
The purpose of the second study is to examine whether an individual's commitment (identification and attachment) to the organization amplifies or diminishes the effect of culture on aggressive tax decision-making. Theory suggests that individuals who are highly committed to the organization will make decisions that are aligned with the organizational culture. However, the results of this study indicate that individuals with low commitment make decisions aligned with their organization's culture. Regardless of their commitment to the organization, individuals in an aggressive culture make more aggressive tax decisions than those in a non-aggressive culture.
The purpose of the third study is to investigate the influence of environment ambiguity, risk, and tolerance of ambiguity on corporate manager aggressiveness in tax decision-making. Seventy-eight senior accounting students and graduate accounting students made a tax decision from three transfer pricing choices provided in an experimental task. Theory suggests individuals operating in ambiguous environments make conservative (unconservative) decisions because they overestimate (underestimate) the level of risk when it is low (high). The overall results of this study indicate that individuals are not impacted by ambiguity when making tax choices. However, the individual's assessment of risk is impacted by ambiguity when the risk of a particular tax choice is low. The tax choices and assessments of risk are not influenced by the individuals' tolerance of ambiguity. However, the importance of the magnitude of tax savings to individuals did differentiate those choosing the low risk tax choice from those choosing an aggressive tax choice. Finally, two new measures, intent of rules observance and tax aggressiveness as the norm, are developed and their influence on aggressive tax decision-making is explored.
This dissertation examines three potential causes, (1) organizational culture, (2) commitment to the organization, and (3) risk and ambiguity of corporate manager aggressiveness in tax decision-making. Collectively, this dissertation contributes to the literature by exploring antecedents and broadening our understanding of aggressive tax decisions made on behalf of corporate taxpayers.
sábado, 12 de setembro de 2009
Procedimento de inspecção
Acordão do TCAS - Inspecçõespdf
E as questões formais voltam a ganhar...
Não teve o sujeito passivo oportunidade de demonstrar a integridade do sistema informático? Essa sim, a questão central na busca da verdade fiscal, à qual foi alheia a decisão judicial.
E as questões formais voltam a ganhar...
Para este caso em concreto, será a questão controvertida suficiente forte para gerar a anulabilidade?
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