所得税处理新规——明确股权投资损失的处理办法

2010年7月28日,国家税务总局（以下简称“国税总局”）发布了《关于企业股权投资损失所得税处理问题的公告》（国家税务总局公告2010年第6号,以下简称‘《公告》’）,明确了关于企业股权投资损失在扣除时间方面的税务处理。该《公告》是在《财政部、国家税务总局关于企业资产损失税前扣除政策的通知》（财税[2009]57号,以下简称“57号文”）、     

土地增值税筹划有方

土地增值税是对转让国有土地使用权、地上建筑物及其附着物并取得收入的单位和个人,就其转让房地产所取得的增值额征收的一种税。土地增值税为房地产开发企业税负中所占比重较大的税种,以下列示几种针对房地产企业的土地增值税筹划方法。     

Redistributive properties of progressive taxation

This note generalizes an equivalence between progressive taxation and the Lorenz-dominance ordering. The results are quite general, allowing for both non-differentiable tax functions and negative taxes.     

Stabilization through taxation inn-person games

In formulating solutions forn-person cooperative games, the concept of stability has played a dominant role. Although the core concept has the strongest stability, the core of a game is often empty. In this paper, the taxation system is incorporated into our framework, so that a modified solution concept, which enjoys the stability of core, can be developed. Various formulations based on principles such astaxation proportional to income andequity after tax are given.     

Accrual capital gains taxation and the lock-in effect

The recent literature on capital gains taxation suggests that assets are sold sooner when taxes are assessed and paid continuously rather than at the time of sale. Our analysis tends to support this view, for this suggestion is valid if the asset value function is convex or if it is concave and there is full or partial-loss-offset.     

Optimal income taxation with discrete skill distribution

This paper studies the pattern of the optimal marginal income tax rates in a discrete model allowing all forms of individual skill distribution. It derives an explicit solution to the optimal marginal income tax rates in terms of the parameters of the model, and then rigorously shows the optimal marginal tax rate can be U-shaped, inverse U-shaped, strictly increasing, or strictly decreasing in the interior of skill levels, depending crucially on skill distribution. The numerical examples indicate that the optimal marginal tax rates can be W-shaped and inverse W-shaped in the interior of skill levels. The explicit solution to the optimal marginal income tax rate derived in this discrete model can be used to find optimal marginal income tax rates for an economy with any empirical skill distribution, without the need to estimate the density function of skill.     

A note on taxation,incentives and risk sharing

The necessary and sufficient conditions for a tax system to guarantee the consistency of private and public evaluation of risky projects are derived. A stochastic dominance approach is used.     

Regulation of a prey-predator fishery by taxation

Bioeconomic exploitation of a prey-predator fishery is discussed by using a reasonable catch-rate function instead of the usual 'catch-per-unit-effort hypothesis'. The model is based on the assumption that only the prey species is harvested. A regulatory agency controls exploitation of the fishery by imposing a tax per unit biomass of the landed fish. The fishing effort is taken as a dynamic variable depending on the capital invested in the fishery. The dynamical system consisting of the growth equations of the species and also the fishing effort is formulated. The existence and stability of steady states are discussed. The optimal tax policy is studied with the help of Pontryagin's maximum principle. Finally, some numerical examples are carried out to illustrate the results of the model.     

Feedback Nash equilibria in optimal taxation problems

A well-known result in public economics is that capital income should not be taxed in the long run. This result has been derived using necessary optimality conditions for an appropriate dynamic Stackelberg game. In this paper we consider three models of dynamic taxation in continuous time and suggest a method for calculating their feedback Nash equilibria based on a sufficient condition for optimality. We show that the optimal tax on capital income is generally different from zero.     

Impact of taxation on international transfer pricing and offshoring decisions

A multinational company may move production to a foreign country to take advantage of low manufacturing cost, and/or experience tax savings. Transfer prices play an important and strategic role on income shifting by multinational companies. In this paper, we construct a framework for optimal decision making in global supply chains with uncertain and price-dependent demand, propose methods to improve global supply chain parties’ performance, and explore schemes to integrate global supply chains. The optimal pricing and offshoring decisions are investigated for different situations where the low foreign production cost and low foreign tax rate exist or only one of them is available. The case of low foreign tax rate without the advantage of low foreign production cost provides the most interesting findings that partial offshoring dominates when a certain threshold is met. In addition, the double marginalization is examined in decentralized global supply chains similar to the mechanism in newsvendor problems. Due to the existence of the tax jurisdiction, the double marginalization cannot be completely eliminated by coordinating schemes. Finally, the traditional buy back contract is found to be unable to coordinate global supply chains, while a modified sales sharing contract can improve the performance of the global supply chain.     

Progressive stable interpolation

In this paper, we study several interpolating and smoothing methods for data which are known “progressively”. The algorithms proposed are governed by recurrence relations and our principal goal is to study their stability. A recurrence relation will be said stable if the spectral radius of the associated matrix is less than one. The iteration matrices depend on shape parameters which come either from the connection at the knots, or from the nature of the interpolant between two knots. We obtain various stability domains. Moving the parameters inside these domains leads to interesting shape effects. This revised version was published online in June 2006 with corrections to the Cover Date.     

Axiomatic and game-theoretic analysis of bankruptcy and taxation problems: An update

A group of agents have claims on a resource but there is not enough of it to honor all of the claims. How should it be divided? A group of agents decide to undertake a public project that they can jointly afford. How much should each of them contribute? This essay is an update of Thomson (2003), a survey of the literature devoted to the study of such problems.     

Modelling taxation and redistribution: A discrete active particle kinetic approach

In this paper a general framework is proposed, suitable for the modelling of the taxation and redistribution process in a closed society. This framework arises within a discrete kinetic approach for active particle systems, and is expressed by a system of nonlinear ordinary differential equations. It is intended to describe the evolution of the wealth distribution over the population, based on the interactions of single individuals. The framework is then employed towards the construction of a toy model, which is analytically and computationally investigated.     

Premediation analysis of the energy taxation dispute in Finland

This paper illustrates a real application of negotiation and decision analytic techniques to a long-continued dispute between industry and the environmentalists in Finland. Specifically, we applied the so-called premediation analysis to discover efficient compromise solutions for Finland’s future energy taxation problem. The author’s role was to act as a neutral mediator. The premediation included the elicitation of the fundamental objectives of the disputants as well as their preferences relating to the issues under negotiation. The quantitative analysis pointed out several efficient compromise solutions to the dispute, implying that it was worth negotiating rather than unilaterally seeking to influence the state authorities. This induced the participants to start unofficial face-to-face negotiations mediated by the author. The compromise achieved together with the contacts created during the post-analysis negotiations contributed immediately to the Finnish Government’s first move towards a real ecological tax reform. Later on, the Government implemented a refund scheme for the industry that resembled by and large the one outlined in the post-analysis negotiations. This study thus provides a clear indication of the usefulness of the premediation concept in an unsettled conflict situation, where the disputants have not earlier tried to resolve their disagreements by negotiating.     

Progressive scattered data filtering

Given a finite point set $\text{Z⊂}\text{R}{}^{\mathrm{d}}$, the covering radius of a nonempty subset X⊂Z is the minimum distance r_X,Z such that every point in Z is at a distance of at most r_X,Z from some point in X. This paper concerns the construction of a sequence of subsets of decreasing sizes, such that their covering radii are small. To this end, a method for progressive data reduction, referred to as scattered data filtering, is proposed. The resulting scheme is a composition of greedy thinning, a recursive point removal strategy, and exchange, a postprocessing local optimization procedure. The paper proves adaptive a priori lower bounds on the minimal covering radii, which allows us to control for any current subset the deviation of its covering radius from the optimal value at run time. Important computational aspects of greedy thinning and exchange are discussed. The good performance of the proposed filtering scheme is finally shown by numerical examples.     

Progressive Basic Decision CPM

PERT and CPM are two valuable tools for the planning, scheduling and controllingof projects, but they do not on their own deal with the interdependence between planning resource utilization or direct cost expenditure and sclheduling with its overhead cost (penalty cost and/or reward bonus) implications. Several approaches to overcome this deficiency are possible, this paper dealing with one known as Decision CPM. The most recent approach to the Decision CPM problem known to the authors leads to relatively large integer programming problems which are solved as such. This paper considers a restricted formulation of the Decision CPM problem in an integer programming framework, and shows how it may be solved relatively easily witlhout resort to integer programming methods. Extensions of the restricted model are also considered briefly, some of which pose no difficulties, while others suggest the need for a hybrid of other approaches and that described here.     

A bilevel fuzzy principal-agent model for optimal nonlinear taxation problems

This paper presents a bilevel fuzzy principal-agent model for optimal nonlinear taxation problems with asymmetric information, in which the government and the monopolist are the principals, the consumer is their agent. Since the assessment of the government and the monopolist about the consumer’s taste is subjective, therefore, it is reasonable to characterize this assessment as a fuzzy variable. What’s more, a bilevel fuzzy optimal nonlinear taxation model is developed with the purpose of maximizing the expected social welfare and the monopolist’s expected welfare under the incentive feasible mechanism. The equivalent model for the bilevel fuzzy optimal nonlinear taxation model is presented and Pontryagin maximum principle is adopted to obtain the necessary conditions of the solutions for the fuzzy optimal nonlinear taxation problems. Finally, one numerical example is given to illustrate the effectiveness of the proposed model, the results demonstrate that the consumer’s purchased quantity not only relates with the consumer’s taste, but also depends on the structure of the social welfare.     

Progressive transmission of subdivision surfaces

Triangle meshes are a standard representation for surface geometry in computer graphics and virtual reality applications. To achieve high realism of the modeled objects, the meshes typically consist of a very large number of faces. For broadcasting virtual environments over low-bandwidth data connections like the Internet it is highly important to develop efficient algorithms which enable the progressive transmission of such large meshes. In this paper we introduce a special representation for storing and transmitting meshes with subdivision connectivity which allows random access to the detail information. We present algorithms for the decomposition and the reconstruction of subdivision surfaces. With this technique, the receiver can reconstruct smooth approximations of the original surface from a rather small amount of data received.