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Tax Havens: International Tax Avoidance and Evasion

為了解決MAIN Dividend的問題，作者Gravelle, Jane G. 這樣論述：

Addressing tax evasion and avoidance through use of tax havens has been the subject of a number of proposals in Congress and by the President. Actions by the Organization for Economic Cooperation and Development (OECD) and the G-20 industrialized nations also have addressed this issue. In the 111th

Congress, the HIRE Act (P.L. 111-147) included several anti-evasion provisions, and P.L. 111-226 included foreign tax credit provisions directed at perceived abuses by U.S. multinationals. Numerous legislative proposals to address both individual tax evasion and corporate tax avoidance have been adv

anced. Multinational firms can artificially shift profits from high-tax to low-tax jurisdictions using a variety of techniques, such as shifting debt to high-tax jurisdictions. Because tax on the income of foreign subsidiaries (except for certain passive income) is deferred until income is repatriat

ed (paid to the U.S. parent as a dividend), this income can avoid current U.S. taxes, perhaps indefinitely. The taxation of passive income (called Subpart F income) has been reduced, perhaps significantly, through the use of hybrid entities that are treated differently in different jurisdictions. Th

e use of hybrid entities was greatly expanded by a new regulation (termed check-the-box) introduced in the late 1990s that had unintended consequences for foreign firms. In addition, earnings from income that is taxed often can be shielded by foreign tax credits on other income. On average, very lit

tle tax is paid on the foreign source income of U.S. firms. Ample evidence of a significant amount of profit shifting exists, but the revenue cost estimates vary substantially. Evidence also indicates a significant increase in corporate profit shifting over the past several years. Recent estimates s

uggest losses that may approach, or even exceed, ＄100 billion per year. Individuals can evade taxes on passive income, such as interest, dividends, and capital gains, by not reporting income earned abroad. In addition, because interest paid to foreign recipients is not taxed, individuals can evade t

axes on U.S. source income by setting up shell corporations and trusts in foreign haven countries to channel funds into foreign jurisdictions. There is no general third-party reporting of income as is the case for ordinary passive income earned domestically; the Internal Revenue Service (IRS) relies

on qualified intermediaries (QIs). In the past, these institutions certified nationality without revealing the beneficial owners. Estimates of the cost of individual evasion have ranged from ＄40 billion to ＄70 billion. The Foreign Account Tax Compliance Act (FATCA; included in the HIRE Act, P.L. 11

1-147) introduced required information reporting by foreign financial intermediaries and withholding of tax if information is not provided. These provisions became effective only recently, and their consequences are not yet known. Most provisions to address profit shifting by multinational firms wou

ld involve changing the tax law: repealing or limiting deferral, limiting the ability of the foreign tax credit to offset income, addressing check-the-box, or even formula apportionment. President Obama's proposals include a proposal to disallow overall deductions and foreign tax credits for deferre

d income, along with a number of other restrictions. Changes in the law or anti-abuse provisions have also been introduced in broader tax reform proposals. Provisions to address individual evasion include increased information reporting and provisions to increase enforcement, such as shifting the bu

rden of proof to the taxpayer, increased penalties, and increased resources. Individual tax evasion is the main target of the HIRE Act, the proposed Stop Tax Haven Abuse Act, and some other proposals.

The Valuation of Financial Companies: Tools and Techniques to Value Banks, Insurance Companies, and Other Financial Institutions

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為了解決MAIN Dividend的問題，作者Massari, Mario/ Gianfrate, Gianfranco/ Zanetti, Laura 這樣論述：

This book presents the main valuation approaches that can be used to value financial institutions. By sketching 1) the different business models of banks (both commercial and investment banks) and insurance companies (life, property and casualty and reinsurance); 2) the structure and peculiarities o

f financial institutions' reporting and financial statements; and 3) the main features of regulatory capital frameworks for banking and insurance (ie Basel III, Solvency II), the book addresses why such elements make the valuation of financial institutions different from the valuation of non-financi

al companies.The book then features the valuation models that can be used to determine the value of banks and insurance companies including the Discounted Cash Flow, Dividend Discount Model, and Residual Income Model (with the appropriate estimation techniques for the cost of capital and cash flow i

n financial industries). The main techniques to perform the relative valuation of financial institutions are then presented: along the traditional multiples (P/E, P/BV, P/TBV, P/NAV), the multiples based on industry-specific value drivers are discussed (for example, P/Pre Provision Profit, P/Deposit

s, P/Premiums, P/Number of branches). Further valuation tools such as the "Value Maps" or the "Warranted Equity Method" will be explained and discussed. The closing section of the book will briefly focus on the valuation of specific financial companies/vehicles such as closed-end funds, private equi

ty funds, leasing companies, etc. Mario Massari (Milan, Italy) is Full Professor of Corporate Finance, Head of the Finance Department, Director of the Institute of Accounting, Finance and Control from 2003 to 2007 at Bocconi University. Formerly full professor of Financial Management at Università

Cattolica di Milano and Ca’ Foscari of Venice. Gianfranco Gianfrate (Milan, Italy) is Assistant Professor of Finance, Bocconi University. He is Visiting Scholar, Boston College (2003) and Cass Business School (2006), Visiting Fellow, Harvard University (2007-2008) and Deputy Director, Clefin-Financ

e MSc. Laura Zanetti (Milan, Italy) is Associate Professor of Finance at Bocconi and Visiting Professor at the HKUST Business School.

投資者購買投資型保單之決策行為研究 -以Y券商為例

為了解決MAIN Dividend的問題，作者簡玫瑜 這樣論述：

國內證券商近幾年積極發展財富管理業務，在我國的金融市場，保險商品除了提供保障，尚具有十分重要的理財功能。不論是保守的傳統型儲蓄險，亦或是積極型的投資型保單，皆是當前熱銷的金融商品之一。國內有關投資型保單購買行為之相關文獻，多半以量化方式對消費者的購買偏好做研究，研究方向多從涉入程度、服務滿意度、產品績效等面向進行。本文將以Y證券商客戶為研究對象，探入探討影響其購買投資型保單之決策行為因素，從而提供證劵業未來投資型保單行銷策略規劃上的建議。本研究發現，受訪者在進行投資型保單購買決策時，「投資績效」、「風險性」與「配息平穩度」為主要的考量因素；而「品牌」、「口碑」、「費用率」與「業務員」等則為購

買決策的次要考量因素。高資產受訪者重視投資型保單的平穩度、風險性及稅制；在顧客滿意度與購買意願的關係上，年輕受訪者的購買決策與服務人員的服務態度並無相關性；而在高齡受訪者或是高資產受訪者，業務員對其購買決策則具有影響力。