The 36th Annual American Taxation Association (ATA) Midyear Meeting

6:30 am - 5:30 pm

7:30 am - 6:00 pm

20th Annual KPMG/ATA Doctoral Consortium

Sponsored by KPMG Foundation

7:30 am - 7:00 pm

10th Annual ATA Teaching and Curriculum Conference

(space is limited; requires an additional registration fee)
Sponsored by PwC

6:30 am – 5:00 pm

7:00 am - 4:15 pm

Tabletop Displays

7:15 am – 8:15 am

8:15 am – 9:45 am

Concurrent Sessions

1.01 JATA Conference I
Does Tax Complexity Discourage Entrepreneurship?
Daphne Armstrong, University of North Carolina*; Stephen Glaeser, University of North Carolina Discussant: Hansol Jang, National University Singapore

When a Dollar is Not a Dollar: Examining How Timing and Delivery of Government Transfers Influence Household Consumption Decisions Ethan LaMothe, University of Central Florida*, Mary Marshall, Portland State University; Jason Schwebke, Texas Tech University
Discussant: Spenser Seifert, University of South Carolina

8:15 – 9:45 am

1.02 JLTR Conference I

 

Too Far and Not Far Enough: The Revised Statements on Standards for Tax Services
John Gamino, University of Texas at Dallas
Discussant: Julia Camp, Providence College

Ideas for JLTR Scholarship Based on 2023 Tax Developments
Presenter: Annette Nellen, San Jose State University

9:00am – 9:20am - Presentation

9:20am – 9:45am – Table Discussions

9:45 am – 10:15 am

10:15 am - 11:45 am 

Concurrent Sessions

2.01 JATA Conference II
Predicting Future GDP Growth: The Macroeconomic Information Content of Corporate Tax Receipts
Erin Henry, University of Arkansas; George Plesko, University of Connecticut; Dillon Walker, University of Arkansas*
Discussant: Brad Hepfer, University of Iowa

Qualitative Disclosure as a Tax Enforcement Mechanism: Evidence from the U.K. Tax Strategy Disclosure Requirement
Junwei Xia, Texas A&M University*
Discussant: Michelle Nessa, Michigan State University
 

10:15 am - 11:45 am 

2.02 JLTR Conference II

10:15am – 11:00am - Paper presentation:
Navigating the Premium Tax Credit Maze: Unlocking Healthcare Subsidies for International Students in the U.S.
Authors: Tony Lin, Rowan University and Anthony Curatola, Drexel University
Discussant: Amy Yurko, Duquesne University

11:00am - Ideas for JLTR Scholarship Based on IRA 2022 Energy Credits for Businesses
Author: Brigitte Muehlmann, Babson College
Presenter: Lynn Comer Jones, Georgia State University

11:00am – 11:20am - Presentation

11:20am – 11:45am – Table Discussions*

 

*Volunteers to be at different tables to aid discussion: Lynn Jones, Brigitte Muehlmann, Annette Nellen, Amy Yurko

11:55 am - 1:00 pm 

1:10 pm - 2:25 pm 

Concurrent Sessions

3.01 Concurrent – Multinational Taxation I
Moderator: Jenna El-Khalili, University of Florida

How Does Tax Enforcement Impact Effective Tax Rates Globally?
Lisa De Simone, University of Texas-Austin; Bridget Stomberg, University of Indiana; Brian Williams, Texas A&M University*
Discussant: Scott Rane, University of Florida

Lost in Information: National Implementation of Global Tax Agreements
Annette Alstadsæter, Norwegian University of Life Sciences; Elisa Casi-Eberhard, Norwegian School of Economics (NHH)*; Jakob Miethe, University of Munich; Barbara Stage, WHU – Otto Beisheim School of Management
Discussant: Susan Tang, University of Georgia

Carbon Leakage to Developing Countries
Diego Kaenzig, Northwestern University; Julian Marenz, London Business School; Marcel Olbert, London Business School*
Discussant: Henning Giese, Paderborn University

3.02 Concurrent – IRS Attention
Moderator: Alan Sohn, University of Florida

Regulatory Enforcement and CEO Race: Evidence from IRS Attention
Saipriya Kamath, London School of Economics; Shaphan Ng, Singapore Management University; Devin Shanthikumar, University of California-Irvine* Discussant: Jennifer Glenn, Ohio State University

A Perfect Storm: The Effect of Repeat Notices and Processing Delays on Taxpayer Behavior
Amy Hageman, Kansas State University*; Cass Hausserman, Portland State University; Mary Marshall, Portland State University; Kelli Saunders, University of Nebraska-Lincoln
Discussant: Jason Schwebke, Texas Tech University

The Impact of In-person Communication on Resolving Tax Uncertainty with the IRS: Evidence from Social Shutdowns during the COVID-19 Pandemic
Matthew Cobabe, Virginia Tech University; Jingjing Huang, Virginia Tech University*; Petro Lisowsky, Boston University; Kaishu Wu, University of Waterloo Discussant: Eric Weisbrod, University of Kansas

Abstract: We investigate whether in-person communication affects firms’ ability to resolve tax uncertainty with the IRS. Using publicly available data, we construct a novel measure that approximates the driving traffic between the firm’s headquarters and its closest IRS office to capture in-person communication between the firm and the IRS. We test our prediction by exploiting an exogenous social restriction shock—issuances of stay-at-home orders by different states during the COVID-19 pandemic. Firms with high in-person communication with the IRS before the issuance of stay-at-home orders experience a significant decline in their traffic to and from the closest IRS office, which supports our driving measure plausibly capturing the extent of in-person communication. Further, we find these firms are less effective at resolving tax uncertainty following the implementation of stay-at-home orders. This effect is particularly pronounced for firms having more interaction with the IRS prior to the pandemic, such as through participating in the Compliance Assurance Process (CAP) program and through auditors who provide more tax services. Our study informs both regulators and businesses on the relative effectiveness of in-person versus virtual communication during tax audits.

3.03 – CPA Exam Update
Moderator: JaLynn Thomas, University of Arkansas

Joe Maslott (AICPA Associate Director), and Annette Nellen (San Jose State University)

2:25 pm – 2:40 pm

2:40 pm – 3:55 pm

Concurrent Sessions

4.01 Concurrent – Taxes & Investment
Moderator: Tyler Menzer, University of Iowa

Customer Tax Uncertainty and Supplier Investment
Tzu-Ting Chiu, Norwegian School of Economics (NHH); Darcia Fischer, Boston University*; Petro Lisowsky, Boston University; Simone Traini, Norwegian School of Economics (NHH)
Discussant: Roger White, Arizona State University

Planning Through Competitive Threats: Incumbent Firm Tax Responses to Sharing Economic Disruption
Hannah Judd, Brigham Young University
Discussant: Miles Romney, Florida State University

The Consequences of Limiting the Tax Deductibility of R&D
Mary Cowx, Arizona State University; Rebecca Lester, Stanford University; Michelle Nessa, Michigan State University
Discussant: Michelle Harding, Virginia Tech University

Abstract:We study the tax payment and innovation consequences of limiting the deductibility of research and development (“R&D”) expenditures. Beginning with fiscal years ending on or after December 31, 2022, U.S. companies are required to capitalize and amortize R&D rather than immediately deduct these expenditures. Utilizing both cross-country and within-U.S. difference-in-differences research designs, we find affected U.S. firms’ cash effective tax rates increase by 5.6 and 10.1 percentage points, respectively. We also find some evidence that financially constrained U.S. firms’ R&D investments decreased relative to unconstrained firms. Finally, we observe that new tax-related disclosures reveal the existence and sizeable magnitude of firms’ previously unreported R&D activity. The paper provides new evidence on how tax-related disclosures uncover unreported innovation and provides policy-relevant information about the sizeable real and reporting effects to limiting innovation tax incentives.

4.02 Concurrent – Taxes & Human Capital
Moderator: Katie Boylen, University of Wisconsin

CEOs Capital Gains Taxes and Share Pledging
Jonathan Underwood, Boston College*; Ben Yost, Boston College
Discussant: Robert Hills, Penn State University

Communicating Human Capital Information Through Employee-Related Tax Incentive Disclosures
Stefan Richter, University of Illinois-Urbana-Champaign*
Discussant: Mary Vernon, University of Illinois-Chicago

Endowment Taxes, University Research and Corporate Innovation
Yoojin Lee, California State University-Long Beach; Aruhn Venkat, University of Texas-Austin*
Discussant: Russ Hamilton, Southern Methodist University

4.03 – State and Local Tax Insights
Moderator: Casey Schwab, University of North Texas
Presenter: Edvin Givargis and Parvin Van Enger (Andersen Tax)

The first segment of the State and Local Tax Insights presentation will focus on the intricate, and often controversial, California state tax residency landscape. This portion of the session offers a brief overview of California's operative residency laws and regulations, followed by a nuanced exploration of taxpayer motivations to change residency, opportunities, and pitfalls therein, effective and proactive planning, and risk mitigation.

Relevant topics will be highlighted through an examination of precedential administrative opinions issued by the California Office of Tax Appeals and further supplemented by the presenters’ experiences and perspectives arising from numerous decades of practice in the subject area.

3:55 pm –4:10 pm

4:10 pm – 5:25 pm

Plenary Session: Major Changes to Tax Law: CAMT, Pillars 1&2, and Moore v. US

Presenters:
– Sean Nearhoff (KPMG Tax Managing Director) - CAMT
- Doug McHoney (PWC, International Tax Services Global Leader) - Pillars 1&2
- Ted Seto (Loyola Marymount University, Loyola Law School) - Moore v. U.S.
Co-Moderators: Erin Henry (University of Arkansas) and Kelly Wentland (George Mason University)

 

5:30 pm –7:00 pm

6:30 am - Noon

7:00 am - 11:15 am

Tabletop Displays

7:15 am – 8:15 am

8:15 am – 9:30 am

Concurrent Sessions

5.01 Concurrent – Tax Avoidance
Moderator: Adrienne Depaul, University of Connecticut

Public Pensions and Firm Tax Avoidance
Vernon Riviera, University of Connecticut*
Discussant: Danielle Stanley, Coastal Carolina University

Strategic Alliances and Tax Avoidance: The Role of R&D Tax Credits
Sebahattin Demirkan, George Mason University*; Adam Olson, University of Cincinnati; Nan Zhou, University of Cincinnati
Discussant: Ben Osswald, University of Illinois – Urbana-Champaign

Risk, Reward, and Ratings: How Firms Use Tax Avoidance to Sustain Inflated Credit Ratings
Sean Flynn, Cornell University; Todd Kravet, University of Connecticut; Trent Krupa, University of Arkansas*; Samuel Piotrowski, Norwegian School of Economics (NHH) Discussant: Mehmet Kara, University of Kansas

5.02 Concurrent – Current Topics in Taxation
Moderator: Brian Forsberg, University of Illinois-Urbana-Champaign

Side Effects of the Tax Cuts and Jobs Act of 2017: Evidence from the Hospital Industry
Samantha Liew, University of Connecticut*; Frank Murphy, University of Connecticut Discussant: Anne Ehinger, Florida State University

A Tale of Two Taxes: Does Corporate Income Tax Avoidance Undermine the Role of Environmental Taxation in Promoting Environmental Sustainability?
Wei Lu, Xiamen University; Mark Ma, University of Pittsburgh; Kaishu Wu, University of Waterloo*; Jiaxing You, Xiamen University
Discussant: Barbara Stage, WHU-Otto Beisheim University

Market Reactions as Macroeconomic Barometer: Quantifying the TCJA's Effect on GDP and Wages
Kevin Standridge, Duke University
Discussant: Erik Beardsley, University of Illinois – Urbana-Champaign

5.03 ESG Reporting and Tax Considerations
Moderator: Jared Moore, Western Washington University

Presenter: Gustavo Perez, EY Managing Director

This session will share trends across sustainability and Tax and their impacts on Tax functions and business strategies, as well as sharing various governance and reporting items companies may have to comply with now and the future.
Click here to download slides

9:30 am – 9:45 am

9:45 am – 11:00 am

Concurrent Sessions

6.01 Concurrent – Taxes & External Auditors
Moderator: Kaitlyn Kroeger, University of Texas-Austin

Auditor-Provided Tax Services and Tax Disclosure
Thomas Kubick, University of Nebraska-Lincoln; Thomas Omer, University of Nebraska-Lincoln; Xiao Song, University of Nebraska-Omaha*
Discussant: Andrew Finley, Claremont McKenna College

Playing the Game? An Examination of Uncertain Tax Position Reserves Around the Purchase of Auditor Provided Tax Services
Brayden Bulloch, University of Wisconsin; Daniel Lynch, University of Wisconsin; Max Pflitsch, Technical University Munich*; Joe Schroeder, Indiana University
Discussant: Stevie Neuman, University of Missouri

The Effect of PCAOB Oversight on IRS Attention: Evidence from Foreign Companies
Shannon Chen, University of Arizona; Youkun Huang, University of Arizona*; Justin Kim, University of Arizona
Discussant: Aaron Mandell, University of Wisconsin-Milwaukee

Abstract: We examine whether the granting of Public Company Accounting Oversight Board (PCAOB) inspection access in foreign countries and the issuance of PCAOB inspection reports on foreign auditors affect Internal Revenue Service (IRS) attention. We exploit the PCAOB’s staggered inspection access to foreign auditors to examine our research questions and analyze a sample of foreign companies cross-listed in the U.S. We find that IRS attention to foreign companies decreases after their auditors become subject to PCAOB inspection access, suggesting a substitution effect between PCAOB monitoring and IRS attention. The effect is stronger in the presence of a local auditor regulator and among firms that engage a Big 4 auditor, and it is weaker when the IRS has greater resources. In addition, we document that the issuance of PCAOB inspection reports is associated with greater IRS attention, suggesting that the PCAOB’s assessments of audit quality are valuable signals to the IRS. Overall, these results suggest that there is both a substitution effect and spillover effect between PCAOB monitoring and the monitoring activities of the IRS.

6.02 Concurrent – Multinational Taxation II
Moderator: Angie Pae, University of Michigan

The Effect of Transfer Pricing Incentives on Financial Reporting of Intangible Assets: Evidence from Purchase Price Allocations
Jennifer Glenn, Ohio State University; Jeremy Lee, Texas A&M University*; Sean McGuire, Texas A&M University; John Robinson, Texas A&M University
Discussant: Novia Chen, University of Houston

Do Country-by-Country Disclosures to Foreign Tax Authorities Influence US Multinational Firms Public Financial Statement Disclosures about Foreign Operations?
Brian Grant, University of Indiana*; Sonja Rego, University of Indiana
Discussant: Cinthia Valle-Ruiz, IESEG School of Management

When Mandatory Private Disclosure Meets Voluntary Public Disclosure: The Effect of Private Country by Country Reporting on Management ETR Forecasts
Sabrina Chi, California State University-Fullerton*; Jingjing Huang, Virginia Tech University; John Jiang, Michigan State University; Anh Persson, University of Illinois-Urbana-Champaign
Discussant: Andrew Belnap, University of Texas-Austin

Abstract: Over 100 countries now require multinational corporations (MNCs) to annually disclose geographic breakdowns of their economic activities to tax authorities through country-by-country reporting (CbCR) to combat tax avoidance. In this study, we examine whether and how CbCR affects firms’ voluntary effective tax rate (ETR) forecasts. Using difference-in-differences and regression discontinuity design, we find that MNCs are more likely to issue voluntary ETR forecasts after CbCR implementation. This effect is especially pronounced for MNCs engaging in more tax avoidance prior to the policy adoption and for those experiencing an improvement in the tax-related internal information environment following the policy adoption. Additionally, we find CbCR improves analysts’ ETR forecast accuracy in countries with more voluntary ETR forecasts. Our findings suggest that mandatory private tax disclosure leads to improved voluntary public disclosures, generating external benefits for capital market participants.

6.03 DEI Session: Building an Inclusive Classroom
Presenters: Jeri Seidman (University of Virginia) and Bridget Stomberg (Indiana University)

Are you looking for ways to enhance students’ sense of belonging and increase opportunities for student success in your courses? This session is for you! In this interactive workshop, you will learn about and apply techniques to build an inclusive classroom with a focus on your students’ first impressions of you: your syllabus and first day of class. You can use the practical and easy-to-implement tools covered in this session in both tax and non-tax courses at all levels of instruction. Please bring a copy of your syllabus (either hard copy or on a laptop/tablet) to the session.

11:00 am - 11:15 am

11:15 am – 12:30 pm

Concurrent Sessions

7.01 Concurrent Session – Doctoral Research Forum
Moderators : Nathan Goldman, North Carolina State University ; Michelle Hutchens, University of Illinois-Urbana-Champaign

Cash Flow Unchained: Does the Tax Cuts and Jobs Act make U.S. multinational corporations more vulnerable to collective bargaining power?
Dennis Anh, University of California-Irvine ; Elizabeth Chuk-University of California-Irvine ; Charles Lee-University of California-Irvine*; Ryan Wilson-University of Iowa

Does tax regulation reduce uncertainty? Evidence from Transfer Pricing Regulations
Katie Daugherty, Indiana University*; Bridget Stomberg, Indiana University; Brian Williams, Texas A&M University

Capital Gains Taxes and the Acquisition Motive to IPO
Ben Yost, Boston College ; Enshuai Yu, Boston College*

Borderline Tax Planning
Brayden Bulloch, University of Wisconsin* ; Fabio Gaertner, University of Wisconsin ; Jeff Hoopes, University of North Carolina at Chapel Hill

Macroeconomic Effects of Profit Shifting
Jillian Adams, University of Waterloo* ; Preetika Joshi, McGill University ; Kevin Markle, Michigan State University

7.02 Concurrent – Political Costs of Taxation
Moderator: Austin Blake, Arizona State University

Tax Enforcement Aggressiveness as a Political Cost: Evidence from Governmental Contracts
Davidson Gillette, East Carolina University; Ryan Polk, Clemson University*; Shane Stinson, University of Alabama
Discussant: Michele Mullaney, Indiana University

Abstract: Tax authorities frequently focus their attention and resources on the largest companies, reflecting the conventional wisdom that such firms have the most motivation and ability to avoid taxes. However, based on political and accounting theory, we examine how tax authorities may also focus on companies with lucrative governmental contracts. This increase in political visibility, consistent with theory, prompts greater oversight and enforcement action from tax authorities, despite contracting companies’ unique incentives to self-govern their tax reporting and remain in good standing with the government. Further, the resulting settlement outcomes for politically visible corporations are more favorable to the government. Thus, these firms may serve as “targets of convenience” for tax authorities, providing insight into unexpected costs associated with governmental contracting. In supplementary analysis, we find that the SEC reduces its level of monitoring of politically visible firms, indicating that the strategy to increase enforcement is unique to the IRS.

Domestic Product Market Impacts of Politically Motivated Foreign Tariffs
Carlyle Burd, North Carolina State University; Victor Duke Ferguson, University of Kentucky*
Discussant: Christina Ruiz, Indiana University

The Effect of Complex Tax Administration on Small Businesses: Evidence from the Alabama Restaurant Industry
David Kenchington, Arizona State University; Christian Paparcuri, City University of Hong Kong; Jared Smith, North Carolina State University; Roger White, Arizona State University
Discussant: Eric Allen, University of California – Riverside

Abstract: We examine whether, controlling for tax rates, the compliance costs brought on by complex sales tax regimes are meaningful enough to discourage small business formation and survival. We measure complexity as locales requiring businesses to interact with multiple sales tax administrators for state, county, and municipal sales taxes. We study this question in the Alabama restaurant industry, as counties and municipalities in Alabama can choose to locally administer, have the state administer, or contract with a third-party to administer the county and local sales taxes. Academic research and professional commentary suggest that the incremental compliance costs from facing multiple sales tax administrators can be considerable, especially for small businesses, given the fixed cost component of compliance activities. Echoing this perspective, we find that more complex local sales tax administration regimes predict fewer restaurants operating in an area. In cross-sectional tests, we find that this effect is entirely concentrated in small restaurants with fewer than ten employees. These results are consistent with the idea that locally dictated dimensions of tax complexity can increase compliance costs to a degree that negatively impacts the entry and survival of small businesses.

7.03 AI in the Classroom
Presenter: John Barrick (Brigham Young University)

In today's rapidly evolving tax landscape, integrating generative AI into professional tax research is no longer a futuristic concept but a vital necessity. Creating a course policy for generative AI is a necessity. Understanding how to harness the power of generative AI enhances the precision and efficiency of tax research. It empowers professionals with the knowledge to construct their own GPT models tailored to their unique research needs. This session will discuss my use of generative AI last semester, build and deploy a course GPT, and compare student tax research performance with and without generative AI.

12:30 pm