A Theory of Tax Planning

46 Pages Posted: 14 Dec 2021

See all articles by Mark Penno

Mark Penno

University of Iowa - Department of Accounting

Multiple version iconThere are 2 versions of this paper

Date Written: December 7, 2021


I present a model of tax planning in which the deductibility of the taxpayer’s transaction – if challenged – must be deliberated by the tax authority. Even when all facts are known, the outcome of a deliberation remains uncertain, and the only penalty that can be assessed when the tax authority prevails is the loss of the taxpayer’s claimed deduction. The results indicate that tax planning behavior and regulation differ substantially from the theoretical results found in the literature on tax evasion. For example, the tax authority’s implicit commitment to fewer challenges may actually increase net tax collections, while a policy of randomized challenges may not be an equilibrium. The theory of tax planning also suggests that the ‘undersheltering paradox’ is due to emergent shadow standards which create two distinct classes (conservative versus aggressive) of taxpayers.

Keywords: Tax planning; Shadow standard; S-curves

JEL Classification: M40

Suggested Citation

Penno, Mark C., A Theory of Tax Planning (December 7, 2021). Available at SSRN: https://ssrn.com/abstract=3980005 or http://dx.doi.org/10.2139/ssrn.3980005

Mark C. Penno (Contact Author)

University of Iowa - Department of Accounting ( email )

21 E Market St, Iowa City, IA 52242
Iowa City, IA 52242-1000
United States

Do you have a job opening that you would like to promote on SSRN?

Paper statistics

Abstract Views
PlumX Metrics