The effect of tax accounting rules on capital structure and discretionary accruals

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Abstract

This study investigates the effect of changing tax accounting provisions for long-term manufacturing contracts between 1984–1985 and 1989–1990 on debt and accrual policies using a simultaneous equations approach. The results indicate that firms adjust debt ratios and discretionary accruals with relatively high book-tax conformity to achieve tax planning goals and use discretionary accruals with relatively low book-tax conformity to accomplish financial reporting objectives. Manufacturing firms directly affected by the change in tax rules for long-term contracts increase their leverage by 6.2 percentage points more than other manufacturers.

Introduction

This paper investigates the effect of changes in the tax accounting rules for long-term manufacturing contracts on debt and accrual policies. More specifically, I determine the extent to which affected firms simultaneously adjust debt ratios and accounting accruals in response to changes in their marginal tax rates due to tax law changes between 1986 and 1989. I predict that affected firms will react to the increase in marginal tax rates by increasing debt ratios and reducing income-increasing accruals that have relatively high book-tax conformity to reduce their expected taxable income. Because these decisions reduce both taxable income and financial statement income, I argue that firms will simultaneously increase their financial statement income by recording income-increasing accruals that have relatively low book-tax conformity to avoid approaching debt covenant violations.

This investigation follows an important line of research on how firms coordinate their corporate policies to achieve potentially conflicting objectives (e.g., Trezevant, 1994; Beatty et al., 1995; Collins et al., 1995; Hunt et al., 1996). Previous research shows that tax rules can affect debt ratios (e.g., MacKie-Mason, 1990; Graham, 1996b) and discretionary accruals (e.g., Guenther, 1994; Guenther et al., 1997). However, empirical research does not document the interaction of changes in debt and discretionary accrual policies due to changes in tax rules. Documenting relations between leverage and financial reporting decisions that result from changes in tax accounting rules creates a richer theory of corporate policy differences across firms (Smith and Watts, 1992).

The analysis compares the changes in debt ratios and discretionary accruals for 54 manufacturing firms with significant revenues from long-term contracts and 410 other manufacturers between 1984–1985 (before the tax law change) and 1989–1990 (after the tax law change was fully phased-in). During this period, the average sample firm increased its debt ratio by approximately 38%. Using a simultaneous equations approach, the results indicate that changes in debt ratios during this period are negatively related to changes in discretionary accruals with relatively high book-tax conformity and positively related to changes in discretionary accruals with relatively low book-tax conformity. These results are consistent with the hypothesis that firms adjust debt ratios and discretionary accruals with relatively high book-tax conformity to achieve tax planning goals and use discretionary accruals with relatively low book-tax conformity to accomplish financial reporting objectives. The results also show that manufacturing firms directly affected by the change in tax accounting rules for long-term contracts increased their leverage by 6.2 percentage points more than other manufacturers. Though I do not find that affected firms adjusted their discretionary accruals between 1984–1985 and 1989–1990 more than other firms, I provide evidence that changes in income-increasing discretionary accruals with relatively high book-tax conformity are inversely related to expected changes in the marginal tax rates due to the change in the taxation of long-term contracts.

The results in this study are important for several reasons. First, I provide evidence that tax accounting rules can affect both financing and accounting policies. These results should interest policy makers who are concerned about the relation between tax law changes and tax revenue and finance and accounting scholars who investigate the relation between taxes and corporate policies. The results imply that it is important to analyze the effect of taxes on corporate policies across a variety of dimensions. Second, I provide additional evidence that discretionary accruals with relatively high book-tax conformity are used to achieve tax-planning goals. This finding extends previous research that documents the use of discretionary current accruals to manage earnings for tax-based objectives (e.g., Manzon, 1992; Guenther, 1994; Guenther et al., 1997) and managers’ reluctance to make income-increasing estimate revisions when the revision has potential tax ramifications (Keating and Zimmerman, 1999). Third, I find that managers are more likely to use discretionary accruals with relatively low book-tax conformity to manage earnings than accruals with relatively high book-tax conformity. This finding extends and generalizes the conclusions of previous studies that identify specific types of discretionary accruals that are used to manage earnings for financial reporting-based objectives (e.g., Beatty et al., 1995; Collins et al., 1995; Teoh et al., 1998). This finding will interest standard setters, auditors, and accounting researchers who are engaged in identifying the types of accruals used for earnings management (Healy and Wahlen, 1999).

The next section provides background on the tax accounting change examined in this study and analyzes the effect of tax accounting provisions on marginal tax rates and firm value. Section 3 describes prior research and develops the hypotheses. Section 4 describes sample selection procedures and the methodology used to test the hypotheses. Section 5 presents some descriptive statistics and the results. Section 6 offers some concluding remarks.

Section snippets

Tax accounting for long-term manufacturing contracts before TRA86

Prior to 1987, tax rules generally required manufacturing firms to account for their sales and cost of goods sold under an accrual method of accounting. However, special rules applied to firms that produced products under long-term contracts (LTCs) spanning two or more tax years. At the corporation's discretion, revenue and expenses attributable to long-term building, installation, construction, and manufacturing contracts could be accounted for under the percentage-of-completion (POC) method

Hypothesis development

TRA86 set in motion a series of tax bills that changed the economic landscape for companies with long-term contracts. The gradual elimination of the CC method during the years 1987–1989 caused many companies to recognize (for tax purposes) sizable amounts of income from old contracts (which were still taxed under the CC method) at the same time they were recognizing income from new contracts under the POC method. The tax law change provides an experimental setting to examine the effect of taxes

Data and empirical design

I examine the predictions in a three-equation model that explains changes in debt ratios (ΔDR), discretionary book-tax accrual ratios (ΔDTA), and discretionary book-only accrual ratios (ΔDBA) between 1984–1985 (pre-change years) and 1989–1990 (post-change years). Thus, the model examines changes in capital structure and discretionary accruals for the period beginning before the tax accounting rules for long-term contracts were first changed in TRA86 and ending after the POC method was required

Descriptive statistics

Table 2 presents descriptive statistics for the certain debt and discretionary accrual variables. The mean (median) debt ratio for all companies in 1984–1985 (BEGDR) is 14.7% (11.9) and the mean (median) discretionary book-tax accrual ratio for all companies in 1984–1985 is 2.3% (2.1) . In both cases, the ratios for POC firms are significantly higher than for non-POC firms. The mean discretionary book-only accrual ratio for all companies (0.5%) is also significantly lower than the ratio for POC

Summary and conclusions

This study uses a simultaneous equations approach to examine the effect of tax accounting rules on capital structure and financial accrual policies. I demonstrate how changes in tax accounting rules can affect marginal tax rates, rendering corporate debt and accrual policies suboptimal. I construct a three-equation model to explain interactions between taxes, debt policy, and accrual policy. Following MacKie-Mason (1990) and Graham (1996a), I focus on changes in debt and accruals, rather than

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    I thank S.P. Kothari (the editor), Merle Erickson (the referee), Jan Barton, Dan Dhaliwal, Greg Geisler, Clarece Nash, and workshop participants at Georgia State University, the 1998 annual meeting of the American Accounting Association, and the 1997 Southeast Regional AAA Consortium for helpful comments and suggestions, Scott Butterfield and Peijian Huang for research assistance, and Georgia State University for summer research support.

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