IRS Private Letter Rulings: Initial Evidence on Determinants and Consequences
研究了企业向美国国税局申请私人信函裁决的决定因素，发现积极税收筹划、并购多、分析师关注度高、杠杆率高及内部税务专长不足的企业更可能申请，而审计红旗企业则相反；申请后企业现金持有减少，表明裁决降低了税收不确定性。
Abstract This study examines the determinants of firms' requests for Private Letter Rulings (PLRs) from the US Internal Revenue Service (IRS) and their impact on firms' cash holdings. Our results show that PLR requests tend to be made by firms with more active tax planning, more acquisitions, higher analyst following, higher leverage, and less in‐house tax expertise. We also show that firms with IRS audit red flags are less likely to request a PLR. We use a difference‐in‐difference approach to assess changes in cash holdings following PLR requests and report a decrease in cash holdings for PLR firms, consistent with the notion that PLRs act to reduce tax uncertainty. Our study provides the first empirical evidence about the determinants of PLR requests and complements prior work on tax uncertainty and cash holdings (Hanlon, Maydew and Saavedra, 2017).