港报刊 admin 0评论


文:廖敏雄 Minxiong


Tax cut passage trumps fear of political failure


Steven Blitz






税改通过了,贸易协议的压力将上升- 中国不会愿意玩

Senate passes tax plan designed for negotiation withthe House

Focus of House and Senate plans is cut business notpersonal taxes

Eventual goal is to capture business expansion occurringabroad

With taxes passed, trade agreement pressures to increase–Chinais unwilling to play



The House tax plan looks like a plan to us; the Senateversion looks more like an agglomeration of bits and pieces designed to either captureneeded votes (which it did) and/or be bargaining chips in negotiating with theHouse. The Senate version consequently reflects Republicans’ fear of failing toget something enacted, a realistic fear when passage requires 50 of their 52 membersto agree.



It isdifficult to discern the economic impact of the Senate plan with its mix of taxchanges that either drop in late or leave early, all in the name of keeping thetotal cost of the package below the mandated $1.5trn ceiling over 10 years. Itsimpact is somewhat moot in any event, as a House/Senate conference committee, itsmembers chosen by the leaders of the two chambers, will now be tasked with reconcilingthe differences between the two plans. 

这两个税收计画的总体重点是提高企业的资本税后回报- 无论是企业或仲介实体(通常是小企业,专业服务,地产合伙企业等)。一揽子计画中包括了个人税收的变化,因为不管哪一方占多数席位,国会都不会通过把个人排除在外的企业减税。

The overarching focus of both tax plans is to raisethe after-tax return on capital for business – be they corporations or pass-throughentities (typically smaller businesses, professional services, real estate partnerships,etc). Personal tax changes were included in the package because Congress, regardlessof which party is in the majority, won’t pass a tax cut for businesses that excludesindividuals.



What the House plan does on the individual side is tosimplify the tax code for households by essentially reducing the number and levelof tax rates, increasing standard deductions and ending AMT. It pays for the costby eliminating or severely limiting deductions for medical expenses, mortgage interestand state and local taxes. On net, the outcome is not all that different from thestarting point: some income groups will gain a bit more than others lose. The costof simplification is the elimination of tax incentives that shape spending decisions,such as choosing to own rather than rent.


参议院的版本使得众议院在个人方面的计画複杂化,没有明显的目的,而不是让整体数字获得平衡。它结束了平价医疗法案(ACA)个人的强制条款,并通过取消州和地方的税收抵扣以及不废除最低替代缴税额度(AMT)来提高税收。但它恢复了全额抵押贷款利息抵扣。就好像原来还不够混杂要再弄混杂一点,参议院怕预算赤字变得太大,对个人所得税减免附加了所谓“夕阳”条款(5年后失效)。“夕阳”条款仅仅是为了使计画的静态数位游戏达到预期目标- 但没有人会期待下一任总统或国会允许这个太阳下山。

TheSenate version complicates the House plan on the individual side to no obviouspurpose other than to make the overall numbers work. It ends the ACA individualmandate and raises taxes by eliminating state and local tax deductions without endingAMT. But it restores the full mortgage interest deduction. As if this mixed bagwasn’t mixed up enough, the Senate attached sunset provisions to the personal ratecuts in case the budget deficit gets too big. The sunset clause is there only tomake the static maths of the programme work out as intended – no one expects thenext president or Congress to allow this sun to go down. 



私人洽购请致电1333-28-77772 联繫大公馆画廊叶小姐,或点击本连结访问内页索引


Thetax plan will ultimately be judged by its impact on capital formation, notably whetherit alters the business dynamic of growing profits but a net product (capital pluslabour) that, on a trend basis, has been a declining portion of GDP (see chart below).The three-pronged attack on increasing overseas production by US firms is to reduceregulations, lower taxes and renegotiate trade pacts. The flat trend for industrialoutput of durables and the surge in net imports of capital goods ex-autos, illustratedbelow, is a particular focus of this policy.


On the business side of the tax plan, here are somemajor differences between the House and Senate bills:



公司利息支出:众议院限制为税息折旧及摊销前利润(EBITDA)的30%。参议院将抵扣额调整到调整后的应纳税所得额的30%- 这个抵扣额比议会版本少。


仲介机构:众议院提出仲介机构25%的最高税率,限制其使用,并设定利润/工资的认定规则。参议院允许个人抵扣除国内合格营业收入的23%,降低有效税率。众议院设置25%的税率。参议院提出23%的抵扣,并扩大这些实体的定义,把公开交易合伙制企业(publicly traded partnerships)包括进来。



Corporate tax rate: cut to 20% from 35%, Senate begins2019.

Corporate interest expenses: House limits to 30% ofEBITDA. The Senate limits deduction to 30% of adjusted taxable income – effectivelya smaller deduction than the House version.

Capital investment: House has full expensing in yearone, provision expires in 2022. Senate also moves to full expensing, but phasesit out by 20 percentage points per year after 2022.

Pass-throughs: The House proposes a 25% top rate onpass-through businesses, limits its use and sets profit/wage designation. The Senatelowers the effective tax rate by allowing individuals to deduct 23% of domesticqualified business income. House sets 25% rate. Senate provides 23% deduction andwidens the definition of entities to include publicly traded partnerships

One-time tax on repatriated accumulated foreign profits:House taxes cash held abroad at 14% and the Senate at 14.5%. For illiquid assets,the House tax rate is 7% and the Senate’s is 7.5%.

Internationalincome: House and Senate versions move toward a territorial tax system. The Houseimposes an excise tax on some  payments madeby US corporations to related foreign firms. Senate requiresU.S.corporationsto include in taxable income its global intangible low-tax income.

为了调和这两个计画,我们认为众议院版本一般在个人方面胜出,而参议院版本在商业方面胜出,除了一个例外- 企业减税不要延迟一年。我们将看到他们如何为此多增加的成本达成一致,甚至可能採用22%的公司税率。

As for reconciling the two plans, we think the Houseversion generally wins out on the personal side and the Senate version predominateson the business side with one exception – no one-year delay on the corporate taxcut. We will see how they agree to pay for that, perhaps even by adopting a 22%corporate rate.



In regardto the deficit, whether one thinks the plan will generate the growth anticipatedby its backers or not (we lean towards the nots), it is virtually impossible toenact tax cuts that are not deficit-financed. That is because so muchUSbudget expenditureis in the form of transfers tied to entitlements such as Medicare and Medicaid(see chart below). Considering the low level of government consumption relativeto GDP compared with prior years, the impact on growth would probably be greaterif the government widened the deficit by spending more on goods and services (infrastructure).Then again, tax cuts are easier to legislate than a new bridge.


To help make sure the proposed cuts in businesstaxes do indeed boost domestic capex, we now expect mounting pressure to reformexisting trade deals and/or agree new ones. NAFTA, for example, is likely tocome back into the headlines in January. As forChina,the bonhomie of Trump’s Beijing visit has fadedfurther with the administration’s rejection of Beijing’s bid for market economy status andan anti-dumping investigation into PRC aluminium alloy sheet exports. Afull-scale trade war still seems unlikely, but expect plenty of pot shots inthe meantime, not least because Chinese exports to theUSin the first10 months of the year grow 11% yoy.




The US-China Comprehensive Economic Dialogue hasbeen frozen, and there has been a flurry of leaks from the administration abouta tougher trade approach. How much does that reflect the growing influence ofhawks on President Trump, how much presidential frustration, how much shapingup for midterm elections, how much inside-the-Beltway game playing? Probablyall four. But it is not going to impress President Xi and Co as they pursuetheir strategy of national projection. Ships passing in the night…


作者:廖敏雄 Minxiong,TS Lombard(中国)总经理,点击本页左下角可以继续“阅读原文”。




私人洽购请致电1333-28-77772 联繫大公馆画廊叶小姐,或点击本连结访问内页索引

(中环陆羽茶室 廖敏雄 Minxiong)








爱中概港股精华 – 微信公众号ichinastocks-hk

牛牛网 – 微信公众号:niuniuwang_cn


微信二维码测试 2 2 2 2 2 2 2 2 2 2 8 2 2 2 3 3 3 2 3 3 3 3 3 5 4 2 3 4 7 3 3 3 3 3 3 3 3 3 3 3 5 3 3 3 4 5 4 5 4 4 3 2 3 2 4 3 3 3 2 3 3 3 3 3 2 3 3 6 5 3 3 3 3 2 2 4 2 3 2 3 3 3 3 3 3 3 3 3 3 3 4 4 3 3 3 2 3 3 4 3 3 2 3 2 2 3 3 3 3 5 4 3 4 2 4 3 3 3 3 3 4 3 4 3 5 4 3 3 2 3 3 7 3 4 2 2 3 4 3 4 2 3 2 3 3 3 2 2 2 2 2 3 3 3 3 3 4 2 3 3 4 5 3 3 4 4 3 7 4 5 4 4 5 4 3 4 2 3 2 2 4 2 4 4 2 2 3 2 3 2 2 2 2 2 2 4

转载请注明:牛牛网 » 港媒:减税途径胜过对政治失败的恐惧——下一步是对华贸易谈判

您必须 登录 才能发表评论!