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A Note on Taxes and the Capital Structure of Partnerships, REITs, and Related Entities



Jaffe (1991) shows that the value of partnerships and REITs is generally invariant to leverage, although certain tax law provisions can result in an inverse relationship between value and leverage. This paper extends Jaffe's analysis to consider recourse and nonrecourse partnership debt, and special allocations of tax items financed by borrowings. It is shown that the relationship between value and leverage for S Corporations is similar to REITs with one added situation where value is inversely related to leverage. Finally, transaction costs can allow for a positive relationship between partnership leverage and value, a situation not addressed by Jaffe.

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  • James R. Hamill, 1993. "A Note on Taxes and the Capital Structure of Partnerships, REITs, and Related Entities," Journal of Real Estate Research, American Real Estate Society, vol. 8(2), pages 279-286.
  • Handle: RePEc:jre:issued:v:8:n:2:1993:p:279-286

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    References listed on IDEAS

    1. Jensen, Michael C. & Meckling, William H., 1976. "Theory of the firm: Managerial behavior, agency costs and ownership structure," Journal of Financial Economics, Elsevier, vol. 3(4), pages 305-360, October.
    2. Howe, John S & Shilling, James D, 1988. " Capital Structure Theory and REIT Security Offerings," Journal of Finance, American Finance Association, vol. 43(4), pages 983-993, September.
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    Cited by:

    1. Ebrahim, M. Shahid & Mathur, Ike, 2013. "On the efficiency of the UPREIT organizational form: Implications for the subprime crisis and CDO's," Journal of Economic Behavior & Organization, Elsevier, vol. 85(C), pages 286-305.

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    JEL classification:

    • L85 - Industrial Organization - - Industry Studies: Services - - - Real Estate Services


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