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Effects of the Tax Reform Act of 1986 on Corporate Financial Policy and Organizational Form

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  • Roger H. Gordon
  • Jeffrey K. MacKie-Mason

Abstract

We examine the effects of the Tax Reform Act of 1986 on the financial decisions made by firms. We review the theory and empirical predictions of prior literature for corporate debt policy, for dividend and equity repurchase payouts to shareholders, and for the choice of organizational form. We then compare the predictions to post-1986 experience. The change in debt/value ratios has been substantially smaller than expected. Dividend payouts increased as predicted, but stock repurchases increased even more rapidly which was unexpected and is difficult to understand. Based on very scant data, it appears that some activities have shuffled among organizational forms; in particular, loss activities may have been moved into corporate form where they are deducted at a higher tax rate, while gain activities may have shifted towards noncorporate form, to be taxed at the lower personal rates. In addition, several interesting new issues are raised. One concerns previously neglected implications for the effective tax on retained earnings that follow from optimal trading strategies when long- and short-term capital gains are taxed at different rates. Also, new interest allocation rules for multinational corporations provide a substantial incentive for many firms to shift their borrowing abroad.

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  • Roger H. Gordon & Jeffrey K. MacKie-Mason, 1990. "Effects of the Tax Reform Act of 1986 on Corporate Financial Policy and Organizational Form," NBER Working Papers 3222, National Bureau of Economic Research, Inc.
  • Handle: RePEc:nbr:nberwo:3222
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    Cited by:

    1. Onji, Kazuki, 2009. "The response of firms to eligibility thresholds: Evidence from the Japanese value-added tax," Journal of Public Economics, Elsevier, vol. 93(5-6), pages 766-775, June.
    2. Konstantinos Tzioumis & Leora F. Klapper, 2012. "Taxation and Capital Structure: Evidence from a Transition Economy," FinanzArchiv: Public Finance Analysis, Mohr Siebeck, Tübingen, vol. 68(2), pages 165-190, June.
    3. Fossen, Frank & Simmler, Martin, 2012. "Differential taxation and firms' financial leverage: Evidence from the introduction of a flat tax on interest income," Discussion Papers 2012/4, Free University Berlin, School of Business & Economics.
    4. Goolsbee, Austan, 2004. "The impact of the corporate income tax: evidence from state organizational form data," Journal of Public Economics, Elsevier, vol. 88(11), pages 2283-2299, September.
    5. Fuest, Clemens & Huber, Bernd & Nielsen, Soren B., 2003. "Why is the corporate tax rate lower than the personal tax rate?: The role of new firms," Journal of Public Economics, Elsevier, vol. 87(1), pages 157-174, January.
    6. Hennessy, Christopher A. & Kasahara, Akitada & Strebulaev, Ilya A., 2020. "Empirical analysis of corporate tax reforms: What is the null and where did it come from?," Journal of Financial Economics, Elsevier, vol. 135(3), pages 555-576.
    7. Gordon, Roger H. & Lee, Young, 2001. "Do taxes affect corporate debt policy? Evidence from U.S. corporate tax return data," Journal of Public Economics, Elsevier, vol. 82(2), pages 195-224, November.
    8. Alan J. Auerbach & Joel Slemrod, 1997. "The Economic Effects of the Tax Reform Act of 1986," Journal of Economic Literature, American Economic Association, vol. 35(2), pages 589-632, June.
    9. Daniel R. Feenberg & James M. Poterba, 1993. "Income Inequality and the Incomes of Very High-Income Taxpayers: Evidence from Tax Returns," NBER Chapters, in: Tax Policy and the Economy, Volume 7, pages 145-177, National Bureau of Economic Research, Inc.
    10. Frank M. Fossen & Martin Simmler, 2016. "Personal taxation of capital income and the financial leverage of firms," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 23(1), pages 48-81, February.
    11. Peter Egger & Christian Keuschnigg & Hannes Winner, 2008. "Incorporation and Taxation: Theory and Firm-level Evidence," University of St. Gallen Department of Economics working paper series 2008 2008-20, Department of Economics, University of St. Gallen.
    12. Hanlon, Michelle & Hoopes, Jeffrey L., 2014. "What do firms do when dividend tax rates change? An examination of alternative payout responses," Journal of Financial Economics, Elsevier, vol. 114(1), pages 105-124.
    13. Xavier Giroud & Joshua Rauh, 2015. "State Taxation and the Reallocation of Business Activity: Evidence from Establishment-Level Data," NBER Working Papers 21534, National Bureau of Economic Research, Inc.
    14. Chang, Xin & Chen, Yunling & Dasgupta, Sudipto, 2019. "Macroeconomic conditions, financial constraints, and firms’ financing decisions," Journal of Banking & Finance, Elsevier, vol. 101(C), pages 242-255.
    15. Rünger, Silke, 2011. "The effect of Germany's Tax Reform Act 2001 on corporate ownership: Insights from disposals of minority blocks," arqus Discussion Papers in Quantitative Tax Research 114, arqus - Arbeitskreis Quantitative Steuerlehre.
    16. Florian Heider & Alexander Ljungqvist, 2012. "As Certain as Debt and Taxes: Estimating the Tax Sensitivity of Leverage from Exogenous State Tax Changes," NBER Working Papers 18263, National Bureau of Economic Research, Inc.
    17. Fossen, Frank M. & Simmler, Martin, 2016. "Personal Taxation of Capital Income and the Financial Leverage of Firms," EconStor Open Access Articles and Book Chapters, ZBW - Leibniz Information Centre for Economics, pages 48-81.
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    19. Clemens Fuest & Bernd Huber & Søren Bo Nielsen, "undated". "Why Is the Corporate Tax Rate Lower than the Personal Tax Rate?," EPRU Working Paper Series 00-17, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
    20. Graham, John R., 1999. "Do personal taxes affect corporate financing decisions?," Journal of Public Economics, Elsevier, vol. 73(2), pages 147-185, August.
    21. Silke Rünger & Rainer Niemann & Magdalena Haring, 2019. "Investor taxation, firm heterogeneity and capital structure choice," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 26(4), pages 719-757, August.
    22. Sanjay Dhamija & Ravinder Kumar Arora, 2019. "Impact of Dividend Tax Change on the Payout Policy of Indian Companies," Global Business Review, International Management Institute, vol. 20(5), pages 1282-1291, October.

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