NATIONAL BUREAU OF ECONOMIC RESEARCH
NATIONAL BUREAU OF ECONOMIC RESEARCH

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

Roger H. Gordon, Jeffrey K. MacKie-Mason

NBER Working Paper No. 3222*
Issued in December 1990
NBER Program(s):   PE

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 erarnings 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.

*Published: Joel Slemrod, editor. Do Taxes Matter?: The Impact of the Tax Reform Actof 1986. Cambridge, MA: The MIT Press, 1991.

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