Does the Investment Interest Limitation Explain the Existence of Dividends?
Miller and Scholes show that under certain conditions the Federal Income tax taxes dividend income at a rate no higher than the rate on capital gains. Tabulations of actual 1977 tax returns show that the special circumstances under which this can occur apply to less than 3% of dividend income and no significant role can be ascribed to their result in the determination of corporate dividend policy.
Feenberg, Daniel. "Does the Investment Interest Limitation Explain the Existence of Dividends?" Journal of Financial Economics, Vol. 9, No. 3, (September 1981), pp. 265-269. citation courtesy of