Mark P. Gergen (UC-Berkeley) has published How Corporate Integration Could Kill the Market for Corporate Tax Shelters, 61 Tax L. Rev. 145 (2008). Here is the Conclusion:
The existing literature on corporate integration has overlooked a significant feature of a model of integration in which income reported by the firm is taxed at the investor’s rate. This creates a conflict between investors who face different tax rates or who have different investment horizons over the desirability of a firm shielding income from being reported as taxable. If streaming of reported and shielded income to the value-maximizing tax clientele can be constrained, then there is good reason to believe that moving to a system of integration would induce most firms to abjure the use of costly tax shields. The ultimate effect depends on many unknowns, in particular, the shape of the cost curve for corporate tax shields, the inclination of firms to exploit tax shields, and the elasticity of the demand by taxpaying investors for corporate equity held in non-tax deferred accounts. One thing I can confidently predict is that integration would shake up the world of corporate tax compliance and financial markets in heretofore uncontemplated ways. It would be a massive scale human subject experiment.



