Martin A. Sullivan (Tax Analysts) presents Small and Big Business Tax Reform at Northwestern today as part of its Advanced Topics in Taxation Colloquium Series:

[P]assthrough businesses accounted for 83% of all business returns in 1980. By 2008, that figure had increased to 94%. Their share of total receipts, only 13% in 1980, grew to 34% by 2008. Their share of profits grew from 20% to 47%. Because the corporate tax is being “hollowed” out from below, the corporate tax more than ever is now a tax on big business. This development is the result of two phenomena: the dramatic increase in the size and number of Subchapter S corporations and the surge, mostly in the 1990s, in the number of limited liability corporations (LLCs), which are taxed as partnerships.