Errata Jcs-1-89

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After the 1986 Act, Congress became aware of the shifting of assets out of the corporate sector into widely-held publicly-traded partnerships (so-called "master limited partnerships") subject to a single-tier tax. To limit this potential corporate tax revenue drain, the Revenue Act of 1987 imposes a corporate level tax on certain publicly-traded partnerships.
A rationale for integration In the 1984-1987 period, domestic nonfinancial corporations re- tired $313 billion of net equity, while incre
...asing net indebtedness by $613 billion (see Table I-A). Billion dollar mergers, acquisitions, and leveraged buyouts are perhaps the most visible transactions fa- cilitating the flow of equity out of corporate solution; however, '^^ A. Atkinson and J. Stiglitz, Lectures on Public Economics, Chapter 5, (1980).
86 equity contraction also may be accomplished by redemption, debt- for-equity swaps (including unbundled stock units), and extraordi- nary distributions. Many commentators have concluded that the unintegrated two-tier income tax encourages these transactions.


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