Abstract
We develop a valuation model that integrates corporate capital structure and dividend payout policies. The resulting “extended” Miller (J Financ 32:261–297, 1977) model explicitly incorporates the different tax rates on corporate income, personal interest, dividends, and capital gains. We apply the model to ten different U.S. tax regimes since 1979 and generate several testable predictions. When the dividend tax rate exceeds the capital gains tax rate, dividend payout can partially offset value-enhancing effects of leverage. When the two rates are close, dividend payout loses its moderating influence. Using the S&P 1500 universe, we obtain empirical results that are consistent with the model’s predictions.
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Notes
τ c : Corporate tax rate; τ s : Personal tax rate on equity income; τ d : Personal tax rate on interest income.
See the Appendix for the intermediate steps.
Note that the after-tax perpetual interest payments discounted by the required rate of return for the riskiness of the firm debt equals the market value of the debt D. The assumptions necessary for this derivation are the same as those in the original MM analyses.
We assume a symbolic value of $1.00 for a non-dividend-paying all-equity firm. The gain from leverage and loss from payout emerge as a percentage of this $1.00 baseline value as a function of the four tax rates.
The slopes of the sides of the wedges in Fig. 2 are smaller for the low payout firms (toward the higher side) than for high payout firms (toward the lower side).
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The paper benefited greatly from detailed insights and comments generously provided by the late Franco Modigliani. Comments by an anonymous reviewer improved the paper significantly. We gratefully acknowledge input by colleagues and research support from University of Washington, Bothell and Georgia State University, Robinson College of Business. Karel Vandromme and Leng Ling provided excellent research assistance. The usual disclaimer applies.
An erratum to this article can be found at http://dx.doi.org/10.1007/s12197-012-9225-z.
Appendix
Appendix
By cross-multiplying the middle term,
and combining the first and the third terms of the new expression, we have
Now, by taking the rD term from the second term and combining it with the third term,
and by taking \( \left( {1 - \tau_{pi} } \right) \) outside of the third term and rearranging,
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Ince, U., Owers, J.E. The interaction of corporate dividend policy and capital structure decisions under differential tax regimes. J Econ Finan 36, 33–57 (2012). https://doi.org/10.1007/s12197-009-9101-7
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DOI: https://doi.org/10.1007/s12197-009-9101-7