Report of the Department of the Treasury on integration of the individual and corporate tax systems

by United States. Dept. of the Treasury

The so-called classical system of current U.S. tax law treats corporations and their investors as separate entities and levies tax at both the corporate and shareholder levels on earnings from investments in corporate equity. Corporate earnings distributed to lenders as interest are generally deductible by the corporation and taxed, if at all, to the lender. Investors who conduct business activity in noncorporate form, such as a sole proprietorship or partnership, are taxed once on their earnings at the owners' tax rate. As a result, despite the critical role played by corporations as a vehicle for economic growth, the United States tax law often perversely penalizes the corporate form of organization. The current system of taxation also distorts corporate financial decisions in particular by encouraging debt and discouraging new equity financing of corporate investments. The tax system also prejudices corporate decisions about whether to retain earnings or pay dividends and encourages