The Influence of Tax Costs on Organizational Choice in the Natural Resource Industry
This study investigates the influence of TRA86, pre-TRA86 tax strategies, and firm characteristics on S conversions in the natural resource industry. TRA86 shifted substantial individual tax costs to corporations, inviting conversions, but also lowered corporate marginal tax rates and changed aspects of the built-in gain provision to reduce conversion benefits. Built-in gain changes affect industries differently because of differences in asset composition and economic conditions. The natural resource industry had substantial built-in gain potential and was consolidating and restructuring during the mid-80s, making built-in gain realization likely. Our results suggest that built-in gains negatively influenced conversions in the natural resource industry. This study enhances our understanding of the interaction between TRA86 rate changes and other provisions on incentives to convert from C to S corporate status. It also contributes to the organizational form literature by identifying factors related to TRA86, S corporation operating restrictions, firm characteristics, and tax strategies that influence conversion decisions.