Entity Structure and Taxes: An Analysis of Embedded Pass-Through Entities

We appreciate thoughtful comments from Charles Boynton, Paul Demere, Michael Donohoe, Katharine Drake, Arnie Greenland (discussant), Michelle Harding, Terri Holbrook, Jing Huang, Michael Mayberry, Scott Rane, Robert Ricketts, Eugene Seago, Erin Towery, Bill Wilson, Ron Worsham, The University of Arizona Tax Readings Group, the University of Connecticut Tax Readings Group, workshop participants at Virginia Polytechnic Institute and State University, and participants at the 2015 Internal Revenue Service-Urban-Brookings Tax Policy Center Joint Research Conference on Tax Administration. We thank Rahul Tikekar, Larry May, and John Guyton from the IRS for providing us with the relevant data and domain expertise and supporting our research.

The Internal Revenue Service (IRS) provided confidential tax information to the authors pursuant to provisions of the Internal Revenue Code that allow disclosure of information to the extent necessary to perform a research contract for the IRS. None of the confidential tax information received from the IRS will be disclosed in this treatise. Statistical aggregates will be used so that a specific taxpayer cannot be identified from information supplied by the IRS. All opinions are those of the authors and do not reflect the views of the IRS.

Ashish Agarwal, The University of Texas at Austin, McCombs School of Business, Department of Information, Risk, and Operations Management, Austin, TX, USA; Shannon Chen, The University of Arizona, Eller College of Management, Department of Accounting, Tucson, AZ, USA; Lillian F. Mills, The University of Texas at Austin, McCombs School of Business, Department of Accounting, Austin, TX, USA.

Editor's note: Accepted by Sonja Olhoft Rego, under the Senior Editorship of Mary E. Barth.