Organizational Form Choice and the Valuation of Oil and Gas Producers.
研究1985-1988年油气行业企业组织形态（公司制与合伙制）选择如何影响市场价值，发现合伙制企业勘探支出更低、股息更高，且股息仅对合伙制企业估值有显著影响，支持税收动机的组织形态选择理论。
Abstract The Tax Reform Act of 1986 reduced individual income tax rates below that of corporations. The fear that this would lead to a systematic disincorporation has not apparently materialized since the major stock exchanges report that only about 100 partnerships were traded during the next five years. Scholes and Wolfson (1992) suggest that this result is predictable because of the additional nontax costs of operating as a partnership, which include increased transactions costs, more restricted access to capital markets, and less control over management. Guenther (1992) and Terando and Omer (1992) provide evidence that firms must have considered both tax and nontax costs when choosing organizational form. This study examines whether the factors taken into consideration in organizational form choice also affected the market value of a sample of firms in the oil and gas industry during the period 1985-1988. We chose for our tests a valuation model used by Harris and Ohlson (1987) and others since many of the publicly traded (master limited) partnerships (MLPs) were created in the oil industry. The studies by Guenther (1992) and Terando and Omer (1992) show that MLPs generally had only one line of business, less debt, and higher dividend yields than their corporate counterparts. These differences are predictable in view of the tax consequences of operating in the partnership form. Guenther also finds MLPs to be less profitable, which is consistent with higher nontax costs of the partnership form. We show that MLPs invested significantly less in exploration for new deposits. The combination of the lower exploration expenditures, higher dividend yields, and poor financial performance suggests that MLPs may have been set up as limited-life entities to distribute assets to their unit holders in a tax-efficient manner. We extend the Harris and Ohlson (1987) valuation model by adding dividends and exploration levels. Exploration levels are found significant for both MLPs and corporations, but dividends are relevant only in the MLP model. We also find that dividend levels are significantly explained by asset values only for the MLPs. These valuation differences are consistent with tax-motivated organizational form choice and the perceived passive nature of the MLPs.