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Don't necessarily disagree with you about the usefulness (or lack thereof) of this idea. Check out http://en.wikipedia.org/wiki/Dodge_v._Ford_Motor_Company for an illustration. But, however you want to characterize the idea, it is still an unavoidable constraint on US corporations. I only bring it up to illustrate the doctrinal ambiguity that is seen in almost every part of the law.

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I take your point. But what may seem ambiguous to a corporation is not at all ambiguous to most citizens – myself included – who tend to see such tax structures as an underhanded way to game the system.

To frame it in more pragmatic terms, deploying these tax structures may hurt a company more than it helps due to the opprobrium they attract. Of course it's difficult to quantify the effects of bad press. But not all decisions should boil down to a cost-benefit analysis – what's wrong is wrong.

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