17-2 Miller added personal income taxes to the MM equation. He argued (1) that the personal
tax rate was high on interest income and dividends but much lower on capital gains income,
and (2) that individuals could use various tax shields, including death, to avoid capital gains
taxes, while corporations could retain earnings, use stock buy-back programs, and so on to
help stockholders minimize personal taxes on income from stock. Miller’s conclusion was
Note that if all the tax rates were zero, the gain from leverage would reduce to zero, and
we would be back at the original MM position. Miller personally thought that this was the
most likely situation. Note also that if Ts = Td, i.e., the tax rates on stock and debt income
are equal, then the gain from leverage is equal to TcD, which is the MM with corporate
taxes position.
Most subsequent researchers concluded that Miller had a good point, but the personal
tax advantage of stock only partially, not completely, offset the advantage of corporate
debt, because Td > Ts. For example, suppose that Tc = 35%, Td = 28%, and Ts = 10%,
17-3 Under the MM and Miller assumptions, firms do not grow and the debt tax shield is
discounted at the cost of debt. Under these assumptions the value of the unlevered firm is
VL = VU + TD and the levered cost of equity is rsL = rsU + (rsU – rd)(1–T)(D/S). This
expression for the levered cost of equity also means that the WACC decreases as the level
of debt increases.