After the adoption of partial integration in 2003, there has been only a modest rise in dividends, but a sixfold increase in redemptions. This article argues that the explanation for that lies in the different treatment of dividends and capital gains to foreign shareholders and that Congress should respond by making sections 302 and 304 inapplicable to foreign shareholders.
Avi-Yonah, Reuven S. "The Redemption Puzzle." Tax Notes 128, no. 8 (2010): 853-5.
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Reprinted with the permission of Tax Analysts.