By Tony Rumble, Mohammed Amin, Edward D Kleinbard (auth.)
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In contrast, the CPS issued by Westpac Banking Corporation in 1993 had a low delta on issue (and hence low equity value) but rapidly gained in optionality as the underlying Westpac share price rallied – as the market expected. Merton, op. cit. 18. Compare the pro-integration approach of Warren, AC: Reporter’s Study of Corporate Tax Integration (American Law Institute, Philadelphia, 1993) with the US Treasury Department, Report of the Department of the Treasury on Individual and Corporate Tax Systems: Taxing Business Income Once (US Government Printing Office, Washington, January 1992).
This has vital implications for the investment appraisal of structured and synthetic equity positions, as well as for the broader construction of contemporary investment portfolios. CASE STUDY: INSTALMENT WARRANTS Instalments are the fastest growing structured product on the Australian Stock Exchange (ASX). Instalments can be used simply to increase leverage within portfolios, but for a risk-averse investor, they can also be used to increase the yield and reduce the tax payable within a wide range of investment vehicles, including complying superannuation funds.
Australia operates an ‘integrated’ corporate and personal tax system, where corporate proﬁts are taxed at the corporate level, with a tax beneﬁt – the franking credit – being provided to the investor to reﬂect the beneﬁt of tax paid at the corporate level. The seminal article by Merton suggests a framework for analysis of the efficiency of ﬁnancial products, and is central to the understanding of the efficiency of structured products 23 TA X AT I O N O F E Q U I T Y D E R I VAT I V E S AND STRUCTURED PRODUCTS 5 6 7 8 9 10 11 12 13 14 15 16 17 18 24 and synthetics which this book develops; see Merton RC: ‘Financial Innovation and Economic Performance’ (1992) 4 Continental Bank Jnl.