"Daniel N. Shaviro of New York University School of Law lauded the plan's move away from its old pure integration model, saying that 'there's a lot to like' in the new plan. He called the annual tax collection and the addressing of debt-equity positions of tax-exempts positive points to the proposal, but he still worried that companies may be discouraged from going public, even with the transition rules, and that the divide between publicly traded and nonpublicly traded companies still remained. Shaviro also expressed some skepticism that corporate tax reform could be accomplished in such sweeping measures.
"Shaviro said that one possible solution would be to address the biggest problems of the U.S. corporate tax system more narrowly, arguing for stronger thin capitalization rules and debt limits, rules on normal versus extra-normal returns, and international tax changes. 'There's a time for a bunt, instead of a grand slam,' he said.