Since the first tax bite was taken from the dollar of sales at the
point the company decided to report it as earnings instead of spending
it, the only tax that affects the decision whether to retain after-tax
earnings or pay dividends is the tax paid by the recipient of
the dividend. The majority of the stock of most high technology
companies and, by their inclusion in that group, New
Technological Corporations, is held by institutions. Many of these
institutions pay no taxes either because they are
tax-exempt, as are most pension funds, or by virtue of returning all
earnings beneficially to their shareholders, as do most
mutual funds. An institutional tax-exempt shareholder in
a company with high earnings may view dividend payments in a very
different light than an individual investor. The professional fund
manager who invests in a company is basically paid to return yields
greater than those achievable from Treasury Bills. If a company he
invests in cannot think of anything more productive do with its
earnings than buy Treasury Bills, he has every right and reason to
insist that profits be returned to him for investment at the
higher yields his investors hired him to obtain. In addition, whether
managing a diversified fund or a narrow industry-indexed fund, the
portfolio manager desires a ``pure play'' in the main business of the
companies he selects for his portfolio. It's not clear where a
``combined personal computer software manufacturer and money market
fund'' fits into the picture.