An Accretion Corporate Income Tax
This paper also describes how to implement the tax. In order for the tax to fall on income requires some adjustments. The basic rule for making these adjustments is to add nondeductible expenditures, such as dividends and federal income taxes, and to subtract nonincludable items, such as the proceeds of loans and equity offerings. The tax would also require the periodic valuation of nontraded securities, such as stock options issued to management, using option pricing techniques.
Stanford Law Review
49 Stan. L. Rev. 1 (1996)