Firm M and firm N are related parties. For the past several years, Firms M's marginal tax rate has been 34%, Firm N's marginal tax rate has been 25%. Firm M is evaluating a transaction that will generate $10,000 income in each of the next three years. Firm M could restructure the transaction so that the income would shift to firm N. Because of the restructuring, the annual income would decrease to $9,000.
Should Firm M restructure the contract?