[byrneseyeview]

But if the money is never distributed, how does it benefit the shareholders? My thought experiment from earlier in the thread: what is the net present value of a billion dollars in cash, if I put it on a rocket and launch it into space? If you can't get the money, you can't spend the money, and you can't enjoy the money.

You could theoretically borrow against those assets, but only if your lender expected you to be paid. That's the beauty of the plan: it means that the only taxable event is the one that materially benefits you.