What if Harvard Chemistry were structured as a for-profit corporation?

Bloomberg's Matt Levine is a very fun financial writer, and this week's column as to how to avoid the new potential 21% endowment tax is hilarious. 

In the current framework, a big capital gain is good, for the university. In a 21% excise tax framework, it is less good. (It’s 21% less good.) In the excise-tax framework, $100 of endowment income would pay for $79 of professors’ salaries. But if a for-profit corporation were to pay $100 of professors’ salaries, that payment would be tax-deductible (for the corporation). And so the trade is something like:

1. The for-profit Chemistry Corporation hires all of Harvard’s chemistry professors, sets them up with labs, buys their equipment and pays their graduate students. Let’s say the operating budget of the chemistry department is $8 million, a number I just made up. The Chemistry Corporation takes over the responsibility for that budget.
2. Harvard invests $100 million in the Chemistry Corporation and gets 95% of the stock; the professors get the rest.
3. The Chemistry Corporation re-invests that cash with whoever currently manages Harvard’s endowment, targeting an 8% annual return.
4. The Chemistry Corporation makes $8 million a year on its investments, and pays $8 million a year in operating expenses, for a net income of $0.
5. It pays no taxes, because it has no net income.
6. Harvard doesn’t pay any excise tax on the return on its $100 million Chemistry Corporation investment, because that return is zero.
7. Harvard also rents office space to the Chemistry Corporation (not taxable, because not investment income?) and pays, you know, $1 a year for the Chemistry Corporation to provide teachers for undergraduate chemistry classes.
8. I guess if they discover a valuable new chemical that’s gravy.

There is a precisely analogous approach for the Harvard Professional Football Team Inc., though it could also earn revenue from ticket sales. Or for the Classics Corporation, which probably couldn’t.

First of all, surely the Harvard chemistry department's annual budget is much more than $8 million. I'm guessing it's closer to $80 million, but university department finances are weird, especially since each professor can bring in their own money, etc, etc. 

Second, I would be interested in hearing about the vague ratios of grant funds brought in versus startup package, and how those "ROIs" compare to 8% annual returns. 

Large organizations seem to spend a lot of time working around tax avoidance, so it seems reasonable that if the US government began levying further excise taxes on endowments that universities would begin doing odd things to structure their finances to avoid them.