Following Miller and Modigliani (1961) dividend irrelevance proposition, many researchers have attempted to explain why firms pay a substantial portion of their earnings as dividends if the amount of dividends paid to shareholders does not affect firm value. One of the most cited reasons for why firms pay dividends is the free cash flow hypothesis, which is based on the notion that there is a conflict of interest between managers and shareholders. Rather than act in shareholders’ best interests, managers could allocate the firm’s resources to benefit themselves (Jensen and Meckling, 1976). Managers’ selfish behaviors can include undertaking unjustified mergers and acquisitions or lavish spending on perquisites. Hence, free cash flows can create agency problem because they may be used to fund negative NPV projects. To mitigate agency problem, Easterbrook (1984) and Jensen (1986) suggest that firms return free cash flows to shareholders by paying dividends. Easterbrook (1984) argues that dividends require managers to raise external funds more often and thus are more monitored by outsiders. According to Jensen (1986), dividends reduce the amount of cash that could be wasted by managers. Thus, dividends may be used as a mechanism to alleviate agency cost of free cash flows.