Most people don't buy IBC totes of dish soap to save a few bucks on the unit price because it's impractical, never-mind that they don't have the equipment to reasonably deal with liquids in that volume.

If you're not that rich then it doesn't make sense to go all out optimizing your taxes because the savings aren't big enough and the costs of doing so are high enough to make the net result a savings.

Not being rich enough to have access to certain tax avoiding structures is like complaining you not being able to get the savings of buying a ton of dish soap because you don't have a fork lift.