It's very unlikely that a serializer will give you options over this. Certainly there's no standard XSLT serialization option for it. This is because it's assumed that the XML is destined to be read by a conformant XML parser, and every conformant XML parser will treat the two constructs in exactly the same way. (similarly, serializers don't usually allow you to say whether you want spaces around the "=" sign in attribute="value", for exactly the same reason).
Where does this requirement come from?
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Michael Kay
http://www.saxonica.com/
Author, XSLT 2.0 and XPath 2.0 Programmer\'s Reference
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