Taxes and Ownership Structure: Corporations, Partnerships and Royalty Trusts

This paper investigates the effect of taxes on the equilibrium ownership structure of productive assets. Ownership structure includes the traditional choice between debt and equity financing, but also the larger choice between corporate and partnership forms. A key feature of these alternative forms is that corporations are subject to taxation at both the corporate and investor levels, whereas partnerships are not. At the same time, depreciation and interest tax shields are taken at the corporate tax rate for corporate assets and at investors' tax rates for partnership assets. We find that assets endowed with excess non-interest tax deductions are best held in partnership form by high tax bracket investors. Assets whose allowed deductions are low enough to generate a net tax liability in corporate formare best held as partnerships by low tax bracket investors. All other assets are held in the corporate sector and are financed in a manner consistent with Miller's(1977) capital structure equilibrium.We argue that our analysis illuminates the tax aspects of such transactionsas mergers and sales or spin-offs of corporate assets to partnerships and royalty trusts. We also show that our results afford a simple characterization of the lease or buy decision.

Contingent Claims Valuation of Corporate Liabilities: Theory and Empirical Tests

Although the Contingent Claims Analysis model has become the premier theory of how value is allocated among claimants on firms,its empirical validity remains an open question. In addition to being of academic interest, a test of the model would have significant practical implications. If it can be established that the model predicts actual market prices, then the model can be used to price new and untraded claims, to infer firm values from prices of traded claims like equity and to price covenants separately. In this paper evidence is presented on how well a model which makes the usual assumptions in the literature does in predicting market prices for claims in standard capital structures. The results suggest that the usual assumption list requires modification before it can serve as a basis for valuing corporate claims.

The mechanics of takeoffs in the aerials event of freestyle skiing

The aerials event of freestyle skiing is a relatively new discipline having only been introduced into the Olympic Games as a medal event in 1994. The purpose of this study was to develop a simulation model for the takeoff phase of aerials, with the intention of learning more about how the requisite linear and angular velocities at takeoff are generated. Experimental data was collected for six triple somersaulting aerial jumps. The jumps were filmed with four high-speed video cameras and a total of 17 points were manually digitised for each camera view of each jump. The digitised coordinates were reconstructed using a three dimensional direct linear transformation (3D-DLT) and processed using a film program written in FORTRAN. The program produced kinematic data for the takeoff phase of the six jumps. A simulation model for takeoff was developed, comprising of a rod (body) and a ski. At the connection between the rod and the ski is a passive torque, governed by the stiffness coefficient K. Experimental values for the height of the centre of mass (CoM), moment of inertia (MoI), initial linear velocity (VG) and initial angular velocity (ωpg) were used as model inputs. A combined drag and air resistance coefficient (D) was varied with K to match the experimental VG and ωpg at takeoff, resulting in an average difference of -0.07% for VG, and -16.10% for ωpg. A straight body simulation was run, eliminating the effect of joint angle changes on CoM height and MoI, it was found that a straight body matches the experimental data just as well as a simulation using joint angles. This result suggests that joint angles changes play a different role, other than to generate angular and linear velocity. Further alterations were made to the model parameters; K was varied, which increased the angle of the CoM behind the normal to the skis (ψ) as K increased. Initial angular velocity was varied with results suggesting that a forwards leaning motion at the start of the kicker generated a larger angular velocity at takeoff. An additional ankle torque was implemented for the final 0.1s of takeoff, this increased ωpg and reduced the difference to just -3.01%. Conclusions were drawn that the passive torque of the skis and an additional ankle torque prior to takeoff play a large role in governing takeoff conditions

Spatial and Temporal Extrapolation of Disdrometer Size Distributions Based on a Lagrangian Trajectory Model of Falling Rain

Methodologies to improve disdrometer processing, loosely based on mathematical techniques common to the field of particle flow and fluid mechanics, are examined and tested. The inclusion of advection and vertical wind field estimates appears to produce significantly improved results in a Lagrangian hydrometeor trajectory model, in spite of very strict assumptions of noninteracting hydrometeors, constant vertical air velocity, and time independent advection during a radar scan time interval. Wind field data can be extracted from each radar elevation scan by plotting and analyzing reflectivity contours over the disdrometer site and by collecting the radar radial velocity data to obtain estimates of advection. Specific regions of disdrometer spectra (drop size versus time) often exhibit strong gravitational sorting signatures, from which estimates of vertical velocity can be extracted. These independent wind field estimates can be used as initial conditions to the Lagrangian trajectory simulation of falling hydrometeors.Comment: 25 pages, 15 figures, 4 tables. Submitted to The Open Atmospheric Science Journal, http://www.bentham.org/open/toascj

Improving animal health on organic dairy farms: stakeholder views on policy options

Although ensuring good animal health is a stated aim of organic livestock farming and an important reason why consumers purchase organic products, the health states actually achieved are comparable to those in conventional farming. Unfortunately, there have been no studies to date that have assessed stakeholder views on different policy options for improving animal health on organic dairy farms. To address this deficit, stakeholder consultations were conducted in four European countries, involving 39 supply-chain stakeholders (farmers, advisors, veterinarians, inspectors, processors, and retailers). Stakeholders were encouraged to discuss different ways, including policy change, of improving organic health states. Acknowledging the need for further health improvements in organic dairy herds, stakeholders generally favoured establishing outcome-oriented animal health requirements as a way of achieving this. However, as a result of differing priorities for animal health improvement, there was disagreement on questions such as: who should be responsible for assessing animal health status on organic farms; and how to define and implement minimum health requirements. The results of the study suggest that future research must fully explore the opportunities and risks of different policy options and also suggest ways to overcome the divergence of stakeholders’ interests in public debates

Measurements of DSD Second Moment Based on Laser Extinction

Using a technique recently developed for estimating the density of surface dust dispersed during a rocket landing, measuring the extinction of a laser passing through rain (or dust in the rocket case) yields an estimate of the 2nd moment of the particle cloud, and rainfall drop size distribution (DSD) in the terrestrial meteorological case. With the exception of disdrometers, instruments that measure rainfall make in direct measurements of the DSD. Most common of these instruments are the rainfall rate gauge measuring the 1 1/3 th moment, (when using a D(exp 2/3) dependency on terminal velocity). Instruments that scatter microwaves off of hydrometeors, such as the WSR-880, vertical wind profilers, and microwave disdrometers, measure the 6th moment of the DSD. By projecting a laser onto a target, changes in brightness of the laser spot against the target background during rain, yield a measurement of the DSD 2nd moment, using the Beer-Lambert law. In order to detect the laser attenuation within the 8-bit resolution of most camera image arrays, a minimum path length is required, depending on the intensity of the rainfall rate. For moderate to heavy rainfall, a laser path length of 100 m is sufficient to measure variations in optical extinction using a digital camera. A photo-detector could replace the camera, for automated installations. In order to spatially correlate the 2nd moment measurements to a collocated disdrometer or tipping bucket, the laser's beam path can be reflected multiple times using mirrors to restrict the spatial extent of the measurement. In cases where a disdrometer is not available, complete DSD estimates can be produced by parametric fitting of DSD model to the 2nd moment data in conjunction with tipping bucket data. In cases where a disdrometer is collocated, the laser extinction technique may yield a significant improvement to insitu disdrometer validation and calibration strategie

Modeling the Deterioration of Engine and Low Pressure Compressor Performance During a Roll Back Event Due to Ice Accretion

The main focus of this study is to apply a computational tool for the flow analysis of the engine that has been tested with ice crystal ingestion in the Propulsion Systems Laboratory (PSL) of NASA Glenn Research Center. A data point was selected for analysis during which the engine experienced a full roll back event due to the ice accretion on the blades and flow path of the low pressure compressor. The computational tool consists of the Numerical Propulsion System Simulation (NPSS) engine system thermodynamic cycle code, and an Euler-based compressor flow analysis code, that has an ice particle melt estimation code with the capability of determining the rate of sublimation, melting, and evaporation through the compressor blade rows. Decreasing the performance characteristics of the low pressure compressor (LPC) within the NPSS cycle analysis resulted in matching the overall engine performance parameters measured during testing at data points in short time intervals through the progression of the roll back event. Detailed analysis of the fan-core and LPC with the compressor flow analysis code simulated the effects of ice accretion by increasing the aerodynamic blockage and pressure losses through the low pressure compressor until achieving a match with the NPSS cycle analysis results, at each scan. With the additional blockages and losses in the LPC, the compressor flow analysis code results were able to numerically reproduce the performance that was determined by the NPSS cycle analysis, which was in agreement with the PSL engine test data. The compressor flow analysis indicated that the blockage due to ice accretion in the LPC exit guide vane stators caused the exit guide vane (EGV) to be nearly choked, significantly reducing the air flow rate into the core. This caused the LPC to eventually be in stall due to increasing levels of diffusion in the rotors and high incidence angles in the inlet guide vane (IGV) and EGV stators. The flow analysis indicating compressor stall is substantiated by the video images of the IGV taken during the PSL test, which showed water on the surface of the IGV flowing upstream out of the engine, indicating flow reversal, which is characteristic of a stalled compressor

Modeling the Deterioration of Engine and Low Pressure Compressor Performance During a Roll Back Event Due to Ice Accretion

The main focus of this study is to apply a computational tool for the flow analysis of the engine that has been tested with ice crystal ingestion in the Propulsion Systems Laboratory (PSL) of NASA Glenn Research Center. A data point was selected for analysis during which the engine experienced a full roll back event due to the ice accretion on the blades and flow path of the low pressure compressor. The computational tool consists of the Numerical Propulsion System Simulation (NPSS) engine system thermodynamic cycle code, and an Euler-based compressor flow analysis code, that has an ice particle melt estimation code with the capability of determining the rate of sublimation, melting, and evaporation through the compressor blade rows. Decreasing the performance characteristics of the low pressure compressor (LPC) within the NPSS cycle analysis resulted in matching the overall engine performance parameters measured during testing at data points in short time intervals through the progression of the roll back event. Detailed analysis of the fan-core and LPC with the compressor flow analysis code simulated the effects of ice accretion by increasing the aerodynamic blockage and pressure losses through the low pressure compressor until achieving a match with the NPSS cycle analysis results, at each scan. With the additional blockages and losses in the LPC, the compressor flow analysis code results were able to numerically reproduce the performance that was determined by the NPSS cycle analysis, which was in agreement with the PSL engine test data. The compressor flow analysis indicated that the blockage due to ice accretion in the LPC exit guide vane stators caused the exit guide vane (EGV) to be nearly choked, significantly reducing the air flow rate into the core. This caused the LPC to eventually be in stall due to increasing levels of diffusion in the rotors and high incidence angles in the inlet guide vane (IGV) and EGV stators. The flow analysis indicating compressor stall is substantiated by the video images of the IGV taken during the PSL test, which showed water on the surface of the IGV flowing upstream out of the engine, indicating flow reversal, which is characteristic of a stalled compressor