The Effects of Taxation on the Merger Decision

This paper presents estimates of the tax benefits generated by a sample of U.S. mergers and acquisitions involving two public corporations over the period 1968-83 and estimates a "marriage model" based on differences between these mergers and another sample of "pseudomergers" that did not occur to determine the impact of these tax benefits on the probability of two firms combining. Our findings reject the hypothesis that leverage played a large role in fostering these transactions, and that the tax losses and credits of acquired firms likewise exerted no impact on merger activity. Though the use of such benefits by acquiring firms to shield profits of other firms did increase the level of activity, the impact was quite small. On the whole, our results suggest that the changes in tax provisions with respect to mergers introduced by the Tax Reform Act of 1986 will have a small impact on U.S. mergers and acquisitions.

Generalized Cash Flow Taxation

We show the unique form that must be taken by a tax system based entirely on realization accounting to implement a uniform capital income tax, or, equivalently, a uniform wealth tax. This system combines elements of an accrual based capital income tax and a traditional cashflow tax, having many of the attributes of the latter while still imposing a tax burden on marginal capital income. Like the traditional cash-flow tax, this system may be integrated with a tax on labor income. We also show how such a tax can be supplemented with an optional accounting for a segregated subset of actively traded securities, subjected separately to mark-to-market taxation at the uniform capital income tax rate, to permit a fully graduated tax system applicable to labor income.

Assessing fundamental tax reform

A look at how some basic tax reform proposals stack up against four, sometimes competing, requirements laid out by President Clinton in a December 1997 speech: Is the proposal fiscally responsible? Will it be good for the economy? Will it lead to a simpler tax system? And finally, is it fair to all Americans?Taxation

The annuitization of Americans' resources: a cohort analysis

An analysis of the changes since 1960 in the share of Americans' resources that are annuitized, which has declined slightly for younger Americans but has risen dramatically for the elderly, with important implications for the national saving rate and income inequality.Saving and investment

Simulating U.S. tax reform

A presentation of a large-scale, dynamic simulation model for comparing the equity, efficiency, and macroeconomic effects of five alternatives to the current U.S. federal income tax: a proportional income tax, a proportional consumption tax, a flat tax, a flat tax with transition relief, and a progressive variant of the flat tax called the "X tax."Income tax

Acetylcholine Receptor Gating at Extracellular Transmembrane Domain Interface: the Cys-Loop and M2–M3 Linker

Acetylcholine receptor channel gating is a propagated conformational cascade that links changes in structure and function at the transmitter binding sites in the extracellular domain (ECD) with those at a “gate” in the transmembrane domain (TMD). We used Φ-value analysis to probe the relative timing of the gating motions of α-subunit residues located near the ECD–TMD interface. Mutation of four of the seven amino acids in the M2–M3 linker (which connects the pore-lining M2 helix with the M3 helix), including three of the four residues in the core of the linker, changed the diliganded gating equilibrium constant (Keq) by up to 10,000-fold (P272 > I274 > A270 > G275). The average Φ-value for the whole linker was ∼0.64. One interpretation of this result is that the gating motions of the M2–M3 linker are approximately synchronous with those of much of M2 (∼0.64), but occur after those of the transmitter binding site region (∼0.93) and loops 2 and 7 (∼0.77). We also examined mutants of six cys-loop residues (V132, T133, H134, F135, P136, and F137). Mutation of V132, H134, and F135 changed Keq by 2800-, 10-, and 18-fold, respectively, and with an average Φ-value of 0.74, similar to those of other cys-loop residues. Even though V132 and I274 are close, the energetic coupling between I and V mutants of these positions was small (≤0.51 kcal mol−1). The M2–M3 linker appears to be the key moving part that couples gating motions at the base of the ECD with those in TMD. These interactions are distributed along an ∼16-Å border and involve about a dozen residues

Incorporating spiritual beliefs into a cognitive model of worry

Cognitive theory and research have traditionally highlighted the relevance of the core beliefs about oneself, the world, and the future to human emotions. For some individuals, however, core beliefs may also explicitly involve spiritual themes. In this article, we propose a cognitive model of worry, in which positive/negative beliefs about the Divine affect symptoms through the mechanism of intolerance of uncertainty. Using mediation analyses, we found support for our model across two studies, in particular, with regards to negative spiritual beliefs. These findings highlight the importance of assessing for spiritual alongside secular convictions when creating cognitive-behavioral case formulations in the treatment of religious individuals

The Annuitization of Americans' Resources: A Cohort Analysis

This paper constructs a unique cohort data set to study the changes since 1960 in the share of Americans' resources that are annuitized. Understanding these changes is important because the larger this share, the more cohorts are likely to consume and the less they are likely to bequeath. Hence, the degree of annuitization affects national saving as well as the transmission of inequality over time. Our findings are striking. Although the annuitized share of resources of younger Americans declined slightly between 1960 and 1990, it increased dramatically for older Americans. It doubled for older men and quadrupled for older women. Since the elderly have much higher mortality probabilities than do the young, their degree of annuitization is much more important for aggregate bequests and saving. According to our estimates, aggregate U.S. bequests would now be 66 percent larger had the post-1960 increase in annuitization not occurred. In addition, U.S. national saving would likely be substantially larger than is currently the case.

Growing a Software Language for Hardware Design

The Liquid Metal project at IBM Research aimed to design and implement a new programming language called Lime to address some of the challenges posed by heterogeneous systems. Lime is a Java-compatible programming language with features designed to facilitate high level synthesis to hardware (FPGAs). This article reviews the language design from the outset, and highlights some of the earliest design decisions. We also describe how these decisions were revised recently to accommodate important requirements that arise in networking and cryptography