How Much Do Taxes Discourage Incorporation.

One of the most basic distortions created by the double taxation of corporate income is the disincentive to incorporate. In this paper, we investigate the extent to which the aggregate allocation of assets and taxable income in the U.S. between corporate vs. noncorporate forms of organization during the period 1959-86 has responded to the size of the tax distortion discouraging firms from incorporating. In theory, profitable firms should shift out of the corporate sector when the tax distortion to incorporating is larger, and conversely for firms with tax losses. Our empirical results provide strong support for these theoretical forecasts, and hold consistently across a wide variety of specifications and measures of the tax variables. Measured effects are small, however, throwing doubt on the economic importance of tax-induced changes in organizational form.

Why Is There Corporate Taxation In a Small Open Economy? The Role of Transfer Pricing and Income Shifting

Several recent papers argue that corporate income taxes should not be used by small, open economies. With capital mobility, the burden of the tax falls on fixed factors (e.g., labor), and the tax system is more efficient if labor is taxed directly. However, corporate taxes not only exist but rates are roughly comparable with the top personal tax rates. Past models also forecast that multinationals should not invest in countries with low corporate tax rates, since the surtax they owe when profits are repatriated puts them at a competitive disadvantage. Yet such foreign direct investment is substantial. We suggest that the resolution of these puzzles may be found in the role of income shifting, both domestic (between the personal and corporate tax bases) and cross-border (through transfer pricing). Countries need cash-flow corporate taxes as a backstop to labor taxes to discourage individuals from converting their labor income into otherwise untaxed corporate income. We explore how these taxes can best be modified to deal as well with cross-border shifting.

Effects of the Tax Reform Act of 1986 on Corporate Financial Policy and Organizational Form

We examine the effects of the Tax Reform Act of 1986 on the financial decisions made by firms. We review the theory and empirical predictions of prior literature for corporate debt policy, for dividend and equity repurchase payouts to shareholders, and for the choice of organizational form. We then compare the predictions to post-1986 experience. The change in debt/value ratios has been substantially smaller than expected. Dividend payouts increased as predicted, but stock repurchases increased even more rapidly which was unexpected and is difficult to understand. Based on very scant data, it appears that some activities have shuffled among organizational forms; in particular, loss activities may have been moved into corporate form where they are deducted at a higher tax rate, while gain activities may have shifted towards noncorporate form, to be taxed at the lower personal rates. In addition, several interesting new issues are raised. One concerns previously neglected implications for the effective tax on retained earnings that follow from optimal trading strategies when long- and short-term capital gains are taxed at different rates. Also, new interest allocation rules for multinational corporations provide a substantial incentive for many firms to shift their borrowing abroad.

Rapid characterization of the ultraviolet induced fiber Bragg grating complex coupling coefficient as a function of irradiance and exposure time

We report the application of optical frequency domain reflectometry and a discrete-layer-peeling inverse scattering algorithm to the spatial characterization of the UV induced complex coupling coefficient during fiber Bragg grating growth. The fiber grating is rapidly characterized using this technique to give irradiance dependent growth as a function of exposure time, thereby providing the complete characterization of the coupling coefficient in the form of a "growth surface," which is related to the fiber's photosensitivity. We compare measurements of fiber Bragg grating growth in SMF-28 when exposed to continuous wave 244 nm irradiation from 0 to 90 W cm(-2) for exposure times up to 3230 s with a selection of other fibers including high germanium concentration fiber and erbium doped fiber. (c) 2007 Optical Society of America

System architecture for the Canadian interim mobile satellite system

The system architecture for the Canadian Interim Mobile Satellite Service (IMSS) which is planned for commencement of commercial service in late 1989 is reviewed. The results of an associated field trial program which was carried out to determine the limits of coverage and the preliminary performance characteristics of the system are discussed

User's guide for the Solar Backscattered Ultraviolet (SBUV) instrument first year ozone-S data set

Total-ozone and ozone vertical profile results for Solar Backscattered Ultraviolet/Total Ozone Mapping Spectrometer (SBUV/TOMS) Nimbus 7 operation from November 1978 to November 1979 are available. The algorithm used have been thoroughly tested, the instrument performance has been examined in details, and the ozone results have been compared with Dobson, Umkehr, balloon, and rocket observations. The accuracy and precision of the satellite ozone data are good to at least within the ability of the ground truth to check and are self-consistent to within the specifications of the instrument. The 'SBUV User's Guide' describes the SBUV experiment and algorithms used. Detailed information on the data available on computer tape is provided including how to order tapes from the National Space Science Data Center

Vortex lattice stability and phase coherence in three-dimensional rapidly rotating Bose condensates

We establish the general equations of motion for the modes of a vortex lattice in a rapidly rotating Bose-Einstein condensate in three dimensions, taking into account the elastic energy of the lattice and the vortex line bending energy. As in two dimensions, the vortex lattice supports Tkachenko and gapped sound modes. In contrast, in three dimensions the Tkachenko mode frequency at long wavelengths becomes linear in the wavevector for any propagation direction out of the transverse plane. We compute the correlation functions of the vortex displacements and the superfluid order parameter for a homogeneous Bose gas of bounded extent in the axial direction. At zero temperature the vortex displacement correlations are convergent at large separation, but at finite temperatures, they grow with separation. The growth of the vortex displacements should lead to observable melting of vortex lattices at higher temperatures and somewhat lower particle number and faster rotation than in current experiments. At zero temperature a system of large extent in the axial direction maintains long range order-parameter correlations for large separation, but at finite temperatures the correlations decay with separation.Comment: 10 pages, 2 figures, Changes include the addition of the particle density - vortex density coupling and the correct value of the shear modulu