Quantum local-field corrections and spontaneous decay

A recently developed scheme [S. Scheel, L. Knoll, and D.-G. Welsch, Phys. Rev. A 58, 700 (1998)] for quantizing the macroscopic electromagnetic field in linear dispersive and absorbing dielectrics satisfying the Kramers-Kronig relations is used to derive the quantum local-field correction for the standard virtual-sphere-cavity model. The electric and magnetic local-field operators are shown to be consistent with QED only if the polarization noise is fully taken into account. It is shown that the polarization fluctuations in the local field can dramatically change the spontaneous decay rate, compared with the familiar result obtained from the classical local-field correction. In particular, the spontaneous emission rate strongly depends on the radius of the local-field virtual cavity.Comment: 7 pages, using RevTeX, 4 figure

Optimal operating conditions and characteristics of acetone/CaF_2 detector for inverse photoemission spectroscopy

Performance and characteristics of a band-pass photon detector using acetone gas and CaF_2 window (acetone/CaF_2) have been studied and compared with an ethanol/MgF_2 detector. The optimal operating conditions are found to be 4 mbar acetone pressure and 745+/-20 V anode voltage. The count rate obtained by us is about a factor of 3 higher than what has been reported earlier for the acetone detector. Unlike other gas filled detectors, this detector works in the proportional region with very small dead time (4 micro sec). A detector band-pass of 0.48+/-0.01 eV FWHM is obtained.Comment: Review of Scientific Instruments 76, 066102 (2005

Samuel Zell, the Chicago Tribune, and the Emergence of the S ESOP: Understanding the Tax Advantages and Disadvantages of S ESOPs

Samuel Zell’s acquisition of the Chicago Tribune Company (the Tribune) in December 2007 using a little-known type of Employee Stock Ownership Plan (ESOP) made headlines. In a complicated transaction, which took nearly a year to complete, the Tribune converted from a subchapter C corporation to a subchapter S corporation, established an ESOP that purchased 100 percent of the company’s equity, and sold Zell a call option giving him the right to purchase 40 percent of the company’s equity. Press reports claim that Zell’s novel structure enabled Zell to outbid other suitors. And financial commentators predict that many acquirers will employ that same structure as soon as acquisition activity picks up. Zell’s Tribune transaction also caught the eye of legislators, including Congressman Charles Rangel, who introduced a bill that would increase the tax on indirect claims – such as the one owned by Zell – on the equity of an S corporation held by an ESOP (synthetic equity). Although ESOPs are more than 30 years old, until 1998, an S corporation could not sponsor an ESOP. Over the last ten years, so-called S ESOPs have grown rapidly, but largely outside of public view. The Tribune transaction has focused a bright light on S ESOPs and there are some who believe that their current tax treatment is too favorable. Yet, there has been little in-depth analysis of the tax treatment of S ESOPs. Accordingly, this paper attempts to fill that gap by presenting a systematic economic evaluation of the tax consequences of using an S ESOP. It seeks to describe both qualitatively and quantitatively the tax advantages and disadvantages of using an S ESOP (with or without synthetic equity) relative to alternative available structures. This paper also estimates by how much the S ESOP structure likely allowed Zell to increase his bid for the Tribune

Section 83(b) Election for Restricted Stock: A Joint Tax Perspective

In the wake of the Financial Accounting Standard Board\u27s decision to require firms that grant employee stock options (ESOs) to treat such options as an expense, many large and sophisticated firms are switching from ESOs to restricted stock. Restricted stock - stock granted to an employee as part of her compensation and subject to the condition that if she leaves the firm within a period of time (often 3 years) she forfeits the stock - appears to be on its way to becoming the dominant form of equity-based pay in the United States. Yet, in spite of its prominence, little attention has been paid to how employers should design their restricted stock programs in light of tax considerations. The tax consequences to both the employee and the employer of a grant of restricted stock are deferred until the restriction lapses and the stock vests. There is however an exception to that general rule: If, within 30 days of receiving the stock, the employee makes what is called the Section 83(b) election, then both the employer and the employee are taxed at the time of grant. Employing a joint tax perspective that looks at the tax consequences to both the employer and the employee, this paper attempts to answer several compensation design issues raised by the use of restricted stock. Specifically, I address the question under what circumstances should the employer charge the employee explicitly for her restricted shares and when should the employer charge implicitly for the restricted stock through a lower salary. I also look at the desirability to the employee, the employer, and the employee and employer together of the employee making the Section 83(b) election. Finally, I look at the value to the employee and cost to the employer of the employee\u27s option to wait 30 days until making the Section 83(b) election

The Tax Cuts and Jobs Act’s Incorporation “Incentive”

Many observers have asserted that the reduced corporate tax rate instituted by the 2017 Tax Cuts and Jobs Act (TCJA) has transformed entity choice for business owners, incentivizing owners of businesses structured as sole proprietorships or passthrough entities to incorporate their businesses and to use these new corporations as pocketbook investment vehicles to invest in and hold portfolio investments, substantially reducing wealthy individuals’ tax obligations and Treasury’s tax collections. This brief offers a different view, and discusses why predictions of widespread conversions to the corporate form at a substantial cost to the fiscal position of the U.S. are overstated. The brief explores the various purported tax advantages to incorporating, both when business owners are looking to invest substantial profits in portfolio assets, as well as when retained earnings are reinvested in the business and produce ordinary income.https://repository.upenn.edu/pennwhartonppi/1069/thumbnail.jp

Gray-Market Imports: Causes, Consequences and Responses

This article explores the issue of gray-market imports. The author explains the four causes of gray-market imports and explores the possibility of private remedies in order to stem the flow of these imports. The article then turns to the possibility of protection in the public sector by discussing pertinent statutory provisions and the development of the case law in this area