17 research outputs found

    Round Trip

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    Tax Avoidance, Uncertainty, and Firm Risk

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    The Pricing and Performance of Supercharged IPOs

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    This study examines a new form of initial public offerings, ā€œsuperchargedā€ IPOs, where a firm organized pre-IPO as a pass-through entity undergoes a series of transactions that steps-up the adjusted tax basis of the IPO firmā€™s assets. This step-up imposes tax liabilities on pre-IPO owners but also creates significant future tax benefits for the firm; the average anticipated deferred tax asset is 486million(486 million (13 per share) for our sample of supercharged IPO firms. Pursuant to tax receivable agreements, supercharged IPO firms pay a large portion of these tax benefits to pre-IPO owners as they are realized in the future. Future firm performance must be sufficiently strong for the IPO firm and the pre-IPO owners to realize the future tax benefits created by the supercharged transaction structure. We hypothesize and provide evidence of higher IPO offer prices and stronger future performance for supercharged IPO firms relative to traditional IPO firms

    Progesterone has rapid positive feedback actions on LH release but fails to reduce LH pulse frequency within 12 h in estradiol-pretreated women.

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    In women, progesterone suppresses luteinizing hormone (LH) (gonadotropinā€releasing hormone) pulse frequency, but how rapidly this occurs is unknown. In estradiolā€pretreated women in the late follicular phase, progesterone administration at 1800 did not slow sleepā€associated LH pulse frequency. However, mechanisms controlling LH pulse frequency may differ according to sleep status; and we thus hypothesized that progesterone acutely suppresses waking LH pulse frequency. This was a randomized, doubleā€blind, crossover study of LH secretory responses to progesterone versus placebo administered at 0600. We studied 12 normal women in the late follicular phase (cycle days 7ā€“11), pretreated with 3Ā days of transdermal estradiol (0.2Ā mg/day). Subjects underwent a 24ā€h blood sampling protocol (starting at 2000) and received either 100Ā mg oral micronized progesterone or placebo at 0600. In a subsequent menstrual cycle, subjects underwent an identical protocol except that oral progesterone was exchanged for placebo or vice versa. Changes in 10ā€h LH pulse frequency were similar between progesterone and placebo. However, mean LH, LH pulse amplitude, and mean follicleā€stimulating hormone exhibited significantly greater increases with progesterone. Compared to our previous study (progesterone administered at 1800), progesterone administration at 0600 was associated with a similar increase in mean LH, but a less pronounced increase in LH pulse amplitude. We conclude that, in estradiolā€pretreated women in the late follicular phase, a single dose of progesterone does not suppress waking LH pulse frequency within 12Ā h, but it acutely amplifies mean LH and LH pulse amplitude ā€“ an effect that may be influenced by sleep status and/or time of day

    The Pricing and Performance of Supercharged IPOs

    No full text
    This study examines a new form of initial public offerings, ā€œsuperchargedā€ IPOs, where a firm organized pre-IPO as a pass-through entity undergoes a series of transactions that steps-up the adjusted tax basis of the IPO firmā€™s assets. This step-up imposes tax liabilities on pre-IPO owners but also creates significant future tax benefits for the firm; the average anticipated deferred tax asset is 486million(486 million (13 per share) for our sample of supercharged IPO firms. Pursuant to tax receivable agreements, supercharged IPO firms pay a large portion of these tax benefits to pre-IPO owners as they are realized in the future. Future firm performance must be sufficiently strong for the IPO firm and the pre-IPO owners to realize the future tax benefits created by the supercharged transaction structure. We hypothesize and provide evidence of higher IPO offer prices and stronger future performance for supercharged IPO firms relative to traditional IPO firms

    Looking at the distant universe with the MeerKAT array: discovery of a luminous OH megamaser at z > 0.5

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    In the local universe, OH megamasers (OHMs) are detected almost exclusively in infrared-luminous galaxies, with a prevalence that increases with IR luminosity, suggesting that they trace gas-rich galaxy mergers. Given the proximity of the rest frequencies of OH and the hyperfine transition of neutral atomic hydrogen (H i), radio surveys to probe the cosmic evolution of H i in galaxies also offer exciting prospects for exploiting OHMs to probe the cosmic history of gas-rich mergers. Using observations for the Looking At the Distant Universe with the MeerKAT Array (LADUMA) deep H i survey, we report the first untargeted detection of an OHM at z > 0.5, LADUMA J033046.20-275518.1 (nicknamed "Nkalakatha"). The host system, WISEA J033046.26-275518.3, is an infrared-luminous radio galaxy whose optical redshift z ≈ 0.52 confirms the MeerKAT emission-line detection as OH at a redshift z OH = 0.5225 ± 0.0001 rather than H i at lower redshift. The detected spectral line has 18.4σ peak significance, a width of 459 ± 59 km s-1, and an integrated luminosity of (6.31 ± 0.18 [statistical] ± 0.31 [systematic]) × 103 L ⊙, placing it among the most luminous OHMs known. The galaxy's far-infrared luminosity L FIR = (1.576 ±0.013) × 1012 L ⊙ marks it as an ultraluminous infrared galaxy; its ratio of OH and infrared luminosities is similar to those for lower-redshift OHMs. A comparison between optical and OH redshifts offers a slight indication of an OH outflow. This detection represents the first step toward a systematic exploitation of OHMs as a tracer of galaxy growth at high redshifts
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