The Impact of the “Grain Glitch Fix” on Specialized Cooperatives

This paper examines the influence of the tax rule changes associated with the Tax Cuts and Jobs Act of 2017 (“TCJA 2017”) and the Consolidated Appropriations Act of 2018 (“2018 Act”) fix to the Grain Glitch on the financing decisions and after-tax cash flows of Specified Cooperatives and their patrons. I show Specialized Coops have incentive pass-down their Section 199A(g) deduction to eligible patrons to increase their after-tax cash flows. I also show that, depending on the situation, Specialized Coops will have incentive to issue qualified or non-qualified distributions to their patrons in the form or stock to increase their own level allocated equity as well as to provide their patrons future cash flow flexibility. Finally, I suggest that the ability of Exempt Coops to take the Section 199A(g) deduction on non-patronage income may increase their incentive to organize as a Section 521 Exempt Specialized Coop

Valuation and Classification of Company Issued Cash and Share-Puts

This paper examines whether investors’ valuations of cash and share-put warrants are influenced by their potential differential effect on firm solvency. It is motivated by the enactment of SFAS 150, which requires that all contingent put warrant obligations be classified as balance sheet liabilities regardless of put type. Consistent with the critics of SFAS150, we show that market participants differentially value cash and share-puts based on their solvency characteristics beyond the firm’s recorded assets and liabilities. Our results add to existing capital structure literature by suggesting that complex financial instruments (such as cash and share-puts) be reported separately from each other on a firm’s balance sheet

The Impact of the Repeal of the Stock-for-Debt Exception on Corporate Bankruptcy Restructurings

This paper investigates the effect repeal of the stock-for-debt exception on corporate bankruptcy restructurings. This exception permitted corporations to exclude cancellation of indebtedness income from gross income provided they exchanged their own common equity for debt while in Chapter 11. Consistent with claims made by Easton (1994), it is found that the change in tax law imposed significant explicit tax costs on bankruptcy filers. Despite these costs, it is found that many of these firms altered their debt restructure method to preserve net operating losses and reduce their cost of equity. Almost half of the sample firms issued significant levels of debt while in Chapter 11. Additionally, approximately a third of these firms responded to the change in tax law to preserve NOLs by electing an alternative provision available under the ownership change rule bankruptcy exception that allows for a one-time reduction in NOL tax attributes. It is also shown that the remaining firms were precluded from changing their debt restructure method, despite the loss of all of their NOL tax attributes, because the financial reporting marginal costs of doing so exceeded any marginal tax benefits that might have been generated

Are JCT Analyses of Tax Change Proposals Useful to Individual Taxpayers?

This article examines whether taxpayers may rely on Joint Committee of Taxation (JCT) studies to assess how a proposed tax change will impact their circumstances by evaluating the impact of a proposed tax law change to broaden the individual income tax base and lower individual income tax rates by performing a microeconomic analysis on their explicit tax burdens before and after the proposed change in tax law. Our results indicate that JCT studies do not fully reveal the impact of proposed tax law changes on individual explicit tax burdens. Finally, we provide a simple methodology to determine the distributional impact of tax proposals on individuals using publically available information

It\u27s just a game, or is it? Real money, real income, and real taxes in virtual worlds

Virtual worlds like Second Life offer players opportunities to earn real-world income through their activities in the game. It will not be long before governments begin to establish policies and regulations regarding the income generated by players of these game environments. This paper examines the issue of taxes in virtual world games. Two alternative places for recognizing income could be established by regulators: 1) at the point when in-game transactions take place; or 2) when players convert game assets into real-world currency. We argue for realization of income, and therefore taxation, at the exchange. We expect that burdensome policies such as requiring game operators to monitor and report taxable activities to the authorities will dissuade game play and likely result in the collapse of these vibrant economies. Therefore, our recommendation is that the IRS should establish specific rules that inform players about how they should calculate income and work with game operators to inform participants of both the rules and consequences for non-compliance

Plasma microRNA levels following resection of metastatic melanoma

Melanoma remains the leading cause of skin cancer–related deaths. Surgical resection and adjuvant therapies can result in disease-free intervals for stage III and stage IV disease; however, recurrence is common. Understanding microRNA (miR) dynamics following surgical resection of melanomas is critical to accurately interpret miR changes suggestive of melanoma recurrence. Plasma of 6 patients with stage III (n = 2) and stage IV (n = 4) melanoma was evaluated using the NanoString platform to determine pre- and postsurgical miR expression profiles, enabling analysis of more than 800 miRs simultaneously in 12 samples. Principal component analysis detected underlying patterns of miR expression between pre- vs postsurgical patients. Group A contained 3 of 4 patients with stage IV disease (pre- and postsurgical samples) and 2 patients with stage III disease (postsurgical samples only). The corresponding preoperative samples to both individuals with stage III disease were contained in group B along with 1 individual with stage IV disease (pre- and postsurgical samples). Group A was distinguished from group B by statistically significant analysis of variance changes in miR expression ( P < .0001). This analysis revealed that group A vs group B had downregulation of let-7b-5p, miR-520f, miR-720, miR-4454, miR-21-5p, miR-22-3p, miR-151a-3p, miR-378e, and miR-1283 and upregulation of miR-126-3p, miR-223-3p, miR-451a, let-7a-5p, let-7g-5p, miR-15b-5p, miR-16-5p, miR-20a-5p, miR-20b-5p, miR-23a-3p, miR-26a-5p, miR-106a-5p, miR-17-5p, miR-130a-3p, miR-142-3p, miR-150-5p, miR-191-5p, miR-199a-3p, miR-199b-3p, and miR-1976. Changes in miR expression were not readily evident in individuals with distant metastatic disease (stage IV) as these individuals may have prolonged inflammatory responses. Thus, inflammatory-driven miRs coinciding with tumor-derived miRs can blunt anticipated changes in expression profiles following surgical resection

On combining antineoplastic drugs with tumor vaccines

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/46863/1/262_2003_Article_426.pd

Regression of melanoma metastases after immunotherapy is associated with activation of antigen presentation and interferon-mediated rejection genes

We present the results of a comparative gene expression analysis of 15 metastases (10 regressing and 5 progressing) obtained from 2 melanoma patients with mixed response following different forms of immunotherapy. Whole genome transcriptional analysis clearly indicate that regression of melanoma metastases is due to an acute immune rejection mediated by the upregulation of genes involved in antigen presentation and interferon mediated response (STAT-1/IRF-1) in all the regressing metastases from both patients. In contrast, progressing metastases showed low transcription levels of genes involved in these pathways. Histological analysis showed T cells and HLA-DR positive infiltrating cells in the regressing but not in the progressing metastases. Quantitative expression analysis of HLA-A,B and C genes on microdisected tumoral regions indicate higher HLA expression in regressing than in progressing metastases. The molecular signature obtained in melanoma rejection appeared to be similar to that observed in other forms of immune-mediated tissue-specific rejection such as allograft, pathogen clearance, graft versus host or autoimmune disease, supporting the immunological constant of rejection. We favor the idea that the major factor determining the success or failure of immunotherapy is the nature of HLA Class I alterations in tumor cells and not the type of immunotherapy used. If the molecular alteration is reversible by the immunotherapy, the HLA expression will be upregulated and the lesion will be recognized and rejected. In contrast, if the defect is structural the MHC Class I expression will remain unchanged and the lesion will progress.Fondo de Investigaciones Sanitarias (FIS). Grant Numbers: CP03/0111, PI 08/1265. Proyecto de investigacion MEC I + D. Grant Numbers: SAF 2007-63262, SAF 2010-20273. Red Genomica del Cancer. Grant Number: RETIC RD 06/020. Plan Andaluz de Investigacion. Grant Numbers: CTS 143, CTS-695. Proyectos de Excelencia. Grant Numbers: CTS-03952, CVI-04740. Integrated European Cancer Immunotherapy. Grant Numbers: OJ2004/C158, 518234

Developing a translational ecology workforce

We define a translational ecologist as a professional ecologist with diverse disciplinary expertise and skill sets, as well as a suitable personal disposition, who engages across social, professional, and disciplinary boundaries to partner with decision makers to achieve practical environmental solutions. Becoming a translational ecologist requires specific attention to obtaining critical non-scientific disciplinary breadth and skills that are not typically gained through graduate-level education. Here, we outline a need for individuals with broad training in interdisciplinary skills, use our personal experiences as a basis for assessing the types of interdisciplinary skills that would benefit potential translational ecologists, and present steps that interested ecologists may take toward becoming translational. Skills relevant to translational ecologists may be garnered through personal experiences, informal training, short courses, fellowships, and graduate programs, among others. We argue that a translational ecology workforce is needed to bridge the gap between science and natural resource decisions. Furthermore, we argue that this task is a cooperative responsibility of individuals interested in pursuing these careers, educational institutions interested in training scientists for professional roles outside of academia, and employers seeking to hire skilled workers who can foster stakeholder-engaged decision making