Tax-Optimal Step-Up and Imperfect Loss Offset

In the field of mergers and acquisitions, German and international tax law allow for several opportunities to step up a firm's assets, i.e., to revaluate the assets at fair market values. When a step-up is performed the taxpayer recognizes a taxable gain, but also obtains tax benefits in the form of higher future depreciation allowances associated with stepping up the tax base of the assets. This tax-planning problem is well known in taxation literature and can also be applied to firm valuation in the presence of taxation. However, the known models usually assume a perfect loss offset. If this assumption is abandoned, the depreciation allowances may lose value as they become tax effective at a later point in time, or even never if there are not enough cash flows to be offset against. This aspect is especiallyrelevant if future cash flows are assumed to be uncertain. This paper shows that a step-up may be disadvantageous or a firm overvalued if these aspects are not integrated into the basic calculus. Compared to the standard approach, assets should be stepped up only in a few cases and - under specific conditions - at a later point in time. Firm values may be considerably lower under imperfect loss offset.

Global Standards: Recent Developments betweend the Poles of Privacy and Cloud Computing

The development of the Internet has made it possible to transfer data ‘around the globe at the click of a mouse’. Especially fresh business models such as cloud computing, the newest driver to illustrate the speed and breadth of the online environment, allow this data to be processed across national borders on a routine basis. A number of factors cause the Internet to blur the lines between public and private space: Firstly, globalization and the outsourcing of economic actors entrain an ever-growing exchange of personal data. Secondly, the security pressure in the name of the legitimate fight against terrorism opens the access to a significant amount of data for an increasing number of public authorities.And finally,the tools of the digital society accompany everyone at each stage of life by leaving permanent individual and borderless traces in both space and time. Therefore, calls from both the public and private sectors for an international legal framework for privacy and data protection have become louder. Companies such as Google and Facebook have also come under continuous pressure from governments and citizens to reform the use of data. Thus, Google was not alone in calling for the creation of ‘global privacystandards’. Efforts are underway to review established privacy foundation documents. There are similar efforts to look at standards in global approaches to privacy and data protection. The last remarkable steps were the Montreux Declaration, in which the privacycommissioners appealed to the United Nations ‘to prepare a binding legal instrument which clearly sets out in detail the rights to data protection and privacy as enforceable human rights’. This appeal was repeated in 2008 at the 30thinternational conference held in Strasbourg, at the 31stconference 2009 in Madrid and in 2010 at the 32ndconference in Jerusalem. In a globalized world, free data flow has become an everyday need. Thus, the aim of global harmonization should be that it doesn’t make any difference for data users or data subjects whether data processing takes place in one or in several countries. Concern has been expressed that data users might seek to avoid privacy controls by moving their operations to countries which have lower standards in their privacy laws or no such laws at all. To control that risk, some countries have implemented special controls into their domestic law. Again, such controls may interfere with the need for free international data flow. A formula has to be found to make sure that privacy at the international level does not prejudice this principle.

Firms, do you know your currency risk exposure? Survey results

This paper surveys the currency risk management practices of Swiss industrial corporations. We find tha industrials do not quantify their currency risk exposure and investigate possible reasons. One possibility is that firms do not think they need to know because they use on-balance-sheet instruments to protect themselves before and after currency rates reach troublesome levels. This is puzzling because a rough estimate of at least cash flow exposure is not a prohibitive task and could be helpful. It is also puzzling that firms use currency derivatives to hedge/insure individual short-term transactions, without apparently trying to estimate aggregate transaction exposure.

Affective attitudes to face images associated with intracerebral EEG source location before face viewing

We investigated whether different, personality-related affective attitudes are associated with different brain electric field (EEG) sources before any emotional challenge (stimulus exposure). A 27-channel EEG was recorded in 15 subjects during eyes-closed resting. After recording, subjects rated 32 images of human faces for affective appeal. The subjects in the first (i.e., most negative) and fourth (i.e., most positive) quartile of general affective attitude were further analyzed. The EEG data (mean=25±4.8 s/subject) were subjected to frequency-domain model dipole source analysis (FFT-Dipole-Approximation), resulting in 3-dimensional intracerebral source locations and strengths for the delta–theta, alpha, and beta EEG frequency band, and for the full range (1.5–30 Hz) band. Subjects with negative attitude (compared to those with positive attitude) showed the following source locations: more inferior for all frequency bands, more anterior for the delta–theta band, more posterior and more right for the alpha, beta and 1.5–30 Hz bands. One year later, the subjects were asked to rate the face images again. The rating scores for the same face images were highly correlated for all subjects, and original and retest affective mean attitude was highly correlated across subjects. The present results show that subjects with different affective attitudes to face images had different active, cerebral, neural populations in a task-free condition prior to viewing the images. We conclude that the brain functional state which implements affective attitude towards face images as a personality feature exists without elicitors, as a continuously present, dynamic feature of brain functioning.

The Influence of MGA and PG600 on the Out of Season Reproductive Performance of Ewes

Seasonal lamb supply has been established as one of the major hindrances to the American sheep industry. The ability to consistently lamb ewes on an accelerated production system offers additional benefits of reduced maintenance costs, more uniform cash flow along with reduced labor and facility demands. Previous work at McNay with spring breeding indicated that light priming rams regardless of genetic base improved conception rates, however, MGA feeding postweaning gave inconsistent and sometimes depressed reproductive activity in ewes. This study was conducted to evaluate the use of MGA in late lactation and a single PG600 injection at weaning, either individually or in combination.

Profiting from the Cattle Cycle: Alternative Cow Herd Investment Strategies

Beef cow herd owners can benefit from incorporating price signals into their heifer retention decisions. Whereas a perfect forecast of calf prices over the productive life of the heifer added to the herd would be ideal, such information is not available. However, simple decision rules that incorporate current or recent prices and the knowledge that the cattle cycle likely will repeat itself can help producers improve their investment decisions. A dollar cost averaging strategy that retains the same dollar value of heifers each year and a rolling average value strategy that retains a 10-year average value of heifers out performed strategies that sought to maintain a constant herd size or a constant cash flow.

Botulinum toxin A and B raise blood flow and increase survival of critically ischemic skin flaps

BACKGROUND Botulinum toxin (BTX) A and B are commonly used for aesthetic indications and in neuromuscular disorders. New concepts seek to prove efficacy of BTX for critical tissue perfusion. Our aim was to evaluate BTX A and B in a mouse model of critical flap ischemia for preoperative and intraoperative application. METHODS BTX A and B were applied on the vascular pedicle of an axial pattern flap in mice preoperatively or intraoperatively. Blood flow, tissue oxygenation, tissue metabolism, flap necrosis rate, apoptosis assay, and RhoA and eNOS expression were endpoints. RESULTS Blood-flow measurements 1 d after the flap operation revealed a significant reduction to 53% in the control group, while flow was maintained or increased in all BTX groups (103%-129%). Over 5 d all BTX groups showed significant increase in blood flow to 166-187% (P < 0.01). Microdialysis revealed an increase of glucose and reduced lactate/pyruvate ratio and glycerol levels in the flap tissue of all BTX groups. This resulted in significantly improved tissue survival in all BTX groups compared with the control group (62% ± 10%; all P < 0.01): BTX A preconditioning (84% ± 5%), BTX A application intraoperatively (88% ± 4%), BTX B preconditioning (91% ± 4%), and intraoperative BTX B treatment (92% ± 5%). This was confirmed by TUNEL assay. Immunofluorescence demonstrated RhoA and eNOS expression in BTX groups. All BTX applications were similarly effective, despite pharmacologic dissimilarities and different timing. CONCLUSIONS In conclusion, we were able to show on a vascular, tissue, cell, and molecular level that BTX injection to the feeding arteries supports flap survival through ameliorated blood flow and oxygen delivery.

Ethanol-induced gastric damage in the rat: Lack of a correlation with oxygen-derived free radicals

The present study investigated the role of oxygen-derived free radicals as mediators of acute damage to rat gastric mucosae exposed to topically applied absolute ethanol. Although a hydroxyl radical scavenger, Dimethylthiourea, was noted to exhibit profound gastroprotective properties, other pretreatment regimens employing a host of known free radical scavengers, and enzyme inhibitors failed to confirm this hypothesis. Furthermore, no change in mucosal malondialdehyde, an indicator of free radical attack to cell membranes, could be detected in ethanol exposed tissues. Taken together, the present study fails to confirm that oxygen-derived free radicals mediate the gastric damaging effects of topically applied absolute ethanol. ^

Firm-level strategic orientation and performance: a synthesis and extension of the knowledge base on entrepreneurial, market and learning orientation

Should a firm stay focused or should it rather adopt a broader strategic perspective? This dissertation summarizes and extends the existing knowledge base on entrepreneurial, market, and learning orientation. Building on multiple theoretical perspectives, empirical evidence from prior studies, as well as on survey and archival data collected in two economic contexts, performance effects from individual orientations, their dimensions and combinations are explored. Results reveal that the three strategic orientations are highly interrelated and that their relationship to firm performance is more complex than previously assumed.

Non-rigid Free-Form 2D-3D Registration Using Statistical Deformation Model

This paper presents a non-rigid free-from 2D-3D registration approach using statistical deformation model (SDM). In our approach the SDM is first constructed from a set of training data using a non-rigid registration algorithm based on b-spline free-form deformation to encode a priori information about the underlying anatomy. A novel intensity-based non-rigid 2D-3D registration algorithm is then presented to iteratively fit the 3D b-spline-based SDM to the 2D X-ray images of an unseen subject, which requires a computationally expensive inversion of the instantiated deformation in each iteration. In this paper, we propose to solve this challenge with a fast B-spline pseudo-inversion algorithm that is implemented on graphics processing unit (GPU). Experiments conducted on C-arm and X-ray images of cadaveric femurs demonstrate the efficacy of the present approach.

Production of Ethanol from Hardwood

Diminishing crude oil and natural gas supplies, along with concern about greenhouse gas are major driving forces in the search for efficient renewable energy sources. The conversion of lignocellulosic biomass to energy and useful chemicals is a component of the solution. Ethanol is most commonly produced by enzymatic hydrolysis of complex carbohydrates to simple sugars followed by fermentation using yeast. C6Hl0O5 + H2O −Enxymes→ C6H12O6 −Yeast→ 2CH3CH2OH + 2C02 In the U.S. corn is the primary starting raw material for commercial ethanol production. However, there is insufficient corn available to meet the future demand for ethanol as a gasoline additive. Consequently a variety of processes are being developed for producing ethanol from biomass; among which is the NREL process for the production of ethanol from white hardwood. The objective of the thesis reported here was to perform a technical economic analysis of the hardwood to ethanol process. In this analysis a Greenfield plant was compared to co-locating the ethanol plant adjacent to a Kraft pulp mill. The advantage of the latter case is that facilities can be shared jointly for ethanol production and for the production of pulp. Preliminary process designs were performed for three cases; a base case size of 2205 dry tons/day of hardwood (52 million gallons of ethanol per year) as well as the two cases of half and double this size. The thermal efficiency of the NREL process was estimated to be approximately 36%; that is about 36% of the thermal energy in the wood is retained in the product ethanol and by-product electrical energy. The discounted cash flow rate of return on investment and the net present value methods of evaluating process alternatives were used to evaluate the economic feasibility of the NREL process. The minimum acceptable discounted cash flow rate of return after taxes was assumed to be 10%. In all of the process alternatives investigated, the dominant cost factors are the capital recovery charges and the cost of wood. The Greenfield NREL process is not economically viable with the cost of producing ethanol varying from $2.58 to $2.08/gallon for the half capacity and double capacity cases respectively. The co-location cases appear more promising due to reductions in capital costs. The most profitable co-location case resulted in a discounted cash flow rate of return improving from 8.5% for the half capacity case to 20.3% for the double capacity case. Due to economy of scale, the investments become more and more profitable as the size of the plant increases. This concept is limited by the amount of wood that can be delivered to the plant on a sustainable basis as well as the demand for ethanol within a reasonable distance of the plant.

Integrating sequence information in microarray data analysis by free energy modeling

Microarray technology is a high-throughput method for genotyping and gene expression profiling. Limited sensitivity and specificity are one of the essential problems for this technology. Most of existing methods of microarray data analysis have an apparent limitation for they merely deal with the numerical part of microarray data and have made little use of gene sequence information. Because it's the gene sequences that precisely define the physical objects being measured by a microarray, it is natural to make the gene sequences an essential part of the data analysis. This dissertation focused on the development of free energy models to integrate sequence information in microarray data analysis. The models were used to characterize the mechanism of hybridization on microarrays and enhance sensitivity and specificity of microarray measurements. ^ Cross-hybridization is a major obstacle factor for the sensitivity and specificity of microarray measurements. In this dissertation, we evaluated the scope of cross-hybridization problem on short-oligo microarrays. The results showed that cross hybridization on arrays is mostly caused by oligo fragments with a run of 10 to 16 nucleotides complementary to the probes. Furthermore, a free-energy based model was proposed to quantify the amount of cross-hybridization signal on each probe. This model treats cross-hybridization as an integral effect of the interactions between a probe and various off-target oligo fragments. Using public spike-in datasets, the model showed high accuracy in predicting the cross-hybridization signals on those probes whose intended targets are absent in the sample. ^ Several prospective models were proposed to improve Positional Dependent Nearest-Neighbor (PDNN) model for better quantification of gene expression and cross-hybridization. ^ The problem addressed in this dissertation is fundamental to the microarray technology. We expect that this study will help us to understand the detailed mechanism that determines sensitivity and specificity on the microarrays. Consequently, this research will have a wide impact on how microarrays are designed and how the data are interpreted. ^

A Case Study of an Agency's Three Family Preservation Contracts

This article presents a case study of a nonprofit child welfare agency that delivered family preservation services under three different purchase-of-service (POS) contracts. The research specifically focuses on how certain POS contract provisions and reimbursement rates influence the delivery of family preservation services. The three contacts examined differed on criteria, such as reimbursement mechanism, service volume, definition of clientele, and reimbursement rate. The study found that as reimbursement rates decline and as administrative costs increase, the service provider struggled with cash flow, staffing, fundraising, and service provision, among other things. It is concluded that contract-related resources, policies, and procedures impact provider agencies in multiple, significant ways that are critical to the provision of services and the accomplishment of positive client outcomes.

Aplicación de la teoría de opciones reales a la determinación del momento óptimo de cosecha forestal

Se propone el enfoque de opciones reales como herramienta económico-financiera para la toma de decisiones estratégicas en el sector forestal. En términos de instrumentos financieros, consideraremos en particular una opción exótica conocida como barrier option del tipo knock-in. Suponemos que la proyección del precio de venta promedio de los subproductos sigue un proceso estocástico del tipo Geométrico Browniano, mientras que la producción se determina mediante simulación de un turno forestal. La decisión de talar la masa forestal surge de comparar en cada periodo, el valor de flujo de fondos en cada nodo (FFij(t)) de una rejilla binomial con el valor esperado en el próximo año (X t+1 x e−rΔ t) ). En un ejemplo analizado el criterio tradicional del VAN indica que el mayor valor actual se produce en el instante t = 0 (año 10), mientras que el enfoque de opciones reales arroja que el máximo valor de ejercicio se da en el periodo t = 8 (año 18).

Diversificación con frambuesa : : el impacto de su introducción en sistemas hortícolas de Coronda, Santa Fe, Argentina : análisis de un caso de estudio

El objetivo del presente trabajo fue analizar el impacto micro-económico que produce la introducción del cultivo de frambuesa en una pyme hortícola de Coronda, dedicada esencialmente a la producción de frutillas.El patrón de diversificación actual es escaso, debido principalmente a las limitaciones financieras existentes a nivel predial. Se combina el cultivo de frutilla con otras hortalizas, a contra-ciclo, tales como zapallito, berenjena, choclo, sandía y melón. Se analizaron los resultados económicos del ejercicio 2009/2010 de una empresa pyme, estudiada como caso, con una Superficie Agrícola Útil de 5,5 ha, que implantó en el ejercicio evaluado 2 ha de frutilla e introdujo 0,5 ha de frambuesa al esquema productivo, en reemplazo de alguno de los cultivos hortícolas que realizaba. Se obtuvo un Ingreso al capital equivalente a $ 59.786, una rentabilidad sobre el capital total de 12,95 % y sobre el capital sin tierra de 28,79 %. Estos tres indicadores mostraron un incremento de 258%, 248% y 236% respecto de la situación sin frambuesa, respectivamente. Se mejora el grado de diversificación analizado a través del Índice de Entropía y exhibe una excelente complementariedad tanto en el aspecto financiero como laboral.