1,720,956 research outputs found
Insiders\u27 Rule 10b5-1 plan sales and earnings management
No full textThis dissertation examines whether insiders manage quarterly earnings in connection with their SEC Rule 10b5-1 plan stock sales. Prior research provides evidence of competing incentives regarding the timing of insider stock sales. For example, insiders can (1) sell after they have managed earnings upward ( pump-and dump ) or (2) manage earnings upward after they have sold ( litigation avoidance ). Rule 10b5-1(c) reduces the litigation avoidance incentive by providing an insider with an affirmative defense against insider trading charges if the insider, at a time when the insider had no material inside information, commits in advance to a stock sale plan. The study of Rule 10b5-1 sales, which are typically pre-planned, also helps overcome an obstacle in prior literature as to whether the decision to sell occurred before or after the earnings announcement. ^ Consistent with prior research, I find evidence that insiders sell after meeting or beating quarterly analyst forecasts, consistent with a pump-and-dump strategy. On the other hand, I find some evidence that insiders increase quarterly accrual-based measures after selling, consistent with a litigation avoidance strategy. I also find extensive evidence that insiders reduce accrual-based measures before selling, arguably consistent with a litigation avoidance strategy. However, I find very little evidence of a differential effect for sales made under a 10b5-1 plan versus sales made outside a 10b5-1 plan. This dissertation also offers recommendations for the SEC in connection with 10b5-1 plans.
Insiders\u27 Rule 10b5-1 plan sales and earnings management
No full textThis dissertation examines whether insiders manage quarterly earnings in connection with their SEC Rule 10b5-1 plan stock sales. Prior research provides evidence of competing incentives regarding the timing of insider stock sales. For example, insiders can (1) sell after they have managed earnings upward ( pump-and dump ) or (2) manage earnings upward after they have sold ( litigation avoidance ). Rule 10b5-1(c) reduces the litigation avoidance incentive by providing an insider with an affirmative defense against insider trading charges if the insider, at a time when the insider had no material inside information, commits in advance to a stock sale plan. The study of Rule 10b5-1 sales, which are typically pre-planned, also helps overcome an obstacle in prior literature as to whether the decision to sell occurred before or after the earnings announcement. ^ Consistent with prior research, I find evidence that insiders sell after meeting or beating quarterly analyst forecasts, consistent with a pump-and-dump strategy. On the other hand, I find some evidence that insiders increase quarterly accrual-based measures after selling, consistent with a litigation avoidance strategy. I also find extensive evidence that insiders reduce accrual-based measures before selling, arguably consistent with a litigation avoidance strategy. However, I find very little evidence of a differential effect for sales made under a 10b5-1 plan versus sales made outside a 10b5-1 plan. This dissertation also offers recommendations for the SEC in connection with 10b5-1 plans.
The Internal Revenue Code\u27s Section 351 Implied Deferred Tax Liability Problem
Full text linkMost people take for granted that the fair market value of property exchanged for other property is of equal value. However, in the case of transfers of appreciated property to a corporation in a transaction qualifying for non-recognition under Section 351, the creation of a second unrealized gain in the hands of the transferee corporation—and thus a newly created implied deferred tax liability on such gain when later realized—reduces the value of the stock issued to the shareholder. Despite this, in Section 351 settings academics, textbook and casebook writers, the Treasury, and the courts take a standard approach of equating the value of the transferred-in property and the transferee stock is- sued in return.
The failure to factor in the IDTL leads to an overstated amount re- alized—and thus realized gain—for transferors in Section 351 settings. The IDTL is of no immediate effect for transferor shareholders and transferee corporations under Section 351(a), which provides for non- recognition of the realized gain. However, it is of immediate effect if boot is also involved, as Section 351(b) requires recognition (i.e., taxa- tion) of the lesser of the boot received or the realized gain. This Article argues that the transferor’s amount realized—and thus realized gain, and thus recognized gain—should be reduced to reflect the IDTL.
This Article supports its argument with analogies to GAAP’s ac- counting guidance on formal deferred tax liabilities, empirical research on the effect of taxes—including deferred taxes—on stock value, and published advice recommending shareholders in a Section 351 setting factor IDTL when negotiating share allocations. Furthermore, the standard approach of value equivalency in Section 351 settings is especially inapt in light of the many estate and gift tax court decisions—after the legislative demise in 1986 of General Utilities—that now allow discounts for the lurking IDTL when determining the value of closely held corporations.
This Article also shows how the Treasury erred in 2006 when it changed the Section 1.351-3 regulations that have long required the parties to Section 351 transactions to file statements about values and basis in the transfers. First, the 2006 change requires the transferee to disclose the value of property received by the transferee, as opposed to the pre-2006 requirement to disclose the value of stock issued by the transferee. Second, information required in the 2006 change is arguably inconsistent with Revenue Procedure 83-59, which directs taxpayers seeking a private letter ruling related to Section 351 to represent that the transferor will receive stock approximately equal in value to the property transferred into the transferee. Furthermore, the presence of the IDTL means that it will be difficult for parties to make the “value for value” representation required in their PLR requests.
This Article offers advice to parties in a Section 351 transaction. It also proposes amendments to the 1.351-1 and -3 regulations
Going Beyond Counting First Authors in Author Co-citation Analysis
Full text linkThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
Variations on the Author
Full text link“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
Appropriate Similarity Measures for Author Cocitation Analysis
Full text linkWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
Dispelling the Myths Behind First-author Citation Counts
Full text linkWe conducted a full-scale evaluative citation analysis study of scholars in the XML research field to explore just how different from each other author rankings resulting from different citation counting methods actually are, and to demonstrate the capability of emerging data and tools on the Web in supporting more realistic citation counting methods. Our results contest some common arguments for the continued
use of first-author citation counts in the evaluation of scholars, such as high correlations between author rankings by first-author citation counts and other citation
counting methods, and high costs of using more realistic citation counting methods that are not well-supported by the ISI databases. It is argued that increasingly available digital full text research papers make it possible for citation analysis studies to go beyond what the ISI databases have directly supported and to employ more
sophisticated methods
- …
