Does not work. Virus does not survive in water. Too fragile. A terrorist would want to use any of a variety of agents which can survive outside the body. There are plenty.
Ebola's strength is fast action and high degree of damage(even if the person survives). Its weakness which keeps it from wiping out a major chunk of the world's population is that it is fragile. It survives in bodily fluids only. It is transmitted because, in late stages of the disease, the body sheds massive amounts of disease ladden fluids which the next victim must come in contact within a short time frame before the virus dies. The biggest danger is that being an RNA based virus, replication is unreliable resulting in a high rate of mutation/picking up fragments of random RNA. With enough people carrying the virus and many billions of replications occurring, the virus may randomly pick up the capability of surviving longer outside the body. This would turn it into a major world threat. The longer the epidemic lasts, the more likely this is.
While the disease is a world threat, the market potential for any drug is poor. If the world acts responsibly, the disease will be contained in Central Africa and affect primarily people unable to pay obscene western drug prices.
A spinoff from a C corp in the form of mlp units is a taxable dividend. Not generally desirable. A C corp can do a distribution of stock or a spinoff of a C corp entity tax free, but mlp units are considered a distribution of the underlying assets.
A "C" corp can "drop down" to an existing Mlp because that is not legally a sale or distribution. It is done as a tax-free "like kind" exchange of property for MLP units representing equivalent property.
Most REIT mergers are better for seller than buyer. Not much in economies of scale beyond a few thousand apartments. Only makes sense to do an acquisition if seller trading below NAV of properties. Colonial had mediocre management, but that does not really matter since can quickly convert to MAA systems and procedures. Only thing that matters is the value of properties acquired. Location of Colonial properties was in same market are making integration easier.
I'm watching as price drops. At some point will make sense to buy more. I wish there was more reliable information available on NAV/share. Long run value should track cost of developing equivalent new buildings as long as population in service areas is growing. Should not matter where interest rates are or what inflation is. These will drive faster or slower new development, but in the long run, new buildings will be developed and old ones will have value adjust accordingly
New KMI structure will be equivalent of UPREIT structure in REITs. A corporation will own a partneship. This means that can acquire individual properties or partnerships in exchange for partnership units tax free to seller (exchangeable at no cost for shares whenever holder wants to sell some for cash) and can merge with corporations tax free to seller. Good structure for an entity expecting to expand through acquisitions.
Both companies are merging into a new shell which will have the Covidien home country. Merger is taxable to both sides, per the merger disclosure.
U.S. dollar getting strong enough to slow U.S. economy. This also strengthening Chinese export industries. Should be buying opportunity soon. Even with a rate cut, rates likely to stay above U.S. rates which will rise slowly.
Google not in hardware business.
Like most things today, takes a huge patent portfolio to make anything. You need to be able to negotiate cross-licensing agreements with a variety of other tech conglomerates and patent trolls. What would be gained?
Makes a lot more sense to invest in internet related areas such as broadband capacity or server farms that would, at least, be related and complementary to existing business.
The big question in 3D printing s when will existing ink jet printer makers get into 3d printing. They have much of the patent portfolio and the technology is similar enough. They can either buy in or just develop their own products if existing 3D companies have too high valuation.
The tax benefit comes from the treatment of MLP units as a sale to KMI. That is why the KMP portion is taxable. On purchase, the assets of KMP are stepped up in basis to the purchase price (market value of assets technically but comparable). Thus KMI gets to do depreciation, depletion and amortization just as a new KMP holder would on the old assets. There is no foreign entity involved.
For what its worth, the administration has no power to stop a foreign inversion. They can apply political pressure and try to "reinterpret" IRS rules to make life more difficult for inverting companies, but that is about it. It is crazy that we have such a socialist government that claims it is "unpatriotic" to move headquarters overseas. What made America great was companies and investors WANTING to be here, not staying in the U.S. because they have a gun to their heads. U.S. tax laws discriminate against U.S. based companies which is absurd and should be fixed as a matter of economics not patriotism. (Though it would be much more patriotic to fix the tax system than to attack companies doing business in the U.S.)
As owner of MLP units you owe taxes to ALL states the MLP passes through. This is a result of your activity in the state(Legally owning MLP units is doing business in the state). In many cases, if the MPL is generating losses or gains are small, the state does not bother coming after you. The merger is a big deal because it may generate a large enough amount of ordinary income (recapture) which IS taxable at the state levels (each state according to the proportion of income generated in that state and the state's rules)
If you are living outside the U.S., while legally owing the taxes, they may be noncollectable. If the state wins a court judgement against you, it needs to find assets or accounts to attach in order to collect. If you have no U.S. assets, it would need to go to a Mexican court. As a matter of practicality, West Virginia would probably list you as a tax deadbeat, but not take further action unless the tax amount is very large.
Medtronics is OK as long as it keeps its foreign cash overseas and builds R&D and manufacturing facilities there. If it dares to try and invest money to create jobs in the U.S., the O'bummer administration is determined to be sure it is punished. The U.S. is the only country that punishes its companies for investing at home.
Most REITs hold depreciable real estate assets. FFO backs out this depreciation to get an ongoing rent stream.
This company grows trees which are cut down after many years. Not nearly the same kind of business. Cash is not received annually from each tree. Trees can go many years without generating any revenue. Company cashflow easily manipulated by cutting more trees or making more discretionary land sales. Good management is to hold back when prices are lousy and sell more when prices are good. Timber and timberland allow a great deal of discretion in which year to make a sale
Vaccines sound good, but are only useful in limited circumstances. Do not want immune system constantly active since it tends to run down or run amuck. The body is designed to clear most items including hormones. Balances are maintained by producing a compound and producing a counter agent that breaks it down.
It is a valid concern that over the long life of this company there has only been one marginally useful drug approved. This also reduces the company's credibility. There is, however progress in understanding and designing synthetic RNA sequences. If the existing drug were designed today, it would be a much better drug. It would require new regulatory approvals which unfortunately are not worth the cost. (They may be once current drug exclusivity expires--though with biologicals, this does not seem to happen) New drugs under development are based on an improved synthetic RNA structure which should be better tolerated.
Old fashion drug discovery was trial and error. The new drug development process is a deliberate design to produce a specific protein.It benefits from a better understanding of the underlying biology of disease and attempts to fix that which is actually broken rather than offset the damage. IMHO, This company has positioned itself well for this new world. The variety of knowledgeable large drug companies willing to advance it funds in the hope of a marketable drug carries a lot of credibility.
Walgreen subject to heavy dependence on Medicare/Medicaid programs. Obama administration plays following laws loosely- could retaliate and make life very difficult for company. In addition, a large part of income and cash was in U.S. already. Tax benefit is on cash and income generated by overseas units
Covidien/Medtronic more distant from government control. FDA less political then some other agencies. More at stake since much of income can be allocated overseas. With a foreign parent, can even bring overseas cash into the U.S. for investment or dividends without penalty. Company's cash allocation more rational--no longer have to find ways to use huge surplus of cash overseas while being cash starved in U.S. operations. U.S. would still be a good place to do R&D if Government did not penalize it so heavily.
Depends on how much of the cash is outside the country. U.S. Tax laws heavily penalize U.S. based companies bringing the cash back into the country, whether it is to pay a dividend or invest in factories or research facilities. The U.S. tax system is the only one in an advanced country that pushes companies to invest and create jobs overseas and not domestically.
Many high tech firms have this problem. Means that funds are often spent on wasteful overseas acquisitions. Nobody wants to be "patriotic" and pay the heavy tax penalty. Of course, if the parent were a foreign company, tax law s much more forgiving. That is why we have companies considering inversions (reverse takeover with foreign parent as surviving entity)
Benefit to KMI is step-up in basis of assets of partnership units purchased from outside holders providing future depreciation tax shield. Cost, besides acquisition premium, is loss of incentive distributions. The lopsided existing contract giving the GP large incentive distributions is why I initially bought KMI. The structure also made KMI a highly leveraged play on the success of the partnership. After the merger, we just have a boring pipeline stock starting out with high tax basis on assets Admittedly Kinder has built a very good management team. Without the current structure, it becomes easier to justify buying assets that provide a lower return than KMI previously required. More growth does not mean it is good for shareholders. Many companies waste resources buying up competitors without the shareholders benefiting. Eliminating incentive distribution rights will lower the quality hurdle for new acquisitions.
I do not anticipating holding this long term anymore, but am enjoying the run for now.
tax is NOT on the dividends. It is on your share of the company's income. In early years, depletion, depreciation and amortization wipe out income. Up until merger, dividends are irrelevant for tax purposes. As an MLP, your K-1 form allocates a portion of the company's income to you and you report it on your taxes. Distributions are not a taxable event--the income is. At sale/merger, there can be a reversal ("recapture") of depreciation to the extent the company sold for more than the book value of assets. This is a potential tax exposure. Separately, any profit above recapture is a capital gain--not taxable to an IRA.
Tax treatment identical for all tax-exempt entities: nonprofit organizations, pensions, all IRA types
Always better to make more money. If you believe the price will be higher later, hold on. Incremental gains are capital gains. Only ordinary income up to point recapture noncash deductions taken. At the merger date, you are treated as if you sold your entire position and bought KMI with the proceeds. So no difference in tax treatment.
UBIT is already an issue for income OF KMP. If have used up tax losses and have income in excess of $1,500 from MLPs then owe tax.. no uncharted issue. Tax law is clear. Capital transaction(sale or taxable exchange) is not of itself a taxable issue per UBIT. However, if you have recapture of losses (should not be an issue in IRA since never recognized losses) then it would be UBIT taxable.
Furthermore, after exchange, a C corp has no UBIT issues.