[In 1981, Congress enacted a "safe harbor" lease law that permitted firms to sell unneeded tax depreciation deductions and tax credits to other firms. During the effective life of the law, the Financial Accounting Standards Board (FASB) did not establish reporting or disclosure requirements for firms entering the safe harbor transactions. Because of this, many policies were followed. This paper examines the impact of this lack of reporting and disclosure guidance on the comparability and interpretability of financial statements across firms involved in leasing. This study provides examples of problems the FASB might need to address when analyzing changes under the new tax bill.]

[The Tax Reform Act of 1986 reduced individual income tax rates below that of corporations. The fear that this would lead to a systematic disincorporation has not apparently materialized since the major stock exchanges report that only about 100 partnerships were traded during the next five years. Scholes and Wolfson (1992) suggest that this result is predictable because of the additional nontax costs of operating as a partnership, which include increased transactions costs, more restricted access to capital markets, and less control over management. Guenther (1992) and Terando and Omer (1992) provide evidence that firms must have considered both tax and nontax costs when choosing organizational form. This study examines whether the factors taken into consideration in organizational form choice also affected the market value of a sample of firms in the oil and gas industry during the period 1985-1988. We chose for our tests a valuation model used by Harris and Ohlson (1987) and others since many of the publicly traded (master limited) partnerships (MLPs) were created in the oil industry. The studies by Guenther (1992) and Terando and Omer (1992) show that MLPs generally had only one line of business, less debt, and higher dividend yields than their corporate counterparts. These differences are predictable in view of the tax consequences of operating in the partnership form. Guenther also finds MLPs to be less profitable, which is consistent with higher nontax costs of the partnership form. We show that MLPs invested significantly less in exploration for new deposits. The combination of the lower exploration expenditures, higher dividend yields, and poor financial performance suggests that MLPs may have been set up as limited-life entites to distribute assets to their unit holders in a tax-efficient manner. We extend the Harris and Ohlson (1987) valuation model by adding dividends and exploration levels. Exploration levels are found significant for both MLPs and corporations, but dividends are relevant only in the MLP model. We also find that dividend levels are significantly explained by asset values only for the MLPs. These valuation differences are consistent with tax-motivated organizational form choice and the perceived passive nature of the MLPs.]

The Tax Reform Act of 1986 reduced individual income tax rates below that of corporations. The fear that this would lead to a systematic disincorporation has not apparently materialized since the major stock exchanges report that only about 100 partnerships were traded during the next five years. Scholes and Wolfson (1992) suggest that this result is predictable because of the additional nontax costs of operating as a partnership, which include increased transactions costs, more restricted access to capital markets, and less control over management. Guenther (1992) and Terando and Omer (1992) provide evidence that firms must have considered both tax and nontax costs when choosing organizational form. This study examines whether the factors taken into consideration in organizational form choice also affected the market value of a sample of firms in the oil and gas industry during the period 1985-1988. We chose for our tests a valuation model used by Harris and Ohlson (1987) and others since many of the publicly traded (master limited) partnerships (MLPs) were created in the oil industry. The studies by Guenther (1992) and Terando and Omer (1992) show that MLPs generally had only one line of business, less debt, and higher dividend yields than their corporate counterparts. These differences are predictable in view of the tax consequences of operating in the partnership form. Guenther also finds MLPs to be less profitable, which is consistent with higher nontax costs of the partnership form. We show that MLPs invested significantly less in exploration for new deposits. The combination of the lower exploration expenditures, higher dividend yields, and poor financial performance suggests that MLPs may have been set up as limited-life entities to distribute assets to their unit holders in a tax-efficient manner. We extend the Harris and Ohlson (1987) valuation model by adding dividends and exploration levels. Exploration levels are found significant for both MLPs and corporations, but dividends are relevant only in the MLP model. We also find that dividend levels are significantly explained by asset values only for the MLPs. These valuation differences are consistent with tax-motivated organizational form choice and the perceived passive nature of the MLPs.

In 1981, Congress enacted a "safe harbor" lease law that permitted firms to sell unneeded tax depreciation deductions and tax credits to other firms. During the effective life of the law, the Financial Accounting Standards Board (FASB) did not establish reporting or disclosure requirements for firms entering the safe harbor transactions. Because of this, many policies were followed. This paper examines the impact of this lack of reporting and disclosure guidance on the comparability and Interpretability of financial statements across firms involved in leasing. This study provides examples of problems the FASB might need to address when analyzing changes under the new tax bill.

[In this article, we examine the information content of announcements of increased reserves for loan loss by Citicorp and other banks, and the later write-off announcement made by the Bank of Boston. During 1987, most major U.S. banks, led by Citicorp on 19 May 1987, announced large increases in their loan loss reserves because of problem loans in lesser developed countries (LDC). With substantial flexibility in accounting rules for determining loss exposure, the banks announced varying levels of reserve increases. On 14 December 1987, the Bank of Boston began a second round of activity relating to LDC debt by announcing a $200 million write-off of LDC loans and further increase in loan loss reserves. Financial reporters suggested that these events could be interpreted differently. Because Citicorp was a leading money-center bank, its announcement could be interpreted favorably as a signal of willingness to deal with the LDC debt problem. This interpretation could similarly apply to other banks, especially the more exposed money-center banks. In comparison, the Bank of Boston announcement was portrayed in the press as detrimental to the money-center banks for two reasons. First, unlike a reserve increase, a write-off reduces a bank's capital adequacy ratio. Capital adequacy ratios are used by bank regulators in determining the need for, and the level of, supervisory intervention. Second, the write-off was construed as an effort by regional banks to exploit their relatively limited exposure to LDC loans as a competitive advantage in the domestic banking market. We find evidence consistent with the expectations of the financial press. The strongest stock-price increases associated with both the Citicorp announcement and the subsequent announcements of reserve increases by other banks were found for the banks with the greatest exposure to LDC debt. In contrast, those banks with the greatest exposure to LDC debt and with the largest reserves sustained the largest stock-price decreases at the Bank of Boston write-off announcement. The larger money-center banks sustained, on average, a three-day decline in value of 5 percent around the Bank of Boston announcement date.]