Mapping Center Answer:

No, they’re not the same kind of object. The clipboard manages the object that has been copied and will only paste it into a container that supports the kind of object being copied/pasted. In ArcMap’s case this is a little fuzzy because while you’re editing, you could select some map text using the Select Elements tool and then switch to the Editor’s Edit tool and choose paste. The active tool isn’t the rule, even though it usually provides a basis for most operations.