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Construction Semantics And Generative Pre-Trained Transformer (Gpt) Language Models, Ankur Mitra, Ahmed Hassan, Mark Mulville
Construction Semantics And Generative Pre-Trained Transformer (Gpt) Language Models, Ankur Mitra, Ahmed Hassan, Mark Mulville
Articles
The article explores the impact of ChatGPT, a powerful language model developed by OpenAI, on the construction industry. ChatGPT, with its ability to provide contextually accurate responses to a wide range of queries, has the potential to enhance safety, scheduling, and knowledge dissemination in construction. While it shows promise in tasks like hazard recognition and project scheduling, the article emphasizes the need for cautious optimism and human oversight. The construction industry could benefit from ChatGPT's digital assistance to boost productivity and address skills shortages, but it is essential to recognize the value of human expertise alongside AI advancements.
Tax Reporting As Regulation Of Digital Financial Markets, Young Ran (Christine) Kim
Tax Reporting As Regulation Of Digital Financial Markets, Young Ran (Christine) Kim
Articles
FTX’s recent collapse highlights the overall instability that blockchain assets and digital financial markets face. While the use of blockchain technology and crypto assets is widely prevalent, the associated market is still largely unregulated, and the future of digital asset regulation is also unclear. The lack of clarity and regulation has led to public distrust and has called for more dedicated regulation of digital assets. Among those regulatory efforts, tax policy plays an important role. This Essay introduces comprehensive regulatory frameworks for blockchain-based assets that have been introduced globally and domestically, and it shows that tax reporting is the key …
Venture Predation, Matthew T. Wansley, Samuel N. Weinstein
Venture Predation, Matthew T. Wansley, Samuel N. Weinstein
Articles
Predatory pricing is a strategy firms use to suppress competition. The predator prices below its own costs to force its rivals out of the market. After they exit, the predator raises its prices to supracompetitive levels and recoups the cost of predation. The Supreme Court has described predatory pricing as “rarely tried” and “rarely successful” and has established a liability standard that is nearly impossible for plaintiffs to satisfy. We argue that one kind of company thinks predatory pricing is worth trying and at least potentially successful—venturebacked startups.
A venture predator is a startup that uses venture finance to price …
An Analysis Of The Impact And Efficacy Of An Online Mindfulness-Based Intervention As A Support For First-Year University Students, Wyndham Chalmers, Aiden Carthy, Maria Kenneally, Niamh Bruce, Colm Mcguinness, Philip Owende
An Analysis Of The Impact And Efficacy Of An Online Mindfulness-Based Intervention As A Support For First-Year University Students, Wyndham Chalmers, Aiden Carthy, Maria Kenneally, Niamh Bruce, Colm Mcguinness, Philip Owende
Articles
As a result of the COVID-19 pandemic, many university courses transitioned to online delivery, therefore, educators and students faced new challenges associated with the delivery of modules and the provision of necessary student supports. Given the scale of this transition, it is likely that many universities will continue to teach remotely far beyond the reach of any pandemic specific restrictions. This study sought to explore the impact and efficacy of a five-week online mindfulness course to a cohort of first year university students (n = 25) at Technological University Dublin (TU Dublin), Ireland. Results demonstrated that participation in the course …
Rethinking Resilience Using The R-Factor: Neurobiological Mechanisms Of Static And Dynamic Components Of Resilience Following Trauma, Sanne Van Rooij, Justin Santos, Cecilia A. Hinojosa, Timothy Ely, Nathaniel Harnett, Vishnu P. Murty, Lauren Lebois, Tanja Jovanovic, Stacey House, Robert A. Swor
Rethinking Resilience Using The R-Factor: Neurobiological Mechanisms Of Static And Dynamic Components Of Resilience Following Trauma, Sanne Van Rooij, Justin Santos, Cecilia A. Hinojosa, Timothy Ely, Nathaniel Harnett, Vishnu P. Murty, Lauren Lebois, Tanja Jovanovic, Stacey House, Robert A. Swor
Articles
Resilience is a dynamic process of recovery after trauma, but in most studies it is conceptualized as the absence of specific psychopathology following trauma. Using the large emergency department AURORA study (n=1,865, 63% women), we took a longitudinal, dynamic and transdiagnostic approach to define a static resilience (r) factor, that could explain >50% of variance in mental wellbeing 6-months following trauma, and a dynamic r-factor, which represented recovery from initial symptoms. We assessed its neurobiological profile across threat, inhibition, and reward processes using fMRI collected 2-weeks post-trauma. Our neuroimaging results suggest that resilience is promoted by activation of higher-level cognitive …
Optical Characterisation Of Holographic Diffusers And Bangerter Foils For Treatment Of Amblyopia, Matthew Hellis, Suzanne Martin, Matthew Sheehan, Kevin Murphy
Optical Characterisation Of Holographic Diffusers And Bangerter Foils For Treatment Of Amblyopia, Matthew Hellis, Suzanne Martin, Matthew Sheehan, Kevin Murphy
Articles
Amblyopia is a significant issue for children worldwide, and current treatment methods have drawbacks that can hinder treatment effectiveness and/or patient experience. This study proposes a new treatment method using holographic diffusers while also comparing their optical characteristics to a current treatment method (Bangerter foils). Holographic diffusers were developed by optically patterning thin polymer layers on a micron scale. Two compositions of photopolymer (acrylamide and diacetone acrylamide based) are analysed herein. Characterisation shows that holographic diffusers of either composition can achieve a wide range of on-axis intensity reductions, allowing for precise and customisable treatment levels by altering recording exposure time …
Addressing Low Heat Pump Heating System Sales In The Uk, Ben Costelloe
Addressing Low Heat Pump Heating System Sales In The Uk, Ben Costelloe
Articles
The replacement of existing fossil fuel boilers with heat pumps is seen as a key measure in the decarbonisation of heating systems and addressing climate change. This policy however, is currently failing in many Western European states, particularly in the UK. The many reasons for this situation are examined. However, the age of UK housing stock and particularly the high number of dwellings built prior to the introduction of building insulation regulations in 1980, are key. To maintain the running cost of air source heat pumps competitive with those of the gas boilers they generally replace the heat pump lift …
(Some) Land Back...Sort Of: The Transfer Of Federal Public Lands To Indian Tribes Since 1970, Audrey Glendenning, Martin Nie, Monte Mills
(Some) Land Back...Sort Of: The Transfer Of Federal Public Lands To Indian Tribes Since 1970, Audrey Glendenning, Martin Nie, Monte Mills
Articles
Federal public lands in the United States were carved from the territories of Native Nations and, in nearly every instance, required that the United States extinguish pre-existing aboriginal title. Following acquisition of these lands, the federal government pursued various strategies for them, including disposal to states and private parties, managing lands to allow for multiple uses, and conservation or protection. After over a century of such varied approaches, the modern public landscape is a complex milieu of public and private interests, laws and policies, and patchwork ownership patterns. This complexity depends on—and begins with—the history of Indigenous dispossession but subsequent …
Considering A Right To Repair Software, Robert W. Gomulkiewicz
Considering A Right To Repair Software, Robert W. Gomulkiewicz
Articles
The right to repair movement aims to extend the usability of products by allowing a consumer (or a repair professional acting on the consumer’s behalf) to fix broken products. Implicitly, the movement’s focus has been on hardware—on the right to repair cars, tractors, and phones. But as more and more of the functionality of goods comes from software, it is important to consider whether we need a right to repair software. There are practical challenges to software repair. For example, fixing software is more difficult and treacherous than fixing hardware. Complicating matters further, more and more software is embedded in …
Biopolymer-Based Sustainable Food Packaging Materials: Challenges, Solutions, And Applications, Kalpani Y. Perera, Amit Jaiswal, Swarna Jaiswal
Biopolymer-Based Sustainable Food Packaging Materials: Challenges, Solutions, And Applications, Kalpani Y. Perera, Amit Jaiswal, Swarna Jaiswal
Articles
Biopolymer-based packaging materials have become of greater interest to the world due to their biodegradability, renewability, and biocompatibility. In recent years, numerous biopolymers—such as starch, chitosan, carrageenan, polylactic acid, etc.—have been investigated for their potential application in food packaging. Reinforcement agents such as nanofillers and active agents improve the properties of the biopolymers, making them suitable for active and intelligent packaging. Some of the packaging materials, e.g., cellulose, starch, polylactic acid, and polybutylene adipate terephthalate, are currently used in the packaging industry. The trend of using biopolymers in the packaging industry has increased immensely; therefore, many legislations have been approved …
Definition And Characteristic Features Of A ‘Cultural Flashpoint’: A Case Study Of Exploring Masculinities, A Controversial Gender And Education Programme In Ireland, Joan Hanafin, Paul Conway, Cormac O Beaglaoich, Jack Hanafin
Definition And Characteristic Features Of A ‘Cultural Flashpoint’: A Case Study Of Exploring Masculinities, A Controversial Gender And Education Programme In Ireland, Joan Hanafin, Paul Conway, Cormac O Beaglaoich, Jack Hanafin
Articles
The concept ‘cultural flashpoint’ (CF) has not been fully defined or described. The authors test this concept through the prism of a controversial gender-focused Irish school programme, Exploring Masculinities (EM). Adopting an instrumental case study methodology, they use media content analysis to develop a temporal trajectory of the CF, describe its shape, explicit and implied contentious themes, and its process. They identify characteristic features of a cultural flashpoint: (i) a focal issue, event and/or object; (ii) conflict; (iii) bounded time period; (iv) the involvement of exo- and multi-sectoral individuals and groups; (v) randomness, opaqueness and conflation among its expressions; and …
Considerations For Scaling A Social Enterprise: Key Factors And Elements, Clodagh O'Reilly, Lucia Walsh, Ziene Mottiar
Considerations For Scaling A Social Enterprise: Key Factors And Elements, Clodagh O'Reilly, Lucia Walsh, Ziene Mottiar
Articles
The number of social enterprises has grown exponentially in recent times. International research regarding how social enterprises scale is starting to emerge and is becoming an area of increased focus. Due to their hybridity, social enterprises experience unique scaling challenges, and research has started to examine these experiences. This theoretical paper reviews existing literature on social enterprise scaling and, based on this, proposes a conceptual model for understanding the interdependent factors and elements social enterprises must navigate when scaling. The proposed conceptual model will provide a base for further empirical research. When validated, it will also provide a practical tool …
Comparison Of Control Parameters For Roller Blinds, Hani Alkhatib, Philippe Lemarchand, Brian Norton, Dominic O'Sullivan
Comparison Of Control Parameters For Roller Blinds, Hani Alkhatib, Philippe Lemarchand, Brian Norton, Dominic O'Sullivan
Articles
Roller blinds can reduce the heating and cooling building energy consumption required to maintain thermal comfort. The effectiveness of roller blinds is influenced by the strategies and input parameters for their control. This study is the first to identify the most effective of seven alternative control parameters to control roller blinds. It further defines the benefits from using paired control parameters to maximise energy savings and optimise occupants’ comfort. For the particular case studies and conditions examined, it is concluded that operating roller blinds using indoor air temperature as a single control parameter with rule-based controller provided, 16 %, 19 …
A W-Shaped Convolutional Network For Robust Crop And Weed Classification In Agriculture, Syed Imran Moazzam, Tahir Nawaz, Waqar Shahid Qureshi, Umar Shahbaz Khan, Mohsin Islam Tiwan
A W-Shaped Convolutional Network For Robust Crop And Weed Classification In Agriculture, Syed Imran Moazzam, Tahir Nawaz, Waqar Shahid Qureshi, Umar Shahbaz Khan, Mohsin Islam Tiwan
Articles
Agricultural image and vision computing are significantly different from other object classification-based methods because two base classes in agriculture, crops and weeds, have many common traits. Efficient crop, weeds, and soil classification are required to perform autonomous (spraying, harvesting, etc.) activities in agricultural fields. In a three-class (crop-weed-background) agricultural classification scenario, it is usually easier to accurately classify the background class than the crop and weed classes because the background class appears significantly different feature-wise than the crop and weed classes. However, robustly distinguishing between the crop and weed classes is challenging because their appearance features generally look very similar. …
The State Of Accessibility In Blackboard: Survey And User Reviews Case Study, Mohamed Wiem Mkaouer, Wajdi Aljedaani, Stephanie Ludi, Mohammed Alkahtani, Marcelo M. Eler, Marouane Kessentini, Ali Ouni
The State Of Accessibility In Blackboard: Survey And User Reviews Case Study, Mohamed Wiem Mkaouer, Wajdi Aljedaani, Stephanie Ludi, Mohammed Alkahtani, Marcelo M. Eler, Marouane Kessentini, Ali Ouni
Articles
Context: Nowadays, mobile applications (or apps) have become vital in our daily life, particularly within education. Many institutions increasingly rely on mobile apps to provide access to all their students. However, many education mobile apps remain inaccessible to users with disabilities who need to utilize accessibility features like talkback or screen reader features. Accessibility features have to be considered in mobile apps to foster equity and inclusion in the educational environment allowing to use of such apps without limitations. Gaps in the accessibility to educational systems persist.
Objective: In this paper, we focus on the accessibility of the Blackboard mobile …
Novel Block Grid Analysis (Bga) Based Algorithm For Use In Determining Coefficients Of Similarities Between Uv Fluorescent Spectra, Kevin N. Mellon Dr, Noel Carey Mr
Novel Block Grid Analysis (Bga) Based Algorithm For Use In Determining Coefficients Of Similarities Between Uv Fluorescent Spectra, Kevin N. Mellon Dr, Noel Carey Mr
Articles
This paper presents a novel computational process used for determining matching coefficients for optical spectra either in real time or from a database. This simple algorithmic method is capable of outputting a set of coefficients relating to comparative matching datapoints and to a weighted similarity ratio between spectra whilst still maintaining high computational efficiency due to the minimization of floating-point calculations. The process works as effectively on signal data during real time processing or on images of spectra which may be stored in a database. A subset of the algorithm has already been used very effectively in an embedded mobile …
Energy-Specific Greenhouse Gas Emissions Measurements From 2-Stroke Marine Diesel Engine Using Liquefied Natural Gas, Kang-Ki Lee, Wilfried Hochegger, Alessandro Schonborn
Energy-Specific Greenhouse Gas Emissions Measurements From 2-Stroke Marine Diesel Engine Using Liquefied Natural Gas, Kang-Ki Lee, Wilfried Hochegger, Alessandro Schonborn
Articles
This study reports the energy specific air emissions from a diesel-cycle high pressure injection dual fuel engine for operation on liquefied natural gas and heavy fuel oil. An experiment at sea was performed onboard a bulk carrier during commercial voyages, to measure the efficiency of the engine and to measure air emissions relevant to air pollution and climate impact for operation on both fuels. The measurements showed that the energy conversion efficiency of the engine was higher for operation on liquefied natural gas because its lower NOx emissions permitted the use of a higher effective compression ratio whilst meeting the …
Submitting The ‘Right’ Reflection, Catherine Murphy, Tom O'Mahony
Submitting The ‘Right’ Reflection, Catherine Murphy, Tom O'Mahony
Articles
While the benefits of reflection for students are well documented, there is a parallel body of research pointing to varying levels of engagement with reflection. Students on a four-year business information systems programme have to complete a reflection as part of their placement assessment. Using a constructivist qualitative methodology, this research explores the students' experience of reflecting with a view to identifying what supports could be useful to guide students in the future. Using semi-structured interviews, the students described a focus on description of activities and overall uncertainty on what to write. There are multiple possible interventions which could support …
Telegraph, Telephone And The Internet: The Making Of The Symbiotic Model Of Surveillance States, Dongsheng Zang
Telegraph, Telephone And The Internet: The Making Of The Symbiotic Model Of Surveillance States, Dongsheng Zang
Articles
In the early 2000s, shortly before the September 11 attacks, Daniel J. Solove noted that computer databases in the United States were controlled by public as well as private bureaucracies. In that sense, Solove argued, the "Big Brother" metaphor "fails to capture the most important dimension of the database problem." In his 2008 Lockhart lecture, constitutional law scholar Jack M. Balkin argued that the United States has gradually transformed from a welfare and national security state to a National Surveillance State: "a new form of governance that features the collection, collation, and analysis of information about populations both in the …
The Replication Crisis And Ip Law: A Novel Policy Tool For Open Science, Or Cohen Sasson, Ofer Tur‐Sinai
The Replication Crisis And Ip Law: A Novel Policy Tool For Open Science, Or Cohen Sasson, Ofer Tur‐Sinai
Articles
In recent years, the scientific community has faced a considerable problem the replication crisis. Replication is the process of verifying scientific findings by repeating a published study. It is considered a cornerstone of the scientific enterprise, contributing to the credibility of research findings. Over the past two decades, however, replication has become increasingly difficult; in fact, in some disciplines the non-replicability rate is over 50%. A major factor accounting for this is diminished access to research materials required for replication (replication materials). This problem is particularly acute in computational studies, where the code, software documentation, datasets, and other information are …
Startup Biases, Jennifer S. Fan
Startup Biases, Jennifer S. Fan
Articles
This Article provides an original descriptive account of bias in the startup context and explains why litigation is eschewed and what happens when it is used as a mechanism to combat bias in the venture capital ecosystem. Further, this Article identifies two particular phenomena in the startup context that exacerbate gender and racial bias. First, homophily—the idea that like attracts like—abounds and has been part of the DNA of venture capital since its inception. The thick networks that developed as venture capital made its way from the East Coast to the West Coast were limited to an elite group that …
Taxing Digital Platforms, Andrew Hayashi, Young Ran (Christine) Kim
Taxing Digital Platforms, Andrew Hayashi, Young Ran (Christine) Kim
Articles
The proliferation of digital services taxes (DSTs) in Europe is generally understood as a way for those countries to claim taxing rights over the profits of large digital platforms such as Google, Facebook, and Amazon. Under prevailing norms of international income taxation, these businesses had been able to avoid paying taxes in countries where they had no physical presence, even if they had many users in those countries. But the rise of big tech has generated a set of regulatory and political challenges, and tax is only one of these. The adoption of DSTs is not only about the fair …
Pvpbc: Privacy- And Verifiability-Preserving E-Voting Based On Permissioned Blockchain, Muntadher Sallal, Ruairí De Fréin, Ali Malik
Pvpbc: Privacy- And Verifiability-Preserving E-Voting Based On Permissioned Blockchain, Muntadher Sallal, Ruairí De Fréin, Ali Malik
Articles
Privacy and verifiability are crucial security requirements in e-voting systems and combining them is considered to be a challenge given that they seem to be contradictory. On one hand, privacy means that cast votes cannot be traced to the corresponding voters. On the other hand, linkability of voters and their votes is a requirement of verifiability which has the consequence that a voter is able to check their vote in the election result. These two contradictory features can be addressed by adopting privacy-preserving cryptographic primitives, which at the same time as achieving privacy, achieve verifiability. Many end-to-end schemes that support …
Enhanced Internal Coating Structure And Light Reflectance Of Coated Papers: A Sludge Valorization Process, Bilge N. Altay, Anamika Huq, Burak Aksoy, Richard Hailstone, Muslum Demir, Cem Aydemir, Arif Karademir, Scott Williams
Enhanced Internal Coating Structure And Light Reflectance Of Coated Papers: A Sludge Valorization Process, Bilge N. Altay, Anamika Huq, Burak Aksoy, Richard Hailstone, Muslum Demir, Cem Aydemir, Arif Karademir, Scott Williams
Articles
Paper mill sludge (PMS) is a high-volume waste of the pulppapermaking industry, containing cellulose fibers. This paper introduces cellulose nanofibers extracted from PMS (CNFsPMS) and their application in paper coatings using a wire-wound coating method to enhance internal and optical properties of paper. Three factors were investigated: (i) CNFsPMS amount, (ii) number of layers, and (iii) surface treatment via a 4 × 2 × 2 factorial design. The experimental responses were tracked by fundamentally important internal properties including porosity, air permeability, thickness, roughness, and optical properties of brightness, gloss, and CIE L*a*b* color coordination. The results showed that CNFPMS enhances …
Precise And Analytical Calculation Of Interface Surface Area In Sharp Interfaces And Multiphase Modeling, Simon P. Shipkowski, Isaac Bernabe Perez Raya
Precise And Analytical Calculation Of Interface Surface Area In Sharp Interfaces And Multiphase Modeling, Simon P. Shipkowski, Isaac Bernabe Perez Raya
Articles
Various kinds of Piecewise Linear Interface Calculations (PLIC) are commonly used in Computational Fluid Dynamics (CFD) for multiphase flows. Here, a new method is proposed to calculate the interface size for CFD simulations. This PLIC method with the modifier, Analytic Size Based [method], (PLIC-ASB), being that the calculation requires a symbolic equation and no approximation or numerical methods. The primary advantage of the PLIC-ASB is maintaining a sharp interface and providing for physics-based (not iterative or empirically derived factors) mass transfer due to the cell-by-cell accuracy. Along with the sharp interface, this method leads to precise interface displacements and suppresses …
Pilot Study Of The Association Between Microbiome And The Development Of Adverse Posttraumatic Neuropsychiatric Sequelae After Traumatic Stress Exposure, Abigail L. Zeamer, Marie-Claire Salive, Xinming An, Stacey L. House, Francesca L. Beaudoin, Jennifer S. Stevens, Donglin Zeng, Thomas C. Neylan, Gari D. Clifford, Robert A. Swor
Pilot Study Of The Association Between Microbiome And The Development Of Adverse Posttraumatic Neuropsychiatric Sequelae After Traumatic Stress Exposure, Abigail L. Zeamer, Marie-Claire Salive, Xinming An, Stacey L. House, Francesca L. Beaudoin, Jennifer S. Stevens, Donglin Zeng, Thomas C. Neylan, Gari D. Clifford, Robert A. Swor
Articles
Background Patients exposed to trauma often experience high rates of adverse post-traumatic neuropsychiatric sequelae (APNS). The biologic mechanisms promoting APNS are currently unknown, but the microbiota-gut-brain axis offers an avenue to understanding mechanisms as well as possibilities for intervention. Microbiome composition at the time of trauma exposure has been poorly examined regarding neuropsychiatric outcomes. We aimed to determine whether baseline the gut microbiomes of trauma-exposed emergency department patients who later develop APNS have dysfunctional gut microbiome profiles and discover potential associated mechanisms.
Methods We performed metagenomic analysis on stool samples (n=51) from a subset of adults enrolled in the Advancing …
An Evaluation Of A Computational Technique For Measuring The Embeddedness Of Sustainability In The Curriculum Aligned To Aashe-Stars And The United Nations Sustainable Development Goals, Philippe Lemarchand, Cormac H. Macmahon Dr, Mick Mckeever, Philip Owende
An Evaluation Of A Computational Technique For Measuring The Embeddedness Of Sustainability In The Curriculum Aligned To Aashe-Stars And The United Nations Sustainable Development Goals, Philippe Lemarchand, Cormac H. Macmahon Dr, Mick Mckeever, Philip Owende
Articles
Introduction: SDG 4.7 mandates university contributions to the United Nations (UN) Sustainable Development Goals (SDGs) through their education provisions. Hence, universities increasingly assess their curricular alignment to the SDGs. A common approach to the assessment is to identify keywords associated with specific SDGs and to analyze for their presence in the curriculum. An inherent challenge is associating the identified keywords as used in the diverse set of curricular contexts to relevant sustainability indicators; hence, the urgent need for more systematic assessment as SDG implementation passes its mid-cycle.
Method: In this study, a more nuanced technique was evaluated with notable capabilities …
Digital Tax Arithmetic., James R. Hines Jr.
Digital Tax Arithmetic., James R. Hines Jr.
Articles
More than 20 countries recently adopted digital services taxes, with many others threatening to do so. The Organisation for Economic Co-operation and Development (OECD) is attempting to convince countries to withdraw their digital taxes in return for an international agreement to implement its Pillar One proposal that would let countries tax prorated shares of the profits of foreign firms with local sales. This paper identifies incentives that countries have to impose inefficiently high rates of digital taxes and calls attention to shortcomings of the OECD’s formulary apportionment alternative. Diverging interests and the inflexible nature of the multilateral bargaining process make …
Fables Of Scarcity In Ip, Zahr K. Said
Fables Of Scarcity In Ip, Zahr K. Said
Articles
In this chapter, I use methods drawn from literary analysis to bear on artificial scarcity and explore how literary and legal storytelling engages in scarcity mongering. I find three particular narrative strategies calculated to compel a conclusion in favor of propertization: the spectacle of need, the diversionary tactic, and the rallying cry. First, I unpack the spectacle of need and its diversionary aspects through several literary accounts of scarcity and starvation. I juxtapose Franz Kafka's “A Hunger Artist,” a story explicitly centered on a wasting body, with J.M. Coetzee's The Life and Times of Michael K. Second, to explore how …
Microsoft's Cost-Sharing Arrangement: Frankenstein Strikes Again, Stephen L. Curtis, Reuven S. Avi-Yonah
Microsoft's Cost-Sharing Arrangement: Frankenstein Strikes Again, Stephen L. Curtis, Reuven S. Avi-Yonah
Articles
This paper performs a forensic analysis of Microsoft Corporation’s transfer pricing cost sharing arrangement based on forensic economic analysis of public and information, including Microsoft’s SEC and foreign country regulatory filings, documents disclosed during a recent federal court trial, materials published by Microsoft, and information from former insiders interviewed for this paper, and other sources. The paper finds that Microsoft appears to have violated U.S. transfer pricing laws in 2009 and later years, in ways that caused its transfer pricing cost sharing arrangement with its Irish, Singaporean and Puerto Rican affiliates under U.S. tax laws to be invalid. However IRS …