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Guilty As Charged: Reflections On Tra 17, Reuven S. Avi-Yonah

Articles

The international provisions of TRA 17S are in some ways an improvement over TRA 17H, but they are nevertheless deeply flawed. U.S.-based MNEs have accumulated $ 2.6 trillion of low taxed income offshore. This "guilty" income derives not just from IP developed in the United States, but in many cases (for example, Google, Facebook, and Big Pharma) also from exploiting the U.S. consumer market. This is a classic "round tripping" situation in which both the supply side (production) and the demand side (consumption) are in the United States, and yet both TRA 17H and TRA 17S let the guilty parties …

Once More, With Feeling: The 'Tax Cuts And Jobs' Act And The Original Intent Of Subpart F, Reuven S. Avi-Yonah, Nir Fishbien

Law & Economics Working Papers

For the first time since 1913, Congress is considering abandoning the principle that US residents should be subject to tax on all income “from whatever source derived.” Specifically, the House proposed tax reform legislation, the so-called “Tax Cuts and Jobs Act”, would completely exempt from US taxation dividends from “Controlled Foreign Corporations”. This is therefore a good occasion for considering the reasons we tax such dividends in the first place.

In the course of investigating the Stanley Surrey papers at the Harvard Law School Library, we discovered a remarkable report that support the view that the main impetus behind Subpart …

Professional Sports Events, Concerts, And Urban Place Based Policy: Evidence From The Staples Center, Iuliia Chikish, Brad R. Humphreys, Crocker H. Liu, Adam D. Nowak

Economics Faculty Working Papers Series

We analyze the relationship between sports events and concerts, important hospitality demand drivers and key components of many urban renewal projects, in the Staples Center in Los Angeles, an arena home to three pro teams, and nearby hotel performance, exploiting exogenous daily variation in the timing of games and concerts from 2002 to 2017. Results show a small positive impact on revenue per available room at hotels within one mile of the arena and an osetting decrease at hotels located one to four miles away. Granting nearby hotels exemptions from Los Angeles hotel taxes reduces potential tourism-generated hotel tax revenue …

The Pich Exception: Reservations, Exceptions To Warranty,And Exceptions To Grant In The Chain Of Title, Zackary D. Callarman

LSU Journal of Energy Law and Resources

No abstract provided.

The Kingfish’S Mineral Legacy: An Analysis Of The Legality Ofstate Mineral Leases Granted To W.T. Burton And Jamesa. Noe During The Years 1934–1936 And Their Relevanceto Former United States Senator And Louisiana Governorhuey P. Long, Ryan M. Seidemann, Ethel S. Graham, Steven B. "Beaux" Jones, William T. Hawkins, Frederic Augonnet

LSU Journal of Energy Law and Resources

No abstract provided.

The War On Coal, John Copeland Nagle

LSU Journal of Energy Law and Resources

No abstract provided.

Grand Isle Iii’S Tarpen Rodeo: The Confused Seas Of Ocslaand Maritime Law In The Fifth Circuit, Christopher B. Ortte

LSU Journal of Energy Law and Resources

No abstract provided.

A Watershed Agreement: Fixing The Wild West Of Waterusage, Jane M. Daily

LSU Journal of Energy Law and Resources

No abstract provided.

Drive Down To Electric Avenue: Taking Electric Vehicleincentives Higher, Andrew Rabalais

LSU Journal of Energy Law and Resources

No abstract provided.

State V. Resendiz Appellant's Brief Dckt. 45006

Not Reported

No abstract provided.

State V. Smalley Appellant's Reply Brief Dckt. 44233

Not Reported

No abstract provided.

State V. Clyne Respondent's Brief Dckt. 44953

Not Reported

No abstract provided.

State V. Jones Respondent's Brief Dckt. 44994

Not Reported

No abstract provided.

2017 November 20 - Faculty Senate Agenda And Minutes, Faculty Senate, East Tennessee State University

Faculty Senate Agendas and Minutes

No abstract provided.

Faculty Senate Executive Committee Agenda, November 20, 2017, Utah State University

Faculty Senate & Faculty Senate Executive Committee

• EPC November Report
• USUSA Annual Report
• Retention and Student Success Annual Report
• Policy 405.6.2 Promotion Advisory Committee (PAC) (second reading)
• Policy 405.11.4 External Peer Reviews (first reading)

State V. Miller Appellant's Brief Dckt. 45028

Not Reported

No abstract provided.

State V. Rodriguez Respondent's Brief Dckt. 45013

Not Reported

No abstract provided.

Localization Of Interacting Fields In Five-Dimensional Braneworld Models, Dewi Wulandari, Triyanta, Jusak S. Kosasih, Douglas Singleton, Preston Jones

Publications

We study localization properties of fundamental fields which are coupled to one another through the gauge mechanism both in the original Randall-Sundrum (RS) and in the modified Randall-Sundrum (MRS) braneworld models: scalar-vector, vector-vector, and spinor-vector configuration systems. For this purpose we derive conditions of localization, namely the finiteness of integrals over the extra coordinate in the action of the system considered. We also derive field equations for each of the systems and then obtain their solutions corresponding to the extra dimension by a separation of variable method for every field involved in each system. We then insert the obtained solutions …

Lanthorn, Vol. 52, No. 26, November 20, 2017, Grand Valley State University

Volume 52, July 10, 2017 - April 23, 2018

Lanthorn is Grand Valley State's student newspaper, published from 1968 to the present.

The Dynamics Of Stress And Fatigue Across Menopause: Attractors, Coupling, And Resilience, Lisa Taylor-Swanson, Alexander E. Wong, David Pincus, Jonathan E. Butner, Jennifer Hahn-Holbrook, Mary Koithan, Kathryn Wann, Nancy F. Woods

Psychology Faculty Articles and Research

Objective:

The objective of this study was to evaluate the regulatory dynamics between stress and fatigue experienced by women during the menopausal transition (MT) and early postmenopause (EPM). Fatigue and perceived stress are commonly experienced by women during the MT and EPM. We sought to discover relationships between these symptoms and to employ these symptoms as possible markers for resilience.

Methods:

Participants were drawn from the longitudinal Seattle Midlife Women's Health Study. Eligible women completed questionnaires on 60+ occasions (annual health reports and monthly health diaries) (n = 56 women). The total number of observations across the sample was 4,224. …

Analysis Of The Acid-Base Balance Of Mainstream Tobacco Smoke And Its Effect On The Gas/Particle Partitioning Of Nicotine, Amy Kathleen Devita-Mcbride

Dissertations and Theses

Tobacco smoke particulate matter (PM) is a complex mixture of condensed organic compounds, with about 5 to 10% water. Its general properties are similar in some respects to that of atmospheric organic aerosol PM and thus provides a useful surrogate when studying atmospheric PM. Due to its ability to undergo acid-base chemistry, nicotine is of particular interest in the tobacco smoke system. The gas/particle partitioning of nicotine depends on the protonation state of nicotine in the particles, so the distribution of nicotine between these phases provides a means of understanding the acid-base balance in the tobacco smoke system. The goal …

Social Support And Survival Strategies Of Older African American Grandmother Caregivers, Gaynell M. Simpson, Tracy D. Pressley, Dana L. Carthron, Kim Stansbury

GrandFamilies: The Contemporary Journal of Research, Practice and Policy

The effects of caring for grandchildren on grandparents’ emotional and physical well-being have become a significant area of focus in behavioral and medical research. Research suggests that African American grandmothers may experience increased mental and physical health challenges due to their caregiving stressors. To buffer the adverse influence of stress, caregivers often rely on informal social support from family and/or community members. In this study we explored older, African American caregivers’ management of their emotional well-being within the context and circumstances of available to minimal social support from family and community. During an 18-month period, seven caregiving grandmothers participated in …

Problems In Embalming: Cyanide Poisoning, Rebecca Majus

ASA Multidisciplinary Research Symposium

To inform funeral professionals, or anyone interested, what cyanide poisoning is, how death from it occurs, how to detect it in postmortem remains, how it poses a problem for embalmers, and what embalming techniques can be used to treat it.

The Dark Side Of Counterfeit Luxury Goods, Carissa Teal, Seung-Hee Lee

ASA Multidisciplinary Research Symposium

The purposes of this research were to examine prevalence of fashion luxury counterfeit products online, and investigate negative aspects of counterfeit product consumption.

Southern Illinois: An Analysis Of Opioid Prevention Strategies, Brittany Clemmons, Brooke Griffin

ASA Multidisciplinary Research Symposium

This research analyzes the opioid epidemic in Southern Illinois and evaluates the effectiveness of current prevention and intervention programs.

A Combinatorial Approach To Cns Regeneration Using Activated Transcription Factors, Saloni T. Mehta

Open Access Dissertations

Approximately 300,000 Americans are living today with permanent disability related to traumatic spinal cord injury (SCI), with almost 12,000 new cases each year. There are no current methods to promote robust regeneration and long-term functional recovery in SCI patients. This is partially because, following SCI, axon regeneration in the CNS is poor, owing both to neuron intrinsic factors and to external inhibitory factors. One major intrinsic limitation on axon regeneration is the altered activities of regeneration-associated transcription factors (TFs) in mature neurons of the central nervous system (CNS); these factors fail to be activated post-injury. In contrast, axons in the …

Testing The National Reading Panel’S Fluency Claims: A Study Examining Repeated Readings And Tracking The Nature Of Miscues, Edward Lehner, John R. Ziegler

Publications and Research

The National Reading Panel’s (NRP; 2000) claim that reading fluency is the direct result of phonemic awareness skills seemed to set a research direction for numerous literacy scholars. As a result, much of the reading fluency research examined the construct from a particular perspective seemingly informed by the NRP. The summative results of a generation of fluency research have subsequently defined reading fluency as a principal and predicative construct in children’s reading potential. The current study examined how children develop reading fluency skills and reports data gathered from a New York City elementary school. Specifically, the present work tracked the …

Collection Of Cryptocurrency Customer-Information: Tax Enforcement Mechanism Or Invasion Of Privacy?, Austin Elliott

Duke Law & Technology Review

After granting permission to the Internal Revenue Service to serve a digital exchange company a summons for user information, the Federal District Court for the Northern District of California created some uncertainty regarding the privacy of cryptocurrencies. The IRS views this information gathering as necessary for monitoring compliance with Notice 2014-21, which classifies cryptocurrencies as property for tax purposes. Cryptocurrency users, however, view the attempt for information as an infringement on their privacy rights and are seeking legal protection. This Issue Brief investigates the future tax implications of Notice 2014-21 and considers possible routes the cryptocurrency market can take to …

Assemblage Of The Emergent Plantation Museum Experience, Amy E. Potter, Candace Bright, Derek H. Alderman, David L. Butler, Perry L. Carter, Stephen P. Hanna, E. Arnold Modlin

Earth, Environment & Sustainability: Faculty Presentations (1988-2022)

This presentation was given during the Southeastern Division of the Association of American Geographers Annual Meeting.

Causes Of Tractor Breakdowns And Requisite Solutions A Case Study Of Small Tractor Use In Riau Province, Indonesia, Paman Ujang, Uchida S., Inaba S., Kojima T.

ASEAN Journal on Science and Technology for Development

A survey has been undertaken to look into the causes of tractor breakdowns on field operations and the main constraints associated with repair and maintenance, and to recommend a solution to the problems in Riau Province. The owners of sixty-two small tractors were interviewed, from three regencies chosen of the Province in 2003. As a result, the working capacity of the tractors was relatively high and the average annual use was relatively low compared to the national average. Most tractor operators did not have sufficient skill to operate tractors. The tractor breakdowns resulted from operators’ mistakes, fuel and oil defilement, …