Digital Commons Network^™

Esg And The Demand For State Tax Incentives, Mark J. Cowan, Joshua Cutler

Florida Tax Review

This Article argues that a business which embeds environmental, social, and governance (ESG) considerations in its strategy should consider whether seeking or accepting targeted state and local economic development incentives (which we refer to as “state tax incentives”) is consistent with that strategy. The outcome of that consideration will vary by locality, incentive package, and strategy. But given the demonstrated negative impact of state tax incentives on government finances and the community, most ESG-minded companies should either forgo them or cooperate with the state in crafting incentives that benefit both the company and the community. A well-crafted ESG reporting standard …

Tax Law Enforcement And Redistributive Politics, Yehonatan Givati, Andrew T. Hayashi

Florida Tax Review

The Inflation Reduction Act signed by President Biden on August 16, 2022, allocated $80 billion in additional funding for the IRS. While Democrats unanimously supported the bill, not a single Republican voted in favor of it. The first legislation advanced by the new Republican majority in 2023 was to repeal this increase in IRS funding. Given the diminished state of IRS enforcement capacity, increasing the resources devoted to tax enforcement seems like an obvious imperative without a clear partisan valence. One might think that political and ideological battles would be fought over what the tax law is, not whether the …

The Shifting Economic Allegiance Of Capital Gains, Amanda Parsons

Florida Tax Review

Technological advances and the digitalization of the global economy have created an economic environment beyond the imagination of the original designers of the international tax system. Much scholarly attention has been paid to the question of how these economic transformations should affect which country is able to tax a multinational company’s income. But which country should be able to tax capital gains income from the sale of that company’s shares is an important and overlooked question.

This Article answers this question. It concludes that taxing authority over capital gains income must be reallocated to the countries in which companies conduct …

Designing A Billionaires' Tax, Lawrence Zelenak

Florida Tax Review

With ProPublica’s dramatic revelation in 2021 of the low “true tax rates” of America’s billionaires serving as a catalyst, the exclusion of unrealized gains from the base of the federal income tax has been challenged to an extent unprecedented in the century-plus history of the tax. In late 2021, a proposal by Senate Finance Committee Chair Ron Wyden (D, OR) to tax billionaires’ unrealized gains in tradable assets might have become law, but for the opposition of Senator Joe Manchin (D, WV). And in early 2022, the Treasury Department of President Joe Biden included a minimum tax on the unrealized …

A New Pillar To Address Tax Challenges Arising From Digitalization Of The Economy: Consensus-Based Digital Services Taxes?, Jingyi Wang

Florida Tax Review

Traditional international tax rules empower a source state to tax non-residents who have a strong physical connection to that state. Digitalized business models reduce, or even eliminate, the need for a physical presence to conduct economic activities in the state where customers are located. This change has created significant challenges for tax administrations, and many jurisdictions have adopted unilateral digital services taxes to increase collection from digitalized businesses. The OECD/G20 Inclusive Framework aims to reform the ‘outdated’ international tax rules by promoting the Pillar One project on the tax challenges of digitalization in order to enable greater taxing rights by …

Taxing Zero, Hillel Nadler

Florida Tax Review

“Zero-price” transactions—in which goods or services are provided at a cash price of zero—are an increasingly important feature of economic life. Consumers can search the web, use email, listen to music and even trade stocks, all without paying anything out of pocket. But zero-price transactions are not free: for-profit businesses provide products at zero price because they get something valuable from consumers in return. Consumers pay with their time, attention or private information. Zero-price transactions are not giveaways; they are a form of barter exchange.

Under federal income tax principles, barter exchanges are taxable: both parties to the transaction are …

The Paradox Of Taxing The Rich, Edward J. Mccaffery

Florida Tax Review

America does not tax its richest citizens, such as Elon Musk or Jeff Bezos, at all. This Article argues that part of the reason is the paradox that under current income tax law and theory, taxing the rich would cost resources that could be made available to benefit the not-rich. The Article explores the paradox in theory and practice, then points to ways to move beyond it. Taxing the rich will mean accepting compelling justifications for doing so other than providing resources to the not-rich. We must either pay the price or reset the terms of the debate to move …

The Passthrough Entity Tax Scandal, Daniel J. Hemel

Florida Tax Review

Three dozen states have enacted laws since 2018 that are designed to provide passthrough entity owners with an unlimited federal tax deduction for state and local business income taxes. These “passthrough entity tax” regimes respond to the December 2017 federal tax law, which imposed a $10,000 cap on the state and local tax deduction. The new state laws generally allow passthrough entities to opt into paying an entity-level state income tax in exchange for a dollar-for-dollar benefit on their owners’ state personal income tax returns. The optional tax has proven to be immensely popular among passthrough entity owners across the …

How Federal Government Policy Helped Create Retirement Insecurity, Beverly Moran

Florida Tax Review

Financial security in retirement is crucial. Without it, people fall into poverty, work until they die, and die younger than they should.

In the 21st century, Americans fund their retirement from Social Security, traditional pension plans, defined contributions plans and private retirement savings plans. Of these four, only Social Security is exclusively the creature of government. Nevertheless, federal law regulates the other three to such an extent that it is fair to say that all four reflect government retirement policy.

Since 1974, the federal government has spent billions of dollars supporting the private retirement system. In turn, the private retirement …

How Agency From Precollege Experiences Empowers Black Student-Athletes To Succeed And Find Belonging At Pwis: A Phenomenological Study, Deborah V. Hogan

Journal of Issues in Intercollegiate Athletics

In the ever-changing college football landscape, Division I (DI) student-athletes seek to maximize their athletic and financial potential while navigating the academic and social challenges of college life. For Black student-athletes (BSAs) at predominantly White institutions (PWIs), the campus racial climate shapes their college experience and sense of belonging. The current phenomenological study explores how DI Black football student-athletes (BFSAs) use agency from precollege experiences to navigate racial climates and find belonging at PWIs. Using Critical Race Theory (CRT) and sense of belonging frameworks, semi-structured interviews were conducted with 13 former BFSAs from DI PWIs. The study revealed three main …

The Common Sense Of A Wealth Tax: Thomas Paine And Taxation As Freedom From Aristocracy, Jeremy Bearer-Friend, Vanessa Williamson

Florida Tax Review

Thomas Paine’s writing helped spur the American colonies to independence and ensure that the new nation would be a republic, not a monarchy. In light of the renewed interest in wealth taxes, this article provides a close examination of Thomas Paine’s wealth tax proposal in the second volume of The Rights of Man. Unlike Paine’s proposal to tax inheritances, his 1792 proposal to tax wealth on an annual basis is often overlooked. The article identifies Paine’s various design specifications, provides original estimates of the impact of Paine’s wealth tax proposal within his own time period and as applied to billionaires …

Tcas Constitution And Bylaws Annotated, Tarrant County Archeological Society

North Texas Archeological Society Records

Annotated constitution and bylaws for TCAS.

Tcas Constitution And Bylaws, Tarrant County Archeological Society

North Texas Archeological Society Records

The constitution and bylaws for TCAS.

Tcas Meeting Minutes October 2014, Chris A. Meis

North Texas Archeological Society Records

TCAS meeting minutes for October 1, 2014.

Tas Public Outreach & Membership Report, Carol Macaulay

North Texas Archeological Society Records

Outreach and membership committee report for TAS.

Tcas Meeting Minutes August 2009, Chris A. Meis

North Texas Archeological Society Records

TCAS meeting minutes for August 6, 2009.

Tcas Meeting Minutes August 2001, Tarrant County Archeological Society

North Texas Archeological Society Records

TCAS meeting minutes for August 2, 2001 and August 9, 2001.

Taking A Stand For Quality: Demonstrating Pqs Effectiveness By Operationalizing Qrm And Km, Kevin O'Donnell, Martin J. Lipa, Anne Greene (Editor)

Journal of Applied Pharmaceutical Regulatory Science

While the authors have published widely on the need to unite the twin enablers of ICH Q10 [1], quality risk management (QRM) and knowledge management (KM), how to integrate QRM and KM in practice has proven to be quite challenging. QRM and KM are wide-ranging activities that impact many elements of pharmaceutical manufacturing and regulation. Pharmaceutical manufacturers and their regulators work to apply risk-based approaches to their work and strive to use knowledge in a smart and efficient way, but so far, in the experience of the authors, it has proven difficult to get these things right.

One way to …

Statistical Securities Compliance, Brian Haney

Journal of Technology Law & Policy

This Article makes three main contributions. First, this Article introduces the Solana blockchain as a public good and provides policy analysis for open innovation. Second, this Article introduces a new dataset for SEC blockchain enforcement, supporting empirical compliance analysis. Third, this Article draws on the legal informatics literature to provide a mechanism for applied analysis of digital assets on the Solana blockchain in the context of securities law. The main purpose of this Article is to introduce new methods for using natural language processing to automate compliance services on the Solana blockchain.

Moving The United States Into The 21st Century For Children's Online Privacy Rights, Zackary A. Blanton

Journal of Technology Law & Policy

It has been more than twenty-five years since the Children’s Online Privacy Protection Act (COPPA) was first implemented in the United States. Since its enactment—well over a decade ago—there has been only one instance in which Congress successfully passed noteworthy modifications to the Act. While there has been a recent increase in proposed amendments to the Act better to protect children in our current reality of everchanging technology, little has been done to initiate the much-needed change. The increased focus on children’s online rights has been sparked primarily by changes made in the United Kingdom. At the forefront of the …

The People's War And Its Application To China's Legal Framework For Cybersecurity, Christopher J. Lin

Journal of Technology Law & Policy

This Article addresses the growing threat of cyberattacks on critical infrastructure by examining China’s response, particularly through its Cybersecurity Law (CSL), against the backdrop of global cybersecurity laws like the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). The CSL, enacted in 2016, is analyzed within the context of Chinese military doctrine, specifically, the concept of the People’s War introduced by Mao Zedong. Part I traces the historical evolution of the People’s War, Part II explores its continued relevance in cyberspace, and Part III discusses how the People’s War elements manifest in the CSL and related …

Numerical Investigation Of Temperature Distribution Analysis For A Domestic Refrigerator With Different Duct Shapes, Faisal Elhabashy, A.A. Hawwash, Aly M.A. Soliman, Walid G. Alshaer

Journal of Engineering Research

The domestic refrigerator is one of the most home appliance used and the enhancement in its performance will has a significant effect on energy saving and environment. Preserving food at low and uniform temperatures is especially important to avoid Food spoilage and decreases the microorganisms. The aim of this study is to investigate numerically a different duct shapes to achieve an efficient cooling in the refrigerator and keep the temperature at the required range, using software called SIMULIA. The numerical model was developed to simulate the refrigeration system accurately, porous media and heat balance techniques were combined to the conservation …

A Non-Standard Finite Difference Approach For Optimizing The Thermal Behaviour Of Photovoltaic Panel With Hybrid Cooling Techniques, E.F. El-Gazar, A.A Hawwash, Hamdy Hassan, Shinsuke Mori, Ayman Refat Abd Elbar

Journal of Engineering Research

A finite difference model is developed to simulate the thermal behaviour of the PV system with an innovative cooling system. The proposed cooling system combines an aluminium heat spreader (AHS) with phase change material (PCM) placed at the backside of the solar panel. The new non-standard model is solved using MATLAB software and is validated with real experimental data collected under hot climate conditions. The new nonlocal model is found to be more effective in analyzing heat transfer processes throughout the entirety of the PV system compared to conventional PV models. Additionally, the new cooling PV system has been compared …

Lessons Learned From The Covid-19 Pandemic Crisis Management In The Gaza Strip: A Qualitative Study., Belal Aljamal

Journal of the Arab American University مجلة الجامعة العربية الامريكية للبحوث

Aims of the study: The main aim of this study was to discover the lessons learned from the COVID-19 pandemic crisis management from health policymakers' perspective in the Gaza Strip. Methods: The researcher used a qualitative design, targeting 25health policymakers using a purposeful sampling technique and face-to-face semi-structured interviews to collect data. To analyze the interview data, the directed qualitative content analysis approach was used.

Results: All interviewees agreed that the Palestinian Ministry of Health (MoH) managed the COVID-19pandemic well despite the insufficient resources and lack of experience. More specifically, the average of most participants’ assessments of Palestinian MoH “Preparedness” …

The Degree Of The Possession Of Designing, Managing And Practicing Electronic Courses Competencies By Faculty Members At The Palestinian Universities, Ashraf Al Hennawi

Journal of the Arab American University مجلة الجامعة العربية الامريكية للبحوث

The current study aimed to reveal the degree of the possession of designing, managing and practicing electronic courses competencies by faculty members at the Palestinian universities. The researcher prepared a questionnaire to measure the degree of the possession of those competencies, and achieve the objectives of the study. The researcher followed the descriptive approach to describe the phenomenon under study. The study was applied to a sample of 388 randomly selected faculty members in three Palestinian universities (Al-Aqsa - Khadoori - Islamic). The results of the degree of the possession of designing and managing electronic courses competencies by faculty members …

The Impact Of Cultural Procedures On Peaceful Coexistence In The State Of Qatar In Light Of Goals Of Qatari Immigration For The Alliance Of Civilization, Hind Alhammadi

Journal of the Arab American University مجلة الجامعة العربية الامريكية للبحوث

In terms of the Global Peace Index (IEP), Qatar has been highly ranked globally and regionally. Hence, it was necessary to study the experience of Qatar's population diversity and peaceful coexistence. The finding of this study would have a positive impact on decreasing the global media attacks on Muslims, and contribute to protecting Muslim minorities from persecution in some other countries of the world. The aim of this case study was to focus on the immigration to Qatar by providing some clarifications about the procedures in the cultural field, which were inspired by the principles of the Islamic Sharia and …

Conquer And Prevail Issue 179 January 9 2025, Wofford College. Office Of Marketing And Communications

Conquer and Prevail Newsletter

No abstract provided.

Mosaicos De La Comunidad (Mosaics Of The Community): Community-Engaged Participatory Muraling With Madres Emprendedoras, Jesica S. Fernandez, Laura A. Nichols

Ethnic Studies

In this paper, we describe a collaborative community-based research project that centered on community members’ lived experiences, which led to the identification of key community issues that resulted in a representative art project in the form of a public mural. Eleven mothers who were long-time residents of the community were the drivers of the issue identification and mural creation. The issues identified, and subsequently depicted in the mural, revealed the importance of the environment in neighborhoods, with residents dealing with encampments, illegal dumping, prostitution, eviction, and gentrification. In the mural Mosaicos de la Comunidad (Mosaics of the Community), a group …

As 333-001 Leading People & Effective Com., John Phinney

Aerospace Studies Syllabi

No abstract provided.

Species Differences In The Biotransformation Of Aflatoxin B1: Primary Determinants Of Relative Carcinogenic Potency In Different Animal Species, David L. Eaton, David E. Williams, Roger A. Coulombe

Animal, Dairy, and Veterinary Science Faculty Publications

It has been known since the early days of the discovery of aflatoxin B1 (AFB1) that there were large species differences in susceptibility to AFB1. It was also evident early on that AFB1 itself was not toxic but required bioactivation to a reactive form. Over the past 60 years there have been thousands of studies to delineate the role of ~10 specific biotransformation pathways of AFB1, both phase I (oxidation, reduction) and phase II (hydrolysis, conjugation, secondary oxidations, and reductions of phase I metabolites). This review provides a historical context and substantive analysis of each of these pathways as contributors …