Digital Commons Network^™

Seismic Shifts And Stair Steps: Revisions To The Creditability Determination In The Foreign Tax Credit Rules, Rebecca Rosenberg

Loyola of Los Angeles Law Review

There has been a seismic shift in the regulatory rules for determining which foreign taxes are eligible to be credited against a taxpayer’s U.S. federal income tax. This Article explains why these regulatory changes have such a big impact, including some non-obvious, indirect results. First, the creditability determination is the necessary first step for claiming a foreign tax credit. Second, even a small disparity between a foreign tax and the section 901 creditability regulations can now make the entire foreign tax non-creditable, even for taxpayers who are not subject to the nonconforming portion of the foreign tax. Third, the section …

25 Conference Program - Micro-Nano Plastics In Water: Characterization, Cure And Prevention, David Hunkeler, Nicholas Clesceri, Albert Gray, Franco Berruti

Micro-Nano Plastics in Water: Characterization, Cure and Prevention

David Hunkeler has written eleven books, including Water: Resource-Stewardship-Treatment, please click the link below to see the full book.

https://dc.engconfintl.org/cgi/viewcontent.cgi?article=1000&context=microplastics

Please click Additional Files below to see the video

Courts And Social Justice, Shai Dothan

Loyola of Los Angeles Law Review

Many scholars have argued that courts are either harmful or useless when it comes to improving social justice in society. There are three main reasons offered in support of this argument: (1) Courts are elitist institutions that support the high social class of the judges at the expense of the rest of society, (2) the structure of litigation is geared towards harming the rights of people with modest economic means, (3) even when courts try to impose a higher standard of social justice, they are not able to initiate real social change. The purpose of this paper is to investigate …

The Articularis Genu As A Surrogate For Structural Determinants Of Peri-Articular Myopenia In Osteoarthritis, Davis Martin, José A.Cruz Ayala, Mary C. Gatterer, Tara Soria, Ryan Schroeder, Vinod Dasa, Luis Marrero

School of Medicine Faculty Publications

The functional limitations associated with the painful stiffness of knee osteoarthritis (kOA) can affect the muscles of the knee, such as the quadriceps femoris (QF) and articularis genu (AG). The vastus medialis oblique (VMO) of the QF complex is particularly sensitive to kOA. The AG, which can be sampled during total knee arthroplasty (TKA) for kOA, can provide information about the condition of the QF when affected by patient-reported disuse, helping to identify indicators of muscle weakness in the synovial fluid. This study compares the structural and gene expression changes between the VMO and the AG collected from patients with …

Hacking Generative Ai, Ido Kilovaty

Loyola of Los Angeles Law Review

Generative AI platforms, like ChatGPT, hold great promise in enhancing human creativity, productivity, and efficiency. However, generative AI platforms are prone to manipulation. Specifically, they are susceptible to a new type of attack called “prompt injection.” In prompt injection, attackers carefully craft their input prompt to manipulate AI into generating harmful, dangerous, or illegal content as output. Examples of such outputs include instructions on how to build an improvised bomb, how to make meth, how to hotwire a car, and more. Researchers have also been able to make ChatGPT generate malicious code.

This Article asks a basic question: do prompt …

A Rare Cause Of Severe Bleeding In Neonate: Congenital Afibrogenemia Case Report, Abdul Azeem Hulkoti, Qudsiya Ansari, Kailas Randad, Akash Dnyandeo Sarkate Dr

Digital Journal of Clinical Medicine

Background- Congenital afibrinogenemia is a rare autosomal recessive disorder characterized by the complete absence of fibrinogen, a critical factor for clot formation in the blood. This deficiency leads to significant bleeding tendencies from birth. Patients typically present with severe haemorrhagic symptoms early in the neonatal period.

Case presentation- We describe a case of a neonate presenting with umbilical bleeding diagnosed with congenital afibrinogenemia. Initial clinical manifestations included active umbilical bleeding and pallor, while hematological workup revealed a lack of detectable fibrinogen. The diagnosis was confirmed by coagulation assays and genetic testing. The infant was managed with Fresh Frozen Plasma (FFP) …

Psychopharmacological Therapy Positively Modulates Disease Activity In Inflammatory Bowel Disease: A Systematic Review, Elena Chiera, Gaspare Filippo Ferrajoli, Francesco Pesaresi, Alessio Simonetti, Marianna Mazza, Georgios Demetrios Kotzalidis, Mauro Pettorruso, Giovanni Martinotti, Loris Riccardo Lopetuso, Antonio Gasbarrini, Gabriele Sani, Gionata Fiorino, Franco Scaldaferri, Giovanni Camardese

Faculty, Staff and Students Publications

Depression, anxiety, and perceived stress are common comorbidities in patients with inflammatory bowel disease (IBD) and may negatively influence the disease course. Likewise, severe IBD may contribute to the development or worsening of psychiatric symptoms. Despite the established relevance of the gut-brain axis and frequent use of psychotropic medications in IBD patients, limited evidence exists regarding the effects of psychiatric treatments on gastrointestinal disease activity. Therefore, the aim of this systematic review is to evaluate the effectiveness of psychiatric therapies on gastrointestinal symptoms and disease activity in patients with IBD. The work was conducted in accordance with PRISMA guidelines. Searches …

Machine Learning Prediction Of Urban Heat Island Severity In The Midwestern United States, Ali Mansouri, Abdolmajid Erfani

Michigan Tech Publications

Rapid population growth and urbanization have greatly impacted the environment, causing a sharp rise in city temperatures—a phenomenon known as the Urban Heat Island (UHI) effect. While previous research has extensively examined the influence of land use characteristics on urban heat islands, their impact on community demographics and UHI severity remains unexplored. Moreover, most previous studies have focused on specific locations, resulting in relatively homogeneous environmental data and limiting understanding of variations across different areas. To address this gap, this paper develops ensemble learning models to predict UHI severity based on demographic, meteorological, and land use/land cover factors in Midwestern …

Conflicting Social Information And Its Impact On Sentence Comprehension In Young Adults With Dld: An Eye Tracking Study, Ansley Davis

USF Tampa Graduate Theses and Dissertations

Individuals must recognize linguistic and non-linguistic social cues to resolve contextual ambiguities in their conversations. When the linguistic and social cues match, sentence processing is facilitated. However, conflicts between linguistic and social stimuli (i.e., incongruency) can lead to prediction errors which slow sentence processing. Limited research has explored the social cognition conflict resolution skills in individuals with Developmental Language Disorder (DLD) despite their documented emotion processing deficits. This study considers the role of social prediction processing in adults with DLD as they engage in a social cognition conflict resolution task.

Young adults with DLD (n=29) and typically developing (TD) peers …

Community Health Workers: Key To Decreasing Food Insecurity In Pregnant Individuals, Linda Waggener Dnp

Doctor of Nursing Practice Scholarly Projects

Objectives: Food insecurity (FI) in pregnant individuals (PI)s is a global threat to birthing individuals and fetuses with potential immediate and intergenerational impacts on family and community. Community Health Workers (CHWs) facilitate support including food resources for FIPIs. The Family Fresh Rx (FFRx) program, within Food as Medicine (FaM) model provides fresh fruits and vegetables, optimize nutrition, and mitigates threats to health. This Doctor of Nursing Practice (DNP) Quality Improvement (QI) project’s two objectives were CHWs’ FFRx program and referral process satisfaction evaluation through a pre, post, and four-week post refresher presentation (RP) modified System Usability Scale (mSUS) …

Educating Healthcare Providers To Prevent And Mitigate The Effects Of Zoom Fatigue, Andrea Lima

Doctor of Nursing Practice Scholarly Projects

Zoom Fatigue (ZF), or physical and neuropsychological responses to excessive videoconferencing (VC), increased during the COVID-19 pandemic. Like burnout, ZF can compromise patient safety by causing decreased job satisfaction, social isolation, disrupted focus, and difficulty empathizing with patients. This Plan-Do-Study-Act quality improvement project aimed to assess feelings about VC, raise awareness of the adverse effects of overuse, and empower primary care providers (PCPs) to improve their work experiences. A group of on-site PCPs at a tertiary care medical center in the Southwest, who continued holding exclusive virtual team meetings after the pandemic, was asked to complete the 15-question Zoom Exhaustion …

Speak Now With The Courage To Confront: An Educational Intervention To Address Bullying, Dominique Desiree Gomez

Doctor of Nursing Practice Scholarly Projects

Abstract

Background: Nurse-to-nurse bullying is a critical issue within the nursing profession, impacting close to half of all nurses. This phenomenon, articulated by the phrase "nurses eat their young," detrimentally influences employee retention, job satisfaction, morale, and ultimately, patient care. Furthermore, nurse-to-nurse bullying significantly affects the well-being of nursing professionals, particularly targeting novice nurses. This targeting raises substantial concerns regarding their retention, as many consider leaving the profession within their initial years of practice due to experiences of bullying. The educational intervention project titled “Speak Now with the Courage to Confront” is designed to mitigate bullying among novice nurses through …

Doubly Erased: Lgbtq Literature In Appalachia By Allison Carey, Lis Regula

Critical Humanities

A book review of Allison Carey's Doubly Erased: LGBTQ Literature in Appalachia

Directional Poetics: An Interview With Ed Simon On Pittsburgh, Appalachia, And The Memories Of Geography, Ed Simon, Scott C. Mcdaniel

Critical Humanities

An Interview with Ed Simon

Where The Fog Hangs: An Interview With Elaine Sheldon Mcmillion On Appalachia, Filmmaking, And The Power Of Small Acts, Elaine Mcmillion Sheldon, Scott C. Mcdaniel

Critical Humanities

An Interview with Elaine Sheldon McMillion

Fire In The Hole: Appalachia’S Elemental Narrative In Harlan County, Usa And King Coal, Somak Mukherjee

Critical Humanities

In Elaine McMillion Sheldon’s documentary King Coal (2023) coal is being referred to as a matter that is “not dirty or clean, but elemental.” The acclaimed film centers on the complex histories and cultures of coal in Central Appalachia, based on the perspective of Sheldon, a coal miner’s daughter, and a West Virginia native. The elemental nature of coal is explored in the film by situating coal less as a resource and more as a mythic foundation for the community's cultural history. This article puts King Coal in conversation with Barbara Kopple's seminal Harlan County, USA (1976) which narrates the …

Appalachian Archipelagos: "Writing From Measureless Location” In C.S. Giscombe’S Geopoetics, Jay Butler

Critical Humanities

This essay begins with a speculative gesture: what if we read Appalachia not as a bounded, landlocked region, but as an archipelago—where coherence lies not in contiguity, but in multiplicity and geopoetic drift? Drawing on the poetry of C.S. Giscombe, which spans the Caribbean to Appalachia and unsettles geographic conventions by inhabiting “measureless location” – not as a metaphor but as a method, materially grounded yet elusively meaningful – and guided by R.A. Judy’s Sentient Flesh and its theory and practice of para-semiosis and poiesis-in-black, this essay follows Giscombe’s pragmatic and prismatic geopoetics as it upends dominant frameworks of …

Planetary Thinking: Hellbenders As Emissaries Of Appalachia, Tierra R. Curry

Critical Humanities

Hellbenders are prehistoric salamanders that have thrived in cold rivers since before the continents divided. Once found throughout Appalachian watersheds, due to exploitation and habitat degradation only a few dozen healthy populations survive. Monstrous yet fascinating, hellbenders were often reviled historically, but in recent decades they have gained iconic status and are now celebrated as charismatic indicators for clean rivers. Hellbenders are symbols of the wild because of their ancient history, elusive nature, and contribution to ecosystem resilience. The same forces that drove the decline of these amphibian sentinels have sacrificed public health in Appalachia. Their demise echoes the struggle …

“Here’S To The Long Haul: Dark Green Religion And Planetary Thinking In Appalachian Environmental Movements”, Joseph Witt

Critical Humanities

Environmental humanities scholars have worked to develop alternative frameworks for understanding and relating to Earth’s systems in the hope of reforming the exploitative and extractive practices and attitudes characteristic of the Anthropocene. For example, Dipesh Chakrabarty argued that addressing climate change necessitated appreciating the entanglements between global (human) and planetary (Earth systems) scales. While Chakrabarty noted that ancient and Indigenous cultures may have retained approaches necessary for this work, he was skeptical of the ability of modern secular intellectual traditions focused on global justice perspectives to ultimately facilitate a planetary non-anthropocentric ethic. However, by only briefly engaging with themes of …

Planetary [] Appalachia: Editor’S Introduction, Scott C. Mcdaniel

Critical Humanities

Editor's Introduction to Volume 4 Issue 1

Irs Viewpoint: Erisa Plan Amendments Under Encep, S. Allen Winborne

Tax Adviser

No abstract provided.

Tax Clinic, Kevin Hennessey

Tax Adviser

No abstract provided.

Foreign Investment In U.S, Real Estate—A New Set Of Rules, Neal W. Zimmerman

Tax Adviser

No abstract provided.

The Tax Adviser, Volume 12, Number 5, May 1981, American Institute Of Certified Public Accountants

Tax Adviser

No abstract provided.

Washington Report: Aicpa Suggestions For Improvement Of Social Security System, Kenneth F. Thomas, Janice M. Johnson, American Institute Of Certified Public Accountants

Tax Adviser

No abstract provided.

Tax Clinic, Stuart R. Josephs

Tax Adviser

No abstract provided.

Estate Planning: Significant Recent Developments Concerning Estate Planning (Part Ii) Part, Byrle M. Abbin, David K. Carlson

Tax Adviser

No abstract provided.

The Tax Adviser, Volume 12, Number 4, April 1981, American Institute Of Certified Public Accountants

Tax Adviser

No abstract provided.

Subject Index, 12 Months Ended March 1981, American Institute Of Certified Public Accountants

Tax Adviser

No abstract provided.

Author Index, 12 Months Ended March 1981, American Institute Of Certified Public Accountants

Tax Adviser

No abstract provided.