Digital Commons Network^™

Tax Arbitration And The Rule Of Law: A Challenge For The Coordination Of International Taxation, Gianluigi Bizioli, Frederico Bertocchi

Akron Law Review

Tax arbitration mechanisms, which are provided both at the international and EU level, play a significant role in solving international tax disputes. However, such mechanisms do not seem to be fully compliant with the concept of Rule of Law that seems to arise from International and EU Laws. In fact, tax arbitration mechanisms appear to lack —mainly— certain due process guarantees that allow such procedures to comply with the equality principle.

More specifically, tax arbitration involves almost only the States, which are the party to it, allowing them to exercise relevant powers and influence —for instance— over the arbitration body …

The Foundations Of International Taxation: Knocked From Post To Pillars, Yariv Brauner

Akron Law Review

After a century of convergence and consolidation, the international tax regime is at a crossroads. A recent program promoted by the OECD, known as the two pillars program, departs in many ways from long standing norms of the regime. But the OECD and many states insist that the foundations of the regime have not changed, portraying the two pillars as a negotiated, pragmatic compromise that responds mainly to the challenges that the digital economy presented to the old rules. This article rejects this portrayal, arguing that the program is far from being a balanced or a truly negotiated compromise between …

Reforming The Foreign Tax Credit, Subpart F, And Gilti In Light Of Pillar Two, Andrew Duxbury, Jonathan D. Grossberg, Genevieve Tokic

Akron Law Review

The foreign tax credit has been a cornerstone of the United States international tax system since as early as 1919. However, there have been a number of recent developments in the international tax landscape that warrant a significant revision to the foreign tax credit rules as they apply to controlled foreign corporations (“CFCs”). In particular, the current global tax deal known as the OECD/G20 Inclusive Framework, Pillars One and Two, may cause the United States to lose significant tax revenue if changes are not made to international tax rules, including the foreign tax credit. Thus far, the United States has …

The Status Of Fluoridation

West Michigan District Dental Society Bulletin

The future of community water fluoridation is uncertain amid legal action and federal leadership changes. Fluoridation is still recommended by the federal government, with new research following those recommendations affirming previous findings of safety and efficacy, however dentists remain central to public education and advocacy. A link to updated resources from the MDA is included.

Wmdds Bulletin Spring 2025

West Michigan District Dental Society Bulletin

In the Spring 2025 issue, the reader will find the following feature articles:

• Advocacy Avenue: "The Status of Fluoridation"
• "WMDDS at the MDA Annual Session"
• "The Shrinking Stack: A Shift Toward Digital in Dental Publications"
• A NEW and highly requested section, Clinical Corner! Each Bulletin will feature 2-4 pearls of clinical wisdom from local dentists and specialists.

Also included are your monthly tripartite update, news from West Michigan counties, the President's Message and Editor's Letter.

A Drop In The Ocean: A Critical Look At Belonging And Community In Carceral Setting, Jelena Petrovic, Jacob Bickel, Jonathan Cantero, Romano Estrada, Malcolm J. Thrower, Gregory White

Feminist Pedagogy

In this commentary, we explore the opportunities and challenges of community building within our own higher education in prison program. Since 2015, the program fostered a community grounded in feminist pedagogy, emphasizing interconnectedness and decentralization of power. However, our 2024 evaluation revealed that new students often feel excluded and marginalized, highlighting the aspirational nature of the community. With this in mind, we examine how incarcerated individuals become members of a learning community and the unique struggles they face. We also discuss the importance of creating classroom communities that support students' sense of belonging, particularly in carceral settings, while also reflecting …

Beyond Deep Listening With The ‘Feminist Ear’: Introducing The Full-Circle Model Of Listening And Expressing, Alana M. Nicastro, Shelly Valdez

Feminist Pedagogy

Feminist pedagogy calls for more than presence and voice—it asks us to listen deeply and express courageously. This article introduces the Full-Circle Model of Listening and Expressing, a framework that extends the concept of deep listening by pairing it with intentional expression. Building on previous work on deep listening (Nicastro & Valdez, 2022), we articulate six essential components of feminist communication: openness, attunement, integration (for listening), and self-reflection, courage, and intentional dialogue (for expressing). These interconnected practices foster genuine connection, challenge hierarchies, and make visible the often-unseen emotional labor of communication. Using the metaphor of a circle, we explore how …

Teaching #Metoo And #Blacklivesmatter Amid The Anti-Woke Moral Panic, Stephanie Medden

Feminist Pedagogy

The introduction of over 100 anti-DEI bills across 30 states and President Trump’s signing of executive orders that target DEI programs demonstrate the backlash against the social, cultural, and political gains made by movements such as #MeToo and #BlackLivesMatter. “Anti-woke" sentiment presents challenges for educators preparing students to engage critically with certain histories, movements, and theories. This article explains current debates around what it means to be “woke”; provides strategies to teach about inequality across race, gender, class, and sexuality in this polarized environment; and imagines futures that uphold the ideals of diversity, equity, and inclusion.

Balancing Care And Challenge: Integrating Trauma-Informed Learning And Desirable Difficulty, Cerise L. Glenn, Katie Lind, Jessica D. Mccall

Feminist Pedagogy

Amid changing landscapes of campus culture (e.g., new technologies, increasing accommodations requests, program reviews), we utilize pedagogical strategies to expand feminist frontiers in ways that re-energize and promote an inclusive culture of feminist pedagogy. By implementing “desirable difficulty,” we seek collaborative learning environments that address the changing needs of students and teachers while fostering learning effectiveness. Combining aspects of trauma-informed learning with desirable difficulty helps balance these demands with a culture of care, created through approaches designed to promote learning opportunities and meet student needs without overwhelming faculty.

Feminist Participatory Action Research And Service-Learning In The New Feminist Frontier, Megan A. Fletcher

Feminist Pedagogy

This critical commentary explores the tensions of embodying feminist pedagogy as both researcher and teacher. Drawing on the success of Feminist Participatory Action Research (FPAR) in redesigning women's shelter intake procedures, I argue for integrating service-learning into the classroom. However, the effectiveness of both PAR and service-learning hinges on a strong foundation in feminist methodologies that prioritize equity, justice, and community care (Bowdon, Pigg, & Mansfield, 2014; Johnson & Flynn, 2021; Vergés Bosch, Freude, & Camps Calvet, 2021). Acknowledging past critiques of these approaches when lacking a feminist lens (Langhout & Gordon, 2021), I call for researchers and teachers to …

Making Space For Our Own Rhythms, Lauren Mark Dr.

Feminist Pedagogy

This original teaching activity invites students to investigate dominant influences on enacted daily rhythms to arrive at a clearer understanding of their own rhythms and those around them. Students are guided to somatically sense habitual rhythms and understand how habits of accent collectively form to hold us together. Through a two-part activity, involving large group interaction and paired observation, students explore degrees of releasing or withholding natural rhythmic impulses through concession to or freedom within group rhythms and when navigating online platforms. The aim is to explore desired emotional arcs of how experiences might unfold.

Creating And Re-Energizing Communities Of Meaning Throughout A Course, Nancy A. Heise, Anum Ahmed

Feminist Pedagogy

We propose a feminist course approach wherein instructors build what Amie Macdonald (2002) called "communities of meaning" in their classrooms (p.120). Through an intentional focus on supporting students' 1) individual identities, 2) holistic well-being, and 3) epistemic "buy-in" to classroom content, students will connect more deeply not only to themselves and their classmates, but also to the course material. We suggest four community-building touchpoints as a starting point for instructors looking to integrate this course approach. We start with an activity to lessen awkwardness around first-day name pronunciation. We emphasize the importance of creating collaborative classroom expectations with students, and …

Persuasion And Critical Art Analysis: A New Approach To Student-Led Collaboration In A Communication Classroom, Melissa Cheng, Emma Mink

Feminist Pedagogy

No abstract provided.

Choose Your Own Reading Assignment: A Strategy To Diversify Perspectives In Class Discussion, Breena J. Brockmann

Feminist Pedagogy

This activity reimagines course reading assignments by offering students a choice between multiple texts that work together to explore a shared theory or theme. Students are invited to select readings that align with their interests or learning goals. This activity embraces the feminist pedagogical principle of collaborative learning and uses the active learning strategy of learning through teaching by asking students to work in groups to create mini lessons that teach their classmates about their selected reading. Through their discussion of multiple case studies, the class develops an understanding of feminist theory as “geographically, historically, and culturally grounded (Mohanty, 2003, …

The Existential Nature Of Touch Exchange For Blind People As A Bridge To Confidence And Participation In Physical Activities. A Qualitative Preparatory Study Using Reflexive Thematic Analysis, Mathias Alberton

International Symposium of Adapted Physical Activity and International Symposium on Physical Activity and Visual Impairment and Deafblindness

Title of the submission

The existential nature of touch exchange for blind people as a bridge to confidence and participation in physical activities. A qualitative preparatory study using Reflexive Thematic Analysis.

Introduction

Lack of full proprioception in visually impaired and blind people (VI) negatively affects their lifestyle and, in combination with structural and societal barriers, lead to low participation in physical activities (Alcaraz-Rodríguez et al., 2021; Lieberman et al., 2018), deemed to build confidence and social interaction with further benefit to their phycological well-being (Elsman et al., 2018; Ilhan et al., 2020). Being confident in touching and being touched by …

Review: The Storyteller's Candle, Rachel Schwedt

Ages 7-9

Cooperation, Diversity, Ethnic pride, Inspiration, Thoughtfulness

Review: Radio Rescue, Rachel Schwedt

Ages 7-9

Caring, Citizenship, Cooperation, Compassion, Courage, Curiosity, Dedication, Determination, Diligence, Friendship, Inquisitiveness, Knowledge, Neighborliness, Resourcefulness, Responsibility, Work ethic

Review: One Thousand Tracings: Healing The Wounds Of World War Ii, Rachel Schwedt

Ages 7-9

Caring, Compassion, Empathy, Generosity, Giving, Initiative, Sacrifice, Sharing, Unselfishness

Review: Mr. Waynes Masterpiece, Rachel Schwedt

Ages 7-9

Courage, Confidence, Encouragement, Fearlessness, Inspiration,

Review: Whittington, Rachel Schwedt, Janice Delong

Ages 10-12

Caring, Community, Compassion, Cooperation, Coping, Courage, Determination, Empathy, Encouragement, Faithfulness, Fear, Family loyalty, Friendship, Hope, Inspiration, Manners, Obedience, Persistence, Pride, Resolve, Respect, Self-control, Understanding, Work ethic

Review: We Are America, Rachel Schwedt, Janice Delong

Ages 10-12

Citizenship, Courage, Endurance, Ethnic pride, Hope, Inspiration, Leadership, Perseverance, Pride, Resolve, Sacrifice, Self-respect, Survival, Work ethic

Review: The King's Swift Rider: A Novel On Janice The Bruce, Janice Delong, Rachel Schwedt

Ages 10-12

Ambition, Boldness, Citizenship, Cleverness, Cooperation, Courage, Cunning, Dedication, Dependability, Determination Dignity, Discipline, Duty, Fairness, Faithfulness, Fearlessness, Hope, Ingenuity, Initiative, Inspiration, Inventiveness, Leadership, Loyalty, Obedience, Passion, Patriotism, Perseverance, Pride, Resolve, Respect, Responsibility, Sacrifice, Steadfastness, Strength, Survival (Physical), Trustworthiness

Review: The Heart Of A Chief, Janice Delong, Janice Delong

Ages 10-12

Appreciation of nature, Citizenship, Community, Compassion, Cooperation, Coping, Courage, Dependability, Devotion, Diligence, Duty, Encouragement, Enthusiasm, Ethnic pride, Family love, Friendship, Honesty, Hope, Individuality, Initiative, Inventiveness, Joyfulness, Knowledge, Leadership, Loyalty, Manners, Passion, Pride, Resolve, Respect, Responsibility, Self-respect, Sharing, Spunk, Steadfastness, Wisdom, Work ethic

Review: Stickteen: John Muir And The Brave Little Dog, Janice Delong, Rachel Schwedt

Ages 10-12

Confidence, Cooperation, Courage, Determination, Diligence, Encouragement, Endurance, Enthusiasm, Fear, Fearlessness, Friendship, Hope, Intuition, Joyfulness, Knowledge, Obedience, Passion, Perseverance, Resolve, Respect, Responsibility, Spunk, Survival (Physical), Trust, Wonder, Work ethic

Review: Schomburg: The Man Who Built A Library, Rachel Schwedt, Janice Delong

Ages 10-12

Ambition, Boldness, Courage, Dedication, Diligence, Diversity, Ethnic pride, Generosity, Initiative, Knowledge, Leadership, Passion, Persistence, Pride, Resolve, Respect, Sacrifice,

Review: Rules, Janice Delong, Rachel Schwedt

Ages 10-12

Caring, Compassion, Dependability, Duty, Encouragement, Friendship, Giving, Hope, Humor, Individuality, Initiative, Inspiration, Kindness, Maturity, Patience, Persistence, Self-reliance, Survival (emotional), Thoughtfulness, Trust, Trustworthiness, Wisdom

Review: Rules Of The Road, Janice Delong, Rachel Schwedt

Ages 10-12

Competition, Confidence, Cooperation, Coping, Courage, Dedication, Dependability, Determination, Devotion, Dignity, Discernment, Duty, Encouragement, Faithfulness, Generosity, Gratitude, Greed, Honesty, Hope, Ingenuity, Initiative, Inspiration, Knowledge, Leadership, Love, Loyalty, Manners, Maturity, Obedience, Passion, Patience, Pride, Resilience, Respect, Responsibility, Selflessness, Spunk, Steadfastness, Survival (Emotional), Trustworthiness

Review: Rimshots: Basketball Pix, Rolls, And Rhythms, Janice Delong, Rachel Schwedt

Ages 10-12

Confidence, Competition, Cooperation, Craftsmanship, Determination, Discipline, Diversity, Encouragement, Endurance, Enthusiasm, Friendship, Hope, Humility, Humor, Initiative, Passion, Patience, Persistence, Pride, Resilience, Self-respect, Sharing, Work ethic

Review: Project Mulberry, Janice Delong, Rachel Schwedt

Ages 10-12

Appreciation of Nature, Competitiveness, Cooperation, Coping, Creativity, Curiosity, Dependability, Determination, Devotion, Diligence, Diversity, Enthusiasm, Forgiveness, Friendship, Ingenuity, Initiative, Neighborliness, Obedience, Patience, Respect, Responsibility, Sharing, Trust, Work ethic

Review: Prarie Lotus, Rachel Schwedt, Janice Delong

Ages 10-12

Coping, Courage, Dependability, Determination, Diligence, Ethnic pride, Fairness, Fearlessness, Hope, Passion, Perseverance, Resourcefulness, Self-acceptance, Spunk, Tolerance, Trustworthiness, Unselfishness, Wisdom, Work ethic