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 …

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.

Light Field Sensitive Polarization Detectors

Defensive Publications Series

Embodiments of light field sensitive polarization detectors are described herein. Prior methods for measuring the 3D profile of an object utilize the polarization properties of detected light, captured by intensity-only, RGB, or polarization-sensitive cameras. However, these methods require knowledge or assumptions of several parameters, including the polarization state of the scene illumination light, the spatial distribution of light sources, and the object's material properties. While existing techniques can provide a certain level of accuracy, they are limited by the need for additional information about the scene or light field properties to enhance the precision of reconstructions.

An Integrated Geophysical Approach For Estimating The Depth Of Mineral Potential In Some Part Of Basement Complex Terrain Southwestern Nigeria, Hamid Titilope Oladunjoye, Joseph Coker, Niyi-Ola Adebisi, Omolara Abosede Adenuga, Sofiat Adetomilola Adekoya, Aderemi Alabi, Abisola Akinmoladun

Al-Bahir

Effective mineral exploration in a basement complex necessitates precise delineation of overburden thickness and mineral potential within the Basement Complex terrain. This study examined the subsurface geology and assesses the abundance of prospective mineral deposits within the study area The objective of the study was to outline the overburden thickness and infer mineral potential using integrated ground magnetic and electrical resistivity geophysical methods. The electrical resistivity method unraveled the litho-stratigraphic sequence as surmised from geo-electric layers. Consequently, the mineralization of the basement delineated was characterized by the magnetic method. The acquired data were processed using WINRESIST and Oasis Montaj respectively. …

Hydrochemical Assessment And Geospatial Analysis Of Borehole Water Quality In Effurun, Delta State, Nigeria, Ojo Odunayo Tope, Ike Joy Chiaka, Austin Emeka Okoli, Namdie Joseph Inyang

Al-Bahir

Borehole water is a primary drinking water source in Effurun, Delta State, Nigeria, making its quality a critical public health concern. Contaminants such as major ions and trace metals can affect water safety, necessitating comprehensive assessment. This study evaluates the hydrochemical characteristics of borehole water, identifies contamination sources, and assesses compliance with World Health Organization (WHO) and Nigerian Standard for Drinking Water Quality (NSDWQ) guidelines. The study aims to determine the spatial distribution of major ions and trace metals in borehole water, assess water quality variations, and identify contamination patterns due to natural and anthropogenic influences. Water samples were collected …

Unpacking White Language Supremacy In The Acrl Framework For Information Literacy For Higher Education, Anders Tobiason

Library Faculty Publications and Presentations

This article explores how the ACRL’s Framework for Information Literacy for Higher Education codes the idealized information literate individual as White. It illuminates how White language supremacy is used in the Framework to code the idealized information literate individual as White. By articulating the use of White language supremacy in the Framework, this article suggests how to begin the process of deconstructing this White ideal and thus transforming the Framework from a tool of colonization and oppression into something that steps toward liberation.

Voting And Civic Engagement Among Utah Women: A 2025 Update, Corinne Clarkson, Susan R. Madsen, Kolene Anderson

Marketing and Strategy Faculty Publications

In 2016, the Utah Women & Leadership Project (UWLP) released a research snapshot called “Voting and Civic Engagement Among Utah Women.”¹ At the time, despite having a strong history of women’s political and civic involvement, Utah had fallen to the bottom of national rankings in terms of women’s political participation.² In 2019 and 2021, UWLP released updates of this report, which showed some improvement in voter participation rates for both the United States (US) and for Utah women. Since 2016, the level of political participation among women in Utah and the US has grown, and civic engagement—a critical …

Science Communication Through Cool Critters: An Informal Learning Experience For Youth, Jamila L. Bajelan, Mary J. Harner

Transactions of the Nebraska Academy of Sciences and Affiliated Societies

There are numerous ways to communicate science and assess the effectiveness of that communication. One approach focuses on increasing awareness, enjoyment, interest, opinion, and/or understanding of science. For this study, we created an informal learning experience for youth to communicate the science of animals in Nebraska. We developed Cool Critters, a weeklong summer camp for elementary school-aged students, to increase participants' enjoyment, interest, and opinion of Nebraska animals. In 2023, Cool Critters was led in three educational settings in central Nebraska and reached sixty-six participants. Surveys were used to determine the camp's success in effective science communication and whether …

Exploring The Interplay Between Kidney Dysfunction And Cardiovascular Disease, Rajesh Yadav, Aqsa Kaim Abubakar, Richa Mishra, Saurabh Gupta, Neelesh Kumar Maurya, Vivek Kashyap, Sarvesh Rustagi, Deependra Pratap Singh, Sanjay Kumar

School of Medicine Publications

This article reveals the various types of complications that are associated with dialysis and kidney-associated disease, including left ventricular hypertrophy, heart failure, vascular heart disease, arrhythmias, diabetes mellitus, intradialytic hypertension, and coronary heart disease. The molecular mechanisms underlying the development of cardiovascular disease in patients with chronic kidney disease (CKD), including the role of nitric oxide (NO) signaling, have been extensively studied. Patients suffering from CKD need treatment with hemodialysis at the end stages. The kidney is considered the chief excretory organ in humans, which excretes various types of waste materials from the body and balances the acid–base ratio, due …

2025 Legislative Update, J. David Aiken

Cornhusker Economics

The 2025 Nebraska state Unicameral dealt with major state budget challenges but also managed to enact four bills affecting Nebraska agriculture and holding three other bills over for possible action in the 2026 legislative session. Enacted legislation dealt with a ban on laboratory-grown meat, the merger of state natural resource and environmental agencies, amending the 2024 paid sick leave initiative, and establishing a School Financing Review Commission. Agricultural-related bills carried over to the 2026 legislative session include modifying cattle feedlot brand inspection fees, inheritance tax reductions, and modifying the 2022 minimum wage initiative.

Parameters Summer 2025, Usawc Press

The US Army War College Quarterly: Parameters

Welcome to the Summer 2025 issue of Parameters. This issue consists of an In Focus special commentary, three forums (Indo-Pacific Challenges, Russia-Ukraine Issues, and Historical Studies).

What The Russia-Ukraine Conflict Tells Us About Educational Resilience, Jason Jabbari

The US Army War College Quarterly: Parameters

Education, which can operate as a source of vulnerability or resiliency across multiple domains before, during, and after armed conflicts, is often only examined within a single domain, limiting the use and effectiveness of civil-affairs operations. This article outlines a novel conceptual framework of the primary mechanisms across seven unique domains by which education can serve as a key area of resiliency or vulnerability. A case study of Russia’s invasion of Ukraine illustrates how vulnerabilities can manifest in the seven domains and what military planners can do to build resiliency. The article concludes with a discussion of the costs, benefits, …

A More Perfect Peace: Can The Russia-Ukraine War End Justly?, Nathaniel B. Davis, Marlon A. Thomas

The US Army War College Quarterly: Parameters

This article argues that thinking creatively about war termination, both philosophically and politically, utilizing jus post bellum principles and counterintuitive political trade-offs, reveals an opportunity to achieve a sustainable peace that approximates justice. The article surveys how war aims among belligerents have changed, indicating that further change is possible, particularly at the point of war termination. Next, the article examines jus post bellum principles and their application to the Russia-Ukraine War. Finally, the article contends that Ukraine relinquishing Crimea and the Donbas in exchange for NATO membership might be the key to achieving a durable peace that addresses long-term security.

Book Reviews, Usawc Press

The US Army War College Quarterly: Parameters

No abstract provided.

Martha Stringer V. County Of Bucks

2025 Decisions

USDC for the Eastern District of Pennsylvania

Kyon Mcdonald V. Attorney General United States Of America

2025 Decisions

Agency

John Seitz, Iv V. East Nottingham Township

2025 Decisions

USDC for the Eastern District of Pennsylvania

William Webb, Jr. V. Gdwg Law Firm

2025 Decisions

USDC for the District of Delaware

Kenneth Crandall V. Denis Mcdonough

2025 Decisions

USDC for the Eastern District of Pennsylvania

Munjal V. Ziebke

All Decisions

A landlord's holdover petition was dismissed because it failed to properly plead the Good Cause Eviction Law (GCEL) status of the premises. The landlord attempted to amend the petition to claim a "small landlord" exemption, but the proposed amendment was deemed conclusory and lacked specific details required by RPAPL § 741(5-b) and RPL § 214(1), such as the names of all owners, the number of units they own statewide, and their addresses (excluding principal residences). The court held that proper pleading of the GCEL exemption is an essential element of a landlord's prima facie case.

Potential Of Blood-Based Assays To Enhance The Diagnosis, Risk Stratification And Monitoring Of Multiple Myeloma Patients, Aisling O Brien

Theses

Multiple Myeloma (MM) remains an incurable haematological malignancy; however, continuous advancements in treatment strategies have significantly improved patient survival. There is now a pressing need for enhanced detection methods to ensure optimal patient outcomes. This includes rapid diagnosis, early detection of relapses, and identification of high-risk patients. Diagnosis: For optimal patient results, initiating early MM diagnosis at the primary care level is essential. Delays in diagnosis can result from nonspecific presenting symptoms such as anaemia and bone pain. A retrospective observational study identified calculated globulin as a promising clinical biomarker to indicate MM in primary care. Subsequent implementation of calculated …

Practicality Of Implementing Sub-Clause 8.4 [Advance Warning] Of The Fidic 2017 Red Book In Egypt, Gehad Ibrahim

Theses and Dissertations

Disputes in construction projects can cause cost and time overruns that can be detrimental to the parties involved and to the project. Several measures have been advocated by the industry’s practitioners in an attempt to avoid disputes and their adverse impacts. One of these measures is the introduction of advance warning sub-clauses in construction contracts, where the contracting parties play a proactive and collaborative role in warning each other of potential adverse impacts to the project. Such clauses have been in the NEC suite of standard construction contracts for decades and have recently found their way to the 2017 edition …

The Impact Of Currency Depreciation On Egyptian Exports: A Firm-Level Study, Noor Elghorab

Theses and Dissertations

This study investigates the impact of real exchange rate depreciations of the Egyptian Pound on the intensive and extensive margins of firm-level exports in the years 2008, 2013, 2016, and 2020 using a comprehensive dataset of over 7,000 firms from the World Bank Enterprise Survey. Employing a firm-level fixed effects model, the study finds that real depreciation boosts export performance by 5.7 percentage points and 6.2 percentage points at the intensive and extensive margins respectively. Results also indicate a positive relationship between firm exports and firm size, foreign ownership, and firms with greater reliance on imports in their inputs. Additionally, …

The Communal Lyric: Poetry In Devotional And Oppressed Communities, Michael N. Yacoub

Theses and Dissertations

This thesis investigates the interaction between lyric and community; it asks what a communal lyric is, how it functions, and to what ends. In Chapter One, I compare Jonathan Culler’s performative model of lyric with the theory of Takhyīl as expounded by Arab philosopher-critics al-Farabi, Ibn Sina, and al-Qartajanni to argue that a communal lyric is a form of audience-oriented public discourse distinguished by formal features that prompt the poem’s (re-)iteration and establish an interpersonal relationship with the audience in order to influence them and make shareable value claims about the world. In Chapters Two and Three I provide close-reading …

Paradise Lost Thrice: Exile And The Abrahamic Religions In Aciman, Werfel, And Ashour, Malak K. Hosny

Theses and Dissertations

Exile is an integral part of the history of all three Abrahamic religions: Judaism, Christianity and Islam. This thesis compares between literary narratives of the exile of Jews, Christians, and Muslims. It explores the notion that having been exiled from Eden with the fall of Adam and Eve, and having each religion’s prophet’s story intrinsically tied with exile, the believers’ exile is then the third in a layered cycle of exile. Having lost the paradise, believers tend to search for earthly paradises that they attach themselves to, and then tragically lose those as well. The thesis’ three primary literary texts …

Implications Of The Mind’S Active Participation In The Formation Of Perception, Maikel Adel Samy Michael

Theses and Dissertations

The mind-body problem, particularly the issue of qualia, remains a fundamental challenge in understanding the nature of the mind and its relation to the body. In this thesis I argue that the problem is epistemic, stemming from how we perceive and know ourselves as physical and mental beings. This argument will be explored through the respective of idealisms proposed by George Berkeley and Immanuel Kant. Berkeley's idealism suggests that reality is rooted in perception, offering a major steppingstone by demonstrating the major role perception plays in understanding and acquiring knowledge. Kant contributes by asserting that the "thing-in-itself" is beyond our …

Stuck In The Maze: Syrian Unaccompanied Children Navigating Spheres Of Protection In Egypt, Anouk Pelletier De Chambure

Theses and Dissertations

This research explores the protection of Syrian unaccompanied and separated children (UASC) in Egypt who have fled the Syrian conflict and reflects on the role of formal protection providers and informal networks of solidarity. In hopes of pushing back against the over- essentialization of UASC as vulnerable children, this research unravels the lived experiences of seven aged-out Syrian UASCs who have been living in Egypt for a few years, which reveals their authentic and original crafting of spheres of protection. This thesis aims to contribute to a more extensive and more accurate understanding of the lives and needs of Syrian …

A Tragedy Of Incommensurability: Indigenous Rights And The Limits Of Human Rights Law, Zeina Ali

Theses and Dissertations

This thesis explores the tragedy of incommensurability between indigenous rights and international human rights law. Despite the emergence of frameworks like the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), indigenous calls for sovereignty remain fundamentally unintelligible within a liberal order structured to preserve settler-state legitimacy. Tracing the historical and theoretical evolution of indigenous advocacy, this study critiques the strategic shift from demands for self-determination to claims of cultural rights. It argues that this shift offers no real alternative: self-determination and cultural rights are functionally equivalent, as both are ultimately filtered through legal and political frameworks that cannot …