Digital Commons Network^™

An Overview Concerning Certain Recent Changes For Foreign Compensatory Trusts: 402(B)Trusts, Grantor Trusts And "Rabbi" Trusts, Steven W. Rabitz

Florida Tax Review

This article seeks to describe some of the salient practical and policy issues confronting the foreign deferred compensatory trust world in light of the recent changes to the Code and the more recently issued proposed regulations. Part II first outlines some of the basic U.S. federal income tax considerations involved in trust-structured foreign deferred compensatory arrangements. Part II describes the conditions necessary for grantor trust treatment as well as the tax consequences associated with section402(b) secular trust arrangements. Part II further discusses the recent changes in law refining the boundary between domestic and foreign trusts. Part III highlights "inbound" foreign …

Tax Consequences Of Assigning Life Insurance—Time For Another Look, Douglas A. Kahn, Lawrence W. Waggoner

Florida Tax Review

The Taxpayer Relief Act of 1997 furnishes the courts and the Internal Revenue Service an opportunity to close certain loopholes in the federal tax consequences of assigning life insurance. About twenty years ago, we published an article arguing that the tax consequences of assigning life insurance affords taxpayers unwarranted opportunities for tax avoidance. Since then, developments in the case law and Internal Revenue Service rulings have broadened the loopholes. In this update of our article, we show how the new tax law supports our original position.

Our position is that the Silverman analysis gives taxpayers a windfall and provides life …

Taxation Of Private Business Firms: Imagining A Future Without Subchapter K, Lawrence Lokken

Florida Tax Review

Congress should radically reshuffle the respective jurisdictions of subchapters K, S, and C. Form of organization should no longer play any role in an entity's tax classification. Subchapter K should only remain available to service entities for which capital is not a material income-producing factor. The more restrictive conduit regime of subchapter S should be opened to all private business fins with simple capital structures and should be revised to incorporate as much of the flexibility of subchapter K as is possible without making it unreasonably susceptible to abuse. All firms with more complex ownership structures should be subject to …

Taxation Of Electronic Commerce: Federal Income Tax Issues In The Establishment Of A Software Operation In A Tax Haven, David R. Tillinghast

Florida Tax Review

The advent of the Internet and other electronic means of conducting commercial transactions has created a new galaxy of ways to structure business operations and a concomitant range of novel tax issues. It is commonly said that, because of the diminished need for a vendor to have a physical presence in the country of the customer, one of the likely effects of electronic commerce will be to shift revenues away from source jurisdictions and towards residence jurisdictions. In fact, this may be only partially true. Income may be shifted away from the customers' countries all right, but into a tax …

The Future Taxation Of Private Business Firms, George K. Yin

Florida Tax Review

Recent federal and state law developments liberalizing the permissible forms of business organizations and the classification of such organizations for tax purposes have underscored the need to reexamine the current system of taxing the income of private businesses. This article, which undertakes that reexamination, makes two principal claims. First, current law ought to be replaced by a system whereby all private business firms, no matter what their form of organization and organizational characteristics, are taxed as conduits for income tax purposes. Second, because conduit taxation is so complicated, the system should be implemented through a "two-track" approach in which a …

International Comity And The Foreign Tax Credit: Crediting Nonconforming Taxes, Glenn E. Coven

Florida Tax Review

This article examines the workings and derivation of four specific and related features of the foreign tax credit: (1) The rules defining "the tax" for which a credit may be claimed; (2) The rules governing the extent to which the use of proxies for computed income destroys the classification of a tax as an "income" tax; (3) The rules limiting the ability to credit alternative or minimum taxes imposed in connection with an income tax; and (4) The rules governing the extent to which such nonconforming provisions of foreign law may be treated as a creditable tax "in lieu" of …

The Constitutionality Of Taxing Compensatory Damages For Mental Distress When There Was No Accompanying Physical Injury, Douglas A. Kahn

Florida Tax Review

Since 1919, statutory tax law has excluded from gross income compensatory damages received on account of a personal injury or sickness. The current version of that exclusion is set forth in section 104(a)(2) of the Internal Revenue Code of 1986. The construction of that exclusion, both by the courts and by the Commissioner, underwent significant alterations over the 80-year period that the provision has existed. The statute itself was amended several times, most recently in 1996. It is the 1996 amendment that has raised a constitutional issue concerning the validity of a portion of the statute.

As a consequence of …

Winner-Take-All Markets: Easing The Case For Progressive Taxation, Martin J. Mcmahon Jr., Alice G. Abreu

Florida Tax Review

With this Article we begin the process of exploring the ways in which winner-take-all markets can alter perceptions about the appropriate distribution of the tax burden. This is neither a soak-the-rich polemic nor a plea for rejection of the tools of traditional economic analysis. It is an attempt to apply economic analysis to markets that produce unique incentives and that have resulted in a dramatically skewed distribution of income. Winner-take-all markets are probably here to stay, so it behooves us to study them and to consider their operation when crafting tax policy.

In Part II of this Article we analyze …

Verso

Bryant University Undergraduate Journal

No abstract provided.

Drawing Down On The Value Of A Non-Fungible Token (Nft) And Its Associated Asset Via Sale Or Transfer On The Blockchain To Fund And Or Provide Credit Collateral On A Purchase, Samuel James Oliver

Defensive Publications Series

The present disclosure relates to a method and system for drawing down on an NFT’s value to fund a purchase in real-time. The method comprises transmitting a purchase request to an NFT Application Programming Interface (API) 108 hosted on a payment server seeking an authorization to purchase goods/services using the value of the NFT. In response to the purchase request, the NFT API 108 holding the NFT may transfer, via sale on the blockchain the NFT’s ownership to the merchant to settle and approve the transaction. Alternatively, the NFT API 108 may sell a portion of the NFT to the …

Reconnaissance: Relationship Between Social Presence And Knowledge Construction In Second Life, Leah A. Hardesty

Organization, Information and Learning Sciences ETDs

This qualitative research study explored levels of social presence in Second Life (virtual world) associated with phases of knowledge construction. The study explored images and data collected from users at two discussion-based activities. The findings revealed the three levels of social presence, according to the Interactional Process Model of Social Presence developed by Schultze and Brooks. Social presence established a sense of mutual monitoring of users that increased users’ sense of presence. This made their virtual interactions more real. Various phases of knowledge construction were observed as specified in the Interaction Analysis Model developed by Gunawardena, Lowe and Anderson. Knowledge …

The Fierce Green Fire: Vol. 13 Issue 17, Wofford College. Department Of Environmental Studies

The Fierce Green Fire

No abstract provided.

May 12th Letter From Chuck To Glennis

0455: Brigadier General Chuck Yeager Collection, 1923-1987

May 12th (with no listed year) letter from Chuck to Glennis in which he describes his activities on a new base, along with monetary discussions.

May 13th Letter From Chuck To Glennis From Korea, Chuck Yeager

0455: Brigadier General Chuck Yeager Collection, 1923-1987

May 12th letter from Chuck to Glennis in which they discuss properties and day-to-day life. Letter is from Seoul, Korea.

Utilizing Interprofessional Collaboration To Assist Clients And Communities With Disaster Relief, Baylen D. Bellamy

Social Work Masters Capstone Projects

Hello and thank you for reading my capstone project, which focuses on utilizing interprofessional collaboration to assist clients and communities with disaster relief. My practicum placement was at a crisis center in the next town over. I shadowed and assisted staff with working with clients and the community. A natural disaster had occurred while I was at my practicum placement. Near the end of July in 2022 a massively, devastating flood had hit South Eastern KY and several surrounding counties. The flood happen so sudden people hardly had any warning. People’s homes, vehicles, animals, and personal belongings were washed away. …

Medical School Watercooler Newsletter - May 12, 2023, Lindsey Lyle

Watercooler Newsletter

This is the May 12, 2023 edition of the Frederick P. Whiddon College of Medicine's newsletter - Watercooler.

Contents include:

• Pathology resident wins at tri-state conference
• Five medical students named to foreign languages honor society
• USA student-Run free clinic receives donation from local medical society alliance
• Join us for medical alumni reunion weekend June 8-10
• Faculty present at the southern neurosurgical society annual meeting
• Resident and fellow academic Expo set for May 24

Interprofessional Collaboration For Addiction Intervention In A Community College Setting, Cathi Smith

Social Work Masters Capstone Projects

Substance abuse has become a major problem in our nation. It is no surprise that a great percentage of people have admitted that prior to their arrest they had either been drinking or using illicit drugs. When they commit these illegal acts, they then begin to cycle through the criminal justice system. It is also not obvious whether they have an AUD or SUD or that they are chemically dependent. In fact, some of them at this stage will still be in denial that there is even a problem, especially if the offense is something that does not come with …

Utilizing An Evidence-Based Treatment Program For Offenders With Mental Health Disorders To Demonstrate Interprofessional Social Work Practice, Erica Kessinger, Ann Callahan

Social Work Masters Capstone Projects

Sixty-four percent of jail offenders, 54% of state prisoners, and 45% of federal prisoners have a mental illness (Taylor, 2022). Mental illness increases the risk of recidivism. Individuals with mental illness have limited access to appropriate treatment. They are more likely to respond negatively to the prison environment. This can lead to infractions and solitary confinement. In addition, 51% of incarcerated individuals, whether they received mental health treatment or not, are likely to experience recidivism (Pflueger et al., 2015). The practice of interprofessional social work inside the American prison system is desperately needed. The following paper proposes an evidence-based treatment …

Utilizing Interprofessional Collaboration In An Opioid Addiction Treatment Center, Lindsey K. Centers

Social Work Masters Capstone Projects

This paper examines the practicum placement I've held for the duration of this semester. This paper discusses Behavioral Health Group's Level 1 outpatient substance abuse clinic. Behavioral Health Group is located in Richmond, Kentucky's rural Madison County. BHG Richmond offers Methadone, Suboxone, and Vivitrol Medication-Assisted Treatment. This paper explores the function of the social worker as a counselor and member of an interdisciplinary team. This paper examines the ethical models and skills that social workers can use to promote an effective treatment experience for patients who present to BHG Richmond, as well as the close monitoring from the beginning to …

Construction Underway This Summer At Taylor, Taylor University

2023 Website News Stories

No abstract provided.

The Genome, Genetic Genealogy Database (3g Database), Salma Obaid Alotaibi

Online Theses and Dissertations

This is a qualitative research paper that used the content analysis method. Thirty-one sources which include journal articles, credible websites, and books were used to discuss the importance of having national and global genetic databases. DNA phenotyping is the technology used in criminal justice to identify crime suspects through observable traits in their DNA. This can play a key role in convicting the right crime perpetrators and avoiding future court appeals. It also helps during disaster recovery, where the victims are identified based on their DNA samples. Law enforcement agencies frequently use DNA to identify victims and solve high-profile cases …

Post-Racism As Ideology: Character Construction And Placement, & Narrative Structure In Dear White People, Mphatso Kaufulu

Dissertations

My project looks at post-racism as ideology. Through my chosen text – the Netflix streamed television series called Dear White People – I examine the ways in which post-racism is persists through representational abstractions which reformulate race as largely sets of interpersonal and intercultural, person-to-person social problems rather that a more general condition rooted in institutional or structural social, political and economic arrangements which organize society and produce its cultural dispensation.

To do this, I applied some of Stuart Hall’s ideas – on identity, ideology and commodification – and Bonilla-Silva – specifically in the area of obfuscations or abstractions of …

Commencement [Program], May 12-13, 2023, University Of Northern Iowa

UNI Commencement Programs

The program of the commencement ceremonies, including a list of institutional leadership, a list of the departments by college, awards given at the ceremonies, and a list of undergraduate and graduate degree candidates. This commencement program is not an official graduate list.

What Is The Effect Of Differentiated Instruction On Student Engagement In Learning?, Charlotte Lester

Doctor of Education in Teacher Leadership Dissertations

WHAT IS THE EFFECT OF DIFFERENTIATED INSTRUCTION ON STUDENT ENGAGEMENT IN LEARNING? The purpose of this research was to determine the effect of differentiated instruction on student engagement in learning. This mixed method study inspected the effectiveness of assigning different learning strategies to students according to their academic ability. One class received different assignments that addressed student’s specific learning needs while the other class received common assignments. Attendance, achievement, and behavior data were also collected from this study to determine the overall effectiveness of differentiated instruction. This study was conducted in a middle school located in Georgia. Both classes were …

A New Museum Experience: Survival And Best Practices, Sophia Holmes

Art 895 Research Papers

This study researches how museums adapt to changing technologies as well as opportunities to retain their audience and visitors while finding new best practices to help in their survival as an institution. It examines how different museums in the United States predict the trajectory of their museum will continue forwards through the different offerings they provide. This study explores how technology and social media, modern exhibitions and initiatives, community outreach and campaigns, and more contribute to the museums’ continuation in the current industry landscape. I examine these ideas through interviewing art museum educators at institutions around the US, examining the …

Sex Trafficking In Southern Nevada, Julianna Jovillar

Student Research

Southern Nevada is facing a sex trafficking epidemic that continues to impact people in the state. Thus, in this brief, I investigate Southern Nevada’s sex trafficking crisis. Based on recent sex trafficking studies and the current legislature, it is apparent that although Southern Nevada is aware of the problem, more can still be done to stop it. As a result, this policy work explores sex trafficking in Southern Nevada, addresses stigmatization as a causal factor, provides political context, and offers policy recommendations related to child victim aid and protection to be considered for legislation.

Digital Updates, Yemisi Dina

Librarian Publications & Presentations

A presentation on recent updates in digital scholarship at Osgoode Hall Law School.

Designing The Power System Of A Robot, Nolan Hays

Honors College Theses

This thesis outlines the acquired skills and knowledge acquired through the course of four years of Murray State University’s School of Engineering. The capstone for students in the department was to team up and complete an interdisciplinary senior design project using skills from various tracks of engineering. For this thesis, there is a greater emphasis on the electrical engineering track. The objective of the project was to build an autonomous robot to complete the various tasks within the scope of the IEEE SoutheastCon 2023 Hardware Competition. The robot was controlled via a Raspberry Pi 4 Model B. There were three …

Integrated Neutrosophic Best-Worst Method For Comprehensive Analysis And Ranking Of Flood Risks: A Case Study Approach From Aswan, Egypt, Safa Al-Saeed, Nabil M. Abdelaziz

Neutrosophic Systems with Applications

This paper presents a comprehensive framework for the analysis and ranking of flood risks with respect to regional variations and data uncertainties under a Neutrosophic environment. The research introduces a novel approach to flood risk mitigation and management, bringing together the scientifically robust Best-Worst Method (BWM) and single-valued Neutrosophic set for the first time. The unique application of a single-valued Neutrosophic set allows us to better illustrate and manage uncertainty, imprecision, and vagueness in data. Additionally, we employ BWM, a multi-factor decision-making method, for discerning and ranking the most influential flood risk factors. Together, the integrated methodologies provide a balanced, …

Let’S Talk: How Communication Apprehension And Intercultural Communication Affect Intercultural Conflicts And International Relations, Jessica P. Overbay

Honors Theses

Communication apprehension or anxiety can cause strains on conversations and relationships. This is prevalent in intercultural communication because it can cause intercultural conflicts and strains on international relations. Communication plays such a large role in international relations, however, communicating interculturally can pose barriers. Different cultures communicate differently and when trying to communicate with those outside one’s own culture, complications can arise. This apprehension in turn can lead to intercultural conflict. Difficulties communicating interculturally such as language barriers, differences in cultures norms (nonverbal misinterpretation), and preconceptions can lead to communication apprehension, and even intercultural conflict. This research aimed to examine how …