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Articles 61201 - 61230 of 5205129
Full-Text Articles in Entire DC Network
Hyssop, Joshua Williams
Report On The Harding University Research Conference, Caden W. Haustein
Report On The Harding University Research Conference, Caden W. Haustein
Ex Sapientia Loqui
A report on the history of Harding Undergraduate Research Conference (HURC), an interdisciplinary undergraduate research conference sponsored by the Harding Honors College and the Arkansas Eta chapter of Alpha Chi
Report On The Honors College, Bryce Phillips
Report On The Honors College, Bryce Phillips
Ex Sapientia Loqui
A report on the 2026 state of the Harding University Honors College.
Report On Alpha Chi, Camille Bewley
Report On Alpha Chi, Camille Bewley
Ex Sapientia Loqui
A report on the state in 2026 of the Arkansas Eta Chapter of Alpha Chi.
Editor's Note, Caden W. Haustein
Back Matter, Julie E Harris
Front Matter, Julie Harris
Full Issue, Clara Kernodle
Are Nonprofit Tax Exemptions And Deductions "Federal Financial Assistance"? Should They Be?, Lloyd Hitoshi Mayer
Are Nonprofit Tax Exemptions And Deductions "Federal Financial Assistance"? Should They Be?, Lloyd Hitoshi Mayer
Florida Tax Review
Two recent federal court decisions have reignited the debate over whether “Federal financial assistance” as used in four federal anti-discrimination statutes includes the tax benefits enjoyed by most nonprofit organizations. Both courts concluded that it does. While an appellate court reversed one decision, and the other case settled without appellate review, these holdings create significant uncertainty. And this uncertainty affects the more than 1.8 million tax-exempt nonprofits, many if not most of which do not receive federal financial assistance through other channels and so could safely conclude these statutes do not reach them, absent these decisions. This uncertainty is also …
Redemption! Valuing Closely Held Companies After Connelly, Adam Chodorow
Redemption! Valuing Closely Held Companies After Connelly, Adam Chodorow
Florida Tax Review
In Connelly v. United States, the Supreme Court resolved a long-standing dispute over how to treat redemption obligations when valuing a decedent’s shares in a closely held company. The Court held that redemption obligations do not offset corporate-owned life insurance proceeds obtained to fund a redemption, upsetting a long-standing practice. While the Court undoubtedly reached the right conclusion, it (1) failed to address important arguments the parties and amici raised; (2) assumed away the effects of discounts, premiums and different valuation techniques, which would have complicated the analysis without changing the conclusion; and (3) muddied the water somewhat by …
State Tax Discrimination And Internal Consistency, Michael T. Fatale
State Tax Discrimination And Internal Consistency, Michael T. Fatale
Florida Tax Review
The contours of the U.S. Supreme Court’s dormant Commerce Clause doctrine of internal consistency, which asks whether a state tax intrinsically overreaches in imposing a burden upon interstate commerce, are difficult to understand. This is despite the fact that a determination that a state tax violates internal consistency can have significant state fiscal consequences. This uncertainty was suggested again by the recent case, Zilka v. Tax Review Board City of Philadelphia, for which the Supreme Court later denied certiorari. See 304 A.3d 1153 (Pa. 2023), cert. denied, 145 S. Ct. 1045 (2025).
The parameters of the internal consistency …
The Mother Of All Tax Shelters, Michael Doran
The Mother Of All Tax Shelters, Michael Doran
Florida Tax Review
By its own account, the federal government spends more than $500 billion every year to subsidize retirement savings in 401(k) plans, IRAs and similar arrangements. That figure is larger than the annual budget of every government agency other than the four largest. The theory behind this massive subsidy is that it gives workers at all income levels an incentive to save money that they would otherwise spend, thereby enhancing retirement security, reducing old-age poverty and easing dependence on Social Security. But the theory is wrong. The retirement tax subsidy is anything but egalitarian. Less than five percent of the subsidy …
The Chilling Effect Of Sffa V. Unc/Harvard On Race-Based Affirmation By Tax-Exempt Charities, David A. Brennen
The Chilling Effect Of Sffa V. Unc/Harvard On Race-Based Affirmation By Tax-Exempt Charities, David A. Brennen
Florida Tax Review
Recently, the Supreme Court decided in SFFA v. Harvard/UNC that colleges are restricted in their use of race-based affirmative action in admissions. Post-SFFA, many have incorrectly suggested that this means that race may never be considered in admissions. This Article asserts that this expansive view of SFFA is incorrect and leads to a chilling effect on affirmative action by colleges. However, instead of simply asserting that SFFA permits some considerations of race in admissions, the Article goes further by arguing that SFFA does not even apply to admissions by some private colleges. For instance, private colleges that are …
Taxing Royalties Where Value Is Created: Is A Redraft Of The Oecd Model Tax Convention Necessary?, Valentina Emanuele
Taxing Royalties Where Value Is Created: Is A Redraft Of The Oecd Model Tax Convention Necessary?, Valentina Emanuele
Florida Tax Review
This Article examines whether Article 12 of the OECD Model Tax Convention should be redrafted to tax royalties where value is created in an increasingly IP-driven and digitalized economy. It traces the historical evolution and current structure of royalty provisions in the OECD, U.N. and U.S. Model Conventions, highlighting inconsistencies between formal source rules and the underlying economics of royalty income. Building on an economic concept of value creation, the Article argues that royalties are best understood as active, business-related income generated through research and development, IP protection and market exploitation across multiple jurisdictions. It then proposes a reallocation of …
Pillar Two: Much Ado About Next To Nothing?, Julie A. Roin
Pillar Two: Much Ado About Next To Nothing?, Julie A. Roin
Florida Tax Review
The OECD has spent the last fifteen years working on the design and implementation of rules for the taxation of income derived from international transactions, rules that are supposed to both increase corporate tax revenues and minimize “destructive” tax competition. Pillar Two, the second part of the two-part “Inclusive Framework,” was released in July of 2021. It is designed to force countries to impose a minimum tax on income derived by large multinational enterprises. Pillar Two–compliant taxes have been enacted by most of the countries in the European Union, Japan, South Korea and other economically important countries, but not by …
Time Value Of Money (One More Time), Daniel Halperin
Time Value Of Money (One More Time), Daniel Halperin
Florida Tax Review
Nearly 40 years ago I wrote Interest in Disguise: Taxing the Time Value of Money. The article showed that if the party’s marginal tax rate is constant, since the present value of the amount included or deducted may not change, deferral (or acceleration) of income or expense does not necessarily affect the tax impact. However, there seems to be surprisingly little recognition of the widespread impact of the insight that the timing of income and deductions may not affect value.
There are several academic proposals suggesting that recognition of present value equivalence can improve understanding of the impact of …
The Short-Term Water Quality Impacts Of The College Lake Low-Head Dam Removal, Lorraine L. Upton
The Short-Term Water Quality Impacts Of The College Lake Low-Head Dam Removal, Lorraine L. Upton
Student Scholar Showcase
Dam removal in the United States has become a common practice for stream restoration and community safety. Studies have shown removals to restore an ecosystem to its natural flow, but in urban environments, dams can serve as a retention basin that helps to mitigate increased amounts of stormwater and high pollution loads from increased percentages of impervious surfaces. A central Virginia watershed located in an urbanized community recently experienced a low-head dam removal and its conversion to a constructed wetland. This study assesses the short-term impacts of the dam removal through water quality sampling based on its chemical, biota, and …
Electrostatic Doping Of Graphene For Tunable Diodes, Andrew Bales
Electrostatic Doping Of Graphene For Tunable Diodes, Andrew Bales
Linfield University Student Symposium: A Celebration of Scholarship and Creative Achievement
In this work, devices were fabricated to explore the limits of electrostatically doped graphene diodes utilizing hexagonal boron nitride as an insulating layer. Initial tests confirmed the graphene’s responsiveness to gate voltages and demonstrated the viability of electrostatic doping through a thin insulating layer. Degradation of the graphene during testing resulted in a lack of measurable shifts in the completed devices.
Normal Matrices, Fuzhen Zhang
Normal Matrices, Fuzhen Zhang
Mathematics Colloquium Series
Normal matrices form a central class in matrix analysis, including Hermitian, skew-Hermitian, and unitary, positive semidefinite, permutation matrices and so on. This presentation surveys fundamental properties of normal matrices, including spectral characterization, unitary diagonalization, and trace (in)equality through majorization. It highlights equivalent conditions for normality, with discussions extending to matrix exponentials and polynomials. Examples and counterexamples are provided to clarify certain subtle points about matrix normality. The talk is based on a recent paper published in JMC (joint work with Y.-J. Hu)
Storage-Aware Shuffle Planner (Sasp): A Storage-Constrained Shuffle Optimisation Layer For Distributed Computation Engines, Ananya Verma, Raouf Khan
Storage-Aware Shuffle Planner (Sasp): A Storage-Constrained Shuffle Optimisation Layer For Distributed Computation Engines, Ananya Verma, Raouf Khan
Defensive Publications Series
The present disclosure relates to the field of distributed data processing, in particular to storage-aware adaptive shuffle planning (SASP) for shuffle optimisation in distributed computation engines. SASP provides a storage-aware planning layer that restructures shuffle execution based on actual storage capacity. The system collects object-store telemetry, including bandwidth, IOPS, latency, throttling, and concurrency, to construct a storage pressure vector for each prefix. Concurrently, expected shuffle partition sizes are analysed from execution plans. Based on these inputs, SASP forecasts partition-level strain and generates a Shuffle Prefix Mapping Table (SPMT) to assign partitions to output prefixes, ensuring balanced I/O load. A plan …
Trusted Distribution And Authentication Of Ai Agent Artifacts, Niranjan M M
Trusted Distribution And Authentication Of Ai Agent Artifacts, Niranjan M M
Defensive Publications Series
AI-driven systems increasingly rely on externally developed AI agent artifacts, such as agents, tools, plugins, and services, that are distributed through registries or marketplaces and executed within enterprise environments. While existing registries enable discovery and existing runtime security systems focus on detecting malicious behavior during execution, there is no mechanism to ensure that such artifacts are authentic, legitimately published, and governed across their lifecycle before execution.
The proposal introduces systems and methods for trusted distribution and authentication of AI agent artifacts, establishing a pre-execution trust framework that enables consuming systems to verify publisher identity, artifact authenticity, provenance, and lifecycle state …
An Improved Process For The Preparation Of Solid Dispersion Of (N4-(4-([1,2,4]Triazolo[1,5-A]Pyridin-7-Yloxy)-3Methylphenyl)-N6-(4,4-Dimethyl-4,5-Dihydrooxazol-2-Yl)Quinazoline-4,6-Diamine With Co-Povidone, Msn Laboratories Private Limited, R&D Center; Srinivasan Thirumalai Rajan; Subrahmanyavithal Irukuvajjula; Saimanoj Kesari; Bhatraju Daveedu
An Improved Process For The Preparation Of Solid Dispersion Of (N4-(4-([1,2,4]Triazolo[1,5-A]Pyridin-7-Yloxy)-3Methylphenyl)-N6-(4,4-Dimethyl-4,5-Dihydrooxazol-2-Yl)Quinazoline-4,6-Diamine With Co-Povidone, Msn Laboratories Private Limited, R&D Center; Srinivasan Thirumalai Rajan; Subrahmanyavithal Irukuvajjula; Saimanoj Kesari; Bhatraju Daveedu
Defensive Publications Series
The present invention provides an improved process for the preparation of solid dispersion of (N4-(4-([1,2,4]triazolo[1,5-a]pyridin-7-yloxy)-3methylphenyl)-N6-(4,4-dimethyl-4,5-dihydrooxazol -2-yl)quinazoline-4,6-diamine with Co-povidone
Relationship-Validated Unified Payments Interface (Upi) Reverse Payment Safety System For Fraud Prevention, Alok Roy
Defensive Publications Series
The present disclosure relates to a system and method for relationship‑validated fraud prevention in digital payment reversal transactions. The system may be configured to monitor incoming transactions to a user account. Based on monitoring, the system may be configured to detect a user initiation of an outgoing payment following receipt of an incoming payment. Thereafter, the system may be configured to determine whether a payer and payee associated with the payment have an established transaction history and further evaluates timing between the incoming payment and the outgoing payment. The system may be then configured to compare an outgoing transaction amount …
Proactive Automation For Xdevice Layout And Information Retrieval, Rachel Burrows, Karen Vertierra, Daniel Adam, Grant Ashley Rowles, Matthew David Sienzant, Shama Laxmikant Toshniwal, Katie Jean Van Loo, Ricardo Bittencourt Alves Da Luz, Anders Johan Prag
Proactive Automation For Xdevice Layout And Information Retrieval, Rachel Burrows, Karen Vertierra, Daniel Adam, Grant Ashley Rowles, Matthew David Sienzant, Shama Laxmikant Toshniwal, Katie Jean Van Loo, Ricardo Bittencourt Alves Da Luz, Anders Johan Prag
Defensive Publications Series
This document describes a smart system that automatically sets up a user's digital workspace, proactively launching and arranging apps on one or more screens—such as smartphones, tablets, laptops, or multi-monitor computer setups—before the user manually does so. The system detects a trigger, signal, or clue, such as a scheduled calendar event, a geographic location, or daily routines and habits, to anticipate what task the user is about to start. Using artificial intelligence (AI) and machine learning to predict user intent, the system identifies the available hardware (e.g., knowing if the user is commuting on a train with just a mobile …
Dynamic Watch Complications, Sumukh A. Shevde, Kamran Mustafa, Abhijit Adsule
Dynamic Watch Complications, Sumukh A. Shevde, Kamran Mustafa, Abhijit Adsule
Defensive Publications Series
This document describes a system in which a smart watch—also referred to as a wearable device, fitness tracker, or digital timepiece—displays different configurations of watch faces, widgets, app shortcuts, or complications, depending on different contexts. The system utilizes a context engine to monitor real-time data from sensors and system applications, such as temporal data, spatial data, schedule data, and activity data, to determine a user’s current situation and predict the user’s desired screen layout. The system uses a strict set of rules to resolve any conflicting information to ensure predictable and relevant information delivery. Based on the user’s current context …
Preventing Spurious Bfd Faults On Remote Nodes During Make-Before-Break Updates On Local Nodes, Anonymous
Preventing Spurious Bfd Faults On Remote Nodes During Make-Before-Break Updates On Local Nodes, Anonymous
Defensive Publications Series
The present disclosure relates to a mechanism for preventing spurious Bidirectional Forwarding Detection (BFD) faults during make-before-break (MBB) updates in a segment-routing traffic-engineering (SR-TE) network (10). A first node (12-1), operating as a head-end router, is configured to perform a label-stack update for a first SR-TE candidate path while maintaining continuity of BFD monitoring. Prior to the update, the first node (12-1) disables a local BFD detection timer and transmits a first BFD control packet that omits a reverse-path Binding Segment Identifier (BSID). The packet includes a diagnostic field instructing a peer node (12-6) to disable its BFD detection timer. …
Topological Phase Matrix Computing With Hyper-Spatial Extensions: Integer 12-Vector Lattice With Dynamic Small-World Connectivity (Moution Extension), Olexandr Lozovyi
Topological Phase Matrix Computing With Hyper-Spatial Extensions: Integer 12-Vector Lattice With Dynamic Small-World Connectivity (Moution Extension), Olexandr Lozovyi
Defensive Publications Series
We present a deterministic spatial computing architecture extending integer-based phase lattices (VOC AI / MOUTION frameworks) with dynamically evolving non-local connections. The system operates on a 12-vector isotropic neighborhood approximating a face-centered cubic (FCC) topology in 2D projection. By introducing bounded virtual links, the lattice forms an emergent small-world network enabling rapid global information propagation (insight generation) while preserving strictly O(1) per-node complexity. The model is fully integer-based, requires no floating-point arithmetic, and deterministically converges to metastable attractors. This work establishes prior art for bounded-degree hyper-spatial phase computation, dynamic plasticity, and M-layered multiplexed topologies.
System And Method For Dynamic, On-Demand Pedestrian Corridor Management In A Connected Vehicle Environment, Sumukh A. Shevde, Abhijit Adsule, Kamran Mustafa
System And Method For Dynamic, On-Demand Pedestrian Corridor Management In A Connected Vehicle Environment, Sumukh A. Shevde, Abhijit Adsule, Kamran Mustafa
Defensive Publications Series
This document describes a dynamic, on-demand pedestrian corridor management system in a connected vehicle environment. This management system receives pedestrian crossing requests from personal devices (often referred to as user equipment (UE), wearable assistive technology, or a pedestrian V2X node), such as smartphones, smartwatches, and extended reality glasses. In response to a pedestrian crossing request, the management system analyzes real-time traffic data from connected vehicles to calculate a coordinated slowdown of the connected vehicles. This coordinated slowdown creates a safe gap for a pedestrian to cross a roadway without forcing vehicles to a complete stop. The intersection manager can monitor …
Automatedly Assemblable Roll-Cage For Formula Racecars, Triggered By Artificial Intelligence (Ai), Anonymous
Automatedly Assemblable Roll-Cage For Formula Racecars, Triggered By Artificial Intelligence (Ai), Anonymous
Defensive Publications Series
Here, it is disclosed the roll cage of an active / automated safety system for the protection of Formula racecar drivers. It consists of a multiple times deployable and retractable titanium or other metal roll cage comprised by two semi-roll cages at each side, that rotate from an undeployed position to a deployed position to assemble said roll cage. When undeployed, each semi-roll cage at each side is concealed inside the corresponding sidepod of the racecar (See Figures 1 to 4). This active safety system can be deployed as a preventive safety measure or deployed to provide protection in an …
Low Latency Wake Up Of Wearable Devices, Nazih Almalki, Sumukh A. Shevde
Low Latency Wake Up Of Wearable Devices, Nazih Almalki, Sumukh A. Shevde
Defensive Publications Series
This disclosure describes techniques for improving the responsiveness of wearable devices, such as smartwatches, by predicting when a user is about to interact with the device. Often, wearable devices use a low-power co-processor to show a basic watch face while the main application processor is asleep to save battery. However, waiting for a physical touch or button press to wake the main processor can cause a noticeable and frustrating delay. The described techniques use sensors like accelerometers and gyroscopes to define an interaction zone, which is a specific physical position where the device is likely visible to the user's eye. …