The Great ETF Tax Swindle: The Taxation of In-Kind Redemptions

Since the repeal of the General Utilities doctrine over 30 years ago, corporations must recognize gain when distributing appreciated property to their shareholders. Regulated investment companies (RICs), which generally must be organized as domestic corporations, are exempt from this rule when distributing property in kind to a redeeming shareholder. In-kind redemptions, while rare for mutual funds, are a fundamental feature of exchange-traded funds (ETFs). Because fund managers decide which securities to distribute, they distribute assets with unrealized gains and thereby significantly reduce the future tax burdens of their current and future shareholders. Many ETFs have morphed into investment vehicles that offer better after-tax returns than IRAs funded with after-tax contributions. Furthermore, this rule is now being turbocharged. Some mutual fund families have created ETF classes of shares for some of their mutual funds, which permits the ETF shareholders to remove the gains attributable to the shareholders of the regular share class. Another firm acts as a strategic investor to assist mutual funds in eliminating their unrealized gains through contributions and redemptions. These transactions permit current and future fund shareholders to inappropriately defer tax on their economic gains and give ETFs and other mutual funds with ETF share classes a significant tax advantage over other investment vehicles. This article considers various options that tax policymakers should consider to eliminate the ETF tax subsidy including explicitly extending this favorable tax treatment to all RICs by exempting fund-level gains from tax, repealing the exemption rule, limiting the amount of unrealized gains a fund can distribute, requiring ETFs to reduce the basis of their remaining property by the unrecognized gain of distributed property, or requiring ETFs to be taxed as partnerships

Understanding Cognition Across Modalities for the Assessment of Digital Resources

Drawing from the theories of the cognitive process, this paper explores the transmission, retention and transformation of information across oral, written, and digital modes of communication and how these concepts can be used to examine the assessment of digital resource tools. The exploration of interactions across modes of communication is used to gain an understanding of the interaction between the student, digital resource and teacher. Cognitive theory is considered as a basis for the assessment of digital resource tools. Lastly, principles for the assessment of digital resource tools are presented along with how assessment can be incorporated in the educational practice to enhance learning in higher education

ESL Student Perceptions of Online Resources

This study explores how ESL student perceptions guide their use of online resources, with the goal of helping teachers select meaningful resources. Data were collected using a combination of interview responses and computer-recorded online actions. An evaluation of three case studies of advanced adult English language learners were used to gain insights into student perceptions. The results indicated that the ESL students use Google and native language sites when researching online, at times alternating between English and their native language. However, they expressed a sense of shame when using native language sites, as one student stated that he felt he should know things (i.e. English) that he does not and it would be unfair for him to use an online translator or other native language resources in his chemistry class

Citizen Journalist to Activist: the Language Behind Black Lives Matter

This study explores the discourse surrounding an event in the social movement, Black Lives Matter, to gain insights into how digital literacy practices influence and mediate participation in the 21st century civil rights movement for a new generation of activist. This study examines three points of engagement, (1) the experience of the event as it is initially interpreted and shared online, (2) the intermingling of consciousness through social media, and (3) the post social media interpretation and action. Data was collected from Twitter analyzed using discourse analysis

Calculation of the thermodynamic properties of a mixture of gases as a function of temperature and pressure

The evaluation of the thermodynamic properties of a gas mixture can be performed using a generalized correlation which makes use of the second virial coefficient. This coefficient is based on statistical mechanics and is a function of temperature and composition, but not of pressure. The method provides results accurate to within 3 percent for gases which are nonpolar or only slightly polar. When applied to highly polar gases, errors of 5 to 10 percent may result. For gases which associate, even larger errors are possible. The sequences of calculations can be routinely programmed for a digital computer. The thermodynamic properties of a mixture of neon, argon and ethane were calculated by such a program. The result will be used for the design of the gas replenishment system for the Energetic Gamma Ray Experiment Telescope

Diabetes alone should not be a reason for withholding adjuvant chemotherapy for stage III colon cancer

Background: With increasing prevalence of diabetes mellitus and colon cancer, the number of patients suffering from both diseases is growing, and physicians are being faced with complicated treatment decisions. Objective: To investigate the association between diabetes and treatment/course of stage III colon cancer and the association between colon cancer and course of diabetes. Materials and Methods: Additional information was collected from the medical records of all patients with both stage III colon cancer and diabetes (n=201) and a random sample of stage III colon cancer patients without diabetes (n=206) in the area of the population-based Eindhoven Cancer Registry (1998–2007). Results: Colon cancer patients without diabetes were more likely to receive adjuvant chemotherapy compared with diabetic colon cancer patients (OR 1.8; 95% CI 1.2–2.7). After adjustment for age, this difference was borderline significant (OR 1.6; 95% CI 1.0–2.6). Diabetic patients did not have: significantly more side-effects from surgery or adjuvant chemotherapy; more recurrence from colon cancer; significantly shorter time interval until recurrence; or a poorer disease-free survival or overall survival. Age and withholding of adjuvant chemotherapy were most predictive of all-cause mortality. After colon cancer diagnosis, the dose of antiglycaemic medications was increased in 22% of diabetic patients, resulting in significantly lower glycaemic indexes than before colon cancer diagnosis. Conclusions: Since diabetic patients did not have more side-effects of adjuvant chemotherapy, and adjuvant chemotherapy had a positive effect on survival for both patients with and without diabetes, diabetes alone should not be a reason for withholding adjuvant chemotherapy.Journal of Comorbidity 2011;1(1):19–2