Time to Start Over on Deferred Compensation

Government regulators would do well to follow simple heuristics like that. Writing good regulations-- good in the sense of promoting the public interest--always presents challenges. Regulators must hit a small but important target where private conduct is brought within appropriate government control, but unnecessary compliance burdens and other deadweight costs are minimized. Even if they see the government\u27s objectives clearly, regulators often have only a limited understanding of the underlying private activities. Moreover, regulators may be unaware of how their rules disrupt or distort those activities in socially harmful ways. Regulators occasionally hit the target exactly. More often, they miss--though not by an intolerably wide margin (good enough for government work, as the saying goes). However, sometimes regulators miss the mark so badly that the only responsible next step is to acknowledge the failure. That is the case with the final regulations under Internal Revenue Code (Code) section 409A. Those regulations are irreparably flawed--so flawed that the best members of the practicing bar cannot make sense of them for basic transactions. When the government issues rules that even experts cannot understand, the government should start over

Concurrent object-oriented programming: The MP-Eiffel approach

This article evaluates several possible approaches for integrating concurrency into object-oriented programming languages, presenting afterwards, a new language named MP-Eiffel. MP-Eiffel was designed attempting to include all the essential properties of both concurrent and object-oriented programming with simplicity and safety. A special care was taken to achieve the orthogonality of all the language mechanisms, allowing their joint use without unsafe side-effects (such as inheritance anomalies)

Applied Type System: An Approach to Practical Programming with Theorem-Proving

The framework Pure Type System (PTS) offers a simple and general approach to designing and formalizing type systems. However, in the presence of dependent types, there often exist certain acute problems that make it difficult for PTS to directly accommodate many common realistic programming features such as general recursion, recursive types, effects (e.g., exceptions, references, input/output), etc. In this paper, Applied Type System (ATS) is presented as a framework for designing and formalizing type systems in support of practical programming with advanced types (including dependent types). In particular, it is demonstrated that ATS can readily accommodate a paradigm referred to as programming with theorem-proving (PwTP) in which programs and proofs are constructed in a syntactically intertwined manner, yielding a practical approach to internalizing constraint-solving needed during type-checking. The key salient feature of ATS lies in a complete separation between statics, where types are formed and reasoned about, and dynamics, where programs are constructed and evaluated. With this separation, it is no longer possible for a program to occur in a type as is otherwise allowed in PTS. The paper contains not only a formal development of ATS but also some examples taken from ats-lang.org, a programming language with a type system rooted in ATS, in support of employing ATS as a framework to formulate advanced type systems for practical programming

Developing a Framework for Sensible Regulation: Lessons from OSHA's Proposed Ergonomics Rule

Injuries caused by workplace activities that involve repetitive motion, known as musculoskeletal disorders (MSDs), increasingly concern workers, employers, and regulators because of their frequency and high treatment costs. The Occupational Safety and Health Administration (OSHA) recently proposed a national rule designed to reduce the workplace risk of MSDs. OSHA estimates there were about 626,000 MSDs in 1997, representing about one-third of all serious nonfatal workplace injuries and illnesses. OSHA estimates the proposed rule will cost $4 billion per year and generate$9 billion per year in benefits. Yet, OSHA does not provide sufficient evidence that private markets are failing to reduce MSD risk without government intervention and does not convincingly demonstrate that the rule will result in more good than harm. Unless OSHA effectively addresses some of the more serious flaws in the proposed rule, OSHA should not proceed with the final regulation. OSHA should more carefully evaluate the nature and extent of MSDs in the workplace than it did in the proposed rule and use improved economic analysis to target serious MSDs that employers can reduce at low cost. Furthermore, OSHA should include new provisions to improve employer access to information about reducing workplace risk of MSDs. The rule's ergonomics program requirements should apply only to those MSDs which employers do not have sufficient incentive to reduce without government intervention.