The New Section 1202 Tax-Free Business Sale: Congress Rewards Small Businesses That Survived the Great Recession

On September 27, 2010, President Barack Obama signed the Creating Small Business Jobs Act of 2010 (“SBJA”) that contains a temporary amendment to Internal Revenue Code (“IRC”) § 1202. The amendment permits original shareholders of eligible corporation stock to sell the stock without being taxed on the sale. The temporary amendment initially only applied to certain stock acquired after the enactment of the SBJA and before January 1, 2011, but the amendment was extended on December 17, 2010 for another year ending January 1, 2012. With the impending sunset of the 15% capital gains rate at the end of 2012, this 100% exclusion from both capital gains taxes and the alternative minimum tax (“AMT”), would be a very big financial windfall to business owners with qualified small business stock (“QSBS”). A qualified small business (“QSB”) is a C corporation with assets of $50 million or less where at least 80$10 million or 10 times the adjusted basis in the corporation. Victor Fleischer stated that the main purpose for enhancing the IRC § 1202 exclusion is to encourage investment in certain new C corporation ventures and small businesses. Manufacturing, construction, and retail wholesaling industries appear to be some of the main areas promoted by the expanded exclusion, since the definition of “qualified trade or business” excludes many other major areas of industry. This Article provides an overview of the IRC Section § 1202 tax-free business sale provision, the history behind the development of the IRC amendments, the apparent intent for enactment, the likelihood the Act will achieve its purposes, the statute’s ambiguities, and some policy implications of creating a tax-free business sale provision

Strategic Control for a U.K. Regional Health Authority: A Conceptual Framework

After a brief review of the nature of strategic planning, and the problems of defining health service objectives, the paper concentrates on the question of "strategic control", in the context of a regional health authority. The purpose of monitoring is defined in detail. A critical review of concepts of control in various disciplines considers their suitability to the health authority context. An integration of feedforward and feedback control loops is developed, in order to meet the specific characteristics of a system in which "environment" can be viewed as the "input", and to provide the adaptive, learning capability which is required by the situation of insufficient data, ignorance of underlying mechanisms, and continuing change

The Scale of Ethylene Plants: Backgrounds and Issues

Questions of scale have been the subject of research at IIASA since January 1978. Following the publication in September 1978 of the IIASA Research Memorandum "'Problems of Scale' -- The Case for IIASA Research" (M.F. Cantley and V.N. Glagolev; RM-78-47), plans were made for a workshop to be held in June 1979 on the topic "Size and Productive Efficiency -- The Wider Implications". This workshop is planned around a selected list of "Key Topics" and specific industries -- the latter including initially electricity generation, ethylene plants, and coal liquefaction. Since not all workshop participants can be familiar with all topics and industries, it was felt that it would be useful to provide background material where necessary. This paper is intended to provide sufficient up-to-date factual information on the petrochemical industry to enable participants to understand and contribute to discussions about questions of size in ethylene plants, and to relate these to the more general issues raised at the workshop. The information presented here is based on the published articles listed in the references, and on correspondence and conversation with experts in the industry; but the author, while wishing to acknowledge the extensive help received from these sources, accepts responsibility for any inaccuracies or over-simplifications he has introduced

Mid-Project Observations from a Study of Strategic Monitoring in Health Care

Within the research program of IIASA's Management and Technology Area, the subject of Program Management has been defined as "the general problem of translating ideal, multidimensional goals into achievable goals, and devising the necessary mechanisms for achieving this in a complex organizational situation". Strategic planning and control for health care is an example of such a problem. Since early 1978, research has been conducted in co-operation with the U.K. authorities into some aspects of the implementation of the systematic strategic planning system initiated in 1976 by the ministry responsible, the Department of Health and Social Security. The research has concentrated on the subject of strategic control, or "monitoring". The study is still in progress, but this paper describing "mid-project observations" illustrates the need for monitoring, describes some research and ideas contributing towards more effective monitoring, and suggests some of the difficulties facing its further development. The work is set in the specific terms of a particular service in one country; but the issues involved are of universal significance, for the development of systems by which large-scale public programs can "learn", gradually but systematically, in a long cyclic progress

Biomimetic nanopores from atomically thin membranes

Biological cells are filled with a variety of pores and channels that transport ions and molecules across the cell membrane. These passageways are vital to cell function and remarkably effective due to their high selectivity, high flux, and sensitivity to environmental stimuli. This level of control is extremely attractive for applications ranging from biotechnology to energy and the environment. In this thesis, the unique properties of two dimensional materials are utilized to create solid-state nanopores that closely mimic the function of biological ion channels. Ionic conductance measurements were used to demonstrate that nanopores introduced into graphene membranes exhibit K+/Na+ selectivity and can modulate the ionic current with an applied gate voltage. These devices are shown to respond to low gate voltages (<500 mV) at biologically relevant concentrations (up to 1M). Cation-anion selectivity, concentration dependence, and pH dependence were also investigated. We propose the observed behavior is dependent on the presence of surface adsorbates that modify the surface energy of the membrane and near the pore, creating a gaseous barrier that is modulated via electro-wetting. Additionally, we work toward creating light responsive MoS2 nanopores operating in solution, by monitoring the current through a MoS2 nanopore while the device is exposed to a focused laser beam.2018-07-09T00:00:00

George Watson (1892-1965)

George Watson, retired district manager of the Hudson's Bay Company, died at Lachine, Que. on 25 December, 1965. He was born on 25 September, 1892 in Aberdeen, Scotland. After finishing his education and working for a short time there, he, like so many of his young fellow countrymen, joined the Hudson's Bay Company and came to Canada in June, 1914. After spending three years at Norway House in northern Manitoba, he was transferred to Moose Factory, James Bay, where he remained until 1925, first as district accountant and later as assistant district manager. At that time, when communications were not what they are today, both these places were the administrative and distribution centres of the large Indian territories around them. Coming to Montreal in 1926, he was appointed assistant to the manager of the then recently amalgamated districts comprising Quebec, Labrador, Ungava, and the Eastern Arctic. Promoted to district manager in 1931, he directed the operations of several of these areas until his retirement in 1954, after forty years of service. During most of this period, he had occasion to travel extensively throughout these territories and thus acquired an intimate knowledge of them and of their economic and sociological problems that is given to few today. Rather reluctantly George Watson came out of retirement to serve as temporary Director of the Montreal office of the Arctic Institute from 1955 to 1957. While there, his keen administrative ability and long experience in northern work proved to be most useful. George Watson was married in August 1919 to Edith Parsloe Cruickshank, also an Aberdonian, who had entered Canada by way of Hudson Strait and Hudson Bay for her marriage in Moose Factory. He is survived by his wife and one son, George Jr., both of whom reside in Lachine, Que