Tax Loss Offset Restrictions - Last Resort for the Treasury? An Empirical Evaluation of Tax Loss Offset Restrictions Based on Micro Data

In Germany, the tax loss carry-forward of corporations significantly increased over the last decade. At the same time only a small percentage of losses have been effectively offset in the following periods. One potential reason for this puzzle is that stricter loss offset restrictions have been introduced in recent years. I use a newly developed micro simulation model for the corporate sector in Germany to evaluate the fiscal effects of these restrictions. Additionally, distributional breakdowns concerning the amounts of tax loss carry-forward and the effects of loss offset restrictions are provided. I find that the restrictions on the use of tax loss carryback are rather ineffective while the newly introduced minimum taxation considerably increases yearly tax revenue by 1.1 billion

Rising Sound Intensity: An Intrinsic Warning Cue Activating the Amygdala

Human subjects overestimate the change of rising intensity sounds compared with falling intensity sounds. Rising sound intensity has therefore been proposed to be an intrinsic warning cue. In order to test this hypothesis, we presented rising, falling, and constant intensity sounds to healthy humans and gathered psychophysiological and behavioral responses. Brain activity was measured using event-related functional magnetic resonance imaging. We found that rising compared with falling sound intensity facilitates autonomic orienting reflex and phasic alertness to auditory targets. Rising intensity sounds produced neural activity in the amygdala, which was accompanied by activity in intraparietal sulcus, superior temporal sulcus, and temporal plane. Our results indicate that rising sound intensity is an elementary warning cue eliciting adaptive responses by recruiting attentional and physiological resources. Regions involved in cross-modal integration were activated by rising sound intensity, while the right-hemisphere phasic alertness network could not be supported by this stud

Rubidium metal target development for large scale 82Sr production: LA-UR-14-22338

Strontium-82 (t1/2 = 25.5 d) is one of the medical isotopes produced on a large scale at the Isotope Production Facility (IPF) of the Los Alamos National Laboratory (LANL), employing a high intensity 100 MeV proton beam and RbCl targets. A constant increase in the 82Sr demand over the last decade combined with an established thermal limit of molten RbCl salt targets [1,2] has challenged the IPF’s world leading production capacity in recent years and necessitated the consideration of low-melting point (39.3 °C) Rb metal targets. Metal targets are used at other facilities [3–5] and offer obvious production rate advantages due to a higher relative density of Rb target atoms and a higher expected thermal performance of molten metal. One major disadvantage is the known violent reaction of molten Rb with cooling water and the potential for facility damage following a catastrophic target failure. This represents a significant risk, given the high beam intensities used routinely at IPF. In order to assess this risk, a target failure experiment was conducted at the LANL firing site using a mockup target station. Subsequent fabrication, irradiation and processing of two prototype targets showed a target thermal performance consistent with thermal modeling predictions and yields in agreement with predictions based on IAEA recommended cross sections [6]. Target failure test: The target failure test bed (FIG. 1) was constructed to represent a near replica of the IPF target station, incorporating its most important features. One of the most vulnerable components in the assembly is the Inconel beam window (FIG. 2) which forms the only barrier between the target cooling water and the beam line vacuum. The test bed also mimicked relevant IPF operational parameters seeking to simulate the target environment during irradiation, such as typical cooling water flow velocities around the target surfaces. While the aggressive thermal effects of the beam heating could not be simulated directly, heated cooling water (45 °C) ensured that the rubidium target material remained molten during the failure test. A worst case catastrophic target failure event was initiated by uncovering an oversized predrilled pinhole (1 mm Φ) to abruptly expose the molten target material to fast flowing cooling water. Prototype target irradiations: Two prototype Rb metal target containers were fabricated by machining Inconel 625 parts and by EB welding. The target containers were filled with molten Rb metal under an inert argon atmosphere. Follow-ing appropriate QA inspections, the prototype targets were irradiated in the medium energy slot of a standard IPF target stack using beam currents up to 230 µA. After irradiation the targets were transported to the LANL hot cell facili-ty for processing and for 82Sr yield verification. During the target failure test, cooling water conductivity and pressure excursions in the target chamber were continuously monitored and recorded at a rate of 1 kHz. Video footage taken of the beam window and the pinhole area combined with the recorded data indicated an aggressive reaction between the Rb metal and the cooling water, but did not reveal a violent explosion that could seriously damage the beam window. These observations, together with thermal model predictions, provided the necessary confidence to fabricate and fill prototype targets for irradiation at production-scale beam currents. X-ray imaging of filled targets (FIG. 3) shows a need for tighter control over the target fill level. One prototype target was first subjected to lower intensity (< 150 µA) beams before the second was irradiated at production level (230 µA) beams. During irradiation, monitoring of cooling water conductivity indicated no container breach or leak and, as anticipated given the model predictions, the post irradiation target inspection showed no sign of imminent thermal failure (see FIG. 4). Subsequent chemical processing of the targets followed an established procedure that was slightly modified to accommodate the larger target mass. TABLE 1 shows that post chemistry 82Sr yields agree to within 2 % of the in-target production rates expected on the basis of IAEA recommended cross sections. The table also compares 82Sr yields from the Rb metal targets against yields routinely obtained from RbCl targets, showing an increase in yield of almost 50 %