A curriculum for Methodist Episcopal Sunday schools in the central China area

Thesis (M.A.)--Boston Universit

Monogroove cold plate

The coolant fluid evaporated in a compact heat absorbing panel utilizing monogroove heat pipes in a pumped two-phase system is replenished through a liquid inlet control valve under the control of an ultrasonic liquid presence detector which is connected to the panel. The detector maintains the desired liquid quantity in the panel's liquid coolant channels, thereby dynamically responding to varying heat loads

Permitting Abused Spouses to Claim the Earned Income Tax Credit in Separate Returns

The earned income tax credit (EITC) is a refundable tax credit for federal income tax purposes that is generally available to lowincome taxpayers who have income from either employment or selfemployment. The EITC is currently the largest government program providing aid to low-income individuals. The subsidy provided by the EITC is of particular importance to individuals subjected to domestic abuse, given that such individuals are often impoverished, and the EITC can provide them with the financial resources necessary to improve, endure, or leave an abusive relationship. Despite the importance of the EITC, married individuals subjected to domestic abuse face serious difficulties in claiming the credit. Because married individuals are not permitted to claim the EITC on a married filing separate return, such individuals are left with three return-filing options for claiming EITCs: (1) file a joint return, (2) qualify and file as a single taxpayer, or (3) qualify and file as a head of household. As discussed in this Article, the first option may be undesirable given the particular circumstances surrounding the abuse, and the second and third options may be either unattainable or only attainable by taking steps that may not be in the best interests of an individual from the standpoint of overall well-being

Proposal to Reform the Like Kind and Involuntary Conversion Rules in Light of Fundamental Tax Policies: A Simpler, More Rational and More Unified Approach

This Article seeks to improve the like kind and involuntary conversion rules, that is, make the provisions more rational and less complex, by analyzing them in light of the fundamental tax policies of efficiency, equity, and administrability. A review of these rules under efficiency and equity principles arguably will lead to a more rational scheme for providing nonrecognition treatment to voluntary and involuntary dispositions given the recognized importance of these policies in structuring the federal income tax system. Further, a careful consideration of tax administration concerns should serve to simplify the application of these nonrecognition provisions. Part II of this Article reviews the fundamental tax policies of efficiency, equity, and administrability. Part III examines the policies underlying the like kind and involuntary conversion rules and identifies the fundamental policies that may support these provisions. Part IV develops a methodology for reforming the like kind and involuntary conversion rules in light of fundamental tax policies that, in part, recognizes the limits of efficiency and equity analyses and the importance of administrability concerns. Part V the applies this methodology for reform to several features of the like kind and involuntary conversion rules, and recommends an approach that is general simpler, more, rational, and more unified. Part VI summarizes and concludes the Article

An Equity-Based, Multilateral Approach for Sourcing Income Among Nations

The source of income rules used in the United States and elsewhere in large part establish the contours of tax jurisdiction exercised by countries. The source rules play a vital role in the foreign tax credit system applicable to U.S. persons with foreign investment or business activities. The source rules also play a central role in the United States’ exercise of source taxation over foreign persons with U.S. businesses or investments. Other countries likewise use source rules or their equivalent in applying foreign tax credit or territorial systems to their residents and exercising source taxation over nonresidents. The current approach for sourcing income suffers from two related problems. First, the source rules lack coherence in that they fail to advance a consistent normative tax policy. More fundamentally, the rules fail to reflect the consistent application of the key principle appropriate for allocating nations’ primary taxing rights – namely, the benefits principle. The second problem is the variation in the source rules used worldwide. This may produce double taxation or non-taxation. This article addresses both of these problems by offering an approach for sourcing income that has the potential for being adopted by countries on a multilateral basis. The article develops an equity-based standard for sourcing that would allow for the derivation of source rules for various types of income. The core idea underlying the proposed sourcing standard is the benefits principle: income should be sourced to the country that provides the taxpayer with significant governmental benefits related to the income. Specifically, the article develops a standard that would devise source rules by evaluating the source of income on the basis of three factors: the destination of the services, property or capital giving rise to income; the location(s) of the activities giving rise to income; and the residence of the person receiving income. Based on this evaluation, the rule for a given type of income may divide the source of the income among multiple locations. By basing the source rules on an equity-based standard that allows source to be divided when appropriate, this article seeks to rationalize and harmonize the provisions used to source income for purposes of taxing cross-border investment and business activities

Determining the Character of Section 357(c) Gain

Under section 351, a person transferring property to a controlled corporation generally recognizes no gain or loss on the transaction. An exception to tax-free treatment is contained in section 357(c), which generally provides that a transferor in a section 351 transaction recognizes gain to the extent that any liabilities assumed by the corporation on the transfer exceed the transferor\u27s aggregate adjusted basis in the assets transferred. An issue under section 357(c) is whether the recognized gain should be capital gain or ordinary income. The statute suggests that the character of section 357(c) gain should be based on the character of the transferred assets, but this does not provide a clear answer when two or more assets of differing character are transferred to the corporation. The Treasury regulations prescribe a method for determining the character of section 357(c) gain that allocates the gain according to the relative fair market value of the transferred assets. However, a few U.S. Tax Court decisions have not followed this method, and several commentators have stated that the regulatory method is simply wrong; instead, these cases and commentators espouse an alternative method that determines the character of section 357(c) gain based on the relative amount of realized gain on the transferred assets. This article analyzes the section 357(c) character issue and determines which of the competing methods and underlying constructs is more appropriate in light of the relevant tax rules and principles, and in particular those relating to nonrecognition. The article offers different ways of conceptualizing transfers to corporations in connection with the assumption of liabilities, each of which supports one of the competing methods for determining the character of section 357(c) gain. The relative fair market value allocation method is supported by an aggregate asset construct that combines the tax attributes of the transferred assets; the relative realized gain allocation method is supported by a modified separate assets construct that generally treats the transaction as transfers of separate assets. The article then evaluates the constructs and resulting methods, and determines that the modified separate assets construct and resulting relative realized gain allocation method is the more appropriate manner for determining the character of section 357(c) gain