Qualification of Taxable Entities and Treaty Protection: United States

This report was prepared for the 2014 International Congress of the International Fiscal Association. The general reporters for the Congress asked IFA branches around the world to prepare a report designed to provide information on how countries address (1) the question of when domestic and foreign entities are treated as transparent or taxable and (2) conflicts between different countries’ treatment of entities as transparent or taxable for treaty purposes. This report constitutes the IFA U.S.A. Branch’s submission to the general reporters. The report is divided into two sections. The first section of the report provides a general description of how both domestic and foreign entities are classified under U.S. federal tax law. The second section of the report focuses on how the United States deals with conflicts in entity classification when applying tax treaties. This section of the report consists of an analysis of a series of different scenarios posed by the general reporters to all IFA branches where different countries classify the same entity differently (i.e., one or more countries treat the entity as taxable while one or more other countries treat the entity as transparent)

Genetic Diversity of the Noncoding Control Region of the Novel Human Polyomaviruses.

The genomes of polyomaviruses are characterized by their tripartite organization with an early region, a late region and a noncoding control region (NCCR). The early region encodes proteins involved in replication and transcription of the viral genome, while expression of the late region generates the capsid proteins. Transcription regulatory sequences for expression of the early and late genes, as well as the origin of replication are encompassed in the NCCR. Cell tropism of polyomaviruses not only depends on the appropriate receptors on the host cell, but cell-specific expression of the viral genes is also governed by the NCCR. Thus far, 15 polyomaviruses have been isolated from humans, though it remains to be established whether all of them are genuine human polyomaviruses (HPyVs). The sequences of the NCCR of these HPyVs show high genetic variability and have been best studied in the human polyomaviruses BK and JC. Rearranged NCCRs in BKPyV and JCPyV, the first HPyVs to be discovered approximately 30 years ago, have been associated with the pathogenic properties of these viruses in nephropathy and progressive multifocal leukoencephalopathy, respectively. Since 2007, thirteen novel PyVs have been isolated from humans: KIPyV, WUPyV, MCPyV, HPyV6, HPyV7, TSPyV, HPyV9, HPyV10, STLPyV, HPyV12, NJPyV, LIPyV and QPyV. This review describes all NCCR variants of the new HPyVs that have been reported in the literature and discusses the possible consequences of NCCR diversity in terms of promoter strength, putative transcription factor binding sites and possible association with diseases

Journal Staff

Primary Immunodeficiencies (PID) are genetically inherited disorders characterized by defects of the immune system, leading to increased susceptibility to infection. Due to the variety of clinical symptoms and the complexity of current diagnostic procedures, accurate diagnosis of PID is often difficult in daily clinical practice. Thanks to the advent of "next generation'' sequencing technologies and target enrichment methods, the development of multiplex diagnostic assays is now possible. In this study, we applied a selector-based target enrichment assay to detect disease-causing mutations in 179 known PID genes. The usefulness of this assay for molecular diagnosis of PID was investigated by sequencing DNA from 33 patients, 18 of which had at least one known causal mutation at the onset of the experiment. We were able to identify the disease causing mutations in 60% of the investigated patients, indicating that the majority of PID cases could be resolved using a targeted sequencing approach. Causal mutations identified in the unknown patient samples were located in STAT3, IGLL1, RNF168 and PGM3. Based on our results, we propose a stepwise approach for PID diagnostics, involving targeted resequencing, followed by whole transcriptome and/or whole genome sequencing if causative variants are not found in the targeted exons

Capabilities and limitations of gel electrophoresis for elemental speciation : a laboratory's experience

Gel electrophoresis is a fractionation/separation technique that yields valuable information in the field of metalloproteomics, often referred to as metallomics. This paper is based on four years of practical experience of the authors' lab in this domain and highlights the capabilities and limitations of gel electrophoresis. Pitfalls of the technique were recognized by identifying the origin of artefacts in the separation, species degradation being the most important. Gel electrophoresis can be accomplished under either native or denaturing conditions. The speciation of vanadium and selenium among serum and yeast proteins, respectively, is sued to illustrate these two major modes. The most powerful approach is two-dimensional denaturing gel electrophoresis. This review of the methods used in our laboratory also descries the application of the two major detection techniques, autoradiography on the one hand and electrothermal vaporization - or laser ablation (LA)-inductively coupled plasma-mass spectrometry (ICP-MS) on the other

Substrate-dependent bacterivory by intertidal benthic copepods

The trophic importance of bacteria to harpacticoid copepods in intertidal areas remains poorly understood, and so do the mechanisms of bacterial feeding. It is, for instance, unclear whether harpacticoids directly target bacterial cells, or merely co-ingest them with substrates to which bacterial cells may be attached. Here, we investigate bacterial uptake and substrate requirement for four mud intertidal species (Microarthridion littorale, Platychelipus littoralis, Delavalia palustris, Nannopus palustris) by means of 13C-labeled bacteria and biomarker fatty acids (FA). Bacterial uptake strongly depended on grazing on a primary food source but bacterial ingestion rates were low and no clear indication of copepods directly targeting bacteria was found. Delavalia was the only species that accumulated bacteria-derived FA and gained in polyunsaturated FA (PUFA) probably through bioconversion of bacteria-derived FA. In general, however, our results suggest that bacteria represent a relatively minor and low-quality food for intertidal harpacticoid copepods

Imposing Relation Structure in Language-Model Embeddings Using Contrastive Learning

Though language model text embeddings have revolutionized NLP research, their ability to capture high-level semantic information, such as relations between entities in text, is limited. In this paper, we propose a novel contrastive learning framework that trains sentence embeddings to encode the relations in a graph structure. Given a sentence (unstructured text) and its graph, we use contrastive learning to impose relation-related structure on the token-level representations of the sentence obtained with a CharacterBERT (El Boukkouri et al.,2020) model. The resulting relation-aware sentence embeddings achieve state-of-the-art results on the relation extraction task using only a simple KNN classifier, thereby demonstrating the success of the proposed method. Additional visualization by a tSNE analysis shows the effectiveness of the learned representation space compared to baselines. Furthermore, we show that we can learn a different space for named entity recognition, again using a contrastive learning objective, and demonstrate how to successfully combine both representation spaces in an entity-relation task.Comment: To be presented at CoNLL 202

The fate of intertidal microphytobenthos carbon: an in situ ¹³C-labeling study

At two intertidal sites (one sandy and one silty, in the Scheldt estuary, The Netherlands), the fate of microphytobenthos was studied through an in situ 13C pulse- chase experiment. Label was added at the beginning of low tide, and uptake of 13C by algae was linear during the whole period of tidal exposure (about 27 mg m-2 h-1 in the top millimeter at both sites). The 13C fixed by microphytobenthos was rapidly displaced toward deeper sediment layers (down to 6 cm), in particular at the dynamic, sandy site. The residence times of microphytobenthos with respect to external losses (resuspension and respiration) were about 2.4 and 5.6 d at the sandy and silly stations, respectively. The transfer of carbon from microphytobenthos to benthic consumers was estimated from the appearance of 13C in bacterial biomarkers, handpicked nematodes, and macrofauna. The incorporation of 13C into bacterial biomass was quantified by carbon isotope analysis of polar lipid derived fatty acids specific for bacteria. The bacterial polar lipid-derived fatty acids (i14:0, i15:0, a15:0, i16:0, and 18:1 omega 7c) showed rapid, significant transfer from benthic algae to bacteria with maximum labeling after 1 d. Nematodes became enriched after 1 h, and 13C assimilation increased until day 3. Microphytobenthos carbon entered all heterotrophic components in proportion to heterotrophic biomass distribution (bacteria > macrofauna > meiofauna). Our results indicate a central role for microphytobenthos in moderating carbon flow in coastal sediments

Lactobacillus rhamnosus GG and Saccharomyces cerevisiae boulardii exert synergistic antipathogenic activity in vitro against enterotoxigenic Escherichia coli

Short-term colonic in vitro batch incubations were performed to elucidate the possible synergistic effects of Lactobacillus rhamnosus GG (CNCM-I-4798) and Saccharomyces cerevisiae boulardii (CNCM-1-1079) (associated in Smebiocta/Smectaflora Protect (R)) on the colonic microbial fermentation process, as well as their antipathogenic activity against enterotoxigenic Escherichia coli (LMG2092) (ETEC). These incubations adequately simulate the native microbiota and environmental conditions of the proximal colon of both adult and toddler donors, including the colonic mucosal layer. Results indicated that both strains were capable of growing together without showing antagonistic effects. Co-cultivation of both strains resulted in increased butyrate (stimulated by L. rhamnosus GG), propionate (stimulated by S. boulardii), and ethanol (produced by S. boulardii) production compared to the control incubations, revealing the additive effect of both strains. After inoculation of ETEC under simulated dysbiotic conditions, a 40 and 46% reduction in the concentration of ETEC was observed upon addition of both strains during the experiments with the adult and toddler donor, respectively. Furthermore, ETEC toxin levels decreased upon S. boulardii inoculation, probably due to proteolytic activity of this strain, with a synergistic effect being observed upon co-cultivation of L. rhamnosus GG and S. boulardii resulting in a reduction of 57 and 46% for the adult and toddler donor, respectively. Altogether, the results suggest that both probiotics together may help microbiota functionality, in both adults and toddlers and under healthy or impaired conditions, which could be of great interest when the colonic microbiota is dysbiotic and therefore sensitive to pathogenic invasion such as during antibiotic treatment