Perpetual Trusts: The Walking Dead and Congress Should Effectively Curb GST Exemption for Perpetual Trusts.

In separate but complementary letters to the editor of Tax Notes, Calvin Johnson (University of Texas School of Law) and Lawrence Waggoner (University of Michigan Law School) respond to an article by Dennis Belcher and seven other practicing attorneys that defend the GST exemption for perpetual trusts. In Federal Tax Rules Should Not Be Used to Limit Trust Duration, 126 Tax Notes 832 (Aug 13, 2012), the attorneys argue that the duration of a trust is a state law issue. Their article is actually a response to a Shelf Project article: Lawrence W. Waggoner, Effectively Curbing the GST Exemption for Perpetual Trusts, 125 Tax Notes 1267 (June 4, 2012), Doc 2012-9442, 2012 (TNT 110-14, available electronically at http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2083804). In Perpetual Trusts: The Walking Dead, 126 Tax Notes 1215 (Sept. 3, 2012), Johnson argues that the harm to the national wealth done by perpetual trusts is a federal responsibility. Trusts reduce the value of wealth, and settlors could figure that out if they were not seduced by the tax exemption. Specific settlor instructions get out of date and become an impediment after a generation. Delegating to trustees accountable to no one means trusts are managed primarily for the benefit of the trustees. Perpetual trusts become monsters, the walking dead. The federal exemption is motivating the harm; federal law is responsible for the harm that perpetual trusts cause. In Congress Should Effectively Curb the GST Exemption for Perpetual Trusts, 126 Tax Notes 1216 (Sept. 3, 2012), Waggoner reaffirms his Shelf Project proposal and his criticism of the Treasury Department’s proposal for dealing with perpetual trusts. The Treasury Department’s proposal would leave many trusts and much wealth GST exempt for much longer than Congress originally intended. The Waggoner proposal, if enacted, would be much more effective. Belcher and the other attorneys argue that Congress should do nothing (a position refuted by Johnson), but if Congress is to do something, the attorneys essentially embrace the Treasury proposal

Generalized Rate-Code Model for Neuron Ensembles with Finite Populations

We have proposed a generalized Langevin-type rate-code model subjected to multiplicative noise, in order to study stationary and dynamical properties of an ensemble containing {\it finite} $N$ neurons. Calculations using the Fokker-Planck equation (FPE) have shown that owing to the multiplicative noise, our rate model yields various kinds of stationary non-Gaussian distributions such as gamma, inverse-Gaussian-like and log-normal-like distributions, which have been experimentally observed. Dynamical properties of the rate model have been studied with the use of the augmented moment method (AMM), which was previously proposed by the author with a macroscopic point of view for finite-unit stochastic systems. In the AMM, original $N$-dimensional stochastic differential equations (DEs) are transformed into three-dimensional deterministic DEs for means and fluctuations of local and global variables. Dynamical responses of the neuron ensemble to pulse and sinusoidal inputs calculated by the AMM are in good agreement with those obtained by direct simulation. The synchronization in the neuronal ensemble is discussed. Variabilities of the firing rate and of the interspike interval (ISI) are shown to increase with increasing the magnitude of multiplicative noise, which may be a conceivable origin of the observed large variability in cortical neurons.Comment: 19 pages, 9 figures, accepted in Phys. Rev. E after minor modification

Evidence for ammonium-bearing minerals in Ceres

Evidence for ammonium-bearing minerals was found on the surface of the largest asteroid Ceres. The presence of ammonium-bearing clays suggests that Ceres has experienced a period of alteration by substantial amounts of an ammonium-bearing fluid. The presence of the ammonium-bearing clays does not preclude Ceres maintaining a volatile inventory in the core or in a volatile-rich zone at some distance below the surface. Telescopic observations of Ceres, using the 3.0 meter NASA Infrared telescope facility prompted this reevaluation of its surface mineralogy

Effective Theories for Circuits and Automata

Abstracting an effective theory from a complicated process is central to the study of complexity. Even when the underlying mechanisms are understood, or at least measurable, the presence of dissipation and irreversibility in biological, computational and social systems makes the problem harder. Here we demonstrate the construction of effective theories in the presence of both irreversibility and noise, in a dynamical model with underlying feedback. We use the Krohn-Rhodes theorem to show how the composition of underlying mechanisms can lead to innovations in the emergent effective theory. We show how dissipation and irreversibility fundamentally limit the lifetimes of these emergent structures, even though, on short timescales, the group properties may be enriched compared to their noiseless counterparts.Comment: 11 pages, 9 figure

Characteristics of STP Pre-2004 Archived KE Basin Sludge Samples Before and After Re-Jarring in the RPL - April 2012

This report describes results of work performed in the Shielded Analytical Laboratory (SAL) at the Pacific Northwest National Laboratory’s (PNNL) Radiochemical Processing Laboratory (RPL) with archive K East (KE) Basin sludge samples obtained before the year 2004, with some of them composited and initially characterized five years ago (Delegard et al. 2011). The previously performed testing included the physical properties determinations for selected samples (settled and particle densities, water and solids concentrations), the pH, as well as identification of crystalline phases by X-ray diffractometry (XRD) for selected samples. Another objective of the previous characterization and testing campaign was to transfer some sludge composites and individual samples into new storage containers to overcome the embrittlement effect which develops in original glass containers as a result of extended exposure to high radiation fields and which increases probability of sample loss

A Study of Sukuk Bond market-making at the London Stock Exchange, 2011-20

This paper has the objective of studying the Islamic bond market in the London Stock Exchange (LSE) which surprisingly is a latecomer, 21 years after the first Islamic bond that was listed in 1990. London took time to assess the market debut although it is the Bank of England that paved the way for the level-playing-field regulations to create Islamic banking. The Shariah-compliant Islamic bonds known as sukuk are traded in 23 plus markets and there are 2,340 such faith-based issues as at 2021. The total funds raised to-date in such exchange-traded Islamic bond exchanges over 31 years is worth US$526 billion with an average issue size of US$220 million each globally. London has raised US$50 billion with some 125 issues during its ten-year history. With perhaps the fastest growth rate among all exchanges, LSE chalked a growth rate of 56% per year, an extraordinary achievement with an average issue size 2 times bigger than the world average. In contrast, the global sukuk market growth rate is about 8% to 12% per year. The growth rate of the much older and larger mainstream bond market in some 137 market places is in the range of 4% to 5% per year. That makes it interesting to study the London market to understand its institutional structure, market-making efforts, liquidity, issuance effect and other pertinent aspect

Understanding visual map formation through vortex dynamics of spin Hamiltonian models

The pattern formation in orientation and ocular dominance columns is one of the most investigated problems in the brain. From a known cortical structure, we build spin-like Hamiltonian models with long-range interactions of the Mexican hat type. These Hamiltonian models allow a coherent interpretation of the diverse phenomena in the visual map formation with the help of relaxation dynamics of spin systems. In particular, we explain various phenomena of self-organization in orientation and ocular dominance map formation including the pinwheel annihilation and its dependency on the columnar wave vector and boundary conditions.Comment: 4 pages, 15 figure

A Memetic Analysis of a Phrase by Beethoven: Calvinian Perspectives on Similarity and Lexicon-Abstraction

This article discusses some general issues arising from the study of similarity in music, both human-conducted and computer-aided, and then progresses to a consideration of similarity relationships between patterns in a phrase by Beethoven, from the first movement of the Piano Sonata in A flat major op. 110 (1821), and various potential memetic precursors. This analysis is followed by a consideration of how the kinds of similarity identified in the Beethoven phrase might be understood in psychological/conceptual and then neurobiological terms, the latter by means of William Calvin’s Hexagonal Cloning Theory. This theory offers a mechanism for the operation of David Cope’s concept of the lexicon, conceived here as a museme allele-class. I conclude by attempting to correlate and map the various spaces within which memetic replication occurs

Central spindle self-organization and cytokinesis in artificially activated sea urchin eggs

Author Posting. © Marine Biological Laboratory, 2016. This article is posted here by permission of Marine Biological Laboratory for personal use, not for redistribution. The definitive version was published in Biological Bulletin 230, no.2 (2016): 85-95.The ability of microtubules of the mitotic apparatus to control the positioning and initiation of the cleavage furrow during cytokinesis was first established from studies on early echinoderm embryos. However, the identity of the microtubule population that imparts cytokinetic signaling is unclear. The two main––and not necessarily mutually exclusive–– candidates are the central spindle and the astral rays. In the present study, we examined cytokinesis in ammonia-activated sea urchin eggs, which lack paternally derived centrosomes and undergo mitosis mediated by unusual anastral, bipolar mini-spindles. Live cell imaging and immunolabeling for microtubules and the centralspindlin constituent and kinesin-related protein, MKLP1, demonstrated that furrowing in ammonia-activated eggs was associated with aligned arrays of centralspindlin-linked, opposed bundles of antiparallel microtubules. These autonomous, zipper- like arrays were not associated with a mitotic apparatus, but did possess characteristics similar to the central spindle region of control, fertilized embryos. Our results highlight the self-organizing nature of the central spindle region and its ability to induce cytokinesis-like furrowing, even in the absence of a complete mitotic apparatus.This research was supported by student/faculty summer research grants from the Dickinson College Research and Development Committee to JHH; Laura and Arthur Colwin Summer Research Fellowships from the MBL to JHH and CBS; a National Science Foundation Major Research Instrumentation grant to JHH (MRI-0320606); and a NSF collaborative research grant to JHH (MCB-1412688) and to CBS (MCB- 1412734)

USMC VERTICAL TAKEOFF AND LANDING AIRCRAFT: HUMAN–MACHINE TEAMING FOR CONTROLLING UNMANNED AERIAL SYSTEMS

The United States Marine Corps (USMC) is investing in aviation technologies through its Vertical Takeoff and Landing (VTOL) aircraft program that will enhance mission superiority and warfare dominance against both conventional and asymmetric threats. One of the USMC program initiatives is to launch unmanned aerial systems (UAS) from future human-piloted VTOL aircraft for collaborative hybrid (manned and unmanned) missions. This hybrid VTOL-UAS capability will support USMC intelligence, surveillance, and reconnaissance (ISR), electronic warfare (EW), communications relay, and kinetic strike air to ground missions. This capstone project studied the complex human-machine interactions involved in the future hybrid VTOL-UAS capability through model-based systems engineering analysis, coactive design interdependence analysis, and modeling and simulation experimentation. The capstone focused on a strike coordination and reconnaissance (SCAR) mission involving a manned VTOL platform, a VTOL-launched UAS, and a ground control station (GCS). The project produced system requirements, a system architecture, a conceptual design, and insights into the human-machine teaming aspects of this future VTOL capability.Major, United States ArmyMajor, United States ArmyMajor, United States ArmyMajor, United States ArmyMajor, United States ArmyApproved for public release. Distribution is unlimited