The Great ETF Tax Swindle: The Taxation of In-Kind Redemptions

Since the repeal of the General Utilities doctrine over 30 years ago, corporations must recognize gain when distributing appreciated property to their shareholders. Regulated investment companies (RICs), which generally must be organized as domestic corporations, are exempt from this rule when distributing property in kind to a redeeming shareholder. In-kind redemptions, while rare for mutual funds, are a fundamental feature of exchange-traded funds (ETFs). Because fund managers decide which securities to distribute, they distribute assets with unrealized gains and thereby significantly reduce the future tax burdens of their current and future shareholders. Many ETFs have morphed into investment vehicles that offer better after-tax returns than IRAs funded with after-tax contributions. Furthermore, this rule is now being turbocharged. Some mutual fund families have created ETF classes of shares for some of their mutual funds, which permits the ETF shareholders to remove the gains attributable to the shareholders of the regular share class. Another firm acts as a strategic investor to assist mutual funds in eliminating their unrealized gains through contributions and redemptions. These transactions permit current and future fund shareholders to inappropriately defer tax on their economic gains and give ETFs and other mutual funds with ETF share classes a significant tax advantage over other investment vehicles. This article considers various options that tax policymakers should consider to eliminate the ETF tax subsidy including explicitly extending this favorable tax treatment to all RICs by exempting fund-level gains from tax, repealing the exemption rule, limiting the amount of unrealized gains a fund can distribute, requiring ETFs to reduce the basis of their remaining property by the unrecognized gain of distributed property, or requiring ETFs to be taxed as partnerships

Understanding Cognition Across Modalities for the Assessment of Digital Resources

Drawing from the theories of the cognitive process, this paper explores the transmission, retention and transformation of information across oral, written, and digital modes of communication and how these concepts can be used to examine the assessment of digital resource tools. The exploration of interactions across modes of communication is used to gain an understanding of the interaction between the student, digital resource and teacher. Cognitive theory is considered as a basis for the assessment of digital resource tools. Lastly, principles for the assessment of digital resource tools are presented along with how assessment can be incorporated in the educational practice to enhance learning in higher education

Citizen Journalist to Activist: the Language Behind Black Lives Matter

This study explores the discourse surrounding an event in the social movement, Black Lives Matter, to gain insights into how digital literacy practices influence and mediate participation in the 21st century civil rights movement for a new generation of activist. This study examines three points of engagement, (1) the experience of the event as it is initially interpreted and shared online, (2) the intermingling of consciousness through social media, and (3) the post social media interpretation and action. Data was collected from Twitter analyzed using discourse analysis

Solid waste management in Puerto Rico : an assessment of environmental impacts and benefits

Municipal solid waste (MSW) management has been a challenging issue throughout history. Waste management options have evolved, but they can present distinct environmental impacts, such as the emission of greenhouse gases (GHG). This study quantified the environmental benefits (i.e., greenhouse gas emission and energy use reductions) of various MSW management plans proposed for Puerto Rico through the use of the Waste Reduction Model (WARM). The waste management initiative known as the “Base Case” was found to offer the most environmental benefits. Thus, higher benefits can be attained from the implementation of an integrated solid waste managementDepartment of Natural Resources and Environmental ManagementThesis (M.S.

ESL Student Perceptions of Online Resources

This study explores how ESL student perceptions guide their use of online resources, with the goal of helping teachers select meaningful resources. Data were collected using a combination of interview responses and computer-recorded online actions. An evaluation of three case studies of advanced adult English language learners were used to gain insights into student perceptions. The results indicated that the ESL students use Google and native language sites when researching online, at times alternating between English and their native language. However, they expressed a sense of shame when using native language sites, as one student stated that he felt he should know things (i.e. English) that he does not and it would be unfair for him to use an online translator or other native language resources in his chemistry class

Effective operator contributions to the oblique parameters

We present a model and process independent study of the contributions from non-Standard Model physics to the oblique parameters S, T and U. We show that within an effective lagrangian parameterization the expressions for the oblique parameters in terms of observables are consistent, while those in terms of the vector-boson vacuum polarization tensors are ambiguous. We obtain the constraints on the scale of new physics derived from current data on S, T and U and note that deviations in U from its Standard Model value would favor a scenario where the underlying physics does not decouple.Comment: 13 pages, RevTe

Sea Contributions to Spin 1/2 Baryon Structure, Magnetic Moments, and Spin Distribution

We treat the baryon as a composite system made out of a \lq\lq core" of three quarks (as in the standard quark model) surrounded by a \lq\lq sea" (of gluons and $q\bar{q}$-pairs) which is specified by its total quantum numbers like flavor, spin and color. Specifically, we assume the sea to be a flavor octet with spin 0 or 1 but no color. The general wavefunction for spin 1/2 baryons with such a sea component is given. Application to the magnetic moments is considered. Numerical analysis shows that a scalar (spin 0) sea with an admixture of a vector (spin 1) sea can provide very good fits to the magnetic moment data {\em using experimental errors}. Our best fit automatically gives $g_A/g_V$ for neutron beta decay in agreement with data. This fit also gives reasonable values for the spin distributions of the proton and neutron.Comment: 24 pages, REVTEX. References modifie