Comparative Analysis of Systems of Domestic Taxation of Controlled Foreign Corporations

This Note outlines the existing law and practice of the domestic taxation of CFC\u27s in the United States, United Kingdom, France, West Germany, and Japan, each of which exhibits a high level of economic and industrial advancement. United States developments are important because the statutory provisions of Subpart F have been adopted, with modifications, by other nations, including West Germany and Japan. The United Kingdom and France, on the other hand, have not yet adopted an integrated statutory scheme providing for domestic taxation of CFC\u27s. These countries attack tax evasion schemes utilizing foreign controlled companies primarily through general laws, exchange controls, and the requirement of government consent for certain international transactions

Chi hotspots trigger a conformational change in the helicase-like domain of AddAB to activate homologous recombination

In bacteria, the repair of double-stranded DNA breaks is modulated by Chi sequences. These are recognised by helicase-nuclease complexes that process DNA ends for homologous recombination. Chi activates recombination by changing the biochemical properties of the helicase-nuclease, transforming it from a destructive exonuclease into a recombination-promoting repair enzyme. This transition is thought to be controlled by the Chi-dependent opening of a molecular latch, which enables part of the DNA substrate to evade degradation beyond Chi. Here, we show that disruption of the latch improves Chi recognition efficiency and stabilizes the interaction of AddAB with Chi, even in mutants that are impaired for Chi binding. Chi recognition elicits a structural change in AddAB that maps to a region of AddB which resembles a helicase domain, and which harbours both the Chi recognition locus and the latch. Mutation of the latch potentiates the change and moderately reduces the duration of a translocation pause at Chi. However, this mutant displays properties of Chi-modified AddAB even in the complete absence of bona fide hotspot sequences. The results are used to develop a model for AddAB regulation in which allosteric communication between Chi binding and latch opening ensures quality control during recombination hotspot recognition

Star-Forming or Starbursting? The Ultraviolet Conundrum

Compared to starburst galaxies, normal star forming galaxies have been shown to display a much larger dispersion of the dust attenuation at fixed reddening through studies of the IRX-beta diagram (the IR/UV ratio "IRX" versus the UV color "beta"). To investigate the causes of this larger dispersion and attempt to isolate second parameters, we have used GALEX UV, ground-based optical, and Spitzer infrared imaging of 8 nearby galaxies, and examined the properties of individual UV and 24 micron selected star forming regions. We concentrated on star-forming regions, in order to isolate simpler star formation histories than those that characterize whole galaxies. We find that 1) the dispersion is not correlated with the mean age of the stellar populations, 2) a range of dust geometries and dust extinction curves are the most likely causes for the observed dispersion in the IRX-beta diagram 3) together with some potential dilution of the most recent star-forming population by older unrelated bursts, at least in the case of star-forming regions within galaxies, 4) we also recover some general characteristics of the regions, including a tight positive correlation between the amount of dust attenuation and the metal content. Although generalizing our results to whole galaxies may not be immediate, the possibility of a range of dust extinction laws and geometries should be accounted for in the latter systems as well.Comment: 18 pages, 17 figures, accepted for publication in Ap

Star formation and dust extinction properties of local galaxies from AKARI-GALEX All-Sky Surveys: First results from most secure multiband sample from FUV to FIR

The AKARI All-Sky Survey provided the first bright point source catalog detected at 90um. Starting from this catalog, we selected galaxies by matching AKARI sources with those in the IRAS PSCz. Next, we have measured total GALEX FUV and NUV flux densities. Then, we have matched this sample with SDSS and 2MASS galaxies. By this procedure, we obtained the final sample which consists of 607 galaxies. If we sort the sample with respect to 90um, their average SED shows a coherent trend: the more luminous at 90um, the redder the global SED becomes. The M_r--NUV-r color-magnitude relation of our sample does not show bimodality, and the distribution is centered on the green valley between the blue cloud and red sequence seen in optical surveys. We have established formulae to convert FIR luminosity from AKARI bands to the total infrared (IR) luminosity L_TIR. With these formulae, we calculated the star formation directly visible with FUV and hidden by dust. The luminosity related to star formation activity (L_SF) is dominated by L_TIR even if we take into account the far-infrared (FIR) emission from dust heated by old stars. At high star formation rate (SFR) (> 20 Msun yr^-1), the fraction of directly visible SFR, SFR_FUV, decreases. We also estimated the FUV attenuation A_FUV from FUV-to-total IR (TIR) luminosity ratio. We also examined the L_TIR/L_FUV-UV slope (FUV- NUV) relation. The majority of the sample has L_TIR/L_FUV ratios 5 to 10 times lower than expected from the local starburst relation, while some LIRGs and all the ULIRGs of this sample have higher L_TIR/L_FUV ratios. We found that the attenuation indicator L_TIR/L_FUV is correlated to the stellar mass of galaxies, M*, but there is no correlation with specific SFR (SSFR), SFR/M*, and dust attenuation L_TIR/L_FUV. (abridged)Comment: 13 pages, 18 figures, accepted for publication in A&

Spitzer Analysis of HII Region Complexes in the Magellanic Clouds: Determining a Suitable Monochromatic Obscured Star Formation Indicator

HII regions are the birth places of stars, and as such they provide the best measure of current star formation rates (SFRs) in galaxies. The close proximity of the Magellanic Clouds allows us to probe the nature of these star forming regions at small spatial scales. We aim to determine the monochromatic IR band that most accurately traces the bolometric IR flux (TIR), which can then be used to estimate an obscured SFR. We present the spatial analysis, via aperture/annulus photometry, of 16 LMC and 16 SMC HII region complexes using the Spitzer IRAC and MIPS bands. UV rocket data and SHASSA H-alpha data are also included. We find that nearly all of the LMC and SMC HII region SEDs peak around 70um, from ~10 to ~400 pc from the central sources. As a result, the sizes of HII regions as probed by 70um is approximately equal to the sizes as probed by TIR (about 70 pc in radius); the radial profile of the 70um flux, normalized by TIR, is constant at all radii (70um ~ 0.45 TIR); the 1-sigma standard deviation of the 70um fluxes, normalized by TIR, is a lower fraction of the mean (0.05 to 0.12 out to ~220 pc) than the normalized 8, 24, and 160um normalized fluxes (0.12 to 0.52); and these results are invariant between the LMC and SMC. From these results, we argue that 70um is the most suitable IR band to use as a monochromatic obscured star formation indicator because it most accurately reproduces the TIR of HII regions in the LMC and SMC and over large spatial scales. We also explore the general trends of the 8, 24, 70, and 160um bands in the LMC and SMC HII region SEDs, radial surface brightness profiles, sizes, and normalized (by TIR) radial flux profiles. We derive an obscured SFR equation that is modified from the literature to use 70um luminosity, SFR(Mo/yr) = 9.7(0.7)x10^{-44} L(70)(ergs/s), which is applicable from 10 to 300 pc distance from the center of an HII region.Comment: 21 pages, 12 figures, 4 tables. Will be published in ApJ

Corn stover harvest increases herbicide movement to subsurface drains – Root Zone Water QualityModel simulations

BACKGROUND: Crop residue removal for bioenergy production can alter soil hydrologic properties and the movement of agrochemicals to subsurface drains. The Root Zone Water Quality Model (RZWQM), previously calibrated using measured flow and atrazine concentrations in drainage from a 0.4 ha chisel-tilled plot, was used to investigate effects of 50 and 100% corn (Zea mays L.) stover harvest and the accompanying reductions in soil crust hydraulic conductivity and total macroporosity on transport of atrazine, metolachlor andmetolachlor oxanilic acid (OXA). RESULTS: The model accurately simulated field-measured metolachlor transport in drainage. A 3 year simulation indicated that 50% residue removal reduced subsurface drainage by 31% and increased atrazine and metolachlor transport in drainage 4–5-fold when surface crust conductivity and macroporosity were reduced by 25%. Based on itsmeasured sorption coefficient, approximately twofold reductions in OXA losses were simulated with residue removal. CONCLUSION: The RZWQM indicated that, if corn stover harvest reduces crust conductivity and soil macroporosity, losses of atrazine andmetolachlor in subsurface drainagewill increase owing to reduced sorption related tomorewatermoving through fewermacropores. Losses of the metolachlor degradation product OXA will decrease as a result of themore rapid movement of the parent compound into the soil